Contract analysis

I. Introduction Calderwood & Harkness LLP represents Greenfield Agricultural Partners LLC ("GAP") in connection with the above-referenced Prevention of Significant Deterioration ("PSD") Construction Permit application filed with the Iowa Department of Natural Resources ("IDNR") Air Quality Bureau ("AQB") on April 28, 2023, pursuant to Iowa Administrative Code 567—Chapter 33. The application seeks authorization for th

II. Response to Comment No. 1: AERMOD Receptor Grid Spacing and Configuration A. Summary of IDNR Comment In its completeness review comments, AQB requested additional detail regarding the receptor grid configuration used in the AERMOD air dispersion modeling analysis submitted as Appendix C to the PSD application. Specifically, AQB asked GAP to confirm and document: (i) the receptor grid spacing intervals from the fa

III. Response to Comment No. 2: Startup and Shutdown Emission Estimates for EU-01 and EU-02 A. Summary of IDNR Comment AQB's second completeness review comment requested clarification of the emission estimates for EU-01, the natural gas-fired process heater rated at 120 MMBtu/hr heat input capacity, and EU-02, the soybean dryer rated at 80 MMBtu/hr heat input capacity and also fired on natural gas. Specifically, AQB

IV. Response to Comment No. 3: Baghouse Filter PM Outlet Specification for EU-04 A. Summary of IDNR Comment AQB's third completeness review comment requested supplemental documentation supporting the proposed particulate matter ("PM") outlet concentration specification of 0.005 grains per dry standard cubic foot ("gr/dscf") for the baghouse filters controlling emissions from EU-04. Emission unit EU-04 encompasses mat

V. Enclosures and Attachments Summary For AQB's convenience, GAP provides the following summary of all supplemental materials enclosed with this response: Attachment A — Supplemental Receptor Grid Map. AERMOD receptor grid configuration map showing the 50-meter Cartesian receptor grid extending to 5 kilometers from the facility fenceline, the 25-meter nested receptor grid within 500 meters of the fenceline, and discr

VI. Request for Completeness Determination Based on the foregoing responses and the enclosed supplemental materials, GAP respectfully requests that AQB review the submissions and issue a completeness determination for the PSD Construction Permit application at its earliest convenience. GAP understands, based on prior communications with AQB, that the completeness determination is anticipated by May 19, 2023, and GAP

VII. Availability and Contact Information GAP and its counsel remain available to discuss these responses or provide any additional information at AQB's request. To facilitate efficient communication, GAP respectfully directs the following categories of inquiries to the appropriate points of contact: Technical Questions regarding AERMOD air dispersion modeling, emissions calculations, startup/shutdown emission estima

VIII. Closing We appreciate AQB's prompt review of the PSD application and the thoroughness of the completeness review comments. GAP looks forward to the completeness determination and to continuing to work cooperatively with AQB throughout the permitting process for the Muscatine Expansion Facility. Please do not hesitate to contact us if you have any questions regarding these responses or the enclosed supplemental