michael l. parson, governor carol s. comer, director · eu0150 10 mm btu/hr bentone flash dryer #1...

Michael L. Parson, Governor

NOV O 7 Mr. Bill Lashley Elcmentis Specialties, Inc. - St. Louis Plant 5548 Manchester Avenue St. Louis, MO 63110

Re: Elementis Specialties, Inc. - St. Louis Plant, 510-0066 Permit Number: OP2018-094

Dear Mr. Lashley:

Carol S. Comer, Director

Enclosed with this letter is your Part 70 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 (CA V) can be set up with you. To request a CA V, please contact your local regional office or fill out an online request. The regional office contact information can be found at http://dnr.mo.gov/regions/. The online 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 RS Mo 643.078.16 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.

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

Sincerely,

AIR. POLLUTION J~.-: N.TRRf L PROGRAM

f) ?~Jafl j~--12] Michael J. Stansfield, P.E. Operating Permit Unit Chief

MJS:kwj

Enclosures

c: PAMS File: 2016-05-076

Recycled paper

~~MISSOURI f\lJ & I DEPARTMENT OF l_gJ ~ NATURAL RESOURCES Air Pollution Control Program

PART 70 PERMIT TO OPERA TE

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

Operating Permit Number: Expiration Date:

Installation ID: Project Number:

Installation Name and Address Elementis Specialties, Inc. - St. Louis Plant 5548 Manchester A venue St. Louis, MO 63110 City of St. Louis

Installation Description:

OP2018-094 NOV O 7 2023 510-0066 2016-05-076

Parent Company's Name and Address Elementis Specialties, Inc. 469 Old Trenton Road East Windsor, NJ 08512

Elementis Specialties, Inc. - St. Louis Plant specializes in the production ofrheological agents. Rheological agents change the flow characteristics of liquids. Elementis Specialties, Inc. uses several varieties of clay, polyethylene waxes, oils, amines and solvents in different combinations and processes to produce its line of agents. The processes are Wet Process Bentone Manufacturing, Dry Process Bentone Manufacturing, Paste and Gel Manufacturing, and Nalzin Manufacturing. The installation is a potential major source of volatile organic compounds (VOC), particulate matter smaller than 10 microns in diameter (PM10), and particulate matter smaller than 2.5 microns in diameter (PM2 5). It is an area source of hazardous air pollutants (HAPs ).

NOV O 7 Effective Date

Elementis Specialties, Inc. - St. Louis Plant Installation ID: 510-0066

Table of Contents

Part 70 Operating Permit 2 Project No. 2016-05-076

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

EMISSION UNITS WITH LIMITATIONS ......................................................................................................... 4 EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS ............................................................................... 5

II. PLANT WIDE EMISSION LIMITATIONS ............................................................................................ 7

PERMIT CONDITION PW00l ...................................................................................................................... 7 10 CSR 10-6.065(6) Voluntary Limitation(s) ............................................................................................... 7

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ....................................................................... 8

PERMIT CONDITION 001 ............................................................................................................................ 8 10 CSR 10-6.060 Construction Permits Required ........................................................................................ 8 MoDNR Construction Permit 082018-009, issued August 7, 2018 ............................................................. 8

PERMIT CONDITION 002 ............................................................................................................................ 9 10 CSR 10-6.060 Construction Permits Required ........................................................................................ 9 MoDNR Construction Permit 122013-006, issued December 17, 2013 ....................................................... 9 10 CSR 10-6.065 Operating Permits (Voluntary Limitations) ..................................................................... 9

PERMIT CONDITION 003 .......................................................................................................................... 11 10 CSR 10-6.060 Construction Permits Required ...................................................................................... 11 MoDNR Construction Permit 082018-009, issued August 7, 2018 ........................................................... 11 MoDNR Construction Permit 122013-006, issued December 17, 2013 ..................................................... 11

PERMIT CONDITION 004 .......................................................................................................................... 12 10 CSR 10-5.520 Control of Volatile Organic Compound Emissions From Existing Major Sources ....... 12 10 CSR 10-5.520 RACT Proposal, Approved March 5, 2001.. .................................................................. 12 10 CSR 10-6.060 Construction Permits Required ...................................................................................... 12 MoDNR Construction Permit 082018-009, issued August 7, 2018 ........................................................... 12 MoDNR Construction Permit 122013-006, issued December 17, 2013 ..................................................... 12 St. Louis City Construction Permit 05-09-008, issued January 10, 2006 ................................................... 12

PERMIT CONDITION 005 .......................................................................................................................... 13 10 CSR 10-6.070, New Source Performance Regulations .......................................................................... 13 40 CFR Part 60, Subpart De - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units .............................................................................................................................. 13

PERMIT CONDITION 006 .......................................................................................................................... 14 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants .................................................... 14

IV. CORE PERMIT REQUIREMENTS .................................................................................................... 16

V. GENERAL PERMIT REQUIREMENTS .............................................................................................. 22

VI. ATTACHMENTS .............................................................................................................................. 27

ATTACHMENT A················································································································································· 28 Fugitive Emission Observations ................................................................................................................. 28

ATTACHMENT B .................................................................................................................................................. 29 Method 22 Visible Emissions Observations ............................................................................................... 29

ATTACHMENT C .................................................................................................................................................. 30 Method 9 Opacity Observations ................................................................................................................. 30

ATTACHMENT D ............................................................................................................................ ····· ................ 32 Inspection/Maintenance/Repair/Malfunction Log ...................................................................................... 32

ATTACHMENT E .................................................................................................................................................. 33 Oxidizer Monitoring Log - Example of Electronic Recordkeeping ........................................................... 33



ATTACHMENT F .................................................................................................................................................. 34 Oxidizer Monitoring Log - Example of Manual Data Recordkeeping ...................................................... 34

ATTACHMENT G ················································································································································· 35 Pressure Drop Monitoring .......................................................................................................................... 3 5


Part 70 Operating Permit

I. Installation Equipment Listing

EMISSION UNITS WITH LIMITATIONS

4 Project No. 2016-05-076

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

Emission Unit Emission Unit Description Control Device1

EU0040 Parkson Filter Press CD-64 (RTO)

EU0050 Bentone Central Vacuum System CD-11 (Baghouse) EU0090 Bentone Reaction Tanks CD-64 (RTO)

EU0l00 Clay Receiver #1 -EU0l 10 Clay Receiver #2 -EU0120 Clay Storage Silos CD-1 (Baghouse)

EU0140 Wet Process Day Silo CD-2 (Baghouse)

EU0150 10 MMBtu/hr Ben tone Flash Dryer # 1

CD-8 (Cyclone)2, CD-9 (Baghouse) (Product Conveying & Drying)

EU0160 10 MMBtu/hr Bentone Flash Dryer #2

CD-10 (Cyclone)2, CD-11 (Baghouse) (Product Conveying & Drying)

EU0l 70 4.185 MMBtu/hr Nalzin Kiln Dryer (Product

CD-15 (Baghouse) Conveying and Drying)

EU0200 Nalzin Mill CD-17 (Baghouse)

EU0210 Nalzin Packing System East CD-18 (Baghouse)

EU0220 Nalzin Packing System West CD-19 (Baghouse)

EU0240a Bentone Pneumatic Transfer CD-13 (Baghouse)

EU0250 Polyethylene Wax Storage Silos CD- 24 (Baghouse)

EU0270 South Horizontal Belt Filter Vacuum Pump CD-64 (RTO)

EU0280 North Horizontal Belt Filter Vacuum Pump CD-64 (RTO)

EU0290 Nalzin Zinc Oxide Transfer CD-16 (Baghouse)

EU0410 PUG Mill Day Silo CD-66 (Baghouse)

EU0430 PUG Mill Baghouse Receiver CD-67 (Baghouse), CD-64 (RTO)

EU0440 PUG Mill Bag Dump Station CD-68 (Baghouse)

EU0730 15 MMBtu/hr natural gas boiler, installed 2017 -

EU0660 Ashbrook Simon Hartley Filter Press CD-64 (RTO)

EU0670 Anion Convey System CD-81 (Baghouse)

EU0680 Soda Ash Convey System CD-82 (Baghouse)

EU0690 Mill "A" CD-83 (Baghouse)

EU0700 Mill "B" CD-84 (Baghouse)

EU0710 Packing Hopper CD-85 (Baghouse)

1 Only control devices that their use is federally enforceable or their use is considered inherent are included in this table. 2 Its use is inherent; the cyclone is conveying the material.



Emission Unit Emission Unit Description Control Device1

EU0720 Packing Station CD-86 (Baghouse)

EU0650 Regenerative Thermal Oxidizer (RTO), 2.295 -

(CD-64) MM Btu/hr (Natural Gas)

EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS The following list provides a description of the equipment that does not have unit specific limitations at the time of permit issuance.

Emission Unit Emission Unit Description

EU0060 (2) Bentone Dispersion Tanks; 3,500 gal

EU0070 Bentone Gel Reactor

EU0150 10 MM Btu/hr Bentone Flash Dryer #1 (Natural Gas)

EU0160 10 MM Btu/hr Bentone Flash Dryer #2 (Natural Gas)

EU0l 70 4.185 MM Btu/hr Nalzin Kiln Dryer (Natural Gas)

EU0190 (2) Nalzin Formation Tank ; 4,300 gal

EU0260 Salt Unloading

EU0300 Amine Tank #4 (10,000-gallon tank, Pre-1970's)

EU0310 Amine Tank #8 ( I 0,000-gallon tank, Pre-1970's)

EU0320 Amine Tank #7 (17,600-gallon tank, Pre-1970's)

EU0330 Toluene Storage Tank (10,000-gallon tank, March 1991)

EU0340 Mineral Spirits Storage Tank (I 0,000-gallon tank, March 1991)

EU0345 Spent Mineral Spirits Storage (500-gallon tank)

EU0350 Xylene Storage Tank ( I 0,000-gallon tank, March 1991)

EU0360 Butanol Storage Tank (10,000-gallon tank, March 1991)

EU0380 East Amine Storage Tank (7,500-gallon tank, January 1998)

EU0390 West Amine Storage Tank (7,500-gallon tank, January 1998)

EU0500 Paste Reactor

EU0510 Paste Hold Tank

EU0520 Paste Drumming

EU0530 Seal Water/Hot Water Tank System

EU0540 P & G Drum Pump Room Vent

EU0550 P & G Reactor Bag Dump

EU0560 Bentone Spill Tanks

EU0570 Gel Drumming

EU0590 Fugitive Piping Emissions

EU0595 Powder Box Emissions (fugitive)

EU0600 12.56 MMBtu/hr Powerhouse Boiler (Natural Gas), 1984

EU0620 Therminol Hot Oil System - Paste & Gel

EU0630 13.836 MMBtu/hr Comfort Space Heating (Natural Gas)


Emission Unit


Emission Unit Description

EU0640 0.48 MMBtu/hr Amine Storage Tank Heater (Natural Gas)

6 Project No. 2016-05-076

Elemcntis Specialties, Inc. - St. Louis Plant Installation ID: 510-0066


II. Plant Wide Emission Limitations

7 Project No. 2016-05-076

The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued. The plant wide conditions apply to all emission units at this installation. All emission units are listed in Section I under Emission Units with Limitations and Emission Units without Limitations.

PERMIT CONDITION PW00l 10 CSR 10-6.065(6) Voluntary Limitation(s)

Monitoring: The permittee shall calibrate, maintain and operate all instruments and control equipment according to the manufacturer's recommendations and according to good engineering practices.

Recordkeeping: 1) The permittee shall record all required recordkeeping (i.e. inspections and corrective actions) in the

appropriate format. Records may be kept electronically using database or workbook systems, as long as all required information is readily available for compliance determinations.

2) All records shall be kept for at least five years.

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

malfunction which could cause an exceedance any of the terms imposed by this permit, no later than ten (10) days after the exceedance or event causing the exceedance (unless otherwise specified in the specific condition), to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102.

2) The permittee shall report any deviations from the emission limitation, operational limitations, monitoring/recordkeeping, and reporting requirements of this permit condition in the semi-annual monitoring report and annual compliance certification required by Section V of this permit.



III. Emission Unit Specific Emission Limitations

8 Project No. 2016-05-076

The installation shall comply with each of the following emission limitations. Consult the appropriate

sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of

the date that this permit is issued.

PERMIT CONDITION 001 10 CSR 10-6.060 Construction Permits Required

MoDNR Construction Permit 082018-009, issued August 7, 2018

Emission Unit Description

EU0120 Clay Storage Silos

EU0140 Wet Process Day Silo

EU0l00 Clay Receiver# 1

EU0110 Clay Receiver #2

EU0600 Powerhouse Boiler

EU0300 Amine Tank #4 (Working Losses)



EU0150 Bentone Flash Dryer #1 (Natural Gas Combustion)

Bentone Flash Dryer # 1 (Product Conveying & Drying)

EU0160 Bentone Flash Dryer #2 (Natural Gas Combustion)

Bentone Flash Dryer #2 (Product Conveying & Drying)

EU0240a Bentone Pneumatic Transfer

EU0640 Amine Tank Heater

EU0270 South Horizontal Belt Filter

EU0280 North Horizontal Belt Filter

EU0040 Parkson Filter Press

EU0060 Bentone Dispersion Tanks

EU0090 Bentone Reaction Tanks

EU0660 Ashbrook Simon Hartley Filter Press

EU0670 Anion Pneumatic Transfer System

EU0680 Soda Ash Pneumatic Transfer System

EU0690 Mill "A"

EU0700 Mill "B"

EU0710 Packing Hopper


EU0720 Packing Station


EU0730 15 MM Btu/hr natural gas water heater, installed 2017 EU0530 Seal Water Tank

Operational Limitation:

9 Project No. 2016-05-076

The permittee shall not exceed a production limit of 14,330 tons from the Bentone process per 12-month consecutive period. [Special Condition lAJ

Monitoring/Recordkeeping: 1) The permittee shall record the monthly and the sum of the most recent consecutive 12 months

production from the Bentone process at EU0720. [Special Condition lBJ 2) The permittee shall keep all records on-site for a minimum of 5 years and the records shall be made

immediately available for inspection to Department of Natural Resources' personnel upon request. These records shall include SDS for all materials used. [Special Condition 4A]

Reporting: 1) The permittee shall report to the Air Pollution Control Program's Compliance/Enforcement Section

at P.O. Box I 76, Jefferson City, MO 65102 or [email protected], no later than ten days after an exceedance of the operating limitation.

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


MoDNR Construction Permit 122013-006, issued December 17, 2013 IO CSR 10-6.065 Operating Permits (Voluntary Limitations)

Emission Unit Description Control Device

EU0050 Bentone Central Vacuum System CD-11 (Baghouse)

EU0l 70 Nalzin Kiln Dryer CD-15 (Baghouse)

EU0200 Nalzin Mill CD-17 (Baghouse)

EU02 l 0 Nalzin Packing System East CD-18 (Baghouse)

EU0220 Nalzin Packing System West CD-19 (Baghouse)

EU0250 Polyethylene Wax Storage Silos CD-24 (Baghouse)

EU0290 Nalzin Zinc Oxide Transfer CD-16 (Baghouse)

EU0120 Clay Storage Silos CD-1 (Baghouse)

EU0410 PUG Mill Day Silo CD-66 (Baghouse)

EU0440 PUG Mill Bag Dump Station CD-68 (Baghouse)

Emission Limitation: The permittee shall not emit visible emissions from the baghouses of this permit condition at all times.

Elementis Specialties, Jnc. - St. Louis Plant Jnstallation ID: 510-0066

Operational Limitation:

Part 70 Operating Permit 10 Project No.2016-05-076

1) The permittee shall operate the fabric filters or baghouses whenever the associated emission units are operating. [Special Condition 2A, Voluntary]

2) The baghouses shall be operated and maintained in accordance with the manufacturer's specifications. [Special Condition 2B, Voluntary]

3) The permittee 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). [Special Condition 2B, Voluntary]

4) During proper operation of the baghouses, no visible emissions are expected. When visible emissions are noted, corrective actions shall be taken. [Special Condition 2C, Voluntary]

Monitoring I Recordkeeping: 1) The permittee shall keep a copy of the manufacturer's specifications on-site. [Voluntary] 2) The permittee shall keep maintenance logs, using Attachment D ( or its equivalent), for the

baghouses, which shall include the following: [Special Condition 2D, Voluntary] a) Incidents of malfunction with impact on emissions, duration of event, probable cause, and

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

3) The permittee shall perform a daily visible emissions observation on the exhaust from the baghouses when the associated process is in operation: [Special Condition 2C, Voluntary J a) Observations shall be made using an U.S. EPA Method 22 trained observer and U.S. EPA

Method 22 like procedures using Attachment Boran equivalent. b) The duration of the observation shall be for a two minute time period on a daily basis. c) The condition of no visible emissions in considered normal for the emission units of this permit

condition. When visible emissions are noted from the emission units, it shall be documented and corrective actions be taken.

d) The observation of visible emissions from an emission unit is considered an excursion and corrective actions shall be implemented within a 24 hour period.

e) Only applies to CD-66 (EU0410) and CD-68 (EU0440): When the level of excursions exceed three percent (3%) of the total number of observations performed during a six month period, the permittee shall contact the Air Pollution Control Program and perform source testing within 90 days of the last excursion to ensure control efficiency of CD-66 and CD-68 are at least 99.0%. If the testing shows a control efficiency less than 99.0%, then the permittee shall apply for a new construction permit to take in account the new control efficiency.

4) The permittee shall keep all records on-site for a minimum of 5 years and the records shall be made immediately available for inspection to Department of Natural Resources' personnel upon request. These records shall include SDS for all materials used. l Special Condition 3A, Voluntary]


at P.O. Box 176, Jefferson City, MO 65102 or [email protected], no later than ten days after an exceedance of the emission and operating limitations.


Elcmentis Specialties, Inc. - St. Louis Plant Installation ID: 510-0066



11 Project No. 2016-05-076

MoDNR Construction Permit 082018-009, issued August 7, 2018 MoDNR Construction Permit 122013-006, issued December 17, 2013

Emission Unit Description Control Device

EU0120 Clay Storage Silos CD-1 (Baghouse)

EU0140 Wet Process Day Silo CD-2 (Baghouse)

EU0 I 00 Clay Receiver# 1 CD-3 (Baghouse)

EU0110 Clay Receiver #2 CD-4 (Baghouse)

EU0 150 Bentone Flash Dryer #1 (Natural Gas Combustion)

Bentone Flash Dryer# I (Product Conveying & Drying) CD-9 (Baghouse)

EU0l 60 Bentone Flash Dryer #2 (Natural Gas Combustion)

Bentone Flash Dryer #2 (Product Conveying & Drying) CD-11 (Baghouse)

EU0240a Bentone Pneumatic Transfer CD-13 (Baghouse)

EU0430 CD-67 (Baghouse ), PUG Mill Baghouse Receiver

CD-64 (RTO)

EU0670 Anion Pneumatic Transfer System CD-82 (Baghouse)

EU0680 Soda Ash Pneumatic Transfer System CD-81 (Baghouse)

EU0690 Mill "A" CD-83 (Baghouse) I---

EU0700 Mill "B" CD-84 (Baghouse)

EU0710 Packing Hopper CD-85 (Baghouse)

EU0720 Packing Station CD-86 (Baghouse)

Operational Limitation: 1) The permittee shall control emissions from the emission sources of this permit condition using

baghouses/fabric filters. lBoth CPs: Special Condition 2A] 2) The permittee shall control emissions from EU0430 using a baghouse followed by a thermal

oxidizer. [122013-006: Special Condition 2AJ 3) The baghouses/filters shall be operated and maintained in accordance with the manufacturer's

specifications. lBoth CPs: Special Condition 2B] 4) Replacement filters for the baghouses shall be kept on hand at all times. The bags/fabric filters shall

be made of fibers appropriate for operating conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance). [Both CPs: Special Condition 2B J

5) The baghouses/fabric filters 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 the Department of Natural Resources' employees may easily observe them. [Both CPs: Special Condition 2C]

6) The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty. In the absence of a manufacturer's performance warranty, the baghouses/fabric filters shall be operated and maintained with a written standard operating



procedures (SOP) developed by the permittee. The SOP shall incorporate baghouse/fabric filter industry design standards. [122013-006 S.C. 2C; 082018-009 S.C. 2EJ

Monitoring/Recordkeeping: 1) The permittee shall keep a copy of the manufacturer's specifications on-site. 2) The permittee shall monitor and record the operating pressure drop across the baghouses/fabric

filters at least once daily when the plant is in operation using Attachment Hor an equivalent. [082018-009 S.C. 2D & 122013-006 S.C. 2C]

3) The permittee shall maintain an operating and maintenance record for the baghouses/fabric filters (e.g. the Malfunction/Breakdown Reporting form) using Attachment Dor an equivalent which shall include the following: [082018-009 S.C. 3D & 122013-006 S.C. 2E] 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 keep all records on-site for a minimum of 5 years and the records shall be made immediately available for inspection to Department of Natural Resources' personnel upon request. These records shall include SDS for all materials used. [Special Condition 4A J


at P.O. Box 176, Jefferson City, MO 65102 or [email protected], no later than ten days after an exceedance of the operating limitation.


PERMIT CONDITION 004 10 CSR 10-5.520 Control of Volatile Organic Compound Emissions From Existing Major Sources

10 CSR 10-5.520 RACT Proposal, Approved March 5, 2001 10 CSR 10-6.060 Construction Permits Required

MoDNR Construction Permit 082018-009, issued August 7, 2018 MoDNR Construction Permit 122013-006, issued December 17, 2013 St. Louis City Construction Permit 05-09-008, issued January 10, 2006

Emission Unit Description Control Device EU0270 South Horizontal Belt Filter

EU0280 North Horizontal Belt Filter

EU0040 Parkson Filter Press CD-64

EU0090 Bentone Reaction Tanks (RTO)

EU0660 Ashbrook Simon Hartley Filter Press

EU0430 PUG Mill and Baghouse Receiver CD-67 (Baghouse ),

CD-64 (RTO) EU0650 Regenerative Thermal Oxidizer (RTO), 2.295 MMBtu/hr (CD-64) (Natural Gas) -

Note: Enclosures Band C may be referenced for more detailed information on the RTO and its operation.


Operating Limitation:


1) The permittee shall control emissions from the emission sources of this permit condition using the thermal oxidizer at all times. [122013-006 S.C. 2A, 082018-009 S.C. 3A]

2) The thermal oxidizer shall be operated and maintained in accordance with the manufacturer's specifications. l 082018-009: Special Condition 3B]

3) Bed 1 and Bed 2 of the oxidizer shall have a temperature set point at l 500°F, controlled by the manufacturer. [082018-009: Special Condition 3Cj

4) The destruction efficiency of the thermal oxidizer shall be at least 95 percent. [RACT]

Performance Testing: The permittee shall conduct a performance test on the oxidizer every five years to verify the control efficiency using the methodologies set forth in 40 CFR Part 60 Appendix A, Methods 1 through 4 and 25A.3 [05-09-008 S.C. 111.3, 122013-006 S.C. 2D]

Monitoring/Recordkeeping: 1) The Average Chamber Temperature of the thermal oxidizer shall be continuously monitored.

[082018-009: Special Condition 3C] 2) The permittee shall maintain an operating and maintenance record for the thermal oxidizer (e.g. the

Malfunction/Breakdown Reporting form) which shall include the following: [082018-009: Special Condition 3DJ a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and

corrective actions; and b) A written record of regular inspection schedule, the date and the results of all inspections,

including any actions or maintenance activities that result from that inspection. 3) Records shall be kept of: [05-09-008 S.C. IV.2, RACT, 082018-009 S.C. 3C]

a) Quantity of Bentone product produced with the percent of IP A in tallow based amine; b) Percentage ethanol in the tallow based amine; c) Percentage water in the tallow based amine; d) The Average Chamber Temperature of the thermal oxidizer, recorded every 15 minutes.


at P.O. Box 176, Jefferson City, MO 65102 or [email protected], no later than ten days after an exceedance of the operating limitation.


PERMIT CONDITION 005 10 CSR 10-6.070, New Source Performance Regulations

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

Emission Unit Description Control Device EU0730 15 MM Btu/hr natural gas water heater, installed 2017 -

3 As of issuance of this permit, the most recent stack test was done on December 9, 2015.



Recordkeeping/Reporting: 1) The permittee shall keep fuel supplier certifications. Fuel supplier certification shall include the

following information: [§60.48c(f)( 4)] a) The name of the supplier of the fuel; [§60.48c(f)(4)(i)] b) The potential sulfur emissions rate or maximum potential sulfur emissions rate of the fuel in ng/ J

heat input; and [§60.48c(f)(4)(ii)] c) The method used to determine the potential sulfur emissions rate of the fuel. [§60.48c(f)(4)(iii)]

2) The permittee shall record and maintain the following records: [§60.48c(g)] a) The amount of fuel combusted in each water heater during each operating day, or[§60.48c(g)(l)J b) The amount of fuel combusted in each water heater during each calendar month, or

[§60.48c(g)(2)J, or c) The total amount of steam generating unit fuel delivered to the property during each calendar

month [§60.48c(g)(3)] 3) The permittee shall keep all records on-site for a minimum of 5 years and the records shall be made

immediately available for inspection to Department of Natural Resources' personnel upon request.

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

PERMIT CONDITION 006 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants

Emission Unit Description EU0I00 Clay Receiver # 1 EU0110 Clay Receiver #2 EU0120 Clay Storage Silos EUl40 Wet Process Day Silo

EU0l50 Bentone Flash Dryer #1 (Product Conveying & Drying)

EU0160 Bentone Flash Dryer #2 (Product Conveying & Drying)

EU0240a Bentone Pneumatic Transfer EU0430 PUG Mill Baghouse Receiver EU0070 Bentone Gel Reactor EU0430 PUG Mill Baghouse Receiver EU0670 Anion Convey System

EU0680 Soda Ash Convey System

EU0690 Mill "A" EU0700 Mill "B" EU0710 Packing Hopper

EU0720 Packing Station

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

units any visible emissions with an opacity greater than 20 percent for any continuous six-minute period. [10 CSR 10-6.220(3)(A)l]

-~



2) Exception: The permittee may discharge into the atmosphere from any emission unit visible emissions with an opacity up to 40 percent for one continuous six-minute period in any 60 minutes. l l O CSR 10-6.220(3)(A)2]

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

Monitoring: I) Monitoring schedule:

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

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

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

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

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

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

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

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

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

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

Reporting: 1) The pcrmittee shall report to the Air Pollution Control Program's Compliance/Enforcement Section

at P.O. Box 176, Jefferson City, MO 65102 or [email protected], no later than ten days after an exceedance of the emission limitation.




IV. Core Permit Requirements

16 Project No.2016-05-076

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

10 CSR 10-6.045 Open Burning Requirements and St. Louis Ci Ordinance 68657 16 0 en Burnin Restrictions

1) No person shall cause, suffer, allow or permit the open burning of refuse. 2) No person shall conduct, cause or permit the conduct of a salvage operation by open burning. 3) No person shall conduct, cause or permit the disposal of trade waste by open burning. 4) No person shall cause or permit the open burning ofleaves, trees or the byproducts therefrom, grass,

or other vegetation. 5) It shall be prima-facie evidence that the person who owns or controls property on which open

burning occurs, has caused or permitted said open burning.

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

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

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

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

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

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

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



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

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

I to CSR 10-6.060 Construction Permits Required The pcrmittee 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.

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

10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants and 40 CFR Part 61 Sub art M National Emission Standard for Asbestos

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.

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

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

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

3) The permittee shall pay an annual emission fee per ton of regulated air pollutant emitted according to the schedule in the rule. This fee is an emission fee assessed under authority of RSMo. 643.079.

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

I t0 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.

Elementis Specialties, Inc. - St. Louis Plant Installation 10: 510-0066


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

18 Project No.2016-05-076

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. This odor evaluation shall be taken at a location outside of the installation's property boundary.

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

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 particulate matter emissions to go beyond the premises of origin in quantities that the particulate matter may be found on surfaces beyond the property line of origin. The nature or origin of the particulate matter shall be determined to a reasonable degree of certainty by a technique proven to be accurate and approved by the director.

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

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

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

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

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

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

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

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


R ecordkeeping:


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

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

I 10 CSR 10-6.180 Measurement of Emissions of Air Contaminants l) 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 Exem tion Re uirements

This is a State Only permit requirement. 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 Missouri Department of Natural Resources Air Pollution Control Program. This rule requires training providers who offer training for asbestos abatement occupations to be accredited by the Missouri Department of Natural Resources 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.

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

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

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

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

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



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

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

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

10 CSR 10-5.060 Refuse Not to be Burned in Fuel Burning Installations (Rescinded on Februa 11, 1979, Contained in State Im lementation Plan)

No person shall burn or cause or permit the burning ofrefuse in any installation which is designed for the primary purpose of burning fuel.

I 40 CFR Part 82 Protection of Stratospheric Ozone (Title VI) 1) The permittee shall comply with the standards for labeling of products using ozone-depleting

substances pursuant to 40 CFR Part 82, Subpart E: a) All containers in which a class I or class II substance is stored or transported, all products

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

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

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

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

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

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

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

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

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

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

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

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

Elementis Specialties, Inc. - St. Louis Plant Installation JD: 510-0066


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

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



V. General Permit Requirements

22 Project No. 2016-05-076

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

10 CSR 10-6.065(6)(C)l.B Permit Duration 10 CSR 10-6.065 6 E 3.C Extension of Ex ired Permits

This permit is issued for a term of five years, commencing on the date of issuance. This permit will expire at the end of this period unless renewed. If a timely and complete application for a permit renewal is submitted, but the Air Pollution Control Program fails to take final action to issue or deny the renewal permit before the end of the term of this permit, this permit shall not expire until the renewal permit is issued or denied.

I 10 CSR 10-6.065(6)(C)l.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, Compliance and

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

i) October 1st for monitoring which covers the January through June time period, and ii) April 1st for monitoring which covers the July through December time period.

c) Each report shall identify any deviations from emission limitations, monitoring, record keeping, reporting, or any other requirements of the permit, this includes deviations or Part 64 exceedances.

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

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

Elcrnentis Specialties, Inc. - St. Louis Plant Installation ID: 510-0066


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

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

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

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

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

J 10 CSR 10-6.065(6)(C)l.F Severability Clause In the event of a successful challenge to any part of this permit, all uncontested permit conditions shall continue to be in force. All terms and conditions of this permit remain in effect pending any administrative or judicial challenge to any portion of the permit. If any provision of this permit is invalidated, the permittee shall comply with all other provisions of the permit.

J 10 CSR 10-6.065(6)(C)l.G General Requirements I) 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 pursuant to IO CSR 10-6.065(6)(C)l.

10 CSR 10-6.065(6)(C)l.H Incentive Programs Not Requiring Permit Revisions No permit revision will be required for any installation changes made under any approved economic incentive, marketable permit, emissions trading, or other similar programs or processes provided for in this permit.



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

I to CSR to-6.065(6)(C)3 Compliance Requirements

24 Project No. 2016-05-076

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 EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219, as well as the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and Part 64 exceedances and excursions must be included in the compliance certifications. The compliance certification shall include the following: a) The identification of each term or condition of the permit that is the basis of the certification; b) The current compliance status, as shown by monitoring data and other information reasonably

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

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

compliance status of this installation.

Elcmentis Specialties, Inc. - St. Louis Plant Installation ID: 510-0066

110 CSR 10-6.065(6)(C)6 Permit Shield


1) Compliance with the conditions of this permit shall be deemed compliance with all applicable requirements as of the date that this permit is issued, provided that: a) The applicable requirements are included and specifically identified in this permit, or b) The permitting authority, in acting on the permit revision or permit application, determines in

writing that other requirements, as specifically identified in the permit, are not applicable to the installation, and this permit expressly includes that determination or a concise summary of it.

2) Be aware that there are exceptions to this permit protection. The permit shield does not affect the following: a) The provisions of section 303 of the Act or section 643.090, RSMo concerning emergency

orders, b) Liability for any violation of an applicable requirement which occurred prior to, or was existing

at, the time of permit issuance, c) The applicable requirements of the acid rain program, d) The authority of the Environmental Protection Agency and the Air Pollution Control Program of

the Missouri Department of Natural Resources to obtain information, or e) Any other permit or extra-permit provisions, terms or conditions expressly excluded from the

permit shield provisions.

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

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

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

I 10 CSR 10-6.065(6)(C)8 Operational Flexibility An installation that has been issued a Part 70 operating permit is not required to apply for or obtain a permit revision in order to make any of the changes to the permitted installation described below if the changes are not Title I modifications, the changes do not cause emissions to exceed emissions allowable under the permit, and the changes do not result in the emission of any air contaminant not previously emitted. The permittee shall notify the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219, at least seven days in advance of these changes, except as allowed for emergency or upset conditions. Emissions allowable under the permit means a federally enforceable permit term or condition determined at issuance to be required by an applicable requirement that establishes an



emissions limit (including a work practice standard) or a federally enforceable emissions cap that the source has assumed to avoid an applicable requirement to which the source would otherwise be subject. 1) Section 502(b )( 10) changes. Changes that, under section 502(b )( 10) of the Act, contravene an

express permit term may be made without a permit revision, except for changes that would violate applicable requirements of the Act or contravene federally enforceable monitoring (including test methods), record keeping, reporting or compliance requirements of the permit. a) Before making a change under this provision, The permittee shall provide advance written notice

to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219, describing the changes to be made, the date on which the change will occur, and any changes in emission and any permit terms and conditions that are affected. The permittee shall maintain a copy of the notice with the permit, and the APCP shall place a copy with the permit in the public file. Written notice shall be provided to the EPA and the APCP as above at least seven days before the change is to be made. If less than seven days notice is provided because of a need to respond more quickly to these unanticipated conditions, the permittee shall provide notice to the EPA and the APCP as soon as possible after learning of the need to make the change.

b) The permit shield shall not apply to these changes.

I to CSR 10-6.065(6)(C)9 Off-Permit Changes 1) Except as noted below, the permittee may make any change in its permitted operations, activities or

emissions that is not addressed in, constrained by or prohibited by this permit without obtaining a permit revision. Insignificant activities listed in the permit, but not otherwise addressed in or prohibited by this permit, shall not be considered to be constrained by this permit for purposes of the off-permit provisions of this section. 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 subject to any requirements under Title IV of the Act or is a Title I modification;

b) The permittee must provide contemporaneous written notice of the change to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219. This notice shall not be required for changes that are insignificant activities under 10 CSR 10-6.065(6)(8)3 of this rule. 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.

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; and

d) The permit shield shall not apply to these changes.

I to CSR 10-6.020(2)(R)34 Responsible Official The application utilized in the preparation of this permit was signed by Bill Lashley, Plant Manager. If this person terminates employment, or is reassigned different duties such that a different person becomes the responsible person to represent and bind the installation in environmental permitting affairs, the owner or operator of this air contaminant source shall notify the Director of the Air Pollution Control Program of the change. Said notification shall be in writing and shall be submitted within 30 days of the change. The notification shall include the name and title of the new person assigned by the source



owner or operator to represent and bind the installation in environmental permitting affairs. All representations, agreement to terms and conditions and covenants made by the former responsible person that were used in the establishment of limiting permit conditions on this permit will continue to be binding on the installation until such time that a revision to this permit is obtained that would change said representations, agreements and covenants.

I t 0 CSR 10-6.065(6)(E)6 Reopening-Permit for Cause This permit shall be reopened for cause if: I) The Missouri Department of Natural Resources (MoDNR) receives notice from the Environmental

Protection Agency (EPA) that a petition for disapproval of a permit pursuant to 40 CFR § 70.8( d) has been granted, provided that the reopening may be stayed pending judicial review of that determination,

2) MoDNR 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,

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

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

the installation and the installation receives authorization for coverage under that general permit, 4) The installation is an affected source under the acid rain program and additional requirements

(including excess emissions requirements), become applicable to that source, provided that, upon approval by EPA, excess emissions offset plans shall be deemed to be incorporated into the permit; or

5) MoDNR or EPA determines that the permit must be reopened and revised to assure compliance with applicable requirements.

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

VI. Attachments

Attachments follow.


Visible Emissions

Date Time Beyond Boundary

No Yes


Attachment A Fugitive Emission Observations

28 Project No. 2016-05-076

If There Are Visible Emissions Beyond the Property Boundary

Initial Cause Corrective

Action



Attachment B

Method 22 Visible Emissions Observations

Installation Name Observer Name

Location Date

Sky Conditions Wind Direction

Precipitation Wind Speed

Time Emission unit

29 Project No. 2016-05-076

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

Seconds Minute 0 15 30 45 Comments

Visible Emissions Yes (Y) or No (N) 0 1 2

3 4

5 6

If visible e1111ss10ns are observed, the installation is not required to complete the entire six-minute observation. The installation shall note when the visible emissions were observed and shall conduct a Method 9 opacity observation.



Attachment C

Method 9 Opacity Observations

Installation Name:

Emission Point:

Emission Unit:

Observer Name and Affiliation:

Observer Certification Date:

Method 9 Observation Date:

Height of Emission Point:

Time:

Distance of Observer from Emission Point:

Observer Direction from Emission Point:

Approximate Wind Direction:

Estimated Wind Speed:

Ambient Temperature:

Description of Sky Conditions (Presence and color of clouds):

Plume Color: Approximate Distance Plume is Visible from Emission Point:

Seconds I-minute 6-minute Minute 0 15 30 45 Avg.% Avg.%

Opacity Readings(% Opacity)6 Opacity4 Opacity5

0 NIA I NIA 2 NIA 3 NIA 4 NIA 5

6

7

8

9

10

11

12

30 Project No. 2016-05-076

Sketch of the observer's position relative to the emission unit

Start of End of observations observations

Steam Plume (check if applicable) Comments

Attached Detached

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


13

14

15 16

17

18 19

20 21

22

23 24

25

26 27 28

-·

29

30


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

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

Signature of Observer



Emission Unit#

Attachment D Inspection/Maintenance/Repair/Malfunction Log

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

Inspection/ Malfunction Activities

Date/Time Maintenance Activities Malfunction Impact Duration Cause

32 Project No. 2016-05-076

Action Initials



Attachment E

33 Project No. 2016-05-076

Oxidizer Monitoring Log - Example of Electronic Recordkeeping

(Excel Spreadsheet, export from automatic Data Logger recording the Average Chamber Temperature every 15 minutes)

~c':'f'l;IIYr•lc.Js?::·,,f :'.]\'.£\// .':.,"~,rn,-. ,,;'·'.\\\iCii\\ . :;,; '\'.'.AB l::JE:t:t r' .:>li:1 ;:111,r#11MESW~A"?:t:. ;:1; ,i~wouXc1r# 1041219 Chamber Average 1639 0l/0l/20xx 12:04:53 AM 192 1041224 Chamber Average 1694 0l/0l/20xx 12:19:53 AM 192 1041229 Chamber Average 1650 0l/0l/20xx 12:34:53 AM 192 1041234 Chamber Average 1660 0l/0l/20xx 12:49:53 AM 192 1041239 Chamber Average 1692 0l/0l/20xx 1:04:53 AM 192 1041244 Chamber Average 1640 0l/0l/20xx 1:19:53 AM 192 1041249 Chamber Average 1692 0l/0l/20xx 1:34:53 AM 192 1041254 Chamber Average 1646 0l/0l/20xx 1:49:53 AM 192 1041259 Chamber Average 1653 0l/0l/20xx 2:04:53 AM 192 1041264 Chamber Average 1697 0l/0l/20xx 2:19:53 AM 192 1041269 Chamber Average 1675 0l/0l/20xx 2:34:53 AM 192 1041274 Chamber Average 1660 0l/0l/20xx 2:49:53 AM 192 1041279 Chamber Average 1673 0l/0l/20xx 3:04:53 AM 192 1041284 Chamber Average 1640 0l/0l/20xx 3:19:53 AM 192 1041289 Chamber Average 1695 0l/0l/20xx 3:34:53 AM 192 1041294 Chamber Average 1646 0l/0l/20xx 3:49:53 AM 192 1041299 Chamber Average 1658 0l/0l/20xx 4:04:53 AM 192 1041304 Chamber Average 1689 0l/0l/20xx 4:19:53 AM 192 1041309 Chamber Average 1639 0l/0l/20xx 4:34:53 AM 192 1041314 Chamber Average 1692 0l/0l/20xx 4:49:53 AM 192 1041319 Chamber Average 1641 0l/0l/20xx 5:04:53 AM 192 1041324 Chamber Average 1652 0l/0l/20xx 5:19:53 AM 192 1041329 Chamber Average 1696 0l/0l/20xx 5:34:53 AM 192 1041334 Chamber Average 1671 0l/0l/20xx 5:49:53 AM 192 1041339 Chamber Average 1658 0l/0l/20xx 6:04:53 AM 192 1041344 Chamber Average 1680 0l/0l/20xx 6:19:53 AM 192 1041348 Chamber Average 1642 0l/0l/20xx 6:34:53 AM 192 1041354 Chamber Average 1694 0l/0l/20xx 6:49:53 AM 192 1041359 Chamber Average 1660 0l/0l/20xx 7:04:53 AM 192 1041364 Chamber Average 1658 0l/0l/20xx 7:19:53 AM 192 1041370 Chamber Average 1691 0l/0l/20xx 7:34:53 AM 192 1041374 Chamber Average 1631 0l/0l/20xx 7:49:53 AM 192 1041379 Chamber Average 1691 0l/0l/20xx 8:04:53 AM 192 1041384 Chamber Average 1640 0l/0l/20xx 8:19:53 AM 192 1041389 Chamber Average 1652 0l/0l/20xx 8:34:53 AM 192 1041394 Chamber Average 1696 0l/0l/20xx 8:49:53 AM 192 1041399 Chamber Average 1667 0l/0l/20xx 9:04:53 AM 192 1041404 Chamber Average 1658 0l/0l/20xx 9:19:53 AM 192 1041409 Chamber Average 1668 0l/0l/20xx 9:34:53 AM 192 1041414 Chamber Average 1641 0l/0l/20xx 9:49:53 AM 192 1041419 Chamber Average 1695 0l/0l/20xx 10:04:53 AM 192 1041424 Chamber Average 1667 0l/0l/20xx 10:19:53 AM 192 1041429 Chamber Average 1658 0l/0l/20xx 10:34:53 AM 192



Attachment F

34 Project No. 2016-05-076

Oxidizer Monitoring Log - Example of Manual Data Recordkeeping

(Excel Spreadsheet)

Instructions: If the data logger is not operating, record the following oxidizer parameters every 15 minutes while any pro t' h ·d· cess ven m~ to t e oxz zzer zs operating

Elementis Specialties - St. Louis Plant Oxidizer Operating Log sheet

Diverter Oxidizer

Avg. Chamber Valves in

in Run Automatic Date Time Operator

Mode, Temperature,

and Venting Comments

YIN Deg. F.

to Oxidizer, Y/N71

Enter Enter Enter Enter Enter Enter Enter y y y y y y y y y y y y y y y y y y y y y y y y y y y y y y y y y

7 Diverter valves have been removed and process air is always venting to the oxidizer.


Emission Point/ Date Control Device


Attachment G Pressure Drop Monitoring

Pressure Drop (w.c.)

35 Project No. 2016-05-076

Manufacturer's Within Recommended Value Specifications?

(w.c.) (Yes I No)



STATEMENT OF BASIS

INSTALLATION DESCRIPTION

SB - 1 Project No. 2016-05-076

Elementis Specialties, Inc. - St. Louis Plant (once formerly known as Rheox, Inc.) specializes in the production of rheological agents. Rheological agents change the flow characteristics of liquids. Elementis Specialties, Inc. uses several varieties of clay, polyethylene waxes, oils, amines and solvents in different combinations and processes to produce its line of agents. The processes are the Wet Process Bentone Manufacturing, Dry Process Bentone Manufacturing, Bentone Paste and Gel Manufacturing and Nalzin Manufacturing.

The installation is a potential major source of volatile organic compounds (VOC) and particulate matter smaller than ten microns in diameter (PM10). The installation is an area source of hazardous air pollutant (HAP) emissions. It is not on the List of Named Installations found in 10 CSR 10-6.020(3)(B), Table 2.

Updated Potential to Emit for the Installation Pollutant Potentialto Emit (tons/yr 11

PM10 123.39

PM2s 120.91

Sulfur Oxides (SOx) 0.18

Nitrogen Oxides (NOx) 29.36

Volatile Organic Compounds (VOCs) 174.66

Carbon Monoxide (CO) 24.66

Hazardous Air Pollutants (HAPs) 6.37

Ethyl Benzene (100-41-4) 0.92

Xylene (1330-20-7) 2.72

Toluene (108-88-3) 2.49

8 Each emission unit was evaluated at 8,760 hours of uncontrolled annual operation unless otherwise noted. PM10, PM25, and VOC emissions were calculated with their control devices for all units where their use is federally enforceable or inherent. HAPs < 1.0 ton not included in table.



Repor d A. P II te Ir o utant E .. m1ss10ns, tons oer vear Pollutants 2017 2016 2015

Particulate Matter 2.17 7.37 8.03 _::: Ten Microns (PM10)

Particulate Matter 1.99 7.37 8.03 < 2.5 Microns (PM2s)

Sulfur Oxides 0.03 0.02 0.02 (SO,)

Nitrogen Oxides 4.26 3.59 3.89 (NO,)

Volatile Organic Compounds 37.87 33.13 37.20 (VOC)

Carbon Monoxide 3.58 3.02 3.26 (CO)

Hazardous Air Pollutants 0.23 0.28 0.27 (HAPs)

Permit Reference Documents

SB - 2 Project No. 2016-05-076

2014 2013

11.14 9.30

11.14 9.30

0.05 0.03

8.31 4.47

59.88 51.51

6.97 3.76

0.36 0.35

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) Part 70 Operating Permit Application, received May 27, 2016; 2) 2017 Emissions Inventory Questionnaire, submitted April 28, 2018; 3) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition; 4) Construction Permit 082018-009, Issued August 7, 2018 5) Construction Permit 122013-006, Issued December 17, 2013 6) Construction Project 2013-12-039, No Permit Required. 7) Construction Permit 09-06-014, Issued September 17, 2009 8) Construction Permit 07-08-014, Issued October 2, 2007 9) Construction Permit 012007-018, Issued January 29, 2007 10) Construction Permit 05-09-008, Issued January 10, 2006 11) Construction Permit 98-07-048, Issued January 15, 1999

Missouri Code of State Regulations (CSR) Applicability

10 CSR 10-5.520, Control of Volatile Organic Compound Emissions From Existing Major Sources The Reasonably Available Control Technology (RACT) plan submitted by the permittee to satisfy state rule 10 CSR 10-5.520 contains this statement: "Records of the hours of operation for this emission unit shall be kept." This statement is not included in the operating permit conditions because it is not relevant to compliance of the thermal oxidizer.

Additionally, the requirement to record the exhaust temperatures of the air stream exiting the oxidizer has been removed due to not being relevant for compliance. The RACT states "The actual temperature design constraints will be identified upon completion of the final system design." The exhaust temperature parameter was chosen before the oxidizer was selected. However, once a


Part 70 Operating Permit SB - 3 Project No. 2016-05-076

specific oxidizer was selected, the manufacturer identified, as part of the final system design, that the temperature set point on the beds is the parameter that correlates to the required destruction efficiency, not the exit exhaust temperature.

The primary control device under the RACT plan is the thermal oxidizer. Enclosure B shows the flow diagram to and through the thermal oxidizer as well as the temperature monitoring schematic. Enclosure C gives information on: Oxidizer Operating Parameters; Oxidizer Range for Normal Operations; Performance Criteria for Monitoring Elements; Monitoring Activities; and, Supplemental Information on Oxidizer Operations and Procedures.

As a part of the capital project to install the thermal oxidizer, the cost effectiveness for each emission unit to be controlled was reviewed. As discussed with St. Louis City Air Pollution Control Program and the Missouri Department of Natural Resources in the period of December 2001 - January 2002, the cost of installing a thermal oxidizer to control VOC emissions from EU0l 50, Bentone Flash Dryer #1 and EU0160, Bentone Flash Dryer #2 exceeded the RACT cost effectiveness requirements and it was determined that there was no RACT available for these units.

10 CSR 10-5.300, Control ofEmissionsfrom Solvent Metal Cleaning. This regulation does not apply because the cold cleaner uses an aqueous cleaning compound that contains less than 1.2% VOC.

10 CSR 10-5.385, Control ofHeavy Duty Diesel Vehicle Idling Emissions. The permittee does not own or operate diesel vehicles.

10 CSR 10-5.455, Control ofEmissionsfrom Industrial Solvent Cleaning Operations. This regulation does not apply because the emissions from solvent cleaning operations are less than 3 tons of VOC per any consecutive 12-month period.

10 CSR 10-5.540, Control ofEmissionsfrom Batch Process Operations. The batch processes potential to emit VOC is much less than the 100 tons/year as required by the regulation to apply.

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

10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants This rule applies. This rule applies to non-fugitive PM-emitters that emit to the outdoors. Natural gas fueled units are exempt per (l)(L). This includes the burners for dryers EU0150, EU0160, and EU0l 70, the boilers EU0730 and EU0600, and the heaters EU0630 and EU0640.

While the rule applies to the following units, the units are subject to a more stringent opacity limitation in this operating permit (no allowable visible emissions). In order to streamline this operating permit this rule was not applied to them:



Emission Unit Description EU0050 Bentone Central Vacuum System EU0170 Nalzin Kiln Dryer (Product Conveying & Drying) EU0200 Nalzin Mill EU0210 Nalzin Packing Svstem East EU0220 Nalzin Packing System West EU0250 Polyethylene Wax Storage Silos EU0290 Nalzin Zinc Oxide Transfer EU0410 PUG Mill Dav Silo EU0440 PUG Mill Bag Dump Station

10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds.

SB - 4 Project No.2016-05-076

This regulation does not apply because all combustion units use exclusively pipeline grade natural gas.

10 CSR 10-6.261, Control of Emission of Sulfur Compounds. This regulation does not apply because there are no non-combustible sources of SO2. Additionally, the combustion units are fired exclusively with natural gas, thus the facility is exempt from this rule.

10 CSR 10-6.400, Restriction of Emission of Particulate Matter from Industrial Processes This rule does not apply. Natural gas fueled emission points do not meet the definition of 'process weight' in 10 CSR 10-6.020 and thus are not applicable to the rule. For other determinations, see Enclosure A.

10 CSR 10-6.405, Restriction of Emission of Particulate Matter From Fuel Burning Equipment Used for Indirect Heating

This regulation does not apply because all applicable units use exclusively natural gas and are thus exempt via (1 )(E).

Construction Permit History

Construction Permit 98-07-048, Issued December 10, 1998 This construction permit was not included in the operating permit because the permitted equipment is no longer in service.

Construction Permit #05-09-008, issued January 10, 2006 This permit was issued for a raw material change. It also required a performance test to determine VOC emissions and thermal oxidizer VOC destruction efficiency. Conditions were included to maintain this tested destruction efficiency. In December 2015 a stack test was performed to confirm the destruction efficiency of 95% at a set point of 1500°F.

• Special Condition 1 requires a performance test to be performed on the thermal oxidizer after a raw material change. This special condition has been met and thus has not been incorporated into the operating permit.

• Special Condition 2 requires the thermal oxidizer to operate the combustion temperature per the performance test to ensure proper VOC destruction. This condition was not included due to already incorporating an identical requirement from CP082018-009.

• Special Condition 3 requires performance testing to be done the oxidizer every 5 years to verify oxidizer control efficiency. This condition has been incorporated into the operating permit.



Construction Permit #012007-018, issued January 29, 2007

SB - 5 Project No. 2016-05-076

This permit was issued for an addition of a pug mill production process. This stated that "During proper operation no visible emissions are expected from this emission unit". However, one of the baghouses (control device CD-67 for EU0430) does not actually vent to the atmosphere, but rather to the thermal oxidizer. The "zero" opacity limit was not intended to apply to the thermal oxidizer. All special conditions are superseded by 122013-006.

Construction Permit #07-08-014, issued October 2, 2007 This permit was issued for a modification of the bentone packing system to increase capacity. This construction permit contains conditions that apply to EU0080 and EU0450; however, both of these emission units have been removed and replaced with EU0720. Because the emission units with applicable limitations have been removed from the installation, the conditions in the construction permit were not incorporated into this operating permit.

Construction Permit #09-06-014, issued September 17, 2009 This permit was issued for a modification of a Bentone Organoclay Pneumatic Transfer System by replacing the Pneumatic 7.5-hp Inlet and 15-hp Outlet Fan with a new Pneumatic 30-hp Outlet Fan. The Transfer Line was also replaced with a larger diameter, increasing potential maximum hourly design rate. This construction permit conditions special conditions to ensure proper operations of the baghouse through visible emission monitoring. CP082018-009 modifies the baghouse and contains new conditions to demonstrate proper operation of the baghouse. Because CP082018-009 contains new conditions to demonstrate proper operation of the baghouse, the special conditions of this construction permit were not included.

Construction Permit #122013-006, issued December 17, 2013 This permit was issued for an increase in production through operational changes and the installation of a spare impact mill. • Special Condition 1 supersedes all special conditions in CP 012007-018. • Special Condition 2 requires use of baghouses, and contains visible emission monitoring and

maintenance to demonstrate proper use of the baghouses. It has been incorporated into this operating permit.

• Special Condition 3 contains general recordkeeping and reporting requirements which have been incorporated into this operating permit.

Construction Permit #082018-009, issued August 7, 2018 This permit was issued to allow the operation of two filter presses simultaneously which increases production. This project also modifies and replaces existing pieces of equipment like baghouses and the packaging station. • Special Condition 1 includes a production limit and recordkeeping requirements for the Bentone

process, which has been incorporated into this operating permit. • Special Condition 2 contains baghouse requirements which require their use, a pressure drop test

to be done daily, and general recordkeeping requirements. It has been incorporated into this operating permit.


Part 70 Operating Pennit SB - 6 Project No. 2016-05-076

• Special Condition 3 requires the thermal oxidizer to be used with existing emission points, and includes operational requirements to make sure the oxidizer is being used correctly. It has been incorporated into the operating permit.

• Special Condition 4 contains general recordkeeping requirements which have been incorporated into this operating permit.

New Source Performance Standards (NSPS) Applicability

40 CFR Part 60, Subpart De: Standards of Performance for Small Industrial-Commercial-Industrial Steam Generating Units

This regulation applies to the new EU0730 Boiler due to having a rating over 10 MMBtu/hr and because it was installed after the applicability date. This regulation does not apply to EU0600 because the natural gas boiler was installed before the applicability date of June 9, 1989 and is therefore a grandfathered unit.

40 CFR Part 60, Subpart K: Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 40 CFR Part 60, Subpart Ka: Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984

These regulations do not apply because none of the tanks were manufactured within the applicable dates.

40 CFR Part 60, Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessel:,,) for Which Construction, Reconstruction, or Modification Commenced afier July 23, 1984

This regulation does not apply because all VOL storage tanks manufactured after the applicable starting date are below the limit of 75 m3 (19,813 gallons).

40 CFR Part 60, Subpart 000: Standards of Performance for Nonmetallic Mineral Processing Plants This regulation does not apply because the permittee does not crush or grind clay at this facility and therefore, by definition, is not considered a Nonmetallic Mineral Processing Plant

Maximum Achievable Control Technology (MACT) Applicability

40 CFR Part 63, Subpart T: National Emission Standards.for Halogenated Solvent Cleaning. This regulation does not apply because the installation does not use the halogenated solvents listed in 40 CFR 63.460.

40 CFR Part 63 Subpart FFFF: National Emission Standardsfor Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing.

This regulation does not apply because the installation is not a major source of HAP.

40 CFR 63 Subpart VVVVVV: National Emission Standards for Hazardous Air Pollutantsfor Chemical Manufacturing Area Sources.


Part 70 Operating Permit SB - 7 Project No. 2016-05-076

This regulation does not apply because the installation does not use any of the HAPs listed in Table 1 to the Subpart in amounts greater than 0.1 percent for carcinogens or greater than 1.0 percent for non-carcmogens.

40 CFR Part 63 Subpart BBBBBBB: National Emission Standards/or Hazardous Air Pollutants for Area Sources: Chemical Preparations Industry.

This regulation does not apply. The installation does not use or manufacture materials which contain the target HAP's listed in the rule in amounts greater than or equal to the relevant de minimis levels.

40 CFR Part 63 Subpart JJJJJJ: National Emission Standardsfor Hazardous Air Pollutantsfor Industrial, Commercial, and Institutional Boilers Area Sources.

This regulation does not apply because EU0600, the Powerhouse Boiler, bums pipeline grade natural gas only.

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

None.

Compliance Assurance Monitoring (CAM) Applicability 40 CFR Part 64, Compliance Assurance Monitoring (C'AM) The CAM rule applies to each pollutant specific emission unit that: • Is subject to an emission limitation or standard, and • Uses a control device to achieve compliance, and • Has pre-control emissions that exceed or are equivalent to the major source threshold.

40 CFR Part 64 is not applicable because none of the pollutant-specific emission units uses a control device to achieve compliance with a relevant standard.

Greenhouse Gas Emissions Note that this source may be subject to the Greenhouse Gas Reporting Rule. However, the preamble of the GHG Reporting Rule clarifies that Part 98 requirements do not have to be incorporated in Part 70 permits operating permits at this time. In addition, Missouri regulations do not require the installation to report CO2 emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2 emissions were not included within this permit. If applicable, the applicant is required to report the data directly to EPA. If applicable, the public may obtain CO2 emissions data for this installation by visiting

Other Regulatory Determinations

None.

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;

Elemcntis Specialties, Inc. - St. Louis Plant Installation ID: 510-0066


2. The installation is not in the source category regulated by that rule;

SB - 8 Project No.2016-05-076

3. The installation is not in the county or specific area that is regulated under the authority of that rule; 4. The installation does not contain the type of emission unit which is regulated by that rule; 5. The rule is only for administrative purposes.

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


Part 70 Operating Pennit

Enclosure A, Review of Particulate Emission Sources for Applicability of 10 CSR 10-6.400

Calculated Maximum PM Maximum

Emission Emission Unit Description

Design Emission Emission Factor PM Emission Unit Capacity Factor Source Rate

(tons/hr) (lbs/ton) Uncontrolled (lbs/hr)

Not subject to 10 CSR 10-6.400: Emission Rate< 0.5 lbs/hr EU0060 Bentone Dispersion Tanks 5.9 0.0498 AP-42, Eqn 11.12-1 0.2938 EU0190 Nalzin Formation Tank Vent 2 0.0498 AP-42, Eqn 11.12-1 0.0996 EU0210 Nalzin Packing System East 0.03575 0.19 sec 30101406 0.0068 EU0220 Nalzin Packing System West 0.03575 0.19 sec 30101406 0.0068 EU0290 Nalzin Zinc Oxide Transfer 0.1 0.038 AP-42, Ean 13 .2.4.3-1 0.0038 EU0440 PUG Mill Bag Dump Station 0.075 0.0004 AP-42, Ean 13.2.4.3-1 0.00003 EU0550 P & G Reactor Bag Dump 0.0625 0.498 AP-42, Ean 11.12-1 0.0031 EU0595 Powder box Dump (fugitive) 2.083333 0.0018 AP-42 13.2.4.3; Eqn 1 0.0037

Control Device

None None

CD-18 CD-19 CD-16 CD-68 None None

Not subject to 10 CSR 10-6.400: Uncontrolled Emissions < Calculated PWR limit (listed control devices not enforceable) EU0070 Bentone Gel Reactor 0.76 2 sec 30102005 1.52 CD-27 EU0100 Clay Receiver #1 2.95 2.5 Engineering Cale. 7.375 CD-3 EU0l 10 Clay Receiver #2 2.95 2.5 Emdneerine: Cale. 7.375 CD-4 EU0260 Salt Unloading 12.5 0.0498 AP-42, Eqn 11.12-1 0.6225 None

Overall Control

Efficiency

--

49.5% 49.5% 49.5% 49.5%

--

99.0% 99.0% 99.0%

-

Not subject to 10 CSR 10-6.400: Federally Enforceable Control Device Efficiency> 90% Emission Emission Unit Description Control Device

Unit EU0050 Bentone Central Vacuum System CD-34 EU0080 Bentone Packing System "A'' CD-47 EU0120 Clay Storage Silos CD-1 EU0140 Wet Process Day Silo CD-2 EU0150 Bentone Flash Dryer # l (Product Conveying & Drying) CD-9 EU0160 Bentone Flash Dryer #2 (Product Conveying & Drying) CD-11 EU0170 Nalzin Kiln Dryer (Product Conveying & Drying) CD-15 EU0200 Nalzin Mill CD-17

EU0240a Bentone Pneumatic Transfer CD-13 EU0250 Wax Storage Silos CD-24 EU0410 PUG Mill Day Silo CD-66 EU0430 PUG Mill Baghouse Receiver CD-67

ENC- 1 Project No. 2016-05-076

Calculated Maximum PM Emission

PM Emission Limit Rate Established in

Controlled Rule (lb/hr) (lbs/hr)

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

- 3.41 - 8.46 - 8.46 - 22.27

Overall Control Efficiency

99.0% 99.0% 99.0% 99.0% 99.0% 99.0% 99.0% 99.0% 99.0% 99.0% 99.0% 99.0%

Elementis Specialties, Inc. - St. Louis Plant Installation ID: 51 0-0066

EU0670 Anion Convev System EU0680 Soda Ash Convey System EU0690 Mill"A" EU0700 Mill ''B" EU0710 Packing Hopper EU0720 Packin_g Station


CD-81 CD-82 CD-83 CD-84 CD-85 CD-86

ENC-2 Project No.2016-05-076

99.0% 99.0% 99.0% 99.0% 99.0% 99.0%



Enclosure B, Oxidizer Temperature Monitoring Schematic

Figure 1: Oxidizer Temperatme Monitoring Schematic

:: _;,:,~;.::.:1 F ,,

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-=~·_; '~,; ':- ~.:: -.;.:... - ;7" ."i _-:-

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Elementis Specialties, fnc. - St. Louis Plant Installation ID: 510-0066

Part 70 Operating Permit ENC-4 Project No. 2016-05-076

Enclosure C, Outline of Operating and Monitoring Parameters to Ensure Proper Operation of the Thermal Oxidizer

Goal: To ensure that the oxidizer meets the desired minimum 95 percent DRE required for compliance with RACT for the following emission units:

EU0040 (Parkson Filter); EU0090 (Bentone Reaction Tanks); EU0270 (South Horizontal Belt Filter); EU0280 (North Horizontal Belt Filter); and EU00430 (PUG Mill Packer)

- ~

Operating Temperature Inspections Performance Testing

I. Oxidizer Operating Parameters

Oxidizer Set Point The oxidizer, including alarms and Performance test demonstrating a

Indicator automatic cutoffs, is in a condition to Oxidizer Average Chamber Temperature ensure proper operations.

minimum 95% control efficiency

Set point is proprietary and controlled by solely by the

Measurement Approach manufacturer (Adwest Technologies Inc). Standard operating practices, inspections Conduct an emissions test in accordance

Continuously monitor the Average Chamber and preventive maintenance activities. with USEPA methodologies. Temperature.

II. Oxidizer Range for Normal Operations

The oxidizer operates at a temperature set point of 1500 0 P for both Bed 1 and Bed 2, controlled by the

Oxidizer is structurally intact. The oxidizer was installed to provide a manufacturer. Indicator Range

The temperature of each chamber is expected to vary Oxidizer alarms and interlocks are minimum of95% control efficiency, as

operating as designed. per the facility's RACT analysis. between 1450 and 2000 °P, with the typical Average Chamber Temperature between 1500 °P to 1750 °P.

I. If the average chamber temperature drops below 1515°P, processes which exhaust to the oxidizer will be shut down and the main alarm sounds at the oxidizer unit [See Part V, B.4.]. A secondary set of alarms has Inspect the oxidizer and repair as been installed and oxidizer operations will be closely Repair the oxidizer or associated alarms indicated, in consultation with the

Corrective Action monitored if the oxidizer temperature begins to drop and interlocks as required in the event manufacturer, in the event that any below 1600°P. that a non-standard item is identified. performance test indicates a less than

2. The oxidizer automatically "faults" and shuts off flow 95% control efficiency. from emission sources based on a number of monitored criteria, all of which relate to the performance of the oxidizer. [See Part V, A.5] Any automatic shut off of flow from emission sources results in the following:

Elementis Specialties, Inc. - St. Louis Plant Installation TD: 510-0066


Operating Temperature Inspections

a) An alarm sounds in the Wet Process Control Room which triggers a manual shutdown of the wet bentone manufacturing process.

b) The dry bentone manufacturing process automatically goes to a recycle mode, during which no VOCs are emitted.

c) Corrective action is initiated to resolve or repair the cause of the problem.

III. Performance Criteria for Monitoring Elements

The oxidizer will be inspected for The thermocouples used to measure oxidizer temperatures structural integrity and for performance

Data Representativeness will be accurate to within± 5 °F. effectiveness as per manufacturer's

recommendations.

Oxidizer temperatures are displayed in the control room.

Verification of Operation The Average Chamber Temperature is recorded electronically. Inspection records.

Status Automatic alarms and shutdown if the oxidizer is non-operational.

Validation of: QA I QC Practices and • Thermocouple accuracy Criteria • Data logger adequacy

Not applicable

• Automatic shutdown

IV. Monitoring Activities

Elementis:

a) Daily informal observation of oxidizer to verify operations.

b) Monthly vibration test of the oxidizer

Monitoring Frequency Temperature is measured and displayed continuously. process air fan to confirm integrity. c) Semi-annual inspection I replacement

(as needed) of mist eliminator elements.

d) Annual validation of the temperature recording system.

ENC- 5 Project No. 2016-05-076

Performance Testing

A test protocol will be prepared and approved (as required) to determine the destruction efficiency of the oxidizer.

Not applicable

As per the approved protocol

Performance tests will be conducted every 5 years.

Elementis Specialties. Inc. - St. Louis Plant Installation ID: 510-0066


Operating Temperature Inspections

Manufacturer (Ad-West}:

a) Annual internal inspection of oxidizer, including the accuracy of the various oxidizer monitoring devices, alarms, and interlocks.

Electronic: The Average Chamber Temperature is recorded electronically on the data logger every 15 minutes with backup data logging in DeltaV control Maintains records of inspections, along

Data Collection Procedures system. with any corrective action taken.

Manual Backup: In the event of a problem with both of Maintain records of repairs and the electronic data loggers, the Average Chamber replacements. Temperature is recorded in the operating log every 15 minutes while either department is operating.

Recordkeeping Electronic data records and paper records are maintained Electronic data records and paper records for a minimum of 5 years. are maintained for a minimum of 5 years.

Malfunctions that result in excess emissions will be reported within 24 hours. A written follow-up report will be submitted as specified in the Title V operating permit. The malfunction will be included in the semi-annual

Reporting compliance reports, as specified in the Title V operating

Not applicable permit.

Malfunctions that do not result in excess emissions will be reported within 10 days of the event and included in the semi-annual compliance report, as specified in the Title V operating permit.


Performance Testing

As per the approved test methods.

Electronic data records and paper records are maintained for a minimum of 5 years.

The test protocol will be submitted to St. Louis City and the MDNR as least 30 days prior to the test.

The test report will be submitted to the MDNR within 60 days following the completion of the test.



V. Supplemental Information on Oxidizer Operations and Procedures

Also refer to Figure 1, Oxidizer Temperature Monitoring Schematic

A. OXIDIZER OPERATIONS:


Operating at a set point of 1500 °F for Bed l and Bed 2 automatically maintains the operating temperatures within the ranges necessary to achieve complete combustion and a destruction efficiency of greater than 95%. The Average Chamber Temperature is used as the primary indicator because it demonstrates that the oxidizer is operating as designed, within the desired set point.

The Average Chamber Temperature is defined to be the arithmetic average of the instantaneous Chamber 1 and Chamber 2 temperatures, rounded to the nearest whole num her. It is calculated as ( TE-103 + TE-104) / 2.

Oxidizer chamber temperatures constantly fluctuate based on the set point, the upper temperature limit of2000 °F, and other process parameters:

1. One bed is active while the other regenerates. Once the second bed is finished regenerating and is now active, the first bed begins regenerating. The process air flows through each bed, from the low temperature bed to the higher temperature bed. The direction of flow reverses on average every 4 minutes.

2. The oxidizer uses natural gas at start up until the oxidizer reaches "Run Mode" which occurs when both beds greater than 1300 °F and the average chamber temperature reaches 1700 °F.

3. The oxidizer will continue to maintain the bed temperatures above the set point using the VOC in the process air as the primary fuel. Natural gas flow is adjusted and fed as needed to maintain the oxidizer temperature above the set point any time either bed temperature is less than 1500 °F. As a safeguard, if either chamber temperature is greater than 1700 °F, natural gas will shut off, regardless of the bed temperatures.

4. In addition to the reversal of the air flow direction, process variability can affect the bed and chamber temperatures because higher or lower VOC levels in the process air can require supplemental natural gas to be used or the natural gas to be cut off The temperature variation does not affect the control efficiency as long as the bed and chamber temperatures remain within the range indicated by the selected set point.

5. The oxidizer automatically faults and shuts off process air as a result ofa number of variables, including a power failure, a high differential temperature, low compressed air pressure, low/high fuel gas pressure, combustion blower failure, etc. which indicate problems with normal operations of the oxidizer will also trigger a fault and an automatic shutdown of the unit.

6. The oxidizer was demonstrated to control emissions to greater than 95% efficiency, even with a set point as low as 1450 °F. [The most recent stack test in December 2015 showed a 99% control efficiency at a set point of 1500 °F. The December 2010 test showed a 97.8% control efficiency at a set point of 1500 °F and a 97.7% control efficiency at 1450 °F.]

B. FACILITY PROCEDURES I. The facility does not vent process operations to the oxidizer until the oxidizer has reached "Run Mode" and can accept process air. 2. The facility will not operate the affected wet process or dry process operations unless process air from these operations is venting to the oxidizer and the oxidizer is

operational. 3. As per A.5. above, the oxidizer PLC controller continuously monitors a variety of parameters associated with oxidizer operations and will automatically shut down the

oxidizer when it is not operating as designed. This triggers the following: a. An audible alarm sounds at the oxidizer unit to alert all nearby personnel. b. An alarm sounds in the Wet Process Control Room, which triggers a manual shutdown of wet process operations. c. An alarm sounds in the Dry Process Control Room, which triggers a manual switch to recirculation mode, with no VOC emissions. d. Elementis personnel investigate and correct the cause of the problem before restarting the oxidizer. e. Wet process I dry process operations are not restarted until the oxidizer is operating normally and has reached ·'Run Mode'' and can accept process air.

Elementis Specialties. Inc. - St. Louis Plant [nstallation ID: 5 l 0-0066

Part 70 Operating Permit ENC - 8 Project No. 2016-05-076

4. As an additional practice to ensure that affected production operations will not run when the oxidizer cannot control emissions to at least a 95% DRE. a secondary warning system has been installed. Once the oxidizer reaches normal operating temperature, an alarm sounds if the oxidizer Average Chamber Temperature drops to 1600 °F, 1550 °F, and 1525 °F. The wet process control room operator must acknowledge each alarm. a. At 1600 °F, a wet process control room operator will begin monitoring the Average Chamber Temperature closely. b. At 1550 °F, the wet process control room operator will alert the dry process control room operator and supervision to potential problems with the oxidizer. c. At 1525 °F, the wet process control room operator will alert supervision and the dry process control room operator that the temperature is continuing to drop. d. If the Average Chamber Temperature continues to drop and drops to 1515 F, an alarm will sound at the oxidizer shack and wet process and dry process operations

which exhaust to the oxidizer will be manually shut down. e. The same procedures described in 8.3., above, will be followed if the oxidizer shuts down.

C. MONITORING COMMENTS: The combination of the continuous monitoring of oxidizer parameters, including Average Chamber Temperature, along with automatic oxidizer shut down, and facility response practices, ensure that recording the average chamber temperature every 15 minutes will sufficiently document that the oxidizer operated effectively during the time period.



Response to Public Comments

RPC- I Project No.2016-05-076

The draft permit was put up on public notice September 14, 2018 for a period of 30 days. During this time public comments from Robert Cheever from EPA Region 7 were received on September 26, 2018. The comments are addressed in the order in which they appear within the received email.

Comment #1: Permit Condition 004 incorporates the applicable requirements associated with the South Horizontal and North Horizontal Belt Filters; the Parkson Filter Press; the Bentone Reaction Tanks; the Ashbrook Simon Hartley Filter Press; the PUG Mill and Baghouse Receiver and the Regenerative Thermal Oxidizer. There are two (2) enclosures associated with this operating permit which appear to be related to the operation and control of the thermal oxidizer, and yet there is no mention of Enclosure B or Enclosure C within the context of Permit Condition 004. EPA suggests MoDNR consider describing the availability and usefulness of Enclosure B and Enclosure C in Permit Condition 004.

Response to Comment #1: A note under Permit Condition 004's box has been added that references Enclosures Band C as additional helpful information on the RTO.