RESPONSE TO COMMENTS RICELAND FOODS, INC ......ARK A N S A S Department of Environmental Quality APR...

RESPONSE TO COMMENTS

RICELAND FOODS, INC. - WHEATLEYPERMIT #0478-AR-12

AFIN: 62-00012

On March 27, 2012, the Arkansas Department of Environmental Quality issued a draft permitunder a de minimis modification for the above referenced facility. During the comment period,written comments on the draft permitting decision were submitted on behalf ofthe facility. TheDepartment's response to these issues follows.

Comment #1: Unit #7 Berico Dryer #1 (SN-55) has been removed from service as part of therequested Shanzer Dryer installation (SN-73). Please remove SN-55 from the permit.

Response to Comment #1: The final permit will reflect this change.

Comment #2: From the permittee's comments dated Apri14, 2012:

NSPS Condition #12(iii) requires column dryers SN-68, SN-71, and SN-73 to havecolumn plate perforations less than 0.094 inches in diameter. None of these dryers havecolumns constructed ofperforated plate. All three (3) dryers have columns constructedof woven wire screen. The condition gives the impression that the dryer columns shouldbe changed from woven wire to perforated plate.

These dryers are all enclosed in structures made of louvered panels with 24 mesh screenover the louvers. Because the 24 mesh screens have openings less than 0.094 inches, theDepartment has determined in previous Riceland permits that 24 mesh fulfills the SubpartDD opacity requirements.

Riceland would like to recommend the following language for this condition:

SN-68, SN-71 and SN-73 are subject to 40 CFR Part 60, Subpart DD - StandardsofPerformance for Grain Elevators. The permittee shall comply with allapplicable regulations under 40 CFR Part 60, Subpart DD. SN-68, SN-71 andSN-73 comply with the opacity requirements by having a clear opening in thewire mesh of less than 0.094 inches.

This is the same language that was used in the NSPS condition for regulation a graindryer at Riceland's Stuttgart Rice Division, Permit 0489-AR-15. Please substitute thelanguage found at NSPS Condition #12(iii), with the recommended language.

Response to Comment #2: This change will be reflected in the final permit, except that theword "opacity" will be omitted from the condition's third sentence suggested by Riceland.

Page 1 of 1

ADEQARK A N S A SDepartment of Environmental Quality

APR 20 2012

Neil Washburn, Environmental EngineerRiceland Foods, Inc. - WheatleyPO Box 927Stuttgart, AR 72160

Dear Mr. Washburn:

The enclosed Permit No. 0478-AR-12 is your authority to construct, operate, and maintain theequipment and/or control apparatus as set forth in your application initially received on1/19/2012.

After considering the facts and requirements of A.C.A. §8-4-101 et seq., and implementingregulations, I have determined that Permit No. 0478-AR-12 for the construction, operation andmaintenance of an air pollution control system for Riceland Foods, Inc. - Wheatley to be issuedand effective on the date specified in the permit, unless a Commission review has been properlyrequested under Arkansas Department of Pollution Control & Ecology Commission'sAdministrative Procedures, Regulation 8, within thirty (30) days after service of this decision.

The applicant or permittee and any other person submitting public comments on the record mayrequest an adjudicatory hearing and Commission review of the final permitting decisions asprovided under Chapter Six of Regulation No.8, Administrative Procedures, Arkansas PollutionControl and Ecology Commission. Such a request shall be in the form and manner required byRegulation 8.603, including filing a written Request for Hearing with the APC&E CommissionSecretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas 72201. If you have anyquestions about filing the request, please call the Commission at 501-682-7890.

Sincerely,

Lt~·Mike BatesChief, Air Division

Enclosure

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501·682-0744 / FAX501-682-0880

www.adeq.state.ar.us

ADEQMINOR SOURCE

AIR PERMITPermit No.: 0478-AR-12

IS ISSUED TO:

Riceland Foods, Inc. - Wheatley133 Dennis

Wheatley, AR 72392St. Francis CountyAFIN: 62-00012

THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE'S AUTHORITY TOCONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/ORFACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT'S MINOR SOURCEAIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THEPROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT(ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATEDTHEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINEDHEREIN.

Signed:

~ r

-----'~~.Mike BatesChief, Air Division

APR 2 0 20ll

Date

Riceland Foods, Inc. - WheatleyPermit #: 0478-AR-12AFIN: 62-00012

Table of Contents

Section I: FACILITY INFORMATION 4Section II: INTRODUCTION 5

Summary of Permit Activity 5Process Description 5Regulations 9Total Allowable Emissions 10

Section III: PERMIT HISTORY 11Section IV: EMISSION UNIT INFORMATION 14

Facility-wide Conditions 22NSPS Conditions 23

Section V: INSIGNIFICANT ACTIVITIES 24Section VI: GENERAL CONDITIONS 25Appendix A - 40 CFR Part 60, Subpart DD - Standards ofPerfonnance for Grain Elevators

2


List ofAcronyms and Abbreviations

A.C.A.

AFIN

CFR

CO

HAP

lb/hr

No.

NOx

PM

PM lO

S02

Tpy

UTM

VOC

Arkansas Code Annotated

ADEQ Facility Identification Number

Code ofFederal Regulations

Carbon Monoxide

Hazardous Air Pollutant

Pound Per Hour

Number

Nitrogen Oxide

Particulate Matter

Particulate Matter Smaller Than Ten Microns

Sulfur Dioxide

Tons Per Year

Universal Transverse Mercator

Volatile Organic Compound

3


Section I: FACILITY INFORMATION

PERMITTEE: Riceland Foods, Inc. - Wheatley

AFIN: 62-00012

PERMIT NUMBER: 0478-AR-12

FACILITY ADDRESS: 133 DennisWheatley, AR 72392

MAILING ADDRESS: PO Box 927Stuttgart, AR 72160

COUNTY: St. Francis County

CONTACT NAME: Neil Washburn

CONTACT POSITION: Environmental Engineer

TELEPHONE NUMBER: 870-673-5337

REVIEWING ENGINEER: Bart Patton

UTM North South (Y):

UTM East West (X):

Zone 15: 3865027.78 m

Zone 15: 672506.79 m

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Section II: INTRODUCTION

Summary of Permit Activity

Riceland Foods, Inc, owns and operates Wheatley Grain Drying Cooperative, located at 133Dennis, Wheatley, Arkansas 72392. Operations at the Wheatley Grain Drying Cooperativeinclude receiving, cleaning, drying, handling, storage and load-out ofwheat, rice, and soybeans.

With this revision, the facility makes the following changes:

• Adding SN-73 (Unit #7 Shanzer Dryer, south) and SN-74 (Unit #7 Hull Tank)• Reducing emissions at SN-64 (Unit #7 Trash Tank)• Removing SN-55 (Unit #7 Berico Dryer #1), SN-58 (Unit #7 Berico Dryer #4) and SN-

63 (Unit #7 Dryer Sweeps Transfer Cyclone)

The facility had requested the removal from service ofSN-61 in R11. This was mistakenlyomitted from R11 and has been incorporated in this revision.

Some conditions were updated to match standard language in permit templates (e.g., "rolling 12-month" in lieu of "consecutive 12-month," etc.). NSPS Condition #12 was updated.

Emissions changed as follows: VOC, +0.3 tpy; CO, +4.0 tpy; NOx, +4.8 tpy.

Process Description

Riceland's facility operations at Wheatley in St. Francis County include the receiving, drying,handling, storage, and loadout of rice, soybeans, and wheat. The Wheatley facility has a licensedstorage capacity of 7,514,000 bushels.

The following Process Description is an overview of the typical receipts of each Unit and themanner in which they are processed. The calculations here were performed in accordance withthe 1996 Permit Appeal Resolution (PAR) for Corning, Wheatley, Dumas, Lonoke, andMcGehee. The calculations assume that each Unit will process the facility's entire receipts. Assuch, they do not reflect typical plant operations as a whole, but rather give a worst-case scenariofor annual permitted emission rates.

UNIT #1 (Sources SN-Ol, SN-02, SN-04, SN-07, SN-08, SN-13, SN-26 and SN-69)

Unit #1, originally constructed in 1941, receives various grains. The maximum annual grainreceipts are estimated at 285,000 tons.

Grain is normally received at a rate of 105 tonslhr at the receiving pit (SN-01). The receiving pitis equipped with an aspiration system that transfers collected particulate dust to an Aircon

5


bagfilter system designated as Units #1 & #2 Receiving Bagfilter (SN-02) which also capturesdust from the Unit #2 receiving pit, so that the maximum hourly receiving rate for SN-02 canreach 210 tons/hr. The pit aspiration system captures 90% of the fugitive dust generated fromunloading. The dust collected by SN-02 is transferred to a trash transfer cyclone.

The grain received at Unit #1 is scalped (cleaned) with the particulate matter controlled by thefully enclosed trash blower system. The rice is conveyed to storage bins through the use ofelevator legs, conveyor belts, and drag conveyors. Particulate dust generated by the grainhandling systems is collected by the Unit #1 Nuisance Dust System Bagfilter (SN-04). Dustcaptured by the SN-04 bagfilter is transferred to the Unit #1 Scalper Cyclone (SN-03).

The moisture content of grain is reduced by drying operations in the two Hess Grain Driers (SN-07 and SN-08). The dryers are natural gas fired with heat capacity ratings of 4.1 MMBtuIhrrespectively per dryer. Dryer screens and louvers control particulate matter generated by thedryers.

Dried rice is loaded onto trucks from gravity loadout spouts (SN-13) located at Unit #2.

Trash collected by the dust control devices is transferred to the Units #1, #2, #3 and #4 TrashTank (SN-26). The nuisance dust baghouse (SN-69) controls dust generated in the Unit #1Gallery, the Unit #2 Basement, Gallery, and Headhouse, and the Unit #4 Garner Bin.

Units #2/#3 (Sources SN-02, SN-09, SN-12, SN-13, SN-14, SN-15, SN-26 and SN-69)

Unit #2 was originally constructed in 1948. Unit #3 is used for processing and storage of grainreceived at the Unit #2 dump pit. Unit #3 is equipped only to dry and store.

Grain is normally received at a rate of 105 tons/hr at the Unit #2 receiving pit (SN-09). Thereceiving pit is equipped with an aspiration system that transfers collected particulate dust to anAircon bagfilter system designated as Units #1 & #2 Receiving Bagfilter (SN-02) which alsocaptures dust from the Unit #1 receiving pit, so that the maximum hourly receiving rate for SN-02 can reach 210 tons/hr. The pit aspiration system captures 90% of the fugitive dust generatedfrom unloading. The dust collected by SN-02 is transferred to a trash transfer cyclone.

The total processing rate of the Unit #2 receiving pit (SN-09) is 105 tons/hr. The receiving pit isequipped with an aspiration system for controlling fugitive emissions generated from theunloading operations. The aspiration system conveys the dust to the Units #1 & #2 ReceivingBagfilter (SN-02) for collection and control. Grain transferred in the Units is accomplished withelevator legs, belt conveyors and drag conveyors. Dust generated by these conveyors iscontrolled by the Units #2/#3 Rolfes Baghouse (SN-14). A baghouse was added for dust controlon internal conveyors in 1999. This is the Units #2/#3/#4 Aircon Baghouse (SN-69).

The moisture content of the grain is reduced by the drying operations in two Hess driers. Onedrier located at Unit #2 (SN-12) and one drier at Unit #3 (SN-15). The driers are natural gas

6


fired rack driers with heat inputs of 4.1 MMBtulhr each. Drier screens and louvers controlparticulate matter generated during all drying operations.

The Unit #2/#3 Nuisance Dust Baghouse (SN-14) controls the dust generated by the Unit #2tunnel belts and elevator legs, and also the Unit #3 tripper belt, tunnel belt and elevator legs.

Trash collected by the dust control devices is transferred to the Units #1, #2, #3 and #4 TrashTank (SN-26). The nuisance dust baghouse (SN-69) controls dust generated in the Unit #1Gallery, the Unit #2 Basement, Gallery, and Headhouse, and the Unit #4 Garner Bin.

Grain is loaded onto trucks from Units #1, #2, #3 & #4 through the spouts located at Unit #2(SN-13) at a maximum rate of300 tons/hr.

Unit #4 (Sources SN-Ol, SN-02, SN-13, SN-19, SN-22, SN-26 and SN-69)

Unit #4 is primarily a drying and storage unit. Grains are received into Unit #4 from the Unit #1truck dump (SN-01). The Unit # 1 truck dump is aspirated into the SN-02 Bagfilter system.Grain handling equipment in Unit #1 is vented to the SN-04 Bagfilter system.

Particulate emissions generated by the grain handling equipment are controlled by the newAircon Model 14RA296-10 bagfilter (designated as SN-19, Unit #4 Dust System). The grain isdried in a Hess dryer (SN-22), rated at 4.1 MMBtulhr.

Trash from Unit #4 Dust System Bagfilter is transferred by the trash blower system to the TrashTank (SN-26). The trash tank point source emissions are controlled by a bagfilter. Fugitiveemissions will also be generated during the trash dumping process.

The nuisance dust baghouse (SN-69) controls dust generated in the Unit #1 Gallery, the Unit #2Basement, Gallery, and Headhouse, and the Unit #4 Garner Bin.

Unit #2 loads out product received and processed in Units #1, #2, #3 and #4. Four gravityloadout spouts (SN-13) are available.

Unit #5 (Sources SN-27, SN-29, SN-31, SN-32, SN-38, SN-39, SN-40, SN-48, SN-66, SN-67and SN-68)

Unit #5, originally constructed in 1959, is equipped with two truck dumps. Each of the truckdumps is estimated to receive 950,000 bushels of rice, 275,000 bushels of soybeans and 400,000bushels ofwheat annually.

The maximum combined receiving rate of the two Receiving Pits (SN-27 and SN-29) is 8500bushels per hour. Particulate emissions generated during the unloading of the grain arecontrolled by the pit aspiration systems bag filter (SN-66) installed in 1997. After receiving, thegrain is cleaned at a scalperator. Emissions generated by the cleaning process are controlled bythe unit #5 Scalperator Dust System Baghouse (SN-31).

7


The grain received at this unit is dried in a natural gas fired Shanzer Dryer (SN-68) (added in1997) which has a rated capacity of 15 MM BTU/ hour and two Amarillo Driers (SN-38 & SN-39).

Another baghouse, the Unit #5 Upper Nuisance Dust System (SN-32) controls emissions fromthe top conveyors and the top ofthe headhouse. A bagfilter, the Unit #5 Upper Nuisance DustSystem (SN-67), was added in 1997 to control emissions from the tunnel conveyors and lowerheadhouse.

Grain will be loaded out from Unit #5 by one truck loadout or a railcar loadout (SN-40).

Dust from the new baghouses will be transferred to the units #1, #2, #3, and #4 trash tank. Dustfrom the cleaning operations and the Shanzer Dryer will be transferred to the Units #5 and #6Trash Tank (SN-48).

Unit #6 (Sources SN-41, SN-42, SN-43, SN-44, SN-45, SN-46, SN-47, SN-48 and SN-50)

Unit #6, originally constructed in 1966, receives 550,000 bushels of rice, 250,000 bushels ofsoybeans, and 200,000 bushels of wheat annually.

Grain is received at a rate of 7,000 bushels per hour at the Unit #6 Receiving Pit (SN-41). Aboutninety percent of the fugitive emissions generated by the receiving pit are routed to the Unit #6Receiving Pit Cyclones (SN-42). The particulates captured in the receiving pit cyclones arerouted to the Unit #6 Trash Transfer Cyclone (SN-43). The grain is then transferred to storagebins. Emissions generated by the handling of the grain are controlled by the Unit #6 UpperNuisance Dust System (SN-44) and the Unit #6 Lower Nuisance Dust System (SN-45). Thegrains are dried in two Shanzer Dryers (SN-46 and SN-47). Emissions created by the dryingprocess are controlled through the use of screens and louvers. Particulates captured by the dustcontrol devices at this unit are sent to the Units #5 and #6 Trash Tank (SN-48).

Dried grain can be loaded out from either a truck spout or a railcar spout at Unit #6 (SN-50) atthe rate of 10,000 bushels per hour.

Unit #7 (Sources SN-51, SN-52, SN-53, SN-54, SN-56, SN-57, SN-59, SN-60, SN-62, SN-64,SN-65, SN-71, SN-72, SN-73, and SN-74A/B)

Unit #7, originally constructed in 1976, is equipped with two receiving pits. Each pit isestimated to receive 1,230,000 bushels of rice, 775,000 bushels of soybeans, and 500,000bushels ofwheat annually.

Grain is normally received at a rate of 10,000 bushels per hour at either Dump Pit #7 (SN-51) orDump Pit #8 (SN-53). Each of the Dump Pits is equipped with an aspiration system that transferscollected particulate dust to the multiple-cyclone systems (SN-52 or SN-54). Fugitive particulateemissions are generated from the unloading operations. The pit aspiration system captures 90%

8


of the fugitive dust generated from unloading. The dust collected in the multiple cyclone istransferred to a Unit 7 trash tank (SN-64).

The licensed storage capacity ofUnit 7 is approximately 1.5 million bushels. Due to its size, thefacility was divided into two sections, a Northeast section and a Southwest section. Each sectionhandles approximately half of the grain received at the Unit. The grain is conveyed to storagebins through the use of elevator legs, conveyor belts, and drag conveyors. Particulate dustgenerated by the handling systems is collected in the Upper Nuisance Dust System (NE)baghouse (SN-59), the Upper Nuisance Dust System (SW) baghouse (SN-60), the LowerNuisance Dust System (SW) cyclone (SN-62), and the Scalperator Baghouse (SN-72) thatcollects nuisance dust from four scalperators and the lower nuisance dust system in the northeastsection of the facility.

The moisture content of rice is reduced by drying operations in the two Berico Grain Dryers(SN-56, and 57) and two Shanzer Dryers (SN-71 and SN-73). All dryers are natural gas fired.The Berico dryers have heat capacity ratings of 15.0 MMBtulhr per dryer, and the Shanzerdryers are rated at 25.9 MMBtulhr. All dryers are in louvered enclosures with 24 mesh screensover the louvers. The debris (rice hulls) captured by the Berico and the Shanzer dryer enclosuresis collected by the Hull Tank (SN-74A and 74B).

Trash collected by the dust control devices (SN-52, 54, 59, 60, 62, and 72) is transferred to theUnit #7 Trash Tank (SN-64). Tank vent emissions are controlled by Aircon bin vent bagfilters.Fugitive emissions generated by trash dumping are uncontrolled.

Unit #7 is capable of shipping grain from truck spouts and a railcar spout at the rate of 16,000bushels per hour. The loadout (SN-65) emissions are uncontrolled.

SN-55 (Unit #7 Berico Dryer #1), SN-58 (Unit #7 Berico Dryer #4), SN-61 (Unit #7 LowerNuisance Dust System, northeast), and SN-63 (Unit #7 Dryer Sweeps Transfer Cyclone) havebeen removed from service.

Regulations

The following table contains the regulations applicable to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective June 18, 2010

Regulations of the Arkansas Plan of Implementation for Air Pollution Control,Regulation 19, effective July 18,2009

40 CFR Part 60, Subpart DD - Standards ofPerformance for Grain Elevators

9


Total Allowable Emissions

The following table is a summary of emissions from the facility. This table, in itself, is not anenforceable condition of the pennit.

TOTAL ALLOWABLE EMISSIONS

Emission RatesPollutant

lb/hr tpy

PM 471.4 102.8

PM10 193.4 27.3

S02 1.4 1.5

VOC 1.6 4.5

CO 12.7 59.9

NOx 14.7 71.0

10


Section III: PERMIT HISTORY

Permit No. 478-A was issued to Wheatley Grain Drying Co-Op on March 13, 1978. The permitwas issued to add aspiration on three grain receiving stations and screens on six existing graindryers. The permit contained no emission limits.

Permit No. 478-AR-l was issued to Wheatley Grain Drying Co-Op on June 13, 1985. Thepermit modification was to install cyclofans on the outlets of the trash tanks to correct opacityproblems on the vents from the tanks. There were no emission limits, but the cyclofans wereassigned an opacity limit of 10%.

Permit No. 478-AR-2 was issued to Wheatley Grain Drying Cooperative on April 22, 1991. Thepermit modification was issued to allow the installation of 3 new bag filters to reduce particulateemissions. There were 7 units listed with a total of 61 source numbers. Emission limits were422.421b/hr and 1,850.22 tpy of PM. No other pollutants were listed. All emission sources wereassigned an opacity limit for the first time.

Permit No. 478-AR-3 was issued to Wheatley Grain Drying Cooperative - Riceland Foods, Inc.on January 28, 1994. This permit modification was to replace a cylofan with a bag filter, add sixgrain dryers which were existing but unlisted, and add loadout emissions. This permit defined abaseline PSD limit for particulate matter of 588.6 tpy. There were 81 sources listed. Emissionlimits were: PM -588.6 tpy, S02 - 1.6 tpy, VOC - 1.7 tpy, CO - 1.9 tpy and NOx - 11.8 tpy.

Permit No. 478-AR-4 was issued to Wheatley Grain Drying Cooperative - Riceland Foods, Inc.on August 9, 1996. This permit modification was issued for a upgrade of Unit No.5. Permitlimits were listed as PM - 23.1 tpy, PM lO - 15.2 tpy, S02 - 1.4 tpy, VOC - 1.4 tpy, CO - 1.4 tpyand NOx - 3.4 tpy.

Permit No. 478-AR-5 was issued to Wheatley Grain Drying Cooperative - Riceland Foods, Inc.on May 9, 1997. The permit modification was issued to allow for: (1) the installation of a newgrain dryer, (2) replacement of six cyclones with one baghouse, (3) having a facility wide grainreceiving limit, (4) increasing the opacity limits for several pieces of equipment as agreed to inthe permit appeal resolution, (5) changes in the wording of the visible emissions specificcondition, (6) the removal of the specific condition stating that the permittee shall comply withthe SIP and the Air Code, and (7) increasing the permitted limit of natural gas usage. Permitlimits were listed as PM! PM lO - 85.8 tpy, S02 - 1.5 tpy, VOC - 4.4 tpy, CO - 19.4 tpy and NOx-78.3 tpy.

A permit appeal resolution was issued August 27, 1997 for the above permit which allowed dualopacities for the trash tanks. SN-48 was assigned opacities of 10% for the vent and 40% for thetank and SN-64 was assigned opacities of 10 % for the vent and 20% for the tank.

Permit No. 478-AR-6 was issued to Wheatley Grain Drying Cooperative-Riceland Foods Inc onJune 28, 2000, and amended on July 7, 2000. The permit modification was issued to allow forthe installation of a new dust collection System (SN-69) for the Unit 1 Gallery, and Unit 2

11


Basement, Gallery and Headhouse, and Unit 4 Garner bins. Permit limits were listed in tpy asPM-150.6, PM IO,-49.6, S02-1.5, VOC-3.6, CO-49.7, and NOx.

Permit No. 478-AR-7 was issued to allow the permittee to improve the dust collection system byreplacing ten (10) cyclone collectors with two (2) new bagfilters. One bagfilter replaced six (6)cyclones associated with Units 1 and 2 receiving pit cyclones (sources SN-02 and SN-10). Thesecond bagfilter replaced four (4) cyclones associated with Unit 1 Upper, Lower, and Elevatordust systems (sources SN-04, SN-05 and SN-06). As a result of this modification Unit #1 LowerNuisance Dust System (former SN-05), Unit #1 Elevator Nuisance Dust System (former SN-06)and Unit #2 receiving pit cyclone (former SN-10) are no longer in service.

This modification also affected the emissions from the transfer cyclone (SN-03), whichpreviously received only scalpings from the Unit 1 scalperator and transferred the material to thetrash tank. The material from the two new bagfilters will also be sent to the SN-03 cyclone to berelayed to the trash tame

The potential emissions for this modification will be from new sources SN-02 and SN-04including the emissions increase from SN-03. The PM IO emissions from SN-02 will be 0.2 tpy,and 0.1 tpy from SN-04. The increase in emissions from SN-03 was 4.0 tpy and the totalpotential increase in emissions resulting from installation of the baghouses was 4.3 tpy.

Permit No. 478-AR-8 was issued to include the following:

1) Installation of a new, more efficient, dust collection system at Unit #4 that included anew Aircon Model 14RA296-10 bagfilter (designated as SN-19, Unit #4 Dust System) whichreplaced three existing cyclones (old SN-19, SN-20 and SN-21). The emission rate from SN-19was 0.21b/hr ofPMlPM IO•

2) Installation of a new trash blower system that allowed the elimination of three existingcyclones (SN-03, SN-24 and SN-25).

3) Eliminating the following equipment/control devices that had been removed fromservice:

SN-11 - Unit #2 Dust System CycloneSN-16 - Unit # 4 Receiving PitSN-17 - Unit #4 Receiving Pit CyclonesSN-18 - Unit #4 Scalperator Aspiration SystemSN-23 - Unit #4 Sanders Dryer

Equipment grain throughputs remained the same. Because of equipment changes and somechanges in emission factors, total annual permitted emission rates ofPM decreased from 150.6tpy to 108.9 tpy and PM IO rates decreased from 49.6 tpy to 32.7 tpy. Permitted NOx emissionrates decreased from 59.2 tpy to 54.8 tpy.

12


Permit No. 0478-AR-8 was issued to replace the cyclones associated with the Unit #6 Dump Pit(SN-42) with a new bagfilter and fan, Unit #6 Dust System (SN-70). The new baghouseemissions also included emissions from previously Uncontrolled equipment. Equipment on theSN-06 dust system included the dump pit, receiving drag conveyors, reclaim drag, reclaimelevator legs, tripper floor drags and tripper belt. The changes at the facility resulted in increasedemissions from SN-48, Units #5 & #6 Trash Tank. However, since the facility-wide PM andPM lO emission rates are based on the worst case unit (Unit #1), the permitted facility-wideemissions did not change as a result of this modification. All changes in emission rates were aresult of updated calculations for sources unrelated to the requested modification.

Permit No. 0478-AR-9 was issued to replace the cyclones associated with the Unit #6 Dump Pit(SN-42) with a new bagfilter and fan, Unit #6 Dust System (SN-70). The new baghouseemissions also included emissions from previously uncontrolled equipment. Equipment on theSN-06 dust system included the dump pit, receiving drag conveyors, reclaim drag, reclaimelevator legs, tripper floor drags and tripper belt. These changes at the facility resulted inincreased emissions from SN-48, Units #5 & #6 Trash Tank, However, since the facility-widePM and PM lO emission rates were based on the worst case unit (Unit #1), the permitted facility-wide emissions did not change as a result of this modification. All changes in emission rateswere a result of updated calculations for sources unrelated to the requested modification.

Permit No. 0478-AR-10 was issued on February 14,2011, to approve installation of a 25.9MMBtulhr natural gas fired Shanzer grain dryer (SN-71) at Unit #7. The permitted receipt limitof285,000 tons per year remained unchanged.

Permit No. 0478-AR-II was issued on June 2, 2011. The permitted receipt limit of285,000 tonsper year remained unchanged. With this revision, the facility made the following changes:

• Adding SN-72 (Unit #7 Scalperator Baghouse)• Decreasing emissions at SN-64 (Unit #7 Trash Tank) by adding bin vent bagfilters

(99.5% efficiency)• Updating facility NAICS and SIC codes

Emissions changed as follows: PM at SN-64 decreased by 0.2 tpy; PM lO at SN-64 decreased by0.1 tpy; PM at SN-72 was added at 0.3 tpy; and PM lO at SN-72 was added at 0.1 tpy.

13


Section IV: EMISSION UNIT INFORMATION

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 19 §19.501 et seq. and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311]

SN Description Pollutant lb/hr tpy

01 Unit #1 Receiving Pit (Dump #1) PMlO 0.6 0.8*

02 Unit #2 Receiving Pit Bagfilter PM lO 0.3 0.2*

04 Unit #1 Nuisance Dust System - Bagfilter PM10 0.1 0.1*

PM lO 4.6 10.8*

S02 0.1 0.1

07 Unit #1 Hess Dryer (#101) (2.4 MMBtu/hr) VOC 0.1 0.1

CO 0.2 0.9

NOx 0.3 1.1

PM lO 4.6 10.8*

S02 0.1 0.1


CO 0.2 0.9

NOx 0.3 1.1

09 Unit #2 Receiving Pit (Dump #2) PM 10 0.6 0.8

PM lO 15.9 10.8

S02 0.1 0.1


CO 0.4 1.5

NOx 0.4 1.8

13 Unit #2 Loadouts PM lO 8.7 4.1*

14 Units #2 and #3 Nuisance Dust Baghouse PM lO 0.1 0.1

15 Unit #3 Hess Dryer (#301) (4.1 MMBtu/hr) PM 10 12.7 10.8

14



S02 0.1 0.1

VOC 0.1 0.1

CO 0.4 1.5

NOx 0.4 1.8

19Unit #4 Dust System

PM lO 0.1 0.1Aircon Model 14RA296-10 Bagfilter

PM 10 12.7 10.8

S02 0.1 0.1


CO 0.4 1.5

NOx 0.4 1.8

26 Units #1, #2, #3, #4, and #5 Trash Tank PM10 0.7 0.4*

27 Unit #5 Receiving Pit (Dump #4) PM lO 0.8 0.3

29 Unit #5 Receiving Pit (Dump #5) PM10 0.8 0.3

31 Unit #5 Sca1peratorAspiration System PM lO 0.2 0.1

32 Unit #5 Upper Nuisance Dust System PM10 0.1 0.1

PM10 1.5 1.0

S02 0.1 0.1

38 Unit #5 Amarillo Dryer (#501) VOC 0.1 0.3

CO 0.9 3.7

NOx 1.0 4.4

PM10 1.5 1.0

S02 0.1 0.1

39 Unit #5 Amarillo Dryer (#502) VOC 0.1 0.3

CO 0.9 3.7

NOx 1.0 4.4

40 Unit #5 Loadouts PM lO 6.5 3.1

41 Unit #6 Receiving Pit (Dump #6) PM lO 0.9 0.6

15



43 Unit #6 Trash Transfer Cyclone PM 10 74.3 2.9

44 Unit #6 Upper Nuisance Dust System PM 10 0.8 0.5

45 Unit #6 Lower Nuisance Dust System PM 10 0.8 0.5

PM IO 1.1 1.0

S02 0.1 0.1

46 Unit #6 Shanzer Dryer (#601) VOC 0.1 0.2

CO 0.5 2.3

NOx 0.6 2.7

PM 10 1.1 1.0

S02 0.1 0.1

47 Unit #6 Shanzer Dryer (#602) VOC 0.1 0.2

CO 0.5 2.3

NOx 0.6 2.7

48 Units #5 and #6 Trash PM 10 0.4 1.5

50 Units #6 Loadouts PM 10 6.5 3.1

51 Unit #7 Receiving Pit (Dump #7) PM 10 1.4 0.3

52 Unit #7 Dump Pit #7 Cyclones PM 10 2.4 0.6

53 Unit #7 Receiving Pit (Dump #8) PMlO 1.4 0.3

54 Unit #7 Dump Pit #8 Cyclones PM lO 2.4 0.6

55 Unit #7 Berico Dryer (#1) Removed from Service

PM 10 2.7 0.9

S02 0.1 0.1

56 Unit #7 Berico Dryer (#2) VOC 0.1 0.4

CO 1.3 5.6

NOx 1.5 6.6

PM lO 2.7 0.957 Unit #7 Berico Dryer (#3)

S02 0.1 0.1

16


SN Description Pollutant lblhr tpy

VOC 0.1 0.4

CO 1.3 5.6

NO x 1.5 6.6

58 Unit #7 Berico Dryer (#4) Removed from Service

59 Unit #7 Upper Nuisance Dust System PM 10 0.1 0.1(Northeast)

60 Unit #7 Upper Nuisance Dust System PMlO 0.1 0.1(Southwest)

61 Unit #7 Lower Nuisance Dust System Removed from Service(Northeast)

62 Unit #7 Lower Nuisance Dust System PM10 0.5 0.2(Southwest)

63 Unit #7 Dryer Sweeps Transfer Cyclone Removed from Service

64 Unit #7 Trash Tank PM 10 0.6 0.3

65 Unit #7 Loadouts PM10 10.3 3.1

66 Unit #5 Dump Pits Bagfilter PM10 0.2 0.1

67 Unit #5 Lower Nuisance Dust System PMlO 0.1 0.1

PM10 1.2 0.8

S02 0.1 0.1

68 Unit #5 Shanzer Dryer VOC 0.1 0.4

CO 1.3 5.6

NOx 1.5 6.6

69 Units #1, 2, 3, & 4 Nuisance Dust Baghouse PMlO 0.3 0.1*

70 Unit #6 Dust System Baghouse PMlO 0.2 0.2

PM10 3.5 2.571 Unit #7 Shanzer Dryer (25.9 MMBtulhr)

S02 0.1 0.1

17


*These sources belong to Umt #1. The facility -wide PM and PM IO tpy emissions limits are based on handlmgthe throughput limit ofgrain for the facility through the least efficient unit (Unit #1). PM and PM IO emissionsfor all sources are accounted for under the facility-wide emission limits.


VOC 0.2 0.7

CO 2.2 9.6

NOx 2.6 11.4

72 Unit #7 Scalperator Baghouse PM IO 0.3 0.1

PM 10 3.5 2.5

S02 0.1 0.1

73Unit #7 Shanzer Dryer, south

VOC 0.2 0.7(25.9 MMBtu/hr)

CO 2.2 9.6

NOx 2.6 11.4

74A Unit #7 Hull Tank (tank vent emissions) PM 10 0.2 0.1

74B Unit #7 Hull Tank (tank unloading emissions) PM 10 0.1 0.1. . ..

2. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 18 §18.801 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


01Unit #1 Receiving Pit

PM 1.9 2.6*(Dump #1)


PM 0.8 0.5*Bagfilter

Unit #1 Nuisance04 Dust System - PM 0.2 0.2*

BagfilterUnit #1 Hess Dryer

07 (#101) (2.4 PM 18.1 43.0*MMBtu/hr)

Unit #1 Hess Dryer08 (#102) (2.4 PM 18.1 43.0*

MMBtu/hr)


PM 1.9 2.6(Dump #2)

12Unit #2 Hess Dryer

PM 63.1 43.0(#201) (4.1

18



MMBtu/hr)

13 Unit #2 Loadouts PM 25.8 12.3*

Units #2 and #314 Nuisance Dust PM 0.1 0.2

BaghouseUnit #3 Hess Dryer

15 (#301) (4.1 PM 50.5 43.0MMBtu/hr)

Unit #4 Dust System19 Aircon Model PM 0.2 0.2

14RA296-10 BagfilterUnit #4 Hess Dryer

22 (#401) (4.1 PM 50.5 43.0MMBtu/hr)

26Units #1, #2, #3, #4,

PM 2.3 1.0*and #5 Trash Tank


PM 3.2 1.3(Dump #4)


PM 3.2 1.3(Dump #5)

31Unit #5 Scalperator

PM 0.7 0.3Aspiration System

32Unit #5 Upper

PM 0.4 0.2Nuisance Dust System

38Unit #5 Amarillo

PM 5.4 2.5Dryer (#501)

39Unit #5 Amarillo PM 5.4 2.5

Dryer (#502)

40 Unit #5 Loadouts PM 25.8 12.3


PM 3.8 2.6(Dump #6)

43Unit #6 Trash

PM 17.1 11.6Transfer Cyclone

44Unit #6 Upper


45Unit #6 Lower


46Unit #6 Shanzer Dryer PM 4.1 3.4

(#601)

47Unit #6 Shanzer Dryer PM 4.1 3.4

(#602)

19



48 Units #5 and #6 Trash PM 1.3 5.1

50 Units #6 Loadouts PM 25.8 12.3


PM 5.4 1.3(Dump #7)

52Unit #7 Dump Pit #7

PM 9.7 2.3Cyclones


PM 5.4 1.3(Dump #8)

54Unit #7 Dump Pit #8

PM 9.7 2.3Cyclones

55Unit #7 Berico Dryer

Removed from Service(#1)


PM 10.1 1.7(#2)


PM 10.1 1.7(#3)


Removed from Service(#4)

Unit #7 Upper59 Nuisance Dust System PM 0.2 0.1

(Northeast)Unit #7 Upper

60 Nuisance Dust System PM 0.2 0.1(Southwest)

Unit #7 Lower61 Nuisance Dust System Removed from Service

(Northeast)Unit #7 Lower

62 Nuisance Dust System PM 1.8 0.9(Southwest)

63Unit #7 Dryer Sweeps

Removed from ServiceTransfer Cyclone

64 Unit #7 Trash Tank PM 1.6 0.5

65 Unit #7 Loadouts PM 41.3 12.6

66Unit #5 Dump Pits

PM 0.8 0.3Bagfiltcr

67Unit #5 Lower


68 Unit #5 Shanzer Dryer PM 4.2 1.6

20

Riceland Foods, Inc. - WheatleyPermit #: 0478-AR-12AFIN: 62"-00012

SN Description Pollutant 1b/hr tpy

Units #1,2,3, & 469 Nuisance Dust PM 0.5 0.2*

Bazhouse

70Unit #6 Dust System

PM 0.6 0.4Baghouse

71Unit #7 Shanzer Dryer

PM 13.2 7.2(25.9 MMBtu/hr)

72Unit #7 Scalperator

PM 1.0 0.3Baghouse

Unit #7 Shanzer73 Dryer, south (25.9 PM 13.2 7.2

MMBtu/hr)

74AUnit #7 Hull Tank

PM 0.8 0.2(tank vent emissions)

Unit #7 Hull Tank74B (tank unloading PM 0.1 0.1

emissions)*These sources belong to Unit # 1. The facility -wide PM and PM IO tpy emissions limits are based onhandling the throughput limit ofgrain for the facility through the least efficient unit (Unit # 1). PM andPM IO emissions for all sources are accounted for under the facility-wide emission limits.

3. Visible emissions may not exceed the limits specified in the following table of this permitas measured by EPA Reference Method 9. [A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

SN Limit Regulatory Citation

01,07-09, 12, 13,22,27,29,38-48, 40% §19.503

5026,51-54,56,57,61,62,64,65,69, 20% §19.503

7402,04,14,19,48(vent), 59, 60, 64 10% §18.501(vent), 74A (vent)

31,32,66,67 0% §19.304 and 40 CFR 60.302

68, 70-73 5% §18.501

4. The permittee shall not cause or permit the emission of air contaminants, including odorsor water vapor and including an air contaminant whose emission is not otherwiseprohibited by Regulation #18, if the emission of the air contaminant constitutes air

21


pollution within the meaning ofA.C.A. §8-4-303. [Regulation 18 §18.80l andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

5. The permittee shall not conduct operations in such a manner as to unnecessarily cause aircontaminants and other pollutants to become airborne. [Regulation 18 §18.901 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Facility-wide Conditions

6. During the loading ofwaste material generated from grain cleaning and pollution controldevices from trash tanks onto trucks for the purposes of disposal, Riceland will be limitedto 20% opacity, to be detennined by averaging all readings taken in accordance withUSEPA Method 9, over a period of thirty-six consecutive minutes. If, at any time,Riceland exceeds the opacity limitation, the occurrence shall be reported to ADEQ inaccordance with Regulation 18.

Riceland will maintain a written log at the facility which documents each time material isloaded from the trash tanks onto a truck. Each entry shall include the approximate weightof the material loaded, and the duration of the loading operation.

The activity will be conducted in such a manner as to cause no nuisance to thesurrounding community. ADEQ reserves the right to rescind this authority if, at anytime, the emissions from the operations become a nuisance to the surroundingcommunity. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

7. The facility shall not emit more than 23.7 ton per year ofPM 10 at the facility per rolling12 month period. Compliance with this limit shall be demonstrated by compliance withSpecific Condition 9. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

8. The facility shall not emit more than 102.8 ton per year ofPM at the facility per rolling12 month period. Compliance with this limit shall be demonstrated by compliance withSpecific Condition 9. [Regulation 19, §19.501 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

9. The permittee shall not process more than 285,000 tons ofgrain at the facility per rolling12-monthperiod. [Regulation 19, §19.705 andA.C.A. §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-311]

10. The permittee shall maintain monthly records which demonstrate compliance withSpecific Condition #9. The permittee shall update these records by the fifteenth day ofthe month following the month to which the records pertain. The twelve month rollingtotals and each individual month's data shall be maintained on-site and made available toDepartment personnel upon request. [Regulation 19, §19.705 and A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]

22


11. The permittee will utilize only pipeline quality natural gas or LP gas to fuel the dryers atthis facility. Record keeping of usage is not required since the dryers are permitted atmaximum capacity. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

NSPS Conditions

12. This facility is considered an affected source under 40 CFR Part 60, Subpart DD,Standards of Performance for New Stationary Sources - Grain Elevators and shall complywith all requirements applicable in this subpart. The permittee is subject, but not limitedto, the following applicable requirements. [Regulation 19, §19.304 and 40 CFR Part 60,Subpart DD]

1. SN-31, SN-32, SN-66, and SN-67 will not emit more than 0.01 gr/dscf ofparticulate emissions or exhibit more than 0% opacity. [Regulation 19, §19.705and 40 CFR 60.302(b)]

11. For sources requiring performance tests under 40 CFR Part 60, Subpart DD, theperformance test data shall be maintained on-site and made available toDepartment personnel upon request. [Regulation 18, §18.1002 and 40 CFR60.302(b)]

111. SN-68, SN-71 and SN-73 are subject to 40 CFR Part 60, Subpart DD - Standardsof Performance for Grain Elevators. The permittee shall comply with allapplicable regulations under 40 CFR Part 60, Subpart DD. SN-68, SN-71 andSN-73 comply with the requirements by having a clear opening in the wire meshofless than 0.094 inches. [Regulation No. 19 §19.503 and 40 CFR §60.302(a)(l)]

23


Section V: INSIGNIFICANT ACTIVITIES

The Department deems the following types of activities or emissions as insignificant on the basisof size, emission rate, production rate, or activity in accordance with Group A of theInsignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activityemission determinations rely upon the information submitted by the permittee in an applicationdated January 19,2012.

Description

None

24

Category


Section VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit that specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (A.C.A. §8-4-101 et seq.) as the sole origin of and authority for theterms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. ArkansasPollution Control & Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any terms orconditions included in this permit that specify and reference Arkansas Pollution Control& Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution ControlAct (A.C.A. §8-4-101 et seq.) as the origin of and authority for the terms or conditionsare enforceable under this Arkansas statute.

2. This permit does not relieve the owner or operator of the equipment and/or the facilityfrom compliance with all applicable provisions of the Arkansas Water and Air PollutionControl Act and the regulations promulgated under the Act. [A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

3. The permittee shall notify the Department in writing within thirty (30) days aftercommencement of construction, completion of construction, first operation of equipmentand/or facility, and first attainment of the equipment and/or facility target production rate.[Regulation 19 §19.704 and/or A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-31I]

4. Construction or modification must commence within eighteen (18) months from the dateof permit issuance. [Regulation 19 §19.41O(B) and/or Regulation 18 §18.309(B) andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

5. The permittee must keep records for five years to enable the Department to determinecompliance with the terms of this permit such as hours of operation, throughput, upsetconditions, and continuous monitoring data. The Department may use the records, at thediscretion of the Department, to determine compliance with the conditions of the permit.[Regulation 19 §19.705 and/or Regulation 18 §18.1004 and A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

6. A responsible official must certify any reports required by any condition contained in thispermit and submit any reports to the Department at the address below. [Regulation 19§19.705 and/or Regulation 18 §18.1004 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector Supervisor

25


5301 Northshore DriveNorth Little Rock, AR 72118-5317

7. The permittee shall test any equipment scheduled for testing, unless stated in the SpecificConditions of this permit or by any federally regulated requirements, within the followingtime frames: (l) newly constructed or modified equipment within sixty (60) days ofachieving the maximum production rate, but no later than 180 days after initial start up ofthe permitted source or (2) existing equipment already operating according to the timeframes set forth by the Department. The permittee must notify the Department of thescheduled date of compliance testing at least fifteen (15) business days in advance ofsuch test. The permittee must submit compliance test results to the Department withinthirty (30) calendar days after the completion of testing. [Regulation 19 §19.702 and/orRegulation 18 §18.1002 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

8. The permittee shall provide: [Regulation 19 §19.702 and/or Regulation 18 §18.1002 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

a. Sampling ports adequate for applicable test methods;b. Safe sampling platforms;c. Safe access to sampling platforms; andd. Utilities for sampling and testing equipment

9. The permittee shall operate equipment, control apparatus and emission monitoringequipment within their design limitations. The permittee shall maintain in goodcondition at all times equipment, control apparatus and emission monitoring equipment.[Regulation 19 §19.303 and/or Regulation 18 §18.1104 and A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

10. lfthe permittee exceeds an emission limit established by this permit, the permittee will bedeemed in violation of said permit and will be subject to enforcement action. TheDepartment may forego enforcement action for emissions exceeding any limitsestablished by this permit provided the following requirements are met: [Regulation 19§19.601 and/or Regulation 18 §18.1101 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

a. The permittee demonstrates to the satisfaction of the Department that theemissions resulted from an equipment malfunction or upset and are not the resultofnegligence or improper maintenance, and the permittee took all reasonablemeasures to immediately minimize or eliminate the excess emissions.

b. The permittee reports the occurrence or upset or breakdown of equipment (bytelephone, facsimile, or overnight delivery) to the Department by the end of thenext business day after the occurrence or the discovery of the occurrence.

c. The permittee must submit to the Department, within five business days after theoccurrence or the discovery of the occurrence, a full, written report of suchoccurrence, including a statement of all known causes and of the scheduling and

26


nature of the actions to be taken to minimize or eliminate future occurrences,including, but not limited to, action to reduce the frequency of occurrence of suchconditions, to minimize the amount by which said limits are exceeded, and toreduce the length of time for which said limits are exceeded. If the information isincluded in the initial report, the information need not be submitted again.

11. The permittee shall allow representatives of the Department upon the presentation ofcredentials: [A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

a. To enter upon the permittee's premises, or other premises under the control of thepermittee, where an air pollutant source is located or in which any records arerequired to be kept under the terms and conditions of this permit;

b. To have access to and copy any records required to be kept under the terms andconditions of this permit, or the Act;

c. To inspect any monitoring equipment or monitoring method required in thispermit;

d. To sample any emission of pollutants; ande. To perform an operation and maintenance inspection of the permitted source.

12. The Department issued this permit in reliance upon the statements and presentationsmade in the permit application. The Department has no responsibility for the adequacy orproper functioning of the equipment or control apparatus. [A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

13. The Department may revoke or modify this permit when, in the judgment of theDepartment, such revocation or modification is necessary to comply with the applicableprovisions of the Arkansas Water and Air Pollution Control Act and the regulationspromulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19§19.41O(A) and/or Regulation 18 §18.309(A) and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

14. This permit may be transferred. An applicant for a transfer must submit a written requestfor transfer of the permit on a form provided by the Department and submit the disclosurestatement required by Arkansas Code Annotated §8-1-106 at least thirty (30) days inadvance of the proposed transfer date. The permit will be automatically transferred to thenew permittee unless the Department denies the request to transfer within thirty (30) daysof the receipt of the disclosure statement. The Department may deny a transfer on thebasis of the information revealed in the disclosure statement or other investigation or,deliberate falsification or omission of relevant information. [Regulation 19 §19.407(B)and/or Regulation 18 §18.307(B) and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

15. This permit shall be available for inspection on the premises where the control apparatusis located. [A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

27


16. This permit authorizes only those pollutant emitting activities addressed herein. [A.C.A.§8-4-203 as referenced by §8-4-304 and §8-4-311]

17. This permit supersedes and voids all previously issued air permits for this facility.[Regulation 18 and 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

18. The permittee must pay all permit fees in accordance with the procedures established inRegulation No.9. [A.C.A §8-1-105(c)]

19. The permittee may request in writing and at least 15 days in advance of the deadline, anextension to any testing, compliance or other dates in this permit. No such extensions areauthorized until the permittee receives written Department approval. The Departmentmay grant such a request, at its discretion in the following circumstances:

a. Such an extension does not violate a federal requirement;b. The permittee demonstrates the need for the extension; andc. The permittee documents that all reasonable measures have been taken to meet

the current deadline and documents reasons it cannot be met.

[Regulation 18 §18.314(A), Regulation 19 §19.416(A), A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

20. The permittee may request in writing and at least 30 days in advance, temporaryemissions and/or testing that would otherwise exceed an emission rate, throughputrequirement, or other limit in this permit. No such activities are authorized until thepermittee receives written Department approval. Any such emissions shall be included inthe facilities total emissions and reported as such. The Department may grant such arequest, at its discretion under the following conditions:

a. Such a request does not violate a federal requirement;b. Such a request is temporary in nature;c. Such a request will not result in a condition of air pollution;d. The request contains such information necessary for the Department to evaluate

the request, including but not limited to, quantification of such emissions and thedate/time such emission will occur;

e. Such a request will result in increased emissions less than five tons of anyindividual criteria pollutant, one ton of any single HAP and 2.5 tons of totalHAPs; and

f. The permittee maintains records of the dates and results of such temporaryemissions/testing.

[Regulation 18 §18.314(B), Regulation 19 §19.416(B), A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

28


21. The permittee may request in writing and at least 30 days in advance, an alternativeto the specified monitoring in this permit. No such alternatives are authorized until thepermittee receives written Department approval. The Department may grant such arequest, at its discretion under the following conditions:

a. The request does not violate a federal requirement;b. The request provides an equivalent or greater degree of actual monitoring to the

current requirements; andc. Any such request, if approved, is incorporated in the next permit modification

application by the permittee.

[Regulation 18 §18.314(C), Regulation 19 §19.416(C), A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

29


Appendix A

40 CFR Part 60, Subpart DD - Standards of Performance for Grain Elevators

31

Title 40: Protection of EnvironmentPART GO-STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES

Subpart DO-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 storageelevator, except as provided under §60.304{b). The affected facilities are each truck unloading station, truck loadingstation, barge and ship unloading station, barge and ship loading station, railcar loading station, railcar unloadingstation, grain dryer, and all grain handling operations.

(b) Any facility under paragraph (a) of this section which commences construction, modification, or reconstructionafter 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 ofthis 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, orloaded.

(c) Grain tenninal 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, cerealmanufacturers, breweries, and livestock feedlots.

(d) Pennanent 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 (humanconsumption), 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 directlyinto the atmosphere from an affected facility at a grain elevator.

(i) Capture system means the equipment such as sheds, hoods, ducts, fans, dampers, etc. used to collect particulatematter 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 atruck, railcar, barge, or ship.

A-l

(I) Grain handling operations include bucket elevators or legs (excluding legs used to unload barges or ships), scalehoppers and surge bins (garners), turn heads, scalpers, cleaners, trippers, and the headhouse and other suchstructures.

(m) Column dryer means any equipment used to reduce the moisture content of grain in which the grain flows fromthe 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 thetop to the bottom in a cascading flow around rows of baffles (racks).

(0) Unloading leg means a device which includes a bucket-type elevator which is used to remove grain from a bargeor 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 shallcause 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 oroperator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any affectedfacility 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 shallcause 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 greaterthan 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.

(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 bottompulley 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).

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(3) Rather than meet the requirements of paragraphs (d)(1) and (2) of this section the owner or operator may useother methods of emission control if it is demonstrated to the Administrator's satisfaction that they would reduceemissions 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 andprocedures 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 thissection.

(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 theeffluent gas. The sampling time and sample volume for each run shall be at least 60 minutes and 1.70 dscm (60dscf). 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 inthis 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 determinewhether 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 amodification 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.

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CERTIFICATE OF SERVICE

I, Cynthia Hook, hereby certify that a copy of this permit has been mailed by first class mail to

/7I\--f'&-Riceland Foods, Inc. - Wheatley, PO Box 927, Stuttgart, AR, 72160, on thiscX_V_ day of

April, 2012.

Cl~=-----_._Cynthia Hook, ASHI, Air Division

Date post:	12-Feb-2021
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RESPONSE TO COMMENTS RICELAND FOODS, INC ......ARK A N S A S Department of Environmental Quality APR...

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