June 11, 2010

Ms. Cynthia Steiner

EPA Region 9 - Air Enforcement Office (AIR-5)

75 Hawthorne Street

San Francisco, CA 94105

Fed Ex Tracking No. 7936 3118 7051

RE: Knauf Insulation, Shasta Lake, California, PSD Permit NSR 4-4-4, SAC 03-01

Dear Ms. Steiner:

With this letter are completed application forms to support Knauf's request to obtain a PSD permit

modification to lower the minimum pressure drop on the seven (7) 641 MFG Line forming venturi

scrubbers. Knauf requests that the applicable permit conditions in the above referenced permit

be revised to state a minimum forming scrubber pressure drop of >3 inches of water column

(WC) rather than the current 10 inches of WC.

In January of 2009 the Shasta take facility was converted to Knauf's patented ECOSETM

Technology binder. ECOSETM Technology is an evolutionary advancement in the chemistry of

the binder, or glue, that is sprayed onto the fiberglass to bond the fibers together. ECOSETM

Technology binder raw materials contain no formaldehyde or phenol, nor do they contain any

listed Clean Air Act Hazardous Air Pollutants (HAPs).

There is considerable electrical energy consumption associated with maintaining the higher

scrubber pressure drops. Test data clearly shows that there is no difference in emissions

between operating at the lower scrubber pressure drop settings and higher scrubber pressure

drop settings. With the WESP as a final control, the particulate matter emission rate is unaffected

by the lower forming scrubber pressure drop. The WESP has never been considered to have a

significant impact on gaseous emissions (NOx, CO, NMHC, etc.). Approving the lower minimum

scrubber pressure drop will lower electricity demand at the facility with no impact on emissions.

Knauf performed emissions tests on the Shasta Lake facility's Main Stack (641 MFG

forming/curing/cooling - ECOSETM Technology) on March 25, 2010 with the forming scrubber

pressure drops adjusted to 3-5 inches of WC. This testing event was performed with prior

approval from the Shasta County AQMD per a variance approved by the Air Board on February

18, 2010. The full test reports for the stack sampling events in September 2009 (ECOSETM

Technology) and March 2010 summarized in the table below have been submitted to Shasta

County AQMD. As noted in the table there is virtually no difference from the September 2009

testing event results that were performed at the currently required >10 inches of WC. The March

2010 tests were performed at a slightly higher production rate than the September 2009 event

and both sampling events were performed while producing the same product.

Knauf Insulation GmbH, 3100 Ashby Road, ShastaLake, CA 96019

Telephone(530) 275-9665, Fax (530) 275-4993, www.Knauflnsulation.com
The venturi scrubbers at a minimum pressure drop of >3 inches of WC followed by the Wet

Electrostatic Precipitator (WESP) perform as well as with the scrubbers at the higher pressure

drop (>10 inches WC). Therefore, Knauf request that the pressure drops for the seven (7)

forming scrubbers in the applicable conditions in the PSD permit referenced above be revised to

state a minimum >3 inches of WC.

Emission Rate (Ib / hr)

Main Stack Main Stack Main Stack

Parameter Tested Tested Allowable

March 2010 Sept 2009-

- DP >3" DP >10"

Total Particulate 5.669 6.455 21.6

Nltroqen oxide 3.45 3.00 16.5

Carbon monoxide 9.13 9.07 22.3

Total Non-Methane 2.44 1.70 9.0

Hydrocarbons

Phenol BDL - -- 6.0

Formaldehyde 0.2 -- - 2.0

Ammonia 14.82 19.94 38.0

--- Not tested. BDL =Below Detection Limit

If you have any questions please feel free to call Randall Peterson at 530-276-9665, ext. 112, or

email himatRandaII.Peterson@us.knaufinsulation.com. Otherwise we will proceed as explained

above.

Sincerely,

'b't :<Z4-Q~ lain James

Director of Operations

Attachments: Applicable Shasta County Permit Application Forms

CC: Randall Peterson, EH&S Manager - Knauf, Shasta Lake

Stephen Aldridge, Corp. Manager EH&S - Knauf, Shelbyville

Mr. Ross Bell, Shasta County air Quality Management District

KnaufInsulation GmbH, 3100AshbyRoad, ShastaLake, CA 96019

Telephone (530)275-9665, Fax(530)275-4993, www.Knauflnsulation.com
44.

45.

G·

"'·"''''' ' ... l

r 46.

47.

b. PMlO - 28.4 lb/hr and 3.03 Ib/ton of glass pulled, based on a 3-hour rolling

average.

The opacity ofthe Main Stack exhaust, excluding condensed water vapor, shall not

exceed 20 percent based on a six (6) minute average and shal1 apply at all times. An

audible alarm shall sound in the control room to indicate an opacity exceeding the above

opacity limit.

The Permittee shall continuously operate and maintain a stack gas opacity monitor on the

Main Stack. The continuous opacity monitor shall meet all applicable design and quality

assurance requirements specified in 40 CFR 60. L3 and 40 CFR Part 60, Specification 1 of

Appendix B. A computer data acquisition system which has the capability of interpreting

the sampling data, providing a graphical trend analysis, and producing a summary report

of all six (6) minute averages of opacity readings shall also be provided.

The Permittee shall continuously operate and maintain the venturi scrubbers for the

removal ofsuspended particulate matter and for the pretreatment of the gas upstream of

the wet electrostatic precipitator. The scrubbers shall maintain a minimum gas pressure

drop of 10 inches water across the venturi throat and a minimum water flow to each

scrubber of 200 gal/min, The pressure drop and water flow parameters shall be measured

and recorded continuously. The solids in the scrubber water shall be removed to the

extent necessary and fresh make-up water added at all times of operation.

The Permittee shall continuously operate and maintain a wet electrostatic precipitator for

the control ofsuspended particulate matter from the outlet ofthe forming zone venturi

scrubbers. The wet electrostatic precipitator shall maintain a minimum water flow and a

minimum total corona power as' established during initial emission testing to determine

compliance with 40 CFR 60, Subpart PPP.

15

Knauf lnsulauon, GmbH

PSD Permit Revision I

Permit No. NSR 4-4-4, SAC 03·01

May 11, 2006
40. Natural gas shall constitute the only fuel allowed for use in the forming and curing

operations.

41. The Permittee shall maintain a log ofthe throughput ofmolten glass averaged on an

hourly, daily and weekly basis in tons of glass pulled per day. The log shall be available

for inspection by the EPA.

. 42. • The Permittee shall install, and thereafter continuously operate whenever fiberglass is

.. being produced, and maintain the following air pollution control technologies capable of

meeting the emission limitations specified in Condition 40 ofthis permit:

a. Fonning Sections: Use of combustion controls which minimize peak flame

temperatures in the fiber forming process for control ofNOx. Use ofsix (6)

venturi scrubbers on the bonded wool forming line and one (1) venturi scrubber

on the unbonded wool forming line (each with a minimum of lO" wc pressure

drop), followed by a wet electrostatic precipitator with continuous water spray

wash system and four (4) electrical fields (minimum) for the control of particulate

matter.

b. Curing Section: Use oflow NOx burners buming natural gas for the control of

NOx. Use oftwo thermal oxidizers operating in parallel with a minimum

temperature of 1400°F and a residence time of at least 0.5 second for the control

ofVOC and particulate matter. (A lower minimum operating temperature, not

less then 1200np) may be used for the thermal oxidizers if, through emission

testing, it is demonstrated to the satisfaction ofthe EPA that the lower

temperature offers an equivalent emission control ofVOC and particulate matter

as provided by the 140QoP minimum temperature.)
EPA Plant ID: CAR000039412

DISTRICT: Shasta County Air Quality Management District

COMPANY NAME: Knauf Insulation

I. FACILITY IDENTIFICATION

1. Facility Name: Knauf Insulation GmbH

2. Four digit SIC Code: 3296

3. Parent Company (if different than Facility Name): Same

4. Mailing Address: 3100 Ashby Road

City of Shasta Lake, CA 96019

5. Street Address or Source Location: Same

6. UTM Coordinates (ifrequired):

7. Source located within: 50 miles ofthe state line [ ] Yes [X] No

50 miles of a Native American Nation [ ] Yes [X] No [ ] Not Applicable

8. Type ofOrganization: [ ] Corporation [X] Sole Ownership [ ] Government [ ] Partnership [ ] Utility Company

9. Legal Owner's Name: Knauf Insulation GmbH

10. Owner's Agent Name (if any): Randall Peterson

11. Responsible Official: lain James

12. Plant Site Manager/Contact: Randall Peteerson Telephone #: 530-275-9665

13. Type offacility: Fiberglass insulation manufacturing

14. General description ofprocesses/products:

Mineral raw materials are mixed and then melted at approximately 2500 OF in an electric glass melting furnace. The

molten glass is then formed into fibers, a binder or glue is sprayed on the fibers. The binder coated fibers are collected on

a conveyor and sent through a curing oven (the binder is thermosetting) where the product is cured and the thickness is

set. The cured product then goes through various processes that trim and size the finished product before packaging.

Packaged product is stored in an on-site warehouse.

1 page outof 70 pages
15. Does your facility store, or otherwise handle, greater than threshold quantities of any substance on the Section l12(r) List of Substances

and their Thresholds (see attachment A)? [] Yes [X] No

16. Is a Federal Risk Management Plan [pursuant to Section 112(r)] required? [ ] Not Applicable [ ] Yes [X] No

(Ifyes, attach verification that Risk Management Plan is registered with appropriate agency or description ofstatus ofRisk Management

Plan submittal.) .,-..-.

2 page outof 70 pages
DISTRICT: SHASTA COUNTY AQMD

COMPANY NAME: Knauf Insulation

II. TYPE OF PERMIT ACTION

~~~InitialTitle V Application

D Permit Renewal

Si nificant Permit Modification

D Minor Permit Modification

D Administrative Amendment

III. DESCRIPTION OF PERMIT ACTION

1. Does the permit action requested involve: -a:

FACILITY NAME: Knauf Insulation

[ ] Portable Source [ ] Voluntary Emissions Caps

T ] Acid Rain Source [] Alternative Operating Scenarios

[ ] Source Subject to MACT Requirements [Section 112]

b: [ ] None ofthe options in l.a. are applicable

2. Is source operating under Compliance Schedule? [] Yes [X] No

3. For permit modifications, provide a general description ofthe proposed permit modification:

Based on emissions tests performed on the Main Stack with the 641 MFG Line forming scrubbers pressure drops

lowered to a minimum of 3 inches of water column (in WC) on ??????, 2010 it was determined that emissions rates of all

permit listed pollutants do not increase at the lower pressure drop. This permit application is to request that the

applicable permit conditions be revised to state a minimum forming scrubber pressure drop of 3 inches of water column

for all scrubbers.

3 pageout of 70 pages
DISTRICT: SHASTA COUNTY AQMD

COMPANY NAME: Knauf Insulation

I. TOTAL STATIONARY SOURCE EMISSIONS

FACILITY NAME: Knauf Insulation

Provide a brief description of operating scenario: Mineral raw materials are mixed and thel!melted at approximately 2500 of in an

electric glass melting furnace. The molten glass is then formed into fibers, and a binder or glue is sprayed on the fibers. The binder coated

fibers are collected on a conveyor and sent through a curing oven (the binder is thermosetting) where the product is cured and the thickness is

set. The cured product then goes through various processes that trim and size the finished product before packaging. Packaged product is

stored in an on-site warehouse.

PMlo(as rsn' 97.5 In compliance

In compliance

NOx2

In compliance In compliance

72.3

CO2

In compliance In compliance

97.67

sol In compliance In compliance

4.38

VOClRod

In compliance In compliance

39.42

Fluoride2

In compliance In compliance

2.74

Ammonia2 166.44 In compliance In compliance

Formaldehyde'

8.76 In compliance In compliance

Phenof

26.28 In compliance In compliance

* Emissions for all pollutants that the source IS major for and all regulated arr pollutants must be reported. See Attachment A.

Note: 1. Total plant PMlo(as TSP) permitted PTE from the glass melting furnace and the manufacturing line per April 15, 2008 Title V

Operating Permit.

2. Permitted PTE per April 15, 2008 Title V Operating Permit.

3. Total plant permitted PTE from the glass melting furnace and the manufacturing line gaseous fluoride emissions from the glass melting

furnace and the manufacturing line per April 15, 2008 Title V Operating Permit.

4 pageout of 70 pages
DISTRICT: SHASTA COUNTY AQMD

DISTRICT·ID:

COMPANY NAME: Knauf Insulation

I. PERMIT NUMBER: 03-VP-Ol

II. EQUIPMENT DESCRIPTION

FACILITY NAME: Knauf Insulation

.......

1. Equipment type: Liquid raw material storage tanks - 9 tanks

2. Equipment description: Closed top tanks with powered ventilation to capture emissions

3. Equipment make, model & serial number: Unavailable

4. Control device(s) type and description (if any): Emissions captured and vented to be discharged through the forming

scrubbers and WESP.

III. OPERATIONAL INFORMATION

1. Operating schedule:

2. Raw material used or processed:

(hours/day) 24 (hours/year) 8760

<Water 212 130 CBI

Non-HAP Content Proprietary Ingredient <Water 212 Ambient CBI

Mix Tank - 2 @ 6,000 and 3,000 gal.

Mineral oil- 1 @ 10,000 gal. ""0.00 850 150 CBI

Organosilane weigh tank- 1 @ 1 gal ""0.10 172 Ambient CHI

<Water 212 Ambient

Binder mix tank-l@2,000gal. CBI

Binder supply hold tanks - 2 @ 3000 <Water 212 Ambient CBI

gal.

Aqueous Ammonia Tank @ 8,000 gal. 3.9 97 Ambient CBI

3. Total annual throughput: (1000 gallons)

4. Profile ofmaterial throughput: Jan-Mar (% oftotal) 25 April-June (% oftotal) 25

July-Sep (% oftotal) 25 Oct-Dec (% oftotal) ,25

5 page out of72 pages
DISTRICT: SHASTA COUNTY AQMD

COMPANY NAME: KnaufInsulation

IV. TANK DESIGN AND SPECIFICATIONS

FACILITY NAME: Knauf Insulation

1. Tank design: [] Floating Roof(external)

[X] Fixed Roof

[] Pressure

[ "] Floating Roof(intern!l)

[ ] Underground

[ ] Other: --'- _

2. Tank specifications: Max Fill Rate: By truck load (gals/hr)

Height: . (ft)

Diameter: (ft)

Capacity: (gal)

Max Withdrawal: Batch mixes (gallhr)

Vapor Space: (ft)

Paint color:

3. Shell type: [] Gunited [ ] Riveted [X] Welded [] Other:

6 page outof 72pages
i?ii." .." ??, .., . i >

• , , i

DISTRICT: SHASTA COUNTYAQMD ,~-. n!Sl'IUCT -VSEONL¥«

lJtSl'IUGT IJ): . , ... .. .. " -; . .,?..•/ . i

COMPANY NAME: Knauf Insualtion FACILITY NAME: Knauf Insulation

4. Rooftype: [ ] Pan [ ] Pontoon [X] Other: fixed roof, welded, with vent pipe

5. Tank Seals: [ ] Single Seal [ ] Double Seal -dPt-·

Primary Seal Shoe Type:

[ ] Metallic Shoe

[ ] Vapor Mounted Resilient Seal

[ ] Liquid Mounted Resilient Seal

[ ] Wiper Seal

[ ] Other: Welded

Secondary Seal Shoe Type:

[ ] Shoe Mounted Wiper Seal

[ ] Rim Mounted Wiper Seal

[ ] Weathershield

[ ] Other: NA

6. Unit emissions:

power vented to the forming area.

For permit modifications only; emissions prior to project modification.

Difference between Pre-Modification Emissions (Section B.) and Emissions (Section A.).

For voluntary emissions cap and emission limits [i.e. expressed as parts per million (ppm) corrected/or dilution air, pounds per hour (lbs/hr), pounds per million BTU

(lb/MMBTU, etc.] required by any applicable federal requirement.

7 page out of 72 pages
DISTRICT: SHASTA COUNTY AQMD

COMPANY NAME: Knauf Insulation

I. PERMIT NUMBER: 03-VP-Ol

II. EQUIPMENT DESCRIPTION

FACILITY NAME: Knauf Insulation

..-.

1.General process description: Wool Fiberglass Manufacturing Line

2. Equipment type: Forming section, curing oven, cooling section

3. Equipment description: One natural gas-fired forming section with 3" ~P venturi scrubbers exhausting through a WESP,

one natural gas fired curing oven exhausting through I-Regenerative Thermal Oxidizers (RTO) operating at I475°F,

and one 2" venturi scrubber on the cooling exhaust:

4. Equipment make, model & serial number: Manufacturing line is a proprietary Knauf design.

5.Maximum design process rate or throughput: Designed to process greater than 225 tons of molten glass per day.

6.Control device(s) type and description (if any): Fisher-Klosterman venturi Scrubbers, Hamon Research-Cottrell Wet

Electrostatic Precipitator, United McGill RTOs.

III. OPERATIONAL INFORMATION

1.Operating schedule:

2. Exhaust gas flow rate:

(hours/day) 24

SCFM @ = 425,000 ± 25%,

%HzO =6.0

3.Raw products used and finished products produced:

(hours/year) 8760

Glass

Binder

225+ tons/day Fiberglass insulation Equal to or Greater than 225 tons

of molten glass er da

8 page out of 72pages
.: ...... ':,.':--::'.:"-,'" : .. .': "".

DISTRICT: SHASTA COUNTY AQMD » DISTRIGT USE ONLY

j)IS!IDG1?11): '. :.•.... .'. i'·; \

GOMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

4. Unit emissions: ..'.

0.0

39.42

0.0

4.38

4.38

26.28

0.0

<

Detection

Limit

<

Detection

Limit

0.0

0.0

8.76

:= 1.0

97.67

:= 1.0

0.0

72.3

14.15

0.0

87.34

87.34

166.44

0.0

0.0

2.74

2.74

2.74

;',~,;"--~'J~ --::-,-, . '":,,",::.. ,-,,,~1~ -,-,'" ,.-->:::,.,--~

ED·AlR'POLLUTAN"T.El\nSSiONS,'td

For permit modifications only; emissions prior to project modification.

Difference between Pre-Modification Emissions (Section B.) and Emissions (Section A.). ;

For voluntary emissions cap and emission limits [i.e. expressed as parts per million (ppm) correctedfor dilution air, pounds per hour (Ibs/hr), pounds per

million BTU (lb/MMBTU, etc.} required by any applicablefederal requirement.

9 page out of72pages
DISTRICT: SHASTA COUNTY AQMD

COMPANY NAME: Knauf Insulation

I. PERMIT NUMBER: 03-VP-Ol

II. EQUIPMENT DESCRIPTION

FACILITY NAME: Knauf Insulation

...,.

1. General process description: Wool Fiberglass Manufacturing Line

2. Equipment type: Wet venturi scrubbers

3. Equipment description: Wet venturi scrubbers

4. Equipment make, model & serial number: Fisher-Klosterman - 2 ea. Model MSllOO-H, 1 ea. Model MSI200-H, 4 ea.

Model MSI000-H, Serial number - 641-1 thru 641-7

5. Emission unites) served by this equipment: Forming

6. Maximum design or rated capacity: The forming process is designed to process greater than 225 tons of molten glass per

day.

III. EQUIPMENT DESIGN INFORMATION

1. Exhaust gas: Temperature: -150 (F) Flow Rate: 350,000 (SCFM)

Moisture: 6.0 (%) Oxygen: 20.5 (%)

CO2: 0.4 (%) =--- 2. General: Manufacturer: Fisher-Klosterman Pressure Drop: >0.73 (in-Hg)

Inlet Temp.: Unknown (F) Outlet Temp.: -150 (F)

3. Catalyst data: Catalyst TypelMaterial: None

Catalyst Life: (years) Volume: (Ft3)

Space Velocity: (Ft3/Ft)NH3 inj. Rate: (gal/hr)

NH3 Inj. Temp.: (F)

4. Baghouse data: Design: [] Positive Pressure [X] Negative Pressure

Cleaning Method:

Fabric Material: Polypropylene felt

Flow Rate: t (SCFM) Air/Cloth Ratio:

5. ESP data: Number offields: Cleaning Method:

Power Input:

6. Scrubber data: Type/design: Veturi Sorbent Type: Water

7. Other Control Devices (include appropriate design information):

10 page out of 72 pages
-,

........ '. DISTRICT: SHASTA COUNTY AQMD .».DISTRICT USE ONLY .((

DISTRICT ID: •... / .•.... /

COMPANY NAME : Knauf Insulation FACILITY NAME: Knauf Insulation I

IV. OPERATIONAL INFORMATION

1. Operating schedule: (hours/day) 24 (hours/year) 8760

2. Raw products used by control device: None

3. Operating information: All forming section gases pass through these scrubbers

";;.;...;.. ', .•.. ' .' '. '; .... .

, ..' .."., , -: " .. '.".".' " .."'"

POLLUTANT

(name)

See Form 5F2

INLET CONCENTRATION

(ppm or grIDSCF1

)

OUTLET CONCENTRATION CONTROL

EFFICIENCY

(% weight)

Unknown

Specify percent O2 or percent CO2•

11 pageout of72 pages
DISTRICT: SHASTA COUNTY AQMD

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

I. PERMIT NUMBER: 03-VP-Ol

...'-

II. EQUIPMENT DESCRIPTION

I. General process description: Wool fiberglass manufacturing

2. Equipment type: Main stack

3. Equipment description: Forming gases pass through the 7 forming scrubbers, are combined and pass through the

WESP and are then routed to the main stack. The oven exhaust gases pass through 2 thermal oxidizers and are

combined with the cooling exhaust from the cooling scrubber and routed to the main stack. Permitted emissions rates

are designated for the manufacturing line, or the total emissions from the forming, curing and cooling processes.

4. Equipment make, model & serial number: Main stack

5. Emission unit(s) served by this equipment: Manufacturing Line

6. Maximum design or rated capacity: The manufacturing line is designed to process greater tahn 195 tons of molten glass

per day.

(Ft3)

(gal/hr)

[X] Negative Pressure

Sorbent Type:

Flow Rate: 350-400, 000 (SCFM)

Oxygen: 20.5 (%)

2. General:

3. Catalyst data:

4. Baghouse data:

5. ESP data:

6. Scrubber data:

III. EQUIPMENT DESIGN INFORMATION

1. Exhaust gas: Temperature: -150 (F)

Moisture: -6.0 (%)

CO2: 0.4 (%) -"""'='- Manufacturer: Knauf Pressure Drop: NA (in-Hg)

Inlet Temp.: NA (F) Outlet Temp.: -150 (F)

Catalyst Type/Material: None

Catalyst Life: (years) Volume:

Space Velocity: (Ft3IFt)NH3 inj. Rate:

NH3 Inj. Temp.: (F)

Design: [] Positive Pressure

Cleaning Method:

Fabric Material: Polypropylene felt

Flow Rate: (SCFM) Air/Cloth Ratio:

Number offields: Cleaning Method:

Power Input:

Type/design:

12 page out of 72 pages
7. Other Control Devices (include appropriate design information):

, ,

DISTRICT..SHASTA COUNTY AQMD ». J)IS1':R1C1' lJSE ONLY '..:;('

"J)IS'l'J.UC'I'IIJ: .: "'" .r, , " : , ,

COMPANY NAME. Knauf Insulation FACILITY NAME . .

. Knauf Insulation

'.

IV. OPERATIONAL INFORMATION

I. b Operating schedule: (hours/day) 24 (hours/year) 8760

2. Raw products used by control device: None

3. Operating information: All manufacturing line gases are exhausted through the main stack.

POLLUTANT

(name)

PMIO

NOx

CO

S02

VOV/ROG

Fluoride

Ammonia

Formaldehyde

Phenol

INLET CONCENTRATION

(ppm or grIDSCF1

)

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

OUTLET CONCENTRATION

Actual

(ppm or grIDSCF1

)

0.002 gr/dscf

2.0 ppm

6-7.0 ppm

< Detection Limit

3-4.0 ppm

0.2 ppm

15-25.0 ppm

0.1- 0.2 ppm

< Detection Limit

CONTROL

EFFICIENCY

(% weight)

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Unable to determine

Specify percent O2 or percent CO2•

13 page outof72 pages
DISTRICT: SHASTA COUNTY AQMD » DISTRICT USE ONLY <:

DISTRICT ID:

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

I. PROCEDURE FOR USING FORM 5-1

r:Jj= Thisform shall be submitted as part ofthe Title V Application. The Responsible Official shall identify the applicable federal

requirement(s) to which the source is subject. In the Compliance Plan (Fo'f'm 5-1), a Responsible Official shall identify

whether the source identified in the Title V Application currently operates in compliance with all applicable federal

requirements.

II. APPLICABLE FEDERAL REQUIREMENTS

;, ...

AIJJ.>I.,I~~IJ!jFFJ]j~It\L J1EQ~MENT ~~I~SI~~~1~9r IN EFFECTIVE

:PERl\fI':rNtJMBER Sg~L~(],E DATE~ ..

(yesl!1o(~x~mptl)

.. -: .'. >. , .. .... '

May 7, 2007

PSD/ATC Permit NSR 4-4-4, SAC 03-01 Yes

Title V Operating Permit No. 03-VP-Ol Yes April 15,2008

Permit to Operate

02-PO-1O Yes Auzust 3 2006

Permit to Operate 02-PO-9 Yes August 3, 2006

Permit to Operate 97-PO-29 Yes August 3,2006

Permit to Operate 97-PO-28 Yes August 3, 2006

Permit to Operate 97-PO-27 Yes August3, 2006

Permit to Operate 97-PO-26 Yes August 3, 2006

NSPS Subpart PPP - Wool Fiberglass Manufacturing Plant start-up,

Line #97-PO-28 Yes 2/4/02

40 CFR Part 60 Subpart A. Sections 60.1 through Plant start-up,

60.19 #97-PO-26 thru 29 Yes 2/4/02

Plant start-up,

40 CFR Part 82: Protection of Stratospheric Ozone #97-PO-26 thru 29 Yes 2/4/02

Plant start-up,

40 CFR Part 60 Performance Spec. 1 AppendixB #97-PO-27 thru 28 Yes 2/4/02

#97-PO-26 thru 29

40 CFR Part 61: Subpart M (National Emission Yes Plant start-up,

Standards for Asbestos) 2/4/02

District Rules included in the SIP. (1:1,1:2, 2:1A, 2:4, #97-PO-26 thru 29 Yes Plant start-up,

2:5,2:6,2:7,2:8,2:10,2:11,2:12,2:13,2:14,2:18, 2/4/02

2:19,2:20,2:22,2:23,2:24,2:25,2:26,2:27,3:1,3:2,

3:3,3:4,3:5,3:6,3:7,3:9,3:11,3:12,3:14, 3:15,

3:17,4:1,4:2,4:3,4:5,4:6,4:7).

1 Ifexemptfrom applicablefederal requirement, attach explanation for exemption. 2 Indicate the date during the permit term that the applicablefederal requirement will become effective.

14 page out of 72 pages
,

DISTRICT: SHASTA COUNTY AQMD »DISTRICT USE ONLY

DISTRICT ID: ",.

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

.d!It•.

III. COMPLIANCE CERTIFICATION

Under penaltv ofper;ury, I certify the following:

Based on information and beliefformed after reasonable inquiry, the source identified in this application will continue to

comply with the applicable federal requirement(s) with which the source is in compliance identified in form XXX-Il;

o Based on information and beliefformed afterreasonable inquiry, the source identified in this application will comply with the

future-effective applicable federal requiremenus) identified in form 5-Il, on a timely basi/ ;

Based on information and beliefformedafterreasonable inquiry, the source identified in this application is notin compliance

with the applicable federal requiremenus), identified in form 5-Il, and I have attached a compliance plan schedule.2

fP'il.:

Signature

lAW

ofResponsible A.J~Official Date

blll/'O

1. Unless a more detailed schedule is expressively required by the applicable federal requirement.

2. At the time ofexpected permit issuance, ifthe source expectsto be out ofcompliance with an applicable federal requirement, the applicant

is required to provide a compliance schedule with this application, with the following exception. A source which is operating under a

variance that is effective for less than 90 days need not submit a Compliance Schedule. Forsources operating under a variance, which is in

effect for more than 90 days, the Compliance Schedule is the schedule that was approved as part ofthe variance granted by the hearing

board.

The compliance schedule shall contain a schedule ofremedial measures, including an enforceable sequence ofactions with milestones,

leading to compliance with this applicable federal requirement. Forsources operating under a variance, the compliance schedule is part of

the variance granted by the hearing board. The compliance schedule shall resemble, and be at least as stringent as that contained in any

judicial consent decree or administrative order to which the source is subject. For sources not operating under a vaiance, consult the Air

Pollution Control Officer regarding procedures for obtaining a compliance schedule.

15 pageout of 72 pages
DISTRICT: SHASTA COUNTY AQMD }> DISTRICT USE ONLY

DISTRICT ID:

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

I. CERTIFICATION STATUS

1. Indicate the dates the applicant intends to submitthe COMPLIANCE CERTIFICATION REPORT to the district during the entire

permit term, The district federal operating permits rule requires the applicant to submit this report at least annually.

Knauf will submit the annual certification report by June 30 of each year.

2. For sources required to have a schedule of compliance to remedy a violation, indicate the dates the applicant intends to submit

CERTIFIED PROGRESS REPORTS to the district during the permit term, The district federal operating permitsrule requires the

applicant to submit this report at least semiannually.

3. Describe the compliance status of the source with respect to applicable enhanced monitoring, and compliance certification

requirements ofSection 114(a)(3) ofthe Clean Air Act:

This source is in compliance with the monitoring requirements ofthe applicablePSD permit issued by EPA Region 9 on May

7,2007, the Title V permit to operate issued on April 15, 2008 and the Permit to Operate issued by SCAQMD on August 3,

2006, and the requirements in the NSPS Subpart PPP.

16 page out of 72 pages
DISTRICT: SHASTA COUNTY AOMD

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

II. CERTIFICATION INFORMATION

EMISSION UNITor

PERMIT NUMBER: 03-VP-Ol

APPLICABLE.

FEDERAL

REQUIREMENT: PSD/Title V/ATC..,.fennit

-. '.'

METHOD DESCrdPTtON.OI{{{EFkiF,~G~N.ni'['It{)P . ,

Monitoring Broken baz detectors on batch house silos

Reporting Monthlvto SCAOMD

Record Keeping Data acoulsitlon svstem to comouter

Test Methods None

EMISSION UNITor

PERMIT NUMBER: 97-PO-27

APPLICABLE

FEDERAL

REQUIREMENT: PSD/Title V/ATC Permit

',,'

METHOD I)ESCIUPTION OR REFERENCE METHOD . . "" . <

Monitoring Broken baz detectors and an Ooacitv monitor

Reporting Monthlv to SCAOMD

Record Keeping Data acouisition system to comouter

Test Methods Method 5 and Method 202 for PM

"

17 page outof72 pages
t-:

DISTRICT: SHASTA COUNTY AOMD ~J.lISTR.tGT PSEONlf¥ •..(

:Pl$'I'lUCT1P: \ .:', .•....... >

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

II. CERTIFICATION INFORMATION

EMISSION UNITor

PERMIT NUMBER 03-VP-OI

APPLICABLE

FEDERAL

REQUIREMENT: PSD/Title VlATC Permit - ··A'·

-: , . .. .... ····.·.·.··.\ ...···i:' ...·'ii ..····..-: ..................... \ ....,......... .......•. >

METHOD J):ESCRIPTIONQRREFERENCE METHOD ..... .,' ... ...\ .......... >.

Monitoring ComoIiance with monltorlna reouirements in the PSD/ATC Permit NSPS Suboart PPP and

And NESHAP Subpart NNN

Reporting Monthlv to SCAOMD

Record Keeping Data acouisition svstem to comouter

Test Methods Test methods required in the PSD/ATC Permit

EMISSION UNITor

PERMIT NUMBER: 03-VP-Ol

APPLICABLE

FEDERAL

REQUIREMENT: PSD/Title V/ATC Permit

- ...

METHOD DESCRIPTION ORREFERENCE METHOD -

Monitoring ComoIiance with monltorlnz reuuirements in the PSD/ATC Permit NSPS Subnart PPP and

.And NESHAP Subpart NNN

Reporting MonthlvtoSCAOMD

Record Keeping Data acouisition svstem to comouter

Test Methods Test methods reauired in the PSD/ATC Permit

18 pageout of72 pages
DISTRICT: SHASTA COUNTY AQMD » DISTRICT USE ONLY <

DISTRICT ID:

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

I. FACILITY INFORMATION .....

1. Company Name: Knauf Insulation

2. Facility Name (ifdifferent than Company Name): Same

3. Mailing Address: 3100 Ashby Drive

City of Shasta Lake, CA 96019

4. Street Address or Source Location: Same

5. Facility Permit Number: Title V Permit 03-VP-Ol, SCAQMD PTOs97-PO-26 to 29, EPA Region 9 PSD permit NSR4-4-4, SAC

03-01

II. GENERAL INFORMATION

1. Reporting period (specify dates): Monthly, Bi-annualy & Annually

2. Due date for submittal ofreport: 30 to 60 days

3. Type ofsubmittal: [] Monitoring Report (complete Section III below)

[] Compliance Schedule Progress Report (complete Section IV ofForm 5-K2)

[X] Compliance Certification (complete Section V ofForm 5-K2)

III. MONITORING REPORT INFORMATION

1. Were deviations from monitoring requirements encountered during the reporting period?

[ ] No [X] Yes (IfYes, complete Form 5-L)

19 page out of 72 pages
DISTRICT:

DISTRICTID:

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

IV. COMPLIANCE SCHEDULE PROGRESS INFORMATION

1. Dates the activities, milestones, or compliance required by schedule of compliance was achieved/will be achieved:

Not appliacable

2. Provide explanation ofwhy any dates in schedule of compliance were not/will not be met:

3. Describe in chronological order preventive or corrective action taken:

v. COMPLIANCE CERTIFICATION

1. Was source in compliance during the reporting period specified in Section II ofForm 5-K1 and is source currently in compliance with

all applicable federal requirements and permit conditions.

[X] Yes [ ] No (If no, re-submit Forms 5-1 and 5-J)

fa " '0

Signature ofResponsible Official Date

lain James

I certifY based on information and beliefformedafterreasonable inquiry, the statement and information in this document andsupplements

are true, accurate, and complete.

Print Name ofResponsible Official

Director ofOperations, KnaufInsumtion

Title ofResponsible Official and Company Name

Telephone Number ofResponsible Official: ( 530 ) 275-9665

20 pageout of 72pages
DISTRICT: SHASTA COUNTYAQMD »DISTRJ:CT USE ONLY <0(

DISTRJ:CTill:

COMPANY NAME: Knauf Insulation FACILITY NAME: Knauf Insulation

Identify, by checking offbelow, the forms and attachments that are part ofyour application. Ifthe application contains forms or attachmentsthat

are not identified below, please identify these attachments in the blank space provided below. Review the instructions ifyou are unsure ofthe

Forms included with application

_X_ Stationary Source Sufum.aryF0nn.

_X Total Stationary Source Emission

Form

-X_Compliance Plan Forni

_X_Compliance Plan Certification

X Certification Statement-Form

II

AttachmentsTncluded with application

List otherforms or attachments

5-Al~2,5-B, 5-Cl&2,.5..Dl&2,5..El&2,

5-Fl&2, 5-Gl&2,5-1I, 5-U&2, 5-Jl&2,

5- Kl&2, 5-L, .5-M

[ ] check here if additional forms

forms and attachments that need to be included in a complete application.

I certify under penalty oflaw, based on information and beliefformed after reasonable inquiry, that the information contained in this application,

composed ofthe forms and attachments identified above, are true, accurate, and complete,

ittingrule),

lain James, Director of Operations

21 page out of 72 pages.
List Other Forms or Attachments (cont.)

A'·

22 page out of 72 pages