DEC 3 1 2019

Mr Matt Lydon Director of Regulatory Compliance ProEnergy Services 8303 McHard Road Houston TX 77053

RE New Source Review Permit-Project Number 2019-10-027

Dear Mr Lydon

Enclosed with this letter is your permit to construct Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit Also note the special conditions on the accompanying pages The document entitled Review of Application for Authority to Construct is part of the permit and should be kept with this permit in your files Operation in accordance with these conditions and your new source review permit application 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 ofMissouri

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 (CAV) can be set up with you To request a CAV please contact your local regional office or fill out an online request The regional office contact information can be found at the following website httpdnrmo12ovretdons The online CAV request can be found at httpdnrmorrovcavcornpliancehtm

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 621250 and 6430756 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 Ifany such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed if it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the administrative hearing commission whose contact information is Administrative Hearing Commission United States Post Office Building 131 West High Street Third Floor PO Box 1557 Jefferson City Missouri 65102 phone 573-751-2422 fax 573-751-5018 website VWWoamo govahc

0 Recycled paper

Mr Matt Lydon Page Two

If you have any questions regarding this permit please contact the Air Pollution Control Program at PO Box 176 Jefferson City MO 65102 or at (573) 751-4817 Thank you for your attention to this matter

Sincerely

AIR POLLUTION CONTROL PROGRAM

Susan Heckenkamp New Source Review Unit Chief

SHrsa

Enclosures

c Northeast Regional Office P AMS File 2019-10-027

Permit Number 12 2 01 9 - 0 l 0

~[sectj MISSOURI Ii 11 amp IDEPARTMENT OF ~ tf NATURALRESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT bull

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

Permit Number 12201 9 -0 l 0 Project Number 2019-10-027 Installation Number 159-0063

Parent Company ProEnergy Services

Parent Company Address 2001 ProEnergy Boulevard Sedalia MO 65301

Installation Name ProEnergy Services

Installation Address 2001 ProEnergy Boulevard Building 9 Sedalia MO 65301

Location Information Pettis County (S32 T46N R21W)

Application for Authority to Construct was made for The installation of a combustion turbine test cellstand This review was conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

Dire~ Department of Natural Resources

DEC 3 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 Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit or if construction or modification is suspended for one year or more

You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications

You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)

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

You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC

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

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

Contact Information Missouri Department of Natural Resources

Air Pollution Control Program PO Box 176

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

The regional office information can be found at the following website httpdnrmogovreqions

- 2 -

~[sectj MISSOURI Ii 11 amp IDEPARTMENT OF ~ tf NATURALRESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT bull

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

Permit Number 12201 9 -0 l 0 Project Number 2019-10-027 Installation Number 159-0063

Parent Company ProEnergy Services

Parent Company Address 2001 ProEnergy Boulevard Sedalia MO 65301

Installation Name ProEnergy Services

Installation Address 2001 ProEnergy Boulevard Building 9 Sedalia MO 65301

Location Information Pettis County (S32 T46N R21W)

Application for Authority to Construct was made for The installation of a combustion turbine test cellstand This review was conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

Dire~ Department of Natural Resources

DEC 3 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 Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit or if construction or modification is suspended for one year or more

You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications

You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)

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

You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC

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

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

Contact Information Missouri Department of Natural Resources

Air Pollution Control Program PO Box 176

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

The regional office information can be found at the following website httpdnrmogovreqions

- 2 -

STANDARD CONDITIONS

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

You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications

You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)

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

You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC

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

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

Contact Information Missouri Department of Natural Resources

Air Pollution Control Program PO Box 176

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

The regional office information can be found at the following website httpdnrmogovreqions

- 2 -

Project No 2019-10-027

Permit No 1 2 2 0 1 9 - 0 1 0 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 643075) and by the Missouri Rules listed in Title 10 Division 10 of the Code of State Regulations (specifically 10 CSR 10-6060) For specific details regarding conditions see 10 CSR 10-6060 paragraph (3)(E) Conditions required by permitting authority

ProEnergy Services Pettis County (S32 T46N R21W)

1 Control Device Requirement - NOx Water Injection amp Low-NOx Burners A ProEnergy Services shall control emissions from the combustion turbine

test cellstand using NOx water injection andor low-NOx burners as specified in the permit application

B The control devices shall be operated and maintained in accordance with the manufacturers specifications which shall be kept on site

C ProEnergy Services shall maintain an operating and maintenance log for the control devices which shall include the following 1) Incidents of malfunction with impact on emissions date and

duration of event probable cause corrective actions etc 2) Maintenance activities with inspection schedule repair actions

replacements etc

2 Fuel Requirement - Generator Sets A ProEnergy Services shall burn exclusively ultra-low sulfur diesel fuel with

a sulfur content less than or equal to 15 parts per million in the generator sets (EP-02 amp EP-03)

B ProEnergy Services shall demonstrate compliance with Special Condition 2A by obtaining records of the fuels sulfur content from the vendor for each shipment of fuel received or by testing each shipment of fuel for the sulfur content in accordance with the method described in 10 CSR 10-6 040 Reference Methods

3 Record Keeping and Reporting Requirements ProEnergy Services 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

- 3 -

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

Project Number 2019-10-027 Installation ID Number 159-0063

Permit Number 12 2 O l 9 _ 01 O

Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)

REVIEW SUMMARY

bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand

bull The application was deemed complete on November 12 2019

bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot

bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary

Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand

40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart

bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air

Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart

40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions

bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment

-4-

bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants

bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability

bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules

bull No Operating Permit is required for this installation

bull Approval of this permit is recommended with special conditions

INSTALLATIONPROJECT DESCRIPTION

ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators

Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners

Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine

Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid

- 5 -

EMISSIONSCONTROLS EVALUATION

Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors

Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run

Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates

- 6 -

Table 1 Emissions Summary (tons per year)

PoUutant Regulatory DeMinimis

Levels

Existing Potential

Emissions

Existing Actual

Emissions

Potential Emissions of the middotProject

Conditioned Potential

Emissions of the Project

PM 250 N0 N0 226 NA

PM10 150 N0 ND 226 NA

PM2s 100 N0 ND 226 NIA

SOx 400 N0 ND 014 NA

NOx 400 ND ND 3427 NA

voe 400 ND N0 192 NA

co 1000 ND ND 1439 NA

Total HAPS 250 ND ND 023 NA ND = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

APPLICABLE REQUIREMENTS

ProEnergy Services 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

bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050

bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the

first full calendar year the equipment is in operation

bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170

bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220

bull Restriction of Emission of Odors 1 0 CSR 10-6165

-7-

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation

- 8 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -

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

Project Number 2019-10-027 Installation ID Number 159-0063

Permit Number 12 2 O l 9 _ 01 O

Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)

REVIEW SUMMARY

bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand

bull The application was deemed complete on November 12 2019

bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot

bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary

Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand

40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart

bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air

Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart

40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions

bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment

-4-

bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants

bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability

bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules

bull No Operating Permit is required for this installation

bull Approval of this permit is recommended with special conditions

INSTALLATIONPROJECT DESCRIPTION

ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators

Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners

Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine

Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid

- 5 -

EMISSIONSCONTROLS EVALUATION

Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors

Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run

Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates

- 6 -

Table 1 Emissions Summary (tons per year)

PoUutant Regulatory DeMinimis

Levels

Existing Potential

Emissions

Existing Actual

Emissions

Potential Emissions of the middotProject

Conditioned Potential

Emissions of the Project

PM 250 N0 N0 226 NA

PM10 150 N0 ND 226 NA

PM2s 100 N0 ND 226 NIA

SOx 400 N0 ND 014 NA

NOx 400 ND ND 3427 NA

voe 400 ND N0 192 NA

co 1000 ND ND 1439 NA

Total HAPS 250 ND ND 023 NA ND = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

APPLICABLE REQUIREMENTS

ProEnergy Services 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

bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050

bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the

first full calendar year the equipment is in operation

bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170

bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220

bull Restriction of Emission of Odors 1 0 CSR 10-6165

-7-

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation

- 8 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -

bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants

bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability

bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules

bull No Operating Permit is required for this installation

bull Approval of this permit is recommended with special conditions

INSTALLATIONPROJECT DESCRIPTION

ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators

Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners

Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine

Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid

- 5 -

EMISSIONSCONTROLS EVALUATION

Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors

Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run

Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates

- 6 -

Table 1 Emissions Summary (tons per year)

PoUutant Regulatory DeMinimis

Levels

Existing Potential

Emissions

Existing Actual

Emissions

Potential Emissions of the middotProject

Conditioned Potential

Emissions of the Project

PM 250 N0 N0 226 NA

PM10 150 N0 ND 226 NA

PM2s 100 N0 ND 226 NIA

SOx 400 N0 ND 014 NA

NOx 400 ND ND 3427 NA

voe 400 ND N0 192 NA

co 1000 ND ND 1439 NA

Total HAPS 250 ND ND 023 NA ND = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

APPLICABLE REQUIREMENTS

ProEnergy Services 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

bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050

bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the

first full calendar year the equipment is in operation

bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170

bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220

bull Restriction of Emission of Odors 1 0 CSR 10-6165

-7-

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation

- 8 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -

EMISSIONSCONTROLS EVALUATION

Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors

Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run

Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates

- 6 -

Table 1 Emissions Summary (tons per year)

PoUutant Regulatory DeMinimis

Levels

Existing Potential

Emissions

Existing Actual

Emissions

Potential Emissions of the middotProject

Conditioned Potential

Emissions of the Project

PM 250 N0 N0 226 NA

PM10 150 N0 ND 226 NA

PM2s 100 N0 ND 226 NIA

SOx 400 N0 ND 014 NA

NOx 400 ND ND 3427 NA

voe 400 ND N0 192 NA

co 1000 ND ND 1439 NA

Total HAPS 250 ND ND 023 NA ND = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

APPLICABLE REQUIREMENTS

ProEnergy Services 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

bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050

bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the

first full calendar year the equipment is in operation

bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170

bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220

bull Restriction of Emission of Odors 1 0 CSR 10-6165

-7-

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation

- 8 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -

Table 1 Emissions Summary (tons per year)

PoUutant Regulatory DeMinimis

Levels

Existing Potential

Emissions

Existing Actual

Emissions

Potential Emissions of the middotProject

Conditioned Potential

Emissions of the Project

PM 250 N0 N0 226 NA

PM10 150 N0 ND 226 NA

PM2s 100 N0 ND 226 NIA

SOx 400 N0 ND 014 NA

NOx 400 ND ND 3427 NA

voe 400 ND N0 192 NA

co 1000 ND ND 1439 NA

Total HAPS 250 ND ND 023 NA ND = Not Determined

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels

APPLICABLE REQUIREMENTS

ProEnergy Services 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

bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050

bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the

first full calendar year the equipment is in operation

bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170

bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220

bull Restriction of Emission of Odors 1 0 CSR 10-6165

-7-

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation

- 8 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 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

bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation

- 8 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -

APPENDIX A Abbreviations and Acronyms

percent

degF 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

C02carbon dioxide

C02e carbon dioxide equivalent

COMS Continuous Opacity Monitoring System

CSR Code of State Regulations

dscf dry standard cubic feet

EIQEmission 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

HAPHazardous Air Pollutant

hr hour

hp horsepower

lb pound

lbshr pounds per hour

MACT Maximum Achievable Control Technology

microgm3 bull micrograms per cubic meter

mis meters per second

Mgal 1000 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

PM2s particulate matter less than 25 microns in aerodynamic diameter

PM10 particulate matter less than IO microns in aerodynamic diameter

ppm parts per million

PSD Prevention of Significant Deterioration

PTE potential to em it

RACT Reasonable Available Control Technology

RAL Risk Assessment Level

SCC Source Classification Code

scfm standard cubic feet per minute

SDS Safety Data Sheet

SIC Standard Industrial Classification

SIP State Implementation Plan

SMAL Screening Model Action Levels

SOx sulfur oxides

S02 sulfur dioxide

SSM Startup Shutdown amp Malfunction

tph tons per hour

tpy tons per year

VMT vehicle miles traveled

VOC Volatile Organic Compound

- 9 -