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PERr,1JT BOOK STATE OF MISSOURI G~ ~ DEPARTMENT OF NATURAL RESOURCES MISSOURI AIR CONSERVATION COMMISSION PERMIT TO CONSTRUCT Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein. Permit Number: 0 3 2 00 7 - 0 1 0 Parent Company: Project Number: 2006-12-013 Southeast Cooperative Service Company Parent Company Address: P.O. Box 340, Advance, MO 63730 Insta"ation Name: Facility Southeast Cooperative Service Company - Dexter Insta"ation Address: Hwy 25 South, Dexter, MO 63841 Location Information: Stoddard County, S27, T25N, R10E Application for Authority to Construct was made for: A bulk fertilizer and fuel facility. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.. D rr Standard Conditions (on reverse) are applicable to this permit. Standard Conditions (on reverse) and Special Conditions are applicable to this permit. MAR 2 9 2007 EFFECTIVE DATE STANDARD CONDITIONS: Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit. Permittee should notify the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit, or if construction or modification is suspended for one year or more. You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. In the event that there is a discrepancy between the permit application and this permit, the conditions of this permit shall take precedence. Specifically, all air contaminant control devises shall be operated and maintained as specified in the application, associated plans and specifications. You must notify the department’s Air Pollution Control Program of the anticipated date of start up of this (these) air contaminant sources(s). The information must be made available not more than 60 days but at least 30 days in advance of this date. Also, you must notify the Department of Natural Resources Regional office responsible for the area within which you are located with 15 days after the actual start up of this (these) air contaminant source(s). A copy of this permit and permit review shall be kept at the installation address and shall be made available to Department of Natural Resources’ personnel upon request. You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.075.6 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC. If you choose not to appeal, this certificate, the project review and your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant sources(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances. The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit at (573) 751-4817. If you prefer to write, please address your correspondence to the Missouri Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176, attention: Construction Permit Unit. Page No. 3 Permit No. Project No. 2006-12-013 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions: The special conditions listed in this permit were included based on the authority granted the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10 CSR 10-6.060 paragraph (12)(A)10. “Conditions required by permitting authority.” Southeast Cooperative Service Company - Dexter Facility Stoddard County, S27, T25N, R10E 1. 2. Particulate Matter Emission Limitation A. Southeast Cooperative Service Company - Dexter Facility shall emit less than 15 tons of particulate matter less than ten (10) microns in diameter (PM10) in any consecutive 12 month period from the bulk fertilizer facility, which includes receiving (EP-1,) conveying (EP-2,) mixing (EP-3) and shipping (EP-4). B. Southeast Cooperative Service Company - Dexter Facility shall maintain an accurate record of PM10 emitted into the atmosphere from the bulk fertilizer facility. Attachment A or an equivalent form shall be used for this purpose. Southeast Cooperative Service Company - Dexter Facility shall maintain all records required by this permit for not less than five (5) years and shall make them available immediately to any Missouri Department of Natural Resources’ personnel upon request. C. Southeast Cooperative Service Company - Dexter Facility shall report to the Air Pollution Control Program’s Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102, no later than ten (10) days after the end of the month during which the records from Special Condition Number 1.B indicate that the source exceeds the limitation of Special Condition Number 1.A. Volatile Organic Compound Emission Limitation A. Southeast Cooperative Service Company - Dexter Facility shall emit less than 40 tons of Volatile Organic Compounds (VOCs) in any consecutive 12-month period from the following equipment: diesel storage tanks (EP5,) the ethanol storage tanks (EP-6,) the unleaded gasoline storage tanks (EP-7) and the kerosene storage tanks (EP-8). B. Attachment B and Attachment C or equivalent forms approved by the Air Pollution Control Program shall be used to demonstrate compliance with Special Conditions 2.A. Southeast Cooperative Service Company Dexter Facility shall maintain all records required by this permit for not less Page No. 4 Permit No. Project No. 2006-12-013 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions: than five (5) years and shall make them available immediately to any Missouri Department of Natural Resources’ personnel upon request. These records shall include Material Safety Data Sheets (MSDS) for all fuels used in the fuel tanks. C. Southeast Cooperative Service Company - Dexter Facility shall report to the Air Pollution Control Program’s Enforcement Section, P.O. Box 176, Jefferson City, Missouri 65102, no later than ten (10) days after the end of the month during which the records from Special Condition Number 2.B indicate that the source exceeds the limitation of Special Conditions Number 2.A. REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW Project Number: 2006-12-013 Installation ID Number: 207-0051 Permit Number: Southeast Cooperative Service Company - Dexter Facility Hwy 25 South Dexter, MO 63841 Parent Company: Southeast Cooperative Service Company P.O. Box 340 Advance, MO 63730 Complete: 12/04/2006 Reviewed: 01/23/2007 Stoddard County, S27, T25N, R10E REVIEW SUMMARY • Southeast Cooperative Service Company - Dexter Facility has applied for authority to construct a bulk fertilizer and fuel facility. • Hazardous Air Pollutant (HAP) emissions are not expected from the proposed equipment. • None of the New Source Performance Standards (NSPS) apply to the proposed equipment. Specifically, the applicability requirements of subparts Kb, X and XX are not met. • None of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) or currently promulgated Maximum Achievable Control Technology (MACT) regulations apply to the proposed equipment. • No air pollution control equipment is being used in association with the new equipment. • This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of VOCs and PM10 are conditioned below de minimis levels. • This installation is located in Stoddard County, an attainment area for all criteria air pollutants. • This installation is not on the List of Named Installations [10 CSR 10-6.020(3)(B), Table 2]. • Ambient air quality modeling was not performed since potential emissions of the -5- application are below de minimis levels. • Emissions testing is not required for the equipment. • No Operating Permit is required for this installation. • Approval of this permit is recommended with special conditions. INSTALLATION DESCRIPTION The Southeast Cooperative Service Company installation in Dexter is a bulk fertilizer and fuel distributor. The fuel facility, which was built in 1986, is comprised of four (4) diesel, two (2) ethanol, three (3) unleaded gasoline and two (2) kerosene tanks. The bulk fertilizer facility, which was built in 1994, processes fertilizer composed of diammonium phosphate, ammonium sulfate, potash, triple superphosphate and urea. The installation is a de minimis source and is not required to obtain an operating permit. No permits have been issued to Southeast Cooperative Service Company - Dexter Facility from the Air Pollution Control Program. Both the bulk fertilizer and fuel facilities were constructed without obtaining a permit. PROJECT DESCRIPTION The bulk fertilizer facility receives the fertilizer components and conveys them to a mixer. From the mixer, fertilizer is loaded out to customers. The maximum hourly design rate for this process is 50 tons of fertilizer per hour. The fuel facility receives fuel shipments from tanker trucks and distributes that fuel to local farmers and fuel venders. EMISSIONS/CONTROLS EVALUATION The emission factors and control efficiencies used in this analysis were obtained from the Environmental Protection Agency (EPA) document AP-42, Compilation of Air Pollutant Emission Factors, Fifth Edition, section 8.3 Ammonium Nitrate, July 1993 and the Tanks 4.0 program. Potential emissions of the application represent the potential of the new equipment, assuming continuous operation (8760 hours per year.) The following table provides an emissions summary for this project. -6- Table 1: Emissions Summary (tons per year) Pollutant Regulatory De Minimis Levels Existing Potential Emissions Existing Actual Emissions (2005 EIQ) Potential Emissions of the Application New Installation Conditioned Potential PM10 15.0 N/A 0.14 17.52 < 15 SOx 40.0 N/A N/A N/A N/A NOx 40.0 N/A N/A N/A N/A VOC 40.0 N/A 0.30 56.89 < 40 CO 100.0 N/A N/A N/A N/A HAPs 10.0/25.0 N/A N/A N/A N/A *N/A = Not Applicable; N/D = Not Determined PM10 emissions are associated with the bulk fertilizer facility. VOC emissions are associated with the eleven (11) fuel storage tanks. PERMIT RULE APPLICABILITY This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of VOCs and PM10 are conditioned below de minimis levels. APPLICABLE REQUIREMENTS Southeast Cooperative Service Company - Dexter Facility shall comply with the following applicable requirements. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. Compliance with these emission standards, based on information submitted in the application, has been verified at the time this application was approved. GENERAL REQUIREMENTS • Submission of Emission Data, Emission Fees and Process Information, 10 CSR 10-6.110 The emission fee is the amount established by the Missouri Air Conservation Commission annually under Missouri Air Law 643.079(1). Submission of an Emissions Inventory Questionnaire (EIQ) is required April 1 for the previous year's emissions. • Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin, 10 CSR 10-6.170 • Restriction of Emission of Visible Air Contaminants, 10 CSR 10-6.220 • Restriction of Emission of Odors, 10 CSR 10-3.090 -7- SPECIFIC REQUIREMENTS • Restriction of Emission of Particulate Matter From Industrial Processes, 10 CSR 10-6.400 STAFF RECOMMENDATION On the basis of this review conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required, I recommend this permit be granted with special conditions. Michael Mittermeyer Environmental Engineer Date PERMIT DOCUMENTS The following documents are incorporated by reference into this permit: • The Application for Authority to Construct form, dated 11/06/2006, received 12/04/2006, designating Southeast Cooperative Service Company as the owner and operator of the installation. • U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors, Fifth Edition. • Southeast Regional Office Site Survey. -8- Attachment A – PM10 Compliance Worksheet Southeast Cooperative Service Company - Dexter Facility Stoddard County, S27, T25N, R10E Project Number: 2006-12-013 Installation ID Number: 207-0051 Permit Number: This sheet covers the period from to (month, year) Month Example Fertilizer Produced (tons) 4000 . (month, year) 1 PM10 Emission Factor (lbs/ton) 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 Monthly PM10 Emissions (lbs) 320 2 Monthly PM10 Emissions (tons) 0.16 3 12-Month Total PM10 Emissions (tons) 1.92 1. Monthly PM10 Emissions (lbs) are calculated by multiplying the monthly Fertilizer Produced by the PM10 Emission Factor. 2. Monthly PM10 Emissions (tons) are calculated by dividing the Monthly PM10 Emissions (lbs) by 2000. 3. 12-Month Total PM10 Emissions (tons) are calculated by adding the Monthly PM10 Emissions (tons) of the previous 11 months with the current Monthly PM10 Emissions (tons) -9- Attachment B - Monthly Working Loss Tracking Sheet Month Unleaded Gas Received (1000 gal) Example 2 Unleaded Working Loss Emission Factor VOC Emissions (lbs/1000 gal) (lbs) 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 2.26 Ethanol Received (1000 gal) 0.5 Ethanol Emission Working Loss Diesel Emission Working Loss Factor VOC Emissions Diesel Received Factor VOC Emissions (lbs/1000 gal) (lbs) (1000 gal) (lbs/1000 gal) (lbs) 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.153 0.0765 1. To calculate the Working Loss VOC Emissions, multiply the monthly fuel received by the corresponding emission factor. 2. To calculate the Total Working Loss VOC Emissions, add the four Working Loss VOC Emissions for each fuel. 6 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.00424 0.0254 Kerosene Received (1000 gal) 0.2 Kerosene Working Loss Emission Factor VOC Emissions (lbs/1000 gal) (lbs) 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00755 0.00151 Total Working Loss VOC Emissions (lbs) 2.36 Attachment C – VOC Compliance Worksheet Southeast Cooperative Service Company - Dexter Facility Stoddard County, S27, T25N, R10E Project Number: 2006-12-013 Installation ID Number: 207-0051 Permit Number: This sheet covers the period from to (month, year) 1 Month Example Working Loss VOC Emissions (lbs) 2.36 . (month, year) 4 Breathing Loss VOC Emissions (lbs) 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 85.62 2 Total VOC Emissions (lbs) 87.98 3 Total VOC Emissions (tons) 0.0440 12-Month Total VOC Emissions (tons) 1.30 1. Working Loss VOC Emissions from Monthly Working Loss Tracking Sheet. 2. Total VOC Emissions (lbs) are calculated by adding the Working Loss VOC Emissions and the Breathing Loss VOC Emissions. 3. Monthly VOC Emissions (tons) are calculated by dividing the Monthly VOC Emissions (lbs) by 2000. 4. 12-Month Total VOC Emissions (tons) are calculated by adding the Monthly VOC Emissions (tons) of the previous 11 months with the current Monthly VOC Emissions (tons) - 10 - Mr. Mike Galloway Plant Manager Southeast Cooperative Service Company - Dexter Facility Hwy 25 South Dexter, MO 63841 RE: New Source Review Permit - Project Number: 2006-12-013 Dear Mr. Galloway: Enclosed with this letter is your permit to construct. Please study it carefully. Also, note the special conditions, if any, on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files. Operation in accordance with these conditions and your new source review permit application is necessary for continued compliance. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri. If you have any questions regarding this permit, please do not hesitate to contact me at (573) 751-4817, or you may write to me at the Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102. Sincerely, AIR POLLUTION CONTROL PROGRAM Kendall B. Hale New Source Review Unit Chief KBH:mml Enclosures c: Southeast Regional Office PAMS File 2006-12-013 Permit Number:

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