Operating Permits: Guidance on Calculating Potential to Emit for Country Grain Elevators

Air Pollution Control Program fact sheet
Division of Environmental Quality Director: Ed Galbraith

Definition - Country Grain Elevator
A country grain elevator is any grain elevator located in a city with a population less than 50,000 that receives more than 50 percent of its grain from farmers in the immediate vicinity during the harvest season. The only municipalities in Missouri with a population of 50,000 or more are Columbia, Florissant, Independence, Kansas City, St. Charles, St. Joseph, St. Louis and Springfield. Country grain elevators may also contain other components such as feed or milling operations or fertilizer plants. Grain terminals, grain elevators that receive grain primarily from other grain elevators, are not included in this definition.

Calculating Potential to Emit of Country Grain Elevators
When calculating potential emissions from a manufacturing facility, it is reasonable to assume that the facility could operate continuously. However, this assumption is not reasonable for country grain elevators, which for all practical purposes can receive grain only from farmers in the surrounding countryside. Further, the amount of grain that these farmers can produce is governed by the prevailing growing seasons in Missouri. For these reasons, this guidance allows the country grain elevator to use the highest annual amount of grain received during the previous five years, multiplied by an adjustment factor of 1.2, to calculate potential emissions. This adjustment factor constitutes a realistic upper bound on the annual amount of grain a country elevator could receive.

This fact sheet is intended solely as guidance related to the applicability of the operating permit program and does not represent final Missouri Department of Natural Resources action. This guidance is not intended to replace the establishment of operational limitations in permits to construct or operate when such limitations are deemed appropriate or necessary. Additionally, it is not intended for use as the basis to cancel any such restrictions already in place. This guidance should not be interpreted as having any effect on whether New Source Performance Standards apply to a given elevator. This guidance may not be used when determining whether a construction permit is required for a new country grain elevator. Also, it is not intended to prevent any control agency from imposing requirements designed to provide for attainment of the National Ambient Air Quality Standards.