AQ_F_1000054_20210312_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Archer Daniels Midland Company
NC Facility ID 1000054
Inspection Report County/FIPS: Brunswick/019
Date: 03/12/2021
Facility Data Permit Data
Archer Daniels Midland Company Permit 02502/T27
1730 East Moore Street, SE Issued 1/4/2021
Southport,NC 28461 Expires 12/31/2023
Lit: 33d 56.3390m Long: 77d 59.5780m Class/Status Title V
SIC: 2869/Industrial Organic Chemicals,nec Permit Status Active
NAICS: 325199/All Other Basic Organic Chemical Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/PSD
Jim Atack Ryan Howard Jim Atack MACT Part 63: Subpart ZZZZ
Environmental Engineer Plant Manager Environmental Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/24/2021
Inspector's Name Jmanda Dunston
Inspector's Signature: Operating Status Operating
UUU Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: Z/Z� Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 *HAP
2019 21.23 0.1100 4.75 0.3300 2.79 5.28 110.69
2018 22.09 2.96 11.96 0.3100 4.08 5.16 100.35
2017 23.41 0.5200 5.92 1.81 3.09 6.26 897.82
* Highest HAP Emitted inpounds)
Five Year Violation History: None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
Full Compliance Inspection 2/24/2021

ADM Full Compliance Inspection
2/24/2021
Page 2 of 30
1. Directions: From Wilmington, take Highway US-74/76 West. Take the US-17S exit toward
Myrtle Beach and travel to the NC 87S Exit (exit is to your left —12 miles from Leland side of
the Cape Fear river). Follow Highway NC 87S toward Southport (14.8 miles). Make a left onto
Rob Gandy Blvd and travel —0.8 mi to E. Leonard St. Turn left and travel —0.6 mi on E Leonard
until it dead ends, making a slight left onto E Moore St. Main plant entrance is —400 ft on your
right, just past the railroad track. Proceed another —0.4 mile and take the first right. The Main
parking lot is to your right. Enter the lot from the North side entrance, which is the entrance
furthest from the guard shack. Visitor parking spaces are to your left bordering the roadway as
you enter the lot. The Guard Shack is just past the parking lot. All visitors must sign in at the
guard shack before entering the facility.
2. SafetyEquipment: A hard hat, safety shoes, gloves, earplugs, and safety glasses are required at
this facility. Gloves are required because hand injuries were identified in the past as the leading
cause of injury and wearing them in all process areas is mandatory.
3. Inspection Details: On 2/24/21, Fmanda Dunston met with Jim Atack, Environmental Engineer
for ADM. The physical part of the inspection was conducted on site; however, the record review
was done virtually due to COVID-19. By both the physical inspection and the record review
being conducted on the same day,the inspection is seen as a full compliance inspection.
4. Site Description: ADM is a food additives processing facility. The facility sits on —480 acres of
property, of which the main process area consumes about —90 acres. It produces citric acid
(liquid and dry), sodium citrate and potassium citrate through a process consisting of bio-
fermentation, separation, evaporation and drying. The by-product sludge from the fermentation
process is currently processed and sold as a product or utilized as a fertilizer for land application.
The gypsum (CaSO4) is currently stored on ADM property just to the north of the main
processing area. Steam is purchased from Capital Power Inc. (CPI), a cogeneration facility
located on adjacent property, however, ADM is currently in the process of adding three new
boilers to the facility to be able to provide the necessary steam. ADM typically operates 24/7
year-round.
5. Facility Changes: The facility is currently in the process of adding three new boilers to the
plant. The boilers will be used to provide the steam required to operate the facility.
6. Permit: The facility is currently operating under NCDAQ Permit No. 02502T27. The current
permit became effective on January 4, 2021 and expires December 31, 2023. This permit
revision was a result of a significant permit modification to add three new boilers to the permit.
7. Process Overview: The first step of the process is called Media Prep. In this step, the
fermentation fungi are grown on a suitable media support. This class of fungi is specific to
converting dissolved sugars in the feed solution to citric acid.
In the next step, Fermentation, the media is charged to batch reactors that contain a
sterilized sugar/water solution. The sugar solution functions as a nutrient for the fungi and is
subsequently converted to citric acid (C6H807) in its digestion.
0 O OH
HOOH
Citric Acid

ADM Full Compliance Inspection
P P
2/24/2021
Page 3 of 30
The fermentation process that takes place within requires several days in ADM's largest
fermentation vessel and requires precise temperature control of the stirred tank reactor. ADM has
multiple fermentation reactors. An emergency "black start" diesel generator, EU48, provides
emergency power to start the electrical turbine generators to provide power to the plant to
maintain operation of these reactors should power outages occur.
At one time, starch was more economical to use as the carbohydrate raw material feed,
but this required processing the starch further to make it biologically available to the fungi. This
was accomplished in a section of the facility called the Starch Plant. The starch plant is currently
shut down.
A variety of nutrients have been tried over the years and ADM maintains the ability to
utilize any of them based on process and economic considerations.
The final step is Recovery, in which the citric acid product is recovered from the
fermentation "broth". First, calcium carbonate (CaCO3) is mixed with the broth in an acid/base
reaction that precipitates calcium citrate. The calcium salt of the acid is then filtered from the rest
of the neutralized broth and the broth sent to Waste Treatment.
The crude calcium citrate is then reacted with concentrated sulfuric acid which causes the
calcium to precipitate, forming gypsum (CaSO4), and leaves a citric acid/CaSO4 slurry. The
gypsum is filtered out and these solids thoroughly washed in order to maximize the recovery of
citric acid. It is then pumped to the onsite gypsum storage pile on the property to the North of the
process areas (see Appendix A).
The resulting mother liquor is then evaporated to a citric acid concentration just below its
saturation point. The solution is passed through a polishing filter to remove the last traces of
precipitated gypsum. This is done to minimize the amount of calcium that can feed forward with
the nearly saturated product stream.
The polished product liquor is then passed to a crystallizer, where citric acid is
crystallized, separated, re-dissolved, concentrated again and re-crystallized. The final crystalline
citric acid product is then separated from this finished mother liquor, dried and passed through a
product cooler before being packaged.
ADM makes both crystalline and liquid citric acid products. It can also produce sodium
citrate and potassium citrate salts as needed by reacting the citric acid solution with sodium
hydroxide or potassium hydroxide. A process to produce purified calcium citrate was installed
but was abandoned prior to production. At one time, ADM also produced Mono Sodium
Glutamate (MSG) at this facility, but this process has been abandoned as well. Part of this
process's footprint has been used for the new spray-dried animal feed product, CitriStim®.
Utilities: Both steam and power are typically purchased. CPI supplies steam to ADM through a
dedicated pipeline, however, ADM is currently in the process of adding three new boilers to the
plant to provide the necessary steam. Power is supplied by Duke Progress Energy.
The electrical power for the site's various process areas can be provided by three
permitted fuel fired single cycle turbine generators when economics dictates their use. Two
turbines are permitted to fire either natural gas or #2 fuel oil, while the third is only permitted to
fire natural gas. When firing #2 fuel oil, the permit requires the control of NOx emissions
through the use of steam injection at a steam to fuel ratio of>0.46. No steam injection is required
on either of these turbine generators while firing natural gas. Exhaust gas emissions from these
turbines are uncontrolled.

ADM Full Compliance Inspection
2/24/2021
Page 4 of 30
Waste Treatment: The filtrate from the Calcium Citrate filtration step in the Recovery process is
sent to Waste Treatment. At Waste Treatment, the solution is aerated to reduce the BOD to
within acceptable discharge limits and the solids separated in clarifying thickeners. The surge
solution from this operation is permitted to be discharged into the Cape Fear River on the
outgoing tide. The sludge from these thickeners is either land applied on local farms or spray-
dried to produce CitriStim®, a dried yeast animal feed product for sale.
8. Permit Changes: Below is a summary of the permit changes.
Summary of Changes to Permit
The following changes were made to the Archer Daniels Midland-Southport facilty, Air Permit No.02502T26:
Cover Letter Cover Letter • Used current shell language,permit numbers,dates,etc.
insignificant Same . Removed errant"*•"indicator on IEU58.This should have been removed
activities list from the renewed air permit T27 .
Permit page Same . Revised dates,permit numbers,etc.using current shell standards
one
Section 1 Same • Added three new boilers(ID Nos. EU60,EU61 and EU62)
NA Section 2.11 • Added a new section for the three new boilers. All conditions are new as
described in permit review.
NA Section 2.2 A.3 • Added a 02D.1100 toxics condition to reflect the facility-wide modeling
demonstration.Given the margin of compliance and the modeling
consisting of emissions greater than or equal to the potential emissions
from each source,no monitoring,recordkeeping or reporting is required.
Updated from version 5.3 08/21/2018 to version 5.5,08/25/2020. Changes
include:
• Condition Y—fix typographical spacing error
• Condition BB-correct regulatory reference from 02Q.0507(d)(4)to
Section 3 (d)(3)
General Same • Condition CC—correct regulatory reference from 02Q.0501(e)to(d)
Conditions
• Condition KK.I.d.—changed"ensure"to"assure"
• Condition JJ—clarified the applicable requirements for sources required
to test pursuant to.0524, .1110,and.1111.
• Condition NN—correct regulatory references from 02Q .0501(c)(2)to
(b)(2)in paragraph 1. and from 02Q.0501(d)(2)to(c)(2)in paragraph 2.
Attachment- Same . Revised substantially
List of
Acronyms
9. Insignircant Items List Below is the list of insignificant items identified in permit T27.
ATTACHMENT to Permit No.02502T27

li ce Inspection
ADM Full Compliance Insp o
2/24/2021
Page 5 of 30
Insignificant Activities per 15A NCAC 02Q .0503(8)
Emission Source Emission Source Description - -
ID No-
IEU49
GACT ZZZZ One diesel-fired emergency generator(45 kW)
G C One diesel-fired emergency generator(230 kW)
GACT ZZZZ
IEU15 One calcium carbonate slurry mix tank
IEU 16 One Epson salt mix tank
IEU30 Gypsum pile
IEU32 Paint booth(with a 9 square foot paint arrestor filter)
IEU35 and IEU36 Two Fire fighting IC engines
GACT ZZZZ
IEU37 Parts cleaner
IEU46 Activated carbon bag unloading
IEU53 Natural gas-fired low-NOx burner(7.6 million Btu per hour capacity)preheating
incoming air for spray dryer(EU54)
IT-255 Glycerin storage tank
IT-2219 Glycerin storage tank
IT-101, IT-256, IT-268,IT-434, IT435, IT-436 Sulfuric acid storage tanks
IG701,IG702, ICTMOI Cooling Towers
IT-722 Gasoline Tank
IT-711, IT-720 No.2 fuel oil storage tanks
IT-707-1,IT-707-2,IT-724 Diesel fuel storage tanks
I 1 Maintenance repair and sandblasting
IEU56 Natural gas-fired low-NOx burner(8 million Btu per hour capacity)preheating incoming
air for spray dryer(EU57)
IEU58 Natural gas-fired low-NOx burner(8 million Btu per hour capacity)preheating incoming
air for spray dryer(EU59)
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement
or that the Permittee is exempted from demonstrating compliance with any applicable requirement.
2. When applicable, emissions from stationary source activities identified above shall be included in determining
compliance with the permit requirements for toxic air pollutants under 15A NCAC 02D.1100"Control of Toxic
Air Pollutants" or 02Q.0711 "Emission Rates Requiring a Permit."
3. For additional information regarding the applicability of MACT or GACT see the DAQ page titled"Specific
Permit Conditions Regulatory Guide."The link to this site is as follows: http://deg.nc.pov/about/divisions/air-
qualit% air-quality-permits/specific-permit-conditions-re ug latorv-euide.

ADM Full Compliance Inspection
2/24/2021
Page 6 of 30
10. Permitted Sources: ADM is permitted under Permit No. 02502T27, issued 1/4/21 to operate the
following pieces of equipment and air pollution control devices:
SECTION 1- PERMITTED EMISSION SOURCE(S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE(S)AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and
appurtenances _
Page Emission Emission Source Description Control Control Dever Description
Nos Source IDNo. Dever IDNo.
Sodium CitrateOperation
5 EU1 One sodium citrate packaging CH One wet Venturi scrubber(25 to 50
operation gallons per minute liquid injection
rate
Citric Acid D ers/Coolers
7 EU2 Citric acid dryer CE2 One dynamic wet scrubber(20 to 50
gallons per minute liquid injection
rate
7 EU3,EU4 Two citric acid coolers CE3 One dynamic wet scrubber(30 to 70
gallons per minute injection rate
7 EU5 One sodium citrate dryer CE5 One wet Venturi scrubber(25 to 50
gallons per minute injection rate
Railcar U
9 EU6 Sodium carbonate railcar CE6 One bagfilter(406 square feet of
unloading filter area
9 EU47 Limestone railcar unloading N/A N/A
Filter Preeoat Preparation Tanks
I I EU7, EU8 Two filter precoat preparation CE7 and Two vent spray systems followed by
tanks CE8 HV-2 filter cells
SBas
13 EU9, EU17 Two limestone(calcium *CE9 and Two bagfilters(375 square teet of
carbonate)storage silos *CE 17 filter area each
13 EU14 One hydrated lime(calcium CE14 One bagfilter(400 square feet of
hydroxide)storage silo filter area
13 EU10,EUl l Two Filteraid(perlite)storage **CE10 Two bagfilters(375 square feet of
silos and filter area each)
**CE11
13 EU25,EU26 Two starch storage silos CE25 One bagfilter(710 square feet of
filter area
13 EU38,EU39 Two starch storage silos CE38 One bagfilter(708 square feet of
filter area
Calcium Horoxide Slurry Mixim Tang
17 EU 12 One hydrated lime(calcium CE 12 One cartridge filter dust collector
hydroxide) slu mi, tank (1,020 square feet of filter area)
Limestone Slany Mixing Tanks
15, EU 18, EU 19, Three limestone slurry mixing CE 18 One vent spray(20 to 40 gallon, per
EU20 tanks minute injection rate

ADM Full Compliance Inspection
2/24/2021
Page 7 of 30
Page Emission Emission Source Description Control Control Device Description
Nos. Source ID No. Device ID
No.
Combustion Turbines
19 EU21, E122 "fwo natural gas/No.2 fuel oil- CE21 and Steam-injection for nitrogen oxide
fired combustion turbines(240 CE22 control while firing No.2 fuel oil(no
million Btu per hour firing rate steam injection required while firing
each) natural gas), minimum steam to fuel
s: ratio of 0.46
19 EU23 One natural gas-fired N/A N/A
combustion turbine(190 million
Btu per hour firm rate
Powdered Products
20 EU27 One steam-heated fluidized bed CE27 One cyclonic wet scrubber(75 to 125
dryer(powdered products) gallons per minute liquid injection
rate
20 EU28 Powdered products packaging CE28 One multi-vane scrubber(10 to 40
gallons per minute liquid injection
rate)with a demister
20 EU40 One steam-heated fluidized bed CE40 One cyclonic wet scrubber(20 to 70
dryer(powdered products) gallons per minute liquid injection
rate
20 EU54 Spray dryer CE54 One bagfilter(2,507 square feet of
filter area
20 EU55 Dried yeast pneumatic transfer, CE55 and One bagfilter(1,024 square feet of
storage, and packaging CE55A filter area)and one check filter(150
s uare feet area
20 *EU57 Spray dryer *CE57 One bagfilter(3,525 square feet of
filter area
20 **EU59 Spray dryer **CE59 One bagfilter(3,525 square feet of
filter area
Citric Acid Fermentation System
22 EU33a,EU33b, Citric acid fermentation system CE33 and One cyclonic impingement scrubber
EU33c, CE34 and a gravity spray tower wet
EU33d, scrubber equipped with a demister
EU33e, section(0 to 1200 gallons per minute
EU33f, liquid injection rate)
EU33g,
EU33h
22 EU31 a, Citric acid fermentation system CE31 One packed bed scrubber equipped
EU3lb, with a demister section(0400
EU31 c, gallons per minute liquid
EU31 d, recirculation rate)
EU31e
Emergency Diesel Generator
22 EU48 One 1,500 hp/1000kw diesel- N/A N/A
GACT ZZZZ fired black-start enerator
Boilers
25 EU60 One natural gas/No.2 fuel oil- N/A N/A
(NSPS Dc) fired boiler(99 million Btu per
hour maximum heat input rate)
equipped with low NOx burners

ADM Full Compliance Inspection
2/24/2021
Page 8 of 30
Page Emission Emission Source Description Control Control Device Description
Nos. Source ID No. Device ID
No.
25 EU61 (NSPS One natural gas/No.2 fuel oil- N/A
Dc) fired boiler(99 million Btu per
hour maximum heat input rate)
equipped with low NOx burners
25 EU62 (NSPS One natural gas/No.2 fuel oil- N/A N/A
De) fired boiler(99 million Btu per
hour maximum heat input rate)
equipped with low NOx burners
11. Specific Limitations and Conditions: The following is a list of permit limitations and conditions
taken from Permit No. 02502T27. Some limitations and conditions have been omitted because
there are no compliance observations required. Specific observations/comments are bold and
underlined.
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1-Emission Source(s) and Control Devices(s) Specific Limitations and
Conditions
The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to
the following specific terms,conditions,and limitations,including the testing,monitoring, recordkeeping,and
reporting requirements as specified herein:
A. One sodium citrate packaging operation (ID No. EU1)with associated wet Venturi
scrubber(ID No. CE1)
I'he followin>prmides a summary of limits and/or standards for the emission sources described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D .0515
E=4.10xPo.et
For process rates greater than 30 tons per hour:
E=55.0xP°'t-40
Where: E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D.0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring/Recordkeeoing [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the sodium citrate packaging operation(ID No. EUI)shall be controlled
by the wet Venturi scrubber(ID No.CEI). To ensure compliance,the Permittee shall perform inspections
and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and
maintenance recommendations, or if there are no manufacturer's inspection and maintenance
recommendations,as a minimum,the inspection and maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork for leaks,

ADM Full Compliance Inspection
P P
2/24/2021
Page 9 of 30
H. A monthly check of the differential pressure drop and liquid flow rate;and
iii. An annual(for each 12 month period following the initial inspection)internal inspection of the
scrubber's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork and scrubber
are not inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. The date and time of each recorded action;
ii. Observations from each visual inspection;
iii. A record of the differential pressure drop and liquid flow rate from each monthly check;
iv. The results of any maintenance performed on the scrubber;and
v. Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Monthly maintenance/inspections and annual internal inspection are beine conducted and recorded
in a log as required by the permit. Records were reviewed from the date of the last inspection,
2/19/20,through ytd.The liquid infection rate and differential pressure drop are being recorded
monthly and were found to be within the acceptable permit ranges. During the walkabout,the liquid
iniection rate and differential pressure were observed to be 46.5 gym and 11 in H2O, respectively.
The last annual inspection was completed on 7/21/2020.Compliance is indicated.
Reporting[15A NCAC 02Q.0508(o]
e. The Permittee shall submit the results of any maintenance performed on the scrubber within 30 days of a
written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities given in Section
2.1 A.Lc and d above postmarked on or before January 30 of each calendar year for the preceding six-
month period between July and December and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this permit must be
clearly identified.
A semiannual summary report of monitorine,recordkeeping,and reportine activities is being
submitted on a timely basis with the required information. Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring [15A NCAC 02Q.0508(f)]
a. i. To ensure compliance,once a month the Permittee shall observe the emission points of this source(ID
No.EUI)for any visible emissions above normal.The monthly observation must be made for each
month of the calendar year period to ensure compliance with this requirement. If visible emissions
from this source are observed to be above normal,the Permittee shall either:
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610(Method 9)for 12 minutes is below the limit given in
Section 2.1 A.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if.
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;or
(C) the monthly observations are not conducted per c.i above.
Opacity was seen to be essentially"zero" as observed during the walkabout inspection of the facility.
Compliance is indicated.

ADM Full Compliance Inspection
2/24/2021
Page 10 of 30
Recordkeeping [15A NCAC 02Q.0508(f)]
d. i. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site
and made available to an authorized representative upon request. The logbook shall record the
following:
(A)the date and time of each recorded action;
(B)the results of each observation and/or test noting those sources with emissions that were observed
to be in noncompliance along with any corrective actions taken to reduce visible emissions;and
(C)the results of any corrective actions performed.
ii. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not
maintained per d.i. above.
Monthly VEs are beine observed and recorded in a log as required by the permit. Observations were
checked back to the date of the previous inspection,2/19/2020,through vtd.The opacity is beine
recorded monthly and found to be within acceptable permit ranges.Compliance is indicated.
Reporting [15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section 2.1 A.2.c and d above postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December and July 30 of each calendar year for the preceding six-
month period between January and June. All instances of deviations from the requirements of this permit
must be clearly identified.
A semiannual summary report of monitoring, recordkeeping,and reporting activities is beine
submitted on a timely basis with the required information.Compliance is indicated.
B. Citric acid dryers/sodium citrate dryers/coolers including:
• One citric acid dryer(ID No. EU2)with associated dynamic wet scrubber(ID No.
CE2)
• Two citric acid coolers (ID Nos. EU3 and EU4)with associated dynamic wet
scrubber(ID No. CE3)
• One sodium citrate dryer(ID Nos. EU5) with associated dynamic wet Venturi
scrubber(ID No. CE5)
The citric acid dryers(EU2 & EU5),citric acid cooler(EU3)and dynamic wet scrubbers(CE2.CE3,&
CE5)were operating at the time of the inspection.
The following provides a summary of limits and/or standards for the emission source(s)described above.
Regulated Pollutant LimitwNtandards Applicable Regulation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D .0515
E=4.10xP0-"
For process rates greater than 30 tons per hour:
E=55.0xP°"-40
Where: E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D .0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring[15A NCAC 02Q.0508(f)]
c. Particulate matter emissions from these sources shall be controlled as follows:

ADM Full Compliance Inspection
2/24/2021
Page 11 of 30
i. The citric acid dryer(ID No. EU2)shall be controlled by the dynamic wet scrubber with a liquid
injection rate of 20 to 50 gallons per minute(ID No.CE2).
ii. The two civic acid coolers(ID Nos. EU3 and EU4)shall be controlled by the dynamic wet scrubber
with a liquid injection rate of 30 to 70 gallons per minute(ID No.CE3).
iii. The sodium citrate dryer(ID No. EU5)shall be controlled by the dynamic wet Venturi scrubber with a
liquid injection rate of 20 to 50 gallons per minute(ID No.CE5).
d. To assure compliance,the Permittee shall perform inspections and maintenance of each affected control
device as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance
recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a
minimum,the inspection and maintenance requirements shall include the following:
(A)a monthly visual inspection of the system ductwork for leaks,
(B)a monthly check of the differential pressure drop and liquid flow rate;and
(C)an annual(for each 12 month period following the initial inspection) internal inspection of the
scrubbers' structural integrity.
ii. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork and
scrubbers are not inspected and maintained.
Recordkeepin¢[15 NCAC 02Q.0508(f)]
e. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request.The logbook shall record the
following:
i.the date and time of each recorded action;
ii. the results of each inspection;
iii. a record of the differential pressure drop and liquid flow rate from each monthly check;
iv.the results of any maintenance performed on any scrubber; and
v. any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if these records are not
maintained per d.i. above.
Monthly maintenance/inspections and annual internal inspection are being conducted and recorded
in a loe as required by the permit. Records were reviewed from the date of the last inspection,
2/19/20,through ytd.The liquid infection rate and differential pressure drop are being recorded
monthly and were found to be within the acceptable permit ranges.Durine the walkabout,the liquid
infection rate and differential pressure were observed. CE2's flow rate and differential pressure drop
were 44.7 spin and 0.5 in H2O.respectively. CE3's flow rate was between 35-37 gm and differential
pressure drop was 1.75 in H2O.CE5's flow rate and differential pressure drop were 45.1 epm and
11.5 in H2O,respectively.Annual inspections were last completed on 7/21/2020 for CE2&CE3 and
1/13/2021 for CES.Compliance is indicated.
Reporting [15A NCAC 02Q.0508(f)]
f. The Permittee shall submit the results of any maintenance performed on the scrubbers within 30 days of a
written request by the DAQ.
g. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on
or before January 30 of each calendar year for the preceding six-month period between July and December
and July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
A semiannual summary report of monitorine,recordkeepins,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring [15A NCAC 02Q.0508(f)]
c. i. To ensure compliance,once a month the Permittee shall observe the emission points of these sources
(ID Nos. EU2,EU3,EU4,and EU5)for any visible emissions above normal. The monthly
observation must be made for each month of the calendar year period to ensure compliance with this

ADM Full Compliance Inspection
2/24/2021
Page 12 of 30
requirement. If visible emissions from these sources are observed to be above normal,the Permittee
shall either:
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610(Method 9)for 12 minutes is below the limit given in
Section 2.1 B.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521 if.
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;
(C) the monthly observations are not conducted per c.i above.
Opacity was seen to be essentially"zero"as observed during the walkabout inspection of the facility.
Compliance is indicated.
Recordkeeping[15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not
maintained.
Monthly VEs are being observed and recorded in a log as required by the permit.Observations were
checked back to the date of the previous inspection,2/19/2020,through vtd.The opacity is being
recorded monthly and found to be within the acceptable permit ranges. Compliance is indicated.
Reporting [15A NCAC 02Q .0508(t)]
e. The Permittee shall submit the results of any maintenance performed on any scrubber within 30 days of a
written request by the DAQ.
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 B.1.c and d above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring,recordkeeping,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
C. Railcar unloading operations including:
• Sodium carbonate railcar unloading(ID No. EU6)with associated bagfilter(ID No.
CE6)
• Limestone railcar unloading (ID No. EU47)
The following provides a summary of limits and/or standards for the emission source s)described above.
Regubted Pollutant Uni twNtandards Applicable Regnlation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D .0515
E=4.1OxP061
For process rates greater than 30 tons per hour:

ADM Full Compliance Inspection
2/24/2021
Page 13 of 30
E=55.0 x P 1-"-40
Where: E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D .0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring[15A NCAC 02Q.0508(f)]
c. Particulate matter emissions from sodium carbonate railcar unloading(ID No. EU6)shall be controlled by
the bagfilter(ID No.CE6).To ensure compliance, the Permittee shall perform inspections and
maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and
maintenance recommendations, or if there are no manufacturer's inspection and maintenance
recommendations,as a minimum,the inspection and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;and
ii. an annual(for each 12-month period following the initial inspection)internal inspection of the
bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork and
bagfilters are not inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed on any control device;and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Monthly visual inspections are being completed. All monthly recorded pressure drop across the
control device were within permitted conditions. The last annual inspection was completed on
6/9/2020.Compliance is indicated.
Reporting [15A NCAC 02Q.0508(f)]
e. The Permittee shall submit the results of any maintenance performed on any control device within 30 days
of a written request by the DAQ.
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 C.Lc and d above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring,recordkeepine,and reporting activities are being
submitted on a timely basis with the required information.Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring[15A NCAC 02Q .0508(f)]
c. i. To ensure compliance,once a month the Permittee shall observe the emission points of these railcar
unloading sources(ID Nos. EU6 and EU47)for any visible emissions above normal. The monthly
observation must be made for each month of the calendar year period to ensure compliance with this
requirement. If visible emissions from these sources are observed to be above normal, the Permittee
shall either:

ADM Full Compliance Inspection
2/24/2021
Page 14 of 30
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D.2610(Method 9)for 12 minutes is below the limit given in
Section 2.1 C.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521 if:
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;or
(C) the monthly observations are not conducted per c.i above.
Recordkeeping [15A NCAC 02Q.0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be
in noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Monthly VEs are being observed and recorded in a log as required by the permit.Observations were
checked back to the date of the previous inspection.2/19/2020,through ytd.The opacity is being
recorded monthly and found to be within acceptable permit ranges.Compliance is indicated.
Reporting[I 5A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Sections 2.1 C.2.c and d above postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December and July 30 of each calendar year for the preceding six-
month period between January and June. All instances of deviations from the requirements of this permit
must be clearly identified.
A semiannual summary report of monitoring, recordkeeping,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
D. Two filter pre-coat preparation tanks (ID Nos. EU7 and EU8)with associated vent
spray systems followed by 20" x 21" x 2" HV-2 filter cells (ID Nos. CE7 and CE8)
The Following provides a summary of limits and/or standards for the emission source(s)described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D .0515
E=4.1OxPo.a1
For process rates greater than 30 tons per hour:
E=55.OxPIa'-40
Where: E=allowable emission rate in pounds per how,and
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D .0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring [15A NCAC 02Q .0508(f)]

ADM Full Compliance Inspection
2/24/2021
Page 15 of 30
c. Particulate matter emissions from the two filter pre-coat preparation tanks(ID Nos. EU7 and EU8)shall be
controlled by the vent spray systems followed by filter cells(ID Nos. CE7 and CE8). To assure
compliance,the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if there
are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and
maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;and
ii. an annual(for each 12-month period following the initial inspection)internal inspection of the filter
cells' structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork and filter
cells are not inspected and maintained.
Recordkeepine [15A NCAC 02Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the vent spray systems and filter cells;and
iv. Any variance from manufacturer's recommendations,if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Monthly visual inspections are being completed as required by the permit.Records were reviewed
from the date of the previous inspection,2/19/2020,through vtd.The internal inspections for CE7&
CE8 were completed on 3/11/20. Compliance is indicated.
Reporting[15A NCAC 02Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the vent spray systems and filter
cells within 30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Sections(s)2.1 D.Lc and d above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitorine, recordkeepine,and reporting activities are being
submitted on a timely basis with the required information.Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring [15A NCAC 02Q .0508(f)]
c. i. To ensure compliance,once a month the Permittee shall observe the emission points of the filter
precoat preparation tanks(ID Nos. EU7 and EU8)for any visible emissions above normal. The
monthly observation must be made for each month of the calendar year period to ensure compliance
with this requirement. If visible emissions from this/these source(s)are observed to be above normal,
the Permittee shall either:
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610(Method 9)for 12 minutes is below the limit given in
Section 2.1 D.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if:
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;or

ADM Full Compliance Inspection
2/24/2021
Page 16 of 30
(C) the monthly observations are not conducted per c.i above.
Opacity was seen to be essentially"zero'as observed during the walkabout inspection of the facility.
Compliance is indicated.
Recordkeeping [15A NCAC 02Q.0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Monthly VEs are being observed and recorded in a log as required by the permit.Observations were
checked back to the date of the previous inspections. 2/19/2020, through vtd. The opacity is being
recorded monthly and found to be within the acceptable permit ranges. Compliance is indicated.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s) 2.1 D.2.c and d above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring, recordkeeping,and reporting activities are being
submitted on a timely basis with the required information.Compliance is indicated.
E. Storage silos including:
• Two limestone (calcium carbonate) storage silos (ID Nos. EU9 and EU17) and one
hydrated lime (calcium hydroxide) storage tank(ID No. EU14)with three associated
bagfilters (ID Nos. CE9, CE17, and CE14).
• Two Filteraid (perlite) storage silos (ID Nos. EU10 and EUll) with two associated
bagfilters (ID Nos. CE10 and CE11)
• Two starch storage silos (ID Nos. EU25 and EU26) with one associated bagfilter (ID
No. CE25)
• Two starch storage silos (ID Nos. EU38 and EU39) with one associated bagfilter (ID
No. CE38)
The starch silos (EU25, EU26, EU38. & EU39), hydrated lime (calcium hydroxide) storage tank (EU14)
and bagfilters(CE14,CE25,CE38)are not in service.
The iulk,��ing,provides a summary of limits and/or standards for the emission source(s)described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D.0515
E=4.10xP1-11
For process rates greater than 30 tons per hour:
E=55.0xP°0-40
Where: E=allowable emission rate in pounds per hour,and

ADM Full Compliance Inspection
2/24/2021
Page 17 of 30
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D .0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring[15A NCAC 02Q.0508(f)]
c. Particulate matter emissions from the affected sources shall be controlled as follows:
i. The two limestone storage silos(ID Nos. EU9 and EU17)and the one hydrated lime storage tank(11)
No.EU14)shall be controlled by bagfilters (ID Nos. CE9,CE17,and CE14, respectively).
ii. The two Filteraid(perlite)storage silos(ID Nos. EU10 and EUl1)shall be controlled by bagfilters
(ID Nos.CE10 and CEI1, respectively).
iii. The two starch storage silos(ID Nos. EU25 and EU26)shall be controlled by a bagfilter(ID No.
CE25).
iv. The two starch storage silos(ID Nos. EU38 and EU39)shall be controlled by a bagfilter(ID No.
CE38).
b. To assure compliance,the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if there
are no manufacturer's inspection and maintenance recommendations, as a minimum,the inspection and
maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks,
ii. A monthly check of the differential pressure drop and liquid flow rate;and
iii. An annual (for each 12 month period following the initial inspection)internal inspection of the
bagfilters' structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork and
bagfilters are not inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
c. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. the date and time of each recorded action;
H. the results of each inspection;
iii. a record of the differential pressure drop and liquid flow rate from each monthly check;
iv. the results of any maintenance performed on the bagfilters;and
v. any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if these records are not
maintained.
Logs for the limestone and the Filteraid silos were examined,as these are still in use.All monthly
maintenance/inspections and annual internal inspections are being conducted and recorded as
required by the permit per examination of logs since the previous inspection,2/19/2020,through vtd.
The annual internal inspections were completed as follows:
CE9—5/16/20
CE10& CEI I —1/5/21
CE17-6/l/20
Compliance is indicated.
Reporting [15A NCAC 02Q.0508(f)]
d. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 days of a
written request by the DAQ.
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 E.l.c,d and a above postmarked on or before January 30 of each calendar year for the

ADM Full Compliance Inspection
2/24/2021
Page 18 of 30
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring,recordkeeping,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring[15A NCAC 02Q.0508(f)]
c. i. To ensure compliance, once a month the Permittee shall observe the emission points of these storage
silos(ID Nos. EU9,EU17,EUIO,EU14,EUII,EU25, EU26, EU38,and EU39)for any visible
emissions above normal. The monthly observation must be made for each month of the calendar year
period to ensure compliance with this requirement. If visible emissions from these silos are observed to
be above normal,the Permittee shall either:
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D.2610 (Method 9)for 12 minutes is below the limit given in
Section 2.1 E.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if.
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;or
(C) the monthly observations are not conducted per c.i above.
Opacity was seen to be essentially "zero'as observed during the walkabout inspection of the facility.
Compliance is indicated.
Recordkeeping [15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Monthly VEs are being observed and recorded in a log as required by the permit. Observations were
checked back to the date of the previous inspection,2/19/2020,through vtd.The opacity is being
recorded monthly and found to be within the acceptable permit ranges.Compliance is indicated.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 E.2.c and d above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring, recordkeepine,and reporting activities are being
submitted on a timely basis with the required information.Compliance is indicated.
F. Three limestone slurry mixing tanks (ID Nos. EU18, EU19, and EU20) with associated
vent spray (ID No. CE18)

ADM Full Compliance Inspection
2/24/2021
Page 19 of 30
At the time of the inspection the three limestone slurry mixing tanks (EU18, EU19, & EU20) and vent
spray system(CE18)were operating.
The following provides a summary of limits and/or standards for the emission sources described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D .0515
E=4.1OxP"'
For process rates greater than 30 tons per hour:
E=55.0 x P 1-"-40
Where: E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D.0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the limestone slurry mixing tanks(ID Nos. EU18, EU19,and EU20)
shall be controlled by the vent spray system(ID Nos.CE18).To assure compliance,the Permittee shall
perform inspections and maintenance as recommended by the manufacturer. In addition to the
manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection
and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall
include the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii. an annual(for each 12-month period following the initial inspection)internal inspection of the vent
spray system's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork and vent
spray system are not inspected and maintained.
Recordkeepine [15A NCAC 02Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. The date and time of each recorded action;
H. The results of each inspection;
iii. The results of any maintenance performed on the vent spray systems;and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
Monthly visual inspections are being completed as required by the permit. Records were reviewed
from the date of the previous inspection,2/19/2020,through vtd.The annual internal inspection for
CE18 was completed on 3/11/20. Compliance is indicated.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the vent spray system within 30
days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities given in Section(s)
2.1 F.Lc and d above postmarked on or before January 30 of each calendar year for the preceding six-
month period between July and December and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this permit must be
clearly identified.

ADM Full Compliance Inspection
2/24/2021
Page 20 of 30
A semiannual summary report of monitoring, recordkeepine,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring [15A NCAC 02Q.0508(f)]
c. i. To ensure compliance,once a week the Permittee shall observe the emission points of these sources
(ID Nos. EU18,EU19,and EU20) for any visible emissions above normal. The weekly observation
must be made for each week of the calendar year period to ensure compliance with this requirement. If
visible emissions from these sources are observed to be above normal,the Permittee shall either:
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610 (Method 9)for 12 minutes is below the limit given in
Section 2.1 F.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if:
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made;or
(C) the weekly observations are not conducted per c.i above.
Opacity was seen to be essentially"zero'as observed during the walkabout inspection of the facility.
Compliance is indicated.
Recordkeepine[15A NCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Monthly VEs are being observed and recorded in a log as required by the permit.Observations were
checked back to the date of the previous inspection.2/19/2020,through ytd.The opacity is being
recorded monthly and found to be within acceptable permit ranges.Compliance is indicated.
Reporting [15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 F.2.c and d above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring, recordkeeping,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
G. One calcium hydroxide slurry mixing tank (ID No. EU12) with associated cartridge
filter dust collector(ID No. CE12)
The calcium hydroxide slurry mixing tank (EU12) and associated cartridge filter dust collector (CE12)
are out of service.

ADM Full Compliance Inspection
2/24/2021
Page 21 of 30
H. Combustion Turbines including:
• Two natural gas/No. 2 fuel oil-fired combustion turbines (ID Nos. EU21 and EU22)
and steam-injection with a minimum steam to fuel (s:f) ratio of 0.46 while firing No.
2 fuel oil
• One natural gas-fired combustion turbine (ID No. EU23)
The combustion turbines were not operating at the time of the inspection, so no VE observations
were made.
'The following provides a summary of limits and/or standards for the emission sources described above.
Regulated Pollutant Limits/Standards Applicable Regulates
Sulfur dioxide 2.3 pounds per million Btu 15A NCAC 02D .0516
Visible emissions 20 percent opacity 15A NCAC 02D.0521
S02,NOx,CO, PM-10, See Section 2.2.B.1.of this permit 15A NCAC 02Q.0317
and VOC I I (PSD Avoidance)
1. 15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur
dioxide formed by the combustion of sulfur in fuels,wastes, ores, and other substances shall be included
when determining compliance with this standard.
Testin [15A NCAC 02Q.0508(f)]
�E
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the
results of this test are above the limit given in Section 2.1 H.La above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
Monitoring/Recordkeeping[15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of natural gas/No.2
fuel oil in these turbines(ID Nos. EU21, EU22,and EU23).
When operated,all three turbines are primarily being fired with natural gas except under periods of
natural gas curtailment when they are fired by No.2 Fuel Oil.There has been limited operation of
the sources since the last inspection. They were recently operating for a short period of time for
testing. The last time fuel oil was used was December 2020. 1416 gallons were used at that time.
Compliance is indicated.
1. Powdered Products Sources, including:
• One steam-heated fluidized bed dryer (powdered products) (ID No. EU27) with
associated cyclonic wet scrubber (ID No. CE27)
• Powdered products packaging(ID No. EU28) with associated multi-vane scrubber
(ID No. CE28)with a demister
• One steam-heated fluidized bed dryer (powdered products) (ID No. EU40) with an
associated cyclonic wet scrubber(ID No. CE40)
• Spray dryer(ID No. EU54)with associated bagfilter(ID No. CE54)
• Dried yeast pneumatic transfer, storage, and packaging(ID No. EU55)with
associated bagfilter and check filter (ID Nos. CE55 and CE55A)
• Spray dryer (ID No. EU57)with associated bagfilter(ID No. CE57)

ADM Full Compliance Inspection
2/24/2021
Page 22 of 30
• Spray dryer (ID No. EU59)with associated bagfilter (ID No. CE59)
The steam-heated fluidized bed dryers(EU27& EU40).cyclone wet scrubbers(CE27&CE40),multi-vane
scrubber(CE28),and the powdered products packaging(EU28)are out of service.
The following provides a summary of limits and/or standards for the emission sources described above.
RegnIated Pollntant Limits/Standards Applicable Regulation
Particulate matter For process rates up to 30 tons per hour: 15A NCAC 02D .0515
E=4.1OxPos1
For process rates greater than 30 tons per hour:
E=55.0 x P°-"-40
Where: E=allowable emission rate in pounds per hour,and
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 02D .0521
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
Monitoring[15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the affected sources shall be controlled as follows:
i. The steam-heated fluidized bed dryer(ID No.EU27)shall be controlled by one associated cyclonic
wet scrubber with a liquid injection rate of 75 to 125 gallons per minute(ID No. CE27).
ii. The powdered products packaging operation(ID No. EU28)shall be controlled by the multi-vane
scrubber with a liquid injection rate of 10 to 40 gallons per minute(ID No.CE28).
iii. The steam-heated fluidized bed dryer(ID No.EU40)shall be controlled by one associated cyclonic
wet scrubber with a liquid injection rate of 20 to 70 gallons per minute(ID No.CE40).
iv. The spray dryer(ID No. EU54)shall be controlled by one associated bagfilter(ID No.CE54)with
2,507 square feet of filter area.
v. The dried yeast pneumatic transfer,storage,and packaging(ID No. EU55)shall be controlled by one
associated bagfilter(ID No.CE55)with 1,024 square feet of filter area and one associated check filter
(ID No.CE55A)with 150 square feet of area.
vi. The spray dryer(ID Nos. EU57 and EU59)shall be controlled by one associated bagfilters(ID No.
CE57 and CE59)with 3,525 square feet of filter area,each.
d. To assure compliance,the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if there
are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and
maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork for leaks,
ii. a monthly check of the differential pressure drop and liquid flow rate for each scrubber; and
iii. an annual (for each 12 month period following the initial inspection) internal inspection of the
structural integrity for each scrubber and bagfilter.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork,scrubbers,
and bagfilters are not inspected and maintained.
Recordkeeping [15A NCAC 02Q .0508(f)]
e. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. a record of the differential pressure drop and liquid flow rate from each monthly check of the
scrubbers;

ADM Full Compliance Inspection
2/24/2021
Page 23 of 30
iv. the results of any maintenance performed on the scrubbers and bagfilters;and
v. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if these records are not
maintained.
All monthly and annual maintenance/inspections for CE55,CE55A,CE54,CE57,and CE59 are
being conducted and recorded as required by the permit per examination of loes.Monthly
differential pressures are being recorded as well. The last annual inspection was 12/22/20 for CE55,
12/30/20 for CE57,and 9/23/20 for CE59, respectively. Records were check from 2/19/20,through
ytd.Compliance is indicated.
Reporting [15A NCAC 02Q .0508(f)]
f. The Permittee shall submit the results of any maintenance performed on the scrubbers and the bagfilters
within 30 days of a written request by the DAQ.
g. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 L l.c,d and a above postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June. All instances of deviations from the requirements
of this permit must be clearly identified.
A semiannual summary report of monitoring,recordkeenine,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring[15A NCAC 02Q.0508(f)]
c. i. To ensure compliance,once a month the Permittee shall observe the emission points of these sources
(ID Nos. EU27,EU28,EU40, EU54,EU55,EU57 and EU59)for any visible emissions above
normal. The monthly observation must be made for each month of the calendar year period to ensure
compliance with this requirement. If visible emissions from these sources are observed to be above
normal,the Permittee shall either:
(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements
below,or
(B) demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610(Method 9)for 12 minutes is below the limit given in
Section 2.1 I.2.a above.
ii. The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if:
(A) the above-normal emissions are not corrected per c.i.(A)above;
(B) the demonstration in c.i.(B)above cannot be made; or
(C) the monthly observations are not conducted per c.i above.
Opacity was seen to be essentially"zero"as observed during the walkabout inspection of the facility.
Compliance is indicated.
Recordkeeping[15A NCAC 02Q.0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.

ADM Full Compliance Inspection
2/24/2021
Page 24 of 30
Monthly VEs are being observed and recorded in a loe as required by the permit. Observations were
checked back to the date of the previous inspection.2/19/20,throueh ytd.The opacity is being
recorded months and found to be within the acceptable permit ranges. Compliance is indicated.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in
Section(s)2.1 1.2.c and d above postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December and July 30 of each calendar year for the preceding six-
month period between January and June. All instances of deviations from the requirements of this permit
must be clearly identified.
A semiannual summary report of monitoring,recordkeeping,and reporting activities are being
submitted on a timely basis with the required information. Compliance is indicated.
J. Citric acid fermentation system (ID Nos. EU33a, EU33b, EU33c, EU33d, EU33e, EU33f,
EU33g, and EU33h)with associated cyclonic impingement scrubber(ID No. CE33) and
gravity spray tower wet scrubber(ID No. CE34) and equipped with a demister section
Citric acid fermentation system (ID Nos. EU31a, EU31b,EU31c, EU31d, and EU31e)
with associated packed bed scrubber (ID No. CE31) and equipped with demister section
The following provides a summary of limits and/or standards for the emission source(s)described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Odors State-enforceable only l5A NCAC 02D .1806
See Section 2.2.A.1
No odors were noticed off-site.
K. One diesel-fired black-start generator (ID No. EU48)
"fhe following provides a summary of limits and/or standards for the emission source(s)described above.
Regulated Pollutant Limits/Standards Applicable Regulation
Sulfur dioxide 2.3 pounds per million Btu 15A NCAC 02D .0516
Visible emissions 20 percent opacity 15A NCAC 02D .0521
Hazardous Air See Section 2.1 K.3,below 15A NCAC 02D.1 I I I
Pollutants 1 1 (40 CFR Part 63, Subpart ZZZZ)
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
Monitoring/Recordkeeoing/Reportine [15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of diesel fuel in
this black-start generator(ID No.EU48).
The black-start generator (EU48) was not operatine at the time of inspection. 279.0 hours vs. 241.4
hours at the time of the last inspection, 2/19/20, indicating 37.6 hours of operation since the last
inspection. All hours were associated with emergency use or readiness testine. On an annualized
basis, all engines (including insignificant sources — two firepumps and two emergency generators)
were below 50 hours of non-emergency operation, which is less than the 100 hours total allowed for
non-emergency use and readiness testine.Compliance is indicated for MACT ZZZZ requirements.

ADM Full Compliance Inspection
2/24/2021
Page 25 of 30
3. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Ooeratine and Maintenance Requirements [15A NCAC 02Q .0508(b)]
f The Permittee shall minimize the black-start generator's(ID No. EU48)time spent at idle during startup
and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine,
not to exceed 30 minutes,after which time the non-startup emission standards in Section 2.1 K.3.g,below,
apply. [40 CFR 63.6603(a),Table 02D and 63.6625(h)]
g. Except during periods of startup of the IC engine,the Permittee shall:
i. Change oil and filter every 500 hours of operation or annually,whichever comes first;
ii. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;and
iii. Inspect all hoses and belts every 500 hours of operation or annually,whichever comes fast,and
replace as necessary
[40 CFR 63.6603(a),Table 02D]
h. The Permittee shall have the option to utilize the oil analysis program as described in 40 CFR 63.6625(i)in
order to extend the specified oil change requirement in Section 2.1 K.3.g[40 CFR 63.6603(a),Table 02D,
63.6625(i)]
i. If performing the management practice on the required schedule in Section 2.1 K.3.g would otherwise pose
an unacceptable risk under Federal, State,or local law,the management practice can be delayed until the
unacceptable risk under Federal,State,or local law has abated. The management practice should be
performed as soon as practicable after the unacceptable risk under Federal,State,or local law has abated.
The Permittee shall report any failure to perform the management practice on the schedule required and the
Federal, State or local law under which the risk was deemed unacceptable. [40 CFR 63.6603(a),Table
02D]
j. The Permittee shall be in compliance with the emission limitations,operating limitations and other
requirements that apply at all times. [40 CFR 63.6605(a)]
k. The Permittee shall operate and maintain the black-start generator(ID No.EU48),including associated air
pollution control equipment and monitoring equipment,in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the Permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Administrator which may include, but is not limited to,
monitoring results,review of operation and maintenance procedures,review of operation and maintenance
records,and inspection of the source. (40 CFR 63.6605(b)]
I. The Permittee shall operate and maintain the black-start generator(ID No. EU48)and after-treatment
control device(if any)according to the manufacturer's emission-related written instructions or develop a
maintenance plan which must provide to the extent practicable for the maintenance and operation of the
engine in a manner consistent with good air pollution control practice for minimizing emissions. [40 CFR
63.6625(e)(3)and 63.6640(a),Table 6]
m. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .I I 1 I if Sections 2.1 K.3.e.
through 1. are not met.
Recordkeeoine [15A NCAC 02Q.0508(f)]
n. The Permittee shall keep the following:
i. A copy of each report that the Permittee submitted to comply with Section 2.1 K.3, including all
documentation supporting any Initial Notification or Notification of Compliance Status that the
Permittee submitted,according to the requirement in 40 CFR 63.10(b)(2)(xiv).[40 CFR 63.6655(a)(1)]
ii. Records of the occurrence and duration of each malfunction of operation(i.e.,process equipment)or
the air pollution control and monitoring equipment. [40 CFR 63.6655(a)(2)1
iii. Records of all required maintenance performed on the air pollution control and monitoring equipment.
[40 CFR 63.6655(a)(4)]
iv. Records of actions taken during periods of malfunction to minimize emissions in accordance with
Section 2.1 K.31., including corrective actions to restore malfunctioning process and air pollution
control and monitoring equipment to its normal or usual manner of operation. [40 CFR 63.6655(a)(5)]
v. Records of the maintenance conducted on the black-start generator(ID No. EU48)pursuant to Section
2.1 K.3.1. [40 CFR 63.6655(d)and(e)]

ADM Full Compliance Inspection
2/24/2021
Page 26 of 30
o. The Permittee shall keep each record in a form suitable and readily accessible in hard copy or electronic
form for at least 5 years after the date of each occurrence,measurement,maintenance,corrective action,
report,or record,according to 40 CFR 63.10(b)(1). [40 CFR 63.6660(a),(b),(c)]
p. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1111 if Sections 2.1 K.3.n and o
are not met.
Required maintenance is beine performed,not only for this permitted"black start"emergency
generator,but also for the four other insignificant sources.The most recent maintenance work was
conducted on 2/22/21.This work is currently being performed on a semiannual basis.All emergency
engines were compliant with the<100 hours combined maintenance and testing limit rule
requirement.Compliance is indicated.
Reporting[15A NCAC 02Q.0508(f)]
q. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December
and July 30 of each calendar year for the preceding six-month period between January and June. All
instances of noncompliance must be clearly identified. [40 CFR 63.6640(b),(e),and 63.6650(f)]
i. The summary report shall also include any reporting required under Section 2.1 K.31 as necessary.
[40 CFR 63.6603(a),Table 02D]
The Permittee shall be deemed in noncompliance with the reporting requirements of 15A NCAC 02D A I I I
if Section 2.1 K.3.q is not met.
A semiannual summary report of monitoring,recordkeepin2,and reporting activities are being
submitted on a timely basis with the required information.Compliance is indicated.
L. The following boilers:
Emission Emission Source Description Control Control Device
Source ID Device ID Description
No. No.
EU60 One natural gas/No.2 fuel oil-fired boiler(99 million Btu per NA NA
hour maximum heat input rate)equipped with low NOx burners
EU61 One natural gas/No.2 fuel oil-fired boiler(99 million Btu per NA NA
hour maximum heat input rate)equipped with low NOx burners
EU62 One natural gas/No.2 fuel oil-fired boiler(99 million Btu per NA NA
hour maximum heat input rate)equipped with low NOx burners
The boilers have not vet been installed at the facility.Compliance is indicated.
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-wide affected sources
The above emission sources are subject to this multiple emission source limit.
Regulated Pollutant Links/Standards Applicable Regulation
Odors State-enforceable only 15A NCAC 02D .1806
Odorous emissions must be controlled
Toxic air pollutants State-enforceable only 15A NCAC 02Q .0711
Toxic air pollutant emissions shall not exceed the
levels listed in 02Q.0711 unless ambient standards are
notexceeded

ADM Full Compliance Inspection
2/24/2021
Page 27 of 30
STATE-ENFORCEABLE ONLY
1. 15A NCAC 02D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or installing and
operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
No odors were noticed off-site.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 02Q.0711: TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT
a. For each of the toxic air pollutants(TAPS)below listed,the Permittee has made a demonstration that
facility-wide actual emissions do not exceed the Toxic Permit Emission Rates(TPERs)listed in 15A
NCAC 02Q.0711. The facility, specifically the sulfuric acid storage tanks(ID Nos. IT-101, IT-256,IT-
268,IT-434,IT-435 and IT-436),shall be operated and maintained in such a manner that emissions of any
listed TAPS from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC
02Q.0711.
b. A permit to emit any of the below listed TAPS shall be required for this facility if actual emissions from all
sources will become greater than the corresponding TPERs.
c. PRIOR to exceeding any of these listed TPERs,the Permittee shall be responsible for obtaining a permit to
emit TAPS and for demonstrating compliance with the requirements of 15A NCAC 02D.1100 "Control of
Toxic Air Pollutants".
d. In accordance with the approved application,the Permittee shall maintain records of operational
information demonstrating that the TAP emissions do not exceed the TPERs as listed below:
TPERs Limitations
Pollutant
, (CAS Number) Carcinogens Chronic Toxicants Acute Systemic Acute Irritants
(lb/yr) (lb/day) Toxicants(lb/hr) (lb/hr)
Sulfuric acid
(7664-93-9)
There have been no chances to the sulfuric acid storage tanks since the last inspection on 2/19/20.
Compliance is indicated.
B. Two natural gas/No. 2 fuel oil-fired turbines (ID Nos. EU21 and EU22)
One natural gas-fired turbine (ID No. EU23)
The above emission sources are subject to this multiple emission source limit.
Regulated Pollutant Limits/Standards Applicable Regulation
Nitrogen oxides Less than 466.6 tons per year. 15A NCAC 02Q .0317
(PSD Avoidance)
Sulfur dioxide Less than L315 tons per year. 15A NCAC 02Q .0317
(PSD Avoidance)
Carbon monoxide Less than 120.71 tons per year. 15A NCAC 02Q .0317
(PSD Avoidance)
PM-10 Less than 118.68 tons per year. 15A NCAC 02Q .0317
(PSD Avoidance)
Volatile organic Less than 41.16 tons per year 15A NCAC 02Q .0317
compounds (PSD Avoidance)

ADM Full Compliance Inspection
2/24/2021
Page 28 of 30
1. 15A NCAC 02Q.0317: AVOIDANCE CONDITIONS
for 15A NCAC 02D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
Monitorine/Recordkeepine [I5A NCAC 02Q.0508(f)]
d. The Permittee shall keep monthly records of fuel usage in a logbook(written or in electronic format), as
follows:
i. The total quantity of natural gas fired(in million scf)and No.2 fuel oil fired(in 1,000 gal)at the
affected turbines;and,
ii. The fuel oil supplier certification for any fuel oil fired at the affected turbines, including the sulfur
content of the oil(in percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if records of the natural gas
and fuel oil usage and No.2 fuel oil sulfur content are not created and retained as required above.
Monthly fuel logs documenting fuel usage for this site's turbine venerators are being maintained,
examined,and found to be in compliance with the permit requirement.Compliance is indicated.
f The Permittee shall calculate rolling 12-month emissions from the affected turbines within 30 days after the
end of each calendar month. Emissions shall be estimated by summing the monthly emissions,as calculated
in Section 2.2 B.Le above for the previous,consecutive 12-month period. The Permittee shall be deemed
in noncompliance with I5A NCAC 02D.0530 if records of the 12-month rolling calculations listed above
are not created and retained,or if the emission total exceeds a limit in Section 2.2 B.La above.
The required monthly calculations are being kept on an electronic spreadsheet.All emissions were
below the permit limitations. Compliance is indicated
Reporting [15A NCAC 02Q.0508(f)]
g. The Permittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality
Supervisor,of monitoring and recordkeeping activities given in Section 2.2 B.I.d through f above
postmarked on or before January 30 of each calendar year for the preceding six-month period between July
and December,and July 30 of each calendar year for the preceding six-month period between January and
June. The report shall contain the following
i. The monthly quantities of natural gas and No.2 fuel oil fired in the affected turbines for the each of
the previous 17 months;
ii. The monthly NOx, S02,CO, PM-10, and VOC emission rates from the affected turbines for the
previous 17 months;
iii. The total NOx, S02,CO,PM-10, and VOC emissions from the affected turbines for each 12-month
period ending during the six month reporting period;
iv. The minimum steam to fuel ratio in turbines(ID Nos. EU21 and EU22)over the previous six-month
period; and,
V. All instances of deviations from the requirements of this permit must be clearly identified.
Required semiannual reportiny is beinv received on time and includes the required emission
estimates.Compliance is indicated.
12. MACT ZZZZ: There are five CI engines on site with potential MACT/GACT ZZZZ
applicability. The permit identifies a 1,500 hp/1,000 kW diesel-fired emergency "black
start" generator (ID No. EU48) for use in starting up the electric turbines. But there are
also two smaller emergency generators (IEU49 & IEU50) on site, plus two emergency
fire pumps. ADM has taken emergency generator (IEU49) out of service.
ADM is currently complying with maintenance requirements for all MACT Subpart
ZZZZ subject CI engines. Routine maintenance is performed semiannually on these
engines twice per year and all on the same day. This maintenance includes changing the

ADM Full Compliance Inspection
2/24/2021
Page 29 of 30
oil, oil filter, changing the air cleaner, and inspection of belts. Maintenance records were
reviewed since the previous inspection on 2/12/20 for all Cl engines. Maintenance on all
engines was last performed on 2/22/21 for EU48,IEU35 & IEU36 and 2/23/21 for IEU50.
A table of hour meter readings is shown below:
ID Description 2/24/21 2/12/20 0 Hrs. 8/28/19 3/13/19
Black Start
EU48 Emergency
(Q706) Generator 279.0 241.4 37.6 227.5 218.6
Old Admin
Building
IEU49 Emergency Out of Out of Out of Out of
(Q705) Generator service service service service
Waste
Treatment
IEU50 Emergency
(Q918) Generator 430 387 43 376 373
IEU35 Emergency
(P771) Fire Pump 2129.0 1960.2 168.8 1925.3 1907.6
IEU36 Emergency
(P772) Fire Pump 2135.96 2124.02 11.94 2111.16 2096.86
All hours for the prior year are less than the 100-hrs allowed for readiness testing, excluding
hours of emergency operation. Compliance with this rule is indicated.
13. 2019 Emissions: The 2019 emissions for this facility are summarized in the table below
from data contained in the Emissions Inventory Database.
CY 2018
CY 2019 from ED
from ED Actual
Actual Emissions
Pollutant Emissions (Tons/year)

ADM Full Compliance Inspection
2/24/2021
Page 30 of 30
(Tons/year)
CO 2.79 4.08
NOx 4.75 11.96
PM (TSP) 21.23 22.03
PM10 5.28 5.16
PM2.5 1.27 1.18
SO2 0.11 2.96
VOC 0.33 0.31
HAPs
Largest
Individual
HAP -
Xylenes
(mixed
isomers) 0.03 1 0.45
Total HAP 1 0.039 0.199
14. Five Year Compliance History A five year records review was conducted in order to see
if there were any recent violations or compliance issues. Nothing was found.
15. Conclusions. Comments, and Recommendations: ADM appeared to be operating in
compliance with Air Quality regulations at this time of the inspection.