STATE OF MISSOURI Matr DEPARTMENT OF NATURAL RESOURCES … · STATE OF MISSOURI Matr Blunt, Governor. Doyle Childers, Director DEPARTMENT OF NATURAL RESOURCES JUL 1 2 2007 Mr. BrianBonebright

STATE OF MISSOURI Matr Blunt, Governor. Doyle Childers, Director

DEPARTMENT OF NATURAL RESOURCESwww.dnr.mo.gov

JUL 1 2 2007

Mr. Brian BonebrightVice President, OperationsDairiConcepts, L.P.305 West US Highway 54EI Dorado Springs, MO 64744

Re: DairiConcepts, L.P.Installation ID: 039~0003

Pennit Number: OP2007-034

Dear Mr. Bonebright:

Enclosed with this letter is your Part 70 operating pennit. Please review this document carefully.Operation of your installation in accordance with the rules and regulations, cited in thisdocument, is necessary for continued compliance. It is very important you read and understandthe requirements contained in your pennit.

You may appeal this permit 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 toappeal, you must file a petition with the ARC within thirty days after the date this decision wasmailed or the date it was delivered, whichever date was earlier. If any such petition is sent byregistered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent byany method other than registered mail or certified mail, it will be deemed filed on the date it isreceived by the ARC.

If you have any questions or need additional infonnation regarding this permit, please contactJill Wade at the Department ofNatural Resources' Air Pollution Control Program, P.O. Box 176,Jefferson City, MO 65102 or telephone (573) 751-4817. Thank you for your time and attention.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

!!!::±£!!4WOperating Pennit Unit Chief

MJS:jwk

Enclosure

c: Ms. Tamara Freeman, U.S. EPA Region VIISouthwe~t Regional Office \)PAMS FIle: 2005-08-071 Rco)'c1erl P.per

G - Missouri Department of Natural Resources~ ~ Air Pollution Control Program

PART 70PERMIT TO OPERATE

Under the authority ofRSMo 643 and the Federal Clean Air Act the applicant is authorized to operate the aircontaminant source(s) described below, in accordance with the laws, rules, and conditions set forth here in.

Operating Permit Number: OP2007-034Expiration Date: JUL 1 1 2012

Installation ill: 039-0003Project Number: 2005-08-071

Installation Name and AddressDairiConcepts, L.P.305 West US Highway 54EI Dorado Springs, MO 64744Cedar County

Parent Company's Name and AddressDairiConcepts, L.P.3253 E. Chestnut ExpresswaySpringfield, MO 65802

Installation Description:DairiConcepts, L.P. operates a food processing plant in EI Dorado Springs. The installationproduces various dried dairy products.. Processes include two boilers, three blendingoperations, three spray dryers, three fuel oil storage tanks and packaging lines.

JUL 1 2 2007Effective Date

DairiConcepts, L.P.Installation ill: 039-0003

Table of Contents

Part 70 Operating Pennit 2Project No. 2005-08-071

I. INSTALLATION DESCRIPTION AND EQUIPMENT LISTING 4

INSTALLATION DESCRIPTION 4EMISSION UNITS WITH LIMITATIONS 4EMISSION UNITS WITHOUT LIMITATIONS 4DOCUMENTS INCORPORATED BY REFERENCE 4

II. PLANT WIDE EMISSION LIl\fiTATIONS 5

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS 6

EU0010 - BOILER #1 6PERMIT CONDITION EU0010-001 .. , 6

10 CSR 10-3.060 Maximum Allowable Emissions ofParticulate Matter From Fuel Burning Equipment Used for IndirectHeating 6

PERMIT CONDITION EU001 0-002 610 CSR 10-6.220 Restriction of Emission ofVisible Air Contaminants 6

PERMIT CONDITION EU0010-003 710 CSR 10-6.260 Restriction of Emission of Sulfur Compounds 7

EU0020 - BOILER #2 8PERMIT CONDITION EU0020-001 8

10 CSR 10-3.060 Maximum AIIowable Emissions ofParticulate Matter From Fuel Burning Equipment Used for IndirectHeating 8

PERMIT CONDITION EU0020-002 910 CSR 10-6.070 New Source Performance Regulations 940 CFR Part 60 Subpart Dc Standards ofPerformance for Small Industrial-Commercial-Institutional Steam Generating Units9

PERMIT CONDITION EU0020-003 1010 CSR 10-6.220 Restriction ofEmission ofVisible Air Contaminants 10

EU0030 - BLENDING FOR DRYER #1 11EU0040 - BLENDING FOR DRYER #2 11PERMIT CONDITION (EU0030 and EU0040)-001 11

10 CSR 10-6.220 Restriction ofEmission ofVisible Air Contaminants 11

PERMIT CONDITION (EU0030 and EU0040)-002 1210 CSR 10-6.400 Restriction ofEmission of Particulate Matter From Industrial Processes 12

EU0050 - SPRAY DRYER #1 13PERMIT CONDITION EU0050-001 13

10 CSR 10-6.060 Construction Permits Required 13Construction Permit 032000-004, Issued 1/31/2000 1310 CSR 10-6.400 Restriction of Emission ofParticulate Matter From Industrial Processes 13

PERMIT CONDITION EU0050-002 ; 14io CSR 10-6.220 Restriction of Emission ofVisible Air Contaminants 14

EU0060 - SPRAY DRYER #2 ; 15EU0070- SPRAY DRYER #3 15PERMIT CONDITION (EU0060 and EU0070)-001 16

10 CSR 10-6.060 Construction Permits Required 16Construction Permit 012002-007, Issued 11/7/2001 1610 CSR 10-6.400 Restriction of Emission of Particulate Matter From Industrial Processes 16

PERMIT CONDITION (EU0060 and EU0070)-002 1710 CSR 10-6.220 Restriction of Emission ofVisible Air Contaminants 17

IV. CORE PERMIT REQUIREMENTS .....•.....•....•....•..............................................•...•..••......••............... 19

V. GENERAL PERMIT REQUIREMENTS ........•.•.........•.•..........•.••.........•.........••.••.........•.•••••.•.••••.....•.•. 24

VI. ATTACHMENTS ~ 30



AITACIIMENT A 31AITACIIMENT B-1 32AITACIIMENT B-2 33AITACIIMENT C 34AITACIIMENT D 35AITACIIMENT E 36

DairiConcepts, L.P.Installation ID: 039-0003

Part 70 Operating Permit 4Project No. 2005-08-071

I. Installation Description and Equipment Listing

INSTALLATION DESCRIPTIONDairiConcepts, L.P. operates a food processing plant in EI Dorado Springs. The installation producesvarious dried dairy products. Processes include two boilers, three blending operations, three spraydryers, three fuel oil storage tanks and packaging lines.

The most recent five years ofactual emissions reported from the EIQ are listed in the table below.

Reported Air Pollutant Emissions, tons per yearYear Particulate

Sulfur NitrogenVolatile

Carbon HazardousMatter Organic Lead AirOxides Oxides Monoxide:s Ten Microns

(SOx) (NOx)Compounds

(CO)(Pb) Pollutants

(PM-1 0) (VOCs) (HAPs)2005 24.40 0.06 6.69 0.53 8.10 0.00 0.002004 15.53 0.04 4.94 0.38 5.78 0.00 0.002003 17.22 0.4 4.95 0.39 6.01 0.00 0.002002 14.68 0.03 3.95 0.30 4.58 0.00 0.002001 16.66 1.61 3.08 0.23 3.42 0.00 0.00

EMISSION UNITS WITH LIMITATIONSThe following list provides a description of the equipment at this installation which emits air pollutantsand which is identified as having unit-specific emission limitations.

Emission Unit #EUOOlOEU0020EU0030EU0040EU0050EU0060EU0070

Description ofEmission UnitBoiler #1Boiler #2Blending for Dryer #1Blending for Dryer #2Spray Dryer #1Spray Dryer #2Spray Dryer #3

2004 EIO Reference #EP-01EP-09EP-04EP-10EP-05EP-llEP-13

EMISSION UNITS WITHOUT LIMITATIONSThe following list provides a description of the equipment that does not have unit specific limitations atthe time ofpermit issuance.

Description ofEmission SourceBlending for dryer #3, vents indoorsTwo 12,000-gallon fuel oil #6 storage tanks, installed pre-1963One 12,000-gallon fuel oil #2 storage tank, installed pre-1963Packaging lines

2004 BIO Reference #EP-12EP-6, EP-7EP-8

DOCUMENTS INCORPORATED BY REFERENCEThese documents have been incorporated by reference into this permit.1) Construction Permit 032000-0042) Construction Permit 012002-007


II. Plant Wide Emission Limitations


The installation shall comply with each ofthe following emission limitations. Consult the appropriatesections in the Code ofFederal 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 ofthe date that this pennit is issued.

None


Part 70 Operating Pennit 6Project No. 2005-08-071 '

III. Emission Unit Specific Emission Limitations

The installation shall comply with each of the following emission limitations. Consult the appropriatesections in the Code ofFederal Regulations (CFR) and Code of State Regulations (CSR) for the full textof the applicable requirements. All citations, unless otherwise noted, are to t1;le regulations in effect as ofthe date that this permit is issued.

Boiler; primary fuel - natural gas; secondary fuel - fuel oil #6;MHDR 56 MMBtu/hr; installed 1982

PERMIT CONDITION EUOOIO-OOI10 CSR 10-3.060 Maximum Allowable Emissions ofParticulate Matter From Fuel Burning

Equipment Used for Indirect Heating

Emission Limitation:The permittee shall not emit particulate matter in excess of 0.27 pounds per million BTU ofheat input.

OperationaVEquipment Limitation:EUOO10 shall be limited to burning pipeline grade natural gas and fuel oil #6.

Monitoring/Recordkeeping:The permittee will be in compliance with this regulation as long as the EUOOlO burns natural gas andfuel oil #6 exclusively. Calculations demonstrating compliance are in Attachment A. The permitteeshall keep this attachment with this permit. No additional monitoring or recordkeeping is required forthis permit condition.

PERMIT CONDITION EUOOIO-00210 CSR 10-6.220 Restriction ofEmission ofVisible Air Contaminants

Emission Limitations:1) No owner or other person shall cause or permit emissions to be discharged into the atmosphere from

any source any visible emissions with an opacity greater than 20%.2) Exception: A person may discharge into the atmosphere from any source of emissions for a

period(s) aggregating not more than six (6) minutes in any 60 minutes air contaminants with anopacity up to 60%.

Monitoring:1) The permittee shall conduct opacity readings on this emission unit (EUOO10) using the procedures

contained in USEPA Test Method 22. At a minimum, the observer should be trained andknowledgeable about the effects on visibility of emissions caused by background contrast, ambientlighting, observer position relative to lighting, wind and the presence ofuncombined water.Readings are only required when the emission unit is operating and when the weather conditionsallow. Ifno visible or other significant emissions are observed using these procedures, then no



further observations would be required. For emission units with visible emissions perceived orbelieved to exceed the applicable opacity standard, the source representative would then conduct aMethod 9 observation.

2) The following monitoring schedule must be maintained:a) Weekly observations shall be conducted for a minimum of eight consecutive weeks after permit

issuance. Should no violation of this regulation be observed during this period then-b) Observations must be made once every two weeks for a period of eight weeks. If a violation is

noted, monitoring reverts to weekly. Should no violation of this regulation be observed duringthis period then-

c) Observations must be made once per month. If a violation is noted, monitoring reverts toweekly.

3) If the source reverts to weekly monitoring at any time, monitoring frequency will progress in anidentical manner from the initial monitoring frequency.

Recordkeeping:1) The permittee shall maintain records of all observation results (see Attachment B1 or B2), noting:

a) Whether any air emissions (except for water vapor) were visible from the emission units,b) All emission units from which visible emissions occurred, andc) Whether the visible emissions were normal for the process.

2) The permittee shall maintain records of any equipment malfunctions. (see Attachment C)3) The permittee shall maintain records of any Method 9 test performed in accordance with this permit

condition. (see Attachment D)4) Attachments Bl, B2, C and D contain logs including these recordkeeping requirements. These logs,

or equivalent forms created by the permittee, must be used to certify compliance with thisrequirement.

5) These records shall be made available to the Missouri Department ofNatural Resources' personnelupon request.

6) All records shall be maintained for five years.

Reporting:1) The permittee shall report to the Air Pollution Control Program Enforcement Section, P.O. Box 176,

Jefferson City, MO 65102, no later than ten days after the permittee determined using the Method 9test that the emission unit exceeded the opacity limit.

2) Reports of any deviations from monitoring, recordkeeping and reporting requirements of this permitcondition shall be submitted semiannually, in the semi-annual monitoring report and annualcompliance certification, as required by Section N ofthis permit.

PERMIT CONDITION EUOOIO-00310 CSR 10-6.260 Restriction ofEmission of Sulfur Compounds

Emission Limitations:1) No person shall cause or permit emissions of sulfur dioxide into the atmosphere from any indirect

heating source in excess of eight pounds of sulfur dioxide per million BTUs actual heat inputaveraged on any consecutive three hour time period

2) No person shall cause or permit the emission of sulfur compounds from any source which causes orcontributes to concentrations exceeding those specified in 10 CSR 10-6.010 Ambient Air QualityStandards.

DairiConcepts, L.P.fustallation ill: 039-0003

Sulfur Dioxide(S02)

Hydrogen Sulfide(H2S)

Sulfuric Acid(H2S04)

0.14 ppm (365 ~g/m3)

0.05 ppm (70 ~g/m3)

0.03 ppm (42 ~g/m3)


24-hour average not to be exceeded morethan once er ear3-hour average not to be exceeded morethan once er earY2-hour average not to be exceeded over2 times er earY2-hour average not to be exceeded over2 times in an 5 consecutive da s24-hour average not to be exceeded morethan once in an 90 consecutive da sI-hour average not to be exceeded morethan once in an 2 consecutive da s

Operational LimitationlEquipment Specifications:EUOO10 shall be limited to burning pipeline grade natural gas and fuel oil #6 with a sulfur content ofnomore than 1.5 % sulfur by weight.

MonitoringlRecordkeeping:1) The permittee shall maintain records ofthe fuel burned (natural gas or fuel oil #6) and verify the

sulfur content. Fuel purchase receipts, analyzed samples or certifications that verify the fuel typeand sulfur content will be acceptable.

2) These records shall be made available immediately for inspection to the Department ofNaturalResources' personnel upon request.


Reporting:The permittee shall report any deviations/exceedances of this permit condition using the semi-annualmonitoring report and annual compliance certification to the Air Pollution Control ProgramEnforcement Section, P.O. Box 176, Jefferson City, MO 65102, as required by as required by Section IVofthis permit.

Boiler; primary fuel - natural gas; secondary fuel - fuel oil #2;MHDR 25.106 MMBtu/hr; installed 1999

PERMIT CONDITION EU0020-00110 CSR 10-3.060 Maximum Allowable Emissions ofParticulate Matter From Fuel Burning

Equipment Used for Indirect Heating

Emission Limitation:The permittee shall not emit particulate matter in excess of 0.27 pounds per million BTU ofheat input.



OperationallEquipment Limitation:EU0020 shall be limited to burning pipeline grade natural gas and fuel oil #2.

Monitoring/Recordkeeping:The permittee will be in compliance with this regulation as long as EU0020 bums natural gas and fueloil #2 exclusively. Calculations demonstrating compliance are in Attachment A. The permittee shallkeep this attachment with this permit. No additional monitoring or recordkeeping is required for thispermit condition.

PERMIT CONDITION EU0020-00210 CSR 10-6.070 New Source Performance Regulations

40 CFR Part 60 Subpart Dc Standards ofPerformance for Small Industrial-Commercial-InstitutionalSteam Generating Units

Note: The emissions limitations, monitoring, record keeping and reporting requirements below applyonly when EU0020 bums #2 fuel oil.

Emission Limitations:1) The permittee shall not combust oil in EU0020 that contains greater than 0.5 weight percent sulfur.

[§60.42c(d)]2) The permittee has elected to demonstrate compliance with the fuel oil sulfur limits based on a

certification from the fuel supplier. [§60.42c(h)(1)]3) The fuel oil sulfur limit applies at all times, including periods of startup, shutdown, and malfunction.

[§60.42c(i)]

Monitoring:The monitoring requirements of §60.46c do not apply to facilities where the owner or operatordemonstrates compliance with the S02 standards based on fuel supplier certification. Therefore, thereare no further monitoring requirements. [§60.46c(e)]

Recordkeeping/Reporting:1) The permittee shall keep records and submit reports as required including the following information,

as applicable: [§60.48c(e)]a) Calendar dates covered in the reporting period. [§60.48c(e)(1)]b) If fuel supplier certification is used to demonstrate compliance, records of fuel supplier

certification as described under §60.48c(f)(1). [§60.48c(e)(11)]i) Fuel supplier certification for distillate oil shall include the following information:

[§60.48c(f)(1)]1. The name of the oil supplier; and [§60.48c(f)(1)(i)]2. A statement from the oil supplier that the oil complies with the specifications under the

definition ofdistillate oil in §60.41c. [§60.48c(f)(1 )(ii)]c) In addition to records of fuel supplier certifications, the report shall include a certified statement

signed by the responsible official that the records of fuel supplier certifications submittedrepresent all ofthe fuel combusted during the reporting period. [§60.48c(e)(11)]

2) The permittee shall record and maintain records of the amounts of each fuel combusted during eachday. [§60.48c(g)]



3) All records shall be maintained for five years and shall be made available immediately for inspectionto the Department ofNatural Resources' personnel upon request.

4) The reporting period for the reports required under subpart Dc is each six-month period. All reportsshall be submitted to the MDNR and shall be postmarked by the 30th day following the end of thereporting period. [§60.48c(i)]

5) The permittee shall report any deviations/exceedances of this permit condition using the semi-annualmonitoring report and annual compliance certification to the Air Pollution Control ProgramEnforcement Section, P.O. Box 176, Jefferson City, MO 65102, as required by Section IV ofthispermit.

PERMIT CONDITION EU0020-00310 CSR 10-6.220 Restriction of Emission ofVisible Air Contaminants




Monitoring:1) The permittee shall conduct opacity readings on this emission unit (EU0020) using the procedures

contained in USEPA Test Method 22. At a minimum, the observer should be trained andknowledgeable about the effects on visibility of emissions caused by background contrast, ambientlighting, observer position relative to lighting, wind and the presence ofuncombined water.Readings are only required when the emission unit is operating and when the weather conditionsallow. Ifno visible or other significant emissions are observed using these procedures, then nofurther observations would be required. For emission units with visible emissions perceived orbelieved to exceed the applicable opacity standard, the source representative would then conduct aMethod 9 observation.



noted, monitoring reverts to weekly. Should no violation ofthis regulation be observed duringthis period then-



Recordkeeping:1) The permittee shall maintain records ofall observation results (see Attachment B1 or B2), noting:


2) The permittee shall maintain records of any equipment malfunctions. (see Attachment C)



3) The pennittee shall maintain records of any Method 9 test perfonned in accordance with this pennitcondition. (see Attachment D)

4) Attachments B1, B2, C and D contain logs including these recordkeeping requirements. These logs,or equivalent fonns created by the pennittee, must be used to certify compliance with thisrequirement.



Reporting:1) The pennittee shall report to the Air Pollution Control Program Enforcement Section, P.O. Box 176,

Jefferson City, MO 65102, no later than ten days after the pennittee detennined using the Method 9test that the emission unites) exceeded the opacity limit.

2) Reports of any deviations from monitoring, recordkeeping and reporting requirements of this pennitcondition shall be submitted semiannually, in the semi-annual monitoring report and annualcompliance certification, as required by Section IV of this pennit.

EU0030

EU0040

Blending operation; Natural gas fIred dryer; MOOR 4.0ton/br; equipped with rotoclone dynamic wet separator;installed 1997Blending ofraw material in mixing tank; Natural Gas fIreddryer; MHDR 2.0 ton/br; equipped with rotoclone dynamicwet s arator; installed 2002

AAF International!Model 1428606-1

AAF International!ModelBR2

EP-04

EP-I0

PERMIT CONDITION (EU0030 and EU0040)-OOl10 CSR 10-6.220 Restriction ofEmission ofVisible Air Contaminants

Emission Limitations:1) No owner or other person shall cause or pennit emissions to be discharged into the atmosphere from



Monitoring:1) The pennittee shall conduct opacity readings on these emission units (EU0030 and EU0040) using

the procedures contained in USEPA Test Method 22. At a minimum, the observer should be trainedand knowledgeable about the effects on visibility of emissions caused by background contrast,ambient lighting, observer position relative to lighting, wind and the presence ofuncombined water.Readings are only required when the emission unit is operating and when the weather conditionsallow. Ifno visible or other significant emissions are observed using these procedures, then nofurther observations would be required. For emission units with visible emissions perceived or


Part 70 Operating Permit, 12Project No. 2005-08-071

believed to exceed the applicable opacity standard, the source representative would then conduct a. Method 9 observation.




c) Observations must be made once per month. If a violation is noted, monitoring reverts to weekly.3) If the source reverts to weekly monitoring at any time, monitoring frequency will progress in an

identical manner from the initial monitoring frequency.

Recordkeeping:1) The permittee shall maintain records of all observation results (see Attachment B1 or B2), noting:


2) The permittee shall maintain records of any equipment malfunctions. (see Attachment C)3) The permittee shall maintain records ofany Method 9 test performed in accordance with this permit






Jefferson City, MO 65102, no later than ten days after the permittee determined using the Method 9test that the emission unites) exceeded the opacity limit.

2) Reports of any deviations from monitoring, recordkeeping and reporting requirements ofthis permitcondition shall be submitted semiannually, in the semi-annual monitoring report and annualcompliance certification, as required by Section N of this permit.

PERMIT CONDITION (EU0030 and EU0040)-00210 CSR 10-6.400 Restriction ofEmission ofParticulate Matter From Industrial Processes

Emission Limitations:1) Particulate matter shall not be emitted from EU0030 in excess of 10.38Ib/hr.2) Particulate matter shall not be emitted from EU0040 in excess of 6.52 lb/hr.3) These emission rates were calculated using the following equation:

E = 4.1 0(p)O.67Where:E = rate of emission in lb/hrP = process weight rate in ton/hr

4) The concentration ofparticulate matter in the exhaust gases shall not exceed 0.30 gr/scf.



Monitoring:The permittee shall calibrate, maintain and operate the wet dust collectors according to themanufacturer's specifications and recommendations.

Recordkeeping:1) The permittee shall maintain a written record of all inspections, maintenance, calibration and any

action resulting from these actions.2) Attachment C contains a log including these recordkeeping requirements. This recordkeeping sheet,

or an equivalent created by the pennittee, must be used to certify compliance with this requirement.3) These records shall be made available to the Missouri Department ofNatural Resources' personnel

upon request.4) All records shall be maintained for five years.


Jefferson City, MO 65102, no later than ten days after the permittee determined that the emissionunites) exceeded the emission limitation listed above.

2) Reports of any deviations from monitoring, recordkeeping and reporting requirements of this pennitcondition shall be submitted semiannually, in the semi-annual monitoring report and annualcompliance certification, as required by Section IV of this pennit.

Spray dryer; MHDR 4 ton/hr, spray dryer installed 1978; heatedwith natural gas direct-fIred burner; MHDR 18 MMBtu/hr; burner

EU0050 installed 1999; spray dryer and burner are part of an integralprocess and share the same control equipment and stack; equippedwith rimary and second dust collectors and wet scrubber

Dryer - Niro/SD-500BurnerMaxon

EP-05

PERMIT CONDITION EU0050-00110 CSR 10-6.060 Construction Pennits Required

Construction Pennit 032000-004, Issued 1/31/200010 CSR 10-6.400 Restriction ofEmission ofParticulate Matter From Industrial Processes

Emission Limitations:1) Particulate matter shall not be emitted from EU0050 in excess of 10.38 lb/hr.2) This emission rate was calculated using the following equation:

E = 4.1 0(p)O.67Where:E = rate of emission in lb/hrP = process weight rate in tonlhr

3) The concentration ofparticulate matter in the exhaust gases shall not exceed 0.30 gr/sc£4) The permittee shall control emissions ofparticulate matter less than ten microns in aerodynamic

diameter (PM lO) from the spray dryer (EU0050) with a wet venturi scrubber at all times when thedryer is in use. This scrubber shall be equipped with a gauge or meter which indicates the pressure

·.



drop across the scrubber. This gauge or meter shall be located such that it may be easily observed bythe Department ofNatural Resources' employees. [Pennit 032000-004, Special Condition IJ

Monitoring/Recordkeeping:1) The permittee shall monitor and record the operating pressure drop across the scrubber at lease once

every twenty-four hours. The operating pressure drop shall be maintained within the design ,conditions specified by the manufacturer's performance warranty. (see Attachment E) [Pennit032000-004, Special Condition 2J

2) The permittee shall maintain an operating and maintenance log for the scrubber which shall includethe following: (see Attachment C) [Pennit 032000-004, Special Condition 3Ja) Incident ofmalfunction, with impact on emission, duration ofevent, probably cause, and

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

3) Attachments C and E contain logs including these recordkeeping requirements. These logs, orequivalent forms created by the permittee, must be used to certify compliance with this requirement.



Reporting:1) The permittee shall report to the Air Pollution Control Program Enforcement Section, P,O. Box 176,

Jefferson City, MO 65102, no later than ten days after the permittee determined that the emissionunit exceeded the emission limitation listed above.

2) Reports of any deviations from monitoring other than the pressure drop range, recordkeeping andreporting requirements of this permit condition shall be submitted semiannually, in the semi-annualmonitoring report and annual compliance certification, as required by Section IV ofthis permit.

PERMIT CONDITION EU0050-00210 CSR 10-6.220 Restriction of Emission ofVisible Air Contaminants




Monitoring:1) The permittee shall conduct opacity readings on this emission unit (EU0050) using the procedures

contained in USEPA Test Method 22. At a minimum, the observer should be trained andknowledgeable about the effects on visibility of emissions caused by background contrast, ambientlighting, observer position relative to lighting, wind and the presence ofuncombined water.Readings are only required when the emission unit is operating and when the weather conditionsallow. Ifno visible or other significant emissions are observed using these procedures, then nofurther observations would be required. For emission units with visible emissions perceived orbelieved to exceed the applicable opacity standard, the source representative would then conduct aMethod 9 observation.



2) The following monitoring schedule must be maintained:a) Weekly observations shall be conducted for a minimum ofeight consecutive weeks after permit

issuance. Should no violation of this regulation be observed during this period then-b) Observations must be made once every two weeks for a period ofeight weeks. If a violation is




Recordkeeping:1) The permittee shall maintain records of all observation results (see Attachments B1 or B2), noting:


2) The permittee shall maintain records ofany equipment malfunctions. (see Attachment C)3) The permittee shall maintain records ofany Method 9 test performed in accordance with this permit







2) Reports of any deviations from monitoring, recordkeeping and reporting requirements of this permitcondition shall be submitted semiannually, in the semi-annual monitoring report and annualcompliance certification, as required by Section N ofthis permit.

EU0060

EU0070

Spray dryer; MHDR 2 tonlhr, spray dryer installed 2002; heatedwith natural gas indirect-fIred burner; MHDR 4 MMBtu/br; burnerinstalled 2002; spray dryer and burner are part of an integralprocess and share the same control equipment and stack; equippedwith rim and second dust collectors and wet scrubberSpray dryer; MOOR 2.5 tonlhr, spray dryer installed 2002; heatedwith natural gas indirect-fIred burner; MOOR 8 MMBtu/br; burnerinstalled 2002; spray dryer and burner are part of an integralprocess and share the same control equipment and stack; equippedwith rim and second dust collectors and wet scrubber

Dryer Myers-SternerBurnerMaxon

Dryer Myers-SternerBurnerMaxon

EP-ll

EP-13



PERMIT CONDITION (EU0060 and EU0070)-OOl10 CSR 10-6.060 Construction Permits Required

Construction Permit 012002-007, Issued 11/7/200110 CSR 10-6.400 Restriction of Emission ofParticulate Matter From Industrial Processes

Emission Limitations:1) Particulate matter shall not be emitted from EU0060 in excess of 6.52Ib/hr.2) Particulate matter shall not be emitted from EU0070 in excess of7.58Ib/hr.3) This emission rate was calculated using the following equation:

E = 4.1 0(p)O.67Where:E = rate of emission in lb/hrP = process weight rate in ton/hr

4) The concentration ofparticulate matter in the exhaust gases shall not exceed 0.30 gr/scf.5) The permittee shall control emissions ofparticulate matter less than ten (10) microns in aerodynamic

-diameter (PMIO) from the spray dryers (EU0060 and EU0070) with a wet scrubber at all times whenthe dryer is in use. This scrubber shall be equipped with a gauge or meter, which indicates thepressure drop across the scrubber. This gauge or meter shall be located such that the Department ofNatural Resources' employees may easily observe it. [Permit 012002-007, Special Condition 1]

MonitoringlRecordkeeping:1) The permittee shall monitor and record the operating pressure drop across the scrubber at lease once

every twenty-four hours. The operating pressure drop shall be maintained within the designconditions specified by the manufacturer's performance warranty. (see Attachment E) [Pem1it012002-007, Special Condition 2]

2) The permittee shall maintain an operating and maintenance log for the scrubber which shall include'the following: (see Attachment C) [Permit 012002-007, Special Condition 3]a) Incident ofmalfunction, with impact on emission, duration of event, probably cause, and

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

3) Attachments C and E contain logs including these recordkeeping requirements. These logs, orequivalent forms created by the permittee, must be used to certify compliance with this requirement.




Jefferson City, MO 65102, no later than ten days after the permittee determined that the emissionunites) exceeded the emission limitation listed above.

2) Reports of any deviations from monitoring other than the pressure drop range, recordkeeping andreporting requirements ofthis permit condition shall be submitted semiannually, in the semi-annualmonitoring report and annual compliance certification, as required by Section IV of this permit.



PERMIT CONDITION (EU0060 and EU0070)-00210 CSR 10-6.220 Restriction ofEmission ofVisible Air Contaminants




Monitoring: .1) The peJ;1Ilittee shall conduct opacity readings on these emission units (EU0060 and EU0070) using

the procedures contained in USEPA Test Method 22. At a minimum, the observer should be trainedand knowledgeable about the effects on visibility of emissions caused by background contrast,ambient lighting, observer position relative to lighting, wind and the presence ofuncombined water.Readings are only required when the emission unit is operating and when the weather conditionsallow. Ifno visible or other significant emissions are observed using these procedures, then nofurther observations would be required. For emission units with visible emissions perceived orbelieved to exceed the applicable opacity standard, the source representative would then conduct aMethod 9 observation.


issuance. Should no violation ofthis regulation be observed during this period then-b) Observations must be made once every two weeks for a period of eight weeks. If a violation is

noted, monitoring reverts to weekly. Should no violation ofthis regulation be observed duringthis period then-



Recordkeeping:1) The permittee shall maintain records of all observation results (see Attachments Bl or B2), noting:


2) The permittee shall maintain records ofany equipment malfunctions. (see Attachment C)3) The permittee shall maintain records of any Method 9 test performed in accordance with this permit







Reporting:1) The pennittee shall report to the Air Pollution Control Program Enforcement Section, P.O. Box 176,


2) Reports ofany deviations from monitoring, recordkeeping and reporting requirements of this permitcondition shall be submitted semiannually, in the semi-annual monitoring report and annualcompliance certification, as required by Section IV of this permit.


IV. Core Permit Requirements


The installation shall comply with each of the following requirements. Consult the appropriate sectionsin the Code ofFederal Regulations (CFR) and Code of State Regulations (CSR) for the full text of theapplicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of thedate that this permit is issued.

110 CSR 10-6.050 Start-up, Shutdown and Malfunction Conditions1) 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 ofinstallation;b) Name and telephone number ofperson 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 ofexcess emissions;f) Cause ofthe excess emissions;g) Air pollutants involved;h) Best estimate of the magnitude ofthe 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; andj) 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 list to the director in writing at least ten days

prior to any maintenance, start-up or shutdown, which is expected to cause an excessive release ofemissions that exceed one hour. Ifnotice ofthe event cannot be given ten days prior to the plannedoccurrence, it shall be given as soon as practicable prior to the release. If an unplanned excessrelease of emissions exceeding one hour occurs during maintenance, start-up or shutdown, thedirector shall be notified verbally as soon as practical during normal working hours and no later thanthe close ofbusiness of the following working day. A written.notice shall follow within ten workingdays.

3) Upon receipt ofa notice of excess emissions issued by an agency holding a certificate of authorityunder section 643.140, RSMo, the permittee may provide information showing that the excessemissions were the consequence of a malfunction, start-up or shutdown. The information, at aminimum, should be the paragraph 1 list and shall be submitted not later than 15 days after receipt ofthe notice of excess emissions. Based upon information submitted by the permittee or any otherpertinent information available, the director or the commission shall make a determination whetherthe excess emissions constitute a malfunction, start-up or shutdown and whether the nature, extentand duration of the excess emissions warrant enforcement action under section 643.080 or 643.151,RSMo.

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

5) Compliance with this rule does not automatically absolve the permittee ofliability for the excessemissions reported.


110 CSR 10-6.060 Construction Permits Required


The pennittee shall not commence construction, modification, or major modification of any installationsubject to this rule, begin operation after that construction, modification, or major modification, or beginoperation of any installation which has been shut down longer than five years without first obtaining apennit from the pennitting authority.

110 CSR 10-6.065 Operating PermitsThe pennittee shall file a complete application for renewal of this operating permit at least six monthsbefore the date ofpennit expiration. In no event shall this time be greater than eighteen months.[10 CSR 1O-6.065(6)(B)l.A(V)] The pennittee shall retain the most current operating pennit issued tothis installation on-site. [10 CSR 10-6.065(6)(C) l.C(II)] The pennittee shall immediately make suchpennit available to any Missouri Department ofNatural Resources personnel upon request.[10 CSR 1O-6.065(6)(C)3.B]

110 CSR 10-6.110 Submission of Emission Data, Emission Fees and Process Information1) The pennittee shall complete and submit an Emission Inventory Questionnaire (EIQ) in accordance

with the requirements outlined in this rule.2) The permittee shall pay an annual emission fee per ton ofregulated air pollutant emitted according to

the schedule in the rule. This fee is an emission fee assessed under authority ofRSMo. 643.079 tosatisfy the requirements of the Federal Clean Air Act, Title V.

3) The fees shall be due June 1 each year for emissions produced during the previous calendar year.The fees shall be payable to the Department ofNatural Resources and shall be accompanied by theEmissions Inventory Questionnaire (EIQ) form or equivalent approved by the director.

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

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

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

1) The permittee shall not cause or allow to occur any handling, transporting or storing of any material;construction, repair, cleaning or demolition of a building or its appurtenances; construction or use ofa road, driveway or open area; or operation of a commercial or industrial installation withoutapplying reasonable measures as may be required to prevent, or in a manner which allows or mayallow, fugitive particulate matter emissions to go beyond the premises oforigin in quantities that theparticulate matter may be found on surfaces beyond the property line oforigin. The nature or originof the particulate matter shall be detennined to a reasonable degree of certainty by a techniqueproven to be accurate and approved by the director.

2) The permittee shall not cause nor allow to occur any fugitive particulate matter emissions to remainvisible in the ambient air beyond the property line oforigin.

0-



3) Should it be detennined that noncompliance has occurred, the director may require reasonablecontrol measures as may be necessary. These measures may include, but are not limited to, thefollowing:a) Revision of procedures involving construction, repair, cleaning and demolition ofbuildings and

their appurtenances that produce particulate matter emissions;b) Paving or frequent cleaning of roads, driveways and parking lots;c) Application ofdust-free surfaces;d) Application ofwater; ande) Planting and maintenance ofvegetative ground cover.

110 CSR 10-6.180 Measurement of Emissions of Air Contaminants1) The director may require any person responsible for the source of emission ofair contaminants to

make or have made tests to determine the quantity or nature, or both, of emission of air contaminantsfrom the source. The director may specify testing methods to be used in accordance with goodprofessional practice. The director may observe the testing. Qualified personnel shall perfonn alltests.

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

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

110 CSR 10-3.030 Open Burning Restrictions1) The pennittee shall not conduct, cause, pennit or allow a salvage operation, the disposal of trade

wastes or burning of refuse by open burning.2) Exception - Open burning oftrade waste or vegetation may be permitted only when it can be shown

that open burning is the only feasible method ofdisposal or an emergency exists which requires openburning.

3) Any person intending to engage in open burning shall file a request to do so with the director. The.request shall include the following:a) The name, address and telephone number of the person submitting the application; The type of

business or activity involved; A description of the proposed equipment and operating practices,the type, quantity and composition of trade wastes and expected composition and amount of aircontaminants to be released to the atmosphere where known;

b) The schedule ofburning operations;c) The exact location where open burning will be used to dispose of the trade wastes;d) Reasons why no method other than open burning is feasible; ande) Evidence that the proposed open burning has been approved by the fire control authority which

has jurisdiction.4) Upon approval ofthe open burning pennit application by the director, the person may proceed with

the operation under the tenns of the open burning pennit. Be aware that such approval shall notexempt DairiConcepts, L.P. from the provisions of any other law, ordinance or regulation.

5) The pennittee shall maintain files with letters from the director approving the open burningoperation and previous DNR inspection reports.



110 CSR 10-3.090 Restriction of Emission of Odors INo person may cause, permit or allow the emission of odorous matter in concentrations and frequenciesor for durations that odor can be perceived when one volume of odorous air is diluted with sevenvolumes ofodor-free air for two separate trials not less than 15 minutes apart within the period of onehour.

This requirement is not federally enforceable.

ITitle VI - 40 CFR Part 82 Protection of Stratospheric Ozone1) The permittee shall comply with the standards for labeling ofproducts using ozone-depleting

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

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

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

c) The form ofthe label bearing the required warning statement must comply with the requirementspursuant to §82.110.

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

2) The permittee shall comply with the standards for recycling and emissions reduction pursuant to40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners (MYACs) inSubpart B:a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices pursuant to §82.156.b) Equipment used during the maintenance, service, repair, or disposal ofappliances must comply

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

an approved technician certification program pursuant to §82.161.d) Persons disposing of small appliances, MYACs, and MYAC-like appliances must comply with

recordkeeping requirements pursuant to §82.166. ("MVAC-like" appliance as defined at§82.152).

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

f) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keeprecords ofrefrigerant purchased and added to such appliances pursuant to §82.166.

3) If the permittee manufactures, transforms, imports, or exports a class I or class II substance, thepermittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A, Productionand 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 airconditioner (MYAC), the permittee is subject to all the applicable requirements as specified in40 CFR part 82, Subpart B, Servicing ofMotor 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 beencompleted. The term "MYAC" as used in Subpart B does not include the air-tight sealedrefrigeration system used as refrigerated cargo, or system used on passenger buses using HCFC-22refrigerant.

DairiConcepts, L.P.mstallation ill: 039-0003


The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that islisted 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

110 CSR 10-(i.280 Compliance Monitoring Usage1) The permittee is not prohibited from using the following in addition to any specified compliance

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

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

2) Any credible evidence may be used for the purpose of establishing whether a permittee has violatedor is in violation of any such plan or other applicable requirement. Information from the use of thefollowing methods is presumptively credible evidence ofwhether a violation has occurred by apermittee: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; andc) 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 credibletesting, monitoring, or information gathering methods:a) Applicable monitoring or testing methods, cited in:

i) 10 CSR 10-6.030, "Sampling Methodsfor 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, thatproduce information comparable to that produced by any method listed above.

DairiConcepts, L.P.mstallation ill: 039-0003


v. General Permit RequirementsThe installation shall comply with each ofthe following requirements. Consult the appropriate sectionsin the Code ofFederal Regulations (CFR) and Code of State Regulations (CSR) for the full text of theapplicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of thedate that this permit is issued,

\10 CSR 10-6.065(6)(C)1.B PermirDurationThis permit is issued for a term of five years, commencing on the date of issuance. This permit willexpire at the end ofthis period unless renewed.

110 CSR 10-6.065(6)(C)1.C General Recordkeeping and Reporting Requirements1) Recordkeeping

a) All required monitoring data and support information shall be retained for a period of at leastfive years from the date of the monitoring sample, measurement, report or application.

b) Copies ofall current operating and construction permits issued to this installation shall be kepton-site for as long as the permits are in effect. Copies of these permits shall be made immediatelyavailable to any Missouri Department ofNatural Resources' personnel upon request.

2) Reportinga) All reports shall be submitted to the Air Pollution Control Program, Enforcement Section,

P. O. Box 176, Jefferson City, MO 65102.b) The permittee shall submit a report of all required monitoring by:

i) October 1st for monitoring which covers the January through June time period, andii) April 1st for monitoring which covers the July through December time period.iii) Exception. Monitoring requirements which require reporting more frequently than semi

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

c) Each report shall identify any deviations from emission limitations, monitoring, recordkeeping,reporting, or any other requirements of the permit, this includes deviations or Part 64exceedances.

d) Submit supplemental reports as required or as needed. Supplemental reports are required no laterthan ten days after any exceedance of any applicable rule, regulation or other restriction. Allreports ofdeviations shall identify the cause or probable cause of the deviations and anycorrective actions or preventative measures taken.i) Notice of any deviation resulting from an emergency (or upset) condition as defined in

paragraph (6)(C)7.A of 10 CSR 10-6.065 (Emergency Provisions) shall be submitted to thepermitting authority either verbally or in writing within two working days after the date onwhich the emission limitation is exceeded due to the emergency, ifthe permittee wishes toassert an affirmative defense. The affirmative defense of emergency shall be demonstratedthrough properly signed, contemporaneous operating logs, or other relevant evidence thatindicate 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 duringthe period of the emergency the permittee took all reasonable steps to minimize levels ofemissions that exceeded the emission standards or requirements in the permit. The noticemust contain a description ofthe emergency, the steps taken to mitigate emissions, and thecorrective actions taken.

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


Part 70 Operating Penl1it 25Project No. 2005-08-071

iii) Any other deviations identified in the permit as requiring more frequent reporting than thepermittee's semiannual report shall be reported on the schedule specified in this permit, andno later than ten days after any exceedance of any applicable rule, regulation, or otherrestriction.

e) Every report submitted shall be certified by the responsible official, except that, if a report of adeviation must be submitted within ten days after the deviation, the report may be submittedwithout a certification if the report is resubmitted with an appropriate certification within tendays after that, together with any corrected or supplemental information required concerning thedeviation.

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

110 CSR 10-6.065(6)(C)I.D Risk Management Plan Under Section 112(r)The permittee shall comply with the requirements of40 CPR Part 68, Accidental Release PreventionRequirements. If the permittee has more than a threshold quantity ofa regulated substance in process, asdetermined by 40 CPR Section 68.115, the permittee shall submit a Risk Management Plan inaccordance with 40 CPR Part 68 no later than the latest of the following dates:1) June 21, 1999;2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130;

or3) The date on which a regulated substance is first present above a threshold quantity in a process.

110 CSR 1O-6.065(6)(C)l.F Severability ClauseIn the event of a successful challenge to any part of this permit, all uncontested permit conditions shallcontinue to be in force. All terms and conditions of this permit remain in effect pending anyadministrative or judicial challenge to any portion ofthe permit. If any provision ofthis permit isinvalidated, the permittee shall comply with all other provisions of the permit.

110 CSR 10-6.065(6)(C)l.G General Requirements1) 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, permittermination, permit revocation and re-issuance, permit modification or denial of a permit renewalapplication.

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

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

4) This permit does not convey any property rights ofany 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 infonnation that the Air Pollution Control Program reasonablymay require to determine whether cause exists for modifying, reopening, reissuing or revoking thepermit or to deterrp.ine compliance with the permit. Upon request, the permittee also shall furnish tothe 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 pursuant to10 CSR 1O-6.065(6)(C)1.

110 CSR 1O-6.065(5)(C)l.H Incentive Programs Not Requiring Permit RevisionsNo permit revision will be required for any installation changes made under any approved economicincentive, marketable permit, emissions trading, or other similar programs or processes provided for inthis permit.

110 CSR lO-6.065(5)(C)1.C Reasonably Anticipated Operating ScenariosNone

110 CSR 10-6.065(6)(C)3 Compliance Requirements1) 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 ofthe Missouri Department ofNatural Resources, or their authorizedagents, to perform the following (subject to the installation's right to seek confidential treatment ofinformation submitted to, or obtained by, the Air Pollution Control Program):a) Enter upon the premises where a permitted installation is located or an emissions-relatedactivity

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 orrequired under this permit; and

d) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the Act, sample ormonitor, at reasonable times, substances or parameters for the purpose of assuring compliancewith 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 submittedsemiannually (or more frequently ifspecified in the applicable requirement). These progress reportsshall 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, andb) An explanation ofwhy 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 applicablerequirement specifies more frequent submission. These certifications shall be submitted to EPARegion VII, 901 North 5th Street, Kansas City, Kansas 66101, as well as the Air Pollution ControlProgram, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and Part 64exceedances and excursions must be included in the compliance certifications. The compliancecertification shall include the following:a) The identification of each term or condition of the permit that is the basis ofthe 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 methodes) used for determining the compliance status of the installation, both currently andover the reporting period; and

e) Such other facts as the Air Pollution Control Program will require in order to determine thecompliance status of this installation.

110 CSR 10-6.065(6)(C)6 Permit Shield1) Compliance with the conditions of this permit shall be deemed compliance with all applicable

requirements as of the date that this permit is issued, provided that:a) The application requirements are included and specifically identified in this permit, orb) The permitting authority, in acting on the permit revision or permit application, determines in

writing that other requirements, as specifically identified in the permit, are not applicable to theinstallation, and this permit expressly includes that determination or a concise summary of it.

2) Be aware that there are exceptions to this permit protection. The permit shield does not affect thefollowing:a) The provisions of section 303 ofthe Act or section 643.090, RSMo concerning emergency

orders,b) Liability for any violation of an applicable requirement which occurred prior to, or was existing

at, the time ofpermit issuance,c) The applicable requirements of the acid rain program,d) The authority of the Environmental Protection Agency and the Air Pollution Control Program of

the Missouri Department ofNatural Resources to obtain information, ore) Any other permit or extra-permit provisions, terms or conditions expressly excluded from the

permit shield provisions.

110 CSR 10-6.065(6)(C)7 Emergency Provisions1) An emergency or upset as defined in 10 CSR 1O-6.065(6)(C)7.A shall constitute an affirmative

defense to an enforcement action brought for noncompliance with technology-based emissionslimitations. 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 ofthe

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, andd) That the permittee submitted notice ofthe emergency to the Air Pollution Control Program

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

2) Be aware that an emergency or upset shall not include noncompliance caused by improperlydesigned equipment, lack ofpreventative maintenance, careless or improper operation, or operatorerror.

110 CSR 10-6.065(6)(C)8 Operational FlexibilityAn installation that has been issued a Part 70 operating permit is not required to apply for or obtain apermit revision in order to make any of the changes to the permitted installation described below if thechanges are not Title I modifications, the changes do not cause emissions to exceed emissions allowableunder the permit, and the changes do not result in the emission of any air contaminant not previously



emitted. The pennittee shall notify the Air Pollution Control Program, Enforcement Section,P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 901 North 5th Street,Kansas City, Kansas 66101, at least seven days in advance of these changes, except as allowed foremergency or upset conditions. Emissions allowable under the permit means a federally enforceablepennit tenn or condition determined at issuance to be required by an applicable requirement thatestablishes an emissions limit (including a work practice standard) or a federally enforceable emissionscap that the source has assumed to avoid an applicable requirement to which the source would ot4erwisebe subject.1) Section 502(b)(1 0) changes. Changes that, under section 502(b)(1 0) ofthe Act, contravene an

express pennit tenn may be made without a pennit revision, except for changes that would violateapplicable requirements ofthe Act or contravene federally enforceable monitoring (including testmethods), recordkeeping, reporting or compliance requirements of the pennit.a) Before making a change under this provision, The permittee shall provide advance written notice

to the Air Pollution Control Program, Enforcement Section, P.O. Box 176, Jefferson City, MO .65102, as well as EPA Region VII, 901 North 5th Street, Kansas City, Kansas 66101, describingthe changes to be made, the date on which the change will occur, and any changes in emissionand any pennit terms and conditions that are affected. The permittee shall maintain a copy ofthenotice with the permit, and the APCP shall place a copy with the permit in the public file.Written notice shall be provided to the EPA and the APCP as above at least seven days beforethe change is to be made. Ifless than seven days notice is provided because of a need to respondmore quickly to these unanticipated conditions, the permittee shall provide notice to the EPA andthe APCP as soon as possible after learning ofthe need to make the change.

b) The pennit shield shall not apply to these changes.

110 CSR 10-6.065(6)(C)9 Off-Permit Changes1) Except as noted below, the permittee may make any change in its permitted operations, activities or

emissions that is not addressed in, constrained by or prohibited by this permit without obtaining apennit revision. Insignificant activities listed in the application, but not otherwise addressed in orprohibited by this pennit, shall not be considered to be constrained by this pennit for purposes of theoff-pennit provisions of this section. Off-pennit changes shall be subject to the followingrequirements and restrictions:a) The change mustmeet all applicable requirements of the Act and may not violate any existing

pennit tenn or condition; the permittee may not change a permitted installation without a permitrevision ifthis change is subject to any requirements under Title IV ofthe Act or is a Title Imodification;

b) The pennittee must provide written notice of the change to the Air Pollution Control Program,Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII,901 North 5th Street, Kansas City, Kansas 66101, no later than the next annual emissions report.This notice shall not be required for changes that are insignificant activities under10 CSR 1O-6.065(6)(B)3. This written notice shall describe each change, including the date, anychange in emissions, pollutants emitted and any applicable requirement that would apply as aresult of the change.

c) The pennittee shall keep a record describing all changes made at the installation that result inemissions ofa regulated air pollutant subject to an applicable requirement and the emissionsresulting from these changes; and

d) The pennit shield shall not apply to these changes.



If the responsible official has changed since the application was submitted. change the first sentence inthis regulation to the following two sentences. "The application utilized in the preparation of this permitwas signed by X. On Y, the Air Pollution Control Program was infonned that Z is now the responsibleofficial." Replace the X with the original responsible official's name and title. Replace the Y with thedate of the letter changing to the most recent responsible official. Replace the Z with this responsibleofficial's name and title.

110 CSR 10-6.020(2)(R)12 Responsible OfficialThe application utilized in the preparation of this pennit was signed by Brian Bonebright, V.P.Operations. If this person tenninates employment, or is reassigned different duties such that a differentperson becomes the responsible person to represent and bind the installation in environmental pennittingaffairs, the owner or operator of this air contaminant source shall notify the Director of the Air PollutionControl Program of the change. Said notification shall be in writing and shall be submitted within30 days ofthe change. The notification shall include the name and title of the new person assigned bythe source owner or operator to represent and bind the installation in environmental pennitting affairs.All representations, agreement to tenns and conditions and covenants made by the former responsibleperson that were used in the establishment oflimiting pennit conditions on this permit will continue tobe binding on the installation until such time that a revision to this pennit is obtained that would changesaid representations, agreements and covenants.

110 CSR 10-6.065(6)(E)6 Reopening-Permit for CauseThis permit may be reopened for cause if:1) The Missouri Department ofNatural Resources receives notice from the Environmental Protection

Agency (EPA) that a petition for disapproval ofa pennit pursuant to 40 CFR § 70.8(d) has beengranted, provided that the reopening may be stayed pending judicial review of that determination,

2) Missouri Department ofNatural Resources or EPA detennines that the permit contains a materialmistake or that inaccurate statements were made which resulted in establishing the emissionslimitation standards or other tenns of the permit,

3) 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;

orc) 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 pennit,4) The installation is an affected source under the acid rain program and additional requirements

(including excess emissions requirements), become applicable to that source, provided that, uponapproval by EPA, excess emissions offset plans shall be deemed to be incorporated into the pennit;or

5) Missouri Department ofNatural Resources or EPA detennines that the permit must be reopened andrevised to assure compliance with applicable requirements.

110 CSR 10-6.065(6)(E)I.C Statement of BasisThis permit is accompanied by a statement setting forth the legal and factual basis for the draft pennitconditions (including references to applicable statutory or regulatory provisions). This Statement ofBasis, while referenced by the pennit, is not an actual part of the pennit.


Part 70 Operating Pennit 30Project No. 2005~08-071

If there are attachments, put them one to a page starting on the next page. Separate them with pagebreaks, not section breaks. If there are no attachments, delete the following lines down to, but notincluding the Section Break (Next Page).

VI. ATTACHMENTS

Attachments follow.



ATTACHMENT A10 CSR 10-3.060 Compliance Demonstration

This attachment may be used to demonstrate that the listed emission units are in compliance with 10CSR 10-3.060, Restriction ofEmission ofParticulate Matter from Fuel Burning Equipment UsedforIndirect Heating.

Installation's Total Heat Input (Q

EUOOlOEU0020EU0050EU0060EU0070

s ace heaters

5625.106

1848

0.6

Allowable PM emission limitation for new indirect heating source having an intermediate capacitybetween 10 MMBtu and 2,000 MMBtu: E = 1.31 (QrO.338

E = 1.31(111.71r°.338 = 0.271b/MMBtu

natural 7.61b AP-42 1050MMBtu0.007 0.27 YES

EUOOlOas /106 sef Table 1.4-2 /106 sef

fuel oil 10ib AP-42 150MMBtu#6 /103 al Table 1.3-1 /103 al 0.067 0.27 YES

natural 7.6 AP-42 1050MMBtu0.007 0.27 YES

EUOO20as Ib/106 sef Table 1.4-2 /106 scf

fuel oil 2lb AP-42 140MMBtu#2 /103 al Table 1.3-1 /103 al

0.014 0.27 YES

The calculations show that no further monitoring or recordkeeping is necessary because the emissionunit's worst-case emissions are substantially lower than the applicable limit.



ATTACHMENT B-1Method 22 (Outdoor) Observation Log

This recordkeeping sheet or an equivalent form may be used for the recordkeeping requirements of 10CSR 10-6.220, Restriction ojEmission ojVisible Air Contaminants.

DairiConcepts, L.P.fustallation ill: 039-0003


ATTACHMENT B-2Method 22 (Outdoor) Observation Log

This recordkeeping sheet or an equivalent fonn may be used for the recordkeeping requirements of 10CSR 10-6.220, Restriction a/Emission 01 Visible Air Contaminants.

Emission Unit

Observer

Sky Conditions

Precipitation

Wind Direction

Date

.Wind Speed

Sketch process unit: Indicate the position relative to the source and sun; mark the potential emission points and/orthe observing emission points.

Begin Observation

End Observation



ATTACHMENT CInspection/MaintenancelRepair/Malfunction Log

This recordkeeping sheet or an equivalent fonn may be used to record inspections of equipment,maintenance, calibration, repairs and malfunctions.



ATTACHMENT DMethod 9 Opacity Emissions Observations

This recordkeeping sheet or an equivalent fonn may be used for the recordkeeping requirements of 10CSR 10-6.220, Restriction a/Emission a/Visible Air Contaminants.

Company

Location

Date

Time

Observer

Observer Certification Date

Emission Unit

Control Device

o123456789101112131415161718

Readings ranged from to % opacity.

Was the emission unit in compliance at the time of evaluation?YES NO Signature of Observer



ATTACHMENT EPressure Drop Log

This recordkeeping sheet or an equivalent form may be used to record daily pressure drop readings.


Operating Pennit

STATEMENT OF BASIS

SB -1Project No. 2005-08-071

Permit Reference DocumentsThese documentswere relied upon in the preparation ofthe operating permit. Because they are notincorporated by reference, they are not an official part of the operating permit.

1) Part 70 Operating Permit Application, received August 29,2005;2) 2004 Emissions Inventory Questionnaire, received February 26,2005;3) U.S. EPA document AP-42, Compilation ofAir Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition. .

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

None,

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

10 CSR 10-6.100, Alternate Emission Limits does not apply to this installation because the installation isnot in a non-attainment zone.

Construction Permit RevisionsThe following revisions were made to construction permits for this installation:I) Construction Permit 032000-004 authorized the installation of a direct fired natural gas burner

(EU0050) for an existing spray dryer.a) Special Condition 2 states that the permittee " ...shall monitor and record the operating pressure

drop across the baghouse..." However, this statement should read " ...shall monitor and recordthe operating pressure drop across the scrubber..." because Special Condition 1 required that awet venturi scrubber, not a baghouse, be installed and operated at all times the dryer is in use.

b) This permit indicated that 10 CSR 10-3.080, Restriction ofEmission ofVisible Air Contaminant,and 10 CSR 10-3.050, Restriction ofEmission ofParticulate from Industrial Processes, wereapplicable rules. These rules were rescinded and replaced by 10 CSR 10-6.220 and10 CSR 10-6.400, respectively.

c) This permit indicated that 10 CSR 10-6.260, Restriction ofEmission ofSulfur Compounds wasan applicable rule. However, according to §(1)(A)2, any combustion equipment that usesexclusively pipeline grade natural gas as defined in 40 CFR 72.2 is exempt from the provisionsof this rule.

NSPS Applicability1) 40 CFR Part 60 Subpart Dc, Standards ofPerformance for Small Industrial-Commercial

Institutional Steam Generating Units


Operating Permit SB -2Project No. 2005-08-071

This rule applies to a steam generating unit for which construction, modification, or reconstruction iscommenced after June 9, 1989 and that has a maximum design heat input capacity ofless than orequal to 100 MMBtu/hr but greater than or equal to 10 MMBtu!hr.a) EUOOlO (Boiler #1) was constructed in 1982 alld therefore is not subject to this rule.b) EU0020 (Boiler #2) was constructed in 1999 and has a maximum design input capacity of

25.106 MMBtu/hr and therefore is subject to this subpart when burning fuel oil #2.2) 40 CFR Part 60 Subpart K, Standards ofPerformance for Storage Vessels for Petroleum Liquids for

Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior toMay 19,197840 CFR Part 60 Subpart Ka, Standards ofPerformance for Storage Vessels for Petroleum Liquidsfor Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Priorto July 23, 198440 CFR Part 60 Subpart Kb, Standards ofPerformance for Volatile Organic Liquid Storage Vessels(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, orModification Commenced After July 23,1984The three storage vessels at this facility were constructed prior to 1963 and therefore are not subjectto these rules.

None of the other New Source Performance Standards apply to this installation.

MACT ApplicabilityThe facility does not emit any single hazardous air pollutant (HAP) in an amount greater than10 tons per year nor does the facility emit any combination ofHAP in an amount greater than25 tons per year. Therefore, MACT regulations (40 CFR Part 63) are not applicable to this facility.

NESHAP Applicability10 CSR 10-6.080, Emission Standardsfor Hazardous Air Pollutants40 CFR Part 61 Subpart M, National Standardsfor Asbestos10 CSR 10-6.250, Asbestos Abatement Projects - Certification, Accreditation, and Business ExemptionMissouri Air Conservation Law Asbestos Abatement, 643.225 through 643.250

In the permit application and according to Air Pollution Control Program records, there was noindication that any of these requirements apply to this installation. The installation is subject tothese regulations ifthey undertake any projects that deal with or involve any asbestos containingmaterials. None ofthe installation's operating projects underway at the time ofthis review deal withor involve asbestos containing material. .Therefore, the above regulations were not cited in theoperating permit. Ifthe installation should undertake any construction or demolition projects in thefuture that deal with or involve any asbestos containing materials, the installation must follow all ofthe applicable requirements of the above rules related to that specific project.

None of the other National Emission Standards for Hazardous Air Pollutants (NESHAPs) apply to thisinstallation.

CAM Applicability40 CFR Part 64, Compliance Assurance Monitoring (CAM)

At the time of issuance, the permittee does not have any emission units subject to the applicabilityportion of40 CFR Part 64 requiring submittal of a CAM plan; none ofthe pollutant-specificemission units have precontrol emissions that exceed or are equivalent to the major source threshold.

DairiConcepts, L.P.e Installation ill: 039-0003

Operating Pennit SB -3Project No. 2005-08-071

Other Regulatory Determinations1) 10 CSR 10-3.060, Restriction ofEmission ofParticulate Matter From Fuel Burning Equipment

Usedfor Indirect Heatinga) This rule is not applicable to EU0050 (Spray Dryer #1), EU0060 (Spray Dryer #2), or EU0070

(Spray Dryer #3) because these emission units are direct-fired.2) 10 CSR 10-6.260, Restriction ofEmission ofSulfur Compounds

a) According to §(1)(A)I, emission sources subject to an applicable sulfur compound emissionlimit under 10 CSR 10-6.070 are exempt from this rule. Since EU0020 (Boiler #2) is subject to10 CSR 10-6.070, the unit is not subject to this rule.

b) According to §(1)(A)2, any combustion equipment that uses exclusively pipeline grade naturalgas as defined in 40 CFR 72.2 is exempt from the provisions of this rule.

3) 10 CSR 10-6.400, Restriction ofEmission ofParticulate Matter From Industrial Processesa) This rule is not applicable to EUOOIO (Boiler #1) and EU0020 (Boiler #2) because according to

§(1)(B)6 the burning of fuels for indirect heat is exempt.b) This rule is applicable to EU0030 (Blending for Dryer #1), EU0040 (Blending for Dryer #2),

EU0050 (Spray Dryer #1), EU0060 (Spray Dryer #2), and EU0070 (Spray Dryer #3). Thecalculations below verify compliance provided the required control devices are in operation andworking properly:

PM Emission Rate ComplianceEmission Rate Limit (lb/hr) E = 4.1(p)O.67Where: P = rocess wei t rate (ton/hr)

EU0030

EU0040

Blending forD er#1

Blending forD er#2'

4

2

5.5

5.5

0.98

0.98

0.44

0.22

10.38

6.52

EU0050 S ra D er #1 4 2.5 See note 2 10.00 10.38EU0060 S ra D er #2 2 2.5 See note 2 5.00 6.52EU0070 S ray D er #3 2.5 2.5 See note 2 6.25 7.58

1. EU0030 and EU0040: The uncontrolled PM emission factor was reported by facility; Brent Rottinghaus'1/27/2000 letter to the MDNR states "the uncontrolled PM emi~sion rate for blending was recentlydeteqnined to be 5.5 pounds per ton."

2. EU0050, EU0060 & EU0070: EPA document AP-42 does not list a PM emission factor for SCC#30203001, milk spray dryer. The PM emission factor for SCC 30203020, cheese dryer with wet scrubberor venturi scrubber, is given as 2.5Ib/ton in AP-42 Chapter 9.6.1.


Operating Permit SB -4Project No. 2005-08-071

PM Concentration ComplianceEmission rate (gr/dscf) = Emission Rate (lb/hr)*7000 (grains/lb)/Stack flow rate (SCFM)/60(min/hr)Flow rates converted from actual to standard conditions usin the ideal as law.

EU0030 0.44 65 3,000 3,017 0.02 0.3

EU0040 0.22 65 3,000 3,017 0.01 0.3

EU0050 10.00 160 53,500 45,561 0.03 0.3

EU0060 5.00 130 41,000 36,692 0.02 0.3

EU0070 6.25 130 25,000 22,373 0.03 0.3

Other Regulations Not Cited in the Operating Permit or the Above Statement of BasisAny regulation which is not specifically listed in either the Operating Permit or in the above Statementof Basis does not appear, based on this review, to be an applicable requirement for this installation forone 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 regulationscited in this Statement ofBasis or other regulations which were not cited, the installation shall determineand demonstrate, to th~ Air Pollution Control Program's satisfaction, the installation's compliance withthat regulation(s). If the installation is not in compliance with a regulation which was not previouslycited, the installation shall submit to the Air Pollution Control Program a schedule for achievingcompliance for that regulation(s).

Prepared by:

sjI]n<'l~I1L~h-.......__Jill S~adeEnvironmental Engineer