CALDERWOOD & HARKNESS LLP Attorneys at Law 801 Grand Avenue, Suite 4400 Des Moines, Iowa 50309 Telephone: (515) 244-7800 Facsimile: (515) 244-7801 www.calderwoodharkness.com
April 28, 2023
VIA HAND DELIVERY AND ELECTRONIC MAIL
Jonathan Kreske, P.E. Environmental Engineer Air Quality Bureau Iowa Department of Natural Resources 502 East 9th Street Des Moines, Iowa 50319
Re: Prevention of Significant Deterioration (PSD) Construction Permit Application — Muscatine Expansion Facility Applicant: Greenfield Agricultural Partners LLC Site: 14800 Highway 61 North, Muscatine, Iowa 52761 Muscatine County Parcel ID: 0735-19-200-004
Dear Mr. Kreske:
This firm represents Greenfield Agricultural Partners LLC ("GAP"), an Iowa limited liability company organized and existing under the laws of the State of Iowa (Iowa Secretary of State Filing No. 548213; Employer Identification Number 46-3827194), with its principal offices located at 4200 Prairie Wind Drive, Suite 300, West Des Moines, Iowa 50266. We submit this letter and the accompanying materials on behalf of GAP to transmit GAP's application for a Prevention of Significant Deterioration ("PSD") Construction Permit pursuant to Iowa Administrative Code 567—Chapter 33 and the corresponding provisions of the federal Clean Air Act, 42 U.S.C. §§ 7470–7492. This submission is assigned Calderwood & Harkness LLP Matter Number 1020-00004.
The application pertains to GAP's proposed Muscatine Expansion Facility (the "MEF"), a new greenfield soybean processing and specialty fertilizer blending facility to be constructed on an approximately 147-acre site located at 14800 Highway 61 North, Muscatine, Iowa 52761, in Muscatine County, Iowa. As set forth in detail below and in the enclosed application materials, the MEF will constitute a new major stationary source subject to PSD preconstruction review. GAP respectfully submits this application and requests that the Iowa Department of Natural Resources ("IDNR") Air Quality Bureau undertake its completeness review and processing of the application in a timely manner consistent with applicable regulatory requirements.
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 approximately 450 tons per day, encompassing fertilizer receiving, granulation, drying, cooling, screening, and loadout. The MEF will operate on a continuous basis, with the soybean processing line designed for year-round operation and the fertilizer blending line operating on a seasonal basis driven by regional agricultural demand cycles.
The 147-acre parcel on which the MEF will be sited was acquired by GAP from the Reinholt Family Trust pursuant to a Purchase and Sale Agreement dated October 3, 2022, with closing occurring on January 20, 2023. The purchase price for the parcel was $3,820,000. The parcel is identified in the Muscatine County Assessor records as Parcel ID 0735-19-200-004 and is located on the east side of Highway 61 North, approximately 4.5 miles north of the City of Muscatine corporate limits.
The facility and civil engineering design for the MEF is being performed by Ridgeline Engineering Group LLC, headquartered in Lincoln, Nebraska, under the direction of Thomas Novak, P.E., who serves as Project Manager. Ridgeline's scope of work encompasses site civil engineering, process piping and instrumentation design, structural engineering, and stormwater management planning. The total estimated project capital cost for construction of the MEF, inclusive of all process equipment, supporting infrastructure, site preparation, and engineering costs, is approximately $178 million. GAP anticipates that construction will proceed in a single phase, with site preparation activities commencing promptly following issuance of the PSD Construction Permit and all other required authorizations.
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 Conditional Use Permit by the Muscatine County Board of Supervisors.
On November 15, 2022, following public notice and a duly noticed public hearing, the Muscatine County Board of Supervisors approved Conditional Use Permit No. MC-2022-041, authorizing the construction and operation of soybean processing and fertilizer blending operations on the subject parcel, subject to conditions set forth therein relating to setback compliance, stormwater management, transportation access, and hours of construction activity. The approval was adopted by a vote of 3-0, with no appeals having been filed within the applicable statutory appeal period. A complete copy of CUP No. MC-2022-041 is included as Exhibit A to the enclosed application materials.
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 criteria pollutants, PSD preconstruction review under 42 U.S.C. §§ 7470–7492 and Iowa Administrative Code 567—33.3 is applicable to the proposed source for each pollutant for which the facility's potential to emit exceeds the applicable significance threshold.
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 desolventizing process. The heater will be equipped with low-NOx burners and flue gas recirculation as described in the enclosed BACT analysis.
EU-02 — Soybean Dryer. This unit consists of a natural gas-fired soybean meal dryer rated at 80 MMBtu/hr heat input capacity, used to reduce the moisture content of the processed soybean meal to specifications suitable for storage and transport. The dryer will likewise be equipped with low-NOx burners and flue gas recirculation.
EU-03 — Fertilizer Granulation Dryer. This unit consists of a natural gas-fired rotary dryer rated at 60 MMBtu/hr heat input capacity, dedicated to the drying and conditioning of granulated fertilizer products on the fertilizer blending line.
EU-04 — Material Handling and Storage. This group of emission points encompasses all grain elevators, belt conveyors, bucket elevators, transfer points, storage bins, and fertilizer loadout operations associated with soybean receiving, in-process transfer, and finished product handling. Fugitive and point-source particulate matter emissions from these operations will be controlled by enclosed conveying systems and baghouse dust collectors.
EU-05 — Emergency Diesel Generator. This unit consists of a diesel-fired emergency generator rated at 2,000 kW, intended solely for emergency standby power and required testing. The generator will be subject to an operational limit of 500 hours per year, consistent with the limitations applicable to emergency engines under 40 C.F.R. Part 63, Subpart ZZZZ, and the corresponding provisions of 40 C.F.R. Part 60, Subpart IIII.
EU-06 — Cooling Towers. This emission unit comprises two mechanical-draft cooling tower cells with a combined circulation rate of 18,000 gallons per minute ("gpm"), providing process cooling water for the soybean extraction and fertilizer granulation operations. Drift eliminators will be installed to minimize particulate matter emissions from cooling tower drift.
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 listed under Section 169(1) of the Clean Air Act. Because the MEF is an unnamed source category, the 250 tpy threshold applies. In addition, because the MEF triggers PSD review for a non-GHG pollutant (i.e., NOx), the facility qualifies as an "anyway" source for purposes of greenhouse gas PSD applicability. The facility's GHG PTE of 148,600 tpy CO₂e exceeds the 75,000 tpy CO₂e significance threshold applicable to sources that are already subject to PSD review for another regulated pollutant.
Accordingly, a Best Available Control Technology ("BACT") analysis is required for each pollutant for which the facility's emissions exceed the applicable PSD significance levels. As reflected in the enclosed BACT analysis, BACT review has been performed for NOx, PM₁₀, PM₂.₅, and CO₂e.
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 results, and a discussion of the facility's compliance with all applicable NAAQS and PSD increment standards.
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 BACT determinations include the following principal control measures:
•  Low-NOx burners with flue gas recirculation on EU-01 (process heater) and EU-02 (soybean dryer), with a proposed NOx emission limit of 0.036 lb/MMBtu, consistent with the most stringent recent BACT determinations for similar natural gas-fired combustion units in the agricultural processing sector.
•  Baghouse dust collectors on EU-04 grain handling operations, achieving a particulate matter outlet concentration of 0.005 grains per dry standard cubic foot ("gr/dscf") and a control efficiency of 99.5%, representing the top-performing control option for fugitive and point-source particulate matter from grain and material handling operations.
•  High-efficiency drift eliminators on EU-06 cooling towers, achieving a drift rate of 0.0005% of the circulating water flow rate, consistent with the best-performing drift elimination technology currently available for mechanical-draft cooling towers.
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 paired with upper-air data from the Davenport, Iowa, National Weather Service station. The receptor grid was established at 50-meter spacing extending to a distance of 5 kilometers from the facility boundary in all directions, with refined receptor grids placed at property boundaries and the locations of nearby sensitive receptors. The nearest sensitive receptor — an occupied residence — is located approximately 0.42 miles (2,218 feet) east-northeast of the proposed primary stack location.
The modeling results demonstrate compliance with all applicable NAAQS and PSD increment consumption limits. By way of example, the maximum modeled 24-hour PM₁₀ impact attributable to the MEF was determined to be 38.2 µg/m³. When combined with the representative background concentration of 72 µg/m³ (as determined from IDNR ambient monitoring data), the total combined impact is 110.2 µg/m³, which is well below the 24-hour PM₁₀ NAAQS of 150 µg/m³. Complete modeling input files, meteorological data files, and results summaries are provided in the modeling report appendices.
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 sourced from AP-42, manufacturer performance guarantee data, and stack test results from comparable facilities, as identified in the inventory documentation.
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 product storage, material handling, and loadout operations. These diagrams identify each emission point and the associated air pollution control equipment.
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 of Dr. Leonard Fisk, P.E., Principal of Pinnacle's Air Quality Practice. Dr. Fisk is a registered Professional Engineer in the State of Iowa with over twenty-five years of experience in air quality permitting and air dispersion modeling for industrial facilities throughout the Midwest.
Calderwood & Harkness LLP coordinated closely with Pinnacle and with GAP's internal environmental staff throughout the application preparation process to ensure consistency, accuracy, and regulatory compliance across all application components. However, Calderwood & Harkness LLP did not direct Pinnacle's engineering calculations, modeling methodology selections, or other technical work product. Pinnacle is solely responsible for the technical accuracy of its work, and Dr. Fisk has certified the technical components of the application under his professional engineering seal.
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 Agricultural Partners LLC 4200 Prairie Wind Drive, Suite 300 West Des Moines, Iowa 50266 Telephone: (515) 223-4100
Email: pcaldwell@greenfieldagpartners.com
Derek Yun Director of Environmental, Health & Safety Greenfield Agricultural Partners LLC 4200 Prairie Wind Drive, Suite 300 West Des Moines, Iowa 50266 Telephone: (515) 223-4118
Email: dyun@greenfieldagpartners.com
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 thirty days of receipt. GAP is prepared to respond promptly and thoroughly to any completeness questions, deficiency notices, or requests for additional information that IDNR may issue during its review.
GAP wishes to bring to IDNR's attention that the applicant is pursuing the construction of the MEF on an aggressive development schedule driven by contractual commitments with downstream purchasers and commodity supply agreements that contemplate facility commissioning by the fourth quarter of 2025. Timely issuance of the PSD Construction Permit is critical to maintaining this schedule. GAP and its counsel are available and committed to working cooperatively with the Air Quality Bureau to facilitate an efficient and thorough review process.
We thank you and the Air Quality Bureau staff for your attention to this application. We are available at your convenience to discuss any aspect of the submission, to arrange a pre-application meeting if IDNR deems one beneficial, or to provide any supplemental information that may assist in the Bureau's review. Please do not hesitate to contact me directly at the telephone number or email address listed below.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Rafael Dominguez Lead Associate Environmental & Natural Resources Practice Group Calderwood & Harkness LLP 801 Grand Avenue, Suite 4400 Des Moines, Iowa 50309 Telephone: (515) 244-7836
Email: rdominguez@calderwoodharkness.com
Enclosures:
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 Prentice, Responsible Partner, Calderwood & Harkness LLP Dr. Leonard Fisk, P.E., Principal, Pinnacle Environmental Consultants Inc. Thomas Novak, P.E., Project Manager, Ridgeline Engineering Group LLC
Pollutant | Potential to Emit (tons per year)
Nitrogen Oxides (NOx) | 312
Sulfur Dioxide (SO₂) | 28
Particulate Matter (PM₁₀) | 196
Fine Particulate Matter (PM₂.₅) | 87
Carbon Monoxide (CO) | 245
Volatile Organic Compounds (VOC) | 164
Greenhouse Gases (CO₂e) | 148,600