777 12th Street, Third Floor Sacramento, CA 95814

STATEMENT OF BASIS

ADMINISTRATIVE AMENDMENT OF

TITLE V FEDERAL OPERATING PERMIT

TITLE V PERMIT NO.: TV2008-02-03A

FACILITY NAME: THE PROCTER & GAMBLE

MANUFACTURING CO.

FACILITY LOCATION: 8201 Fruitridge Road

Sacramento, CA 95826

MAILING ADDRESS: 8201 Fruitridge Road

Sacramento, CA 95826

RESPONSIBLE OFFICIAL: Vernon Murdock

Plant Manager

916-383-3800

CONTACT PERSON: Justin Gorman

Environmental Manager

916-381-9859

REVIEWING ENGINEER: Ady R. Santos

DATE: December 28, 2012
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 2 of 27

Sacramento Metropolitan Air Quality Management District

TABLE OF CONTENTS

A. PURPOSE OF STATEMENT OF BASIS ....................................................................... 3

B. PROPOSAL .................................................................................................................. 4

C. PERMIT ACTIONS........................................................................................................ 5

D. FACILITY DESCRIPTION ............................................................................................. 6

E. PROCESS DESCRIPTION ........................................................................................... 7

F. SIGNIFICANT EMISSIONS UNIT DESCRIPTION

SMAQMD Permit No. 23262 – Methyl Ester and Glycerine Manufacturing Process ...... 8

SMAQMD Permit No. 22794 – IC Engine Standby ........................................................ 10

G. INSIGNIFICANT EMISSIONS UNIT DESCRIPTION ..................................................... 11

H. ALTERNATIVE OPERATING SCENARIO..................................................................... 13

I. ADMINISTRATIVE PERMIT AMENDMENTS

1. SMAQMD Permit No. 23262 – Methyl Ester and Glycerine Manufacturing Process .. 14

2. SMAQMD Permit No. 22794 – IC Engine Standby .................................................... 14

J. APPLICABLE FEDERALLY ENFORCEABLE REQUIREMENTS

Facility-Wide Requirements........................................................................................... 15

Equipment-Specific Requirements ................................................................................ 19

K. TITLE V PERMIT CONDITIONS ................................................................................... 27

ATTACHMENT ‘A’ - SMAQMD RULE 201 PERMITS TO OPERATE

o SMAQMD Permit No. 22794

o SMAQMD Permit No. 23262
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 3 of 27

Sacramento Metropolitan Air Quality Management District

A. PURPOSE OF THIS STATEMENT OF BASIS

The Title V Federal Operating Permit is intended to be a document containing only enforceable

terms and conditions as well as any additional information, such as the identification of emission

units, emission points, emission sources and processes that make the terms meaningful. 40

CFR Part 70.7(a)(5) requires that each Title V permit have an accompanying “...statement that

sets forth the legal and factual basis for the draft permit conditions”. The purpose of this

Statement of Basis is to satisfy the above requirement by providing pertinent details regarding

the permit/application data and permit conditions in a more easily understandable format. This

report will also include background narrative and explanations of regulatory decisions made by

the reviewer. It should be emphasized that this Statement of Basis, while based on information

contained in the permit, is a separate document and is not itself an enforceable term and

condition of the permit.

This Statement of Basis is limited to the permit actions evaluated under the SMAQMD New

Source Review rule that were constructed and/or modified since the last Title V permit minor

modification, TV2008-02-03.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 4 of 27

Sacramento Metropolitan Air Quality Management District

B. PROPOSAL

The Procter & Gamble Manufacturing Co. (P&G) submitted an application for the modification of

their Title V Federal Operating Permit (TV2008-02-03) which was issued on 4-30-2009. Since

the last modification to this Title V permit on 12-30-2011, P&G recently implemented a change

to their Methyl Ester and Glycerine Manufacturing Process which involved the replacement of

Tank 532 with a larger capacity tank in the glycerine recovery area. There was no change in

the material and process throughput conditions. This was authorized in SMAQMD’s Authority to

Construct permit (A/C 23262). The permit process change was evaluated in accordance with

the Enhanced New Source Review requirements specified in SMAQMD Rule 207, Sections 305

and 401 - 408.

SMAQMD Rule 207, Section 202.5 states that a permit action that has complied with the

procedural and compliance requirements stated above can incorporate into the Title V permit all

the conditions in the related Authority to Construct. Therefore, this Title V permit revision is not

deemed a modification but an administrative amendment.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 5 of 27

Sacramento Metropolitan Air Quality Management District

C. PERMIT ACTIONS

The following permit actions have occurred since the initial issuance of Federal Operating

Permit No. TV1996-02-01.

Permit Actions Date Issued Permit No.

Initial Title V Federal Operating Permit 04-27-1999 TV1996-02-01

1

st Permit Renewal 04-30-2004 TV2004-02-01

1

st Minor Modification 02-27-2009 TV2004-02-02

2

nd Permit Renewal 04-30-2009 TV2008-02-01

1

st Significant Modification 09-22-2009 TV2008-02-02

1

st Minor Modification 12-30-2011 TV2008-02-03

Current Title V Permit Action

This Title V permit action, TV2008-02-03A, includes two administrative amendments to Title V

Permit TV2008-02-03.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 6 of 27

Sacramento Metropolitan Air Quality Management District

D. FACILITY DESCRIPTION

The Procter & Gamble Manufacturing Company Sacramento plant is an integrated industrial

facility comprised of four primary process areas. The processes include: (1) physically refined

vegetable oil process (PROP); (2) fatty acid process; (3) methyl ester and glycerine process;

and (4) fatty alcohol process. The facility converts natural oils, such as coconut and palm kernel

oil, to produce various products.

Emissions units associated with these process areas generally include storage and process

tanks, bulk silos, reactors, process vessels, condensers, filters, separators, centrifuges,

evaporators, distillation and stripping equipment, dryers, cooling towers, sumps, traps, and other

miscellaneous process equipment. Air pollution control devices include scrubbers, baghouses

and thermal oxidizers. In addition to the process area, other emissions units include natural

gas-fired heaters and boilers, and emergency standby IC engine.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 7 of 27

Sacramento Metropolitan Air Quality Management District

E. PROCESS DESCRIPTION

STORAGE TANK FARM

This is storage for raw materials, intermediates and finished products, including coconut oil,

esters, fatty alcohols and fatty acids. The tank farm includes rail car and tank truck loading and

unloading capability.

PHYSICALLY REFINED OIL PROCESS

Also known as ‘PROP’, this process removes contaminants from vegetable oils, preparing them

for further processing into esters and glycerine. PROP employs filtration aids, filtration, steam

stripping and vacuum to remove particles, free fatty acids and odor bodies from the oil, resulting

in an intermediate known as refined, bleached and deodorized oil.

METHYL ESTER & GLYCERINE MANUFACTURING PROCESS

Vegetable oils, predominantly coconut and palm kernel, are reacted with methyl alcohol in the

presence of sodium methylate. The glycerides which make up the oils react to form methyl

esters and crude glycerine. The mixture of glycerine and esters are gravity separated, washed

and dried prior to entering interim storage. The esters are fractionated into short chain (C6-

C10) and long chain (C12-C18) blends for further processing into finished product. The

glycerine is shipped to a P&G facility for final processing.

FATTY ALCOHOL MANUFACTURING PROCESS

Long chain methyl esters (C12-C18) are heated and pressurized prior to mixing with hydrogen

and catalyst. The mixture reacts in a four-stage plug flow reactor, hydrogenating the ester to a

fatty alcohol and liberating methanol. The methanol and excess hydrogen are recovered for

reuse. The mixture of fatty alcohol and catalyst are separated by means of centrifuges and

filters. The fatty alcohol mixture is fractionated into C12-C14 blend used for surfactant making

and pure forms of cetyl and stearyl alcohol which find many uses in the chemical and cosmetic

industries.

FATTY ACIDS MANUFACTURING PROCESS

Short chain methyl esters (C6-C10) are reacted with sodium hydroxide, liberating methanol and

producing a soapy material. The soap is reacted with sulfuric acid to produce a fatty acid, water

and sodium sulfate salt. Following washing and gravity separation, the fatty acid is vacuum

dried and distilled to finished product. The methanol is dried and returned to the ester making

process.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 8 of 27

Sacramento Metropolitan Air Quality Management District

F. SIGNIFICANT EMISSIONS UNIT DESCRIPTION

SMAQMD PERMIT NO. 23262 – METHYL ESTER AND GLYCERINE MANUFACTURING

PROCESS CONSISTING OF:

1. SODIUM METHOXIDE CATALYST MAKING PROCESS

A. METHANOL ANALYSIS TANK

B. SODIUM METHOXIDE INTERCHANGE

C. SODIUM METHOXIDE ANALYSIS TANKS

D. SODIUM METHOXIDE PUMP

E. SODIUM METHOXIDE COLUMN

F. SODIUM METHOXIDE REBOILER

G. DRY METHANOL FINAL CONDENSER

2. ESTER MAKING, FLASHING, WASHING AND DRYING PROCESS

A. ESTERIFICATION 1ST, 2ND AND 3RD SETTLER MIXERS

B. ESTERIFICATION REACTOR

C. ESTERIFICATION 1ST, 2ND AND 3RD SETTLERS

D. ESTER PUMP

E. ESTER FLASH INTERCHANGER

F. ESTER FLASH PREHEATER

G. ESTER FLASH TANK

H. ESTER FLASH COOLER

I. ESTER FLASH PUMP

J. ESTER WASH WATER COOLER

K. FOUR (4) ESTER WASH COLUMNS

L. ESTER DRYER

M. ESTER DRYER PUMP

N. ESTER DRYER CONDENSER

O. ESTER DRYER VACUUM SYSTEM

P. ESTER DRYER METHANOL CONDENSER

Q. ESTER DRYER CONDENSATE PUMP

3. LIGHT CUT ESTER FRACTIONATION PROCESS

A. LIGHT CUT ESTER PREHEATER

B. LIGHT CUT ESTER STILL

C. LIGHT CUT ESTER CONDENSER

D. LIGHT CUT ESTER VENT CONDENSER

E. SINGLE STAGE EJECTOR

F. LIGHT CUT ESTER PUMPS

G. LIGHT CUT ESTER PRODUCT COOLER

H. LIGHT CUT ESTER REBOILER

I. LIGHT CUT ESTER POT PUMPS

4. INTERMEDIATE ESTER FRACTIONATION PROCESS

A. INTERMEDIATE ESTER STILL

B. INTERMEDIATE ESTER CONDENSER

C. INTERMEDIATE ESTER VENT CONDENSER

D. HEAVY CUT ESTER DISTILLATE RECEIVER
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 9 of 27

Sacramento Metropolitan Air Quality Management District

E. INTERMEDIATE ESTER DISTILLATE PUMP

F. INTERMEDIATE ESTER COOLER

G. INTERMEDIATE ESTER REBOILER

H. INTERMEDIATE ESTER POT PUMPS

I. THREE (3) ESTER BOTTOMS TANKS

J. ESTER BOTTOMS TO REFINERY TANKS

K. TWO (2) ESTER FEED TO REFINERY TANKS

L. ESTER SCALE TANK

M. TWO (2) ESTER SWING TANKS

N. WCE BOTTOMS TANKS

5. ESTER FRACTIONATION PROCESS

A. ESTER STILL

B. ESTER CONDENSER

C. ESTER VENT CONDENSER

D. ESTER DISTILLATE RECEIVER

E. ESTER DISTILLATE PUMP

F. ESTER COOLER

G. ESTER REBOILER

H. ESTER POT PUMPS

I. FIVE (5) ESTER TO SCALE TANKS

J. THREE (3) ESTERS TO HFA

K. ESTER TO HFA TANK

L. TWO (2) ESTERS TO LCFA TANKS

M. FOUR (4) ESTERS TO LCFA/SCALES TANKS

6. METHANOL CONCENTRATOR PROCESS

A. METHANOL CONCENTRATOR FEE/BOTTOMS INTERCHANGER

B. METHANOL CONCENTRATOR

C. METHANOL CONCENTRATOR BOTTOM PUMP

D. METHANOL CONCENTRATOR RE BOILER

7. METHANOL CONCENTRATOR REBOILER

A. ESTER VENT SEAL TANK

B. METHANOL DRYER FEED TANK

C. METHANOL DRYER FEED PUMP

D. METHANOL DRYER INTERCHANGER

E. METHANOL DRYER PUMP

F. METHANOL DRYER

G. WEST VENT CONDENSER

H. WEST VENT FINAL CONDENSER

I. METHANOL STORAGE TANK

J. METHANOL CONDENSER

K. METHANOL DISTILLATE TANK

L. METHANOL DISTILLATE PUMP

8. GLYCERINE COLUMN PROCESS

A. DRY GLYCERINE TANK

B. DRY GLYCERINE FEED PUMP
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 10 of 27

Sacramento Metropolitan Air Quality Management District

C. GLYCERINE COLUMN

D. GLYCERING COLUMN PUMP

E. GLYCERINE COLUMN REBOILER

F. GLYCERINE INTERCHANGER

G. GLYCERINE BOTTOMS COOLER

9. GLYCERINE ACIDULATION AND NEUTRALIZATION PROCESS

A. GLYCERINE ACIDULATION MIXER

B. GLYCERINE ACIDULATION REACTOR/SETTLER

C. ACIDULATED GLYCERINE PUMP

D. DILUTE CAUSTIC PUMP

E. GLYCERINE NEUTRALIZATION MIXER

F. ACIDULATED SOAPSTONE SURGE TANK

G. ACIDULATED SOAPSTONE SURGE PUMP

10. GLYCERINE CONCENTRATION FEED TANK

A. GLYCERINE EVAPORATOR FEED TANK

B. GLYCERINE EVAPORATOR

C. GLYCERINE EVAPORATOR REBOILER

D. GLYCERINE EVAPORATOR PUMP

E. GLYCERINE PRODUCT PUMP

F. GLYCERINE EVAPORATOR CONDENSER

G. GLYCERINE EVAPORATOR CONDENSER PUMP

H. 3-STAGE EJECTOR

I. GLYCERINE TO SHIPMENT TANK

SMAQMD PERMIT NO. 22794 – IC ENGINE STANDBY

IC ENGINE STANDBY, CUMMINS, MODEL CFP5E-F50, SERIAL NO. 73227471, 146 BHP @

2100 RPM, 4.5 L DISPLACEMENT, DIESEL-FUELED, DRIVING AN EMERGENCY FIRE

PUMP
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 11 of 27

Sacramento Metropolitan Air Quality Management District

G. INSIGNIFICANT EMISSIONS UNIT DESCRIPTION:

Equipment Description

Determination of Insignificant Emissions Unit is Based on

SMAQMD “List and Criteria”,

Part B, Section 5 (Amended 4-26-01)

Combustion Equipment List and Criteria [Part B, Section 5, IIB.1]

Combustion equipment with a maximum heat input rating of no

more than 5 MMBtu/hr and fired exclusively with natural gas,

LP gas, or any combination thereof.

Internal Combustion Engine List and Criteria [Part B, Section 5, IIB.2]

Any piston-type internal combustion engine with a maximum

continuous rating of no more than 50 bhp.

Printing and Reproduction

Equipment

List and Criteria [Part B, Section 5, IID.1]

Any printing, coating or laminating activity, which uses no more

than 2 gallons per day of graphic arts materials, including inks,

coatings, adhesives, fountain solutions, thinner, retarders, or

cleaning solutions.

Storage Containers,

Reservoirs and Tanks, and

Transfer Equipment

List and Criteria [Part B, Section 5, IIG.2]

Any equipment with a capacity of no more than 1,500 gallons

used exclusively for the storage of gasoline.

List and Criteria [Part B, Section 5, IIH.1]

Any equipment used exclusively for the storage of unheated

organic material with an initial boiling point of 302°F or greater;

or a vapor pressure of no more than 5 mm Hg.

List and Criteria [Part B, Section 5, IIH.2]

Any equipment with a capacity of no more than 250 gallons

used exclusively for the storage of unheated organic liquid.

List and Criteria [Part B, Section 5, IIL.1]

Any transfer equipment when used with the equipment

described in Section 5 G-K.

Adhesive Application List and Criteria [Part B, Section 5, IIM.1]

Any adhesive operation in which no more than 173 gallons of

adhesives are applied in a consecutive 12-month period.

Surface Coating List and Criteria [Part B, Section 5, IIN.1]

Any equipment or activity using no more than 1 gallon per day

of surface coating, or any combination of surface coating and

solvent, which contains either VOC or HAP, or both.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 12 of 27

Sacramento Metropolitan Air Quality Management District

Equipment Description

Determination of Insignificant Emissions Unit is Based on

SMAQMD “List and Criteria”,

Part B, Section 5 (Amended 4-26-01)

Solvent Cleaning List and Criteria [Part B, Section 5, IIO.1]

Any equipment or activity using no more than 1 gallon per day

of solvent, or combination of solvent and surface coating,

which contains either VOC or HAP, or both.

Abrasive Blasting List and Criteria [Part B, Section 5, IIP.1]

Any blast cleaning equipment using a suspension of abrasive

material in water and the control equipment venting such blast

cleaning equipment.

Laboratory Fume Hoods

and Vents

List and Criteria [Part B, Section 5, IIW.1]

Any laboratory fume hood or vent, provided such equipment is

used exclusively for the purpose of teaching, research, or

quality control.

Refrigeration Units List and Criteria [Part B, Section 5, IIX.1]

Any refrigeration unit provided the unit contains less than 50 lb.

of refrigerant and is not used in conjunction with pollution

control equipment.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 13 of 27

Sacramento Metropolitan Air Quality Management District

H. ALTERNATIVE OPERATING SCENARIOS

There are no alternative operating scenarios identified in the Title V application.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 14 of 27

Sacramento Metropolitan Air Quality Management District

I. ADMINISTRATIVE PERMIT AMENDMENTS

The administrative Title V permit amendments will include the modification to the methyl ester

and glycerine manufacturing process and correcting the IC engine/fire pump specification.

1. SMAQMD PERMIT NO. 23262 – METHYL ESTER AND GLYCERINE

MANUFACTURING PROCESS

The process modification involves the replacement of Tank No. 532. Tank No. 532 is located in

the glycerine recovery area that serves as a glycerine acidulation reactor where the process

stream primarily consists of soapy crude glycerine. The new Tank No. 532 has a larger

capacity than the tank replaced. The bigger tank will prolong the residence time for the

glycerine recovered from the glycerine column because of its increased working volume.

Material and process throughput conditions remain unchanged.

As requested by P&G, this permit was reviewed and issued under the Enhanced New Source

Review process. Thus, it has complied with the procedural requirements in SMAQMD Rule

207, Sections 401 through 408, that include, among others, the publication of the preliminary

decision and allowing public comment after the preliminary decision was made. A written

notification of the final action of the Air Pollution Control Officer was also published in the local

newspaper. At the same time as the public comment period, EPA was given 45-days to review

the Title V permit modification. No comments were received from the EPA and the public.

In accordance with SMAQMD Rule 207, Section 409, public notice is not required for an

administrative Title V permit amendment.

2. SMAQMD PERMIT NO. 22794 – IC ENGINE STANDBY

The engine data for the fire pump engine were verified during the initial inspection of the unit

and errors and omissions were confirmed as follows:

IC Engine Standby, Cummins, Model CFP5E-F50, Serial No. 73227471, 146 BHP @ 2100

RPM, 4.5 L (275 cu. in.), Diesel-fueled

This new emissions unit was included in the Title V minor modification, TV2008-02-03, but was

not yet installed until after the issuance of the Title V permit. Therefore, this change is an

administrative permit amendment because it is only a correction to the equipment

description/identification.

In accordance with SMAQMD Rule 207, Section 409, public notice is not required for an

administrative Title V permit amendment.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 15 of 27

Sacramento Metropolitan Air Quality Management District

J. APPLICABLE FEDERALLY ENFORCEABLE REQUIREMENTS

FACILITY-WIDE REQUIREMENTS

SMAQMD RULE 101 – GENERAL PROVISIONS AND DEFINITIONS

SIP Approved: 3-19-1999 (64 FR 13514)

[9-03-1988 adopted version]

Rule Description: This rule provides definition of terms, specifies authority to

arrest and specifies what data is public information.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 102 – CIRCUMVENTION

SIP Approved: 12-05-1984 (49 FR 47490)

[5-15-1972 adopted; 11-29-1983 renumbered version]

Rule Description: This rule prohibits concealment of emission and specifies how

compliance determinations are made for combined and

separated emissions.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 105 – EMISSION STATEMENT

SIP Approved: 5-26-2004 (69 FR 29880)

[9-05-1996 amended version]

Rule Description: This rule requires the facility to provide annual emission data

for ROC and NOx.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 201 – GENERAL PERMIT REQUIREMENTS

SIP Approved: 7-13-1987 (52 FR 26148)

[11-20-1984 amended version]

The current 08-24-2006 version of this rule is not SIPapproved.

Rule Description: This rule provides an orderly procedure for the review of new

sources of air pollution and of the modification and operation

of existing sources through the issuance of permits.

Compliance Status: The permittee complies with the rule requirements.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 16 of 27

Sacramento Metropolitan Air Quality Management District

SMAQMD RULE 202 – NEW SOURCE REVIEW

SIP Approved: 6-19-1985 (50 FR 25417)

[11-20-1984 amended version]

The current 02-24-2005 version of this rule is not SIPapproved.

Rule Description: This rule sets the procedures for review of new and modified

stationary sources and provides the mechanisms for

evaluating the applicability of BACT and/or offset

requirements.

Compliance Status: SMAQMD A/C No. 23262 was evaluated under SMAQMD

Rule 202, Section 404 (Enhanced New Source Review).

Accordingly, the applications were reviewed following the

procedures specified in SMAQMD Rule 207, Sections 305 and

401 ~ 408 (Title V Federal Operating Permit Program). The

Engineering Evaluation and draft Authorities to Construct were

submitted to the U.S. EPA for a 45-day review. EPA did not

provide any comment. SMAQMD A/C No. 22794 was issued

on 1-26-11. This Title V minor modification was reviewed in

Procter & Gamble’s Title V permit, TV2008-02-03.

The permittee complies with the rule requirements.

SMAQMD RULE 207 – TITLE V FEDERAL OPERATING PERMIT PROGRAM

SIP Approved: 11-21-2003 (68 FR 65637)

[4-26-2001 amended version]

Rule Description: This rule sets forth the procedures for review, issuance,

modification and renewal of Title V operating permits.

Compliance Status: The permittee has submitted a timely and complete permit

application for Title V permit modification. The permittee

complies with the rule requirements.

By complying with the procedure specified in SMAQMD Rule

202, Section 404 (Enhanced New Source Review), the minor

modification to the methyl ester and glycerine manufacturing

process will be incorporated into the Title V permit. The

installation of a replacement IC engine driving the fire pump

was incorporated in the Title V minor modification under

TV2008-02-03. The updating of the serial number for the IC

engine is considered as an administrative amendment to the

Title V permit.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 17 of 27

Sacramento Metropolitan Air Quality Management District

SMAQMD RULE 214 – FEDERAL NEW SOURCE REVIEW

SIP Approved 7-20-11 (68 FR XXXXX)

[8-23-12 amended version]

Rule Description This rule sets the procedures for review of new and modified

major stationary sources and provides the mechanisms for

evaluating the applicability of BACT and/or offset

requirements.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 301 – PERMIT FEES - STATIONARY SOURCE (Title V related fees

only)

SIP Approved: This rule is not SIP-approved but the portions of the rule

related to Title V permit fees are applicable because they are

part of the SMAQMD Title V Federal Operating Permit

program approved by the U.S. EPA on 11-21-2003 (68 FR

65637).

Rule Description: This rule requires Title V sources to pay specified fees.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 307 – CLEAN AIR ACT FEES

SIP Approved: 8-26-2003 (68 FR 51184)

[9-26-2002 adopted version]

Rule Description: This rule requires major sources of ROC and NOx to pay

specified fees beginning after the U.S. EPA determines that

the SMAQMD has failed to demonstrate attainment of the one

hour ozone ambient air quality standard by the attainment

year.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 401 – RINGELMANN CHART

SIP Approved: 2-01-1984 (49 FR 3987)

[4-19-1983 amended version]

Rule Description: This rule limits the discharge of air contaminants into the

atmosphere through visible emissions and opacity limitations.

Compliance Status: The permittee complies with the rule requirements.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 18 of 27

Sacramento Metropolitan Air Quality Management District

SMAQMD RULE 403 – FUGITIVE DUST

SIP Approved: 12-05-1984 (49 FR 47490)

[8-03-1977 adopted version]

Rule Description: This rule regulates operations which may cause fugitive dust

emissions into the atmosphere.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 442 – ARCHITECTURAL COATINGS

SIP Approved: 11-09-1998 (63 FR 60214)

[9-05-1996 amended version]

The current 05-24-2001 version of this rule is not SIPapproved.

Rule Description: This rule limits the quantity of volatile organic compounds in

architectural coatings supplied, sold, offered for sale, applied,

solicited for application or manufactured for use within the

SMAQMD.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 701 – EMERGENCY EPISODE PLAN

SIP Approved: 9-05-2000 (65 FR 53602)

[5-27-1999 amended version]

Rule Description: This rule requires a plan be prepared for specific actions to be

taken when health related levels of ozone, carbon monoxide or

PM10 are exceeded.

Compliance Status: The permittee complies with the rule requirements
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

Title V Permit No. TV2008-02-03A

December 28, 2012

Page 19 of 27

Sacramento Metropolitan Air Quality Management District

EQUIPMENT-SPECIFIC REQUIREMENTS

SMAQMD RULE 404 – PARTICULATE MATTER

SIP Approved: 7-13-1987 (52 FR 26148)

[11-20-1984 amended version]

Rule Description: This rule limits the discharge of particulate matter into the

atmosphere to 0.1 grains per dry standard cubic foot.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 406 – SPECIFIC CONTAMINANTS

SIP Approved: 12-05-1984 (49 FR 47490)

[12-06-1978 amended version]

Rule Description: This rule regulates emissions of sulfur compounds and

combustion contaminants by limiting the emission

concentration of: (a) sulfur compounds, calculated as sulfur

dioxide (SO2), to 0.2% by volume, and (b) combustion

contaminants (PM) to 0.23 grams/dscm (0.1 grains/dscf) of

gas calculated to 12% CO2.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 411 – NOx FROM BOILERS, PROCESS HEATERS AND STEAM

GENERATORS

SIP Approved: 8-01-2007 (72 FR 41894)

[10-27-2005 amended version]

Rule Description: This rule limits NOx and CO emissions from boilers, steam

generator and process heaters with heat input ratings of 1

MMBTU/hour or greater.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 420 – SULFUR CONTENT OF FUELS

SIP Approved: 12-05-1984 (49 FR 47490)

[8-13-1981 amended version]

Rule Description: This rule regulates emissions of sulfur compounds from the

combustion of fuels by limiting the sulfur content of the fuel.

This rule limits the sulfur content of gaseous fuel to less than

50 grains per 100 cubic feet of sulfur compounds, calculated
Statement of Basis

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The Procter & Gamble Manufacturing Co.

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as hydrogen sulfide.

Compliance Status: The permittee complies with the rule requirements.

SMAQMD RULE 443 – LEAKS FROM SYNTHETIC ORGANIC CHEMICAL AND

POLYMER MANUFACTURING

SIP Approved: 11-09-1998 (63 FR 60214)

[9-05-1996 amended version]

Rule Description: This rule limits emissions of VOCs from leaking components at

chemical plants that manufacture synthetic organic chemicals

and polymers.

Compliance Status: This rule specifies a Leak Detection and Repair (LDAR)

program for fugitive VOC emitting components, including but

not limited to flanges and affected devices (e.g. valves,

pumps, compressors, pressure relief valves). The permittee

has been implementing an LDAR program.

The permittee complies with the rule requirements.

SMAQMD RULE 464 – ORGANIC CHEMICAL MANUFACTURING OPERATIONS

SIP Approved: 4-19-2000 (65 FR 20912)

[9-25-2008 amended version]

Rule Description: This rule limits emissions of VOCs from organic chemical

plants including but not limited to process tanks, reactors,

distillation columns, crystallizers, evaporators, process tanks,

centrifuges, filters, separators, and wastewater tanks.

Compliance Status: Section 301 – Reactors, Distillation Columns, Crystallizers,

Evaporators or Centrifuges:

P&G operates numerous affected devices such as reactors,

distillation columns and centrifuges where process vents to

common emission points like the North Vent Seal Tank, South

Vent Seal Tank and Fire Pit Stack. These emissions units

have maximum allowable emissions limits that comply with the

standards in Section 301.1. Compliance is verified by annual

compliance source testing. Process modifications are inprogress and control devices have been installed in

accordance with the applicable Federal MON regulation. The

permittee complies with the applicable requirements.

Section 302 – Separation Operations: This section applies to
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the operation of centrifuge, rotary vacuum filter or other

devices with an exposed liquid surface.

P&G does not operate any device that is subject to this

section.

Section 303 – Dryers or Production Equipment Exhaust

Systems: Other equipment like dryers likewise vent to the

common emission points mentioned above which have

maximum allowable emissions limits that comply with the

standards in Section 303.1.

The permittee complies with the applicable requirements.

Section 304 – Process Tanks: This section applies to process

tanks with a VOC composite vapor pressure of greater than 26

mm HG at 20°C and which emits more than 15 lb/day of

uncontrolled ROC emissions.

The standards in this section do not apply to P&G’s process

tanks because they do not fall within the conditions stated

above. The permittee complies with this section.

Section 305 – Wastewater: This section prohibits the use of

any equipment that receives, manages or treats wastewater

with a VOC concentration of 500 ppm by weight or higher and

a flow rate of greater than or equal to 1 liter per minute, or with

a VOC concentration of 10,000 ppm per weight or higher at

any flow rate, unless the equipment comply with the applicable

standards.

P&G operates a system of open trench drains, sumps and two

oil water separators that are subject to the requirements in

Section 305. The permittee has complied with the inspection,

monitoring and reporting requirements.

The permittee complies with the applicable requirements.

Section 306 – Liquid Transfer: This section applies to the

transfer of liquids with a VOC composite partial vapor pressure

of greater than 26 mm HG at 20°C into any tank truck, trailer,

railroad tank car or storage tank with a capacity of 2,000

gallons or greater.

P&G’s operations involve the transfer of methanol from

process tanks into rail cars and vice versa. The transfer of

methanol into the rail cars is controlled by passing the

displaced vapor through two 60-gallon packed-bed scrubbers

under SMAQMD Permit No. 12609. The APC Scrubbers were
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determined to have achieved a combined system efficiency of

at least 85% by weight and a control efficiency of at least 90%

by weight.

The permittee complies with the applicable requirements.

Section 307 – Storage Tanks: This section applies to any

storage tank with a capacity of either less than or equal to

40,000 gallons with a VOC composite partial vapor pressure

greater than 78 mm Hg at 20°C (1.5 psi at 68°F).

Most of P&G’s storage tanks in the tank farms have capacities

greater than 40,000 gallons and store materials with a VOC

composite partial vapor pressure of less than or equal to 78

mm Hg at 20°C (1.5 psi at 68°F).

These storage tanks are not subject to SMAQMD Rule 446, as

well, because the vapor pressure of the materials stored are

less than or equal to 1.5 psia under actual storage conditions.

The permittee complies with the applicable requirements.

Section 308 – Cleanup and Storage Requirements: The

requirements of this section have been incorporated in the

Title V permit. The future effective date requirement for the

new VOC content limit for maintenance solvent cleaning shall

likewise be included in the permit.

The permittee complies with the applicable requirements.

40 CFR 60, SUBPART VV – STANDARDS OF PERFORMANCE FOR EQUIPMENT

LEAKS OF VOC IN THE SYNTHETIC ORGANIC CHEMICALS MANUFACTURING

INDUSTRY

Promulgated: 10-18-1983

Rule Description: This subpart specifies a Leak Detection and Repair Program

(LDAR) for affected facilities in the synthetic organic chemicals

manufacturing industry (SOCMI) which were constructed,

reconstructed or modified after 1-05-81 and on or before 11-

07-06. Affected facilities are defined as process units that

produce an intermediate or final product listed in Section

60.489. The facility’s Methyl Ester/Glycerine Manufacturing

process produces glycerine as a co-product. The process

involves the transesterfication of tri-glycerides to methylated

esters and glycerine. The process both consumes methanol

as a reactant, which is later liberated, recovered and recycled
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back into the process. The feedstock of the process unit is

refined coconut oil (triglycerides).

Section 60.480(d)(3) exempts process units that produce

heavy liquid chemicals only from heavy liquid feed. Heavy

liquid chemicals are defined as mixtures with a vapor pressure

of less than 0.3 kPa at 20°C or mixtures containing less than

20% by weight of a pure volatile organic substance with a

vapor pressure greater than 0.3 kPa at 20°C. Coconut oil and

glycerine meet the criteria of a heavy liquid. The methylated

ester product contains a mix of esters ranging from C6 (methyl

caproate) to C18 (methyl oleate). Only the C6 ester has a

vapor pressure above the threshold. From information

obtained from P&G, approximately 5% by weight of the C6

ester is present in the mixture. Therefore, the process is

exempt from this regulation. However, P&G will still have to

comply with the recordkeeping requirement specified in

Section 486(i), by submitting a statement and analysis

indicating that the raw materials, feedstock and products of the

affected facility are exempt from the standards of this Subpart.

Compliance Status: The permittee complies with the rule requirements.

40 CFR 60, SUBPART NNN – STANDARDS OF PERFORMANCE FOR VOC

EMISSIONS FROM SYNTHETIC ORGANIC CHEMICAL MANUFACTURING INDUSTRY

(SOCMI) DISTILLATION OPERATIONS

Promulgated: 6-29-1990

Rule Description: This subpart applies to each affected facility that is part of a

process unit that produces any one of the chemicals listed in

Section 60.667 as a product, co-product, by-product, or

intermediate. The affected facilities consist of distillation units

and recovery systems (stearyl still, scavenger still and two

distillation columns) which were constructed, modified or

reconstructed after 12-30-83.

Compliance Status: The permittee complies with the rule requirements.

40 CFR 60, SUBPART RRR – STANDARDS OF PERFORMANCE FOR VOC

EMISSIONS FROM SYNTHETIC ORGANIC CHEMICAL MANUFACTURING INDUSTRY

(SOCMI) REACTOR PROCESSES

Promulgated: 8-31-1993

Rule Description: This subpart applies to each affected facility that is part of a

process unit that produces any one of the chemicals listed in
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Section 60.707 as a product, by-product, or co-product, or

intermediate. The fatty alcohol manufacturing process

produces mixed alcohols and the methyl ester/glycerine

manufacturing process produces glycerine. The affected

facilities consist of all reactors and recovery systems (ester

reactors and fatty alcohol reactors) which were constructed,

modified or reconstructed after 6-29-90.

Compliance Status: The permittee complies with the rule requirements.

40 CFR 60, SUBPART IIII – STANDARDS OF PERFORMANCE FOR STATIONARY

COMPRESSION IGNITION INTERNAL COMBUSTION ENGINES

Promulgated: 7-11-2006

Rule Description This subpart applies to engines with a displacement of less

than 30 liters per cylinder where the model year is 2007 or

later for non-fire pump engines and the model year listed in

Table 3 of the subpart or later year, for fire pump engines. It

also applies to engines manufactured after April 1, 2006 for

non-fire pump engines and engines manufactured as a

certified National Fire Protection Association (NFPA) fire pump

after July 1, 2006.

Compliance Status: The permittee complies with the rule requirements.

40 CFR 61, SUBPART V – NATIONAL EMISSION STANDARDS FOR EQUIPMENT

LEAKS (FUGITIVE EMISSION SOURCES)

Promulgated: 6-06-1984

Rule Description: This subpart applies to pumps, compressors, pressure relief

devices, sampling connection systems, open-ended valves or

lines, connectors, surge control vessels, bottoms receivers,

and control devices or systems operating in volatile hazardous

air pollutant (VHAP) service. Several of the facility’s

processes involve the use of methanol, a VHAP. Those

devices transporting liquid or vapor consisting of 10% or

greater methanol by weight are subject to this subpart. The

entire facility, including devices in VHAP service is subject to

the Enhanced Leak Detection and Repair Program (LDAR).

Compliance Status: The permittee complies with the rule requirements.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

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40 CFR 63, SUBPART F – NATIONAL EMISSION STANDARDS FOR ORGANIC

HAZARDOUS AIR POLLUTANTS FROM THE SYNTHETIC ORGANIC CHEMICAL

MANUFACTURING INDUSTRY

Promulgated: 4-22-1994

Rule Description: This subpart provides applicability criteria for operators of

chemical manufacturing process units where they :a)

manufacture as a primary product one or more of the

chemicals listed in Table 1 of the subpart; b) use as a reactant

or manufacture as a product, or co-product, one or more of the

organic hazardous air pollutants listed in Table 2 of the

subpart; and c) are located at a site that is a major source

with a potential to emit 10 TPY of any individual HAP and 25

TPY total HAPs. This subpart also includes provisions that

are applicable in subparts G and H (the Hazardous Organic

NESHAP).

P&G operates a process unit that produces methyl esters and

glycerol from refined oil (triglycerides). The methyl esters are

further processed into fatty acids and glycerol is purified and

sold as a product. The reaction uses methanol, which is listed

in Table 2, as a reactant. Of the two products in this process,

only glycerol is listed in Table 1, as the methyl esters are C6

and higher. The term ‘primary product’ is not defined in this

subpart or in subpart A. Glycerol was determined not to be a

primary product of the process, but rather a co-product. This

determination was made because the mass of methyl esters

produced exceeds the mass of glycerine produced by several

times and because other processes at the facility are designed

to use methyl esters as a feed stock.

Compliance Status: The facility is not subject to this subpart, although it is

referenced in other subparts of 40 CFR 63 that are applicable

to P&G.

40 CFR 63, SUBPART Q – NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLLUTANTS FOR INDUSTRIAL PROCESS COOLING TOWERS

Promulgated: 9-08-1994

Rule Description: This subpart applies to all new and existing industrial cooling

towers that are operated with chromium-based water

treatment chemicals and are either major sources or are

integral parts of facilities that are major sources. The cooling

tower associated with the physically refined oil process does

not use chromium-containing water treatment chemicals.
Statement of Basis

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Compliance Status: The permittee complies with the rule requirements.

40 CFR 63, SUBPART FFFF – NATIONAL EMISSION STANDARDS FOR HAZARDOUS

AIR POLLUTANTS: MISCELLANEOUS ORGANIC CHEMICAL MANUFACTURING

Promulgated: 11-10-2003

Rule Description: This Miscellaneous Organic NESHAP (MON) subpart

establishes emission standards for hazardous air pollutants

from miscellaneous organic chemical manufacturing

operations by establishing maximum achievable control

technology (MACT) standards to site-specific process units. It

also establishes requirements to demonstrate initial and

continuous compliance with the emission limits, operating

limits and work practice standards.

Compliance Status: The permittee complies with the rule requirements.

40 CFR 63 SUBPART ZZZZ – NATIONAL EMISSION STANDARDS FOR HAZARDOUS

AIR POLLUTANTS FOR STATIONARY RECIPROCATING INTERNAL COMBUSTION

ENGINES

Promulgated: 6-15-2004

Rule Description: This subpart establishes emission limitations and operating

standards for hazardous air pollutants (HAP) emitted from

stationary reciprocating internal combustion engines (RICE)

operating at both major and area sources of HAP emissions.

This applies to new and reconstructed RICE less than or equal

to 500 HP. Additionally, the engine must comply with the

requirements specified in 40 CFR 60 Subpart IIII.

Compliance Status: The permittee complies with the rule requirements.
Statement of Basis

Title V Federal Operating Permit Administrative Amendment

The Procter & Gamble Manufacturing Co.

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K. TITLE V PERMIT CONDITIONS

It is recommended that The Procter & Gamble Manufacturing Co.’s Title V Federal

Operating Permit be administratively amended.

Refer to the proposed Title V Federal Operating Permit No. TV2008-02-03A for the permit

conditions.

APPROVED BY: DATE: