Contract analysis

I. Description of the Proposed Facility The Muscatine Expansion Facility will be a multi-unit industrial facility consisting of two principal process operations: (1) a soybean crush operation with a design capacity of approximately 3,200 tons per day, encompassing grain receiving, cleaning, preparation, solvent extraction, meal drying, and oil degumming; and (2) a granular fertilizer blending line with a capacity of

II. Local Land-Use Approvals GAP has obtained all required local land-use approvals necessary for the construction and operation of the MEF at the proposed site. The 147-acre parcel is classified under the Agricultural-Industrial ("AI") zoning district pursuant to the Muscatine County Zoning Ordinance. Soybean processing and fertilizer blending operations are permitted in the AI district subject to the issuance of a

III. Attainment Status The MEF is located within Muscatine County, Iowa. Muscatine County is currently designated as an attainment area for all criteria pollutants under the National Ambient Air Quality Standards ("NAAQS") established pursuant to Section 109 of the Clean Air Act, 42 U.S.C. § 7409. Because the proposed MEF constitutes a new major stationary source located in an area that is in attainment for all crite

IV. Emission Units The application identifies the following emission units at the MEF, each of which is described in full detail in the enclosed Application Narrative and Emissions Inventory: EU-01 — Natural Gas-Fired Process Heater. This unit consists of a natural gas-fired process heater rated at 120 MMBtu/hr heat input capacity, which will serve as the primary heat source for the soybean solvent extraction and des

V. Aggregate Potential-to-Emit Summary Based on the detailed emissions calculations set forth in the enclosed Emissions Inventory, the facility-wide potential to emit ("PTE") for criteria pollutants and greenhouse gases is summarized as follows: PSD review is triggered for the MEF because the facility's NOx PTE of 312 tpy exceeds the 250 tpy major-source threshold applicable to source categories not specifically list

VI. Enclosed Application Materials The following materials are enclosed with this transmittal and collectively constitute GAP's PSD Construction Permit application:

1. Application Narrative. This document, drafted by Calderwood & Harkness LLP in coordination with the applicant and its technical consultants, provides a comprehensive description of the proposed facility, all emission units and associated processes, the regulatory basis for PSD applicability, summaries of the BACT analysis for each applicable pollutant, a description of the air dispersion modeling protocol and resu

2. Top-Down BACT Analysis. The enclosed BACT analysis follows the EPA's established top-down methodology and addresses each pollutant subject to BACT review — specifically NOx, PM₁₀, PM₂.₅, and CO₂e. The analysis includes a thorough review of the EPA's RACT/BACT/LAER Clearinghouse database and comparable recent PSD permits issued for soybean processing and agricultural processing facilities nationwide. The proposed B

3. AERMOD Air Dispersion Modeling Report. The enclosed modeling report presents the results of air dispersion modeling performed using AERMOD Version 23.1, the EPA-preferred regulatory model for PSD ambient air quality analyses. The modeling utilized a five-year meteorological dataset covering the period 2018 through 2022, obtained from the Muscatine Municipal Airport surface station (station identifier KMUT) and pai

4. Emissions Inventory. The enclosed emissions inventory provides detailed emission calculations for each emission unit (EU-01 through EU-06), including all applicable emission factors, assumed operating hours and capacity utilization rates, throughput assumptions, and resulting annual and short-term emission rates for all criteria pollutants, hazardous air pollutants, and greenhouse gases. Emission factors are sourc

5. Process Flow Diagrams. Enclosed are process flow diagrams prepared by Ridgeline Engineering Group LLC depicting the complete process sequence for (a) soybean receiving, cleaning, and preparation; (b) soybean crushing and solvent extraction; (c) meal desolventizing, toasting, drying, and cooling; (d) crude oil degumming and storage; (e) fertilizer blending, granulation, drying, and screening; and (f) finished produ

6. Exhibit A — Muscatine County Conditional Use Permit No. MC-2022-041. A certified copy of CUP No. MC-2022-041 as approved by the Muscatine County Board of Supervisors on November 15, 2022, authorizing soybean processing and fertilizer blending operations at the subject parcel.

7. Application Filing Fee. Enclosed is a check in the amount of $7,500 payable to the Iowa Department of Natural Resources, representing the PSD Construction Permit application filing fee as required under Iowa Administrative Code 567—30.5.

VII. Technical Appendices — Pinnacle Environmental Consultants Inc. The technical appendices supporting this application — including the complete emissions inventory, AERMOD modeling files and report, and top-down BACT analysis — were prepared by Pinnacle Environmental Consultants Inc. ("Pinnacle"), located at 1120 Ingersoll Avenue, Suite 210, Des Moines, Iowa 50309. Pinnacle's work was performed under the direction

VIII. Applicant Contact Information Questions regarding the substance of this application or requests for additional information may be directed to the undersigned at Calderwood & Harkness LLP. In addition, the following representatives of the applicant are authorized to discuss the application and respond to inquiries from IDNR: Patricia Caldwell General Counsel & Vice President of Regulatory Affairs Greenfield Agri

IX. Request for Timely Processing and Completeness Determination GAP respectfully requests that IDNR process this PSD Construction Permit application on an expedited basis, consistent with all applicable regulatory timelines set forth in Iowa Administrative Code 567—Chapter 33 and EPA guidance regarding PSD application processing. GAP understands that IDNR will conduct a completeness review of the application within

1. PSD Construction Permit Application Narrative

2. Top-Down BACT Analysis (NOx, PM₁₀, PM₂.₅, CO₂e)

3. AERMOD Air Dispersion Modeling Report (Version 23.1)

4. Emissions Inventory (EU-01 through EU-06)

5. Process Flow Diagrams (Ridgeline Engineering Group LLC)

6. Exhibit A — Muscatine County Conditional Use Permit No. MC-2022-041 (approved November 15, 2022)

7. Check No. 040817 in the amount of $7,500 (Application Filing Fee — payable to Iowa Department of Natural Resources) cc: Patricia Caldwell, General Counsel & VP of Regulatory Affairs, Greenfield Agricultural Partners LLC Derek Yun, Director of Environmental, Health & Safety, Greenfield Agricultural Partners LLC Margaret Solberg, VP of Operations / Muscatine Project Lead, Greenfield Agricultural Partners LLC James P