Simmons Feed Ingredients- Southwest City · Dryer #1 - Process Condenser, and CD12 #2 Packed Bed...

~[§j MISSOURI ~ 'I & I DEPARTMENT OF ~ ~ NATURALRESOURCES

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:

Parent Company:

052019-008A Project Number: 2019-06-052 Installation Number: 119-0017

Simmons Foods, Inc.

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

Installation Name:

Installation Address:

Location Information:

Simmons Feed Ingredients, Inc.

10700 South State Highway 43, Southwest City, MO 64863

McDonald County, S21, T21 N, R23W

Application for Authority to Construct was made for: The amendment of Permit Number 052019-008 which was a modification of the feather meal line to allow for the production of blood meal. This review was conducted in accordance with Section (5) of Missouri State Rule 1 O CSR 10-6.060 Construction Pennits Required.

'S Standard Conditions {on reverse) are applicable to this permit. D Standard Conditions {on reverse) and Special Conditions are applicable to

this permit.

Director or Designee Department of Natural Resources

JUN 2 8 2019 Effective Date

STANDARD CONDITIONS:

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

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

You must notify the Enforcement and Compliance Section of the Department's Air Pollution Control Program of the anticipated date of start up 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 Southwest Regional Office within 15 days after the actual start up of this (these) air contaminant source(s).

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

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

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

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

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

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

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

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Project No. 2019-06-052 Permit No. 052019-00BA

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(3)(E) "Conditions required by permitting authority."

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

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

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

Table 1: Installation-wide List of CO Emission Sources

CD03 (3) Dupps Spray Tower

(3) Dupps Continuous Condensers, EP01B CD04 Fiberglass Poultry Meal Line Cookers

Spray Tower, and CD05 #1 Packed Bed Scrubber

EP06 Boiler #2 EP07 Boiler #3 None EP0B Boiler #4 EP09 Boiler #5 Low NOx Burners Blood/Feather Meal

EP12 Blood/Feather Meal Line

D er #1 - Combustion Blood/Feather Meal

None EP13

D er #2 - Combustion

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

EU26 Haarslev Feather Meal Thermal Oxidizers Blood/Feather Meal

Pre-D er Line EU27 Thermal Oxidizer #1 Blood/Feather Meal

EU28 Thermal Oxidizer #2 Line and Poultry Meal Line

EU31 Erner enc Generator None N/A EU32 Erner enc Generator

EU33 Dehumidifiers/Roof Heaters Processing Plant

EU45 S ace Heaters

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

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SPECIAL CONDITIONS:


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

Table 2: Installation-wide List of PM10 Emission Sources

CD01 or CD02 Cyclones, CD04

Blood/Feather EP01A (2) Feather Hydrolyzers Fiberglass Spray Tower, Meal Line

and COOS #1 Packed Bed Scrubber CD03 (3) Dupps Spray

(3) Dupps Continuous Tower Condensers, EP01B CD04 Fiberglass Spray

Cookers Tower, and COOS #1 Packed Bed Scrubber

Poultry Meal Line CD09 #1 Venturi Scrubber, CD04

EP01C (6) Dupps Screw Presses Fiberglass Spray Tower, and COOS #1 Packed Bed Scrubber

EP06 Boiler #2 EP07 Boiler #3 None EP08 Boiler#4 -- -EP09 Boiler#S Low NOx Burners

CD06 Cyclone, CD11

Blood/Feather Meal Spray Tower

EP10 Dryer #1 - Process

Condenser, and CD12 #2 Packed Bed Scrubber CD07 Cyclone, CD11 Blood/Feather

Blood/Feather Meal Spray Tower Meal Line

EP11 Dryer #2 - Process

Condenser, and CD12 #2 Packed Bed Scrubber

EP12 Blood/Feather Meal D er #1 - Combustion Blood/Feather Meal

None EP13

D er #2 - Combustion EP14 Link Belt Screener Buildin

EP15 Blood/Feather Meal Enclosed Transfer Le

EP16 Feed Grade Meal

None Stora e Bins

CD11 Feather Spray

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

Scrubber

EP17B Feed Grade Meal Day Building Stora e Bin

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EP18 Feed Grade, High Ash, Low Ash, and Pet Food Grade Bucket Elevators None

1--------+--------------l High Ash, Low Ash, and Petfood Stora e Bins

EP19

EP20 Truck Loadout Building

Hanging Room Exhaust Vents N 1------+--------------i one

EP21

EP22

EU23

EU25

Blood/Feather Meal Silos

(2) Haarslev Continuous Cookers

Feed Bin, (3) Dupps Screw Presses, and Fat Centrifuge

EU26 Haarslev Feather Meal Pre-Dr er

EU27 Thermal Oxidizer #1

EU28 Thermal Oxidizer #2

EU27 Thermal Oxidizer #1 or EU28 Thermal Oxidizer #2 CD13 #2 Venturi Scrubber, CD04 Fiberglass Spray Tower, and COOS #1 Packed Bed Scrubber EU27 or EU28 Thermal Oxidizers

EU30 Lime Silo ~E-U-31---+------------l None

EU32 Erner enc Generator EU33 Dehumidifiers/Roof

Heaters EU35 Petfood Hammermill #1 CD18 Ba house

Poultry Meal Line

Blood/Feather Meal Line and Poult Meal Line

Processing Plant

Blood/Feather Meal Line

Poultry Meal Line

Blood/Feather Meal Line Blood/Feather Meal Line and Poult Meal Line

N/A

Processing Plant

EU36 Petfood Hammermill #2 CD19 Ba house Poultry Meal Line -----+-------------~--------< EU37 Feed Grade Hammermill CD20 Ba house EU41 Blood/Feather Meal Hammermill Building

EU45 S ace Heaters None

CT01 Coolin Tower #1 CT02 Coolin Tower #2 Drift eliminators CT03 Coolin Tower #3

Blood/Feather Meal Line Processin Plant Blood/Feather Meal Line Poultr Meal Line

Processing Plant

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

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CD03 (3) Dupps Spray Tower Condensers, (3) Dupps Continuous EP01B CD04 Fiberglass Poultry Meal Line Cookers Spray Tower, and COOS #1 Packed Bed Scrubber

EP06 Boiler#2 EP07 Boiler#3 None EP0B Boiler #4 EP09 Boiler #5 Low NOx Burners Blood/Feather Meal

EP12 Blood/Feather Meal Line

D er #1 - Combustion Blood/Feather Meal

None EP13

D er #2 - Combustion

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

EU26 Haarslev Feather Meal Thermal Oxidizers Blood/Feather Meal

Pre-0 er Line EU27 Thermal Oxidizer #1 Blood/Feather Meal

EU28 Thermal Oxidizer #2 Line and Poultry Meal Line

EU31 None N/A EU32 Erner enc Generator

EU33 Dehumidifiers/Roof Heaters Processing Plant

EU45 S ace Heaters

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

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

#5 using low NOx burners.

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

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

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SPECIAL CONDITIONS:



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

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

and replacements, etc.

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

Feather Hydrolyzers using CD01 or CD02 Cyclones.

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

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

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

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

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

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

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

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

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

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SPECIAL CONDITIONS:



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

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



4. Control Device Requirement- Condensers A. Simmons Feed Ingredients, Inc. shall control emissions from EP01 B (3)

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

B. Simmons Feed Ingredients, Inc. shall control emissions from the following emission sources/control devices using CD11 Spray Tower Condenser: 1) CD06 and CD07 Cyclones 2) EP01 D Blood Coagulator 3) EP01 E Blood Centrifuge 4) EP01F Raw Blood Screen 5) EP17A Poultry Meal Day Storage Bin 6) EP40 Coagulated Blood Flash Tank 7) EU42 Agitated Tank 8) EU43 Blood/Feather Meal Dryers Feed Bin

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

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

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

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

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



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SPECIAL CONDITIONS:



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

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

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

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

D. Simmons Feed Ingredients, Inc. shall equip each venturi scrubber with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

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

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

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

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



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

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

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SPECIAL CONDITIONS:



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

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



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

Fiberglass Spray Tower using COOS #1 Packed Bed Scrubber.

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

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

D. Simmons Feed Ingredients, Inc. shall equip each packed bed scrubber with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

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

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

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

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

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

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SPECIAL CONDITIONS:



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

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

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



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

Petfood Hammermill #1 using CD18 Bag house.

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

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

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

E. Simmons Feed Ingredients, Inc. shall equip each baghouse with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

F. Simmons Feed Ingredients, Inc. shall keep replacement filters for the bag houses on hand at all times. The bags shall be made of fibers appropriate for operating conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance).

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

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

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SPECIAL CONDITIONS:



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



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

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

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

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

D. The three-hour rolling average operating temperature of each thermal oxidizer shall be maintained at greater than or equal to 1327.73°F1 .

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

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



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

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

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

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SPECIAL CONDITIONS:

Project No. 2019-06-052 Permit No. 052019-008A


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

permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources' personnel upon request. These records shall include SOS for all materials used.

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

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

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

voe 0.146 0.188 0.188

B. Simmons Feed Ingredients, Inc. shall determine VOC emissions using EPA Test Methods 25A and 18 or other methods as approved by the Air Pollution Control Program's Stack Testing Unit.

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

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

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

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SPECIAL CONDITIONS:



F. A completed Proposed Test Plan Form shall be submitted to the Air Pollution Control Program at [email protected] 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. The proposed test plan shall clearly state which chemicals will be tested for using Method 18 and how the VOC emission rate will be determined using the results from Methods 25A and 18.

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

H. The test report is to fully account for all operational and emission parameters addressed both in the permit conditions as well as in any other applicable state or federal rules or regulations, specifically: 1) EP10/EP12 and EP11/EP13 Blood/Feather Meal Dryers combined

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

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

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

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

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

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

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

Condenser at the beginning and end of each performance test run

I. If the performance testing results indicate a higher VOC emission factor than listed in Table 4, Simmons Feed Ingredients, Inc. shall submit an application to amend this construction permit to the Department's Air Pollution Control Program's Permits Section no later than 90 days after Department approval of the performance test report. The application shall address a true-up of project emissions calculations. A higher voe emission factor is not considered a violation.

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SPECIAL CONDITIONS:



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

13. Superseding Condition A This permit supersedes the entirety of Construction Permit 052019-008

previously issued by the Air Pollution Control Program.

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

Installation Address:

Project Number: 2019-06-052 Installation ID Number: 119-0017 Permit Number: 052019-00BA

Parent Company: Simmons Foods, Inc. P.O. Box430

Simmons Feed Ingredients, Inc. 10700 South State Highway 43 Southwest City, MO 64863 Siloam Springs, AR 72761

McDonald County, S21, T21 N, R23W

REVIEW SUMMARY

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

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

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

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

CO01 or CO02

(2) Feather Blood/Feather Cyclones, CO04 Special

EP01A Fiberglass Spray Conditions 3, 6, Hydrolyzers Meal Line Tower, and CO05 #1 and 7 Packed Bed Scrubber CO03 (3) Oupps

(3) Oupps Spray Tower Special EP01B Continuous Condensers, CO04 Conditions 4, 6,

Cookers Fiberglass Spray

and 7 Poultry Meal

Tower, and COOS #1 Packed Bed Scrubber

Line CO09 #1 Venturi

(6) Oupps Screw Scrubber, CO04 Special

EP01C Fiberglass Spray Conditions 5, 6, Presses Tower, and COOS #1 and 7 Packed Bed Scrubber

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CD11 Spray Tower Special Blood/Feather Condenser and CD12 Meal Line #2 Packed Bed

Conditions 4 and

Screen Scrubber 7

CD09 #1 Venturi

(3) Fat Poultry Meal Scrubber, CD04 Special

EP01I Fiberglass Spray Conditions 5, 6, Centrifuges Line

Tower, and COOS #1 and 7 Packed Bed Scrubber

(2) Blood Tanks Construction

CD12PCB Packed Permit 112011-EU01PC and (4) SPN Other

Bed Scrubber 001 Special Tanks Condition 2.8

EP09 Boiler#5 Low NOx Burners Special Condition 2

CD06 Cyclone, CD11 Blood/Feather Spray Tower

EP10 Meal Dryer #1 - Condenser, and Process Blood/Feather CD12 #2 Packed Bed

Special Meal Line Scrubber

CD07 Cyclone, CD11 Conditions 3, 4,

Blood/Feather Spray Tower and 7

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

Scrubber CD11 Spray Tower

Special EP17A Poultry Meal Day Condenser and CD12 Conditions 4 and

Storage Bin #2 Packed Bed 7

Scrubber (2) Haarslev

EU27 or EU28 Special Condition EU23 Continuous Poultry Meal

Thermal Oxidizers 9 Cookers Line

Feed Bin, (3) CD13 #2 Venturi Scrubber, CD04 Special

EU25 Dupps Screw

Fiberglass Spray Conditions 5, 6, Presses, and Fat Centrifuge Tower, and COOS #1

and 7 Packed Bed Scrubber

EU26 Haarslev Feather Blood/Feather EU27 or EU28 Special Condition

Meal Pre-D er Meal Line Thermal Oxidizers 9

EU35 Petfood

CD18 Bag house Hammermill #1

EU36 Petfood Poultry Meal

CD19 Baghouse Special Condition

Hammermill #2 Line 8

EU37 Feed Grade CD20 Baghouse Hammermill

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EU38 (3) Digest Batch Poultry Meal CD04 Fiberglass Special Tanks Line Spray Tower, and Conditions 6 and

EU39 Hydrolyzers COOS #1 Packed Bed 7 Packin Fan Vent Scrubber

EP40 Coagulated Blood Flash Tank CD11 Spray Tower

Special EU42 A itated Tank Condenser and CD12

Blood/Feather Blood/Feather #2 Packed Bed Conditions 4 and

EU43 Meal Dryers Feed Meal Line Scrubber 7

Bin CD04 Fiberglass Special

EU44 Feather Meal Pre- Spray Tower, and

Conditions 6 and Dryer Feed Bin COOS #1 Packed Bed 7

Scrubber CT01 Coolin Tower #1

Processing CT02 Coolin Tower#2 Drift eliminators NIA CT03 Coolin Tower#3

Plant

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

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

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

• Ambient air quality modeling was not performed since the project emissions increases are below the de minimis.

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

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

• Approval of this permit is recommended with special conditions.

EXISTING INSTALLATION DESCRIPTION

Simmons Feed Ingredients, Inc. operates a poultry rendering plant near Southwest City, Missouri. The installation currently operates three distinct lines: a feather meal line, a poultry meal line, and the Pro*CAL line.

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In the feather meal line, feathers are received from the rendering plant onsite or from other offsite locations and stored in a bin. Feathers are fed to two continuous hydrolyzers, EP01A. The material then passes through a pre-dryer, EU26. Steam is fed to the pre-dryer from the installation's boilers. After the pre-dryer, the material is dried in either EP10/EP12 or EP11/EP12 Feather Meal Dryers. Each dryer is rated at 18.9 MMBtu/hr natural gas and is steam assisted by the installation's boilers.

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

The feather meal line is physically bottlenecked by EP01A Feather Hydrolyzers, which have a physical MHDR of 30 tph. This bottlenecks EU26 Haarslev Feather Meal Pre-Dryer to 20.56 tph, EP1 O and EP11 Feather Meal Dryers to 12.87 tph combined, and feather meal screening (EP14), milling (EU41), transfer (EP15), and storage (EP22) to 9.38 tph.

In the poultry meal line, poultry by-products are received from the rendering plant onsite and from other offsite locations. The raw meat fed to continuous cookers, EP01 B or EU23, with an animal fat mixture. The resulting product is drained of excess fat that is recycled to the cookers, and then fed to screw presses, EP01 C or EU258, removing more of the fat and liquids. The product is transferred to storage bins, EP17, and then to a series of hammermills (EU35, EU36, and EU37) that produce two grades of meal: feed grade and petfood grade. The meal passes through a series of screens (EU47) that separates the meal into different sizes for different applications before being transferred by bucket elevators, EP18, to storage bins, EP16 or EP19, to await shipping via trucks to customers.

The poultry meal line is physically bottlenecked by EP018 and EU23 Continuous Cookers, which have physical MHDRs of 60.5 tph and 53 tph, respectively. This bottlenecks the screw presses (EP01C and EU25) to 38.25 tph and storage (EP17, EP16, and EP19) and transfer (EP18) to 24.18 tph.

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

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

The installation also operates (4) 50.4 MMbtu/hr natural gas-fired or propane-fired boilers (EP06, EP07, EP08, and EP09), (2) four-stroke lean burn emergency generator engines - (1) 80 HP and (1) 107 HP (EU31 and EU32), dehumidifiers and roof heaters combusting a total of 5 MMBtu/hr natural gas (EU33), (8) 0.6 MMBtu/hr natural gas-fired

- 19 -

space heaters (EU45), (2) 85 MMBtu/hr natural gas-fired thermal oxidizers (EU27 and EU28), (1) 40 MMBtu/hr natural gas-fired thermal oxidizer (EU12PC), a lime silo (EU30), a wastewater treatment plant (EU29), (2) solvent parts washers (EU34), and (3) cooling towers (CT01, CT02, and CT03).

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

0199-020

082001-008

082001-008A 052005-026 032006-005 032006-005A 112011-001 032006-0058 OP2016-049

052019-008

01/22/99

08/10/01

10/31/02 05/25/05 03/06/06 08/02/06 11/02/11 05/23/14 01/26/17

05/29/19

Modification of Feather Meal Line and addition of blood coa ulation s stem Use of poultry derived fuel as an alternative fuel in existing boilers

Installation of Pro*CAL Line

Modification of the feather meal line to allow for blood meal reduction

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

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

PROJECT DESCRIPTION

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

2 1.e. EU02PC (2) 10,500 gallon Pro*CAL Process Tanks and (1) 10,000 gallon Pro*CAL CIP Tank, EU03PC (1) 6,000 gallon Pro*CAL Caustic Tank, EU04PC (2) Pro*CAL Mixers, EU05PC Pro*CAL Preheater, EU06PC Pro*CAL Press, EU06PCB Pro*CAL Centrifuge, EU07PC Pro*CAL Dryer, EU0BPC Pro*CAL Hammermill, EU09PC Pro*CAL Screening, EU10PC Pro*CAL Conveyors, EU11PC (3) Pro*CAL Storage Bins, EU 12PC Thermal Oxidizer, and EU13PC Pro*CAL Truck Loadout.

- 20 -

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

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

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

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

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

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

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

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

- 21 -

113.5 tph

N/D N/D

EU25 10 tph 38.25 tph

EP01C 34.87 t h EP01I N/D N/D EU38 N/D N/D EP01H N/D N/D EU48A N/D N/D EU48B N/D N/D EU48C N/D N/D

EP17A and EP178 25 tph 24.18 tph

EP18 24.18 t h EP16 24.18 tph EP19 EU35 and EU36

24.18 tph EU37 EU47 4 Screeners 24.18 t h

Cea ulated Blood Flash Tank New

EP10 Blood/Feather Meal Dryer #1

N/D Modified - Process

15.6 tph feed4 Blood/Feather Meal Dryer #2

EP11 - Process

N/0 Modified

EP01F Raw Blood Screen 9.18 t h 9.18 t h New EU42 A itated Tank N/0 N/D New EP01D N/D N/D New EU39 N/0 N/0 Unaffected EP01A 30 t h 30 t h Unaffected EU44 N/D 20.56 t h Unaffected EU26 28.5 t h 20.56 t h Unaffected

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

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EU43

EU46

EP14

EU41

EP15

EP22

EP12

EP13

EP06 EP07 EP08 EP09

EU31 EU32 EU33 EU45 EP21

EU01PC

EU30 EU29 EU34 CT01 CT02 CT03

Blood/Feather Meal Dryers N/D

Feed Bin (2) Blood/Feather Meal Day

N/D Stora e Bins Link Belt Screener 30 t h Blood/Feather Meal

N/D Hammermill Blood/Feather Meal Transfer

25tph Le 2) Blood/Feather Meal Silos 15 t h

Blood/Feather Meal Dryer #1 18.9 MMBtu/hr

- Combustion Blood/Feather Meal Dryer #2

18.9 MMBtu/hr - Combustion Boiler #2 50.4 MMBtu/hr Boiler #3 50.4 MMBtu/hr Boiler #4 50.4 MMBtu/hr Boiler#5 50.4 MMBtu/hr

Truck Loadout Thermal Oxidizer #1 85 MMBtu/hr Thermal Oxidizer #2 85 MMBtu/hr

Dehumidifiers/Roof Heaters

(2) 26,083 gallon Pro*CAL Blood Tanks and 4 26,083 allon Pro*CAL SPN Tanks Lime Silo Wastewater Treatment Plant 2 Parts Washers

- 23 -

15.6 tph Modified

11.21 tph Modified

11.21 t h Modified

11.21 tph Modified

11.21 tph Modified

11.21 t h Modified

N/A Unaffected

N/A Unaffected

NIA Unaffected N/A Unaffected NIA Unaffected NIA Unaffected

80 HP 107 HP 5 MMBtu/hr total 4.8 MMBtu/hr total 28.5 t h

NIA

NIA 13,200 153,600 127,200 N/A N/A N/A NIA N/A NIA

NIA NIA NIA NIA NIA NIA NIA NIA

care tank NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA

EMISSIONS/CONTROLS EVALUATION

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

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

- 24 -

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

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

HAP emissions from CD12 #2 Packed Bed Scrubber have not been determined but are addressed with the voe limit.

PM and PM2.5 emissions from CD12 #2 Packed Bed Scrubber were determined using emission factors obtained from testing conducted on the control device in December 2017. In December 2017, the meal dryers (EP10 and EP11) only processed hydrolyzed feathers, but after this project, the meal dryers (EP10 and EP11) will process hydrolyzed feathers and blood solids. To ensure that the emission factors remain representative stack testing is required by Special Condition 12.

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

PM 25.0 150. 71 NIA 12.75 NIA PM10 15.0 272.72 78.18 12.28

PERMIT RULE APPLICABILITY

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

APPLICABLE REQUIREMENTS

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

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

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

• 10 CSR 10-6.165 Restriction of Emission of Odors

• 10 CSR 10-6 .170 Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin

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

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

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

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

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

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

- 26 -

STAFF RECOMMENDATION

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

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

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

- 27 -

Attachment A - CO Compliance Worksheet

Simmons Feed Ingredients, Inc. McDonald County, S21, T21N, R32W Project Number: 2019-06-052 Installation ID Number: 119-0017 Permit Number: 052019-00BA

This sheet covers the period from _______ to ______ _ (month, year) (month, year)

EP01B (3) Dupps Continuous Cookers tons

reduct

EP06 Boiler#2 MMscf

Mal

EP07 Boiler #3 MMscf

Mal

EP08 Boiler#4 MMscf

Mal


Mal

EP12 Blood/Feather Meal Dryer #1 MMscf

Mal


Mal

EU23

(2) Haarslev Continuous Cookers -tons

controlled by EU27 or EU28 Thermal feed

Oxidizers (2) Haarslev Continuous Cookers - SSM tons emissions reduct

EU26 Haarslev Feather Meal Pre-Dryer -

tons controlled by EU27 or EU28 Thermal

feed Oxidizers

EU31 107.23 BHP Erner enc Generator hours11

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

0.006 lb/ton7

84 lb/MMscf8 7.5 lb/M al9






0.696 lb/ton feed10

0.006 lb/ton7

1.109 lb/ton feed10

16. 335 lb/hr12

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

- 28 -

EU32 EU33 EU45 I Inst.al

13 72.91 g/HP-hr per manufacturer.

•• .

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

- 29 -

Attachment B - NOx Compliance Worksheet

Simmons Feed Ingredients, Inc. McDonald County, S21, T21 N, R32W Project Number: 2019-06-052 Installation ID Number: 119-0017 Permit Number: 052019-00BA

This sheet covers the period from ______ to ______ _ (month, year) (month, year)

EP01B (3) Dupps Continuous Cookers tons

reduct


Mal

EP07 Boiler#3 MMscf

Mal

EP08 Boiler#4 MMscf

Mal

EP09 Boiler#5 MMscf

Mal


Mal


Mal (2) Haarslev Continuous Cookers - controlled tons

EU23 b EU27 or EU28 Thermal Oxidizers feed (2) Haarslev Continuous Cookers - SSM tons emissions reduct Haarslev Feather Meal Pre-Dryer - controlled tons b EU27 or EU28 Thermal Oxidizers feed 107.23 BHP Erner enc Generator 127.89 BHP Erner enc Generator Dehumidifiers/Roof Heaters S ace Heaters

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

0.006 lb/ton7

100 lb/MMscf8 13 lb/M al9

100 lb/MMscf8

13 lb/M al9





0.749 lb/ton feed 10

0.006 lb/ton7

0.443 lb/ton feed 10

0.759 lb/hr17

1.139 lb/hr18

100 lb/MMscf8 100 lb/MMscf8

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

- 30 -

Attachment C - PM10 Compliance Worksheet

Simmons Feed Ingredients, Inc. McDonald County, S21, T21 N, R32W Project Number: 2019-06-052 Installation ID Number: 119-0017 Permit Number: 052019-00BA

This sheet covers the period from ______ to _____ _ (month, year) (month, year)

(2) Feather Hydrolyzers controlled by CD01 or CD02 Cyclones, CD04 Fiberglass Spray Tower, and CD05 #1 tons

EP01A Packed Bed Scrubber (2) Feather Hydrolyzers

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

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

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

EP01C CD05 #1 Packed Bed Scrubber (6) Dupps Screw Presses

tons - SSM23 emissions

MMscf EP06 Boiler #2

Mgal

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

0.034 lb/ton22

0.068 lb/ton24

0.105 lb/ton25

0.640 lb/ton26

0.034 lb/ton22

0.068 lb/ton27

7.6 lb/MMscf8 0.7 lb/M al9

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

- 31 -

EP07 Boiler#3 MMscf

Mal

EP08 Boiler#4 MMscf

Mal

EP09 Boiler#5 MMscf

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

Blood/Feather Meal Dryer #1 tons

EP10 meal - SSM23 emissions reduct

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

reduct.

EP17A Poultry Meal Day Storage Bin

tons - SSM23 emissions


Mal


Mal

EP14 Link Belt Screener tons

EP15 Blood/Feather Meal Transfer Leg tons

EP16 Feed Grade Meal Storage Bins tons

EP17B Feed Grade Meal Day Storage Bin tons

EP18 Feed Grade, High Ash, Low Ash, and

tons Pet Food Grade Bucket Elevators

EP19 High Ash, Low Ash, and Petfood

tons Stora e Bins

EP20 Meal Loadout tons

28 Obtained from the December 2017 Stack Test. 29 Obtained from AP-42 Section 9.5.3 "Meat Rendering Plants" (September 1995). 30 Includes 3.7% control for being located within a building/enclosure.

- 32 -




0.188 lb/ton28

1.22 lb/ton29

1.22 lb/ton29

0.0063 lb/ton22

7.6 lb/MMscf8 0.7 lb/M al9 7.6 lb/MMscf8 0.7 lb/M al9 0.033 lb/ton22• 30 0.033 lb/ton22• 30 0.0063 lb/ton22

0.006 lb/ton22· 30 0.034 lb/ton22

0.0063 lb/ton22 0.028 lb/ton22• 30

EP21 Hanging Room Exhaust Vents tons 0.022 lb/ton31

EP22 Blood/Feather Meal Silos tons 0.0063 lb/ton22

(2) Haarslev Continuous Cookers controlled by EU27 tons

0.402 lb/ton cooker or EU28 Thermal Oxidizers

feed feed 10

EU23 tons

(2) Haarslev Continuous Cookers cooker

0.640 lb/ton - SSM23 emissions

feed feed32

Feed Bin Controlled by CD13 #2 Venturi Scrubber, 0.034

CD04 Fiberglass Spray Tower, and CD05 #1 Packed tons lb/ton22

EU25A Bed Scrubber

Feed Bin - SSM23 emissions tons 0.068 lb/ton27

(3) Dupps Screw Presses Controlled by CD13 #2 0.034

Venturi Scrubber, CD04 Fiberglass Spray Tower, and tons lb/ton22

EU25B CD05 #1 Packed Bed Scrubber

(3) Dupps Screw Presses - SSM23 emissions tons 0.068 lb/ton27

tons Haarslev Feather Meal Pre-Dryer controlled by EU27 pre- 0.593 or EU28 Thermal Oxidizers dryer lb/ton10

EU26 feed tons

Haarslev Feather Meal Pre-Dryer pre- 1.186 - SSM23 emissions dryer lb/ton32

feed EU30 Lime Silo tons 0.61 lb/ton33 EU31 Generator hours11 0.009 lb/hr34 EU32 Generator hours11 0.012 lb/hr35

EU33 Dehumidifiers/Roof Heaters MMscf 7.6 lb/MMscf8

Petfood Hammermill #1 controlled by CD18 tons

0.012

EU35 Ba house lb/ton22 Petfood Hammermill #1

tons 1.2 lb/ton36 - SSM23 emissions

31 Obtained from the January 2011 Engineering Test. 32 Assumes the thermal oxidizers control 99% of organic condensable emissions and 0% of inorganic condensable and filterable emissions. 33 Obtained from AP-42 Section 11.17 "Lime Manufacturing" (February 1998). 34 Obtained by multiplying the MHDR of the engine (0.879 MM Btu) by the PM10 Primary emission factor of 0.0099871 lb/MMBtu obtained from AP-42 Section 3.2 "Natural Gas-fired Reciprocating Engines" (August 2000). 35 Obtained by multiplying the MHDR of the engine (1.177 MM Btu) by the PM10 Primary emission factor of 0.0099871 lb/MMBtu obtained from AP-42 Section 3.2 "Natural Gas-fired Reciprocating Engines" {August 2000). 36 Assumes bag houses control 99% of PM10 emissions.

- 33 -

Petfood Hammermill #2 controlled by CD19 tons O.O12 lb/ton22

EU36 Ba house Petfood Hammermill #2

tons 1.2 lb/ton36 - SSM23 emissions Feed Grade Hammermill controlled by CD2O

tons 0.012 lb/ton22 EU37

Ba house Feed Grade Hammermill

tons 1.2 lb/ton36 - SSM23 emissions

EU41 Blood/Feather Meal Hammermill tons 1.156 lb/ton22· 30

EU45 S ace Heaters MMscf 7.6 lb/MMscf8 EU46 2 Blood/Feather Meal Da Stora e Bins tons 0. 006 I b/ton22· 30

EU47 4 Screeners tons 0.033 lb/ton22· 30

CTO1 Cooling Tower #1 MMgal 0.274 lb/MM al37

CTO2 Cooling Tower #2 MMgal 0.274 lb/MM al37

CTO3 0.274 lb/MM

37 Based on a maximum drift loss of 0.002%, a maximum TDS content of 7700 ppm, and "Calculating Realistic PM10 Emissions from Cooling Towers" (Joel Reisman and Gordon Frisbie). 38 Installation-wide Monthly PM10 Emissions (tons) = the sum of each emission source's Monthly PM10 Emissions (tons). 39 Installation-wide 12-Month Rolling Total PM10 Emissions (tons)= the sum of the 12 most recent Installation-wide Monthly PM10 Emissions (tons). Installation-wide 12-Month Rolling Total PM10 Emissions of less than 250 tons indicates compliance with Special Condition 1.B.

- 34 -

APPENDIX A Abbreviations and Acronyms

% ............ percent Mgal ......... 1,000 gallons ~F ............ degrees Fahrenheit MW ........... megawatt acfm ....... actual cubic feet per minute MHDR ....... maximum hourly design rate BACT ...... Best Available Control Technology MMBtu ...... Million British thermal units BMPs ...... Best Management Practices MMCF ....... million cubic feet Btu .......... British thermal unit MSDS ....... Material Safety Data Sheet CAM ....... Compliance Assurance Monitoring NAAQS ..... National Ambient Air Quality

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

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

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

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

CO2e ....... carbon dioxide equivalent

COMS ..... Continuous Opacity Monitoring System

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

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

EIQ ......... Emission Inventory Questionnaire EP ........... Emission Point

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

NSR .. ........ New Source Review PM ............ particulate matter

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

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

ppm .......... parts per million PSD .......... Prevention of Significant Deterioration

EU ........... Emission Unit PTE ........... potential to emit fps .......... feet per second RACT ........ Reasonable Available Control ft ............. feet Technology GACT ..... Generally Available Control RAL .......... Risk Assessment Level Technology sec .......... Source Classification Code GHG ....... Greenhouse Gas scfm ......... standard cubic feet per minute gpm ........ gallons per minute SDS .......... Safety Data Sheet gr ............ grains SIC ........... Standard Industrial Classification GWP ....... Global Warming Potential SIP ............ State Implementation Plan HAP ........ Hazardous Air Pollutant SMAL ....... Screening Model Action Levels hr ............ hour SOx ........... sulfur oxides hp ........... horsepower SO2 ........... sulfur dioxide lb ............ pound SSM .......... Startup, Shutdown & Malfunction lbs/hr ...... pounds per hour tph .... ........ tons per hour MACT ..... Maximum Achievable Control Technology

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

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

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

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

- 35 -

JUN 28 2019 Mr. Seth Walters Director of Environmental Quality Simmons Feed Ingredients,·Inc. 107oo·south State Highway 43 Southwest City, MO 64863

. RE: New Source Review Permit Amendment - Project Number: 2019-06-052

Dear Mr. Walters:

dnr.mo.gov

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

• conditions and your rights and obligations under the laws and regulations of the State of Missouri.

This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CA V) can be set up

, . with you. To request a CAV, please contact your local regional office or fill out an online request. The regional office contact information can be found at the following website: http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo.gov/cav/compliance.htm.

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to §§621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed;)f 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.

0 Recycled paper

Mr. Seth Walters Page Two

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

Sincerely,

AIR POLLUTION CONTROL PROGRAM

\,_

Susan Heckenkamp New Source Review Unit Chief

SH:ahd

Enclosures

c: Southwest Regional Office PAMS File: 2019-06-052

Permit Number: 052019-00SA

Date post:	31-Jan-2021
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