rai San Joaquin Valley AIR POLLUTION CONTROL DISTRICT

Transcription

1 rai San Joaquin Valley AIR POLLUTION CONTROL DISTRICT HEALTHY JAN Mark Ferguson Diamond Pet Food Processors of Ripon 942 South Stockton Ave Ripon, CA Re: Notice of Preliminary Decision - Authority to Construct Facility Number: N-8234' Project Number: N Dear Mr. Ferguson: Enclosed for your review and comment is the District's analysis of Diamond Pet Food Processors of Ripon's application for an Authority to Construct for re-establishing emission limits and processing rates for pet food manufacturing operations, at 942 South Stockton Ave, Ripon, California. The notice of preliminary decision for this project will be published approximately three days from the date of this letter. After addressing all comments made during the 30-day public notice period, the District intends to issue the Authority to Construct. Please submit your written comments on this project within the 30-day public comment period, as specified in the enclosed public notice. Thank you for your cooperation in this matter. If you have any questions regarding this matter, please contact Mr. Jag Kahlon of Permit Services at (209) Sincerely, David Warner Director of Permit Services DW: JK Enclosures cc: Mike Tollstrup, CARB (w/ enclosure) via Ken Zuidervaart, City of Ripon via Seyed Sadredin Executive DirectorlAir 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: Printed an recycled paper. 0

2 San Joaquin Valley Air Pollution Control District Authority to Construct Application Review Facility Name: Mailing Address: Contact Person: Telephone: Fax: Application #(s): Project #: Deemed Complete: Diamond Pet Food Processors of Ripon 942 S Stockton Ave Ripon, CA Randy Frazier, Consultant (925) (925) N , '-2-2, '-3-2, '-4-1, '-5-1 and '-6-1 N December 17, 2013 Date: January 14, 2014 Engineer: Jagmeet Kahlon Lead Engineer: Nick Peirce I. PROPOSAL Diamond Pet Food Processors of Ripon ("Diamond") has proposed to reestablish emission factors and process rates. Detailed proposal under each permit is as follows: N : Pet food material receiving, storage, and load out operation Diamond Pet Food Processors of Ripon ("Diamond") has proposed to limit material receiving rate or loadout rate to 380,000 tons per year. The outstanding ATC N is required to be implemented prior to or concurrently with this permit. N : Pet food material dispensing, pre-grinding, conveying and storage operations Diamond has proposed to establish PK emission factor of lb/ton of material for the pre-grind system. The District will establish production rates of 400 tons/day and 50,000 tons/yr for the pre-grind system. Note that Diamond's proposed emission rates of 8.4 lb/day and 1,050 lb/yr for the pre-grind system equate to production rates of 400 tons/day and 50,000 tons/year using the above proposed emission factor. The emission rates are proposed to appropriately address the ambient air quality analysis (AAQA) for PMio emissions.

3 Diamond Pet Food Processors of Ripon N to '-6, N The District will limit material dispensing and storage operation production, including the pre-grind system production rate to 800 tons/day and 50,000 tons/yr in the permit. Note that Diamond's proposed emission rates of 0.2 lb-pmio/day and 13 lb- PMio/yr equate to material processing rates of 800 tons/day and 50,000 tons/year, using the emission factor of lb/ton of material in permit N The Authority to Construct (ATC) issued under this project will supersede the previously issued ATCs N and `-2-1. Note that the equipment changes proposed under ATC N will be transferred into the ATC being issued under this project. N : Pet food material dispensing, mixing, grinding and screening, extrusion surge bins, and associated conveying operations Diamond has proposed to establish PK() emission factor of lb/ton of material for each hammermill system. Diamond has proposed to establish an individual and combined process rate of 800 tons/day for the hammerm ills. The ATC issued under this project will supersede the previously issued ATCs N and '-3-1. Note that the equipment changes proposed under ATC N will be transferred onto the ATC being issued under this project. N : Pet food processing line #1 N : Pet food processing line #2 N : Pet food processing line #3 Diamond has proposed to establish VOC emission limit of lb/ton of material l for all VOC emitting operations including sources vented through wet cyclone, dryer cyclone, dryer cooler cyclone, and vertical cooler cyclone. The District will establish the total PMio emission limit of lb/ton of material 2 for all PK emitting operations including sources vented through wet cyclone, dryer cyclone, dryer cooler cyclone, vertical cooler, and other material conveying activities. Diamond has proposed to establish material processing rate of 780 tons/day/line as well as 780 tons/day for all three lines. The production rate is proposed to appropriately address AAQA for PMio emissions lb-voc/day, taken from worksheet in Appendix Ill of this document 780 tons/day = lb- VOC/ton of material processed lb-pm i dday, taken from worksheet in Appendix ill of this document 780 tons/day = lb- VOC/ton of material processed. Page: 2

4 Diamond Pet Food Processors of Ripon N to `-6, N Diamond has proposed to establish CO emission limit of % 02 for each dryer. The District is going to incorporate the previously authorized use of cold plasma injector systems under permit N in this permit. Note that cold plasma injection systems will be used to abate pet food odors from wet cyclone, dryer cyclone, dryer cooler cyclone, and vertical cooler cyclone. The ATC issued under this project will supersede the previously issued ATCs N , `-5-0 and `-6-0. II. APPLICABLE RULES Rule 2201 New and Modified Stationary Source Review Rule (4/21/11) Rule 4001 New Source Performance Standards (4/14/99) Rule 4101 Visible Emissions (02/17/05) Rule 4102 Nuisance (12/17/92) Rule 4201 Particulate Matter Concentration (12/17/92) Rule 4202 Particulate Matter Emission Rate (12/17/92) Rule 4301 Fuel Burning Equipment (12/17/92) Rule 4309 Dryer, Dehydrators, and Ovens (12/15/05) Rule 4801 Sulfur Compounds (12/17/92) California Health & Safety Code (Public Nuisance) California Health & Safety Code (School Notice) Public Resources Code : California Environmental Quality Act (CEQA) California Code of Regulations, Title 14, Division 6, Chapter 3, Sections : CEQA Guidelines III. PROJECT LOCATION The facility location is 942 S Stockton Ave, Ripon, California. There is no K-12 school within 1,000 feet of this location. Therefore, this project is not subject to school notice requirements in Section of the California Health and Safety Code. IV. PROCESS DESCRIPTION This facility has several emission units including material receiving and storage operations (silos/bins), hammermills, screens/scalpers, elevators, conditioners, dryers, coolers, boilers, mechanical and pneumatic material conveying systems and packing machines. Diamond receives raw materials such as whole corn, beet pulp, chicken meal, cracked barley and peas via rail cars or trucks. The material is screened and Page: 3

5 Diamond Pet Food Processors of Ripon N to `-6, N stored in appropriate silos/bins located outside of the main production building. On a as need basis, an appropriate amount of the stored materials is dispensed from the silos/bins into a pre-grinding ham mermill system or directly to enclosed drag screw conveyors. The pre-ground material and the materials in the enclosed drag screw conveyors are then transferred to enclosed belt conveyors, which transfers the material to the bins in the mill tower via enclosed bucket elevators. The material in the mill tower is then dispensed to associated scale bins. From the scale bins, the material is dispensed into surge bins. The material in the surge bins is then dispensed into an enclosed mixer, and then either transferred into an enclosed bucket elevator feeding an enclosed transfer auger or into a truck loadout spout. The enclosed transfer auger feeds three surge bins, each associated with one of the three identical hammermill systems. Each hammermill system consists of a feeding system, hammermill unit, plenum, enclosed screw conveyor, vibratory screener, and a pneumatic transfer system (bin vent filter with static socks) for transferring "overs" from the screener to the extruder surge bin, which feeds the extruder of each pet food processing line. Frozen meat (beef, chicken and lamb) is delivered to the facility via trucks. The meat is stored in a refrigerated building. There are currently three separate identical pet food processing lines. Each of these processing lines is capable of manufacturing various pet food kibble based on the production needs and given recipes. The process starts with a specific pet food kibble recipe. Depending on the recipe, an appropriate amount of each material is dispensed from the small bins, mixed, and transferred into steam conditioners. Each recipe may use frozen meat (beef, chicken and lamb), which is delivered to the facility via trucks, and stored in a refrigerated building. As part of the recipe, ground meat is injected into the steam conditioners, and thoroughly pasteurized/steam conditioned to release starches, which act as binding agents for the material. The material is then extruded to form pet food kibble. The freshly extruded moist kibble is transferred via cyclone to the conveyor belt that serves the dryer and dryer-cooler in each processing line. In the dryer and dryer-cooler the kibble is dried using hot air from natural gas combustion then cooled. The dried kibble is then coated with chicken fat and canola oil to bind other nutrients such as dry digest and probiotics. The coated kibble is then cooled further in vertical coolers, then packaged and stored in a warehouse or shipped directly to the customers. V. EQUIPMENT LISTING N : PET FOOD MATERIAL RECEIVING, STORAGE, AND LOAD OUT OPERATION The following permit conditions are included as part of the equipment during under ATC N These conditions are retained under this project: Page: 4

6 Diamond Pet Food Processors of Ripon N to `-6, N Receiving Equipment: Two rail car receiving pits (pit #1 and pit #2), one truck receiving pit (pit #3), four enclosed screw conveyors, two Prater scalpers, two enclosed belt conveyors, and two enclosed bucket elevators each feeding enclosed drag A and B screw conveyors. The rail car receiving pit (pit #1) and the truck receiving pit (pit #3) delivers the product to the enclosed screw conveyor from where the material transfers into a Prater scalper. The accepts from the scalper transfer to another enclosed screw conveyor to an enclosed belt conveyor that delivers the material into an enclosed bucket elevator (leg #2) feeding enclosed drag A and B screw conveyors that fills the silos and or bins mentioned in the storage equipment (below). The railcar receiving pit (pit #2) has a conveying mechanism set up identical to the rail car receiving pit (pit #1) and the truck receiving pit (pit #3). The rail car receiving pit (#1) and the truck pit (#3) uses a bucket elevator (leg #1). The rail car receiving pit (2) uses a bucket elevator (leg #2). Each receiving pit shall have a choke feed system. The rail car receiving pit (#1), the truck receiving pit (#3), Prater scalper, the bucket elevator (leg #1) all shall be vented to a CAMCORP Model 10TR10x100 bag house. The rail car receiving pit (#2), Prater scalper, the enclosed elevators and the bucket elevator (leg #2) all shall be vented to another CAMCORP Model 10TR10x100 baghouse. [District Rule 2201] Storage Equipment: Three 21,430 cubic feet each approx. 21.5' dia, 58.8' side wall silos and six 2,560 cubic feet each approx. 8' x 8' x 40' side wall in storage area A being fed by drag A enclosed screw conveyor, three 21,430 cubic feet each approx. 21.5' dia, 58.8' side wall and six 2,560 cubic feet each approx. 8' x 8' x 40' side wall in storage area B being fed by drag B enclosed screw conveyor. Each silo and bin shall be equipped with HORIZON SYSTEMS Model 21VFTC6 (or equal) cartridge dust collector system. [District Rule 2201] N : PET FOOD MATERIAL DISPENSING, PRE-GRINDING, CONVEYING AND STORAGE OPERATIONS The following permit conditions are included as part of the equipment during under ATC N These conditions are retained under this project: Dispensing System: The material in three 21,430 cubic feet (each) silos in storage area A (West) shall be dispensed into an enclosed drag screw conveyor A-1 and/or A-2, and the material in six 2,560 cubic feet (each) bins in storage area A may be dispensed into a pre-grind mill or directly to enclosed belt conveyor C and or D. The material in three 21,430 cubic feet (each) silos and six 2,560 cubic feet (each) bins in storage area B (East) shall be dispensed into an enclosed drag screw conveyor A-3 and/or A-4 and then dispensed into enclosed belt conveyor C and or D. [District Rule 2201] Page: 5

7 Diamond Pet Food Processors of Ripon N to `-6, N Pre-grind System: This system consists of a hammermill and screen (one package unit) system. This system shall be vented to a MAC 96 LDT 64 STYLE II baghouse via a plenum with auger. The ground material from pregrind system shall be conveyed through the diverters to enclosed belt conveyors C and or D. [District Rule 2201] Conveying and Storage System: The enclosed drag screw conveyors Al, A- 2, A-3 and A-4 transfer the material into enclosed belt conveyor C and/or D. Enclosed belt conveyor C and/or D transfers material into an enclosed bucket elevators (leg #3, leg #4) that feeds any of the 75 bins in the mill tower. The enclosed bucket elevators (leg #3, leg #4), drag screw conveyors, and each mill tower bin shall be equipped with HORIZON SYSTEMS Model 21VFTC6 (or equal) cartridge dust collector systems. [District Rule 2201] N : PET FOOD MATERIAL DISPENSING, MIXING, GRINDING AND SCREENING, EXTRUSION SURGE BINS, AND ASSOCIATED CONVEYING OPERATIONS The following permit conditions are included as part of the equipment during under ATC N These conditions are retained under this project: Dispensing System: The material is dispensed from the bins in the mill tower to their associated scale bins. There are 4 scale bins located under the 75 bins. Each scale services approximately 25% of the bins in the mill tower. The four scale bins dispense into a six ton dual ribbon mixer described in item the condition below. Each scale bin shall be equipped with HORIZON SYSTEMS Model 21VFTC6 (or equal) cartridge dust collector system. [District Rule 2201] Mixing and Conveying System: The material in the 4 scale bins is dispensed into an enclosed six ton dual ribbon mixer. There is one mixer surge bin with a connected screw conveyor that transfers the material into another screw conveyor served by HORIZON SYSTEMS MODEL 21VFTC6 (or equal) dust collector system that either transfers the material into an enclosed bucket elevator feeding an enclosed transfer auger or a portion of the material into a truck loadout spout. The enclosed transfer auger feeds three surge bins one associated with each hammer mill. Each surge bin shall be equipped with HORIZON SYSTEMS MODEL 21VFTC6 (or equal) dust collector system. The truck loadout spout distributes product into a turn-head that services 4 unloading bins. Each unloading bin is vented with HORIZON SYSTEMS Model 21VFTC6 (or equal) dust collector system. The loadout spout of each unloading bin shall have a sock filter to minimize entrainment of material dust into the atmosphere. [District Rule 2201] Grinding, Screening, and Conveying System: There are three identical hammermill systems. Each system consists of a hammer mill feeding Page: 6

8 Diamond Pet Food Processors of Ripon N to `-6, N system, a hammermill, a hammermill plenum, an enclosed screw conveyor, a vibratory screener, and a pneumatic transfer system (bin vent filter with static socks) transferring overs from the screener to the surge bin of hammermill. Each hammermill/plenum shall be equipped with MAC LST AIR 96LST196 (or equal) baghouse. Each vibratory screener shall be vented to HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge filter. The ground material from each hammermill system shall be pneumatically transferred using a filter receiver system into three sets of a paired extruder surge bin system (mentioned in the condition below). The displaced air from the filter receiver system shall be vented through a HORIZON SYSTEMS 40SWRDL 16 (or equal) baghouse. [District Rule 2201] Extruder Surge Bins: Three sets of identical extruder surge bins, each set contains two bins, each with dimensions approx. 8' x 8' x 20', and each bin shall be equipped with HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge dust collector system. [District Rule 2201] N , `-5-1, PET FOOD PROCESSING LINES The following permit conditions are included as part of the equipment description: Material Dispensing, Kibble Manufacturing, and Conveying Systems: The material from the extruder surge bin is dispensed into an extruder bin from where the material is transferred into an EXTRU-TECH 24X144 steamconditioner system. The material is extruded to form kibbles. The kibbles are pneumatically conveyed using HEPA filtered air into a dryer receiving chamber using HORIZON SYSTEMS HT-68 (or equal) high volume cyclone with a static sock. The owner or operator shall install, maintain, and operate Uniqair's, 6kW, 6 plasma cylinders, cold plasma injection system to abate odors in laden air stream from the wet cyclone (Horizon HT-68) prior to being discharged into the atmosphere. District Rules 2201 and 4102] Dryer System: The system consists of EXTRU-TECH P-AF11, 10 MMBtu/hr (total) direct-fired natural gas fired dryer with five drying sections, each section equipped with an ECLIPSE WINNOX WX0200 burner rated with a maximum heat input rate of 2.0 MMBtu/hr. The dryer exhaust is vented to a MAC HE60 (or equal) high efficiency cyclone. The owner or operator shall install, maintain, and operate Uniqair's, 15kW, 15 plasma cylinders, cold plasma injection system to abate odors in laden air stream from the dryer cyclone (MAC HE60) prior to being discharged into the atmosphere. [District Rules 2201 and 4102] Cooler and Conveying System: The system consists of three cooler sections, all vented to MAC high efficiency cyclone, a discharge conveyor transfer dried kibbles into a hopper. The material from the hopper is pneumatically Page: 7

9 Diamond Pet Food Processors of Ripon N to '-6, N conveyed to an enclosed shaker screener. The owner or operator shall install, maintain, and operate Uniqair's, 9 kw, 9 plasma cylinders, cold plasma injection system to abate odors in laden air stream from the dryer cooler cyclone (MAC) prior to being discharged into the atmosphere. [District Rules 2201 and 4102] Fines Collection and Conveying System: This system collects fines from two locations in the dryer, the dryer cyclone discharge, and the cooler cyclone discharge, and vent these fines to a HORIZON SYSTEMS 285 WRDL8 (or equal) baghouse. This baghouse is vented indoors. [District Rule 2201] Screening and Conveying System. The system consists of an enclosed shaker screener, an enclosed surge bin, and an enclosed weigh belt. The fines (rejects) are conveyed to the totes in the basement. The surge bin shall be vented to a HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge dust collector system. Each tote shall have tight-fitting top lid with a static sock filter. [District Rule 2201] Coating and Conveying System: The system consists of a hopper where material from a weight belt is sprayed with chicken fat and canola oil (or other similar ingredients) and a coating reel where dry dog/cat digest and probiotics (or other similar ingredients) are sprinkled to be absorbed into the kibbles. The kibbles are then conveyed pneumatically to a vertical cooler system using filter receiver system with a static sock. [District Rule 2201] Vertical Cooler and Conveying System: A vertical cooler vented to a MAC HE52 (or equal) high efficiency cyclone. The dried material falls on a vibratory pan on sliding rails. The material (accepts) from vibratory pan drops into a hopper from where the dried kibbles are pneumatically conveyed to 14 finished product bins. Each bin shall be vented to a HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge dust collector system. The fines (rejects) from MAC H E52 (or equal) cyclone discharge and vibratory pan are conveyed to the totes in the basement. Each tote shall have tight-fitting top lid with a static sock filter. The owner or operator shall install, maintain, and operate Uniqair's, 3 kw, 3 plasma cylinders, cold plasma injection system to abate odors in laden air stream from the vertical cooler cyclone (MAC HE52) prior to being discharged into the atmosphere. [District Rules 2201 and 4102] VI. EMISSION CONTROL TECHNOLOGY EVALUATION N to '-6-0: Baghouses: Baghouses (or dust collectors, sock filters, cartridge filters etc.) are expected to have at least 99% control efficiency for PM10 emissions. Page: 8

10 Diamond Pet Food Processors of Ripon N to `-6, N To ensure the proper operation of these baghouses, the visible emissions from each dust collector will be limited to less than 5% opacity per District Policy SSP (9/16/98). The following condition will be included in each permit: Visible emissions, at the exhaust of each dust collector system (baghouse, cartridge dust collector, cyclone etc.) shall not equal or exceed 5% opacity for a period or periods aggregating more than three minutes in any one hour. [District Rule 2201] Cyclones: There are multiple high efficiency cyclones at this site. Per EPA's AP-42, Appendix B.2, high efficiency cyclones control 80% of the particles between microns in size. Thus, the proposed high efficiency cyclones are assumed to control at least 80% of the particles between microns in size (PMio). Cold Plasma Injection Systems: The primary purpose of this technology is to abate pet food odors. Pilot testing (July, 2013) showed 92-97% odor reduction for the most odorous streams from the pet food manufacturing operations. The effect of this technology on VOC, NOx and CO emissions is unknown at this time. VII. EMISSION CALCULATIONS A. Assumptions Assumptions will be stated as they are made during the evaluation. B. Emission Factors 1. Pre-project Emission Factors (EF1) N Per ATC N , EF1 = lb-pm 1 0/ton of material N to `-6 The previously issued ATCs cannot be converted into Permit to Operate (PT0s). Therefore, EF1s are not listed here. 2. Post-project Emission Factors (EF2) N The applicant is not proposing any changes to the existing emission factor. Therefore, EF2 will be equal to EF1. Page: 9

11 EF2 = lb-pm10/ton of material Diamond Pet Food Processors of Ripon N to `-6, N N Pre-grind system: Under ATC N , `-3-0, Diamond was required to conduct source testing on one of the four hammermills. The test results indicate that the average PK emissions were lb/ton of material processed. Based on these results, Diamond proposed to establish an emission factor of lb-pm10/ton of material processed. Thus, EF2 = lb-pm10/ton of material processed Material transfer and storage operations: Diamond is not proposing any changes to the material transfer and storage operations. Therefore, the EF established under ATC N is used here. EF2 = lb-pmio/ton of material transferred N Grinding system: EF2 = lb-pmio/ton of material 3 Material transfer into the unloading bins and truck loadout operation: Diamond is not proposing any changes to the material transfer operations. Therefore, the EF established under ATC N is used here. EF2 = lb-pm 10/ton of material transferred N , `-5-1 and `-6-1 Natural aas combustion in dryer: Pollutant EF2 Source NO % 02 (0.024 lb/mmbtu) N , `-5-0 and `-6-0 SO, lb/mmbtu District Policy APR *PK() -- See table footnote CO % 02 Applicant's proposal (0.112 lb/mmbtu) *VOC -- See table footnote *PMit) and VOC emissions are included in the process emissions (see below); note that the dryers are direct-fired units. 3Please refer to the discussion under permit N Page: 10

12 Diamond Pet Food Processors of Ripon N to `-6, N Process emissions: PMio: There are multiple emission units under each permit. These emissions are shown on a worksheet in Appendix Ill of this document. Based on the emissions in this worksheet PK emission factor is determined to be lb/ton of finished material for all particulate matter emitting operations including sources vented through wet cyclone, dryer cyclone, dryer cooler cyclone, vertical cooler, and other material conveying activities. Therefore, EF2 = lb-pmio/ton of finished material VOC: The applicant has proposed to establish VOC emission limit of lb/ton of finished material for all VOC emitting operations including sources vented through wet cyclone, dryer cyclone, dryer cooler cyclone, vertical cooler. Therefore, EF2 = lb/ton of finished material C. Potential to Emit 1. Pre-Project Potential to Emit (PE1) N The ATC N limits the processing rate to 1,200 tons/day. Therefore, PE1 = ( lb-pm10/ton of material)(1,200 tons/day) = 1.8 lb-pmiciday (657 lb-pmio/yr) N to `-6 These units are treated as new emissions units, as none of the previously issued ATCs can be converted into Permit to Operate (PTO). Therefore, EF1s are not listed here. 2. Post-Project Potential to Emit (PE2) N The applicant is not, proposing any changes to the daily processing rate. Thus, PE2 will be same as PE1 for daily emissions. PE2 = 1.8 lb-pmio/day The applicant has proposed to establish a processing rate of 380,000 tons/yr. Thus, Page: 11

13 Diamond Pet Food Processors of Ripon N to `-6, N PE2 = ( lb-pmio/ton of material)(380,000 tons/yr) = 570 lb-pm 1 0/yr N Pre-grind system: Using process rates of 400 tons/day and 50,000 tons/yr for the pre-grind system, the potential emissions would be: PE2 = (0.021 lb-pmio/ton of material)(400 tons/day) = 8.4 lb-pmio/day PE2 = (0.021 lb-pm 1 0/ton of material)(50,000 tons/yr) = 1,050 lb-pmio/yr Material transfer and storage operations: Using process rates of 800 tons/day and 50,000 tons/yr, the potential emissions would be: PE2 = ( lb-pmio/ton of material)(800 tons/day) = 0.2 lb-pmio/day PE2 = ( lb-pmio/ton of material)(50,000 tons/yr) = 13 lb-pm10/yr N Grinding system: Using the proposed rate of 800 tons/day/hammermill and a combined rate of 800 tons/day for all hammermills, the emissions would be: PE2 = (0.021 lb-pmio/ton of material)(800 tons/day/hammermill) = 16.8 lb-pmio/day (6,132 lb-pmio/yr) Material transfer into the unloading bins and truck loadout operation: Using process rate of 800 tons/day, the emissions would be: PE2 = ( lb-pm10/ton of material transferred)(800 tons/day) = 0.7 lb-pmio/day (256 lb-pmio/yr) N , `-5-1, `-6-1 Natural gas combustion in dryer: The potential emissions for a dryer under each permit unit are as follows: PE2 (lb/day) PE2 (lb/yr) = (EF2 lb/mmbtu)(10.0 MMBtu/hr)(24 hr/day) = (PE2 lb/day)(365 days/yr) Page: 12

14 Diamond Pet Food Processors of Ripon N to `-6, N Pollutant EF2 (Ib/MMBtu) PE2 (lb/day) PE2 (lb/yr) NO ,117 50x *PK CO ,819 *VOC *Potential emissions are included in the process emissions (see below) Process emissions: There are several emission units under each permit. Overall, emissions from the permit units are determined in the following section using proposed production rate of 780 tons/day for each line, and a combined rate of 780 tons/day for all lines. PMio: PE2 = ( lb-pmio/ton of finished material)(780 tons/day/line) = 47.7 lb-pmio/day (17,411 lb-pm10/yr) VOC: PE2 = (0.037 lb-voc/ton of finished material)(780 tons/day/line) = 28.9 lb-voc/day (10,549 lb-voc/yr) 3. Quarterly Emissions Changes (QEC) This calculation is required for application's emission profile, which is used for the District's internal tracking purposes. QECs are calculated as follows: QEC = (PE2 - PE1)/4 Permit Quarterly (lb) NO SO x PMio CO VOC N (21.75) -- N N , N ,451* 2, * N ,451* 2, * N ,451* 2, * *QECs are equally proportioned among the three dryers. 4. Adjusted Increase in Permitted Emissions (AIPE) AIPE is used to determine if BACT is required for modifications to an existing emissions unit with valid Permit to Operate. AIPE is calculated using the equations mentioned in Section 4.3 and 4.4 of Rule Page: 13

15 Diamond Pet Food Processors of Ripon N to `-6, N AIPE= PE2 (EF2) 0E1) EF1) N The existing ATC N can be converted into PTO. PE2 is equal to PE1 and EF2 is equal to EF1. Therefore, AIPE will be zero for PM10 emissions (the only pollutant of concern related to this permit unit). N to `-6 The existing ATCs cannot be converted into PT0s. Therefore, these units are treated as new emission units under this project. BACT for these units will be evaluated on "Potential to Emit" basis rather than "AIPE" basis. B. Facility Emissions 1. Pre-Project Stationary Source Potential to Emit (SSPE1) Pursuant to Section 4.9 of District Rule 2201, SSPE1 is the Potential to Emit 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 (ERCs) which have been banked since September 19, 1991 for Actual Emissions Reductions (AERs) that have occurred at the source, and which have not been used on-site. Except for permit N , the potential emissions are taken from the application review under project N The potential emissions for N are taken from the application review under project N SSPE1 (lb/yr) Permit NO SOx PMio CO VOC N N N N N , , N , , N ERC SSPE1 3, ,302 9,597 1,067 Page: 14

16 Diamond Pet Food Processors of Ripon N to `-6, N Post-Project Stationary Source Potential Emissions (SSPE2) Pursuant to Section 4.10 of District Rule 2201, the Post-Project Stationary Source Potential to Emit (SSPE2) 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 that have occurred at the source, and which have not been used on-site. SSPE2 (lb/yr) Permit NO SOx PMio CO VOC N N , N , N , ,819 N , ,411 9,819 10,549 N , ,819 N N N N , , N , , N ERC SSPE2 9,558 1,498 28,077 39,054 11, 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 specific source categories specified in 40 CFR

17 Diamond Pet Food Processors of Ripon N to `-6, N Rule 2201 Major Source Determination (lb/year) Category NO Sax PMio CO VOC SSPE1 3, ,302 9,597 1,067 SSPE2 9,558 1,498 28,077 39,054 11,616 Major Source Thresholds 20, , , ,000 20,000 Major Source? No No No No No From the above table, the facility is not an existing Major Source and is not becoming a Major Source as a result of this project. 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)(i). Therefore the following PSD Major Source thresholds are applicable. PSD Major Source Determination (tons/year) Category NO2 VOC SO2 CO PM PM10 CO2e Estimated Facility PE before Project ,980 4 Increase PSD Major Source ,000 Thresholds PSD Major Source? No No No No No No No From the above table, the facility is not an existing major source under PSD for any pollutant. 4. Stationary Source Increase in Permitted Emissions (SSIPE) SSIPE = SSPE2 - SSPE1 4Total CO2e = (116.6 lb-0o2e/mmbtu)(2 boilers x MMBtu/hr/boiler)(8,760 hr/yr)(ton/2,000 lb) for boilers under permits N and '-11 + (161.6 lb-0o2e/mmbtu)(14.3 gal/hr)(0.137 MMBtu/gal)(100 hr/yr) for diesel emergency engine under permit N = 14,964 tons-0o2e/yr + 16 tons-0o2e/yr = 14,980 tons-0o2e/yr Page: 16

18 Diamond Pet Food Processors of Ripon N to `-6, N Pollutant SSPE2 SSPE1 SSIPE (lb/yr) (lb/yr) (lb/yr) NO 9,558 3,207 6,351 SO x 1, PM 10 28,077 3,302 24,775 CO 39,054 9,597 29,457 VOC 11,616 1,067 10, SB 288 Major Modification The purpose of Major Modification calculations is to determine the following: A. If Best Available Control Technology (BACT) is triggered for a new or modified emission unit that results in a Major Modification (District Rule 2201, 4.1.3); and B. If a public notification is triggered (District Rule 2201, 5.4.1). Per section VII.D.3 of this document, this facility is not a Major Source for any pollutant. Thus, this project will not trigger an SB-288 Major Modification. 6. Federal Major Modification The purpose of Federal Major Modification calculations is to determine the following: A. If a Rule-compliance project qualifies for District Rule 2201's Best Available Control Technology (BACT) and offset exemptions (District Rule 2201, ); and B. If an Alternate Siting analysis must be performed (District Rule 2201, ); C. If the applicant must provide certification that all California stationary sources owned, operated, or controlled by the applicant that are subject to emission limits are in compliance with those limits or are on a schedule for compliance with all applicable emission limits and standards; and D. If a public notification is triggered. (District Rule 2201, 5.4.1) Per section VII.D.3 of this document, this facility is not a Major Source for any pollutant. Thus, this project will not trigger a Federal Major Modification. Page: 17

19 Diamond Pet Food Processors of Ripon N to '-6, N VIII. COMPLIANCE Rule 2201 New and Modified Stationary Source Review Rule 1. Best Available Control Technology (BACT) BACT requirements shall be triggered on a pollutant-by-pollutant basis and on an emissions unit-by-emissions unit basis. Unless exempted pursuant to Section 4.2, BACT shall be required for the following actions: Any new emissions unit or relocation from one Stationary Source to another of an existing emissions unit with a Potential to Emit (PE2) exceeding 2.0 pounds in any one day; Modifications to an existing emissions unit with a valid Permit to Operate resulting in an Adjusted Increase in Permitted Emissions (AIPE) exceeding 2.0 pounds in any one day; Any new or modified emissions unit, in a stationary source project, which results in a Major Modification, as defined in this rule. NO R : The following units have potential to emit in excess of 2.0 pounds per day: o Dryers (N , '-5, and '-6) BACT Guideline is referenced to determine BACT for these dryers. The most stringent emission limit in this guideline is % 02 (0.024 lb/mmbtu). This limit is a technologically feasible option. The applicant has proposed to achieve % 02 or less (0.024 lb/mmbtu) for each dryer. Thus, BACT requirements are satisfied. Moreover, the District has also conducted a cost-effectiveness analysis to equip each dryer with a burner system capable of achieving 9.0 3% 02 (0.011 lb/mmbtu) or less for each dryer, and concluded that this option is not cost-effective at this time. Refer to Appendix II for detailed "Top-Down BACT Analysis". SO R : None of the proposed units has a potential to emit more than 2.0 pounds per day for SO R. PMio: The following units have potential to emit in excess of 2.0 pounds per day: o Hammermills (N , '-3) Page: 18

20 Diamond Pet Food Processors of Ripon N to '-6, N o o o o Hot kibble conveying operation (N , '-5, and '-6) Dryers (N , '-5, and '-6) Dryer coolers (N , '-5, and '-6) Vertical coolers (N , '-5, and '-6) Hammermills BACT Guideline is referenced to determine the BACT for a feed mill grain grinder. The most stringent technique is to use a baghouse. Each hammermill is vented to its own baghouse. Thus, BACT requirements are satisfied. Hot kibble conveying operation (N , '-5, and '-6) Dryers (N , '-5, and '-6) BACT Guideline is referenced to determine the BACT for conveying and drying process emissions. The most stringent technique is to use high efficiency cyclones due high moisture in the material. The hot kibble conveying and drying operations are vented through its own high efficiency cyclone. Thus, BACT requirements are satisfied. Dryer coolers (N , '-5, and '-6) BACT Guideline is referenced to determine the BACT for the cooling process emissions. The most stringent technique is to use enclosed conveyors and vent grain coolers to a 1D-3D cyclone high efficiency cyclone. Each dryer cooler and vertical cooler is vented through its own high efficiency cyclone. Thus, BACT requirements are satisfied. Refer to Appendix II for detailed "Top-Down BACT Analysis". CO: The potential CO emissions from the entire stationary source are less than 200,000 pounds per year. Thus, BACT is triggered for CO emissions. VOC: The following units have potential to emit in excess of 2.0 pounds per day: o o o o Hot kibble conveying operation (N , '-5, and '-6) Dryers (N , '-5, and '-6) Dryer coolers (N , '-5, and '-6) Vertical coolers (N , '-5, and '-6) A project specific "Top-Down BACT analysis" is presented in Appendix ll of this document. Based on this analysis, none of technologically feasible options (i.e., use of regenerative thermal oxidizer (RTO), carbon adsorption system, VOC Page: 19

21 Diamond Pet Food Processors of Ripon N to `-6, N concentrator with RTO, and biofiltration system) is cost effective, and therefore, is not required as BACT at this time. Note that Diamond has been authorized under ATC N to install multiple cold plasma injection units to abate pet food odors from various exhausts including dryer cyclone (MAC HE60), dryer cooler cyclone (MAC), wet kibble conveying cyclone (Horizon HT-68) and vertical cooler cyclone (MAC HE52). Diamond has conducted a pilot test in July 2013 to determine the effectiveness of the cold plasma injection system. The results of the pilot test study showed 92-97% odor reduction for the most odorous streams from the pet food manufacturing operations. The technology is not expected to have significant increase in collateral emissions; however, the District will require a test to ensure compliance with the emission factors in the permit. Diamond is not claiming any VOC control efficiency for the proposed plasma injection systems. The system is solely proposed to reduce pet food odor and nuisance complaints. 2. Offsets Offsets are examined on pollutant-by-pollutant basis. The following table summarizes SSPE2, offset thresholds, and whether or not offsets are triggered. Category NO SO x PMio CO VOC SSPE2 9,558 1,498 28,077 39,054 11,616 Offset Thresholds 20,000 54,750 29, ,000 20,000 Offsets Triggered? No No No No No 3. Public Notification District Rule 2201, section 5.4, requires a public notification for the affected pollutants from the following types of projects: New Major Sources Major Modifications (SB 288, Federal Major Modification) New emission units with a PE>100 lb/day of any one pollutant Modifications with SSPE1 below an Offset threshold and SSPE2 above an Offset threshold on a pollutant-by-pollutant basis New stationary sources with SSPE2 exceeding Offset thresholds Any permitting action with a SSIPE exceeding 20,000 lb/yr for any one pollutant Page: 20

22 Diamond Pet Food Processors of Ripon N to `-6, N Per section VII.D.4 of this document, SSIPE for CO and PNAio emissions exceed the 20,000 lb/yr threshold. Thus, this project triggers a 30-day public notice. 4. Daily Emission Limits (DELs) The daily emissions limitations (DELs) and other enforceable conditions are required by Section 3.17 to restrict a unit's maximum daily emissions. DELs for each permit are as follows: N The total PK() emissions from this permit unit shall not exceed pounds per ton of material received. [District Rule 2201] The combined amount of material received and loaded out shall not exceed 1,200 tons/day and 380,000 tons/year (12-month rolling basis). [District Rule 2201] N PK () emissions from the baghouse serving the pre-grind system shall not exceed pounds per ton of material processed. [District Rule 2201] The amount of material processed through the pre-grind system shall not exceed 400 tons/day and 50,000 tons/year (12-month rolling basis). [District Rule 2201] PIV110 emissions from material transfer and storage operations covered under this permit shall not exceed pounds per ton of material stored. [District Rule 2201] No more than 800 tons/day and 50,000 tons/year (12-month rolling basis) of total material, that is processed in pre-grind grind system and dispensed from other outdoor silos/bins, shall be transferred to storage bins in the mill tower. [District Rule 2201] N PK() emissions from each hammermill system shall not exceed pounds per ton of material processed. [District Rule 2201] The amount of material processed through each hammermill system shall not exceed 800 tons in any one day. [District Rule 2201] The total material processed through all three hammermill systems shall not exceed 800 tons in any one day. [District Rule 2201] Page: 21

23 Diamond Pet Food Processors of Ripon N to `-6, N PK emissions from the truck loadout operation shall not exceed pounds per ton of material loaded into trucks. [District Rule 2201] No more than 800 tons of material shall be processed or loaded into trucks using truck loadout spout in any one day. [District Rule 2201] N , `-5-1, `-6-1 PK () emissions from the operations covered under this permit shall not exceed pounds per ton of finished material produced. [District Rule 2201] VOC emissions from the operations covered under this permit shall not exceed pounds per ton of finished material produced. [District Rule 2201] No more than 36 tons of ground meat shall be injected into the steamconditioner in any one day. [District Rule 2201] 5 The amount of finished material produced under this line shall not exceed 780 tons in any one day. [District Rule 2201] The total material processed through all pet food manufacturing lines (N , `-5 and `-6) shall not exceed 780 tons in any one day. [District Rule 2201] Emissions from the dryer shall not exceed any of the following limits: 2.1 ppmvd 19% 02 (0.024 lb-nommbtu), 16.5 ppmvd 19% 02(0.112 lb-co/mmbtu) and lb-sommbtu. [District Rules 2201 and 4309] 5. Compliance Assurance Source Testing N This permit unit has two baghouse, each CAMCORP MODEL 10TR10x100 baghouse, that serves material receiving pits, scalpers (screening units), and elevators. Furthermore, each storage bins has own HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge dust collector system. Per District Policy APR-1705, Section II, Step 4, non-combustion equipment served by a baghouse or dust collector with expected PK emissions of 30 pounds per day or greater must be tested upon initial start-up. Units with PNlio 5This condition is taken from the ATC project N , and is retained in this project to validate VOC and PM10 emission factor, which were established during testing under ATC N , '-5-0 and '-6-0. Page: 22

24 Diamond Pet Food Processors of Ripon N to `-6, N emissions in excess of 70 pounds per day should also be tested on annual basis. The potential emissions from the permit unit are 1.8 lb-pm 10/day. These emissions are estimated using generally accepted emission factors. Therefore, source testing is not required. N The hammermill and screen (one packaged unit) in this permit is served by a MAC96 LDT64 STYLE II baghouse. The other units such as the enclosed bucket elevators (leg #3, leg #4), drag screw conveyors, and each mill tower bin are served by HORIZON SYSTEMS Model 21VFTC6 cartridge dust collector systems. Per District Policy APR-705, Section II, Step 4, non-combustion equipment served by a baghouse or dust collector with expected PK() emissions of 30 pounds per day or greater must be tested upon initial start-up. Units with PNlio emissions in excess of 70 pounds per day should also be tested on annual basis. The potential PK() emissions from the permit unit are 8.6 pounds per day. About 8.4 pounds per day (i.e., about 98% of the PMio emissions) of these emissions are associated with the hammermill system served by a baghouse. These emissions were estimated using pipposed emission factor of lb/ton of material. In the past, Diamond has conducted a source test on one of the four hammermills and found that the average PK emissions are lb/ton of material. Therefore, compliance is expected With the proposed emission factor and no additional testing is required. The potential emissions for other units (2% of the total emissions) such as material transfer and storage operations under this permit are determined using generally accepted emission factors established under permit N Therefore, source testing is not required for these units. N This permit unit has HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge dust collectors that will serve various surge bins (mixer bins, extruder bins etc.), scales and a vibratory screener, and the unloading bins in the truck loadout, and a MAC LST AIR 96LST196 (or equal) baghouses that serves hammermill systems. Per District Policy APR-705, Section II, Step 4, non-combustion equipment served by a baghouse or dust collector with expected PM10 emissions of 30 pounds per day or greater must be tested upon initial start-up. Units with PMio emissions in excess of 70 pounds per day should also be tested on annual basis. Page: 23

25 Diamond Pet Food Processors of Ripon N to `-6, N The potential PMio emissions from the permit unit are 17.5 pounds per day. About 16.8 pounds per day (i.e., about 96% of the PM10 emissions) of these emissions are associated with hammermill systems served by baghouses. The emissions were estimated using proposed emission factor of lb/ton of material. In the past, Diamond has conducted a source test on one of the four hammermills and found that the average PK emissions are lb/ton of material. Therefore, compliance is expected with the proposed emission factor and no additional testing is required. The potential emissions for other units (4% of the total emissions) such as material transfer operations and truck loadout under this permit are determined using generally accepted emission factors established under permit N Therefore, source testing is not required for these units. N , `-5-1, `-6-1 Each of these permit units have a hot kibble conveying cyclone (Horizon HT- 68 cyclone) conveying wet kibbles from an extruder to a dryer, a 10 MMBtu/hr natural gas-fired dryer exhaust of which is vented through a MAC HE60 high efficiency cyclone, a dryer cooler vented through a MAC high efficiency cyclone, material fines collection system collecting fines from two locations in the dryer and vent those to an indoor HORIZON SYSTEMS 285 WRDL8 (or equal) bag house, a vertical cooler vented through a MAC HE52 high efficiency cyclone, and finished storage bins each served by HORIZON SYSTEMS MODEL 21VFTC6 (or equal) cartridge dust collector systems. VOC and odorous compounds: The exhaust streams from Horizon HT-68, MAC HE60, MAC, and MAC HE52 are odorous and contain several types of VOC compounds. These streams will be treated by injecting extremely reactive gas comprised of a mixture of oxygen atoms, ions, and radicals, etc. (approx. 10% of the laden airflow rate stream) generated by the cold plasma injection systems by ionizing the ambient air. The injected plasma will react with the laden stream and is expected to reduce the intensity of odorous compounds including VOC emissions. Diamond is required to determine odor control efficiency (via odor panel tests) of full-scale cold plasma injection system on each exhaust stream. The test data will be useful to evaluate performance of the full-scale system, and to determine if additional cold plasma injection units are needed for further reduction of odorous compounds to completely eliminate nuisance concerns. Diamond is also required to conduct VOC testing after installing the cold plasma injection systems. This testing will ensure compliance with the proposed VOC emission limits. Note that the proposed plasma injection system will have some effect on the VOC emissions, so this testing is Page: 24

26 Diamond Pet Food Processors of Ripon N to '-6, N necessary to ensure that the system would not adversely affect the VOC emissions. Both VOC and odor control efficiency testing will be required to be completed within 60 days of startup under the permit, and at any time after the initial test should conditions at this facility warrant such testing. PMio emissions: Per District Policy APR-705, Section II, Step 4, non-combustion equipment served by a baghouse or dust collector with expected PK emissions of 30 pounds per day or greater must be tested upon initial start-up. Units with PN/lio emissions in excess of 70 pounds per day should also be tested on annual basis. The potential emissions from each permit unit are 47.7 lb-pm10/day. These emissions are estimated using the results from previous source tests. The proposed cold plasma injection system is not expected to adversely affect the particulate matter emissions. Therefore, no additional testing is not considered. NOx and CO: Diamond is required to conduct NO and CO testing within 60-days after installing the cold plasma injection system and 24-months thereafter. This testing will ensure that the cold plasma injection is not generating collateral NOx or CO emissions by oxidizing nitrogen and carbon compounds in the exhaust stream. Note that the on-going periodic testing is required by Rule Monitoring N to `-3-2 No monitoring is required. N , `-5-1, `-6-1 The applicant has proposed to monitor NO x, CO and 02 concentrations on a monthly basis using portable analyzer under ATCs N , '-5-0 and '-6-0. This monitoring scheme is retained in the permits associated with this project. Recordkeeping N to `-3-2 The applicant will be required to keep records of the date, type of material, and amount of the material received/processed. N , `- 5-1, `-6-1 The applicant will be required to keep records of NO x, CO and 02 readings on a monthly basis, and process rate records. All records are required to be kept for a period of at least 5 years. Page: 25

27 Diamond Pet Food Processors of Ripon N to `-6, N Reporting Source test reports will be required to be submitted within 60 days of each source test. 6. Ambient Air Quality Analysis (AAQA) Pursuant to Section 4.14 of Rule 2201, an AAQA shall 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. The District's Technical Services Division conducted the required analysis. The following table shows the summary of AAQA: Pollutant 1 Hour 3 Hours 8 Hours 24 Hours Annual CO 'Pass X Pass X X NO Rass i X X X Rass SO x 'Pass Pass X P,ass Pass PM10 X X X Pass2 Pass' PM25 X X X Pass 2 Pas2 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. 2Refined modeling was performed to determine if the pollutant's impact was below EPA's level of significance as found in 40 CFR Part (b)(2). The criteria pollutant was determined to be below EPA's level of significance. The emissions from the proposed equipment will not cause or contribute significantly to a violation of the State and National AAQS. 7. Compliance Certification Per Section 4.15 of Rule 2201, "Compliance Certification" and "Alternative Siting Analysis" is required for any project, which constitutes a New Major Source or a Federal Major Modification. This facility is not a new major source. Furthermore, the proposed project does not constitute a Federal major modification. Therefore, compliance certification and alternative siting analysis is not required. Compliance is expected with this Rule. Rule 4101 Visible Emissions Section 5.0, indicates that no air contaminant shall be discharged into the atmosphere for a period or periods aggregating more than three minutes in any one hour, which is dark or darker than Ringlemann 1 or equivalent to 20% opacity. The following condition will be placed in each permit: No air contaminant shall be discharged into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is as dark as, or darker than, Ringelmann 1 or 20% opacity. [District Rule Compliance is expected with this Rule. Page: 26

28 Diamond Pet Food Processors of Ripon N to `-6, N Rule 4102 Nuisance Section 4.0 prohibits discharge of air contaminants, which could cause injury, detriment, nuisance or annoyance to the public. The following condition will be placed on each permit: No air contaminant shall be released into the atmosphere, which causes a public nuisance. [District Rule 4102] California Health & Safety Code Health Risk Assessment District Policy APR 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. The Risk Management Review summary is as follows: Categories Prioritization Score Acute Hazard Index Chronic Hazard Index Maximum Individual Cancer Risk T-BACT Required? Special Permit Conditions? Risk Mariagemerif Review Summary Unit - Unit Unit nit V' Unit 1-2 Unit 6-1 Project Total Facility,17otal N/A N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A 1 N/A No No No No No No No No No No No No The project passed on prioritization with a score ess than.0; therefore, no further analysis is necessary. 2There was no increase in emissions associated with this unit; therefore, this unit is not included in the analysis. 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. Compliance is expected with this Rule. Rule 4201 Particulate Matter Concentration Section 3.0 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. Page: 27

29 Diamond Pet Food Processors of Ripon N to `-6, N N , `-2-2, `-3-2 Source test conducted on one of the hammermills indicates grain loading factor of gr/dscf, which is below the 0.1 gr/dscf limit. Therefore, each baghouse at this site is expected to comply with the requirements in this rule. N , `-5-1 and `-6-1 The following equation is used to estimate the grain loading factor for each of the PM emitting unit under these permits: pm( gr dscf (E lb PM )(7,000 gr PM) hr lb PM ( IF ft 3 \(60 min) minj hr ) Unit Emissions (E, lb/h r) Flow rate (F, dscfm) PM (gr/dscf) Expect Compliance (Yes/No) Extruder served by Horizon HT-68 cyclone , Yes Dryer served by MAC HE-60 cyclone , Yes Dryer cooler served by MAC cyclone , Yes Vertical cooler served by MAC HE-52 cyclone , Yes *Hourly emissions are estimated using daily emissions from potential emissions worksheet in Appendix II of this document. The following condition will be listed in each permit: Particulate matter emissions shall not exceed 0.1 grains/dscf in concentration. [District Rule 4201] Compliance is expected with this Rule. Rule 4202 Particulate Matter - Emission Rate Section 4.0 of this rule, a person shall not discharge into the atmosphere PM emissions in excess of the maximum allowable limit (E Max), in lb/hr, determined by the following specified in this Rule: EN/lax = 3.59 P.62 for Process weight (P) less than or equal to 30 tons/hr Emax = P c3.16 for Process weight (P) greater than 30 tons/hr Page: 28

30 Diamond Pet Food Processors of Ripon N to '-6, N Permit # Total PK (lb/hr) Process Rate (tons/hr) E Proposed (lb-pm/hr) Emax (lb-pm/hr) Expect Compliance (Yes/No) N * Yes N * Yes N * Yes N , '-5-1, ' Yes *Prvl io/pm fraction of 0.91 is used based on the information in the source test on 9/11/12. The proposed PM emission rate (EProposed) is not greater than the maximum allowable PM emission rate (Emax) for each permit unit. Therefore, compliance is expected with this Rule. Rule 4301 Fuel Burning Equipment Section 3.1 of the rule defines fuel burning equipment as any furnace, boiler, apparatus, stack, and all appurtenances thereto, used in the process of burning fuel for the primary purpose of producing heat or power by indirect heat transfer. The dryers under permits N , '-5 and '-6 are direct-fired heat transfer system. Therefore, this rule is not applicable to these units. Rule 4309 Dryers, Dehydrators, and Ovens This rule is applicable to dryers, dehydrator and oven that are rated at total heat input rating of 5.0 MMBtu/hr or greater. Each of the proposed dryers is rated at 10.0 MMBtu/hr. Therefore, these dryers are subject to the requirements of this Rule. Section 5.2 requires the permittee to meet 4.3 ppmvd 19% 02 (or 4.3 ppmvd, if stack 02> 19% 02) and 42 ppmvd 19% 02 (or 42 ppmvd, if stack 02> 19% 02) using gaseous fuel. The applicant has proposed to achieve 2.2 ppmvd NO 19% 02 and % 02). Therefore, compliance is expected with these limits. Section 5.4 requires the permittee to install and maintain APCO-approved CEMS for NOx and 02 or other alternative emissions monitoring method. The applicant has proposed to utilize portable analyzer to measure NOx, CO and 02 concentrations. This monitoring scheme satisfies the requirements of this section. The compliance determination is required to be performed in accordance with Section 5.5 of this Rule. Page: 29

31 Diamond Pet Food Processors of Ripon N to `-6, N Section requires the permittee to keep records of total hours of operation, type and quantity of fuel used during the operation, measurement for each surrogate parameter, and range of allowed values for each surrogate parameter. The permittee has proposed to use portable analyzer to measure NOR, CO and 02 concentrations. No surrogate parameter is being established. The permittee will be required to keep records of total hours of operation and type and quantity of fuel used on daily basis. Section requires the permittee to keep all records on-site for a period of five years. The applicant will be required to keep all records for a period of at least five years. Section requires the permittee to perform initial source test to determine compliance with NO x and CO emission limits. Furthermore, the unit is required to be tested every 24 months. The applicant has already demonstrated compliance with NOx and CO emissions. Therefore, initial test is not required. The unit is required to test once every 24 months. Compliance is expected with this Rule. Rule 4801 Sulfur Compounds Section 3.1 states that a person shall not discharge into the atmosphere sulfur compounds, which would exist as a liquid or gas at standard conditions, exceeding a concentration of two-tenths (0.2) percent by volume calculated as sulfur dioxide (S02) at the point of discharge on a dry basis averaged over 15 consecutive minutes. This rule applies to the dryers under permits N , `-5 and `-6. For natural gas combustion at a reference state of 60 F, the Rule 4801 limit of 2,000 ppmvd is equivalent to: (2000 ppmvd) 8,578 dscf )(64 lb S0 x MMBtuA lb mol (379.5 dscf 006) lb mol 2.9 lb S0x MMBtu The expected SOx emissions are lb/mmbtu significantly less than 2.9 lb- S0x/MMBtu allowed by this Rule. Therefore, compliance is expected with the requirements of this Rule. California Environmental Quality ACT (CEQA) The California Environmental Quality Act (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, Page: 30

32 Diamond Pet Food Processors of Ripon N to '-6, N including the orderly evaluation of projects and preparation of environmental documents. The San Joaquin Valley Unified Air Pollution Control District (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. 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. The City of Ripon (City) is the public agency having principal responsibility for approving the project. As such, the City served as the Lead Agency (CCR 15367). In approving the project, the Lead Agency prepared and adopted a Negative Declaration. The Lead agency filed a Notice of Determination, stating that the environmental document was adopted pursuant to the provisions of CEQA and concluding that the project would not have a significant effect on the environment. The District is a Responsible Agency for the project because of its discretionary approval power over the project via its Permits Rule (Rule 2010) and New Source Review Rule (Rule 2201), (CCR 15381). As a Responsible Agency the District complies with CEQA by considering the environmental document prepared by the Lead Agency, and by reaching its own conclusion on whether and how to approve the project (CCR 15096). The District has considered the Lead Agency's environmental document. Furthermore, the District has conducted an engineering evaluation of the project, this document, which demonstrates that Stationary Source emissions from the project would be below the District's thresholds of significance for criteria pollutants. Thus, the District finds that through a combination of project design elements, compliance with applicable District rules and regulations, and compliance with District air permit conditions, project specific stationary source emissions will have a less than significant impact on air quality. The District does not have authority over any of the other project impacts and has, therefore, determined that no additional findings are required (CEQA Guidelines 15096(h)). Page: 31