Simmons Feed Ingredients - Southwest City · Simmons Feed Ingredients, Inc. 10700 South State Hwy...

fmj Missouri Department of Natural Resources ~ Air Pollution Control Program

INTERMEDIATE STATE PERMIT TO OPERA TE

Under the authority ofRSMo 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: OP2016-049 Expiration Date: JAN_? ~ 2022 Installation ID: 11'9 (Jt):t7

Project Number: 2014-09-054

Installation Name and Address Simmons Feed Ingredients, Inc. 10700 South State Hwy 43 Southwest City, MO 64863 McDonald County

Installation Description:

Parent Company's Name and Address Simmons Foods, Inc. P.O. Box 430 Siloam Springs, AR 72761

Simmons Feed Ingredients, Inc. operates a poultry rendering plant near Southwest City, Missouri. The installation operates three distinct lines: a feather meal line, a poultry meal line, and a feed production process line. The installation also contains four 50.4 MMBtu/hr boilers. The installation is a synthetic minor source of NOx, PM10, CO, and PM2_s.

02W1adHVtr Prepared by: Alana L. Hess Operating Permit Unit

Director or esignee Department of Natural Resources

JAN 2 6 2017 Effective Date

Simmons Feed Ingredients, Inc. Intermediate State Operating Permit 2 Installation ID: 119-0017 Project No. 2014-09-054

Table of Contents

I. INSTALLATION EQUIPMENT LISTING .............................................................................................4

II. PLANT WIDE EMISSION LIMITATIONS............................................................................................8

PERMIT CONDITION PW001 .................................................................................................................... 8 10 CSR 10-6.020(2)(I)23 and 10 CSR 10-6.065(5)(C)2 Voluntary Limitation(s) ...................................................................... 8

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS .....................................................................11

PERMIT CONDITION 001 ........................................................................................................................ 11 10 CSR 10-6.060 Construction Permits Required..................................................................................................................... 11 Construction Permit 112011-001, Issued November 2, 2011 ................................................................................................... 11

PERMIT CONDITION 002 ........................................................................................................................ 12 10 CSR 10-6.060 Construction Permits Required..................................................................................................................... 12 Construction Permit 032006-005B, Issued May 23, 2014 ........................................................................................................ 12

PERMIT CONDITION 003 ........................................................................................................................ 14 10 CSR 10-6.060 Construction Permits Required..................................................................................................................... 14 Construction Permit 052005-026, Issued May 25, 2005 ........................................................................................................... 14

PERMIT CONDITION 004 ........................................................................................................................ 15 10 CSR 10-6.070 New Source Performance Regulations ......................................................................................................... 15 40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units ......................................................................................................................................................................................... 15

PERMIT CONDITION 005 ........................................................................................................................ 16 10 CSR 10-6.070 New Source Performance Regulations ......................................................................................................... 16 40 CFR Part 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines ......... 16

PERMIT CONDITION 006 ........................................................................................................................ 18 10 CSR 10-6.070 New Source Performance Regulations ......................................................................................................... 18 40 CFR Part 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines ......... 18

PERMIT CONDITION 007 ........................................................................................................................ 21 10 CSR 10-6.075 Maximum Achievable Control Technology Regulations ............................................................................. 21 40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources ............................................................................................................................................ 21

PERMIT CONDITION 008 ........................................................................................................................ 26 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants .................................................................................. 26

PERMIT CONDITION 009 ........................................................................................................................ 27 10 CSR 10-6.400 Restriction of Emission of Particulate Matter From Industrial Processes .................................................... 27

PERMIT CONDITION 010 ........................................................................................................................ 28 10 CSR 10-6.020(2)(I)23 and 10 CSR 10-6.065(5)(C)2 Voluntary Limitation(s) .................................................................... 28

IV. CORE PERMIT REQUIREMENTS ....................................................................................................30

V. GENERAL PERMIT REQUIREMENTS ..............................................................................................36

VI. ATTACHMENTS ..............................................................................................................................40

ATTACHMENT A .......................................................................................................................................... 41 Fugitive Emission Observations ............................................................................................................................................... 41

ATTACHMENT B .......................................................................................................................................... 42 Method 22 Visible Emission Observations ............................................................................................................................... 42

ATTACHMENT C .......................................................................................................................................... 43 Method 9 Opacity Emissions Observations .............................................................................................................................. 43

ATTACHMENT D .......................................................................................................................................... 44 Inspection/Maintenance/Repair/Malfunction Log .................................................................................................................... 44

ATTACHMENT E ........................................................................................................................................... 45 Abbreviations and Acronyms ................................................................................................................................................... 45

ATTACHMENT F ........................................................................................................................................... 46 Synthetic Minor NOx Limit Tracking Sheet ............................................................................................................................. 46


ATTACHMENT G .......................................................................................................................................... 48 Synthetic Minor PM10 Limit Tracking Sheet ............................................................................................................................ 48

ATTACHMENT H .......................................................................................................................................... 52 Synthetic Minor CO Limit Tracking Sheet ............................................................................................................................... 52


I. Installation Equipment Listing EMISSION SOURCES WITH LIMITATIONS The following list provides a description of the equipment at this installation which emits air pollutants and identified as having unit-specific emission limitations in Section III. These emission sources are also subject to the plant wide emission limitations in Section II. Emission Sources

Description Section III Applicable Requirements

EP01A (2) Feather Hydrolyzers 10 CSR 10-6.220, 10 CSR 10-6.400

EP06 Boiler #2 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil

NSPS Dc, MACT JJJJJJ EP07

Boiler #3 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil



EP10 Feather Meal Dryer #1 – material handling 10 CSR 10-6.220, Voluntary Condition

EP11 Feather Meal Dryer #2 – material handling

EP14 Link Belt Screener

10 CSR 10-6.220, 10 CSR 10-6.400 EP15 Feather Meal Transfer Leg

EP20 Feather Meal & Poultry Meal Truck Loadout EP21 Hanging Room Exhaust Vents 10 CSR 10-6.220

EU01PC Two PRO*CAL Poultry Blood Tanks - 26,083 gallons each

Construction Permit 112011-001

Four PRO*CAL SPN Tanks - 26,083 gallons each

EU02PC Two PRO*CAL Process Tanks - 10,500 gallons each One PRO*CAL CIP Tank - 10,000 gallons

EU04PC Two PRO*CAL Mixers

EU07PC PRO*CAL Dryer 10 CSR 10-6.220, 10 CSR 10-6.400

EU08PC PRO*CAL Hammermill Construction Permits 112011-001 and 052005-026

EU09PC PRO*CAL Screening Construction Permit 052005-026

EU10PC PRO*CAL Conveyors

EU11PC (3) PRO*CAL Storage Bins Construction Permit 112011-001

EU13PC PRO*CAL Truck Loadout 10 CSR 10-6.220, 10 CSR 10-6.400

EU23 Two Haarslev Continuous Cookers Construction Permit 032006-005B

EU26 Haarslev Feather Meal Pre-Dryer

EU27 Thermal Oxidizer #2 - 85 MMBtu/hr natural gas Construction Permit 032006-005B, 10 CSR 10-6.220 EU28 Thermal Oxidizer #3 - 85 MMBtu/hr natural gas


Emission Sources

Description Section III Applicable Requirements

EU31 60 kW (80 HP) Generac Emergency Generator NSPS JJJJ

EU32 80 kW (107 HP) Eaton Emergency Generator

EP17A Poultry Meal Day Storage Bin Voluntary Condition

EP17B Feed Grade Meal Day Storage Bin

EMISSION SOURCES WITHOUT SPECIFIC LIMITATIONS The following list provides a description of the equipment, which does not have unit specific limitations at the time of permit issuance. These emission sources are subject to the plant wide emission limitations in Section II. Emission Source Description

EP01B (3) Dupps Continuous Cookers

EP01C (7) Dupps Screw Presses

EP18A Feed Grade Bucket Elevator

EP18B High Ash Buck Elevator

EP18C Low Ash Bucket Elevator

EP18D Pet Food Grade Bucket Elevator

EU12PC Thermal Oxidizer #1 - 40 MMBtu/hr natural gas

EU12PCB Packed Bed Scrubber

EP01C Dupps Screw Presses

EP01D Blood Coagulator

EP01E Blood Centrifuge

EP01F Raw Blood Tank

EP01G Two Poultry Meal Drainers

EP01H Eight Fat Screeners

EP01I Four Fat Centrifuges

EP12 Feather Meal Dryer #1 - 19.05 MMBtu/hr natural gas


EP16 Feather Meal Storage Bins (Eight Compartments)

EP22 Feather Meal Silos

EP19B High Ash Storage Bin

EP19C Low Ash Storage Bin

EP19D Pet Food Storage Bin

EU03PC 6,000 gallon PRO*CAL Caustic Tank

EU05PC PRO*CAL Preheater

EU06PC PRO*CAL Press

EU24 (3) Poultry Meal Drainers

EU25A Feed Bin

EU25B (3) Dupps Screw Presses


Emission Source Description

EU25C Fat Centrifuge

EU30 Lime Silo

EU33 Dehumidifiers/Roof Heaters – 5 MMBtu/hr natural gas total

CT01, CT02, & CT03 Cooling Towers

EU34 Two Solvent Parts Washers

TST30 Stord Dryer Test Cooker

- Eight Space heaters – 0.6 MMBtu/hr natural gas each

EU06PCB Centrifuge

Laboratory

6,990 gallon poultry fat tank

(9) 26,000 gallon poultry fat tanks

(4) 26,000 gallon poultry digest tanks

8,600 gallon poultry fat tank

5,900 gallon phosphoric acid tank

17,600 gallon potable water tank

15,900 gallon poultry blood tank

6,000 gallon heated chemical tank

18,700 gallon PRO*CAL serum water tank

6,000 gallon wastewater tank

24,000 gallon DAF skimmings tank

8,000 gallon DAF skimmings tank

6,000 gallon organic coagulant tank

13,000 gallon alum tank

10,000 gallon acetic acid tank

24,000 gallon biosolids tank

12,000 gallon biosolids tank

6,000 gallon magnesium hydroxide tank

1,500 gallon sodium hypochlorite tank

1,400 gallon soil off tank

1,400 gallon Quadexx 100 tank

1,400 gallon Quadexx poultry care tank

2,400 gallon chlorine tank

2,000 gallon water tank

10,000 gallon sodium chlorite tank

10,000 gallon sodium acid sulfate tank


(2) 39,964 gallon water tanks


500 gallon hydraulic oil tank

500 gallon used oil tank

4,000 gallon compressed air tank


Emission Source Description

(4) 500 gallon poultry viscera tanks 3,000 gallon poultry viscera tank

2,000 gallon used marinate tank

5,000 gallon cooling water tank

8,436 gallon ammonia tank

70,000 gallon CO2 tank






1,000 gallon engine oil tank

1,000 gallon used engine and hydraulic oil tank

250 gallon hydraulic oil tank

10,000 gallon diesel tank

4,000 gallon diesel tank


II. Plant Wide Emission Limitations The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the CFR and 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 sources at this installation. All emission sources are listed in Section I under Emission Sources with Limitations and Emission Sources without Limitations.

PERMIT CONDITION PW001 10 CSR 10-6.020(2)(I)23 and 10 CSR 10-6.065(5)(C)2 Voluntary Limitation(s)

Emission Limitations: 1. The permittee shall emit less than 100.0 tons of NOx from the entire installation in any consecutive

12-month rolling total period. 2. The permittee shall emit less than 100.0 tons of PM10 from the entire installation in any consecutive

12-month rolling total period. 3. The permittee shall emit less than 100.0 tons of CO from the entire installation in any consecutive

12-month rolling total period. Monitoring/Recordkeeping: 1. The permittee shall maintain records of monthly and 12-month rolling total NOx, PM10, and CO

emissions using Attachments F, G, and H or equivalent forms (such as electronic forms or a database) approved by the Air Pollution Control Program.

2. The permittee shall maintain all records required by this permit for not less than five years and shall make them available to Missouri Department of Natural Resources’ personnel upon request.

Performance Testing: 1. The permittee shall conduct stack testing of the following emission sources using the appropriate

methods in 10 CSR 10-6.030 to update the emission factors in Attachments F, G, and H no later than one year after the effective date of this permit1: a) EU12 PC Thermal Oxidizer shall be tested for CO, NOx, filterable PM10, and condensable PM.

During stack testing the feed rate to EU07PC shall be greater than or equal to 8.1 tph. During the test the permittee shall document: i) The average operating temperature of the thermal oxidizer during each performance test run, ii) The amount of natural gas combusted during each performance test run, and iii) The amount of material fed to EU07PC Pro*Cal Dryer during each performance test run. Emission factors shall be established in units of pound of CO per ton of Pro*Cal Dryer feed, pounds of NOx per ton of Pro*Cal Dryer feed, and pounds of Primary PM10 per ton of Pro*Cal Dryer feed. Where the Primary PM10 emission rate is the sum of the filterable PM10 emission rate and the condensable PM emission rate. The established emission factors shall be used to demonstrate compliance for EU07PC and EU12PC.

1 The installation has indicated that they do not plan on combusting poultry oil in the boilers in the near future. Testing of the boilers while combusting poultry oil shall occur within one year of permit issuance or 180 days after poultry oil combustion recommences whichever occurs later.


b) EU27 or EU28 Thermal Oxidizer #2 or #3 shall be tested for CO, NOx, filterable PM10, and condensable PM. During stack testing the feed rates to EU-23 and EU-26 shall be greater than or equal to 47.7 tph and 18.5 tph, respectively. During the tests the permittee shall document: i) The average operating temperature of the thermal oxidizer during each performance test run, ii) The amount of natural gas combusted during each performance test run, iii) The amount of material fed to EU-23 Haarslev Continuous Cookers during each

performance test run, and iv) The amount of material fed to EU-26 Haarslev Feather Meal Pre-Dryer during each

performance test run. Emission factors shall be established in units of pounds of CO per ton of EU-23 Haarslev Continuous Cookers feed, pounds of NOx per ton of EU-23 Haarslev Continuous Cookers feed, and pounds of Primary PM10 per ton of EU-26 Haarslev Feather Meal Pre-Dryer feed. Where the Primary PM10 emission rate is the sum of the filterable PM10 emission rate and the condensable PM emission rate. The established emission factors shall be used to demonstrate compliance for both EU27 and EU28.

c) EP06, EP07, or EP08 Boiler #2, #3, or #4 shall be tested for CO, NOx, filterable PM10, and condensable PM10 while combusting poultry oil. During stack testing the damper allowing air to flow to the Feather Meal Dryers shall be closed. During the tests the permittee shall document: i) The amount of poultry oil combusted during each performance test run, ii) The heat content of the poultry oil combusted during the performance testing event, and iii) The amount of steam produced during each performance test run. Emission factors shall be established in units of pounds of CO per gallon of poultry oil combusted, pounds of NOx per gallon of poultry oil combusted, and pounds of Primary PM10 per gallon of poultry oil combusted. Where the Primary PM10 emission rate is the sum of the filterable PM10 emission rate and the condensable PM emission rate. The established emission factor shall be used to demonstrate compliance for EP06, EP07, EP08, and EP09 while combusting poultry oil.

d) CD12 shall be tested for filterable PM10 and condensable PM. During stack testing the damper allowing air from Boilers #2, #3, #4, and #5 to enter the dryers shall be closed. During the tests the permittee shall document: i) The amount of natural gas combusted in each Feather Meal Dryer during each performance

test run, ii) The amount of material fed to each Feather Meal Dryer during each performance test, iii) The average water flow rate in the Feather Spray Tower Condenser during each performance

test run, iv) The type of scrubbing agent used in the Packed Bed Scrubber during each performance test

run, v) The average flow rate of the scrubbing agent in the Packed Bed Scrubber during each

performance test run, and vi) The average pressure drop across the Packed Bed Scrubber during each performance test

run. An emission factor shall be established in units of pounds of Primary PM10 per ton of Feather Meal Dryer feed. Where the Primary PM10 emission rate is the sum of the filterable PM10 emission rate and the condensable PM emission rate. The established emission factor shall be used to demonstrate compliance for EP10, EP11, EP12, and EP13.

e) A completed Proposed Test Plan Form shall be submitted to the Air Pollution Control Program 30 days prior to the proposed test date so that the Air Pollution Control Program may arrange a


pretest meeting, if necessary, and assure that the test date is acceptable for an observer to be present. The Proposed Test Plan may serve the purpose of notification and must be approved by the Director prior to conducting the required emission testing.

f) One electronic report of the performance test results shall be submitted to the Director within 30 days of completion of any required testing. The report shall include legible copies of the raw data sheets, analytical instrument laboratory data, and complete sample calculations from the required U.S. EPA Method for at least one sample run.

g) The test report is to fully account for all operational and emission parameters addressed both in the permit conditions as well as in any other applicable state or federal rules or regulations.

Reporting: 1. The permittee shall report to the Air Pollution Control Program’s Compliance/Enforcement Section,

P.O. Box 1776, Jefferson City, MO 65102, no later than 10 days after the end of the month during which records indicate an exceedance of any of the emission limitations.

2. The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and annual compliance certification required by Section V of this permit.


III. Emission Unit Specific Emission Limitations The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the CFR and CSR for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect on the date of permit issuance.

PERMIT CONDITION 001 10 CSR 10-6.060 Construction Permits Required

Construction Permit 112011-001, Issued November 2, 2011 Emission Unit Description

EU01PC Two PRO*CAL Poultry Blood Tanks – 26,083 gallons each

Four PRO*CAL SPN Tanks – 26,083 gallons each

EU02PC Two PRO*CAL Process Tanks – 10,500 gallons each

PRO*CAL CIP Tank – 10,000 gallons EU04PC Two PRO*CAL Mixers EU07PC PRO*CAL Dryer EU08PC PRO*CAL Hammermill EU11PC Three PRO*CAL Storage Bins EU12PC Thermal Oxidizer #1 (PRO*CAL) – 40 MMBtu/hr natural gas

EU12PCB Packed Bed Scrubber Operational Limitations: 1. Special Condition 2.A: The permittee shall control VOC and odorous emissions from EU01PC Four

PRO*CAL SPN Tanks, EU01PC Two PRO*CAL Poultry Blood Tanks, EU02PC Two PRO*CAL Process Tanks, EU02PC PRO*CAL CIP Tank, EU04PC Two PRO*CAL Mixers, EU11PC Three PRO*CAL Storage Bins, and EU08PC PRO*CAL Hammermill with EU12PC Thermal Oxidizer #1 at all times during which the production line is in full production. Full production is defined as occurring when steam is flowing and raw ingredients are being fed to EU07PC PRO*CAL Dryer. EU12PC Thermal Oxidizer #1 shall be operated and maintained in accordance with the manufacturer’s specifications.

2. Special Condition 2.B: The permittee shall control odorous emissions from EU01PC Two PRO*CAL Poultry Blood Tanks and EU01PC Four PRO*CAL SPN Tanks with EU12PCB Packed Bed Scrubber whenever EU12PC Thermal Oxidizer #1 is offline. This special condition is not applicable when there is no potential for odorous emissions (e.g. extended plant shutdown where no raw materials are being received). The packed bed scrubber shall be operated and maintained in accordance with the manufacturer’s specifications.

3. The three-hour rolling average operating temperature of EU12PC Thermal Oxidizer #1 shall be maintained at greater than or equal to 1400°F2. Periods of time during which the thermal oxidizer three-hour rolling average temperature does not meet this requirement are considered periods of start-up, shutdown, and/or malfunction (SSM) and shall be reported to the Air Pollution Control Program in accordance with 10 CSR 10-6.050. The permittee shall take corrective action to restore the three-hour rolling average operating temperature to the proper value in a timely manner. If corrective actions fail and the three-hour rolling average temperature has not been restored to the

2 The three-hour rolling average operating temperature of the thermal oxidizer shall be re-established by stack testing required by Permit Condition PW001.


proper value within three hours, the process equipment shall cease production until the thermal oxidizer can be repaired.

4. EU12PCB Packed Bed Scrubber shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. The scrubber shall be equipped with a flow meter that indicates the liquid flow rate through the scrubber. The gauges or meters shall be located such that Department of Natural Resources’ employees may easily observe them.

Monitoring/Recordkeeping: 1. The permittee shall monitor and record the combustion chamber operating temperature of EU12PC

Thermal Oxidizer #1 at least once every 15 minutes. The combustion chamber temperature shall be monitored in the firebox of the thermal oxidizer or immediately downstream of the firebox before any substantial heat exchange occurs. The temperature measurement device shall be installed, calibrated, and maintained according to the manufacturer’s specifications. The device shall have an accuracy of 0.75% of the temperature being measured, expressed in degrees Celsius, or ±2.5°C, whichever is greater.

2. The permittee shall monitor and record the operating pressure drop across EU12PCB Packed Bed Scrubber at least once every 24 hours. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance specifications.

3. The permittee shall monitor and record the liquid flowrate through EU12PCB Packed Bed Scrubber at least once every 24 hours. The liquid flowrate shall be maintained within the design conditions specified by the manufacturer's performance specifications. The permittee shall also note what liquid is being used each day.

4. A copy of the manufacturer’s specifications for EU12PC Thermal Oxidizer #1 and EU12PCB Packed Bed Scrubber shall be retained onsite.

5. Special Condition 2.C: The permittee shall maintain an operating, maintenance, and inspection log for EU12PC Thermal Oxidizer #1 and for EU12PCB Packed Bed Scrubber using Attachment D or an equivalent form which shall include the following:

a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and corrective actions; and

b) Maintenance activities, with inspection schedule, repair actions, and replacements, etc. 6. Special Condition 3.A: The permittee shall maintain all records required by this permit for not less

than five years and shall make them available immediately to Missouri Department of Natural Resources’ personnel upon request. These records shall include SDS for all materials used.

Reporting: The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and compliance certification required by Section V of this permit.


Construction Permit 032006-005B, Issued May 23, 2014 Emission Unit Description

EU23 Two Haarslev Continuous Cookers EU26 Haarslev Feather Meal Pre-Dryer EU27 Thermal Oxidizer #2 – 85 MMBtu/hr natural gas EU28 Thermal Oxidizer #3 – 85 MMBtu/hr natural gas


Operational Limitations: 1. Special Condition 1.A: The permittee shall control VOC, particulate, and odorous emissions from

EU23 Two Haarslev Continuous Cookers and EU26 Haarslev Feather Meal Pre-Dryer with EU27 Thermal Oxidizer #2 and EU28 Thermal Oxidizer #3 at all times during which EU23 and EU26 are in operation. EU27 Thermal Oxidizer #2 and EU28 Thermal Oxidizer #3 shall be operated and maintained in accordance with the manufacturer’s specifications to ensure that outlet PM10 emissions do not exceed 1.5 lb/hr.

2. Special Condition 1.B: The three-hour rolling average operating temperature of EU27 Thermal Oxidizer #2 and EU28 Thermal Oxidizer #3 shall be maintained at greater than or equal to 1541°F3. Periods of time during which the three-hour rolling average temperature of a thermal oxidizer does not meet this requirement are considered periods of start-up, shutdown, and/or malfunction (SSM) and shall be reported to the Air Pollution Control Program in accordance with 10 CSR 10-6.050. The permittee shall take corrective action to restore the three-hour rolling average operating temperature to the proper value in a timely manner. If corrective actions fail and the three-hour rolling average temperature has not been restored to the proper value within three hours, the process equipment shall cease production until the thermal oxidizer can be repaired.

Compliance Demonstration: The permittee performed stack testing in September 2007 which indicated that the PM10 emission rate from EU27 and EU28 Thermal Oxidizers is 1.24 lb/hr each. Repeat stack testing is required by Permit Condition PW001. Monitoring/Recordkeeping: 1. The permittee shall monitor and record the combustion chamber operating temperature of EU27

Thermal Oxidizer #2 and EU28 Thermal Oxidizer #3 at least once every 15 minutes. The combustion chamber temperature shall be monitored in the firebox of the thermal oxidizers or immediately downstream of the firebox before any substantial heat exchange occurs. The temperature measurement devices shall be installed, calibrated, and maintained according to the manufacturer’s specifications. The devices shall have an accuracy of 0.75% of the temperature being measured, expressed in degrees Celsius, or ±2.5°C, whichever is greater.

2. A copy of the manufacturer’s specifications for EU27 Thermal Oxidizer #2 and EU28 Thermal Oxidizer #3 shall be retained onsite.

3. Special Condition 1.C: The permittee shall maintain an operating, maintenance, and inspection log for EU27 Thermal Oxidizer #2 and for EU28 Thermal Oxidizer #3 which shall include the following: a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and

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

4. The permittee shall maintain all records required by this permit for not less than five years and shall make them available immediately to Missouri Department of Natural Resources’ personnel upon request. These records shall include SDS for all materials used.

3 The three-hour rolling average operating temperature of the thermal oxidizers shall be re-established by stack testing required by Permit Condition PW001.




Construction Permit 052005-026, Issued May 25, 2005 Emission Unit Description

EU08PC PRO*CAL Hammermill EU09PC PRO*CAL Screening EU10PC PRO*CAL Conveyors

Operational Limitations: 1. Special Condition 1.A: The permittee shall control particulate emissions from EU08PC PRO*CAL

Hammermill and EU09PC PRO*CAL Screening with baghouses at all times during which EU08PC and EU09PC are in operation. The baghouses shall be operated and maintained in accordance with the manufacturer’s specifications. The baghouses shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources’ employees may easily observe them.

2. Special Condition 2.A: The permittee shall control particulate emissions from EU10PC PRO*CAL Conveyors with filter receivers at all times during which EU10PC is in operation. The filter receivers shall be operated and maintained in accordance with the manufacturer’s specifications. The filter receivers shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources’ employees may easily observe them.

3. Replacement filters for the baghouses and filter receivers 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. Special Condition 1.B: The permittee shall monitor and record the operating pressure drop across the

baghouses at least once every 24 hours. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance specifications. Periods of time during which the operating pressure drop across the baghouse does not meet this requirement are considered periods of start-up, shutdown, and/or malfunction (SSM) and shall be reported to the Air Pollution Control Program in accordance with 10 CSR 10-6.050. The permittee shall take corrective action to restore the operating pressure drop to the proper value in a timely manner. If corrective actions fail and the operating pressure drop has not been restored to the proper value within eight hours, the process equipment shall cease production until the baghouse can be repaired.

2. Special Condition 2.B: The permittee shall monitor and record the operating pressure drop across the filter receivers at least once every 24 hours. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance specifications. Periods of time during which operating pressure drop across the filter receivers does not meet this requirement are considered periods of start-up, shutdown, and/or malfunction (SSM) and shall be reported to the Air Pollution Control Program in accordance with 10 CSR 10-6.050. The permittee shall take corrective action to restore the operating pressure drop to the proper value in a timely manner. If corrective


actions fail and the operating pressure drop has not been restored to the proper value within eight hours, the process equipment shall cease production until the filter receivers can be repaired.

3. A copy of the manufacturer’s specifications for baghouses and filter receivers shall be retained onsite.

4. Special Condition 1.C: The permittee shall maintain an operating, maintenance, and inspection log for the baghouses which shall include the following: a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and


5. Special Condition 2.C: The permittee shall maintain an operating, maintenance, and inspection log for the filter receivers which shall include the following: a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and




PERMIT CONDITION 004 10 CSR 10-6.070 New Source Performance Regulations

40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units

Emission Unit Description EP06 Boiler #2 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil EP07 Boiler #3 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil EP08 Boiler #4 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil EP09 Boiler #5 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil

Recordkeeping: 1. Except as provided under §60.48c(g)(2) and (3), the permittee shall record and maintain records of

the amount of each fuel combusted during each operating day. [§60.48c(g)(1)] 2. As an alternative to meeting the requirements of §60.48c(g)(1), the permittee may elect to record and

maintain records of the amount of each fuel combusted during each calendar month. [§60.48c(g)(2)] 3. The permittee shall maintain all records required by this permit for not less than five years and shall

make them available to any Missouri Department of Natural Resources’ personnel upon request. Reporting: The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and compliance certification required by Section V of this permit.



40 CFR Part 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Emission Unit Description EU31 60 kW (80 HP) Generac Emergency Generator, 2010

Emission Standards: For stationary SI ICE with a maximum engine power greater than 19 kW and less than 75 kW (except gasoline and rich burn engines that use LPG), the permittee shall comply with the emission standards in Table 1 to NSPS JJJJ for their emergency stationary SI ICE. [§60.4233(d)]

Table 1 to NSPS JJJJ – NOx, CO, and VOC Emission Standards for Stationary Emergency Engines > 25 HP

Engine Type and Fuel Maximum Engine Power Manufacture Date Emission Standards

(g/HP-hr) NOx + HC CO

Emergency 25 < HP < 130 1/1/2009 and later 10 387 Monitoring: For emergency stationary SI internal combustion engines that are less than 130 HP, was built on or after July 1, 2008, and does not meet the standards applicable to non-emergency engines, the permittee shall install a non-resettable hour meter upon startup of the emergency engine. [§60.4237(c)] Compliance Requirements: 1. For stationary SI internal combustion engines complying with the emission standards specified in

§60.4233(d) or (e), the permittee shall demonstrate compliance by: [§60.4243(b)] a) Purchasing an engine certified according to procedures specified in NSPS JJJJ, for the same

model year and demonstrating compliance by: [§60.4243(b)(1)] i) Operating and maintaining the certified stationary SI internal combustion engine and control

device according to the manufacturer's emission-related written instructions. The permittee shall keep records of conducted maintenance to demonstrate compliance, but no performance testing is required. The permittee shall also meet the requirements as specified in 40 CFR Part 1068, Subparts A through D, as they apply. If the permittee adjusts engine settings according to and consistent with the manufacturer's instructions, the stationary SI internal combustion engine will not be considered out of compliance. [§60.4243(a)(1)]

2. The permittee shall operate the emergency stationary ICE according to the requirements in §60.4243(d)(1) through (3). In order for the engine to be considered an emergency stationary ICE under NSPS JJJJ, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in §60.4243(d)(1) through (3), is prohibited. If the permittee does not operate the engine according to the requirements in §60.4243(d)(1) through (3), the engine will not be considered an emergency engine under NSPS JJJJ and shall meet all requirements for non-emergency engines. [§60.4243(d)] a) There is no time limit on the use of emergency stationary ICE in emergency situations.

[§60.4243(d)(1)] b) The permittee may operate the emergency stationary ICE for any combination of the purposes

specified in §60.4243(d)(2)(i) for a maximum of 100 hours per calendar year. Any operation for


non-emergency situations as allowed by §60.4243(d)(3) counts as part of the 100 hours per calendar year allowed by this paragraph. [§60.4243(d)(2)] i) Emergency stationary ICE may be operated for maintenance checks and readiness testing,

provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The permittee may petition the Director for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. [§60.4243(d)(2)(i)]

c) Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in §60.4243(d)(2). Except as provided in §60.4243(d)(3)(i), the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. [§60.4243(d)(3)] i) The 50 hours per year for non-emergency situations can be used to supply power as part of a

financial arrangement with another entity if all of the following conditions are met: [§60.4243(d)(3)(i)]

(1) The engine is dispatched by the local balancing authority or local transmission and distribution system operator; [§60.4243(d)(3)(i)(A)]

(2) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. [§60.4243(d)(3)(i)(B)]

(3) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. [§60.4243(d)(3)(i)(C)]

(4) The power is provided only to the facility itself or to support the local transmission and distribution system. [§60.4243(d)(3)(i)(D)]

(5) The permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the permittee. [§60.4243(d)(3)(i)(E)]

3. The permittee may operate the engines using propane for a maximum of 100 hours per year as an alternative fuel solely during emergency operations, but shall keep records of such use. If propane is used for more than 100 hours per year in an engine that is not certified to the emission standards when using propane, the permittee is required to conduct a performance test to demonstrate compliance with the emission standards of §60.4233. [§60.4243(e)]

4. It is expected that air-to-fuel ratio controllers will be used with the operation of three-way catalysts/non-selective catalytic reduction. The AFR controller shall be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. [§60.4243(g)]


General Provisions: The permittee shall comply with the applicable portions of §§60.1 through 60.19 as specified by Table 3 to NSPS JJJJ. Notifications/Recordkeeping/Reporting: 1. For all stationary SI ICE the permittee shall keep records of the following information:

[§60.4245(a)] a) All notifications submitted to comply with NSPS JJJJ and all documentation supporting any

notification. [§60.4245(a)(1)] b) Maintenance conducted on the engine. [§60.4245(a)(2)] c) If the stationary SI internal combustion engine is a certified engine, documentation from the

manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR Parts 90, 1048, 1054, and 1060, as applicable. [§60.4245(a)(3)]

2. For all stationary SI emergency ICE greater than 25 HP and less than 130 HP manufactured on or after July 1, 2008, that do not meet the standards applicable to non-emergency engines, the permittee shall keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. [§60.4245(b)]

3. The permittee shall maintain all records required by this permit for not less than five years and shall make them available to any Missouri Department of Natural Resources’ personnel upon request.

4. The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and compliance certification required by Section V of this permit.


40 CFR Part 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Emission Unit Description EU32 80 kW (107 HP) Generac Emergency Generator, 2014

Emission Standards: For stationary SI ICE with a maximum engine power greater than or equal to 75 KW (except gasoline and rich burn engines that use LPG), the permittee shall comply with the emission standards in Table 1 to NSPS JJJJ for their stationary SI ICE. [§60.4233(e)] Table 1 to NSPS JJJJ – NOx, CO, and VOC Emission Standards for Stationary Emergency Engines > 25 HP

Engine Type and Fuel Maximum Engine Power Manufacture Date Emission Standards

(g/HP-hr) NOx + HC CO

Emergency 25 < HP < 130 1/1/2009 and later 10 387 Monitoring: For emergency stationary SI internal combustion engines that are less than 130 HP, was built on or after July 1, 2008, and does not meet the standards applicable to non-emergency engines, the permittee shall install a non-resettable hour meter upon startup of the emergency engine. [§60.4237(c)]


Compliance Requirements: 1. For stationary SI internal combustion engines complying with the emission standards specified in

§60.4233(d) or (e), the permittee shall demonstrate compliance by: [§60.4243(b)] a) Purchasing an engine certified according to procedures specified in NSPS JJJJ, for the same

model year and demonstrating compliance by: [§60.4243(b)(1)] i) Operating and maintaining the certified stationary SI internal combustion engine and control

device according to the manufacturer's emission-related written instructions. The permittee shall keep records of conducted maintenance to demonstrate compliance, but no performance testing is required. The permittee shall also meet the requirements as specified in 40 CFR Part 1068, Subparts A through D, as they apply. If the permittee adjusts engine settings according to and consistent with the manufacturer's instructions, the stationary SI internal combustion engine will not be considered out of compliance. [§60.4243(a)(1)]

2. The permittee shall operate the emergency stationary ICE according to the requirements in §60.4243(d)(1) through (3). In order for the engine to be considered an emergency stationary ICE under NSPS JJJJ, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in §60.4243(d)(1) through (3), is prohibited. If the permittee does not operate the engine according to the requirements in §60.4243(d)(1) through (3), the engine will not be considered an emergency engine under NSPS JJJJ and shall meet all requirements for non-emergency engines. [§60.4243(d)] a) There is no time limit on the use of emergency stationary ICE in emergency situations.

[§60.4243(d)(1)] b) The permittee may operate the emergency stationary ICE for any combination of the purposes

specified in §60.4243(d)(2)(i) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by §60.4243(d)(3) counts as part of the 100 hours per calendar year allowed by this paragraph. [§60.4243(d)(2)] i) Emergency stationary ICE may be operated for maintenance checks and readiness testing,

provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The permittee may petition the Director for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. [§60.4243(d)(2)(i)]

c) Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in §60.4243(d)(2). Except as provided in §60.4243(d)(3)(i), the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. [§60.4243(d)(3)] i) The 50 hours per year for non-emergency situations can be used to supply power as part of a

financial arrangement with another entity if all of the following conditions are met: [§60.4243(d)(3)(i)]

(1) The engine is dispatched by the local balancing authority or local transmission and distribution system operator; [§60.4243(d)(3)(i)(A)]


(2) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. [§60.4243(d)(3)(i)(B)]

(3) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. [§60.4243(d)(3)(i)(C)]

(4) The power is provided only to the facility itself or to support the local transmission and distribution system. [§60.4243(d)(3)(i)(D)]

(5) The permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the permittee. [§60.4243(d)(3)(i)(E)]

3. The permittee may operate the engines using propane for a maximum of 100 hours per year as an alternative fuel solely during emergency operations, but shall keep records of such use. If propane is used for more than 100 hours per year in an engine that is not certified to the emission standards when using propane, the permittee is required to conduct a performance test to demonstrate compliance with the emission standards of §60.4233. [§60.4243(e)]

4. It is expected that air-to-fuel ratio controllers will be used with the operation of three-way catalysts/non-selective catalytic reduction. The AFR controller shall be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. [§60.4243(g)]

General Provisions: The permittee shall comply with the applicable portions of §§60.1 through 60.19 as specified by Table 3 to NSPS JJJJ. Notifications/Recordkeeping/Reporting: 1. For all stationary SI ICE the permittee shall keep records of the following information:

[§60.4245(a)] a) All notifications submitted to comply with NSPS JJJJ and all documentation supporting any

notification. [§60.4245(a)(1)] b) Maintenance conducted on the engine. [§60.4245(a)(2)] c) If the stationary SI internal combustion engine is a certified engine, documentation from the

manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR Parts 90, 1048, 1054, and 1060, as applicable. [§60.4245(a)(3)]

2. For all stationary SI emergency ICE greater than 25 HP and less than 130 HP manufactured on or after July 1, 2008, that do not meet the standards applicable to non-emergency engines, the permittee shall keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. [§60.4245(b)]

3. For emergency stationary SI ICE with a maximum engine power more than 100 HP that operates for the purposes specified in §60.4243(d)(3)(i), the permittee shall submit an annual report according to the following requirements: [§60.4245(e)] a) The report shall contain the following information: [§60.4245(e)(1)]

i) Company name and address where the engine is located. [§60.4245(e)(1)(i)]


ii) Date of the report and beginning and ending dates of the reporting period. [§60.4245(e)(1)(ii)]

iii) Engine site rating and model year. [§60.4245(e)(1)(iii)] iv) Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place.

[§60.4245(e)(1)(iv)] v) Hours spent for operation for the purposes specified in §60.4243(d)(3)(i), including the date,

start time, and end time for engine operation for the purposes specified in §60.4243(d)(3)(i). The report shall also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine. [§60.4245(e)(1)(vii)]

b) Annual reports covering each calendar year shall be submitted no later than March 31 of the following calendar year. [§60.4245(e)(2)]

c) The annual report shall be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to NSPS JJJJ is not available in CEDRI at the time that the report is due, the written report shall be submitted to the Administrator at the appropriate address listed in §60.4. [§60.4245(e)(3)]

4. The permittee shall maintain all records required by this permit for not less than five years and shall make them available to any Missouri Department of Natural Resources’ personnel upon request.

5. The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and compliance certification required by Section V of this permit.

PERMIT CONDITION 007

10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for

Industrial, Commercial, and Institutional Boilers Area Sources Emission Unit Description

EP06 Boiler #2 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil, 1990 EP07 Boiler #3 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil, 1990 EP08 Boiler #4 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil, 1996 EP09 Boiler #5 - 50.4 MMBtu/hr natural gas, propane, and/or poultry oil, 1997

Standards: 1. The permittee shall comply with each work practice standard, emission reduction measure, and

management practice specified in Table 2 to MACT JJJJJJ that applies. An energy assessment completed on or after January 1, 2008 that meets or is amended to meet the energy assessment requirements in Table 2 to MACT JJJJJJ satisfies the energy assessment requirement. A facility that operates under an energy management program established through energy management systems compatible with ISO 50001, that includes the affected units, also satisfies the energy assessment requirement. [§63.11201(b)]

2. These standards apply at all times the affected boiler is operating. [§63.11201(d)] Table 2 to MACT JJJJJJ – Work Practice Standards, Emission Reduction Measures, and Management Practices Boiler Subcategory The permittee shall meet the following... 4. Existing oil-fired boilers with heat input capacity greater than 5 MMBtu/hr that do not meet the definition of seasonal boiler or limited-use boiler, or use an oxygen trim

Conduct an initial tune-up as specified in §63.11214, and conduct a tune-up of the boiler biennially as specified in §63.11223.


system that maintains an optimum air-to-fuel ratio 16. Existing oil-fired boilers (units with heat input capacity of 10 MMBtu/hr and greater), not including limited-use boilers

Must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this table satisfies the energy assessment requirement. Energy assessor approval and qualification requirements are waived in instances where past or amended energy assessments are used to meet the energy assessment requirements. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units also satisfies the energy assessment requirement. The energy assessment shall include the following with extent of the evaluation for items (1) to (4) appropriate for the on-site technical hours listed in §63.11237: (1) A visual inspection of the boiler system, (2) An evaluation of operating characteristics of the affected boiler systems, specifications of energy use systems, operating and maintenance procedures, and unusual operating constraints, (3) An inventory of major energy use systems consuming energy from affected boiler(s) and which are under control of the permittee, (4) A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage, (5) A list of major energy conservation measures that are within the facility's control, (6) A list of the energy savings potential of the energy conservation measures identified, and (7) A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments.

General Compliance Requirements: At all times the permittee shall operate and maintain any affected source, 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 Director that 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. [§63.11205(a)] Initial Compliance Requirements: 1. For existing affected boilers that have applicable work practice standards, management practices, or

emission reduction measures, the permittee shall demonstrate initial compliance no later than the compliance date that is specified in §63.11196 and according to the applicable provisions in §63.7(a)(2), except as provided in §63.11210(j). [§63.11210(c)]

2. For affected boilers that switch fuels or make a physical change to the boiler that results in the applicability of a different subcategory within MACT JJJJJJ or the boiler becoming subject to


MACT JJJJJJ, the permittee shall demonstrate compliance within 180 days of the effective date of the fuel switch or the physical change. Notification of such changes must be submitted according to §63.11225(g). [§63.11210(h)]

3. For existing affected boilers that have not operated between the effective date of the rule and the compliance date that is specified for the source in §63.11196, the permittee shall comply with the applicable provisions as specified in §63.11210(j)(1) through (3). [§63.11210(j)] a) The permittee shall complete the initial performance tune-up, if subject to the tune-up

requirements in §63.11223, by following the procedures described in §63.11223(b) no later than 30 days after the re-start of the affected boiler. [§63.11210(j)(2)]

b) The permittee shall complete the one-time energy assessment, if subject to the energy assessment requirements specified in Table 2 to MACT JJJJJJ, no later than the compliance date specified in §63.11196. [§63.11210(j)(3)]

4. For an existing oil-fired boiler, the permittee shall conduct a performance tune-up according to §63.11223(b) and the permittee shall submit a signed statement in the Notification of Compliance Status report that indicates that the permittee has conducted a tune-up of the boiler. [§63.11214(b)]

5. For an existing affected boiler with a heat input capacity of 10 million Btu per hour or greater, the permittee shall submit a signed certification in the Notification of Compliance Status report that an energy assessment of the boiler and its energy use systems was completed according to Table 2 to MACT JJJJJJ and is an accurate depiction of the facility. [§63.11214(c)]

Continuous Compliance Requirements: 1. For affected sources subject to the work practice standard or the management practices of a tune-up,

the permittee shall conduct a performance tune-up according to §63.11223(b) and keep records as required in §63.11225(c) to demonstrate continuous compliance. The permittee shall conduct the tune-up while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. [§63.11223(a)]

2. The permittee shall conduct a tune-up of the boiler biennially to demonstrate continuous compliance as specified in §63.11223(b)(1) through (7). Each biennial tune-up must be conducted no more than 25 months after the previous tune-up. [§63.11223(b)] a) As applicable, inspect the burner, and clean or replace any components of the burner as

necessary (the permittee may delay the burner inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. [§63.11223(b)(1)]

b) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. [§63.11223(b)(2)]

c) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the permittee may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection. [§63.11223(b)(3)]

d) Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject. [§63.11223(b)(4)]


e) Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. [§63.11223(b)(5)]

f) Maintain on-site and submit, if requested by the Director, a report containing the information in §63.11223(b)(6)(i) through (iii). [§63.11223(b)(6)] i) The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen

in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler. [§63.11223(b)(6)(i)]

ii) A description of any corrective actions taken as a part of the tune-up of the boiler. [§63.11223(b)(6)(ii)]

iii) The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. [§63.11223(b)(6)(iii)]

g) If the unit is not operating on the required date for a tune-up, the tune-up shall be conducted within 30 days of startup. [§63.11223(b)(7)]

General Provisions: The permittee shall comply with the applicable portions of §§63.1 through 63.15 as specified by Table 8 to MACT JJJJJJ. Notifications/Recordkeeping/Reporting: 1. The permittee shall submit the notifications specified in §63.11225(a)(1) through (5) to the Director.

[§63.11225(a)] a) The permittee shall submit all of the notifications in §§63.7(b); 63.8(e) and (f); and 63.9(b)

through (e), (g), and (h) that apply by the dates specified in those sections except as specified in §63.11225(a)(2) and (4). [§63.11225(a)(1)]

b) The permittee shall submit the Notification of Compliance Status no later than 120 days after the applicable compliance date specified in §63.11196. The permittee shall submit the Notification of Compliance Status in accordance with §63.11225(a)(4)(i) and (vi). The Notification of Compliance Status must include the information and certification(s) of compliance in §63.11225(a)(4)(i) through (v), as applicable, and signed by a responsible official. [§63.11225(a)(4)] i) The permittee shall submit the information required in §63.9(h)(2), except the information

listed in §63.9(h)(2)(i)(B), (D), (E), and (F). [§63.11225(a)(4)(i)] ii) “This facility complies with the requirements in §63.11214 to conduct an initial tune-up of

the boiler.” [§63.11225(a)(4)(ii)] iii) “This facility has had an energy assessment performed according to §63.11214(c).”

[§63.11225(a)(4)(iii)] iv) For units that do not qualify for a statutory exemption as provided in §129(g)(1) of the Clean

Air Act: “No secondary materials that are solid waste were combusted in any affected unit.” [§63.11225(a)(4)(v)]

v) The notification shall be submitted electronically using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to MACT JJJJJJ is not available in CEDRI at the time that the report is due, the written Notification of Compliance


Status must be submitted to the Administrator at the appropriate address listed in §63.13. [§63.11225(a)(4)(vi)]

2. The permittee shall prepare, by March 1 of each year, and submit to the Director upon request, an annual compliance certification report for the previous calendar year containing the information specified in §63.11225(b)(1) through (4). The permittee shall submit the report by March 15 if the permittee had any instance described by §63.11225(b)(3). For boilers that are subject only to a requirement to conduct a biennial tune-up according to §63.11223(a) and not subject to emission limits or operating limits, the permittee may prepare only a biennial compliance report as specified in §63.11225(b)(1) and (2). [§63.11225(b)] a) Company name and address. [§63.11225(b)(1)] b) Statement by a responsible official, with the official's name, title, phone number, email address,

and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart. The notification shall include the following certification(s) of compliance, as applicable, and signed by a responsible official: [§63.11225(b)(2)] i) “This facility complies with the requirements in §63.11223 to conduct a biennial tune-up of

each boiler.” [§63.11225(b)(2)(i)] ii) For units that do not qualify for a statutory exemption as provided in §129(g)(1) of the Clean

Air Act: “No secondary materials that are solid waste were combusted in any affected unit.” [§63.11225(b)(2)(ii)]

c) If the source experiences any deviations from the applicable requirements during the reporting period, include a description of deviations, the time periods during which the deviations occurred, and the corrective actions taken. [§63.11225(b)(3)]

3. The permittee shall maintain the records specified in §63.11225(c)(1) through (7). [§63.11225(c)] a) As required in §63.10(b)(2)(xiv), the permittee shall keep a copy of each notification and report

that the permittee submitted to comply with MACT JJJJJJ and all documentation supporting any Initial Notification or Notification of Compliance Status that the permittee submitted. [§63.11225(c)(1)]

b) The permittee shall keep records to document conformance with the work practices, emission reduction measures, and management practices required by §63.11214 and §63.11223 as specified in §63.11225(c)(2)(i) through (vi). [§63.11225(c)(2)] i) Records shall identify each boiler, the date of tune-up, the procedures followed for tune-up,

and the manufacturer's specifications to which the boiler was tuned. [§63.11225(c)(2)(i)] ii) For each boiler required to conduct an energy assessment, the permittee shall keep a copy of

the energy assessment report. [§63.11225(c)(2)(iii)] c) Records of the occurrence and duration of each malfunction of the boiler, or of the associated air

pollution control and monitoring equipment. [§63.11225(c)(4)] d) Records of actions taken during periods of malfunction to minimize emissions in accordance

with the general duty to minimize emissions in §63.11205(a), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. [§63.11225(c)(5)]

4. Records shall be in a form suitable and readily available for expeditious review. The permittee shall keep each record for five years following the date of each recorded action. The permittee shall keep each record on-site or be accessible from a central location by computer or other means that instantly provide access at the site for at least two years after the date of each recorded action. The permittee may keep the records off site for the remaining three years. [§63.11225(d)]


5. If the permittee switches fuels or makes a physical change to the boiler and the fuel switch or change results in the applicability of a different subcategory within MACT JJJJJJ or in the boiler switching out of MACT JJJJJJ due to a change to 100 percent natural gas, the permittee shall provide notice of the date upon which the permittee switched fuels, made the physical change, or took a permit limit within 30 days of the change. The notification shall identify: [§63.11225(g)] a) The name of the owner or operator of the affected source, the location of the source, the boiler(s)

that have switched fuels, were physically changed, or took a permit limit, and the date of the notice. [§63.11225(g)(1)]

b) The date upon which the fuel switch, physical change, or permit limit occurred. [§63.11225(g)(2)]

6. The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and annual compliance certification required by Section V of this permit. The permittee shall also report any deviations from the requirements of this permit condition to EPA Region VII, 11201 Renner Boulevard, Lenexa, KS 66219.


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

EP01A (2) Feather Hydrolyzers EP10 Feather Meal Dryer #1 EP11 Feather Meal Dryer #2 EP14 Link Belt Screener EP15 Feather Meal Transfer Leg

EP20 & EU13PC Truck Loadout EP21 Hanging Room Exhaust Vents

EU07PC PRO*CAL Dryer EU27 Thermal Oxidizer #2 EU28 Thermal Oxidizer #3

Emission Limitation: 1. The permittee shall not cause or permit to be discharged into the atmosphere from these emission

sources any visible emissions with an opacity greater than 20 percent. [10 CSR 10-6.220(3)(A)] 2. Exception:

a) The permittee may discharge into the atmosphere from any source of emissions for a period(s) aggregating not more than six minutes in any 60 minutes air contaminants with an opacity up to 60 percent. [10 CSR 10-6.220(3)(B)]

Monitoring: 1. The permittee shall conduct opacity readings on these emission sources using the procedures

contained in EPA Test Method 22. Readings are only required when the emission units are operating and when the weather conditions allow. If no visible emissions are observed using Method 22, then no further observations would be required. For emission units with visible emissions, the permittee would then conduct a Method 9 observation.

2. The following monitoring schedule shall be maintained: a) Weekly observations shall be conducted for a minimum of eight consecutive weeks after permit

issuance. Should no violation of this regulation be observed during this period then


b) Observations shall be made once every two weeks for a period of eight weeks. If a violation is noted, monitoring reverts to weekly. Should no violation of this regulation be observed during this period then

c) Observations shall be made once per month. If a violation is noted, monitoring reverts to weekly. 3. If the source reverts to weekly monitoring at any time, monitoring frequency will progress in an

identical manner from the initial monitoring frequency. Recordkeeping: 1. The permittee shall maintain records of all observation results using Attachments B & C or

equivalent forms, such as electronic forms, approved by the Air Pollution Control Program, noting: a) Whether any air emissions (except for water vapor) were visible from the emission units and b) All emission units from which visible emissions occurred.

2. The permittee shall maintain records of any equipment malfunctions and maintenance using Attachment D or an equivalent form, such as an electronic form, approved by the Air Pollution Control Program.

3. The permittee shall maintain records of any Method 9 opacity test performed in accordance with this permit condition.

4. These records shall be made available for inspection to the Department of Natural Resources’ personnel upon request.

5. All records must be maintained for five years. Reporting: 1. The permittee shall report to the Air Pollution Control Program’s Compliance/Enforcement Section,

P.O. Box 176, Jefferson City, MO 65102, no later than ten days after an exceedance of the emission limitation.

2. The permittee shall report any deviations from the requirements of this permit condition in the annual monitoring report and annual compliance certification required by Section V of this permit.


10 CSR 10-6.400 Restriction of Emission of Particulate Matter From Industrial Processes Emission Source Description

EP01A (2) Feather Hydrolyzers EP14 Link Belt Screener EP15 Feather Meal Transfer Leg

EP20 & EU13PC Truck Loadout EU07PC PRO*CAL Dryer

Emission Limitations: The permittee shall not emit PM in excess of the limits given in the following table:

Emission Source Description PM Emission Limit (lb/hr) EP01A (2) Feather Hydrolyzers 25.16 each EP14 Link Belt Screener 19.05 EP15 Feather Meal Transfer Leg 19.05

EP20 & EU13PC Truck Loadout 35.43 each EU07PC PRO*CAL Dryer 17.94


Compliance Demonstration: The following table demonstrates that the emission sources are in compliance with the regulation:

Emission Source

MHDR (tph)

PM Emission

Factor (lb/ton)

Emission Factor Source

Potential Uncontrolled PM

Emission Rate (lb/hr)

PM Emission

Limit (lb/hr)

EP01A 15 each 0.061 FIRE Process SCC 30200530

0.92 25.16 EP14 9.9 0.061 0.60 19.05 EP15 9.9 0.061 0.60 19.05

EP20 & EU13PC

25 each 0.083

FIRE Process SCC 30200560, include 3.75% control due to

partial enclosures as provided by AP-42 Table B.2-3

2.15 35.43

EU07PC 9.05 1.22 AP-42 Table 9.5.3-2 11.04 17.94 Monitoring/Recordkeeping/Reporting: The compliance demonstration shows that the emission sources are in compliance with this regulation without the aid of a control device; therefore, no additional monitoring, recordkeeping, or reporting is required at this time.

PERMIT CONDITION 010 10 CSR 10-6.020(2)(I)23 and 10 CSR 10-6.065(5)(C)2 Voluntary Limitation(s)

Emission Unit Description EP10 Feather Meal Dryer #1 EP11 Feather Meal Dryer #2

EP17A Poultry Meal Day Storage Bin EP17B Feed Grade Meal Day Storage Bin CD12 Feather Spray Tower Condenser & #2 Packed Bed Scrubber

Operational Limitation: 1. The permittee shall control particulate emissions from EP10 Feather Meal Dryer #1, EP11 Feather

Meal Dryer #2, EP17A Poultry Meal Day Storage Bin, and EP17B Feed Grade Meal Day Storage Bin with CD12 Feather Spray Tower Condenser and #2 Packed Bed Scrubber at all times.

2. CD12 #2 Packed Bed Scrubber shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. The scrubber shall be equipped with a flow meter that indicates the liquid flow rate through the scrubber. The spray tower shall be equipped with a flow meter which indicates the water flow rate through the tower. The gauges or meters shall be located such that Department of Natural Resources’ employees may easily observe them.

Monitoring/Recordkeeping: 1. The permittee shall monitor and record the operating pressure drop across CD12 #2 Packed Bed

Scrubber at least once every 24 hours. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance specifications.4

4 After the stack testing required by Permit Condition PW001 has been conducted, the operating pressure drop shall be maintained at the average value observed during the three performance test runs.


2. The permittee shall monitor and record the liquid flowrate through CD12 #2 Packed Bed Scrubber at least once every 24 hours. The liquid flowrate shall be maintained within the design conditions specified by the manufacturer's performance specifications.5

3. The permittee shall monitor and record the water flowrate through CD12 Feather Spray Tower Condenser at least once every 24 hours. The water flowrate shall be maintained within the design conditions specified by the manufacturer's performance specifications.6

4. A copy of the manufacturer’s specifications for CD12 Feather Spray Tower Condenser and #2 Packed Bed Scrubber shall be retained onsite.

5. The permittee shall maintain an operating, maintenance, and inspection log for CD12 Feather Spray Tower Condenser and #2 Packed Bed Scrubber which shall include the following: a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and




5 After the stack testing required by Permit Condition PW001 has been conducted, the liquid flow rate shall be maintained at the average value observed during the three performance test runs. 6 After the stack testing required by Permit Condition PW001 has been conducted, the water flow rate shall be maintained at the average value observed during the three performance test runs.


IV. Core Permit Requirements The installation shall comply with each of the following requirements. Consult the appropriate sections in the CFR, CSR, and local ordinances for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect on the date of permit issuance. The following is only an excerpt from the regulation or code, and is provided for summary purposes only. 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 permittee fails to comply with the conditions or any provisions of the permit.

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) Best 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 list to the director in writing at least ten days

prior to any maintenance, start-up or shutdown, 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, it shall be given as soon as practicable prior to the release. If an unplanned excess release of emissions exceeding one hour occurs during maintenance, start-up or shutdown, the director shall be notified verbally as soon as practical during normal working hours and no later than the close of business of the following working day. A written notice shall follow within ten working days.

3. Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under §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 §§ 643.080 or 643.151, RSMo.

4. Nothing in this rule shall be construed to limit the authority of the director or commission to take appropriate action, under §§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.

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. 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 18 months. [10 CSR 10-6.065(5)(B)1.A(III)] The permittee shall retain the most current operating permit issued to this installation on-site. [10 CSR 10-6.065, §(5)(C)(1) and §(6)(C)1.C(II)] The permittee shall immediately make such permit available to any Missouri Department of Natural Resources’ personnel upon request. [10 CSR 10-6.065, §(5)(C)(1) and §(6)(C)3.B] 10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants and 40 CFR Part 61, Subpart M - National Emission Standard for Asbestos

1. The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for any activities occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart M - National Emission Standard for Asbestos.

2. The permittee shall conduct monitoring to demonstrate compliance with registration, certification, notification, and Abatement Procedures and Practices standards as specified in 40 CFR Part 61, Subpart M.

10 CSR 10-6.110 Submission of Emission Data, Emission Fees and Process Information

1. The permittee shall submit full emissions report either electronically via MoEIS, which requires Form 1.0 signed by an authorized company representative, or on 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. The permittee may be required by the director to file additional reports. 3. 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.

4. The permittee shall submit a full EIQ for the 2017, 2020, 2023, and 2026 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.

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


6. The fees shall be payable to the Department of Natural Resources and shall be accompanied by the emissions report.

7. The permittee shall complete required reports on state supplied EIQ forms or electronically via MoEIS. Alternate methods of reporting the emissions can be submitted for approval by the Director. The reports shall be submitted to the director by April 1 after the end of each reporting year. If the full emissions report is filed electronically via MoEIS, this due date is extended to May 1.

8. The reporting period shall end on December 31 of each calendar year. Each report shall contain the required information for each emission unit for the 12-month period immediately preceding the end of the reporting period.

9. The permittee shall collect, record, and maintain the information necessary to complete the required forms during each year of operation of the installation.

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. 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. 10 CSR 10-6.165 Restriction of Emission of Odors

This requirement is not federally enforceable. 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 PM to the Ambient Air Beyond the Premises of Origin

Emission Limitation: 1. 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 PM emissions to go beyond the premises of origin in quantities that the PM may be found on surfaces beyond the property line of origin. The nature or origin of the PM 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 PM 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: 1. 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.

2. The permittee shall maintain the following monitoring schedule: a) The permittee shall conduct weekly observations for a minimum of eight consecutive weeks after

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

i) The permittee may observe once every two weeks for a period of eight weeks. ii) If a violation is noted, monitoring reverts to weekly. iii) Should no violation of this regulation be observed during this period then-

(1) The permittee may observe once per month. (2) If a violation is noted, monitoring reverts to weekly.

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

Recordkeeping: 1. The permittee shall document all readings on Attachment A or an equivalent form, such as an

electronic form, approved by the Air Pollution Control Program, noting the following: a) Whether air emissions (except water vapor) remain visible in the ambient air beyond the property

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

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 10-6.250 Asbestos Abatement Projects – Certification, Accreditation, and Business Exemption Requirements

The permittee shall conduct all asbestos abatement projects within the procedures established for certification and accreditation by 10 CSR 10-6.250. This rule requires individuals who work in asbestos abatement projects to be certified by the Air Pollution Control Program. This rule requires training providers who offer training for asbestos abatement occupations to be accredited by the Air Pollution Control Program. This rule requires persons who hold exemption status from certain requirements of this rule to allow the department to monitor training provided to employees. Each individual who works in asbestos abatement projects must first obtain certification for the appropriate occupation from the department. Each person who offers training for asbestos abatement occupations must first obtain accreditation from the department. Certain business entities that meet the requirements for state-approved exemption status must allow the department to monitor training classes provided to employees who perform asbestos abatement. 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 by a permittee: 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.

Title VI – 40 CFR Part 82 Protection of Stratospheric Ozone

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 §82.106.


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

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

d) No person may modify, remove, or interfere with the required warning statement except as described in §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 40 CFR Part 82, Subpart B: a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices pursuant to §82.156. b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply

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

an approved technician certification program pursuant to §82.161. d) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with

record keeping requirements pursuant to §82.166. ("MVAC-like" appliance as defined at §82.152).

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

f) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §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 ozone-depleting substance refrigerant (or regulated substitute substance) in the MVAC, the permittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air conditioners. The term "motor vehicle" as used in 40 CFR Part 82, Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term "MVAC" as used in 40 CFR Part 82, 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. 40 CFR Part 82 is federally enforceable only.


V. General Permit Requirements

The installation shall comply with each of the following requirements. Consult the appropriate sections in the CFR and 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. 10 CSR 10-6.065, §(5)(E)2 and §(6)(C)1.B 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. 10 CSR 10-6.065, §(5)(C)1 and §(6)(C)1.C General Record Keeping and Reporting Requirements

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’s Compliance/Enforcement

Section, P. O. 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 10

CSR 10-6.065(6)(C)7 (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.

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 annual report shall be reported on the schedule specified in this permit, and no


later than ten days after any exceedance of any applicable rule, regulation, or other restriction.

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.

10 CSR 10-6.065 §(5)(C)1 and §(6)(C)1.D Risk Management Plan Under §112(r)

1. The permittee shall comply with the requirements of 40 CFR Part 68 - Accidental Release Prevention Requirements. If the permittee has more than a threshold quantity of a regulated substance in process, as determined by §68.115, the permittee shall submit a Risk Management Plan in accordance with 40 CFR Part 68 no later than the latest of the following dates: a) June 21, 1999; b) Three years after the date on which a regulated substance is first listed under §68.130; or c) The date on which a regulated substance is first present above a threshold quantity in a process.

10 CSR 10-6.065(5)(C)1.A 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.

10 CSR 10-6.065(5)(C)1.C Reasonably Anticipated Operating Scenarios

None.


10 CSR 10-6.065, §(5)(B)4; §(5)(C)1, §(6)(C)3.B; and §(6)(C)3.D; and §(5)(C)3 and §(6)(C)3.E.(I) – (III) and (V) – (VI) Compliance Requirements

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

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 the Air Pollution Control Program’s Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and exceedances 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. 10 CSR 10-6.065, §(5)(C)1 and §(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, c) That the permittee took all reasonable steps to minimize emissions that exceeded technology-

based 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.

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 installation’s 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’s Compliance/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.

10 CSR 10-6.020(2)(R)34 Responsible Official

The application utilized in the preparation of this permit was signed by Jeff Webster, Chief Operating Officer. 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 permittee 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 permittee 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. 10 CSR 10-6.065 §(5)(E)4 and §(6)(E)6.A(III)(a)-(c) Reopening-Permit for Cause

1. This permit may be reopened for cause if:


a) The Missouri Department of Natural Resources or 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,

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

expire; or iii) 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,

c) The Missouri Department of Natural Resources or EPA determines that the permit must be reopened and revised to assure compliance with applicable requirements.

10 CSR 10-6.065 §(5)(E)1.A and §(6)(E)1.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 E contains a list of common abbreviations and acronyms used throughout the permit.


Attachment A Fugitive Emission Observations

Date Time

Visible Emissions beyond the Property Boundary Excess Emissions

No Yes7 Cause Corrective Action Initial

7 If there are visible emissions, the permittee shall complete the excess emissions columns.


Attachment B Method 22 Visible Emission Observations

Date Time Emission

Point/Source

Visible Emissions

No Yes8

8 If visible emissions are observed from an emission point/source, the source representative shall conduct a Method 9 opacity observation using Attachment C to quantify the percent opacity.


Attachment C

Method 9 Opacity Emissions Observations

Company Observer

Location Observer Certification Date

Date Emission Unit

Time Control Device

Hour Minute Seconds Steam Plume (check if applicable)

Comments 0 15 30 45 Attached Detached

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

SUMMARY OF AVERAGE OPACITY

Set Number Time Opacity

Start End Sum Average

Readings ranged from ____________ to ____________ % opacity. Was the emission unit in compliance at the time of evaluation? _____ _____ _________________ YES NO Signature of Observer


Attachment D Inspection/Maintenance/Repair/Malfunction Log

Emission Unit # or CVM # ______________________________________

Date/Time

Inspection/ Maintenance

Activities

Malfunction Activities

Malfunction Impact Duration Cause Action Initials


Attachment E Abbreviations and Acronyms

ºC..............degrees Celsius oF ............... degrees Fahrenheit

AAQIA ..... ambient air quality impact analysis

acfm .......... actual cubic feet per minute

BACT ....... Best Available Control Technology

BMPs ........ Best Management Practices

Btu ............ British thermal unit

CAM ......... Compliance Assurance Monitoring

CAS .......... Chemical Abstracts Service

CEMS ....... Continuous Emission Monitor System

CFR .......... Code of Federal Regulations

CO ............ carbon monoxide

CO2 ........... carbon dioxide

CO2e ......... carbon dioxide equivalent

COMS....... Continuous Opacity Monitoring System

CSR .......... Code of State Regulations

dscf ............ dry standard cubic feet

dscm..........dry standard cubic meter

EIQ ........... Emission Inventory Questionnaire

EP ............. Emission Point

EPA .......... Environmental Protection Agency

EU ............. Emission Unit

FGD .......... flue gas desulfurization

FIRE.........EPA’s Factor Information Retrieval System

fps ............. feet per second

ft ................ feet

GACT ....... Generally Available Control Technology

GHG ......... Greenhouse Gas

gpm ........... gallons per minute

gr ............... grains

GWP ......... Global Warming Potential

HAP .......... Hazardous Air Pollutant

hr .............. hour

HP ............. horsepower

lb ............... pound

lb/hr .......... pounds per hour

MACT ...... Maximum Achievable Control Technology

µg/m3 ........ micrograms per cubic meter

m/s ............ meters per second

mg.............milligrams

Mgal ......... 1,000 gallons

MW .......... megawatt

MHDR...... maximum hourly design rate

MMBtu .... Million British thermal units

mmHg.......millimeters mercury

MMscf ...... Million standard cubic feet

MSDS ....... Material Safety Data Sheet

NAAQS .... National Ambient Air Quality Standards

NESHAPs National Emissions Standards for Hazardous Air Pollutants

NOx ........... nitrogen oxides

NSPS ........ New Source Performance Standards

NSR .......... New Source Review

PM ............ particulate matter

PM2.5 ......... particulate matter less than 2.5 microns in aerodynamic diameter

PM10 ......... particulate matter less than 10 microns in aerodynamic diameter

ppm .......... parts per million

PSD ........... Prevention of Significant Deterioration

psi.............pounds per square inch

PTE .......... potential to emit

RACT ....... Reasonable Available Control Technology

RAL .......... Risk Assessment Level

SCC .......... Source Classification Code

scfm .......... standard cubic feet per minute

SCR .......... selective catalytic reduction

SIC ........... Standard Industrial Classification

SIP ............ State Implementation Plan

SMAL ....... Screening Model Action Levels

SOx ............ sulfur oxides

SO2 ............ sulfur dioxide

tph ............ tons per hour

tpy ............. tons per year

VMT ......... vehicle miles traveled

VOC ......... Volatile Organic Compound


Attachment F Synthetic Minor NOx Limit Tracking Sheet

Emission Source

Description Monthly Usage NOx Emission

Factor Emission Factor

Source Monthly NOx

Emissions9 (tons)

EP06 Boiler #2

Mgal 13 lb/Mgal

propane AP-42 Table 1.5-1

MMscf 100 lb/MMscf

natural gas AP-42 Table 1.4-1

Mgal 25.98 lb/Mgal poultry oil10

June 2002 Stack Test

EP07 Boiler #3

Mgal 13 lb/Mgal


MMscf 100 lb/MMscf




EP08 Boiler #4

Mgal 13 lb/Mgal


MMscf 100 lb/MMscf




EP09 Boiler #5

Mgal 13 lb/Mgal


MMscf 100 lb/MMscf




EP12 Feather Meal Dryer

#1

MMscf 100 lb/MMscf


Mgal 13 lb/Mgal



#2

MMscf 100 lb/MMscf


Mgal 13 lb/Mgal


EU12PC Thermal Oxidizer #1 hours 11.6 lb/hr14 Project

2005-01-067

9 Monthly NOx Emissions (tons) = Monthly Usage x NOx Emission Factor x 0.0005 ton/lb. 10 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 11 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 12 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 13 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 14 This emission factor includes NOx created from the combustion of natural gas and from the conversion of NH3 to NOx at the high thermal oxidizer operating temperature. This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001.


Emission Source

Description Monthly Usage NOx Emission

Factor Emission Factor

Source Monthly NOx

Emissions9 (tons)

EU27 Thermal Oxidizer #2 MMscf

100 lb/MMscf natural gas15

AP-42 Table 1.4-1

Mgal 13 lb/Mgal propane16

AP-42 Table 1.5-1



AP-42 Table 1.4-1

Mgal 13 lb/Mgal propane18

AP-42 Table 1.5-1

EU27 & EU28

Thermal Oxidizers #2 and #3

hours 5.45 lb/hr19 Project

2005-12-046

EU31 Emergency Generator

MMBtu 4.08 lb/MMBtu AP-42 Table 3.2-2


MMBtu 4.08 lb/MMBtu AP-42 Table 3.2-2

EU33 Dehumidifiers/Roof

Heaters MHDR = 5 MMBtu/hr

100 lb/MMscf AP-42 Table 1.4-1 0.1820

- (8) Space Heaters MHDR = 0.6

MMBtu/hr each 100 lb/MMscf AP-42 Table 1.4-1 0.1721

Installation Monthly SSM NOx Emissions22 (tons): Installation Monthly NOx Emissions23 (tons):

12-Month Rolling Total NOx Emissions24 (tons):

15 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 16 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 17 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 18 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 19 This emission factor represents NOx emissions from the conversion of NH3 to NOx at the high thermal oxidizer operating temperature. This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 20 Assumes a heat content of 1,020 MMBtu/MMscf. 21 Assumes a heat content of 1,020 MMBtu/MMscf. 22 As reported to the Air Pollution Control Program’s Compliance/Enforcement section for compliance with 10 CSR 10-6.050. 23 Installation Monthly NOx Emissions (tons) = the sum of each emission source’s Monthly NOx Emissions (tons) + Installation Monthly SSM NOx Emissions (tons). 24 12-Month Rolling Total NOx Emissions (tons) = the sum of the 12 most recent Installation Monthly NOx Emissions (tons). 12-Month Rolling Total NOx Emissions of less than 100.0 tons per year indicates compliance with Permit Condition PW001.


Attachment G Synthetic Minor PM10 Limit Tracking Sheet

Emission Source

Description Monthly

Usage

PM10 Emission

Factor

Control Efficiency


Monthly PM10

Emissions25 (tons)

EP01A (2) Feather

Hydrolyzers tons 0.034 lb/ton 0%

FIRE Process SCC 30200530

EP01C (7) Dupps Screw

Presses tons 0.034 lb/ton 0%

EP06 Boiler #2

Mgal 0.7 lb/Mgal

propane 0% AP-42 Table 1.5-1

MMscf 7.6

lb/MMscf natural gas

0% AP-42 Table 1.4-2

Mgal 4.58

lb/Mgal poultry oil26

0% June 2002 Stack

Test

EP07 Boiler #3

Mgal 0.7 lb/Mgal


MMscf 7.6


0% AP-42 Table 1.4-2

Mgal 4.58


0% June 2002 Stack

Test

EP08 Boiler #4

Mgal 0.7 lb/Mgal


MMscf 7.6


0% AP-42 Table 1.4-2

Mgal 4.58


0% June 2002 Stack

Test

EP09 Boiler #5

Mgal 0.7 lb/Mgal


MMscf 7.6


0% AP-42 Table 1.4-2

Mgal 4.58


0% June 2002 Stack

Test

25 Monthly PM10 Emissions (tons) = Monthly Usage x PM10 Emission Factor x 0.0005 ton/lb. 26 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 27 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 28 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001.


Emission Source

Description Monthly

Usage

PM10 Emission

Factor

Control Efficiency


Monthly PM10

Emissions25 (tons)

EP10/EP12 Feather Meal Dryer

#1 tons 0.32 lb/ton30 Scrubber

Controlled Emission Factor31


EP11/EP13 Feather Meal Dryer

#2 tons 0.32 lb/ton32

EP14 Link Belt Screener tons 0.034 lb/ton 0% FIRE Process

SCC 30200530

EP15 Feather Meal Transfer Leg

tons 0.034 lb/ton 0%

EP16 Feather Meal Storage Bins

tons 0.0063 lb/ton

0%

FIRE Process SCC 30200540

EP17A Poultry Meal Day

Storage Bin tons

0.0063 lb/ton

90%33

EP17B Feed Grade Meal Day Storage Bin

tons 0.0063 lb/ton

EP18A Feed Grade Bucket

Elevator

tons 0.034 lb/ton 0% FIRE Process

SCC 30200530

EP18B High Ash Bucket

Elevator

EP18C Low Ash Bucket

Elevator

EP18D Pet Food Grade Bucket Elevator

EP22 Feather Meal Silos tons 0.0063 lb/ton

0% FIRE Process

SCC 30200540

EP19B High Ash Storage

Bin tons

0.0063 lb/ton

EP19C Low Ash Storage

Bin tons

0.0063 lb/ton

EP19D Pet Food Storage

Bin EP20 & EU13PC

Truck Loadout tons 0.029 lb/ton 3.7534% FIRE Process

SCC 30200560

EP21 Hanging Room Exhaust Vents

tons 0.022282

lb/ton 0%

January 2011 Engineering Test

EU07PC Pro*Cal Dryer tons 1.22 lb/ton35 0% AP-42 Table

9.5.3-2

29 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 30 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 31 Scrubber required by Permit Condition 010. 32 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 33 Packed bed scrubber required by Permit Condition 010. 34 For partial enclosures as provided in AP-42 Table B.2-3. 35 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001.


Emission Source

Description Monthly

Usage

PM10 Emission

Factor

Control Efficiency


Monthly PM10

Emissions25 (tons)

EU08PC Pro*Cal

Hammermill tons 0.012 lb/ton

Baghouse Controlled Emission Factor36

Baghouse Controlled, FIRE

Process SCC 30200817

EU09PC Pro*Cal Screening tons 0.38 lb/ton 99.5%37 FIRE Process

SCC 3020053738

EU10PC Pro*Cal Conveyors tons 0.034 lb/ton 99.5%39 FIRE Process

SCC 30200530

EU11PC (3) Pro*Cal Storage

Bins tons

0.0063 lb/ton

50%40 FIRE Process

SCC 30200540

EU12PC Thermal Oxidizer #1

MMscf 7.6 lb/MMScf41

0% FIRE Process SCC 10200602

Mgal 0.7 lb/Mgal propane42

0% AP-42 Table 1.5-1

EU25A Feed Bin tons 0.0063 lb/ton

0% FIRE Process SCC 30200540

EU25B (3) Dupps Screw Presses

tons 0.034 lb/ton 0% FIRE Process SCC 30200530

EU27 Thermal Oxidizer #2

hours 1.5 lb/hr43 0% Construction Permit 032006-

005B limit

EU28 Thermal Oxidizer #3

hours 1.5 lb/hr44 0%

36 Baghouses required by Permit Condition 003. 37 Baghouses required by Permit Condition 003. 38 FIRE Process SCC 30200537 provides a cyclone controlled emission factor of 0.019 lb/ton; however, this is a baghouse controlled source. To establish the uncontrolled emission factor the cyclone control emission factor was divided by an estimated cyclone control efficiency of 95% from AP-42 Table B.2-3. 39 Filter receiver required by Permit Condition 003. 40 Operation of a baghouse. The baghouse is considered an inherent control device; therefore, no practically enforceable control device requirement has been included in the permit. Only 50% control efficiency was given as it is unclear if the control equipment would achieve a higher control efficiency given the relatively low loading level. 41 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 42 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 43 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 44 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001.


Emission Source

Description Monthly

Usage

PM10 Emission

Factor

Control Efficiency


Monthly PM10

Emissions25 (tons)

EU30 Lime Silo tons 1.1 lb/ton 50%45 FIRE Process SCC 30501117


MMBtu 0.0099871 lb/MMBtu

0% AP-42 Table 3.2-2



0% AP-42 Table 3.2-2

EU33 Dehumidifiers/Roof Heaters

MHDR = 5

MMBtu/hr

7.6 lb/MMscf

0% AP-42 Table 1.4-2 0.0146

- (8) Space Heaters MHDR = 0.6

MMBtu/hr each

7.6 lb/MMscf

0% AP-42 Table 1.4-2 0.0147

Installation Monthly SSM PM10 Emissions48 (tons): Installation Monthly PM10 Emissions49 (tons):

12-Month Rolling Total PM10 Emissions50 (tons):

45 Operation of a bin vent filter. The bin vent filter is considered an inherent control device; therefore, no practically enforceable control device requirement has been included in the permit. Only 50% control efficiency was given as it is unclear if the control equipment would achieve a higher control efficiency given the relatively low loading level. 46 Assumes a heat content of 1,020 MMBtu/MMscf. 47 Assumes a heat content of 1,020 MMBtu/MMscf. 48 As reported to the Air Pollution Control Program’s Compliance/Enforcement section for compliance with 10 CSR 10-6.050. 49 Installation Monthly PM10 Emissions (tons) = the sum of each emission source’s Monthly PM10 Emissions (tons) + Installation Monthly SSM PM10 Emissions (tons). 50 12-Month Rolling Total PM10 Emissions (tons) = the sum of the 12 most recent Installation Monthly PM10 Emissions (tons). 12-Month Rolling Total PM10 Emissions of less than 100.0 tons per year indicates compliance with Permit Condition PW001.


Attachment H Synthetic Minor CO Limit Tracking Sheet

Emission Source

Description Monthly

Usage CO Emission

Factor Emission

Factor Source

Monthly CO Emissions51

(tons)

EP06 Boiler #2

Mgal 7.5 lb/Mgal

propane AP-42 Table

1.5-1

MMscf 84 lb/MMscf natural gas

AP-42 Table 1.4-1



EP07 Boiler #3

Mgal 7.5 lb/Mgal

propane AP-42 Table

1.5-1


AP-42 Table 1.4-1



EP08 Boiler #4

Mgal 7.5 lb/Mgal

propane AP-42 Table

1.5-1


AP-42 Table 1.4-1



EP09 Boiler #5

Mgal 7.5 lb/Mgal

propane AP-42 Table

1.5-1


AP-42 Table 1.4-1




#1


AP-42 Table 1.4-1

Mgal 7.5 lb/Mgal

propane AP-42 Table

1.5-1


#2


AP-42 Table 1.4-1

Mgal 7.5 lb/Mgal

propane AP-42 Table

1.5-1

51 Monthly CO Emissions (tons) = Monthly Usage x CO Emission Factor x 0.0005 ton/lb. 52 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 53 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 54 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 55 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001.


Emission Source

Description Monthly

Usage CO Emission

Factor Emission

Factor Source

Monthly CO Emissions51

(tons)

EU12PC Thermal Oxidizer #1 MMscf


AP-42 Table 1.4-1


AP-42 Table 1.5-1



AP-42 Table 1.4-1


AP-42 Table 1.5-1



AP-42 Table 1.4-1


AP-42 Table 1.5-1


MMBtu 0.557 lb/MMBtu AP-42 Table

3.2-2



EU33 Dehumidifiers/Roof

Heaters MHDR = 5 MMBtu/hr

84 lb/MMscf AP-42 Table

1.4-1

0.1562

- (8) Space Heaters MHDR = 0.6 MMBtu/hr

each 84 lb/MMscf 0.1463

Installation Monthly SSM CO Emissions64 (tons): Installation Monthly CO Emissions65 (tons):

12-Month Rolling Total CO Emissions66 (tons): 56 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 57 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 58 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 59 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 60 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 61 This emission factor shall be replaced with the emission factor established during stack testing required by Permit Condition PW001. 62 Assumes a heat content of 1,020 MMBtu/MMscf. 63 Assumes a heat content of 1,020 MMBtu/MMscf. 64 As reported to the Air Pollution Control Program’s Compliance/Enforcement section for compliance with 10 CSR 10-6.050. 65 Installation Monthly CO Emissions (tons) = the sum of each emission source’s Monthly CO Emissions (tons) + Installation Monthly SSM CO Emissions (tons). 66 12-Month Rolling Total CO Emissions (tons) = the sum of the 12 most recent Installation Monthly CO Emissions (tons). 12-Month Rolling Total CO Emissions of less than 100.0 tons per year indicates compliance with Permit Condition PW001.

Simmons Feed Ingredients, Inc. Intermediate Operating Permit SB - 1 Installation ID: 119-0017 Project No. 2014-09-054

STATEMENT OF BASIS Voluntary Limitations 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)1.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 18 months in advance of the exceedance, since it can take that long or longer to obtain a part 70 operating permit. INSTALLATION DESCRIPTION Simmons Feed Ingredients, Inc. operates a poultry rendering plant near Southwest City, Missouri. The installation currently operates three distinct lines: a feather meal line, a poultry meal line, and a feed production process line. In the feather meal line, wet feathers and blood are fed to two continuous hydrolyzer process lines. Using elevated temperatures and pressures, keratin, the main component of feathers, is converted into amino acids. The product is then transferred onto a conveyor that transports the material to a scalper screen and into a bin. The bin feeds two 18.9 MMBtu/hr natural gas-fired feather dryers. Particulate emissions from the dryers are controlled by cyclones. The product exiting the dryers has a moisture content of seven percent and is fed into storage bins. From the storage bin material is transferred to a hammermill to create the appropriate size feeds. The finished products are conveyed to storage bins to await shipping via trucks to customers. The poultry meal line operates along similar lines. Poultry by-products are received from the rendering plant located at the site and from other poultry rendering operations in the region. The meat is crushed and fed to continuous cookers with an animal fat mixture. The resulting product is drained of excess fat that is recycled to the cookers, and then fed to a screw press, removing more of the fat and liquids. The product is transferred to storage bins and then to a series of grinders that produce two grades of meal: feed grade and pet food grade. The feed grade meal is transferred directly to storage bins to await shipping. The pet food grade meal is sent to a pellet cooler and then to a series of screens that separates the meal into different sizes for different applications. The finished products are then transferred to storage bins to await shipping via trucks to customers. This process line has no federally enforceable control devices. The feed production process line uses blood (21,828 pounds per hour) and dissolved air flotation (DAF) skimmings - a wastewater byproduct (24,000 pounds per hour) generated in the Simmons poultry rendering process to bind fat using a low temperature chemical reaction. The process is capable of producing 65.6 tons of feed product per day. A thermal oxidizer is used to control VOC and odorous emissions from this process line. When the thermal oxidizer is offline, a packed bed scrubber is used to control odorous emissions. Baghouses and a filter receiver are used to the control the hammermill, screen, and conveyors on this process line.


The installation also operates four 50.4 MMBTU/hr boilers. The boilers can combust natural gas, propane or poultry derived oil as fuel. The installation is not a named installation; therefore, fugitive emissions do not count towards major source applicability. Updated Potential to Emit for the Installation

Pollutant Unconditioned Potential to Emit

(tons per year)67 Conditioned Potential to Emit

(tons per year) CO 165.80 <100.0 NOx 390.89 <100.0 PM10 169.36 <100.0 PM2.5 147.38 ≤ PM10

SOx 13.18 N/A VOC 17.50 N/A HAP 3.76 N/A

Hexane 3.55 N/A

67 Each emission source was evaluated at 8,760 hours of uncontrolled annual operation unless otherwise noted:

Particulate emissions from EU08PC, EU09PC, and EU10 PC are controlled by baghouses or filter receivers required by Permit Condition 003.

Particulate emissions from EU23 and EU26 are routed to EU27 or EU28 thermal oxidizers and limited to 1.5 lb/hr PM10 as required by Permit Condition 002.

EU31 and EU32 were evaluated at 500 hours of annual operation per EPA guidance for emergency generators.

Potential emissions do not include emissions from storage tanks, the laboratory, or the cooling towers. The PTE includes 3.75 percent control of particulates from EP20 and EU13 Truck Loadout for partial

enclosure. The PTE includes 90 percent control of particulates from EP17A and EP17B due to the operation of a

scrubber required by Permit Condition 010. Potential emissions from the Feather Meal Dryers (EP10 and EP11) were based upon cyclone controlled

stack testing conducted in June of 1998 which indicated 1.7658 pounds PM10 per ton (1.606 lb/ton filterables and 0.16 lb/ton condensables). The cyclones are considered inherent; therefore, practically enforceable conditions for their operation have not been included in the permit. The PTE includes 90% control of filterable particulates from EP10 and EP11 due to the operation of a scrubber required by Permit Condition 010.

The PTE includes 50% control of particulates for EU11PC and EU30 due to the operation of inherent control devices (baghouse and bin vent filter, respectively). Only 50% was given as it is unclear if the control equipment would achieve a higher control efficiency given the relatively low loading level.


Reported Air Pollutant Emissions, tons per year Pollutants 2015 2014 2013 2012 2011

CO 49.68 51.49 48.96 54.05 54.05 NOx 55.86 57.56 54.83 40.07 40.07 PM10 15.49 8.04 7.36 8.11 8.11 PM2.5 13.67 6.34 6.02 6.54 6.55 SOx 0.35 0.37 0.35 0.39 0.39

VOC 4.81 5.79 3.21 3.54 3.54 HAP 0.22 1.05 - - -

Hexane 0.21 1.00 - - - Permit Reference Documents 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 September 29, 2014 2. 2014, 2013, 2012, 2011, and 2010 Emissions Inventory Questionnaires 3. U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition 4. WebFIRE: http://cfpub.epa.gov/webfire/index.cfm?action=fire.SearchEmissionFactors 5. Construction Permits 112011-001, 032006-005, 032006-005A, 032006-005B, 052005-026, 082001-

008, 082001-008A, and 0199-020. Construction Permit History No Construction Permit Required Determination, Issued November 19, 2015: Like kind replacement of 19A Feed Grade Storage Bins with EP22 Feather Meal Silos. Construction Permit 112011-001, Issued November 2, 2011: This Section (5) NSR Permit is for the operation of two alternative scenarios:

o Alternative Scenario #1: Use of EU12PCB Packed Bed Scrubber when EU12PC Thermal Oxidizer #1 is not in use.

o Alternative Scenario #2: Use of EU06PCB Centrifuge as a back-up to EU06PC PRO*CAL Press.

Special Condition 1 supersedes Special Conditions 3 and 4 of Construction Permit 052005-026. Special Conditions 2 and 3 have been applied in Permit Condition 001. Special Condition 4 requires the installation to comply with 10 CSR 10-6.165. 10 CSR 10-6.165 is

included in Section IV of this permit. Construction Permit 032006-005, Issued March 6, 2006: Construction Permit 032006-005A, Issued August 2, 2006: Construction Permit 032006-005B, Issued May 23, 2014: This Section (6) NSR Permit is for an expansion of the offal processing system (EU23, EU24, EU25,

EU26, EU27, and EU28). Special Condition 1 has been included in Permit Condition 002.


Construction Permit 052005-026, Issued May 25, 2005: This Section (6) NSR Permit is for the installation of a new feed production process line (EU01PC

through EU12PC). Special Conditions 1 and 2 have been included in Permit Condition 003. Construction Permit 082001-008, Issued July 12, 2001: Construction Permit 082001-008A, Issued October 31, 2002: This Section (6) NSR Permit is for the use of poultry-derived oil in the installation’s boilers. Special Condition 1 requires the installation to comply with 10 CSR 10-3.090. 10 CSR 10-3.090 has

been rescinded and replaced by 10 CSR 10-6.165. 10 CSR 10-6.165 is included in Section IV of this permit.

The installation conducted stack testing in June 2002 which indicates that poultry-derived oil emits 4.58 lb PM/Mgal, 1.8 lb SOx/Mgal, 25.98 lb NOx/Mgal, 0.09 lb VOC/Mgal, and 0.05 lb CO/Mgal.

Construction Permit 0199-020, Issued December 30, 1998: This Section (5) NSR Permit is allowed for the conversion of the feather meal line from a batch

process to a continuous process and the addition of a blood coagulation system. Special Conditions 1 and 2 require the installation to comply with 10 CSR 10-3.090. 10 CSR 10-

3.090 has been rescinded and replaced by 10 CSR 10-6.165. 10 CSR 10-6.165 is included in Section IV of this permit.

NSPS Applicability 40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units is applicable to EP06, EP07, EP08, and EP09 Boilers and has been applied in Permit Condition 004. 40 CFR Part 60, Subparts K and Ka – Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to July 23, 1984 is not applicable to the installation. These regulations apply to tanks with a capacity greater than 151,412 liters (40,000 gallons) that store petroleum liquids. The only tanks of sufficient capacity are a 150,000 gallon water tank and a 70,000 gallon CO2 tank; however, water and CO2 do not meet the definition of petroleum liquids in §60.111(b) or §60.111a(b). 40 CFR Part 60, Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 is not applicable to the installation and has not been applied within this permit. This regulation applies to tank with a capacity greater than 75 m3 (19,812 gallons) storing a liquid with a maximum true vapor pressure less than 15.0 kPa. Emission Unit Description Maximum True Vapor Pressure (kPa)

- (9) 26,000 gallon poultry fat tanks

N/A – nonvolatile at room temperature

- (4) 26,000 gallon poultry digest tanks

EU01PC (2) 26,083 gallon PRO*CAL Poultry Blood Tanks

(4) 26,083 gallon PRO*CAL SPN Tanks - 24,000 gallon DAF skimming tank - 24,000 gallon biosolids tank


Emission Unit Description Maximum True Vapor Pressure (kPa) - 22,000 gallon water tank

Not a VOL - (2) 39,964 gallon water tanks - 150,000 gallon water tank - 70,000 gallon CO2 tank - 26,000 gallon ammonia tank

40 CFR Part 63, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines applies to EU31 and EU32 and has been applied in Permit Conditions 005 and 006. MACT Applicability 40 CFR Part 63, Subpart Q – National Emission Standards for HAPs for Industrial Process Cooling Towers is not applicable to the installation. This regulation applies to major HAP sources which use chromium-based water treatment chemicals. The installation is an area source of HAP and does not use chromium-based water treatment chemicals. 40 CFR Part 63, Subpart T – National Emission Standards for Halogenated Solvent Cleaning is not applicable to the installation. The installation’s two parts washers are not permitted to use methylene chloride (75-09-2), perchloroethylene (127-18-4), trichloroethylene (79-01-6), 1,1,1-trichloroethane (71-55-6), carbon tetrachloride (56-23-5), or chloroform (67-66-3). 40 CFR Part 63, Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines is applicable to the installation; however, §63.6590(c)(1) states that new stationary RICE located at an area source shall meet the requirements of MACT ZZZZ by meeting the requirements for NSPS JJJJ. 40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources applies to EP06, EP07, EP08, and EP09 while combusting poultry oil as §63.11237 states that the “oil subcategory includes any boiler that burns any liquid fuel and is not in either the biomass or coal subcategories. Gas-fired boilers that burn liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or for periodic testing are not included in this definition. Periodic testing on liquid fuel shall not exceed a combined total of 48 hours during any calendar year.” This regulation has been applied in Permit Condition 008. 40 CFR Part 63, Subpart DDDDDDD – National Emission Standards for Hazardous Air Pollutants for Area Sources: Prepared Feeds Manufacturing is not applicable to the installation and has not been applied in this permit. The installation does not add any materials containing chromium or manganese to the meal they produce. National Emission Standards for Hazardous Air Pollutants Applicability 40 CFR Part 61, Subpart M – National Emission Standards for Asbestos is applicable to the installation and has been applied in Section IV Core Permit Requirements.


Other Regulatory Determinations 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants is applicable to the installation and has been applied in Permit Condition 008. Emission sources regulated by 10 CSR 10-6.070 (EP06, EP07, EP08, EP09, EU31, and EU32) are

exempt per 10 CSR 10-6.220(1)(H). EP01C, EP16, EP17A, EP17B, EP18A, EP18B, EP18C, EP18D, EP22, EP19B, EP19C, EP19D,

EU08PC, EU09PC, EU10PC, EU11PC, EU12PC, EU25A, EU25B, EU30, EU33, TST30, and the space heaters are subject to this regulation, but are expected to be in compliance while being properly maintained and operated; therefore, no monitoring, recordkeeping, or reporting is required at this time.

10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds does not apply to the installation. Emissions sources subject to an applicable sulfur compound emission limit under 10 CSR 10-6.070 (EP06, EP07, EP08, and EP09) are exempt per 10 CSR 10-6.260(1)(A)1. Combustion equipment that exclusively combusts pipeline grade natural gas (EP10, EP11, EU12PC, EU27, EU28, EU31, EU32, EU33, and space heaters) are exempt per 10 CSR 10-6.260(1)(A)2. 10 CSR 10-6.261 Control of Sulfur Dioxide Emissions does not apply to the installation. Emissions sources subject to an applicable sulfur compound emission limit under 10 CSR 10-6.070 (EP06, EP07, EP08, and EP09) are exempt per 10 CSR 10-6.261(1)(C)1. Combustion equipment that exclusively combusts pipeline grade natural gas (EP10, EP11, EU12PC, EU27, EU28, EU31, EU32, EU33, and space heaters) are exempt per 10 CSR 10-6.261(1)(A). 10 CSR 10-6.400 Restriction of Emission of Particulate Matter From Industrial Processes is applicable to the installation and has been applied in Permit Condition 009. The burning of fuel for indirect heating (EP06, EP07, EP08, and EP09) is exempt per 10 CSR 10-

6.400(1)(B)6. Emission sources (EP01C, EP16, EP17A, EP17B, EP18A, EP18B, EP18C, EP18D, EP22, EP19B,

EP19C, EP19D, EU08PC, EU09PC, EU10PC, EU11PC, EU12PC, EU25A, EU25B, EU30, EU33, TST30, and the space heaters) that at maximum design capacity have a potential to emit of less than 0.5 pounds per hour of particulate matter are exempt per 10 CSR 10-6.400(1)(B)12.

Emission sources (EP10 and EP11) subject to a federally enforceable requirement (Permit Condition 010) to install, operate, and maintain a particulate matter control device system that controls at least 90% of particulate matter emissions are exempt per 10 CSR 10-6.400(1)(B)15.

10 CSR 10-6.405 Restriction of Particulate Matter Emissions From Fuel Burning Equipment Used For Indirect Heating is not applicable to the installation. Emission sources (EP06, EP07, EP08, EP09, EP10, EP11, EU33, and space heaters) that are subject to 10 CSR 10-6.070 or are fueled by exclusively by natural gas are exempt per 10 CSR 10-6.405(1)(C). 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 Air Pollution Control Program'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 Air Pollution Control Program a schedule for achieving compliance for that regulation(s).

Simmons Feed Ingredients, Inc. Intermediate Operating Permit RPC - 1 Installation ID: 119-0017 Project No. 2014-09-054

Response to Public Comments The draft Intermediate Operating Permit, Project 2014-09-054, for Simmons Feed Ingredients, Inc. (119-0017) was placed on public notice as of November 23, 2016, 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://www.dnr.mo.gov/env/apcp/PermitPublicNotices.htm on Friday, November 18, 2016. On December 7, 2016, the Air Pollution Control Program received comments from Mark A. Smith, Air Permitting and Compliance Branch Chief for EPA Region VII.

EPA Comment #1: Permit Condition PW001 establishes synthetic minor emission limits on nitrogen oxides (NOx); particulate matter less than ten (10) microns in diameter (PM10); and carbon monoxide (CO) from the entire installation (emphasis added), allowing Simmons Feed to operate under this Intermediate State Permit to Operate. Permit Condition PW001 requires the permittee to record NOx, PM10, and CO emissions using Attachment F (Synthetic Minor NOx Limit Tracking Sheet); Attachment G (Synthetic Minor PM10 Limit Tracking Sheet); and Attachment H (Synthetic Minor CO Limit Tracking Sheet), or a MDNR approved equivalent. However, when comparing the emission sources in Attachments F, G, and H with the emission sources listed in Section I (Installation Equipment Listing), it is unclear whether or not the entire installation (emphasis added) is being counted in the summations of monthly and 12-month rolling total NOx, PM10, and CO emissions. In its response to a petition against an operating permit issued to Hu Honua Bioenergy on February 2, 2014, the Environmental Protection Agency granted the petitioners contention that the permit was unclear whether all actual emissions were considered in determining compliance with the synthetic minor limits. The Environmental Protection Agency granted that for purposes of determining emissions, all emission units that are part of the sources physical and operational design, must be included in determining voluntary limit compliance, including the emission units that have been designated as without limitations and any designated insignificant activities. Additionally, 80 to 86% of the emission factors, used in Attachments F, G, and H, rely on either AP-42 or WebFIRE as the source of the emission factors. The introductions to both AP-42 and WebFIRE, say the “use of these emission factors as source-specific permit limits and/or as emission regulation compliance determinations is not (emphasis added) recommended by the Environmental Protection Agency.” The introductions go on to say “source-specific tests or continuous emission monitors can determine the actual pollutant contribution from an existing source better than these emission factors. A material balance approach also may provide reliable average emission estimates for specific sources.” Therefore, EPA strongly recommends Simmons Feed and MDNR amend Attachments F, G, and H to include all (emphasis added) facility emission units and reduce the reliance on AP-42 and WebFIRE emission factors for compliance verification.


Finally, there are eleven (11) emission factors based on a 2002 stack test; one (1) emission factor from a 1998 stack test; one (1) emission factor from a 2011 engineering test; and two (2) emission factors from 2005 projects being used within Attachment F, G, and H. EPA is concerned with the use of emission factors that were developed 10 or 15 years ago. Based on their construction history, Simmons Feed has undergone several process changes since 2002, yet relies on one-time stack tests done in 1998, 2002, and 2005. EPA strongly recommends MDNR use their 10 CSR 10-6-065(5)(C)1 and 10 CSR 10-6.065(6)(C)1.C(I) authority and include a requirement for Simmons Feed to conduct stack tests within one (1) year of operating permit issue and update emission factors accordingly. EPA also recommends MDNR include a requirement to conduct repeat stack testing at least once during the term of the operating permit.

Missouri Air Pollution Control Program Response: The following table identifies for each piece of equipment at the installation what pollutants are emitted: Emission Sources

Description Pollutants Emitted

EP01A (2) Feather Hydrolyzers PM10, PM2.5


CO, HAP, NOx, PM10, PM2.5, SOx, VOC







EP10 Feather Meal Dryer #1 – material handling PM10, PM2.5 vents to CD12

EP11 Feather Meal Dryer #2 – material handling PM10, PM2.5 vents to CD12

EP14 Link Belt Screener PM10, PM2.5 EP15 Feather Meal Transfer Leg PM10, PM2.5 EP20 Feather Meal & Poultry Meal Truck Loadout PM10, PM2.5 EP21 Hanging Room Exhaust Vents PM10, PM2.5

EU01PC

Two PRO*CAL Poultry Blood Tanks - 26,083 gallons each VOC vents to EU12PC

or EU12PCB Four PRO*CAL SPN Tanks - 26,083 gallons each

EU02PC Two PRO*CAL Process Tanks - 10,500 gallons each VOC vents to EU12PC One PRO*CAL CIP Tank - 10,000 gallons

EU04PC Two PRO*CAL Mixers VOC vents to EU12PC EU07PC PRO*CAL Dryer68 PM10, PM2.5

EU08PC PRO*CAL Hammermill PM10, PM2.5, VOC vents to baghouse & EU12PC

EU09PC PRO*CAL Screening PM10, PM2.5 vents to baghouse

68 Not a combustion source, steam is provided to this emission source from the installation’s boilers.


Emission Sources


EU10PC PRO*CAL Conveyors PM10, PM2.5 vents to baghouse

EU11PC (3) PRO*CAL Storage Bins PM10, PM2.5, VOC Vents to EU12PC

EU13PC PRO*CAL Truck Loadout PM10, PM2.5

EU23 Two Haarslev Continuous Cookers VOC Vents to EU27 or EU28

EU26 Haarslev Feather Meal Pre-Dryer VOC Vents to EU27 or EU28

EU27 Thermal Oxidizer #2 - 85 MMBtu/hr natural gas CO, HAP, NOx, PM10, PM2.5, SOx, VOC

EU28 Thermal Oxidizer #3 - 85 MMBtu/hr natural gas CO, HAP, NOx, PM10, PM2.5, SOx, VOC

EU31 60 kW (80 HP) Generac Emergency Generator CO, HAP, NOx, PM10, PM2.5, SOx, VOC

EU32 80 kW (107 HP) Eaton Emergency Generator CO, HAP, NOx, PM10, PM2.5, SOx, VOC

EP17A Poultry Meal Day Storage Bin PM10, PM2.5 vents to CD12

EP17B Feed Grade Meal Day Storage Bin PM10, PM2.5 vents to CD12

EP01B (3) Dupps Continuous Cookers VOC EP01C (7) Dupps Screw Presses VOC EP18A Feed Grade Bucket Elevator PM10, PM2.5 EP18B High Ash Buck Elevator PM10, PM2.5 EP18C Low Ash Bucket Elevator PM10, PM2.5 EP18D Pet Food Grade Bucket Elevator PM10, PM2.5

EU12PC Thermal Oxidizer #1 - 40 MMBtu/hr natural gas CO, HAP, NOx, PM10, PM2.5, SOx, VOC

EU12PCB Packed Bed Scrubber VOC EP01C Dupps Screw Presses PM10, PM2.5 EP01D Blood Coagulator VOC EP01E Blood Centrifuge VOC EP01F Raw Blood Tank VOC EP01G Two Poultry Meal Drainers VOC EP01H Eight Fat Screeners VOC EP01I Four Fat Centrifuges VOC





EP16 Feather Meal Storage Bins (Eight Compartments)

PM10, PM2.5

EP22 Feather Meal Silos PM10, PM2.5 EP19B High Ash Storage Bin PM10, PM2.5 EP19C Low Ash Storage Bin PM10, PM2.5 EP19D Pet Food Storage Bin PM10, PM2.5 EU03PC 6,000 gallon PRO*CAL Caustic Tank Not an emission


Emission Sources


source EU05PC PRO*CAL Preheater69 VOC EU06PC PRO*CAL Press VOC EU24 (3) Poultry Meal Drainers VOC EU25A Feed Bin PM10, PM2.5 EU25B (3) Dupps Screw Presses PM10, PM2.5 EU25C Fat Centrifuge VOC EU30 Lime Silo PM10, PM2.5

EU33 Dehumidifiers/Roof Heaters – 5 MMBtu/hr natural gas total


CT01, CT02, & CT03

Cooling Towers PM10, PM2.5

EU34 Two Solvent Parts Washers VOC TST30 Stord Dryer Test Cooker70 VOC

- Eight Space heaters – 0.6 MMBtu/hr natural gas each


EU06PCB Centrifuge VOC Laboratory VOC 6,990 gallon poultry fat tank VOC (9) 26,000 gallon poultry fat tanks VOC (4) 26,000 gallon poultry digest tanks VOC 8,600 gallon poultry fat tank VOC

5,900 gallon phosphoric acid tank

Not an emission source

17,600 gallon potable water tank


15,900 gallon poultry blood tank VOC 6,000 gallon heated chemical tank VOC

18,700 gallon PRO*CAL serum water tank


6,000 gallon wastewater tank VOC 24,000 gallon DAF skimmings tank VOC 8,000 gallon DAF skimmings tank VOC 6,000 gallon organic coagulant tank VOC 13,000 gallon alum tank VOC

10,000 gallon acetic acid tank


24,000 gallon biosolids tank VOC 12,000 gallon biosolids tank VOC

6,000 gallon magnesium hydroxide tank


1,500 gallon sodium hypochlorite tank


1,400 gallon soil off tank VOC

69 Not a combustion source, steam is provided to this emission source from the installation’s boilers. 70 Not a combustion source, steam is provided to this emission source from the installation’s boilers.


Emission Sources


1,400 gallon Quadexx 100 tank VOC 1,400 gallon Quadexx poultry care tank VOC

2,400 gallon chlorine tank




10,000 gallon sodium chlorite tank


10,000 gallon sodium acid sulfate tank




(2) 39,964 gallon water tanks




500 gallon hydraulic oil tank VOC 500 gallon used oil tank VOC

4,000 gallon compressed air tank


(4) 500 gallon poultry viscera tanks VOC 3,000 gallon poultry viscera tank VOC 2,000 gallon used marinate tank VOC

5,000 gallon cooling water tank




70,000 gallon CO2 tank












1,000 gallon engine oil tank VOC 1,000 gallon used engine and hydraulic oil tank VOC 250 gallon hydraulic oil tank VOC 10,000 gallon diesel tank VOC 4,000 gallon diesel tank VOC

All NOx emission sources at the installation were included in Attachment F; therefore, no revision of the permit is necessary.


All non-fugitive PM10 emission sources at the installation were included in Attachment F; therefore, no revision of the permit is necessary. Fugitive PM10 emissions from the installation’s cooling towers are not required to be included in the installation’s synthetic minor limit as the installation is not a named source; therefore, fugitive emissions do not count towards major source applicability. All CO emission sources at the installation were included in Attachment H; therefore, no revision of the permit is necessary. The Air Pollution Control Program is only aware of the emission sources/equipment indicated in Section I of the permit. If during an inspection additional emission sources are identified, the permittee will be required to revise this permit to include them. The Air Pollution Control Program agrees that site specific stack testing is more representative than AP-42 and has included site specific stack testing results in Attachments F, G, and H where available. The Air Pollution Control Program also agrees that some of the site specific stack test results are out of date and may no longer be representative due to changes at the installation. Stack testing of each emission source at the installation would be quite costly; therefore, the Air Pollution Control Program believes that stack testing should only be required for the following emission sources: Stack Emission Source & Description Pollutants Requiring Testing

ST-T01 EU12PC Thermal Oxidizer #1 which controls EU07PC Pro*Cal Dryer

NOx, Primary PM10 (filterable and condensable fractions), CO

ST-T02 or ST-T03

EU27 or EU28 Thermal Oxidizer #2 or #3 NOx, Primary PM10 (filterable and condensable fractions), CO

ST-6, ST-7, or ST-8

Boiler #2, #3, or #4 while combusting poultry oil

NOx, Primary PM10 (filterable and condensable fractions), CO

ST-10

CD12 Feather Spray Tower Condenser and Packed Bed Scrubber which controls Feather Meal Dryers #1 & #2 (EP10, EP11, EP12, & EP13)

Primary PM10 (filterable and condensable fractions)

EU12 PC was chosen for stack testing to confirm the NOx emission rate calculated by Project 2005-01-067, confirm the PM10 emission factor obtained from AP-42 Table 9.5.3-2, and/or to establish representative emission factors for demonstrating compliance with the installation’s synthetic minor CO, NOx, and PM10 limits. It is unclear if process changes since 2005 have resulted in increased NH3 production which converts to NOx in the thermal oxidizer. The PM10 emission factor in AP-42 is rated E and was established as the average of only two stack tests. Current calculations do not account for CO emissions from the destruction of VOCs in the thermal oxidizers only from the combustion of natural gas.


EU27/EU28 was chosen for stack testing to confirm the NOx emission rate calculated by Project 2005-12-046, to confirm compliance with the 1.5 lb/hr PM10 emission limit on each of these sources, and to establish representative emission factors for demonstrating compliance with the installation’s synthetic minor CO, NOx, and PM10 limits. The gas from the process equipment where the emissions are expected to occur goes to the same header before being divided between the two thermal oxidizers. As the gas going to each of the thermal oxidizers is the same and the thermal oxidizers are identical, it is reasonable to assume testing of only one thermal oxidizer is needed to develop emission factors for CO, NOx, and PM10. Current calculations do not account for CO emissions from the destruction of VOCs in the thermal oxidizers only from the combustion of natural gas.

EP06/EP07/EP08 was chosen for stack testing to confirm that the CO, NOx, and PM10 emission factors established during stack testing conducted in June 2002 are still representative and/or to establish representative emission factors for demonstrating compliance with the installation’s synthetic minor CO, NOx, and PM10 limits. It is unclear how the boilers were stack tested in June 2002 to accurately account for all CO, NOx, and PM10 emissions from the combustion of poultry oil as part of the exhaust stream from the boilers is routed to the Feather Meal Dryers. During the new stack test the damper allowing air to flow to the Feather Meal Dryers shall be closed. Each of the boilers is identical; therefore, it is reasonable to assume that testing of only one of the boilers is needed to develop emission factors for CO, NOx, and PM10 while combusting poultry oil. Documentation indicates that EP09 may have a low NOx burner; therefore, testing of EP09 would not be considered representative of NOx emissions from EP06, EP07, and EP08. The NOx emission factor established for EP06, EP07, and EP08 may conservatively be used for EP09 or the installation may choose to conduct an additional stack test to establish a separate NOx emission factor for EP09.

CD12 was chosen for stack testing to confirm the PM10 emission factor established during stack testing conducted in June 1998 and/or establish a representative emission factor for demonstrating compliance with the installation’s synthetic minor PM10 limit. The control efficiency of spray towers and wet scrubbers is highly dependent on the liquid flow rate; however, the liquid flow rate was not well documented during the June 1998 stack test.

Permit Condition PW001 has been revised to include stack testing requirements for the indicated emission sources. Subsequent permit renewals may require retesting of these emission sources and/or testing of the other emission sources at the installation.


EPA Comment #2: Second, Permit Condition 001, Permit Condition 002, and Permit Condition 003 require the permittee to perform specific monitoring and record keeping to verify the affected emission units are in compliance with the operational and emission limitations. However, there is no discussion or explanation or requirement to take any contingent action when the limitations are exceeded. EPA strongly recommends Simmons Feed and MDNR add the appropriate contingent action requirements to Permit Condition 001, Permit Condition 002, and Permit Condition 003.

Missouri Air Pollution Control Program Response: Periods during which the control equipment are not operated in accordance with the Provisions of Permit Conditions 001, 002, and 003 would be considered SSM conditions and are required to be reported in accordance with 10 CSR 10-6.050. The requirements of 10 CSR 10-6.050 have already been included in the permit in Section IV Core Permit Requirements. Additional language has been included in Permit Conditions 001, 002, and 003 to clarify this requirement.

EPA Comment #3: Third, operational limitation 1, in Permit Condition 002, requires the permittee to operate Thermal Oxidizer #2 and Thermal Oxidizer #3 to ensure that outlet PM10 emissions do not exceed 1.5 lb/hr. However, the monitoring / record keeping requirements are silent as to what operational parameters are being monitored to verify compliance with the PM10 limit. The permittee appears to be required to only monitor thermal oxidizer combustion chamber temperature and it is unclear how combustion chamber temperature correlates to PM10 emissions. EPA recommends Simmons Feed and MDNR provide added clarity to explain PM10 emission compliance.

Missouri Air Pollution Control Program Response: Construction Permit 032006-005 required the thermal oxidizers to achieve 99% destruction of PM10; however, when the installation tried to perform testing on the inlet of the thermal oxidizers (a necessary component of destruction efficiency testing) they were unable to due to the high oil content of the off gas from the meat cookers and feather dryers. The installation was only able to conduct outlet testing of the thermal oxidizer at the time (September 2007) and observed an average emission rate of 1.24 lb/hr PM10. As the installation was unable to determine compliance with the 99% destruction efficiency testing due to the make-up of the off gas, they requested the special condition be removed from their construction permit. In Construction Permit 032006-005B the 99% destruction efficiency was replaced by a 1.5 lb/hr PM10 limit. It is believed that the high oil content of the off gas is actually organic condensable PM which is combusted at the higher operating temperature of the thermal oxidizer; therefore, temperature monitoring is sufficient to demonstrate compliance with the 1.5 lb/hr limit and no permit revision is necessary. Repeat PM10 (both filterable and condensable) stack testing of this source is required in the revised Permit Condition PW001 which may yield better understanding of this emission source. If the repeat performance test does not indicate compliance with the 1.5 lb/hr PM10 limit, Construction Permit 032006-005B will require revision.


EPA Comment #4: Fourth, Permit Condition 007 incorporates the applicable requirements from 40 CFR part 63, Subpart JJJJJJ-National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boiler Area Sources. If Simmons Feed is an area source of hazardous air pollutants (HAPs), then MDNR relies on EPA for compliance management and all compliance related reporting shall be submitted to the Missouri Air Compliance Coordinator at EPA Region 7, with copies to MDNR as necessary. Therefore, the notification / record keeping / reporting requirement 6, in Permit Condition 007, should be modified to reflect this reporting scenario.

Missouri Air Pollution Control Program Response: The permit has been revised as requested.

Mr. Jeff Webster Simmons Feed Ingredients, Inc. 10700 South State Hwy 43 Southwest City, MO 64863 Re: Simmons Feed Ingredients, Inc., 119-0017 Permit Number: OP2016-049 Dear Mr. Webster: 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 CAV, 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 (30) days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If you send your appeal by registered or certified mail, we will deem it filed on the date you mailed it. If you send your appeal by a method other than registered or certified mail, we will deem it filed on the date the AHC receives it. 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 Michael J. Stansfield, P.E. Operating Permit Unit Chief MJS/ahj Enclosures c: PAMS File: 2014-09-054

MISSOURI DEPARTMENT OF NATURAL RESOURCES FOLDER TRANSMITTAL ROUTING SHEET

Operating Permits

Simmons Feed Ingredients, Inc. 2014-09-054

Originator: Alana L. Hess

Telephone: (573) 526-0189 Date: 1/31/17

Typist: Linda McDonald File Name: P:\APCP\Permits\Users\Alana Rugen\2014-09-054 Simmons Feed Ingredient, Inc\2014-09-054 Simmons Feed Ingredients.docx

SIGNATURE APPROVAL OF:

Program Director Section Chief Unit Chief

ROUTE TO:

Submitted Returned

Unit Chief – Initial Review Date:

Section Chief – Initial Review Date:

Unit Chief – Response to Comments Date:

Program Director Date:

Comments:

JAN 2 6 2017 Mr. Jeff Webster Simmons Feed Ingredients, Inc. 10700 South State Hwy 43 Southwest City, MO 64863

Eric R. Grcitens, Governor • Carol S. Comer, Acting Director

T OF NATURAL RESOURCES dnr.mo.gov

Re: Simmons Feed Ingredients, Inc., 119-0017 Permit Number: OP2016-049

Dear Mr. Webster:

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 (CAY) can be set up with you. To request a CAV, 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 CA V 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 (30) days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If you send your appeal by registered or certified mail, we will deem it filed on the date you mailed it. If you send your appeal by a method other than registered or certified mail, we will deem it filed on the date the AHC receives it.

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,

)1?~1~ Michael J. Stansfield, P .E. Operating Permit Unit Chief

MJS/ahj

Enclosures

c: PAMS File: 2014-09-054

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