Re: Proposed ATC / Certificate of Conformity (Significant Mod) District Facility # S-2033 Project #

Transcription

1 San Joaquin Valley am AIR POLLUTION CONTROL DISTRICT HEALTHY AIR LIVING' DEC Mr. Larry Wanamaker GAF, Elk Corporation of Texas 6200 Zerker Road Shafter, CA Re: Proposed ATC / Certificate of Conformity (Significant Mod) District Facility # S-2033 Project # Dear Mr. Wanamaker: Enclosed for your review is the District's analysis of an application for Authority to Construct for the facility identified above. You requested that a Certificate of Conformity with the procedural requirements of 40 CFR Part 70 be issued with this project. The project authorizes a natural gas-fired dryer. After addressing all comments made during the 30-day public notice and the 45- day EPA comment periods, the District intends to issue the Authority to Construct with a Certificate of Conformity. Please submit your comments within the 30-day public comment period, as specified in the enclosed public notice. Prior to operating with modifications authorized by the Authority to Construct, the facility must submit an application to modify the Title V permit as an administrative amendment, in accordance with District Rule 2520, Section If you have any questions, please contact Mr. Leonard Scandura, Permit Services Manager, at (661) Thank you for your cooperation in this matter. SAcerely, Vrtiaud Marjollet irlector of Permit Services AiVI:kErst Enclosures cc: cc: Mike Tollstrup, CARB (w/enclosure) via Gerardo C. Rios, EPA (w/enclosure) via Seyed Sadredin Executive Director/Air Pollution Control Officer Northern Region 4800 Enterprise Way Modesto, CA Tel: (209) FAX: (209) Central Region (Main Office) 1990 E. Gettysburg Avenue Fresno, CA Tel: (559) FAX: (559) Southern Region Flyover Court Bakersfield, CA Tel: FAX: Primed on /aided paw. 0

2 San Joaquin Valley Air Pollution Control District Authority to Construct Application Review Modification of Filler Heating and Asphalt Roofing Shingle Coating Operations GAF Facility Name: Mailing Address: Contact Person: Telephone: Application #(s): Project #: Deemed Complete: GAF, Elk Corporation of Texas 6200 Zerker Road Shafter, CA Larry Wanamaker S and ' November 10, 2014 Engineer: Richard Edgehill Lead Engineer: Richard Karrs I. Proposal GAF, Elk Corporation of Texas (GAF) manufactures asphaltic felts and coatings. Ground limestone, referred to as "filler", is heated prior to mixing with asphalt in the shingle manufacturing business. In the project, GAF has requested an Authority to Construct (ATC) permit to replace the existing filler heating equipment (hot oil heat exchangers, hot bin) in filler heating operation (S ) with a flash drying system consisting of a drying chamber heated by a MMBtu/hr direct-fired dryer. Equipment description clarification was also requested by the applicant and details are included in the Equipment Section. Installation of the new dryer will result in an increase in combustion emissions which will be mitigated by concurrent reduction in authorized annual throughput to the asphalt roofing shingle coating operation (S ). The project triggers BACT and public notice. Offsets are not required. GAF received their Title V Permit on 12/31/12. The project is a Federal Major Modification; therefore, it is classified as a Title V Significant Modification pursuant to Rule 2520, Section 3.20, and can be processed with a Certificate of Conformity (COC). Since the facility has specifically requested that this project be processed in that manner, the 45-day EPA comment period will be satisfied prior to the issuance of the Authority to Construct. GAF must apply to administratively amend their Title V Operating Permit to include the requirements of the ATC(s) issued with this project. Disposition of Outstanding ATCs ATC S will be implemented prior to the proposed ATCs. Current PTOs S and '-12-8 and ATC S are included in Attachment I. 1

3 II. Applicable Rules Rule 2201 New and Modified Stationary Source Review Rule (4/21/11) Rule 2410 Prevention of Significant Deterioration (6/16/11) Rule 2520 Federally Mandated Operating Permits (6/21/01) Rule 4001 New Source Performance Standards 40 CFR Part 60, Subpart UU - Standards of Performance for Asphalt Processing and Asphalt Roofing Manufacture Rule 4101 Visible Emissions (2/17/05) Rule 4102 Nuisance (12/17/92) Rule 4201 Particulate Matter Concentration (12/17/92) Rule 4202 Particulate Matter Emissions Rate (12/17/92) Rule 4301 Fuel Burning Equipment (12/17/92) Rule 4309 Dryers, Dehydrators, and Ovens (12/15/05) Rule 4801 Sulfur Compounds (12/17/92) CH&SC Health Risk Assessment CH&SC School Notice Public Resources Code : California Environmental Quality Act (CEQA) California Code of Regulations, Title 14, Division 6, Chapter 3, Sections : CEQA Guidelines Ill. Project Location The facility is located at 6200 Zerker Road in Shafter, CA. The equipment is not located within 1,000 feet of the outer boundary of a K-12 school. Therefore, the public notification requirement of California Health and Safety Code is not applicable to this project. IV. Process Description Naturally occurring calcium carbonate (limestone) is mined and then ground to desired particle size to be used in the asphalt shingle manufacturing process as a mineral stabilizer for the asphaltic coating. Ground limestone is referred to as "filler" in the shingle manufacturing business. Current Operation S Unit S receives asphalt filler into a filler receiving bin which is served by baghouse DC- 7. The filler is metered from the receiving bin to two heaters exchanger followed by two hot filler bins. The heat exchangers receive heated fluid from heaters S and '-14. The filler receiving bin is vented to dust collectors DC-7, which vents to DC-5. DC-5 vents to atmosphere. The hot filler bins vent directly to DC-5. An additional dust collector (DC-8) serves the two filler heaters exchangers.

4 S The heated limestone filler proceeds to the coating application process (S ) where hot asphalt is mixed with filler. The "filled" asphalt flows from the mixers to a single 4000 gallon surge tank which feeds the coater on the shingle manufacturing line. Later in the manufacturing process, there is a seal down applicator and storage tanks for adhesives. The continuous mixer, surge tank, coater, and other equipment on the shingle manufacturing line which has the potential to produce asphalt fumes are vented to high velocity air filter FCS-1. Proposed Modifications As proposed, limestone filler with a maximum moisture content of less than 1% by weight will be fed from the existing filler receiving bin to a new cyclone (P-1) that will drop limestone into a new drying chamber served by an air heater with a MMBtu/hr natural gas fired low NOx burner. The heated limestone will be routed to the existing hot bin via a new second cyclone (P-2). New cyclones P-1 and P-2 (and the drying chamber) will be vented to a new dust collector (DC-10) that will separate and return the filler to the process. As designed, a portion of the filtered airflow may be directed back to the air heater for heat recovery, with the remainder exhausted to atmosphere through a stack. Pre- and post-project process flow diagrams are included in Attachment II. V. Equipment Listing Pre-Project Equipment Description* S : FILLER HEATING OPERATION WITH A FILLER RECEIVING BIN AND TWO HOT BINS SERVED BY WHIRL AIR FLOW MODEL DUST COLLECTOR (DC-7) SHARED WITH S , AND ULTRA INDUSTRIES MODEL BD DUST COLLECTOR (DC-5); THERMAL FLUID HEAT FROM TWO HEATERS (S AND S ) PROVIDED FOR TWO HEAT EXCHANGERS SERVED BY ULTRA INDUSTRIES MODEL BB IIG FAN DUST COLLECTOR(DC-8), ROTARY FEEDERS; AND METERING SCREW CONVEYORS FEEDING THE ASPHALT ROOFING SHINGLE COATING OPERATION (S ) * corrections/clarifications made in this project included DC-5 model number was corrected and clarified permit process fed by screw conveyors ATC S : MODIFICATION OF ASPHALT ROOFING SHINGLE COATING OPERATION WITH MACHINE LINE FUME COLLECTION SYSTEM VENTED TO HIGH VELOCITY AIR FILTER (FCS-1): REPLACE CONTINUOUS MIXERS 3

5 Proposed Modifications: S Remove Install One hot filler bin, the two filler heat exchangers, and DC-8 One MMBtu/hr flash dryer, two cyclones (P-1 and P-2), and a dust collector (DC-10). ATC S : MODIFICATION OF FILLER HEATING OPERATION WITH A FILLER RECEIVING BIN AND TWO HOT BINS SERVED BY WHIRL AIR FLOW MODEL DUST COLLECTOR (DC-7) SHARED WITH S , AND ULTRA INDUSTRIES MODEL BD DUST COLLECTOR (DC- 5) SHARED WITH S ; THERMAL FLUID HEAT FROM TWO HEATERS (S AND S ) PROVIDED BY TWO HEAT EXCHANGERS SERVED BY ULTRA INDUSTRIES MODEL BB IIG FAN DUST COLLECTOR (DC-8), ROTARY FEEDERS; AND METERING SCREW CONVEYORS FEEDING THE ASPHALT ROOFING SHINGLE COATING OPERATION (S ): REMOVE ONE HOT BIN, FILLER HEAT EXCHANGERS, AND DUST COLLECTOR (DC-8), ADD FLASH DRYING SYSTEM WITH A MMBTU/HR NATURAL GAS FIRED AIR HEATER WITH AN ECLIPSE MINNOX 3000 CCS-T BURNER OR EQUIVALENT AND TWO CYCLONES SERVED BY FLS AIRTECH MODEL DC8 DUST COLLECTOR (DC-10), AND ASSOCIATED CONVEYANCES S : MODIFICATION OF ASPHALT ROOFING SHINGLE COATING OPERATION WITH MACHINE LINE FUME COLLECTION SYSTEM VENTED TO HIGH VELOCITY AIR FILTER (FCS-1): DECREASE ANNUAL THROUGHPUT Post Project Equipment Description: S *: FILLER HEATING OPERATION WITH A FILLER RECEIVING BIN AND ONE HOT BIN SERVED BY WHIRL AIR FLOW MODEL DUST COLLECTOR (DC-7) AND ULTRA INDUSTRIES MODEL BD DUST COLLECTOR (DC-5) SHARED WITH S ; FLASH DRYING SYSTEM WITH A MMBTU/HR NATURAL GAS FIRED AIR HEATER WITH AN ECLIPSE MINNOX 3000 CCS-T BURNER OR EQUIVALENT AND TWO CYCLONES SERVED BY FLS AIRTECH MODEL DC8 DUST COLLECTOR (DC-10); ROTARY FEEDERS, ASSOCIATED CONVEYANCES; AND METERING SCREW CONVEYORS FEEDING THE ASPHALT ROOFING SHINGLE COATING OPERATION (S ) *reviewed by applicant, 11/14/14 S : ASPHALT ROOFING SHINGLE COATING OPERATION WITH MACHINE LINE FUME COLLECTION SYSTEM VENTED TO HIGH VELOCITY AIR FILTER (FCS-1) 4

6 VI. Emission Control Technology Evaluation Filler Heating Operation (S ) The new dryer will be equipped with an ultra-low NOx burner capable of achieving 2.1 ppmv 19% 02. The pollutants of concern are NOx, CO, VOC, PK, and SOx emitted from the natural gasfired burner and non-combustion PK from filler handling. In addition to fuel-derived NOx, at elevated temperatures in an oxidizing environment, impurities in the limestone have the potential to offgas feed NOx. Various dust collectors will control PK emissions from the filler handling. The dryer will be fired on natural gas and will be equipped with a low NOx burner. Low NOx burners reduce NO formation by producing lower flame temperatures (and longer flames) than conventional burners. Conventional burners thoroughly mix all the fuel and air in a single stage just prior to combustion, whereas low-nox burners delay the mixing of fuel and air by introducing the fuel (or sometimes the air) in multiple stages. Generally, in the first combustion stage, the air-fuel mixture is fuel rich. In a fuel rich environment, all the oxygen will be consumed in reactions with the fuel, leaving no excess oxygen available to react with nitrogen to produce thermal NOx. In the secondary and tertiary stages, the combustion zone is maintained in a fuel-lean environment. The excess air in these stages helps to reduce the flame temperature so that the reaction between the excess oxygen with nitrogen is minimized. Asphalt Roofing Shingle Manufacturing Operation (S ) No physical modifications to the asphalt roofing shingle manufacturing operation are proposed; therefore, an emission control technology evaluation is not required for this process. VII. General Calculations Assumptions (S ) The maximum operating schedule is 24 hours per day, 365 days per year. The maximum total facility filler process rate is 1,141 tons per day (Condition #9, PTO ). The flash dryer will be fired only on PUC-regulated natural gas. Sulfur emissions based on combustion of natural gas, 1 gr S/100scf Natural gas heating value: 1,000 Btu/scf (AP 42 Section 1.4) F-Factor for natural gas: 8,578 dscf/mmbtu corrected to 60 F (40 CFR 60, Appendix B) (S ) Maximum operating schedule is 24 hours per day, 365 days per year. Pre- and post-project maximum daily asphalt throughput is 657 tons per day (Condition #14, PTO S ) Pre-project maximum annual asphalt throughput is 206,500 tons per year (Condition #14, PTO S ) 5

7 The post-project maximum annual asphalt throughput is 203,788 tons per year (proposed). There will be no change in hourly or daily emissions associated with this project. However, annual VOC and PM10 emissions will be reduced. B. Emission Factors fs ) PK () emissions from dust collectors = lb-pm i o/ton of filler material processed (Condition #9, PTO S ) Flash Dryer Burner NOx: % 02 (BACT Requirement, equivalent to 20 3% 02)* Dryer NOx: 19% 02 (when drying filler, Rule 4309 requirement, worst case)* PM, CO and VOC emission factors are the same for all fuels (AP 42 Table 1.5-1, 10/96) Flash Dryer Pollutant Emission Factor Source SOx lb/mmbtu District Policy APR 1720 PNlio lb/mmbtu EPA AP-42 Section 1.4 CO 02* lb/mmbtu Rule 4309 VOC lb/mmbtu EPA AP-42 Section 1.4 I *20 x ( )/(20.9 3) = 2.1 (4.3 ft3/ % 0 2 x [(20.9 0) )] ft 0 2 )/ 0% 02 x 8,578 0% 0 2/MMBtu x (46 lb/ibmol)(1bmol/379.5 scf) = lb/mmbtu (42 ft3/106 19% 0 2 x [(20.9 0) )] 02 )/ ft3@ 0% 02 x 8,578 0% 0 2/MMBtu x (28 lb/ibmol)(1bmol/379.5 scf) = 0.29 lb/mmbtu S lb/hr PM10, 5.04 lb/hr VOC (Condition #13, S ) Annual Emissions Factors Pollutant lb/yr emissions* Emissions factor** PM10 6, VOC 37, * Condition #13 of PTO S **Ib/yr emissions divided by annual throughput of 206,500 tons/yr (Condition #14, PTO S ) 6

8 C. Calculations 1. Pre-Project Potential to Emit (PEI) S Operation is currently limited to 1,141 tons-filler/day and 365 days of operation per year. Therefore, each dust collector (DC-5, DC-7, DC-8) emits the following: P E 1pmio = (1,141 tons-filler/day)( lb-pm i o/ton) = 0.3 lb-pmio/day P E 1 pmio = (0.3 lb-pm10/day)(365 day/year) = 110 lb-pmio/year Daily Emissions (1b/clay) PEI (S ) Annual Emissions (lb/year) Source NOx 0 0 PTO SOx 0 0 PTO PhAio PTO CO 0 0 PTO VOC 0 0 PTO S PE1rnmo PE1pmio PE1voc PElvoc = 0.88 lb/hr x 24 hr/day = 21.0 lb-pm i o/day = 6,638 lb-pm 1 0/yr = 5.04 lb/hr x 24 hr/day = lb-voc/day =37,996 lb-voc/day PEI Daily Emissions (1b/clay) Annual Emissions (lb/year) NO 0 0 SOx 0 0 Knio ,638 CO 0 VOC ,996 7

9 2. Post Project Potential to Emit (PE2) S Operation will remain limited to 1,141 tons-filler/day and 365 days of operation per year. Dust Collectors DC-8 will be removed and DC-10 will be added. Each dust collector (DC-5, DC-7, DC-10) emits the following: PE2pmio = (1,141 tons-filler/day)( lb-pm i o/ton) = 0.3 lb-pmio/day Dryer PE2pmio Pollutant = (0.3 lb-pm10/day)(365 day/year) = 110 lb-pmio/year EF2 (Ib/MMBtu) Heat Input (MMBtu/hr) Daily PE2 Operating Schedule (hr/day) Daily PE2 (lb/day) NOx SO x nlio CO VOC Pollutant EF2 (Ib/MMBtu) Heat Input (MMBtu/hr) Annual PE2 Operating Schedule (hr/year) Annual PE2 (lb/year) NOx ,760 4,443 SO x , PR , CO ,760 26,293 VOC , PE2 Daily Emissions (lb/day) Annual Emissions (lb/year) NO ,443 SO, PMio = =1,019 CO ,293 VOC

10 S No change to daily PM10 and VOC emissions. Annual PE2pm10 = (203,788 tons/year)(0.032 lb-pm10/ton) = 6,521 lb-voc/year Annual PE2voc = (203,788 tons/year)(0.184 lb-voc/ton) = 37,497 lb-voc/year PE2 Daily Emissions (lb/day) Annual Emissions (lb/year) NO 0 0 SOx 0 0 PMio ,521 CO 0 0 VOC ,497 Emissions Profiles are included in Attachment Ill. 3. Pre-Project Stationary Source Potential to Emit (SSPE1) Pursuant to District Rule 2201, the SSPE1 is the Potential to Emit (PE) from all units with valid Authorities to Construct (ATC) or Permits to Operate (PTO) at the Stationary Source and the quantity of Emission Reduction Credits (ERC) which have been banked since September 19, 1991 for Actual Emissions Reductions (AER) that have occurred at the source, and which have not been used on-site. Pre-Project Stationary Source Potential to Emit [SSPE1] (lb/year) _ Permit Unit NOx SOx Mlio CO VOC S S S S S S S S , ,775 ATC S , ,996 S ,892 1,724 1,261 15, S , ,261 15, , Pre-Project SSPE (SSPE1) 3,784 2,059 21,781 31,326 49,354 9

11 4. Post Project Stationary Source Potential to Emit (SSPE2) Pursuant to District Rule 2201, the SSPE2 is the PE from all units with valid ATCs or PTOs at the Stationary Source and the quantity of ERCs which have been banked since September 19, 1991 for AER that have occurred at the source, and which have not been used on-site. Post Project Stationary Source Potential to Emit [SSPE2t (lb/year) Permit Unit NOx SOx Kilo CO VOC S S S S S S S , ,019 26, S S , ,775 S , ,497 S ,892 1,724 1,261 15, S , ,261 15, Post Project SSPE (SSPE2) 8,227 2,317 22,353 57,619 49, Major Source Determination Rule 2201 Major Source Determination: Pursuant to District Rule 2201, a Major Source is a stationary source with a SSPE2 equal to or exceeding one or more of the following threshold values. For the purposes of determining major source status the following shall not be included: any ERCs associated with the stationary source Emissions from non-road IC engines (i.e. IC engines at a particular site at the facility for less than 12 months) Fugitive emissions, except for the source categories specified in 40 CFR Rule 2201 Major Source Determination (lb/year) NOx Sax PM10 CO VOC Facility emissions pre-project 3,784 2,059 21,781 31,326 49,354 Facility emissions post-project 8,227 2,317 22,353 57,619 49,354 Major Source Threshold 20, , , ,000 20,000 Major Source? No No No No Yes 10

12 This source is an existing Major Source for VOC emissions and will remain a Major Source for VOC. Rule 2410 Major Source Determination: The facility or the equipment evaluated under this project is not listed as one of the categories specified in 40 CFR (b)(1)(iii). Therefore the PSD Major Source threshold is 250 tpy for any regulated NSR pollutant. Estimated Facility PE before Project Increase PSD Major Source Determination (tons/year) _ NO2 VOC SO2 CO PM PM PSD Major Source Thresholds PSD Major Source? (Y/N) N N N NN N As shown above, the facility is not an existing major source for PSD for at least one pollutant. Therefore the facility is not an existing major source for PSD. 6. Baseline Emissions (BE) The BE calculation (in lbs/year) is performed pollutant-by-pollutant for each unit within the project to determine the amount of offsets required. Pursuant to District Rule 2201, BE = PE1 for: Any unit located at a non-major Source, Any Highly-Utilized Emissions Unit, located at a Major Source, Any Fully-Offset Emissions Unit, located at a Major Source, or Any Clean Emissions Unit, located at a Major Source. otherwise, BE = Historic Actual Emissions (HAE), calculated pursuant to District Rule As shown in Section VII.C.5 above, the facility is not a Major Source for NOx, S0x, PM10 or CO. Therefore BE=PE1 for NOx, S0x, PM10 or CO. a. BE VOC Pursuant to Rule 2201, a Clean Emissions Unit is defined as an emissions unit that is "equipped with an emissions control technology with a minimum control efficiency of at least 95% or is equipped with emission control technology that meets the requirements for achieved-in-practice BACT as accepted by the APCO during the five years immediately prior to the submission of the complete application. 11

13 S Unit S does not currently emit VOC and therefore BE = 0. S Unit S is equipped with a high velocity air filter, which meets the requirements for achieved-in-practice BACT pursuant to current BACT guideline [Asphalt Roofing Product Mfg. - Coating Operation]. Therefore, BE=PE1 for VOC. 7. SB 288 Major Modification SB 288 Major Modification is defined in 40 CFR Part as "any physical change in or change in the method of operation of a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act." Since this facility is a major source for VOC, the project's PE2 is compared to the SB 288 Major Modification Thresholds in the following table in order to determine if the SB 288 Major Modification calculation is required. Pollutant VOC SB 288 Major Modification Thresholds Project PE2 (lb/year) 37,497 ('-12) ('-8) = 37,996 Threshold (lb/year) SB 288 Major Modification Calculation Required? 50,000 No Since SB 288 Major Modification Thresholds are not surpassed with this project, this project does not constitute an SB 288 Major Modification. 8. Federal Major Modification District Rule 2201, Section 3.17 states that Federal Major Modifications are the same as "Major Modification" as defined in 40 CFR and part D of Title I of the CAA. The determination of Federal Major Modification is based on a two-step test. For the first step, only the emission increases are counted. Emission decreases may not cancel out the increases for this determination. Step 1 For new emissions units, the increase in emissions is equal to the PE2 for each new unit included in this project. The flash dryer is a new emissions unit. For existing emissions units, the increase in emissions is calculated as follows. 12

14 Emission Increase = PAE BAE - UBC Where: PAE = Projected Actual Emissions, and BAE = Baseline Actual Emissions UBC = Unused baseline capacity If there is no increase in design capacity or potential to emit, the PAE is equal to the annual emission rate at which the unit is projected to emit in any one year, selected by the operator, within 5 years after the unit resumes normal operation (10 years for existing units with an increase in design capacity or potential to emit). If detailed PAE are not provided, the PAE is equal to the PE2 for each permit unit. The BAE is calculated based on historical emissions and operating records for any 24 month period, selected by the operator, within the previous 10 year period (5 years for electric utility steam generating units). The BAE must be adjusted to exclude any noncompliant operation emissions and emissions that are no longer allowed due to lower applicable emission limits that were in effect when this application was deemed complete. The project's combined total emission increases are calculated in Section VII.C.2 and compared to the Federal Major Modification Thresholds in the following table. Federa Major Modification Thresholds for Emission Increases Pollutant Total Emissions Increases (lb/yr) Thresholds (lb/yr) Federal Major Modification? VOC* Yes *If there is any emission increases in VOC, this project is a Federal Major Modification and no further analysis is required. Since there is an increase in VOC emissions, this project constitutes a Federal Major Modification. 9. Rule 2410 Prevention of Significant Deterioration (PSD) Applicability Determination Rule 2410 applies to pollutants for which the District is in attainment or for unclasssified, pollutants. The pollutants addressed in the PSD applicability determination are listed as follows: NO2 (as a primary pollutant) SO2 (as a primary pollutant) CO PM PM10 13

15 I. Project Emissions Increase - New Major Source Determination The post-project potentials to emit from all new and modified units are compared to the PSD major source thresholds to determine if the project constitutes a new major source subject to PSD requirements. The facility or the equipment evaluated under this project is not listed as one of the categories specified in 40 CFR (b)(1)(i). The PSD Major Source threshold is 250 tpy for any regulated NSR pollutant. PSD Major Source Determination: Potential to Emit (tons/year) NO2 VOC SO2 CO PM PM10 Total PE from New and Modified Units PSD Major Source threshold New PSD Major Source? N N N NN N As shown in the table above, the potential to emit for the project, by itself, does not exceed any PSD major source threshold. Therefore Rule 2410 is not applicable and no further analysis is required. 10. Quarterly Net Emissions Change ((MEC) The QNEC is calculated solely to establish emissions that are used to complete the District's PAS emissions profile screen. The project QNECs are calculated below. S PE1 (lb/yr) QNEC PE2 (lb/yr) QNEC (lb/qtr) NO 0 4,443 1,111 SO, PN/lio 330 1, CO 0 26,293' 6,573 VOC

16 S PE1 (lb/yr) QNEC PE2 (lb/yr) QNEC (Ib/qtr) NOx SOx PMio 6,638 6, CO VOC 37,996 37, VIII. Compliance Rule 2201 New and Modified Stationary Source Review Rule A. Best Available Control Technology (BACT) 1. BACT Applicability GAF BACT requirements are triggered on a pollutant-by-pollutant basis and on an emissions unit-by-emissions unit basis for the following: a) Any new emissions unit with a potential to emit exceeding two pounds per day*, b) The relocation from one stationary source to another of an existing emissions unit with a potential to emit exceeding two pounds per day, and/or C) Modifications to an existing emissions unit with a valid Permit to Operate resulting in an AIPE exceeding two pounds per day*. d) When a Major Modification is triggered for a modification project at a facility that is a Major Source. *Except for CO emissions from a new or modified emissions unit at a stationary source with an SSPE2 of less than 200,000 pounds per year of CO. a. New emissions units PE > 2 lb/day As seen in Section VII.C.2 of this evaluation, the applicant is proposing to install a new flash drying system with a PE greater than 2.0 lb/day for NOx and CO. BACT is triggered for NOx only; BACT is not triggered for CO since the SSPE2 for CO is not greater than 200,000 lbs/year, as demonstrated in Section VII.C.5 of this document. b. Relocation of emissions units PE > 2 lb/day As discussed in Section I above, there are no emissions units being relocated from one stationary source to another; therefore BACT is not triggered. c. Modification of emissions units AIPE > 2 lb/day The asphalt roofing shingle coating operation (S ) is being modified. AIPE = PE2 HAPE 15

17 Where, AIPE = Adjusted Increase in Permitted Emissions, (1b/clay) PE2 = Post-Project Potential to Emit, (1b/clay) HAPE = Historically Adjusted Potential to Emit, (1b/clay) HAPE = PEI x (EF2/EF1) Where, PE1 = The emissions unit's PE prior to modification or relocation, (lb/day) EF2 = The emissions unit's permitted emission factor for the pollutant after modification or relocation. If EF2 is greater than EF1 then EF2/EF1 shall be set to 1 EF1 = The emissions unit's permitted emission factor for the pollutant before the modification or relocation AIPE = PE2 (PE1 * (EF2 / EF1)) For this project EF2 = EF1 and there is no change in daily PM10 or VOC emissions. Therefore PE2 = PEI, AIPE = 0, and BACT is not triggered. d. SB 288/Federal Major Modification As discussed in Section VII.C.7 above, this project constitutes a Federal Major Modification; therefore BACT is triggered for any pollutants with a Federal Emissions Increase. There is a Federal Emissions Increase for only VOC since the source is not a Major Source for NOx, S0x, CO, and PM BACT Guideline There is not an existing BACT Guideline for his class and category of source. Due to the unique nature of this operation, a project specific BACT analysis will be performed. Control technologies identified in different BACT guidelines for combustion equipment (Attachment IV) form the basis of this BACT evaluation. NOx As discussed above in the emissions control technology evaluation, the applicant has indicated that there is a strong likelihood that with limestone feed will have some degree of contamination with nitrogen compounds, which may be oxidized to NOx within the dryer. This NOx will be in addition to the thermal NOx produced by combustion. The applicant and applicant's consultant (Insight Environmental Consultants) met with the District on to discuss their concerns and present the technical supporting information, including a literature review and vendor emission expectations and guarantees. Based on the top-down source specific BACT review included as Attachment V, the District has determined that an emissions limit of 2.1 ppmv 19% 02 was achievable as a "target limit", but that a higher limit not exceeding 4.3 ppmv 16

18 19% 02 would be also be justified and approved if supported by source test and monitoring results within the first year of operation. (Exhaust gas treatment for NOx control for this unit was determined not be cost effective.) The target limit will be 2.1 ppmv e. 19% Qz which is required by both existing BACT Guideline for "Dryer-Milk Spray, <20 MMBtu/hr" and BACT Guideline "Mineral Products Spray Dryer-Natural Gas Fired, <20 MMBtu/hr". The worst case limit will be 4.3 ppmv 19% 02 which is the Rule 4309 NOx limit. VOCs BACT is satisfied by using gaseous fuel. 3. Top-Down BACT Analysis Pursuant to the attached Top-Down BACT Analysis (see Attachment V), BACT has been satisfied with the following: NOx: (target), 4.3 ppmvd 19% 02 (worst case) VOCs: natural gas fuel B. Offsets 1. Offset Applicability Offset requirements shall be triggered on a pollutant by pollutant basis and shall be required if the SSPE2 equals to or exceeds the offset threshold levels in Table 4-1 of Rule The SSPE2 is compared to the offset thresholds in the following table. Offset Determination (lb/year) NOx SOx PMio CO VOC SSPE2 8,227 2,317 22,353 57,619 49,354 Offset Thresholds 20,000 54,750 29, ,000 20,000 Offsets triggered? No No No No Yes 2. Quantity of Offsets Required As seen above, the facility is an existing Major Source for VOC and the SSPE2 is greater than the offset thresholds. Therefore offset calculations for VOCs will be required for this project. The quantity of offsets in pounds per year for VOC is calculated as follows for sources with an SSPE1 greater than the offset threshold levels before implementing the project being evaluated. 17

19 Offsets Required (lb/year) = (E[PE2 BE] + ICCE) x DOR, for all new or modified emissions units in the project, Where, PE2 = Post Project Potential to Emit, (lb/year) BE = Baseline Emissions, (lb/year) ICCE = Increase in Cargo Carrier Emissions, (lb/year) DOR = Distance Offset Ratio, determined pursuant to Section 4.8 BE = PE1 for: Any unit located at a non-major Source, Any Highly-Utilized Emissions Unit, located at a Major Source, Any Fully-Offset Emissions Unit, located at a Major Source, or Any Clean Emissions Unit, Located at a Major Source. otherwise, BE = HAE As calculated in Section VII.C.6 above, the BE from these units are equal to the PE1 since the units are a Clean Emissions Unit. Also, there are only two emissions units associated with this project and there are no increases in cargo carrier emissions. Therefore offsets can be determined as follows: Offsets Required (lb/year) = ( [PE2 BE] + ICCE) x DOR, for all new or modified emissions units in the project, EPE2 (VOC) = (S S ) = ( ,497) = 37,996 lb/year EBE (VOC) = (S S ) = (0 + 37,996) = 37,996 lb/year ICCE = 0 lb/year Offsets Required (lb/year) = ([37,996 37,996] + 0) x DOR = 0 lb VOC/year As demonstrated in the calculation above, the amount of offsets is zero. Therefore, offsets will not be required for this project. 18

20 i 1 GAF C. Public Notification 1. Applicability Public noticing is required far: a. New Major Sources, Federal Major Modifications, and SB 288 Major Modifications, b. Any new emissions unit with a Potential to Emit greater than 100 pounds during any one day for any one pollutant, c. Any project which results in the offset thresholds being surpassed, and/or d. Any project with an SSIPE of greater than 20,000 lb/year for any pollutant. a. New Major Sources, Federal Major Modifications, and SB 288 Major Modifications New Major Sources are new facilities, which are also Major Sources. Since this is not a new facility, public noticing is not required for this project for New Major Source purposes. As demonstrated in Sections VII.C.7 and VII.C.8, this project constitutes a Federal Major Modification; therefore, public noticinq for SB 288 or Federal Major Modification purposes is required. b. PE > 100 lb/day Applications which include a new emissions unit with a Potential to Emit greater than 100 pounds during any one day for any pollutant will trigger public noticing requirements. As seen in Section VII.C.2 above, this project does not include a new emissions unit which has daily emissions greater than 100 lb/day for any pollutant; therefore, public noticing for PE > 100 lb/day purposes is not required. c. Offset Threshold The SSPE1 and SSPE2 are compared to the offset thresholds in the following table. Offset Thresholds P ollutant SSPE1 SSPE2 Offset Public Notice (lb/year) (lb/year) Threshold Required? NO 3,784 8,227 20,000 lb/year No SOx 2,059 2,317 54,750 lb/year No PK 21,781 22, ,200 lb/year No CO 31,326 57, ,000 lb/year No VOC 49,354 49,354 20,000 lb/year No, Public notification is required for any project where the offset threshold for any pollutant is exceeded. Since there is no increase in facility emissions for this project for VOC, the offset threshold comparison is not necessary and public notification for exceeding the offset threshold is not required. 19

21 d. SSIPE > 20,000 lb/year Public notification is required for any permitting action that results in a SSIPE of more than 20,000 lb/year of any affected pollutant. According to District policy, the SSIPE = SSPE2 SSPE1. The SSIPE is compared to the SSIPE Public Notice thresholds in the following table. SSIPE Public Notice Thresholds P ollutant SSPE1 SSPE2 SSIPE SSIPE Public Public Notice (lb/year) (lb/year) (lb/year) Notice Threshold Required? NO 3,784 8,227 4,443 20,000 lb/year No SO, 2,059 2, ,000 lb/year No PK () 21,781 22, ,000 lb/year No CO 31,326 57,619 26,293 20,000 lb/year Yes VOC 49,354 49, ,000 lb/year No As demonstrated above, the SSIPE for CO exceeds 20,000 lb/year; therefore public noticing for SSIPE purposes is required. 2. Public Notice Action As discussed above, this project will result in emissions, for any pollutant, which would subject the project to any of the noticing requirements listed above. Therefore, public notice will be required for this project. D. Daily Emission Limits (DELs) DELs and other enforceable conditions are required by Rule 2201 to restrict a unit's maximum daily emissions, to a level at or below the emissions associated with the maximum design capacity. The DEL must be contained in the latest ATC and contained in or enforced by the latest PTO and enforceable, in a practicable manner, on a daily basis. DELs are also required to enforce the applicability of BACT. Proposed Rule 2201 (DEL) Conditions (S ): The following DELs include the BACT limit for dryer burner NOx emissions and separate Rule 4309 limits for the flash drying operation as a whole Flash dryer shall combust natural gas only with a sulfur content not exceeding 1 gr S/100 scf. [District Rule 2201] Y Emissions from the flash drying operation shall not exceed any of the following limits: lb-pm10/mmbtu, 42 ppmv 19% 02, or lb-voc/mmbtu. [District Rules 2201 and 4309] Y 20

22 Emissions from the flash dryer shall not exceed 2.2 ppmv 19% 02 except during the first 12 months after the initial source test where NOx emissions shall not exceed 4.3 ppmv 19% 02. [District Rule 2201] Y Within 12 months of the initial source test, GAF shall prepare and submit to the District a report proposing the final NOx limit established though source testing and monitoring. [District Rule 2201] Y The District shall establish the final NOx limit within 90 days of receipt of the GAF report. [District Rule 2201] Y Proposed Rule 2201 (DEL) Conditions (S ): Changes to the following current conditions are underlined: Emission rate from shingle coating operation shall not exceed: PM10: 0.88 lb/hr and 6,521 lb/vr, and VOC: 5.04 lb/hr and 37,497 lb/yr. [District Rule 2201] Total quantity of coating asphalt, sealant asphalt, and laminate adhesive asphalt introduced to asphalt roofing shingle coating operation (S ) shall not exceed 657 tons/day and 203,788 tons/year. [District Rule 2201] E. Compliance Assurance 1. Source Testing S Source testing to measure NOx and CO emissions from this unit shall be conducted within 60 days of initial start-up and at least once every 24 months thereafter. [District Rules 2201 and 4309] Y S The following current requirements will be included on the ATC: Source testing to demonstrate compliance with PM10 and VOC emission limits shall be conducted not less than once every 12 months, except as provided below. [District Rule 1070] Source testing to demonstrate compliance with PM10 and VOC emission limits shall be conducted not less than once every 36 months if compliance is demonstrated on two consecutive annual tests. [District Rule 1070] 2. Monitoring S No monitoring is required to demonstrate compliance with Rule However, 21

23 Rule 4309 requires monthly monitoring of 19% 02, 19% 02, and 02 concentrations using a portable analyzer. S No monitoring is required to demonstrate compliance with Rule Recordkeeping Recordkeeping is required to demonstrate compliance with the offset, public notification and daily emission limit requirements of Rule 2201 and for compliance with Rule S The permittee shall maintain records of: (1) the date and time of NOX, CO, and 02 measurements, (2) the 02 concentration in percent and the measured NOX and CO concentrations corrected to 19% 02, (3) make and model of exhaust gas analyzer, (4) exhaust gas analyzer calibration records, and (5) a description of any corrective action taken to maintain the emissions within the acceptable range. [District Rule 4309] Y Permittee shall maintain accurate daily records of filler material process rate. [District Rules 1070 and 2201] N All records shall be maintained and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rules 1070] Y S The following condition(s) are listed on the ATC/PTO: Records of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 maintenance, inspection, and repairs shall be maintained. The records shall include identification of equipment, date of inspection, corrective action taken, and identification of individual performing inspection. [District Rule 1070] The permittee shall comply with the recordkeeping and reporting requirements of 40 CFR part [40 CFR 64.9] Permittee shall maintain daily records of asphalt process rate and temperature monitoring results, and shall make such records readily available for District inspection upon request for a period of five years. [District Rule 1070] 4. Reporting No reporting is required to demonstrate compliance with Rule

24 F. Ambient Air Quality Analysis (AAQA) Section 4.14 of this Rule requires that an ambient air quality analysis (AAQA) be conducted for the purpose of determining whether a new or modified Stationary Source will cause or make worse a violation of an air quality standard. Technical Services Division performed modeling for criteria pollutants CO, NOx, SOx and PM10 (Attachment VI). The results are as follows: Criteria Pollutant Modeling Results* Steam Generator 1 Hour 3 Hours 8 Hours. 24 Hours Annual CO Pass X Pass X X NO Pass' X X X Pass SO, Pass Pass X Pass Pass PMio X X X Pass 2 Pass/ PM2.5 X X X Pass2 Pass2 *Results were taken from the attached PSD spreadsheet. 1The project was compared to the 1-hour NO2 National Ambient Air Quality Standard that became effective on April 12, 2010 using the District's approved procedures. 2The criteria pollutants are below EPA's level of significance as found in 40 CFR Part (b)(2). As shown, the calculated contribution of PK will not exceed the EPA significance level. This project is not expected to cause or make worse a violation of an air quality standard. G. Compliance Certification The compliance certification is required for any project, which constitutes a New Major Source or a Federal Major Modification. Section of this Rule requires the owner of a new Major Source or a source undergoing a Federal Major Modification to demonstrate to the satisfaction of the District that all other Major Sources owned by such person and operating in California are in compliance or are on a schedule for compliance with all applicable emission limitations and standards. As discussed in Sections VIII-Rule 2201-C.1.a and VIII-Rule 2201-C.1.b, this project does constitute a Federal Major Modification, therefore this requirement is applicable. Included in Attachment VII is GAF's Statewide Compliance Certification Statement. H. Alternate Siting Analysis The current project occurs at an existing facility. The applicant proposes to install one new steam generator. Since the new steam generator will be used at the existing site, its installation will result in the least possible impact from the project. Alternative sites would involve the relocation and/or construction of various support structures on a much greater scale, and would therefore result in a much greater impact. 23

25 Rule 2520 Federally Mandated Operating Permits This facility is subject to this Rule, and has received their Title V Operating Permit. Section 3.29 defines a significant permit modification as a "permit amendment that does not qualify as a minor permit modification or administrative amendment." The project is Federal Major Modification and therefore is also a Title V Significant Modification. As discussed above, the facility has applied for a Certificate of Conformity (COC); therefore, the facility must apply to modify their Title V permit with an Administrative Amendment, prior to operating with the proposed modifications. Included in Attachment VII is GAF's Title V Compliance Certification form. Continued compliance with this rule is expected. Rule 4001 New Source Performance Standards 40 CFR Part 60, Subpart UU - Standards of Performance for Asphalt Processing and Asphalt Roofing Manufacture The affected facilities to which this subpart applies are each saturator and each mineral handling and storage facility at asphalt roofing plants; and each asphalt storage tank and each blowing still at asphalt processing plants, petroleum refineries, and asphalt roofing plants. "Saturator means the equipment in which asphalt is applied to felt to make asphalt roofing products. The term saturator includes the saturator, wet looper, and coater." Mineral handling and storage facility means the areas in asphalt roofing plants in which minerals are unloaded from a carrier, the conveyor transfer points between the carrier and the storage silos, and the storage silos. S Not applicable, S does not include a saturator, a mineral handling and storage facility; nor an asphalt storage tank. Therefore the Subpart is not applicable. S S is not being modified as there is no increase in emissions. Therefore the Subpart is not applicable. Rule 4101 Visible Emissions Per Section 5.0, no person shall discharge into the atmosphere emissions of any air contaminant aggregating more than 3 minutes in any hour which is as dark as or darker than Ringelmann 1 (or 20% opacity). The current PTO includes the following condition: Visible emissions shall not exceed 1/4 Ringelmann or 5% opacity. [District Rule 2201] N 24

26 Continued compliance with this rule is expected. Rule 4102 Nuisance Rule 4102 prohibits discharge of air contaminants which could cause injury, detriment, nuisance or annoyance to the public. Public nuisance conditions are not expected as a result of these operations, provided the equipment is well maintained. Therefore, compliance with this rule is expected. California Health & Safety Code (Health Risk Assessment) District Policy APR 1905 Risk Management Policy for Permitting New and Modified Sources specifies that for an increase in emissions associated with a proposed new source or modification, the District perform an analysis to determine the possible impact to the nearest resident or worksite. An HRA is not required for a project with a total facility prioritization score of less than or equal to one. According to the Technical Services Memo for this project (Attachment VI), the total facility prioritization score including this project was less than or equal to one. Therefore, no future analysis is required to determine the impact from this project and compliance with the District's Risk Management Policy is expected. Rule 4201 Particulate Matter Concentration Section 3.1 prohibits discharge of dust, fumes, or total particulate matter into the atmosphere from any single source operation in excess of 0.1 grain per dry standard cubic foot. The existing equipment authorized by S is currently in compliance with this rule and decreasing throughput is not expected to affect compliance. The existing equipment authorized by S is currently in compliance with this rule and the proposed equipment will be served by cyclones and a dust collector. Continued compliance with this rule is expected. Rule 4202 Particulate Matter Emission Rate: Rule 4202 establishes PM emission limits as a function of process weight rate in tons/hr as calculated by the following: E = 3.59 P.62 for P less than or equal to 30 tons/hr E = P 0.16 for P greater than 30 tons/hr where: E = Emission in Pounds per hour. P = Process weight rate in tons per hour. Unit S Filler feed: 1,141 tons/day (47.54 tons/hr) E = (47.54)

27 = lb PM/hr ( lb PM/day) Assuming PM10 is 0.5 PM, the above value greatly exceeds the DEL (0.3 lb PM10/day) calculated in the calculations section above. Unit S Coating asphalt, sealant asphalt, laminate adhesive asphalt feed: 657 tons/day (27.38 tons/hr) E = 3.59 (27.35) 0.62 = lb PM/hr (670.7 lb PM/day) Assuming PM10 is 0.5 PM, the above value greatly exceed the DEL (21.0 lb PMio/daY) calculated in the calculations section above. Continued compliance is expected. District Rule 4301 Fuel Burning Equipment This rule specifies maximum emission rates in lb/hr for SO2, NO2, and combustion contaminants (defined as total PM in Rule 1020). This rule also limits combustion contaminants to 0.1 gr/scf. According to AP-42 (Table 1.4-2, footnote c), all PM emissions from natural gas combustion are less than 1 gm in diameter. S District Rule 4301 Limits (lb/hr) Pollutant NO2 Total PM SO2 I lb/mmbtu x MMBtu/hr = x = x = Rule Limit The above table indicates compliance with the maximum lb/hr emissions in this rule; therefore, continued compliance is expected. Rule 4309 Dryers, Dehydrators, and Ovens The purpose of this rule is to limit emissions of oxides of nitrogen (N0x) and carbon monoxide (CO) from dryers, dehydrators, and ovens. This rule applies to any dryer, dehydrator, or oven that is fired on gaseous fuel, liquid fuel, or is fired on gaseous and liquid fuel sequentially, and the total rated heat input for the unit is 5.0 million British thermal units per hour (5.0 MMBtu/hr) or greater. Since the dryer being proposed for Unit S in this project has a heat input rating greater than 5.0 MMBtu, the dryer is subject to the requirements of this rule. Section 5.0, Requirements Section 5.0 states that all ppmv limits specified in this section are referenced at dry stack gas conditions and adjusted using an oxygen correction factor of 19% by volume. 26

28 Section 5.2 requires that except for dehydrators, NOx and CO emissions shall not exceed the limits specified in the table below on and after the full compliance schedules specified in Sections 7.1 and 7.3, as appropriate. All ppmv emission limits specified in this section are referenced at dry stack gas conditions and 19 percent by volume stack gas oxygen. Emission concentrations shall be corrected to 19 percent oxygen in accordance with Section 5.0. NOx and CO Limits Process Description NO Limit (in ppmv) CO Limit in ppmv) Gaseous Fuel Fired Liquid Fuel Fired Gaseous Fuel Fired Liquid Fuel Fired Asphalt/Concrete Plants Milk, Cheese, and Dairy Processing <20 MMBtu/hr Milk, Cheese, and Dairy Processing 20 MMBtu/hr Other processes not described above The unit being proposed in this project is part of an asphaltic felts and coating operation. The facility receives hot asphalt from asphalt manufacturing plants; therefore, it is not considered to be an asphalt plant; therefore, it is subject to the requirements of the Other Processes Not Describe Above category listed in the table above. For the unit: the proposed NO emission factor is % 02 the proposed CO emission factor is 42 19% 02 Therefore, compliance with this section is expected. A permit condition listing the emissions limits will be listed on the permit as shown in the DEL section above. Section 5.3 states that the applicable emission limits in Section 5.2 shall not apply during startup or shutdown provided an operator complies with the requirements specified below. The facility has not requested relaxed emission limit requirements for their unit during startup or shutdown, therefore this section does not apply to the unit in this project. Section 5.4, Monitoring Requirements Section states that except for dehydrators, the operator of any unit subject to the applicable emission limits in Sections 4.3.2, or 5.2 shall monitor emissions using one of the techniques specified in Sections or Section states the first technique as the installation and maintenance of an APC0- approved CEMS for NOx, and oxygen that meets the following requirements. 27

29 40 CFR Part 51, and 40 CFR Parts 60.7 and (except subsection h), and 40 CFR Part 60 Appendix B (Performance Specifications), and 40 CFR Part 60 Appendix F (Quality Assurance Procedures), and The applicable provisions of District Rule 1080 (Stack Monitoring). The APCO shall only approve CEMS that meets the requirements of Sections through of this rule. Section states the second technique as the installation and maintenance of an alternate emissions monitoring method that meets the requirements of Sections through of this rule. Section states that the APCO shall not approve an alternative monitoring system unless it is documented that continued operation within ranges of specified emissionsrelated performance indicators or operational characteristics provides a reasonable assurance of compliance with applicable emission limits. Section states that the approved alternate emission monitoring system shall monitor operational characteristics necessary to assure compliance with the emission limit. Operational characteristics shall be one or more of the following: Periodic NOx exhaust emission concentrations, Periodic exhaust oxygen concentration, Flow rate of reducing agent added to exhaust, Catalyst inlet and exhaust temperature, Catalyst inlet and exhaust oxygen concentration, Periodic flue gas recirculation rate, Other surrogate operating parameter(s) that demonstrate compliance with the emission limit. Since the operation of the units subject to this rule are very similar to the operation of the units subject to the requirements of District Rule 4306, Boilers, Steam Generators, and Process Heaters Phase 3, the pre-approved alternate monitoring plans in District Policy SSP-1105 will be considered approved alternate monitoring plans for District Rule 4309 compliance. In order to satisfy the requirements of District Rule 4309, the applicant has proposed to use pre-approved alternate monitoring scheme A (pursuant to District Policy SSP-1105), which requires that monitoring of NOx, CO, and 02 exhaust concentrations shall be conducted at least once per month (in which a source test is not performed) using a portable analyzer. The following conditions will be incorporated into the permit in order to ensure compliance with the requirements of the proposed alternate monitoring plan: The permittee shall monitor and record the stack concentration of NON, CO, and 02 at least once every month (in which a source test is not performed) using a portable emission monitor that meets District specifications. Monitoring shall not be required if 28

30 the unit is not in operation, i.e. the unit need not be started solely to perform monitoring. Monitoring shall be performed within 5 days of restarting the unit unless monitoring has been performed within the last month. [District Rule 4309] If either the NOx or CO concentrations corrected to 19% 02, as measured by the portable analyzer, exceed the allowable emissions concentration, the permittee shall return the emissions to within the acceptable range as soon as possible, but no longer than 1 hour of operation after detection. If the portable analyzer readings continue to exceed the allowable emissions concentration after 1 hour of operation after detection, the permittee shall notify the District within the following 1 hour and conduct a certified source test within 60 days of the first exceedance. In lieu of conducting a source test, the permittee may stipulate a violation has occurred, subject to enforcement action. The permittee must then correct the violation, show compliance has been reestablished, and resume monitoring procedures. If the deviations are the result of a qualifying breakdown condition pursuant to Rule 1100, the permittee may fully comply with Rule 1100 in lieu of the performing the notification and testing required by this condition. [District Rule 4309] All alternate monitoring parameter emission readings shall be taken with the unit operating either at conditions representative of normal operations or conditions specified in the Permit to Operate. The analyzer shall be calibrated, maintained, and operated in accordance with the manufacturer's specifications and recommendations or a protocol approved by the APCO. Emission readings taken shall be averaged over a 15 consecutive-minute period by either taking a cumulative 15 consecutive-minute sample reading or by taking at least five (5) readings, evenly spaced out over the 15 consecutive-minute period. [District Rule 4309] The permittee shall maintain records of: (1) the date and time of NOx, CO, and 02 measurements, (2) the 02 concentration in percent and the measured NO and CO concentrations corrected to 19% 02, (3) make and model of exhaust gas analyzer, (4) exhaust gas analyzer calibration records, and (5) a description of any corrective action taken to maintain the emissions within the acceptable range. [District Rule 4309] Section 5.5, Compliance Determination Section states that all emissions measurements shall be made with the unit operating either at conditions representative of normal operations or conditions specified in the PTO. Section states that except for as provided in Section 5.5.3, no determination of compliance shall be established within two hours after a continuous period in which fuel flow to the unit is shut off for 30 minutes or longer, or within 30 minutes after a re-ignition as defined in Section 3.0. The following condition will be added to the permit to assure compliance with Sections and All emissions measurements shall be made with the unit operating either at conditions representative of normal operations or conditions specified in the Permit to Operate. No 29

31 determination of compliance shall be established within two hours after a continuous period in which fuel flow to the unit is shut off for 30 minutes or longer, or within 30 minutes after a re-ignition as defined in Section 3.0 of District Rule [District Rule 4309] Section states that notwithstanding the requirements of Section 5.5.2, the APCO, ARB, and US EPA may approve a longer or shorter period before compliance determination, if an operator submits an application for a PTO condition which provides a justification for the requested duration. Section states that all CEMS emissions measurements shall be averaged over a period of 15 consecutive minutes to demonstrate compliance with the applicable emission limits of this rule. Any 15-consecutive-minute block average CEMS measurement exceeding the applicable emission limits of this rule shall constitute a violation of this rule. The facility has not proposed to utilize a CEMS; therefore the requirements of this section are not applicable to the dryer in this project. Section states that for emissions monitoring pursuant to Section , emission readings shall be averaged over a 15 consecutive-minute period by either taking a cumulative 15-consecutive-minute sample reading or by taking at least five (5) readings evenly spaced out over the 15-consecutive-minute period. The following condition will be added to the permit to assure compliance with this section. All alternate monitoring parameter emission readings shall be taken with the unit operating either at conditions representative of normal operations or conditions specified in the permit-to-operate. The analyzer shall be calibrated, maintained, and operated in accordance with the manufacturer's specifications and recommendations or a protocol approved by the APCO. Emission readings taken shall be averaged over a 15 consecutive-minute period by either taking a cumulative 15 consecutive-minute sample reading or by taking at least five (5) readings, evenly spaced out over the 15 consecutive-minute period. [District Rule 4309] Section states that for emissions source testing performed pursuant to Section to determine compliance with an applicable emission limit of this rule, the arithmetic average of three (3) 30-consecutive-minute test runs shall apply. If two of the three runs individually demonstrate emissions above the applicable limit, the test cannot be used to demonstrate compliance for the unit, even if the averaged emissions of all three test runs is less than the applicable limit. The following condition will be added to the permit to assure compliance with this section. For emissions source testing, the arithmetic average of three 30-consecutive-minute test runs shall apply. If two of three runs are above an applicable limit the test cannot be used to demonstrate compliance with an applicable limit. [District Rule 4309] 30

32 Section 6.1, Recordkeeping Section states the recordkeeping requirements of a unit that uses CEMS to monitor emissions. Since the applicant has not proposed a CEMS to monitor emissions, the requirements of this section do not apply to the unit in this project. Section states that operators using an alternate emissions monitoring system shall maintain the following records on a periodic basis: Total hours of operation. Type and quantity of fuel used during operations. Measurement for each surrogate parameter. Range of allowed values for each surrogate parameter. The period for recordkeeping shall be specified in the PTO conditions. Section only applies to dehydrators; therefore this section is not applicable to the unit in this project. Section states that the operator of a unit subject to Section 5.2 and performing start-up or shutdown of that unit shall keep records of the duration of each start-up and each shutdown. The facility has not proposed start-up or shutdown emissions for the dryer in this operation; therefore the requirements of this section do not apply to the dryer in this project. Section states the recordkeeping requirements of an operator of any unit operated under the exemption of Section 4.3. Since the applicant has not applied for the exemption in Section 4.3, the requirements in this section do not apply to the dryer in this project. Section states the records and manufacturer's specifications required by Sections through shall meet all of the following requirements. The records shall be maintained for five (5) calendar years, The records shall be made available on-site during normal business hours, and The records shall be submitted to the APCO upon request. The following condition will be added to the permit to assure compliance with this section. All records shall be maintained and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rules 1070 and 4309] Section 6.2, Test Methods Section 6.2 lists the test methods required by the rule. In lieu of the test methods listed below the facility can utilize alternative APCO and US EPA approved test methods. 31

33 Fuel hhv Pollutant Units Test Method Required Fuel hhv shall be certified by third party fuel supplier or: Liquid fuels ASTM D or D Gaseous fuels ASTM D or D in conjunction with ASTM D NO ppmv EPA Method 7E or ARB Method 100 CO ppmv EPA Method 10 or ARB Method 100 Stack Gas 02 % EPA Method 3 or 3A, or ARB Method 100 Stack Gas Velocities ft/min EPA Method 2 Stack Gas Moisture Content ok EPA Method 4 The following permit conditions will be listed on the permit as follows: NO emissions for source test purposes shall be determined using EPA Method 7E or ARB Method 100 on a ppmv basis. [District Rule 4309] CO emissions for source test purposes shall be determined using EPA Method 10 or ARB Method 100. [District Rule 4309] Stack gas oxygen (02) shall be determined using EPA Method 3 or 3A or ARB Method 100. [District Rule 4309] Section states that each unit subject to the requirements in Sections 4.3, or 5.2 shall be initially source tested to determine compliance with the applicable emission limits not later than the applicable full compliance schedule specified in Section 7.0. Thereafter, each unit subject to Section 5.2 emission limits shall be source tested at least once every 24 months. Units subject to Section 5.2 and operating less than 50 days per calendar year shall follow the source test frequency prescribed in Section The following condition will be added to the permit to assure compliance with this section. Source testing to measure NOx and CO emissions from this unit when fired on natural gas shall be conducted within 60 days of initial start-up and at least once every 24 months thereafter. [District Rules 2201 and 4309] Section states that the APCO shall be notified according to the provisions of Rule 1081 (Source Sampling). The following conditions will be added to the permit to assure compliance with this section. (109) Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 1081] 32

34 The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1081] GAF Section states that emissions source testing shall be conducted with the unit operating either at conditions representative of normal operations or conditions specified in the PTO. The requirements of this section will be satisfied by the condition listed in Sections and of this rule evaluation. Section states that all test results for NOx and CO shall be reported in ppmv, corrected to dry stack conditions and adjusted using the oxygen correction factor. The following condition will be added to the permit to assure compliance with this section. All test results for NOx and CO shall be reported in 19% 02, corrected to dry stack conditions. [District Rule 4309] Section states that for the purpose of determining compliance with an applicable emission limit, the arithmetic average of three (3) 30-consecutive-minute test runs shall apply. Section states that if two of the three runs specified by Section individually demonstrate emissions above the applicable limit, the test cannot be used to demonstrate compliance for the unit, even if the averaged emissions of all three runs is less than the applicable limit. The requirements of Sections and will be satisfied by the condition listed in Section of this rule evaluation. Section 6.4 lists the source testing requirements for asphalt/concrete plants. Since this facility is not an asphalt or concrete plant, the requirements of this section do not apply to the dryer in this project. Rule 4801 Sulfur Compounds A person shall not discharge into the atmosphere sulfur compounds, which would exist as a liquid or gas at standard conditions, exceeding in concentration at the point of discharge: 0.2 % by volume calculated as SO 2, on a dry basis averaged over 15 consecutive minutes. The dryer will combust only PUC-regulated natural or propane with low sulfur content. Therefore compliance with District Rule 4801 requirements is expected. California Health & Safety Code (School Notice) California Health & Safety Code requires that the District prepare a school notice prior to approving an application for a permit to construct or modify a source that emits toxic air emissions which is located within 1,000 feet from the outer boundary of a K-12 school site. Since this project is not located within 1,000 feet from the outer boundary of a K-12 school site, a school notice is not required. 33

35 California Environmental Quality Act (CEQA) CEQA requires each public agency to adopt objectives, criteria, and specific procedures consistent with CEQA Statutes and the CEQA Guidelines for administering its responsibilities under CEQA, including the orderly evaluation of projects and preparation of environmental documents. The District adopted its Environmental Review Guidelines (ERG) in The basic purposes of CEQA are to: Inform governmental decision-makers and the public about the potential, significant environmental effects of proposed activities; Identify the ways that environmental damage can be avoided or significantly reduced; Prevent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible; and Disclose to the public the reasons why a governmental agency approved the project in the manner the agency chose if significant environmental effects are involved. Greenhouse Gas (GHG) Significance Determination District is a Lead Agency & GHG emissions increases are from the combustion of fossil fuel other than let fuels It is determined that no other agency has prepared or will prepare an environmental review document for the project. Thus the District is the Lead Agency for this project. On December 17, 2009, the District's Governing Board adopted a policy, APR 2005, Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency, for addressing GHG emission impacts when the District is Lead Agency under CEQA and approved the District's guidance document for use by other agencies when addressing GHG impacts as lead agencies under CEQA. Under this policy, the District's determination of significance of project-specific GHG emissions is founded on the principal that projects with GHG emission reductions consistent with AB 32 emission reduction targets are considered to have a less than significant impact on global climate change. Consistent with District Policy 2005, projects complying with an approved GHG emission reduction plan or GHG mitigation program, which avoids or substantially reduces GHG emissions within the geographic area in which the project is located, would be determined to have a less than significant individual and cumulative impact for GHG emission. The California Air Resources Board (ARB) adopted a Cap-and-Trade regulation as part one of the strategies identified for AB 32. This Cap-and-Trade regulation is a statewide plan, supported by a CEQA compliant environmental review document, aimed at reducing or mitigating GHG emissions from targeted industries. Facilities subject to the Cap-and-Trade regulation are subject to an industry-wide cap on overall GHG emissions. Any growth in emissions must be accounted for under that cap such that a corresponding and equivalent reduction in emissions must occur to allow any increase. Further, the cap decreases over time, resulting in an overall decrease in GHG emissions. 34

36 5-2033, Under District policy APR 2025, CEQA Determinations of Significance for Projects Subject to APB's GHG Cap-and-Trade Regulation, the District finds that the Cap-and- Trade is a regulation plan approved by ARB, consistent with AB32 emission reduction targets, and supported by a CEQA compliant environmental review document. As such, consistent with District Policy 2005, projects complying project complying with Cap-and- Trade requirements are determined to have a less than significant individual and cumulative impact for GHG emissions. The GHG emissions increases associated with this project result from the combustion of fossil fuel(s), other than jet fuel, delivered from suppliers subject to the Cap-and-Trade regulation. Therefore, as discussed above, consistent with District Policies APR 2005 and APR 2025, the District concludes that the GHG emissions increases associated with this project would have a less than significant individual and cumulative impact on global climate change. District CEQA Findings The District is the Lead Agency for this project because there is no other agency with broader statutory authority over this project. The District performed an Engineering Evaluation (this document) for the proposed project and determined that the activity will occur at an existing facility and the project involves negligible expansion of the existing use. Furthermore, the District determined that the activity will not have a significant effect on the environment. The District finds that the activity is categorically exempt from the provisions of CEQA pursuant to CEQA Guideline (Existing Facilities), and finds that the project is exempt per the general rule that CEQA applies only to projects which have the potential for causing a significant effect on the environment (CEQA Guidelines 15061(b)(3)). IX. Recommendation Compliance with all applicable rules and regulations is expected. Issue ATC and ' subject to the permit conditions on the attached draft ATCs in Attachment VIII. X. Billing Information Annual Permit Fees Permit Number Fee Schedule Fee Description Annual Fee S G MMBtu/hr $815 S E 200 hp $412 35

37 Attachments I: Current PTOs and ATC II: Process Flow Diagram III: Emissions Profiles IV: BACT Guidelines Used as Basis in Project Specific BACT Analysis V: BACT Analysis VI: HRA/AAQA VII: Statewide Compliance Statement and Title V Compliance Certification Form VIII: Draft ATCs 36

38 ATTACHMENT I Current PTOs and ATC GAF

39 San Joaquin Valley Air Pollution Control District PERMIT UNIT: EXPIRATION DATE: 04/30/2017 SECTION: 15 TOWNSHIP: 28S RANGE: 26E EQUIPMENT DESCRIPTION: FILLER HEATING OPERATION WITH A FILLER RECEIVING BIN AND TWO HOT BINS SERVED BY DUST COLLECTOR (DC-7) WHIRL AIR FLOW MODEL BIN VENT FILTER(SHARED BY S ), AND DUST COLLECTOR (DC-5) ULTRA INDUSTRIES MODEL BB (SHARED BY S ); THERMAL FLUID HEAT FROM TWO HEATERS (S AND S ) SERVED BY FAN DUST COLLECTOR (DC-8) ULTRA INDUSTRIES MODEL BB IIIG; ROTARY FEEDERS; AND METERING SCREW CONVEYORS FEEDING CONTINUOUS MIXERS PERMIT UNIT REQUIREMENTS 1. All equipment shall be constructed, maintained and operated according to the specifications and plans contained in the permit application except as otherwise specified herein. [District Rule 2201] Federally Enforceable Through Title V Permit 2. The APCO or any authorized representative, upon request, shall have access to inspect any equipment, operation, or method required in this permit, and to sample emissions from the source or require samples to be taken. [District Rule 1081] Federally Enforceable Through Title V Permit 3. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 1081] Federally Enforceable Through Title V Permit 4. Dust collectors shall be maintained and operated according to manufacturers' recommendations. [District Rule 2201] Federally Enforceable Through Title V Permit 5. All conveyors shall be enclosed. [District Rule 2201] Federally Enforceable Through Title V Permit 6. There shall be no visible emissions greater than 0% opacity from mineral conveying, handling, and storage. [District Rule 2201and 40 CFR ] Federally Enforceable Through Title V Permit 7. Visible emissions from dust collectors DC-7 and DC-8 serving the filler heating operation shall not equal or exceed 5% opacity for a period or periods aggregating more than three minutes in one hour. [District Rule 2201] Federally Enforceable Through Title V Permit 8. Maximum particulate matter (PM10) emission rate from dust collector DC-8 shall not exceed lb per ton of filler material processed. [District Rule 2201] Federally Enforceable Through Title V Permit 9. Total facility filler material process rate shall not exceed 1141 tons/day without prior District approval. [District Rule 2201] Federally Enforceable Through Title V Permit 10. Compliance source testing with PM10 emission rate(s) shall be demonstrated within 60 days upon detection of visible emissions greater than 5% opacity from the dust collector(s) exhaust. [District Rule 1070] 11. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1070] 12. The APCO or authorized representative shall have the authority to require mitigation of toxic emissions if total facility health risks are determined to be significant pursuant to Air Toxics "Hot Spot" Information and Assessment Act of [District Rule 2201] Federally Enforceable Through Title V Permit Facility Name: ELK CORPORATION OF TEXAS Location: 6200 ZERKER RO,SHAFTER, CA : No AM - ECK1EHILR PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

40 Permit Unit Requirements for S (continued) Page 2 of Material removed from dust collector(s) shall be disposed of in a manner preventing visible emissions in excess of 0% opacity into the atmosphere. [District Rule 2201] Federally Enforceable Through Title V Permit 14. Method 9 and the procedures in 40 CFR shall be used to measure opacity. [40 CFR ] Federally Enforceable Through Title V Permit 15. Permittee shall maintain accurate daily records of filler material process rate and such records shall be made readily available for District inspection upon request for a period of five years. [District Rule 1070] Facility Name: ELK CORPORATION OF TEXAS Location: 6200 ZERKER RD,SHAFTER, CA S : Nov :65M1 EDGEHILR These terms and conditions are part of the Facility-wide Permit to Operate.

41 San Joaquin Valley Air Pollution Control District PERMIT UNIT: S EXPIRATION DATE: 04/30/2017 SECTION: 15 TOWNSHIP: 28S RANGE: 26E EQUIPMENT DESCRIPTION: ASPHALT ROOFING SHINGLE COATING OPERATION WITH MACHINE LINE FUME COLLECTION SYSTEM VENTED TO HIGH VELOCITY AIR FILTER (FCS-1) PERMIT UNIT REQUIREMENTS I. All equipment shall be constructed, maintained and operated according to the specifications and plans contained in the permit application except as otherwise specified herein. [District Rule 2201] Federally Enforceable Through Title V Permit 2. Sampling facilities for source testing shall be provided in accordance with the provisions of Rule 1081 (Source Sampling). [District Rule 1081] Federally Enforceable Through Title V Permit 3. Operation shall include Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 with 200 hp exhaust blower. [District Rule 2201] Federally Enforceable Through Title V Permit 4. Operation shall include two continuous mixers, 4000 gallon surge tank with agitator, filled coating applicator, sealdown applicator with three 2000 gallon sealdown storage and mix tanks served by high velocity air filter FCS-I. [District Rule 2201] Federally Enforceable Through Title V Permit 5. Operation shall include laminator sealdown applicator, laminator adhesive applicator, and five 250 gallon use tanks served by high velocity air filter FCS-1. [District Rule 2201] Federally Enforceable Through Title V Permit 6. Operation shall include oil pump and 1000 gallon reclaim oil storage tank. [District Rule 2201] Federally Enforceable Through Title V Permit 7. Continuous temperature monitoring equipment (with accuracy of degrees Celsius over its range) shall be installed at inlet of high velocity air filter. [District Rule 2201] Federally Enforceable Through Title V Permit 8. Continuous temperature monitoring results shall be maintained for District inspection upon request for at least five years. [District Rule 1070] 9. Each tank roof appurtenance shall be maintained leak-free (no reading in excess of 10,000 ppm as methane measured at a distance of one centimeter from the source). [District Rule 4623] Federally Enforceable Through Title V Permit 10. Maximum flow rate through high velocity air filter FCS-1 shall not exceed 25,200 acfm. Flow control damper shall be maintained at setting shown to demonstrate compliance with flow limit during source testing. [District Rule 2201] Federally Enforceable Through Title V Permit 11. Visible emissions shall not exceed 1/4 Ringelmann or 5% opacity. [District Rule 2201] Federally Enforceable Through Title V Permit 12. Particulate matter emissions shall not exceed 0.08 lb/ton of asphalt shingle produced. [40 CFR ] Federally Enforceable Through Title V Permit 13. Emission rate from shingle coating operation shall not exceed: PM10: 0.88 lb/hr and 6638 lb/yr, and VOC: 5.04 lb/hr and 37,996 lb/yr. [District Rule 2201] Federally Enforceable Through Title V Permit PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: ELK CORPORATION OF TEXAS Location: 6200 ZERKER RD,SHAFTER, CA : Nov AM EDGEKILR

42 Permit Unit Requirements for S (continued) Page 2 of Total quantity of coating asphalt, sealant asphalt, and laminate adhesive asphalt introduced to asphalt roofing shingle coating operation (S ) shall not exceed 657 tons/day and 206,500 tons/yr. [District Rule 2201] Federally Enforceable Through Title V Permit 15. Source testing to demonstrate compliance with PM10 and VOC emission limits shall be conducted not less than once every 12 months, except as provided below. [District Rule 1070] 16. Source testing to demonstrate compliance with PM 10 and VOC emission limits shall be conducted not less than once every 36 months if compliance is demonstrated on two consecutive annual tests. [District Rule 1070] 17. If permittee fails any compliance demonstration for PMIO and VOC emission limits when testing not less than once every 36 months, compliance with PMIO and VOC emission limits shall be demonstrated not less than once every 12 months. [District Rule 1070] 18. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 1081] Federally Enforceable Through Title V Permit 19. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1070] 20. The APCO or authorized representative shall have the authority to require mitigation of toxic emissions if total facility health risks are determined to be significant pursuant to Air Toxics "Hot Spot" Information and Assessment Act of [District Rule 2201] Federally Enforceable Through Title V Permit 21. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be equipped with a differential pressure monitor to continuously indicate and record the pressure drop across the filter media. [40 CFR 64.3] Federally Enforceable Through Title V Permit 22. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall operate with a minimum differential pressure of 0 inches water column and a maximum differential pressure of 27 inches water column. These parameters shall be reviewed annually and revised if necessary based on PM 10 source test result data, historical npernting riata And manufacturer/cupplier reenmmentintinng f4.ficer Ferirrally Pninrceable Through Title v Permit 23. During each day of operation, the permittee shall record the differential pressure of the Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 and compare the readings with the permitted range. If the baghouses' differential pressure falls outside the permitted range, the permittee shall take all necessary steps to return the baghouses' differential pressure to within the permitted range as soon as possible, but no longer than three hours after detection. If the differential pressure cannot be returned within the permitted range after three hours of operation following detection, the permittee shall shut the operation down and make all necessary repairs to bring the differential pressure back to with the permitted range. [40 CFR Part 64] Federally Enforceable Through Title V Permit 24. Fabric collection system of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be completely inspected annually while in operation for evidence of particulate matter breakthrough and shall be repaired as needed. [District Rule 2201] Federally Enforceable Through Title V Permit 25. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be completely inspected annually while not in operation for tears, scuffs, abrasives or holes which might interfere with PM collection efficiency and shall be replaced as needed. [District Rule 2201] Federally Enforceable Through Title V Permit 26. Visible emissions from Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS- I shall be evaluated using EPA Method 22 for a period of at least 6 minutes at least once per each week the dust collector is operated. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. Corrective action shall include the following: inspecting the dust collection system for any tears, abrasions, or holes in the filters; inspecting closed duct systems for damage; and repairing or replacing any defective or damaged material. [40 CFR 64] Federally Enforceable Through Title V Permit Facility Name: ELK CORPORATION OF TEXAS Location: 6200 ZERKER RO,SHAFTER, CA AI Nov AM FOGEHILR PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

43 Permit Unit Requirements for S (continued) Page 3 of The industry is exempted from the quarterly reports required under 40 CFR During performance testing, the operating temperature of the high velocity air filters shall be recorded and reported as required by 40 CFR 60.7 (d). Facility shall maintain a file of temperature monitoring results for at least 5 years. [40 CFR ] Federally Enforceable Through Title V Permit 28. For saturators, performance tests required under 40 CFR 60.8 shall conducted using procedures in 40 CFR (a)- (c). [40 CFR ] Federally Enforceable Through Title V Permit 29. Method 9 and the procedures in 40 CFR 60.1Ishall be used to measure opacity. [40 CFR ] Federally Enforceable Through Title V Permit 30. The administrator shall determine compliance with the standards in CFR (a)(3) by using Method 22, modified so that readings are recorded every 15 seconds for a period of consecutive observations during representative conditions (in accordance with 40 CFR 60.8 (c) totalling 60 minutes. A performance test shall consist of one run. [40 CFR ] Federally Enforceable Through Title V Permit 31. The owner and operator shall use the monitoring device in (a) to monitor and record continuously the temperature during the particulate matter run and shall report the results to the Administrator with the performance test results. [40 CFR ] Federally Enforceable Through Title V Permit 32. Records of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 maintenance, inspection, and repairs shall be maintained. The records shall include identification of equipment, date of inspection, corrective action taken, and identification of individual performing inspection. [District Rule 1070] 33. The permittee shall comply with the recordkeeping and reporting requirements of 40 CFR part [40 CFR 64.9] Federally Enforceable Through Title V Permit 34. Permittee shall maintain daily records of asphalt process rate and temperature monitoring results, and shall make such records readily available for District inspection upon request for a period of five years. [District Rule 1070] Facility Name: ELK CORPORATION OF TEXAS Location: 8200 ZERKER RD.SHAFTER, CA Nov :S EDGE1411-R These terms and conditions are part of the Facility-wide Permit to Operate.

44 AUTHORITY TO CONSTRUCT PERMIT NO: S ISSUANCE DATE: 07/16/2014 LEGAL OWNER OR OPERATOR: MAILING ADDRESS: LOCATION: ELK CORPORATION OF TEXAS 6200 ZERKER RD SHAFTER, CA ZERKER RD SHAFTER, CA SECTION: 15 TOWNSHIP: 28S RANGE: 26E EQUIPMENT DESCRIPTION: MODIFICATION OF ASPHALT ROOFING SHINGLE COATING OPERATION WITH MACHINE LINE FUME COLLECTION SYSTEM VENTED TO HIGH VELOCITY AIR FILTER (FCS-1): REPLACE CONTINUOUS MIXERS CONDITIONS 1. The facility shall submit an application to modify the Title V permit in accordance with the timeframes and procedures of District Rule [District Rule 2520] Federally Enforceable Through Title V Permit 2. All equipment shall be constructed, maintained and operated according to the specifications and plans contained in the permit application except as otherwise specified herein. [District Rule 2201] Federally Enforceable Through Title V Permit 3. Sampling facilities for source testing shall be provided in accordance with the provisions of Rule 1081 (Source Sampling). [District Rule 1081] Federally Enforceable Through Title V Permit 4. Operation shall include Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 with 200 hp exhaust blower. [District Rule 2201] Federally Enforceable Through Title V Permit 5. Operation shall include one continuous mixer, 4000 gallon surge tank with agitator, filled coating applicator, sealdown applicator with three 2000 gallon sealdown storage and mix tanks served by high velocity air filter FCS-1. [District Rule 2201] Federally Enforceable Through Title V Permit 6. Operation shall include laminator sealdown applicator, laminator adhesive applicator, and five 250 gallon use tanks served by high velocity air filter FCS-1. [District Rule 2201] Federally Enforceable Through Title V Permit CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (661) WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations of all other governmental agencies which may pertain to the above equipment. Seyed Sadredin, Executive Director / APCO Arnaud Marjollet, Director of Permit Services : Nov :50AM EOGEHILR : Joint Inspection NOT Requital:I Southern Regional Office Flyover Court Bakersfield, CA (661) Fax (661)

45 Conditions for S (continued) Page 2 of 3 7. Operation shall include oil pump and 1000 gallon reclaim oil storage tank. [District Rule Federally Enforceable Through Title V Permit 8. Continuous temperature monitoring equipment (with accuracy of degrees Celsius over its range) shall be installed at inlet of high velocity air filter. [District Rule 2201] Federally Enforceable Through Title V Permit 9. Continuous temperature monitoring results shall be maintained for District inspection upon request for at least five years. [District Rule 1070] 10. Each tank roof appurtenance shall be maintained leak-free (no reading in excess of 10,000 ppm as methane measured at a distance of one centimeter from the source). [District Rule 4623] Federally Enforceable Through Title V Permit 11. Maximum flow rate through high velocity air filter FCS-1 shall not exceed 25,200 acfin. Flow control damper shall be maintained at setting shown to demonstrate compliance with flow limit during source testing. [District Rule 2201] Federally Enforceable Through Title V Permit 12. Visible emissions shall not exceed 1/4 Ringelmann or 5% opacity. [District Rule 2201] Federally Enforceable Through Title V Permit 13. Particulate matter emissions shall not exceed 0.08 lb/ton of asphalt shingle produced. [40 CFR ] Federally Enforceable Through Title V Permit 14. Emission rate from shingle coating operation shall not exceed: PM10: 0.88 lb/hr and 6638 lb/yr, and VOC: 5.04 lb/hr and 37,996 lb/yr. [District Rule 2201] Federally Enforceable Through Title V Permit 15. Total quantity of coating asphalt, sealant asphalt, and laminate adhesive asphalt introduced to asphalt roofing shingle coating operation (S ) shall not exceed 657 tons/day and 206,500 tons/yr. [District Rule 2201] Federally Enforceable Through Title V Permit 16. Source testing to demonstrate compliance with PM10 and VOC emission limits shall be conducted not less than once every 12 months, except as provided below. [District Rule 1070] 17 Somme testing to demonstrate compliance with PM111 anti VOC emission limits shall bp ooncincterl not lesc.than.once every 36 months if compliance is demonstrated on two consecutive annual tests. [District Rule 1070] 18. If permittee fails any compliance demonstration for PM10 and VOC emission limits when testing not less than once every 36 months, compliance with PMIO and VOC emission limits shall be demonstrated not less than once every 12 months. [District Rule 1070] 19. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 1081] Federally Enforceable Through Title V Permit 20. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1070] 21. The APCO or authorized representative shall have the authority to require mitigation of toxic emissions if total facility health risks are determined to be significant pursuant to Air Toxics "Hot Spot" Information and Assessment Act of [District Rule 2201] Federally Enforceable Through Title V Permit 22. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS- I shall be equipped with a differential pressure monitor to continuously indicate and record the pressure drop across the filter media. [40 CFR 64.3] Federally Enforceable Through Title V Permit 23. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall operate with a minimum differential pressure of 0 inches water column and a maximum differential pressure of 27 inches water column. These parameters shall be reviewed annually and revised if necessary based on PM10 source test result data, historical operating data and manufacturer/supplier recommendations. [40 CFR 64.3] Federally Enforceable Through Title V Permit D N RESAM - DGEHILA CONDITIONS CONTINUE ON NEXT PAGE

46 Conditions for S (continued) Page 3 of During each day of operation, the permittee shall record the differential pressure of the Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 and compare the readings with the permitted range. If the baghouses' differential pressure falls outside the permitted range, the permittee shall take all necessary steps to return the baghouses' differential pressure to within the permitted range as soon as possible, but no longer than three hours after detection. If the differential pressure cannot be returned within the permitted range after three hours of operation following detection, the permittee shall shut the operation down and make all necessary repairs to bring the differential pressure back to with the permitted range. [40 CFR Part 64] Federally Enforceable Through Title V Permit 25. Fabric collection system of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be completely inspected annually while in operation for evidence of particulate matter breakthrough and shall be repaired as needed. [District Rule 2201] Federally Enforceable Through Title V Permit 26. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-I shall be completely inspected annually while not in operation for tears, scuffs, abrasives or holes which might interfere with PM collection efficiency and shall be replaced as needed. [District Rule 2201] Federally Enforceable Through Title V Permit 27. Visible emissions from Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be evaluated using EPA Method 22 for a period of at least 6 minutes at least once per each week the dust collector is operated. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. Corrective action shall include the following: inspecting the dust collection system for any tears, abrasions, or holes in the filters; inspecting closed duct systems for damage; and repairing or replacing any defective or damaged material. [40 CFR 64] Federally Enforceable Through Title V Permit 28. The industry is exempted from the quarterly reports required under 40 CFR During performance testing, the operating temperature of the high velocity air filters shall be recorded and reported as required by 40 CFR 60.7 (d). Facility shall maintain a file of temperature monitoring results for at least 5 years. [40 CFR ] Federally Enforceable Through Title V Permit 29. For saturators, performance tests required under 40 CFR 60.8 shall conducted using procedures in 40 CFR (a)- (c). [40 CFR ] Federally Enforceable Through Title V Permit 30. Method 9 and the procedures in 40 CFR shall be used to measure opacity. [40 CFR ] Federally Enforceable Through Title V Permit 31. The administrator shall determine compliance with the standards in CFR (a)(3) by using Method 22, modified so that readings are recorded every 15 seconds for a period of consecutive observations during representative conditions (in accordance with 40 CFR 60.8 (c) totaling 60 minutes. A performance test shall consist of one run. [40 CFR ] Federally Enforceable Through Title V Permit 32. The owner and operator shall use the monitoring device in (a) to monitor and record continuously the temperature during the particulate matter run and shall report the results to the Administrator with the performance test results. [40 CFR ] Federally Enforceable Through Title V Permit 33. Records of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 maintenance, inspection, and repairs shall be maintained. The records shall include identification of equipment, date of inspection, corrective action taken, and identification of individual performing inspection. [District Rule 1070] 34. The permittee shall comply with the recordkeeping and reporting requirements of 40 CFR part [40 CFR 64.9] Federally Enforceable Through Title V Permit 35. Pennittee shall maintain daily records of asphalt process rate and temperature monitoring results, and shall make such records readily available for District inspection upon request for a period of five years. [District Rule 1070] S : Nov AM EMERILR

47 ATTACHMENT II Process Diagram 38

48 ṠHAFTER SHINGLE PLANT PRE-PROJECT 6200 ZERKER ROAD VENT TO ATM. 11/10/2014 DC-7 DC-S FILLER HOT OIL TANK HEATEC HEATEC 4-1. WEST FILLER : HEATER _ RECEIVING BIN * EAST FILLER : HEATER HOT OIL JACKETS ON TANKS AND PIPING & ASPHALT HEAT EXCHANGER (HOT OIL RETURNS NOT SHOWN) VENT TO ATM DC-8 DISTRIBUTION HOPPER, CONVEYORS, BUCKET ELEVATORS, USE BINS, DISTRIBUTOR, GRANULE/BACKSURFACING APPLICATOR WEST HOT BIN METERING SCREW EAST HOT BIN METERING SCREW ASPHALT vi WEST MIXER EAST MIXER :4 ASPHALT SURGE TANK

49 SHAFTER SHINGLE PLANT POST-PROJECT 6200 ZERKER ROAD VENT TO ATM 11/10/2014 DC-7 DC-5 HOT OIL TANK HEATEC S HEATEC DC-10 FILLER RECEIVING BIN FLASH DRYER HOT OIL JACKETS ON TANKS AND PIPING & ASPHALT HEAT EXCHANGER (HOT OIL RETURNS NOT SHOWN) ONE HEATEC WILL BE IDLE TO ACT AS A STANDBY BACK-UP DISTRIBUTION HOPPER, CONVEYORS, BUCKET ELEVATORS, USE BINS, DISTRIBUTOR, GRANULE/BACKSURFACING APPLICATOR NEW STACK METERING SCREW EAST HOT BIN NEW MIXER ;4-- ASPHALT S SURGE TANK 4

50 ATTACHMENT III Emissions Profiles 39

51 SJVUAPCD Application Emissions 11/19/14 SOUTHERN 8:55 am Permit #: S Facility: ELK CORPORATION OF TEXAS Last Updated 11/14/2014 EDGEHILR Equipment Pre-Baselined: NO NOX SOX PM1 0 CO VOC Potential to Emit (lb/yr): Daily Emis. Limit (lb/day) Quarterly Net Emissions Change (lb/qtr) Q1: : Q3: Q4: Check if offsets are triggered but exemption applies N N N N N Offset Ratio Quarterly Offset Amounts (lb/qtr) Q1: Q2: Q3: Q4:

52 SJVUAPCD Application Emissions 11/19/14 SOUTHERN 8:55 am Permit #: S Facility: ELK CORPORATION OF TEXAS Last Updated 11/09/2014 EDGEHILR Equipment Pre-Baselined: NO NOX SOX PM10 CO VOC Potential to Emit (lb/yr): Daily Emis. Limit (lb/day l Quarterly Net Emissions Change (Ib/Qtr) Q1: Q2: Q3: Q4: Check if offsets are triggered but exemption applies N N N N N Offset Ratio Quarterly Offset Amounts (lb/qtr) Q1: Q2: Q3: Q4:

53 ATTACHMENT IV BACT Guidelines Used as the Basis for Project Specific BACT Analysis 40

54 San Joaquin Valley Unified Air Pollution Control District Best Available Control Technology (BACT) Guideline * Last Update: 8/4/1999 Dryer - Milk Spray, <20 MMBtu/hr Pollutant Achieved In Practice or contained in the SIP Technologically Feasible Alternate Basic Equipment PM1 0 Baghouse and natural gas fuel with LPG as backup fuel 20 ppmv Low NOx burner fired on natural gas with LPG as backup fuel 9 ppmv 3% 02 - Selective Catalytic Reduction, Low Temperature Oxidation, or equal. BACT is the most stringent control technique for the emissions unit and class of source. Control techniques that are not achieved In practice or contained in s a state implementation plan must be cost effective as well as feasible. Economic analysis to demonstrate cost effectiveness is required for all determinations that are not achieved in practice or contained in an EPA approved State Implementation Plan. *This is a Summary Page for this Class of Source

55 NOx 20 ppmv 3% 02 (low NOx burner) San Joaquin Valley Unified Air Pollution Control District Best Available Control Technology (BACT) Guideline * Last Update: 2/2/2001 Mineral Products Spray Dryer - Natural Gas Fired, < or = 20 MMBtu/hr Pollutant Achieved In Practice or Technologically Alternate Basic atnwca in tr as Eaulament 15 ppmv 02.(TcrJ 7 ritica burner) BACT Is the most stringent control technique for the emissions unit and class of source. Control techniques that are not achieved in practice or contained in s a state implementation plan must be cost effective as well as feasible. Economic analysis to demonstrate cost effectiveness Is required for all determinations that are not achieved in practice or contained in an EPA approved State Implementation Plan. *This is a Summary Page for this Class of Source

56 San Joaquin Valley Unified Air Pollution Control District Best Available Control Technology (BACT) Guideline 1.2.1* Last Update: 3/24/2014 Oilfield Steam Generator (> or =20 MMBtu/hr) Pollutant Achieved In Practice or Technologically Alternate Basic contained in the SIP Feasible Equipment SOx PM1 0 NOx Fired on PUC quality natural gas, commercial propane, and/or commercial LPG; or gaseous fuel treated to remove 95% by weight of sulfur compounds; or treated such that the sulfur content of all fuel streams combined does not exceed 1 gr of sulfur compounds (as S) per 100 dscf; or use of a continuously operating SO2 scrubber and either achieve 95% by weight control of sulfur compounds or achieve an emission rate of 9 ppmvd 3% 02 Fired on PUC quality natural gas, commercial propane, and/or commercial LPG; or gaseous fuel treated to remove 95% by weight of sulfur compounds; or treated such that the sulfur content of all fuel streams combined does not exceed 1 gr of sulfur compounds (as S) per 100 dscf; or use of a continuously operating SO2 scrubber and either achieve 95% by weight control of sulfur compounds or achieve an emission rate of 9 ppmvd 3% 02 Inas rated 85 MMBtu/hr and fired solely on PUC quality natural gas: 6 3% 02; or Units firing on a50% PUC quality natural gas; commercial propane; and/or LPG: 7 3% 02, except units rated 85 MMBtu/hr and fired solely on PUC quality natural gas; or Units firing on <50% PUC quality natural gas; commercial propane; and/or LPG: 9 3% % 02 CO 25 3%

57 ATTACHMENT V BACT Analysis NOx and VOC may be produced by both combustion and from impurities in the limestone. Applicant has stated that use of a dryer for the heating of limestone filler (replacing indirect heat transfer from hot oil ) is novel ( GAF, Insight Environmental Consultants meeting). As such, there are no current BACT Guidelines which are applicable and a proiect specific BACT analysis will be performed. Technologies from BACT Guideline for "Dryer-Milk Spray, <20 MMBtu/hr" (N0x), BACT Guideline "Mineral Products Spray Dryer-Natural Gas Fired, <20 MMBtu/hr (N0x) and BACT Guideline for Oil Field Steam Generators (VOCs) were considered in making this project specific BACT analysis. Top Down BACT Analysis NOx Emissions I. BACT Analysis for Dryer S direct-fired burner: a. Step 1 - Identify All Possible Control Technologies There is no applicable BACT Guideline for this class and category of equipment. The following control technologies have been identified: Natural gas fuel with NOx emission concentration of % 02 (target) and % 02 (worst case) with final limit established after first year of operation - Achieved-in-Practice 9 ppmv 3% 02 Selective Catalytic Reduction, Low Temperature Oxidation, or equal - Technologically feasible* *Equivalent to 1 19% 02 b. Step 2 - Eliminate Technologically Infeasible Options None of the above technologies are technologically infeasible. c. Step 3 - Rank Remaining Control Technologies by Control Effectiveness 9 ppmv 3% 02 Selective Catalytic Reduction, Low Temperature Oxidation, or equal Natural gas fuel with NOx emission concentration of % 02 (target) and % 02 (worst case) with final limit established after first year of operation - Achieved-in-Practice 41

58 d. Step 4 - Cost Effectiveness Analysis Step 4 - Cost Effectiveness Analysis The following cost estimates of installing and maintaining an SCR System w/ air prehe based on estimate provided by K. Slater at RE McDonald on 9/18/2014 Capital Costs: Cost Purchased Equipment Cost (PEC): SCR Preheater Instrumentation and process controls (10% of Equip.) Sub-total = Freight (2% of materials) Sales Tax (7.25% of materials) $175, $75, $250, $5, $18, TOTAL PEC $273, Direct Installation Costs (DIG): SCR Installation Burner Installation $75, $35, TOTAL DIG $110, TOTAL DIRECT COST (TDC) $383, Indirect costs (IC): PEC) Engineering (20% of PEC) Construction and field expenses (10% of Contractor fees (10% of PEC) Start-up expenses (4% of PEC) Performance tests (2% of PEC) TOTAL IC TBD TBD TBD TBD TBD $0.00 Contingency (20% of (TDC + IC)) (Cont.) $

59 TOTAL Capital Investment - TCI (PEC + DIC + IC + Cont.) $383, Pursuant to the District's BACT Policy, Section X, (Revised 4/18/95), the capital cost of the equipment will be amortized as follows. The cost will be spread over the expected life of the equipment which is estimated at 10 years and using the capital recovery equation (Equation 1). A 10% interest rate is assumed in this equation and the assumption will be made that the equipment has no salvage value at the end of the ten year cycle. Equation 1: A = [P * i(i + 1)An] / (i + 1)An -1 years) Where: A = annual cost P = Present Value i = Interest rate (10%) n = Equipment (10 Interest Rate % (i) Equipment Life (n) Present Value of Control Equipment (TCI) Amortized Capital Cost (ACC) 10 % 10 Years $383, $62, Annual Direct Costs: (ADC) Operating Maintenance & Labor Chemical use Catalyst Replacement (per year) Fuel for Preheater 1 TOTAL Direct Costs (ADC) $12, TBD TBD $59, $71, Annual Indirect Costs: (AIC) Overhead (60% of operating, maintenance & labor) Administrative charges (2% of ICI) Taxes and Insurance (2% of TCI) Total Indirect Costs (AIC) TBD TBD TBD $0.00 TOTAL ANNUALIZED COST (ACC + ADC + AIC) $133, MMBtu/hr burner at $4.51/MMBtu 2 Report to the Legislature, Gas-Fired Power Plant NOx Emission Controls and Related Environmental Impacts, California Air Resources Board, Stationary Source Division, May

60 The industrial standard is the Rule 4309 limit of % lb/mmbtu 9 ppmv 3% 02 is equivalent to 9 x [( )/20.9 3)] = 1 ppmv NOx 19% 02 *(1.0 ft 3/106 19% 02 x [(20.9 0)/( )] ft 02 )/ 0% 02 x 8,578 0% 02/MMBtu x (46 lb/ibmol)(1bmol/379.5 scf) = lb/mmbtu ( lb/mmbtu) x MMBtu/hr x 8760 hr/yr/2000 lb/ton = 1.7 tons/yr Cost Effectiveness $133,613/1.7 = $78,596/ton > $24,500 (BACT Cost Effectiveness Threshold) Step 5 - Select BACT As shown in the Top Down Cost Analysis it is not cost effective to utilize SCR to reduce NOx emissions. Therefore, BACT for NOx emissions from the drying operation is a NOx limit of 4.3 ppmvd corrected to 19% 02.with and low NOx burner capable of meeting % 02 (2.1 19% 02) fired on natural gas fuel ; therefore, BACT for NOx emissions is satisfied. 2. BACT Analysis for VOC Emissions: There is no applicable BACT Guideline for this class and category of equipment. The following control technology has been identified: a. Step 1 - Identify all control technologies 1) Gaseous fuel b. Step 2 - Eliminate technologically infeasible options There are no technologically infeasible options to eliminate from step 1. c. Step 3 - Rank remaining options by control effectiveness 1) Gaseous fuel d. Step 4 - Cost effectiveness analysis The only control technology in the ranking list from Step 3 has been achieved in practice. Therefore, per the District's BACT Policy (dated 11/9/99) Section IX.D.2, the cost effectiveness analysis is not required. 44

61 e. Step 5 - Select BACT BACT for VOC emissions is gaseous fuel. Therefore BACT for VOCs emissions is satisfied. 45

62 ATTACHMENT VI HRA/AAQA 46

63 San Joaquin Valley Air Pollution Control District Risk Management Review To: From: Date: Facility Name: Location: Application #(s): Project #: Richard Edgehill AQE Permit Services Esteban Gutierrez AQS Technical Services November 17, 2014 GAF Elk Corporation 6200 Zerker Road, Shafter CA S & S A. RMR SUMMARY Categories RMR Summary Dryer (Unit 8-6) Project Totals Facility Totals Prioritization Score Acute Hazard Index NA 1 NA' 0.00 Chronic Hazard Index NA' NA' 0.00 Maximum Individual Cancer Risk (10 43 ) NA' NA' 0.00 T-BACT Required? No, Special Permit Conditions? No Acute and Chronic Hazard Index and Maximum Individual Cancer Risk were not calculated since the total facility prioritization score was less than 1.0. Proposed Permit Conditions To *ensure that human health risks will not exceed District allowable levels; the following permit conditions must be included for: Unit # 8-6 No special conditions are required.

64 Elk Corperation, Project # Page 2 of 3 B. RMR REPORT I. Project Description Technical Services received a request on November 14, 2014, to perform an Ambient Air Quality Analysis and a Risk Management Review for a proposed modification to an Asphaltic felts and mixing operation. The applicant proposes to replace the existing heating equipment with a MMBtu/hr direct fired dryer. II. Analysis Toxic emissions for this proposed unit were calculated using Ventura County's emission factors for external combustion sources. In accordance with the District's Risk Management Policy for Permitting New and Modified Sources (APR 1905, March 2, 2001), risks from the proposed unit's toxic emissions were prioritized using the procedure in the 1990 CAPCOA Facility Prioritization Guidelines and incorporated in the District's HEARTs database. The prioritization score for this proposed unit was less than 1.0 (see RMR Summary Table). Therefore, no further analysis was necessary. The following parameters were used for the review: Analysis Parameters Unit 8-6 Throughput (MIIABtu/h!) Max Houre per Year I 8760 Closest Receptor (m) 347.i. v..:) ',1;- t -A-j-'-i.:v"" 1!.,44...1!t 6 i' qi_k 1-,,N.,44,si.: Technical Services performed modeling for criteria pollutants CO, NOx, SOx and PM 10; as well as a RMR. The emission rates used for criteria pollutant modeling were 72 lb/day CO, 12.2 lb/day NOx, 0.7 lb/day S0x, and 2.8 lb/day PM 10. The engineer supplied the maximum fuel rate for the IC engine used during the analysis. The results from the Criteria Pollutant Modeling are as follows: Criteria Pollutant Modeling Results* Diesel ICE 1 Hour 3 Hours 8 Hours. 24 Hours Annual, CO Pass X Pass X X NO Pass' X X X Pass SO, Pass Pass X Pass. Pass PK X X X Passe Pass e PM2,5 X X X Passe Passe *Results were taken from the attached PSD spreadsheet. 'The project was compared to the 1-hour NO2 National Ambient Air Quality Standard that became effective on April 12, 2010 using the District's approved procedures 2The criteria pollutants are below EPA's level of significance as found in 40 CFR Part (b)(2).

65 Elk Corperation, Project # Page 3 of 3 III. Conclusion The prioritization score is less than 1.0. In accordance with the District's Risk Management Policy, the project is approved without Toxic Best Available Control Technology (T-BACT). To ensure that human health risks will not exceed District allowable levels; the permit conditions listed on page 1 of this report must be included for this proposed unit. These conclusions are based on the data provided by the applicant and the project engineer. Therefore, this analysis is valid only as long as the proposed data and parameters do not change. The emissions from the proposed equipment will not cause or contribute significantly to a violation of the State and National AAQS. IV. Attachments A. RMR request from the project engineer B. Additional information from the applicant/project engineer C. Toxic emissions summary D. Prioritization score E. Facility Summary

66 ATTACHMENT VII Statewide Compliance Statement and Title V Compliance Certification Form 47

67 RECEIVED NOV SJVAPCD Southern Region San Joaquin Valley Unified Air Pollution Control District MEIN HATA TITLE V MODIFICATION - COMPLIANCE CERTIFICATION FORM I. TYPE OF PERMIT ACTION (Cheek appropriate boa) (J SIGNIFICANT PERMIT MODIFICATION [ ADMINISTRATIVE [X] MINOR PERMIT MODIFICATION AMENDMENT COMPANY NAME: GAF Elk Corporation of Texas 1 FACILITY ID: S Type of Organlzation:[X] -Corporation [ Sole Ownership [ ] Government [J Partnership [ J Utility 2. Owner's Name:. GAF Elk Corporation of Texas. / 3. Agent to the Owner Larry Wanamaker, Manager of Technical Services 11. COMPLIANCE CERTIFICATION (Read each statement carefully and initial all circles for confirmation): ased on Information and belief formed after reasonable inquiry, the equipment identified in this application will E O continue to comply with the applicable federal requirement(s). r Based on information and belief formed after reasonable inquiry, the equipment identified in this application will comply with applicable federal requirement(s) that will become effective during the permit term, on a timely basis. Corrected information will be provided to the District when I become aware that incorrect or incomplete information has been submitted. 'Based on information and belief formed after reasonable inquiry, information and statements in the submitted application package, including all accompanying reports. and required certifications are true accurate and complete. I declare, under penalty of perjury under the laws of the state of California, that the forgoing is correct and true: Signature of Responsible Official Larry Wanamaker Name of Responsible Official (please print) Manager of Technical Services Title of Responsible Official (please print) Date A/V/1V Moiling Addeo',: Central Regional Mee 1990 E. Gattribaeg Avenue Fresno, C,allionda (554) FAX (559) TVFORM-009 It= My101

68 CERTIFICATION OAF, Elk Corporation of Texas (GAF) hereby certifies as follows: 1. GAF owns or operates certain major stationary sources in the State of California. Such sources are comprised of a vast number of emission points. As used in this certification, the term "major stationary source" shall, with respect to GAF stationary sources in the SJVUAPCD, have the meaning ascribed thereto in SJVUAPCD Rule 2201, Section 3.23, and shall, with respect to all of GAF's other stationary sources in the State of California, have the meaning ascribed thereto in section 302(J) of the Clean Air Act (42 U.S.C. Section 7602 (J)). 2. Subject to paragraphs 3 and 4 below, all major stationary sources owned or operated by GAF in the State of California are either in compliance, or on an approved schedule of compliance, with all applicable emission limitations and standards under the Clean Air Act and all of the State Implementation Plan approved by the Environmental Protection Agency. 3. This certification is made on information and belief and is based upon a review of GAF major stationary sources in the State of California by those employees of GAF who have operational responsibility for compliance. In conducting such reviews. GAF and its employees have acted in good faith and have exercised best efforts to identify any exceedance of the emission limitations and standards referred to in paragraph 2 thereof. 4. This certification shall speak as of the time and date of its execution. CERTIFICATION By: Title: i4ie,24r A1ite,46. P pc Zie-ef. Eivwcates Date:

69 ATTACHMENT VIII Draft ATCs GAF

70 San Joaquin Valley Air Pollution Control District PERMIT NO: S LEGAL OWNER OR OPERATOR: MAILING ADDRESS: LOCATION: Akir "7" -7- ELK CORPORATION OF TEXAS 6200 ZERKER RD SHAFTER, CA ZERKER RD SHAFTER, CA SECTION: 15 TOWNSHIP: 28S RANGE: 26E EQUIPMENT DESCRIPTION: MODIFICATION OF FILLER HEATING OPERATION WITH A FILLER RECEIVING BIN AND TWO HOT BINS SERVED BY WHIRL AIR FLOW MODEL DUST COLLECTOR (DC-7), AND ULTRA INDUSTRIES MODEL BD DUST COLLECTOR (DC-5) SHARED WITH S ; THERMAL FLUID HEAT FROM TVVO HEATERS (S AND S ) PROVIDED FOR TVVO HEAT EXCHANGERS SERVED BY ULTRA INDUSTRIES MODEL BB IG FAN DUST COLLECTOR (DC-8), ROTARY FEEDERS; AND METERING SCREW CONVEYORS FEEDING THE ASPHALT ROOFING SHINGLE COATING OPERATION (S ): REMOVE ONE HOT BIN, FILLER HEAT EXCHANGERS, AND DUST COLLECTOR (DC-8), ADD FLASH DRYING SYSTEM WITH A MMBTU/HR NATURAL GAS FIRED AIR HEATER WITH AN ECLIPSE MINNOX 3000 CtS-T BURNER OR EQUIVALENT AND TWO CYCLONES SERVED BY FLS AIRTECH MODEL DC8 DUST COLLECTOR (DC-10), AND ASSOCIATED CONVEYANCES CONDITIONS 1. {1830} This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40 CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District Rule 2201] Federally Enforceable Through Title V Permit 2. {1831} Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section [District Rule 2520, 5.3.4] Federally Enforceable Through Title V Permit 3. Al! equipment shall be constructed, maintained and operated according to the specifications and plans contained in the permit application except as otherwise specified herein. [District Rule 2201] Federally Enforceable Through Title V Permit ISSU Seyed Sadredin, ExaoutivRi PCO CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (681) WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed In accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations of er governmental agencies which may pertain to the above equipment. Arnaud MailolletrDirector of Permit Services 03340:Dea ,1 1 EDGEH1LR : Join! tnspedion NOT Requirad Southern Regional Office Flyover Court Bakersfield, CA (661) Fax (661)

71 Conditions for S (continued) Page 2 of 4 4. The permittee shall obtain written District approval for the use of an y equivalent equipment not specifically approved by this Authority to Construct. Approval of the e quivalent eq uipment shall be made onl y after the District's determination that the submitted desi gn and performance of the proposed alternate e quipment is equivalent to the specifically authorized e quipment. [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 5. The permittee's request for approval of e q uivalent e quipment shall include the make, model, manufacturer's maximum ratin g, manufacturer's guaranteed emission rates, e quipment drawin g(s), and operational characteristics/parameters. [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 6. Alternate equipment shall be of the same class and cate gory of source as the e quipment authorized b y the Authority to Construct. [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 7. The APCO or an y authorized representative, upon re quest, shall have access to inspect an y equipment, operation, or method required in this permit, and to sample emissions from the source or re quire samples to be taken. [District Rule 1081] Federally Enforceable Throu gh Title V Permit 8. Source testin g shall be conducted usin g the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testin g. [District Rule 1081] Federall y Enforceable Throu gh Title V Permit 9. Dust collectors shall be maintained and operated accordin g to manufacturers' recommendations. [District Rule 2201] Federally Enforceable Throu gh Title V Permit 10. All conveyors shall be enclosed. [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 11. There shall be no visible emissions greater than 0% opacit y from mineral conve y ing, handlin g, and stora ge. [District Rule 220 land 40 CFR ] Federall y Enforceable Through Title V Permit 12. Visible emissions from dust collectors DC-5, DC-7 and DC-10 servin g the filler heatin g operation shall not e qual or exceed 5% opacity for a period or periods aggregating more than three minutes in one hour. [District Rule 2201] Federally Enforceable Through Title V Permit imiiiiculate matter (PM10) emission rate from alai Fai t 1e'c1oTT)C-57DC-7, andlygto iffili 1 not --Tc-ER e) lb per ton of filler material processed. [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 14. Total facility filler material process rate shall not exceed 1141 tons/da y without prior District approval. [District Rule 2201] Federally Enforceable Throu gh Title V Permit 15. Compliance source testin g with PMIO emission rate(s) shall be demonstrated within 60 da ys upon detection of visible emissions greater than 5% opacit y from the dust collector(s) exhaust. [District Rule 1070] 16. The results of each source test shall be submitted to the District within 60 da ys thereafter. [District Rule 1070] Federally Enforceable Throu gh Title V Permit 17. The APCO or authorized representative shall have the authorit y to require miti gation of toxic emissions if total facility health risks are determined to be si gnificant pursuant to Air Toxics "Hot Spot" Information and Assessment Act of [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 18. Material removed from dust collector(s) shall be disposed of in a manner preventin g visible emissions in excess of 0% opacity into the atmosphere. [District Rule 2201] Federall y Enforceable Throu gh Title V Permit 19. Method 9 and the procedures in 40 CFR 60.11shall be used to measure opacit y. [40 CFR ] Federall y Enforceable Throu gh Title V Permit 20. Flash dryer shall combust natural gas only with a sulfur content not exceedin g 1 gr S/100 scf. [District Rule 2201] Federally Enforceable Throu gh Title V Permit 21. Emissions from the flash drying operation shall not exceed an y of the followin g limits: lb-pm10/mmbtu, 42 ppmv 19% 02, or b-VOC/MMBtu. [District Rules 2201 and 4309] Federall y Enforceable Throu gh Title V Permit CON DITI NUE ON NEXT PAGE : Dec :23P1.1 EOGEMILR

72 Conditions for S (continued) Page 3 of Emissions from the flash dryer shall not exceed 2.1 ppmv 19% 02 or such higher value as approved by the District based on source test and monitoring results obtained during the 12 month period after initial source test of the flash dryer. In no case shall the emissions from the flash dryer exceed 4.3 ppmv 19% 02. [District Rule 2201] Federally Enforceable Through Title V Permit 23. Within 12 months of the initial source test, GAF shall prepare and submit to the District a report identifying measured NOx emissions established though source testing and monthly monitoring. [District Rule 2201] Federally Enforceable Through Title V Permit 24. Final NOx emissions limit from the flash dryer shall be no less than % 02 and no greater than % 02. The District shall establish the final NOx limit within 90 days of receipt of the GAF report. [District Rule 2201] Federally Enforceable Through Title V Permit 25. The permittee shall monitor and record the stack concentration of NOX, CO, and 02 at least once every month (in which a source test is not performed) using a portable emission monitor that meets District specifications. Monitoring shall not be required if the unit is not in operation, i.e. the unit need not be started solely to perform monitoring. Monitoring shall be performed within 5 days of restarting the unit unless monitoring has been performed within the last month. [District Rule 4309] Federally Enforceable Through Title V Permit 26. If either the NOX or CO concentrations corrected to 19% 02, as measured by the portable analyzer, exceed the allowable emissions concentration, the permittee shall return the emissions to within the acceptable range as soon as possible, but no longer than 1 hour of operation after detection. If the portable analyzer readings continue to exceed the allowable emissions concentration after 1 hour of operation after detection, the permittee shall notify the District within the following 1 hour and conduct a certified source test within 60 days of the first exceedance. In lieu of conducting a source test, the permittee may stipulate a violation has occurred, subject to enforcement action. The permittee must then correct the violation, show compliance has been re-established, and resume monitoring procedures. If the deviations are the result of a qualifying breakdown condition pursuant to Rule 1100, the permittee may fully comply with Rule 1100 in lieu of the performing the notification and testing required by this condition. [District Rule 4309] Federally Enforceable Through Title V Permit 27. All alternate monitoring parameter emission readings shall be taken with the unit operating either at conditions representative of normal operations or conditions specified in the Permit to Operate. The analyzer shall be calibrated, maintained, and operated in accordance with the manufacturer's specifications and recommendations or a protocol approved by the APCO. Emission readings taken shall be averaged over a 15 consecutive-minute period by either taking a cumulative 15 consecutive-minute sample reading or by taking at least five (5) readings, evenly spaced out over the 15 consecutive-minute period. [District Rule 4309] Federally Enforceable Through Title V Permit 28. The permittec shall maintain records of: (1) the date and time of NOX, CO, and 02 measurements, (2) the 02 concentration in percent and the measured NOX and CO concentrations corrected to 19% 02, (3) make and model of exhaust gas analyzer, (4) exhaust gas analyzer calibration records, and (5) a description of any corrective action taken to maintain the emissions within the acceptable range. [District Rule 4309] Federally Enforceable Through Title V Permit 29. All emissions measurements shall be made with the unit operating either at conditions representative of normal operations or conditions specified in the Permit to Operate. No determination of compliance shall be established within two hours after a continuous period in which fuel flow to the unit is shut off for 30 minutes or longer, or within 30 minutes after a re-ignition as defined in Section 3.0 of District Rule [District Rule 4309] Federally Enforceable Through Title V Permit 30. All alternate monitoring parameter emission readings shall be taken with the unit operating either at conditions representative of normal operations or conditions specified in the permit-to-operate. The analyzer shall be calibrated, maintained, and operated in accordance with the manufacturer's specifications and recommendations or a protocol approved by the APCO. Emission readings taken shall be averaged over a 15 consecutive-minute period by either taking a cumulative 15 consecutive-minute sample reading or by taking at least five (5) readings, evenly spaced out over the 15 consecutive-minute period. [District Rule 4309] Federally Enforceable Through Title V Permit 31. For emissions source testing, the arithmetic average of tr -c Insecutive-minute test runs shall apply. If two of three runs are above an applicable limit the tg,_%,criart demonstrate compliance with an applicable limit. [District Rule 4309] Federally Enforceable AlMar ri t : D :22Phi - EDGUHILI1 CONDITICIRS=WINUE ON NEXT PAGE

73 Conditions for S (continued) Page 4 of NOX emissions for source test purposes shall be determined using EPA Method 7E or ARB Method 100 on a ppmv basis. [District Rule 4309] Federally Enforceable Through Title V Permit 33. CO emissions for source test purposes shall be determined using EPA Method 10 or ARB Method 100. [District Rule 4309] Federally Enforceable Through Title V Permit 34. Stack gas oxygen (02) shall be determined using EPA Method 3 or 3A or ARB Method 100. [District Rule 4309] Federally Enforceable Through Title V Permit 35. Source testing to measure NOx and CO emissions from this unit shall be conducted within 60 days of initial start-up and at least once every 24 months thereafter. [District Rules 2201 and 4309] Federally Enforceable Through Title V Perm it 36. All test results for NOx and CO shall be reported in 19% 02, corrected to dry stack conditions. [District Rule 4309] Federally Enforceable Through Title V Permit 37. Permittee shall maintain accurate daily records of filler material process rate. [District Rules 1070 and 2201] Federally Enforceable Through Title V Permit 38. All records shall be maintained and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rules 1070 and 4309] Federally Enforceable Through Title V Permit : D PM - EDGE11101

74 San Joaquin Valley Air Pollution Control District AUTHORITY TO CONSTRUCT PERMIT NO: S ISSU LEGAL OWNER OR OPERATOR: ELK CORPORATION OF TEXAS MAILING ADDRESS: 6200 ZERKER RD SHAFTER, CA LOCATION: 6200 ZERKER RD SHAFTER, CA SECTION: 15 TOWNSHIP: 28S RANGE: 26E EQUIPMENT DESCRIPTION: MODIFICATION OF ASPHALT ROOFING SHINGLE COATING OPERATION WITH MACHINE LINE FUME COLLECTION SYSTEM VENTED TO HIGH VELOCITY AIR FILTER (FCS-1): DECREASE ANNUAL THROUGHPUT CONDITIONS I. (1830) This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40 CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District Rule 2201] Federally Enforceable Through Title V Permit 2. {1831} Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section [District Rule 2520, 5.3.4] Federally Enforceable Through Title V Permit 3. All equipment shall be constructed, maintained and operated according to the specifications and plans contained in the permit application except as otherwise specified herein. [District Rule 2201] Federally Enforceable Through Title V Permit 4. Sampling facilities for source testing shall be provided in accordance with the provisions of Rule 1081 (Source Sampling). [District Rule 1081] Federally Enforceable Through Title V Permit 5. Operation shall include Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 with 200 hp exhaust blower. [District Rule 2201] Federally Enforceable Through Title V Permit CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (861) WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine lithe equipment can be operated In compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of Issuance. The applicant Is responsible for complying with all laws, ordinances and regulations ofi4.ott%er governmental agencies which may pertain to the above equipment. Seyed Sadredin, EKe4ulivRi PCO Arnaud Marjolletrelrector of Permit Services S ; PM eooehitil 1 Joint Inspedion NOT Rorivited Southern Regional Office Flyover Court Bakersfield, CA (661) Fax (661)

75 Conditions for S (continued) Page 2 of 4 6. Operation shall include one continuous mixer, 4000 gallon surge tank with agitator, filled coating applicator, sealdown applicator with three 2000 gallon sealdown storage and mix tanks served by high velocity air filter FCS-1. [District Rule 2201] Federally Enforceable Through Title V Permit 7. Operation shall include laminator sealdown applicator, laminator adhesive applicator, and five 250 gallon use tanks served by high velocity air filter FCS-1. [District Rule 2201] Federally Enforceable Through Title V Permit 8. Operation shall include oil pump and 1000 gallon reclaim oil storage tank. [District Rule 2201] Federally Enforceable Through Title V Permit 9. Continuous temperature monitoring equipment (with accuracy of degrees Celsius over its range) shall be installed at inlet of high velocity air filter. [District Rule 2201] Federally Enforceable Through Title V Permit 10. Continuous temperature monitoring results shall be maintained for District inspection upon request for at least five years. [District Rule 1070] Federally Enforceable Through Title V Permit 11. Each tank roof appurtenance shall be maintained leak-free (no reading in excess of 10,000 ppm as methane measured at a distance of one centimeter from the source). [District Rule 4623] Federally Enforceable Through Title V Permit 12. Maximum flow rate through high velocity air filter FCS-1 shall not exceed 25,200 acfm. Flow control damper shall be maintained at setting shown to demonstrate compliance with flow limit during source testing. [District Rule 2201] Federally Enforceable Through Title V Permit 13. Visible emissions shall not exceed 1/4 Ringelmann or 5% opacity. [District Rule 2201] Federally Enforceable Through Title V Permit 14. Particulate matter emissions shall not exceed 0.08 lb/ton of asphalt shingle produced. [40 CFR ] Federally Enforceable Through Title V Permit 15. Emission rate from shingle coating operation shall not exceed: PM10: 0.88 lb/hr and 65211b/yr, and VOC: 5.04 lb/hr and 37,497 lb/yr. [District Rule 2201] Federally Enforceable Through Title V Permit 16. Total quantity-of coating-asplialt,_sealantaspltalt T anchamillrip arlhesivc_aqphalt introrilirpfl tn slcpb2itroctfing_shingie coating operation (S ) shall not exceed 657 tons/day and 203,788 tons/yr. [District Rule 2201] Federally Enforceable Through Title V Permit 17. Source testing to demonstrate compliance with PM10 and VOC emission limits shall be conducted not less than once every 12 months, except as provided below. [District Rule 1070] Federally Enforceable Through Title V Permit 18. Source testing to demonstrate compliance with PM10 and VOC emission limits shall be conducted not less than once every 36 months if compliance is demonstrated on two consecutive annual tests. [District Rule 1070] Federally Enforceable Through Title V Permit 19. If permittee fails any compliance demonstration for PM10 and VOC emission limits when testing not less than once every 36 months, compliance with PM10 and VOC emission limits shall be demonstrated not less than once every 12 months. [District Rule 1070] Federally Enforceable Through Title V Permit 20. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 1081] Federally Enforceable Through Title V Permit 21. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1070] Federally Enforceable Through Title V Permit 22. The APCO or authorized representative shall have the authority to require mitigation of toxic emissions if total facility health risks are determined to be significant pursuant to Air Toxics "Hot Spot" Information and Assessment Act of [District Rule 2201] Federally Enforceable Through Title V Permit 23. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be equipped with a differential pressure monitor to continuously indicate and record the pressure drop across the filter media. [40 CFR 64.3] Federally Enforceable Through Title V Permit CONDIT' NUE ON NEXT PAGE 8-I : Dec ,23PM EDGEHILR

76 Conditions for S (continued) Page 3 of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall operate with a minimum differential pressure of 0 inches water column and a maximum differential pressure of 27 inches water column, These parameters shall be reviewed annually and revised if necessary based on PMIO source test result data, historical operating data and manufacturer/supplier recommendations. [40 CFR 64.3] Federally Enforceable Through Title V Permit 25. During each day of operation, the permittee shall record the differential pressure of the Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-I and compare the readings with the permitted range. If the baghouses' differential pressure falls outside the permitted range, the permittee shall take all necessary steps to return the baghouscs' differential pressure to within the permitted range as soon as possible, but no longer than three hours after detection. If the differential pressure cannot be returned within the permitted range after three hours of operation following detection, the permittec shall shut the operation down and make all necessary repairs to bring the differential pressure back to with the permitted range. [40 CFR Part 64] Federally Enforceable Through Title V Permit 26. Fabric collection system of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air fi lter FCS- I shall be completely inspected annually while in operation for evidence of particulate matter breakthrough and shall be repaired as needed. [District Rule 2201] Federally Enforceable Through Title V Permit 27. Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be completely inspected annually while not in operation for tears, scuffs, abrasives or holes which might interfere with PM collection efficiency and shall be replaced as needed. [District Rule 2201]Federally Enforceable Through Title V Permit 28. Visible emissions from Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-1 shall be evaluated using EPA Method 22 for a period of at least 6 minutes at least once per each week the dust collector is operated. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. Corrective action shall include the following: inspecting the dust collection system for any tears, abrasions, or holes in the filters; inspecting closed duct systems for damage; and repairing or replacing any defective or damaged material. [40 CFR 64] Federally Enforceable Through Title V Permit 29. The industry is exempted from the quarterly reports required under 40 CFR During performance testing, the operating temperature of the high velocity air filters shall be recorded and reported as required by 40 CFR 60.7 (d). Facility shall maintain a file of temperature monitoring results for at least 5 years. [40 CFR ] Federally Enforceable Through Title V Permit 30. For saturators, performance tests required under 40 CFR 60.8 shall conducted using procedures in 40 CFR (a)- (c). [40 CFR ] Federally Enforceable Through Title V Permit 31. Method 9 and the procedures in 40 CFR shall be used to measure opacity. [40 CFR ] Federally Enforceable Through Title V Permit 32. The administrator shall determine compliance with the standards in CFR (a)(3) by using Method 22, modified so that readings are recorded every I S seconds for a period of consecutive observations during representative conditions (in accordance with 40 CFR 60.8 (c) totalling 60 minutes. A performance test shall consist of one run. [40 CFR ] Federally Enforceable Through Title V Permit 33. The owner and operator shall use the monitoring device in (a) to monitor and record continuously the temperature during the particulate matter run and shall report the results to the Administrator with the performance test results. [40 CFR ] Federally Enforceable Through Title V Permit 34. Records of Monsanto Enviro-Chem Systems, Inc. model EEE high velocity air filter FCS-I maintenance, inspection, and repairs shall be maintained. The records shall include. identification of equipment, date of inspection, corrective action taken, and identification of individual performing inspection. [District Rule 1070] Federally Enforceable Through Title V Permit 35. The permittee shall comply with the recordkeeping and reporting requirements of 40 CFR part [40 CFR 64.9] Federally Enforceable Through Title V Permit 36. Permittee shall maintain daily records of asphalt process rate records readily available for District inspection up.o.q iqqp Enforceable Through Title V Permit mperature monitoring results, and shall make such period of five years. [District Rule 1070] Federally CONDITIMTSMYRTINUE ON NEXT PAGE :Oft MA-COM,KR