August 7, 2012 Technical Demonstration for Negligible Impact to Air Quality For the Amendment to 10 CSR 10

- 6.400 Restriction of Emission of Particulate Matter from Industrial Processes Background The Missouri Air Conservation Commission (MACC) adopted an amendment to 10 CSR 10

- 6.400 Restriction of Emission of Particulate Matter from Industrial Processes on October 28 , 2010. The amendment added an alternative compliance method for wet corn milling drying operations. Prior to the amendment , wet corn milling drying operations were required to operate a control device capable of 99.5% control efficiency by weight and there was no outlet concentration limit that could be used in lieu of the control efficiency requirement. When investigating the orig in of this requirement, the Missouri D epartment of Natural Resources’ Air Pollution Control Program was unable to determine the reason this level of control was specificall y required for these types of operations. It is believed that the rule language w as likel y borrowed from a different s tate’s rule originall y written to control total suspended particulate matter (TSP) emissions, which would make 99.5% control efficiency by weight much easier to achieve when considering the removal of particles much larger than PM 10 . In late 2009, National Starch and Chemical Company (National Starch) requested a variance from this r

ule requirement, as it was demonstrated that due to their clean upfront process and resulting low inlet concentration of PM 10 , 99.5% control efficiency was not possible. Their inlet PM 10 concentration is 0.09 grains/dry standard cubic foot (grain/dscf). Therefore, in order to achieve 99.5% control efficiency , their outlet concentration would need to be 0.00045 grain/dscf. The department’s Air Pollution Control Program is unaware of an y t yp e of control technology that could guarantee this level of control

. National Starch currentl y has a wet scrubber in operation to control particulate matter emissions from their wet corn milling drying operation units, which is able to guarantee a control efficiency of 99% for inlet concentrations ranging from 1

– 2 grai n/dscf. For National Starch’s much lower inlet concentration, the scrubber can onl y guarantee an outlet concentration of 0.01 grain/dscf, which equates to a control efficiency of approximately

88.9%. The next level of control would be a bag house, which could only guarantee a level of control down to 0.005 grain/dscf (a control efficiency of about 94.4%). This still would not achieve the 99.5% control efficiency required in the rule, and due to the high moisture content of the emissions from these units, it is unlikely that a bag house would be able to work as designed. In March 2010, the MACC granted a variance to National Starch from this rule requirement, and the department’s Air Pollution Control Program began developing a rule amendment to address this issue. Through the rulemaking, an alternative compliance method based on an outlet concentration of 0.01 grain/dscf was added to the rule, which could be used to comply with the rule in lieu of the 99.5% control requirement for wet corn milling drying operations. Negligible Impact to Air Quality DemonstrationThere are onl y two sources in the s tate that the wet corn milling drying operations requirement in

10 CSR 10

- 6.400 applies to. Inaddition to National Starch, the other wet corn milling drying operation is owned b y Li feline Foods, which operates with a much higher inlet concentration of PM 10 emissions , making the 99.5% control efficiency easier to meet than the alternative compliance method based on a 0.01 grain/ dscf outlet concentration limit. Therefore, this amendment is not expected to have an y impact on the control requirements for L ifeline Foods. With their wet scrubber in operation (outlet concentration of 0.01 grain/dscf), National Starch currentl y has a controlled potential to emit of 3 ton/year of PM 10 . National Starch investigated the Environmental Protection Agency ’s ( EPA’s ) Best Available Control Technology databases and found no control te chnology that could guarantee an outlet particulate matter concentration of less than or equa l to 0.00045 grain/dscf, which would be required to achieve 99.5% control efficiency . The most stringent technology that could be applied would be a bag house, which could only

guarantee a level of control of 0.005 grain/dscf, and as stated above, a bag h ouse likely could not function properl y because of the high moisture content of the emissions associated with a wet corn milling drying operation process. However, if a bag house were applied this would only

provide an additional 50% control, reducing th e controlled potential to emit from 3 ton/year to 1.5 ton/year and equating to a cost of over $200,000/ton of PM 10 removed. The hy pothetical control scenario of implementing a bag house

—the most stringent technology available

— for National Starch’s wet corn milling drying operation would result in an insignificant reduction in overall PM 10 emissions. Table 1 below shows EPA’s 2008 National Emissions Inventory

data for PM 10 emissions in Missouri for 17 source sectors. As can be seen, 2008 PM 10 primary

e missions in Missouri totaled 882,813.58 tons (actual emissions). The difference of 1.5 tons of controlled potential emissions from a single source equates to less than 0.0002% of the statewide actual PM 10 emissions from 2008, which would be expected to re sult in a negligible impact to overall air quality in the state. Table 1. 2008 PM10 Emissions for the State of Missouri from the National Emissions Inventory
**State Source Sector**  **Pollutant Code DESCRIPTION**  **2008 Emissions (Tons)** 
MO Fuel Comb. Elec. Util. PM10

- PRI PM10 Primary (Filt + Cond) 10 , 124.7 MO Fuel Comb. Industrial PM10

- PRI PM10 Primary (Filt + Cond) 792.54 MO Fuel Comb. Other PM10

- PRI PM10 Primary (Filt + Cond) 6 ,367.80 MO Chemical and Allied Product Mfg. PM10

- PRI PM10 Primary (Filt + Cond) 437.12 MO Metals Processing PM10

- PRI PM10 Primary (Filt + Cond) 889.57 MO Petroleum and Related Industries PM10

- PRI PM10 Primary (Filt + Cond) 45.8 3 MO Other Industrial Processes PM10

- PRI PM10 Primary (Filt + Cond) 14 , 777.45 MO Solvent Utilization PM10

- PRI PM10 Primary (Filt + Cond) 120.0 3 MO Storage and Transport PM10

- PRI PM10 Primary (Filt + Cond) 1 ,774.12 MO Waste Disposal and Recycling PM10

- PRI PM10 Primary (Filt + Cond) 5 , 093.22 MO Highway Vehicles PM10

- PRI PM10 Primary (Filt + Cond) 9 , 808.44MO Off

- Highway PM10

- PRI PM10 Primary (Filt + Cond) 6 , 404.7 8

MO Miscellaneous PM10

- PRI PM10 Primary (Filt + Cond) 806 , 178 .0 MO Total Emissions PM10

- PRI PM10 Primary (Filt + Cond) 862,813.58