PERMIT TO OPERATE INTERMEDIATE STATE · VAC-01 & 2 Hi-Vac plant dust vacuum system WH-01 hot water...

~§MISSOURI li:11 ro I DEPARTMENT oF l_gj \:f;;I NATURAL RESOURCES Air Pollution Control Program

PERMIT TO OPERATE INTERMEDIATE STATE

Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to operate the air contaminant source(s) described below, in accordance with the laws, rules, and conditions set forth herein.

Intermediate Operating Permit Number: OP2018-068 Expiration Date:AUG O 6 2023

Installation ID: 027-0010 Project Number: 2017-12-025

Installation Name and Address Harbison Walker International, Inc. - Fulton Brick Plant 111 St. Eunice Road Fulton, MO 65251 Callaway County

Installation Description:

Parent Company's Name and Address Harbison Walker International, Inc. 1305 Cherrington Parkway, Suite 100 Moon Township, PA 15108

Harbison Walker International, Inc. - Fulton Brick Plant is a manufacturer of high alumina brick, used in the working linings of steel making furnaces such as electric arc furnaces and steel ladles, rotary kilns used in the manufacture of cement and quick lime and many other applications where heat needs to be contained. The plant activities include the crushing, grinding and screening of raw materials, batching, pressing, firing, packaging and shipment of finished goods to the customer.

Prepared by Adam Brooks EIT Operating Permit Unit

AUG O 6 Effective Date

Harbison Walker International, Inc. - Fulton Brick Plant Installation ID: 027-0010 Intermediate State Operating Permit

Table of Contents

2 Project No. 2017-12-025

I. INSTALLATION EQUIPMENT LISTING ............................................................................................. 3

EMISSION UNITS WITH LIMIT A TIO NS ......................................................................................................... 3 EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS ............................................................................... 4

II. PLANT WIDE EMISSION LIMITATIONS ............................................................................................ 5

Ill. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ....................................................................... 6

PERMIT CONDITION Controls .................................................................................................................... 6 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s) ..................................... 6

PERMIT CONDITION 6.220 ....................................................................................................................... 10 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants .................................................... 10

PERMIT CONDITION Tunnel Kilns ........................................................................................................... 13 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s) ................................... 13

IV. CORE PERMIT REQUIREMENTS .................................................................................................... 14

V. GENERAL PERMIT REQUIREMENTS .............................................................................................. 19

VI. ATTACHMENTS .............................................................................................................................. 23

ATTACHMENT A ................................................................................................................................................. 24 Fugitive Emission Observations ................................................................................................................. 24

ATTACHMENT B .................................................................................................................................................. 25 Method 22 Visible Emissions Observations ............................................................................................... 25

ATTACHMENT C .................................................................................................................................................. 26 Method 9 Opacity Observations ................................................................................................................. 26

ATTACHMENT D ················································································································································· 28 Inspection/Maintenance/Repair/Malfunction Log ...................................................................................... 28

ATTACHMENT E .................................................................................................................................................. 29 Pressure Drop Monitoring .......................................................................................................................... 29


I. Installation Equipment Listing

EMISSION UNITS WITH LIMITATIONS

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The following list provides a description of the equipment at this installation that emits air pollutants and that are identified as having unit-specific emission limitations.

Emission Emission Description Maximum Hourly

Point Unit# Desien Rate P-06 EUOOlO Transfer Equipment 35 tons P-07 EU0020 VSI (variable speed impact) Crusher 35 tons P-08 EU0030 Storage Bins 35 tons P-27 EU0040 Transfer Equipment; Green Scrap System 6 tons

EP-05 EU0050 Air Transporter 7 tons EP-05 EU0060 Transfer Equipment: Williams Mill Cyclone Discharge 4.5 tons P-11 EU0070 Transfer Equipment: Skip Hoist System 3 tons P-11 EU0080 Transfer Equipment: Mixer Feed System 17.5 tons P-11 EU0090 Transfer Equipment: Mixer Feed System 17.5 tons P-11 EUOlOO Transfer Equipment: Mixer Feed System 17.5 tons P-11 EUOl 10 Transfer Equipment: Mixer Feed System 17.5 tons

EP-05 EU0120 Transfer Equipment: Mixer Feed System 12.5 tons P-11 EU0130 Transfer Equipment: Mixer Feed System 12.5 tons P-11 EU0140 Transfer Equipment: Bulk Bag Dump System 1.3 tons P-09 EU0150 East Ball Mill 4 tons P-29 EU0151 West Ball Mill 3 tons P-10 EU0180 Transfer Equipment: East Ball Mill System 4 tons P-28 EU0190 Transfer Equipment: Green Scrap Discharge 6 tons P-27 EU0200 Crusher; Green Scrap System 6 tons P-12 EU0210 Mixer 1 17.5 tons P-12 EU0220 Mixer 2 17.5 tons P-12 EU0230 Mixer 3 17.5 tons P-12 EU0240 Mixer 4 12.5 tons P-12 EU0250 Mixer 5 12.5 tons P-12 EU0260 Mixer 6 12.5 tons P-11 EU0270 Batch Car; Raw Material Batching 30 tons P-26 EU0290 Air Transport Bin Vent (TAF) 25 tons P-20 EU0310 Impact Mill: Williams Mill 4.5 tons

EP-18 EU0320 Air Heater 3.5 tons P-16 EU0330 Tunnel Dryers # 1 and #2 10.3 tons

EP-13 & 14 EU0340 Air Heater 4.2 tons P-16 EU0350 Tunnel Dryers #3 and #4 10.3 tons

P-16 EU0360 # 1 Tunnel Kiln - Process 10.3 tons # 1 Tunnel Kiln - Combustion 27.955 MMBtu

P-16 EU0370 #2 Tunnel Kiln - Process 10.3 tons #2 Tunnel Kiln - Combustion 27.955 MMBtu

P-07 EU0440 Transfer Equipment: VSI Crushing System 35 tons P-33 EU0450 Mogensen Screen 35 tons NIA EU0460 Air Transport Bin Vent Potters Flint 25 tons

NIA EU0470 Air Transport Bin Vent M&D Ball Clay Silo Truck

25 tons Delivery

Harbison Walker International, Inc. - Fulton Brick Plant Installation ID: 027-00 IO Intermediate State Operating Permit

Emission Emission Description

Point Unit# NIA EU0480 Air Transport M&D Ball Clay Silo Bin #7

NIA EU0490-Air Transport Bin Vent Bauxite Fines Bin #8

I

NIA EU0490-Air Transport Bin Vent Clay Fines Bin #10

2

EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS

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Maximum Hourly Desien Rate

2 tons

2 tons

2 tons

The following list provides a description of the equipment that does not have unit specific limitations at the time of permit issuance.

Emission Description

Maximum Hourly Design Point Rate

P-02 Railcar Unloading - Hopper (fugitive emissions) P-02 RU Jaw Crusher (fugitive emissions)1

P-02 RU 4 Conveyors, Apron Feeder, Hopper (fugitive emissions) P-04 Outside Clay Handling and Storage (fugitive emissions) P-05 Rotary Dryer (OOC) P-06 Hopper (fugitive emissions) P-25 Haul Road (fugitive emissions) P-26 Raw Material Handling and Transferring 1.3 tons P-30 3 Conveyors 3 tons P-32 Ball Mill Bin 3 tons T-03 4 70 gallon diesel fuel tank NIA # 1 tunnel kiln excess hot air exhaust stack EP-08 # I tunnel kiln under car cooling air exhaust stack EP-11 # I and #2 tunnel kiln dryers roof air space vent EP-12 #3 and #4 tunnel kiln dryers roof air space vent MW-01 Proceco mold wash unit VAC-01 & 2 Hi-Vac plant dust vacuum system WH-01 hot water heater (natural gas fired) 32,000 Btu WH-02 hot water heater (natural gas fired) 199,900 Btu SH-01 I Space Heater (natural gas fired) 30,000 Btu SH-02 3 Space Heaters (natural gas fired) 45,000 Btu each SH-03 1 Space Heater (natural gas fired) 60,000 Btu SH-04 I Space Heater (natural gas fired) 75,000 Btu SH-05 2 Space Heaters (natural gas fired) I 00,000 Btu each SH-06 I Space Heater (natural gas fired) 160,000 Btu SH-07 2 Space Heaters (natural gas fired) 200,000 Btu each SH-08 2 Space Heaters (natural gas fired) 255,000 Btu each SH-09 2 Space Heaters (natural gas fired) 300,000 Btu each SH-10 3 Space Heaters (natural gas fired) 400,000 Btu each

1 These emission units have not been operated in at least 5 years but remain at the installation; therefore, they are still listed. The installation must submit a permit to construct applicability request if they wish to begin operating these units again.


II. Plant Wide Emission Limitations

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The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CPR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued. The plant wide conditions apply to all emission units at this installation.

None.


Ill. Emission Unit Specific Emission Limitations

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The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued.

PERMIT CONDITION Controls

10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s)

Emission Units with Fabric Filters, Bin Vents, and Ba2houses Maximum

Overall Pressure


Hourly Construction Control Control

Drop Point Unit# Design Date Device Range

Rate Efficiency (osia)

Transfer Flex - Kleen

P-06 EUOOlO Equipment

35 tons 1991 Baghouse 98 % 1-6 Filter

VSI (variable 1998, Re- Flex-Kleen P-07 EU0020 speed impact) 35 tons constructed: Bag house 98% 1-6

Crusher 2005 Filter

P-08 EU0030 Storage Bins 35 tons 1966 WW Sly

98% 1-6 Baghouse

Transfer

P-27 EU0040 Equipment;

6 tons 1984 WW Sly

98% 1-6 Green Scrap Baghouse System

EP-05 EUOOSO Air

7 tons 1984 WW Sly

98% 1-6 Transporter Baghouse Transfer Equipment:

WW Sly EP-05 EU0060 Williams 4.5 tons 1966 98% 1-6

Mill Cyclone Baghouse

Discharge Transfer

P-11 EU0070 Equipment:

3 tons August 30, WW Sly

98% 1-6 Skip Hoist 1971 Baghouse System Transfer


17.5 tons 1966 WW Sly

98% 1-6 Mixer Feed Baghouse System Transfer



98% 1-6 Mixer Feed Baghouse System


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Emission Units with Fabric Filters, Bin Vents, and Baghouses Maximum

Overall Pressure




Rate Efficiency (psia)

Transfer

P-11 EUOlOO Equipment:



P-11 EUOl 10 Equipment:



EP-05 EU0120 Equipment:





98% 1-6 Mixer Feed Baghouse System Transfer Equipment:

WW Sly P-11 EU0140 Bulk Bag 1.3 tons 1995 98% 1-6

Dump Baghouse

System

P-09 EU0150 East Ball

4 tons 1966 Sly Bag house

98 % 1-6 Mill Collector

P-29 EU0151 West Ball

3 tons 2012 Scientific Bag

99% 1-6 Mill Collector Transfer


4 tons 1974 Sly Baghouse 98% 1-6 East Ball Mill System Transfer


6 tons 2004 Micropulsaire

98 % 1-6 Green Scrap Baghouse Discharge Crusher;

Micropulsaire P-27 EU0200 Green Scrap 6 tons 2004 98 % 1-6

System Baghouse

P-12 EU0210 Mixer 1 17.5 tons 1966 Micropulsaire

98 % 1-6 Baghouse


98% 1-6 Baghouse


98 % 1-6 Baghouse


98 % 1-6 Baghouse


98% 1-6 Ba!:!house


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Emission Units with Fabric Filters, Bin Vents, and Baghouses Maximum

Overall Pressure




Rate Efficiency (psia)


98% 1-6 Baghouse

Batch Car; Torit

P-11 EU0270 Raw Material 30 tons 1966 Donaldson

98 % 1-6 Batching Air Transport

Donaldson P-26 EU0290 Bin Vent 25 tons 1995

Fabric Filter 98% 1-8

(TAF) Impact Mill:

Griffen Bag P-20 EU0310 Williams 4.5 tons 1984 98 % 1-6

Mill Collector

Transfer



98% 1-8 VSI Crushing Collector System

P-33 EU0450 Mogensen


98 % 1-8 Screen Collector Air Transport

NIA EU0460 Bin Vent 25 tons 1984 Torit Bin Vent 98% 1-6 Potters Flint Air Transport Bin Vent

Cycloneair M&D Ball NIA EU0470 Clay Silo

25 tons 2011 Inside Plant 98% 1-6

Truck Bin Vent

Delivery Air Transport

Cycloneair NIA EU0480

M&D Ball 2 tons 2011 Inside Plant 98% 1-6

Clay Silo Bin Bin Vent

#7 Air Transport

NIA EU0490- Bin Vent 2 tons 2011 None 98% 1-6

1 Bauxite Fines Bin #8 Air Transport

NIA EU0490- Bin Vent 2 tons 2011 None 98% 1-6

2 Clay Fines Bin #10


Operational Limitation:

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1) All fabric filters, bin vents, and baghouses must be in use at all times when any of the equipment associated with its emission source is in operation.

2) The fabric filters, bin vents, and baghouses shall be operated and maintained in accordance with the manufacturer's specifications. This includes operating with control efficiencies equal to or greater than their corresponding values (as listed in Emission Units With Limitations).

3) The fabric filters, bin vents, and baghouses shall be equipped with a gauge or meter, which indicates the pressure drop across the control devices. These gauges or meters shall be located such that the Department of Natural Resources' employees may easily observe them.

4) Replacement filters (including those for the bin vents and baghouses) shall be kept on hand at all times. The bags shall be made of fibers appropriate for operating conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance).

Monitoring!Recordkeeping: 1) The permittee shall monitor and record the operating pressure drop across the fabric filters, bin

vents, and baghouses at least once every 24 hours while the plant is operating using Attachment E or an equivalent. The operating pressure drop for each control device shall be maintained within the design conditions specified under the Emission Units with Limitations section of the Installation Equipment Listing for each corresponding emission unit.

2) The permittee shall maintain an operating and maintenance log for the fabric filters, bin vents, and baghouses (Attachment Dor an equivalent) which shall include the following: a) Incidents of malfunction, with impact on emissions, duration or event, probable cause, and

corrective actions; and b) Maintenance activities, with inspection schedule, repair actions, and replacements, etc.

3) The permittee shall record all required record keeping in an appropriate format. 4) Records may be kept electronically using database or workbook systems, as long as all required

information is readily available for compliance determinations. 5) All records must be kept for a minimum of 5 years and be made available to Department of Natural

Resources' personnel upon request.

Reporting: 1) The permittee shall report any exceedance of any of the terms imposed by this permit condition, or

any malfunction which could cause an exceedance of any of the terms imposed by this permit condition, no later than ten (10) days after the exceedance or event causing the exceedance.

2) The permittee shall report any deviations from the monitoring, recordkeeping, and reporting requirements of this permit condition in the annual compliance certification as required under Section V of this permit.

3) All reports and certifications shall be submitted to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or [email protected] .gov.


PERMIT CONDITION 6.220

10 Project No. 2017-12-025

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants

Emission Sources with Visible Air Contaminants

Emission Emission Maximum

Construction Opacity Description Hourly Design

Point Unit# Rate

Date Limit

P-06 EUOOlO Elevators (2), Hopper, Bin, Vibrating

35 tons 1991 20 Feeder, & Belt Conveyors (2)

1998, Re-P-07 EU0020 Raw Material Crusher 35 tons constructed: 20

2005 P-08 EU0030 Crushed Raw Material Bins 35 tons 1966 40 P-27 EU0040 Elevator, Conveyor, and Bin 6 tons 1984 20

EP-05 EU0050 Raw Material Handling and

7 tons 1984 20 Transferring

EP-05 EU0060 (2) 12" diameter Screew Conveyors

4.5 tons 1966 40 and a Bin

P-11 EU0070 Skip Hoist And Hopper 3 tons August 30,

20 1971

P-11 EU0080 Skip Hoist And Hopper 17.5 tons 1966 40

P-11 EU0090 Mixer Feed, Hopper and 24" Belt

17.5 tons 1966 40 Conveyor

P-11 EUOlOO Mixer Feed, Hopper and 24" Belt


P-11 EUOl 10 Mixer Feed, Hopper and 24" Belt


EP-05 EU0120 Mixer Feed, Hopper and 24" Belt


P-11 EU0130 Mixer Feed, Hopper and (2) 24" Belt


P-11 EU0140 Bulk Bag Dump Station 1.3 tons 1995 20 P-09 EU0150 Ba11 Mill 4 tons 1966 20

Ba11 Mill, Ba11 Mill Feed bin, (2) Belt P-29 EU0151 Conveyors, Bucket Elevator, & #17 3 tons 2012 20

Bin Ball Mil Storage Bin

P-10 EU0180 Chute, 24" Belt Conveyor, 12" Belt

4 tons 1974 20 Elevator

P-28 EU0190 24" Belt Conveyor 6 tons 2004 20 P-27 EU0200 Green Scrap Crusher 6 tons 2004 20 P-12 EU0210 Simpson Mixer # 1 17.5 tons 1966 40 P-12 EU0220 Simpson Mixer #2 17.5 tons 1966 40 P-12 EU0230 Simpson Mixer #3 17.5 tons 1966 40 P-12 EU0240 Simpson Mixer #4 12.5 tons 1966 40

P-12 EU0250 Simpson Mixer #5 12.5 tons 1966 40

P-12 EU0260 Simpson Mixer# 6 12.5 tons 1966 40

P-11 EU0270 Batch Car 30 tons 1966 40


Emission Sources with Visible Air Contaminants

Emission Emission Maximum

Description Hourly Design Point Unit#

Rate

P-26 EU0290 Pneumatic Transport of T AF to Bin

25 tons from Supply Truck

P-20 EU0310 Williams Hammer Mill 4.5 tons EP-18 EU0320 Williams Impact Mill 3.5 tons P-16 EU0330 Tunnel Dryers; Brick Drying 10.3 tons

EP-13 & EU0340

#1, #2, #3 & #4 Tunnel Dryers Air 4.2 tons

14 Heater P-16 EU0350 Tunnel Dryers; Brick Drying 10.3 tons

P-16 EU0360 #1 Tunnel Kiln - Process 10.3 tons # 1 Tunnel Kiln - Combustion 27.955 MMBtu

P-16 EU0370 #2 Tunnel Kiln - Process 10.3 tons #2 Tunnel Kiln - Combustion 27.955 MMBtu Two (2) Vibrating Feeders, (2) 20

P-07 EU0440 Ton Bins, Elevator, and Two (2) Belt 35 tons Conveyors

P-07 EU0450 Mogensen Screen - MDL - 2056 35 tons

NIA EU0460 Pneumatic Transfer of Potters Flint

25 tons from Supply Truck to Bin

NIA EU0470 Pneumatic Transfer of M& D Ball

25 tons Clay from Supply Truck to Bin

NIA EU0480 Pneumatic Transfer of M& D Ball

2 tons Clay form Silo to Bin #7

NIA EU0490- Pneumatic Transfer of DC Bauxite 2 tons

1 Fines to Bin #8

NIA EU0490- Pneumatic Transfer of DC Clay Fines 2 tons

2 toBin#lO

Emission Limitation:

11 Project No. 2017-12-025

Construction Opacity Date Limit

1995 20

1984 20 1984 20 1966 40

1966 40

1966 40

1966 40

1966 40

1991 20

1984 20

1984 20

2011 20

2011 20

2011 20

2011 20

1. The permittee shall not cause or permit emissions to be discharged into the atmosphere from these emission units any visible emissions with an opacity greater than their corresponding opacity limits in the table above for any continuous six-minute period. [10 CSR 10-6.220(3)(A)l]

2. Exception: The permittee may discharge into the atmosphere from any emission unit visible emissions with an opacity up to 60 percent for one continuous six-minute period in any 60 minutes. [10 CSR 10-6.220(3)(A)2]

3. Failure to demonstrate compliance with 10 CSR 10-6.220(3)(A) solely because of the presences of uncombined water shall not be a violation. [10 CSR 10-6.220(3)(B)]


Monitoring: 1) Monitoring schedule:

12 Project No. 2017-12-025

a) The permittee shall conduct weekly observations for a minimum of eight consecutive weeks after permit issuance. Should no violation of this regulation be observed during this period then: i) The permittee shall conduct observations once every two weeks for a period of eight weeks.

If a violation is noted, the permittee shall revert to weekly monitoring. Should no violation of this regulation be observed during this period then: (1) The permittee shall conduct observations once per month. If a violation is noted, the

permittee shall revert to weekly monitoring. 2) If the permittee reverts to weekly monitoring at any time, the monitoring schedule shall progress in

an identical manner from the initial monitoring schedule. 3) Observations are only required when the emission units are operating and when the weather

conditions allow. 4) Issuance of a new, amended, or modified operating permit does not restart the monitoring schedule. 5) The permittee shall conduct visible emissions observation on these emission units using the

procedures contained in U.S. EPA Test Method 22. Each Method 22 observation shall be conducted for a minimum of six-minutes. If no visible emissions are observed from the emission unit using Method 22, then no Method 9 is required for the emission unit.

6) For emission units with visible emissions, the permittee shall have a certified Method 9 observer conduct a U.S. EPA Test Method 9 opacity observation. The permittee may choose to forego Method 22 observations and instead begin with a Method 9 opacity observation. The certified Method 9 observer shall conduct each Method 9 opacity observation for a minimum of 30-minutes.

Recordkeeping: 1) The permittee shall maintain records of all observation results for each emission unit using

Attachments B and C or equivalent forms. 2) The permittee shall make these records available immediately for inspection to the Department of

Natural Resources' personnel upon request. 3) The permittee shall retain all records for five years.




3) All reports and certifications shall be submitted to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or AirComplianceReporting/al,dnr .mo.gov.


13 Project No.2017-12-025

PERMIT CONDITION Tunnel Kilns

10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s)

Tunnel Kilns Emission Emission

Description Maximum Hourly Construction

Point Unit# Design Rate Date

P-16 EU0360 #1 Tunnel Kiln - Process 10.3 tons

1966 #1 Tunnel Kiln - Combustion 27.955 MMBtu

P-16 EU0370 #2 Tunnel Kiln - Process 10.3 tons

1966 #2 Tunnel Kiln - Combustion 27.955 MMBtu

Emission Limitation: 1) The permittee shall limit the production of the tunnel kilns to 90,230 tons during any consecutive 12-

month period. 2) Crude/Ball Clay Additions shall be limited to 40% maximum in the refractory mix.

Monitoring/Recordkeeping: 1) Records shall be kept on site of the amount of material processed in the kilns as well as the

percentage of rolling dry crude and ball clay tons used in the refractory mix. 2) Both monthly and the rolling 12-month totals must be shown. 3) Records may be kept electronically using database or workbook systems, as long as all required

information is readily available for compliance determinations. 4) All records must be kept for a minimum of 5 years and be made available to Department of Natural

Resources' personnel upon request.




3) All reports and certifications shall be submitted to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or AirComplianceReporting@,dnr.mo. gov.


IV. Core Permit Requirements

14 Project No. 2017-12-025

The installation shall comply with each of the following requirements: Consult the appropriate sections in the Code of Federal Regulations (CFR), the Code of State Regulations (CSR), and local ordinances for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued. The following are only excerpts from the regulation or code, and are provided for summary purposes only.

I 10 CSR 10-6.045 Open Burning Requirements 1) General Provisions. The open burning of tires, petroleum-based products, asbestos containing

materials, and trade waste is prohibited, except as allowed below. Nothing in this rule may be construed as to allow open burning which causes or constitutes a public health hazard, nuisance, a hazard to vehicular or air traffic, nor which violates any other rule or statute.

2) Certain types of materials may be open burned provided an open burning permit is obtained from the director. The permit will specify the conditions and provisions of all open burning. The permit may be revoked if the owner or operator fails to comply with the conditions or any provisions of the permit.

I 10 CSR 10-6.050 Start-up, Shutdown and Malfunction Conditions 1) In the event of a malfunction, which results in excess emissions that exceed one hour, the permittee

shall submit to the director within two business days, in writing, the following information: a) Name and location of installation; b) Name and telephone number of person responsible for the installation; c) Name of the person who first discovered the malfunction and precise time and date that the

malfunction was discovered. d) Identity of the equipment causing the excess emissions; e) Time and duration of the period of excess emissions; f) Cause of the excess emissions; g) Air pollutants involved; h) Estimate of the magnitude of the excess emissions expressed in the units of the applicable

requirement and the operating data and calculations used in estimating the magnitude; i) Measures taken to mitigate the extent and duration of the excess emissions; and j) Measures taken to remedy the situation that caused the excess emissions and the measures taken

or planned to prevent the recurrence of these situations. 2) The permittee shall submit the paragraph 1 information to the director in writing at least ten days

prior to any maintenance, start-up or shutdown activity which is expected to cause an excessive release of emissions that exceed one hour. If notice of the event cannot be given ten days prior to the planned occurrence, notice shall be given as soon as practicable prior to the activity.

3) Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under section 643.140, RSMo, the permittee may provide information showing that the excess emissions were the consequence of a malfunction, start-up or shutdown. The information, at a minimum, should be the paragraph 1 list and shall be submitted not later than 15 days after receipt of the notice of excess emissions. Based upon information submitted by the permittee or any other pertinent information available, the director or the commission shall make a determination whether the excess emissions constitute a malfunction, start-up or shutdown and whether the nature, extent and duration of the excess emissions warrant enforcement action under section 643.080 or 643.151, RSMo.


15 Project No.2017-12-025

4) Nothing in this rule shall be construed to limit the authority of the director or commission to take appropriate action, under sections 643.080, 643.090 and 643.151, RSMo to enforce the provisions of the Air Conservation Law and the corresponding rule.

5) Compliance with this rule does not automatically absolve the permittee of liability for the excess emissions reported.

j 10 CSR 10-6.060 Construction Permits Required The permittee shall not commence construction, modification, or major modification of any installation subject to this rule, begin operation after that construction, modification, or major modification, or begin operation of any installation which has been shut down longer than five years without first obtaining a permit from the permitting authority.

j 10 CSR 10-6.065 Operating Permits The permittee shall file a complete application for renewal of this operating permit at least six months before the date of permit expiration. In no event shall this time be greater than eighteen months. The permittee shall retain the most current operating permit issued to this installation on-site. The permittee shall immediately make such permit available to any Missouri Department of Natural Resources personnel upon request.

I 10 CSR 10-6.110 Reporting of Emission Data, Emission Fees and Process Information 1) The permittee shall submit a Full Emissions Report either electronically via MoEIS, which requires

Form 1.0 signed by an authorized company representative, or on Emission Inventory Questionnaire (EIQ) paper forms on the frequency specified in this rule and in accordance with the requirements outlined in this rule. Alternate methods of reporting the emissions, such as spreadsheet file, can be submitted for approval by the director.

2) Public Availability of Emission Data and Process Information. Any information obtained pursuant to the rule(s) of the Missouri Air Conservation Commission that would not be entitled to confidential treatment under 10 CSR 10-6.210 shall be made available to any member of the public upon request.

3) The permittee shall submit a full EIQ for the 2017 and 2020 reporting years. In the interim years the installation may submit a Reduced Reporting Form; however, if the installation's emissions increase or decrease by more than five tons when compared to their last submitted full EIQ, the installation shall submit a full EIQ rather than a Reduced Reporting Form.

4) In addition to the EIQ submittal schedule outlined above, any permit issued under 10 CSR 10-6.060 section (5) or (6) triggers a requirement that a full EIQ be submitted in the first full calendar year after the permitted equipment initially operates.

I 10 CSR 10-6.130 Controlling Emissions During Episodes of High Air Pollution Potential This rule specifies the conditions that establish an air pollution alert (yellow/orange/red/purple), or emergency (maroon) and the associated procedures and emission reduction objectives for dealing with each. The permittee shall submit an appropriate emergency plan if required by the Director.

I 10 CSR 10-6.150 Circumvention The permittee shall not cause or permit the installation or use of any device or any other means which, without resulting in reduction in the total amount of air contaminant emitted, conceals or dilutes an emission or air contaminant which violates a rule of the Missouri Air Conservation Commission.


j 10 CSR 10-6.165 Restriction of Emission of Odors This requirement is a State Only permit requirement.

16 Project No. 2017-12-025

No person may cause, permit or allow the emission of odorous matter in concentrations and frequencies or for durations that odor can be perceived when one volume of odorous air is diluted with seven volumes of odor-free air for two separate trials not less than 15 minutes apart within the period of one hour.

10 CSR 10-6.170 Restriction of Particulate Matter to the Ambient Air Be ond the Premises of Ori in

Emission Limitation: I) The permittee shall not cause or allow to occur any handling, transporting or storing of any material;

construction, repair, cleaning or demolition of a building or its appurtenances; construction or use of a road, driveway or open area; or operation of a commercial or industrial installation without applying reasonable measures as may be required to prevent, or in a manner which allows or may allow, fugitive particulate matter emissions to go beyond the premises of origin in quantities that the particulate matter may be found on surfaces beyond the property line of origin. The nature or origin of the particulate matter shall be determined to a reasonable degree of certainty by a technique proven to be accurate and approved by the director.

2) The permittee shall not cause nor allow to occur any fugitive particulate matter emissions to remain visible in the ambient air beyond the property line of origin.

3) Should it be determined that noncompliance has occurred, the director may require reasonable control measures as may be necessary. These measures may include, but are not limited to, the following: a) Revision of procedures involving construction, repair, cleaning and demolition of buildings and

their appurtenances that produce particulate matter emissions; b) Paving or frequent cleaning of roads, driveways and parking lots; c) Application of dust-free surfaces; d) Application of water; and e) Planting and maintenance of vegetative ground cover.

Monitoring: The permittee shall conduct inspections of its facilities sufficient to determine compliance with this regulation. If the permittee discovers a violation, the permittee shall undertake corrective action to eliminate the violation. The permittee shall maintain the following monitoring schedule: 1) The permittee shall conduct weekly observations for a minimum of eight (8) consecutive weeks after

permit issuance. 2) Should no violation of this regulation be observed during this period then-

a) The permittee may observe once every two (2) weeks for a period of eight (8) weeks. b) If a violation is noted, monitoring reverts to weekly. c) Should no violation of this regulation be observed during this period then

i) The permittee may observe once per month. ii) If a violation is noted, monitoring reverts to weekly.

3) If the permittee reverts to weekly monitoring at any time, monitoring frequency will progress in an identical manner to the initial monitoring frequency.


Recordkeeping:

17 Project No. 2017-12-025

The permittee shall document all readings on Attachment B, or its equivalent, noting the following: 1) Whether air emissions ( except water vapor) remain visible in the ambient air beyond the property

line of origin. 2) Whether equipment malfunctions contributed to an exceedance. 3) Any violations and any corrective actions undertaken to correct the violation.

I 10 CSR 10-6.180 Measurement of Emissions of Air Contaminants 1) The director may require any person responsible for the source of emission of air contaminants to

make or have made tests to determine the quantity or nature, or both, of emission of air contaminants from the source. The director may specify testing methods to be used in accordance with good professional practice. The director may observe the testing. All tests shall be performed by qualified personnel.

2) The director may conduct tests of emissions of air contaminants from any source. Upon request of the director, the person responsible for the source to be tested shall provide necessary ports in stacks or ducts and other safe and proper sampling and testing facilities, exclusive of instruments and sensing devices as may be necessary for proper determination of the emission of air contaminants.

3) The director shall be given a copy of the test results in writing and signed by the person responsible for the tests.

\ 10 CSR 10-6.280 Compliance Monitoring Usage 1) The permittee is not prohibited from using the following in addition to any specified compliance

methods for the purpose of submission of compliance certificates: a) Monitoring methods outlined in 40 CFR Part 64; b) Monitoring method(s) approved for the permittee pursuant to 10 CSR 10-6.065, "Operating

Permits", and incorporated into an operating permit; and c) Any other monitoring methods approved by the director.

2) Any credible evidence may be used for the purpose of establishing whether a permittee has violated or is in violation of any such plan or other applicable requirement. Information from the use of the following methods is presumptively credible evidence of whether a violation has occurred at an installation: a) Monitoring methods outlined in 40 CFR Part 64; b) A monitoring method approved for the permittee pursuant to 10 CSR 10-6.065, "Operating

Permits", and incorporated into an operating permit; and c) Compliance test methods specified in the rule cited as the authority for the emission limitations.

3) The following testing, monitoring or information gathering methods are presumptively credible testing, monitoring, or information gathering methods: a) Applicable monitoring or testing methods, cited in:

i) 10 CSR 10-6.030, "Sampling Methods for Air Pollution Sources"; ii) 10 CSR 10-6.040, "Reference Methods"; iii) 10 CSR 10-6.070, "New Source Performance Standards"; iv) 10 CSR 10-6.080, "Emission Standards for Hazardous Air Pollutants"; or

b) Other testing, monitoring, or information gathering methods, if approved by the director, that produce information comparable to that produced by any method listed above.

Harbison Walker International, Inc. - Fulton Brick Plant Installation ID: 027-00 IO Intermediate State Operating Permit

I 40 CFR Part 82 Protection of Stratospheric Ozone (Title VI)

18 Project No. 2017-12-025

1) The permittee shall comply with the standards for labeling of products using ozone-depleting substances pursuant to 40 CFR Part 82, Subpart E: a) All containers in which a class I or class II substance is stored or transported, all products

containing a class I substance, and all products directly manufactured with a class I substance must bear the required warning statement if it is being introduced into interstate commerce pursuant to 40 CFR §82.106.

b) The placement of the required warning statement must comply with the requirements of 40 CFR §82.108.

c) The form of the label bearing the required warning statement must comply with the requirements of 40 CFR §82.110.

d) No person may modify, remove, or interfere with the required warning statement except as described in 40 CFR §82.112.

2) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B of 40 CFR Part 82: a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices described in 40 CFR §82.156. b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply

with the standards for recycling and recovery equipment described in 40 CFR §82.158. c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by

an approved technician certification program pursuant to 40 CFR §82.161. d) Persons disposing of small appliances, MV A Cs, and MV AC-like appliances must comply with

the record keeping requirements of 40 CFR §82.166. ("MV AC-like" appliance as defined at 40 CFR §82.152).

e) Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to 40 CFR §82.156.

f) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records ofrefrigerant purchased and added to such appliances pursuant to 40 CFR §82.166.

3) If the permittee manufactures, transforms, imports, or exports a class I or class II substance, the permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A, Production and Consumption Controls.

4) If the permittee performs a service on motor (fleet) vehicles when this service involves ozonedepleting substance refrigerant ( or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements contained in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term "MV AC" as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or system used on passenger buses using HCFC-22 refrigerant.

5) The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program. Federal Only - 40 CFR Part 82.


V. General Permit Requirements

19 Project No.2017-12-025

The installation shall comply with each of the following requirements. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued.

j 10 CSR 10-6.065, §(5)(C)l, §(6)(C)l.B, §(5)(E)2.C Permit Duration This permit is issued for a term of five years, commencing on the date of issuance. This permit will expire at the end of this period unless renewed. If a timely and complete application for a permit renewal is submitted, but the Air Pollution Control Program fails to take final action to issue or deny the renewal permit before the end of the term of this permit, this permit shall not expire until the renewal permit is issued or denied.

10 CSR 10-6.065, §(5)(C)l and §(6)(C)l.C General Record Keeping and Reporting Re uirements

1) Record Keeping a) All required monitoring data and support information shall be retained for a period of at least

five years from the date of the monitoring sample, measurement, report or application. b) Copies of all current operating and construction permits issued to this installation shall be kept

on-site for as long as the permits are in effect. Copies of these permits shall be made immediately available to any Missouri Department of Natural Resources' personnel upon request.

2) Reporting a) All reports shall be submitted to the Air Pollution Control Program, Compliance and

Enforcement Section, P. 0. Box 176, Jefferson City, MO 65102. b) The permittee shall submit a report of all required monitoring by:

i) April 1st for monitoring which covers the January through December time period. ii) Exception. Monitoring requirements which require reporting more frequently than annually

shall report no later than 30 days after the end of the calendar quarter in which the measurements were taken.

c) Each report shall identify any deviations from emission limitations, monitoring, record keeping, reporting, or any other requirements of the permit.

d) Submit supplemental reports as required or as needed. All reports of deviations shall identify the cause or probable cause of the deviations and any corrective actions or preventative measures taken. i) Notice of any deviation resulting from an emergency ( or upset) condition as defined in

paragraph (6)(C)7.A of 10 CSR 10-6.065 (Emergency Provisions) shall be submitted to the permitting authority either verbally or in writing within two working days after the date on which the emission limitation is exceeded due to the emergency, if the permittee wishes to assert an affirmative defense. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that indicate an emergency occurred and the permittee can identify the cause(s) of the emergency. The permitted installation must show that it was operated properly at the time and that during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or requirements in the permit. The notice must contain a description of the emergency, the steps taken to mitigate emissions, and the corrective actions taken.


20 Project No. 2017-12-025

ii) Any deviation that poses an imminent and substantial danger to public health, safety or the environment shall be reported as soon as practicable.

iii) Any other deviations identified in the permit as requiring more frequent reporting than the permittee's semiannual report shall be reported on the schedule specified in this permit.

e) Every report submitted shall be certified by the responsible official, except that, if a report of a deviation must be submitted within ten days after the deviation, the report may be submitted without a certification if the report is resubmitted with an appropriate certification within ten days after that, together with any corrected or supplemental information required concerning the deviation.

f) The permittee may request confidential treatment of information submitted in any report of deviation.

I 10 CSR 10-6.065(6)(C)l.D Risk Management Plan Under Section 112(r) If the installation is required to develop and register a risk management plan pursuant to Section l l 2(R) of the Act, the permittee will verify that it has complied with the requirement to register the plan.

I 10 CSR 10-6.065(6)(C)l.G General Requirements 1) The permittee must comply with all of the terms and conditions of this permit. Any noncompliance

with a permit condition constitutes a violation and is grounds for enforcement action, permit termination, permit revocation and re-issuance, permit modification or denial of a permit renewal application.

2) The permittee may not use as a defense in an enforcement action that it would have been necessary for the permittee to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit

3) The permit may be modified, revoked, reopened, reissued or terminated for cause. Except as provided for minor permit modifications, the filing of an application or request for a permit modification, revocation and reissuance, or termination, or the filing of a notification of planned changes or anticipated noncompliance, does not stay any permit condition.

4) This permit does not convey any property rights of any sort, nor grant any exclusive privilege. 5) The permittee shall furnish to the Air Pollution Control Program, upon receipt of a written request

and within a reasonable time, any information that the Air Pollution Control Program reasonably may require to determine whether cause exists for modifying, reopening, reissuing or revoking the permit or to determine compliance with the permit. Upon request, the permittee also shall furnish to the Air Pollution Control Program copies of records required to be kept by the permittee. The permittee may make a claim of confidentiality for any information or records submitted under this rule.

6) Failure to comply with the limitations and conditions that qualify the installation for an Intermediate permit make the installation subject to the provisions of 10 CSR 10-6.065(6) and enforcement action for operating without a valid part 70 operating permit.

j 10 CSR 10-6.065(6)(C)l.I Reasonably Anticipated Operating Scenarios None.

10 CSR 10-6.065, §(5)(B)4; §(S)(C)l, §(6)(C)3.B; and §(6)(C)3.D; and §(5)(C)3 and §(6)(C)3.E.(I) - III and V - VI Com liance Re uirements

1) Any document (including reports) required to be submitted under this permit shall contain a certification signed by the responsible official.


21 Project No. 2017-12-025

2) Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized officials of the Missouri Department of Natural Resources, or their authorized agents, to perform the following (subject to the installation's right to seek confidential treatment of information submitted to, or obtained by, the Air Pollution Control Program): a) Enter upon the premises where a permitted installation is located or an emissions-related activity

is conducted, or where records must be kept under the conditions of this permit; b) Have access to and copy, at reasonable times, any records that must be kept under the conditions

of this permit; c) Inspect, at reasonable times and using reasonable safety practices, any facilities, equipment

(including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; and

d) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the Act, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the terms of this permit, and all applicable requirements as outlined in this permit.

3) All progress reports required under an applicable schedule of compliance shall be submitted semiannually ( or more frequently if specified in the applicable requirement). These progress reports shall contain the following: a) Dates for achieving the activities, milestones or compliance required in the schedule of

compliance, and dates when these activities, milestones or compliance were achieved, and b) An explanation of why any dates in the schedule of compliance were not or will not be met, and

any preventative or corrective measures adopted. 4) The permittee shall submit an annual certification that it is in compliance with all of the federally

enforceable terms and conditions contained in this permit, including emissions limitations, standards, or work practices. These certifications shall be submitted annually by April 1st, unless the applicable requirement specifies more frequent submission. These certifications shall be submitted to EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219, as well as the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and Part 64 exceedances and excursions must be included in the compliance certifications. The compliance certification shall include the following: a) The identification of each term or condition of the permit that is the basis of the certification; b) The current compliance status, as shown by monitoring data and other information reasonably

available to the installation; c) Whether compliance was continuous or intermittent; d) The method(s) used for determining the compliance status of the installation, both currently and

over the reporting period; and e) Such other facts as the Air Pollution Control Program will require in order to determine the

compliance status of this installation.

J 10 CSR 10-6.065(6)(C)7 Emergency Provisions 1) An emergency or upset as defined in 10 CSR 10-6.065(6)(C)7.A shall constitute an affirmative

defense to an enforcement action brought for noncompliance with technology-based emissions limitations. To establish an emergency- or upset-based defense, the permittee must demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, the following: a) That an emergency or upset occurred and that the permittee can identify the source of the

emergency or upset, b) That the installation was being operated properly,


22 Project No. 2017-12-025

c) That the permittee took all reasonable steps to minimize emissions that exceeded technologybased emissions limitations or requirements in this permit, and

d) That the permittee submitted notice of the emergency to the Air Pollution Control Program within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective actions taken.

2) Be aware that an emergency or upset shall not include noncompliance caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error.

j 10 CSR 10-6.065(5)(C)5 Off-Permit Changes 1) Except as noted below, the permittee may make any change in its permitted operations, activities or

emissions that is not addressed in, constrained by or prohibited by this permit without obtaining a permit revision. Off-permit changes shall be subject to the following requirements and restrictions: a) The change must meet all applicable requirements of the Act and may not violate any existing

permit term or condition; the permittee may not change a permitted installation without a permit revision if this change is a Title I modification; Please Note: Changes at the installation which affect the emission limitation(s) classifying the installation as an intermediate source (add additional equipment to the record keeping requirements, increase the emissions above major source level) do not qualify for off-permit changes.

b) The permittee must provide contemporaneous written notice of the change to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219. This written notice shall describe each change, including the date, any change in emissions, pollutants emitted and any applicable requirement that would apply as a result of the change; and

c) The permittee shall keep a record describing all changes made at the installation that result in emissions of a regulated air pollutant subject to an applicable requirement and the emissions resulting from these changes.

j 10 CSR 10-6.020(2)(R)34 Responsible Official The application utilized in the preparation of this permit was signed by Thomas L. Raught, Director, Corporate EHS. If this person terminates employment, or is reassigned different duties such that a different person becomes the responsible person to represent and bind the installation in environmental permitting affairs, the owner or operator of this air contaminant source shall notify the Director of the Air Pollution Control Program of the change. Said notification shall be in writing and shall be submitted within 30 days of the change. The notification shall include the name and title of the new person assigned by the source owner or operator to represent and bind the installation in environmental permitting affairs. All representations, agreement to terms and conditions and covenants made by the former responsible person that were used in the establishment of limiting permit conditions on this permit will continue to be binding on the installation until such time that a revision to this permit is obtained that would change said representations, agreements and covenants.


23 Project No. 2017-12-025

I to CSR 10-6.065, §(5)(E)4 and §(6)(E)6.A(III)(a)-(c) Reopening-Permit for Cause This permit shall be reopened for cause if: 1) The Missouri Department of Natural Resources (MoDNR) or the Environmental Protection Agency

(EPA) determines that the permit contains a material mistake or that inaccurate statements were made which resulted in establishing the emissions limitation standards or other terms of the permit,

2) Additional applicable requirements under the Act become applicable to the installation; however, reopening on this ground is not required if-: a) The permit has a remaining term of less than three years; b) The effective date of the requirement is later than the date on which the permit is due to expire;

or c) The additional applicable requirements are implemented in a general permit that is applicable to

the installation and the installation receives authorization for coverage under that general permit, 3) MoDNR or EPA determines that the permit must be reopened and revised to assure compliance with

applicable requirements.

I to CSR 10-6.065(6)(E)l.C Statement of Basis This permit is accompanied by a statement setting forth the legal and factual basis for the permit conditions (including references to applicable statutory or regulatory provisions). This Statement of Basis, while referenced by the permit, is not an actual part of the permit.

VI. Attachments

Attachments follow.


Attachment A Fugitive Emission Observations

24 Project No. 2017-12-025

Visible Excess Emissions

Emissions Date Time

Emission Source

No Yes1 Cause Corrective Action Initial

1 lf there are visible emissions, the permittee shall complete the excess emissions columns.


Attachment B

Installation Name Observer Name

Location Date

Sky Conditions Wind Direction

Precipitation Wind Speed

Time Emission unit

25 Project No. 2017-12-025

Sketch emission unit: indicate observer position relative to emission unit; indicate potential emission points and/or actual emission points.

2 3 4 5 6

If visible emissions are observed, the installation is not required to complete the entire six-minute observation. The installation shall note when the visible emissions were observed and shall conduct a Method 9 opacity observation.


Attachment C

26 Project No. 2017-12-025

.. : . ;:< . ·:·:• ·/:'.(::•: .. •" .,;.;:~:' :;:(\;:: .j:)fi :); .• >:),::,:: : .... :,• i;i ;,,,

,;;l:i .r,. • ' 'i\ .. ' irifi~. // ':t<;:\ ;;:;;;:,(;:;e:;:,I'? .. ,. . .... : ... .··• ·:,;':+; ii ,;;::·! :.: .. :·: ·.:.• ·, . ,, .'••• .. , .. · .: - · .. '..'\'>'.' .. ,:: .. :,: .'e~;!~:: i':!'.>\., .•. ".':;'.:';,J1t;'::'.v,;>•t\'.:ri>;, :,;1;;,1 <··: f :'.ii+:;'\; ;.;;J f ,:,·:,l'.1>1

•'

Installation Name: Sketch of the observer's position relative to the emission unit

Emission Point:

Emission Unit:

Observer Name and Affiliation:

Observer Certification Date:

Method 9 Observation Date:

Height of Emission Point:

Time: Start of observations

Distance of Observer from Emission Point: Observer Direction from Emission Point: Approximate Wind Direction: Estimated Wind Speed: Ambient Temperature: Description of Sky Conditions (Presence and color of clouds): Plume Color: Approximate Distance Plume is Visible from Emission Point:

.. i ,",j

,:<(:;\}::::/''., ' , •s . d : . > >1; . , ; • 1-minuteC,; 6+;'tnintite Steam Plume (cHeck if :ijl~tii~! ,• : • ·. econ s ... .. . . : , . : :.· .: o 'Ji!J ·., 15 i SQ]:(': <145 , ' \ .. 1xt;*Jt; :.,;y,,,<r ··.~

\ applicable) ?Avg.% , Y" ':Qpacity,Re~folings '(% ,Qpaqity)t · : i.) Qpaci~· Attached Detached i .. ,: :·'.,::: ••'• :;·:. :// ·. Qp/3,qljy;,,:

0 NIA 1 NIA 2 NIA 3 NIA 4 NIA 5 6 7 8 9 10 11 12 13 14

2 I-minute avg.% opacity is the average of the four 15 second opacity readings during the minute. 3 6-minute avg.% opacity is the average of the six most recent I-minute avg.% opacities. 4 Each 15 second opacity reading shall be recorded to the nearest 5% opacity as stated within Method 9.

End of observations

I/ rnmtn~)~~:/t ,<,;,:.c)tH/i1i' '· .J:>r:


15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

27 Project No. 2017-12-025

The emission unit is in compliance if each six-minute average opacity is less than or equal to 20/40 %. Exception: The emission unit is in compliance if one six-minute average opacity is greater than 20/40 %, but less than 60 %.

Was the emission unit in compliance at the time of evaluation (yes or no)? ----

Signature of Observer


Emission Unit#

Attachment D Inspection/Maintenance/Repair/Malfunction Log

------------------

28 Project No.2017-12-025


Emission Point / Date

Control Device

Attachment E Pressure Drop Monitoring

Pressure DrQp (w.c.)

29 Project No. 2017-12-025

Specified Pressure Drop Within

Specifications? Range (w.c.) (Yes/No)


STATEMENT OF BASIS Voluntary Limitations

SB - 1 Project No. 2017-12-025

In order to qualify for this Intermediate State Operating Permit, the permittee has accepted voluntary, federally enforceable emission limitations. Per 10 CSR 10-6.065(5)(C)l.A.(VI), if these limitations are exceeded, the installation immediately becomes subject to 10 CSR 10-6.065(6) and enforcement action for operating without a valid part 70 operating permit. It is the permittee's responsibility to monitor emission levels and apply for a part 70 operating permit far enough in advance to avoid this situation. This may mean applying more than eighteen months in advance of the exceedance, since it can take that long or longer to obtain a part 70 operating permit.

Installation Description Harbison Walker International, Inc. - Fulton Brick Plant is a manufacturer of high alumina brick, used in the working linings of steel making furnaces such as electric arc furnaces and steel ladles, rotary kilns used in the manufacture of cement and quick lime and many other applications where heat needs to be contained. The plant activities include the crushing, grinding and screening of raw materials, batching, pressing, firing, packaging and shipment of finished goods to the customer. This installation is not a Named Source.

The installation has accepted multiple voluntary limitations. Under Plantwide Limitations, Permit Condition Controls has been accepted by the permittee to make the required use of all control devices at the installation federally enforceable. This condition requires overall control of PM emissions exceeding 90% allowing the emission units to meet the exemption in 10 CSR 10-6.400(1 )(A) 15. Under Emission Unit Specific Limitations, Permit Condition Tunnel Kilns has two voluntary limitations that have been accepted by the permittee. The first limits the production rate of the Tunnel Kilns (P-16) to prevent criteria pollutants from having potential emissions above applicable major threshold values for operating permits. The second limits the emissions of HAPs, specifically HF and HCL, to below major levels.

The following table lists emission potentials as well as actual emissions from the last five years for each corresponding criteria pollutant:

Emi . SSIOnS s t ummary, ons per year

Pollutants Potential Reported Emissions

Emissions1 2017 2016 2015 2014 2013 Particulate Matter (PM10) 49.78 12.18 10.59 22.70 26.12 25.19

Particulate Matter (PM2.s) 35.49 6.72 5.90 12.76 14.61 14.00 Sulfur Oxides (SOx) 35.28 7.68 6.84 14.91 16.98 16.15

Nitrogen Oxides (NOx) 30.79 3.78 3.10 6.74 7.67 7.29 Volatile Organic

3.51 0.25 0.21 0.46 0.53 0.50 Compounds (VOC)

Carbon Monoxide (CO) 66.73 12.09 10.54 22.98 26.16 24.88 Hazardous Air Pollutants

2.18 0.30 0.26 0.57 0.65 0.62 (HAP)

1Each emission unit was evaluated at 8,760 hours of uncontrolled annual operation.


SB -2 Project No.2017-12-025

Potential emissions were calculated for each criteria pollutant that can be emitted from all non-fugitive emission units at the installation. The following table details the emission factor sources for each emission point:

Emission Emission Point Pollutants

Emission Factor (EF) EF: Contr. Notes

Point# Information Source(s) Vs Uncontr.

Barmac Crusher & PM&PM10 AP-42 Table 11.3-1 Controlled

P-07 Screen System PM2.s

AP-42 Appendix B Table NIA 15% of 2.2 Category 3 PM

Crushed Material Storage PM&PM10 AP-42 Table 11.3-1 Controlled

P-08 AP-42 Appendix B Table 15% of Bins PM2s 2.2 Category 3

NIA PM

PM&PM10 AP-42 Table 11.3-1 Controlled P-09 Ball Mill

PM2s AP-42 Appendix B Table NIA 15% of 2.2 Category 3 PM

PM&PM10 AP-42 Table 11.3-1 Controlled P-10 Ball Mill Storage Bins


PM&PM10 AP-42 Table 11.3-1 Controlled P-11 Batching


PM&PM10 AP-42 Table 11.3-1 Controlled P-12 Dry Press Mixing


PM&PM10 AP-42 Table 11.3-1 Controlled P-13 Dry Press Forming

PM2.s AP-42 Appendix B Table NIA 15% of 2.2 Category 3 PM

VOC&PM AP-42 Table 11.3-1 Uncontrolled PMlO:

Dryers PM10 & PM2.s

AP-42 Appendix B Table Uncontrolled

51%PM 2.2 Category 3 PM2.5:

15%PM CO,NOx,&

AP-42 Table 11.3-3 Uncontrolled SOx

Process HAPs AP-42 Tables 11.3-6 & 7 Uncontrolled PM&PM10 AP-42 Table 11.3-1 Uncontrolled

P-16 PM2s


Tunnel CO&NOx AP-42 Table 1.4-1 Uncontrolled Kiln HAPs AP-42 Table 1.4-3 Uncontrolled

SOx, VOC, & AP-42 Table 1.4-2 Uncontrolled

Natural Gas PM Combustion PMlO:

PM10 & PM2s AP-42 Appendix B Table

Uncontrolled 79%PM

2.2; Category 2 PM2.5: 45%PM

Williams PM&PM10 AP-42 Table 11.3-1 Controlled

P-20 Mill

Process PM2s



Emission Emission Point Pollutants

Emission Factor (EF) Point# Information Source(s)

CO&NOx AP-42 Table 1.4-1 HAPs AP-42 Table 1.4-3 SOx, VOC, &

AP-42 Table 1.4-2 Natural Gas PM Combustion

PM10 & PM2.s AP-42 Appendix B Table 2.2; Category 2

Air Transport Storage PM& PM10 AP-42 Table 11.3-1

P-26 AP-42 Appendix B Table Bins PM2s 2.2 Category 3

PM& PM10 AP-42 Table 11.3-1 P-27 Green Scrap System

PM2.s AP-42 Appendix B Table 2.2 Category 3

PM&PM10 AP-42 Table 11.3-1 P-28 Green Scrap System Bins

PM2.s AP-42 Appendix B Table 2.2 Category 3

PM&PM10 AP-42 Table 11.3-1 P-29 West Ball Mill

PM2s AP-42 Appendix B Table 2.2 Category 3

P-30 3 Conveyors PM,PM10,& AP-42 Table 11.19.2-2 PM2s

P-31 West Ball Mill Feed Bin PM, PM10, &

AP-42 Table 11.19.2-2 PM2.s

P-32 West Ball Mill Storage PM,PM10,& AP-42 Table 11.19.2-2 Bin PM2s

VOC&PM AP-42 Table 11.3-1

EP-13 & EP-14

Air Heater PM10 & PM2s

AP-42 Appendix B Table 2.2 Category 3

VOC&PM AP-42 Table 11.3-1

EP-18 Air Heater PM10 & PM2s

AP-42 Appendix B Table 2.2 Category 3

CO&NOx AP-42 Table 1.4-1 HAPs AP-42 Table 1.4-3 SOx, VOC, &

AP-42 Table 1.4-2 Heaters

Water Heaters & Space PM Heaters -Natural Gas

PM10 & PM2.s AP-42 Appendix B Table 2.2; Category 2

SB - 3 Project No. 2017-12-025

EF: Contr. Notes

Vs Uncontr. Uncontrolled Uncontrolled

Uncontrolled

PMlO:

Uncontrolled 79%PM PM2.5: 45%PM

Controlled 15% of NIA PM

Controlled

NIA 15% of PM

Controlled

NIA 15% of PM

Controlled

NIA 15% of PM

Controlled

Controlled

Controlled

Uncontrolled PMlO:


Uncontrolled PMlO:


Uncontrolled Uncontrolled

Uncontrolled

PMlO:



Permit Reference Documents

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These documents were relied upon in the preparation of the operating permit. Because they are not incorporated by reference, they are not an official part of the operating permit.

1) Intermediate Operating Permit Application, received December 11, 2017; 2) 2017 Emissions Inventory Questionnaire, received April 19, 2018; and 3) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition. 4) All document referenced in Construction Permits History section

Applicable Requirements Included in the Operating Permit but Not in the Application or Previous Operating Permits In the operating permit application, the installation indicated they were not subject to the following regulation(s). However, in the review of the application, the agency has determined that the installation is subject to the following regulation(s) for the reasons stated.

None.

Other Air Regulations Determined Not to Apply to the Operating Permit The Air Pollution Control Program (APCP) has determined the following requirements to not be applicable to this installation at this time for the reasons stated.

10 CSR 10-6.100, Alternate Emission Limits This rule is not applicable because the installation is in an ozone attainment area.

10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds This regulation was rescinded from Missouri Code of State Regulations on November 30, 2015 but it remains in Missouri's SIP and thus still remains an applicable federal regulation. Upon adoption of 10 CSR 10-6.261 into Missouri's SIP, 10 CSR 10-6.260 will be removed from the SIP and thus this rule will no longer be applicable to the installation.

This rule does not apply to EU00320 (Air Heater for Williams Hammer Mill), EU0340 (Air Heater for Tunnel Dryers), EU0360 (#1 Tunnel Kiln), EU0370 (#2 Tunnel Kiln), all water heaters, and all space heaters are all fueled by natural gas. [10 CSR 10-6.260(l)(A)2]

10 CSR 10-6.261 Control of Sulfur Dioxide Emissions This rule does not apply to EU00320 (Air Heater for Williams Hammer Mill), EU0340 (Air Heater for Tunnel Dryers), EU0360 (#1 Tunnel Kiln), EU0370 (#2 Tunnel Kiln), all water heaters, and all space heaters are all fueled by natural gas. [10 CSR 10-6.26l(l)(A)]


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10 CSR 10-6.400 Restriction of Emission of Particulate Matter From Industrial Processes This rule does not apply to any of the processes at this installation because they all have an uncontrolled potential to emit particulate matter below allowable emissions based on process weight. [ 10 CSR 10-6.400(1 )(B) 16] Calculations demonstrating compliance follow:

PM Emission limit:

E=4.l(P)067

E = 55(P )011 - 40

(P :S 30)

(P > 30)

P is process weight rate in tons/hour and E is emission rate limit in lb/hour

Potential PM Emission Rate: Emission Rate (lb/hr)= Process Weight Rate (ton/hr)*PM Emission Factor (lb/ton)

Emission Process

Emission Emission Calculated

Emission Unit

Unit Weight Factor Factor

Uncontrolled Limit

ID# Description Rate

(lbs/ton) SCC5 Emission Rate (lbs/hr)

(tons/hr) (lbs/hr)

EP-18 EU0320 Air

3.5 3-05-

0.65 9.49 Heater 003-50 Tunnel

3-05-P-16 EU0330 Dryers #1 10.30

003-50 1.93 19.56

&#2 EP-13 &

EU0340 Air

4.20 3-05-

0.79 10.72 14 Heater 003-50

Tunnel 3-05-

P-16 EU0350 Dryers #3 10.30 003-50

1.93 19.56 &#4

Tunnel

EU0360 & Kiln

3-05-P-16

EU0370 Drying & 10.30

003-11 8.76 19.56

Burning -Process

Is EU in

compliance?

Yes

Yes

Yes

Yes

Yes

The following emission units listed in the table on the next page are exempt because their control devices capture 100 percent of particulate matter as well as control for over 90 percent of particulate matter. [10 CSR 10-6.400(1)(A)15.]

5 All Emission Factors obtained from AP-42 Table 11.3-1.


Emission Unit Description EUOOlO Transfer Equipment EU0020 VS! Crusher EU0030 Bin EU0040 Transfer Equipment EU0050 Air Transporter EU0060 Transfer Equipment EU0070 Transfer Equipment EU0080 Transfer Equipment EU0090 Transfer Equipment EUOlOO Transfer Equipment EUOl 10 Transfer Equipment EU0120 Transfer Equipment EU0130 Transfer Equipment EU0140 Bulk Bag Dump Station EU0150 East Ball Mill EU0151 West Ball Mill EU0180 Transfer Equipment EU0190 Transfer Equipment EU0200 Crusher EU0210 Mixer 1 EU0220 Mixer 2 EU0230 Mixer 3 EU0240 Mixer 4 EU0250 Mixer 5 EU0260 Mixer 6 EU0270 Batch Car

EU0290 Air Transporter EU0310 Hammer Mill EU0440 Transfer Equipment

EU0450 Screen

EU0460 Air Transport

EU0470 Air Transport Bin Vent M&D Ball Clay Silo Truck Delivery EU0480 Air Transport M&D Ball Clay Silo Bin #7

EU0490-l Air Transport Bin Vent Bauxite Fines Bin #8 EU0490-2 Air Transport Bin Vent Clay Fines Bin #10

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Control Efficiency (%) 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98 98

This rule does not apply to the remaining emission points because they are fugitive sources and are thus exempt under 10 CSR 10.400(l)(A)7. or they are excluded from applicability via the Process Weight definition.

10 CSR 10-6.405 Restriction of Particulate Matter Emissions From Fuel Burning Equipment Used For Indirect Heating EU00320 (Air Heater for Williams Hammer Mill), EU0340 (Air Heater for Tunnel Dryers), EU0360 (#1 Tunnel Kiln), EU0370 (#2 Tunnel Kiln), all water heaters, and all space heaters are all fueled by natural gas. These emission points are the installation's only indirect heating sources. Therefore, the installation is exempt. [10 CSR 10-6.405(1)(E)]


Construction Permit History Construction Permit 0185-003, issued January 15, 1985:

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This construction permit authorized the construction of a coking oven to heat tar impregnated brick. This coking oven has been removed from the installation.

Construction Permit 0585-002, issued May 9, 1985: This construction permit authorized the construction of a brick impregnation facility consisting of a brick impregnation system, brick cleaning system, and pallet cleaning system. The pollution control equipment included a direct flame incinerator for odor and VOC control and baghouses for particulate. All of these emission units have been removed from the installation.

Construction Permit 1090-009, Issued October 24, 1990: This construction permit authorized the construction of a coking oven to heat tar impregnated brick. This Coking Oven, Emission Unit EU0400, has been removed from the installation. Therefore, the special conditions of this construction permit were not included in the operating permit.

Construction Permit 0895-020, Issued July 20, 1995: This construction permit authorized the installation of a reconditioned Nordber 36' Gyradisc Crusher. This crusher was replaced by the Barmac Crusher (EU0020) in 1998 (as authorized by Construction

Permit 1098-020, Issued October 15, 1998). Therefore, the special conditions in this permit were not included in the operating permit.

Construction Permit 1095-029, Issued September 14, 1995: This construction permit authorized the installation of a new coking pan cleaner booth designed to shot blast pitch residue off of stainless steel pans used in coking oven. This Pan Cleaner has been removed from the installation. Therefore, the special condition of this construction permit were not included in the operating permit.

No Construction Permit Required Project 0270010014, issued November 17, 1997: This no construction permit determination was made for the replacement of several dust collectors with those of higher control efficiencies.

Construction Permit 1098-020, issued October 23, 1998: This construction permit authorized the installation of a ball mill and replacement of an existing gyro disc crusher (30 tons/hr) with a vertical shaft crusher (35 tons/hr). One mixer (12.5 tons/hr) was replaced with a 17.5 tons/hr mixer. A batch car was also replaced with an automated car with 1,200 cfrn dust collector. This construction permit applied NSPS Subpart 000 to Emission Unit EU0020 the VSI Crusher. It was determined that this Subpart does not apply to this installation (see New Source Performance Standards (NSPS) Applicability below). Therefore, the special condition of this construction permit were not included in the operating permit.

No Construction Permit Required Project 1998-09-048, issued September 16, 2018: This no construction permit determination was made for the like-kind replacements of 3 brick presses.


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No Construction Permit Required Project 2003-09-059, issued November 3, 2003: This no construction permit determination was made for the installation of two 20-ton surge bins, two vibrating feeders, a bucket elevator and a dust collection system, as well as the replacement of two existing vibrating conveyors with two belt conveyors. No Construction Permit Required Project 2005-05-071, issued August 2, 2005: This no construction permit determination was made for the replacement of an aging, Barmac crusher with a new REMco SandMax 200-ST, VSI crusher.

Construction Permit 012011-013, issued January 25, 2011: This construction permit authorized the installation of a new 6, 100 cubic foot M&D Ball Clay Silo (EU04 70), an M&D ball clay air transporter system with a receiving silo bin vent (EU0480) and a dust collector fines powder pump transport system with two material receiver vents (EU0490- l and EU490-2). This construction permit has special conditions; however, Permit Condition Controls adapts these same conditions to apply to the emission points installed under this construction permit as well as additional emission points.

Construction Permit 052011-012, issued May 27, 2011: This construction permit authorized the refurbishing of a 3 ton per hour ball mill (P-29) as well as the installation of new material handling equipment for the ball mill plus a dust collector (EP-35). This construction permit has special conditions; however, Permit Condition Controls adapts these same conditions to apply to the emission points installed under this construction permit as well as additional emission points.

No Construction Permit Required Project 2012-10-073, issued December 7, 2012: This no construction permit determination was made for the installation of a fogging product recovery System.

New Source Performance Standards (NSPS) Applicability 40 CFR Part 60 Subpart 000, Standards of Performance for Nonmetallic Mineral Processing Plants. This subpart does not apply to the installation. The subpart defines "Nonmetallic Mineral" as follows: Nonmetallic mineral means any of the following minerals or any mixture of which the majority is any of the following minerals: 1) Crushed and Broken Stone, including

Limestone, Dolomite, Granite, Traprock, Sandstone, Quartz,Quartzite, Marl, Marble, Slate, Shale, Oil Shale, and Shell.

2) Sand and Gravel. 3) Clay including Kaolin, Fireclay, Bentonite,

Fuller's Earth, Ball Clay, and Common Clay.

4) Rock Salt. 5) 6)

Gypsum. Sodium Compounds, including Sodium Carbonate, Sodium Chloride, and Sodium Sulfate.

7) Pumice.

8) Gilsonite. 9) Talc and Pyrophyllite. 10) Boron, including Borax, Kernite, and

Colemanite. 11) Barite. 12) Fluorospar. 13) Feldspar. 14) Diatomite. 15) Perlite. 16) Vermiculite. 17) Mica. 18) Kyanite, including Andalusite, Sillimanite,

Topaz, and Dumortierite.


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The materials processed at this installation in the VSI Crusher (EU0020) and associated equipment are 20% clays, 70% bauxites, and 10% BAT which is brick that has been rejected due to quality issues and has the same makeup as the other processed materials. Since these processed materials do not meet the definition of Nonmetallic Minerals, this Subpart was not applied to these emission units. The Small Crusher (EU0200) processes only clay which meets the definition of Nonmetallic Mineral, however §60.670(c)(3) exempts common clay plants and pumice plants with capacities, as defined in §60.671, of nine megagrams per hour (10 tons per hour) or less. The capacity of this crusher is only 4.5 tons/hour; therefore, it is not subject to Subpart 000.

Maximum Achievable Control Technology (MACT) Applicability None.

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability In the permit application and according to APCP records, there was no indication that any Missouri Air Conservation Law, Asbestos Abatement, 643.225 through 643.250; 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants, Subpart M, National Standards for Asbestos; and 10 CSR 10-6.250, Asbestos Abatement Projects - Certification, Accreditation, and Business Exemption Requirements apply to this installation. The installation is subject to these regulations if they undertake any projects that deal with or involve any asbestos containing materials. None of the installation's operating projects underway at the time of this review deal with or involve asbestos containing material. Therefore, the above regulations were not cited in the operating permit. If the installation should undertake any construction or demolition projects in the future that deal with or involve any asbestos containing materials, the installation must follow all of the applicable requirements of the above rules related to that specific project.

Greenhouse Gas Emissions This source may be subject to the Greenhouse Gas Reporting Rule. However, the preamble of the GHG Reporting Rule clarifies that Part 98 requirements do not have to be incorporated in operating permits at this time. In addition, Missouri regulations do not require the installation to report CO2 emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2 emissions were not included within this permit. If required to report, the applicant is required to report the data directly to EPA. The public may obtain CO2 emissions data by visiting http://epa.gov/ ghgreporting/ ghgdata/reportingdatasets .html.


Other Regulatory Determinations

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The Railcar Unloading to the Hopper (P-02) and the Rotary Dryer (P-05) have not been operated in more than 5 years. They are still listed in this permit because it is still present at the installation. If the permittee wishes to use these emission points in the future, they must submit to the Air Pollution Control Program applicability determinations for (a) permit(s) to construct to re-install the emission point(s).

The # 1 Tunnel Kiln (P-16), emission unit EU0360, has also not been operated in more than 5 years. It is still listed in this permit because it is still present at the installation. If the permittee wishes to use this emission point in the future, they must obtain a permit to construct to re-install this emission point. This emission unit has applicable regulations/permit conditions (see Permit Condition 6.220 & Permit Condition Tunnel Kilns). These regulations/permit conditions do not apply to the emission unit at the time of this operating permit being issued. However, if a construction permit is obtained for this emission unit to be re-installed, the applicable regulations/permit conditions will apply.

The installation previously had a 563-gallon gasoline tank. This tank has been removed from the installation and is thus not referenced elsewhere in this operating permit.

Other Regulations Not Cited in the Operating Permit or the Above Statement of Basis Any regulation which is not specifically listed in either the Operating Permit or in the above Statement of Basis does not appear, based on this review, to be an applicable requirement for this installation for one or more of the following reasons: 1. The specific pollutant regulated by that rule is not emitted by the installation; 2. The installation is not in the source category regulated by that rule; 3. The installation is not in the county or specific area that is regulated under the authority of that rule; 4. The installation does not contain the type of emission unit which is regulated by that rule; 5. The rule is only for administrative purposes.

Should a later determination conclude that the installation is subject to one or more of the regulations cited in this Statement of Basis or other regulations which were not cited, the installation shall determine and demonstrate, to the APCP's satisfaction, the installation's compliance with that regulation(s). If the installation is not in compliance with a regulation which was not previously cited, the installation shall submit to the APCP a schedule for achieving compliance for that regulation(s).


Response to Public Comments

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The draft Intermediate State Operating Permit for Harbison Walker International, Inc. - Fulton Brick Plant (027-0010) was placed on public notice as of June 22, 2018 for a 30-day comment period. The public notice was published on the Department of Natural Resources' Air Pollution Control Program's web page at: http://dnr.mo.gov/env/apcp/permit-public-notices.htm.

No comments were received.

Michael L. Parson, Governor

AUG O 6 2018 Mr. Thomas L. Raught Harbison Walker International, Inc. - Fulton Brick Plant P.O. Box 460 Fulton, MO 65251

Re: Harbison Walker International, Inc. - Fulton Brick Plant, 027-0010 Permit Number: OP2018-068

Dear Mr. Raught:

Carol S. Comer, Director

Enclosed with this letter is your intermediate operating permit. Please review this document carefully. Operation of your installation in accordance with the rules and regulations cited in this document is necessary for continued compliance. It is very important that you read and understand the requirements contained in your permit.

This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CAV) can be set up with you. To request a CA V, please contact your local regional office or fill out an online request. The regional office contact information can be found at http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo.gov/cav/compliance.htm.

You may appeal this permit to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.078.16 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.

If you have any questions or need additional information regarding this permit, please contact the Air Pollution Control Program (APCP) at (573) 751-4817, or you may write to the Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

/!JcAJJ1;0..j.-...-..1.1l ......,---

Michael J. Stansfield, P.E. Operating Permit Unit Chie

MJS:abj

Enclosures

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