17
Michael L. Parson, Governor 2 9 2019 Ms. Gael Rasa Environmental Supervisor Ingredion, Incorporated 1001 Bedford A venue North Kansas City, MO 64115 RE: New Source Review Permit - Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter is your permit to construct. Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit. Also, note the special conditions on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files. Operation in accordance with these conditions, your new source review permit application and with your amended operating permit is necessary for continued compliance. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri. This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CAV) can be set up with you. To request a CA V, please contact your local regional office or fill out an online request. The regional office contact information can be found at the following website: http://dm.mo.gov/regions/. The online CAV request can be found at http://dm.mo.gov/cav/compliance.htm. If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: www.oa.mo.gov/ahc. Recycled paper

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Page 1: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

Michael L. Parson, Governor

2 9 2019 Ms. Gael Rasa Environmental Supervisor Ingredion, Incorporated 1001 Bedford A venue North Kansas City, MO 64115

RE: New Source Review Permit - Project Number: 2018-08-070

Dear Ms. Rasa:

Carol S. Comer, Director

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

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

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: www.oa.mo.gov/ahc.

Recycled paper

Page 2: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

Ms. Gael Rasa Page Two

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

Sincerely,

AI?5£RPO~L\UTIOlCONTROLPROGRAM I j ·."

', /

~ Susan Heckenkamp New Source Review Unit Chief

SH:shj

Enclosures

c: Kansas City Regional Office PAMS File: 2018-08-070

Permit Number: 042019-016

Page 3: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

~§MISSOURI ~11 !'I>, I DEPARTMENT OF l_gJ ~ 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: 4 9 0 16 Project Number: 2018-08-070 0 2 0 1 - Installation Number: 047-0002

Parent Company: lngredion, Incorporated

Parent Company Address: 1001 Bedford Avenue, North Kansas City, MO 64116

Installation Name:

Installation Address:

Location Information:

lngredion, Incorporated

1001 Bedford Avenue, North Kansas City, MO 64116

Clay County, S23, T50N, R33W

Application for Authority to Construct was made for: Modification of the sodium sulfate (salt) unloading operations. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.

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

[Z] Standard Conditions (on reverse) and Special Conditions are applicable to this permit.

Director or Designee Department of Natural Resources

APR 2 9 2019

Effective Date

Page 4: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

STANDARD CONDITIONS:

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

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

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

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

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

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

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

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

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

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

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Page 5: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

SPECIAL CONDITIONS:

Project No. 2018-08-070 Permit No.

042019-01 1

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

The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10 CSR 10-6. 060 paragraph (12)(A) 10. "Conditions required by permitting authority."

lngredion, Incorporated Clay County, S23, T50N, R33W

1. HAPs Emission Limitations A. lngredion, Incorporated shall emit less than 10.0 tons individually and 25.0

tons combined of HAPs in any consecutive 12-month period from the entire installation.

B. lngredion, lncorporatedshall develop and use forms to demonstrate compliance with Special Condition 1.A. The forms shall contain at a minimum the following information, 1) Installation name 2) Installation ID 3) Permit number 4) Current month 5) Current 12-month date range 6) Monthly throughput for each emission unit with the potential to emit

a HAP 7) HAP emission factors for each emission unit:

a. HCI Tanks (T2, T3, T31): i. Breathing and working losses - use equations from

AP-42 Section 7.1.3.1 related to fixed roof tank emissions

b. Epichlorohydrin Drums (T22): i. Breathing and working losses - use equations from

AP-42 Section 5.2 Equation 1 c. Natural gas combustion sources (EP17 Gluten Dryer, EP20

to EP23: Starch flash dryer #1 to #4): i. Combined HAPs emission factor= 1.889 lb/MMscf

(obtained from AP-42 Section 1.4, July 1998). d. Diesel Fire Pump

i. Combined HAPs emission factor= 0.554 lb1000 gal (obtained from webFIRE for sec 2-02-001-02)

e. Piping losses (EP70): Using equations from EPA Protocol for Equipment Leak Emission Estimates, Table 2-1 (EPA Doc. No. EPA-453/R-95-017)

f. Reaction Tanks #3: 0.1 tons of propylene oxide per ton of production

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Page 6: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

SPECIAL CONDITIONS:

Project No. 2018-08-070 Permit No.

042019-016

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

8) Monthly emissions for each emission unit calculated using the following equation:

a. Monthly breathing losses in tanks (ton/month): Annual Emissions/ 12 months

b. All other emission units (ton/month): Monthly throughput x emission unit specific emission factor

9) Monthly emissions of each calculated by summing all individual HAP emissions

10) 12-month rolling total emissions for each individual HAP and the sum of all individual emissions from startup, shutdown, and malfunction as reported the Air Pollution Control Program's Compliance/Enforcement Section

11) 12-month rolling total emission for all combined HAPs 12) Indication of compliance with Special Condition 1.A for each

individual HAP and combined HAPs.

2. Control Device Requirement - Baghouses A. lngredion, Incorporated shall control the particulate emissions from the

Truck/Rail Unloading (EP89) and the Sodium Sulfate Storage Hopper (EP90) using baghouses (CD89 and CD90, respectively).

B. Each baghouse shall be operated and maintained in accordance with the manufacturer's specifications.

C. Each baghouse shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

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

E. lngredion, Incorporated shall monitor and record the operating pressure drop across each baghouse at least once every 24 hours. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance specification.

F. lngredion, Incorporated shall maintain a copy of the baghouse manufacturer's performance specification on site.

G. lngredion, Incorporated shall maintain an operating and maintenance log for each baghouse which shall include the following:

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Page 7: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

Project No. 2018-08-070 Permit No.

042019-016 SPECIAL CONDITIONS: The permittee is authorized to construct and operate subject to the following special conditions:

1) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and corrective actions; and

2) Maintenance activities, with inspection schedule, repair actions, and replacements, etc.

3. Control Device Requirement - Vapor Recovery System A. lngredion, Incorporated shall control the VOC emissions from the

propylene oxide storage tank (T13) by use of a vapor recovery system.

B. The vapor recovery system shall be operated and maintained in accordance with the manufacturer's specifications. lngredion, Incorporated shall maintain a copy of the manufacturer's specifications on site.

C. lngredion, Incorporated shall maintain an operating and maintenance log for the vapor recovery system which shall include the following: 1) Incidents of malfunction, with impact on emissions, duration of event,

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

replacements, etc.

4. Record Keeping and Reporting Requirements A. lngredion, Incorporated shall maintain all records required by this permit

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

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Page 8: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

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

Project Number: 2018-08-070 Installation ID Number: 047-0002

Installation Address: lngredion, Incorporated 1001 Bedford Avenue

Permit Number:

North Kansas City, MO 64116

Clay County, S23, T50N, R33W

042019-016 Parent Company: lngredion, Incorporated 1001 Bedford Avenue North Kansas City, MO 64116

REVIEW SUMMARY

• lngredion, Incorporated (lngredion) has applied for authority to modify the sodium sulfate (salt) unloading operations.

• The application was deemed complete on September 18, 2018.

• HAP emissions are not expected from the proposed equipment

• None of the New Source Performance Standards (NSPS) apply to the installation. o 40 CFR 60, Subpart Kb Standards of Performance for Volatile Organic Liquid

Storage Vessels regulates storage vessels with capacity greater than 19,813 gallons that are used to store volatile organic liquids for which construction, reconstruction, or modification is commenced after July 23, 1984 .. The PO tank is a pressure vessel with a rated max design of 344kPa (50 psig). Per §60.11 0b(d)(2), pressure vessels that are designed to operate in excess of 204.9 kPa are not subject to NSPS Kb. Also, for the tank to be considered modified, there needs to be an increase in the hourly emission rate. There is no increase in the tank's short term throughput and associated emission rate as a result of this project. Thus, the proposed project will not trigger NSPS Kb.

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

• Baghouses (CD89, CD90) are being used to control the particulate emissions from the truck/rail unloading and the sodium sulfate storage hopper. Emissions generated in the salt/mix tank are controlled by a vent filter; however, lngredion has opted not to make the vent filter a federally enforceable control device. As such, no control is taken into account in the potential emissions calculations for the salt/mix tank.

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Page 9: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

• A vapor recovery system is used to control VOC emissions from the PO tank (T13).

• This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all criteria pollutants are below de minimis levels, but above insignificant levels as stated in 10 CSR 10-6.061 (3)(A)3. The HAP emission increase of propylene oxide (PO) is below the SMAL.

• This installation is located in Clay County, a maintenance area for ozone and an attainment area for all other criteria pollutants.

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

• Ambient air quality modeling was not performed since potential emissions of the application are below de minimis levels.

• Emissions testing is not required for the equipment as a part of this permit. Testing may be required as part of other state, federal or applicable rules.

• A Title V operating permit significant modification application is required within year of the issuance date of this permit to include the special conditions contained within this permit.

• Approval of this permit is recommended with special conditions.

INSTALLATION DESCRIPTION

lngredion, Incorporated located in North Kansas City is a manufacturer of corn starch products, gluten meal, gluten feed, germ and high-solids steepwater. They are considered a major source operating permits and a minor source for construction permits. lngredion, Incorporated was issued a Part 70 Operating Permit in December of 2018 (OP2018-099).

The following New Source Review permits have been issued to lngredion, Incorporated from the Air Pollution Control Program.

T bl 1 P a e ermI IS Ory ·t H' t Permit Number Description

1076-014 Corn Products 0684-005 Corn Starch Products 0192-002 An additional packing system and an amphoteric cooker line 0397-004 Chemical unloadinq/reaction, storaqe tanks 0198-029 Cummins diesel fire pump engine and diesel

032008-005 Addition of a dump station 122012-004 Addition of a 33.4 MMBtu per hour natural qas-fired boiler

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Page 10: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

PROJECT DESCRIPTION

In the existing salt unloading process, salt is brought on-site via railcars and unloaded to the bottom of the existing dust collector (CD36) using a negative pressure pneumatic conveying system. The blower for CD36 drives air emissions that are generated during the unloading process through the baghouse filters before exhausting to the atmosphere. Particles captured by the baghouse filters are recovered at the bottom of CD36. From the bottom of CD36, salt that was unloaded from railcars and recovered from the bag filters is transported via a rotary valve into a positive pressure conveying system which blows subsurface into the eight (8) propylene oxide (PO) reaction tanks (Group 3 Reaction Tanks: EP66) at the plant on an as needed basis.

With this project, lngredion is proposing to modify the salt unloading operations as described herein. Salt from the railcars will be unloaded to a new tank/dust collector using negative pressure draw from an unloading blower located at the top of the tank/dust collector. The blower will drive air emissions through the filter socks at the top of the tank/dust collector before exhausting to the atmosphere (New emission point: EP89; CD89). Once the tank/dust collector is filled with salt, the unloading blower will switch to provide positive pressure which will drive the heavy salt particles, and particles that are captured/recovered by the filter sock through the bottom of the tank/dust collector to a new salt storage hopper. The salt storage hopper will be equipped with a dust collector attached to the top of the hopper. The blower for the dust collector will drive air emissions through the filter socks before exhausting to the atmosphere (New emission point: EP90; CD90). From the hopper, the salt will be fed via gravity to a new weigh feeder and then to a new salt mix tank where it will be mixed with a starch slurry and water. The salt mix tank will include a vent (New emission point: EP91 ). The maximum hourly throughput for EP89 and EP90 is 30,000 lb/hr and for EP91, the maximum hourly throughput is 18,470 lb/hr. EP89 and EP90 are bottlenecked on a long-term basis by EP91. Therefore, annual emissions of these units are based on a throughput of 161,797,200 lbs (18,470 lb/hr x 8,760 hr/yr= 161,797,200 lbs).

The slurry from the salt mix tank will then be pumped through an in-line caustic addition mixer and slurry cooler (heat exchanger using well water) before getting transported to the existing eight (8) PO reaction tanks (Group 3 Reaction Tanks, existing emission point: EP66) as needed.

T bl 2 P . t E . . P . a e ro Jee mIssIon omts Emission Emission Point Description New/ Control Co.ntrol Device .·. Point ID E~ist{~g/ Device IQ Description

Modified ..

EP89 Salt Unload Baghouse #1 New CD89 BaQhouse EP89F FuQitives from Salt Unload New N/A NIA EP90 Salt Unload Baghouse #2 New CD90 BaQhouse EP91 Salt/Mix Tank New CD91 Vent Filter1

EP66 Group 3 Reaction Tanks (8 Existing N/A1 N/A total PO reaction tanks)

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·.

Page 11: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

Emission Emission Point Description New/ Control Control Device Point ID Existing/ Device ID Description

. Modified System

EP70 Equipment Leaks Existing N/A N/A TB Sulfuric Acid Storage Tank Existinq N/A N/A EPFUG Haul Road Emissions Existing NIA Documented Water

Spray N/A = Not applicable 1Note that the vent filter is not a federally enforceable control device since there are no special conditions requiring its use. Nitrogen purging and blanketing is viewed as inherent control since its primary purpose is to prevent a flammable atmosphere.

The main purpose of the new in line salt system is to reduce the cycle time needed to produce PO based modified starch in the Group 3 reaction tanks by combining several steps currently used into one step. The Group 3 reaction tanks receive the vast majority of the salt; a much smaller portion is routed to the Group 2 reaction tanks during production of the Group 2 starch products. However, the new system does not reduce the cycle time of the Group 2 products (see Table 3 below). Therefore, this analysis focuses on the effects of the reduction of cycle time of the Group 3 products on upstream and downstream equipment as well as any potential increases in pollutants due to the increase of the PO based starch.

The project was evaluated to see if the addition of the in line salt system debottlenecked any upstream or downstream equipment. The main purpose of the upstream equipment is to produce liquid starch that will be used in the reaction tanks (Group #1 tanks, Group #2 tanks, or Group #3 tanks). Each group of tanks is dedicated to making their own type of modified starch products. Although the inline salt system is expected to reduce the batch time of the Group #3 tank product, the batch time of the product made in Group #3 tanks remains considerably longer than the products made in the other two sets of tanks. As such, even though the annual amount of liquid starch being used to Group #3 products will increase, it is still less than the potential liquid starch that could be used to make one of the other starch products produced in the Group #1 and Group #2 tanks. Therefore, upstream equipment is not being debottlenecked by the new inline salt system.

Table 3: Batch Amounts and Process Times Group Maximum·· •. Potential Minimum Annual

Potential •• Reaction Batch Reaction Production of Processed per Product of all 8 Process Time all 8 Reactors Reactor (lbs) · Reactors (lbs) (hours) (tons)

Group #1 330,000 2,640,000 23 502,747 Tanks (8 total)

Group #2 330,000 2,640,000 37 312,519 Tanks (8 total)

Group #3 330,000 2,640,000 ~46 251,374 Tanks (8 total)

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Page 12: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

All 3 groups of tanks feed into the same downstream equipment. The dryers (EP20 to EP23, 4 total@ 20 ton/hr each) represent the bottleneck in the downstream equipment. At maximum rate, 700,800 tons of product can be dried per year. Assuming the tanks can be cycled such that the downstream equipment can be fully utilized, the dryers will remain the bottleneck of the entire starch product process.

Since equipment upstream and downstream of the reaction tanks are not being debottlenecked by this project, project emissions were based only on the emissions associated with the inline salt system and any other increases experienced due to the potential production increase in PO modified starch products. The ingredients of PO modified starch product has the potential to increase due to the decrease in the batch time. Besides the salt which is discussed above, two ingredients, sulfuric acid and PO, are the main ingredients that may result in increase in emissions. All other ingredients either do not contain any HAPs or voe or are in a liquid form and are not expected to produce any particulate emissions.

Sulfuric acid mist: Sulfuric acid is only used to make PO modified starch. Potential sulfuric acid mist emissions from sulfuric acid bulk storage tanks are expected but in very small quantities due to small vapor pressure associated with sulfuric acid. Sulfuric acid is added to the reaction tanks while the vent is closed and the sulfuric acid is neutralized by the sodium hydroxide within the reaction vessel. Thus, no sulfuric acid mist emissions are expected from the reaction tanks or downstream equipment.

PO: The PO is added from the existing PO tank and is only used to produce PO modified starch. The PO tank has a vapor recovery system that captures all of the volatiles from the working losses of the PO tank. In addition, the tank is underground and uses a nitrogen blanket; therefore, no breathing losses are expected when transfer operations are not occurring. Nitrogen flow does occur when transferring the PO to the reaction tanks and emission from fugitive leaks during this transfer are accounted for under EP70 where the EPA soeMI factors are used.

To minimize voe emissions from the reaction tanks, the tanks themselves employ nitrogen purging and blanketing. Since there is a constant nitrogen flow through the head space of the reaction tanks to prevent a flammable atmosphere, PO emissions could result. To estimate the emissions associated with PO in the reaction tanks, an Indiana test on a similar process was used. In the case of the Indiana test, nitrogen blanketing was used, however, it is unknown whether PO was metered in. Therefore, the test is assumed to be conservative and emissions associated with these reaction tanks are expected to be equal or much less. The last step of the PO reaction process is the use of sulfuric acid to convert any remaining PO to propylene glycol. Thus, no PO is expected downstream of the reaction tanks.

The calculation approach for estimating leaking emission associated with the group 3 reaction tanks and PO transport from the storage tank (EP70) to the Group 3 reaction tanks (EP66) is dependent on the number of components (valves, pump seals and flanges) in the piping. This number is not changing as a result of this project and therefore is not included. A very small amount of particulate emissions due to increase haul roads usage from PO hauling to the site were included in project emission totals.

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Page 13: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

EMISSIONS/CONTROLS EVALUATION

The main pollutants of concern for this project are PM, PM10 and PM2.s from the transfer of the salt. A very small amount of fugitive particulate emissions may occur from the loading spout (EP89F) as it is disconnected from the bottom of the railcar or truck. Some of the material in the spout may fall to the ground potentially generating fugitive dust. The emission factor for truck/rail unloading was estimated from the drop point equation in EPA document AP-42, Compilation of Air Pollutant Emission Factors, Fifth Edition, Section 13.2.4 Aggregate Handling and Storage Piles (November 2006). A moisture content of 0.02% and a wind speed of 15 miles per hour were used in the equation. One percent of the emissions were assumed to be emitted. The remaining portion is routed to a bag house. For truck/rail unloading (EP89) and the sodium sulfate storage hopper (EP90), particulate emissions were calculated based upon the maximum design outlet grain loading of 0.01 gr/dscf and maximum air flow rate of 1,400 cubic feet per minute each. The particle size distribution of the particulate was not determined and therefore, all PM is assumed to equal PM10 and PM2.s.

For the transfer of salt into the salt/mix tank, the drop point equation from Section 13.2.4 was used to estimate the emission factor. A moisture content of 0.02% and a wind speed of 1.3 miles per hour were put into the equation. A low wind speed was chosen since emissions will occur inside the tank and the tank is indoors.

Haul road emission calculations are based on AP-42, Section 13.2.1: Paved Haul Roads (January 2011 ).

Sulfuric acid emissions from increased usage were based on AP-42, Section 7: Liquid Storage Tanks (November 2006).

PO emissions from the reaction tanks are based on 1997 tests conducted at PO reaction tanks in lngredion's sister plant in Indiana. The test summary was provided to MDNR on 3/14/2018.

The following table provides an emissions summary for this project. Existing potential emissions were taken from OP2018-099, except where noted. Existing actual emissions were taken from the installation's 2018 EIQ. Potential emissions of the application represent the potential of the new equipment and increases due to increase the PO modified starches, assuming continuous operation (8760 hours per year). Emissions increase represents the post-project potential emissions minus the pre­project potential emissions.

lngredion would like to maintain its area source status for HAPs. Therefore, they have accepted an installation-wide limit on individual HAPs to less than 10 tpy and combined HAPs to less than 25 tpy.

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Page 14: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

Table 4: Emissions Summary tpy) Regulatory Existing Existing .Actual Potential Emissions

Pollutant De Minimis · Potential · Emissions Emissions of Increase Levels Emissions1,2 (2018 EIQ) the Proiect {tpy) ·.

PM 25.0 N/0 N/0 11.01 N/0

PM10 15.0 237.81 102.21 5.76 N/D

PM2s 10.0 90.98 67.75 1.29 N/D

SOx 40.0 143.00 63.07 N/A N/D

NOx 40.0 131.98 27.16 N/A N/0

voe 40.0 97.43 64.85 12.573 3.24

co 100 0 81.00 22.82 NIA N/D

GHG (CO2e) N/A N/D N/D NIA N/D

GHG (mass) NIA N/D N/D N/A N/D

Sulfuric Acid 7.0 N/D N/D 4 X 10·7 N/0

Mist

HAPs 10.0/25.0 9.8 3.59 12.573 3.24

PO 5.0 N/D N/D 12.573 3.24

N/A = Not Applicable; N/D = Not Determined 1 Existing Potential Emissions (PTE) were calculated assuming 8760 hours of operation for all units except for the emergency generator which was calculated assuming 500 hours of operation. Bottlenecks of equipment were not taken into account and as such, existing potential emissions may be overestimated. Federally enforceable control efficiencies were taken into account. 2 The PTE for HAPs was taken from Construction Permit 122012-004. 3Ingredion has taken an installation-wide individual HAP limit to 10 tpy. Therefore, VOC and HAP emissions for this project are limited to less than 10 tpy.

Since the potential emissions of PO for the project exceeds its individual HAP and SMAL value, the emission increase of PO was evaluated to ensure that the project's emission increase is below the respective levels. The potential emissions of the project before this project were compared to the potential emissions after the project. Table 4 shows that emission increase for PO is below the 5 tpy SMAL for PO and thus also below the individual HAP threshold of 10 tpy.

Table 5: PO Emission Increase Units Pre-Project Potential Post-Project Potential

I . Emissions Emissions Annual Production ton/vr 186,503 251,374

PO Emission Factor lb/ton 0.1 0.1 Group #3 Reaction ton/yr 9.33 12.57

Tank Emissions Emission Increase (tnv) 3.24

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all criteria pollutants are below de minim is levels, but above insignificant levels as stated in 10 CSR 10-6.061 (3)(A)3. The HAP emission increase of PO is below the SMAL.

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Page 15: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

APPLICABLE REQUIREMENTS

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

GENERAL REQUIREMENTS

• Operating Permits, 10 CSR 10-6.065

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

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

o Per 10 CSR 10-6.110(4)(8)2.B(II) and (4)(8)2.C(II) a full EIQ is required for the first full calendar year the equipment (or modifications) approved by this permit are in operation.

• 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 10-6.165

SPECIFIC REQUIREMENTS

• Restriction of Emission of Particulate Matter From Industrial Processes, 10 CSR 10-6.400

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Page 16: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

STAFF RECOMMENDATION

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

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

• The Application for Authority to Construct form, dated September 18, 2018, received September 18, 2018, designating lngredion, Incorporated as the owner and operator of the installation.

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Page 17: Ingredion - North Kansas City · North Kansas City, MO 64115 RE: New Source Review Permit -Project Number: 2018-08-070 Dear Ms. Rasa: Carol S. Comer, Director Enclosed with this letter

APPENDIX A Abbreviations and Acronyms

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

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

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

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

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

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

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

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

CEMS ...... Continuous Emission Monitor System

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

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

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

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

COMS ...... Continuous Opacity Monitoring System

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

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

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

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

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

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

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

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

GACT ...... Generally Available Control Technology

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

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

gr .............. grains

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

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

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

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

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

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

MACT ...... Maximum Achievable Control Technology

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

mis ............ meters per second

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

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

MHDR. ..... maximum hourly design rate

MMBtu .... Million British thermal units

MMCF ..... million cubic feet

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

NAAQS .... National Ambient Air Quality Standards

NESHAPs National Emissions Standards for Hazardous Air Pollutants

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

S02 ............ sulfur dioxide

SSM .......... Startup, Shutdown & Malfunction

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

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

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

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