lilj ~§] missouri - dnr.mo.gov · intermediate operating permit number: op2018-044 expiration...

~§] MISSOURI lilj ro J DEPARTMENT oF ~ \::f;! NATURAL RESOURCES Air Pollution Control Program

INTERMEDIATE STATE PERMIT TO OPERA TE

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

Intermediate Operating Permit Number: OP2018-044 Expiration Date: MAY 2 9 2023

Installation ID: 105-0001 Project Number: 2015-05-025

Installation Name and Address Independent Stave Company, Inc. 1078 S. Jefferson Street Lebanon, MO 65536 Laclede County

Installation Description:

Parent Company's Name and Address ISCO Holding Co. P.O. Box 104 Lebanon,MO 65536

Independent Stave Company, Inc. operates a wine and bourbon barrel toasting facility in Lebanon, Missouri. This installation has accepted a voluntary limitation of 100.0 tons per year of particulate matter less than 10 microns in diameter (PM10) and carbon monoxide (CO) as well as a 10/25 tons per year limit on HAPs to qualify for this Intermediate Operating Permit.

Prepared by: Kasi a W asescha Operating Permit Unit

Director o ~ee Department of Natural Resources

MAY 2 9 2018 Effective Date

Independent Stave Company, Inc. Installation ID: 105-0001

Table of Contents

Intermediate State Operating Permit 2 Project No. 2015-05-025

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

EMISSION UNITS WITH LIMITATIONS ................................................................................................. 4 EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS ....................................................................... 6

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

PERMIT CONDITION PWOOl .................................................................................................................... 8 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s) .................................................................... 8

PERMIT CONDITION PW002 .................................................................................................................... 9 10 CSR 10-6.060 Construction Permits Required ....................................................................................................................... 9 Construction Permit 052016-00lA, Issued July 13, 2017 ........................................................................................................... 9

PERMIT CONDITION PW003 .................................................................................................................... 9 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s) .................................................................... 9

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ..................................................................... 10

PERMIT CONDITION OOlA ..................................................................................................................... 10 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 10 Construction Permit 082006-007, Issued August 28, 2006 ....................................................................................................... 10 Construction Permit 052009-005, Issued May 11, 2009 ........................................................................................................... 10 Construction Permit 022015-005, Issued February 5, 2015 ...................................................................................................... 10 Construction Permit 052016-001, Issued May 3, 2016 ............................................................................................................. 10

PERMIT CONDITION 001B ..................................................................................................................... 11 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 11 Construction Permit 082006-007, Issued August 28, 2006 ....................................................................................................... 11 Construction Permit 022015-005, Issued February 5, 2015 ...................................................................................................... 11 Construction Permit 052016-001, Issued May 3, 2016 ............................................................................................................. 11 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s) .................................................................. 11

PERMIT CONDITION OOlC ..................................................................................................................... 12 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 12 Construction Permit 022015-005, Issued February 5, 2015 ...................................................................................................... 12

PERMIT CONDITION OOlD ..................................................................................................................... 12 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 12 Construction Permit 022010-004, Issued February 16, 2010 .................................................................................................... 12

PERMIT CONDITION OOlE ..................................................................................................................... 13 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 13 Construction Permit 092010-007, Issued September 20, 2010 ................................................................................................. 13

PERMIT CONDITION 002A ..................................................................................................................... 14 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds ............................................................................................. 14

PERMIT CONDITION 002B ..................................................................................................................... 15 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds2

............................................................................................ 15 10 CSR 10-6.261 Control of Sulfur Dioxide Emissions ............................................................................................................ 15

PERMIT CONDITION 003 ........................................................................................................................ 15 10 CSR 10-6.405 Restriction of Particulate Matter Emission From Fuel Burning Equipment Used For Indirect Heating ....... 15

PERMIT CONDITION 004 ........................................................................................................................ 16 10 CSR 10-6.075, Maximum Achievable Control Technology ................................................................................................ 16 40 CFR Part 63 Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources ............................................................................................................................................. 16

PERMIT CONDITION 005 ........................................................................................................................ 19 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 19 Construction Permit 092010-007, Issued September 20, 2010 ................................................................................................. 19

PERMIT CONDITION 006 ........................................................................................................................ 19 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 19 Construction Permit 052016-00lA, issued July 13, 2017 ......................................................................................................... 19

PERMIT CONDITION 007 ........................................................................................................................ 20 IO CSR 10-6.060 Construction Permits Required ..................................................................................................................... 20



Construction Permit 022015-005, Issued February 5, 2015 ...................................................................................................... 20 Construction Permit 052016-00lA, Issued July 13, 2017 ......................................................................................................... 20

PERMIT CONDITION 008 ........................................................................................................................ 21 10 CSR 10-6.060 Construction Permits Required ..................................................................................................................... 21 Construction Permit 022010-004, Issued February 16, 2010 .................................................................................................... 21 Construction Permit 022015-005A, Issued April 13, 2015 ....................................................................................................... 21 Construction Permit 052016-00lA, Issued July 13, 2017 ......................................................................................................... 21

PERMIT CONDITION 009A ..................................................................................................................... 22 10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants .................................................................................. 22

PERMIT CONDITION 009B ..................................................................................................................... 24 10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants .................................................................................. 24

IV. CORE PERMIT REQUIREMENTS .................................................................................................... 26

V. GENERAL PERMIT REQUIREMENTS .............................................................................................. 31

VI. ATTACHMENTS .............................................................................................................................. 35

ATTACHMENT Al ........................................................................................................................................ 36 Plant-wide PM10 Tracking Sheet. .............................................................................................................................................. 36

ATTACHMENT A2 ........................................................................................................................................ 40 EP-57 and EP-58 PM 10 Tracking Sheet .................................................................................................................................... 40

ATTACHMENT Bl ........................................................................................................................................ 41 Plantwide HAP Tracking Sheet ................................................................................................................................................ 41

ATTACHMENT B2 ........................................................................................................................................ 45 Individual HAP Tracking Sheet ................................................................................................................................................ 45

ATTACHMENT C .......................................................................................................................................... 46 Inspection/Maintenance/Repair/Malfunction Log ..................................................................................................................... 46

ATTACHMENT D .......................................................................................................................................... 47 Pressure Drop Monitoring ......................................................................................................................................................... 47

ATTACHMENT E .......................................................................................................................................... 48 Visible Emission Observations ................................................................................................................................................. 48

ATTACHMENT F .......................................................................................................................................... 49 Coating Usage Compliance Worksheet. .................................................................................................................................... 49

ATTACHMENT G .......................................................................................................................................... 50 Method 9 Opacity Emissions Observations .............................................................................................................................. 50

ATTACHMENT H .......................................................................................................................................... 51 Fugitive Emission Observations ............................................................................................................................................... 51

ATTACHMENT 1 ........................................................................................................................................... 52 40.0 Tons NOx Tracking Worksheet ........................................................................................................................................ 52

ATTACHMENT J ..... ...................................................................................................................................... 53 Plantwide CO Tracking Worksheet.. ......................................................................................................................................... 53

ATTACHMENT K .......................................................................................................................................... 54 Alternative Coating Compliance Worksheet. ............................................................................................................................ 54


Intermediate State Operating Permit

I. Installation Equipment Listing

EMISSION UNITS WITH LIMITATIONS

4 Project No. 2015-05-025

The following list provides a description of the equipment at this installation which emits air pollutants and identified as having unit-specific emission limitations.

Emission Description Control Device1

Source EPOI-1 Stave Planers -EPOl-2 Stave Jointers -EPOl-3 Heading Planers ( 4) -EPOl-4 Heading Jointers (12) -EPOI-5 Heading Turner-Hog -EPOl-6 Slicker Wheels (Cull Staves) (2) -EPOl-7 Rip Saw (Cull Staves) -EPOl-8 Wine Barrel Assembly Sanders (3) -

EPOl-10 Bourbon Barrel Assembly Sanders (5) -EPOl-11 Bourbon Finish Rip Saw -

EP02 Heine Fuel Bin CD-6 (Baghouse) EP03 Wood-fired Heine Boiler, 23 MMBtu/hr, installed 1960s -EP05 Wine Head Toasters, 3.0 MMBtu/hr -

EP06 Bourbon Head Char, 3 .59 MMBtu/hr -EP07 Wine Barrel Toaster, 10.3 MMBtu/hr -

EP08 Bourbon Barrel Char (Wood), 5.02 MMBtu/hr Bourbon Barrel Char (Natural Gas), 11.43 MMBtu/hr

-

EPl 1 Wood-fired Barrel Pre-Heater #1, 6 MMBtu/hr -EP24-l Augurs, Bucket Elevator, and Drum Dry System (Wood Waste) -

EP24-2 Drum Heater (Wood), 15.6 MMBtu/hr -Drum Heater (Natural Gas); 0.00098 MMcf/hr

EP27 Cleaver Brooks Storage Silo; 4.5 tons/hr CD-7 (Baghouse) EP32 Regrind Hammermill; 3 .6 tons/hr -

EP33-l Wine Belly/Heading Sanders EP33-2 Wine Belly/Heading Sanders EP33-3 Wine Belly/Heading Sanders EP34 Crozier #2 Wine EP36 Wood-fired Wine Barrel Lasers (2); 0.006 MMBtu/hr -EP37 Storage Bin Drop Point (Green Silo); 0.525 tons/hr -EP40 Wood-fired Stave Toaster Wood Burner; 1.5 MMBtu/hr -

EP41A Alternatives Rip Saw, 0. 75 tons/hr EP41B Alternatives Chop Saw, 0.75 tons/hr CD-16 (Baghouse); EP41C Alternatives Band Saw, 0.75 tons/hr Hoods EP41D Alternatives Planer, 0.75 tons/hr EP41E Alternatives Rip/Chop Saws, 0.75 tons/hr CD-16 (Baghouse)

EP42 Alternatives Chopper w/ Cyclone; 1.0 tons/hr CD-16 (Baghouse );

CD-17 (Cyclone); Hoods

EP45 Alternative Tank Stave Oven Burner; natural gas fueled, 0.00098

-mmscf/hr

1 Only control devices that their use is federally required by this operating permit are listed.



Emission Description Source

EP47 Electric Tank Stave Toaster (Pierre), 0.042 MMBtu/hr EP51 Natural Gas Fired Chip Roasters (4); 0.00088 MMcf/hr

EP53-5 Green Dust Overs Dumpster, 0.67 tons/hr EP53-7 Green Sawdust Product Conveyor, 0.67 tons/hr EP55 Building #4 Paint Booth; 0.053 gal/hr

EP57-1 Green Dust Trailer Dump, 2 tons/hr EP57-2 Bucket Loader Transfer Green Sawdust; 2 tons/hr EP57-3 Bulk Bag Metering Bin; 2 tons/hr EP57-4 Sweco Screener; 2 tons/hr EP57-5 Green Dust Overs Dumpster; 0.28 tons/hr EP57-6 Plant Waste Dump Trailer; 0.28 tons/hr EP57-7 Green Sawdust Product Conveyor, 0.28 tons/hr EP57-8 Green Sawdust Bagger/Bag, 1. 72 tons/hr EP58-1 Green Storage to Heine Bucket Loader; 1. 77 tons/hr EP58-2 Green Storage to Heine Meter Bin, 1.77 tons/hr EP60A Natural Gas-fired Chip Roster Burner #5, 0.00075 MMcf/hr EP60B Natural Gas-fired Chip Roaster Burner #6, 0.00075 MMcf/hr EP62 France Roaster #5 Mechanical Handling, 0.1675 tons/hr EP63 France Roaster #6 Mechanical Handling, 0.1675 tons/hr EP64 Chip Roaster Cooling Table EP68 French Tank Stave Oven (Wood), 0.11 MMBtu/hr

EP69A Fire Tank Stave Toasting #1 (Wood), 0.0098 MMBtu/hr EP69B Fire Tank Stave Toasting #2 (Wood), 0.0098 MMBtu/hr EP70A Fire TIS Toasting Fire Pot Wood Combustion #1, 0.0485 MMBtu/hr EP70B Fire TIS Toasting Fire Pot Wood Combustion #2, 0.0485 MMBtu/hr

EP71 Chop Saw, 0.0012 tons/hr

EP73 Ash/Charcoal Augur to Dumpster EP74 Craft Spirits Belly Sanders EP75 Craft Spirits Bung Bore EP76 Craft Spirits Bung Singe EP77 Craft Spirits Manual Belt Sander (2) EP78 Craft Spirits Head Sander (2) EP79 Craft Spirits Edger EP81 Two Boiler Baghouse; 5.43 tons/hr, connected to other baghouses

EP82A Enclosed Bottom Ash Drum Transfer; 0.00026 tons/hr EP82B Enclosed Bottom Ash Drum Transfer; 0.00026 tons/hr EP83A Wood-fired Boiler #1, 9.289 MMBtu/hr EP83B Wood-fired Boiler #2, 9.289 MMBtu/hr EP84A Enclosed Ash Drum Transfer; 0.00096 tons/hr EP84B Enclosed Ash Drum Transfer; 0.00096 tons/hr EP85 Storage Silo; 5.43 tons/hr

EP87A Craft Barrel Char (Wood burning from process), 93. 7 5 lb/hr EP87B Craft Barrel Char Burners (natural gas), 1 MMBtu/hr

5 Project No. 2015-05-025

Control Device1

-CD-18 (Cyclone)

--

CD-24 (Filter) ----

-

--

-

Enclosure, Negative pressure

CD-18 (Cyclone)

CD-18 (Cyclone) CD-18 (Cyclone)

--

-

-

--

CD-16 (Baghouse); Hoods

------

-

CD-27 (Baghouse) --

CD-28 (MultiCyclone)

--

CD-27 (Baghouse) --



EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS

6 Project No. 2015-05-025

The following list provides a description of the equipment, which does not have unit specific limitations at the time of permit issuance. Plantwide conditions still apply to these emission units.

Emission Description Source EP15 Trailer Loadout/Transfer EP17 Transfer to Storage Bay from Closed Conveyance EP21 Chips to Pre-Heaters Transfer to Box from Storage Bay via FEL EP22 Transfer to Meter Bin # 1 from Storage Bay via FEL EP23 Meter Bin #1 (Toast)

EP25 Pneumatic Transfer to Chip Bagging from Hammermill #2 (Chip Bagging) Pneumatic Transfer to Bag~jng from Closed Conveyance (Chip Bagging)

EP30 Bucket Loader Transfer Regrind Meter Bin EP31 Load Regrind Meter Bin from Enclosed Building via FEL EP35 Enclosed Building - Regrind EP36 Wine Barrel Lasers (2) EP38 Transport Sawdust with Front End Loader (Green Silo) EP39 Loading Semi Trailer with Front End Loader EP43 Storage of Chipped Wood in Alternatives Bay (4) EP44 Transfer Chipped Wood with Bucket Loader in Alternatives Bay EP46 Sweeping and Dumping Plant Waste into Trailer EP48 French Oak Block Building Shavings Storage EP49 French Oak Bucket Loader Transfer EP52 Bulk Bag Bagger (New Alternative Bay)

EP53-l Bucket Loader Transfer to Bulk Bag Loader EP53-2 Bulk Bag Meter Bin EP53-3 Chip Bulk Bag Fill EP53-4 Bulk Bag Unloader/Feeder Conveyor EP53-6 Chip Roaster Overhead Feeder Belt EP53-8 Cooling Table Takeaway Belt Conveyors (2) EP53-9 Chip Roaster Bulk Bag Load

EP53-10 Chip Roaster Cyclone Hopper EP53-l 1 Trash Dumpster for Cyclone Hopper EP54-1 2mm Belt Conveyor to Vibrating Screen EP54-2 2mm Vibrating Screener EP54-3 2mm Chip Conveyor (2) EP54-4 2mm Chip Bags (2)

Truck Shop Parts Cleaner EP56 Building #2 Parts Cleaner

Forklift Shops Parts Cleaner EP59 Heading Trailer Loadout System EP61 Bulk Bag Unloader/Feeder Conveyor EP65 Cooling Table Takeway Belt Conveyor EP66 Chip Roaster Bulk Bag Loading EP67 Chip Roaster Cyclone Hopper (2) EP72 Ash/Charcoal Chute to Auger

EP80A,B,C Steam Heated Kilns (3), 593.6 board ft/hr EP86 Enclosed Building Trailer Loading


Emission Source


Description

EP200-Paved and Unpaved Haul Roads EP228

7 Project No. 2015-05-025



II. Plant Wide Emission Limitations

8 Project No. 2015-05-025

The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect on the date of permit issuance. The plant wide conditions apply to all emission units at this installation. All emission units are listed in Section I under Emission Units with Limitations and Emission Units without Limitations. The following general conditions apply to all units contained in this permit, unless stated otherwise:

Recordkeeping: 1. The permittee shall record all required record keeping in an appropriate format. 2. Records may be kept electronically using database or workbook systems, as long as all required

information is readily available for compliance determinations. 3. The permittee shall keep a copy of this operating permit and review on site as well as copies of all

issued construction permits and reviews on site. 4. All records must be kept for a minimum of 5 years and be made available to Department of Natural

Resources' personnel upon request.

Reporting: 1. The permittee shall report any exceedance of any of the terms imposed by this permit, or any

malfunction which could cause an exceedance of any of the terms imposed by this permit, no later than ten (10) days after the exceedance or event causing the exceedance (unless otherwise specified in the specific condition).

2. The permittee shall report any deviations from the monitoring, recordkeeping, and reporting requirements of this permit condition in the annual compliance certification.

3. All reports and certifications shall be submitted to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 or [email protected].

PERMIT CONDITION PWOOl 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s)

Emission Limitation: The permittee shall not cause or allow the emission of particulate matter of a diameter of less than or equal to 10 microns (PM10) in excess of 100 tons in any consecutive 12 month period.

Monitoring/Recordkeeping: The permittee shall keep track of PM10 emissions using Attachment Al, or an equivalent.



PERMIT CONDITION PW002 10 CSR 10-6.060 Construction Permits Required

Construction Permit 052016-00IA, Issued July 13, 2017

Emission Limitation:

9 Project No. 2015-05-025

The permittee shall emit less than 10.0 tons of any individual HAP and less than 25.0 tons of total HAPs in any consecutive 12-month period from the entire installation. [Special Condition 3A]

Monitoring!Recordkeeping: Records of monthly HAPs shall be recorded on Attachments B 1 and B2, or equivalents: [Special Condition 3F]

PERMIT CONDITION PW003 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s)

Emission Limitation: The permittee shall emit less than 100.0 tons of Carbon Monoxide (CO) in any consecutive 12-month period from the entire installation.

Monitoring!Recordkeeping: Records of monthly CO emissions shall be recorded on Attachment J, or an equivalent.



III. Emission Unit Specific Emission Limitations

10 Project No. 2015-05-025

The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect on the date of permit issuance.

PERMIT CONDITION 001A 10 CSR 10-6.060 Construction Permits Required

Construction Permit 082006-007, Issued August 28, 2006 Construction Permit 052009-005, Issued May 11, 2009

Construction Permit 022015-005, Issued February 5, 2015 Construction Permit 052016-001, Issued May 3, 2016

Emission Source Description Control Device EP42 Alternatives Chopper w/ Cyclone CD-17 (Cyclone) EP51 Natural Gas Fired Chip Roasters (4) CD-18 (Cyclone)

EP60A Natural Gas-fired Chip Roster Burner EP60B Natural Gas-fired Chip Roaster Burner

CD-18 (Cyclone) EP62 France Roaster #5 Mechanical Handling EP63 France Roaster #6 Mechanical Handling

EP83A Wood-fired Boiler #1 CD-28 (Multi Cyclone)

EP83B Wood-fired Boiler #2

Operational Limitation: 1. The permittee shall control emissions from the emission units of this permit condition by using the

specified cyclones. The cyclones shall be in use at all times when the associated emission units are in operation. [052009-005 S.C 3A; 082006-007 S.C. 2B; 022015-005 S.C. SA; 052016-001 S.C. 4A]

2. The cyclones used on EP-42, EP-60A, EP-60B, EP-62, and EP-63 shall be medium efficiency cyclones. [022015-005 S.C. 5A]

3. The cyclone used on EP-83A and EP-83B shall be a multiple cyclone separator. [052016-001 S.C. 4A]

4. The cyclones shall be operated and maintained in accordance with the manufacturer's specifications. The cyclone shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that Department of Natural Resources' employees may easily observe them. [052009-005 S.C. 3B; 082006-007 S.C. 2B; 022015-005 S.C. SB; 052016-001 S.C. 4B]

Monitoring!Recordkeeping: 1. The permittee shall maintain an operating and maintenance log using Attachment C, or an

equivalent, for each of the cyclones that shall include the following: [052009-005 S.C. 3C; 022015-005 S.C. SC; 052016-001 S.C. 4D] a) Incidents of malfunction, with impacts on emissions, durations of events, probable causes and

corrective actions. b) Maintenance activities, with inspection schedule, repair actions and replacements.

2. The permittee shall monitor and record the operating pressure drop across the cyclones at least once every 24 hours using Attachment D or an equivalent. The operating pressure drop shall be



maintained within the design conditions specified by the manufacturer's performance warranty. [022015-005 S.C. C; 052016-001 S.C. 4C]

3. The permittee shall keep a copy of the manufacturer's performance warranty on-site.

PERMIT CONDITION 001B 10 CSR 10-6.060 Construction Permits Required

Construction Permit 082006-007, Issued August 28, 2006 Construction Permit 022015-005, Issued February 5, 2015

Construction Permit 052016-001, Issued May 3, 2016 10 CSR 10-6.020(2)(1)23. and 10 CSR 10-6.065(5)(C)2. Voluntary Limitation(s)

Emission Source Description Control Device EP02 Heine Fuel Bin CD6 (Baghouse) EP27 Cleaver Brooks Storage Silo CD7 (Baghouse)

Alternatives Rip Saws Alternatives Chop Saws

EP41 Alternatives Band Saw CD-16 (Baghouse) Alternatives Planer Alternatives Rip/Chop Saws

EP42 Alternatives Chopper w/ Cyclone CD-16 (Baghouse) EP71 Chop Saw CD-16 (Baghouse) EP81 Two Boiler Baghouse, connected to other baghouses CD-27 (Baghouse) EP85 Storage Silo CD-27 (Baghouse)

Operational Limitation: 1. The baghouses must be in use at all times when any of the equipment associated with its emission

source of this permit condition is in operation. [082006-007 S.C. 2A; 022015-005 S.C. 6A; 052016-001 S.C. 5A, Voluntary]

2. The baghouse shall be operated and maintained in accordance with the manufacturer's specifications. The baghouse shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. These gauges or meters shall be located such that the Department of Natural Resources' employees may easily observe them. [082006-007 S.C. 2A; 022015-005 S.C. 6B; 052016-001 S.C. 5B, Voluntary]

3. Replacement filters for the baghouses shall be kept on hand at all times. The bags shall be made of fibers appropriate for operating conditions expected to occur (i.e. temperature limits, acidic and alkali resistance, and abrasion resistance). [022015-005 S.C. 6C; 052016-001 S.C. SC, Voluntary]

Monitoring/Recordkeeping: 1. The permittee shall monitor and record the operating pressure drop across the baghouses at least

once every 24 hours while the plant is operating using Attachment D or an equivalent. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty. The manufacturer's performance warranty shall be kept onsite. [022015-005, S.C. 6D; 052016-001 S.C. 5D, Voluntary]



2. The permittee shall maintain an operating and maintenance log for the baghouses (Attachment C or an equivalent) which shall include the following: [022015-005, S.C. 6E; 052016-001 S.C. SE, Voluntary] a) Incidents of malfunction, with impact on emissions, duration or event, probable cause, and

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

PERMIT CONDITION OOlC 10 CSR 10-6.060 Construction Permits Required

Construction Permit 022015-005, Issued February 5, 2015 Emission Source Description Control Device

Alternatives Rip Saw

EP41 Alternatives Chop Saw Alternatives Band Saw Alternatives Planer Hoods

EP42 Alternatives Chipper with Cyclone EP71 Chop Saw

Operational Limitation: 1. The permittee shall use hoods to capture emissions form the emission sources of this permit

condition. A hood is a shaped inlet to a pollution control system (the hoods are routed to baghouse CD-16) that does not totally surround emissions form an emission source. [Special Condition 4A]

2. The maximum distance between the hood inlet and the emission source shall not exceed 1.5 times the diameter of the exhaust duct. [Special Condition 48]

Monitoring/Recordkeeping: 1. The permittee shall maintain an operating and maintenance log using Attachment C, or an

equivalent, for each of the hoods that shall include the following: a) Incidents of malfunction, with impacts on emissions, durations of events, probable causes and


PERMIT CONDITION 001D 10 CSR 10-6.060 Construction Permits Required

Construction Permit 022010-004, Issued February 16, 2010 Emission Source I Description I Control Device

EP55 I Building #4 Paint Booth I CD-24 (Filter)

Operational Limitation: 1. The permittee shall vent all exhaust from EP-55 through a filter. [Special Condition 3A] 2. The filter shall be installed, inspected, and maintained in accordance with the manufacturer's

specifications in order to achieve at least 95% control of particulate overspray. [Special Condition 3B]

Monitoring/Recordkeeping: 1. The permittee shall monitor and record the operating pressure drop across the filter at least once

daily while the plant is operating using Attachment D or an equivalent. The operating pressure drop



shall be maintained within the design conditions specified by the manufacturer's performance warranty.

2. The manufacturer's performance warranty shall be kept onsite. 3. The permittee shall maintain an operating and maintenance log using Attachment C, or an

equivalent, for the filter that shall include the following: a) Incidents of malfunction, with impacts on emissions, durations of events, probable causes and


PERMIT CONDITION OOlE 10 CSR 10-6.060 Construction Permits Required

Construction Permit 092010-007, Issued September 20, 2010 Emission Source Description Control Device

EP58-1 Green Storage to Heine Bucket Loader Enclosure, EP58-2 Green Storage to Heine Meter Bin Negative pressure

Operational Limitation: 1. The permittee shall control emissions from conveyors/augers in EP58-1 and EP58-2 by using

complete enclosure and negative pressure at all times when in operation. Negative pressure shall be indicated by the operation of a blower which transfers material into the Heine boiler fuel silo (EP02). [Special Condition 3]

2. The blower shall be maintained and operated in accordance with the manufacturer's specifications and good engineering practices.

Monitoring/Recordkeeping: 1. The permittee shall perform visible emission checks on the emission sources or a visual indicator

check on the enclosure at least once daily using U.S. EPA Method 22. The permittee shall keep records of the daily checks using Attachment E or an equivalent form.

2. In lieu of performing visible emission checks on each emission point, the permittee may demonstrate negative enclosure pressure by using a visible indicator such as pressure gauges, streamers, talc puff test, etc., at enclosure openings that are not closed during normal operations. Each opening if the enclosure must indicate the presence of negative pressure for compliance.

3. The permittee shall maintain an operating and maintenance log using Attachment C, or an equivalent, for the blower that shall include the following:

a) Incidents of malfunction, with impacts on emissions, durations of events, probable causes and corrective actions.

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



PERMIT CONDITION 002A

14 Project No. 2015-05-025

10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds2

Emission Source Description Status3

EP05 Wine Head Toasters New EP06 Bourbon Head Char New EP07 Wine Barrel Toaster Existing EP08 Bourbon Barrel Char New EPll Barrel Pre-Heater #1 New

EP24-24 Drum Heater (Wood) New EP36 Wine Barrel Laser New EP40 Wood-fired Stave Toaster Wood Burner New EP47 Electric Tank Stave Toaster (Pierre) New EP68 French Tank Stave Oven - Wood New

EP69A Fire Tank Stave Toasting #1 - wood New EP69B Fire Tank Stave Toasting #2 - wood New EP70A Fire TIS Toasting Fire Pot Wood Combustion #1 New EP70B Fire TIS Toasting Fire Pot Wood Combustion #2 New

Emission Limitation: 1. No person shall cause or permit the emission into the atmosphere gases containing more than two

thousand parts per million by volume (2,000 ppmv) of sulfur dioxide or more than seventy milligrams per cubic meter (70 mg/m3

) of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three (3)-hour time period from any source listed as existing.

2. No person shall cause or permit the emission into the atmosphere gases containing more than five hundred parts per million by volume (500 ppmv) of sulfur dioxide or more than thirty-five milligrams per cubic meter (35 mg/m3

) of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three (3)-hour time period from any source listed as new.

Monitoring/Recordkeeping: Not required. See Statement of Basis.

2 This regulation was rescinded from Missouri Code of State Regulations on November 30, 2015 but it still remains in the EPA-approved SIP and thus still remains an applicable federal regulation. Upon adoption of IO CSR I 0-6.261 into Missouri's SIP, IO CSR 6.260 will be removed from the SIP and thus this rule will no longer be applicable to the installation. No action on the part of the permittee is needed to revise the operating permit. Upon removal of 10 CSR 10-6.260 from the SIP, Permit Condition 002A shall no longer be enforceable. 3 Existing is defined in 10 CSR 10-6.020 for outstate Missouri area as a piece of equipment existing or constructed before February 24, 1971. New is on and after this date. 4 This permit condition does not apply while burning natural gas. Natural gas is exempt from the rule per 10 CSR I 0-6.260(1 )(A)2. However, the permit condition applies at all times the permittee is burning wood.



PERMIT CONDITION 002B 10 CSR 10-6.260 Restriction of Emission of Sulfur Compounds2

10 CSR 10-6.261 Control of Sulfur Dioxide Emissions Emission Source Description

EP03 Wood-fired Heine Boiler EP83A Wood-fired Boiler #1 EP83B Wood-fired Boiler #2

Note: As of issuance ofth1s permit, JO CSR 10-6.261 is state enforceable only 5

Emission Limitation: No person shall cause or allow emissions of sulfur dioxide into the atmosphere from the emission sources of this permit condition in excess of eight (8) pounds of sulfur dioxide per million Btus (MMBtu) actual heat input averaged on any consecutive three (3)-hour time period.


PERMIT CONDITION 003 10 CSR 10-6.405 Restriction of Particulate Matter Emission From Fuel Burning Equipment Used For

Indirect Heating Emission Source Description

EP03 Wood-fired Heine Boiler EP40 Stave Toaster Wood Burner

EP83A Wood-fired Boiler #1 EP83B Wood-fired Boiler #2

Emission Limitations: 1. EP-03, EP40:

a) The permittee shall not emit particulate matter in excess of 0.46 lb/MMBtu. 2. EP-83A, EP-83B:

a) The permittee shall not emit particulate matter in excess of 0.25 lb/MMBtu.


5 This regulation has not yet been adopted into Missouri's SIP; therefore, this regulation is a state only requirement. Upon

adoption into Missouri's SIP this regulation will be both a state and federal requirement. No action on the part of the permittee is needed to revise the operating permit.



PERMIT CONDITION 004 10 CSR 10-6.075, Maximum Achievable Control Technology

40 CFR Part 63 Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources

Emission Source Description EP03 Wood-fired Heine Boiler

EP83A Wood-fired Boiler # 1 EP83B Wood-fired Boiler #2

Operational Limitations: 1. The permittee must comply with each work practice standard, emission reduction measure, and

management practice specified in Table 2 ofMACT JJJJJJ that applies to the boilers. An energy assessment completed on or after January 1, 2008 that meets or is amended to meet the energy assessment requirements in Table 2 of MACT JJJJJJ satisfies the energy assessment requirement. [§63.l 1201(b)]

a) EP-03 - Heine Boiler: i) Conduct a tune-up of the boiler biennially as specified in §63.11223. [Table 2 of MACT

JJJJJJ, Item 6] ii) Must have a one-time energy assessment performed by a qualified energy assessor. An

energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements of Table 2 of MACT JJJJJJ satisfies the energy assessment requirement. Energy assessor approval and qualifications requirements are waived in instances were past or amended energy assessments are used to meet the energy assessment requirements. The energy assessment must include the following with the extent of the evaluation appropriate for the on-site technical hours listed in §63.11237: [Table 2 ofMACT JJJJJJ, Item 16] (1) A visual inspection of the boiler system; (2) An evaluation of operating characteristics of the affected boiler systems,

specifications of energy use systems, operating and maintenance procedures, and unusual operating constraints;

(3) An inventory of major energy use systems consuming energy from the affected boiler and which are under control of the permittee;

( 4) A review of available architectural and engineering plans, facility operating and maintenance procedures and logs, and fuel usage;

(5) A list of major energy conservation measures that are within the facility's control; (6) A list of the energy savings potential of the energy conservation measures identified; (7) A comprehensive report detailing the ways to improve efficiency, the cost of specific

improvements, benefits, and the time frame for recouping those investments. b) EP-83A and EP-84B - Wood Fired Boilers #1 and #2:

i) Conduct a tune-up of the boiler biennially as specified in §63.11223. [Table 2 of MACT JJJJJJ, Item 7]

2. These standards apply at all times the affected boilers are operating. [§63.11201(d)]


Initial Compliance Requirements:


1. EP-83A and EP-84B - Wood Fired Boilers #1 and #2:

17 Project No. 2015-05-025

a) The permittee is not required to complete an initial performance tune-up, but they are required to complete the applicable biennial as specified in §63 .11223 no later than 25 months after the initial startup of the new or reconstructed affected source. [§63.11210(g)]

2. The permittee must conduct a performance tune-up according to §63.11210(c) and §63.11223(b). [§63.11214(b)]

Continuous Compliance Requirements: 1. At all times the permittee must operate and maintain the affected boilers, including associated air

pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. [§63.11205(a)]

2. The permittee must conduct a performance tune-up according to §63.11225(b) and keep records as required in §63.l 1225(c) to demonstrate continuous compliance. The permittee must conduct the tune-up while burning the type of fuel that provides the majority of the heat input to the boiler over the 12 months prior to the tune-up. [§63.11225(a)]

3. The permittee must conduct a tune-up of the boilers biennially to demonstrate continuous compliance as specified in §63.11223(b)(l) through (7). Each biennial tune-up must be conducted no more than 25 months after the previous tune-up. For EP-83A and EP-83B, the first biennial tune-up must be no later than 25 months after their initial startup. [§63.11223(b)]

a) As applicable, inspect the burner, and clean any components of the burner as necessary (the permittee may delay the burner inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). [§63.l 1223(b)(l)]

b) Inspect the flame pattern, if applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. [§63.11223(b)(2)]

c) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the permittee may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). [§63.l 1223(b)(3)]

d) Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available. [§63.11223(b)( 4)]

e) Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either in a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. [§63.11223(b)(5)]

f) Maintain on-site and submit, if requested by the Director, a report containing the information in §63.11223(b)(6)(i) through (ii). [§63.11223(b)(6)] i) The concentrations of CO in the effluent stream in parts per million, by volume, and

oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler. [§63.11223(b)(6)(i)]

ii) A description of any corrective actions taken as a part of the tune-up of the boiler. [§63.11223(b)(6)(ii)]

g) If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. [§63.11223(b)(7)]



Recordkeeping: 1. The permittee must maintain the records specified in §63.11225(c)(l) through (7).

a) As required in §63.10(b)(2)(xiv), the permittee must keep a copy of each notification and report that they submitted to comply with MACT JJJJJJ and all documentation supporting any Initial Notification or Notification of Compliance Status that they submitted. [§63.l 1225(c)(l)]

b) The permittee must keep records to document conformance with the work practices, emission reduction measures, and management practices required by §63 .11214 and §63 .11223 as specified in §63.11225(c)(2)(i) through (vi). i) Records must identify each boiler, the date of tune-up, the procedures followed for tune-up,

and the manufacturer's specifications to which the boiler was tuned. [§63.11225(c)(2)(i)] ii) For each boiler required to conduct an energy assessment, the permittee must keep a copy of

the energy assessment report. [§63.11225(c)(2)(iii)] iii) Results, including the date, time, and duration of the period from the time the monitoring

indicated a problem to the time that monitoring indicated proper operation. [§63.11225(c)(2)(v)]

iv) Maintenance or corrective action taken (if applicable). [§63.11225(c)(2)(vi)]

Reporting: 1. The permittee must prepare, by March 1 of each year, and submit to the delegated authority upon

request, an annual compliance certification report for the previous calendar year containing the information specified §63 .11225(b )(1) through ( 4 ). The permittee must submit the report by March 15 if they have any instance described by §63. l 1225(b )(3 ). The permittee has the option to instead prepare only a biennial or 5-year compliance report as specified in §63.11225(b)(l) and (2) which requires: [§63.11225(b)]

a) Company name and address. [§63.11225(b)(l)] b) Statement by a responsible official, with the official's name, title, phone number, email

address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart. The permittee's notification must include the following certification(s) of compliance, as applicable, and signed by a responsible official: [§63.11225(b)(2)] i) "This facility complies with the requirements in §63 .11223 to conduct a biennial or 5-

year tune-up, as applicable, of each boiler." [§63.11225(b )(2)(i)] ii) "This facility complies with the requirements in §§63.11214(d) and 63.11223(g) to

minimize the boiler's time spent during startup and shutdown and to conduct startups and shutdowns according to the manufacturer's recommended procedures or procedures specified for a boiler of similar design if the manufacturer's recommended procedures are not available." [§63.11225(b)(2)(iii)]

c) If the source experiences any deviations from the applicable requirements during the reporting period, the permittee shall include a description of deviations, the time periods during which the deviations occurred, and the corrective actions taken. [§63.l 1225(b)(3)]



PERMIT CONDITION 005 10 CSR 10-6.060 Construction Permits Required

19 Project No. 2015-05-025

Construction Permit 092010-007, Issued September 20, 2010 Emission Source Description Control Device

EP57-1 Green Dust Trailer Dump EP57-2 Bucket Loader Transfer Green Sawdust EP57-3 Bulk Bag Metering Bin EP57-4 Sweco Screener

-EP57-5 Green Dust Overs Dumpster EP57-6 Plant Waste Dump Trailer EP57-7 Green Sawdust Product Conveyor EP57-8 Green Sawdust Bagger/Bag EP58-1 Green Storage to Heine Bucket Loader Enclosure, EP58-2 Green Storage to Heine Meter Bin Negative pressure

Emission Limitation: The permittee shall emit less than 15.0 tons of particulate matter less than 10 microns in diameter (PM10) from emission sources of this permit condition in any consecutive 12 month period. [Special Condition IA]

Monitoring/Recordkeeping: The permittee shall keep track of PM10 emissions using Attachment A2, or an equivalent.


Construction Permit 052016-00lA, issued July 13, 2017 Emission Source Description

EP83A Wood-fired Boiler # 1 EP83B Wood-fired Boiler #2 EP87A Craft Barrel Char (Wood burning from process) EP87B Craft Barrel Char Burners (natural gas)

Emission Limitation: The permittee shall emit less than 40 tons of NOx from the emission sources of this permit condition per each consecutive 12 month period. [Special Condition 4A]

Monitoring/Recordkeeping: The permittee shall monitor and record the NOx emissions from the emission sources of this permit condition using Attachment I or an equivalent form.




Construction Permit 022015-005, Issued February 5, 2015 Construction Permit 052016-00lA, Issued July 13, 2017

Emission Source Description EP03 Wood-fired Heine Boiler EP05 Wine Head Toasters EP06 Bourbon Head Char EP07 Wine Barrel Toaster

EP08 Bourbon Barrel Char (Wood) Bourbon Barrel Char (Natural Gas)

EPll Barrel Pre-Heater #1

EP24-2 Drum Heater (Wood) Drum Heater (Natural Gas)

EP36 Wine Barrel Lasers (2) EP40 Stave Toaster Wood Burner EP45 French Tank Stave Oven Burner (Natural Gas) EP47 Electric Tank Stave Toaster (Pierre) EP51 Natural Gas Fired Chip Roasters (4)

EP60A French Natural Gas Fired Chip Roaster #5 EP60B French Natural Gas Fired Chip Roaster #6 EP68 French Tank Stave Oven (Wood)

EP69A Fire Tank Stave Toasting #1 (Wood) EP69B Fire Tank Stave Toasting #2 (Wood) EP70A Fire T/S Toasting Fire Pot Wood Combustion #1 EP70B Fire T/S Toasting Fire Pot Wood Combustion #2 EP83A Wood-fired Boiler #1 EP83B Wood-fired Boiler #2 EP87A Craft Barrel Char (Wood burning from process) EP86B Craft Barrel Char Burners (natural gas)

Operational Limitation:

20 Project No. 2015-05-025

Fuel Type Untreated wood Untreated wood Untreated wood Untreated wood Untreated wood,

natural gas Untreated wood Untreated wood,

natural gas Untreated wood Untreated wood

Natural gas Untreated wood

Natural gas Natural gas Natural gas

Untreated wood Untreated wood Untreated wood Untreated wood Untreated wood Untreated wood Untreated wood Untreated wood,

natural gas

The permittee shall burn exclusively untreated wood or natural gas as specified in this permit condition. [022015-005 S.C. 7; 052016-00lA S.C. 5A]

Monitoring/Recordkeeping: The permittee shall retain fuel records that demonstrate compliance with the operating permit limitation.




Construction Permit 022010-004, Issued February 16, 2010 Construction Permit 022015-00SA, Issued April 13, 2015 Construction Permit 052016-00lA, Issued July 13, 2017

Emission Source I Description I EP55 I Building #4 Paint Booth I

Operational Limitation:

21 Project No. 2015-05-025

Control Device CD-24 (Filter)

1. The permittee shall limit the total amount of coating material applied in EP-55 to less than 411 gallons of coating material in any consecutive 12-month period. [022015-00SA S.C. 2A]

2. The permittee shall keep all solvents and cleaning solutions in sealed containers whenever the materials are not in use. The permittee shall provide and maintain suitable, easily read, permanent markings on all solvent and cleaning solution containers used with EP55. [022010-004, S.C. 2]

Alternative Material: 1. When considering using an alternative coating in the painting booth that is different than the coating

materials in the table below, the permittee shall calculate the potential emissions of VOCs, total HAPs, and all individual HAP in the alternative material. Potential emission calculations may consider the voluntary 411 gallon throughput limit stated in the operational limitation of this permit condition. [022015-00SA S.C. 3A; 052016-00lA S.C. 3C] a) If the alternative coating contains a HAP that is also a product of combustion of wood or natural

gas, the permittee shall track that individual HAP's emissions from all combustion equipment and add them to the alternative coating emissions. [052016-00lA S.C. 3D]

Manufacturer Description Serial Number Sherwin Williams Kem Kromik Primer B50WZ1 Sherwin Williams Sher-Kem Enamel F75WC7 Sherwin Williams Steel Spec B55T804 Sherwin Williams Xylene/SW unavailable

2. The permittee shall seek approval from the Air Pollution Control Program before use of the alternative material in the following cases: [052016-00lA S.C. 3E] a) If the potential VOC emissions for the alternative material is equal to or greater than 131.8 tons

per year6;

b) If the potential individual HAP emissions for the alternative material are equal to or greater than the screening model action level (SMAL) for any chemical listed in the most recent HAP SMAL table located at http://dnr.mo.gov/env/apcp/docs/cp-hapsmaltbl6.pdf;

Monitoring/Recordkeeping: 1. Attachment F, or an equivalent, shall be used to show compliance with the gallon limitation.

[022015-00SA S.C. 2BJ 2. Attachment K, or an equivalent, shall be used to show compliance with the alternative material

limitations. [022015-00SA S.C. 3C]

6 PTE should be calculated without proportionally reducing emissions.



PERMIT CONDITION 009A 10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants

Emission Source Description Status3 EP03 Heine Boiler Existing EP06 Bourbon Head Char New EP07 Wine Barrel Toaster Existing EP08 Bourbon Barrel Char (Wood) New EP32 Regrind Hammermill New EP37 Storage Bin Drop Point (Green Silo) New EP40 Wood-fired Stave Toaster Wood Burner New

EP83A Wood-fired Boiler # 1 New EP83B Wood-fired Boiler #2 New

Emission Limitation: 1. Emission sources listed as existing:

a) The permittee shall not cause or permit to be discharged into the atmosphere from these emission sources any visible emissions with an opacity greater than 40%.

b) Exception: The permittee may discharge into the atmosphere from any source of emissions for a period aggregating not more than six minutes in any 60 minutes air contaminants with an opacity up to 60%.

2. Emission sources listed as new: a) The permittee shall not cause or permit to be discharged into the atmosphere from these emission

sources any visible emissions with an opacity greater than 20%. b) Exception: The permittee may discharge into the atmosphere from any source of emissions for a

period aggregating not more than six minutes in any 60 minutes air contaminants with an opacity up to 60%.

Monitoring: 1. The permittee shall conduct visible emission observations on each emission unit using the

procedures contained in USEPA Test Method 22. The permittee is only required to take readings when the emission unit is operating and when the weather conditions allow. If the permittee observes no visible emissions using these procedures, then no further observations are required. For emission units with visible emissions, the source representative would then conduct a Method 9 observation.

2. The permittee must maintain the following monitoring schedule. Reissuance of an operating permit does not reset this schedule: a) The permittee shall conduct weekly observations for a minimum of eight (8) consecutive weeks

after permit issuance. b) Should the permittee observe no violations of this regulation during this period then-

i) The permittee may observe once every two (2) weeks for a period of eight (8) weeks. ii) If a violation is noted, monitoring reverts to weekly. iii) Should no violation of this regulation be observed during this period then

(1) The permittee may observe once per month. (2) 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 using Attachments C, E, and G ( or their equivalents), 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; c) Whether the visible emissions were normal for the process; d) The permittee shall maintain records of any equipment malfunctions, which may contribute to

visible emissions; and, e) The permittee shall maintain records of all USEP A Method 9 opacity tests performed.



PERMIT CONDITION 009B

24 Project No. 2015-05-025

10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants Emission Source Description Status3

EPOl-1 Stave Planers Existing EPOl-2 Stave Jointers Existing EPOl-3 Heading Planers ( 4) Existing EPOl-4 Heading Jointers (12) Existing EPOl-5 Heading Turner-Hog Existing EPOl-6 Slicker Wheels (Cull Staves) (2) Existing EPOl-7 Rip Saw (Cull Staves) Existing EPOl-8 Wine Barrel Assembly Sanders (5) Existing EPOl-9 Bourbon Barrel Assembly Sanders (5) Existing

EPOl-11 Bourbon Finish Rip Saw Existing EP02 Heine Fuel Bin Existing EPll Wood-fired Barrel Pre-Heater #1 New

EP24-1 Augurs, Bucket Elevator, and Drum Dry System (Wood Waste) New EP24-2' Drum Heater (Wood) New EP33-1 Wine Belly/Heading Sanders New EP33-2 Wine Belly/Heading Sanders New EP33-3 Wine Belly/Heading Sanders New EP34 Crozier #2 Wine Existing

EP41A Alternatives Rip Saw, 0.75 tons/hr New EP41B Alternatives Chop Saw, 0.75 tons/hr New EP41C Alternatives Band Saw, 0.75 tons/hr New EP41D Alternatives Planer, 0.75 tons/hr New EP41E Alternatives Rip/Chop Saws, 0.75 tons/hr New EP42 Alternatives Chopper w/Cyclone, 1.0 tons/hr New EP55 Building #4 Paint Booth, 0.053 gal/hr New EP64 Chip Roaster Cooling Table New EP68 Wood-fired French Tank Stave Oven New

EP69A Wood-fired Fire Tank Stave Toasting #1 New EP69B Wood-fired Fire Tank Stave Toasting #2 New EP70A Fire TIS Toasting Fire Pot Wood Combustion #1 New EP70B Fire TIS Toasting Fire Pot Wood Combustion #2 New EP71 Chop Saw, 0.0012 tons/hr New EP74 Craft Spirits Belly Sanders New EP75 Craft Spirits Bung Bore New EP76 Craft Spirits Bung Singe New EP77 Craft Spirits Manual Belt Sander (2) New EP78 Craft Spirits Head Sander (2) New EP79 Craft Spirits Edger New EP81 Two Boiler Baghouse, connected to other baghouses New

EP87A Craft Barrel Char (Wood burning from process) New

7 This permit condition does not apply while burning natural gas. Natural gas is exempt from the rule per 10 CSRI0-6.220(l)(L). However, the permit condition applies at all times the permittee is burning wood.


Emission Limitation:


1. Emission sources listed as existing:

25 Project No. 2015-05-025

a) The permittee shall not cause or permit to be discharged into the atmosphere from these emission sources any visible emissions with an opacity greater than 40%.

b) Exception: The permittee may discharge into the atmosphere from any source of emissions for a period aggregating not more than six minutes in any 60 minutes air contaminants with an opacity up to 60%.

2. Emission sources listed as new: a) The permittee shall not cause or permit to be discharged into the atmosphere from these emission

sources any visible emissions with an opacity greater than 20%. b) Exception: The permittee may discharge into the atmosphere from any source of emissions for a

period aggregating not more than six minutes in any 60 minutes air contaminants with an opacity upto 60%.




IV. Core Permit Requirements

26 Project No. 2015-05-025

The installation shall comply with each of the following requirements. Consult the appropriate sections in the Code of Federal Regulations (CFR), Code of State Regulations (CSR), and local ordinances for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect on the date of permit issuance. The following are only excerpts from the regulation or code, and are provided for summary purposes only

I 10 CSR 10-6.045 Open Burning Requirements 1. General Provisions. The open burning of tires, petroleum-based products, asbestos containing

materials, and trade waste is prohibited, except as allowed below. Nothing in this rule may be construed as to allow open burning which causes or constitutes a public health hazard, nuisance, a hazard to vehicular or air traffic, nor which violates any other rule or statute.

2. Certain types of materials may be open burned provided an open burning permit is obtained from the director. The permit will specify the conditions and provisions of all open burning. The permit may be revoked if the owner or operator fails to comply with the conditions or any provisions of the permit.

I 10 CSR 10-6.050 Start-up, Shutdown and Malfunction Conditions 1. In the event of a malfunction, which results in excess emissions that exceed one hour, the permittee

shall submit to the director within two business days, in writing, the following information: a) Name and location of installation; b) Name and telephone number of person responsible for the installation; c) Name of the person who first discovered the malfunction and precise time and date that the

malfunction was discovered. d) Identity of the equipment causing the excess emissions; e) Time and duration of the period of excess emissions; t) Cause of the excess emissions; g) Air pollutants involved; h) Estimate of the magnitude of the excess emissions expressed in the units of the applicable

requirement and the operating data and calculations used in estimating the magnitude; i) Measures taken to mitigate the extent and duration of the excess emissions; and j) Measures taken to remedy the situation that caused the excess emissions and the measures taken

or planned to prevent the recurrence of these situations. 2. The permittee shall submit the paragraph 1 information to the director in writing at least ten days

prior to any maintenance, start-up or shutdown activity which is expected to cause an excessive release of emissions that exceed one hour. If notice of the event cannot be given ten days prior to the planned occurrence, notice shall be given as soon as practicable prior to the activity.

3. Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under section 643 .140, RS Mo, the permittee may provide information showing that the excess emissions were the consequence of a malfunction, start-up or shutdown. The information, at a minimum, should be the paragraph 1 list and shall be submitted not later than 15 days after receipt of the notice of excess emissions. Based upon information submitted by the permittee or any other pertinent information available, the director or the commission shall make a determination whether the excess emissions constitute a malfunction, start-up or shutdown and whether the nature, extent and duration of the excess emissions warrant enforcement action under section 643.080 or 643.151, RSMo.



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

5. Compliance with this rule does not automatically absolve the permittee ofliability for the excess emissions reported.

I 10 CSR 10-6.060 Construction Permits Required The permittee shall not commence construction, modification, or major modification of any installation subject to this rule, begin operation after that construction, modification, or major modification, or begin operation of any installation which has been shut down longer than five years without first obtaining a permit from the permitting authority.

I 10 CSR 10-6.065 Operating Permits The permittee shall file a complete application for renewal of this operating permit at least six months before the date of permit expiration. In no event shall this time be greater than eighteen months. The permittee shall retain the most current operating permit issued to this installation on-site. The permittee shall immediately make such permit available to any Missouri Department of Natural Resources personnel upon request.

I 10 CSR 10-6.110 Reporting of Emission Data, Emission Fees and Process Information 1. The permittee shall submit a Full Emissions Report either electronically via MoEIS, which requires

Form 1.0 signed by an authorized company representative, or on Emission Inventory Questionnaire (EIQ) paper forms on the frequency specified in this rule and in accordance with the requirements outlined in this rule. Alternate methods of reporting the emissions, such as spreadsheet file, can be submitted for approval by the director.

2. Public Availability of Emission Data and Process Information. Any information obtained pursuant to the rule(s) of the Missouri Air Conservation Commission that would not be entitled to confidential treatment under 10 CSR 10-6.210 shall be made available to any member of the public upon request.

3. The permittee shall submit a full EIQ for the 2017 and 2020 reporting years. In the interim years the installation may submit a Reduced Reporting Form; however, if the installation's emissions increase or decrease by more than five tons when compared to their last submitted full EIQ, the installation shall submit a full EIQ rather than a Reduced Reporting Form.

4. In addition to the EIQ submittal schedule outlined above, any permit issued under 10 CSR 10-6.060 section (5) or (6) triggers a requirement that a full EIQ be submitted in the first full calendar year after the permitted equipment initially operates.

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

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



I 10 CSR 10-6.165 Restriction of Emission of Odors This requirement is not federally enforceable.

28 Project No. 2015-05-025

No person may cause, permit or allow the emission of odorous matter in concentrations and frequencies or for durations that odor can be perceived when one volume of odorous air is diluted with seven volumes of odor-free air for two separate trials not less than 15 minutes apart within the period of one hour.

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

Emission Limitation: 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 of a road, driveway or open area; or operation of a commercial or industrial installation without applying reasonable measures as may be required to prevent, or in a manner which allows or may allow, fugitive particulate matter emissions to go beyond the premises of origin in quantities that the particulate matter may be found on surfaces beyond the property line of origin. The nature or origin of the particulate matter shall be determined to a reasonable degree of certainty by a technique proven to be accurate and approved by the director.

2. The permittee shall not cause nor allow to occur any fugitive particulate matter emissions to remain visible in the ambient air beyond the property line of origin.

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

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

Monitoring: The permittee shall conduct inspections of its facilities sufficient to determine compliance with this regulation. If the permittee discovers a violation, the permittee shall undertake corrective action to eliminate the violation. The permittee shall maintain the following monitoring schedule. Reissuance of an operating permit does not reset this schedule: 1. The permittee shall conduct weekly observations for a minimum of eight (8) consecutive weeks after

permit issuance. 2. Should no violation of this regulation be observed during this period then-

a) The permittee may observe once every two (2) weeks for a period of eight (8) weeks. b) If a violation is noted, monitoring reverts to weekly. c) Should no violation of this regulation be observed during this period then

i) The permittee may observe once per month. ii) If a violation is noted, monitoring reverts to weekly.

3. If the permittee reverts to weekly monitoring at any time, monitoring frequency will progress in an identical manner to the initial monitoring frequency.


Recordkeeping:


The permittee shall document all readings on Attachment H, or its equivalent, noting the following: 1. Whether air emissions ( except water vapor) remain visible in the ambient air beyond the property

line of origin. 2. Whether equipment malfunctions contributed to an exceedance. 3. Any violations and any corrective actions undertaken to correct the violation.

I 10 CSR 10-6.180 Measurement of Emissions of Air Contaminants 1. The director may require any person responsible for the source of emission of air contaminants to

make or have made tests to determine the quantity or nature, or both, of emission of air contaminants from the source. The director may specify testing methods to be used in accordance with good professional practice. The director may observe the testing. All tests shall be performed by qualified personnel.

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

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

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

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

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

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

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

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

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

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



j 40 CFR Part 82 Protection of Stratospheric Ozone (Title VI)

30 Project No. 2015-05-025

1. The permittee shall comply with the standards for labeling of products using ozone-depleting substances pursuant to 40 CFR Part 82, Subpart E: a) All containers in which a class I or class II substance is stored or transported, all products

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

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

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

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

2. The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners (MV A Cs) in Subpart B of 40 CFR Part 82: a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices described in 40 CFR §82.156. b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply

with the standards for recycling and recovery equipment described in 40 CFR §82.158. c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by

an approved technician certification program pursuant to 40 CFR § 82.161. d) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with

the record keeping requirements of 40 CFR §82.166. ("MV AC-like" appliance as defined at 40 CFR §82.152).

e) Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to 40 CFR §82.156.

f) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records ofrefrigerant purchased and added to such appliances pursuant to 40 CFR §82.166.

3. If the permittee manufactures, transforms, imports, or exports a class I or class II substance, the permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A, Production and Consumption Controls.

4. If the permittee performs a service on motor (fleet) vehicles when this service involves ozonedepleting substance refrigerant ( or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements contained in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term "MV AC" as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or system used on passenger buses using HCFC-22 refrigerant.

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

Independent Stave Company, Inc. Installation ID: 105-000 I


V. General Permit Requirements

31 Project No. 2015-05-025

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

I 10 CSR 10-6.065, §(5)(E)2 and §(6)(C)l.B Permit Duration This permit is issued for a term of five years, commencing on the date of issuance. This permit will expire at the end of this period unless renewed.

10 CSR 10-6.065, §(5)(C)l and §(6)(C)l.C General Record Keeping and Reporting Re uirements

1. Record Keeping a) All required monitoring data and support information shall be retained for a period of at least

five years from the date of the monitoring sample, measurement, report or application. b) Copies of all current operating and construction permits issued to this installation shall be kept

on-site for as long as the permits are in effect. Copies of these permits shall be made immediately available to any Missouri Department of Natural Resources' personnel upon request.

2. Reporting a) All reports shall be submitted to the Air Pollution Control Program, Compliance and

Enforcement Section, P. 0. Box 176, Jefferson City, MO 65102. b) The permittee shall submit a report of all required monitoring by:

i) April 1st for monitoring which covers the January through December time period. ii) Exception. Monitoring requirements which require reporting more frequently than annually

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

c) Each report shall identify any deviations from emission limitations, monitoring, record keeping, reporting, or any other requirements of the permit.

d) Submit supplemental reports as required or as needed. All reports of deviations shall identify the cause or probable cause of the deviations and any corrective actions or preventative measures taken. i) Notice of any deviation resulting from an emergency ( or upset) condition as defined in

paragraph (6)(C)7 of 10 CSR 10-6.065 (Emergency Provisions) shall be submitted to the permitting authority either verbally or in writing within two working days after the date on which the emission limitation is exceeded due to the emergency, if the permittee wishes to assert an affirmative defense. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that indicate an emergency occurred and the permittee can identify the cause(s) of the emergency. The permitted installation must show that it was operated properly at the time and that during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or requirements in the permit. The notice must contain a description of the emergency, the steps taken to mitigate emissions, and the corrective actions taken.

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



iii) Any other deviations identified in the permit as requiring more frequent reporting than the permittee's annual report shall be reported on the schedule specified in this permit, and no later than ten days after any exceedance of any applicable rule, regulation, or other restriction.

e) Every report submitted shall be certified by the responsible official, except that, if a report of a deviation must be submitted within ten days after the deviation, the report may be submitted without a certification if the report is resubmitted with an appropriate certification within ten days after that, together with any corrected or supplemental information required concerning the deviation.

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

I 10 CSR 10-6.065 §(5)(C)l and §(6)(C)l.D Risk Management Plan Under Section 112(r) If the installation is required to develop and register a risk management plan pursuant to Section 1 l 2(R) of the Act, the permittee will verify that it has complied with the requirement to register the plan.

I 10 CSR 10-6.065(5)(C)l.A General Requirements 1. The permittee must comply with all of the terms and conditions of this permit. Any noncompliance

with a permit condition constitutes a violation and is grounds for enforcement action, permit termination, permit revocation and re-issuance, permit modification or denial of a permit renewal application.

2. The permittee may not use as a defense in an enforcement action that it would have been necessary for the permittee to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit

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

4. This permit does not convey any property rights of any sort, nor grant any exclusive privilege. 5. The permittee shall furnish to the Air Pollution Control Program, upon receipt of a written request

and within a reasonable time, any information that the Air Pollution Control Program reasonably may require to determine whether cause exists for modifying, reopening, reissuing or revoking the permit or to determine compliance with the permit. Upon request, the permittee also shall furnish to the Air Pollution Control Program copies of records required to be kept by the permittee. The permittee may make a claim of confidentiality for any information or records submitted under this rule.

6. Failure to comply with the limitations and conditions that qualify the installation for an Intermediate permit make the installation subject to the provisions of 10 CSR 10-6.065(6) and enforcement action for operating without a valid part 70 operating permit.

I 10 CSR 10-6.065(5)(C)l.C Reasonably Anticipated Operating Scenarios None.

10 CSR 10-6.065, §(5)(B)4; §(S)(C)l, §(6)(C)3.B; and §(6)(C)3.D; and §(5)(C)3 and §(6)(C)3.E.(I) - III and V - VI Com liance Re uirements

1. Any document (including reports) required to be submitted under this permit shall contain a certification signed by the responsible official.



2. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized officials of the Missouri Department of Natural Resources, or their authorized agents, to perform the following (subject to the installation's right to seek confidential treatment of information submitted to, or obtained by, the Air Pollution Control Program): a) Enter upon the premises where a permitted installation is located or an emissions-related activity

is conducted, or where records must be kept under the conditions of this permit; b) Have access to and copy, at reasonable times, any records that must be kept under the conditions

of this permit; c) Inspect, at reasonable times and using reasonable safety practices, any facilities, equipment

(including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; and

d) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the Act, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the terms of this permit, and all applicable requirements as outlined in this permit.

3. All progress reports required under an applicable schedule of compliance shall be submitted semiannually ( or more frequently if specified in the applicable requirement). These progress reports shall contain the following: a) Dates for achieving the activities, milestones or compliance required in the schedule of

compliance, and dates when these activities, milestones or compliance were achieved, and b) An explanation of why any dates in the schedule of compliance were not or will not be met, and

any preventative or corrective measures adopted. 4. The permittee shall submit an annual certification that it is in compliance with all of the federally

enforceable terms and conditions contained in this permit, including emissions limitations, standards, or work practices. These certifications shall be submitted annually by April 1st, unless the applicable requirement specifies more frequent submission. These certifications shall be submitted to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and exceedances must be included in the compliance certifications. The compliance certification shall include the following: a) The identification of each term or condition of the permit that is the basis of the certification; b) The current compliance status, as shown by monitoring data and other information reasonably

available to the installation; c) Whether compliance was continuous or intermittent; d) The method(s) used for determining the compliance status of the installation, both currently and

over the reporting period; and e) Such other facts as the Air Pollution Control Program will require in order to determine the

compliance status of this installation.

I to CSR 10-6.065, §(S)(C)l and §(6)(C)7 Emergency Provisions 1. An emergency or upset as defined in 10 CSR I0-6.065(6)(C)7.A shall constitute an affirmative

defense to an enforcement action brought for noncompliance with technology-based emissions limitations. To establish an emergency- or upset-based defense, the permittee must demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, the following: a) That an emergency or upset occurred and that the permittee can identify the source of the

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

based emissions limitations or requirements in this permit, and



d) That the permittee submitted notice of the emergency to the Air Pollution Control Program within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective actions taken.

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

I 10 CSR 10-6.065(5)(C)S Off-Permit Changes 1. Except as noted below, the permittee may make any change in its permitted installation's operations,

activities or emissions that is not addressed in, constrained by or prohibited by this permit without obtaining a permit revision. Off-permit changes shall be subject to the following requirements and restrictions: a) The change must meet all applicable requirements of the Act and may not violate any existing

permit term or condition; the permittee may not change a permitted installation without a permit revision if this change is a Title I modification; Please Note: Changes at the installation which affect the emission limitation(s) classifying the installation as an intermediate source (add additional equipment to the record keeping requirements, increase the emissions above major source level) do not qualify for off-permit changes.

b) The permittee must provide contemporaneous written notice of the change to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219. This written notice shall describe each change, including the date, any change in emissions, pollutants emitted and any applicable requirement that would apply as a result of the change; and

c) The permittee shall keep a record describing all changes made at the installation that result in emissions of a regulated air pollutant subject to an applicable requirement and the emissions resulting from these changes.

I 10 CSR 10-6.020(2)(R)34 Responsible Official The application utilized in the preparation of this permit was signed by David Bollenbach, Plant Manager. If this person terminates employment, or is reassigned different duties such that a different person becomes the responsible person to represent and bind the installation in environmental permitting affairs, the owner or operator of this air contaminant source shall notify the Director of the Air Pollution Control Program of the change. Said notification shall be in writing and shall be submitted within 30 days of the change. The notification shall include the name and title of the new person assigned by the source owner or operator to represent and bind the installation in environmental permitting affairs. All representations, agreement to terms and conditions and covenants made by the former responsible person that were used in the establishment of limiting permit conditions on this permit will continue to be binding on the installation until such time that a revision to this permit is obtained that would change said representations, agreements and covenants.

I 10 CSR 10-6.065 §(S)(E)4 and §(6)(E)6.A(I1I)(a)-(c) Reopening-Permit for Cause This permit may be reopened for cause if: 1. The Missouri Department of Natural Resources (MDNR) or EPA determines that the permit contains

a material mistake or that inaccurate statements were made which resulted in establishing the emissions limitation standards or other terms of the permit,



2. Additional applicable requirements under the Act become applicable to the installation; however, reopening on this ground is not required if-: a) The permit has a remaining term of less than three years; b) The effective date of the requirement is later than the date on which the permit is due to expire;

or c) The additional applicable requirements are implemented in a general permit that is applicable to

the installation and the installation receives authorization for coverage under that general permit, 3. MDNR or EPA determines that the permit must be reopened and revised to assure compliance with

applicable requirements.

j 10 CSR 10-6.065 §(S)(E)l.A and §(6)(E)l.C Statement of Basis This permit is accompanied by a statement setting forth the legal and factual basis for the permit conditions (including references to applicable statutory or regulatory provisions). This Statement of Basis, while referenced by the permit, is not an actual part of the permit.

VI. Attachments

Attachments follow.



Attachment Al Plant-wide PM1o Tracking Sheet

36 Project No. 2015-05-025

This attachment may be used to show compliance with Permit Condition PWOO 1.

This attachment is for the month of _______ in the year _______ _

C

Monthly Control Emission

Description Monthly PM10 Emission Source

Efficiency8 PM10 Unit Throughput Factor (lb/ton) (SCC) Emissions9

(%) (tons)

EPOl-1 Stave Planers tons 0.2 lb/ton 30700802 0 EPOl-2 Stave Jointers tons 0.2 lb/ton 30700802 0 EPOl-3 Heading Planers tons 0.2 lb/ton 30700802 0 EPOl-4 Heading Jointers tons 0.2 lb/ton 30700802 0 EPOl-5 Heading Turner-Hog tons 0.2 lb/ton 30700802 0 EPOl-6 Slicker Wheels tons 0.2 lb/ton 30700802 0 EPOl-7 Rip Saw tons 0.2 lb/ton 30700802 0

EPOl-8 Wine Barrel Assembly

tons 0.2 lb/ton 30700802 0 Sanders

EPOl-10 Bourbon Finish Sanders tons 0.2 lb/ton 30700802 0

EPOl-11 Bourbon Finish Rip

tons 0.2 lb/ton 30700802 0 Saw

EP02 Heine Fuel Bin tons 0.58 lb/ton 30703001 89.5 EP03 Heine Boiler MMBtu 0.36 lb/MMBtu 10200908 0 EP05 Wine Head Toasters MMBtu 0.36 lb/MMBtu 10200908 0 EP06 Bourbon Head Char MMBtu 0.36 lb/MMBtu 10200908 0 EP07 Wine Barrel Toaster MMBtu 0.36 lb/MMBtu 10200908 0

Bourbon Barrel Char MMBtu 0.36 lb/MMBtu 10200908 0

EP08 (Wood) Bourbon Barrel Char

MMcf 1.9 lb/MMcf 10200603 0 (Natural Gas)

EPll Barrel Pre-Heater #1 MMBtu 0.36 lb/MMBtu 10200908 0 EP17 Transfer to Storage Bay tons 1.2 lb/ton 30703002 0

EP22 Chip Transfer to Meter

Tons 0.36 lb/ton 30700803 0 Bin #1

EP23 Meter Bin No. 1 (Toast) tons 0.36 lb/ton 30700803 0 Augurs, Bucket

EP24-1 Elevator, & Drum Dry tons 0.36 lb/ton 10200908 0 System (Wood Waste) Drum Heater (Wood) tons 0.36 lb/ton 10200908 0

EP24-2 Drum Heater (Natural MMcf 1.9 lb/MMcf 10200603 0

Gas) EP25 Chips Bagging (Toast) tons 0.58 lb/ton 30703001 0

EP27 Cleaver Brooks Storage

tons 0.58 lb/ton 30703001 89.5 Silo

EP31 Regrind Metering Bin tons 0.36 lb/ton 30700803 0 EP32 Regrind Hammermill tons 0.2 lb/ton 30700802 0

EP33-1 Wine Belly Sanders tons 0.2 lb/ton 30700802 0 EP33-2 Wine Head Sanders tons 0.2 lb/ton 30700802 0

8 Only emission sources with an enforceable requirement to use its control device can take in account the control efficiency when calculating emissions. 9 [Monthly PM10 Emissions] [Monthly Throughput] x [PM10 Emission Factor] x (1 - [Control Efficiency]/ 100) / 2000


Emission Description Unit

EP33-3 Wine Chime Sanders EP34 Crozier #2

EP35 Enclosed Building Regrind

EP36 Wine Barrel Lasers (2)

EP37 Storage Bin Drop Point (Green Silo)

EP40 Stave Toaster Wood Burner

EP4IA Alternatives Rip Saws EP4IB Alternatives Chop Saws EP41C Alternatives Band Saw EP4ID Alternatives Planer

EP4IE Alternatives Rip/Chop Saws

EP42 Alternatives Chipper w/ Cyclone

EP43 Alternatives Bay (4) French Tank Stave

EP45 Oven Burner (Natural Gas)

EP47 Electric Tank Stave Toaster (Pierre)

EP48 French Oak Block Storage

EP51 Natural Gas Fired Chip Roasters ( 4)

EP52 Bulk Bag Bagger (New Alt)

EP53-2 Bulk Bag Meter Bin EP53-3 Chip Bulk Bag Fill

Bulk Bag EP53-4 Unloader/Feeder

Conveyor

EP53-5 Roaster Mechanical Handling

EP53-6 Chip Roaster Overhead Feeder Belt

EP53-7 Chip Roaster Cooling Tables (2) Cooling Table

EP53-8 Takeaway Belt Conveyors (2)

EP53-9 Chip Roaster Bulk Bag Load

EP53-10 Chip Roaster Cyclone Hoooer

EP53-l l Trash Dumpster for Cyclone Hoooer

EP54-l 2mm Belt Conveyor to Vibrating Screen


Monthly PM10 Emission Source Throughput Factor (lb/ton) (SCC)

tons 0.2 lb/ton 30700802 tons 0.2 lb/ton 30700802

tons 1.2 lb/ton 30703002

MMBtu 0.36 lb/MMBtu 10200908

tons 0.2 lb/ton 30700802


tons 0.2 lb/ton 30700802 tons 0.2 lb/ton 30700802 tons 0.2 lb/ton 30700802 tons 0.2 lb/ton 30700802

tons 0.2 lb/ton 30700802

tons 0.2 lb/ton 30700802

tons 0.36 lb/ton 30700803

MMcf 1.9 lb/MMcf 10200603


tons 0.58 lb/ton 30703001


tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803 tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

37 Project No. 2015-05-025

Control ·· .. Monthly·

Efficiency8 PM10 Emissions9

(%) Jtons) . 0 0

0

0

0

0

96.7 96.7 96.7 96.7

96.7

90

0

0

0

0

65

0

0 0

0

0

0

0

0

0

0

0

0


. . ,, .. .·''.'

Emissio.n Description .Unit

. . .

EP54-2 2mm Vibrating Screener

EP54-3 2mm Chip Conveyor (2)

EP54-4 2mm Chip Bags (2)

EP57-4 Sweco Screener

EP57-5 Green Dust Over Dumpster

EP57-7 Green Sawdust Product Conveyor

EP57-8 Green Sawdust Bagger/Bag

EP58-l Green Storage to Heine Bucket Loader

EP58-2 Green Storage to Heine Meter Bin

EP60A French Natural Gas Fired Chip Roaster #5

EP60B French Natural Gas Fired Chip Roaster #6

EP61 Bulk Bag Unloader/ Feeder Conveyor

EP62 France Roaster #5 Mechanical Handling


EP64 French Chip Roaster Cooling Table

EP65 French Cooling Table Takeaway Conveyor

EP66 French Chip Roaster Bulk Bag Loading

EP67 French Chip Roaster Cyclone Hopper (2)

EP68 French Tank Stave Oven (Wood)

EP69A Fire Tank Stave Toasting #1 (Wood)

EP69B Fire Tank Stave Toasting #2 Fire T/S Toasting Fire

EP70A Pot Wood Combustion #1 Fire T/S Toasting Fire

EP70B Pot Wood Combustion #2

EP71 Chop Saw for Fire Pot Wood

EP72 Ash/Charcoal Chute to Augur


.· <:

Monthly PM10 Emission Source Throughput Factor (lb/ton) (SCC)

. . .

tons 0.36 lb/ton

30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803



tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803

tons 0.36 lb/ton 30700803






tons 0.2 lb/ton 30700802

tons 0.36 lb/ton 30700803

38 Project No. 2015-05-025

Monthly Control Efficiency8 PM10

Emissions9

(%) (tons)

0

0

0

0

0

0

0

100 0

100 0

65

65

0

65

65

0

0

0

0

0

0

0

0

0

95

0


Emission Description Unit

EP73 Ash/Charcoal Augur to Dumpster

EP74 Craft Spirits Belly Sanders

EP75 Craft Spirits Bung Bore

EP76 Craft Spirits Bung Singe

EP77 Craft Spirits Manual Belt Sander (2)

EP78 Craft Spirits Head Sander (2)

EP79 Craft Spirits Edger

EP80A, Steam Heated Kilns (3)

B,C

EP81 Two Boiler Baghouse

EP82A Enclosed Bottom Ash Drum Transfer

EP82B Enclosed Bottom Ash Drum Transfer

EP83A Wood-fired Boiler EP83B Wood-fired Boiler

EP84A Enclosed Bottom Ash Drum Transfer

EP84B Enclosed Ash Drum Transfer

EP85 Storage Silo

EP86 Enclosed Building Trailer Loading

EP87A Craft Barrel Char (wood)

EP87B Craft Barrel Char Burners (NG)

Emission Unit Description

EP55 Building #4 Paint Booth


.. Monthly

Control Monthly PM10 Emission Source Efficiency8 PM10

Throughput Factor (lb/ton) (SCC) Emissions9

(%) (tons)

tons 0.36 lb/ton 30700803 0

tons 0.2 lb/ton 30700802 0

tons 0.2 lb/ton 30700802 0

MMBtu 0.36 lb/MMBtu 10200908 0

tons 0.2 lb/ton 30700802 0

tons 0.2 lb/ton 30700802 0

tons 0.2 lb/ton 30700802 0

0.022 NCDENR

Lumber 1000 board ft lb/I 000 board ft

Kilns tons 0.36 lb/MMBtu 10200908 99.5

tons 0.36 lb/ton 30700803 0

tons 0.36 lb/ton 30700803 0

MMBtu 0.36 lb/MMBtu 10200908 95 MMBtu 0.36 lb/MMBtu 10200908 95

tons 0.36 lb/ton 30700803 0

tons 0.36 lb/ton 30700803 0

tons 0.36 lb/ton 30700803 99.5

tons 0.36 lb/ton 30700803 0

MMBtu 0.36 lb/ton 30700803 0

MMcf 1.9 lb/MMcf 10200603 0 .

Monthly Monthly Density ·· Solids Transfer Control

PM10

Throughput (lb/gal) 10 Content Efficiency Efficiency Emissions11

("wto/0)10 (%) (%) (tons)

gal 50 97.5

Installation Monthlv PM10 emissions12 (tons): .. ·· 12-Month Rolline Total PM10 .Emissions13 (tons): ·.

1° From the SDS sheet of the material. If a range is given, use the highest value in the range. 11

[Monthly PM10 Emissions]= [Monthly Throughput] x [Density] x ([Solids Content]/ 100) x (1- [Transfer Efficiency]/ 100) x (1 - [Control Efficiency]/ 100) / 2000 12

Sum of Monthly PM10 Emissions. Should include Start-up, Shutdown, and Malfunction (SSM) Emissions as reported to the Air Pollution Control Program's Compliance/Enforcement Section in accordance with 10 CSR 10-6.050. 13

The facility must have a 12-month rolling emission total of less than 100.0 tons PM10 in order to be in compliance.



Attachment A2 EP-57 and EP-58 PM10 Tracking Sheet

40 Project No. 2015-05-025

This attachment may be used to show compliance with Permit Condition 005.

This attachment is for the month of ________ in the year _______ _

Emis~Jon • PM10 Emission Source Control Monthly PM10

Description ' Throughput Efficiency Emissions14

Unit Factor (lb/ton) (SCC) ·. ·. (%) (tons)

EP57-1 Green Dust Trailer

tons 0.36 lb/ton 30700803 0 Dump

EP57-2 Bucket Loader Transfer

tons 0.36 lb/ton 30700803 0 Green Sawdust

EP57-3 Bulk Bag Metering Bin tons 0.36 lb/ton 30700803 0 EP57-4 Sweco Screener tons 0.36 lb/ton 30700803 0

EP57-5 Green Dust Over

tons 0.36 lb/ton 30700803 0 Dumpster

EP57-6 Plant Waste Dump

tons 0.36 lb/ton 30700803 0 Trailer

EP57-7 Green Sawdust Product

tons 0.36 lb/ton 30700803 0 Conveyor

EP57-8 Green Sawdust

tons 0.36 lb/ton 30700803 0 Bagger/Bag

EP58-1 Green Storage to Heine

tons 0.36 lb/ton 30700803 100 0 Bucket Loader

EP58-2 Green Storage to Heine

tons 0.36 lb/ton 30700803 100 0 Meter Bin ..

·• . · . ..

Installation Monthlv PM10 emissions15 (tons): ·.· ....• •• ·• . · . . .

12-Month Rollin!! Total PM10 Emissions16 (tons): .. ..

14 [Monthly PMlO Emissions]= [Throughput] x [PMlO Emission Factor] x (1 - [Control Efficiency]/ 100) / 2000 15 Sum of the monthly PM10 Emissions from EP57 and EP58. The sum should include Start-up, Shutdown, and Malfunction (SSM) Emissions as reported to the Air Pollution Control Program's Compliance/Enforcement section for compliance with 10 CSR 10-6.050. 16 A 12-month rolling emission total ofless than 15.0 tons PM10 from EP-57 and EP-58 indicates compliance.



Attachment Bl Plantwide HAP Tracking Sheet

This attachment may be used to show compliance with Permit Condition PW002.

This attachment is for the month of __________ in the year _________ _

Table 1: HAPs from Wood and Fuel Burning: Emission

Description HAP Monthly HAP Emission Monthly HAP

Source Tbrou2bput Factor17 Emissions (tons) HCI 0.164 lb/ton

Hexane 0.005 lb/ton

EP03 Heine Boiler Ethylbenzene

tons 0.0001 lb/ton

Toluene 0.0005 lb/ton Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton

HCl 0.164 lb/ton Hexane 0.005 lb/ton

EP05 Wine Head Ethylbenzene 0.0001 lb/ton Toaster Toluene

tons 0.0005 lb/ton

Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton

HCI 0 .164 lb/ton Hexane 0.005 lb/ton

EP06 Bourbon Head Ethylbenzene 0.0001 lb/ton Char Toluene

tons 0.0005 lb/ton


HCI 0.164 lb/ton Hexane 0.005 lb/ton

EP07 Wine Barrel Ethylbenzene 0.0001 lb/ton Toaster I Bending Toluene

tons 0.0005 lb/ton



Bourbon BBL Ethyl benzene tons

0.0001 lb/ton Char - Wood Toluene 0.0005 lb/ton

EP08 Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton

Bourbon BBL Hexane 1.8 lb/MMcf Char ~ Natural Toluene MMcf 0.0034 lb/MMcf Gas Cobalt 0.000084 lb/MMcf


EPll Barrel Pre-Heater Ethylbenzene

tons 0.0001 lb/ton

#1 Toluene 0.0005 lb/ton Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton

EP24 Drum Heater # 1 - HCI 0 .164 lb/ton Wood Hexane

tons 0.005 lb/ton

17 Factors obtained from Construction Permit 052016-001.


Emission Description

Source

Drum Heater # 1 -Natural Gas

EP36 Wine Barrel Laser

EP40 Stave Toaster

Alternatives Tank EP45 Stave Oven-

Natural Gas

EP47 Electric Tank Stave Toaster

Propane Fired EP51 Chip Roasters -

Natural Gas Chip Roaster

EP60A Burner - Natural Gas Chip Roaster

EP60B Burner- Natural Gas

EP68 Tank Stave Oven Wood Breakdown

EP69A Tank Stave Toasting

Tank Stave EP69B

Toasting


HAP Monthly HAP Emission Monthly HAP

Throu2hput Factor17 Emissions (tons) Ethylbenzene 0.0001 lb/ton

Toluene 0.0005 lb/ton Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton Hexane 1.8 lb/MMcf Toluene MMcf 0.0034 lb/MMcf Cobalt 0.000084 lb/MMcf

HCl 0 .164 lb/ton Hexane 0.005 lb/ton

Ethylbenzene 0.0001 lb/ton Toluene

tons 0.0005 lb/ton



Ethylbenzene tons

0.0001 lb/ton Toluene 0.0005 lb/ton Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton Hexane 1.8 lb/MMcf Toluene MMcf 0.0034 lb/MMcf Cobalt 0.000084 lb/MMcf


Ethyl benzene 0.0001 lb/ton Toluene

tons 0.0005 lb/ton

Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton Hexane 1.8 lb/MMcf Toluene MMcf 0.0034 lb/MMcf Cobalt 0.000084 lb/MMcf Hexane 1.8 lb/MMcf Toluene MMcf 0 .0034 lb/MM cf Cobalt 0.000084 lb/MMcf Hexane 1.8 lb/MMcf Toluene MMcf 0.0034 lb/MMcf Cobalt 0.000084 lb/MMcf


Ethyl benzene 0.0001 lb/ton Toluene

tons 0.0005 lb/ton



Ethylbenzene tons

0.0001 lb/ton Toluene 0.0005 lb/ton Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton

HCl 0 .164 lb/ton Hexane tons 0.005 lb/ton

Ethylbenzene 0.0001 lb/ton


Emission Description

Source

EP70A Wood Fire Pot Combustion

EP70B Wood Fire Pot Combustion

EP80A, Steam Heated B,C Kilns

Wood-Fired EP83A

Boiler

Wood-Fired EP83B

Boiler


HAP Monthly HAP Emission Monthly HAP

Throughput Factor17 Emissions (tons) Toluene 0.0005 lb/ton Xylene 0.0005 lb/ton Cobalt 0.000003 lb/ton



tons 0.0005 lb/ton


HCI 0.164 lb/ton Hexane 0.005 lb/ton


tons 0.0005 lb/ton


Acetaldehyde 0.052 lb/1000

board ft

Acrolein 0.0075 lb/1000

board ft

Formaldehyde 0.018 lb/1000

board ft

Methanol 1000 board ft 0.2 lb/1000 board

ft

Phenol 0.01 lb/1000 board

ft

Propionaldehyde 0.0009 lb/1000

board ft Acetaldehyde 0.014 lb/ton

Benzene tons 0.069 lb/ton Formaldehyde 0.072 lb/ton Acetaldehyde 0.014 lb/ton

Benzene tons 0.069 lb/ton Formaldehyde 0.072 lb/ton

(Continued on next page)



Table 2: HAPs from EP55 Building #4 Paint Booth:

Materials Used Amount HAP Transfer

(Name, Type: Used Density18 HAP Solvent / Ink/ Monthly (lb/gal) (Name, CAS)

Content19 Efficiency

Extender) (gal) (%) (%)

50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50

Include HAPs from both Table 1 and Table 2 of this attachment:

44 Project No. 2015-05-025

Overall Monthly HAP Control

Efficiency20 Emissions21

(%) (tons)

Sum of Monthl Total HAP Emissions22 ton/month : 12 Month Rollin Total HAP Emissions23 tons/ ear :

18 From the SOS for the material. If specific gravity is provided instead, the density can be obtained by multiplying the specific gravity by 8.33. 19 From the SOS for the material. If a range of HAP contents is provided, the highest values in the ranges shall be used to demonstrate compliance. 2° Control efficiency should be 0% when calculating VOC-HAPs. Control efficiency should be 97.5% when calculating PMHAPs. 21 [Amount Used Monthly] x [Density] x ([Hap Content]/100) x ([Transfer Efficiency]/100) x ([Overall Control Efficiency]/100) = [Monthly HAP Emissions] 22 Sum of the Monthly HAP Emissions. Includes Start-Up, Shutdown, and Malfunction (SSM) Emissions as reported to the Air Pollution Control Program's Compliance/Enforcement section for compliance with 10 CSR 10-6.050. 23 Must be under 25.0 tons/year in order to be in compliance.



Attachment B2 Individual HAP Tracking Sheet

45 Project No. 2015-05-025

This attachment is for the month of __________ in the year _________ _

Take the HAP emissions calculated in Table 1 and 2 of Attachment Bl and sum up each individual HAP below.

Individual HAP Monthly Individual HAP Emissions 12-Month RoJJing for Individual

HAP Emissions24

(Name,CAS) (tons/month) (tons/year)

24 12-Month Rolling Total for each HAP should be less than 10.0 tons/year in order to demonstrate compliance.



Emission Unit#

Attachment C Inspection/Maintenance/Repair/Malfunction Log

-------------------

Inspection/ Malfunction Activities

Date/Time Maintenance Activities Malfunction Impact Duration Cause

46 Project No. 2015-05-025

Action Initials


Emission Point I Date

Control Device


Attachment D Pressure Drop Monitoring

47 Project No. 2015-05-025

Manufacturer's Within Pressure Drop

Recommended Value Specifications? (w.c.)

(w.c.) (Yes /No)



Attachment E Visible Emission Observations

48 Project No. 2015-05-025

Visible Emissions Excess Emissions

Date Time Emission

Source No Yes25 Cause Corrective Action Initial

25 If there are visible emissions, the permittee shall complete the excess emissions columns.



Attachment F Coating Usage Compliance Worksheet

49 Project No. 2015-05-025

This attachment may be used to show compliance with Permit Condition 008.

This attachment covers the period from to --------- ---------

Month/Year

(month, year)

Amount of coating used this month (2al)

26 A 12-Month Rolling Total of less than 411.0 gallons indicates compliance.

(month, year)

12-Month Rolling TotaI26 (gal)



Attachment G

'\:. . . . . . .. ,·}:

· Method. 9>Qpacity Eirlissions'Oli~¢ryatiohs,' ..... :: ... , .. ' ' .

Company Observer

Location Observer Certification Date

Date Emission Unit

Time Control Device

Hour

0

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 . .

•: >: Set Number ... · ... ..·:.

Readings ranged from ______ to ______ % opacity.

50 Project No. 2015-05-025

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


Visible Emissions

Date Time Beyond Boundary

No Yes


Attachment H Fugitive Emission Observations

51 Project No. 2015-05-025

If There Are Visible Emissions Beyond the Property Boundary

Initial Cause Corrective

Action



Attachment I 40.0 Tons NOx Tracking Worksheet

This tracking sheet can be used to show compliance with Permit Condition 006.

This tracking sheet is for the month of _______ in the year ______ _

Emission Monthly Source MontblyNOx

Description Emission Factor Emissions27

Source Throughput (SCC) (tons)

EP83A Wood-fired Boiler #1 MMBtu 0.49 lb/MMBtu AP-42, Table

1.6-2

EP838 Wood-fired Boiler #2 MMBtu 0.49 lb/MMBtu AP-42, Table

1.6-2

EP87A Craft Barrel Char (Wood

MMBtu 0.49 lb/MMBtu AP-42, Table

burning from process) 1.6-2

EP87B Craft Barrel Char Burners

MMcf 2.2 lb/MMcf AP-42, Table

(natural gas) 1.4-2 Sum of Monthly NOx Emissions28 (tons):

12-Month Rollin!! Total NOx Emissions29 (tons):

27 [Monthly NOx Emissions] = [Monthly Throughput] x [Emission Factor]/ [2000 lb/ton] 28 The sum of the Monthly NOx Emissions. Should include Start-up, Shutdown, and Malfunction (SSM) Emissions as reported to the Air Pollution Control Program's Compliance/Enforcement Section as required by 10 CSR 10-6.050. 29 A 12-Month Rolling Total NOx Emissions ofless than 40.0 tons indicates compliance.



Attachment J Plantwide CO Tracking Worksheet

This attachment can be used to show compliance with Permit Condition PW003.

Emission Description Monthly Throughput

CO Emission Unit Factor (lb/ton)3° EP03 Heine Boiler tons wood 9.84 lb/ton wood EP05 Wine Head Toasters tons wood 9.84 lb/ton wood EP06 Bourbon Head Char tons wood 9.84 lb/ton wood EP07 Wine Barrel Toaster tons wood 9.84 lb/ton wood

EP08 Bourbon Barrel Char (Wood) tons wood 9. 84 lb/ton wood Bourbon Barrel Char (Natural Gas) MMcf 84 lb/MMcf

EPl 1 Barrel Pre-Heater #1 tons wood 9.84 lb/ton wood

EP24-2 Drum Heater #1 (Wood) tons wood 9.84 lb/ton wood Drum Heater #1 (Natural Gas) MMcf 84 lb/MMcf

EP36 Wine Barrel Lasers (2) tons wood 13 .6 lb/ton wood EP40 Stave Toaster Wood Burner tons wood 9.84 lb/ton wood

EP45 French Tank Stave Oven Burner

MMcf 84 lb/MMcf (Natural Gas) EP47 Electric Tank Stave Toaster (Pierre) tons wood 9.84 lb/ton wood EP51 Natural Gas Fired Chip Roasters (4) MMcf 84 lb/MMcf

EP60A French Natural Gas Fired Chip

MMcf 84 lb/MMcf Roaster #5

EP60B French Natural Gas Fired Chip

MMcf 84 lb/MMcf Roaster #6

EP68 French Tank Stave Oven (Wood) tons wood 9.84 lb/ton wood EP69A Fire Tank Stave Toasting #1 (Wood) tons wood 9.84 lb/ton wood EP69B Fire Tank Stave Toasting #2 (Wood) tons wood 9.84 lb/ton wood

EP70A Fire T/S Toasting Fire Pot Wood

tons wood 9.84 lb/ton wood Combustion # 1

EP70B Fire T/S Toasting Fire Pot Wood

tons wood 9.84 lb/ton wood Combustion #2

EP76 Craft Spirits Bung Singe tons wood 9.84 lb/ton wood EP83A Wood-frred Boiler tons wood 9. 84 lb/ton wood EP83B Wood-frred Boiler tons wood 9.84 lb/ton wood EP87A Craft Barrel Char ( wood) tons wood 9. 84 lb/ton wood EP87B Craft Barrel Char (NG) MMcf 84 lb/MMcf

· Installation Monthly CO emissions31 (tons): 12-Month Rolling Total CO Emissions32 (tons):

Monthly CO Emissions (tons)

30 Emission factors based on a higher heating value of 8,200 Btu/lb wood and an emission factor of 0.6 Ib/MMBtu from SCC

10200908 for wood burning. For natural gas burning, an emission factor of 84 lb/MM cf is used from SCC 10200603. EP3 6 uses SCC 10200906 for wood-fired boilers. 31 Sum of Monthly CO Emissions. Should include Start-up, Shutdown, and Malfunction (SSM) Emissions as reported to the Air Pollution Control Program's Compliance/Enforcement Section in accordance with 10 CSR 10-6.050. 32 The facility must have a 12-month rolling emission total of less than 100.0 tons CO in order to be in compliance.



Attachment K Alternative Coating Compliance Worksheet

This attachment can be used to show compliance with Permit Condition 008.

Coating name: --------------------- Date: _________ _

A B C D E F G Maximum

Overall PM Individual HAP is also Individual Application

Control Individual Individual

HAP Name and PM? HAP Content Rate HAPPTE HAPSMAL CASNo. (yes I no) (max weight%) (lbs coating /

Efficiency (tons/year) (tons/year)

year) (%)

A. Record all the individual HAPs from this single coating SDS.

54 Project No. 2015-05-025

H I

CoatingVOC CoatingVOC PTE (weight%)

(tons/year)

B. Compare the HAP to the most recent HAP SMAL table, available at http://dnr.mo.gov/env/apcp/docs/cp-hapsma1tbl6.pdf as Table of Hazardous Air Pollutants, Screening Model Action Levels for verification as particulate matter.

C. Record the maximum weight percent of each HAP from the SDS. D. Record the maximum application rate with units of lbs of coating per year by multiplying the density (lb/gal) by 411.0 gallons. E. The overall PM control efficiency includes the air atomized spray gun transfer efficiency (50%), booth capture efficiency (100%), and exhaust filter control efficiency

(95%): 50% + (] - 50%) X ]00% X 95% X = 97.5%. F. Calculate the particulate matter HAP potential to emit: F = C x D x (I - E) I 2000. Otherwise calculate the volatile HAP potential to emit: F = C x D / 2000. G. Record the individual HAP SMAL from the most recent HAP SMAL table. Seek approval from the Air Pollution Control Program New Source Review Unit before

using this coating if the individual HAP potential to emit is greater than the SMAL. H. Record or calculate the coating's VOC weight% from the SDS. Verify VOC status according to IO CSR 10-6.020 Definitions and Common Reference Tables (2)(V) 13. I. Calculate the VOC potential to emit. I= D x H / 2000. Seek approval from the Air Pollution Control Program New Source Review Unit before using this coating if the

VOC potential to emit is greater than 131.8 tons per year.


Intermediate Operating Permit

STATEMENT OF BASIS Voluntary Limitations

SB - 1 Project No. 2015-05-025

In order to qualify for this Intermediate State Operating Permit, the permittee has accepted voluntary, federally enforceable emission limitations. Per 10 CSR 10-6.065(5)(C)l.A.(VI), if these limitations are exceeded, the installation immediately becomes subject to 10 CSR 10-6.065(6) and enforcement action for operating without a valid part 70 operating permit. It is the permittee's responsibility to monitor emission levels and apply for a part 70 operating permit far enough in advance to avoid this situation. This may mean applying more than eighteen months in advance of the exceedance, since it can take that long or longer to obtain a part 70 operating permit.

INSTALLATION DESCRIPTION Independent Stave Company, Inc. operates a wine and bourbon barrel toasting facility in Lebanon, Missouri. This installation has accepted a voluntary limitation of 100.0 tons per year of particulate matter less than 10 microns in diameter (PM10) and carbon monoxide (CO) as well as a 10/25 tons per year limit on HAPs to qualify for this Intermediate Operating Permit.

Updated Potential to Emit for the Installation

Pollutant Potential to Emit (tons/yr)33

PM10 < 100 PM2s < 100 co < 100 NOx 80.08 SOX 4.03 voe 14.83 HAPs < 10/25j4

33Each emission unit was evaluated at 8,760 hours of uncontrolled annual operation unless otherwise noted. All pollutants

have been proportionally reduced with respect to the CO limitation ( excluding PM 10). 34 Less than 1 O tons/year individual HAPs, less than 25 tons/year total HAPs.



Reported Air Pollutant Emissions, tons per year

Pollutants 2017 2016 2015 Particulate Matter 25.88 22.69 24.79

_::: Ten Microns (PM 10)

Particulate Matter 17.82 15.10 14.92 _::: 2.5 Microns (PM2s)

Sulfur Oxides 1.68 2.10 2.17 (SOx)

Nitrogen Oxides 33.91 42.07 43.74

(NOx)

Volatile Organic Compounds 4.12 3.73 3.91 (VOC)

Carbon Monoxide 41.12 51.15 53.01 (CO)

Lead < 0.01 < 0.01 < 0.01 (Pb)

Hazardous Air Pollutants 0.66 1.85 1.93 (HAPs)

Permit Reference Documents

SB - 2 Project No. 2015-05-025

2014 2013

19.52 15.57

11.74 10.00

2.64 2.39

52.26 47.37

2.16 1.99

63.73 57.82

0.01 < 0.01

0.18 0.18

These documents were relied upon in the preparation of the operating permit. Because they are not incorporated by reference, they are not an official part of the operating permit.

1) Intermediate Operating Permit Application, received May 7, 2015; 2) 2017 Emissions Inventory Questionnaire, received February 19, 2018; and 3) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary

Point and Area Sources, Fifth Edition. 4) Construction Permit 0995-014, Issued September 5, 1995 5) Construction Permit 072001-008, Issued August 15, 2001 6) Construction Permit 0995-014A, Issued November 6, 2001 7) Construction Permit 092002-024, Issued September 26, 2002 8) Construction Permit 082006-007, Issued August 28, 2006 9) Construction Permit 052009-005, Issued May 11, 2009 10) Construction Permit 022010-004, Issued February 16, 2010 11) Construction Permit 092010-007, Issued September 20, 2010 12) Construction Permit 022015-005, Issued February 5, 2015 13) Construction Permit 022015-005A, Issued April 13, 2015 14) Construction Permit 052016-001, Issued May 3, 2016 15) Construction Permit 052016-00lA, issued July 13, 2017


Construction Permit History


Construction Permit 0995-014, Issued September 5, 1995

SB -3 Project No. 2015-05-025

This permit is for the installation of a wood/bark waste fired boiler for wine barrel toasting. It contains 2 special conditions. • Special Condition 1 and 2 has been removed due to its conditions being similar to 10 CSR 10-

6.170 and 10 CSR 10-6.165 in order to streamline this permit.

Construction Permit 072001-008, Issued August 15, 2001 This permit adds a bucket loader (EP-30), a metering bin (EP-31), and a hammermill (EP-32) with associated baghouse No. 9. It has no special conditions.

Construction Permit 0995-014A, Issued November 6, 2001 This permit amends CP 0995-014 replaces the burning of scrap wood with electric heating elements to provide the heat to toast barrels. It contains no special conditions.

Construction Permit 092002-024, Issued September 26, 2002 This permit adds a process where oak wood dust is drawn out of an enclosed fuel bin and dropped to a storage pile to be loaded by a front end loader and into a semi-trailer to be hauled away. It contains no special conditions.

Construction Permit 082006-007, Issued August 28, 2006 This permit adds two rip saws, four chop saws, one ban saw, a planer (EP-41A, B, C, D, E), a chipper (EP-42), four bays (EP-43), use of a bucket loader for transferring material (EP-44) and a batch oven (EP-45). It contains 2 special conditions. • Special Condition 1 limits CO emissions from the installation. It has been superseded by CP

052009-005. • Special Condition 2 requires a fabric filter to be used with the planer (EP-41) and the cyclone for

EP-42. It has been added to the permit.

Construction Permit 052009-005, Issued May 11, 2009 This permit adds a new screening line and the permitting of existing equipment for a wood chip roasting line. It contains 3 special conditions. • Special Condition 1 supersedes Special Condition 1 found in CP 082006-007. • Special Condition 2 limits CO emissions from the installation. It has been superseded by CP

022015-005. • Special Condition 3 requires cyclones to be used on the four chip roasters (EP-51 ). It has been

added to the permit.

Construction Permit 022010-004, Issued February 16, 2010 This permit adds a paint booth (EP-55) to the facility. It contains 4 special conditions. • Special Condition 1 limits VOC emissions from the paint booth. It has been superseded by CP

022015-005A. • Special Condition 2 requires solvents and cleaning solutions to be properly stored. It has been

added to the permit.


Intermediate Operating Permit SB - 4 Project No. 2015-05-025

• Special Condition 3 requires a filter to be used with the paint booth. It has been added to the permit.

• Special Condition 4 is general recordkeeping and reporting requirements. These have been added to the permit.

Construction Permit 092010-007, Issued September 20, 2010 This permit adds a green sawdust bagging process for a marketable product and sawdust conveyance process for on-site boiler fuel. It contains 4 special conditions. • Special Condition 1 adds a PM10 emission limitation on the sawdust bagging process and

sawdust conveyance for the Heine boiler's fuel. This condition has been added to the permit. • Special Condition 2 limits HAP emissions. It has been superseded by CP 022015-005. • Special Condition 3 requires conveyors/augers of EP-58 to be controlled by complete enclosure

and negative pressure. This condition has been added to the permit. • Special Condition 4 is general recordkeeping and reporting requirements. These have been added

to the permit.

Construction Permit 022015-005, Issued February 5, 2015 This permit is for the installation of two natural gas-fired wood chip roasters, two wood-fired stave toasters, a stave oven, bulk bagging system, and associated conveyors. It contains 9 special conditions. • Special Condition 1 supersedes Special Condition 2 of CP 052009-005 and Special Condition 2

of CP 09201 o~007. • Special Condition 2 limits CO emissions. It has been superseded by CP 052016-001. • Special Condition 3 limits HAP emissions. It has been superseded by CP 052016-001. • Special Condition 4 contains emission capture requirements for hood devices. This condition has

been added to the permit. • Special Condition 5 contains emission capture requirements for medium efficiency cyclones.

This condition has been added to the permit. • Special Condition 6 contains emission capture requirements for baghouses. This condition has

been added to the permit. • Special Condition 7 requires the permittee to bum exclusively untreated wood or natural gas in

certain emission sources. This condition has been added to the permit. • Special Condition 8 requires the permittee to render the waste oil-fired boiler EP-50 inoperable

before the new equipment is added. This condition has been met. • Special Condition 9 is general recordkeeping and reporting requirements. These have been added

to the permit.

Construction Permit 022015-005A, Issued April 13, 2015 This permit creates a voluntary coating throughput limit for the paint usage of the paint booth to make recordkeeping easier. It contains 4 special conditions. • Special Condition 1 supersedes Special Condition 1 of CP 022010-004 and Special Condition 3

of CP 022015-005. • Special Condition 2 adds a limit on coating material from the paint booth. This condition has

been added to the permit. • Special Condition 3 adds conditions to be followed if alternative material is used in the paint

booth. CP 052016-00IA introduces new special conditions intended to replace Special Condition



3. While this special condition is not explicitly superseded, it can be assumed that CP 052016-001 A's Special Condition 3 replaces it. As a result, special condition 3 was excluded from this operating permit.

• Special Condition 4 is general recordkeeping and reporting requirements. These have been added to the permit.

Construction Permit 052016-001, Issued May 3, 2016 This permit is for the installation of two wood-fired boilers and three steam-heated dry kilns. It contains 8 special conditions. • Special Condition 1 superseded Special Conditions 2 and 3 of CP 022015-005. • Special Conditions 2, 3, 6, and 8 have been superseded by CP 052016-00lA. • Special Condition 4 requires a multiple cyclone separator to be used on boilers EP-83A and EP-

83B. This condition has been added to the permit. • Special Condition 5 requires a baghouse to be used on storage silo EP-85. This condition has

been added to the permit. • Special Condition 7 requires the Cleaver Brooks Boiler EP-04 to be rendered inoperable once the

new boilers, EP-83A and EP-83B, have begun operation. This condition has been met and thus it has not been added to the operating permit.

Construction Permit 052016-00lA, issued July 13, 2017 This amendment was done to add a new Craft Barrel process. Because of the close timing of this project with CP 052016-001, this process has been amended to the previous construction permit. • Special Condition 1 supersedes Special Conditions 2, 3, 6, and 8 of CP 052016-001. • Special Condition 2 gives a plant-wide limit of 250.0 tpy CO. This condition was not included

because of the more stringent 100.0 tpy CO limitation set by this Intermediate operating permit. If the facility were to switch to a Part 70 operating permit it would become subject to this special condition.

• Special Condition 3 gives a limitation of 25.0 tpy total HAP and 10.0 tpy individual HAP. It also added conditions for calculating particulate matter control and alternative material emissions via Special Condition 38. This condition assumes a 50% PM transfer efficiency and PM control efficiency of 95% for "EP-55 through EP-57". This assumption appears to apply only to the paint booth EP-55 as it is the only emission point that is sprayed with a gun and has a control device that can use the assumptions appropriately. As a result, it has only been applied to EP-55 in this operating permit. It was not included as a permit condition in order to streamline this operating permit; it has been incorporated into Attachment A 1. Special Condition 3E(l ), which required the permittee to alert the Air Pollution Control Program when alternative material potential emissions are greater than or equal to 131.8 tpy VOC, has been incorporated. It should be noted that this operating permit calculated PTE by proportionally reducing the other criteria pollutants (other than PM10) with respect to CO, hence why the PTE for VOC is below 100 tons/year. Calculating the PTE for the alternative materials for EP55 should be calculated without proportional reduction.

• Special Condition 4 adds a 40.0 tpy NOx limitation for certain equipment. It contains a typo that references Table 4 rather than Table 3 in the construction permit. Table 3 has a typo where it states that the NOx emission factor for EP87B is 22.0 lb/MMcf rather than 2.2 lb/MMcf. This condition has been added to this operating permit.



• Special Condition 5 adds a limitation on fuel used for certain equipment. It has been added to this operating permit.

• Special Condition 6 has general recordkeeping requirements that have been added to this permit.

New Source Performance Standards (NSPS) Applicability

40 CFR Part 60, Subpart De - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units

This subpart does not apply because most of the boilers have a heat capacity less than 10 MMBtu/hr. EP03 Wood-fired Heine Boiler has a heat capacity of 23 MMBtu/hr, however it was installed in the 1960s, before the 1989 applicability date of this subpart.

Maximum Achievable Control Technology (MACT) Applicability

40 CFR Part 63, Subpart DDDD-National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products

The facility is not subject to this subpart. This subpart only applies to facilities that are major sources of HAPs. The facility is an area source ofHAPs.

40 CFR Part 63, Subpart QQQQ - National Emission Standards for Hazardous Air Pollutants: Surface Coating of Wood Building Products

The facility is not subject to this subpart. This subpart only applies to facilities that apply coatings to wood building products. The barrels produced at this facility do not meet the subpart's definition of wood building products.

40 CFR Part 63, Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

The facility is not subject to this subpart. This subpart applies to facilities that perform paint stripping using MeCl, perform spray application of coatings on vehicles, and sprays coatings with a target HAP (chromium, lead, manganese, nickel or cadmium) to a plastic and/or metal substrate on a part or product. The facility performs none of these nor uses coatings with target HAPs.

40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources

This subpart applies to the facility and has been applied within the permit.

40 CFR Part 63, Subpart QQQQQQ - National Emission Standards for Hazardous Air Pollutants for Wood Preserving Area Sources

The facility is not subject to this subpart. This subpart applies to facilities that perform wood preserving, which is the process of pressure or thermal impregnation of chemicals into wood to give it resistance to fungi, bacteria, insects, etc. The facility does not perform wood preserving on its barrels.


Intermediate Operating Permit SB- 7 Project No. 2015-05-025

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

40 CFR Part 61, Subpart M - National Standards for Asbestos In the permit application and according to APCP records, there was no indication that any Missouri Air Conservation Law, Asbestos Abatement, 643.225 through 643.250; 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants, Subpart M, National Standards for Asbestos; and 10 CSR 10-6.250, Asbestos Abatement Projects - Certification, Accreditation, and Business Exemption Requirements apply to this installation. The installation is subject to these regulations if they undertake any projects that deal with or involve any asbestos containing materials. None of the installation's operating projects underway at the time of this review deal with or involve asbestos containing material. Therefore, the above regulations were not cited in the operating permit. If the installation should undertake any construction or demolition projects in the future that deal with or involve any asbestos containing materials, the installation must follow all of the applicable requirements of the above rules related to that specific project.

Greenhouse Gas Emissions

Note that this source may be subject to the Greenhouse Gas Reporting Rule. However, the preamble of the GHG Reporting Rule clarifies that Part 98 requirements do not have to be incorporated in Part 70 permits operating permits at this time. In addition, Missouri regulations do not require the installation to report CO2 emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2 emissions were not included within this permit. The applicant is required to report the data directly to EPA if subject. The public may obtain CO2 emissions data for this installation by visiting http:// epa. gov/ ghgreporti ng/ ghgdata/reportingdatasets .html

Missouri Code of State Regulations (CSR) Applicability

10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants 10 CSR 10-6.250, Asbestos Projects - Certification, Accreditation and Business Exemption Requirements

In the permit application and according to APCP records, there was no indication that any Missouri Air Conservation Law, Asbestos Abatement, 643.225 through 643.250; 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants, Subpart M, National Standards for Asbestos; and 10 CSR 10-6.250, Asbestos Abatement Projects - Certification, Accreditation, and Business Exemption Requirements apply to this installation. The installation is subject to these regulations if they undertake any projects that deal with or involve any asbestos containing materials. None of the installation's operating projects underway at the time of this review deal with or involve asbestos containing material. Therefore, the above regulations were not cited in the operating permit. If the installation should undertake any construction or demolition projects in the future that deal with or involve any asbestos containing materials, the installation must follow all of the applicable requirements of the above rules related to that specific project.

10 CSR 10-6.100, Alternate Emission Limits This rule is not applicable because the installation is in an ozone attainment area.

Independent Stave Company, Inc. Installation ID: I 05-0001


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

SB - 8 Project No. 2015-05-025

This rule applies to the installation. While applicable to the emission sources in Permit Condition 009B, visible emissions are not expected; each emission source has the potential to emit less than 0.5 lb/hr (taking in account applicable control devices). As a result, monitoring/recordkeeping is not required.

The following emission sources are exempt from this rule:

Emission Sources Description Reason EP15 Trailer Loadout/Transfer Fugitive EP17 Transfer to Storage Bay from Closed Conveyance Emits only indoors EP2I Chips to Pre-Heaters Transfer to Box from Storage Bay via FEL Fugitive EP23 Meter Bin #1 (Toast) Emits only indoors

EP25 Pneumatic Transfer to Chip Bagging from Hammermill #2

Emits only indoors Pneumatic Transfer to Bagging from Closed Conveyance

EP30 Bucket Loader Transfer Regrind Meter Bin Fugitive EP31 Load Regrind Meter Bin from Enclosed Building via FEL Emits only indoors EP35 Enclosed Building - Regrind Emits only indoors EP36 Wood-fired Wine Barrel Lasers (2) Emits only indoors EP38 Transport Sawdust with Front End Loader (Green Silo) Fugitive EP39 Loading Semi Trailer with Front End Loader Fugitive EP43 Storage of Chinned Wood in Alternatives Bay (4) Emits only indoors EP44 Transfer Chipped Wood with Bucket Loader in Alternatives Bay Fugitive EP45 Alternative Tank Stave Oven Burner; natural gas fueled Uses onlv natural gas EP46 Sweeping and Dumping Plant Waste into Trailer Fugitive EP48 French Oak Block Building Shavings Storage Emits only indoors EP49 French Oak Bucket Loader Transfer Fugitive EP51 Natural Gas Fired Chip Roasters (4) Uses only natural gas EP52 Bulk Bag Bagger (New Alternative Bay) Emits only indoors

EP53-l Bucket Loader Transfer to Bulk Bag Loader Fugitive EP53-2 Bulk Bag Meter Bin Emits only indoors EP53-3 Chip Bulk Bag Fill Emits only indoors EP53-4 Bulk Bag Unloader/Feeder Conveyor Emits only indoors EP53-5 Green Dust Overs Dumpster Emits only indoors EP53-6 Chip Roaster Overhead Feeder Belt Emits only indoors EP53-7 Green Sawdust Product Conveyor Emits only indoors EP54-l 2mm Belt Conveyor to Vibrating Screen EP54-2 2mm Vibrating Screener

Emits only indoors EP54-3 2mm Chip Conveyor (2) EP54-4 2mm Chip Bags (2)

Truck Shop Parts Cleaner EP56 Building #2 Parts Cleaner Emits only indoors

Forklift Shops Parts Cleaner EP57-l Green Dust Trailer Dump, 2 tons/hr Fugitive EP57-2 Bucket Loader Transfer Green Sawdust; 2 tons/hr Fugitive EP57-3 Bulk Bag Metering Bin; 2 tons/hr Fugitive EP57-4 Sweco Screener; 2 tons/hr Emits only indoors EP57-5 Green Dust Overs Dumpster; 0.28 tons/hr Emits only indoors EP57-6 Plant Waste Dump Trailer; 0.28 tons/hr Fugitive EP57-7 Green Sawdust Product Conveyor, 0.28 tons/hr Emits onlv indoors EP57-8 Green Sawdust Bagger/Bag, 1.72 tons/hr Emits only indoors



Emission Sources Description EP58-l Green Storage to Heine Bucket Loader; I. 77 tons/hr EP58-2 Green Storage to Heine Meter Bin, 1.77 tons/hr EP59 Heading Trailer Loadout

EP60A Natural Gas-fired Chip Roster Burner EP60B Natural Gas-fired Chip Roaster Burner EP61 Bulk Bag Unloader/Feeder Conveyor EP62 France Roaster #5 Mechanical handling EP63 France Roaster #6 Mechanical handling EP65 Cooling Table Takeway Belt Conveyor EP66 Chip Roaster Bulk Bag Loading EP67 Chip Roaster Cyclone Hopper EP72 Ash/Charcoal Chute to Auger EP73 Ash/Charcoal Augur to Dumpster

EP82A Enclosed Bottom Ash Drum Transfer EP82B Enclosed Bottom Ash Drum Transfer EP84A Enclosed Ash Drum Transfer EP84B Enclosed Ash Drum Transfer EP86 Enclosed Building Transfer Loading

EP200 - EP228 Paved and Unpaved Haul Roads

10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds

SB - 9 Project No. 2015-05-025

Reason Emits only indoors Emits only indoors Fugitive Uses only natural gas Uses only natural gas Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Emits only indoors Fugitive

This regulation applies to the facility and has been included in this permit. For Permit Condition 002A, no monitoring/recordkeeping is required due to the emission sources meeting compliance with the limitations as shown below:

General Equations:

ppmv S02 = [S02 Emission Factor in lb/MMBtu] x [ F Factor in MMBtu/wscf] x [Conversion Factor for lb/scf to ppm] x [Conversion Factor for ppmw to ppmv]

mg/m3 S03 = [S02 Emission Factor in lb/MMBtu] x [ F Factor in MMBtu/wscf] x x [Conversion Factor for lb/scf to mg/m3

]

S02 emission factor for wood-fired boilers= 0.025 lb/MMBtu (SCC 10200908)

The F factor is the ratio of gas volume of products of combustion to the heat content of the fuel. For wood the F factor= 1 MMBtu / 9,240 wscf (Part 60 Appendix A Method 19Table 19-2)

Conversion factor for lb/scf to ppm= ppm/ 1.660K7 lb/scf (Part 60 Appendix A Method 19 Table 19-1)

Conversion factor for ppmw to ppmv = (28.8 / Molecular Weight of S02) ppmv / 1 ppmw = (28.8/64) ppmv / ppmw= 0.45 ppmv / ppmw (AP-42 Appendix A)

Compliance Demonstration Conversion to S02:

_ (0.025 lb/ ) (MMBtu; ) (ppmw/ ) (0.45 ppmv; ) _ ppmv SOz - MMBtu 9,240ft3 1.667E-7 lb/scf ppmw - 7.3o ppmv



7.30 ppmv S02 << 500 ppmv S02 or 2,000 ppmv S02

SB - 10 Project No. 2015-05-025

It is assumed all sulfur was converted to S02, therefore it is assumed the facility emits S03 below the specified limit.

The calculations show that no further monitoring or recordkeeping is necessary for 10 CSR 10-6.260 because the emission unit's worst-case emissions are substantially lower than the applicable limit.

10 CSR 10-6.261, Control of Sulfur Dioxide Emissions This regulation applies to the facility and has been included in this permit. This rule technically applies to the following direct-fired emission sources:

Emission Description Source EP05 Wine Head Toasters EP06 Bourbon Head Char EP07 Wine Barrel Toaster EP08 Bourbon Barrel Char EPl 1 Wood-fired Barrel Pre-Heater

EP24-2 Drum Heater (Wood) EP36 Wine Barrel Laser EP40 Wood-fired Stave Toaster Wood Burner EP47 Electric Tank Stave Toaster (Pierre) EP68 French Tank Stave Oven - Wood

EP69A Fire Tank Stave Toasting #1 - wood EP69B Fire Tank Stave Toasting #2 - wood EP70A Fire T/S Toasting Fire Pot Wood Combustion #1 EP70B Fire T/S Toasting Fire Pot Wood Combustion #2

When wood is burned in these emission sources sulfur is emitted. 10 CSR 10-6.261 does not contain any limitations for direct-fired sources that use wood fuel. As a result, 10 CSR 10-6.261 was not applied to these sources in this operating permit. If the emission sources listed were to burn a fuel source other than wood or natural gas, they may become subject to limitations. However, these emission units are still subject to 10 CSR 10-6.260.

For applicable sources with applicable limitations, the following table demonstrates that they will always be in compliance with 10 CSR 10-6.261:

S02 Potential

S02 Emission MHDR Emission Source S02 Emission In Source

Description (MMBtu/hr) Factor (SCC)

Emission Rate Limit Compliance? Rate

(lb/MMBtu) (lb/hr) (lb/hr)

EP-03 Heine Boiler 25.87 0.025 10200908 0.65 8.0 Yes

EP-83A Wood-fired

9.289 0.025 10200908 0.23 8.0 Yes Boiler #1

EP-83B Wood-fired

9.289 0.025 10200908 0.23 8.0 Yes Boiler #2



Since all of the emission rates are below the S02 emission rate limitation, all of the emission sources in the above table are in compliance and thus do not require monitoring or recordkeeping.

10 CSR 10-6.400, Restriction of Emission of Particulate Matter From Industrial Processes This rule does not apply as demonstrated below:

Maximum Allowable PM Emissions= E (lb/hr)= 4.l(P)067

Where P = Process weight rate (tons/hr) E = Allowable emission rate limit (lb/hr)

Emission MHDR PM

Source Unit Description

(per hr) Emission

(SCC) Factor

EPOl-1 Stave Planers 12.3 tons 0.2 lb/ton 30700802

EPOl-2 Stave Jointers 12.3 tons 0.2 lb/ton 30700802

EPOl-3 Heading Planers (4) 2.0 tons 0.2 lb/ton 30700802

EPOl-4 Heading Jointers (12) 1.36 tons 0.2 lb/ton 30700802

EPOl-5 Heading Turner-Hog 3.5 tons 0.2 lb/ton 30700802

EPOl-6 Slicker Wheels (Cull

0.63 tons 0.2 lb/ton 30700802 Staves)

EPOl-7 Rip Saw (Cull Staves) 0.60 tons 0.2 lb/ton 30700802

EPOl-8 Wine Barrel Assembly

0.4 tons 0.2 lb/ton 30700802 Sanders (5)

EPOl-10 Bourbon Barrel

0.35 tons 0.2 lb/ton 30700802 Assembly Sanders (5)

EPOl-11 Bourbon Finish Rip

0.29 tons 0.2 lb/ton 30700802 Saw

EP02 Heine Fuel Bin 4.1 tons 0.58

30703001 lb/ton

EP32 Regrind Hammermill 3.6 tons 0.2 lb/ton 30700802

EP33-l Wine Belly/Heading

0.17 tons 0.2 lb/ton 30700802 Sanders

EP33-2 Wine Belly/Heading


EP33-3 Wine Belly/Heading


EP41A Alternatives Rip Saw 0.75 ton 0.2 lb/ton 30700802

Potential Uncontrolled Control

PM Efficiency Emission (%)35

rate (lb/hr)

2.46 0

2.46 0

0.40 0

0.27 0

0.27 0

0.13 0

0.12 0

0.08 0

0.07 0

0.06 0

2.38 0

0.72 0

0.03 0

0.02 0

0.01 0

0.15 0

PM Emission

Limit Exempt?

(lb/hr)

22.03 Yes,< limit

22.03 Yes,< limit

Yes,< -

0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr

10.55 Yes,< limit

Yes,< 9.67 PWR

limit Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr Yes,<

-0.5 lb/hr

35 While some emission sources may have federally required control devices over 90% (which is an exemption to 10 CSR 10-

6.400), if the emission source meets another exemption, the control efficiency was not applied in this table. This demonstrates that even without the control device, the emission source would be exempt from the rule.


Emission Unit

Description

EP41B Alternatives Chop Saw

EP4IC Alternatives Band Saw

EP4ID Alternatives Planer

EP41E Alternatives Rip/Chop Saws

EP42 Alternatives Chopper w/ Cyclone

EP53 Chip Roasting Process

Building #4 Paint EP55

Booth



EP7I Chop Saw

EP80A, Steam Heated Kilns B,C (3)

EP85 Storage Silo


Potential

MHDR PM

Source Uncontrolled

(per hr) Emission

(SCC) PM

Factor Emission rate (lb/hr)

0.75 ton 0.2 lb/ton 30700802 0.15

0.75 ton 0.2 lb/ton 30700802 0.15

0.75 ton 0.2 lb/ton 30700802 0.15

0.75 ton 0.2 lb/ton 30700802 0.15

1.0 tons 0.2 lb/ton 30700802 0.15

0.67 ton 0.36

30700803 0.24 lb/ton

9.96 0.28 gal

lb/gaI36 Eng. Cale. 1.4037

0.1675 0.36 30700803 0.06

lb/ton tons 0.1675 0.36

30700803 0.06 lb/ton tons

0.0012 0.2 lb/ton 30700802 < 0.01

tons 0.5936 0.022 NCDENR

lOOOboard lb/ 1000 ~ lumber 0.01 ft board ft kilns

0.36 5.43 tons

lb/tons 30700803 1.95

SB - 12 Project No. 2015-05-025

PM Control Emission

Efficiency Limit

Exempt? (%)35

(lb/hr)

0 -Yes,<

0.5 lb/hr

0 -Yes,<

0.5 lb/hr

0 -Yes,<

0.5 lb/hr

0 -Yes,<

0.5 lb/hr

0 -Yes,<

0.5 lb/hr

0 Yes,<

-0.5 lb/hr

Yes~ 97.5 0.03 95%

control

0 Yes,<

-0.5 lb/hr

0 Yes,<

-0.5 lb/hr

0 Yes,<

-0.5 lb/hr

Yes,< 0 -

0.5 lb/hr

Yes~ 99.5 < 0.01 95%

control

All other emission sources not listed are considered fugitive, don't meet the definition of process weight in 10 CSR 10-6.020, and/or are indirect heating sources and are thus exempt. As a result, 10 CSR 10-6.400 does not apply to any emission source at this facility.

10 CSR 10-6.405, Restriction of Particulate Matter Emissions From Fuel Burning Equipment Used for Indirect Heating

This regulation applies to the facility and has been included in this permit. Natural gas fueled units are exempt from this rule. The applicable sources are demonstrated to be in compliance with this rule below:

Emission Source I Description Existin2 Sources

EP03 I Heine Boiler EP40 I Stave Toaster Wood Burner

New Sources EP83A I Wood-fired Boiler # I EP83B I Wood-fired Boiler #2

Sum of Heat Input (Q):

36 Based off of a material density of 13 .3 lb/gal and 75 wt% solids. 37 Assuming 50% transfer efficiency.

MHDR (MMBtu/hr)

25.87 1.76

9.289 9.289

46.208



The allowable PM10 emission limitation for existing indirect heating sources having an intermediate capacity between 10 MMBtu/hr and 10,000 MMBtu/hr is:

E = 0.9(Qro114 E = 0.9(46.208r0174 0.46 lb/MMBtu

The allowable PM10 emission limitation for new indirect heating sources having an intermediate capacity between 10 MMBtu/hr and 10,000 MMBtu/hr is:

E = 1.31 (Qro338 E = 0.9(46.208r0338 = 0.25 lb/MMBtu

All Sources:

Emission Emission Factor Source Emission

Source Description Fuel

(lb/MMBtu) (SCC) Limit

(lb/MMBtu) EP03 Heine Boiler Wood 0.36 10200908 0.51

EP40 Stave Toaster Wood

Wood 0.36 10200908 0.60 Burner

EP83A Wood-fired Boiler # 1 Wood 0.36 10200908 0.60 EP83B Wood-fired Boiler #2 Wood 0.36 10200908 0.60

The indirect heating sources will always be in compliance. As a result, no monitoring or recordkeeping is necessary.

Other Regulatory Determinations

None.

Other Regulations Not Cited in the Operating Permit or the Above Statement of Basis

In Compliance?

Yes

Any regulation which is not specifically listed in either the Operating Permit or in the above Statement of Basis does not appear, based on this review, to be an applicable requirement for this installation for one or more of the following reasons. 1) The specific pollutant regulated by that rule is not emitted by the installation. 2) The installation is not in the source category regulated by that rule. 3) The installation is not in the county or specific area that is regulated under the authority of that rule. 4) The installation does not contain the type of emission unit which is regulated by that rule. 5) The rule is only for administrative purposes.

Should a later determination conclude that the installation is subject to one or more of the regulations cited in this Statement of Basis or other regulations which were not cited, the installation shall determine and demonstrate, to the Air Pollution Control Program's satisfaction, the installation's compliance with that regulation(s). If the installation is not in compliance with a regulation which was not previously cited, the installation shall submit to the APCP a schedule for achieving compliance for that regulation(s).

Independent Stave Company, Inc. Intermediate Operating Permit Installation ID: 105-0001

Response to Public Comments

RPC- 1 Project No. 2015-05-025

The draft permit was put up on public notice on April 6, 2018 for a period of 30 days. During this time no public comments were received.

MAY 2 9 2018 Mr. David Bollenbach Independent Stave Company, Inc. P.O. Box 104 Lebanon,MO 65536

Re: Independent Stave Company, Inc., 105-0001 Permit Number: OP2018-044

Dear Mr. Bollenbach:

Enclosed with this letter is your intermediate operating permit. Please review this document carefully. Operation of your installation in accordance with the rules and regulations cited in this document is necessary for continued compliance. It is very important that you read and understand the requirements contained in your permit.

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

You may appeal this permit to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.078.16 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within thirty (30) days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If you send your appeal by registered or certified mail, we will deem it filed on the date you mailed it. If you send your appeal by a method other than registered or certified mail, we will deem it filed on the date the AHC receives it.

If you have any questions or need additional information regarding this permit, please contact the Air Pollution Control Program (APCP) at (573) 751-4817, or you may write to the Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102.

Sincerely,

Mu'.l~,'-,,'/--Michael J. Stansfield, P .E. Operating Permit Unit Chief

MJS:kwj

Enclosures

c: PAMS File: 2015-05-025