APR 1 1 2019 Mr. Russ Hurt Director of Manufacturing Outdoor Products LLC 1705 Gulf Street Lamar, MO 64759

Michael L. Parson, Governor

RE: New Source Review Permit - Project Number: 2018-12-011

Dear Mr. Hurt:

Carol S. Comer, Director

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

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621.250 and 643.075.6 RSMo. To appeal, you must file a petition with the administrative hearing commission within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, www.oa.mo.gov/ahc. If you have questions regarding this permit, contact Chia-Wei Young, at the Department of Natural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102 or at (573) 751-4817.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

~:)f12ir)~ su';;n Heckenkam~ New Source Review Unit Chief

SH:cyj

Enclosures

c: Southwest Regional Office PAMS File: 2018-12-011

Permit Number: 0 6 ,!~ 0 4 2 0 1. 9 = 0 Vog~ Recyded paper

STATE OF MISSOURI

1°11 l~ @! DEPARTMENT OF NATURAL RESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT Under the authority of RS Mo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein.

Permit Number: 0 4 2 0 l 9 = 0 0 6 Project Number: 2018-12-011 Installation Number: 011-0042

Parent Company: Redneck Outdoor Products LLC

Parent Company Address: 1705 Gulf Street, Lamar, MO 64759

Installation Name:

Installation Address:

Location Information:

Redneck Outdoor Products LLC

1705 Gulf Street, Lamar, MO 64759

Barton County, S25, T32N, R31W

Application for Authority to Construct was made for:

Increasing the daily styrene emissions limits at an existing deer blinds manufacturing installation. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.

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

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

APR 1 1 2019 Effective Date

STANDARD CONDITIONS:

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

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

You must notify the Department's Air Pollution Control Program of the anticipated date of start up of these air contaminant sources. The information must be made available within 30 days of actual startup. Also, you must notify the Department of Natural Resources' regional office responsible for the area within which you are located within 15 days after the actual start up of these air contaminant sources.

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

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

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

The Air Pollution Control Program invites your questions regarding this air pollution permit. Please contact the Construction Permit Unit at (573) 751-4817. If you prefer to write, please address your correspondence to the Missouri Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176, attention: Construction Permit Unit.

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Project No. 2018-12-011

Permit No. 0 4 2 0 1 9 - 0 0 6

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

The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643.075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10 CSR 10-6. 060 paragraph (3)(E). "Conditions required by permitting authority."

1. Superseding Condition The conditions of this permit supersede all special conditions found in the previously issued construction permits No. 032011-004, 062011-012, 062011-012A, 052012-011, 022014-001, 022015-003, 012016-001, 072016-003, 082017-008, 082017-008A, and 012019-003 issued by the Air Pollution Control Program.

2. Styrene Emissions Limits A. Redneck Outdoor Products LLC shall not emit styrene in amounts greater

than those listed in Table 1 below.

Resin (Chop Gun) A lication

18.45

B. Attachment A, or equivalent forms, such as electronic forms, shall be used to demonstrate compliance with Special Condition 2.A. The equivalent forms shall contain the same information and use the same calculation method as Attachment A.

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Project No. 2018-12-011

Permit No. 0 4 2 0 1 9 = 0 0 6

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

3. Methyl Methacrylate (MMA) Emission Limits A. Redneck Outdoor Products LLC shall emit less than 10.0 tons per year of

MMA in any consecutive 12-Month period from the installation.

B. Attachment B, or equivalent forms, such as electronic forms, shall be used to demonstrate compliance with Special Condition 3.A. The equivalent forms shall contain the same information and use the same calculation methods as Attachment B.

4. Control Measures A. During gel coat and resin spraying operations, Redneck Outdoor Products

LLC shall use the controlled spray procedure as outlined in the Composites Fabricators Association's (CFA's) "Controlled Spray Handbook."

B. Redneck Outdoor Products LLC shall ensure that the mold containment flanges are in place during spraying operations in accordance with the CFA's "Controlled Spray Handbook."

C. Redneck Outdoor Products LLC shall keep records that verify the following, in accordance with the CFA's "Controlled Spray Handbook." 1.) The spray gun pressure has been calibrated, at a minimum, once

every 3 months. 2.) The operators have been trained in the techniques of controlled

spraying.

5. Operating Time Restrictions Redneck Outdoor Products LLC shall only operate each site in accordance with the following hours:

At 12th Street Location: 6:00 am to 5:00 pm At 1st Lane Location: 7:00 am to 11 :00 pm At Gulf Street Location: 6:00 am to 6:00 pm

6. Facility Design Requirements Before making significant alterations to the facility design, Redneck Outdoor Products LLC shall submit, to the Air Pollution Control Program, an updated Ambient Air Quality Impact Analysis (AAQIA) that shows continued compliance with the styrene RAL. If the facility cannot show continued compliance with the styrene RAL using the new design, it shall contact the Air Pollution Control Program for further instructions.

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Project No. 2018-12-011

Permit No. 0 4 2 0 1 9 - 0 0 6

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

7. Operational Requirement Redneck Outdoor Products LLC shall keep all chemicals, including the gel coats, resins, catalysts, coatings, and adhesives, in sealed containers whenever the materials are not in use. Redneck Outdoor Products LLC shall provide and maintain suitable, easily read, permanent marking on the containers.

8. Use of Alternative Material and Coatings or Production of Different Deer Blinds A When considering using an alternative gel coat, resin, adhesive, or

manufacturing a different type of deer blind than those listed in the Application for Authority to Construct, Redneck Outdoor Products LLC shall calculate the potential emissions of all HAPs (except styrene and MMA) and all VOCs. If the potential emissions of the voe are equal to or greater than 250.0 tons per year and individual HAP (except styrene and MMA) are greater than their respective SMAL, Redneck Outdoor Products LLC shall seek approval from the Air Pollution Control Program before implementing their use. A list of the SMAL can be found on the website https://dnr. mo.gov/env/apcp/permits/docs/HAPs_ Table _Rev_ 14updated.p df.

B. Attachment C, or equivalent forms, such as electronic forms, approved by the Air Pollution Control Program shall be used to show compliance with Special Condition 8.A.

9. Record Keeping and Reporting Requirements A Redneck Outdoor Products LLC shall maintain all records required by this

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

B. Redneck Outdoor Products LLC shall report to the Air Pollution Control Program's Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than 10 days after the end of the month during which any record required by this permit show an exceedance of a limitation imposed by this permit.

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

Project Number: 2018-12-011 Installation ID Number: 011-0042

Permit Number: 0 4 2 0 1 9 = 0 O 6

Installation Address: Parent Company: Redneck Outdoor Products LLC 1705 Gulf Street

Redneck Outdoor Products LLC 1705 Gulf Street

Lamar, MO 64 759 Lamar, MO 64 759

Barton County, S25, T32N, R31W

REVIEW SUMMARY

• Redneck Outdoor Products LLC has applied for authority to increase the daily emissions limits for styrene at the 12th street location.

• The application was deemed complete on January 18, 2019.

• HAP emissions are expected from the affected equipment. HAPs of concern from this process are styrene and methyl methacrylate (MMA)

• None of the NSPS apply to the installation.

• None of the NESHAPs apply to this installation.

• 40 CFR 63, Subpart WWWW, National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production, of the MACT regulations applies to this installation.

• This review was conducted in accordance with Section (6) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of HAPs are greater than the de minimis/major source level. However, Section (9) permit is not required because the facility is subject to MACT, Subpart WWWW. Emissions of VOC from this project are greater than the de minimis level. Therefore, this permit is issued under Section (6). Emissions of all other criteria pollutants are less than their de minimis levels.

• This installation is located in Barton County, an attainment area for all criteria pollutants.

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

• Ambient air quality modeling was performed to determine the ambient impact of styrene. Ambient air quality modeling was not performed on VOC because no model is readily available which can accurately predict ambient ozone concentrations caused by the VOC emissions. MMA emissions were limited to less than the SMAL of 10.0 tons per year to avoid modeling.

• Emissions testing is not required for the equipment.

• A modification to the facility's Part 70 Operating Permit application is required within one (1) year after permit issuance.

• Approval of this permit is recommended with special conditions.

INSTALLATION DESCRIPTION

Redneck Outdoor Products LLC owns and operates a deer blind production facility in Lamar, MO. Gelcoats are applied to a number of open molds. After a short curing period, fiberglass reinforced resins are applied using a chopper gun system before additional hand-lay resin application and curing. The parts are then sanded and prepped before being assembled into units. Screws and rivets will be used to temporarily hold the pieces together before the seams are bonded together with chopped strand mat. After curing, the blinds are rolled to the next station where the shelves are installed with screws and filled with a seam sealer. The blinds will then be painted with a water-based paint. Catalysts will be used with the resins.

The facility is composed of four separate locations in Lamar, MO: 153 SE 1st Lane, 1701 Maple Street, 1705 Gulf Street, and 1101 East 12th Street. The four (4) locations are considered part of the same installation for permitting purposes and are identified by a single plant ID, 011-0042. The Maple Street location is being used as a warehouse and does not contain any production equipment. The 1st Lane location consists of the gelcoat (EU 1) and chop gun (EU2) operations. The 12th Street location consists of the gelcoat (EU 1) and hand lay/open seaming (EU3) operations. The Gulf Street location consists of the hand lay/open seaming (EU3) operation, the paint application to the blinds (EU4), and the foam application to blinds (EU10).

This facility is considered a major source of HAP and minor source for criteria pollutants. The facility is a Part 70 source for operating permits. The following New Source Review permits have been issued to Redneck Outdoor Products LLC from the Air Pollution Control Program.

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T bl 2 P a e erm1 IS Ory ·t H" t Permit Number Description

032011-004 New deer blinds production facility 062011-012 RelocatinQ deer blind production facility to new location

062011-012A EliminatinQ weekly production limit 052012-011 Increase deer blind production limit 022014-001 Elimination of HAP limits 022015-003 Installation of a new manufacturinQ line 012016-001 Change the amount of gel coat, resins, and adhesives. Adding

a painting operation. Relocate equipment. 072016-003 Increase in gelcoat, resin, and adhesive usage 082017-008 Changing daily styrene limits 102017-005 Usage of new foam resin to replace existing coating

082017 -008A Changing daily styrene emission limits and installation of a new qel coat spray booth.

012019-003 Installation of a new closed mold system and changing daily styrene emission limits.

PROJECT DESCRIPTION

Redneck Outdoor Products LLC proposes changes to the daily styrene emission limits in Permit No. 012019-003. At the 12th street location, styrene emissions from the gel coat application (EU1) will be increased from 42.31 to 80 lb/day, and the styrene emissions from the open resin application (EU3) will be increased from 82.78 to 110 lb/day. The styrene emissions limit from the closed mold resin process (EU9) at the 12th

street location will be eliminated as the facility have decided to not install this process.

At the 1st Lane location, styrene emission limits from the gel coat application (EU1) will be increased from 50.77 to 60 lb/day. At the Gulf Street location, styrene emissions from the open resin process (EU3) will be decreased from 63.09 lb/day to 30 lb/day. Styrene emissions from the chop gun application (EU2) and open resin (EU3) at first lane, and adhesive application (EU6) at Gulf Street will remain unchanged.

The installation will also be changing its operating hours, which would not affect their daily styrene emissions limit but will facilitate new styrene modeling. Instead of operating between the hours of 7:00 am to 12:00 am at all three sites, as permitted in Permit No. 012019-003, the installation will operate under the following hours instead.

At the 12th Street location: 6:00 am to 5:00 pm. At the 1st Lane location: 7:00 am to 11 :00 pm. At the Gulf Street location: 6:00 am to 6:00 pm.

The installation originally submitted the request to add a new location at 1706 Gulf Street in Lamar, MO. However, this application was amended to change the daily styrene emissions limits at the other locations instead.

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EMISSIONS/CONTROLS EVALUATION

For this project, there will be emissions increase from the change in the styrene emissions limit. Normally, emissions increase will be calculated using potential emissions minus the baseline actual emissions. However, finding representative baseline actual emissions is difficult because the facility operates multiple sites and these sites have undergone significant changes within the last few years. Therefore, the emissions from the project are taken to be the potential emissions.

Styrene and MMA emissions from the gelcoat and resin application process were calculated using emission factors from the "Unified Emission Factors for Open Molding of Composites" developed by the National Marine Manufacturer's Association (NMMA) and Composite Fabricators Association (CFA) and published in 1999 in the paper "Technical Discussion of the Unified Emission for Open Molding of Composites." Other VOC and volatile HAPs emissions were calculated using information from the safety data sheets (SOS) and mass balances assuming 100% emitted. The open resin process (EU3) does use resins that contain cobalt, which is a HAP. However, cobalt is considered a particulate and the resins will be applied by a roller. Therefore, the cobalt in the resins is not expected to be emitted into the air.

The following table provides an emissions summary for this project. Existing potential emissions were taken from Permit 012019-003 and includes the closed molding process at the 12th Street location that will no longer be installed. Existing actual emissions were taken from the installation's 2017 EIQ. Potential emissions of the application represent the potential of the gelcoat, resin, and adhesives application taking into account hours of day restrictions. New installation potential emissions include the gelcoat, resin, closed mold and adhesives application as well as the paint booth and combustion emissions. MMA emissions calculated for this project is greater than the SMAL of 10.0 tpy, so in order to avoid HAP modeling, the MMA emissions are limited to 10.0 tp from the entire installation.

T able 3: Emissions Summary (tons per year)

Regulatory Existing Existing Potential New Actual Emissions Installation Pollutant De Minimis Potential

Emissions· ofthe Potential Levels Emissions

(2017 EIQ) Application Emissions

PM 25.0 17.25 N/D NIA 17.25

PM10 15.0 15.30 N/D NIA 15.30

PM2.s 10.0 7.99 N/D NIA 7.99

SOx 40.0 0.000016 N/D NIA 0.000016

NOx 40.0 0.25 N/D NIA 0.25

voe 40.0 153.62 31.79 74.25 135.65

co 100.0 0.14 N/D NIA 0.14

GHG (CO2e) 100,000 243.96 N/D NIA 243.96

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GHG (mass) 250.0 238.77 N/O NIA 238.77

Styrene 11.0/10.0 70.00 N/O 64.83 64.83

MMA 10.0 8.77 N/O 10.15 <10.0 2Total HAPs 10.0/25.0 79.60 N/O 75.01 75.01

N/A = Not Applicable; N/0 = Not Determined Note 1: For Styrene, 1.0 tpy is the SMAL while the 10. 0 tpy is the de minim is level. Note 2: Includes other HAPs than styrene and MMA. The potential emissions of these HAPs are less than their respective SMAL.

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of VOC are greater than the de minimis level.

APPLICABLE REQUIREMENTS

Redneck Outdoor Products LLC shall comply with the following applicable requirements. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. Compliance with these emission standards, based on information submitted in the application, has been verified at the time this application was approved.

GENERAL REQUIREMENTS

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

o Per 10 CSR 10-6.110(4)(8)2.8(11) and (4)(8)2.C(II) a full EIQ is required for the first full calendar year the equipment (or modifications) approved by this permit are in operation.

• Operating Permits, 10 CSR 10-6.065

• Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin, 10 CSR 10-6.170

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

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

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SPECIFIC REQUIREMENTS

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

• MACT Regulations, 10 CSR 10-6.075 o National Emission Standards for Hazardous Air Pollutants: Reinforced

Plastic Composites Production, 40 CFR Part 63, Subpart WWWW

AMBIENT AIR QUALITY IMPACT ANALYSIS

Ambient air quality modeling was performed to determine the ambient impact of styrene. Results show that the facility will be in compliance with the RAL for styrene. Table 4 below gives the highest ambient impact. More information regarding the modeling analysis can be found in the memo "Ambient Air Quality Impact Analysis (AAQIA) for Outdoor Products, LLC" from the Modeling Unit.

Note 1: Highest modeled in the past five years.

Results 1 Modeled Impact

/m3 1635.18 325.28

STAFF RECOMMENDATION

Time Period

24-Hours Annual

On the basis of this review conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6. 060, Construction Permits Required, it is recommended that this permit be granted with special conditions.

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

• The Application for Authority to Construct form, dated December 3, 2018, received December 7, 2018, designating Redneck Outdoor Products as the owner and operator of the installation.

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Attachment A - Styrene Emissions Compliance Worksheet

Redneck Outdoor Products LLC Barton County (S30, T32N, R30W) Project Number: 2018-12-011 Installation ID Number: 011-0042 Permit Number: 0 4 2 0 1 9 = Q O 6 Date:

Gelcoat Application (EU1)

Resin (Chop Gun) Application (EU2)

Open Resin (EU3)

Gelcoat Application (EU1)

Open Resin (EU3)

Open Resin (EU3)

Adhesive Application (EU6)

153 SE 1st Lane Location

1101 12th Street Location

1705 Gulf Street Location

60.00

18.45

56.78

80.00

110.00

30.00

35.78

(a) Emission factors, in lb/ton, for the Gelcoat Application, Resin (Chop Gun) Application, and Open Resin (including resin, styrene monomer, and patchaid) should be taken from the Table "Unified Emission Factors for Open Molding of Composites." Emission factors(% Content) for the adhesive application shall be taken from the Safety Data Sheets (SDS) of the resins. If a range is given, the highest number shall be used. Emission factor(% Content) for the closed mold resin shall be taken from the SDS of the resins.

(b) Emissions (lb/day) for the Gelcoat Application, Resin (Chop Gun) Application, and Open Resin (including resin, styrene monomer, and patchaid) calculated from [Column 2-c- 2,000 lb/ton] x Column 3 Emissions from adhesive application (lb/day) calculated by using Column 2 x Column 3 Emissions from closed molding (lb/day) calculated by using Column 2 x Column 3 x 0.03. The 0.03 is the 3% styrene lost during the closed molding process. The value is taken from AP-42, Chapter 4.4, Polyester Resin Plastic Products Fabrication.

Daily emissions no more than the values given in Column 5 (Special Condition 2.A.) indicate compliance.

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Attachment B - MMA Emissions Compliance Worksheet

Redneck Outdoor Products LLC Barton County (S30, T32N, R30W) Project Number: 2018-12-011 Installation ID Number: 011-0042

Permit Number: 0 4 2 0 1 9 = 0 0 6 For the Month of ______ _ Co this sheet as needed.

Gelcoat Application (EU 1)

Resin (Chop Gun) Application (EU2)

Open Resin (EU3)

Gelcoat Application (EU 1)

Open Resin (EU3)

Open Resin (EU3)

Adhesive Application (EU6)

153 SE 1st Lane Location

1101 East 12th Street Location

1705 Gulf Street Location

Total MMA Emissions of the Current Month (tons) = Total MMA Emissions of the Previous Eleven (11) Months (tons) =

Total MMA Emissions of the Current 12-Month Period (tons) =

(a) Emission factors, in lb/ton, for the Gelcoat Application, Resin (Chop Gun) Application, and Open Resins should be taken from the Table "Unified Emission Factors for Open Molding of Composites."

(b) Monthly Emissions (lb/ton) for the Gelcoat Application, Resin (Chop Gun) Application, and Open Resins calculated from [Column 2+ 2,000 lb/ton] x Column 3. Emissions from Adhesive Application (lb/day) calculated by using Column 2 x Column 3.

(c) Total MMA Emissions of the Current Month (tons) are the sum of the Monthly Emissions (lb/Month) from each emission source divided by 2000 lb/ton.

(d) Total MMA Emissions of the Previous Eleven (11) Months (tons) taken from the Attachment B of the previous eleven (11) months.

(e) Total MMA Emissions of the Current 12-Month Period (tons) calculated by summing the Total MMA Emissions of the Current Month (tons) and the Total MMA Emissions of the Previous Eleven (I 1) Months (tons).

A 12-month rolling total less than 10.0 tons per year indicates compliance.

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Attachment C - Individual HAP and VOC Emissions Calculations from Alternative Material (Other than Styrene and MMA)

Redneck Outdoor Products LLC Barton County (S30, T32N, R30W) Project Number: 2018-12-011 Installation ID Number: 011-0042

Permit Number Q 4 2 0 1 9 - 0 0 6 Individual HAP

(a) Individual HAP PTE (tpy) calculated using (Column 2) x (Column 3) x [(Column 5)+100] x 8760 hours/yr+ 2,000 lb/ton (b) SMAL can be found on-line at https://dnr.mo.gov/env/apcp/permits/docs/HAPs Table Rev 14updated.pdf (c) .

voe

(a) VOC (tpy) calculated using (Column 2) x (Column 3) x [(Column 4) + 100] x 8760 hours/yr+ 2,000 lb/ton. If the material contains styrene or MMA, the styrene and MMA emissions should be calculated using Attachment B and added to the VOC emissions (tpy) from Attachment C.

Redneck Outdoor Products LLC may use the new alternative material if the individual HAP emissions do not exceed their respective SMAL and voe emissions from the entire installation are less than 250.0 tons per year. A copy of the SMAL values can be found on-line at https://dnr.mo.gov/env/apcp/permits/docs/HAPs Table Rev 14updated.pdf or by contacting the Missouri Air Pollution Control Program

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APPENDIX A Abbreviations and Acronyms

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

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

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

BACT ...... Best Available Control Technology

BMPs .. .... Best Management Practices

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

CAM ....... Compliance Assurance Monitoring

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

CEMS ..... Continuous Emission Monitor System

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

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

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

C02e ....... carbon dioxide equivalent

COMS ..... Continuous Opacity Monitoring System

CSR ........ Code of State Regulations dscf ........ dry standard cubic feet ·

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

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

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

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

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

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

GACT ..... Generally Available Control Technology

GHG ....... Greenhouse Gas

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

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

GWP ....... Global Warming Potential

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

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

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

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

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

MACT ..... Maximum Achievable Control Technology

µg/m3 ...... micrograms per cubic meter

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

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

MW ......... megawatt

MHDR. .... maximum hourly design rate

MMBtu ... Million British thermal units

MMCF .. ... million cubic feet

MSDS ..... Material Safety Data Sheet

NAAQS .. National Ambient Air Quality Standards

NESHAPs National Emissions Standards for Hazardous Air Pollutants

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

NSPS ...... New Source Performance Standards

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

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

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

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

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

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

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

RACT ..... Reasonable Available Control Technology

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

sec ........ Source Classification Code

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

SOS ........ Safety Data Sheet

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

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

SMAL ..... Screening Model Action Levels

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

502 ......... sulfur dioxide

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

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

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

voe ........ Volatile Organic Compound

DATE:

TO:

THROUGH:

FROM:

SUBJECT:

Facility ID:

PROJECT:

I. Introduction

MEMORANDUM

March 12, 2019

Chia-Wei Young, Environmental Engineer I11 New Source Review Permit Section

\

Kendall Hale, Section Chief ~"\,,1 Permit Section

Kelly Robson, Environmental Scientist (..,¢:_. Modeling Unit Permit Section

ES Carol S. Comer, Director

Ambient Air Quality Impact Analysis (AAQlA) for Redneck Outdoor Products, LLC

011-0042

2018-12-01 I

On December 7, 2018 the Department of Natural Resources' Air Pollution Control Program received a request from Redneck Outdoor Products, LLC to modify their permit. Redneck Outdoor Products, LLC requested to increase the emission rates at the ] 21h Street site as well as reduce the hours of operation the plant is processing.

During the course of the review of this modification Redneck Outdoor Products, LLC sent in a second request in February. The February submittal requested another change to the styrene emission rates at each of the three facilities as well as changes in the hours of operations.

The following paragraphs describe the scope of the proposed project and the methodology used throughout the modeling study to show attainment of the appropriate standards. The final AAQIA and all supporting documentation can be found within the modeling files maintained by staff.

0 Ret:yde-d pa.per

2

II. Facility Description/ Project History Redneck Outdoor Products, LLC is an existing facility in Lamar, Missouri that manufactures modular hunting blinds. The Outdoor Products process consists of gelcoats being applied to a variety of open molds using the gelcoat guns (EUl). After a short curing period, fiberglass reinforced resin is applied using a chop gun (EU2). After additional curing, the parts are sanded and prepped before being assembled into units. The seams are bonded together with chopped strand mats, and then shelves are installed with screws and filled with a seam sealer. This assembly process consists of two emission releases of styrene: EU3 open seaming, and EU6 bonding putty. Once assembly is finished the blinds are then painted with a water-based paint.

Redneck Outdoor Products, LLC has experienced substantial growth in the last several years. Due to this f:,>rowth Redneck Outdoor Products, LLC has requested several changes to their construction permit as well as move locations to be able to keep up with the demand. Below outlines their project history:

• 20 I 0-05-078 received a permit for the installation of a new deer blind production line within the same building as Fast Eddies Hot Rod Shop at the comer of Francis and I 2th Street within the town of Lamar, Missouri.

• 2011-06-027 -- the 12th Street site was quickly outgrown so the company moved the deer blind Outdoor Products line to a new site on the outside of town on 1st Lane Road.

• 2012-01-042 - the company requested to amend their permit to double the amount of blinds produced by adding a second shift.

• 2013-05-017 - the company requested to expand again to a second location within town at 1705 Gulf Street. While the gelcoating process (EU I) and spraying of fiberglass (EU2) stayed at the pt Lane site the seaming process (EU3) was moved to the Gulf Street site. This project did not change the amount of emissions being emitted but was modeled since the emission release had been moved from what was modeled previously.

• 2013-09-020- requested to modify their permit to remove the annual IO tons per year Hazardous Air Pollutant (HAP) limit on styrene and 25 tons per year limit on combined HAPs within their permit. The installation was still limited to 24 blinds per day and could only operate between the hours of 7 a.m. to midnight.

• 2014-10-059 the company requested to expand again back to the original I 2th Street Building. Redneck Outdoor Products, LLC will be operating within the entire building; Fast Eddies Hot Rod Shop is no longer in operation there.

• 2015-07-055 - the company requested to expand once again to a new fourth location on Maple Street, thus changing what was occurring at the other three locations. With all four sites the operations will occur as listed below between the different buildings. The getcoat (EU 1) and the chop gun (EU2) will still occur at the 1'1 Lane site along with some of the open seaming process (EU3). The gelcoat (EU I) and open seaming process (EU3) will also occur at the 12th Street site. At the new Maple Street site some open seaming (EU3) will occur along with some of the bonding putty process (EU6). Lastly, the Gulf Street site will hold the open flooring resin process (EU3) as well as some of the bonding putty process (EU6).

• 2016-02-048 - a request was sent to increase the hour of day limits to 6 a.m. to midnight for the 12th Street, I st Lane and Maple Street sites, as well as remove the 24 blinds per day limit that was a previous special condition so that they could produce more per day.

• 2017-01-0 I 8 originally requested to change the emission rates for EU2 and EU3 at just the 1'1

Lane site. Because of the missing receptor issue the company needed to change the emission rates to show compliance. They ended up taking a 12 hour operational limit at all remaining sites. They can only operate between the hours of 6 a.m. in the morning to 6 p.m. in the evening. The company also stated that they do not plan to move forward with installing production equipment at the Maple Street site and will keep it only as a warehouse. Therefore it was

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removed from the modeling. Lastly, during the permitting process Redneck Outdoor Products, LLC requested to add an additional coating to their process that would result in higher styrene emissions. The company resubmitted new emission rates and kept the 12 hours a day limit to show continued compliance with the Risk Assessment Levels (RAL).

• 2018-02-025 - requested to change their styrene limit at all three sites, as well as add a new coating to the 1'1 Lane site. Changes were also made to the gel coat stack (EU l) at the 12 th street site.

• 2018-07-053 -- the addition of closed mold system (EU9) and a tank at the 12th Street site. As well as a request to amend their daily styrene limit due to a change in resin for both the chop gun and open resin process, and change the hours of operation from 12 hours to 17 hours a day between the hours of 7 a.m. and midnight.

• 2018-12-011 changes to the emission rates at al.I three plants as well as changes in the hours of operations. The company has stated that it is no longer planning on operating the closed mold system (EU9) at the 12 th Street site. The hours of operation at each site are as follows;

o 12 th Street - 6 a.m. to 5 p.m. o I" Lane - 7 a.m. to I I p.m. o Gulf Street - 6 a.m. to 6 p.m.

III. Model Selection

The modeling procedures utilized in this study follow current air quality modeling guidelines. The AERMOD modeling system, Version 162 I 6r, was used to evaluate the 24-hour and annual impacts that will result from the release of styrene emissions at Redneck Outdoor Products, LLC.

The AERMOD system was developed through a collaborative effort between the American Meteorological Society and the United States Environmental Protection Agency. AERMOD is a steady-state plume model that employs Gaussian and bi-Gaussian probability density functions to characterize the structure of the planetary boundary layer. AERMOD can predict the concentration distribution of pollutants from surface and elevated releases located within simple or complex terrain. The model allows for the input of multiple sources, terrain elevations, structure effects, various grid receptors, wet and dry depletion calculations, urban or rural terrain, and averaging periods ranging from one hour to one year.

IV. Source Data

Styrene emissions will be emitted in significant amounts from the gelcoat and chop guns as well as the open seaming, open flooring resin, and bonding process. Because emission releases vary in nature, they can be classified as point, area, open-pit, or volume sources, in the AERMOD dispersion model. The following paragraphs describe the emission classifications used in the AAQJA for Redneck Outdoor Products, LLC.

Poillt Source Emissions The document entitled "Users Guide for the AMS/EPA Regulatory Model-AERMOD" states that the point source algorithm should be used to model emission releases from stacks and isolated vents. Table l, entitled ··Redneck Outdoor LL(· - Point Soun.:e Emission Rates and Stack Paramekrs'· outlines the point source emissions and their associated stack parameters based upon information provided by company and the pennit engineer reviewing the project.

Both the gelcoat gun and the chop gun, at the I st Lane Site, are contained each within its own walled off area with horizontal exhaust fans. Due to the horizontal release the restriction of vertical flow was accounted for by reducing the exit velocity of the pollutant stream to 0.001 meters per second in the

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model input file. Unlike the gelcoat and chop guns, the open seaming, open floor resin and bonding putty emissions are released inside a large open area inside the buildings that have multiple openings for escape.

The 12 th street site also has a mixture of source types. The gel coat gun emissions (EUl) vent out ofa stack in the southwest corner of the building. The open seeming (EU3) is contained in a large open room on the west side of the building. Emissions are split and vented out two roof exhaust fans located on that side of the building.

Volume Source Emissions At the 1st Lane site the open seaming emissions were split to vent out overhead door openings on both the east and west sides of the building. The door openings are considered volume sources with the release parameters being equivalent to the size of the openings. All emissions at the Gulf Street site are being released out doorway openings. The resin process (EU3) is spread out along the south wall of the entire building. Emissions from this process were split up to be released out three separate openings; two doorway openings on the south wall and another doorway opening on the east wall of the building. The adhesive resin application process (EU6) is located along the middle of the west wall of the extension. All emissions from this process are vented out a doorway opening on the west wall of the building. As with all the sites, the release parameters at Gulf Street were calculated based upon the size of the openings as given by the company. Table 2, entitled '"Redrn:ck Outdoor Products, LLC - Volume Source !.·mission Rates and Reh:ase Parameters" outlines the volume source emission rates and their associated parameters based upon the final plant design.

Area Source Emissions It was determined that the resin tank would be modeled as an area source due to the fact that emissions could be released from opposite ends of the tank. The company stated that the pump for the tank would be at one end while the release vent would be at the opposite end of the tank from the pumps. Therefore to account for all emission leaks that could occur from the tank an area source was created to match the dimensions of the tank itself. Table 3, entitled ''Redneck Outdoor Products, LLC - Area Sourct.: 1-rnission Rates and Release Pararncters,'' outlines the area source emission rates and their associated parameters as contained in the model input file.

Variable Emisswn Rates/Modeled Emission Limits 1n addition to allowing the user to define sources as point, area, or volume sources, the AERMOD model will also accept variable emission rate factors. For example, the user may want to specify that emissions from a haul road only occur for eight hours during a twenty-four hour period. This can be accomplished using the hour of day statement in the model input file.

Redneck Outdoor Products, LLC has an hour of day limit for all styrene emitting sources within the modeling that allows them to operate each of the sites for a different amount of time. The hours of operation for each site are as follows:

o 12th Street - 6 a.m. to 5 p.m. o !st Lane - 7 a.m. to 11 p.m. o Gulf Street - 6 a.m. to 6 p.m.

Release Locatiom· Redneck Outdoor Products, LLC is located at three locations in the city limits of Lamar, Missouri, in Barton County. All of the source emission releases associated with each facility location are displayed in Figures 1 through 3, entitled ··Rcdm:ck Outdoor Products. LLC l ·1 Lane -Soun.:c Locati\ln,; .. , ''1-tcdntd Uutduur Prod11cts. LLC • · 12th Street Source l ,o~:ations," and '•ffrdrn.:d. Outdoor Products. l l C i iu!f

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Street .. [f significant design changes occur after the issuance of the Section 6 permit, the applicant must provide an updated AAQIA that demonstrates continued compliance with the air quality standards.

V. Receptors

Three Cartesian grids with variable spacing were implemented in order to determine the area of maximum impact from the proposed modification at all three facility locations. Along the property boundary, receptors were placed at SO-meter intervals, while the remainder of the grids consisted of I 00 meter grid spacing. An evaluation of the grids revealed that they were sufficient to determine the extent of Redneck Outdoor Products, LLC's maximum impact. Figure 4, entitled "Redneck Outdoor LLC ·

graphically displays the receptor grid utilized in the AAQIA.

In addition to assigning locations, the receptor options within the AERMOD system allow the user to input information regarding the terrain surrounding the facility. AERMOD is capable of calculating air pollutant concentrations in terrain that can be classified as simple, flat, complex, or mountainous land. 1n order to calculate concentrations in complex or mountainous terrain situations, AERMOD must have information about the surrounding terrain and its features. To aid in the definition of the terrain features, EPA developed a pre-processor, AERMAP, to search terrain data for base elevations and features that may influence the dispersion of pollutants within the modeling domain. Outstanding features are assigned an elevation that is referred to as the hill height scale; a value that must be included in the AERMOD input file.

As recommended by the EPA, the elevations for the receptors within the modeling domain for the Redneck Outdoor Products, LLC facility were obtained using the terrain processor, AERMAP. All of the elevations were based upon data contained in 7 .5-minute topographic maps obtained from the United States Geological Survey. A visual review of the region indicates that the pt Lane site is located in an area predominately comprised of agricultural land while the Gulf Street site, and the 12th Street site are both located within the city which has more commercial or urban land use. Figure 5, entitled "Redm.:ck < Pmducls. LLC Terrain Features" graphically displays the terrain within the region. Overall, elevations range from 279.37 meters to 305.7 meters.

V r. Meteorological Data

Because AERMOD does not accept raw meteorological data, it must be processed through AERMET, the meteorological data pre-processor for the AERMOD modeling system. AERMET extracts and processes meteorological data in order to calculate the boundary layer parameters that are ultimately necessary for the calculation of pollutant concentrations within the atmosphere.

To accurately calculate the boundary layer parameters, the user must input three characteristics that describe the surface surrounding the meteorological site, the surface roughness, albedo and Bowen ratio. Because these surface characteristics can influence the similarity profiles that are utilized by the dispersion model, AERMOD, the user must determine if the surface characteristics at the meteorological site are similar to those at the facility site. A direct comparison between the surface characteristics at the meteorological site and those at the surface site is necessary to determine if the differences that result will significantly impact the overall pollutant concentrations.

In order to provide a consistent method for determining surface characteristics, the EPA developed a mathematical tool, AERSURFACE, to determine surface roughness, Bowen ratio, and albedo values for input into AERMET.

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AERSURF ACE employs land cover data from the United States Geological Survey 1992 National Land Cover data archives. Each of the 21 land use categories contained within the land cover database are linked to a set of seasonal surface characterbiics as defined in Tables A-1, A-2, A-3 and 2-2 of the AERSURF ACE User's Guide. The seasonal categories represent the same categories employed by the AERMOD system for its gas deposition algorithms.

As noted in the AERSURFACE User's Guide, EPA's recommendations for determining surface characteristics in Section 3.1 of the AERMOD Implementation Guide dated, January 9, 2008, have been incorporated into the AERSURF ACE tool. The Department's Air Pollution Control Program agrees with the recommendations and executed AERSURF ACE using the default values described below:

• Bowen ratio o Ten kilometer by ten kilometer domain centered on the site.

• Albedo o Ten kilometer by ten kilometer domain centered on the site.

• Surface roughness length o Default upwind distance of one kilometer centered on the site. o Twelve, 30 degree meteorological sectors.

Other considerations made in the execution of the AERSURF ACE tool include the site type (is the site an airport?), site climatology (arid or not?) and surface moisture (dry, average, wet). Because the surface moisture can vary based upon the meteorological period, AERSURF ACE was executed for each moisture condition. The Bowen ratio characteristics applied in Stage 3 AERMET processing were determined based upon the precipitation totals from the meteorological record for the time period being processed. For example, if the meteorological period reported above average precipitation totals, the Bowen ratio values for wet surface moisture were chosen.

For this project, the surface characteristics surrounding multiple airports across the state were compared to the surface characteristics surrounding the facility site in Lamar, Missouri. Based upon this analysis, the Springfield Regional Airport was most similar to the application site. Table 4, entitled "lkdneek Outdum Products, LLC - Surface Characteristics·· quantifies the land use within the region surrounding the meteorological measurement site and the application site.

The one-kilometer land use surrounding Redneck Outdoor Products, LLC is comprised primarily of commercial and agricultural land, with lesser amounts of wetlands and forested upland land use categories. ln comparison, the Springfield Regional Airport is comprised primarily of cultivated land use with lesser amounts of urban and upland (forested and herbaceous) categories. Though there are differences in the land use characteristics between the airport site and facility site the close proximity of the two locations determined that the Springfield Regional Airport was representative of the conditions at the facility. Figures 6 and 7, entitled "Redneck Outdoor Products, LLC - Meteorological Dmnaim; .. and '·Springlicld National Airport - Meteorological Domains'· graphically display the meteorological domains used in the airport comparison that was conducted by staff of the Department's Air Pollution Control Program.

The meteorological data spanned the period from 2013-2017 and included I-minute ASOS wind data. The I -minute ASOS data was obtained from the National Climatic Data Center in the TD-6405 data format that includes the 2-minute average wind speed and direction for each minute within an hour. The use of the I-minute ASOS data more accurately depicts the average hourly wind flow than the single instantaneous reading of wind speed and direction that is currently used in air quality modeling analyses. There are several advantages to supplementing the TD-3280 data with TD-6405 data.

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One advantage of supplementing the TD-3280 data with TD-6405 data is the increased frequency of measurements resulting in increased potential for non-calm or non-missing data. The instantaneous reading included in the TD-3280 data file represents the 2-minute average wind speed and direction at a specified time, typically ten minutes before the hour. 1 f the measured value is missing or variable, the data for that hour is reported as a calm, or missing. On the other hand, when using TD-6405 as a supplement, the wind speed and direction values are based upon the hourly average of all of the two­minute averages that are collected within that hour at the ASOS station. If the hour has at least two usable non-calm observations during the first half hour or at least one usable non-calm observation in the last half hour, the direction and speed will have a value. Using each minute instead of a specific time, the TD-6405 data increases the likelihood that the hour will have a valid value.

Another advantage of supplementing the TD-3280 data with TD-6405 data is that the wind speed threshold of the anemometer increases. Where the TD-3280 data by itself will report any wind speed below three knots as calm; TD-3280 data supplemented with TD-6405 data, the wind speed threshold is less than or equal to two knots. If the ASOS station is a member of the Ice Free Winds Group, the wind speed threshold is effectively zero.

Lastly, the TD-3280 data file reports wind direction to the nearest ten degrees. In order to obtain a wind direction based upon the nearest degree, the EPA developed a procedure to "randomize" the reported wind direction using a single-digit random number for each hour of the year. In order to obtain a wind direction based upon the nearest degree, the sum of the wind direction and the random number are subtracted by four. The process ofrandomizing the wind direction is not necessary when utilizing the 1-mimutre ASOS data because the wind direction is reported to the nearest degree rather than the nearest ten degrees.

AERMET produced two files for input for each of the five years of meteorological data. The first file contains the boundary layer scaling parameters (surface friction velocity, mixing heights, and Monin­Obukhov length), reference height winds and temperature. The second file contains a vertical profile of winds, temperature, and the standard deviation of the fluctuating components of the wind.

It is also important to note that the vertical profile of winds, temperature, and the standard deviation of the fluctuating components of the wind, in the AERMET output files, is limited to the number of levels for which meteorological parameters are measured. The profile file is intended for applications for which on­site meteorological data has been collected. For applications that use NWS measurements, the information in the profile file is identical to the information contained within the surface file. AERMOD will use all of the data included in the profile file to construct vertical profiles of wind speed, direction, temperature, and turbulence (both sigma-theta and sigma-w). In the absence of profile data (i.e. NWS data only), AERMOD will construct vertical profiles of wind, temperature and turbulence based on similarity theory relationships, using the reference wind and temperature observations as one level of the profile. For multi-level on-site meteorological data, the profiles created by AERMOD are forced to follow the observed values at each measurement height. The "theoretical" profiles based on similarity theory are used lo extrapolate above and below the range of measurements and to interpolate between measurement levels, preserving the shape of the theoretical profiles. The procedure of constructing these vertical profiles in AERMOD has been referred to as the "AERMOD Meteorological Interface", and is described in Sections 4 and 7.10 of the AERMOD formulation document (EPA-454/R-03-004).

VII. Building Dowowash

Building downwash was calculated using the Building Profile Input Program (BPIP) with plume rise model enhancements (PRIME). BPIP PRIME was developed in order to calculate enhanced plume dispersion coefficients due to turbulent wakes and to calculate reduced plume rise caused by the

8

combination of the descent of streamlines on the leeward side of buildings and the increased entrainment within the wake. Additionally, PRIME addresses both the near and far field wake zones produced downwind of a building or group of structures. The use of PRIME in conjunction with AERMOD allows the user to describe building/stack configurations and to calculate concentrations within cavity wake regions.

The information needed to execute BPIP PRIME are the heights and locations of structures, which may contribute to building downwash, and the stack locations in relation to these structures. Based upon the facility configuration, the program will determine if a stack is being subjected to wake effects from a surrounding structure or structures. If structure wake effects are evident, flags are set to indicate which stacks are affected by building wake zones. Once it is determined that a stack is influenced by a structure, BPIP will calculate the building heights and widths to be included in the dispersion model so that building down wash effects can be considered.

In order to determine if the building downwash calculations were applied correctly, the coordinates of each building comer are needed. Figures 8 through I 0, entitled "Redneck Outdoor Prodw:ts. LI .C 1'1

Lane·•• Building Configuration,'' "Redneck Outdoor Products, LLC ···· 12th Street Uuilding. C(1nliguratinn." and "Redneck Outdoor Products. LLC ·· Ciulf Street···· Building Configurat.ion." depicts the proposed building configurations that will exist upon the completion of the project. In addition,

Table 5, entitled ··Redneck Outdoor ProdtKts, LLC - Building Heights" outlines the height of

each building and tier located at the facility. This information was used to calculate the building

downwash parameters for input into the AERMOD system.

It is important to note that the facility design can impact the results obtained during the AAQ1A. As such, any significant design changes that occur after the issuance of the permit must be forwarded to the permit authority. This will ensure that compliance with the air quality standards is maintained.

VII. Good Engineering Practice Stack Height

The Clean Air Act states that a stack should be high enough to ensure that its emissions do not result in excessive ground level pollutant concentrations in the area surrounding the stack due to downwash effects caused by the source itself, nearby structures, or complex terrain. It also states that the stack shall not exceed two and one-half times the height of the obstructing source unless a demonstration can be made that this is necessary. According to 40 CFR 51,l(ii), good engineering practice (GEP) stack height is the greater of 65 meters (measured from base of the stack) or the height of the nearby structure (measured from base of stack) plus 1.5 times the lesser dimension of the nearby structure. If neither of the above approaches are used to determine GEP stack height, a fluid model study can be conducted.

None of the stacks contained within the model input file for Redneck Outdoor Products, LLC exceed 65 meters.

JX. Risk Assessment

The Department's Air Pollution Control Program maintains a list of emission thresholds for HAPs as defined in 10 CSR 6.060, Appendix J. A facility is required to submit an air quality analysis for each pollutant that exceeds these thresholds (screen model action levels). Initial estimates provided by the pennit engineer indicate that the proposed project will result in an increase of styrene in excess of the screen model action levels.

9

Under the Departments' Air Pollution Control Program guidelines, a facility must submit an air quality analysis for all emission points within a facility when a refined analysis for a HAP is required. This requirement was introduced to ensure that the applicable RAL are not violated near a facility when an application for a modification is submitted. The facility-wide emissions are modeled because significance levels do not exist for HAPs and the RALs are health based thresholds similar to the NAAQS. Unlike the NAAQS evaluation, however, background concentrations are not included in the assessment of risk. Currently, background concentrations are virtually unknown for most HAPs, thereby, making a background assessment impossible.

Table 6, entitled .. Redneck Outdoor Prodlll.:ts, LLC RAL Results - Styrene." summarizes the high first high concentrations predicted by the AERMOD dispersion model for styrene. The worst case 24-hour and annual impacts occurred during the 2016 meteorological period, with a maximum concentration of 1877.473 µg/mi and 327.850 µg/m3, respectively. The 24-hour and annual averaging periods are below the RALs of 2,240 µg/m 3 and 333 µg/m 3

, respectively. Because the RALs were not exceeded, further review of this pollutant is unnecessary.

For a visual display of the modeling results refer to Figures 11 and 12, entitled "R~dneck Uu!do1ir Products, LLC' - 24-Hour RAL Results," and '·Redneck Outdoor Products. LLC Annual RA!. Results."

X. Recommendations

The AAQJA submitted in support of the Redneck Outdoor Products, LLC minor source application is complete. The following recommendations should be incorporated into the permit as special conditions. Failure to do so may invalidate the results obtained from the AAQlA.

l. The emission rates contained in Tables I, 2 and 3 should not be exceeded. 2. If significant alterations are made to the facility design as proposed in the permit application, the

applicant will be required to submit an updated air quality analysis in order to ensure continued compliance with the air quality standards.

3. The facilities are only allowed to operate during the following hours: 12th Street Site - 6 a.m. to 5 p.m. 1st Lane Site - 7 a.m. to 11 p.m. Gulf Street Site - 6 a.m. to 6 p.m.

Attachments

c: Kelly Robson, Air Pollution Control Program

So~alD Sourt:e. Deacriptlon

EtJf)f':' tt'.: Getcaai ,, EU3

EU2 Chop Gun

··1211-1Slre;;i11s bm,1eci 10 11 11ours a Qay 1 !i'. Lane Site can ooerate 17 hours a day

Table 2: Redneck Outdoor Product&., LLC Volume Source Emfn.lon Rataa and Release Parametera

Source ID Source. Description Modal 10 Lo-cation Elevation EmJaslon Rate R.elaaae Height lnllia.! urte~I :nltl.a.l Vertie.al

Metera (GramaJSee.J {Lba/Houfl (Matera} {Mt!tera} (Mate:raJ

Table J: Rttdneek Outdoot Product., LLC. Ana Sourc4 EmlHlon R.1.tes and Rek!.aae Parametel"II

Souru O..cr!ption Model ID Location Elevation EmlHlon R.aie Allgl, Initial Vertlcai OllTlillnaion

UTM UTM Ma1$/'1l {Gram«!Seclm ) (L0.1/Hout) (Mod&J lflput] (Mode! Input}

St)'f'tlne Emiuion Rates

1 31E-CM 0001

137E-04 0001

Figure 1 Redneck Outdoor Products, LLC - 1st Lane - Source Locations

Legend

1st Lane Boundary 1st Lane Buildings 1111 1st Lane Sources

Figure 2 Redneck Outdoor Products, LLC - 12th Street - Source Locations

Legend

12th Street Boundary ¾,a,, ,0,,M,0WN

12th Street Building Ill , 2th street sources

Figure 3 Redneck Outdoor Products, LLC - Gulf Street - Source Locations

Legend

Gulf Street Boundary Gulf Street Building 111 Gulf Street sources --

Figure 4 Redneck Outdoor Products, LLC - Receptor Grids

Legend

• Receptor

Figure 5 Redneck Outdoor Products, LLC - Terrain Features

1:~;7• ,' ,.:· ,j

Legend

* 1st_Lane_Facility_Center * Gulf_Street_Facility_Center * 12th_Street_Facility_Center

I Tab!.e4

I Redneck Outdoor Products, LLC • SUrtace Characterlstlctii

I Springfield Nailonal Airport Sutface Characterianca • Mo!at1.1t1 Condltiona

SUr1ace Roughneaa AJbado S0Wt1;n Ratio Dry ~wen RM.ic Avg Bowen~tloWat

Sector ID Wirrter Spring Summer Fall Winter Spring Summer Fau Winter Soring Summer Fall Wlnhl:r Sprint:1 Summer Fall Wlnter Spring Summer Fai!

1 0.01S 0024 0037 0030 0180 0150 D 190 0 190 2 010 1 180 1350 2010 0 790 OAOO 0.500 0780 OA30 0250 0310 0430

' 0.025 0034 0044 0037 0.180 0150 0190 0190 2 010 1160 USO 2.010 0-790 0400 0500 0780 0430 0250 0310 0430

' 0024 0032 0 041 O 035 0180 0150 0190 0190 2 010 1160 1350 2_010 0 790 0400 0500 0 780 0430 0250 0310 0430

4 00:?0 0029 0045 0037 0.180 0.150 0190 01eo 2.010 1160 1350 2010 0790 OAOO 0.500 0780 0.430 0250 0.310 0.430

' 0027 0.040 0.067 oc,;1 0180 0 150 0 190 0 ,so 2.010 1160 1 350 2.010 0 790 0..400 0500 0.780 0430 0250 0310 0430

' 0.020 0.030 0058 oc,;o 0.180 0 150 0190 0.190 2 010 1.160 1.350 2.010 0790 0.400 0,500 0.780 0430 0250 0310 0430

7 0.016 0 021 0079 0071 a,ao 0 150 0190 0 190 2.010 1 ,ea 1350 2.010 0-790 0.400 0500 '""' 0.430 0250 0310 0430

• 0.034 0 050 016" 01'l4 0180 0150 0190 0190 2010 ueo 1350 2.010 0790 0400 0500 0.780 0.430 0250 0.3,0 0 430

• 0.035 0 053 0182 0179 0180 0 150 0 190 0190 2 010 1160 1 350 2010 0.790 0400 0500 0780 0430 0250 0310 0430 ,. 0.044 0067 0 t72 0 184 0180 0 150 0190 0190 2 010 neo I 350 2.010 0.790 0.400 0500 0780 0.430 0250 0310 0430

11 0.018 0028 0003 0 054 0180 0 150 0190 0190 :2:.010 1.160 1 350 2.010 0790 0400 0500 0180 0 430 0250 0310 0430 ,, 00\3 0020 0028 00'2 0.180 0150 0.HID 0.190 2.0-10 1160 1.l50 2.010 0.190 0AOO 0500 -0780 0-430 0250 0310 0430

Average 0024 0038 0062 0 075 0180 0 150 o mo 0190 2.010 1160 1 350 2010 0790 0400 0500 0780 0430 0?50 0310 0430

Redneck: Outdoor Products, LLC Surface Char:aderlstlcs • Moisture Cond1tiona

Sur1ace RoUlll'tnea& Albedo Bowen Ratio Ory Bowen Ral!o Avg Bowen Ratio Wet

Sector ID Wlntu Sprina Summer Fall Winter Spring Summer Fall Winter Spring Summer Fall Winter Soring Summar Fall Wintu Soring Summer Fall 1 0603 0660 0667 0667 0170 0140 0190 0190 I 640 0950 1180 i 640 0.670 0.3-40 0450 0670 0.370 0220 0.200 0370

' 0.39<1 0 466 0484 0475 0"170 0140 0190 0190 1640 0950 '160 1.640 0670 0.340 0450 0670 0370 0220 0280 0370

3 0.369 0442 0464 045<l 0170 01<10 0190 D 190 1.640 0950 1160 1 640 0670 0340 0050 0670 0370 0220 02ao 0370

4 0.210 0262 0371 0365 0170 0.i<lO 0,190 o.,so 1.640 0950 1.160 1.640 0.670 0340 0450 0610 0.370 0220 0'8ll 0370

' 0220 0 263 0398 03i;l7 0170 0140 0 190 0.190 1640 0950 1160 1 540 0670 0340 0450 0670 0370 0220 0280 0370

' 0083 0109 0233 0227 0170 0140 0_190 0190 1640 0950 1160 1$40 0.670 Q340 0450 0~70 0.370 0220 02'!0 0370

7 0074 0102 0217 0207 0170 01'\0 0.190 0190 1640 0950 '160 1640 0670 0340 0450 0670 0370 0220 0280 0370

• 0038 0048 0.085 0.000 0170 0.140 0.190 0190 1.640 0.950 1.160 1.640 0670 0.340 0.450 0670 0.370 0220 0 280 0170

' 0026 0033 0.061 0058 0170 0140 0.190 0190 1640 0950 l.160 1,640 0 670 0.3-10 0450 0870 0370 0220 0280 0370

10 0.050 0071 0217 0213 0170 0,140 0.190 OHIO 1640 0.9S0 1180 1640 0.670 0340 0450 0670 0370 0220 0250 0"370

11 0130 0 171 0 341 0 338 0170 0140 0190 01$0 1640 0950 1160 1640 0670 0.340 o,so 0670 0370 0220 0.280 0370

12 0442 0.500 0.557 0553 0170 0.140 0190 0.190 1640 0950 1160 1.640 0670 0340 0.450 0670 0.370 0220 0.280 0370

_____ A~--- 0.220 0261 0 341 D 336 0170 0140 0.190 OHIO 16'0 0950 1160 1JWO 0670 0.3'40 0<50 0670 0)70 0220 0280 0370

Avurage Dlffenrrlcil I C: '* 0010

Springrield·Branson National Airport Combined 1 KM Surface Characteristics Redneck Outdoor P-cdw:;b - Gulf Street &le 1KM Cun1binel'.l &irfa-::e Charactt:~sbr.5

1%~",, 0% .--2%

13(11.12) Wa{E!r

• (21,22,23) D01-etoped

0(31.3i,3JJ Berren

• (41,42,43) Forested Up\ar,d

a(51) Shrubland

0(61) Nori-Natural Woody

11(71) Herbaceous Upland

0(81, 82 83, 84, 85J Herbaceous

.rs1,:\l'il'wJ11~~1TJ

a(0.99) Erroneous

I t!!il!7'!; Herbecec,.i:1- Upland

i j • {8l.t2.83 84.S5)H~eou:3- 1

1 P-4.:trr\fcOl~l~,-aicd I;

• !&1. !:2) /.'crlo-id,;

1 tl'.0 991Erroieou;; \i

Figure 6 Redneck Outdoor Products, LLC - Meteorological Domains

Legend

1_km_Surtace Roughness Facility_Domain 10_km_Albedo & Bowen Ratio Facility_Domain

Figure 7 Springfield National Airport - Meteorological Domains

Legend

1_km_Surface Roughness Airport_Domain 10_km_Albedo & Bowen Ratio Airport_Domain

Figure 8 Redneck Outdoor Products, LLC - 1st Lane - Building Configuration

Legend

1st Lane Boundary 1st Lane Buildings • 1st Lane Sources

Figure 9 Redneck Outdoor Products, LLC - 12th Street - Building Configuration

Legend

12th Street Boundary ,,,,,,,,,,,,,,,,,, 12th Street B Uilding II 12th Street Sources

Figure 10 Redneck Outdoor Products) LLC - Gulf Street - Building Configuration

Legend

Gulf Street Boundary Gul1 Street Building • Gulf Street Sources

Table 5

Redneck Outdoor Products, LLC • Building Heights

Building I.D. Description Easting Norhting # Tiers Base Elevation # Corners Height

(Meters) (Meters) (Meters) (Meters)

BLDG1 1st Lane Building 385077.773 4148797.871 1 295.35 5 85344

385108.057 4148795.955

385106.509 4148765.008

385075.415 4148767.587

385077.773 4148797.871

BLDG2 12th Street Building 388294.54 4150245 026 1 293.83 11 6 096

388325.969 4150243.768

388324.292 4150192.015

388308.997 4150192.644

388308.578 4150177.349

388292.654 4150177.977

388293.073 4150198092

388289.721 4150198.097

388289.93 4150214.225

388294 121 4150214.016

388294 54 4150245.026

BLDG3 Gulf Street Building 386916.257 4149758.152 1 286.512 5 4 8768

386982.482 4149754 051

386980 638 4149707918

386941.886 4149710.789

386942 296 4149716.735

386914 001 4149718.17

386916257 4149758.152

Table 6

Redneck Outdoor Products, LLC - RAL Results

Styrene

Year Averaging MAX Modeled

Period Concentrations

Risk Level Exceeded?

et X>= 2240 µg/m3

Figure 11 Redneck Outdoor Products, LLC

24-Hour RAL Results

O 2240 µg/m" >X>= 1500 µglm" • 1500 µg/m 3 >X>= 1000 µg!m1

® 1000 µg/m3 >X>= 500 µg/ms ii 500 µglnr >X>= 250 µg/m"

• X>= 33 3 µg/m 3

Figure 12 Redneck Outdoor Products, LLC

Annual RAL Results

Legend

O 333 µg/m3 >X>= 250 µglm3 • 250 µglm3 >X>= 100 µg/ms

e 100 µg/m3 >X>= 50 µg!m3 • 50 µg/m' >X>= 25 µg/mi

Orange Tooling Gelcoat 28.09 41.68% 1st Lane Green Gelcoat 562.64 28.00% 1st Lane TanGe!rnat 35.93 28.00%

1st lane Oran eToollngGelcoat 31.51 4168%

1st Lane Resin Appllcatlon 468.39 30.30%

1st lane Resin Catalyst 14.04 0.00% 12th Street Hand Layup Resin Application 2653.88 30.30% 121h Slreet Hand layup Catalyst 63.04 0.00% 12th Street 5tyreneMonomer 5.28 100.00%

12th Street Patchaid 2.62 5718%

12th Street Tooling Resin 79.56 48.00%

1st Lane Hand Layup Resin A plication 1487.24 30.30%

Hand layup Catalyst 43.17 0.00%

OrangeTooHngGelcoat 1.00% N/A 1st Lane Green Gelcoat

1st Lane TanGelcoat 1st Lane Orange Tooling Gelcoat 1.00% N/A 1st Lane Resin Application

1st Lane Resin Catalyst

12th Street Hand Layup Resin A plication

12th Street Hand Layup Catalyst

12th Street 5tyreneMonomer

12th Street 3 Patchaid 100% N/A 12th Street 3 Tooling Resln

1st Lane 3 Hand LayupResinApplicatlon

Hand Layup Catalyst

Hand la up Resin Applkalion

1st Lane Tan Gelcoat 1st Lane OrangeToo\lngGe!coat

1st Lane ReslnAppHcatlon 1st Lane Resin Catalyst

12th Street Hand Layup Resin A plication

12th Street Hand Layup Catalyst

12th Street Styrene Monomer

12th Street Patcha!d

12th Street ToollngResin 1st Lane Hand layup ResinApp!Jcation

11and layup Catalyst

Hand Layup Resin Application

TanGe!coat 1st Lane Orange Tooling Gelcoat

1st Lane ResinApplicat!on 1st Lane Resin Catalyst

12th Street Hand layup Resin Appllcatlon

12th Street Hand Layup Catalyst

12th Street 5tyreneMonomer

182

351 N/A

182 N/A 182 N/A

351 N/A

78.78 N/A

N/A

76.356 N/A N/A

466.2 N/A

221.27 N/A

180 N/A 76.356 N/A

N/A

0.28091168 0 05126638

0.31509972 a 0575057

0.026159 0 00477402

2018-12-011 Redneck Outdoor Products

Styrene and HAP PTE Cale

4.260

N/A 4.930 0.448

N/A 51.200 3.012

N/A 3.270 0.192

N/A N/A 5.530 0.325

N/A N/A 18.450 1.085

N/A N/A 0.000 0.000

N/A N/A 101.320 5.960

N/A N/A 0.000 0.000

N/A N/A 1230 0.072

N/A N/A 0.289 0.017

N/A N/A 7.160 0.421

N/A N/A 56.780 3.340

N/A N/A 0.000 0.000

25% N/A 351 0.64

25% N/A 10.7925 197

25% N/A 10.7925 1.97

25.000% N/A

500% 75 N/A 1 053418803 a rn2 9.34 5.00% 75 N/A 21 0989011 3851 0110% N/A 0 06189011 0 01129495

0.60 5.00% 75 N/A 1 347527473 02"8 0110% N/A 0 00197637 0 00036069

1.01 5.00% 75 N/A 1181623932 0216

3.37 0130% NIA 000044554 0 00555631

0.00

18.49

0.00

0.22

0.05

1.31

10.36

0.00

20% N/A 2.808 051246

20% N/A 12.608 2 30096

20% N/A 8,634 1 575705

12th Street 3 12th Street 3

1st Lane 3 1st Lane 3

Maote/Gulf 3 Manie/Gulf 3

V:v'i';:f_::<(Yqj,{.$totii •. Titik'J!~;· ,<~S~ ,, ; ,,. ·,, ,,;, 6,016 ~lions

9.18 lb/ira!!on

55226.88 lbs

112 63 lb/blind

270312 lb/dav

986638.8 lb/vr

17.86519173 turnover

0012 tov 24.44 lb/yr

Cobalt Carboxylate (PM, not VOC) 0.03

Ethy!ben2ene(VOC) 0.11

Olmethylan!lllne (VOC/HAP) 0.00 N-meth l-2.pyrrolldone (VOC nol HAP) 0.00

Methylethylketoneperoxide (VOC not HAP) '58 Cyclohe)(anone Peroxide (VOC not HAP) 4 39

Elemental Cobalt 0.03

Cobalt Com ounds 0.03

voe 84.06 Total HAPS 75.01

Patchaid

Tooling Resin

Hand LaywpReslnApplicatlon

Hand LaywpCata!yst

Hand layup Resin Application

Hand LayupCata!yst

0.1

10

0.1

01

2018-12-011 Redneck Outdoor Products

Styrene and HAP PTE Cale

voe

12th Tan G!!.lcoat

12th Orange Tooling Gelcoat

1st Lane Green Ge!coat

1st Lane Tan Gelcoat

1st Lane 1 Orange Tool!ng Gelcoat

1st Lane 2 Resin Application

1st Lane 2 Resin Catalyst

12th Stree 3 Hand Layup Resin Application

12th Stree 3 Hand layup catalyst

12th Stree Styrene Monomer

12th Stree Patchaid

12th Stree T oo!ing Resin

1st Lane Hand Layup Resin Application

1st Lane Hand layup Catalyst

Gulf 3 Hand Layup Resin Application

Gulf Hand Layup Catalyst

12th Stree Closed Molding

12th Stree Closed Molding Catalyst

46,81

28.09

562.64

35,93

31.51

468.39

14.04

2653.88

63.04

5.28

2.62

79.56

1487.24

43.17

785.79

22.81

0.00

0.00

2018-12-011 Redneck Outdoor Products

voe PTE

5.00% 2.34 0.43

7.00% 1.97 0.36

10.00% 56.26 10.27

5.00% 1.80 0.33

7.00% 2.21 0.40

3.00% 14.05 2.56

45.00% 6.32 1.15

3.00% 79.62 14.53

45.00% 28.37 5.18

0.00% 0.00 0.00

2.00% 0.05 0.01

48.00% 38.19 6.97

3.00% 44.62 8,14

45.00% 19.43 3.55

3.00% 23.57 4.30

45.00% 10.26 1.87

0.30% 0.00 0.00

45.00% 0.00 0.00

Total;; 74.25