The facility was cited for failing to obtain PSD permits when it modified several corn byproducts dryers at its facility. A CAFO/APO was issued to resolve violations of PSD for CO on the gluten meal dryer. In addition, the company agreed to install BACT-level controls on all its dryers for VOC and CO. This Administrative Order requires that, within a year, Tate and Lyle apply for a permit with these limits. U.S. EPA calculated the VOC emission reductions based on 1999 and 2003 testing conducted at the facility that U.S. EPA believes underquantifies emissions so the actual VOC emission reductions will likely be greater. U.S. EPA was not able to calculate the CO emission reductions due to lack of data. The cost to achieve this source reduction was based on a Tate and Lyle statement that regenerative thermal oxidizers would be installed to achieve these reductions. U.S. EPA estimates that three RTOs will be installed because there are currently three scrubber systems controlling the dryers. Also, based on passed experience, U.S. EPA made a conservatively low estimate that each RTO would cost $1 million.