Date Issued:

*The numerical section references in this Permit are based on Maricopa
County Air Pollution Control Rules and Regulations (Rules) in effect on
the date of issuance of these Permit Conditions. In the event that these
Rules are revised to change the content and numerical references during
the term of this Permit, the revised Rules and numbering system will
apply to this permit.*

**[GENERAL CONDITIONS:]{.underline}**

1.  **Certification:**

Any document which is required to be submitted by this Permit shall
contain certification by a responsible official of truth, accuracy and
completeness. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and
information in the document are true, accurate and complete.

\[Rule 100, §200.95\]

**2. Confidentiality Claims:**

Except as provided for in Rule 100, any records, reports, or information
obtained from the Permittee pursuant to the County Rules or this Permit
shall be available to the public unless the Control Officer has notified
the Permittee in writing and unless a person:

a.  Precisely identifies the information in the permit(s), records, or
    reports which is considered confidential.

b**.** Provides sufficient supporting information to allow the Control
Officer to evaluate whether such information satisfies the requirements
related to trade secrets.

A claim of confidentiality shall not excuse a person from providing any
and all information required or requested by the Control Officer and
shall not be a defense for failure to provide such information.

\[Rule 100, §200.107, §402 and Rule 200, §411\]

**3. Controls:**

> Due to malfunction in an emergency situation, provided that the
> Permittee fulfills the notification requirements in accordance with
> Rule 100 §501, and Rules 130 and 140, the Permittee shall have an
> affirmative defense.

\[Rule 100, §501, Rules 130 and Rule 140\]

> The Permittee shall notify the Control Officer, in accordance with
> Rule 220, before making any additions, modifications or replacements
> to any required air pollution control equipment. This notification
> requirement does not apply to normal maintenance and repair
> activities.
>
> \[Rule 220, §404 and §405\]

4.  **Duty to Supplement or Correct Application:**

The Permittee who fails to submit any relevant facts or who has
submitted incorrect information in a permit application shall, upon
becoming aware of such failure or incorrect submittal, promptly submit
such supplementary facts or corrected information. In addition, an
applicant shall provide additional information as necessary to address
any requirements that become applicable to the source after the date it
filed a complete application but prior to release of a proposed permit.

\[Rule 220, §301.5\]

**5.** **Duty to Comply:**

The Permittee shall comply with all conditions of this Permit including
all applicable requirements of Federal laws, Arizona laws, and Maricopa
County Air Pollution Control Rules and Regulations.

\[Rule 200, §308\]

It shall not be a defense for the Permittee in an enforcement action
that it would have been necessary to halt or reduce the permitted
activity in order to maintain compliance with these Permit Conditions.

\[Rule 220, §302.10\]

**6.** **Fees:**

The Permittee shall pay, in a timely manner, an annual fee for this
Permit as determined by the Control Officer in accordance with Rule 280.

\[Rule 280, §302\]

**7.** **Fugitive Dust:**

The Permittee shall take all reasonable precautions to minimize the
emissions of fugitive dust in accordance with §300 of Rule 310.

\[Rule 310, §300\]

**8.** **Leased/Rented/Borrowed Equipment:**

If the Permittee leases, rents or lends any equipment covered by this
Permit to a second party, the Permittee shall provide the second party
with a copy of this Permit. It is the responsibility of the person using
the equipment to make sure that the equipment is properly permitted and
operated. If the Permittee does not provide the second party with a copy
of this Permit, both the Permittee and the second party shall be
responsible for operating the source in compliance with the Permit and
for any violation thereof.

\[Rule 200, §300\]

**9.** **Malfunctions (Emergency Upsets) and Excess Emissions:**

Emergencies, malfunctions, and other excess emissions shall be reported
as required by Rule 100, Section 500.

\[Rule 100, §400 and §500; Rule 130, §400; Rule 140, §400 and §500\]

**10.** **Material Containment:**

Materials including, but not limited to, solvents or other volatile
compounds, paints, acids, alkalies, pesticides, fertilizer and manure
shall be processed, stored, used and transported in such a manner and by
such means that they will not unreasonably evaporate, leak, escape or be
otherwise discharged into the ambient air so as to cause or contribute
to air pollution.

\[Rule 320, §302\]

**11.** **Modifications:**

The Permittee shall notify the Control Officer, in accordance with Rule
220, of changes, replacements or additions to the source which are not
covered by this Permit.

\[Rule 200, §312.3 and Rule 220, §400\]

**12.** **Odors:**

The Permittee shall not emit gaseous or odorous air contaminants from
equipment, operations or premises under his control in such quantities
or concentrations as to cause air pollution.

\[Rule 320, §300\]

**13. Permit Term, Permit Transfer, and Permit Renewal:**

a\. This Permit shall remain in effect for no more than 5 years.

\[Rule 220, §402\]

b\. Except as provided in Rule 200, this Permit may be transferred to
another person if the person who holds the permit gives notice to the
Control Officer in writing at least 30 days before the proposed transfer
and complies with the permit transfer requirements of Rule 200 and the
administrative permit amendment procedures pursuant to Rule 220.

\[Rule 200, §400 and Rule 220, §405.1\]

The Permittee shall file an application for a permit renewal at least
six months, but not more than 18 months, before the expiration date of
this Permit.

\[Rule 220, §301.3a\]

**14.** **Record Keeping:**

The Permittee shall maintain accurate records as required by these
Permit Conditions and by Section 500 of all applicable Rules. These
records shall be kept in a form, which allows easy verification of
compliance with these Permit Conditions and any applicable Rules.

All records shall be kept for the time as specified. All records
required to demonstrate that each required air pollution control device
is being operated properly shall be retained for five years.

All records required by this Permit should be made available for
inspection upon request by a representative of the Control Officer.

Upon request, the Permittee shall furnish to the Control Officer copies
of records required to be kept by this Permit.

\[Rule 100, §504; Rule 220, §302.7; and §500 of All Applicable Rules\]

15. **Reopening For Cause:**

This Permit shall be reopened or revised prior to expiration under any
of the following conditions:

a.  Either the Control Officer or the Administrator of the United States
    Environmental Protection Agency (Administrator) determines that this
    Permit contains a material mistake or that inaccurate statements
    were made in establishing the emission standards or other terms or
    conditions of this Permit Revision, or

b\. Either the Control Officer or Administrator determines that this
Permit must be revised or revoked to assure compliance with the
applicable requirements.

\[Rule 200, §402\]

16. **Reporting:**

If notified, the Permittee shall submit an annual emissions inventory
report to the Control Officer. The report shall summarize the activities
and air pollution emissions from the facility during the previous
calendar year in accordance with §505 of Rule 100. The report shall be
filed on a form supplied by the Control Officer and shall be due by
April 30 or 90 days after the Control Officer makes the forms available,
whichever is later.

The Permittee shall furnish to the Control Officer, within a reasonable
time, any information that the Control Officer may request in writing to
determine whether cause exists for revising or revoking and reissuing
this Permit or to determine compliance with this Permit.

Upon request, the Permittee shall furnish to the Control Officer copies
of records required to be kept by this Permit.

The Permittee shall file any additional reports required by the Control
Officer in a complete and timely manner.

\[Rule 100, §501 and §505; Rule 220, §302.8 and §302.13\]

**17. Right to Entry:**

The authorized representative of the Control Officer, upon presentation
of credentials, shall be permitted:

a.  To enter upon the premises where the source is located or
    emission-related activity is conducted, or where records are
    required to be kept under the conditions of this Permit and,

b.  To have access to and copy, at reasonable times, any records that
    are required to be kept under the conditions of this Permit, and

c.  To inspect, at reasonable times, any source(s), equipment (including
    monitoring and air pollution control equipment), practices or
    operations regulated or required under the Permit, and

d.  To sample or monitor, at reasonable times, substances or parameters
    for the purpose of assuring compliance with the Permit or other
    applicable requirements, and

e.  To record any inspection by use of written, electronic, magnetic,
    and photographic media.

No claim of confidentiality for trade secrets or commercial information
available to the Permittee under Arizona Revised Statutes (ARS) 49-487
or Rule 200 §400 can limit the scope of or otherwise interfere with an
on-site inspection by a representative of the Control Officer. However,
a claim of confidentiality may be made on any information gathered
during the inspection to the extent identified in ARS 49-487 or Rule 200
§400.

\[Rule 100, §200.107 and §402; Rule 200, §411; Rule 220, §302.17-21\]

**18.** **Rights and Privileges:**

This Permit does not convey any property rights nor exclusive privileges
of any sort.

\[Rule 220, §302.12\]

**19.** **Severability:**

The provisions of this Permit are severable, and, if any provision of
this Permit is held invalid, the remainder of this Permit shall not be
affected thereby.

\[Rule 220, §302.9\]

20. **Start-up Notification:**

If a performance test is required, the Permittee shall give written
notification to the Department, Attention Source Test Compliance Section
Manager, at least 7 days but no more than 30 days before the initial
start-up of any new pollution abatement equipment or process that
requires a test. Start-up of the subject equipment or process, shall be
defined as the earliest occurrence of one of the following dates:

a\. The date that achieved maximum (or permitted) capacity occurs; or

b\. The date that a marketable product has been produced; or

c\. The date that achieved sustained product manufacturing occurs; or

d\. The date that the production line(s) or processes, exhausted to the
air pollution abatement equipment that require the test, have been
qualified to produce product that meets customer requirements.

This startup notification does not apply to processes or equipment
recognized by the Control Officer as being trivial or insignificant
activities.

\[Rule 270, §400\]

**[SPECIFIC CONDITIONS:]{.underline}**

21. **Allowable Emissions:**

> The Permittee shall not allow VOC emissions into the atmosphere to
> exceed 95 tons per any twelve consecutive month period from this
> facility.

\[Rule 220 §§302.2, 304\]

22. **Opacity:**

> The Permittee shall not discharge into the ambient air from any single
> source of emissions any air contaminant, other than uncombined water,
> in excess of 20% opacity.
>
> Visible emissions shall be monitored for on a daily basis from exhaust
> stacks and any associated ducts while the associated process equipment
> is operating at normal production capacity. If any visible emissions
> (excluding water vapor) are detected or reported, the Permittee shall
> determine the cause and/or the source of emissions. The Permittee
> shall then take corrective action(s), and, if necessary, shut down the
> applicable equipment associated with the visible emissions.
>
> \[Rule 300 §301, Rule 220 §302.5\]

23. **Controls:**

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a.  In order to demonstrate that the Permittee has installed Best
    Available Control Technology under Rule 241 §301.2, the Permittee
    shall not process EPS beads unless the exhausts from the
    pre-expansion (including the fluid bed dryer), aging, and mold
    processes are vented to an Emissions Control System (ECS), which
    includes the aging bag total enclosure, the Regenerative Thermal
    Oxidizer (RTO), and associated ductwork and monitoring devices,
    operated in accordance with the approved Operation and Maintenance
    (O&M) Plan and this permit condition. For this permit condition,
    processing of EPS beads refers only to operation of the
    pre-expansion, aging, and/or mold processes.

b.  The Permittee shall operate the ECS to meet the emission standards
    in Rule 358 §301.1 for products not defined as specialty, such that
    the sum of both the VOC that escapes to atmosphere from the
    pre-expansion, aging, and mold processes, and the residual VOC in
    the resulting blocks at the time they are released from the modeling
    machine, do not exceed 3.0 pounds per 100 pounds of raw beads
    processed.

c.  The Permittee shall operate the RTO such that the VOC destruction
    efficiency of RTO is no less than 95.0% of VOC by weight.

d.  The Permittee shall store all pre-puff beads in the bag room total
    enclosure. The Permittee shall maintain a negative pressure
    differential of at least 0.007 inches of water column in the bag
    room total enclosure. The Permittee shall keep the bag room total
    enclosure door closed except when an operator is entering or leaving
    the enclosure.

e.  The Permittee shall operate the RTO at a minimum combustion zone set
    point temperature of 1540 °F unless the Permittee has demonstrated
    through testing acceptable to the Control Officer that the required
    destruction efficiency can be met at a lower set point temperature.
    However, if compliance is demonstrated at a higher set point
    temperature, then the higher temperature shall become the minimum
    set point temperature. Subsequent to the Department's written
    approval of a completed performance test, this permit shall be
    reopened to incorporate the new RTO minimum combustion chamber set
    point temperature determined during the most recent
    Department-approved performance test, at which a minimum VOC
    destruction efficiency of 95.0% of VOC by weight has been achieved.

f.  The Permittee shall operate the ECS such that the overall VOC
    control efficiency from the pre-expansion (and fluid bed dryer),
    aging, and mold processes (i.e., until the block is released from
    the mold) is a minimum of 81.0% by weight. The Permittee shall store
    EPS bead processed in the pre-expander in the aging bag total
    enclosure. The Permittee shall maintain the aging bag total
    enclosure under negative pressure and vented to the RTO at all times
    EPS beads are being aged.

g.  At a minimum, RTO shall be equipped with a continuous combustion
    temperature gauge with continuous recorder (paper or electronic) and
    an instantaneous-read magnehelic gauge for monitoring duct system
    pressure prior to the RTO inlet. Continuous recording means no less
    than sampling, analyzing, and recording once per minute.

h.  At a minimum, the aging bag total enclosure shall be equipped with a
    pressure gauge to measure pressure drop across the enclosure to
    demonstrate compliance with Permit Condition 23(d).

\[Rule 220 §§302.2, 304; Rule 241 §301.2; Rule 358 §§§301, 305 and 306\]

24. **Operations & Maintenance (O&M) Plan Requirements:**

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a.  The Permittee shall submit an approvable O&M Plan for the ECS, to
    the Department, Attn: Permitting Supervisor within 45 days of the
    initial issuance of this permit in accordance with the Department
    guidelines. The Permittee shall revise the O&M Plan upon the request
    of the Department and whenever substantive changes are made to the
    equipment or plan, in accordance with the Department guidelines.

b.  The O&M Plan shall specify key system operating parameters, such as
    temperatures, pressures and/or flow rates, necessary to determine
    compliance and describe in detail procedures to maintain the
    approved emission control system. The Permittee shall monitor,
    operate and maintain the ECS and associated ECS monitoring devices
    in accordance with the approved O&M Plan.

c.  The O&M Plan shall include,

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1.  procedures for collecting and recording required data and other
    information in a form approved by the Control Officer, which shall
    include data collected through the O&M Plan and through the
    monitoring of key system operating parameters; and 

2.  Procedures and schedules for preventive and corrective maintenance
    performed for the purpose of maintaining the emission control system
    in proper operating condition.

> \[Rule 358 §306.2\]

d.  An owner and/or operator of an EPS facility must comply with all O&M
    Plans that the owner and/or operator has submitted for approval but
    which have not yet been approved, unless notified otherwise by the
    Control Officer in writing.\
    \[Rule 358 §306.3\]

e.  Changes to an existing O&M Plan shall be made by submitting a
    complete, revised O&M Plan along with a cover letter identifying all
    changes and the reason for such changes. The Permittee may implement
    the changes addressed in the revised O&M plan after it submits the
    revision to the Department. Unless disapproved in writing by the
    Department, the Permittee shall continue to operate in accordance
    with the revised O&M plan.

f.  If any control device is found to be operating outside a specified
    range, the Permittee shall immediately take corrective action to
    bring the device back into the specified operating range or shut
    down the device and the associated equipment vented to it.

g.  If a pattern of excursions, as determined by the Department or the
    Permittee, of operation outside the specified operating range
    develops, the Permittee shall submit for Department approval a
    Corrective Action Plan to bring the devices back into the specified
    operating range. The Plan shall be submitted to the Department,
    Attn: Compliance Division Manager, within 30 days of the
    determination of the existence of excursions.

h.  The Permittee shall comply with all O&M Plans submitted for approval
    but which have not yet been approved, unless notified otherwise by
    the Control Officer in writing.

> \[Rule 220 § 302.4; Rule 358 §§ 305.2, 306\]

25. **Monitoring Requirements:**

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a.  The Permittee shall prepare a monthly VOC emissions report to be
    kept on site for inspection upon request. The twelve month rolling
    total facility wide VOC emissions shall be calculated within 15 days
    following the end of each calendar month by summing VOC emissions
    over the most recent twelve calendar months.

> VOC emissions shall be calculated by summing emissions from the
> processing and storage of EPS beads, the combustion of fuel and the
> application of ink for block marking, labeling and packaging. The
> processing and storage VOC emissions shall be calculated in accordance
> with the following method, using the results of the most recent
> Department-approved performance test.
>
> \[County Rule 220 §302.8\]

1.  The Permittee shall calculate the VOC emissions from the processing
    and storage of EPS beads using the following equation:

> E*~P~* = Σ \[M*~i~* x P*~i~*\]\[E*~PL~*\]\[1-CE*~COMB~*\] + \[M*~i~* x
> P*~i~*\]\[E*~SL~*\] + \[m*~i~* x P*~i~*\]\[E*~GL~*\]
>
> Where:
>
> E*~P~* = Pentane loss from EPS processing and storage
>
> M*~i~* = Total pounds of EPS bead type *i* processed per month
>
> m*~i~* = Total pounds of EPS bead type *i* scrap foam which is
> processed through the grinders per month
>
> P*~i~* = Pentane content of EPS bead type *i*
>
> E*~PL~* = Process loss emission factor = 45%
>
> CE*~COMB~* = Combined control efficiency = capture efficiency x
> destruction efficiency = 81%
>
> E*~SL~* = Storage loss emission factor = 21% for average storage time
> of product
>
> E*~GL~* = Grinding loss emission factor = 0%
>
> The Permittee shall submit a permit modification, within 30 days of
> receipt of Department's written approval of a completed performance
> test, to reopen the permit and incorporate new Pentane emission loss
> and control efficiency factors established through results of the most
> recent Department-approved performance test.

2.  The Permittee shall calculate the VOC emissions from ink using the
    following equation:

> E*~S~* = Σ \[A*~i~* x C*~i~*\]
>
> Where:
>
> E*~S~* = VOC emissions from the use of ink
>
> A*~i~* = Amount of ink type *i* used at the facility
>
> C*~i~* = Concentration of VOC in ink type *i*

3.  The Permittee shall calculate the VOC emissions from combustion
    using the following equation:

> E*~C~* = Σ \[N*~i~* x EF*~i~*\]
>
> Where:
>
> E*~C~* = VOC emissions from the combustion of fuel
>
> N*~i~* = Amount of energy, or fuel, (depending on EF*~i~*) consumed
> using fuel type *i*
>
> EF*~i~* = VOC emission factor for fuel type *i*

4.  The Permittee shall calculate the total facility wide VOC emissions
    using the following equation:

> E*~T~* = E*~P~* + E*~S~* + E*~C~*

b.  If the twelve month rolling total facility wide VOC emissions
    reaches 76 tons per 12-month period (80% of limit), the Permittee
    shall prepare a weekly VOC emissions report to be kept on site for
    inspection upon request. The weekly rolling total facility wide VOC
    emissions shall be calculated by the end of the following week by
    summing VOC emissions over the most recent fifty two calendar weeks
    and shall record the amount of EPS beads that can be processed for
    the remainder of the calendar month without exceeding the 95-ton
    twelve month rolling total facility wide VOC emission limit. If the
    weekly VOC emissions report demonstrates emissions below 76 tons per
    12-month period, the Permittee shall return to monthly reporting.

c.  The twelve month rolling total bead usage shall be calculated within
    15 days following the end of each calendar month by summing the
    amount of beads used over the most recent twelve calendar months.

d.  The Permittee shall continuously monitor the RTO combustion chamber
    temperature, while EPS beads are being processed through the
    pre-expansion, aging bag total enclosure and/or molding process to
    demonstrate compliance with Permit Conditions 23(e).

e.  The Permittee shall monitor the pressure differential between the
    inside and outside of the aging bag total enclosure while EPS beads
    are being aged to demonstrate compliance with Permit Condition
    23(d).

\[Rule 220 §§302.2, 304\]

26. **VOC Containment, Identification, and Disposal:**

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a.  Contain VOC-Emitting Material:

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3.  When they are not in use, the Permittee shall store all fresh and
    used non-EPS VOC-containing material in closed, leak-free containers
    that are labeled according to paragraph d. Such materials include
    but are not limited to cleaning solvents, inks, coatings, thinners,
    and their residues including residues on rags; and

4.  Store raw EPS beads in closed, leak-free, labeled containers when
    not in use.

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b.  The Permittee may meet the requirements in paragraph a. of this
    permit condition if the materials described are placed in an
    enclosure solely ducted to an ECS that is approved by the Control
    Officer, instead of in closed containers.

c.  The Permittee must implement procedures to minimize spills of
    VOC-containing materials described in paragraph a. of this permit
    condition during their handling and transfer to or from containers,
    vats, enclosed systems, waste receptacles, and other equipment,
    whether the material is fresh, used, or waste.

d.  Identification and Labeling:

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1.  Containers used for initial, intermediate, or final storage of
    VOC-containing materials addressed in paragraph a. of this permit
    condition shall be clearly labeled with their contents.

2.  Content labeling done according to the requirements of federal
    hazardous waste (RCRA) or occupational health (OSHA) statutes and
    codes meets the requirements of this paragraph.

\[Rule 358 §307\]

27. **Reporting Requirements:**

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a.  The Permittee shall submit semiannual bead usage and VOC emissions
    reports within 60 days after the end of each six month period to the
    Department, attention: Compliance Division Manager. Six-month
    periods shall be January through June and July through December. The
    report shall also contain the following information at a minimum:

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1.  The monthly and twelve-month rolling total weight (in pounds) of
    each type of EPS bead conveyed to the pre-expanders and each type of
    EPS bead conveyed to the molders;

2.  The monthly and twelve-month rolling total facility-wide VOC
    emissions (in tons), as calculated pursuant to this permit, using
    the results of the most recent Department-approved performance test;

3.  Daily records showing the pressure differential between the inside
    and outside of the aging bag total enclosure.

4.  All instances of deviations from these permit conditions during the
    reporting period, the cause of the deviations if any were present,
    and any applicable corrective actions taken. If no deviations were
    observed, a statement to that effect will satisfy this requirement.

5.  Any excess emissions due to ECS failure under the provisions of
    Rules 130 or 140 as applicable.

6.  Emission factors from the last Department approved performance test.

7.  Site-wide twelve-month rolling total NOx and CO emissions.

> \[Rule 220 §§302.2, 304\]

28. **Performance Test Requirements:**

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a.  Testing Requirements: The Permittee shall conduct performance tests
    on the following equipment within 60 days after the permit issuance
    date or within 60 days after the new applicable equipment has
    achieved the capability to operate at its maximum production rate on
    a sustained basis, whichever occurs last. The testing deadline may
    be extended by the Control Officer for good cause, but in no case
    shall the testing deadline, including test report submittal, extend
    beyond 180 days after the permit issuance date or 180 days after the
    new applicable equipment has achieved the capability to operate at
    its maximum capacity, whichever occurs last. Failure to test within
    the time frame specified by this condition shall result in a
    continuing violation for each day beyond the deadline until the
    required performance test has occurred.

\[County Rule 200 §309\]\[County Rule 270 §401\]\[SIP Rule 27 §A\]

1.  The Permittee shall measure the VOC concentrations in the thermal
    oxidizer inlet and exhaust streams, at the minimum allowable
    combustion temperature, to demonstrate compliance with the minimum
    95% VOC destruction efficiency requirement and compliance with all
    applicable VOC emission limits of these permit conditions.

2.  The Permittee shall measure the VOC content in raw EPS beads and the
    residual VOC content in blocks after molding for use, in combination
    with the VOC concentration entering the thermal oxidizer, in
    determining the capture efficiency from pre-expansion, drying,
    aging, and molding processes.

3.  Using the test results for the VOC concentrations in the thermal
    oxidizer inlet and exhaust streams, the raw bead VOC content and the
    VOC content in block product after molding, the Permittee shall
    demonstrate that the applicable standards in County Rule 358 §301
    thru 304 are met by using the appropriate equations in County Rule
    358 §503.7.

4.  Using the test results for the VOC concentrations in the thermal
    oxidizer inlet and exhaust streams, the raw bead VOC content and the
    VOC content in block product after molding, the Permittee shall
    demonstrate an overall control efficiency, use the methodology in
    Rule 358 §503.7, of at least 81.0% VOC by weight from pre-expansion,
    drying, aging, and molding processes.

5.  The Permittee shall demonstrate that the aging bag farm meets all
    requirements of EPA Method 204 for determination of a total
    enclosure.

6.  The Permittee shall measure the residual VOC content in blocks that
    have been stored for the average storage time on site to determine
    the storage loss factor stated in condition 25(a).

7.  The Permittee shall measure the VOC content of a specific weight of
    scrap foam which is processed through the grinders and the VOC
    content of the material after grinding to determine the grinding
    loss factor stated in condition 25(a).

8.  The Permittee shall measure the concentrations of NOX and CO in the
    thermal oxidizer exhaust stream. Testing shall be used to determine
    the daily and annual emission rate of NOx and CO from the oxidizer
    to ensure site-wide emissions remain below BACT thresholds.

> \[County Rule 358 §301-304\]\[County Rule 358 §305.1\]\[County Rule
> 358 §503\]

b.  Following the initial performance test for this permit, the
    Permittee shall conduct performance tests annually between June 1
    and August 31.

> \[County Rule 358 §503\]

## Testing Criteria: Performance tests shall be conducted and data reduced in accordance with the test methods and procedures specified in the Test Methods section of this permit condition unless otherwise specified by the Control Officer and/or Administrator. The Control Officer and/or Administrator may specify or approve minor changes in methodology to a reference method, approve the use of an equivalent test method, approve the use of an alternative method that has been determined to be acceptable for demonstrating compliance, or waive the requirement for performance tests because the Permittee has demonstrated by other means that the source is in compliance with the standard. For NSPS facilities, only EPA has the authority to waive initial testing requirements. 

> \[County Rule 270 §402\]\[SIP Rule 27 §B\]

## Test Methods: Sampling sites and velocity traverse points shall be selected in accordance with EPA Test Method 1or 1A. The gas volumetric flow rate shall be measured in accordance with EPA Test Method 2, 2A, 2C, 2D, 2F, 2G or 19. The dry molecular weight shall be determined in accordance with EPA Test Method 3, 3A or 3B. The stack gas moisture shall be determined in accordance with EPA Test Method 4. These methods must be performed, as applicable, during each test run. 

> \[County Rule 270 §301.1\]\[SIP Rule 27 §B\]

1.  VOC destruction efficiency testing shall be conducted in accordance
    with EPA Test Method 25 or 25A. If the Permittee is using EPA Test
    Method 25A for VOC determination, then an analyzer response factor
    must be determined for pentane. Testing to quantify exempt
    compounds, such as methane, shall be conducted in accordance with
    EPA Test Method 18.

2.  Testing to determine the VOC content in raw beads, molded blocks and
    pre and post regrind material shall be conducted in accordance with
    either SCAQMD Method 306-91 or BAAQMD Method 45. Alternatively, the
    Permittee may test molded blocks in an enclosed test chamber using
    EPA Test Method 25 or 25A.

3.  For overall capture efficiency demonstration, the Permittee shall
    use the methodology in County Rule 358 §503.7 and EPA's "Guidelines
    for Determining Capture Efficiency" dated January 9, 1995, as
    applicable. If the Permittee is using EPA Test Method 25A for VOC
    determination, then an analyzer response factor must be determined
    for pentane. This response factor shall be used to compare the VOC
    content of both the raw and finished material and the VOC content
    entering the thermal oxidizer on an equal basis (as pentane) for
    proper calculation of the VOC capture efficiency.

4.  The total enclosure demonstration shall be conducted in accordance
    with EPA Test Method 204.

5.  NOX testing shall be conducted in accordance with EPA Test Method
    7E. CO testing shall be conducted in accordance with EPA Test Method
    10.

> \[County Rule 358 §503\]

## Operating Conditions: The Permittee shall test the destruction efficiency for each operating scenario (combination of pre-expansion, drying, aging and molding processes) that occurs during normal operation including the aging process alone if this is normal operation. Performance tests shall be conducted while operating under representative bead pre-expansion, drying, aging and molding conditions and shall result in the manufacture of a saleable product. The facility shall test using the highest specification range VOC content of bead (defined in Rule 358 §216) desired to be used by the facility to make a saleable product for this permit.

## Performance tests shall be conducted under representative operating conditions and all equipment shall be operated during testing in accordance with the most recently approved O&M Plan or according to its operations manual if no O&M Plan is required. The Permittee shall make available to the Control Officer any records necessary to determine appropriate conditions for performance tests. Operations during periods of startup, shutdown, and equipment malfunction shall not constitute representative conditions for performance tests unless otherwise specified in the applicable standard or permit conditions. 

## \[County Rule 270 §403\] \[County Rule 358 §503\]

## Monitoring Requirements: The Permittee shall record the VOC content of the EPS beads processed, bead usage rates for each process, aging time of beads and actual operating times of each process during the performance test. The Permittee shall record the pressure differential across the bead aging bag farm, the oxidizer combustion chamber temperature and combustion chamber set-point temperature during the performance test. 

## The Permittee shall record all process and control equipment information that are necessary to document operating conditions during the test and explain why the conditions represent normal operation. Operational parameters shall be monitored and recorded at least once every 30 minutes during each of the required test runs and documented in the test report. The operational parameters monitored shall be capable of indicating that the equipment is operating within the permitted limits, both during and after the performance tests. 

> \[County Rule 270 §301.1\]\[SIP Rule 27 §B\]

## Test Protocol Submittal: The Permittee shall submit a separate test protocol for each performance test to the Department for review and approval at least 30 days prior to each performance test unless otherwise specified in the applicable standard or in this permit. The test protocol shall be prepared in accordance with the most recent version of the Department's "Air Quality Performance Test Guidelines for Compliance Determination in Maricopa County." A completed copy of the Department's "Test Protocol Submittal Form" shall accompany each test protocol. 

> \[County Rule 270 §301.1\]\[SIP Rule 27 §B\]

## Notice of Testing: The Permittee shall notify the Department (Attn: Compliance Manager) in writing at least two weeks in advance of the actual date and time of each performance test unless otherwise specified in the applicable standard or in this permit so that the Department may have a representative attend. 

> \[County Rule 270 §404\]

## Testing Facilities Required: The Permittee shall install any and all sample ports or platforms necessary to conduct the performance tests, provide safe access to any platforms, and provide the necessary utilities for testing equipment. 

> \[County Rule 270 §405\]\[SIP Rule 42\]

## Minimum Testing Requirements: Testing shall encompass one complete operating cycle that is representative of daily operations. At the completion of the test, the aging bags shall have the same mass of beads as the beginning of the test (i.e. empty-to-empty or full-to-full). Normal aging times shall apply during testing. If the prepuff is normally aged overnight, then testing shall also occur overnight.

## Each performance test shall consist of three separate test runs with each test run being at least one hour in duration unless otherwise specified in the applicable standard or in this permit. The same test methods shall be used simultaneously for both the inlet and outlet measurements, if applicable, or justification for any necessary exceptions shall be provided in the test protocol. Emissions rates, concentrations, grain loadings, and/or efficiencies shall be determined as the arithmetic average of the values determined for each individual test run. Performance tests may only be stopped for good cause, which includes forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the Permittee's control. Termination of a performance test without good cause after the first test run has commenced shall constitute a failure of the performance test. 

> \[County Rule 270 §406\]

## Test Report Submittal: The Permittee shall complete and submit a separate test report for each performance test to the Department within 45 days after the completion of testing unless otherwise specified in the applicable standard or in this permit. The test report shall be prepared in accordance with the most recent version of the Department's "Air Quality Performance Test Guidelines for Compliance Determination in Maricopa County." A completed copy of the Department's "Test Report Submittal Form" shall accompany each test report. 

> \[County Rule 270 §301.1\]\[SIP Rule 27 §B\]

## Compliance with Emission Limits: Compliance with allowable emission limits and standards shall be determined by the performance tests specified in this permit. If test results do not demonstrate compliance with the requirements of these permit conditions, the Permittee shall make the necessary repairs and/or adjustments to the equipment and demonstrate compliance through retesting. This will not nullify the fact that test results did not demonstrate compliance with the requirements of the permit conditions or nullify any violations that may result from this noncompliance. In addition to compliance demonstrations, test results shall be used for annual emissions inventory purposes if the Permittee is required to complete an emissions inventory survey. 

> \[County Rule 270 §407\]

## Correspondence: All test extension requests, test protocols, test date notifications, and test reports required by this permit shall be submitted to the Department and addressed to the attention of the Performance Test Evaluation Supervisor. 

> \[County Rule 270 §301.1\]\[SIP Rule 27 §B\]

## Authority: The above testing requirements represent the minimum level of testing to monitor for compliance with the emission limits in this permit. Nothing in this section shall prevent the Control Officer from requiring additional performance testing as deemed necessary to ensure permit compliance and protection of the public health and welfare. 

> \[County Rule 200 §309\]\[County Rule 270 §402.5\]

29. **Recordkeeping Requirements:**

> The Permittee shall maintain the following records for at least five
> years. The Permittee shall keep records in a consistent and complete
> manner and make them available without delay to the Control Officer or
> designee upon request.

a.  The Permittee shall maintain records of the 12-month and weekly
    rolling total facility wide VOC emissions reports specified in
    condition 25(a) and (b).

b.  The Permittee shall maintain records of the twelve month rolling
    total bead usage reports specified in condition 25(c).

c.  Lot ID And VOC Content: Prior to expanding any part of a bead-lot,
    the Permittee shall obtain and retain an original or copy of the
    VOC-content, as defined below, for each separate
    lot-number/identifier of beads received.

> For the purposes of this permit, each of the acceptable VOC content
> expressions must be made in terms of either the number of pounds of
> VOC per 100 pounds of beads or the percentage of overall weight
> (including the VOC weight) that the incorporated VOC constitutes. The
> percent value shall be expressed with a precision of no less than the
> nearest tenth of one percent, which is equivalent to expressing the
> same number value in pounds VOC per 100 lbs. beads, to the nearest
> tenth of a pound. The acceptable expressions are:
>
> 1\. Manufacturer-Certified Bead-Lot (MCBL) VOC-Content -- A document
> such as a standard Certificate Of Analysis that numerically presents
> an EPS bead-lot's VOC content and must contain all of the following
> elements:
>
> A. The VOC content printed or written on a paper document by the bead
> manufacturer, after the manufacturer has had the bead-lot tested to
> determine the lot's percent VOC, before shipping from the
> manufacturer; and
>
> B. The manufacturer's name and the bead-lot, identified on the paper
> document with the appropriate bead-lot identifier; and
>
> C. The signature of an officer of the manufacturing facility or the
> signature of an officer's designee, previously designated in writing
> by such an officer.
>
> 2\. Post-Manufacture Laboratory-tested (PMLT) VOC-Content: The results
> of a laboratory test determining the VOC content of a representative
> sampling of an intermediate or finished expanded polystyrene-product,
> or such a test of raw beads any time after their MCBL VOC content has
> been assigned.
>
> 3\. ISO-Certified Maximum Bead-Model (IMBM) VOC Content: A numerical
> value that represents the upper limit of a particular bead-model's
> VOC-content, which has been:
>
> A. Initially stipulated by the bead-model's manufacturer in a document
> that gives the bead-model's unique identifier, and
>
> B. Subsequently certified for accuracy by the International Standards
> Organization (ISO).
>
> \[Rule 220 §§302.2, 304; Rule 358 §216, §502.1(a)\]

d.  Total Expanded by Lot and Date: Each day that raw EPS material is
    expanded in the expander, the Permittee shall record the amount of
    each bead-lot expanded and its corresponding lot number/identifier.

> \[Rule 358 §502.1(b)\]

e.  Each day that blocks are made, the Permittee shall record the
    approximate weight of each newly molded block, measured to the
    nearest 2 pounds.

> \[Rule 358 §502.1(c)\]

f.  Lists of Non-EPS VOC-Containing Materials: Non-EPS materials may
    include, but are not limited to, the following categories: inks,
    coatings, adhesives, reducers, thinners, solvents, cleaning
    materials, additives, spray cans, sprayed lubricants, and any other
    VOC-containing materials that are not EPS.

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1.  The Permittee shall maintain a current list of non-EPS materials,
    containing VOC, used at the facility. A complete and ordered
    assemblage of the required data meets the requirements for a list.

2.  The Permittee shall express VOC content of non-EPS material in one
    of the following three forms:

    A.  Pounds VOC per gallon (or grams VOC per liter), or

    B.  Fractional pounds of VOC per pound of material (or grams per
        kilogram), or

    C.  The percent VOC by weight along with the specific gravity or
        density (2 numbers are required for each entry).

3.  By the end of the following month, the Permittee shall record the
    amount and type of each non-EPS material, containing VOC that was
    used during each month.

\[Rule 358 §502.2\]

g.  The Permittee shall maintain daily records on the operation of the
    RTOs to include the operating temperatures and the data required per
    the approved O&M Plans.

> \[Rule 220 §§302.2, 304\]

h.  The Permittee shall maintain daily records on the operation of the
    aging bag total enclosure to include the pressure drop across the
    enclosure and the data required per the approved O&M Plan.

> \[Rule 220 §§302.2, 304\]

i.  The Permittee shall maintain monthly records on the weight of scrap
    foam which is processed through the grinders.

> \[Rule 220 §§302.2, 304\]

j.  The Permittee shall maintain monthly records of the amount and
    corresponding type of ink used in the facility.

> \[Rule 220 §§302.2, 304\]

k.  Visual Inspection Records: The Permittee shall maintain daily
    results of visual inspections and, if necessary, a record of any
    corrective action taken. Records shall indicate the date, time, and
    location of measurement; and the name of the individual performing
    the inspection.

> \[Rule 220 §302.7\]

**[Boilers]{.underline}**

30. **New Source Performance Standard (NSPS):**

> Boilers for which construction, modification, or reconstruction is
> commenced after June 9, 1989 and have a maximum design heat input
> capacity greater than or equal to 10 million Btu/hr, but less than 100
> million Btu/hr are subject to Part 40, Subpart Dc of the Code of
> Federal Regulations (40 CFR, Subpart Dc - Standards of Performance for
> Small Industrial-Commercial-Institutional Steam Generating Units).

\[Rule 360 §301.5\]

31. **Operational Limitations:**

The Permittee may only use natural gas as fuel for the boilers, heaters,
and supplemental fuel for the regenerative thermal oxidizer.

\[Rule 220 §§302.2, 302.16\]

32. **Limitations -- Nitrogen Oxides:**

The Permittee shall limit nitrogen oxide emissions to no more than 155
ppm heat input, calculated as nitrogen dioxide, when burning gaseous
fuel.

a.  Compliance shall be demonstrated by conducting a performance test on
    the Boiler within 60 days after the permit issuance date:

b.  The testing deadline may be extended by the Control Officer for good
    cause, but in no case shall the testing deadline, including test
    report submittal, extend beyond 180 days after the permit issuance
    date.

\[Rule 270 §401\]

c.  Testing shall measure the concentration of NOx in the boiler exhaust
    stream. Testing shall demonstrate compliance with the NOx
    concentration requirement of this condition. NOx shall be measured
    dry and corrected to 3% oxygen.

d.  NOx testing shall be conducted in accordance with EPA Test Method
    7E.

e.  The Permittee shall record the steam temperature, steam pressure and
    percent fire during the performance test. These and any additional
    operational parameters shall be identified in the test protocol and
    recorded during testing.

\[Rule 323 §304.1\]

33. **Record Keeping & Reporting:**

> The Permittee shall maintain the following records for a period of no
> less than 5 years from the date of such record.

f.  The Permittee shall record and maintain records of the amount of
    natural gas combusted monthly in each boiler, and the days and hours
    of operation. To meet this requirement, the Permittee may keep
    monthly natural gas purchase records for use in determining natural
    gas usage for the boiler.

> \[Maricopa County Policy for 40 CFR §60.48c(g); Rule 323 §501.1\]

g.  The Permittee shall submit to the Control Officer notification of
    the date of construction, anticipated startup, and actual startup of
    any new boiler(s), as provided in 40CFR 60.7 and paragraph c. of
    this Permit Condition. This notification shall include:

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1.  The design heat input capacity of the boiler(s) and identification
    of fuels to be combusted in the boiler(s).

> 2\. The annual capacity factor at which the Permittee anticipates
> operating the boiler(s) based on all fuels fired and based on each
> individual fuel fired.

\[40 CFR §60.48c(a)\]

> c\. The Permittee shall submit to the Control Officer notification of
> the date of construction or reconstruction, anticipated startup, and
> actual startup of any new boiler(s), as follows:
>
> 1\. A notification of the date construction or reconstruction of the
> new boiler(s) is commenced postmarked no later than 30 days after such
> date.
>
> 2\. A notification of the actual date of initial startup of new
> boiler(s) postmarked within 15 days after such date.

\[40 CFR §60.7\]