During the inspection, EPA observed Tri Central Coop load a truck with grain and estimated the opacity of the emissions to be at least 60% during the loading. The truck loadout did not have a sleeve that extended into the truck. In addition, many of the other loadouts at the Facility either did not have sleeves or had sleeve that appeared too short to extend into trucks. The Facility also had a dump pit without pollution controls, did not check the pollution controls that it does have daily as required by the State Implementation Plan and its permit, did not do sufficient housekeeping, did not maintain PM emissions records as required by its operating permit, and did not perform other checks for pollution as required by its permit. In addition the Facility did not perform opacity testing of some conveyors at the Facility as required by NSPS DD.
The ACO requires Tri Central Coop to operate a high efficiency cyclone on the Major Dump Pit that will remove 90% of the particulate matter from that process. It also requires the elevator to close at least one door on the dump pit while unloading trucks, to use loadout socks that extend six inches into trucks, and to calculate PM emissions and maintain the records onsite. By signing the ACO, Tri Central Coop certified that the opacity testing required by NSPS DD has been performed. Finally, the ACO requires Tri Central Coop to follow the housekeeping requirements in the Illinois SIP at Rule 203(d)(9)(A) [35 Ill. Admin. Co