royal oak enterprise-west plains briquetting fileroyal oak enterprises, llc -west plains briquet...

Michael L. Parson, Governor

0 7 Mr. Paul McAllister Royal Oak Enterprises, LLC - West Plains Briquet Plant P.O. Box 850 West Plains, MO 65775

Carol S. Comer, Director

Re: Royal Oak Enterprises, LLC - West Plains Briquet Plant, 091-0037 Permit Number: OP2018-096

Dear Mr. McAllister,

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

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

You may appeal this permit to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.078.16 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within thirty (30) days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If you send your appeal by registered or certified mail, we will deem it filed on the date you mailed it. If you send your appeal by a method other than registered or certified mail, we will deem it filed on the date the AHC receives it.

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

Sincerely,

AIR POLLUTION§ C1

ONT .Q.-L PROGRAM

p?JiJJ j;_ --- ·:W Michael J. Stansfield, P .E. Operating Permit Unit Chief

MJS:nwj

Enclosures

c: PAMS File: 2015-09-012 Recyded paper

MISSOURI DEPARTMENT OF NATURAL RESOURCES

INTERMEDIATE STATE PERMIT TO OPERATE

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

Intermediate Operating Permit Number: OP2018-096 Expiration Date: NOV O 7

Installation ID: 091-0037 Project Number: 2015-09-012

Installation Name and Address Royal Oak Enterprises, LLC - West Plains Briquet Plant

Parent Company's Name and Address Royal Oak Enterprises, LLC

6425 Highway ZZ West Plains, MO 65775 Howell County

Installation Description:

1 Royal Oak Ave Roswell, GA 30076

Royal Oak Enterprises, LLC -West Plains Briquet Plant pulverizes and blends raw materials to form charcoal briquettes. Raw materials include coal fines, limestone, raw charcoal, sawdust, and starch. The installation does not include a charcoal kiln or any limestone crushing operations. The installation has the potential to exceed the Part 70 permitting threshold for particulate matter less than or equal to ten micron in diameter (PM10), but has accepted a voluntary limit to remain below that threshold. The installation is located in an attainment area for all criteria pollutants and is not a Named Installation. There are no NSPS or MACT regulations that apply to this installation.

0 7 Effective Date

Royal Oak Enterprises, LLC - West Plains Briquet Plant Installation ID: 091-003 7 Intermediate State Operating Permit

Table of Contents

2 Project No. 2015-09-012

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

EMISSION UNITS WITH LIMITATIONS ................................................................................................. 3 EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS ....................................................................... 4

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

PERMIT CONDITION PW00I .................................................................................................................... 5 10 CSR 10-6.020 and 10 CSR 10-6.065 Voluntary Limitation(s) ............................................................................................... 5

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ....................................................................... 6

PERMIT CONDITION 001 .......................................................................................................................... 6 IO CSR 10-6.060 Construction Permits Required ....................................................................................................................... 6 Construction Permit 022002-008, Issued February 14, 2002 ...................................................................................................... 6

PERMIT CONDITION 002 .......................................................................................................................... 7 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants .................................................................................... 7

PERMIT CONDITION 003 .......................................................................................................................... 9 10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds .............................................................................................. 9

PERMIT CONDITION 004 ........................................................................................................................ 10 10 CSR 10-6.020 and 10 CSR 10-6.065 Voluntary Limitation(s) ............................................................................................. 10

IV. CORE PERMIT REQUIREMENTS .................................................................................................... 12

V. GENERAL PERMIT REQUIREMENTS .............................................................................................. 17

VI. ATTACHMENTS .............................................................................................................................. 21

A1TACHMENTA .......................................................................................................................................... 22 Method 22 Visible Emissions Observations .............................................................................................................................. 22

ATTACHMENT B ... ....................................................................................................................................... 23 Method 9 Opacity Observations ................................................................................................................................................ 23

ATTACHMENT C .......................................................................................................................................... 25 Inspection/Maintenance/Repair/Malfunction Log ..................................................................................................................... 25

ATTACHMENT D .......................................................................................................................................... 26 Fugitive Emission Observations ............................................................................................................................................... 26

ATTACHMENT E .......................................................................................................................................... 27 Monthly Facility-Wide Emissions of PM10 ............................................................................................................................... 27

ATTACHMENT F .......................................................................................................................................... 32 Construction Permit 022002-008 ......................................................................................................................................... , .... 32 PMw Compliance Worksheet .................................................................................................................................................... 32


I. Installation Equipment Listing

EMISSION UNITS WITH LIMITATIONS

3 Project No. 2015-09-012

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

Emission Unit# EP-01 EP-02 EP-04 EP-09 EP-13 EP-16 EP-27 EP-28 EP-29 EP-31A EP-3 lB EP-33B EP-39 EP-56 EP-57 EP-58 EP-59 EP-60 EP-61 EP-62 EP-63 EP-64 EP-65 EP-66 EP-67 EP-71 EP-72 EP-73 EP-74 EP-75 EP-76 EP-78 EP-79 EP-80 EP-81 EP-82

Description of Emission Unit Charcoal Storage Pile Retort Char/Sawdust Storage Pile Charcoal Storage Pile Hammermill - Charcoal and Coal Load Hopper Hammermill - Sawdust Paddle Mixer Conveying Mixture (2) Press Briquet Dryer/Cooler Briquet Dryer (Sawdust) Combustion Emissions Conveying ( 1) Bagging Briquets Load Sawdust Hopper Screw Conveyor Sawdust Hammermill Screw Conveyor Hopper Loading Screw Conveyors (5) Charcoal Silo Loading Coal Silo Loading Retort Silo Loading Mesquite Silo Loading Lime Silo Pneumatic Loading Starch Silo Pneumatic Loading Mesquite Load Out Vibrator (2) Briquet Storage Bin Loading Load Out Vibrator Shaker Conveyor Conveyor Scale Load Out Vibrator Conveyor Scale Sawdust Storage Pile

Royal Oak Enterprises, LLC - West Plains Briquet Plant Installation ID: 091-0037 Intermediate State Operating Permit

EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS

4 Project No. 2015-09-012

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

Emission Unit # EP-03 EP-05 EP-06 EP-07 EP-08 EP-26 EP-32 EP-33A EP-37 EP-38 EP-50 EP-51 EP-52 EP-53 EP-54 EP-68 EP-69 EP-70 EP-77 EP-83

Description of Emission Unit Mesquite Storage Pile Lime Storage Pile Load Hopper - Charcoal and Coal Hopper Loadout - Charcoal and Coal Conveying Charcoal and Coal Borax & Sodium Nitrate Hoppers Fines Screening & Conveying Conveying (2) Instant Light Dip Tank Dip Tank Loadout Lighter Fluid Bottling Solvent Storage Tanks Diesel Storage Tank Space Heating Starch Boiler Shaker Conveying (3) Fines Storage Pile Conveyor Wax Boiler


II. Plant Wide Emission Limitations

5 Project No. 2015-09-012

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 on the date of permit issuance. 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 10-6.020 and 10 CSR 10-6.065 Voluntary Limitation(s)

Emission Limitation: The permittee shall emit less than 100.0 tons per year of non-fugitive particulate matter less than ten microns (PM10) from the entire installation in any consecutive 12-month period.

Monitoring/Recordkeeping: 1) The permittee shall record the PM10 emissions on a monthly and consecutive 12-month basis. 2) The permittee shall use Attachment E, or similar recordkeeping, to demonstrate compliance with this

permit condition. 3) The permittee shall keep these records for five (5) years and made available for inspection by the

Department of Natural Resources' personnel upon request.

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

P.O. Box 176, Jefferson City, MO 65102, or · ................................................. ~ .................. ~ .. _,.................. no later than ten days after the records indicate an exceedance of the emission limitation.

2) The permittee shall report any deviations from the requirements of this permit condition in the annual compliance certification required by Section V of this permit. [§70.6(a)(3)(iii)]


III. Emission Unit Specific Emission Limitations

6 Project No. 2015-09-012

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 on the date of permit issuance.

PERMIT CONDITION 001 10 CSR 10-6.060 Construction Permits Required

Construction Permit 022002-008, Issued February 14, 2002 Emission Unit Description

EP-56 Load Sawdust Hopper EP-57 Screw Conveyor EP-58 Sawdust Hammermill EP-59 Screw Conveyor EP-60 Hopper Loading EP-61 Screw Conveyors (5) EP-82 Sawdust Storage Pile

Emission Limitation: The permittee shall not discharge into the atmosphere PM10 in excess of 15 tons in any consecutive 12-month period from the above emission points. [Special Condition 1.A.]

Monitoring/Recordkeeping: 1) The permittee shall record the PM10 emissions on a monthly and consecutive 12-month basis. 2) The permittee shall use Attachment F, or similar recordkeeping, to demonstrate compliance with the

15 tons PM 10 emission limitation. [Special Condition 1.B.] 3) These records shall be kept for five (5) years and made available for inspection by the Department of

Natural Resources' personnel upon request. [Special Condition 1.B.]

Reporting: 1) The permittee shall report to the Air Pollution Control Program's Enforcement Section, P.O. Box

176, Jefferson City, MO 65102, no later than ten (10) days after the end of the month during which records indicate that the sources has exceeded the 15 ton emission limitation. [Special Condition 1.C.]



PERMIT CONDITION 002

7 Project No. 2015-09-012

10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants Emission Unit Description Stack No.

EP-01 Charcoal Storage Pile EP-02 Retort/Char/Sawdust Storage Pile Enclosure EP-04 Charcoal Storage Pile EP-13 Load Hopper EP-56 Load Sawdust Hopper EP-57 Screw Conveyor EP-58 Sawdust Hammermill Partial Enclosure EP-59 Screw Conveyor EP-60 Hopper Loading EP-61 Screw Conveyors (5)

EP-31A Briquet Dryer/Cooler EP-31 EP-31B Briquet Dryer (Sawdust) Combustion Emissions EP-09 Hammermill - Charcoal and Coal EP-16 Hammermill - Sawdust EP-62 Charcoal Silo Loading EP-63 Coal Silo Loading S-1 EP-64 Retort Silo Loading EP-65 Mesquite Silo Loading EP-71 Mesquite Load Out Vibrator (2)

EP-33B Conveying (1) EP-39 Bagging Briquets EP-72 Briquet Storage Bin Loading EP-73 Load Out Vibrator EP-74 Shaker EP-75 Conveyor S-2 EP-76 Conveyor EP-78 Scale EP-79 Load Out Vibrator EP-80 Conveyor EP-81 Scale EP-66 Lime Silo Pneumatic Loading S-3 EP-67 Starch Silo Pneumatic Loading S-4

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 60 percent for one continuous six-minute period in any 60 minutes. [10 CSR 10-6.220(3)(A)2]

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


Monitoring: 1) Monitoring schedule:

8 Project No. 2015-09-012

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

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

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

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

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

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

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

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

Attachments A and B 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 permittee shall report to the Air Pollution Control Program's Compliance/Enforcement Section,

P.O. Box 176, Jefferson City, MO 65102, or · ,.'. .. · ... , .. ,, .. ,=,.,.,.,,,.,..0,..,.,.,,.0, , no later than ten days after the records indicate an exceedance of the emission limitation.




9 Project No. 2015-09-012

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds 1

Emission Unit Description Briquet Dryer Combustion Emissions Fuel Type: Sawdust

EP-31B 5 units each rated at 5 MMBtu/hr Total Heat Capacity: 25 MMBtu/hr Construction year: 2001

Emission Limitation: 1) The permittee shall not cause or permit the emission into the atmosphere gases containing more than

five hundred parts per million by volume (500 ppmv) of sulfur dioxide. [6.260(3)(A)l.] 2) The permittee shall not emit stack gasses containing more than thirty-five milligrams per cubic meter

(3 5 mg) of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three hour time period. [6.260(3)(A)l.]

Monitoring/Recordkeeping: None, See Statement of Basis.

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

any malfunction which could cause an exceedance of any of the terms imposed by this permit condition, no later than ten days after the exceedance or event causing the exceedance. The permittee shall submit these reports to EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219.


1This regulation was rescinded by the State of Missouri on November 30, 2015. The regulation appears in this operating permit as it is contained in Missouri's SIP and is a federal only requirement. This permit condition will no longer be applicable when EPA takes final action to incorporate 10 CSR 10-6.261 in Missouri's SIP in place of 10 CSR 10-6.260. No action is required on the part of the permittee to remove this permit condition from this operating permit upon the removal of 10 CSR 10-6.260 from the Missouri SIP.



10 Project No. 2015-09-012

10 CSR 10-6.020 and 10 CSR 10-6.065 Voluntary Limitation(s) Emission Unit Description Stack No. Control Device No.

EP-09 Hammermill - Charcoal and Coal EP-16 Hammermill - Sawdust EP-62 Charcoal Silo Loading EP-63 Coal Silo Loading S-1 CD-03 Fabric Filter EP-64 Retort Silo Loading EP-65 Mesquite Silo Loading EP-71 Mesquite Load Out Vibrator

EP-33B Conveying ( 1) EP-39 Bagging Briquets EP-72 Briquet Storage Bin Loading EP-73 Load Out Vibrator EP-74 Shaker EP-75 Conveyor S-2 CD-06 Fabric Filter EP-76 Conveyor EP-78 Scale EP-79 Load Out Vibrator EP-80 Conveyor EP-81 Scale EP-27 Paddle Mixer

Wet Suppression EP-28 Conveying Mixture (2) -EP-29 Press

System

Operational Limitation: 1) The permittee shall capture and control particulate emissions from the above emission points using

fabric filters and wet suppression with a control efficiency of at least 90%. 2) The permittee shall operate and maintain the fabric filters and wet suppression in accordance with

the manufacturer's specifications. 3) The permittee shall keep replacement filters 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).

4) The permittee shall equip the filters with a gauge or meter, which indicates the pressure drop across the control device. The gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them. The pressure drop shall be maintained within the design conditions specified by the filter manufacturer's performance specifications.

5) The permittee shall operate a wet suppression system at all times when the associated emission units are in operation. The permittee shall maintain a moisture level that prevents any visible emissions.

6) The permittee shall operate a wet suppression system to restrict the emission of particulate matter from the mixing, conveying, and briquetting press (EP-27, EP-28, and EP-29) operations while the installation is operating. This wet suppression system shall be used whenever these units are in operation and the amount of water applied by this wet suppression system shall be in such quantities that no appreciable visible emissions occur from these sources.


Monitoring/Recordkeeping:

11 Project No. 2015-09-012

1) The permittee shall maintain a copy of the filter manufacturer's specification onsite. 2) The pressure drop shall be measured and recorded at least once every 24 hours while operations are

occurnng. 3) The permittee shall maintain an operating and maintenance log (using Attachment C or equivalent)

for the fabric filters and wet suppression system which shall include the following: a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and

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

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

5) The permittee shall monitor and record on a daily basis the moisture of the material produced by the briquetting press (EP-29), which is a representative moisture level of the mixing, conveying, and briquetting press operations (EP-27, EP-28, and EP-29). The moisture of this material shall be measured using a moisture analyzer and adjusted as required to ensure control of emissions from these sources during normal operation.

Reporting: The permittee shall report any deviations from the requirements of this permit condition in the annual compliance certification required by Section V of this permit. [§70.6(a)(3)(iii)]


IV. Core Permit Requirements

12 Project No.2015-09-012

The installation shall comply with each of the following requirements. Consult the appropriate sections in the Code of Federal Regulations (CFR), 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 on the date of permit issuance. The following are only excerpts from the regulation or code, and are provided for summary purposes only.

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

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

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

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

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

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

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

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

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

3) Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under section 643.140, RSMo, the permittee may provide information showing that the excess emissions were the consequence of a malfunction, start-up or shutdown. The information, at a minimum, should be the paragraph 1 list and shall be submitted not later than 15 days after receipt of the notice of excess emissions. Based upon information submitted by the permittee or any other pertinent information available, the director or the commission shall make a determination whether the excess emissions constitute a malfunction, start-up or shutdown and whether the nature, extent and duration of the excess emissions warrant enforcement action under section 643 .080 or 643 .151, RSMo.


13 Project No. 2015-09-012

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

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

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

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

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

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

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

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

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

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

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


I 10 CSR 10-6.165 Restriction of Emission of Odors

This is a State Only permit requirement.

14 Project No. 2015-09-012

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

10 CSR 10-6.170 Restriction of Particulate Matter to the Ambient Air Beyond 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.


Recordkeeping:

15 Project No. 2015-09-012

The permittee shall document all readings on Attachment D, 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 to CSR 10-6.180 Measurement of Emissions of Air Contaminants 1) The director may require any person responsible for the source of emission of air contaminants to

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

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

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

I to 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.


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

16 Project No. 2015-09-012

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

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

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

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

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

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

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

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

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

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

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

f) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records 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.

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 CF'R Part 82.

Royal Oak Enterprises, LLC - West Plains Briquet Plant Installation lD: 091-003 7 Intermediate State Operating Permit

V. General Permit Requirements

17 Project No. 2015-09-012

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.

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

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

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

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

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

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

Enforcement Section, P. 0. Box 176, Jefferson City, MO 65102 or [email protected].

b) The permittee shall submit a report of all required monitoring by: i) April 1st for monitoring which covers the January through December time period. ii) Exception. Monitoring requirements which require reporting more frequently than annually

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

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

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

paragraph (6)(C)7 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

Royal Oak Enterprises, LLC - West Plains Briquet Plant 18 Project No. 2015-09-012 Installation ID: 091-003 7 Intermediate State Operating Permit

must contain a description of the emergency, the steps taken to mitigate emissions, and the corrective actions taken.

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

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

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

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

I 10 CSR 10-6.065 §(S)(C)l and §(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.

I 10 CSR 10-6.065(5)(C)l.A General Requirements 1) The permittee must comply with all of the terms and conditions of this permit. Any noncompliance

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

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

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

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

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

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

I 10 CSR 10-6.065(5)(C)l.C Reasonably Anticipated Operating Scenarios None.


19 Project No. 2015-09-012

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

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

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

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

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

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

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

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

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

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

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

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

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

compliance status of this installation.

I 10 CSR 10-6.065, §(5)(C)l and §(6)(C)7 Emergency Provisions 1) An emergency or upset as defined in 10 CSR 10-6.065(6)(C)7.A shall constitute an affirmative

defense to an enforcement action brought for noncompliance with technology-based emissions limitations. To establish an emergency- or upset-based defense, the permittee must demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, the following:


20 Project No. 2015-09-012

a) That an emergency or upset occurred and that the permittee can identify the source of the emergency or upset,

b) That the installation was being operated properly, c) That the permittee took all reasonable steps to minimize emissions that exceeded technology

based emissions limitations or requirements in this permit, and d) That the permittee submitted notice of the emergency to the Air Pollution Control Program

within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective actions taken.

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

[ 10 CSR 10-6.065(5)(C)S Off-Permit Changes 1) Except as noted below, the permittee may make any change in its permitted installation's operations,

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

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

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

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

[ 10 CSR 10-6.020(2)(R)34 Responsible Official The application utilized in the preparation of this permit was signed by Paul McAllister, Area Vice President. On August 24, 2018, the Air Pollution Control Program was informed that Evan Bryant, Area Director is now the responsible official. 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.


21 Project No. 2015-09-012

I 10 CSR 10-6.065 §(5)(E)4 and §(6)(E)6.A(IIl)(a)-(c) Reopening-Permit for Cause This permit may be reopened for cause if: 1) The Missouri Department of Natural Resources (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,

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

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

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

applicable requirements.

I 10 CSR 10-6.065 §(5)(E)l.A and §(6)(E)l.C Statement of Basis This permit is accompanied by a statement setting forth the legal and factual basis for the permit conditions (including references to applicable statutory or regulatory provisions). This Statement of Basis, while referenced by the permit, is not an actual part of the permit.

VI. Attachments

Attachments follow.


Attachment A

Method 22 Visible Emissions Observations

Installation Name Observer Name

Location Date

Sky Conditions Wind Direction

Precipitation Wind Speed

Time Emission unit

22 Project No. 2015-09-012

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


Attachment B

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.%

23 Project No. 2015-09-012

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

Start of End of observations observations

Steam Plume ( check if applicable) Comments

Opacity Readings(% Opacitv)4 Opacity2 Opacity3 Attached Detached 0 1 2 3 4 5 6 7 8 9 10 11 12

NIA NIA NIA NIA NIA

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

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30


24 Project No. 2015-09-012

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 C Inspection/Maintenance/Repair/Malfunction Log

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

Inspection/ Malfunction Activities Date/Time

Maintenance Activities Malfunction Impact Duration Cause

25 Project No. 2015-09-012

Action Initials


Attachment D Fugitive Emission Observations

26 Project No. 2015-09-012

Visible If There Are Visible Emissions Beyond the Property Boundary

Emissions Date Time Beyond

Boundary Cause Corrective Action Initial

No Yes


Attachment E Monthly Facility-Wide Emissions of PM10

MONTH: ------------

Emission Unit Monthly Throughput Emission Factor

(tons) (lb/ton)5

TOT AL PM10 Emissions for the month: Monthly PM10 Emissions=

27 Project No. 2015-09-012

PM10 Emissions (tons)

[Monthly Throughput (tons)] x [Emission Praetor (lb/ton)] x [(l 00 - Control Efficiency)/ 100] --;[2000 (lb/ton)]

Emissions from startup, shutdown, and malfunctions shall be included in TOT AL PM10 Emissions for the month. 5Emission Factors are defined for each emission unit on starting on page 29


Attachment E ( continued) Monthly Facility-Wide Emissions of PM10

Rolling 12-month PM10 Emissions

28 Project No. 2015-09-012

In order to demonstrate compliance with Permit Condition PW00J, the 12-month Rolling Average Emissions of P M1 o must be less than 100 tons.

Month PM10 Emissions (tons) 12-month Rolling6 Total

Emissions of PM10

January

February

March

April

May

June

July

August

September

October

November

December

6The 12-month Rolling Total column value is the sum of the previous 12 monthly P M10 Emissions Column values.


Emission Point#

EP-01

EP-02

EP-04

EP-06

EP-07

EP-08

EP-09

EP-13

EP-16

EP-26

EP-27

EP-28

EP-29

EP-31A

EP-31B

EP-32

EP-33A

Attachment E ( continued) Monthly Facility-Wide Emissions of PM10

Emission Point sec PM10 Emission

Description Code Emission Factor

Factor Units

Coal Storage Pile - 0.0074 lb/ton

Retort Char/Sawdust 0.0591 lb/ton

Storage Pile -

Charcoal Storage Pile - 0.0591 lb/ton

Load Hopper -0.36 lb/ton

Charcoal and Coal -

Hopper Loadout -30501607 0.18 lb/ton

Charcoal and Coal Conveying-

30501607 0.18 lb/ton Charcoal and Coal

Hammermill -0.26 lb/ton

Charcoal and Coal -

Load Hopper - 0.36 lb/ton

Hammermill 0.26 lb/ton

Sawdust -

Borax & Sodium 0.36 lb/ton

Nitrate Hopper -

Paddle Mixer - 0.156 lb/ton

Conveying Mixture 30501607 0.18 lb/ton

(2) Press 30501602 0.62 lb/ton

Briquet Dryer/Cooler - 0.143 lb/ton

Briquet Dryer (Sawdust)

0.377 lb/MMBtu Combustion

-

Emissions Fines Screening &

0.1 lb/ton Conveying

-

Conveying (2) - 0.1 lb/ton

29 Project No. 2015-09-012

Emission Factor Control

Source Efficiency

(%) AP-42 Chapter

3.75 13.2.4

AP-42 Chapter 3.75

13.2.4 AP-42 Chapter

3.75 13.2.4

MoDNR Letter 3.75

Dated 12/12/1995

WebFIRE 3.75

WebFIRE 3.75

MoDNR Letter 90

Dated 12/12/1995 MoDNR Letter

-Dated 12/12/1995

MoDNR Letter 90


3.75 Dated 12/12/1 99 5

AP-42 Table 90

11.12-2

WebFIRE 90

WebFIRE 90 Particulate

Emissions Testing for a Briquette Dryer in Meta, -

Missouri Test Dated

December 1995

AP-42 Table 1.6-1 -

MoDNR Letter 3.75


3.75 Dated 12/12/1995


Emission Emission Point sec PM10 Emission

Point# Description Code Emission Factor

Factor Units

EP-33B Conveying (1) - 0.1 lb/ton

EP-38 Dip Tank Loadout - 0.1 lb/ton

EP-39 Bagging Briquets 30100508 0.06 lb/ton EP-53 Space Heaters 10100602 0.00745 lb/MMBtu EP-54 Starch Boiler 10100602 0.00745 lb/MMBtu

EP-56 Load Sawdust

0.36 lb/ton -Hopper

EP-57 Screw Conveyor - 0.36 lb/ton

EP-58 Sawdust Hammermill - 0.26 lb/ton

EP-59 Screw Conveyor - 0.36 lb/ton

EP-60 Hopper Loading - 0.36 lb/ton

EP-61 Screw Conveyors (5) - 0.36 lb/ton

EP-62 Charcoal Silo

0.14 lb/ton Loading

-

EP-63 Coal Silo Loading - 0.14 lb/ton

EP-64 Retort Silo Loading - 0.14 lb/ton

EP-65 Mesquite Silo

0.36 lb/ton Loading

-

EP-66 Lime Silo Pneumatic

30501607 0.18 lb/ton Loading

EP-67 Starch Silo

30501607 0.18 lb/ton Pneumatic Loading

EP-68 Shaker - 0.08 lb/ton

EP-69 Conveying (3) - 0.1 lb/ton

EP-71 Mesquite Load Out

0.1 lb/ton Vibrator (2)

-

EP-72 Briquet Storage Bin

0.1 lb/ton Loading

-

EP-73 Load Out Vibrator - 0.1 lb/ton

EP-74 Shaker - 0.1 lb/ton

30 Project No. 2015-09-012


Source Efficiency

(%) MoDNR Letter

90 Dated 12/12/1995

MoDNR Letter 90

Dated 12/12/1995 WebFIRE 90

AP-42 Table 1.4-2 -AP-42 Table 1.4-2 -

MoDNR Letter 1.875


1.875 Dated 12/12/1995

MoDNR Letter 1.875


1.875 Dated 12/12/1995

MoDNR Letter 1.875


1.875 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995

WebFIRE -

WebFIRE -

MoDNR Letter 3.75


3.75 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995


Emission Emission Point sec PM10 Emission

Point# Description Code Emission Factor

Factor Units

EP-75 Conveyor - 0.1 lb/ton



EP-78 Scale - 0.1 lb/ton

EP-79 Load Out Vibrator - 0.1 lb/ton


EP-81 Scale - 0.1 lb/ton

EP-83 Wax Boiler 10100602 0.00745 lb/MMBtu

31 Project No. 2015-09-012


Source Efficiency

(%) MoDNR Letter

90 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995

MoDNR Letter 90


90 Dated 12/12/1995 AP-42 Table 1.4-2 -


Attachment F Construction Permit 022002-008

PM10 Compliance Worksheet

32 Project No. 2015-09-012

This sheet covers the period from ____________ to ------------~ (month, year) (month, year)

Column! Column 2 Column 3 Column 4 Amount of

Composite PM10 Monthly PM10 12-Month PM10 Month Sawdust

Transferred 1 Emission Factor2 Emissions3 Emissions4

(tons) (lb/ton) (tons) (ton/yr)

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

2.04

1 Amount of Sawdust transferred during this month only. 2The composite PM10 emission factor was calculated by taking each unit's potential emissions (lb/hr) and dividing by the bottlenecked maximum hourly design rate. 3Column 3 = Column I x Column 2 x 0.0005 (ton/lb)+ emissions from startup, shutdown, and malfunctions. 4Column 4 = The sum of the last 12-month within Column 3. 12-Month PM10 emissions of less than 15 tons indicates compliance.


STATEMENT OF BASIS Voluntary Limitations

SB - 1 Project No. 2015-09-012

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

INSTALLATION DESCRIPTION Royal Oak Enterprises, LLC -West Plains Briquet Plant pulverizes and blends raw materials to form charcoal briquettes. Raw materials include coal fines, limestone, raw charcoal, sawdust, and starch. The installation does not include a charcoal kiln or any limestone crushing operations. The installation has the potential to exceed the Part 70 permitting threshold for particulate matter less than or equal to ten micron in diameter (PM10), but has accepted a voluntary limit to remain below that threshold. The installation is located in an attainment area for all criteria pollutants and is not a Named Installation. There are no NSPS or MACT regulations that apply to this installation.

Updated Potential to Emit for the Installation and Reported Air Pollutant Emissions, in tons per year Each emission unit was evaluated at 8,760 hours of annual operation. PM10 emission factors for the individual steps of the briquetting process originated from a MoDNR Letter dated December 12, 1995 which states which emission factors should be used for different processes. The briquet dryer combustion emissions (EP-31B) emission factors were taken from AP-42 Chapter 1.6. For natural gas combustion, the space heaters (EP-53), starch boiler (EP-54), and wax boiler (EP-83) emission factors were taken from AP-42 Chapter 1.4. The installation has the potential to emit PM2.s above the major source level. However, the PM10 limitation directly limits the PM2.s potential to less than major source levels because PM2.s is a subset of PMrn, and the amount emitted will always be less than PMrn.

Pollutants Potential Reported Emissions

Emissions 2017 2016 2015 2014 2013 Particulate Matter

< 100.0 56.73 51.15 51.15 51.15 51.57 < Ten Microns (PM10)

Particulate Matter < 100.0 30.88 28.04 28.04 28.04 23.55 :S 2.5 Microns (PM2s)

Sulfur Oxides 2.77 1.19 1.05 1.05 1.05 1.07

(SOx) Nitrogen Oxides

58.28 23.36 20.66 20.66 20.66 20.98 (NOx)

Volatile Organic 15.52 2.59 2.09 2.09 2.09 2.20

Compounds (VOC) Carbon Monoxide

69.58 28.61 25.30 25.30 25.30 25.69 (CO)


SB -2 Project No. 2015-09-012

Pollutants Potential Reported Emissions

Emissions 2017 2016 2015 2014 2013 Hazardous Air Pollutants

2.30 0.96 0.85 0.85 0.85 0.86 (HAPs)

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

1) Intermediate Operating Permit Application, received September 3, 2015; 2) Intermediate Operating Permit Number OP2011-008, issued March 2, 2011; 3) 2014 Emissions Inventory Questionnaire, received April 14, 2015; 4) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition. 5) WebFIRE; and 6) All documents listed under Construction Permit History section.

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

None

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

10 CSR 10-3.060, Maximum Allowable Emissions of Particulate Matter From Fuel Burning Equipment Usedfor Indirect Heating This rule is not applicable as it was rescinded October 30, 2011.

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

10 CSR 10-6.250, Asbestos Projects - Certification, Accreditation and Business Exemption Requirements This rule is not applicable because the installation does not perform the regulated activities

10 CSR 10-6.261, Control of Sulfur Dioxide Emissions This rule establishes requirements for emission units emitting sulfur dioxide. The Briquet Dryer (Sawdust) Combustion Emissions (EP-31B) is exempt from this rule per (l)(C)2. as the emission unit is subject to a more restrictive SO2 emission limit. 10 CSR 10-6.260 restricts sulfur emissions to 500 ppm. The Space Heating (EP-53), Starch Boiler (EP-54), and Wax Boiler (EP-83) are fueled with natural gas and therefore are exempt from this rule per (l)(A).


10 CSR 10-6.330, Restriction of Emissions from Batch-type Charcoal Kilns

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This regulation applies to all batch type charcoal kilns. This installation uses a belt conveyor oven to dry the briquettes, and does not operate any batch type kilns. Therefore, this rule does not apply.

10 CSR 10-6.405, Restriction of Particulate Matter Emissions From Fuel Burning Equipment Used For Indirect Heating The Space Heating (EP-53), Starch Boiler (EP-54), and Wax Boiler (EP-83) are exempt from this rule because all applicable units located at this installation are fueled with natural gas. The emission units meet exemption (l)(E). The Briquet Dryer (EP-31B) is considered a direct heating unit and is not subject to this rule.

Construction Permit History The following construction permits were issued to this installation:

Construction Permit 0184-018, Issued November 23, 1983: • This construction permit is for the initial installation of the charcoal briquette plant. • This construction permit contains no special conditions.

Construction Permit 082001-010, Issued July 19, 2001: • This construction permit is for the replacement of the 18. 6 MMBtu/hr natural gas burners with ( 4) 5

MMBtu/hr Webb sawdust burners (EP-31) and the installation of (4) 12 tons/hr pneumatic transfer units.

• A 200-ton capacity storage silo (EP-55) was permitted but never installed. • This construction permit contains no special conditions.

Construction Permit 022002-008, Issued February 14, 2002: • This construction permit is for the installation of a 10 tons/hr hopper (EP-56), a 10 tons/hr screw

conveyor (EP-57), a 10 tons/hr lump breaker (EP-58), a 1.25 tons/hr screw conveyor (EP-59), a 1.25 tons/hr hopper (EP-60), and a 1.25 tons/hr screw conveyors (4) (EP-61).

• Special Condition 1 limits the emissions from EP-55. EP-56, EP-57, EP-58, EP-59, EP-60, and EP-61 to 15 tons/yr; however, the installation never installed EP-55. Instead of a silo, the facility constructed a sawdust storage pile (EP-82). Because EP-82 took the place of EP-55, the limit was applied to EP-56, EP-57, EP-58, EP-59, EP-60, EP-61, and EP-82 and found in this permit in Permit Condition 001.

Construction Permit 062002-006, Issued June 11, 2002: • This construction permit is for the installation of an additional 5 MMBtu/hr burner to EP-31. EP-31

now has (5) 5 MMBtu/hr for an overall MHDR of 25 MMBtu/hr. The additional burner increased the bottlenecked MHDRs of EP-55, EP-59, EP-60, and EP-61 to 1.5625 tons/hr.

• This construction permit contains no special conditions. Since Construction Permit 022002-008 was not superseded, the 15 ton/yr limit on EP-56, EP-57, EP-58, EP-59, EP-60, EP-61, and EP-82 is still applicable despite the increased capacity of EP-55, EP-59, EP-60, and EP-61.


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New Source Performance Standards (NSPS) Applicability 40 CFR Part 60, Subpart De Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units This subpart applies to steam generating units which construction, modification, or reconstruction commenced after June 9, 1989 and that has a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. The regulation is not applicable to the Space Heating (EP-53), Starch Boiler (EP-54), and Wax Boiler (EP-83) as they have capacities below 10 MMBtu/hr. The Briquet Dryer (EP-3 lB) is considered a process heater and does not meet the definition of steam generating unit in this subpart.

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 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 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 After July 23, 1984

These regulations apply to storage vessels with the following parameters: Rule Constructed/modified/reconstructed .... With contents and capacities ..... K Between June 11, 1973 and May 19, 1978 Petroleum liquids, >40,000 gallons Ka Between May 18, 1978 and July 23, 1984 Petroleum liquids, >40,000 gallons Kb After July 23, 1984 Volatile organic liquids, >19,813

gallons

The solvent storage tank (EP-51) does exceed 75 m3 (19,813 gallons), but as the solvent has a maximum true vapor pressure below 15.0 kPa, the tank is exempt from the regulation per §60.11 0b(b ). The diesel fuel tank (EP-52) is below the 75 m3 capacity threshold of §60.11 0b(a).

40 CFR Part 60, Subpart Y Standards of Performance for Coal Preparation Plants This subpart applies to facilities in coal preparation and processing plants that process more than 200 tons of coal per day per §60.250(a). This facility processes up to 28.8 tons of coal per day, and therefore this rule does not apply.

Maximum Achievable Control Technology (MACT) Applicability 40 CFR Part 63, Subpart JJJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Industrial Boiler Area Sources This subpart applies to any industrial, commercial, or institutional boiler that is located at an area source. The regulation does not apply to the Briquet Dryer (EP-3 lB) as the emission unit is considered a process heater and process heaters are excluded from the definition of a boiler in this subpart. The Space Heating (EP-53), Starch Boiler (EP-54), and Wax Boiler (EP-83) meet the definition of gas-fired boilers and are not subject to this subpart per §63.11195(e).


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

Greenhouse Gas Emissions Note that this source may be subject to the Greenhouse Gas Reporting Rule. In addition, Missouri regulations do not require the installation to report CO2 emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2 emissions were not included within this permit. If required to report, the applicant is required to report the data directly to EPA. The public may obtain CO2 emissions data by visiting http://epa.gov/ghgreporting/ghgdata/reportingdatasets.html.

Other Regulatory Determinations 10 CSR 10-6.065 Voluntary Limitation(s) Permit Condition 004 contains a condition requiring the permittee to control emissions from the mixing (EP-27), conveying (EP-28), and briquetting press (EP-29) processes using a wet suppression system. This wet suppression system consists of manual water addition, as well as steam from the Briquet Dryer (EP-31) that wets the raw briquet material to a moisture content of about 30%. This wet briquet material has a cake-like consistency, and minimal particulate emissions are expected at this point in the process.

10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants The space heaters (EP-53), starch boiler (EP-54), and wax boiler (EP-83) are all fueled with natural gas and meet exemption (l)(L). The rule applies to many emission points at this facility and the rule is applied in Permit Condition 002 in this permit.

10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds The Space Heating (EP-53), Starch Boiler (EP-54), and Wax Boiler (EP-83) are fueled with natural gas and are not subject to this rule per (1 )(A)2. The Briquet Dryer (Sawdust) Combustion Emissions (EP-31 B) will always be in compliance with this rule because the emission rate of SO2 is below the allowable emission rate of 500 ppmv as demonstrated by the following calculations:

General Equation: ppmv SO2 = SO2 Emission Factor (lb/MMBtu) + F factor (wscf/MMBtu) + Conversion Factor (lb/scf) x Conversion Factor (ppmv/ppmw)

1) The SO2 emission factor for wood residue combustion= 0.025 lb/MMBtu (Source: US EPA document AP-42 Table 1.6-2)

2) This emission factor assumes that all of the sulfur in the fuel is converted to SO2 emissions.


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3) The F factor is the ratio of gas volume of products of combustion to the heat content of the fuel. For wood, the F factor is 9240 dscf/MMBtu. (Source: 40 CFR Part 60 Appendix A Method 19 Table 19-2)

4) Conversion factor for lb/scf to ppm is 1.660E-7 lb/scf per ppm. (Source: 40 CFR Part 60 Appendix A Method 19 Table 19-1)

5) Conversion factor for ppm weight to ppmv = 28.8/MW = 28.8/64 = 0.45. (Source: US EPA document AP-42 Appendix A)

Compliance Demonstration

( lb ) ( MMBtu) ( ft

3 ) ( ppmv)

ppmv S02 = 0.025 MM Btu 9240 ft3 l.667E-7lb 0.45 ppmw = 7.304 ppmv

< 500 ppmv

Since the uncontrolled potential to emit rate of 7.304 ppmv is below the allowable emission rate of 500 ppmv, the unit is in compliance.

10 CSR 10-6.400, Restriction of Emission of Particulate Matter from Industrial Processes This regulation does not apply to the installation. All emission units meet an exemption as detailed in the table below. The following emission units are exempt from this regulation based on paragraph (l)(B)6. as the units burn fuel for indirect heating; paragraph (1)(8)12. as the units emit less than 0.5 lb/hr of PM; or paragraph (l)(B)l6. as the emission units' uncontrolled potential to emit is less than the allowable emission limit as calculated in paragraph (3)(A)l.

Process PM PM 10-6.400

EU Description Weight Emission Emission

Limit Is unit in compliance? Rate Factor Rate

(ton/hr) (lb/ton) (lb/hr) (lb/hr)

EP-01 Charcoal Storage Pile 10.0 0.0074 0.074 19.17 Exempt per (l)(B)l2.

EP-02 Retort Char/Sawdust

5.00 0.0591 0.295 12.05 Exempt per (1)(8)12. Storage Pile

EP-03 Mesquite Storage Pile 1.00 0.0594 0.059 4.10 Exempt per (l)(B)12. EP-04 Charcoal Storage Pile 10.0 0.0591 0.591 19.17 Exempt per (l)(B)l6. EP-05 Lime Storage Pile 1.50 0.0385 0.057 5.37 Exempt per (1)(8)12.

EP-06 Load Hopper -

14.5 0.36 5.22 24.59 Exempt per (1)(8)16. Charcoal and Coal

EP-07 Hopper Loadout -


EP-08 Conveying - Charcoal

14.5 0.18 2.61 24.59 Exempt per (1 )(8) 16. and Coal

EP-09 Hammermill -


EP-13 Load Hopper 5.00 0.36 1.80 12.05 Exempt per (1)(8)16.

EP-16 Hammermill -

5.00 0.20 1.00 12.05 Exempt per (1 )(8) I 6. Sawdust


Process PM PM


Rate Factor Rate (ton/hr) (lb/ton) (lb/hr)

EP-26 Borax & Sodium

0.34 0.18 0.061 Nitrate Hoppers

EP-27 Paddle Mixer 12.0 0.02 0.240

EP-28 Conveying Mixture

24.0 0.18 4.32 (2)

EP-29 Press 12.0 0.62 7.44

EP-32 Fines Screening &

0.25 0.10 0.025 Conveying

EP-33A Conveying (2) 24.0 0.10 2.40 EP-33B Conveying ( 1) 12.0 0.10 1.20 EP-38 Dip Tank Loadout 7.70 0.10 0.77 EP-39 Bagging Briquets 23.0 0.06 1.38

EP-53 Space Heaters 4.01 0.0075

0.03 (lb/MMBtu)

EP-54 Starch Boiler 2.25 0.0075

0.02 (lb/MMBtu)

EP-56 Load Sawdust Hopper 10.0 0.36 3.60 EP-57 Screw Conveyor 10.0 0.36 3.60 EP-58 Sawdust Hammermill 10.0 0.20 2.00 EP-59 Screw Conveyor 1.56 0.36 0.56 EP-60 Hopper Loading 1.56 0.36 0.56 EP-61 Screw Conveyors (5) 1.56 0.36 0.56 EP-62 Charcoal Silo Loading 14.5 0.14 2.03 EP-63 Coal Silo Loading 14.5 0.14 2.03 EP-64 Retort Silo Loading 5.00 0.14 0.70

EP-65 Mesquite Silo

1.00 0.36 0.36 Loading

EP-66 Lime Silo Pneumatic

10.5 0.0003 0.003 Loading

EP-67 Starch Silo Pneumatic

9.00 0.0003 0.003 Loading EP-68 Shaker 12.0 0.08 0.96 EP-69 Conveying (3) 36.0 0.10 3.60 EP-70 Fines Storage Pile 0.25 0.0267 0.007

EP-71 Mesquite Load Out

0.80 0.10 0.08 Vibrator (2)

EP-72 Briquet Storage Bin

12.0 0.10 1.20 Loading

EP-73 Load Out Vibrator 13.0 0.10 1.30 EP-74 Shaker 13.0 0.10 1.30 EP-75 Conveyor 13.0 0.10 1.30 EP-76 Conveyor 7.70 0.10 0.77 EP-77 Conveyor 7.70 0.10 0.77 EP-78 Scale 13.0 0.10 1.30 EP-79 Load Out Vibrator 10.0 0.10 1.00

10-6.400 Limit (lb/hr)

1.99

21.67

34.48

21.67

1.62

34.48 21.67 16.10 33.51

10.40

7.06

19.18 19.18 19.18 5.23 5.23 5.53

24.60 24.60 12.05

4.10

19.81

17.87

21.67 41.57

1.62

3.53

21.67

22.86 22.86 22.86 16.10 16.10 22.86 19.18

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Is unit in compliance?

Exempt per (1 )(B) 12.

Exempt per (l)(B)l2.




Exempt per (l)(B)l6. Exempt per (1 )(B) 16. Exempt per (1 )(B) 16. Exempt per (1 )(B)l6.

Exempt per (1 )(B)6.

Exempt per (1 )(B)6.

Exempt per (l)(B)l6. Exempt per (l)(B)l6. Exempt per (1 )(B) 16. Exempt per (1 )(B) 16. Exempt per (1)(B)16. Exempt per (1 )(B) 16. Exempt per (l)(B)l6. Exempt per (1 )(B) 16. Exempt per (1 )(B) 16.




Exempt per ( I )(B) 16. Exempt per (l)(B)l6. Exempt per (l)(B)l2.



Exempt per (1 )(B)l6. Exempt per (l)(B)l6. Exempt per (l)(B)l 6. Exempt per (l)(B)l6. Exempt per (l)(B)l6. Exempt per (l)(B)l6. Exempt per (l)(B)l6.


Process PM PM


Rate Factor Rate (ton/hr) (lb/ton) (lb/hr)

EP-80 Conveyor 10.0 0.10 1.00 EP-81 Scale 10.0 0.10 1.00 EP-82 Sawdust Storage Pile 10.0 0.0595 0.60

EP-83 Wax Boiler 4.50 0.0075

0.03 (lb/MMBtu)

10-6.400 Limit (lb/hr)

19.18 19.18 19.18

11.23

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Is unit in compliance?

Exempt per (l)(B)16. Exempt per (l)(B)16. Exempt per (l)(B)16.

Exempt per (l)(B)6.

In addition, the briquet dryer/cooler (EP-31A & EP-31B) is exempt from this rule as at the maximum hourly design rate, the dryer has an uncontrolled potential to emit less than the allowable emissions. The dryer capacity is 12 tons of briquets per hour plus 1.5625 tons of sawdust fuel per hour. The process weight for the dryer is then 13 .5625 tons per hour. Below are calculations that show that the briquette dryer's uncontrolled emissions are in compliance with this rule:

The allowable particulate matter emission rate for the dryer is: lb PM

4.1 X 13.56250.67 = 23.52 ~

The uncontrolled actual emission rate of the dryer: Process Emissions:

ton lb PM lb PM 12-x 0.143-- = 1.72--

hr ton hr

Sawdust Combustion Emissions: MMBtu lb PM lb PM

25-- X 0.377-- = 9.42-h-hr MMBtu r

lb PM Total= 11.14~

This uncontrolled rate is less than the allowable rate, therefore the emission units are exempt per (1 )(B) 16.

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

Should a later determination conclude that the installation is subject to one or more of the regulations cited in this Statement of Basis or other regulations which were not cited, the installation shall determine


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and demonstrate, to the Air Pollution Control Program's satisfaction, the installation's compliance with that regulation(s). If the installation is not in compliance with a regulation which was not previously cited, the installation shall submit to the APCP a schedule for achieving compliance for that regulation( s ).


Response to Public Comments

RPC- 1 Project No. 2015-09-012

A draft of the Intermediate Operating Permit for Royal Oak Enterprises, LLC - West Plains Briquet Plant was placed on public notice on September 7, 2018 by the Missouri Department of Natural Resources (MDNR). No public comments were submitted to the Air Pollution Control Program regarding this permit.