l. caro! s. comer, director - dnrboiler #1 (cleaver brooks: model no cb-223-200) boiler #2...

Michael L. Parson, Governor

3 0 2019 Mr. Rock A. Stevens Buckman Laboratories, Inc. - Cadet Plant 14664 Highway 4 7 Cadet, MO 63630

Re: Renewal of Intermediate Operating Permit Installation ID: 221-0018, Permit Number: OP2019-024

Dear Mr. Stevens:

Caro! S. Comer, Director

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 (CA V) can be set up with you. To request a CA V, please contact your local regional office or fill out an online request. The regional office contact information can be found at http://dnr.mo.gov/regions/. The online CA V request can be found at http://dnr.mo.gov/cav/compliance.htm.

You may appeal this permit to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in 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 do not hesitate to contact Berhanu Getahun at the St. Louis Regional Office, 7545 S. Lindbergh, Suite 210, St. Louis, MO 63125, or by telephone at (314) 416-2960. You may also contact me with the Department's Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102, or by telephone at (573) 751-4817. Thank you for your time and attention to this matter.

Sincerely,

AIR POLLUTION CONTROL

/Y?dJJ Michael J. Stansfield, P .E. Operating Permit Unit Chief

MJS/bg

Enclosures

c: PAMS File: 2015-02-032 Recycled paper

~[§]MISSOURI ITT! m j DEPARTMENT oF ~ \:f;1 NATURAL RESOURCES Air Pollution Control Program

INTERMEDIATE STATE PERMIT TO OPERA TE

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

Intermediate Operating Permit Number: OP201.9-0Z4 Expiration Date: AUG 3 U ZU2 4

Installation ID: 221-0018 Project Number: 2015-02-032

Installation Name and Address Buckman Laboratories, Inc. - Cadet Plant 14664 Highway 4 7 Cadet, MO 63630 Washington County

Installation Description:

Parent Company's Name and Address Buckman Laboratories, Inc. 14664 Highway 4 7 Cadet, MO 63630

Buckman Laboratories, Inc. operates a specialty chemical manufacturing installation in Cadet, Missouri. The installation stores and processes over 60 raw materials and manufactures more than 50 products for the water treatment, paper, and leather industries.

The installation has the potential to be a major source for volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). However, the installation, in their Intermediate Operating Permit application, is voluntarily limiting the plant wide emissions to less than 100 tons per year for VOCs, less than 10 tons per year for each HAP, and less than 25 tons per year for total HAPs, on a 12 month rolling average.

AUG 3 0 2019

Effective Date Director or Designee Department of Natural Resources

Buckman Laboratories, Inc. - Cadet Plant

Installation ID: 221-0018 Intermediate State Operating Permit

Table of Contents

2 Project No. 2015-02-032

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

EMISSION UNITS WITH LIMITATIONS ................................................................................................. 4

EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS ....................................................................... 5

II. PLANT WIDE EMISSION LIMITATIONS ............................................................................................ 8

Permit Condition PWOO 1 .............................................................................................................................. 8 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(4)(C)2. Voluntary Limitation(s) ................................................................... 8

Permit Condition PW002 .............................................................................................................................. 9 IO CSR 10-6.080 Emission Standards For Hazardous Air Pollutants ........................................................................................ 9 40 CFR Part 61, Subpart FF National Emission Standard for Benzene Waste Operations ........................................................ 9

Permit Condition PW003 ............................................................................................................................ 12 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 12 Permit No. 0596-0036A, Issued December 26, 2000; Amendment to Construction Permit No. 0596-036, 0596-0036 issued March. 11, 1997 ........................................................................................................................................................................ 12

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ..................................................................... 13

EP-Bl,EP-B3,ANDEP-B4 BOILERS ..................................................................................................... 13 Permit Condition (EP-Bl, EP-B21, EP-B3, and EP-B4) - 001.. ................................................................. 13

10 CSR I 0-6.260 Restriction of Emissions of Sulfur Compounds ........................................................................................... 13 10 CSR 10-6.261 Control of Sulfur Dioxide Emissions ........................................................................................................... 13

Permit Condition (EP-Bl, EP-B3, and EP-B4) - 002 ................................................................................. 14 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants .................................................................................. 14

EP-Cl AND EP-C2-DISTILLATION COLUMNS ........................................................................................ 15 EP-PV4, EP-PV5, AND EP-PVlO PROCESS VESSELS ............................................................................ 15

EP-R4Cl TMEDA FRACTIONAL COLUMN ............................................................................................ 15

EPT-31, EP-T33, EP-T38, EP-T42, EP-T43, AND EP-T87-STORAGE TANKS ........................................ 15

Permit Condition EP-C 1 and EP-C2- 001 .................................................................................................. 16 Permit Condition EP-PV4, EP-PV5, and EP-PVlO - 001 .......................................................................... 16

Permit Condition EP-R4Cl - 001 ............................................................................................................... 16

Permit Condition EP-T6, EP-T8, EP-T33, EP-T38, EP-T42, EP-T43, and EP-T87 - 001 ........................ 16 IO CSR 10-6.070 New Source Performance Regulations ........................................................................................................ 16 40 CFR Part 60, Subpart VY Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for which Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Before November 7, 2006 ..................................................................................................................................................... 16

Permit Condition EP-T42 -002, ................................................................................................................ 25

Permit Condition N EP-T45 - 002, And .................................................................................................... 25 Permit Condition EP-T87 - 002 .................................................................................................................. 25

10 CSR I 0-6.060 Construction Permits Required ..................................................................................................................... 25 Construction Permit #1097-027 Issued October 24, I 997 ......................................................................................................... 25

Permit Condition EP-R4Cl - 002, ............................................................................................................. 26

Permit Condition EP-CENT - 001, And ................................................................................................... 26 Permit Condition EP-T3 1 - 001 .................................................................................................................. 26

10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 26 Construction Permit # 1097-026 Issued October 28, 1997 ......................................................................................................... 26

EP-TOX - THERMAL OXIDIZER ................................................................................................................ 27 Permit Condition EP-TOX - 001 ................................................................................................................ 27

10 CSR 10-6.020(2)(1)23. and 10 CSR I0-6.065(4)(C)2. Voluntary Limitation(s) ................................................................. 27 Permit Condition EP-TOX - 002 ................................................................................................................ 27

IO CSR 10-6.261 Control of Sulfur Dioxide Emissions ............................................................................................................ 27 EP-EG- EMERGENCY GENERATOR AND DUAL FIRE PUMPS ..................................................................... 28

Permit Condition EP-EG- 001 .................................................................................................................. 28 IO CSR 10-6.075 Maximum Achievable Control Technology Regulations ............................................................................ 28

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intermediate State Operating Permit

3 Project No. 2015-02-032

40 CFR Paii 63. Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines .................................................................................................................................................... 28

Pennit Condition EP-EG - 002 ................................................................................................................... 33 IO CSR I 0-6.260 Restriction of Emissions of Sulfur Compounds .......................................................................................... 33 IO CSR I 0-6.261 Control of Sulfur Dioxide Emissions .......................................................................................................... 33

IV. CORE PERMIT REQUIREMENTS .................................................................................................... 35

V. GENERAL PERMIT REQUIREMENTS .............................................................................................. 41

VI. ATTACHMENTS .............................................................................................................................. 45

ATTACHMENT A .......................................................................................................................................... 46 Method 22 Visible Emissions Observations ............................................................................................................................. 46

ATTACHMENT B .......................................................................................................................................... 4 7 Method 9 Opacity Observations ............................................................................................................................................... 4 7

ATTACHMENT C .......................................................................................................................................... 49 Inspection/Maintenance/Repair/Malfunction Log .................................................................................................................... 49


4 Project No.2015-02-032

I. Installation Equipment Listing

EMISSION UNITS WITH LIMITATIONS 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-Bl

EP-B2

EP-B3

EP-B4

EP-Cl

EP-C2

Description of Emission Unit Boiler #1 (Cleaver Brooks: Model No CB-223-200)

Boiler #2 (Continental: Model No FlOC200-3871-G436)

Boiler #3 (Industrial Combustion: Model No E976-MLG-84)

Boiler #4 (Cleaver Brooks: Model No CD-200-400)

Dichloroethylether (DCEE) Distillation (C-1)

Secondary Dichloroethylether (DCEE) Distillation Column (C-2)

EP-CENT Centrifuge for Dewatering Busan I 059WC

EP-PV4 Process Vessel #4

EP-PV5 Process Vessel #5

EP-PVl0 Process Vessel #10

EP-R4Cl TMEDA Fractional Column (R4Cl)

EP-T3 l Storage Tank #31 - 8,000 Gallon Storage Tank for Busan I 059WC Liquor

EP-T33 Storage Tank #33 - 16,3000 Gallon Storage Tank for Dichloroethylether

EP-T36 Storage Tank #36 - 16,3000 Gallon Storage Tank for Formaldehide 3 7% Solution

EP-T3 7 Storage Tank #3 7 - 16,3000 Gallon Storage Tank for Bufloc 5031

EP-T38 Storage Tank #38- 5,700 Gallon Storage Tank for Dimethylamine Solution

EP-T42 Storage Tank #42- 16,300 Gallon Storage Tank for Tetramethylethylenediamine

EP-T43 Storage Tank #43 - 16,300 Gallon Storage Tank for Ethylene Dichloride

EP-T45 Storage Tank #45 - 7,000 Gallon Storage Tank for Tetramethylethylenediamine

EP-T87 Storage Tank #87 - 5,000 Gallon Storage Tank for Tetramethylethylenediamine

EP-TOX Thermal Oxidizer - Emission Control Device

EP-EG Plant Emergency Generator

Dual Fire Pumps/Engines

Year Installed or Modified

1957

1963

1963

1986

1983

1983

1998

1994

1994

2001

1998

1998

1999

1998

1998

1986

1986

1986

1987

1983

1996

2004

1988


EMISSION UNITS WITHOUT SPECIFIC LIMIT A TIO NS

5 Project No.2015-02-032

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-BF 1, EP-BF2

EP-BF3

EP-BF4

EP-BF5

EP-BF6, EP-BF7

EP-DRYl, EP-DRY2, EP-DRY3, EP-DRY4

EP-PAC

EP-PV3

EP-PV6 EP-PV7, EP-PV8, EP-PV9

EP-PVl 1

EP-PV12, EP-PVl 5

EP-PV13

EP-PV14, EP-PV16

EP-Rl4Tl

EP-Tl

EP-T2

EP-T6

EP-Tl 5

EP-T16

EP-Tl 8

EP-T19

EP-T2 l

EP-T23

Description of Emission Unit

Bin Filling Location #1 and #2 (Warehouse)

Bin Filling Location #3 (Plant Area)

Portable Tank Filling Location #4 - TMEDA Cylinders

Portable Tank Filling Location #5 - Epichlorohydin cylinders

Bin Filling Location #6 and #7 (Warehouse)

Busan l 059 Drying Process

Phosphorous Acid Colum

Process Vessel #3 (Plant 2)

Process Vessels #6, #7, #8 and #9 (Plant 2)

Process Vessel # 11 (Plant 2)

Process Vessels # 12 and # 15 (Plant #3)

Process Vessel #13 (Plant #3)

Process Vessels #14 and #16 (Plant #3)

Process Vessel #14 Receiver (Plant 3)

Storage Tank # I (PTSA, Plamnt 2) ..............................

Storage Tank #2 - Propylene Glycol/Water (Tank Farm 1)

Storage Tank #6 - 15,000 Gallon Storage Tank for Diethylne Glycol ( 1963)

Storage Tank #8 15,000 Gallon Pressurized Storage Tank for Diemethylamine (1963)

Storage Tank #11 - Salt Water (Tank Farm 2)

Storage Tank# 13 - Process Wastewater (Tank Farm 3)

Storage Tank# I 5 - 7,500 Gallon Pressurized Storage Tank for Tetramethylethylenediamine ( 1961)

Storage Tank# 16 - Acetic Anhydride (Tank Farm 1)

Storage Tank # 18 - Bubreak 456 (Tank Farm 1)

Storage Tank# 19 - Process Wastewater (Tank Farm 1)

Storage Tank #21 - Phosphorous Trichloride (PC 13 Building)

Storage Tank #23 - Untreated Stormwater

Storage Tank #24 Phos 2 (Tank Farm 2)

Buckman Laboratories, Inc. - Cadet Plant 6 Project No.2015-02-032 Installation ID: 221-0018 Intermediate State Operating Permit

Emission Unit# EP-T25 EP-T26

EP-T27

EP-T28

EP-T29

EP-T30

EP-T32

EP-T34

EP-T35

EP-T39

EP-T40

EP-T46

EP-T47

EP-T49, EP-T50

EP-T51

EP-T52

EP-T53

EP-T55

EP-T56

EP-T57

EP-T58

EP-T60

EP-T61

EP-T62

EP-T63, EP-T65

EP-T64

EP-T66

EP-T67

EP-T68

EP-T69

EP-T71

EP-T72


Storage Tank #25 and #26 - Bubreak 4452 (Tank Farm 1)

Storage Tank #27 -Carbon Disulfide Sealed Tank (Tank Farm 3)

Storage Tank #28 - Process Wastewater (Tank Farm 1)

Storage Tank #29 - Monomethylamine Sealed Tank (Tank Farm 1)

Storage Tank #30 Crude Phosphorous Acid (Tank Farm 2)

Storage Tank #32 - Phosphorous Acid Distillate (Tank Farm 2) ..............................

Storage Tank #34 - DMATO (Tank Farm 2)

Storage Tank #35 16,3000 Gallon Storage Tank for Dichloroethylether ( 1980)

Storage Tank #39 - PEG600 (Tank Farm 2)

Storage Tank #40 - Namet (Tank Farm 2)

Storage Tank #41 Dim et (Tank Farm 2)

Storage Tank #44 Phosphorous Acid (Tank Farm 2)

Storage Tank #46- Sulfuric Acid (Tank Farm 2/A W)

Storage Tank #47 - Pit 2 Vacuum System Seal Water (Plant Vacuum)

Storage Tank #49 and #50 BL1480/1020J (Tank Farm 3)

Storage Tank #51 - 24,000 Gallon Storage Tank for WSCP ( 1991)

Storage Tank #52 - 24,000 Gallon Storage Tank for Tall Oil Fatty Acid ( 1991)

Storage Tank #53 - Bufloc 5376 (Tank Farm 3)

Storage Tank #55 - Hydrobromic Acid (Tank Farm 3)

Storage Tank #56 - DMDAAC Monomer (Tank Farm 3)

Storage Tank #57 - PEG400 (Tank Farm 3)

Storage Tank #58 - Bromine Sealed Tank (Tank Farm 3)

Storage Tank #60 - Hydrochloric Acid (Tank Farm 3)

Storage Tank #61 - Epichlorohydrine (Tank Farm 3)

Storage Tank #62 - MDTCMA (Tank Fann 3)

Storage Tank #63 and #65 - Busan 1058 (Tank Farm 3)

Storage Tank #64 - Buchman 4469 (Tank Farm 3)

Storage Tank #66 - Sulfuric Acid (Tank Farm 2/ AW)

Storage Tank #67 -Ammonium Persulfate Solution (Plant 3))

Storage Tank #68- Vapam Mfg Cone (Tank Farm 1))

Water Treatment Tank #69-Ozone (Tank Farm I)

Water Treatment #70 Ozone (Tank Farm I)

Water Treatment #71 -Ozone (Tank Farm I)

Water Treatment #72 -Ozone (Tank Farm 1)

Buckman Laboratories, Inc. - Cadet Plant 7 Project No. 2015-02-032 Installation ID: 221-0018 Intermediate State Operating Permit

Emission Unit#

EP-T73

EP-T76

EP-T80

EP-T81

EP-T82

EP-T85

EP-T91

EP-T92

EP-T22, 100 through

105

EP-T51-Cl

EP-TS-5

EP-RS-3


Storage Tank #73 - Bubreak 4469 (Tank Fann 3)

Storage Tank #76 - Ester R2D2 (Tank Farm 2)

Storage Tank #80 - Acrylamide (Tank Farm 2)

Storage Tank #81 - TDET BPR2 (Tank Farm 2)

Storage Tank #82 - PVl I Distillate/Ester Overs (Tank Farm 2)

Storage Tank #85 - Hydrochloric Acid, Dry Strength (Warehouse)

Storage Tank #90 Pit 2 Vacuum System Seal Water (Plant Vacuum)

Storage Tank #91 - Propylene Glycol (Tank Farm 2)

Storage Tank #92 - TSPP Mix Tank, Dry Strength (Tank Farm 2)

Storage Tanks #22, # I 00 through # I 05 - Unleaded Diesel Fuel

WSCP Stripper Column (Tank Farm 3)

Truck Loading Area #5 (Truck Spot 5)

Railcar Loading #3 (Rail Spot 3)


II. Plant Wide Emission Limitations

8 Project No. 2015-02-032

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(2)(1)23. and 10 CSR 10-6.065(4)(C)2. Voluntary Limitation(s)

Emission Limitation: l) The permittee shall emit less than 100 tons of Volatile Organic Compounds (VOCs) from the entire

installation in any consecutive 12-month period. 2) The permittee shall emit less than ten (10) tons per year of any individual Hazardous Air Pollutants

(HAPs) and twenty-five (25) tons per year of total HAPs from the entire installation in any consecutive 12-month period.

Monitoring/Recordkeeping: 1) The permittee shall retain data sufficient to demonstrate compliance with

Emission Limitations 1) and 2). This data shall include at a minimum: a) The date (month and year). b) The amount ofVOC material and HAP material handled by each emission unit during the month. c) MSDS for each material containing VOC and/or HAP. d) VOC and HAPs emission calculations and/or spreadsheets including VOC and HAPS emissions

from natural gas and fuel oil combustion equipment. e) Monthly VOC, combined HAP, and individual HAP emissions totals. t) 12-Month rolling VOC, combined HAP, and individual HAP emissions totals

2) The permittee 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 Material Safety Data Sheet (MSDS) for all materials used.

3) Recordkeeping shall be accomplished in accordance with the requirements of 10 CSR 10-6.065, §(4)(C)l and §(5)(C)l.C, General Recordkeeping and Reporting Requirements, as stated in Section V of this permit.

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

P.O. Box 176, Jefferson City, Missouri 65102 or AirComplianceReporting(c1)dnr.mo.2-ov:, no later than ten days after the end of the month during which the records indicate that the source exceeds the emissions limitations.

2) Reports of any deviations from monitoring, record keeping and reporting requirements of this permit condition shall be submitted annually in the annual compliance certification and monitoring report, as required by Section V of this permit.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intermediate State Operating Penn it

Permit Condition PW002

l O CSR 10-6.080 Emission Standards For Hazardous Air Pollutants

9 Project No. 2015-02-032

40 CFR Part 61, Subpart FF National Emission Standard for Benzene Waste Operations

Emission Limitation/Stanards: Standards: Treatment processes: 1) The permittee shall not produce process wastewater at the facility with a total annual benzene

quantity equal to or greater than 1 megagram (Mg) (1.1 tons) per year. [§61.348(b)(2)(ii)] a) The permittee shall calculate the annual benzene quantity as the sum of the individual benzene

quantities determined at each location where a waste stream first enters an exempt waste management unit. The benzene quantity discharged from an exempt waste management unit shall not be included in this calculation. [§61.348(b)(2)(ii)(A)]

b) The permittee shall not include the annual benzene quantity in a waste stream managed or treated in an enhanced biodegradation unit in the calculation of the total annual benzene quantity, if the enhanced biodegradation unit is the first exempt unit in which the waste is managed or treated. A unit shall be considered enhanced bi ode gradation if it is a suspended-growth process that generates biomass, uses recycled biomass, and periodically removes biomass from the process. An enhanced biodegradation unit typically operates at a food-to-microorganism ratio in the range of 0.05 to 1.0 kilogram (kg) (0.011 to 2.2 pounds) of biological oxygen demand per kg of biomass per day, a mixed liquor suspended solids ratio in the range of 1 to 8 grams per liter (0.008 to 0. 7 pounds per liter), and a residence time in the range of 3 to 36 hours. [§61.348(b )(2)(ii)(B)]

2) The permittee shall demonstrate that each treatment process or wastewater treatment system unit, except as provided in §61.348( d) , achieves the appropriate conditions specified in §6 l .348(b) in accordance with the following requirements: [§61.348(c)] a) Engineering calculations in accordance with requirements specified in §61.356(e) of this subpart;

or [§61.348(c)(l)] b) Performance tests conducted using the test methods and procedures that meet the requirements

specified in §61.355 of this subpart. [§61.348(c)(2)]

Monitoring/Compliance Provisions: 1) The permittee shall monitor each wastewater treatment system to ensure the unit is properly operated

and maintained by the appropriate monitoring procedure as follows: [§61.354(b )] a) For the first exempt waste management unit in each waste treatment train, other than an

enhanced biodegradation unit, measure the flow rate, using the procedures of §61.355(b ), and the benzene concentration of each waste stream entering the unit at least once per month by collecting and analyzing one or more samples using the procedures specified in §61.355(c)(3). [§61.354(b )(1 )]

b) For each enhanced bi ode gradation unit that is the first exempt waste management unit in a treatment train, measure the benzene concentration of each waste stream entering the unit at least once per month by collecting and analyzing one or more samples using the procedures specified in §61.355(c)(3). [§61.354(b)(2)]

2) The permittee shall determine the total annual benzene quantity from facility waste by the following procedure: [§61.355(a)] a) If the total annual benzene quantity from facility waste is less than 1 Mg per year

(1.1 ton per year), then the owner or operator shall: [§61.355(a)(5)]


10 Project No. 2015-02-032

i) Comply with the recordkeeping requirements of §61.356 and reporting requirements of §61.357 of this subpart; and [§61.355(a)(5)(i)]

ii) Repeat the determination of total annual benzene quantity from facility waste whenever there is a change in the process generating the waste that could cause the total annual benzene quantity from facility waste to increase to I Mg per year (1. 1 ton per year) or more. [§61.355(a)( 5)(ii)]

3) For purposes of the calculation required by §61.355(a)(5), the permittee shall determine the annual waste quantity at the point of waste generation by one of the methods given in §61.355 (b)(5) through (7) (listed below). [§61.355(b)] a) Select the highest annual quantity of waste managed from historical records representing the

most recent 5 years of operation; [§61.355(b )(5)] b) Use the maximum design capacity of the waste management unit; or [§61.355(b)(6)] c) Use measurements that are representative of maximum waste generation rates.

[ §61.3 5 5(b )(7)]

Recordkeeping: 1) The permittee shall comply with the recordkeeping requirements of this section. Each record shall be

maintained in a readily accessible location at the facility site for a period not less than two years from the date the information is recorded unless otherwise specified. [§6 l.356(a)]

2) Each owner or operator shall maintain records that identify each waste stream at the facility subject to this subpart, and indicate whether or not the waste stream is controlled for benzene emissions in accordance with this subpart. In addition the owner or operator shall maintain the following records: [§61.356(b)] a) For each waste stream not controlled for benzene emissions in accordance with this subpart, the

records shall include all test results, measurements, calculations, and other documentation used to determine the following information for the waste stream: waste stream identification, water content, whether or not the waste stream is a process wastewater stream, annual waste quantity, range of benzene concentrations, annual average flow-weighted benzene concentration, and annual benzene quantity. [§61.356(b)(l)]

b) For each facility where the annual waste quantity for process unit turnaround waste is determined in accordance with §6 l.355(b )(5), the records shall include all test results, measurements, calculations, and other documentation used to determine the following information: identification of each process unit at the facility that undergoes turnarounds, the date of the most recent turnaround for each process unit, identification of each process unit turnaround waste, the water content of each process unit turnaround waste, the annual waste quantity determined in accordance with §6 l.355(b )(5), the range of benzene concentrations in the waste, the annual average flow-weighted benzene concentration of the waste, and the annual benzene quantity calculated in accordance with §61.355(a)(l)(iii). [§61.356(b)(5)]

3) The permittee using a treatment process or wastewater treatment system unit in accordance with §61.348 of this subpart shall maintain the following records. The documentation shall be retained for the life of the unit. [§61.356(e)] a) A statement signed and dated by the owner or operator certifying that the unit is designed to

operate at the documented performance level when the waste stream entering the unit is at the highest waste stream flow rate and benzene content expected to occur. [§61.356(e)(l)]

b) If engineering calculations are used to determine treatment process or wastewater treatment system unit performance, then the owner or operator shall maintain the complete design analysis for the unit. The design analysis shall include for example the following information: Design


11 Project No.2015-02-032

specifications, drawings, schematics, piping and instrumentation diagrams, and other documentation necessary to demonstrate the unit performance. [§61.356( e )(2)]

c) If performance tests are used to determine treatment process or wastewater treatment system unit performance, then the owner or operator shall maintain all test information necessary to demonstrate the unit performance. [§61.356(e)(3)] i) A description of the unit including the following information: type of treatment process;

manufacturer name and model number; and for each waste stream entering and exiting the unit, the waste stream type (e.g., process wastewater, sludge, slurry, etc.), and the design flow rate and benzene content. [§61.356(e)(3)(i)]

ii) Documentation describing the test protocol and the means by which sampling variability and analytical variability were accounted for in the determination of the unit performance. The description of the test protocol shall include the following information: sampling locations, sampling method, sampling frequency, and analytical procedures used for sample analysis. [§61.356( e )(3)(ii)]

iii) Records of unit operating conditions during each test run including all key process parameters. [§61.356( e)(3 )(iii)]

iv) All test results. [§61.356(e)(3)(iv)]

Reporting: 1) If the total annual benzene quantity from facility waste is less than 1 Mg/yr (1.1 ton/yr), then the

permittee shall submit to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102 or AirComplianceRep01iing(a)dnr.mo.gov, a report that updates the information listed in 40 CFR §61.357 (a)(l) through (a)(3) (listed below) whenever there is a change in the process generating the waste stream that could cause the total annual benzene quantity from facility waste to increase to 1 Mg per year (1.1 ton per year) or more. [§61.357(b )] a) Total annual benzene quantity from facility waste determined in accordance with §61.355(a).

[§61.357(a)(l)] b) A table identifying each waste stream and whether or not the waste stream will be controlled for

benzene emissions in accordance with the requirements of this subpart. [§61.357(a)(2)] c) For each waste stream identified as not being controlled for benzene emissions in accordance

with the requirements of this subpart the following information shall be added to the table: [§61.357(a)(3)] i) Whether or not the water content of the waste stream is greater than 10 percent;

[§61.357(a)(3)(i)] ii) Whether or not the waste stream is a process wastewater stream, product tank drawdown, or

landfill leachate; [§61.357(a)(3)(ii)] iii) Annual waste quantity for the waste stream; [§61.357(a)(3)(iii)] iv) Range of benzene concentrations for the waste stream; [§61.357(a)(3)(iv)] v) Annual average flow-weighted benzene concentration for the waste stream; and

[§61.357(a)(3)(v)] vi) Annual benzene quantity for the waste stream. [§61.357(a)(3)(v)]


Permit Condition PW003

10 CSR 10-6.060 Construction Permits Required

12 Project No. 2015-02-032

Permit No. 0596-0036A, Issued December 26, 2000; Amendment to Construction Pem1it No. 0596-036, 0596-0036 issued March. 11, 1997

Work Practice Standards: 1) The permittee shall implement a visual inspection/maintenance program for the facility to reduce

process fugitive emissions from any equipment which comes in contact with any of the following materials: a) Dimethylamine, Ammonia, Monomethylamine, Ester 80, DMATO, Nabonate, Metam

Concentrate, Kn-Methyl, Busan 1020, Busan 881, Busan 1058, and BL-1182, Carbon Disulfide, Diethylene Glycol, Formaldehyde, Methanol, Methylene Chloride, Phosphorous Acid 70%, Phosphorous Trichloride, and TMEDA 85.

Monitoring/Recordkeeping: 1) The permittee shall clearly mark leaks detected with a weatherproof and readily visible

identification, which includes the equipment identification number. The identification shall remain in place until the leak is repaired.

2) The permittee shall record leaks detected in a log with the following information: a) The equipment identification number, b) The date the leak was detected. c) The date when the equipment was fixed or replaced, and d) The repair method used.

Reporting: The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102 or AirComplianceReporting(ct).dnr.mo.gov, as required by Section V of this permit.


III. Emission Unit Specific Emission Limitations

13 Project No.2015-02-032

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.

EP-Bl, EP-B3, and EP-B4- Boilers

Emission Description Manufacturer/Model#

Unit EP-BI Boiler #1: Industrial Dual-Fuel Fired Boiler (Natural Gas and #2 Cleaver-Brooks/

Fuel Oil), 8.0 MMBtu/hr, Installed January 1957. CB-223-200 EP-B2 Boiler #2: Industrial Natural Gas Fired Boiler, 8.4 MMBtu/hr, Continental/

Installed January 1963. Fl 0C200-387 l-G436 EP-B3 Boiler #3: Heat Transfer Flued (Dowtherm) Dual-Fuel Fired Industrial Combustion/

Furnace (Natural Gas and #2 Fuel Oil), 8.4 MMBtu/hr, Installed E976-MLG-84 January 1963.

EP-B4 Boiler #4: Industrial Dual-Fuel Fired Boiler (Natural Gas and #2 Cleaver-Brooks/ Fuel Oil), 16. 7 MM Btu/hr, Installed January 1986 CD-200-400

Permit Condition (EP-B1, EP-B21, EP-B3, and EP-B4) - 001

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

10 CSR 10-6.261 Control of Sulfur Dioxide Emissions

Emission Limitation: 1) The permittee shall not cause or allow emissions of sulfur dioxide into the atmosphere from any

boiler (EP-B 1, EP-B3, or EP-B4) eight pounds (8 lbs) of sulfur dioxide per million British thermal units (MMBtus) actual heat input averaged on any consecutive three (3) - hour time period. [10 CSR 10-6.260(3)(B)2.A] and [10 CSR 10-6.261(3)(B)l]

2) For emission units combusting natural gas: the permittee shall comply with the record keeping requirements of 10 CSR 10-6.261(4). [10 CSR 10-6.261(1)(A)]

Monitoring/Recordkeeping: 1) The permittee shall maintain a record of data, calculations, results, records, and reports from all fuel

deliveries. [10 CSR 10-6.261(4)(A)3.] 2) The permittee must maintain fuel delivery/purchase receipts and/or fuel sampling tests. 3) The permittee must also maintain the fuel supplier certification information to certify all fuel

deliveries. Bills of lading and/or other fuel delivery documentation containing the following information for all fuel purchases or deliveries are deemed acceptable to comply with the requirements of this rule: a) The name, address, and contact information of the fuel supplier; b) The type of fuel;

1 l 0 CSR 10-6.260 was rescinded on November 30, 2015 and replaced by 10 CSR 10-6.261; however, the provisions of IO CSR I 0-6.260 currently remain in State Implementation Plan. The provisions of 10 CSR I 0-6.260 will expire, once 10 CSR l 0-6.261 is incorporated into the federally-approved SIP as a final EPA action.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 22I-0018 Intermediate State Operating Permit

14 Project No. 2015-02-032

c) The sulfur content or maximum sulfur content expressed in percent sulfur by weight or in ppm sulfur; and

d) The heating value of the fuel. 4) The permittee must use fuel sampling and analysis to determine sulfur weight percent, or equivalent,

offuel(s) in accordance with 10 CSR 10-6.040. 5) The permittee must retain all reports and records on-site for a minimum of five (5) years and made

available within five (5) business days upon written or electronic request by the director.

Reporting: 1) The permittee must furnish the Director all data necessary to determine compliance status. 2) The permittee shall report any excess emissions other than startup, shutdown, and malfunction

excess emissions already required to be reported under 10 CSR 10-6.050 to the Director for each calendar quarter within thirty (30) days following the end of the quarter. In all cases, the notification must be written and include the information listed in 10 CSR 10-6.261 (4) (A) 1.

3) The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the Air Pollution Control Program's Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or AirComplianceReporting1ZD.dnr.mo.gov, as required by Section V of this permit.

Permit Condition (EP-B1, EP-B3, and EP-B4) - 002

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

Emission Limitation: 1) The permittee shall not cause or permit to be discharged into the atmosphere from EP-B 1 and EP-B3

any visible emissions with an opacity greater than 40 percent for any continuous six-minute period. [10 CSR 10-6.220(3)(A)l]

2) The permittee shall not cause or permit to be discharged into the atmosphere from EP-B4 any visible emissions with an opacity greater than 20 percent for any continuous six-minute period. [10 CSR 10-6.220(3)(A)l]

3) 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]

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

Monitoring: 1) Monitoring schedule:

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

If a violation is noted, the permittee shall revert to weekly monitoring. Should no violation of this regulation be observed during this period then:

ii) 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.

Buckman Laboratories, Inc. - Cadet Plant 15 Project No.2015-02-032 Installation ID: 221-0018 Intermediate State Operating Penn it

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 B and C or equivalent forms. 2) The permittee shall make these records available within a reasonable period of time 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 AirComplianceReporting(a:dnr.mo.gov, no later than ten days after an exceedance of the emission limitation.

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

EP-Cl and EP-C2 - Distillation Columns EP-PV4, EP-PVS, and EP-PVlO-Process Vessels

EP-R4Cl - TMEDA Fractional Column EPT-31, EP-T33, EP-T38, EP-T42, EP-T43, and EP-T87- Storage Tanks

Emission Description

Unit EP-Cl Dichloroethylether (DCEE) Distillation Column (C-1); Installed January, 1983.

EP-C2 Secondary Dichloroethylether (DCEE) Distillation Column (C-1 ); Installed January, 1983.

EP-PV4 Process Vessel #4; Installed January; 1994. Manufacturer: Trinity Industries, Model #PD-3860.

EP-PV5 Process Vessel #5; Installed January; 1994. Manufacturer: Trinity Industries, Model #PD-3859.

EP-PVl0 Process Vessel #10; Installed January; 2001. Manufacturer: Andrew P. Duffy, Model #6-01-1443.

EP-R4CI TM EDA Fractional Column - Fractional Column for processing Tetramethylethylenediamine (TMEDA); Installed April, 1998.

EP-T3 l Storage Tank #31 - 7,500 Gallon Storage Tank for Tetramethylethylenediamine (TMEDA); Installed January 1961.

EP-T33 Storage Tank #33 - 16,300 Gallon Storage Tank for Dichloroethylether (DCEE); Installed January 1999.

Manufacturer: Trumbo, Inc., Model #50652.

Buckman Laboratories, Inc. - Cadet Plant 16 Project No. 2015-02-032 Installation ID: 221-0018 Intermediate State Operating Permit

EP-T38

EP-T42

EP-T43

EP-T45

EP-T87

Storage Tank #38 - 5,700 Gallon Pressurized Storage Tank for Dimethylamine (OMA); Installed January; 1986.

Manufacturer: Henders Boiler and Tank Company, Model #6125. Storage Tank #42 - 16,300 Gallon Storage Tank for Tetramethylethylenediamine (TMEDA); Installed January 1986.

Manufacturer: Plant Maintenance and Service Corporation, Model #0-341-8. Storage Tank #43 - 16,300 Gallon Storage Tank for Ethylene Dichloride (EDC); Installed January 1986.

Manufacturer: Plant Maintenance and Service Corporation, Model #0-341-8. Storage Tank #45 - 7,000 Gallon Storage Tank for Tetramethylethylenediamine (TMEDA); Installed January 1986.

Manufacturer: Mid-South Maintenance, Model #0193. Storage Tank #87 - 5,000 Gallon Storage Tank for Anhydrous Tetramethylethylenediamine (ATMEDA); Installed January 1983.

Manufacturer: Trumbo.

Permit Condition EP-Cl and EP-C2- 001 Permit Condition EP-PV4, EP-PVS, and EP-PVl0 - 001

Permit Condition EP-R4Cl - 001 Permit Condition EP-T6, EP-T8, EP-T33, EP-T38,

EP-T42, EP-T43, and EP-T87 - 001

IO CSR I 0-6.070 New Source Performance Regulations 40 CFR Part 60, Subpart VV Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for which Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Before November 7, 2006

Operational Limit/Equipment Specifications: The owner or operator of Synthetic Organic Chemical Manufacturing facilities with the design capacity for producing a chemical affected by 40 CFR Part 60, Subpart VV [§60.489] in amounts equal to or greater than 1000 Mg per year ( 1, 102 tons per year), affecting processes installed after January 5, 1981, are subject to the provisions of 40 CFR Part 60, Subpart VV and include the following operational limits and/or equipment specifications:

1) Pumps in Light Liquid Service: [40 CFR §60.482-21 a) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar

days after it is detected, except as provided in §60.482-9. [§60.482-l(c)(l)] b) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected.

First attempts at repair include, but are not limited to, the practices described in §60.482-l ( c )(2)(i) and (ii) (listed below), where practicable. [§60.482-l(c)(2)] i) Tightening the packing gland nuts; [§60.482-1 ( c )(2)(i)] ii) Ensuring that the seal flush is operating at design pressure and temperature.

[§60.482-1 ( C )(2)(ii)]

2) Compressors: [40 CFR §'60.482-31 a) Each compressor shall be equipped with a seal system that includes a barrier fluid system and

that prevents leakage of V OC to the atmosphere, except as provided in §60 .482-1 ( c) and paragraphs (h), (i), and (i) of §60.482-3 and the aforementioned seal system shall be: [§60.482-3(a) and (b)]


17 Project No. 2015-02-032

i) Operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or [§60.482-3(b)(l)]

ii) Equipped with a barrier fluid system degassing reservoir that is routed to a process or fuel gas system or connected by a closed vent system to a control device that complies with the requirements of §60.482-10; or [§60.482-3(b)(2)]

iii) Equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions to the atmosphere. [§60.482-3(b)(3)]

b) Each barrier fluid system as described in 60.482-3 (a) shall be equipped with a sensor that will detect failure of the seal system, barrier fluid system, or both. The permittee shall determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. [§60.482-3(d) and (e)(2)]

c) If the sensor indicates failure of the seal system, the barrier system, or both based on the criterion determined under paragraph (e)(2) of §60.482-3, a leak is detected. [§60.482-3(±)]

d) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in §60.482-9. [§60.482-3(g)(l)

e) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [§60.482-3(g)92)

3) Pressure Relie(Devices in Gas/Vapor Service: [40 CFR §60.482-41 a) Except during pressure releases, each pressure relief device in gas/vapor service shall be

operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as determined by the methods specified in §60.485(c). [§60.482-4(a)]

b) After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in §60.482-9. [§60.482-4(b)(l)]

c) Any pressure relief device that is routed to a process or fuel gas system or equipped with a closed vent system capable of capturing and transporting leakage through the pressure relief device to a control device as described in §60.482-10 is exempted from the requirements of §60.482-4(a) and (b). [§60.482-4(6) and (c)]

d) Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is exempt from the requirements of §60.482-4(a) and (b), provided that a new rapture disk is installed upstream of the pressure relief device as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in §60.482-9. [§60.482-4(d)(l) and (2)]

4) Sampling Connection Systems: [40 CFR §60.482-51 a) Each sampling connection system shall be equipped with a closed-purge, closed-loop, or closed

vent system, except as provided in §60.482-l(c) and §60.482-5(c). [§60.482-5(a)] b) Each closed-purge, closed-loop, or closed-vent system as required in paragraph (a) of this section

shall comply with the requirements specified in paragraphs (b )(1) through ( 4) of §60.482-5) (listed below). [§60.482-5(b )] i) Gases displaced during filling of the sample container are not required to be collected or

captured. [ §60.482-5(b )(1)] ii) Containers that are part of a closed-purge system must be covered or closed when not being

filled or emptied. [§60.482-5(b)(2)]


l 8 Project No. 2015-02-032

iii) Gases remaining in the tubing or piping between the closed-purge system valve(s) and sample container valve(s) after the valves are closed and the sample container is disconnected are not required to be collected or captured. [§60.482-5(b)(3)]

iv) Each closed-purge, closed-loop, or closed-vent system shall be designed and operated to meet requirements in either paragraph (b )( 4 )(i), (ii), (iii), or (iv) of §60.482-5(b) (listed below). [§60.482-5(b)(4)] (1) Return the purged process fluid directly to the process line. [§60.482-5(b)(4)(i)] (2) Collect and recycle the purged process fluid to a process. [§60.482-5(b)(4)(ii)] (3) Capture and transport all the purged process fluid to a control device that complies with

the requirements of §60.482-10. [§60.482-5(b)(4)(iii)] ( 4) Collect, store, and transport the purged process fluid to any of the following systems or

facilities: [§60.482-5(b )( 4 )(iv)] (A) waste management unit as defined in §63 .111, if the waste management unit is

subject to and operated in compliance with the provisions of 40 CFR part 63, subpart G, applicable to Group 1 wastewater streams; [§60.482-5(b)(4)(iv)(A)]

(B) A treatment, storage, or disposal facility subject to regulation under 40 CFR part 262, 264,265, or 266; [§60.482-5(b)(4)(iv)(B)]

(C) A facility permitted, licensed, or registered by a state to manage municipal or industrial solid waste, if the process fluids are not hazardous waste as defined in 40 CFR part 261; [§60.482-5(b)(4)(iv)(C)]

(D) A waste management unit subject to and operated in compliance with the treatment requirements of §61.348(a), provided all waste management units that collect, store, or transport the purged process fluid to the treatment unit are subject to and operated in compliance with the management requirements of §§61.343 through 61.347; or [§60.482-5(b )( 4)(iv)(D)]

(E) A device used to bum off-specification used oil for energy recovery in accordance with 40 CFR part 279, subpart G, provided the purged process fluid is not hazardous waste as defined in 40 CFR part 261. [§60.482-5(b)(4)(iv)(E)]

c) In situ sampling systems and sampling systems without purges are exempt from the requirements of paragraphs (a) and (b) of §60.482-5. [§60.482-5(c)]

5) Open-Ended Valves or Lines: [§'60.482-61 a) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second

valve, except as provided in §60.482-l(c) and paragraphs (d) and (e) of this section. [ §60 .482-6( a )(1)]

b) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line. [§60.482-6(a)(2)]

c) Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. [§60.482-6(b )]

d) When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with paragraph (a) at all other times. [§60.482-6(c)]

e) Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt from the requirements of paragraphs ( a), (b) and (c) of §60.482-6. [§60.482-6(d)]

f) Open-ended valves or lines containing materials which would autocatalytically polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped


19 Project No. 2015-02-032

with a double block and bleed system as specified in paragraphs (a) through (c) of this section are exempt from the requirements of paragraphs (a) through (c) of §60.482-6. [§60.482-6(e)]

6) Valves in Gas/Vapor Service and in Light Liquid service: [§60.482-71 a) If an instrument reading of 10,000 ppm or greater is measured according to§60.485, a leak is

detected. [§60.482-7(b )] b) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar

days after the leak is detected, except as provided in §60.482-9. [§60.482-7( d)(l )] c) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected.

[§60.482-7( d)(2)] d) First attempts at repair include, but are not limited to, the following best practices where

practicable: [§60.482-7(e)] i) Tightening of bonnet bolts; [§60.482-7(e)(l)] ii) Replacement of bonnet bolts; [§60.482-7(e)(2)] iii) Tightening of packing gland nuts; [§60.482-7(e)(3)] iv) Injection oflubricant into lubricated packing. [§60.482-7( e )( 4)]

e) Any valve that is designated, as described in §60.486(e)(2), for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt from the requirements of §60.482-7(a) if the valve: [§60.482-7(£)] i) Has no external actuating mechanism in contact with the process fluid, [§60.482-7(f)(l )] ii) Is operated with emissions less than 500 ppm above background as determined by the

method specified in §60.485(c), and [§60.482-7(£)(2)] iii) Is tested for compliance with §60.482-7(£)(2) of this section initially upon designation,

annually, and at other times requested by the director. [§60.482-7(£)(3)] f) Any valve that is designated, as described in §60.486(£)(1 ), as an unsafe-to-monitor valve is

exempt from the requirements of §60.482-7 (a) if: [§60.482-7(g)] i) The owner or operator of the valve demonstrates that the valve is unsafe to monitor because

monitoring personnel would be exposed to an immediate danger as a consequence of complying with §60.482-7 (a), and [§60.482-7(g)(l )]

ii) The owner or operator of the valve adheres to a written plan that requires monitoring of the valve as frequently as practicable during safe-to-monitor times. [§60.482-7(g)(2)]

g) Any valve that is designated, as described in §60.486(£)(2), as a difficult-to-monitor valve is exempt from the requirements of paragraph (a) if: [§60.482-7(h)] i) The permittee of the valve demonstrates that the valve cannot be monitored without elevating

the monitoring personnel more than 2 meters above a support surface. [§60.482-7(h)(l )] ii) The process unit within which the valve is located either becomes an affected facility through

§60.14 or §60.15 or the permittee designates less than 3.0 percent of the total number of valves as difficult-to-monitor, and [§60.482-7(h)(2)]

iii) The permittee of the valve follows a written plan that requires monitoring of the valve at least once per calendar year. [§60.482-7(h)(3)]

7) Delay of Repair: N60.482-91 a) Delay of repair of equipment for which leaks have been detected will be allowed if repair within

15 days is technically infeasible without a process unit shutdown. Repair of this equipment shall occur before the end of the next process unit shutdown. Monitoring to verify repair must occur within 15 days after startup of the process unit. [§60.482-9(a)]

b) Delay of repair of equipment will be allowed for equipment which is isolated from the process and which does not remain in VOC service. [§60.482-9(b)]


c) Delay ofrepair for valves will be allowed if: [§60.482-9(c)]

20 Project No.2015-02-032

i) The permittee demonstrates that emissions of purged material resulting from immediate repair are greater than the fugitive emissions likely to result from delay of repair, and [§60.482-9( C )(1 )]

ii) When repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with §60.482-10. [§60.482-9( c )(2)]

d) Delay ofrepair for pumps will be allowed if: [§60.482-9(d)] i) Repair requires the use of a dual mechanical seal system that includes a barrier fluid system,

and [§60.482-9(d)(l)] ii) Repair is completed as soon as practicable, but not later than 6 months afl:er the leak was

detected. [ §60 .482-9( d)(2)] e) Delay of repair beyond a process unit shutdown will be allowed for a valve, if valve assembly

replacement is necessary during the process unit shutdown, valve assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. [§60.482-9( e )]

f) When delay of repair is allowed for a leaking pump or valve that remains in service, the pump or valve may be considered to be repaired and no longer subject to delay of repair requirements if two consecutive monthly monitoring instrument readings are below the leak definition. [ §60.482-9( f)]

8) Closed Vent Systems and Control Devices: (¢60.482-101 a) Vapor recovery systems (for example, condensers and absorbers) shall be designed and operated

to recover the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 parts per million by volume, whichever is less stringent. [§60.482-1 0(b )]

b) Enclosed combustion devices shall be designed and operated to reduce the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 parts per million by volume, on a dry basis, corrected to 3 percent oxygen, whichever is less stringent or to provide a minimum residence time of0.75 seconds at a minimum temperature of 816 °C. [ §60 .482-1 O(c)]

c) Leaks, as indicated by an instrument reading greater than 500 parts per million by volume above background or by visual inspections, shall be repaired as soon as practicable except as provided in paragraph (h) of this section. [§60.482-l0(g)] i) A first attempt at repair shall be made no later than 5 calendar days after the leak is detected.

[§60.482-1 0(g)(l )] ii) Repair shall be completed no later than 15 calendar days after the leak is detected. [§60.482-

10(g)(2)] d) Delay of repair of a closed vent system for which leaks have been detected is allowed if the

repair is technically infeasible without a process unit shutdown or if the owner or operator determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be complete by the end of the next process unit shutdown. [§60.482-1 0(h)]

e) Closed vent systems and control devices used to comply with provisions of this subpart shall be operated at all times when emissions may be vented to them. [§60 .482-10( m)]

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-00 I 8 Intermediate State Operating Permit

Monitoring: 1) Pumps in Light Liquid Service:

21 Project No.2015-02-032

a) Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in §60.485(b ), except as provided in §60.482-1 ( c) and (f) and §60.482-1 ( d), ( e ), and (f). [§60.482-l(a)(l)]

b) Each pump in light liquid service shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal, except as provided in 40 CFR §60.482-1 (f). [§60.482-1 ( a)(2)]

c) If there are indications of liquids dripping from the pump seal, the owner or operator shall follow the procedure specified in either §60.482-1 (b )(2)(i) or (ii) (listed below). This requirement does not apply to a pump that was monitored after a previous weekly inspection if the instrument reading for that monitoring event was less than 10,000 ppm and the pump was not repaired since that monitoring event. [§60.482-1 (b )(2)] i) Monitor the pump within 5 days as specified in §60.485(b ). If an instrument reading of

10,000 ppm or greater is measured, a leak is detected. The leak shall be repaired using the procedures in §60.482-1 ( c ). [§60.482-1 (b )(2)(i)]

ii) Designate the visual indications of liquids dripping as a leak, and repair the leak within 15 days of detection by eliminating the visual indications of liquids dripping. [§60.482-1 (b )(2)(ii)]

2) Compressor: a) Each sensor as required in paragraph ( d) shall be checked daily or shall be equipped with an

audible alarm. [§60.482-3(e)(l )] b) The owner or operator shall determine, based on design considerations and operating experience,

a criterion that indicates failure of the seal system, the barrier fluid system, or both. [§60.482-3( e )(2) )]

3) Pressure Relie(Devices in Gas/Vapor Service: [40 CFR §60.482-41 a) No later than 5 calendar days after the pressure release, the pressure relief device shall be

monitored to confirm the conditions of no detectable emissions, as indicated by an instrument reading ofless than 500 ppm above background, by the methods specified in §60.485(c). [§60.482-4(b )(2)]

4) Valves in Gas/Vapor Service and in Light Liquid service: [§60.482-71 a) Each valve shall be monitored monthly to detect leaks by the methods specified in §60.485(b)

and shall comply with paragraphs (b) through (e) of §60.482-7, except as provided in paragraphs (f), (g), and (h) of §60.482-7, §60.482-l(c) and (f), and §§60.483-1 and 60.483-2. [§60.482-7(a)(l )] i) Method 21 shall be used to determine the presence of leaking sources. The instrument shall

be calibrated before use each day of its use by the procedures specified in Method 21. The following calibration gases shall be used: [§60.485(b)(l)] (1) Zero air (less than 10 ppm of hydrocarbon in air); and [§60.485(b)(l)(i)] (2) A mixture of methane or n-hexane and air at a concentration of about, but less than,

10,000 ppm methane or n-hexane. [§60.485(b)(l)(ii)] b) Any valve for which a leak is not detected for 2 successive months may be monitored the first

month of every quarter, beginning with the next quarter, until a leak is detected. [§60.482-7( C )(1 )(i)]

c) As an alternative to monitoring all of the valves in the first month of a quarter, an owner or operator may elect to subdivide the process unit into 2 or 3 subgroups of valves and monitor each

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intermediate State Operating Perm it

22 Project No.2015-02-032

subgroup in a different month during the qumier, provided each subgroup is monitored every 3 months. The owner or operator must keep records of the valves assigned to each subgroup. [§60.482-7( C )( 1 )(ii)]

d) If a leak is detected, the valve shall be monitored monthly until a leak is not detected for 2 successive months. [§60.482-7(c)(2)]

e) The permittee may elect to comply with alternative work practices specified in §60.483-2( b)(2) and (3) if the permittee notifies the Administrator before implementing one of the alternative work practices, as specified in §60.487(d) and comply with the initial requirements for valves in gas/vapor service and valves in light liquid service, as described in §60.482-7. [§60.483-2]

5) Closed Vent Systems and Control Devices: (§60.482-101 a) Except as provided in paragraphs (i) through (k) of §60.482-10( c ), each closed vent system shall

be inspected according to the procedures and schedule specified in paragraphs (f)(l) and (f)(2) of §60.482-10 (listed below). [§60.482-1 0(f)] i) If the vapor collection system or closed vent system is constructed of hard-piping, the owner

or operator shall comply with the requirements specified in paragraph (f)(l )(ii) of §60.482-10 (listed below): [§60.482-1 0(f)(l )] ( 1) Conduct annual visual inspections for visible, audible, or olfactory indications of leaks.

[§60.482-1 0(f)(l )(ii)] ii) If the vapor collection system or closed vent system is constructed of ductwork, the the

permittee shall: [§60.482-10(£)(2)] (1) Conduct annual inspections according to the procedures in §60.485(b). [§60.482-

1 0(f)(2)(ii)] b) If a vapor collection system or closed vent system is operated under a vacuum, it is exempt from

the inspection requirements of paragraphs (f)(l)(i) and (f)(2) of §60.482-10. [§60.482-l0(i)] c) Any parts of the closed vent system that are designated, as described in paragraph (1)(1) of this

section, as unsafe to inspect are exempt from the inspection requirements of paragraphs (f)(l )(i) and (f)(2) of this section if they comply with the requirements specified in paragraphs (i)(l) and (i)(2) of this section: [§60.482-l0(i)] i) The permittee determines that the equipment is unsafe to inspect because inspecting

personnel would be exposed to an imminent or potential danger as a consequence of complying with paragraphs (f)(l)(i) or (f)(2) of §60.482-10; and [§60.482-lO(i)(l)]

ii) The owner or operator has a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. [§60.482-1 0(i)(2)]

d) Any parts of the closed vent system that are designated, as described in paragraph (1)(1) of §60.482-10, as unsafe to inspect are exempt from the inspection requirements of paragraphs (f)(l )(i) and (f)(2) of §60.482-10 if they comply with the requirements specified in paragraphs (i)(l) and (i)(2) of §60.482-10: [§60.482-lO(k)] i) The permittee determines that the equipment cannot be inspected without elevating the

inspecting personnel more than 2 meters above a support surface; and [§60.482-l0(k)(l)] ii) The process unit within which the closed vent system is located becomes an affected facility

through §§60.14 or 60.15, or the owner or operator designates less than 3.0 percent of the total number of closed vent system equipment as difficult to inspect; and [§60.482-1 0(k)(2)]

iii) The permittee has a written plan that requires inspection of the equipment at least once every 5 years. A closed vent system is exempt from inspection if it is operated under a vacuum. [§60.482-1 0(k)(3)]


Recordkeeping:

23 Project No. 2015-02-032

The permittee shall comply with the following recordkeeping requirement: [§60.486(a)(l)] 1) When each leak is detected as specified in §§60.482-2, 60.482-3, and 60.482-7, the following

requirements apply: [§60.486(b )] a) A weatherproof and readily visible identification, marked with the equipment identification

number, shall be attached to the leaking equipment. [§60.486(b )(1 )] b) The identification on a valve may be removed after it has been monitored for 2 successive

months as specified in §60.482-7(c) and no leak has been detected during those 2 months. [§60.486(b)(2)]

c) The identification on equipment except on a valve, may be removed after it has been repaired. [ §60 .486(b )(3)]

2) When each leak is detected as specified in §§60.482-2, 60.482-3, and 60.482-7, the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location: [§60.486( C )]

a) The instrument and operator identification numbers and the equipment identification number. [§60.486( C )(1 )]

b) The date the leak was detected and the dates of each attempt to repair the leak. [§60.486(c)(2)] c) Repair methods applied in each attempt to repair the leak. [§60.486(c)(3)] d) "Above 10,000" if the maximum instrument reading measured by the methods specified in

§60.485(a) after each repair attempt is equal to or greater than 10,000 ppm. [§60.486(c)(4)] e) "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days

after discovery of the leak. [§60.486(c)(5)] f) The signature of the owner or operator ( or designate) whose decision it was that repair could not

be effected without a process shutdown. [ §60 .486( c )( 6)] g) The expected date of successful repair of the leak if a leak is not repaired within 15 days.

[§60.486(c)(7)] h) Dates of process unit shutdowns that occur while the equipment is umepaired. [§60.486(c)(8)] i) The date of successful repair of the leak. [§60.486(c)(9)]

3) The following information pertaining to the design requirements for closed vent systems and control devices described in §60 .482-10 shall be recorded and kept in a readily accessible location: [§60.486(d)] a) Detailed schematics, design specifications, and piping and instrumentation diagrams.

[§60.486(d)(l)] b) The dates and descriptions of any changes in the design specifications. [§60.486( d)(2)] c) A description of the parameter or parameters monitored, as required in §60 .482-10( e ), to ensure

that control devices are operated and maintained in conformance with their design and an explanation of why that parameter ( or parameters) was selected for the monitoring. [§60.486(d)(3)]

d) Periods when the closed vent systems and control devices required in §§60.482-2, 60.482-3, 60.482-4, and 60.482-5 are not operated as designed, including periods when a flare pilot light does not have a flame. [§60.486(d)(4)]

e) Dates of startups and shutdowns of the closed vent systems and control devices required in §§60.482-2, 60.482-3, 60.482-4, and 60.482-5. [§60.486(d)(5)]

4) The following information pertaining to all equipment subject to the requirements of this subpart shall be recorded in a log that is kept in a readily accessible location: [§60.486(e)] a) A list of identification numbers for equipment subject to the requirements of this subpart.

[§60.486(e)(l)]


24 Project No. 2015-02-032

b) A list of equipment identification numbers for pressure relief devices required to comply with §60.482-4. [§60.486(e)(3)]

c) The dates of each compliance test as required in §§60.482-2(e), 60.482-3(i), 60.482-4, and 60.482-7(f). [§60.486(e)(4)(i)]

d) The background level measured during each compliance test. [§60.486(e)(4)(ii)] e) The maximum instrument reading measured at the equipment during each compliance test.

[§60.486( e )( 4)(iii)] t) A list of identification numbers for equipment in vacuum service. [§60.486(e)(5)]

5) The following information pertaining to all valves subject to the requirements of §60.482-7(g) and (h) and to all pumps subject to the requirements of §60.482-2(g) shall be recorded in a log that is kept in a readily accessible location: [§60.486(f)] a) A list of identification numbers for valves and pumps that are designated as unsafe-to-monitor,

an explanation for each valve or pump stating why the valve or pump is unsafe-to-monitor, and the plan for monitoring each valve or pump. [§60.486(f)(l )]

b) A list of identification numbers for valves that are designated as difficult-to-monitor, an explanation for each valve stating why the valve is difficult-to-monitor, and the schedule for monitoring each valve. [§60.486(f)(2)]

Reporting: 1) The permittee shall submit semiannual reports to Air Pollution Control Program's

Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or AirComplianceRcporting(q;dnr.mo.gov. All semiannual reports shall include the following information, summarized from the information in §60.486: [§60.487(a) and (c)] a) Process unit identification. [§60.487(c)(l)] b) For each month during the semiannual reporting period, [§60.487(c)(2)]

i) Number of valves for which leaks were detected as described in §60.482-7(b) or §60.483-2, [ §60.487( C )(2)(i)]

ii) Number of valves for which leaks were not repaired as required in §60.482-7( d)(l ), [§60.487( C )(2)(ii)]

iii) Number of pumps for which leaks were detected as described in §60.482-2(b ), ( d)( 4 )(ii)(A) or (B), or (d)(5)(iii), [§60.487(c)(2)(iii)]

iv) Number of pumps for which leaks were not repaired as required in §60.482-2(c)(l) and (d)(6), [§60.487(c)(2)(iv)]

v) Number of compressors for which leaks were detected as described in §60.482-3(f), [§60.487(c )(2)(v)]

vi) Number of compressors for which leaks were not repaired as required in §60.482-3(g)( 1 ), and [§60.487(c)(2)(vi)]

vii) The facts that explain each delay of repair and, where appropriate, why a process unit shutdown was technically infeasible. [§60.487(c)(2)(vii)]

c) Dates of process unit shutdowns which occurred within the semiannual reporting period. [§60.487( C )(3)]

d) Revisions to items reported according to §60.487(b) if changes have occurred since the initial report or subsequent revisions to the initial report. [§60.487( c )( 4 )]

2) The permittee shall report the results of all performance tests in accordance with §60.8 of the General Provisions. [§60.487(e)]


Permit Condition EP-T42 - 002, Permit Condition N EP-T45 - 002,

And Permit Condition EP-T87 - 002

10 CSR 10-6.060 Construction Permits Required Construction Permit # 1097-027 Issued October 24, 1997

Operational Limitation:

25 Project No.2015-02-032

1) The permittee shall vent EP-T42, EP-T45, and EP-T87 to the thermal oxidizer. 2) The thermal oxidizer must be in use at all times when the EP-T42, EP-T45, and EP-T87 are in

operation and shall be operated and maintained in accordance with the manufacturer's specifications.

Monitoring/Recordkeeping: 1) The pennittee shall maintain an operating and maintenance log for the thermal oxidizer 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.

2) A copy of the operating log shall be kept at the plant site for the most recent 60 months and be made immediately available to the Department of Natural Resources' personnel upon request.

Reporting: 1) If, in the opinion of the Director, a continuing situation of demonstrated nuisance odors exists for the

neighbors of the facility, the director may require the permittee to submit a corrective action plan adequate to timely and significantly mitigate the odors. The Permittee shall implement any such plan immediately upon its approval by the director. Failure to either submit or implement such a plan shall be a violation of this permit.

2) The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102 or AirComplianceReporting1ciJ.dnr.mo.gov, as required by Section V of this permit.


Permit Condition EP-R4Cl - 002, Permit Condition EP-CENT- 001,

And Permit Condition EP-T31 - 001

10 CSR 10-6.060 Construction Permits Required Construction Permit# 1097-026 Issued October 28, 1997

Operational Limitation:

26 Project No. 2015-02-032

1) The permittee shall operate the dimethylamine (DMA) scrubber at all times during the use of the fractionation column (EP-R4Cl). a) The flowrate and pH of the scrubbing solution shall be maintained within the manufacturer's

design specifications. 2) The permittee shall vent the centrifuge (EP-CENT) and the 1059 WC liquor storage tank (EP-T31)

to the thermal oxidizer. 3) The permittee shall maintain all equipment which emits any regulated pollutant in good working

order at all times when the installation is in operation.

Monitoring/Recordkeeping: 1) Scrubber:

a) The scrubber shall be equipped with a gauge or meter which indicates the flowrate and pH of the scrubbing solution.

b) The flowrate and pH of the scrubbing solution shall be recorded once every three hours of operation to verify the operation of the scrubber.

2) Thermal Oxidizer: a) The permittee shall maintain an operating and maintenance log for the thermal oxidizer which

shall include the following: i) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and

corrective actions; and ii) Maintenance activities, with inspection schedule, repair actions, and replacements, etc. iii) A copy of the operating log shall be kept at the plant site for the most recent 60 months and

be made immediately available to the Department of Natural Resources' personnel upon request.

Reporting: 1) If, in the opinion of the Director, a continuing situation of demonstrated nuisance odors exists for the

neighbors of the facility, the director may require the permittee to submit a corrective action plan adequate to timely and significantly mitigate the odors. The Permittee shall implement any such plan immediately upon its approval by the director. Failure to either submit or implement such a plan shall be a violation of this permit.

2) The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102 or AirCornplianceReportingrc1ldnr.mo.gov, as required by Section V of this permit.


EP-TOX-Therrnal Oxidizer


Unit EP-TOX Thermal Oxidizer: Emission Control Device, 2.0 MMBtu/hr natural

gas burner, Installed January 1996

Permit Condition EP-TOX - 001

27 Project No. 2015-02-032

Manufacturer/Model #

Eclipse/ 200 RM-S

10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(4)(C)2. Voluntary Limitation(s)

Operational Limitation: 1) The permittee shall operate the Thermal Oxidizer control device a minimum of 70% of the available

run-time2•

2) The permittee shall ensure the following emission units are vented to the Thermal Oxidizer at all times: a) EP-BFI, EP-BF2, EP-Cl, EP-CENT, EP-R4Cl, EP-R4T2, EP-RlOTl, EP-T15, EP-T20, EP

T31, EP-T33, EP-T35, EP-T36, EP-T42, EP-T43, EP-T45, EP-T47, EP-T48, EP-T49, EP-T50, EP-T60, EP-T61, EP-T62, EP-T63, EP-T68, EP-T-VENT, EP-T51-Cl, EP-TS-5, EP-RS-3, EPVAC, EP-R14Tl, EP-DRYl

Monitoring/Recordkeeping/Reporting: The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102 or [email protected], as required by Section V of this permit.

Permit Condition EP-TOX - 002

10 CSR 10-6.261 Control of Sulfur Dioxide Emissions3

Operational Limitation: For emission units combusting natural gas: the permittee shall comply with the record keeping requirements of 10 CSR 10-6.261(4). [10 CSR 10-6.26l(l)(A)]

Monitoring/Recordkeeping: 1) The permittee shall maintain a record of data, calculations, results, records, and reports from all fuel

deliveries. [10 CSR 10-6.261(4)(A)3.] 2) The permittee must maintain the fuel supplier certification information to certify all fuel deliveries.

Bills of lading and/or other fuel delivery documentation containing the following information for all fuel purchases or deliveries are deemed acceptable: [ 10 CSR 10-6.261 ( 4 )(C)] a) The name, address, and contact information of the fuel supplier; [10 CSR 10-6.261(4)(C)l.] b) The type of fuel; [10 CSR 10-6.261(4)(C)2.] c) The sulfur content or maximum sulfur content expressed in percent sulfur by weight or in ppm

sulfur; and [10 CSR 10-6.261(4)(C)3.]

2 This is a voluntary limitation taken by the pennittee. This condition does not relieve the permittee of any compliance obligations specified in issued construction permits. 3 This regulation is state enforceable only. When this regulation is incorporated into the SIP, this permit condition will be state and federally enforceable.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intennediate State Operating Permit

d) The heating value of the fuel. [10 CSR 10-6.261(4)(C)4.]

28 Project No. 2015-02-032

3) The permittee must retain all required reports and records on-site for a minimum of five years and make available within five business days upon written or electronic request by the director. [10 CSR 10-6.261(4)(F)]

4) The permittee must furnish the director all data necessary to determine compliance status. [10 CSR 10-6.261(4)(G)]

Reporting: 1) The permittee shall report any exceedance of the limitations no later than ten days after an

exceedance of the emission limitation. 2) The permittee shall report any deviations from the monitoring, recordkeeping, and reporting

requirements of this permit condition in the annual compliance certification reports required by Section V of this permit.

3) All reports and certifications shall be submitted to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or AirComplianccReporting(cildnr.mo.gov.

EP-EG - Emergency Generator and Dual Fire Pumps


Unit EP-EG Emergency Generator - 1250 Kilowatt (Kw), Four cycle, I 6 Cylinder,

One stage Turbocharged 50 Liter Cummins Diesel Engine. 1850 Horsepower (HP), Model #DFLC-5676691, Serial #H040682726. Installed October 20, 2004 Dual Fire Pumps/Engines - (2) 235 Hp Caterpillar 3208 Diesel Engines. Model# FM/UL TO/3208-DIT, Serial# 03Z07194. Installed 1988

Permit Condition EP-EG - 001

10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 40 CFR Part 63, Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

Emission Limitation: The permittee must comply with the requirements in Table 2d to Subpart ZZZZ of 40 CFR Part 63 which apply to the facility (listed below). [40 CFR §63.6603(a)]

Buckman Laboratories, Inc. - Cadet Plant 29 Project No.2015-02-032 Installation ID: 221-0018 Intermediate State Operating Permit

For each .....

Emergency CI RICE 2

[Item 4 of Table 2d]

The permittee must meet the following requirement, except during periods of staiiup a. Change oil and filter every 500 hours of operation or annually,

whichever comes first; 1

b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and

c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.

The pennittee has the option to utilize an oil analysis program as described in 40 CFR §63.6625(i) in order to extend the specified oil change requirement in Table 2d of Subpart ZZZZ

If the emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Table 2d of Subpart ZZZZ, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under Federal, State, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. The permittee must report any failure to perform the management practice on the schedule required and the Federal, State or local law under which the risk was deemed unacceptable.

Monitoring. Operation and Maintenance Requirements: 1) The pennittee must operate and maintain the stationary RICE and after-treatment control device

(if any) according to the manufacturer's emission-related written instructions or develop the permittee's maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. [40 CFR §63.6625(e)]

2) The permittee must install a non-resettable hour meter if one is not already installed. [40 CFR §63.6625(£)]

3) The permittee must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Table 2d to Subpart ZZZZ of Part 63 apply. [40 CFR §63.6625(h)]

4) The permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Tables 2d to Subpart ZZZZ of 40CFR Part 63. The oil analysis must be performed at the same frequency specified for changing the oil in Table 2d to Subpart ZZZZ of 40 CFR Part 63. The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the permittee is not required to change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. If any of the limits are exceeded, the permittee must change the oil before continuing to use the engine. The permittee must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes


30 Project No.2015-02-032

for the engine. The analysis program must be part of the maintenance plan for the engine. [40 CFR §63.6625(i)]

Compliance Requirements: 1) The permittee must be in compliance with the operating limitations in Subpart ZZZZ of 40 CFR Part

63 that apply to the permittee at all times. [40 CFR §63.6605(a)] 2) The permittee must monitor and collect data according to §63.6635.

a) Except for monitor malfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities, the permittee must monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR §63.6635(b)]

b) The permittee may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. The permittee must, however, use all the valid data collected during all other periods. [§63.6635(c)]

3) The permittee must demonstrate continuous compliance with each operating limitation in Tables 2d to Subpart ZZZZ of 40 CFR Part 63 that apply to the permittee according to methods specified below (from Table 6 to Subpart ZZZZ of 40 CFR Part 63). [40 CFR §63.6640(a)]

For Each ...

Existing stationary RICE not subject to any numerical emission limitations

Complying with the requirements to ...

Work or Management practices

The permittee must demonstrate continuous compliance by ...

Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

4) The permittee must operate the emergency stationary RICE according to the requirements in paragraphs (f)(l), (f)(l)(i), (±)(2), (f)(2)(i) and(f)(4)(ii) of 40 CFR §63.6640. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in nonemergency situations for 50 hours per year, as described in paragraphs (f)( 1) through ( 4) of 40 CFR §63.6640, is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(l) through ( 4) of §63.6640, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. [40 CFR §63.6640(±)] a) There is no time limit on the use of emergency stationary RICE in emergency situations.

[40 CFR §63.6640(±)(1)] b) The permittee may operate the emergency stationary RICE for any combination of the purposes

specified in paragraphs (f)(2)(i) of §40 CFR 63.6640 for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraph (±)(4) of 40 CFR


31 Project No. 2015-02-032

§63.6640 counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2). [§63.6640(£)(2)] i) The emergency stationary RICE may be operated for maintenance checks and readiness

testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year. [40 CFR §63.6640(f)(2)(i)]

c) The emergency stationary RICE may be operated for up to 50 hours per calendar year in nonemergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph (f)(2) of 40 CFR §63.6640. Except as provided in paragraph (f)(4)(ii) of 40 CFR §63.6640, the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. i) The 50 hours per year for non-emergency situations can be used to supply power as part of a

financial arrangement with another entity if all of the following conditions are met: [40 CFR §63.6640(f)(4)(ii)] (A) The engine is dispatched by the local balancing authority or local transmission and

distribution system operator. [ 40 CFR §63 .6640(£)( 4 )(ii)(A)] (B) The dispatch is intended to mitigate local transmission and/or distribution limitations so

as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. [40 CFR §63.6640(f)(4)(ii)(B)]

(C) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. [40 CFR §63.6640(f)(4)(ii)(C)]

(D) The power is provided only to the facility itself or to support the local transmission and distribution system. [ 40 CFR §63.6640(£)( 4 )(ii)(D)]

(E) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. [40 CFR §63.6640(f)(4)(ii)(E)]

Recordkeeping: 1) The permittee must keep the records described in paragraphs (a)(l) through (a)(5), (b)(l) through

(b)(3) and (c) of §63.6655. [40 CFR §63.6655(a)] a) A copy of each notification and report that the permittee submitted to comply with Subpart

ZZZZ of 40 CFR Part 63, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in 40 CFR §63.10(b)(2)(xiv). [40 CFR §63.6655(a)(l)]

b) Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. [40 CFR §63.6655(a)(2)]

c) Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR §63.6605(b). [40 CFR §63.6655(a)(5)]


32 Project No. 2015-02-032

2) The permittee must keep the records required in Table 6 of Subpart ZZZZ of 40 CFR Part 63 to show continuous compliance with each emission or operating limitation that applies to the permittee. [40 CFR §63.6655(d)]

3) The permittee's records must be in a form suitable and readily available for expeditious review according to 40 CFR §63.l0(b)(l). [40 CFR §63.6660(a)]

4) As specified in 40 CFR §63 .1 0(b )(1 ), the permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. [40 CFR §63.6660(b)]

5) The permittee must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40 CFR §63.lO(b)(l). [40 CFR §63.6660(c)]

Reporting: 1) The permittee must report each instance in which the permittee did not meet each operating

limitation in Table 2d to Subpart ZZZZ of 40 CFR Part 63 that applies. These instances are deviations from the emission and operating limitations in Subpart ZZZZ of 40 CFR Part 63. These deviations must be reported according to the requirements in 40 CFR §63.6650. [40 CFR §63.6640(b)]

2) The permittee must also report each instance in which the permittee did not meet the applicable requirements in Table 8 to Subpart ZZZZ of 40 CFR Part 63 Applicability of General Provisions to Subpart ZZZZ. [40 CFR §63.6640(e)]

3) Reporting requirements [40 CFR §63.6650] a) Pursuant to 40 CFR §63.6650(b)(5), the permittee shall report any deviations/exceedances of this

permit condition using the semi-annual monitoring report and annual compliance certification to the Missouri Air Compliance Coordinator at EPA region 7 with complimentary copies to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as required by Section V of this permit instead of according to the dates specified in in paragraphs (b)(l) through (b)(4) of §63.6650.

b) The Compliance report must contain the information in paragraphs ( c )( l) through ( 6) of 40 CFR §63.6650. [40 CFR §63.6650(c)] (1) Company name and address. [40 CFR §63.6650(c)(l)] (2) Statement by a responsible official, with that official's name, title, and signature, certifying

the accuracy of the content of the report. [40 CFR §63.6650(c)(2)] (3) Date of report and beginning and ending dates of the reporting period.

[40 CFR §63.6650(c)(3)] ( 4) If the permittee had a malfunction during the reporting period, the compliance report must

include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by the permittee during a malfunction of an affected source to minimize emissions in accordance with 40 CFR §63 .6605(b ), including actions taken to correct a malfunction. [40 CFR §63.6650(c)(4)]

(5) If there are no deviations from any emission or operating limitations that apply, a statement that there were no deviations from the emission or operating limitations during the reporting period. [§63.6650(c)(5)]

c) For each deviation from operating limitation that occurs for the stationary RICE where the permittee is not using a CMS to comply with the emission or operating limitations in Subpart ZZZZ of 40 CFR Part 63, the Compliance report must contain the information in paragraphs


33 Project No. 2015-02-032

(c)(l) through (4) of 40 CFR §63.6650 and the information in paragraphs (d)(l) and (2) of 40 CFR §63.6650. [40 CFR §63.6650(d)] (1) The total operating time of the stationary RICE at which the deviation occurred during the

reporting period. [40 CFR §63.6650(d)(l)] (2) Information on the number, duration, and cause of deviations (including unknown cause, if

applicable), as applicable, and the corrective action taken. [40 CFR §63.6650(c)(2)] d) The permittee must report all deviations as defined in Subpart ZZZZ of 40 CFR Part 63 in the

semiannual monitoring rep01i required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). [40 CFR §63.6650(£)]

Permit Condition EP-EG - 002

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds4

10 CSR 10-6.261 Control of Sulfur Dioxide Emissions

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

than 500 ppmv of sulfur dioxide or more than 35 mg/m3 of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three-hour time period from the Emergency Generators. [10 CSR 10-6.260(3)(A)2.]

2) The permittee must limit the fuel sulfur content of the fuel oil to no more than 8,812 parts per million (ppm). [10 CSR 10-6.261(3)(C)]

Compliance Demonstration: The permittee must determine compliance with the fuel sulfur content limitation of this permit condition as follows: l) Fuel delivery records; or 2) Fuel sampling and analysis; or 3) Fuel supplier certification letters may be used as an alternate method of compliance.

Recorkeeping: 1) The permittee must maintain fuel delivery/purchase receipts and/or fuel sampling tests as applicable

or fuel oil supplier certification letters. 2) The permittee must maintain the fuel supplier certification information to certify all fuel deliveries.

Bills of lading and/or other fuel delivery documentation containing the following information for all fuel purchases or deliveries are deemed acceptable to comply with the requirements of this rule: a) The name, address, and contact information of the fuel supplier; b) The type of fuel (diesel or#2 fuel oil); c) The sulfur content or maximum sulfur content expressed in percent sulfur by weight or in ppm

sulfur; and d) The heating value of the fuel.

3) The permittee must use fuel sampling and analysis to determine sulfur weight percent, or equivalent, of fuel(s) in accordance with 10 CSR 10-6.040. This requirement does not apply if the permittee uses the fuel supplier certification as a method of compliance.

4 IO CSR I 0-6.260 was rescinded on November 30, 2015 and replaced by 10 CSR 10-6.261; however, the provisions of IO CSR 10-6.260 currently remain in State Implementation Plan. The provisions of IO CSR I 0-6.260 will expire, once 10 CSR I 0-6.261 is incorporated into the federally-approved SIP as a final EPA action.


34 Project No. 2015-02-032

4) The permittee must retain all reports and records on-site for a minimum of five ( 5) years and make available within five (5) business days upon written or electronic request by the Director.

Reporting: 1) The permittee must furnish the Director all data necessary to determine compliance status. 2) The permittee shall report any excess emissions other than startup, shutdown, and malfunction

excess emissions already required to be reported under 10 CSR 10-6.050 to the Director for each calendar quarter within thirty (30) days following the end of the quarter. In all cases, the notification must be written and include the information listed in 10 CSR 10-6.261 (4) (A) 1.

3) The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or AirComplianceRepo1iing(c/~.dnr.mo.gov, as required by Section V of this permit.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intermediate State Operating Pem1it

IV. Core Permit Requirements

35 Project No. 2015-02-032

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.

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) Ce1iain 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.

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.


36 Project No. 2015-02-032

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.

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.

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 make such permit available within a reasonable period of time to any Missouri Department of Natural Resources personnel upon request.

10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants and 40 CFR Part 61 Subpart M National Emission Standard for Asbestos The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for any activities occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart M, National Emission Standard for Asbestos.

10 CSR 10-6.110 Reporting of Emission Data, Emission Fees and Process Information I) 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 full EI Q's per the schedule in the rule. 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 I 0-6.060 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.

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.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intem1ediate State Operating Permit

10 CSR 10-6.150 Circumvention

37 Project No.2015-02-032

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.

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

10 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.


10 CSR 10-6.250 Asbestos Abatement Projects Certification, Accreditation, and Business Exemption Requirements This is a State Only permit requirement.

38 Project No.2015-02-032

The permittee shall conduct all asbestos abatement projects within the procedures established for certification and accreditation by 10 CSR 10-6.250. This rule requires individuals who work in asbestos abatement projects to be certified by the Missouri Department of Natural Resources Air Pollution Control Program. This rule requires training providers who off er training for asbestos abatement occupations to be accredited by the Missouri Department of Natural Resources Air Pollution Control Program. This rule requires persons who hold exemption status from certain requirements of this rule to allow the department to monitor training provided to employees.

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

methods for the purpose of submission of compliance certificates: a) Monitoring methods outlined in 40 CFR Part 64; b) Monitoring method(s) approved for the permittee pursuant to 10 CSR I 0-6.065, "Operating

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

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

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

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

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

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

10 CSR 10-5.040 Use of Fuel in Hand-Fired Equipment Prohibited No owner or operator shall operate applicable hand-fired fuel burning equipment unless the owner or operator meets the conditions set forth in 10 CSR 10-5.040. This regulation shall apply to all hand-fired fuel-burning equipment at commercial facilities including, but not limited to, furnaces, heating and cooking stoves and hot water furnaces. It shall not apply to wood-burning fireplaces and wood-burning stoves in dwellings, nor to fires used for recreational purpose, nor to fires used solely for the preparation of food by barbecuing or to other equipment exempted under 10 CSR 10-5.040. Hand-fired fuel-burning equipment is any stove, furnace, or other fuel-burning device in which fuel is manually introduced directly into the combustion chamber.


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

39 Project No. 2015-02-032

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

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

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

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

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

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

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

2) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners (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.

t) 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 "MVAC" 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.


40 Project No. 20 I 5-02-032

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


V. General Permit Requirements

41 Project No. 2015-02-032

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.

Permit Duration 10 CSR 10-6.065, §(4)(C)l, §(5)(C)l.B, §(4)(E)2.C 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.

General Record Keeping and Reporting Requirements 10 CSR 10-6.065, §(4)(C)l and §(S)(C)l.C 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 available within a reasonable period of time 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 (5)(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


42 Project No.2015-02-032

emissions that exceeded the emission standards or requirements in the permit. The notice must contain a description of the emergency, the steps taken to mitigate emissions, and the corrective actions taken.

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.

Risk Management Plan Under Section 112(r) 10 CSR 10-6.065 §(4)(C)l and §(S)(C)l.D If the installation is required to develop and register a risk management plan pursuant to Section 1 l 2(R) of the Act, the permittee will verify that it has complied with the requirement to register the plan.

General Requirements 10 CSR 10-6.065(4)(C)l.A 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(5) and enforcement action for operating without a valid part 70 operating permit.


Reasonably Anticipated Operating Scenarios 10 CSR 10-6.065(4)(C)l.C There are no reasonably anticipated operating scenarios.

Compliance Requirements

43 Project No. 2015-02-032

10 CSR 10-6.065, §(4)(B)4; §(4)(C)l, §(S)(C)3.B; and §(S)(C)3.D; and §(4)(C)3 and §(S)(C)3.E.(I) - (III) and (V) - (VI) 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.


Emergency Provisions 10 CSR 10-6.065, §(4)(C)l and §(S)(C)7

44 Project No.2015-02-032

1) An emergency or upset as defined in 10 CSR 10-6.065(5)(C)7.A shall constitute an affirmative defense to an enforcement action brought for noncompliance with technology-based emissions limitations. To establish an emergency- or upset-based defense, the permittee must demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, the following: a) That an emergency or upset occurred and that the permittee can identify the source of the

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

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

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

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

Off-Permit Changes 10 CSR 10-6.065(4)(C)5 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.

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


45 Project No.2015-02-032

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.

Reopening-Permit for Cause 10 CSR 10-6.065 §(4)(E)4 and §(5)(E)6.A(III)(a)-(c) 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 ofless 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.

Statement of Basis 10 CSR 10-6.065 §(4)(E)l.A and §(5)(E)l.C 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.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-00 I 8 Intermediate State Operating Penn it

Attachment A

Installation Name Observer Name

Location Date

Sky Conditions Wind Direction

Precipitation Wind Speed

Time Emission unit

46 Project No.2015-02-032

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

0

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

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:

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

Start of observations

End of observations

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-00 l 8 Intermediate State Operating Permit

48 Project No.2015-02-032

Attachment B ( continued) Method 9 Opacity Observations

I NIA 2 NIA 3 NIA 4 NIA 5 6 7 8 9 10 l I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

The emission unit is in compliance if each six-minute average opacity is less than or equal to 20% (Boiler 4) and 40 % (Boilers 1 and 3). Exception: The emission unit is in compliance if one six-minute average opacity is greater than 20% (Boiler 4) and 40 % (Boilers 1 and 3), but less than 60 %.

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

Signature of Observer

5 l-minute avg.% opacity is the average of the four 15 second opacity readings during the minute. 6 6-minute avg.% opacity is the average of the six most recent I-minute avg.% opacities. 7 Each 15 second opacity reading shall be recorded to the nearest 5% opacity as stated within Method 9.

Buckman Laboratories, Inc. - Cadet Plant Installation ID: 221-0018 Intermediate State Operating Pem1it

Attachment C Inspection/Maintenance/Repair/Malfunction Log

Emission Unit # or CVM # ------------------

49 Project No. 2015-02-032


STATEMENT OF BASIS Voluntary Limitations

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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(4)(C)l.A.(VI), if these limitations are exceeded, the installation becomes subject to 10 CSR 10-6.065(5) 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 Buckman Laboratories was established in 1945 as a manufacturer of specialty chemicals for aqueous industrial systems. The company was founded on its unique ability to create and manufacture innovative solutions to control the growth of microorganisms. Buckman Laboratories works with industries worldwide providing advanced chemical treatment technologies and extensive technical service to provide solutions to complex industrial processing issues. Buckman's expertise spans a broad range of specialty chemicals, including microorganism control, scale inhibitors, corrosion inhibitors, polymer dispersants and defoamers. Buckman' s products are successfully applied in a number of industries, including pulp and paper, water treatment, agriculture, wood, leather, and coatings.

Buckman Laboratories established the Cadet, Missouri facility in the early 1960's. The Cadet Plant manufacturers approximately 50 types of the specialty chemicals mentioned above. The manufacturing of these products require the storage and processing of approximately 60 different raw materials. Chemical manufacturing processes are completed through a combination of blend and reaction chemistry.

Manufacturing of the specialty chemicals occur in the Cadet Plant Production Buildings, Plant 2 and Plant 3. The Production Buildings contain 15 process vessels used to react and formulate the various specialty chemical products. In addition to the process vessels, chemical manufacturing is supported by a system of approximately 100 raw material, product and utility tanks. Additional material handling and support processes include three extensive tank farm systems, railcar and tank trucking loading/unloading stations, small container storage and packing functions, and plant utility systems; including three steam boilers, one vaporizer, one chilled water unit, one emergency generator, one wastewater treatment ozone generator with four treatment tanks, and one thermal oxidizer and caustic scrubber unit. In addition to the thermal oxidizer and scrubber unit, Buckman Cadet has also installed and maintains an emergency release containment system to reduce the consequences of an accident release. The process vessels are equipped with systems to relieve pressures beyond design limits. The relief systems consist of piping, which leads from each process vessel pressure relief to a knock-out and quench tank system. Production processes are monitored and controlled by a Distributive Control System (DCS), or automated computer control system. The DCS allows for the continuous monitoring of thousands of process parameters, and allow for quick identification of process variances/deviations/upsets. The DCS is programmed to automatically correct or alarm these parameter deviations, allowing for the safe operation of the production, material handling and storage processes. In addition to the DCS, highly trained chemical operators and material handlers perform tasks required to operate the facility in a safe and environmentally responsible manner.


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Updated Potential to Emit for the Installation and Reported Air Pollutant Emissions, in tons per year

Pollutants Potential

Emissions1 2018 Particulate Matter

1.62 0.18 _s Ten Microns (PM10) Particulate Matter

1.62 0.18 < 2.5 Microns (PM2.s)

Sulfur Oxides 1.15 0.01

(SOx) Nitrogen Oxides

24.53 2.41 (NOx)

Volatile Organic Less than 0.13

Compounds (VOC) 100 Carbon Monoxide

0.61 2.02 (CO)

Hazardous Air Pollutants Less than 0.00

(HAPs) 10/25

Reported Emissions 2017 2016 2015 2014

0.18 0.22 0.23 0.19

0.18 0.22 0.23 0.19

0.01 0.01 0.01 0.01

2.41 2.95 3.11 2.57

0.13 0.16 0.17 0.14

2.02 2.48 2.61 2.16

0.00 0.00 0.00 0.00

1. The emissions of PM10, PM2s, SO,, NO,, and CO are calculated based on maximum operation (up to 8760 hours per year except the emergency generators). The maximum potential to emit for these pollutants is below the major thresholds of 100 tons per year therefore no plant-wide voluntary limit was taken.

Emissions from the emergency generators were evaluated at 500 hours of operation per year

Emissions of VOC and HAPS are limited below the major source thresholds in construction permit #092013-16 (Permit Condition PW00 1)

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 Renewal Application, received February 10, 2015; 2) Intermediate Operating Permit, Project No. 2008-03-083, Permit No. OP2010-014

Issued February 3, 2015; 3) 2017 Emissions Inventory Questionnaire, received May 1, 2018; 4) U.S. EPA document AP-42, Compilation o__f Air Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition. 5) Air Pollution Control Program Construction Permits:


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_P_erm!! Number_ _ Desctjption ____ ____ _ _______________________________ _ 0979-031 .. Bulk specialty chemical manufacturing 0979-033

0895-029

0596-031

0596-034

0596-035

0596-036

1097-026

1097-027

1097-028

Addition of processes to produce epichlorohydrin based polymers

Addition of a new reactor in the MET AM process and new product storage tank

manufacture of a new product Bis(BromoAcetoxy)-2- Butene using existing equipment with a few equipment

Batch manufacture of new product using existing

equipment

Equipment installed after 1980 without permits

Addition of centrifuge and storage tank

Modification of existing processes

Addition of HCI and formalin storage tanks

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.

See Other Regulatory Determinations

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.

1) 10 CSR 10-6.405, Restriction o_f Particulate Matter Emissions from Fuel Burning Equipment Used for Indirect Heating. This regulation does not apply to the installation. 10 CSR 10-6.405( 1 )(E) exempts installations which exclusively combust natural gas and fuel oils #2 through #6.

Construction Permit History The following revisions were made to construction permits for this installation: 1) Construction Permit #1097-026:

Permit Condition EP-CENT 001: Construction Permit # 1097-026 was issued under the premise that the centrifuge used for dewatering Busan 1059 WC would be vented to the liquor storage tank, which would then be vented to the thermal oxidizer. Based on the operating permit application and EIQ process flow diagrams, it appears that the centrifuge is vented directly to the thermal oxidizer, rather than to the liquor storage tank, which is still consistent with the intent of the construction permit. Consequently, Permit Condition EP-CENT - 001 states that emissions from the centrifuge shall be controlled by the thermal oxidizer.


2) Construction Permit #1097-028A:

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a) Construction Permit #1097-028A, Issued November 18, 1997 requires that Tank #81, a 16,000 gallon storage tank for Formalin (37% Formaldehyde Solution), be vented to the thermal oxidizer. According to the renewal application, this tank is used to store TDET BPR2. Therefore, since tank #81 does not currently store the materials described in special condition # 1 of Permit 0895-029A, EP-T81 is listed as emission unit without limitations.

b) Permit 1097-028A was also issued for the installation of a 16,000 gallon tank for hydrochloric acid (Tank 82). According to the permittee, they do not use or store any hydrochloric acid on site and the tank designated as Tank 82 is used to store PV distillate. Based on correspondence with a representative of the permittee, PV distillate is an organic liquid at atmospheric conditions with a vapor pressure of approximately 8 KPa. Since PV distillate is not of similar chemical composition to hydrochloric acid, requiring it to be vented to the thermal oxidizer would not be a logical continuation of the intention of Permit 1097-028A. Therefore, based upon current use and review of issued permits, EP-T82 is listed as an emission unit without limitations.

c) Permit 0895-029A: Special condition #3 states that emissions from tanks containing BL-2186 (Tank 64) and ethylenediamine (Tank 66) shall be controlled by venting the tanks to the thermal oxidizer. According to a representative of the permittee, BL-2186 never entered production for business reasons. Tank 64 currently contains Buchman 792 product and Tank 66 contains sulfuric acid (H2SO4). Therefore, since tanks 64 and 66 do not currently store the materials described in special condition #3 of Permit 0895-029 A, EP-T64 and EP-T66 are listed as emission units without limitations.

d) Permit No. 0596-0036A, Issued December 26, 2000; Amendment to Construction Permit No. 0596-036, 0596-0036: Special condition #1 .A states that Buckman shall implement a visual inspectionlmaintenance program for the facility to reduce process fugitive emissions from any equipment which comes in contact with any of the following materials:

Bromine, Hydrobromic Acid, Busan 90C, Dimethylamine, Ammonia, Busan 85, Monomethylamine, Unitol Alk, Ester 80, DMATO, Nabonate, Metam Concentrate, Kn-Methyl, Busan 1020, Busan 881, Busan 1058, and BL-1182, 1,2-Butylene Oxide, Carbon Disulfide, Diethylene Glycol, Formaldehyde, Methanol, Methylene Chloride, P-mix, Phosphorous Acid 70%, Phosphorous Trichloride, SKW cyanamid L500, and TMEDA 85.

The following materials: Bromine, Hydrobromic Acid, Busan 90C, Busan 85, Unitol Alk, 1,2-Butylene Oxide, P-mix, and SK W Cyanamid L500 are no longer being processed and are notore not included in this permit.

New Source Performance Standards (NSPS) Applicability 10 CSR 10-6.070, New Source Performance Regulations. The installation is potentially subject to several NSPS rules. Below is a summary of the potentially applicable subparts and the facilities applicability and compliance status to those subparts. 1) 40 CFR Part 60 - Subpart A, General Provisions.

The installation becomes subject to Subpart A - General Provisions upon becoming subject to an NSPS standard. If the installation is subject to various NSPS Standards; therefore, they are also subject to Subpart A.


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2) 40 CFR Part 60 - Subpart D, Standards of Pe1formance for Fossil-Fuel-Fired Steam Generators for Which Construction is Commenced After August 17, 1971. The provisions of this subpart apply to each fossil-fuel-fired steam generating unit of more than 73 megawatts (MW) heat input rate (250 million Btu per hour (MMBtu/hr)) and/or each fossil-fuel and wood-residue fired steam generating unit capable of firing fossil fuel at a heat input rate of more than 73 MW (250 MMBtu/hr).

A fossil-fuel-fired steam generating unit is a furnace or boiler used that burns fossil fuels to produce steam by heat transfer. A fossil fuel and wood residue-fired team generating unit is a furnace or boiler that burns fossil fuel and wood residue to produce steam by heat transfer. Fossil fuels are natural gas, petroleum, coal, and any form of solid, liquid, or gaseous fuel derived from such materials for the purpose of creating useful heat (vs. solid waste reduction). Wood residue is bark, sawdust, slabs, chips, shavings, mill trim, and other wood products derived from wood processing and forest management operations.

The installation has four (4) natural gas and fuel oil #2 fired boilers - None of these boiler has a heat input rate at or more than 250 MMBTU/hr. Therefore, the Facility is not subject to this NSPS Standard.

3) 40 CFR Part 60 - Subpart Da, Standards of Performance for Electric Utility Steam Generating Units for Which Construction is commenced After September 18, 1978. This subpart applies to each electric steam generating unit that commences construction, modification, or reconstruction after September 18, 1978, and has a heat input capacity greater than 73 megawatts (MW) (250 million British thermal units per hour - MMBtu/hr) from combusting fossil fuels.

An electric utility steam-generating unit is any steam electric generating unit that is constructed for the purpose of supplying more than one-third of its potential electric output capacity and more than 25 MW net-electrical output to any utility power distribution system for sale. Also, any steam supplied to a steam distribution system for the purpose of providing steam to a steam-electric generator that would produce electrical energy for sale is considered in determining the electrical energy output capacity of the affected Facility. Fossil fuel are natural gas, petroleum, coal, and any form of solid, liquid, or gaseous fuel derived from such material for the purpose of creating useful heat.

The installation has four ( 4) boilers - None of the boilers are electric utility steam-generating units. Therefore, the installation is not subject to this NSPS Standard.

4) 40 CFR Part 60 - Subpart Db, Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units. This subpart applies to each steam generating unit that commences construction, modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam generating unit of greater than 29 megawatts (MW) (100 million British thermal units per hour (MMBtu/hr).

A steam generating unit is a device that combusts any fuel or byproduct/waste and produces steam or


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heats water or heats any heat transfer medium. This term includes any municipal-type solid waste incinerator with a heat recovery steam generating unit or any steam generating unit that combusts fuel and is part of a co generation system or a combined cycle system. This term does not include process heaters.

The installation has four ( 4) boilers - Only boiler #4 was installed after June 19, 1984. The heat input capacity boiler #4 boilers is not greater than 100 MMBtu /hr. Therefore, the installation is not subject to this NSPS Standard.

5) 40 CFR Part 60 - Subpart De, Standards· cl Performance for Small Industrial-CommercialInstitutional Steam Generating Units. This subpart applies to each steam generating unit that commences construction, modification, or reconstruction after June 9, 1989, and that has a heat input capacity from fuels combusted in the steam generating unit of 29 megawatts (MW) ( 100 million British thermal units per hour (MMBtu/hr) or less, but more than 2.9 MW (10 MMBtu/hr).

A steam generating unit is a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium. This term includes any duct burner that combusts fuel and is part of a combined cycle system. This term does not include process heaters as defined in this subpart.

The installation has four ( 4) boilers - None of the boilers were installed after June 19, 1989. Therefore, the installation is not subject to this NSPS Standard.

6) 40 CFR Part 60 - Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids. This subpart applies to each petroleum liquid storage vessel with a storage capacity greater than 151,412 liters (40,000 gallons), but not exceeding 246,052 liters (65,000 gallons), and commenced construction or modification after March 8, 1974, and prior to May 19, 1978. Additionally, this subpart also applies to each petroleum liquid storage vessel with a storage capacity greater than 246,052 liters (65,000 gallons) and commenced construction or modification after June 11, 1973, and prior to May 19, 1978.

A Petroleum liquid is any petroleum, condensate, and any finished or intermediate products manufactured in a petroleum refinery but does not include Nos. 2 through 6 fuel oils, gas turbine fuel oils Nos. 2-GT through 4-GT, or diesel fuel oils Nos. 2-D and 4-D.

The installation has three diesel fuel storage tanks. Diesel fuel is not included as a petroleum liquid according to this subpart. Therefore, the installation is not subject to this NSPS Standard.

7) 40 CFR Part 60 - Subpart Ka, Standards ()f Performance for Storage Vessels for Petroleum Liquids· for Which Construction, Reconstruction Or Modification Commenced After May 19, 1978, and Prior to July 23, 1984. This subpart applies to each petroleum liquid storage vessel with a storage capacity greater than 151,412 liters (40,000 gallons) and commenced construction after May 18, 1978.

A Petroleum liquid is any petroleum, condensate, and any finished or intermediate products manufactured in a petroleum refinery but does not include Nos. 2 through 6 fuel oils, gas turbine fuel oils Nos. 2-GT through 4-GT, or diesel fuel oils Nos. 2-D and 4-D.


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The installation has three diesel fuel storage tanks. Diesel fuel is not included as a petroleum liquid according to this subpart. Therefore, the installation is not subject to this NSPS Standard.

8) 40 CFR Part 60 - Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessefa) for Which Construction, Reconstruction Or Modification Commenced After July 23, 1984. This subpart applies to any tank storing a volatile liquid with a design capacity greater than or equal to 75 cubic meters (m3

) (19,800 gal) but less than 151 m3 storing a liquid with a maximum true vapor pressure less than 15.0 kPa (2.2 psia )that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. Note -Volatile organic liquid (VOL) as defined in this subpart means any organic liquid which can emit volatile organic compounds into the atmosphere except those VOL's that emit only those compounds which the Administrator has determined do not contribute appreciably to the formation of ozone.

Tanks #51 and #52 (EP-T5 l and EP-T52) are storage vessels with capacities greater than 7 5 m3 but less than 151 m3 and are used for storing volatile organic liquids. Tank #51 stores WSCP, which has an approximate vapor pressure of 1.65 KPa. Tank #52 stores Tall Oil Fatty Acid (TOF A), which has an approximate vapor pressure of 0.3 KPa. According to 40 CFR 60.11 0b(b ), they are exempt from the requirements of Subpart Kb because the maximum true vapor pressures of the volatile organic liquids currently stored are less than 15 KPa.

9) 40 CFR Part 60 - Subpart VV, Standards of Performance for Equipment Leaks ofVOC in the Synthetic Organic Chemicals Manufacturing Industry for which Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Befhre November 7, 2006. Subpart VY applies to manufacturing facilities that produce as an intermediate or final product any chemical listed in §60.489. The rules and regulations found in this subpart regulate a variety of process equipment components in VOC service. Exemptions to the requirements of this rule exist on a case by case analysis of the applicable process components.

Buchman operates a synthetic organic chemicals manufacturing facility with equipment constructed, reconstructed, or modified after January 5, 1981, and on or before November 7, 2006. The following emission units are subject to this subpart:

• Distillation Columns (EP-Cl and EP-C2) • Process Vessels (EP-PV4, EP-PV5, and EP-PVl 0) • TMEDA Fractional Column (EP-R4Cl) • Storage Tanks (EP-T6, EP-T8, EP-T33, EP-T38, EP-T42, EP-T43, and EP-T87)

10) 40 CFR Part 60, Subpart NNN, Standards of Pe,formancefor Volatile Organic Compound (VOC) Emissions From Synthetic Organic Chemical Manufacturing Industry (SOCMI) Distillation Operations. The provisions of this subpart apply to each affected facility designated in paragraph (b) of §60.660 that is part of a process unit that produces any of the chemicals listed in §60.667 as a product, coproduct, by-product, or intermediate, except as provided in §60.660 (c).


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The affected facility is any of the following for which construction, modification, or reconstruction commenced after December 30, 1983:

• Each distillation unit not discharging its vent stream into a recovery system. • Each combination of a distillation unit and the recovery system into which its vent stream is

discharged. • Each combination of two or more distillation units and the common recovery system into

which their vent streams are discharged.

The permittee is a batch manufacturer of organic chemicals, therefore the pe1mittees batch manufacturing distillation processes are exempt from the requirements of this subpart in accordance with 40 CFR 60.660(c)(3) which states, "Any distillation unit that is designed and operated as a batch operation is not an affected facility."

11) 40 CFR Part 60, Subpart RRR, Standards of Performance for Volatile Organic Compound Emissions From Synthetic Organic Chemical Manufacturing Industry (SOCMI) Reactor Processes. The provisions of this subpart apply to each affected facility designated in §60.700(6) that is part of a process unit that produces any of the chemicals listed in §60.707 as a product, co-product, byproduct, or intermediate, except as provided in §60.700(c).

The affected facility is any of the following for which construction, modification, or reconstruction commenced after June 29, 1990:

• Each reactor process not discharging its vent stream into a recovery system. • Each combination of a reactor process and the recovery system into which its vent stream is

discharged. • Each combination of two or more reactor processes and the common recovery system into

which their vent streams are discharged.

The permittee is a batch manufacturer of organic chemicals, therefore the permittees batch manufacturing reactor processes are exempt from the requirements of this subpart in accordance with 40 CFR 60.700(c)(l) which states, "Any reactor process that is designed and operated as a batch operation is not an affected facility."

12) NSPS Applicability Summary The installation is subject to the following NSPS Standards:

• 40 CFR Part 60 - Subpart VV, Standards of Performance for Equipment Leaks ofVOC in the Synthetic Organic Chemicals Manufacturing Industry.

Maximum Achievable Control Technology (MACT) Applicability 10 CSR 10-6.075, Maximum Achievable Control Technology Regulations. The installation is potentially subject to several MACT rules. Below is a summary of the potentially applicable subparts and the facilities applicability and compliance status to those subparts.

Industries subject to MACT standards are classified as either major sources or area sources. • Major sources are sources that emit 10 tons per year of any of the listed HAPs, or 25 tons per

year of a mixture of HAPs.


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• Area sources are sources that emit less than 10 tons per year of a single HAP or less than 25 tons per year of a combination of HAPs.

The installation has the potential to emit various HAPs.

1) 40 CFR Part 63, Subpart ZZZZ - National Emissions Standards.for Hazardous Air Pollutants.for Stationary Reciprocating Internal Combustion Engines (RICE). The Subpart ZZZZ standards are applicable to Reciprocating Internal Combustion Engines (RICE) located at both major and/or area sources of hazardous air pollutants (HAPs) and RICE with a site rating of less than or equal to 500 brake horsepower (bhp ). In addition, the standards for existing non-emergency compression ignition (CI) engines with a site rating of greater than 500 bhp at major sources and revised provisions related to Startup, Shutdown, and Malfunction (SSM) events for engines previously regulated under the rule. Finally, emergency RICE with a rating greater than 500 bhp located at a major source are subject to this rule, but with limited requirements.

The installation operates standby diesel generator and dual fire pumps/engines whose operations are limited to emergency situations. The engine was installed prior to June 12, 2006 and according to §63.6590(a)9l)(iii) of this subpart, stationary RICE located at an area source of HAP emissions is existing if commenced construction or reconstruction before June 12, 2006. The engines are subject to the Work Practice Standards, Maintenance Plan, Monitoring, and Recordkeeping requirements. Therefore, this subpart applies.

Note: On May 1, 2015, the U.S. Court of Appeals for the District of Columbia Circuit issued a Decision vacating paragraphs 40 CFR 63.6640(f)(2)(ii)-(iii). Therefore, these paragraphs are not applied within Permit Condition EP-EG- 001.

2) 40 CFR Part 63 Subpart DDDDD - National Emission Standards.for Hazardous Air Pollutants.for Industrial, Commercial, and Institutional Boilers and Process Heaters. The Subpart applies to a facility that owns or operates industrial boilers, institutional boilers, commercial boilers, and process heaters that is a major source, or is located at a major source, or is part of a major source of HAP emissions. A process heater is defined as a unit in which the combustion gases do not directly come into contact with process material or gases in the combustion chamber ( e.g., indirect fired). A boiler is defined as an enclosed device using controlled flame combustion and having the primary purpose of recovering thermal energy in the form of steam or hot water.

HAPS are limited below the major source thresholds (10/25 tons per year) in construction permit #092013-16 (Permit Condition PW00l); therefore the installation is not subject to this subpart.

3) 40 CFR Part 63, Subpart JJJJJJ - National Emission Standards.for Hazardous Air Pollutants.for Industrial, Commercial, and Institutional Boilers Area Sources. This subpart applies to boilers at area source facilities that bum coal, oil, biomass, or non-waste materials. Boilers burning natural gas as defined in this regulation would not be affected by the subpart.

This regulation does not apply to the boilers because these boilers are natural gas and fuel fired units. The rule exempts boilers fired with these types of fuels. According to this rule, gas-fired boiler


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includes any boiler that burns gaseous fuels not combined with any solid fuels, burns liquid fuel only during periods of gas curtailment, gas supply emergencies, or periodic testing on liquid fuel.

4) MACT Applicability Summary: Buchman is currently area source HAPs. Based upon a comparison of the installations operations to each MACT Standard (area and major standards), the installation is subject to the following MACT Standard: • Subpart ZZZZ - Reciprocating Internal Combustion Engines (RICE) - 40 CFR 63.6580

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants. National Emission Standards for Hazardous Air Pollutants (NESHAPS) are stationary source standards for hazardous air pollutants. NESHAPS were originally required by the 1970 Clean Air Act (CAA). These standards were developed for sources and source categories that were determined to pose adverse risk to human health by the emission of HAPs. The Part 61 NESHAPs regulate only 7 hazardous air pollutants - Asbestos, Beryllium, Mercury, Vinyl Chloride, Benzene, Arsenic, Radon/Radionuclides. Prior to 1990, the Clean Air Act required EPA to set standards for each toxic air pollutant individually, based on its particular health risks. Thus, NESHAPs are risk based standards that apply to all existing and new/ modified sources regardless if they are a minor or major HAP Facility. (NOTE: This is not an analysis of every NESHAP standard; it is an analysis of the NESHAP standard that is potentially applicable to the installation). 1) 40 CFR Part 61, Subpart F, National Emission Standard/or Vinyl Chloride.

The Subpart F NESHAP applies to facilities that produce vinyl chloride as a final product. The process equipment produces a very small amount (less than 2 parts per million in the liquid material) of vinyl chloride impurities, but does not produce vinyl chloride as a final product. Therefore, Subpart F is not applicable.

2) 40 CFR Part 61 Subpart M National Emission Standard/or Asbestos. The installation is not subject to any NESHAP standard with the exception of Subpart M - National Emission Standard for Asbestos. The installation is potentially subject to Subpart M. If the installation conducts any demolition or renovation projects to a building(s) containing asbestos, they must determine applicability with the following NESHAP regulations: • Demolition and Renovation - 40 CFR 61.145 • Waste Disposal for Manufacturing, Fabricating, Demolition, Renovation, and Spraying - 40 CFR

61.150

3) 40 CFR Part 61, Subpart FF, National Emission Standard for Benzene Waste Operations. Subpart FF NESHAP applies to owners and operators of chemical manufacturing plants. Based on the permittees SIC code (2899), they are part of Division D: Manufacturing, Major Group 28: Chemicals and Allied Products, 2899: Chemicals and Chemical Preparations, Not Elsewhere Classified, and thus subject to the rules and regulations of Subpart FF. The review of the permittees manufacturing operation indicates that benzene waste would not be expected at their facility. If the permittee exceeds the limits prescribed by permit condition PW002, they will be subject to more stringent requirements located in Subpart FF. It is the permittees responsibility to familiarize themselves with all pertinent contents in Subpart FF regarding the generation of benzene waste.


Greenhouse Gas Emissions

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Note that this source may be subject to the Greenhouse Gas Reporting Rule. However, the preamble of the GHG Reporting Rule clarifies that Part 98 requirements do not have to be incorporated in operating permits at this time. In addition, Missouri regulations do not require the installation to report CO2 emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2 emissions were not included within this permit. If 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 1) 10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants.

• Boiler # 1, Boiler #3, and Boiler #4 are dual fuel boilers, capable of com busting natural gas and fuel oil, while Boiler #2 combusts natural gas only. The installation also operates natural gas burners associated with the thermal oxidizer (EP-TOX) and the Ozone Destruct Unit. This regulation was not applied to units combusting natural gas, as it is highly unlikely that these units would ever exceed the opacity requirements listed in the regulation.

• Internal Combustion Engine (Distillate Oil): According to 10 CSR 10-6.220(1 )(A), stationary internal combustion engines operated in the St. Louis metropolitan area are exempt from the requirements of this rule.

2) 10 CSR 10-6.260, Restriction of Emissions of Sulfur Compounds and 10 CSR 10-6.261, Control of Sul.fur Dioxide Emissions. 10 CSR 10-6.260 was rescinded on November 30, 2015 and replaced by 10 CSR 10-6.261; however, the provisions of 10 CSR 10-6.260 currently remain in State Implementation Plan. The provisions of 10 CSR 10-6.260 will expire, once 10 CSR 10-6.261 is incorporated into the federally-approved SIP as a final EPA action. • 10 CSR 10-6.260(3)(A)2. and 10 CSR 10-6.261(3)(C) apply to Boiler #1, Boiler #3, Boiler #4,

emergency generator, and fire pumps. • According to 10 CSR 10-6.260(l)(A)(2), natural gas fired sources are exempt from the

requirements of 10 CSR 10-6.260.

According to the exception in 10 CSR 10-6.26l(l)(A), the permittee is required to comply with the record keeping requirement in 10 CSR 10-6.261 ( 4) for SO2 emitting sources com busting natural gas to determine the exception.

3) Emission Units Without Limitations: The emission units listed as units without limitations are not subject to any specific rule except the installation wide requirements of Permit Condition PW00l: 10 CSR 10-6.065(2)(C) and 10 CSR 10-6.065(5)(A) Voluntary Limitation(s).


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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 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

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The draft Intermediate Operating Permit for Buckman Laboratories, Inc. - Cadet Plant was placed on public notice June 7, 2019 for a 30-day comment period. The public notice was published on the Department of Natural Resources' Air Pollution Control Program's web page at: https://dnr.mo.gov/env/apcp/permit-public-notices.htm. The Air Pollution Control Program did not receive any public comments during the 30-day comment period.