_IGIIEI Missouri Department of dn,.mo.go, ~[i] ~.~!~~L RESOC~~o~~~

MAY 2 9 2019

Mr. Seth Walters Director of Environmental Quality Simmons Feed Ingredients, Inc. 10700 South State Highway 43 Southwest City, MO 64863

RE: New Source Review Permit- Project Number: 2019-01-011

Dear Mr. Walters:

Enclosed with this letter is your permit to construct. Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit. Also, note the special conditions on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files. Operation in accordance with these conditions, your new source review permit application, and submittal of a Part 70 operating permit application are necessary for continued compliance. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri.

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 (CA V) 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 the following website: http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo.gov/cav/compliance.htm.

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to §§621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: \V\Vw.oa.mo.gov/ahc.

0 Recycled paper

Mr. Seth Walters Page Two

If you have any questions regarding this permit, please do not hesitate to contact Alana Hess, at the Department of Natural Resources' Air Pollution Control Program, P.O. Box 176, ·. · Jefferson City, MO 65102 or at (573) 751-4817. Thank you for your attention to this matter.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Susan Heckenkarnp New Source Review Unit Chief

SH:ahd

Enclosures

c: Southwest Regional Office PAMS File: 2019-01-011

Permit Number:

~§MISSOURI Ii"" JI ~ 1 DEPARTMENT OF l__gj ~ NATURAL RESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT

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

Permit Number:

Parent Company:

052019-008 Project Number: 2019-01-011 Installation Number: 119-0017

Simmons Foods, Inc.

Parent Company Address: P.O. Box 430, Siloam Springs, AR 72761

Installation Name:

Installation Address:

Location Information:

Simmons Feed Ingredients, Inc.

10700 South State Highway 43, Southwest City, MO 64863

McDonald County, S21, T21 N, R23W

Application for Authority to Construct was made for: Modification of the feather meal line to allow for the production of blood meal. This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060 Construction Permits Required.

D Standard Conditions (on reverse) are applicable to this permit. @ Standard Conditions (on reverse) and pecial Conditions are applicable to

this permit.

Effective Date

STANDARD CONDITIONS:

Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit. Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit, or if construction or modification is suspended for one year or more.

You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. In the event that there is a discrepancy between the permit application and this permit, the conditions of this permit shall take precedence. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications.

You must notify the Enforcement and Compliance Se;ction of,th.e Oepartment's Air Pollution Control Program of the anticipated date of start up ofthis (these) air contaminant source(s). The information must be made available within 30 days of actual startup. Also, you must notify the Department's Southwest Regional Office within 15 days after the actual start up of this (these) air contaminant source(s).

A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Department's personnel upon request.

You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.075.6 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.

If you choose not to appeal, this certificate, the project review and your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant source(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances.

The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit using the contact information below.

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

Jefferson City, MO 65102-0176 (573) 751-4817

.. . . . . The regional office information can be found at the following website:

http://dnr.mo.gov/regions/

- 2 -

Project No. 2019-01-011 Permit No.

052019-0 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643. 075) and by the Missouri Rules listed in Title 10, Division 1 0 of the Code of State Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10 CSR 10-6.060(3)(E) "Conditions required by permitting authority."

Simmons Feed Ingredients, Inc. McDonald County, S21, T21 N, R23W

1. Synthetic Minor NSR Emission Limitations A. Simmons Feed Ingredients, Inc. shall emit less than 250.0 tons of CO in

any consecutive 12-month period from the entire installation as listed in Table 1.

Table 1: Installation-wide List of CO Emission Sources Emission

Description Control Production Area Source Equipment EP06 Boiler#2 EP0? Boiler #3 EP08 Boiler#4

EP12 Blood/Feather Meal None

Dryer #1 - Combustion Blood/Feather Meal

EP13 Blood/Feather Meal Line Dryer #2 - Combustion

EP09 Boiler#5 Low NOx Burners

EU26 Haarslev Feather Meal EU27 or EU28 Pre-Drver Thermal Oxidizers

CD03 (3) Dupps Spray Tower

(3) Dupps Continuous Condensers,

EP01B CD04 Fiberglass Poultry Meal Line Cookers

Spray Tower, and CD05 #1 Packed Bed Scrubber

EU23 (2) Haarslev EU27 or EU28 Poultry Meal Line Continuous Cookers Thermal Oxidizers

EU27 Thermal Oxidizer #1 Blood/Feather Meal

EU28 Thermal Oxidizer #2 None Line and Poultry Meal

Line EU31 Emeroencv Generator

None N/A EU32 Emeroency Generator

EU33 Dehumidifiers/Roof Heaters None Processing Plant

EU45 Space Heaters

B. Simmons Feed Ingredients, Inc. shall emit less than 250.0 tons of PM10 in any consecutive 12-month period from the entire installation as listed in Table 2.

- 3 -

8

Project No. 2019-01-011

Permit No.0 5 2 0 1 9 .. 0 0 8

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

Table 2: Installation-wide List of PM10 Emission Sources Emission··· .· ' '"

Source Description Control. Equipment . .Produ

Project No. 2019-01-011

Permit No. 0 5 2 0 1 9 - 0 0 8 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

Emission Description Control· Equipment ·· Pr9duction Area

Source .

EP16 Feed Grade Meal Storage Bins Feed Grade, High Ash,

EP18 Low Ash, and Pet Food None Grade Bucket Elevators

EP19 High Ash, Low Ash, and Petfood StoraQe Bins

CD11 Feather Spray

EP17A Poultry Meal Day Tower Condenser and Storage Bin CD12 #2 Packed Bed

Scrubber

EP17B Feed Grade Meal Day Storage Bin Building Poultry Meal Line

EU47 ( 4) Screeners

(2) Haarslev Continuous EU27 Thermal Oxidizer EU23 #1 or EU28 Thermal

Cookers Oxidizer#2 CD13 #2 Venturi

Feed Bin, (3) Dupps Scrubber, CD04 EU25 Screw Presses, and Fat Fiberglass Spray Tower,

Centrifuge and CD05 #1 Packed Bed Scrubber

EU35 Petfood Hammermill #1 CD18 Baghouse EU36 Petfood Hammermill #2 CD19 Bag house EU37 Feed Grade Hammermill CD20 Baghouse EP20 Truck Loadout Building Blood/Feather EU27 Thermal Oxidizer #1

None Meal Line and

EU28 Thermal Oxidizer #2 Poultry Meal Line

EP21 Hanging Room Exhaust Vents

EU33 Dehumidifiers/Roof None Heaters

EU45 Space Heaters Processing Plant

CT01 Cooling Tower #1 Drift eliminator CT02 CoolinQ Tower #2 Drift eliminator CT03 Cooling Tower #3 Drift eliminator EU30 Lime Silo EU31 Emergency Generator None N/A EU32 EmerQency Generator

C. Simmons Feed Ingredients, Inc. shall emit less than 250.0 tons of NOx in any consecutive 12-month period from the entire installation as listed in Table 3.

- 5 -

Project No. 2019-01-011

Permit NQ 5 2 0 1 9 - 0 0 8 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

Table 3: Installation-wide List of NOx Emission Sources Emission Control .. !

Source Description Equipment Production Area .· CD03 (3) Dupps Spray Tower

(3) Dupps Continuous Condensers,

EP01B CD04 Fiberglass Cookers Spray Tower, and Poultry Meal line

CD05 #1 Packed Bed Scrubber

EU23 (2) Haarslev EU27 or EU28 Continuous Cookers Thermal Oxidizers

EP06 Boiler#2 EP07 Boiler#3 EP08 Boiler#4

EP12 Blood/Feather Meal None

Dryer #1 - Combustion Blood/Feather Meal

EP13 Blood/Feather Meal Line

Dryer #2 - Combustion EP09 Boiler#5 Low NOx Burners

EU26 Haarslev Feather Meal EU27 or EU28 Pre-Dryer Thermal Oxidizers

EU27 Thermal Oxidizer #1 Blood/Feather Meal

EU28 Thermal Oxidizer #2 None Line and Poultry Meal

Line EU31 Emergency Generator

None N/A EU32 Emergency Generator

EU33 Dehumidifiers/Roof Heaters None Processing Plant

EU45 Space Heaters

D. Attachments A, B, and C equivalent forms, such as electronic forms, approved by the Air Pollution Control Program shall be used to demonstrate compliance with Special Conditions 1.A, 1.8, and 1.C.

2. Control Device Requirement - Low NOx Burners A. Simmons Feed Ingredients, Inc. shall control emissions from EP09 Boiler

#5 using low NOx burners.

8. Simmons Feed Ingredients, Inc. shall operate and maintain the low NOx burners in accordance with the manufacturer's specifications.

C. Simmons Feed Ingredients, Inc. shall maintain a copy of the manufacturer's specifications for the low NOx burners onsite.

D. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the low NOx burners which shall include the following:

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SPECIAL CONDITIONS:

Project No. 2019-01-011 Permit No.

052019-008

The permittee is authorized to construct and operate subject to the following special conditions:

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

2) Maintenance activities, with inspection schedule, repair actions, and replacements, etc.

3. Control Device Requirement - Cyclones A. Simmons Feed Ingredients, Inc. shall control emissions from EP01A (2)

Feather Hydrolyzers using CD01 or CD02 Cyclones.

8. Simmons Feed Ingredients, Inc. shall control process emissions from EP10 Blood/Feather Meal Dryer #1 using CD06 Cyclone.

C. Simmons Feed Ingredients, Inc. shall control process emissions from EP11 Blood/Feather Meal Dryer #2 using CD07 Cyclone.

D. Simmons Feed Ingredients, Inc. shall operate and maintain the cyclones in accordance with the manufacturer's specifications.

E. Simmons Feed Ingredients, Inc. shall equip CD01 and CD02 Cyclones with a gauge or meter, which indicates negative pressure in outlet Eluct of the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

F. Simmons Feed Ingredients, Inc. shall monitor and record the operating pressure of the outlet ducts of CD01 and CD02 Cyclones at least once every 24 hours.

G. Simmons Feed Ingredients, Inc. shall equip CD06 and CD07 Cyclones with a vacuum sealed door and a limit switch. These limit switches shall be located such that Department of Natural Resources' employees may easily observe them.

H. Simmons Feed Ingredients, Inc. shall monitor and record that the limit switches indicate that vacuum sealed door on CD06 and CD07 Cyclones is closed at least once every 24 hours.

I. Simmons Feed Ingredients, Inc. shall inspect the solids discharge valve of each cyclone at least once each week.

J. Simmons Feed Ingredients, Inc. shall record the results of each weekly solids discharge valve inspection.

K. Simmons Feed Ingredients, Inc. shall maintain onsite a copy of the manufacturer's specifications for each cyclone.

- 7 -

SPECIAL CONDITIONS:

Project No. 2019-01-011 Permit No.

052019-008 The permittee is authorized to construct and operate subject to the following special conditions:

L. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the cyclones which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of

event, probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions,

and replacements, etc.

4. Control Device Requirement - Condensers A. Simmons Feed Ingredients, Inc. shall control emissions from EP018 (3)

Dupps Continuous Cookers using CD03 (3) Dupps Spray Tower Condensers.

8. Simmons Feed Ingredients, Inc. shall control emissions from the following emission sources/control devices using CD11 SprayTower Condenser: 1) CD06 and COO? Cyclones 2) EP17 A Poultry Meal Day Storage Bin 3) EP01 E Blood Centrifuge 4) EP40 Coagulated Blood Flash Tank 5) EP01 F Raw Blood Screen 6) EU42 Agitated Tank 7) EU43 Blood/Feather Meal Dryers Feed Bin 8) EP01 D Blood Coagulator

C. Simmons Feed Ingredients, Inc. shall operate and maintain the spray tower condensers in accordance with the manufacturer's specifications.

D. Simmons Feed Ingredients, Inc. shall monitor and record the temperatures of the exhaust streams leaving CD03 (3) Dupps Spray Tower Condensers and CD11 Spray Tower Condenser at least once every 24 hours.

E. Simmons Feed Ingredients, Inc. shall monitor and record the liquid flow rate entering each spray tower condenser at least every 24 hours.

F. Simmons Feed Ingredients, Inc. shall maintain onsite a copy of the manufacturer's specifications for each condenser.

G. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the condensers which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of

event, probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions,

and replacements, etc.

- 8 -

SPECIAL CONDITIONS:

Project No. 2019-01-011 Permit No.

052019-008 The permittee is authorized to construct and operate subject to the following special conditions:

5. Control Device Requirement - Venturi Scrubbers A. Simmons Feed Ingredients, Inc. shall control emissions from EP01 C (6)

Dupps Screw Presses and EP01 I (3) Fat Centrifuges using CD09 #1 Venturi Scrubber.

8. Simmons Feed Ingredients, Inc. shall control emissions from EU25 Feed Bin, (3) Dupps Screw Presses, and (1) Fat Centrifuge using CD13 #2 Venturi Scrubber.

C. Simmons Feed Ingredients, Inc. shall operate and maintain the venturi scrubbers in accordance with the manufacturer's specifications.

D. Simmons Feed Ingredients, Inc. shall equip each venturi scrubber 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.

E. Simmons Feed Ingredients, Inc. shall monitor and record the operating pressure drop across each venturi scrubber at least once every 24 hours.

F. Simmons Feed Ingredients, Inc. shall monitor and record the liquid flow rate entering each venturi scrubber at least once every 24 hours.

G. Simmons Feed Ingredients, Inc. shall maintain onsite a copy of the manufacturer's specifications for each venturi scrubber.

H. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the venturi scrubbers which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of

event, probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions,

and replacements, etc.

6. Control Device Requirement- Spray Towers A. Simmons Feed Ingredients, Inc. shall control emissions from the following

emissions sources/control devices using CD04 Fiberglass Spray Tower: 1) CD01 and CD02 Cyclones 2) CD03 (3) Dupps Spray Tower Condensers 3) CD09 #1 Venturi Scrubber 4) CD13 #2 Venturi Scrubber 5) EU38 (3) Digest Tanks 6) EU39 Hydrolyzers Packing Fan Vent 7) EU44 Feather Meal Pre-Dryer Feed Bin

- 9 -

Project No. 2019-01-011 Permit No. ,

052019-008 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

8. Simmons Feed Ingredients, Inc. shall monitor and record the liquid flow rate entering the spray tower at least once every 24 hours.

C. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the spray tower which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of

event, probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions,

and replacements, etc.

7. Control Device Requirement - Packed Bed Scrubbers A. Simmons Feed Ingredients, Inc. shall control emissions from CD04

Fiberglass Spray Tower using CD05 #1 Packed Bed Scrubber.

8. Simmons Feed Ingredients, Inc. shall control emissions from CD11 Spray Tower Condenser using CD12 #2 Packed Bed Scrubber.

C. Simmons Feed Ingredients, Inc. shall operate and maintain the packed bed scrubbers in accordance with the manufacturer's specifications.

D. Simmons Feed Ingredients, Inc. shall equip each packed bed scrubber 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.

E. Simmons Feed Ingredients, Inc. shall monitor and record the operating pressure drop across each packed bed scrubber at least once every 24 hours.

F. Simmons Feed Ingredients, Inc. shall monitor and record the liquid flow rate entering each packed bed scrubber at least once every 24 hours.

G. Simmons Feed Ingredients, Inc. shall monitor and record the pH of the liquid in each of the packed bed scrubbers at least once every 24 hours.

H. Simmons Feed Ingredients, Inc. shall maintain the liquid flow rate entering CD12 #2 Packed Bed Scrubber within ± 10% of the average liquid flow rate entering the scrubber during the stack testing required by Special Condition 12.

I. Simmons Feed Ingredients, Inc. shall maintain the pH of the liquid in CD12 #2 Packed Bed Scrubber within ± 10% of the average pH of the liquid in the scrubber during the stack testing required by Special Condition 12.

- 10 -

SPECIAL CONDITIONS:

Project No. 2019-01-011 Permit No.

052019-008 The permittee is authorized to construct and operate subject to the following special conditions:

J. Simmons Feed Ingredients, Inc. shall maintain SOS for the scrubbing agent(s) onsite.

K. Simmons Feed Ingredients, Inc. shall maintain onsite a copy of the manufacturer's specifications for each packed bed scrubber.

L. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the packed bed scrubbers which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of

event, probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions,

and replacements, etc.

8. Control Device Requirement - Baghouses A. Simmons Feed Ingredients, Inc. shall control emissions from EU35

Petfood Hammermill #1 using CD18 Bag house.

B. Simmons Feed Ingredients, Inc. shall control emissions from EU36 Petfood Hammermill #2 using CD19 Bag house.

C. Simmons Feed Ingredients, Inc. shall control emissions from EU37 Feed Grade Hammermill using CD20 Baghouse.

D. Simmons Feed Ingredients, Inc. shall operate and maintain the baghouses in accordance with the manufacturer's specifications.

E. Simmons Feed Ingredients, Inc. shall equip each baghouse 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.

F. Simmons Feed Ingredients, Inc. shall keep replacement filters for the baghouses 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).

G. Simmons Feed Ingredients, Inc. shall monitor and record the operating pressure drop across each baghouse at least once every 24 hours.

H. Simmons Feed Ingredients, Inc. shall maintain a copy of the manufacturer's specifications for each baghouse onsite.

I. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the baghouses which shall include the following:

- 11 -

SPECIAL CONDITIONS:

Project No. 2019-01-011 Permit No.

052019-008 The permittee is authorized to construct and operate subject to the following special conditions:

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

2) Maintenance activities, with inspection schedule, repair actions, and replacements, etc.

9. Control Device Requirement - Thermal Oxidizers A. Simmons Feed Ingredients, Inc. shall control emissions from the following

emission sources/control devices using EU27 Thermal Oxidizer #1 or EU28 Thermal Oxidizer #2: 1) EU23 (2) Haarslev Continuous Cookers 2) EU26 Haarslev Feather Meal Pre-Dryer

B. Simmons Feed Ingredients, Inc. shall operate and maintain thermal oxidizers in accordance with the manufacturer's specifications.

C. Simmons Feed Ingredients, Inc. shall monitor and record the combustion chamber temperature of each of the thermal oxidizers at least once every 15 minutes.

D. The three-hour rolling average operating temperature of each thermal oxidizer shall be maintained at greater than or equal to 1327. 73°F1.

E. Simmons Feed Ingredients, Inc. shall maintain onsite a copy of the manufacturer's specifications for each thermal oxidizer.

F. Simmons Feed Ingredients, Inc. shall maintain an operating and maintenance log for the thermal oxidizers which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of

event, probable cause, and corrective actions; and 2) Maintenance activities, with inspection schedule, repair actions,

and replacements, etc.

10. Operational Prohibitions A. Simmons Feed Ingredients, Inc. shall not combust poultry oil.

B. Simmons Feed Ingredients, Inc. shall not process blood, blood solids, or blood protein in EU26 Haarslev Feather Meal Pre-Dryer.

11 . Record Keeping and Reporting Requirements A. Simmons Feed Ingredients, Inc. shall maintain all records required by this

permit for not less than five years and shall make them available

1 This is 50°F below the average operating temperature during the May 2018 stack test. This value and the stack tested emission factors for EU23, EU26, EU27, and EU28 may be reset based on the results of future stack tests upon approval by the Air Pollution Control Program.

- 12 -

Project No. 2019-01-011 Permit No.

SPECIAL CONDITIONS: 052019-008

The permittee is authorized to construct and operate subject to the following special conditions:

immediately to any Missouri Department of Natural Resources' personnel upon request. These records shall include SOS for all materials used.

B. Simmons Feed Ingredients, Inc. shall report to the Air Pollution Control Program's Compliance/Enforcement Section, by mail at P.O. Box 176, Jefferson City, MO 65102 or by email at AirComplianceReporting@dnr.mo.gov, no later than 10 days after the end of the month during which any record required by this permit shows an exceedance of a limitation imposed by this permit.

12. Performance Testing A. Simmons Feed Ingredients, Inc. shall conduct stack testing on CD12 #2

Packed Bed Scrubber to verify the emission factors in Table 4.

Table 4: CD12 #2 Packed Bed Scrubber Emission Factors for Verification

Pollutant Emission Factor (lb/ton of EP10/EP12 and EP11/EP13 Blood/Feather Meal Dryers feed)

voe 0.146 Primary PM 0.188 Primary PM10 0.188

B. Simmons Feed Ingredients, Inc. shall determine VOC emissions using EPA Test Method 18 or other methods as approved by the Air Pollution Control Program's Stack Testing Unit.

C. Simmons Feed Ingredients, Inc. shall determine PM and primary PM10 emissions by conducting an unheated EPA Test Method 5 or other test methods as approved by the Air Pollution Control Program's Stack Testing Unit.

D. If EP10/EP12 and EP11/EP13 Blood/Feather Meal Dryers are not operated on average within 10% of their physical MHDR of 15.6 tph combined feed during the stack testing event, EP10/EP12 and EP11/EP13 Feather Meal Dryers combined shall be limited to 110% of the average combined feed rate observed during the stack testing event.

E. These tests shall be performed within 60 days after achieving the maximum production rate of the installation, but not later than 180 days after initial start-up for commercial operation and shall be conducted in accordance with the Stack Test Procedures outlined in Special Condition 12.

F. A completed Proposed Test Plan Form shall be submitted to the Air Pollution Control Program at stacktesting@dnr.mo.gov 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

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Project No. 2019-01-011

Permit No. 0 5 2 0 1 9 - 0 0 8

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

G.

H.

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.

One electronic copy of a written report of the performance test results shall be submitted to StackTesting@dnr.mo.gov within 60 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.

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, specifically: 1) EP10/EP12 and EP11/EP13 Blood/Feather Meal Dryers combined

feed rate during each test run 2) The weight % of blood solids in the combined dryer feed during

each test run 3) The weight% of hydrolyzed feathers in the combined dryer feed

during each test run 4) Whether chicken, turkey, or both types of feathers were run during

each test run 5) The scrubbing agent(s) being used by CD12 #2 Packed Bed

Scrubber during each test run and an SOS 6) The liquid flow rate entering CD12 #2 Packed Bed Scrubber during

each test run 7) The pH of the liquid in CD12 #2 Packed Bed Scrubber during each

test run 8) The temperature of the exhaust stream leaving CD11 Spray Tower

Condenser at the beginning and end of each performance test run

I. If the performance testing results indicate a higher VOC emission factor than listed in Table 4, Simmons Feed Ingredients, Inc. shall: 1) Submit an application to amend this construction permit to true-up

the project emissions calculations no later than 90 days after submitting the performance test report. A higher VOC emission factor is not considered a violation.

2) Conduct HAP testing no later than 180 days after the VOC performance testing using TO 15, Method 18, Method 320, or other methods as approved by the Air Pollution Control Program to determine the emission rates of: a) Acetaldehyde (75-07-0) b) Acetonitrile (75-05-8) c) Acrolein (107-02-8) d) Benzene (71-43-2)

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Project No. 2019-01-011 Permit No. 0 5 2 0 1 9 - 0 0 8

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

e) Carbon Disulfide (75-15-0) f) Chlorobenzene ( 108-90-7) g) Ethylbenzene (100-41-4) h) Formaldehyde (50-00-0) i) Hexane (110-54-3) j) Methanol (67-56-1) k) Methylene Chloride (75-09-2) I) Naphthalene (91-20-3) m) Propionaldehyde (123-38-6) n) Quinoline (91-22-5) o) Tetrachloroethylene (127-18-4) p) Toluene (108-88-3) q) Trichloroethylene (79-01-6)

3) During the HAP testing, if EP10/EP12 and EP11/EP13 Blood/Feather Meal Dryers are not operated on average within 10% of their physical MHDR of 15.6 tph combined feed during the stack testing event, EP10/EP12 and EP11/EP13 Feather Meal Dryers combined shall be limited to 110% of the average combined feed rate observed during the stack testing event.

4) A completed Proposed Test Plan Form shall be submitted to the Air Pollution Control Program at stacktesting@dnr.mo.gov 30 days prior to the proposed HAP testing 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.

5) One electronic copy of a written report of the HAP test results shall be submitted to StackTesting@dnr.mo.gov within 60 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.

6) The HAP 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, specifically: a) EP10/EP12 and EP11/EP13 Blood/Feather Meal Dryers

combined feed rate during each test run b) The weight% of blood solids in the combined dryer feed

during each test run c) The weight% of hydrolyzed feathers in the combined dryer

feed during each test run d) Whether chicken, turkey, or both types of feathers were run

during each test run

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Project No. 2019-01-011

Permit NoO 5 2 Q 1 9 - 0 Q 8

SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

e) The scrubbing agent(s) being used by CD12 #2 Packed Bed Scrubber during each test run and an SOS

f) The liquid flow rate entering CD12 #2 Packed Bed Scrubber during each test run

g) The pH of the liquid in CD12 #2 Packed Bed Scrubber during each test run

h) The temperature of the exhaust stream leaving CD11 Spray Tower Condenser at the beginning and end of each performance test run

J. If the performance testing results indicate higher PM or PM10 emission factors than listed in Table 4, Simmons Feed Ingredients, Inc. shall submit an application to amend this construction permit to true-up the project emissions calculations no later than 90 days after submitting the performance test report. Higher PM or PM10 emission factors are not considered a violation, but may trigger modeling requirements.

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REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW

Project Number: 2019-01-011 Installation ID Number: 119-0017

Permit Number: O 5 2 0 1 9 - 0 0 8

Installation Address: Simmons Feed Ingredients, Inc. 10700 South State Highway 43 Southwest City, MO 64863

McDonald County, S21, T21 N, R23W

Parent Company: Simmons Foods, Inc. P.O. Box 430 Siloam Springs, AR 72761

REVIEW SUMMARY

• Simmons Feed Ingredients, Inc. has applied for authority to modify the feather meal line to allow for the production of blood meal.

• The application was deemed complete on January 9, 2019.

• HAP emissions are expected from the feather meal dryers. HAPs of concern are toluene, carbon disulfide, and quinoline.

• None of the currently promulgated standards in 40 CFR Parts 60, 61, and 63 are applicable to the modified equipment.

• Table 5 provides a list of control equipment employed by the installation and the practically enforceable requirements for their use.

Table 5: Installation-wide Control Equipment List Practically

Emission Description Control Equipment Production Enforceable

Source Area Control Device Requirement

EP09 Boiler #5 Low NOx Burners Blood/Feather Special Meal Line Condition 2

(2) Haarslev EU27 or EU28 Thermal Poultry Meal

EU23 Continuous Cookers Oxidizers

Line Special

Haarslev Feather EU27 or EU28 Thermal Blood/Feather Condition 9

EU26 Meal Pre-Dryer Oxidizers Meal Line

CD01 or CD02

(2) Feather Cyclones, CD04

Blood/Feather Special

EP01A Hydrolyze rs

Fiberglass Spray Meal Line

Conditions 3, 6, Tower, and CD05 #1 and 7 Packed Bed Scrubber

-17-

; . Practically .. Emission

Description . Control Equjpment Production Enforceable

Source Area Control Device .. . • Requirement·

CD03 (3) Dupps Spray (3) Dupps Tower Condensers,

Poultry Meal Special

EP01B Continuous CD04 Fiberglass Spray Conditions 4, 6, Cookers Tower, and CD05 #1

Line and 7 Packed Bed Scrubber

EP01C (6) Dupps Screw CD09 #1 Venturi Presses Scrubber, CD04

Fiberglass Spray EP01I (3) Fat Centrifuges Tower, and CD05 #1

Special Packed Bed Scrubber Poultry Meal Conditions 5, 6,

Feed Bin, (3) CD13 #2 Venturi Line and 7 Scrubber, CD04

EU25 Dupps Screw

Fiberglass Spray Presses, and Fat Centrifuge

Tower, and CD05 #1 Packed Bed Scrubber CD06 Cyclone, CD11

Blood/Feather Spray Tower EP10 Meal Dryer #1 - Condenser, and CD12

Process #2 Packed Bed Special

Scrubber Blood/Feather COO? Cyclone, CD11 Meal Line

Conditions 3, 4,

Blood/Feather Spray Tower and 7

EP11 Meal Dryer #2 - Condenser, and CD12 Process #2 Packed Bed

Scrubber CD11 Spray Tower

EP17A Poultry Meal Day Condenser and CD12 Poultry Meal Storage Bin #2 Packed Bed Line

Scrubber EP01O Blood Coaoulator EP01E Blood Centrifuoe Special

EP40 Coagulated Blood

CD11 Feather Spray Conditions 4

Flash Tank and 7 EP01F Raw Blood Screen

Tower Condenser and Blood/Feather

EU42 Aoitated Tank CD 12 #2 Packed Bed Meal Line

Blood/Feather Scrubber

EU43 Meal Dryers Feed Bin

CT01 CoolinQ Tower #1 Drift eliminator Processing CT02 Cooling Tower #2 Drift eliminator N/A

CT03 Cooling Tower #3 Drift eliminator Plant

EU35 Petfood

CD18 Baghouse Hammermill #1

EU36 Petfood

CD19 Baghouse Poultry Meal Special

Hammermill #2 Line Condition 8

EU37 Feed Grade

CD20 Baghouse Hammermill

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Practically Emission

Description Control Equipment Production Enforceable

Source Area Control Device Requirement

(3) Digest Batch CD04 Fiberglass Spray Poultry Meal EU38 Tanks

Tower, and COOS #1 Line

Packed Bed Scrubber Special

EU39 Hydrolyzers CD04 Fiberglass Spray Conditions 6

Packing Fan Vent Blood/Feather and 7 Feather Meal Pre-

Tower and CD0S #1 Meal Line

EU44 Drver Feed Bin

Packed Bed Scrubber

Construction

EU01PC (2) Blood Tanks CD12PCB Packed Bed

Other Permit 112011-

and (4) SPN Tanks Scrubber 001 Special Condition 2.8

• This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060 Construction Permits Required. The project emissions increases are below the de minimis and screening model action levels for all pollutants.

• This installation is located in McDonald County, an attainment/unclassifiable area for all other criteria pollutants.

• This installation is not on the List of Named Installations found in 10 CSR 10-6.020(3)(8), Table 2. The installation's major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability.

• Ambient air quality modeling was not performed since the project emissions increases are below the de minimis and screening model action levels.

• Emissions testing is required for CD12 #2 Packed Bed Scrubber as a part of this permit. Testing may be required as part of other state, federal or applicable rules.

• A Part 70 Operating Permit application is required for this installation immediately.

• Approval of this permit is recommended with special conditions.

EXISTING 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 the Pro*CAL line.

In the feather meal line, feathers are received from the rendering plant onsite or from other offsite locations and stored in a bin. Feathers are fed to two continuous hydrolyzers, EP01A. The material then passes through a pre-dryer, EU26. Steam is fed to the pre-dryer from the installation's boilers. After the pre-dryer, the material is dried in

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either EP10/EP12 or EP11/EP12 Feather Meal Dryers. Each dryer is rated at 18.9 MMBtu/hr natural gas and is steam assisted by the installation's boilers.

The product exiting the dryers has a moisture content of seven percent and is fed into day storage bins (EU46). The product is then screened by EP14 Link Belt Screener and crushed by EU41 Feather Meal Hammermill to create the appropriate size feeds. The finished products are conveyed to EP22 Feather Meal Silos to await shipping via trucks to customers.

The feather meal line is physically bottlenecked by EP01A Feather Hydrolyzers, which have a physical MHDR of 30 tph. This bottlenecks EU26 Haarslev Feather Meal Pre-Dryer to 20.56 tph, EP10 and EP11 Feather Meal Dryers to 12.87 tph combined, and feather meal screening (EP14 ), milling (EU41 ), transfer (EP15), and storage (EP22) to 9.38 tph.

In the poultry meal line, poultry by-products are received from the rendering plant onsite and from other offsite locations. The raw meat fed to continuous cookers, EP01 B or EU23, with an animal fat mixture. The resulting product is drained of excess fat that is recycled to the cookers, and then fed to screw presses, EP01 C or EU25B, removing more of the fat and liquids. The product is transferred to storage bins, EP17, and then to a series of hammermills (EU35, EU36, and EU37) that produce two grades of meal: feed grade and petfood grade. The meal passes through a series of screens (EU47) that separates the meal into different sizes for different applications before being transferred by bucket elevators, EP18, to storage bins, EP16 or EP19, to await shipping via trucks to customers.

The poultry meal line is physically bottlenecked by EP01 B and EU23 Continuous Cookers, which have physical MHDRs of 60.5 tph and 53 tph, respectively. This bottlenecks the screw presses (EP01 C and EU25) to 38.25 tph and storage (EP17, EP16, and EP19) and transfer (EP18) to 24.18 tph.

EP20 Truck Loadout has a physical MHDR of 50 tph, but is currently bottlenecked to 33.56 tph (9.38 tph feather meal and 24.18 tph poultry meal).

The Pro*CAL line uses blood (21,828 pounds per hour) and dissolved air flotation (OAF) skimmings - a wastewater byproduct (24,000 pounds per hour) generated in the onsite wastewater treatment plant to bind fat using a low temperature chemical reaction. The process is capable of producing 65.6 tons of feed product per day.

The installation also operates (4) 50.4 MMbtu/hr natural gas-fired or propane-fired boilers (EP06, EP07, EP08, and EP09), (2) four-stroke lean burn emergency generator engines-(1) 80 HP and (1) 107 HP (EU31 and EU32), dehumidifiers and roof heaters combusting a total of 5 MMBtu/hr natural gas (EU33), (8) 0.6 MMBtu/hr natural gas-fired space heaters (EU45), (2) 85 MMBtu/hr natural gas-fired thermal oxidizers (EU27 and EU28), (1) 40 MMBtu/hr natural gas-fired thermal oxidizer (EU12PC), a lime silo (EU30), a wastewater treatment plant (EU29), (2) solvent parts washers (EU34), and (3) cooling towers {CT01, CT02, and CT03).

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The following permits have been issued to Simmons Feed Ingredients, Inc. by the Air Pollution Control Program:

Table 6: Permit History Permit Issuance

Description Number Date

0199-020 01/22/99 Modification of Feather Meal Line and addition of blood coaQulation system

082001-008 08/10/01 Use of poultry derived fuel as an alternative fuel in existing boilers

082001-008A 10/31/02 Amend poultry derived fuel emission factors 052005-026 05/25/05 Installation of Pro*CAL Line 032006-005 03/06/06 Expansion of Poultry Meal Line 032006-005A 08/02/06 Modification of stack testinQ provisions 112011-001 11/02/11 Changes to Pro*CAL Line and its control equipment 032006-005B 05/23/14 Modification stack testing and control equipment provisions OP2016-049 01/26/17 Intermediate operatinQ permit

Stack testing was conducted in May 2018, which indicates significantly higher emissions from EU27 and EU28 Thermal Oxidizers than permitted under Construction Permit 032006-005 and its amendments. The installation is required to model CO and PM10 emissions and amend Construction Permit 032006-005 to account for the higher emissions.

The installation's current actual emission rates exceed the synthetic minor Title V limits in their Intermediate Operating Permit, OP2016-049. Special Condition 2 contains emission limitations to ensure that the installation is a synthetic minor NSR source for this permitting action. The installation is required to obtain a Part 70 operating permit.

PROJECT DESCRIPTION

Simmons Feed Ingredients, Inc. is proposing to construct equipment to facilitate the production of blood meal through the existing Feather Meal Line. All Pro*CAL equipment2 other than EU01 PC (2) Pro*CAL Blood Tanks and EU01 PC (4) Pro*CAL SPN Tanks will be shutdown and decommissioned.

Blood/Feather Meal Line Feathers will continue to be received from the rendering plant onsite or from other offsite locations and stored in a bin. Feathers are fed to two continuous hydrolyzers, EP01A. The material then passes through a pre-dryer, EU26. Steam is fed to the pre-dryer from the installation's boilers. After the pre-dryer, the feather meal is temporarily stored in the EU43 Blood/Feather Meal Dryers Feed Bin.

2 1.e. EU02PC (2) 10,500 gallon Pro*CAL Process Tanks and (1) 10,000 gallon Pro*CAL CIP Tank, EU03PC (1) 6,000 gallon Pro*CAL Caustic Tank, EU04PC (2) Pro*CAL Mixers, EU05PC Pro*CAL Preheater, EU06PC Pro*CAL Press, EU06PCB Pro*CAL Centrifuge, EU07PC Pro*CAL Dryer, EU08PC Pro*CAL Hammermill, EU09PC Pro*CAL Screening, EU1 0PC Pro*CAL Conveyors, EU11 PC (3) Pro*CAL Storage Bins, EU12PC Thermal Oxidizer, and EU13PC Pro*CAL Truck Loadout.

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Poultry blood and secondary protein nutrients (SPN)/DAF is received from the onsite processing plant and/or from offsite locations and stored in EU01 PC (2) Pro*CAL Blood Tanks and (4) Pro*CAL SPN Tanks. These tanks will continue to vent to EU12PCB Packed Bed Scrubber. SPN is not processed by the installation - only stored and later shipped offsite.

Poultry blood passes through a new EP01 F Raw Blood Screen to remove any solids before being thoroughly mixed in a new EU42 Agitated Tank. The material then passes through a new steam injected EP01 D Blood Coagulator (which will replace the existing EP01 D Blood Coagulator) to remove proteins.

Coagulated material and liquids are separated from gases in a new EP40 Coagulated Blood Flash Tank. The coagulated material and liquids are further separated into solids and water in a new EP01 E Blood Centrifuge (which will replace the existing EP01 E Blood Centrifuge). The blood solids are then added to the feather meal in the existing EU43 Blood/Feather Meal Dryers Feed Bin. The blood/feather meal is dried in either of the existing Blood/Feather Meal Dryers, EP10/EP12 or EP11/EP13. Each dryer is rated at 18.9 MMBtu/hr natural gas and is steam assisted by the installation's boilers. The installation is prohibited from introducing blood, blood protein, and blood solids to EU26 Haarslev Feather Meal Pre-Dryer.

The product exiting the Blood/Feather Meal Dryers (EP1 0/EP11) has a moisture content of seven percent and is fed into existing day storage bins (EU46). The product then passes through an existing Link Belt Screener, EP14, and an existing hammermill, EU41, to create the appropriate size feeds. The existing Blood/Feather Meal Transfer Leg, EP15, conveys the finished products to the existing Blood/Feather Meal Silos, EP22, to await shipping to customers via the existing Truck Loadout, EP20.

The blood/feather meal line is physically bottlenecked by EP01A Feather Hydrolyzers and the new blood system (EP01 F, EP01 D, EP01 E, EU42, and EP40). EP01A Feather Hydrolyzers have a combined physical MHDR of 30 tph. This bottlenecks feather meal pre-drying (EU26) to 20.56 tph. The new blood system (EP01 F, EP01 D, EP01 E, EU42, and EP40) has physical MHDRs of 9.18 tph blood (input) and 2.73 blood solids (output). This bottlenecks blood/feather meal drying to 15.6 tph (feed) and blood/feather meal screening, transfer, storage, and loadout to 11.21 tph.

EP20 Truck Loadout has a physical MHDR of 50 tph, but will be bottlenecked to 35.39 tph ( 11.21 tph feather meal and 24.18 tph poultry meal).

Table 7 provides an installation-wide emission source list and indicates how each emission source is affected by this project.

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Table 7: Installation-wide Emission Source List Poultry Meal Line - Unaffected by the Project

,

·-. Physically Emissio'1 Physical Description Bottlenecked Source MHDR · MHDR EP01B (3) Dupps Continuous Cookers 60.5 tph

113.5tph EU23 (2) Haarslev Continuous Cookers 53 tph3

EU24 (3) Poultry Meal Drainers N/D N/D EP01G (2) Poultry Meal Drainers N/D N/D

EU25 (1) Feed Bin, (3) Dupps Screw Presses,

10 tph and ( 1) Fat Centrifuge 38.25 tph

EP01C (6) Dupps Screw Presses 34.87 tph EP01I (3) Fat Centrifuges N/D N/D EU38 (3) 26,000 gallon Digest Tanks N/D N/D EP01H (6) Fat Screeners N/D N/D EU48A 6,990 gallon Poultry Fat Tank N/D N/D EU48B (9) 26,000 gallon Poultry Fat Tanks N/D N/D EU48C 8,600 gallon Poultry Fat Tank N/D N/D

EP17 A and EP17B Poultry Meal and Feed Grade Meal Day

25 tph 24.18 tph Storage Bins

EP18 Bucket Elevators 25 tph 24.18 tph EP16 Meal Storage Bins 9.9 tph

24.18 tph EP19 Ash and Petfood Storage Bins 16.25 tph EU35 and EU36 (2) Petfood Hammermills N/D

24.18 tph EU37 Feed Grade Hammermill N/D EU47 ( 4) Screeners N/D 24.18 tph

Blood/Feather Meal Line

Emission Physical Physically Project

Source Description

MHDR Bottlenecked Status MHDR

EP01E Blood Centrifuge 9.18 tph 9.18tph New EP40 Coagulated Blood Flash Tank N/D N/D New

EP10 Blood/Feather Meal Dryer #1

N/D Modified - Process

15.6 tph feed4 Blood/Feather Meal Dryer #2

EP11 - Process

N/D Modified

EP01F Raw Blood Screen 9.18tph 9.18tph New EU42 Agitated Tank N/D N/D New EP01D Blood Coagulator N/D N/D New EU39 Hvdrolvzers Packing Fan Vent N/D N/D Unaffected EP01A (2) Feather Hydrolyzers 30 tph 30 tph Unaffected EU44 Feather Meal Pre-Dryer Feed Bin N/D 20.56 tph Unaffected EU26 Haarslev Feather Meal Pre-Dryer 28.5 tph 20.56 tph Unaffected

3 EU23 is currently limited to 33.1 tph until a new stack test is conducted. 4 EP10 and EP11 are currently limited to 8.27 tph combined until a new stack test is conducted.

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Blood/Feather Meal Lirie ,, .,

'Physically Emission. Physical Prject Source

· DescrJption Bottlenecked ·. MHDR MHDR ·. 1 Status

EU43 Blood/Feather Meal Dryers N/D 15.6 tph Modified Feed Bin

EU46 (2) Blood/Feather Meal Day N/D 11.21 tph Modified Storage Bins EP14 Link Belt Screener 30 tph 11.21 tph Modified

EU41 Blood/Feather Meal N/D 11.21 tph Modified Hammermill

EP15 Blood/Feather Meal Transfer

25 tph 11.21 tph Modified Leo

EP22 (2) Blood/Feather Meal Silos 15 tph 11.21 tph Modified

EP12 Blood/Feather Meal Dryer #1

18.9 MMBtu/hr N/A Unaffected - Combustion

EP13 Blood/Feather Meal Dryer #2

18.9 MMBtu/hr N/A Unaffected - Combustion

EP06 Boiler#2 50.4 MMBtu/hr N/A Unaffected EP07 Boiler#3 50.4 MMBtu/hr N/A Unaffected EP08 Boiler#4 50.4 MMBtu/hr N/A Unaffected EP09 Boiler #5 50.4 MMBtu/hr N/A Unaffected

Blood/Feather Meal Line and Poultry Meal Line Shared Emission Sources Emission

Description Physical Physically Project

Source MHDR Bottlenecked MHDR Status EP20 Truck Loadout 50 tph 35.39 tph Modified EU27 Thermal Oxidizer #1 85 MMBtu/hr N/A Unaffected EU28 Thermal Oxidizer #2 85 MMBtu/hr N/A Unaffected

Other Emission Sources - Unaffected by the Project Emission Source Description Physical MHDR EU31 Emergency Generator 80 HP EU32 Emergency Generator 107 HP EU33 Dehumidifiers/Roof Heaters 5 MMBtu/hr total EU45 Space Heaters 4.8 MMBtu/hr total EP21 Hanging Room Exhaust Vents 28.5 tph

EU01PC (2) 26,083 gallon Pro*CAL Blood Tanks N/A and (4) 26,083 gallon Pro*CAL SPN Tanks

EU30 Lime Silo 20 tph EU29 Wastewater Treatment Plant 83,333 gph EU34 (2) Parts Washers N/A CT01 Cooling Tower #1 13,200 aoh CT02 Cooling Tower #2 153,600 gph CT03 Cooling Tower #3 127,200 gph

Laboratory N/A 6,000 oallon heated chemical tank N/A 5,900 gallon Phosphoric Acid Tank N/A 17,600 gallon Potable Water Tank N/A 6,000 gallon wastewater tank N/A 6,000 gallon organic coagulant tank N/A

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Other Emission Sources - Unaffected by the Project Emission Source Description Physical MHDR

13,000 gallon alum tank N/A 10,000 gallon acetic acid tank N/A 24,000 gallon biosolids tank N/A 12,000 gallon biosolids tank N/A 6,000 gallon magnesium hydroxide tank N/A 1,500 gallon sodium hypochlorite tank N/A 1,400 gallon soil off tank N/A 1,400 gallon Quadexx 100 tank N/A 1 ,400 gallon Quadexx poultry care tank N/A 2,400 gallon chlorine tank N/A 2,000 gallon water tank N/A 10,000 gallon sodium chlorite tank N/A 10,000 gallon sodium acid sulfate tank N/A 22,000 gallon water tank N/A (2) 39,964 gallon water tanks N/A 150,000 gallon water tank N/A 500 gallon hydraulic oil tank N/A 500 gallon used oil tank N/A 4,000 gallon compressed air tank N/A ( 4) 500 gallon poultry viscera tanks N/A 3,000 gallon poultry viscera tank N/A 2,000 gallon used marinate tank N/A 5,000 gallon cooling water tank N/A 8,436 gallon ammonia tank N/A 70,000 gallon CO2 tank N/A 26,000 gallon ammonia tank N/A 3,881 gallon ammonia tank N/A 1,525 gallon ammonia tank N/A 5,563 gallon ammonia tank N/A 6,904 gallon ammonia tank N/A 1,000 gallon engine oil tank N/A 1,000 gallon used engine and hydraulic oil tank N/A 250 gallon hydraulic oil tank N/A 10,000 gallon diesel tank N/A 4,000 gallon diesel tank N/A

N/A = Not Applicable; N/D = Not Determined

EMISSIONS/CONTROLS EVALUATION

NOx, PM10, and CO emissions were determined using the MHDRs in Table 7 and the emission factors in Attachments A, B, and C.

-~

PM and PM2.5 emissions from the (2) Blood/Feather Meal Day Storage Bins, EP14 Link Belt Screener, EU41 Blood/Feather Meal Hammermill, EP15 Blood/Feather Meal Transfer Leg, EP22 (2) Blood/Feather Meal Silos, and EP20 Truck Loadout were estimated using emission factors obtained from AP-42 Section 9.9.1 "Grain Elevators & Processes" (May 2003).

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VOC emissions from CD12 #2 Packed Bed Scrubber were estimated using data obtained from stack testing at a similar facility in Bellevue, NE. This emission factor will be verified via the stack testing required by Special Condition 12.

H2S emissions from CD12 #2 Packed Bed Scrubber were determined using an emission factor of 0.08 lb/ton obtained from AP-42 Section 9.5.3 "Meat Rendering Plants" (September 1995).

Multiple scientific papers and stack test results from similar facilities indicate CD12 #2 Packed Bed Scrubber is a HAP emission source. If VOC emissions from CD12 exceed 0.146 lb/ton blood/feather meal dryer feed, HAP emissions testing is triggered in Special Condition 12.

PM and PM2.s emissions from CD12 #2 Packed Bed Scrubber were determined using emission factors obtained from testing conducted on the control device in December 2017. In December 2017, the meal dryers (EP10 and EP11) only processed hydrolyzed feathers, but after this project, the meal dryers (EP10 and EP11) will process hydrolyzed feathers and blood solids. To ensure that the emission factors remain representative stack testing is required by Special Condition 12.

Table 8 provides an emissions summary for this project. Existing potential emissions were taken from OP2016-049 and updated by using the installation's December 2017 and May 2018 stack test results and removing Pro*CAL emission sources. Existing actual emissions were taken from the installation's 2017 EIQ. The project emissions increase represents the post-project potential to emit of the new and modified Blood/Feather Meal Line emission sources minus the pre-project potential to emit of the modified Feather Meal Line emission sources, assuming continuous operation (8,760 hours per year).

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Table 8: Emissions Summary (tpy] ..

· Existing ·· New Regulatory Existirag . Project Actual I nstallat1011 Pollutant DeMinimis Potential Emissions Emissions Conditioned Levels Emissions (2017 EIQ) Increase PTE

PM 25.0 150.71 N/A 12.75 N/A

PM10 15.0 272.72 78.18 12.28

Pollutant

T etrachloroethylene (127-18-4} Toluene

(108-88-3} Trichloroethylene

(79-01-6}

Regulatory DeMiniinis

levels . 10.0

SMAL = 10 10.0

SMAL = 10 10.0

SMAL = 10

.l:xisting Existing . Pr~Jett I Ne\'ll' ' / J'.· otential. E ~ct~al Emissions Installation E . . < m1ss1ons 1 . . . Ce>,Ji~itie>,ned "1•ss1011s (2017 EIQ) ... · ncrease PTE

N/D N/D N/D N/ A

N/D 0.002 N/D N/A

N/D N/D N/D N/A N/A = Not Applicable; N/D = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 1 0 CSR 10-6.060 Construction Permits Required. The project emissions increases are below the de minimis and screening model action levels for all pollutants.

APPLICABLE REQUIREMENTS

Simmons Feed Ingredients, Inc. shall comply with the following applicable requirements. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. Compliance with these emission standards, based on information submitted in the application, has been verified at the time this application was approved. For a complete list of applicable requirements for your installation, please consult your operating permit.

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

o Part 70 installations are required to submit a full EIQ each calendar year.

• 10 CSR 10-6.165 Restriction of Emission of Odors

• 10 CSR 10-6.170 Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin

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

• 10 CSR 10-6.070 New Source Performance Regulations o 40 CFR Part 60, Subpart De- Standards of Performance for Small

Industrial-Commercial-Institutional Steam Generating Units continues to apply to EP06, EP07, EP08, and EP09 Boilers.

o 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines continues to apply to EU31 and EU32 Emergency Generators.

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• 10 CSR 10-6.075 Maximum Achievable Control Technology Regulations o 40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for

Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources no longer applies to EP06, EP07, EP08, and EP09 Boilers. Special Condition 10 prohibits the combustion of poultry oil in these boilers; therefore, these boilers now combust natural gas and/or propane and meet the definition of "gas-fired boiler" at §63.11237. Gas-fired boilers are not subject to this regulation per §63.11195( e ).

STAFF RECOMMENDATION

Based on this review conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060 Construction Permits Required, it is recommended that this permit be granted with special conditions.

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

• The Application for Authority to Construct form, dated January 9, 2019, received January 9, 2019, designating Simmons Feed Ingredients, Inc. as the owner and operator of the installation.

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Attachment A - CO Compliance Worksheet

Simmons Feed Ingredients, Inc. McDonald County, S21, T21 N, R32W Project Number: 2019-01-011 Installation ID Number: 119-0017 O O B Permit Number: 0 5 2 0 1 9 -This sheet covers the period from ______ to ______ _

(month, year) (month, year)

co Emission Description Monthly Emission Source Usage Factor

EP01B (3) Dupps Continuous Cookers tons

0.006 lb/ton7 product

EP06 Boiler #2 MMscf 84 lb/MMscf8

Mgal 7.5 lb/Mgal9

EP07 Boiler#3 MMscf 84 lb/MMscf8

Mgal 7.5 lb/Mgal9

EP08 Boiler #4 MMscf 84 lb/MMscf8

Mgal 7.5 lb/Mgal9

EP09 Boiler #5 MMscf 84 lb/MMscf8

Mgal 7.5 lb/Mgal9

EP12 Blood/Feather Meal Dryer #1 MMscf 84 lb/MMscf8

Mgal 7 .5 lb/Mgal9

EP13 Blood/Feather Meal Dryer #2 MMscf 84 lb/MMscf8

Mgal 7.5 lb/Mgal9

(2) Haarslev Continuous Cookers -tons 0.696 lb/ton controlled by EU27 or EU28 Thermal feed feed10

EU23 Oxidizers (2) Haarslev Continuous Cookers - SSM tons

0.006 lb/ton7 emissions product Haarslev Feather Meal Pre-Dryer -

tons 1.109 lb/ton EU26 controlled by EU27 or EU28 Thermal

feed feed10 Oxidizers

EU31 107.23 BHP Emergency Generator hours11 16.335 lb/hr12

6 Monthly CO Emissions (tons)= Monthly Usage x CO Emission Factor x 0.0005.

Monthly co Emissions (tons)6

7 Obtained from "Compliance emissions testing of the Supercooker at IBP, Inc. Dakota City, NE" (July 1998). 8 Obtained from AP-42 Section 1.4 "Natural Gas Combustion" (July 1998) 9 Obtained from AP-42 Section 1.5 "Liquified Petroleum Gas Combustion" (July 2008) 10 Obtained from the May 2018 Stack Test. This value includes both process emissions and natural gas combustion emissions from the thermal oxidizer. 11 As obtained from the non-resettable meter on the engine. Monthly usage= hour reading this month - hour reading last month. 12 69.1 g/HP-hr per manufacturer.

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co Monthly Emission Description Monthly Emission

co Source Usage Emissions Factor (tons)6

EU32 127.89 BHP Emerqencv Generator hours11 20.557 lb/hr13

EU33 Dehumidifiers/Roof Heaters MMscf 84 lb/MMscf8

EU45 Space Heaters MMscf 84 lb/MMscf8 Installation-wide Monthly CO Emissions (tons)14: Installation-wide 12-Month Rolling Total CO Emission (tons)15: '

.. i. : ' ·' ..

13 72.91 g/HP-hr per manufacturer. 14 Installation-wide Monthly CO Emissions (tons)= the sum of each emission source's Monthly CO Emissions (tons). 15 Installation-wide 12-Month Rolling Total CO Emissions (tons)= the sum of the 12 most recent Installation-wide Monthly CO Emissions (tons). Installation-wide 12-Month Rolling Total CO Emissions of less than 250 tons indicates compliance with Special Condition 1.A.

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Attachment B - NOx Compliance Worksheet

Simmons Feed Ingredients, Inc. McDonald County, S21, T21 N, R32W Project Number: 2019-01-011 Installation ID Number: 119-0017 Permit NumbeO 5 2 0 1 9 - 0 0 8 This sheet covers the period from ______ to _____ _

(month, year) (month, year)

Emission Description Monthly Source Usage

EP01B (3) Dupps Continuous Cookers tons

product

EP06 Boiler #2 MMscf

Mgal

EP07 Boiler#3 MMscf

Mgal

EP08 Boiler #4 MMscf

Mgal

EP09 Boiler#5 MMscf

Mgal

EP12 Blood/Feather Meal Dryer #1 MMscf

Mgal

EP13 Blood/Feather Meal Dryer #2 MMscf

Mgal (2) Haarslev Continuous Cookers - controlled tons

EU23 by EU27 or EU28 Thermal Oxidizers feed (2) Haarslev Continuous Cookers - SSM tons emissions product

EU26 Haarslev Feather Meal Pre-Dryer - controlled tons by EU27 or EU28 Thermal Oxidizers feed

EU31 107.23 BHP Emeroencv Generator hours11

EU32 127.89 BHP Emergency Generator hours11

EU33 Dehumidifiers/Roof Heaters MMscf EU45 Space Heaters MMscf Installation-wide Monthly NOx Emissions (tons}19:

16 Monthly NOx Emissions (tons)= Monthly Usage x NOx Emission Factor x 0.0005. 17 3.21 g/HP-hr per manufacturer. 18 4.04 g/HP-hr per manufacturer

NOx Emission Factor

0.006 lb/ton7

100 lb/MMscf8 13 lb/Mgal9

100 lb/MMscf8 13 lb/Mgal9

100 lb/MMscf8 13 lb/Moal9

50 lb/MMscf8 13 lb/Mgal9

100 lb/MMscf8

13 lb/Moal9

100 lb/MMscf8 13 lb/Mgal9

0.749 lb/ton feed 10

0.006 lb/ton7

0.443 lb/ton feed10

0. 759 lb/hr17

1.139 lb/hr18

100 lb/MMscf8 100 lb/MMscf8

Monthly NOx Emissions (tons}16

19 Installation-wide Monthly NOx Emissions (tons)= the sum of each emission source's Monthly NOx Emissions (tons). - 32 -

NOx Monthly

Emission Description Monthly Emission NOx Source Usage Emissions Factor (tons)16 Installation-wide 12-Month Rolling Total NOx Emission (tons)20:

20 Installation-wide 12-Month Rolling Total NOx Emissions (tons)= the sum of the 12 most recent Installation-wide Monthly NOx Emissions (tons). Installation-wide 12-Month Rolling Total NOx Emissions of less than 250 tons indicates compliance with Special Condition 1.C.

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Attachment C- PM10 Compliance Worksheet

Simmons Feed Ingredients, Inc. McDonald County, S21, T21 N, R32W Project Number: 2019-01-011 Installation ID Number: 119-0017 Permit Number: O 5 2 0 1 9 _ O O 8 This sheet covers the period from _______ to ______ _

(month, year) (month, year)

Emission Description Monthly Source Usage

(2) Feather Hydrolyzers controlled by CD01 or CD02 Cyclones, CD04

tons EP01A

Fiberglass Spray Tower, and CD05 #1 Packed Bed Scrubber (2) Feather Hydrolyzers

tons - SSM23 emissions (3) Dupps Continuous Cookers controlled by CD03 (3) Dupps Spray Tower Condensers, CD04 Fiberglass tons

EP01B Spray Tower, and CD05 #1 Packed Bed Scrubber (3) Dupps Continuous Cookers

tons - SSM23 emissions (6) Dupps Screw Presses controlled by CD09 #1 Venturi Scrubber, CD04

tons EP01C

Fiberglass Spray Tower, and CD05 #1 Packed Bed Scrubber (6) Dupps Screw Presses

tons - SSM23 emissions

21 Monthly PM10 Emissions (tons)= Monthly Usage x PM10 Emission Factor x 0.0005. 22 Obtained from AP-42 Section 9.9.1 "Grain Elevators & Processes" (May 2003)

PM10 Emission Factor

0.034 lb/ton22

0.068 lb/ton24

0.105 lb/ton25

0.640 lb/ton26

0.034 lb/ton22

0.068 lb/ton27

Monthly PM10 Emissions (tons)21

23 No start-up or shutdown emissions are expected from this emission source as control equipment is in operation prior to and after start-up and shutdown of process equipment. Malfunctions of the control equipment may occur and will be recorded here. 24 Assumes the cyclones, spray tower, and packed bed scrubber control 50% of PM10 emissions. 25 Assumes the condenser and packed bed scrubber control 50% of filterables, 70% of organic condensables, and 95% of inorganic condensables. 26 Engineering estimate based on EU23's stack tested emission factors and assuming the RTO controlled 99% of organic condensables. 27 Assumes the venturi scrubber, spray tower, and packed bed scrubber control 50% of PM10 emissions.

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. . · ::;1,

Emission: Description Monthly So~rce Usc1ge

' Feed Bin Controlled by CD13 #2 Venturi Scrubber, CD04 Fiberglass Spray Tower, and COOS #1 tons

EU25A Packed Bed Scrubber

Feed Bin - SSM23 emissions tons

(3) Dupps Screw Presses Controlled by CD13 #2 Venturi Scrubber, CD04 Fiberglass Spray Tower, tons

EU25B and COOS #1 Packed Bed Scrubber

(3) Dupps Screw Presses - SSM23 emissions tons

EP06 Boiler #2 MMscf

Mgal

EP07 Boiler#3 MMscf

Mgal

EP08 Boiler #4 MMscf

Mgal

EP09 Boiler #5 MMscf

Mgal EP10, PM10 Emission Sources controlled by CD11 Spray tons EP11, Tower Condenser and CD12 #2 Packed Bed dryer EP17A Scrubber feed

Blood/Feather Meal Dryer #1 tons EP10 meal - SSM23 emissions

product

Blood/Feather Meal Dryer #2 tons EP11 meal - SSM23 emissions

product

EP17A Poultry Meal Day Storage Bin

tons - SSM23 emissions

EP17B Feed Grade Meal Day Storage Bin tons

EP12 Blood/Feather Meal Dryer #1 MMscf

Mgal

EP13 Blood/Feather Meal Dryer #2 MMscf

Mgal

28 0btained from the December 2017 Stack Test. 29 Obtained from AP-42 Section 9.5.3 "Meat Rendering Plants" (September 1995).

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. . MQnthly PM10 Emission PM.10 Em,i~sic:ms Factor (tons)21

0.034 lb/ton22

0.068 lb/ton27

0.034 lb/ton22

0.068 lb/ton27

7.6 lb/MMscf8

0. 7 lb/Mgal9

7.6 lb/MMscf8 0.7 lb/Mgal9

7.6 lb/MMscf8 0.7 lb/Mgal9

7.6 lb/MMscf8 0. 7 lb/Mgal9

0.188 lb/ton28

1.22 lb/ton29

1.22 lb/ton29

0.0063 lb/ton22

0.006 lb/ton22. 31 7.6 lb/MMscf8

0.7 lb/Mgal9

7.6 lb/MMscf8

0. 7 lb/Mgal9

: ·; ~· .-, ' f;19nthly ' PM10 Emisslc;h: Description Monthly Emission

.·PM16::

.

PM10 Monthly

Emission Description

Monthly Emission

PM10 Source Usage Emissions

Factor (tons)21 .·

EU31 Emerqencv Generator hours11 0.009 lb/hr35

EU32 Emergency Generator hours11 0.012 lb/hr36

EU33 Dehumidifiers/Roof Heaters MMscf 7 .6 lb/MMscf8 EU45 Space Heaters MMscf 7.6 lb/MMscf8 CT01 Coolinq Tower #1 MMgal 0.274 lb/MMqal37

CT02 Cooling Tower #2 MMgal 0.274 lb/MMgal37

CT03 Cooling Tower #3 MMgal 0.274 lb/MMgal37

Installation-Wide Monthly PM10 Emissions (tons)38: f"

Installation-wide 12-Month Rolling Total PM10 E.mission (tons)39:

35 Obtained by multiplying the MHDR of the engine (0.879 MMBtu) by the PM10 Primary emission factor of 0.0099871 lb/MMBtu obtained from AP-42 Section 3.2 "Natural Gas-fired Reciprocating Engines" (August 2000). 36 Obtained by multiplying the MHDR of the engine (1.177 MM Btu) by the PM10 Primary emission factor of 0.0099871 lb/MMBtu obtained from AP-42 Section 3.2 "Natural Gas-fired Reciprocating Engines" (August 2000). 37 Based on a maximum drift loss of 0.002%, a maximum TDS content of 7700 ppm, and "Calculating Realistic PM10 Emissions from Cooling Towers" (Joel Reisman and Gordon Frisbie). 38 Installation-wide Monthly PM10 Emissions (tons)= the sum of each emission source's Monthly PM10 Emissions (tons). 39 Installation-wide 12-Month Rolling Total PM10 Emissions (tons)= the sum of the 12 most recent Installation-wide Monthly PM10 Emissions (tons). Installation-wide 12-Month Rolling Total PM10 Emissions of less than 250 tons indicates compliance with Special Condition 1.8.

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APPENDIX A Abbreviations and Acronyms

% ............ percent Mg al ......... 1,000 gallons ~F ............ degrees Fahrenheit MW ........... megawatt acfm ....... actual cubic feet per minute MHDR ....... maximum hourly design rate BACT ...... Best Available Control Technology MMBtu ...... Million British thermal units BMPs ...... Best Management Practices MMCF ....... million cubic feet

Btu .......... British thermal unit MSDS ....... Material Safety Data Sheet

CAM ....... Compliance Assurance Monitoring NAAQS ..... National Ambient Air Quality CAS ........ Chemical Abstracts Service Standards

CEMS ..... Continuous Emission Monitor System NESHAPs National Emissions Standards for Hazardous Air Pollutants CFR ........ Code of Federal Regulations

CO .......... carbon monoxide NOx ........... nitrogen oxides

CO2 ......... carbon dioxide NSPS ........ New Source Performance Standards

CO2e ....... carbon dioxide equivalent

COMS ..... Continuous Opacity Monitoring System

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

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

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

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

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

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

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

PM2.s ......... 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

EU ........... Emission Unit PTE ........... potential to em it fps .......... feet per second RACT ........ Reasonable Available Control ft ............. feet Technology GACT ..... Generally Available Control RAL .......... Risk Assessment Level Technology sec .......... Source Classification Code GHG ....... Greenhouse Gas scfm ......... standard cubic feet per minute gpm ........ gallons per minute SDS .......... Safety Data Sheet gr ............ grains SIC ........... Standard Industrial Classification GWP .. ..... Global Warming Potential SIP ............ State Implementation Plan HAP ........ Hazardous Air Pollutant SMAL ....... Screening Model Action Levels hr ............ hour SOx ........... sulfur oxides hp ........... horsepower S02 ........... sulfur dioxide lb ............ pound SSM .......... Startup, Shutdown & Malfunction lbs/hr ...... pounds per hour tph ............ tons per hour MACT ..... Maximum Achievable Control Technology

1,1g/m3 .. .... micrograms per cubic meter mis ........... meters per second

tpy ............ tons per year VMT .......... vehicle miles traveled

voe ........ Volatile Organic Compound

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