Michael L. Parson, Governor

JAN O 2 2019 Mr. Daniel Chamberlin Plant Environment Coordinator Nestle Purina PetCare Company 22450 East State Highway Y Bloomfield, MO 63825

RE: New Source Review Permit - Project Number: 2018-04-033

Dear Mr. Chamberlin:

Carol S. Comer, Director

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

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

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission 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 administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: www.oa.mo.gov/ahc.

Recycled paper

Mr. Daniel Chamberlin Page Two

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

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Susan Heckenk:amp New Source Review Unit Chief

SH:rsj

Enclosures

c: Southeast Regional Office PAMS File: 2018-04-033

Permit Number: 01 2 0 1 9 - 0 0 1

~!§]MISSOURI ITII & I DEPARTMENT OF ~ t::fj NATURAL RESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT

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

Permit Number: 01 2 0 1 9 - 0 0 1 Project Number: 2018-04-033 Installation Number: 207-0014

Parent Company: Nestle Purina PetCare Company

Parent Company Address: Checkerboard Square - 2B, St. Louis, MO 63164

Installation Name:

Installation Address:

Location Information:

Nestle Purina PetCare Company

22450 East State Highway Y, Bloomfield, MO 63825

Stoddard County (S28, T27N, R11 E)

Application for Authority to Construct was made for: The installation of two new process lines that will increase the production of lightweight pet absorbent material (litter) from the expansion of perlite ore. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.

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

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

Di~

JAN O 2 2019

Effective Date Department of Natural Resources

STANDARD CONDITIONS:

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

You will be in violation of 10 CSR 10-6. 060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. In the event that there is a discrepancy between the permit application and this permit, the conditions of this permit shall take precedence. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications.

You must notify the Enforcement and Compliance Section of the Department's Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s). The information must be made available within 30 days of actual startup. Also, you must notify the Department's regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s).

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

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

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

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

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

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

The regional office information can be found at the following website: http://dnr.mo.gov/regions/

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Project No. 2018-04-033

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

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

The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643. 075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10 CSR 10-6.060 paragraph (12)(A)10. "Conditions required by permitting authority."

Nestle Purina PetCare Company Stoddard County (S28, T27N, R11 E)

1. Superseding Condition The conditions of this permit supersede Special Conditions 2 & 3 found in Construction Permit No. 032015-010, previously issued by the Air Pollution Control Program.

2. NOx Emission Limit A. Nestle Purina PetCare Company shall emit less than 95.0 tons of NOx in

any consecutive 12-month period from the entire installation. All current NOx emitting sources include the dryers, preheaters, and furnaces (EP-05, EP-21, EP-23, EP-29 & EP-40-EP-59), which all combust natural gas.

8. Nestle Purina PetCare Company shall develop and use forms to demonstrate compliance with Special Condition 2.A. These forms shall contain, at a minimum, the following information: 1) Installation name & ID number 2) Permit number 3) Current month & 12-month date range 4) Monthly throughput for each NOx emitting source 5) NOx emission factor for each emission source (100 lb/MMscf) 6) Monthly NOx emissions from each emission source 7) Total monthly NOx emissions from all emission sources 8) 12-month rolling total NOx emissions (plus the sum of all startup,

shutdown, and malfunction emissions, as reported to the Air Pollution Control Program's Compliance/Enforcement Section according to the requirements of 10 CSR 10-6.050)

9) Indication of compliance with Special Condition 2.A.

3. CO Emission Limit A. Nestle Purina PetCare Company shall emit less than 95.0 tons of CO in

any consecutive 12-month period from the entire installation. All current CO emitting sources include the dryers, preheaters, and furnaces (EP-05, EP-21, EP-23, EP-29 & EP-40-EP-59), which all combust natural gas.

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Project No. 2018-04-033

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

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

B. Nestle Purina PetCare Company shall develop and use forms to demonstrate compliance with Special Condition 3.A. These forms shall contain, at a minimum, the following information: 1) Installation name & ID number 2) Permit number 3) Current month & 12-month date range 4) Monthly throughput for each CO emitting source 5) CO emission factor for each emission source (84 lb/MMscf) 6) Monthly CO emissions from each emission source 7) Total monthly CO emissions from all emission sources 8) 12-month rolling total CO emissions (plus the sum of all startup,

shutdown, and malfunction emissions, as reported to the Air Pollution Control Program's Compliance/Enforcement Section according to the requirements of 10 CSR 10-6.050)

9) Indication of compliance with Special Condition 3.A.

4. Control Device Requirement- Baghouses A Nestle Purina PetCare Company shall control emissions from the

equipment listed in Table 1 using baghouses, as specified in the permit application.

T bl 1 E a e :quIpmen on roe ,u aq ouses tC t lldb B h Emission .

Point Eqllipo,entJQ · ·: • :9escription .. . . .. . . .. ··•· .• . ·.. .. . ... . ..... .•

EP-50 POL0004406 Perlite Separator 1 POL0004414 Hiqh Temperature Fines Baqhouse 1

EP-51 POL0004506 Perlite Separator 2 POL0004514 Hiqh Temperature Fines Baqhouse 2

EP-52 POL0004606 Perl ite Separator 3 POL0004614 Hiqh Temperature Fines Baqhouse 3

EP-53 POL0004706 Perlite Separator 4 ROL0004714 Hiqh Temperature Fines Baqhouse 4

EP-54 POL0004806 Perlite Separator 5 ROL0004814 Hiqh Temperature Fines Baqhouse 5

EP-55 ROL0004456 Rerlite Separator 6 ROL0004464 Hiqh Temperature Fines Baqhouse 6

EP-56 ROL0004556 Perlite Separator 7 POL0004564 Hiqh Temperature Fines Baqhouse 7

EP-57 ROL0004656 Perlite Separator 8 POL0004664 Hiqh Temperature Fines Baqhouse 8

EP-58 POL0004756 Rerlite Separator 9 POL0004764 High Temperature Fines Baghouse 9

EP-59 POL0004856 Perlite Separator 10 POL0004864 High Temperature Fines Bag house 1 O

EP-60 POL0004411 Expander Furnace 1 - XP Receiver EP-61 POL0004511 Expander Furnace 2 - XP Receiver

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Project No. 2018-04-033

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

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

·Emission .. .. \ .: ... ·:•/ / : : . · .

Point > EquipmentlD I Description

> ··.· ::· .·

EP-62 POL0004611 Expander Furnace 3 - XP Receiver EP-63 POL0004711 Expander Furnace 4 - XP Receiver EP-64 POL0004811 Expander Furnace 5 - XP Receiver EP-65 POL0004461 Expander Furnace 6 - XP Receiver EP-66 POL0004561 Expander Furnace 7 - XP Receiver EP-67 POL0004661 Expander Furnace 8 - XP Receiver EP-68 POL0004761 Expander Furnace 9 - XP Receiver EP-69 POL0004861 Expander Furnace 1 O - XP Receiver

EP-70 POL0004590 Ore Loadout POL0004632 Ore Aspiration Baqhouse

EP-71 POL0004648 Expanded Ore Aspiration Baqhouse 1 EP-72 POL0004641 Exoanded Ore Aspiration Baghouse 2 EP-73 POL0004543 XP Processinq Dust Collector

B. The baghouses shall be operated and maintained in accordance with the manufacturer's specifications. The baghouses shall be equipped with gauges or meters, which indicates the pressure drop across the control devices. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

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

D. Nestle Purina PetCare Company shall monitor and record the operating pressure drop across the baghouses at least once every 24 hours while the plant is operating. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty.

E. Nestle Purina PetCare Company shall maintain a copy of the baghouse manufacturer's performance warranty on site.

F. Nestle Purina PetCare Company shall maintain an operating and maintenance log for the baghouses, which shall include the following: 1) Incidents of malfunction, with impact on emissions (tons), duration

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

and replacements, etc.

5. Control Device Requirement - Filters A. Nestle Purina PetCare Company shall control emissions from the

equipment listed in Table 2 using filters, as specified in the permit application.

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Project No. 2018-04-033

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

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

T bl 2 E a e :q u1pmen on roe ,,, 1 ers t C t II db Flt Emission

. .

Point EquipmentIP ' \) < . Description ·-' .. , .. ·. .. . ., . •,· .,·

POL0003845 Fines StoraQe - Filter Receiver POL0003996 Filter Receiver (Perlite Fines Loadout)

EP-32 POL0004535 Filter Receiver (XP SurQe Bines 1-3) POL0004532 Filter Receiver (XP Surge Bins 4-6) POL0004538 Filter Receiver (XP SurQe Bins 7-10) POL0003842 Filter Receiver (Overs/Fines)

EP-74 POL0004691 Central Vacuum Filter Receiver POL0004493 North XP Storage Bin Vent

EP-75 POL0004313 South XP Storage Bin Vent

B. The filters shall be operated and maintained in accordance with the manufacturer's specifications. The filters shall be equipped with gauges or meters, which indicates the pressure drop across the control devices. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

C. Replacement filters shall be kept on hand at all times. The filters shall be made of fibers appropriate for operating conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance).

D. The filter receivers from pneumatic conveyance systems are inherent to the material transfer process and do not operate continuously; therefore, Nestle Purina PetCare Company is not required to regularly monitor and record the pressure drop across the devices.

E. Nestle Purina PetCare Company shall maintain a copy of the filter manufacturer's performance warranty on site.

F. Nestle Purina PetCare Company shall maintain an operating and maintenance log for the filters, which shall include the following: 1) Incidents of malfunction, with impact on emissions (tons), duration

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

and replacements, etc.

6. Record Keeping and Reporting Requirements A. Nestle Purina PetCare Company shall maintain all records required by this

permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources' personnel upon request.

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Project No. 2018-04-033

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

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

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

7. Performance Testing A. Nestle Purina PetCare Company shall perform testing on EP-53 or EP-54

and EP-63 or EP-64 in accordance with 40 CFR 60, Subpart 000, §60.675 Test methods and procedures, to account for any increased throughput in the existing processes. Nestle Purina PetCare Company shall perform testing on EP-58 or EP-59, EP-68 or EP-69, and EP-73 in accordance with 40 CFR 60, Subpart 000, §60.675 Test methods and procedures, to develop updated emission factors for these processes. Nestle Purina PetCare Company shall also perform testing on EP-58 & EP-59 in accordance with 40 CFR 60, Subpart UUU, §60.736 Test methods and procedures.

8. These tests shall be performed within 60 days after achieving the maximum production rate of the specified emission units, but not later than 180 days after initial start-up for commercial operation.

C. A completed Proposed Test Plan Form (enclosed) must be submitted to the Air Pollution Control Program 30 days prior to the proposed test date so that the Air Pollution Control Program may arrange a pretest meeting, if necessary, and assure that the test date is acceptable for an observer to be present. The Proposed Test Plan may serve the purpose of notification and must be approved by the Director prior to conducting the required emission testing.

D. One electronic copy of a written report of the performance test results shall be submitted to Stacktesting@dnr.mo.gov within 60 days of completion of any required testing. The report must include legible copies of the raw data sheets, analytical instrument laboratory data, and complete sample calculations from the required U.S. EPA Method for at least one sample run.

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

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Project No. 2018-04-033

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

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

F. Nestle Purina PetCare Company shall submit either an amendment to this construction permit or a new construction permit application if any of the stack test results exceed the emission rates provided in Table 3. The amendment or application shall be submitted to the Air Pollution Control Program within 180 days upon completion of the stack test report.

Table 3: Performance Testin Emission Rate Summa Emission Point

EP-53 EP-54 EP-58 EP-59 EP-63 EP-64 EP-68 EP-69 EP-73

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

Project Number: 2018-04-033 Installation ID Number: 207-0014

Permit Number: 0 1 2 0 1 9 - 0 0 1

Installation Address: Nestle Purina PetCare Company 22450 East State Highway Y Bloomfield, MO 63825 Stoddard County (S28, T27N, R11 E)

Parent Company: Nestle Purina PetCare Company Checkerboard Square - 28 St. Louis, MO 63164

REVIEW SUMMARY

• Nestle Purina PetCare Company has applied for authority to install two new process lines that will increase the production of lightweight pet absorbent material (litter) from the expansion of perlite ore.

• The application was deemed complete on April 27, 2018.

• No HAP emissions are expected from the proposed equipment.

• 40 CFR 60, Subpart 000 - Standards of Performance for Nonmetallic Mineral Processing Plants applies to all perlite handling equipment, and 40 CFR 60, Subpart UUU - Standards of Performance for Calciners and Dryers in Mineral Industries applies to the expander furnaces (see Table 5).

• None of the NESHAPs apply to this installation. None of the currently promulgated MACT regulations apply to the proposed equipment.

• Baghouses and filters are being used to control particulate emissions from the equipment in this permit (see Tables 1 & 2).

• This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all pollutants are below de minimis levels.

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

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

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• Emissions testing is required for EP-53/EP-54, EP-58/EP-59, EP-63/EP-64, EP-68/ EP-69 & EP-73 as a part of this permit. Further testing may be required as part of other state, federal, or applicable rules.

• Submittal of an update to your Intermediate Operating Permit application is required for this installation within 90 days of commencement of operations.

• Approval of this permit is recommended with special conditions.

INSTALLATION DESCRIPTION

Nestle Purina PetCare Company's Golden Products Division operates a facility in Bloomfield, Missouri that manufactures pet absorbent material. The facility mines and processes clay to produce the pet absorbent materials, such as cat litter. The facility has numerous pieces of equipment in series that handle in-process clay, such as elevators, conveyors, and receiving bins. An essential and integral part of the production process involves the removal of fines from the clay as it passes through the various production steps in order to meet product specifications. To enhance the removal of fines from the clay, the facility uses special devices called aspirators (also referred to as air ladders) at several locations throughout each production line. The aspirators are devices uniquely designed for the express purpose of pneumatically separating fines from the in-process clay. After passing an aspirator, the in-process clay is essentially free of fines. Fines picked up at the aspirators and at various material transfer points along the production line are aspirated to and removed by a common bag house prior to the air stream being discharged to atmosphere. It is important to emphasize that the primary function of this aspiration system, including the collectors, is for fines removal to achieve strict product specifications which include a 99% dust free product, and not for emission control. This makes the collector an integral part of the process and not an emission control device. Nearly all of the fines removed from the processed clay are reworked as a raw ingredient in the Engineered Litter Process.

The following New Source Review permits have been issued to Nestle Purina PetCare Company from the Air Pollution Control Program.

Table 4: Permit Histo

Permit Number

1093-013 Installation of a dust collector

1094-012 Installation of a bagging system

0195-004 Installation of various processing and handling equipment

0495-004 Installation of various processing and handling equipment

0995-009 Installation of a transfer system and unloading station

0396-027 Modification of pneumatic conveyor system

1296-005 Modification of rotary dryer control system

1199-006 Modification of conventional processing area and upgrade of aspirator system

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,' ', . ,'' .. Permit Nu,mber Description

,.', . . . .

072000-010 Installation of a fines recovery system

032001-014 Installation of a silica gel packaging line and modification of clumping process

052001-025 Replacement of rotary dryer and associated equipment

082002-018 Reopening of surface clay mine at Avert Mine site

032004-013 Installation of equipment for clay fines recycling

052005-009 Installation of equipment to Reconstituted Clay Process

072005-046 Increase of mill area throughput to 125 tons per hour

102011-009 Installation of a dryer and associated equipment

102011-009A Correction to monitoring requirements

042013-012 Installation of equipment for the production of lightweight litter from perlite

032013-009 Temporary permit for lightweight litter production pilot program

112013-004 Installation of equipment for the production of lightweight litter from perlite

012014-004 Installation of equipment for the production of lightweight litter from perlite

032015-010 Installation of equipment for the production of lightweight litter from perlite

042015-008 As-built update to Construction Permit No. 012014-004

042015-00SA Increase in lightweight litter production capacity

PROJECT DESCRIPTION

Nestle Purina PetCare Company is proposing to install two new process lines that will increase the production of lightweight pet absorbent material (litter) from the expansion of perlite ore. New equipment will be installed for the handling and expansion of perlite, as well as for the screening and transfer of perlite fines. Existing process equipment that was previously installed for similar perlite expansion projects will also be relocated and utilized in the new process lines. Table 5 provides a summary of all equipment being affected by this project.

T bl 5 E t S a e .qwpmen ummarv Emission

-.;;• . ': '• ,' ,. ,·'.; ·•.•' ,•·

NSPS Point

EquipmentlD ··. \. Descrip~iqn · Aoolicabilitv •. Equipment Status

BIN0003845 Fines Storage Bin - Existing POL0003733 Filter Receiver (Raw Material) 000 Existing CNV0003989 Fines Loadout Screw Conveyor - Existing

EP-32 POL0003996 Filter Receiver (Perlite Fines Loadout) - Existing POL0004535 Filter Receiver (XP Surge Bins 1-3) - New POL0004532 Filter Receiver (XP Surge Bins 4-6) - New POL0004538 Filter Receiver (XP Surge Bins 7-10) - New (9 & 10) POL0003842 Filter Receiver (Overs/Fines) 000 Existing DRY0004755 Ore Preheater - New

EP-58 DRY0004754 Expander Furnace 9 uuu New POL0004756 Perlite Separator 000 New POL0004764 High Temperature Fines Baghouse - New DRY0004855 Ore Preheater - New

EP-59 DRY0004854 Expander Furnace 1 O uuu New POL0004856 Perlite Separator 000 New POL0004864 High Temperature Fines Baghouse - New

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Emission · •. Qe~cr:iptipri . NSPS

: ... ·

Point Equipment ID

?.· .. ,Acclicabilitv ~q uiprnen~ 9.t~!Y~ .. .. .•.· : : .. : '·: .•c,.. :•.':••·•<.:;: :. ::. ...

EP-68 POL0004761 Expander Furnace 9 - XP Receiver - New EP-69 POL0004861 Expander Furnace 10 - XP Receiver - New

CNV0004433 Incline Unloading Belt 000 Existing CNV0004436 Ore Reversing Conveyor 000 Existing BIN0004437 South Ore Bin 000 Existing BIN0004441 North Ore Bin 000 Existing CNV0004440 Reversing Belt Feeder 000 Existing

- Truck Loading Station - Existing SCR0004444 Screener 000 Existing ELE0004484 Bank Ore Elevator 000 Existing BIN0004541 Ore Fines Surge Bin 000 Existing BIN0004389 Fines Transfer Bin 000 Existing POL0004590 Ore Loadout 000 Existing BIN0004448 Surge Hopper 000 Existing CNV0004483 Ore Shuttle Supply Weigh Belt 000 Existing CNV0004485 Bank Shuttle Conveyor 000 Existing BIN0004401 Ore Surge Bin 1 000 Existing BIN0004501 Ore Surge Bin 2 000 Existing BIN0004601 Ore Surne Bin 3 000 Existing

EP-70 BIN0004701 Ore Surge Bin 4 000 Existing BIN0004801 Ore Surge Bin 5 000 Existing BIN0004451 Ore Surge Bin 6 000 Existing BIN0004551 Ore Surge Bin 7 000 Existing BIN0004651 Ore Surge Bin 8 000 Existing BIN0004751 Ore Surge Bin 9 000 New BIN0004851 Ore Surge Bin 10 000 New BSC0004402 Ore Weigh Belt 1 000 Existing BSC0004502 Ore Weigh Belt 2 000 Existing BSC0004602 Ore Weigh Belt 3 000 Existing BSC0004702 Ore Weigh Belt 4 000 Existing BSC0004802 Ore Weigh Belt 5 000 Existing BSC0004452 Ore Weigh Belt 6 000 Existing BSC0004552 Ore Weigh Belt 7 000 Existing BSC0004652 Ore Weigh Belt 8 000 Existing BSC0004752 Ore Weigh Belt 9 000 New BSC0004852 Ore Weigh Belt 10 000 New CNV0004633 Screw Conveyor 000 Existing POL0004632 Ore Aspiration Bag house - Existing SCR0004409 XP Screener 1 000 Existing SCR0004509 XP Screener 2 000 Existing SCR0004609 XP Screener 3 000 Existing SCR0004709 XP Screener 4 000 Moved to EP-72 SCR0004809 XP Screener 5 000 Moved to EP-72 BIN0004416 XP Hoooer - System 1 000 Existing BSC0004425 Fines Weigh Belt Conveyor 000 Existing

EP-71 BIN0004417 XP Hoooer 1 000 Existing BIN0004517 XP Hoooer 2 000 Existing BIN0004617 XP Hoooer 3 000 Existing BIN0004717 XP Hopper4 000 Moved to EP-72 BIN0004817 XP Hopper 5 000 Moved to EP-72 BSC0004418 XP Furnace Reversing Weigh Belt 1 000 Existing BSC0004518 XP Furnace Reversing Weigh Belt 2 000 Existing BSC0004618 XP Furnace Reversing Weigh Belt 3 000 Existing

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· Emlsslon•· ··•· .. ';. .. : .· : ·.'· .. • ..... ·· •·.:,.. . .. :: NSPS ·.

: .Equipment lD Description Equipment Status 1• Point ... . . .. ·.· .··. ' .·.· Applicability

BSC0004718 XP Furnace Reversina Weiah Belt 4 000 Moved to EP-72 BSC0004818 XP Furnace Reversing Weiah Belt 5 000 Moved to EP-72 BIN0004416 Expanded Perlita Fines Surge Bin 1 000 Existing BIN0004516 Expanded Perlite Fines Surae Bin 2 000 Existinq BIN0004616 Expanded Perlite Fines Surge Bin 3 000 Existing BIN0004716 Expanded Perlite Fines Surge Bin 4 000 Moved to EP-72 BIN0004816 Expanded Perlita Fines Surqe Bin 5 000 Moved to EP-72 CNV0004490 Collection Conveyor 000 Existina ELE0004491 XP Elevator 000 Existinq ELE0004496 XP Bin Elevator 000 Existing CNV0004497 South Bridge Conveyor 000 Existina CNV0004495 West Storaae Discharae Conveyor 000 Existinq SCR0004311 Screener 000 Existing CNV0004315 Storage Discharge Conveyor 2 000 Existinq SCR0004316 Screener 000 Existing CNV0004492 Reversing XP Conveyor 000 Existinq CNV0004317 XP Conveyor from Railcar 000 Existing CNV0004318 XP Conveyor 000 Existinq CNV0004682 Screw Conveyor 000 Updated ExistinQ POL0004648 Expanded Ore Aspiration Baghouse 1 - Updated Existing SCR0004709 XP Screener 4 000 Moved from EP-71 SCR0004809 XP Screener 5 000 Moved from EP-71 SCR0004459 XP Screener 6 000 Existinq SCR0004559 XP Screener 7 000 Moved to EP-73 SCR0004659 XP Screener 8 000 Moved to EP-73 BIN0004717 XP Hopper4 000 Moved from EP-71 BIN0004817 XP Hopper 5 000 Moved from EP-71 BIN0004467 XP Hopper6 000 Existing BIN0004567 XP Hopper 7 000 Moved to EP-73 BIN0004667 XP Hoooer 8 000 Moved to EP-73 BSC0004718 XP Furnace ReversinQ Weigh Belt 4 000 Moved from EP-71

EP-72 BSC0004818 XP Furnace Reversina Weiqh Belt 5 000 Moved from EP-71 BSC0004468 XP Furnace Reversina Weigh Belt 6 000 Existing BSC0004568 XP Furnace Reversing Weigh Belt 7 000 Moved to EP-73 BSC0004668 XP Furnace Reversina Weiqh Belt 8 000 Moved to EP-73 BIN0004716 Expanded Perlite Fines Surge Bin 4 000 Moved from EP-71 BIN0004816 Expanded Perlite Fines Surae Bin 5 000 Moved from EP-71 BIN0004466 Expanded Perlite Fines SurQe Bin 6 000 Existing BIN0004566 Expanded Perlite Fines Surqe Bin 7 000 Moved to EP-73 BIN0004666 Expanded Perlite Fines Surge Bin 8 000 Moved to EP-73 CNV0004490 Collection Conveyor 000 Existinq CNV0004642 Screw Conveyor 000 Updated Existina POL0004641 Expanded Ore Aspiration Baahouse 2 - Updated Existing SCR0004559 XP Screener 7 000 Moved from EP-72 SCR0004659 XP Screener 8 000 Moved from EP-72 SCR0004759 XP Screener 9 000 New SCR0004859 XP Screener 10 000 New

EP-73 BIN0004567 XP Hopper 7 000 Moved from EP-72 BIN0004667 XP Hopper 8 000 Moved from EP-72 BIN0004767 XP Hopper 9 000 New BIN0004867 XP Hopper 10 000 New BSC0004568 XP Furnace Reversina Weiqh Belt 7 000 Moved from EP-72 BSC0004668 XP Furnace Reversina Weigh Belt 8 000 Moved from EP-72

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Emission Equipment ID

' ... ,,·. .. . ::., '"' NSPS •,· C

Point p~s~rlpliP~ ; ,, .•. · ... ), , ... , < < Aoolicabilitv •.·· EquipmentStptll~. ,. ··: , .... ' . '.' •' '.' ''" .. ' ' .

BSC0004768 XP Furnace Reversing Weigh Belt 9 000 New BSC0004868 XP Furnace Reversinq Weiqh Belt 10 000 New BIN0004566 Expanded Perlite Fines Surqe Bin 7 000 Moved from EP-72 BIN0004666 Expanded Perlite Fines Surge Bin 8 000 Moved from EP-72 BIN0004766 Expanded Perlite Fines Surqe Bin 9 000 New BIN0004866 Expanded Perlite Fines Surge Bin 10 000 New POL0004543 XP Processinq Dust Collector - Existinq BIN0004584 Hopper 000 Existing BLW0004639 Blower - Existinq

EP-74 POL0004691 Central Vacuum Filter Receiver - Existing BIN0004574 Hoooer 000 Existinq

CNV0004883 North Reversing Waste Belt Conveyor 000 Existing CNV0004884 South Reversinq Waste Belt Convevor 000 Existing

EP-75 BIN0004203 Surge Bin/Diverter 000 Existing

CNV0004202 South Pickup Belt Conveyor 000 Existing CNV0004200 South Pickup Belt Conveyor 000 Existinq POL0004493 North XP Storage Bin Vent 000 Existing POL0004313 South XP Storaqe Bin Vent 000 Existinq

EP-32 represents equipment associated with the Edison filter receivers. Two of the filters accept material from the expanded fines surge bin, and the filter receivers will accept material from the expanded perlite baghouses. Emissions will exhaust through the filter receivers, which are inherent to the process and do not operate continuously. The overall maximum design rate of EP-32 will be• tons per hour.

EP-58 & EP-59 represent the high temperature fines baghouses for each expander bank. Each emission point will account for particulate emissions from material handling and natural gas combustion from an ore expander furnace and an expanded perlite separator. The maximum design rates for EP-58 & EP-59 will each be 1111 tons per hour. Stack testing will be conducted on one of the previously tested expander banks to account for the increased throughput, and on one of the additional expander banks to develop updated emission factors.

EP-68 & EP-69 represent the low temperature baghouses for each expander bank. Each bag house/receiver will accept material from the perlite separator, and each emission point will account for particulate emissions from transfer of expanded perlite to the baghouse/receiver. The maximum design rates for EP-68 & EP-69 will each be 1111 tons per hour. Stack testing will be conducted on one of the previously tested expander banks to account for the increased throughput, and on one of the additional expander banks to develop updated emission factors.

EP-70 accounts for emissions from the aspirated perlite ore handling sources. Baghouse POL0004632 was added to control aspirated emissions from ore processing. The overall maximum design rate of EP-70 will be• tons per hour.

EP-71 & EP-72 are existing emission points that account for emissions from the expanded perlite aspirated sources. Baghouse POL0004641 was added to control aspirated emissions from expanded perlite processing. EP-71 & EP-72 have been

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rebalanced, with EP-71 handling expander banks 1-3 and EP-72 handling expander banks 4-6. Because EP-71 is reducing the number of expander banks it handles to three and EP-72 was originally tested with three expander banks (6, 7 & 8), additional testing is not required. EP-71 will have an overall maximum d~ate of• tons per hour, and EP-72 will have an overall maximum design rate of - tons per hour.

EP-73 exhausts through a filter receiver, which accepts perlite ore fines from the ore baghouse screw conveyor and ore fines surge bin. This material is transferred to the ore fines loadout bin. EP-73 will have an overall maximum design rate of-tons per hour. Stack testing will be conducted to account for the increased throughput.

EP-74 represents the central vacuum filter receiver, which is part of the Perlite Central Vacuum System. The unit is a general purpose vacuum that accepts material from the expander building, the brid~ conveyor, and the truck loading building. EP-74 will have a maximum design rate of• tons per hour.

EP-75 represents both the north and south bins that store expanded perlite, which exhaust through vent filters. The bins have been repurposed from the Edison Process (formerly EP-31). EP-75 will have an overall maximum design rate of• tons per hour.

Nestle Purina PetCare Company has requested to keep the design rates, emission factors, and equipment layout of this project confidential per Missouri State Rules 10 CSR 10-6.210 Confidential Information. This is the public version of the permit. A confidential version is available under Project No. 2018-04-047.

The Air Pollution Control Program received a separate construction permit application (Project No. 2018-04-053) shortly after receiving the application for this project. The two projects originated from different departments within the company and pertain to different processes at the facility. Although both projects could feasibly be grouped together into one, Nestle Purina PetCare Company wishes to keep them separate. The projects are not being separated to avoid exceeding emission thresholds, modeling requirements, or NSPS/MACT applicability; therefore, the Air Pollution Control Program is allowing the two projects to be kept separate.

EMISSIONS/CONTROLS EVALUATION

PM, PM10, and PM2.s emissions are expected from the processing and handling of perlite. The emission factors used in this analysis for all existing emission points were obtained from stack tests that were previously performed on the same emission points. These emission factors were used to develop emission estimates that will be used until new stack tests are performed on the updated emission points that will include the new and/or relocated equipment. The emission factors used in this analysis for the new emission points were obtained from stack tests previously performed on similar emission points at the installation. These emission factors will also be updated with the results of stack testing that will be performed on the respective emission points.

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The following table provides an emissions summary for this project. Existing potential emissions were taken from the installation's previous construction permit (042015-008), which included rounded values. Existing actual emissions were taken from the installation's most recent EIQ. Potential emissions of the project represent the potential of all new and affected existing equipment, assuming continuous operation (8,760 hours per year). New installation conditioned potential emissions represent the sum of the existing potential emissions, the potential emissions of this project, and the potential emissions of Project No. 2018-04-053.

Table 6: Emissions Summary tons per year

Regulatory Pollutant De Minimis

Levels ....

: ·. <

PM 25.0 N/D N/D 7.62 N/O

PM10 15.0 47 30.31 3.81 50.84

PM2.s 10.0 19 9.57 1.55 20.56

SOx 40.0 38 0.33 0.03 38.03

NOx 40.0 95 67.64 4.91 <95.0

voe 40.0 8 3.05 0.27 8.27

co 100.0 95 47.23 4.12 <95.0

Total HAPs 25.0 3 0.16 0.09 3.09 N/A = Not Applicable; N/D = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all pollutants are below de minimis levels.

APPLICABLE REQUIREMENTS

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

GENERAL REQUIREMENTS

• Start-Up, Shutdown, and Malfunction Conditions, 10 CSR 10-6.050

• Operating Permits, 10 CSR 10-6.065

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

• Per 10-6.110(4)(8)2.B(II), a full EIQ is required for the first full calendar year the equipment in this permit is in operation

• Restriction of Emission of Odors, 10 CSR 10-6. 165

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

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

SPECIFIC REQUIREMENTS

• New Source Performance Regulations, 10 CSR 10-6.070 • Standards of Performance for Nonmetallic Mineral Processing Plants,

40 CFR 60, Subpart 000

• Standards of Performance for Calciners and Dryers in Mineral Industries, 40 CFR 60, Subpart UUU

STAFF RECOMMENDATION

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

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

• The Application for Authority to Construct form, dated April 18, 2018, received April 19, 2018, designating Nestle Purina PetCare Company as the owner and operator of the installation.

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APPENDIX A Abbreviations and Acronyms

% .............. percent

~F .............. degrees Fahrenheit

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

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

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

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

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

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

CEMS ...... Continuous Emission Monitor System

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

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

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

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

COMS ...... Continuous Opacity Monitoring System

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

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

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

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

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

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

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

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

GACT ...... Generally Available Control Technology

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

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

gr .............. grams

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

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

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

hp ............. horsepower

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

lbs/hr ........ pounds per hour

MACT ...... Maximum Achievable Control Technology

/ 3 • b. t µg m ........ micrograms per cu 1c me er

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

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

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

MHDR. ..... maximum hourly design rate

MMBtu .... Million British thermal units

MMCF ..... million cubic feet

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

NAAQS .... National Ambient Air Quality Standards

NESHAPs National Emissions Standards for Hazardous Air Pollutants

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

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

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

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

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

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

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

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

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

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

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

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

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

SDS ........... Safety Data Sheet

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

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

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

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

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

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

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

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

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