Flr;;;l --- - - -- _-.··- - ----:----­~EJ MISSOURI - . ITTj & 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: · 1 0 2 0 1 7 - 01 6 Project Number: 2017-07-019 Installation Number: 095-0011

Parent Company: Bayer CropScience LP

Parent Company Address: 2 TW Alexander Drive, Research Triangle Park, NC 27709

Installation Name:

Installation Address:

Location Information:

Bayer CropScience

8400 Hawthorn Road, Kansas City, MO 64120

Jackson County (S29, T50N, R32W)

Application for Authority to Construct was made for: The installation of new equipment and t_he modification of existing equipment to allow for the production of Fluopyram in the Sencor/FOE Plant. 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.

@ Standard Conditions (on reverse) and Special Conditions are applicable to this permit.

~~ Prepared by Ryan Schott New Source Review Unit

DirectorDesignee Department of Natural Resources

OCT 2· s- 2017 Effective Date

STANDARD CONDITIONS:

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

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

You must notify the Enforcement and Compliance Section of the Department's Air Pollution Control Program of the anticipated date of startup 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 startup of this (these) air contaminant source(s).

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

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

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

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

Contact Information: Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

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

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

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Project No. 2017-07-019 Permit No.

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

The special conditions listed in this permit were included based on the authority granted the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075) and by the Missouri Rules listed in Title 10, Divis.ion 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."

Bayer CropScience Jackson County (S29, T50N, R32W)

1. Superseding Condition The conditio~s of this permit supersede Special Conditions 2 and 3, found in Construction Permit No. 022017-004, previously issued by the Air Pollution Control Program.

2. Installation-Wide Emission Limitations A Bayer CropScience shall not exceed the annual plant-wide emission limits

listed below in Table 1. All limits are based on a consecutive 12-month period. The limits apply to emissions from all equipment/processes installed or permitted at Bayer CropScience as of the issuance date of this permit.

Table 1. Installation-Wide-Emission Limits ,:1t'!s,J1;,;, i~'Zf Pr\;;,_;;·;:., ,,:1tTI:i1:" i f~;froJ~~i6n1~CirrlI,;.'.: ,~

PM 99.0 PM10 99.0 SOx 99.0 NOx 99.0 voe 99.o co 99.0

Anv Individual HAP 9.9 Total HAPs 24.9

T.-

B. Bayer CropScience shall develop and use forms to demonstrate compliance with Special Condition 2.A. The forms shall contain at a minimum the following information: 1) Installation name & ID number 2) Permit number 3) Current month 4) Pollutants 5) Emission units 6) Each emission unit's respective current monthly throughput 7) Each emission unit's respective emission factor and emission factor

source (project emission factors can be found in Appendix B) 8) Total pollutant emissions from the month · 9) 12-month rolling total pollutant emissions 10) Indication of compliance status with Special Condition 2.A.

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Project No. 2017-07-019

Permit No. 1 0 2 0 1 7 "' 0 1 6

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

C. As available, the emission factors and demonstrated control efficiencies developed from the most recent performance testing shall be used in the recordkeeping developed under Special Condition 2.8.

3. Vent Stream Control Devices A. Source operations subject to 10 CSR 10-2.320 (see column "Subject to

Special Condition 3.A." in Table 2) shall vent emissions to a VOC emissions control device.

8. Process vents subject to 40 CFR 63 Subpart VVVVVV (MACT 6V) Table· 3 . emission limitations (see column "Subject to Special condition 3.8." in Table 2) must route emissions through a closed vent system to a HAP reduction device.

C. Emissions from vent streams controlled through combustion must be routed to a halogen reduction device.

D. One or more control devices shall be in operation at all times when emissions from one or more emission units or processes associated with the vent streams specified in Special Condition 3.A. or 3.8. are vented to them.

Table 2: Emission Units & Control Devices

0.1-D1 Steam Boiler #1 0.1-D2 Steam Boiler #2 1.0-F1 K2, Herbicide Formulation Plant Vent

2.8-1<2 TDA TDA Process X X 3.6-1<2 309 AE309 KSalt Process X 3.6-1<2 747 AE747 KSalt Process X

4.0-F1 K4, Char in to 4.1-X1/X2 - 4.4-X1/X2 4.0-K1 FOL Folicur Process - WW Stri er X 4.0-K1 SEN Sencor Process X 4.0-1<2 FOL X

4.2-F5 4.4-F2 4.6-F6 Folicur Packa in

5.0-82COMB TDA/FOE Combined Process X X 5.0-84 FOE FOE Process X 5.0-1<2 309 AE 309 Al Process X 5.0-1<2 747 AE7 4 7 Al Process X 5.0-1<2 CY C clanilide Process X 5.0-K2 H61 MKH 6561 Process X

5.2-F3 K2, Sencor Silo Vent

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Project No. 2017-07-019

Permit No. 1 0 2 0 1 7' - 0 1 6

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

1

5.4-81 K4, Glycerin Tank 5.4-82 K4, Propylene Glycol Tank 5.4-84 K4, Sunspray Tank 6.3-F1 K2, Folicur Repack

7.2-K1 J12 JAU Steps 1-2 Processes X 8.0-K1 JA4 JAU Steps 3-4 Chloromethylketone X 8.0-K1 JA5 JAU Step 5 Process X 8.7-K1 309 AE309 Acid Chloride Process X 8.7-K1 747 AE747 Acid Chloride Process X

EP3-T02TKF Thermal Oxidizer II Tank Farm Vent EP3-WTP WTP Vents to WTP Hypo Scrubber-Divert

EP5 Thermal Oxidizer II EP6 Thermal Oxidizer II Fuel Oil Tanks EP20 Fenton Wastewater Treatment

EU0001 Parts Washers EU0003(1) Cooling Tower, Site I EU0003(11). Cooling Tower, Site II

EU0003(1VP) Cooling Tower, Site IV Process EU0003(1VU) Cooling Tower, Site IV Utilities

FLU-01 Fluopyram Process X FLU-02 TFMB-Amide Bag Unloading FLU-03 Potassium Hydroxide Bag Unloading FLU-04 Potassium Hydroxide Transfer FLU-05 Fluopyram Packaging

ICE-GT600 Internal Combustion Engines (>600 HP) (ICE-SEG-1, through ICE-SEG-6)

Internal Combustion Engines (<600 HP)

ICE-LT600 (ICE-FWP-1 through ICE-FWP-3, ICE-SWP-1 through ICE-SWP-4, ICE-SEG-7,

and ICE-SEG-8)

ICE-NG Internal Combustion Engines (Natural Gas) (ICE-SEG-9 and ICE-SEG-10) '

ICE-SEG-11 Internal Combustion Engine (Gasoline) K1-001 GA Production

Maint-001 2,000 qallon Gasoline Storage Tank Maint-002 Site IV Maint. Diesel Tank

VGl-01 Vent Gas Incinerator (VGI) WASH-001 Washouts (various) ..

The TDA/FOE Combined Process represents an em1ss1on point resulting from the combination of process vent streams from the TDA Process (2.8-K2 TDA) and from the FOE Process (5.0-84 FOL). Emissions from 5.082COMB may be regulated under MACT 6V because they may contain process vent emissions from 2.8-1<2 TDA (regulated under MACT 6V); however, 5.0B2COMB is not itself a chemical manufacturing process unit subject to MACT 6V. ·

4. Control Device Requirement - Vent Gas Incinerator & Thermal Oxidizer A. Bayer CropScience shall control emissions from the Fluopyram production

process (FLU-01) using either a vent gas incinerator (VGl-01) or a thermal oxidizer (EP5), as specified in the permit application.

B. Bayer CropScience shall operate the vent gas incinerator using the minimum combustion chamber temperature and maximum natural gas flow rate determined by the performance testing required by Special Conditions 4 and 8 of Construction Permit No. 062015-006.

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SPECIAL CONDITIONS:

Project No. JQOj?-07-019 . O l /J Permit No. l 2 0 1 7 "' .. u

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

C. The vent gas incinerator and thermal oxidizer shall be operated and maintained in accordance with the manufacturer's specifications, which shall be kept onsite.

D. Bayer CropScience shall maintain an operating and maintenance log for the vent gas incinerator and thermal oxidizer, which shall include the following: 1) Incidents of malfunction, with impact on emissions (tons), duration

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

and replacements, etc.

5. Control Device Requirement - Venturi Scrubbers A. Bayer CropScience shall control emissions from TFMB-amide bag

unloading (FLU-02), potassium hydroxide bag unloading (FLU-03), and Fluopyram packaging (FLU-05) using venturi scrubbers (2.2-KS, 2.1-K34, and 5.3-KS respectively), as specified in the permit application.

B. The venturi scrubbers shall be operated and maintained in accordance with the manufacturer's specifications. The scrubbers shall be equipped with gauges or meters, which indicate the pressure drop across the control devices. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them.

C. Bayer CropScience shall monitor and record the operating pressure drop across the venturi scrubbers at least once each day during solids charging or packaging. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty.

D. Bayer CropScience shall monitor the liquid flow rate into the venturi scrubbers at least once each day during solids charging or packaging and maintain a liquid flow rate within the manufacturers' specifications.

E. Bayer CropScience shall maintain copies of the venturi scrubber manufacturers' performance warrantie~ onsite.

F. Bayer CropScience shall maintain an operating and maintenance log for the venturi scrubbers, which shall include the following: 1) Incidents of malfunction, with impact on emissions (tons), duration

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

and replacements, etc.

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Project No. 2017-07-019 Permit No. 1 0 2 O 1 7 ~ () 1 6

SPECIAL CONDITIONS: The permittee is authorized to construct arid operate subject to the following special conditions:

6. Control Device Requirement - Cartridge Filters A. Bayer CropScience shall control emissions from the potassium hydroxide

transfer (FLU-04) using cartridge filters (2.1-F13),,as specified in the permit application.

B. The cartridge filters shall be operated and maintained in accordance with the manufacturer's specifications.

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

D. Bayer CropScience shall maintain a copy of the cartridge filter manufacturer's performance warranty on site.

E. Bayer CropScience shall maintain an operating and maintenance log for the cartridge filters, which shall include the following: 1) Incidents of malfunction, with impact on emissions (tons), duration

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

and replacements, etc.

7. Record Keeping and Reporting Requirements A. Bayer CropScience shall maintain all records required by this permit for

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

B: Bayer CropScience shall report to the Air Pollution Control Program's Compliance/Enforcement Section, by mail at P.O. Box 176, Jefferson City, MO 65102 or by email at aircompliancereporting@dnr.mo.gov, no later than 10 days after the end of the month during which any record required by this permit shows an exceedance of a limitation imposed by this permit.

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

Installation Address: Bayer CropScience 8400 Hawthorn Road Kansas City, MO 64120

Project Number: 2017-07-019 Installation ID Number: 095-0011

Permit Number: 10201 7 - 016

Parent Company: Bayer CropScience LP 2 TW Alexander Drive Research Triangle Park, NC 27709

Jackson County (S29, T50N, R32W)

REVIEW SUMMARY

• Bayer CropScience has applied for authority to install new equipment and modify existing equipment to allow for the production of Fluopyram in the Sencor/FOE Plant.

• The application was deemed complete on July 24, 2017.

• HAP emissions are expected from the proposed equipment. HAPs of concern include formaldehyde, hydrogen chloride, methanol, methyl tert-butyl ether, and toluene.

• None of the New Source Performance Standards (NSPS) apply to the installation.

• 40 CFR 63 Subpart EEE National Emission Standard for Hazardous Air Pollutants from Hazardous Waste Combustors applies to the thermal oxidizer (EP5).

• 40 CFR 63 Subpart VWVW National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources applies to existing chemical manufacturing process units at the installation; however, it does not apply to this project. The production of Fluopyram is not expected to emit any of the HAPs listed in this subpart.

• 10 CSR 10-2.320 Control of Emissions from Production of Pesticides and Herbicides applies to the installation.

• A vent gas incinerator or a thermal oxidizer will be used to control VOC and HAP emissions from the Fluopyram production process.

• Wet scrubbers and dust filters are being used to control the particulate matter emissions from the dry material handling processes.

• This review was conducted in accordance with Section (5) of Missouri State Rule

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• 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all pollutants are below de minimis levels.

• This installation is located in Jackson County, a maintenance area for ozone (1979 standard) and an attainment area for all other criteria pollutants.

• This installation is classified as item number 20, Chemical process plants, on the List of Named Installations found in 10 CSR 10-6.020(3)(8). The installation's major source level is 100 tons per year and fugitive emissions are counted toward major source applicability.

• 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.

• Submittal of an update to your Part 70 Operating Permit Application (Project No. 2013-12-029) is required within 1 year of permit issuance.

• Approval of this permit is recommended with special conditions.

INSTALLATION DESCRIPTION

Bayer CropScience operates an industrial chemical manufacturing plant in Jackson County. The main products are crop protection chemicals. The facility is composed of chemical manufacturing, chemical formulation, and auxiliary operations. The auxiliary operations include a wastewater treatment plant, a hazardous waste combustor, · utilities, laboratories, and maintenance.

Bayer CropScience combusts the liquid hazardous wastes that result from the manufacture of agricultural chemicals. The combustor exhaust gas is controlled by a high-energy venturi wet scrubber, a low-energy packed bed wet scrubber, and a fiber bed mist eliminator. The installation is a minor source for construction permits and a Part 70 source for operating permits.

Although the facility is a minor (area) source for construction permits, applicable rules for hazardous waste combustors (40 CFR 63, Subpart EEE) and for chemical manufacturing area sources (40 CFR 63, Subpart VWVW) require sources to obtain a Part 70 Operating Permit. Previously, Bayer CropScience had operated under a Part 70 Operating Permit for the thermal oxidizer and a Basic Operating Permit for the remaining equipment at the installation. In 2013, the facility submitted a request to operate the entire installation under a single Part 70 Operating Permit. The request was given Project No. 2013-12-029 and is still undergoing review by the Air Pollution Control Program.

The following New Source Review permits have been issued to Bayer CropScience from the Air Pollution Control Program.

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T bl 3 P . H. a e erm1t ,story i~11~1t~~ffrU~NUmbefiI;:,;· lO~scriptiohI_;',~:r :'{),~:{;0:;': .:.,\!\:::: ;~'?)Y:.:;-;~ttr .. :;'. ?),~::,/itt\ .: :t:t~::"_,\: '/' i'' :~,-.. :·:· .· :/::··

022017-004 Modification to allow simultaneous production of Folicur and Sencor 102016-001 Relocation of the Cyclanilide process 082015-014 Wastewater treatment 062015-006 Vent Gas Incinerator

1425 Temporary thermal oxidizer 1398 Temporary boiler 1391 Temporary thermal oxidizer 1371 Temporary thermal oxidizer 1353 Temporary thermal oxidizer 1299 CorrectinQ Permits 1123 and 1285 1285 JAU expansion project 1263 Herbicide production 1260 Temporary portable thermal oxidizer 1234 New products 1123 New backup thermal oxidizer

0697C Reroutinq oxidizer 1035 Production of Mesosulfuron {confidential) 1032 Production of Phenyl Aldol (confidential) 1024 New funQicide (confidential) 0976 New Metosulam (confidential) 0946 500 kW Qenerator 0941 MKH manufacturing 0911 Pharmaceutical plant 0873 Construction of high active herbicide formulation plant 0836 Modification to the monochloropinaclone (MCP) process 0825 Construction of new herbicide formulation plant 0795 Catalytic oxidizer at liquid formulation plant 0781 Production of crop protection chemicals and intermediates.

0697A The production of MDTC, TOA, TDA-sulfone, and FOE 5043 USEPA Wastewater treatment

PROJECT DESCRIPTION

Bayer CropScience's Sencor/FOE plant (SFP) is currently permitted to manufacture four different pesticide active ingredients: Sencor, Folicur, FOE, and JAU. Sencor and FOE are herbicides, while Folicur and JAU are fungicides. Current manufacturing operations allow for all four products to be made concurrently.

Bayer CropScience is proposing to install new equipment and modify existing equipment to allow for the manufacture of Fluopyram within the SFP. Fluo fun icide used on otatoes, su ar beets,· and other cro s.

be able to produce up to

~lly.

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Several aqueous and organic waste streams will be incinerated in an existing hazardous waste incinerator (EP5). Wastewater streams will be directed to the existing · wastewater treatment plant for biological treatment. Process vent streams containing voes and HAPs will be directed to an existing vent gas incinerator (VGl-01) or thermal oxidizer (EP5). Particulate matter from the handling of dry materials will be controlled using wet scrubbers (2.2-K5, 2.1-K34 & 5.3-K5) and cartridge filters (2.1-F13).

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Bayer CropScience has asked to keep the .Fluopyram process description and the process design rates confidential per Missouri State Rules 10 CSR 10-6.210, Confidential Information. This is the public version of the permit. A confidential version is available under Project No. 2017-07-020.

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EMISSIONS/CONTROLS EVALUATION

Emissions from the project include VOCs, HAPs, and particulate matter. The majority of the emissions come from the· Fluopyram production process (FLU-01 ), which include all of the VOCs and HAPs, while the remaining emission points (FLU-02 - FLU-05) account for the particulate matter emissions.

FLU-01 includes the VOC and HAP emissions from each of the manufacturing steps, the storage tanks, the two solvent recovery operations, and the wastewater treatment operation. There are five· HAPs present at various steps of the manufacturing process: formaldehyde, hydrogen chloride, methanol, methyl tert-butyl ether, and toluene. Formaldehyde acts as a reactant; methanol, methyl tert-butyl ether, and toluene are process solvents; and hydrogen chloride is a reactant/processing aid.

For the manufacturing, recovery, and wastewater treatment operations, the VOC and HAP emission factors were based on engineering calculations, assuming that the vapor space inside the process vessels is saturated with the chemicals present in the vessels at representative temperatures. Emissions primarily result from vent flows associated with transfers, and the emission factors include the average emission rates over time summed for each of the process vessels. Emissions from storage tanks were estimated using the EPA's TANKS 4.09d software.

VOC and HAP emissions from FLU-01 are controlled by either a vent gas incinerator (VGl-01) or a thermal oxidizer (EP5). VGl-01 is designed to meet the control requirements of 10 CSR 10-2.320 for VOCs (99% destruction/removal efficiency) and the control requirements of 40 CFR 63 Subpart WVVVV National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources (95% HAP destruction/removal efficiency and 95% hydrogen halide and halogen HAP removal efficiency), as outlined in Special Conditions 4.A, 4.B, and 5.A in Construction Permit No. 102015-006. A performancetestwas completed in September of 2016, in which the unit demonstrated 99.985% reduction of total organic HAPs and 98.5% reduction of hydrogen halide and halogen HAPs.

EP5 will act as a backup device for the control of VOCs and HAPs from manufacturing proqess vents. EP5 is subject to 40 CFR 63 Subpart EEE National Emission Standard for Hazardous Air Pollutants from-Hazardous Waste Combustors. The unit demonstrated 99.998% VOC and HAP destruction/removal efficiency during a 2004 comprehensive performance test and 99.973% removal efficiency for acid gases during a 2014 comprehensive performance test.

VGl-01 and EP5 were only given an overall control efficiency of 90% for VOCs and HAPs emitted from FLU-01, which is conservative for what their previous performance tests have demonstrated; however, these values represent the federally enforceable requirements originally set forth in their respective construction permits.

FLU-02 and FLU-03 include the particulate emissions from the unloading of TFMB­amide and potassium hydroxide from FIBC big bags. The emission factors for bag

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unloading are based on an estimated loss of 0.5% of the material handled during unloading. This value was taken from Appendix B, Section 8.5 Dust Emissions from Transferring Solids Model of the OECD Environment, Health, and Safety Publication Series on Emission Scenario Documents, Number 28 (July 2011 ). Emissions for each operation were estimated by setting the amount of material handled equal to the amount necessary to support Fluopyram production at the maximum design rate (alllll tons per hour). The emission factors were then calculated to be the amount of material lost divided by the amount of Fluopyram produced.

FLU-04 includes the particulate emissions from transferring potassium hydroxide to a storage bin, and FLU-05 includes the particulate emissions from the packaging of Fluopyram into FIBC big bags. The emission factors for each of these processes were estimated using the same method as the aforementioned bag unloading processes.

Particulate emissions from FLU-02, FLU-03 and FLU-05 are each controlled by a separate wet scrubber (2.2-KS, 2.1-K34, and 5.3-:-KS respectively). The wet scrubbers will circulate water through a venturi, where process dust will be captured in liquid droplets. The venturi scrubbers were each given a control efficiency of 95% for PM and PM10. This control efficiency was taken from Table 8.2-3 of the EPA document AP-42 Appendix 8.2 Generalized Particle Distributions (September 1996).

Particulate emissions from FLU-04 are controlled by cartridge filters (2.1-F13). The filters were given a control efficiency of 99% for PM and PM10. This is a conservative value because the manufacturer's specifications claim greater than 99.9% removal efficiency.

Secondary emissions are associated with the onsite production of steam necessary for Fluopyram production and with the incineration of aqueous and organic liquid wastes from Fluopyram production. The steam boilers (0.1-D1 and 0.1-D2) and the thermal oxidizer (EP5) are all existing units that have been permitted at their maximum capacities. No additional capacity is being added to any existing unit for this project; therefore, the emissions associated with these units are already accounted for in the existing potential emissions. In fact, due to the displacement of existing processes by the new Fluopyram production, there will actually be a decrease in steam demand and a decrease in waste generated. These changes were not evaluated as part ofthis project.

The following table provides an emissions summary for this project. Existing potential emissions were taken from the installation's previous construction permit (022017-004). Existing actual emissions were taken from the installation's 2016 EIQ. Potential emissions of the project represent the potential of the equipment, assuming continuous operation (8,760 hours per year). Because PM and PM10 emissions are both limited below 99.0 tons per year, PM2.s emissions will be subsequently limited below 99.0 tons per year as well. PM2.5 emissions were not independently evaluated for this project.

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PM N/D 1.46 <99.0

PM10 15.0 <99.0 9.63 1.46 <99.0

PM2.s 10.0 N/D 9.62 N/D N/D

SOx 40.0 <99.0 4.42 N/A <99.0

NOx 40.0 <99.0 56.89 N/A <99.0

voe 40.0 <99.0 12.66 13.91 <99.0

co 100.0 <99.0 29.46 N/A <99.0

Formaldehyde 10.0/i N/A N/A 0.0039 0.0039

Hydrogen Chloride 10.0/101 . <9.9 N/D 0.035 <9.9

Methanol 10.0/101 <9.9 N/D 3.50 <9.9

Methyl Tert-Butyl Ether 10.0/101 <9.9 N/D 5.33 <9.9

Toluene 10.0/101 <9.9 N/D 1.33 <9.9

Total HAPS 25.0 <24.9 3.11 10.21 <24.9

N/A = Not Applicable; N/D = Not Determined 1Screening Model Action Level (SMAL)

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 pollutants are below de minimis levels.

APPLICABLE REQUIREMENTS

Bayer CropScience 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

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

• Operating Permits, 10 CSR 10-6.065

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

~ Per 10 CSR 10-6.110(4)(8)2.A, a full EIQ is required annually.

• Restriction of Emission of Odors, 1 O CSR 10-6.165

• 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

SPECIFIC REQUIREMENTS

• MACT Regulations, 10 CSR 10-6.075 ~ National Emission Standard for Hazardous Air Pollutants from Hazardous

Waste Combustors, 40 CFR 63, Subpart EEE ·

~ National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources, 40 CFR 63, Subpart VWVW

• Control of Emissions from Production of Pesticides and Herbicides, 10 CSR 10-2.320

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 June 29, 2017, received July 10, 2017, designating Bayer CropScience LP as the owner and operator of the installation.

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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

C02e ......... 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 µ.gm ........ micrograms per cu 1c me er

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

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

PM2.5 ....••••. 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

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

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

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

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

APPENDIXB Project Emission Factors

PM - - - -PM10 - - - -voe -Formaldehyde -Hydrogen Chloride -Methanol -Methyl tert-butyl Ether -Toluene -Total HAPs -Vent Gas

Incinerator/ Venturi Venturi Cartridge Venturi Thermal Scrubber Scrubber Filter Scrubber Oxidizer

90% 95% 95% 99% 95%

VOC/HAP PM/PM10 PM/PM10 PM/PM10 PM/PM10

Maximum Fluopyram production rate (FLU-01) = 11111 tons per hour FLU-01 composite emission factors based off TANKS 4.09d and engineering calculations for

process vessel reactions and vent flows (see submitted calculations) Maximum precursor handling rate (FLU-02, -03, -04, -05) = - tons per hour Assume 0.5% loss of precursor, which is emitted as PMIPM10

To calculate controlled emission factors, multiply the uncontrolled emission factors by their corresponding control efficiencies subtracted from 100% [Example: FLU-02 controlled PM emission factor= 11111 lb/ton x (1 - 0.95)]

OCT 26 2017 Mr. Scott Munk Senior Regulatory Affairs Consultant Bayer CropScience P.O. Box 4913 Kansas City, MO 64120

RE: New Source Review Permit - Project Number: 2017-07-019

Dear Mr. Munk:

dnr.mo.gov

Enclosed with this letter is your permit to construct. Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit. Also, note the special conditions on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files. Operation in accordance with these conditions, your new source review permit application and 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 (CA V) can be set up with you. To request a CAV, please contact your local regional office or fill out an online request. The regional office contact information can be found at the following website: http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo. gov /cav /compliance.htm.

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to 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 th.e 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

Mr. Scott Munk Page Two

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

Sincerely,

AIR POLLUTION CONTROL PROGRAM

p New Source Review Unit Chief

SH:rsj

Enclosures

c: Kansas City Regional Office PAMS File: 2017-07-019

Permit Number: 10 2 0 1 7 = 0 16