Contract analysis

Section 1: Introduction and Purpose 1.1 Purpose of Application Greenfield Agricultural Partners LLC ("GAP" or the "Applicant") hereby submits this application to the Iowa Department of Natural Resources ("IDNR"), Air Quality Bureau, for a Prevention of Significant Deterioration ("PSD") Construction Permit authorizing the construction and operation of the Muscatine Expansion Facility (the "MEF" or the "Facility"), a n

Section 2: Facility and Site Description 2.1 Project Overview The following provides a summary overview of the proposed project: Project Name: Muscatine Expansion Facility ("MEF") Facility Type: Soybean processing and specialty fertilizer blending Design Capacity: The MEF is designed with a soybean crush capacity of 3,200 tons per day and a granular fertilizer blending line capable of processing 450 tons per day. Nat

Section 3: Attainment Status and PSD Applicability 3.1 Area Attainment Designation Muscatine County, Iowa is currently designated as being in attainment (or unclassifiable/attainment) for all National Ambient Air Quality Standards ("NAAQS") established for criteria pollutants under the Clean Air Act ("CAA"), including ozone (O₃), particulate matter (PM₁₀ and PM₂.₅), carbon monoxide (CO), nitrogen dioxide (NO₂), sulfu

Section 4: Emission Units and Emissions Inventory 4.1 Overview of Emission Units The MEF will include six emission units, designated EU-01 through EU-06. These emission units encompass all stationary sources of air pollutant emissions at the facility, including combustion sources, material handling and storage operations, an emergency generator, and cooling tower systems. Emissions from each emission unit have been c

Section 5: Best Available Control Technology (BACT) Analysis 5.1 BACT Methodology

Section 165(a)(4) of the Clean Air Act and 40 C.F.R. § 52.21(j) require that each new major source subject to PSD review apply Best Available Control Technology ("BACT") for each pollutant subject to regulation under the Act that the source would have the potential to emit in significant amounts. BACT is defined as an emission limitation based on the maximum degree of reduction for each regulated pollutant, taking in

1. Selective Catalytic Reduction ("SCR"): SCR is a post-combustion NOx control technology in which a reducing agent (typically aqueous ammonia or urea) is injected into the exhaust gas stream upstream of a catalyst bed. The reducing agent reacts with NOx in the presence of the catalyst to form nitrogen (N₂) and water (H₂O). SCR systems are capable of achieving NOx reduction efficiencies of 80–90 percent or greater wh

2. Low-NOx Burners with Flue Gas Recirculation ("LNB+FGR"): Low-NOx burners are designed to reduce the formation of thermal NOx by staging the combustion process, controlling the mixing of fuel and air, and reducing peak flame temperatures. Flue gas recirculation supplements the LNB technology by redirecting a portion of the cooled flue gas back into the combustion zone, which further reduces peak flame temperatures

3. Low-NOx Burners Alone ("LNB"): LNB technology without FGR typically achieves NOx emission rates in the range of 0.05 to 0.10 lb/MMBtu for natural gas-fired units.

4. Good Combustion Practices ("GCP"): Proper air-fuel ratio management, burner tuning, and maintenance constitute the baseline level of NOx control and do not achieve NOx reductions beyond the inherent performance of conventional burner designs. All four technologies were determined to be technically feasible for application to the process heater and soybean dryer. Evaluation of SCR: Although SCR is technically feasi

1. Baghouse Filters (Pulse-Jet Type): Fabric filter baghouses using pulse-jet cleaning technology are capable of achieving outlet particulate concentrations of 0.005 gr/dscf or lower, corresponding to control efficiencies of 99 percent or greater. Pulse-jet baghouses are widely used in the grain handling and fertilizer blending industries and are commercially available from multiple equipment vendors for the types of

2. Cartridge Filters: Cartridge filter dust collectors use pleated filter media rather than conventional felt bags. Cartridge filters are capable of achieving outlet particulate concentrations comparable to pulse-jet baghouses but may be less suitable for high-dust-loading applications and grain handling environments where the risk of moisture-induced filter blinding or grain dust accumulation is elevated.

3. Cyclone Separators: Mechanical cyclone separators are effective for removing coarse particulate (typically greater than 10 microns) but have limited efficiency for fine particulate in the PM₁₀ and PM₂.₅ size fractions. Typical cyclone efficiencies for PM₁₀ range from 70 to 90 percent.

4. Wet Suppression Only: Water spray dust suppression systems reduce fugitive emissions by increasing the moisture content of the material and wetting exposed surfaces. Wet suppression alone is typically credited with 50–70 percent fugitive dust control effectiveness, depending on the application.

5. Enclosure Only: Enclosing material transfer points and conveyors reduces windborne fugitive emissions but does not capture and collect particulate from the enclosed airspace. Enclosure alone, without ventilation and filtration, is the least effective control option. All five technologies were determined to be technically feasible. However, based on the step-by-step evaluation: Selection of Baghouse Filters (Pulse-

1. High-Efficiency Drift Eliminators: High-efficiency drift eliminators use multiple passes of blade or cellular media to capture entrained water droplets from the cooling tower exhaust air stream before the air exits the tower. Modern high-efficiency drift eliminators are capable of achieving drift rates of 0.0005 percent of circulating water flow, which represents the lowest drift rate achievable with commercially

2. Standard Drift Eliminators: Conventional or standard drift eliminators typically achieve drift rates in the range of 0.001 to 0.005 percent of circulating water flow. Both technologies are technically feasible and are standard features of modern cooling tower systems. High-efficiency drift eliminators are commercially available from all major cooling tower manufacturers and add minimal incremental cost relative to

1. Carbon Capture and Storage/Sequestration ("CCS"): CCS involves the capture of CO₂ from the exhaust gas stream (using amine scrubbing, membrane separation, or other technologies), followed by compression, transportation, and permanent geological sequestration of the captured CO₂.

2. Combined Heat and Power ("CHP"): CHP (also known as cogeneration) involves the integrated generation of electricity and useful thermal energy from a single fuel source, achieving higher overall energy efficiency than separate generation of heat and power.

3. Process Energy Efficiency Measures and Good Combustion Practices: These include the use of the lowest-carbon fuel available, high-efficiency burners and combustion controls, waste heat recovery, variable-frequency drives on motors and fans, building insulation, and process optimization to minimize overall energy consumption and associated GHG emissions. Evaluation of CCS: Carbon capture and storage was evaluated a