ATTACHMENT A – KDHE JULY 21, 2009 TITLE V PERMIT AND MARCH 12, 2009 

EXTERNAL CULLET INCREASE CONTRUCTION PERMIT FOR JM MCPHERSON 

PLANT 
MCPHERSON TITLE V PERMIT 
DEPARTMENT OF HEALTH 

AND ENVIRONMENT 

Mark Parkinson, Governor 

Roderick 1. Bremby, Secretary 

Division of Environrnenl 

July 2 1,2009 RECEIVED JUL 2 4 2069 

Source ID No. 1 130036 

Mr. Bill Eccles, Environmental Coordinator 

Johns Manville International, Inc. 

P.O. Box 1287 

McPherson, KS 67460 

RE: Class I Operating Permit 

Dear Mr. Eccles: 

Enclosed is the Class I Operating Permit Renewal and amual certification of compliance forms for 

Johns Manville International, Incfacility located inMcPherson, Kansas The certifications are required to 

be submitted to the Kansas Department of Health and Environment (KDHEJoy July 15, for each 

calendar year the permit is in effect Please use copies of the enclosed form for the required 

certifications, retaining the original blank form for subsequent certifications. This form wibt be mailed 

to you on a yearly basis. 

Please review the enclosed operating permit carefully since it obligates Johns Manville 

International, Inc. to certain requirements. 

As provided for in K.S.A. 65-3008b(e), an owner or operator may request a hearing within 15 days 

after affirmation,modificationor reversal of a permit decision pursuant to subsection (b) of K.S.A. 65-3008a. 

In the Request for Hearing, the owner or operator shall specify the provision of this act or rule and regulation 

allegedly violated, the facts constituting the alleged violation and secretary's intended action. Such request 

must be submitted to: Director, Office of AdministrativeHearings, 1020 S. Kansas Avenue, Topeka, Kansas 

66612-1327. Failure to submit a timely request shall result in a waiver of the right to hearing. 

In October 2007 KDHE began addressing green house gas (GHG) emissions in Kansas to protect the 

health and environment of Kansans. To accomplish this task, KDHE will engage industries and stakeholders 

to establish goals for reducing GHG emissionsand strategies to achieve them. Therefore, in accordancewith 

K.S.A. 65-3005Cj), KDHE is seeking your cooperation to voluntarily implement strategies, including the 

development and use of innovative technologies, market-based principles and other private initiatives to reduce 

or prevent GHG emissions. 

DIVISION OF ENVIRONMENT 

Bureau of Air & Radiation 

Air Permitting Section 

CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE 3 10, TOPEKA, KS 666 12-1 366 

Voice 785-296- 1570 Fax 785-291-3953 
Page 2 

Mr. Bill Eccles 

July 21,2009 

Please include the source ID number listed above in all communications with KDHE in reference 

to this permitted facility. If you have any questions about the enclosed permit, or need any additional 

information, please contact me at (785)296 17 19. 

Sincerely, 

Air Permitting Section 

LMS:saw 

Enclosures 

c: NCDO 

0-8223 
Mark Parkinson, Governor 

Roderick L. Breemby, Sectetary 

DEPARTMENT OF HEALTH 

AND ENVIRONMENT www. kd heks.gov 

Division of Environment 

AIR EMISSION SOURCE 

CLASS I OPERATING PERMIT 

Source ID No.: 

Initial Date: 

Renewal Date: 

Expiration Date: 

Source Name: 

SIC Code: 

NAICS Code: 

Source Location: 

Mailing Address: 

June 15,2004 

July 2 1,2009 

July 20,2014 

Johns Manville International, Inc. 

3296; Mineral Wool 

327993; Mineral Wool Manufacturing 

1465 17'~ venue 

McPherson, Kansas 67460- 1287 

P.O. Box 1287 

McPherson, Kansas 67460-1 287 

DIVISION OF ENVIRONMENT 

Bureau of Air & Radiation 

Air Permitting Section 

CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE. 310, TOPEKA, KS 66612-1366 

Voice 785-296-1570 Fax 785-291-3953 
Authority 

This permit, developed in accordance with the provisions of K.A.R. 28-19-500 et seq., 

"Operating Permit," meets the requirements of K.A.R. 28-19-5 10 et seq., Class I 

Operating Permits, and Title V of the federal Clean Air Act. 

Permit Intent 

The purpose of this Class I Air Operating Permit is to identify the emission sources and 

types of regulated air pollutants emitted from the facility; the emission limitations, 

standards and requirements applicable to each source; and the monitoring, record keeping 

and reporting requirements applicable to each source as of the effective date of this 

permit. At the time of permit issuance, this facility required a Class I Operating Permit 

because it met the definition of a major stationary source as defined under K.A.R 28-19- 

200. 
TABLE OF CONTENTS 

Section Page No . Facility Description ............................................................................................................. 4 

Emission Source Information .............................................................................................. 5 

Summary of Applicable Requirements ............................................................................. 15 

Applicable Requirements ................................................................................................... 16 

StackNent Opacity Summary ........................................................................................... 27 

Facility-Wide Applicable Requirements ........................................................................... 27 

Opacity Limitations and Monitoring ................................................................................. 29 

Requirements Which Will Become Applicable During the Permit Term ......................... 30 

Permit Shield ..................................................................................................................... 30 

Testing. Monitoring. Recordkeeping. & Reporting ....................................................... 31 

Reporting of Deviations from Permit Terms ..................................................................... 32 

General Provisions ............................................................................................................. 32 

1 . K.A.R. 28-1 9-1 1. Exceptions Due to Breakdowns or Scheduled Maintenance ..... 32 

2 . K.A.R. 28-19-752a, HAP; Limitations Applicable to Construction of New Major 

Sources or Reconstruction of Existing Major Sources ........................................ 33 

3 . Permit Term and Renewal ...................................................................................... 33 

4 . Severability ............................................................................................................. 33 

5 . Property Rights ....................................................................................................... 33 

6 . Compliance ............................................................................................................. 34 

7 . Compliance Certification ....................................................................................... 34 

8 . Emergency .............................................................................................................. 35 

9 . Inspection and Entry ............................................................................................... 35 

10 . Permit Amendment, Modification, Reopening and Changes Not Requiring a Permit 

Action ...................................................................................................................... 36 

1 1 . Duty to Provide Information ................................................................................ 37 

12 . Duty to Supplement ................................................................................................ 37 

13 . Other Permits and Approvals; Applicability .......................................................... 37 

14 . Submissions ............................................................................................................ 37 

Attachment A: Site Diagrams 

Attachment B: List of Acronyms and Symbols 

Attachment C: Compliance Assurance Monitoring (CAM) Plan 
Facility Description: 

Johns Manville International, Inc. operates a wool fiberglass insulation manufacturing facility 

located in McPherson Kansas. The facility's major air emission sources are the fiberglass 

melting; fiberizing and forming; curing; and cooling manufacturing lines. Other sources of 

regulated pollutants include materials handling equipment and trimming, cutting, and packaging 

operations. 

Insignificant activities at the plant include: two 750 hp diesel fired generators; 50 hp fire pump; 

two (2) 5000 gallon silicone tank; two (2) 10,000 gallon emulsified dedusting oil tanks; two (2) 

1000 gallon emulsified dedusting oil tanks; one (1) 1320 gallon Larostat mix tank; one (1) 880 

gallon Larostat use tank; one (1) 700 gallon process water sludge mix tank; one (1) 275 gallon 

diesel fuel tank; one (1) 60 gallon diesel fuel tank; one (1) 500 gallon diesel fuel tank; three (3) 

18,000 gallon Acrylic Resin tanks; one (1) 6500 gallon Sodium Hydroxide - 50% tank; one (1) 

5500 gallon Sulfuric Acid - 93% tank; two (2) 250 gallon silane mix tanks; one (1) 100 gallon 

small caustic tank; one (1) 100 gallon gasoline storage tank; one (I) anti-sludgeloil skimmer 

tank; eight (8) natural gas fired 12.8 mmBtu/hr space heaters; six (6) high bay buffalo vents - 

over processes; eighteen (1 8) high bay turbine vents over line 122 process; seven (7) 

intermediate bay buffalo vents over curing processes; water room buffalo vents over process 

water vibrating screens; one (1) compactor room buffalo roof vent; one (1) caustic room buffalo 

roof vent; one (1) 2.5 mmBtu/hr 1 & 2 room natural gas fired space heater; two (2) blowing wool 

penthouse wall vents; two (2) blowing wool penthouse Chelsea fans - east wall; two (2) line 123 

CPW packaging buffalo roof exhausts; four (4) line 123 fiberizing level- Chelsea wall fans - 

Westside; one (1) batch dust house roof vent; two (2) 1.7 mmBtu/hr natural gas fired water tube 

boiler; one (1) 2.1 mmBtu/hr natural gas fired water tube boiler; line 122 and 123 hivac selfcontained vacuum cleaners; one (1) sand blasting cabinet; one (1) outdoor sand blasting activity; 

two (2) line 122 spinner by-pass vent; two (2) line 123 spinner by-pass vent; one (1) line 122 

oven gas by-pass vent; one (1) line 123 oven gas by-pass vent; three (3) combustion air blowers 

by-pass vents; MEK inkjet printing processes; propane and cal gas container venting; brick 

refractory sorting; five (5) maintenance solvent machine 17 gallon tanks; four (4) electrical burnout ovens; six (6) line 123 Dwell tank cooling blowers; two (2) line 122 cullet chute exhaust 

vents; and three (3) line 123 cullet chute exhaust vents. 
Emission Source Information: 

Page 5 of 38 

Applicable 

Requirements 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

Construction Permit 

(713 1/02) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

K.A.R.28-19-501 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28- 19-20 

K.A.R. 28- 19- 

650(a)(3) 

K.A.R.28-19-501 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28-1 9- 

650(4(3) 

K.A.R.28-19-501 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28- 19- 

650(a)(3) 

K.A.R.28- 19-50 1 (d) 

Construction Permit 

(713 1/02) 

Control 

Equipment 

Description 

NA 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Emission 

Source ID 

EU-BOO 1 

EU-B002(a - i ) 

EU-BOO3 

P 

EU-BOO4 

- 

EU-123001 

StacWVent ID 

SV-BOO1 

SV -B002(a - i ) 

SV- 123 004 

SV-123005 

SV-BOO4 

SV- 123 00 1 

Emission Source 

Description 

Raw Material 

Unloading 

Nine (9) Raw 

Material Storage 

Silos 

Weigh Scale 

Bad Batch 

Hopper 

123 Blender 

Receiver Hopper 

Control 

Equipment ID 

N/A 

CE-B002(a - i) 

CE-123004 

CE-123005 

CE-BOO4 

CE-123001 
Page 6 of 38 

Emission 

Source ID 

EU- 123 002 

EU- 123003(a-d) 

EU- 123 004 

EU-123005 

Emission Source 

Description 

123 Blender 

123 Melter Day 

Bins (3) (a-c) 

123 Spare 

Storage Bins (1) 

(4 

123 Module #I 

Melter 

123 Module #2 

Melter 

StacWVent ID 

SV-123002 

SV- 123003(a-d) 

SV- 123 004 

SV-123005 

Control 

Equipment ID 

CE-123002 

CE-123003(adl 

CE-123004 

CE-123004 

Control 

Equipment 

Description 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Applicable 

Requirements 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

K.A.R.28-19-50 1 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28- 19-20 

K.A.R. 28-1 9- 

65o(a)(3) 

K.A.R.28-19-501(d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(a)(3) 

40 CFR Part 64 

Construction Permit 

(713 1/02) 

Construction Permit 

(311 2/09) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(4(3) 

40 CFR Part 64 

Construction Permit 

(713 1/02) 

Construction Permit 

(311 2/09) 
Page 7 of 38 

Emission 

Source ID 

EU-123006 

EU- 123 007 

EU-123008 

EU-123009 

Emission Source 

Description 

123 Module #3 

Melter 

123 Module #1 

Fiber 

Forming/Collecti 

on 

123 Module #2 

Fiber 

Forming/Collecti 

on 

123 Module #3 

Fiber 

FormingICollecti 

on 

StacWVent ID 

SV- 123006 

SV- 123007 

SV-123008 

SV- 123009 

Control 

Equipment 

Description 

Fabric Filter 

N/ A 

IV/A 

N/A 

Control 

Equipment ID 

CE-123004 

N/ A 

N/ A 

NI A 

Applicable 

, Requirements 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(a)(3) 

40 CFR Part 64 

Construction Permit 

(713 1/02) 

Construction Permit 

(311 2/09) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

65o(a)(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-19-20 

K.A.R. 28-1 9- 

65o(a)(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

65o(a)(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 
Page 8 of 38 

Emission 

Source ID 

EU- 123 0 1 0 

EU-123011 

EU-123012 

EU-123013 

Emission Source 

Description 

123 Curing Oven 

(HEAF) High 

Energy Air 

Filtration 

123 Cooling 

Table - North 

123 Cooling 

Table - South 

123 Horizontal 

Slitting (vents 

inside) 

Applicable 

Requirements 

K.A.R. 28-19-20 

K.A.R. 28- 19- 

65o(a)(3) 

K.A.R.28-19-501 (d) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(a)(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1 102 

K.A.R. 28-19-20 

K.A.R. 28- 19- 

65o(a)(3) 

StackNent ID 

SV-123010 

SV-123011 

SV-123012 

SV-123013 

Control 

Equipment ID 

CE-123010 

N/ A 

N/A 

CE-123013 

Control 

Equipment 

Description 

High 

Energy Air 

Filtration 

(Fiberglass 

Mat) 

N/A 

NIA 

Cyclone 
Page 9 of 38 

Emission 

Source ID 

EU-123014 

EU-123014a 

EU-123015 

EU-123016a 

EU-123016b 

Emission Source 

Description 

123 Waste Edge 

Removal (vents 

outside high bay) 

123Edge 

Material Refeed 

123 Hot Roll 

Laminator (vents 

inside) 

123 K&S 

Vacuum Wind-up 

(upper 

level)(vents 

inside) 

123 K&S 

Vacuum Wind-up 

(lower 

level)(vents 

inside) 

StacWent ID 

SV-123014 

SV-OMMI 1 

SV-123015 

SV-123016a(UL) 

SV-123016b(LL) 

EU-123018 

EU-123019 

Control 

Equipment ID 

CE-1230 14 

CE-OMMIl b 

N/ A 

CE-123016a 

CE-123016b 

123 CPW 

Pkg .(vents inside) 

123 ARB 

Pkg.(vents inside) 

Control 

Equipment 

Description 

Fabric Filter 

Fabric Filter 

N/A 

Baghouse 

Baghouse 

N/A 

SV-123019 

Applicable 

Requirements 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

K.A.R.28- 19-50 1 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28-1 9- 

650(4(3) 

K.A.R.28-19-501(d) 

K.A.R. 28- 19-20 

K.A.R. 28- 19- 

650(4(3) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

K.A.R. 28-19-20 

K.A.R. 28-1 9- 

N/A 

N/ A 

N/A 

N/A 

K.A.R. 28- 19-20 

K.A.R. 28- 19- 

650(a)(3) 

K.A.R. 28-19- 

650(4(3) 
Page 10 of 38 

Emission 

Source ID 

EU- 12200 1 

EU- 122002 

EU-122003a 

EU-122003b 

EU-122003~ 

Emission Source 

Description 

122 Blender 

Receiver Hopper 

122 Blender 

122 M-1 Melter 

Day Bin 

122 M-2 Melter 

Day Bin 

122 Spare Day 

Bin 

StacWent ID 

SV- 12200 1 

SV- 122002 

SV- 122003a 

SV-122003b 

SV- 122003~ 

Control 

Equipment ID 

CE-12200 1 

CE- 122002 

CE-122003a 

CE-122003b 

CE- 122003~ 

Control 

Equipment 

Description 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Applicable 

Requirements 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(a)(3) 

K.A.R.28-19-501(d) 

Construction Permit 

(713 1/02) 

K.A.R. 28- 19-20 

K.A.R. 28-19- 

650(a)(3) 

K.A.R.28-19-50 1 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(a)(3) 

K.A.R.28-19-50 1 (d) 

Construction Permit 

(713 1102) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(a)(3) 

K.A.R.28-19-50 1 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(a)(3) 

K.A.R.28-19-501 (d) 

Construction Permit 

(713 1/02) 
Page 11 of 38 

Emission 

Source ID 

EU- 122004 

EU- 122005 

EU-122006a 

EU-122006b 

Emission Source 

Description 

1 22 Module # 1 

Melter 

122 Module #2 

Melter 

122 Module #1 

North Forming & 

Collection 

122 Module #l 

South Forming & 

Collection 

StacWent ID 

SV- 122004 

SV- 122005 

SV-122006a 

SV- 122006b 

Applicable 

Requirements 

K.A.R. 28- 19-20 

K.A.R. 28-19- 

650(a)(3) 

40 CFR Part 64 

Construction Permit 

(713 1/02) 

Construction Permit 

(311 2/09) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

650(4(3) 

40 CFR Part 64 

Construction Permit 

(713 1/02) 

Construction Permit 

(311 2/09) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(4(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-19-20 

K.A.R. 28-1 9- 

65O(a)(3 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

Control 

Equipment ID 

CE-122004 

CE- 122005 

N/A 

N/A 

Control 

Equipment 

Description 

Fabric Filter 

Fabric Filter 

NIA 

N/ A 
Page 12 of 38 

Emission 

Source ID 

EU-122007a 

EU-122007b 

Emission Source 

Description 

122 Module #2 

North Forming & 

Collection 

122 Module #2 

South Forming & 

Collection 

Construction Permit 

StacWent ID 

SV-122007a 

SV-122007b 

EU-122008 

Control 

Equipment ID 

N/A 

N/A 

122 

CuringIHEAF 

(High Energy Air 

Filtration) 

Control 

Equipment 

Description 

N/A 

N/A 

SV-122008 

Applicable 

Requirements 

K.A.R. 28-19-20 

K.A.R. 28-19- 

65O(a)(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-19-20 

K.A.R. 28-19- 

65O(a)(3) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

CE-122008 High 

Energy Air 

Filtration 

(Fiberglass 

Mat ) 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

65o(a)(3) 

K.A.R.28-19-50 1 (d) 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 
Page 13 of 38 

Emission 

Source ID 

EU- 122009 

EU-122010 

EU-122011 

EU- 1220 1 1 a 

EU-122012 

EU- 1220 1 3 a 

Emission Source 

Description 

122 Cooling 

Table 

122 Horizontal 

Slitting (cyclonevents inside) 

122 Waste Edge 

Removal 

122 Edge 

Material Refeed 

122 Hot Roll 

Laminator (vents 

inside) 

1 22 K&S 

Vacuum Windup (Upper levelvents inside) 

StacWent ID 

SV- 122009 

SV-122010 

SV-1220 1 1 

SV-OMM11 

N/A 

SV-122013a 

Control 

Equipment ID 

N/A 

CE-122010 

CE- 1220 1 1 

CE-OMMl 1 a 

- 

N/A 

CE-1220 13a 

Control 

Equipment 

Description 

N/A 

Cyclone 

Fabric Filter 

Fabric Filter 

N/ A 

Fabric Filter 

Applicable 

Requirements 

K.A.R. 28-19-20 

K.A.R. 28-19- 

650(a)(3 

40 CFR Part 60, 

Subpart A 

40 CFR Part 60, 

Subpart PPP 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9-20 

K.A.R. 28- 19- 

65o(a)(3 

K.A.R. 28- 19-20 

K.A.R. 28-1 9- 

650(a)(3) 

K.A.R.28- 19-50 1 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28- 19-20 

K.A.R. 28-1 9- 

650(a)(3) 

K.A.R.28-19-501(d) 

K.A.R. 28- 19-20 1 

K.A.R. 28-1 9- 

65o(a)(3) 

K.A.R. 28- 19-20 

K.A.R. 28-19- 

65O(a)(3) 
Page 14 of 38 

' 

Emission 

Source ID 

EU-122013b 

EU- 1220 14 

EU-122015 

EU-B WOO 1 a 

EU-BWOOl b 

EU-OMMI 1 a 

EU-OMMl 1 b 

Emission Source 

Description 

122 K&S 

Vacuum Wind-up 

(Lower levelvents inside) 

122 ARB Pkg. 

(Vents inside) 

122 Heat Shrink 

System (gasfired) (vents 

inside) 

North Blowing 

Wool Operations 

(includes B W pit, 

BW receiving & 

Packaging) 

South Blowing 

Wool Operations 

(includes B W pit, 

BW receiving & 

Packaging) 

122 OMMI Scrap 

Refeed System 

123 OMMI Scrap 

Refeed System 

StacWent ID 

SV-122013b 

----- 

SV- 1220 14 

N/A 

SV-BW001a 

SV-B WOO 1 b 

SV-OMMI 1 a 

SV-OMMI 1 b 

Control 

Equipment ID 

CE-1220 13b 

N/ A 

N/ A 

CE-B WOO 1 a 

CE-BW001 b 

CE-OMMI 1 a 

CE-OMMI 1 b 

Control 

Equipment 

Description 

Fabric Filter 

Applicable 

Requirements 

K.A.R. 28-1 9-20 

K.A.R. 28-19- 

65O(a)(3) 

N/A K.A.R. 28-19- 

N/A 

Fabric Filter 

Fabric Filter 

Fabric Filter 

Fabric Filter 

K.A.R. 28-19-20 

K.A.R. 28-1 9- 

65o(a)(3 

K.A.R. 28- 19-20 

K.A.R. 28- 19- 

650(4(3) 

K.A.R.28-19-501 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28- 19-20 

K.A.R. 28- 19- 

65o(a)(3) 

K.A.R.28-19-50 1 (d) 

Construction Permit 

(713 1/02) 

K.A.R. 28- 19-20 

K.A.R. 28- 19- 

650(a)(3) 

K.A.R.28-19-501(d) 

Construction Permit 

(713 1/02) 

K.A.R. 28-1 9- 

65o(a)(3) 

K.A.R.28-19-501 (d) 

Construction Permit 

(713 1/02) 
Summary of Applicable Requirements 

Emission 

Source ID 

EU-OMNII2 

K.A.R. 28- 19-30 through K.A.R. 28- 19-32, Emission Limitations Indirect Heating Units ......... 27 

K.A.R. 28-19-720, 40 CFR Part 60, Subpart A and Subpart PPP ................................................ 18 

K.AR 28- 19.20, Particulate Matter Emission Limitations ........................................................... 16 

40 CFR Part 64, Compliance Assurance Monitoring ................................................................... 21 

K.A.R. 28-1 9.650, Emission Opacity Limits ............................................................................. 27 

K.A.R. 28-19-55 through K.A.R. 28.19.58, Emergency Episode Plans ...................................... 27 

K.A.R. 28.19.202, Annual Fee Payment ...................................................................................... 27 

K.A.R. 28- 19-2 10, Calculation of Actual Emissions .................................................................... 27 

K.A.R. 28-1 9-5 17, Annual Emissions Inventory .......................................................................... 28 

K.A.R. 28.19.645, Open Burning ............................................................................................... 28 

K.A.R. 28- 19.735, Which Adopted by Reference 40 CFR Part 6 1, Subparts A and M ............... 28 

40 CFR Part 68, Chemical Accident Prevention Provisions ......................................................... 28 

40 CFR Part 82, Protection of Stratospheric Ozone ..................................................................... 28 

Page 15 of 38 

Emission Source 

Description 

122 OMMI Scrap 

Refeed Clean-up 

System (vents 

inside) 

StacWVent ID 

SV-OMMI002 

Control 

Equipment ID 

CE-OMMI002 

Control 

Equipment 

Description 

Fabric Filter 

Applicable 

Requirements 

K.A.R. 28- 19- 

65o(a)(3) 

Construction Permit 

(713 1/02) 
Applicable Requirements 

A. The following emission sources are subject to the requirement listed below: 

IA-SPCHTRa-h1SV-SPCHTRa-h eight (8) 12.8 mmBTU/hr natural gas fired space 

heaters 

IA-SHTRdSV-SHTRa one (1) 2.5 mmBTU/hr Centac 1&2 Rm. natural gas 

fired space heater 

IA-WTBdSV-WTBa 1.7 mmBTU/hr natural gas fired water tube boiler 

IA-WTBblSV-WTBb 2.1 mmBTU/hr natural gas fired water tube boiler 

1. Limitation or Standard 

Particulate matter emissions are limited to the amount determined by the following equation 

[K.A.R. 28-19-3 l(a)]: 

Where: 

A =the allowable emission rate in lb1106 BTU 

I = the total heat input in 1 o6 BTU/hr [K.A.R. 28-1 9-3 1 (a)] 

The allowable emission rate in lb/106 BTU for indirect heating equipment with total heat 

input less than ten (1 0) million BTUh is 0.6 lbll o6 BTU. 

Monitoring: 

The owner or operator shall re-evaluate the particulate emission rate limitation when either 

the process changes or an emission factor changes. 

Record keeping and Reporting 

Records shall be maintained of any recalculations and evaluations. These records shall 

include the design rate capacity of the unit, emission factors used in calculations and 

potential/allowable emissions rates. 

Page 16of38 
B. The following emission sources are subject to the requirements listed below: 

EU-B002a-i/SV-B002a-i1CE-B002a-i 

EU-B003lSV-B004lCE-BOO4 

EU-B004lSV-B004lCE-BOO4 

EU-123001lSV-123001lCE-123001 

EU- 123002lSV- 123 002lCE- 123 002 

EU-l23003a-dlSV- 123 003a-d/CE- 123003a-d 

EU-122001lSV-122001lCE-122001 

EU-122002lSV- 122002lCE- 122002 

EU-l22003a-c/SV- 122003a-c1CE- 122003a-c 

EU- 1220 1 1 a1SV-OMMI 1/CE-OMMI 1 a 

EU-B WOO la-b/SV-B WOO 1 a-b1CE-B WOO1 a-b 

EU-123014lSV-123014lCE-123014 

EU-122011lSV-12201 11CE-12201 1 

EU-ONIMI 1 a-b/SV-OMMI 1 a-b/CE-OMMI 1 a-b 

EU-122008/SV-122008/CE-122008 

EU-123010lSV-123OlOlCE-123010 

Raw Material Silos 

Weigh Scale 

Bad Batch 

Blender Receiver 

Blender . 

Melter Day Bins 

Blender Receiver 

Blender 

M- 1, M-2 & spareS~ay Bins 

Edge Material Refeed 

Blowing Wool Operations 

Waste Edge Removal 

Waste Edge removal 

Scrap Refeed System 

122 Curing Oven/HEAF 

123 Curing OvenIHEAF 

1. Limitation or Standard 

The air emission control equipment, including high energy air filtration (HEAF) equipment, 

shall be continuously used while operating the emission unit. [K.A.R. 28-1 9-50 1 (d)(l)] 

Monitoring 

A written air pollution control maintenance plan for the air emission control equipment shall 

be developed (within 180 days of permit issuance), implemented and maintained. [K.A.R. 

28-19-501(d)(2)] 

Recordkeeping and Reporting 

The owner or operator shall maintain a log showing the date of all routine or other 

maintenance or repairs of the air emission control equipment, the action taken on such date, 

and any corrective action or preventative measures taken. [K.A.R. 28-19-501(d)(3)] 

C. The following emission sources are subject to the requirements listed below: 

EU- 123 007lSV- 123 007 

EU- 123008lSV-123008 

EU-123010/SV123010 

EU-123011lSV-123011 

M- 1 Collection 

M-2 Collection 

HEAF 

North Cooling 

Page 17 of 38 
M-1 North Collection 

M- 1 South Collection 

M-2 South Collection 

HEAF 

M-3 Collection 

South Cooling 

M-2 North Collection 

Cooling 

1. Limitation or Standard 

Particulate emissions fiom the combined forming, curing, and cooling sections of the rotary 

spin wool fiberglass insulation manufacturing lines (Lines 122 and 123) shall not exceed 11 .O 

lb particulatelton of glass pulled for each line. [K.A.R. 28-19-720; New source performance 

standards, which adopts by reference 40 CFR Part 60, Subpart PPP, Standard of Performance 

for Wool Fiberglass Insulation Manufacturing Plants, and Subpart A, General Provisions; 

Construction Permit dated 713 1/02] 

Monitoring 

Initial compliance was determined by performance tests conducted in accordance with the 

provisions of 40 CFR 60.685. (Construction Permit dated 713 112002) 

The owner or operator shall continuously monitor the glass pull rate (in poundsh) of line 

122 and 123. The frequency of the monitoring shall be no less than once every four hours. 

The glass pull rate of line 122 and line 123 shall not exceed the maximum glass pull rate 

measured during a successful performance test. (Construction Permit dated 713 112002) 

In the event the owner or operator of the rotary spin wool fiberglass insulation manufacturing 

lines elects to utilize either a wet scrubber or electrostatic precipitator control device in 

operating the lines, the monitoring requirements of 40 CFR 60.684 shall apply. (Construction 

Permit dated 713 112002). 

Recordkeeping and Reporting 

Records documenting the occurrence and duration of any start-up, shutdown, or malfunction 

in the operation of Lines 122 and 123 and the associated control equipment are to be 

maintained [40 CFR 60.7(b); Construction Permit dated 713 1120021. 

Page 18 of 38 
Records of the glass pull rates (in lbhour) shall be maintained for the life of the permit. 

In the event the owner or operator of the rotary spin wool fiberglass insulation manufacturing 

lines elects to utilize either a wet scrubber or electrostatic precipitator control device in 

operating the lines, the recordkeeping and reporting requirements of 40 CFR 60.684 shall 

apply. 

D. The following emission sources are subject to the requirement listed below: 

EU-B0011SV-BOO 1 

EU-BOO2(a-i)/SV-BOO2(a-i) 

EU-B004/SV-BOO4 

EU-B003/SV-BOO4 

EU-123003(a-d)/SV-123003(a-d) 

EU-123007lSV-123007 

EU-123009lSV-123009 

EU-123010lSV-123010 

EU-123012/SV-123012 

EU-123013lSV-123013 

EU-123015lSV-123015 

EU-123016dSV-B123Ol6a 

EU-123018lSV-123018 

EU- 1220 12lSV-1220 12 

EU- 1220021SV- 122002 

EU- 122003dSV- 122003 a 

EU- 122003cISV- 122003~ 

EU- 122006alSV- 122006a 

EU- 122006blSV-122006b 

EU-122007blSV- 122007b 

EU-122008lSV-122008 

EU- 1220 1 OISV- 1220 10 

EU-122011lSV-122011 

EU-122013dSV-122013a 

EU-122013blSV-122013b 

EU-BWOOl(a-b)/SV-BWOOl(a-b) 

EU-OMMI1 dSV-OMMI 1 a 

EU-123001lSV-123001 

EU- 1230021SV- 123 002 

EU-123008lSV-123008 

EU-123011lSV-123011 

EU-123014lSV-123014 

Batch Unload 

Raw Material Silos 

Bad Batch 

Weigh Scale 

Melter Day Bins 

M- 1 Collection 

M-3 Collection 

HEAF 

South Cooling 

Slitting Cyclone 

Hot Roll 

K&S Upper Level 

CPW Packaging 

Hot Roll 

Blender 

M-1, M-2 & Spare Day Bins 

Spare Day Bin 

M-1 North Collection 

M-1 South Collection 

M-2 South Collection 

HEAF 

Slitting Cyclone 

Waste edge removal 

K&S Upper Level 

K&S Lower Level 

Blowing Wool N&S 

Scrap Refeed 

Blender Receiver 

Blender 

M-2 Collection 

North Cooling 

Waste Edge removal 

Page 19 of 38 
EU-123016b/SV-123016b 

EU- 12200 1 /SV- 12200 1 

EU- 122003b/SV-122003b 

EU- 122007dSV- 122007a 

EU- 122009/SV-122009 

EU-122011dSV-12201 la 

EU- 1220 15/SV- 1220 15 

EU- 1230 14dSV-OMMI 1 

K&S Lower Level 

Blender Receiver 

M-2 Day Bin 

M-2 North Collection 

Cooling 

Edge Material Refeed 

Heat Shrink 

Edge Material Refeed 

1. Limitation or Standard 

Particulate matter emissions are limited to the amounts determined by the following 

equations: [K.A.R. 28-1 9-20] 

Where: E = the rate of emissions in lbh 

P = the process weight in tonsh 

for: Process weight 5 30 tonsh 

E = 4.1PO.^^) 

for: Process weight > 30 tonsh 

Monitoring: 

The owner or operator shall re-evaluate the particulate emission rate limitation when either 

the process changes or an emission factor increases. 

Recordkeeping and Reporting: 

Records shall be maintained of any recalculations and evaluations. These records shall 

include the design rate capacity of the unit, emission factors used in calculations and 

potential/ allowable emission rates. 

E. The following emission sources are subject to the requirements listed below: 

EU-l22004/SV-122004 

EU-122005/SV- 122005 

EU- 123004/SV- 123004 

M-1 Melter 

M-2 Melter 

M-1 Melter 

Page 20 of 38 
EU-123005lSV-123005 M-2 Melter 

EU-123006lSV-123006 M-3 Melter 

1. Limitation or Standard 

Particulate matter emissions are limited to the amounts determined by the following 

equations: [K.A.R. 28- 19-20] 

Where: E = the rate of emissions in lbh 

P = the process weight in tonsh 

for: Process weight I 30 tonslhr 

for: Process weight > 30 tonsh 

Monitoring: 

Compliance Assurance Monitoring 

Monitoring shall be performed in compliance with 40 CFR Part 64, Compliance Assurance 

Monitoring (CAM) found in CAM Plan, Attachment C. 

Alternate monitoring may be established through the development of a revised CAM Plan. 

Once approved in writing by KDHE, the ownerloperator will comply with the new 

requirements on such date as agreed upon with the KDHE. The newly approved 

requirements will supersede the monitoring established above. The new monitoring will be 

incorporated into the permit upon renewal or significant modification to the permit, 

whichever comes first. See CAM Plan, Attachment C. 

CAM Monitoring shall begin with the reporting period that begins July 1,2009. Prior to July 

1,2009, the facility shall conduct monitoring as required by the Class I permit issued on June 

15,2004. 

Recordkeeping and Reporting 

Records shall be maintained in accordance with the requirements of 40 CFR 64 and the 

CAM Plan in Attachment C. The CAM Plan and any revisions of such plan approved by the 

KDHE shall be maintained onsite in a form suitable for inspection. 

CAM Recordkeeping and Reporting shall begin with the reporting period that begins July 1, 

2009. Prior to July 1,2009, the facility shall conduct monitoring as required by the Class I 

permit issued on June 15,2004. 

Page 21 of 38 
2. Limitation or Standard 

Upon completion of changes authorized by the Construction Approval dated March 12,2009, 

the external glass cullet usage shall be limited such that the combined emissions of sulfur 

dioxides (SO2) from Lines 122 and Line 123 shall not exceed 40 tons during any consecutive 

twelve (1 2) month period, calculated monthly by the following inequality: 

[3.15 x ~o"x(A) +2.142 x ~o-~x(B)] 12000 <40 tons of SO^: 

Where: 

A = amount of External Glass Cullet (in lbs) processed on Line 122 

B = amount of External Glass Cullet (in lbs) processed on Line 123 

(Construction Approval dated March 12,2009) 

Monitoring 

The sulfur dioxide emission rates from each melter on Line 122 and Line 123 shall be 

verified by a performance test. (Construction Approval dated March 12,2009) 

External Glass Cullet usage rates (in lbs) for each line shall be calculated monthly no later 

than the last day of the month following the month to which the record relates. 

Recordkeeping and Reporting 

Records of monthly External Glass Cullet usage rates (in lbs) for each line shall be 

maintained and updated monthly no later than the last day of the month following the month 

to which the record relates. 

Records of the 12 month consecutive total of Sulfur Dioxide emissions shall be maintained 

and updated monthly, no later than the last day of the month following the month to which 

the record relates. (Construction Approval dated March 12,2009) 

F. The following emission sources are subject to the requirements listed below: 

EU- 122003dSV- 122003a M-1, M-2 & Spare Day Bins 

EU-122003blSV-122003b M-2 Day Bin 

EU-122004lSV-122004 M-1 Melter 

EU- 122005lSV-122005 M-2 Melter 

EU- 122002lSV- 122002 Blender 

EU- 122006dSV- 122006a M- 1 North Collection 

EU-122007dSV- 122007a M-2 North Collection 

Page 22 of 38 
EU- 122007blSV- 122007b 

EU- 122009lSV- 122009 

EU- 12201 11SV-122011 

EU-123003a-d1SV-l23003a-d 

EU- 12300 11SV- 123 00 1 

EU- 123004lSV- 123 004 

EU-123005lSV- 123005 

EU-B0011SV-BOO1 

EU-BOO2(a-i)/SV-BOO2(a-i) 

EU-B003lSV-BOO4 

EU-B004lSV-BOO4 

EU- 123007lSV- 123007 

EU- 123009lSV- 123009 

EU-123010lSV-123010 

EU-123012lSV-123012 

EU-123014lSV-123014 

EU-123002lSV-123002 

EU-OMMI2lSV-OMMI2 

EU- 122003cISV- 122003~ 

EU- 12200 11SV- 12200 1 

EU-122006bISV-122006b 

EU-122008lSV-122008 

EU-123006lSV- 123006 

EU-123008lSV-123008 

EU-l23011lSV-123011 

EU-BWOOlaISV-BWOOla 

EU-BWOO1 blSV-B WOO 1 b 

EU-OMMI 1 a-b/SV-OMMI 1 a-b 

M-2 South Collection 

Cooling 

Waste Edge Removal 

Day Bins 

Blender Receiver 

M- 1 Melter 

M-2 melter 

Batch Unload 

Raw Material Silos 

Weigh Scale 

Bad Batch 

M- 1 Collection 

M-3 Collection 

HEAF 

South Cooling 

Waste Edge removal 

Blender 

Scrap Refeed Clean-out 

Spare Day Bin 

Blender Receiver 

M- 1 South Collection 

HEAF 

M-3 Melter 

M-2 Collection 

North Cooling 

Blowing Wool North 

Blowing Wool South 

Scrap Refeed 

1. Limitation or Standard 

The combination of emissions from Lines 122 and 123, including raw material handling, 

fiberglass production, and finished product handling shall be less than the following mass 

emission rates: [Construction Permit effective 713 1/02] 

a. Carbon monoxide 225.0 lbsh 

b. Nitrogen oxides 20.5 lbsh 

c. Particulate matter 116.9 lbsh 

d. Particulate matter (< 10 microns) 116.9 lbslhr 

e. Volatile organic compounds 74.1 lbsh 

Page 23 of 38 
Monitoring 

The owner or operator shall re-evaluate the mass emission limits above whenever 

modifications to the lines are made that may alter line emission rates. 

When required as described above, demonstration of compliance with the mass emission 

limits shall be accomplished by performance test as follows: 

a. Carbon monoxide emission rates for the melting, forming, curing and 

cooling operations shall be determined using EPA Method 10. 

b. Volatile organic compound emission rates for the melting, forming, curing 

and cooling operations shall be determined using EPA Method 25A or other 

methods agreed to by KDHE. 

c. Nitrogen oxides emission rates for the melting, forming, curing and cooling 

operations shall be determined using EPA Method 7E. 

d. Particulate matter and particulate matter less than .lo microns emission rates 

for the melting, forming, curing and cooling operations shall be determined 

using EPA Method 5 for the determination of filterable particulate and 

Method 202 for the determination of condensable particulate. 

e. One forming module from each line may be tested with the results being 

considered representative for the other forming modules on that line. 

Performance tests shall be conducted on lines 122 and 123 while the product with the 

highest loss on ignition (LOI) value expected to be produced on the line is being 

manufactured. 

Recordkeeping and Reporting 

Written notification of any physical or operational change to the unit which may increase 

the emission rate of the unit as required at 40 CFR 60.7(a)(4) shall be provided to the 

KDHE. This notice shall be postmarked 60 days, or as soon as practicable, before the 

change is implemented and shall include the following information: 

1. The pre cise nature of the change; 

2. Present and proposed emission control systems; 

3. The production capacity of the unit before and after the change; and 

4. The expected completion date of the change. 

Page 24 of 3 8 
Notification of performance testing shall be given to the JSDHE no less than 30 days prior 

to testing. A written report of the results of performance testing shall be submitted to the 

JSDHE no less than 30 days after successful completion of the testing. 

2. Limitation or Standard 

The glass pull rates of Lines 122 and 123 shall not exceed the maximum glass pull rates 

achieved during successful performance tests as required above. [Construction Permit 

effective 713 1/02] 

Monitoring 

The pull rate may be determined by either of the following methods: 

a. Pull rates may be verified no less often than once every four hours, in which 

case the pull rate may not exceed the above limits; or 

b. Pull rates may be verified once every 30 minutes, in which case the average 

pull rate of any three consecutive readings may not exceed the above limits. 

Recordkeeping and Reporting 

Records of the glass pull rates (in lbhour) shall be maintained for the life of the permit. 

(Construction Permit effective 713 112002) 

Single measurement excursions above the maximum glass pull rates achieved during the 

performance tests, but within the limits of precision of the measurement method [two (2) 

percent of the maximum value] shall not be considered a deviation in accordance with the 

Reporting of Deviations from Permit Terms section of this permit. The glass pull rates 

of Lines 122 and 123 may be altered as operating configurations change provided that any 

combined emission rate changes associated with the changes are documented and the 

maximum combined emission rate limitations established above are not exceeded. 

G. The following emission sources are subject to the requirement listed below: 

EU-122003a-clSV-122003a-c 

EU- 122004lSV- 122004 

EU- 12200 1 ISV- 12200 1 

EU- 122002lSV- 122002 

EU- 1220 1 OISV- 1220 10 

EU- 1 220 1 1 ISV- 1220 1 1 

Melter Day Bins 

M-1 Melter 

Blender Receiver 

Blender 

Slitting Cyclone 

Waste Edge Removal 

Page 25 of 38 
EU-l23003a-d1SV-l23003a-d 

EU-123001lSV-123001 

EU-123013lSV-123013 

EU-123014lSV-123014 

EU-123016dSV-B123016a 

EU-123016blSV-123016b 

EU-122005lSV-122005 

EU-122008lSV-122008 

EU-122011dSV-12201 la 

EU-B004lSV-BOO4 

EU- 123004lSV-123004 

EU-123014dSV-123014a 

EU-123010lSV-123010 

Melter Day Bins 

Blender receiver 

Slitting Cyclone 

Waste Edge Removal 

K&S Upper Level 

K&S Lower Level 

M-2 Melter 

HEAF 

Edge Material Refeed 

Bad Batch 

M-1 Melter 

Edge Material Refeed 

HEAF 

1. Limitation or Standard 

Emissions from the raw material storage silos, material handling, glass melters, and curing 

section on lines 122 and 123 shall be vented to emission control equipment. [K.A.R. 28-1 9- 

501 (d)(l); Construction Permit dated 713 1120021 

Monitoring 

A written air pollution control maintenance plan for the air emission control equipment 

shall be developed (within 180 days of permit issuance), implemented and maintained. 

[K.A.R. 28- 19-50 1 (d)(2)] 

Recordkeeping and Reporting 

The owner or operator shall maintain a log showing the date of all routine or other 

maintenance or repairs of the air emission control equipment, the action taken on such date, 

and any corrective action or preventative measures taken. [K.A.R. 28-1 9-501 (d)(3)] 

Qualitative assessments as described in the Opacity Limitations and Monitoring Section and 

other reporting requirements as described in the Applicable Requirements Section of this 

permit are required. The facility is required to submit semi-annual reports. Refer to the 

Testing, Monitoring, Recordkeeping and Reporting Section of this permit for the submittal 

dates of these reports. 

Page 26 of 38 
StacMVent Opacity Summary 

All emission units are limited to 20% opacity: Periodic monitoring and recordkeeping of 

periodic monitoring will be performed and maintained as provided in the Opacity Limitations 

and Monitoring section of this permit. 

Facility-Wide Applicable Requirements 

The permittee shall comply with the following when required by the relevant regulation: 

K.A.R. 28- 19-30 through K.A.R. 28- 19-32, Emission Limitations (Indirect Heating Equipment 

Except as provided in K.A.R. 28-19-32, aggregated emissions of particulate matter from 

indirect heating equipment shall not exceed those specified in table H-1 of K.A.R. 28-19- 

3 1 (a) or for equipment having intermediate heat input between 1 O(1 06) BTUh and 

10,000(1 06) BTUh, the allowable emission rate may be determined by the equation 

provided at K.A.R. 28-1 9-3 l(a). 

Records shall be maintained of any recalculations and evaluations. These records shall 

include the design rate capacity of the unit, emission factors used in calculations and 

potential/allowable emission rates. 

K.A.R. 28-19-55 through K.A.R. 28-19-58, Emergency Episode Plans 

The permittee shall comply with the requirements of K.A.R. 28-19-55 through 28-19-58, 

Emergency Episode Plans, and shall maintain on site an emergency episode plan if the 

KDHE requires an emergency episode plan be developed pursuant to K.A.R. 28-19-58. 

K.A.R. 28-19-202, Annual Fee Payment 

The owner or operator of a permitted emissions unit or stationary source is required to pay 

fees to the permitting authority consistent with the fee schedule set out in the regulations 

pursuant to K.A.R. 28-19-202. 

K.A.R. 28-1 9-21 0, Calculation of Actual Emissions 

The following applies to emission control equipment not otherwise addressed in this 

permit: 

If the owner or operator uses air emission control equipment, not otherwise addressed in 

this permit, to calculate actual emissions, the air emission control equipment shall be 

maintained in accordance with the manufacturer's recommendation. The owner or operator 

shall keep a written log recording the date and type of action taken when performing 

preventive or other maintenance on the air emission control equipment. 

Page 27 of 38 
K.A.R. 28-1 9-5 17. Annual Emissions Inventory 

The owner or operator shall submit all operating or relevant information to estimate 

emissions for the preceding year to the KDHE. This information shall be submitted on or 

before the date specified at K.A.R. 28-19-517 or amendments thereto and shall be 

submitted on forms provided or approved by the KDHE. At the time of permit issuance, 

the due date for submittal of this information is June 1. 

The permittee is prohibited from conducting open burning, except as allowed by K.A.R. 

28-19-647 and K.A.R. 28-19-648. 

K.A.R. 28-1 9-735, Which Adopted by Reference 40 CFR Part 6 1, Subpart A 

and Subpart M 

The permittee shall comply with the National Emission Standard for Hazardous Air 

Pollutants (NESHAP) 40 CFR Part 61, Subpart A, General Provisions and Subpart M, 

National Emission Standard for Asbestos, adopted by K.A.R. 28-19-735, and K.A.R. 28- 

50-1 et sea. when conducting any renovation or demolition activities at the facility. 

40 CFR Part 68, Chemical Accident Prevention Provisions 

Chemical Accident Prevention Provisions, 40 CFR Part 68, is applicable to an owner or 

operator of a stationary source that has more than a threshold quantity of a regulated 

substance in a process, as determined in 40 CFR 68.1 15. 

If the stationary source is subject to 40 CFR Part 68, but is not required to comply with 

those requirements as of the effective date of this operating permit, the stationary source 

shall be in compliance with the requirements of 40 CFR Part 68 no later than the latest of 

the following dates: 

a. Three years after the date on which a regulated substance is first listed in 40 CFR 

68.130; or 

b. The date on which a regulated substance is first present above a threshold quantity in a 

process. 

40 CFR Part 82, Protection of Stratospheric Ozone 

The permittee shall comply with 40 CFR Part 82, Protection of Stratospheric Ozone. 

Affected controlled substances include, but are not limited to, chlorofluorocarbons, 

hydrochlorofluorocarbon refrigerants, halons, carbon tetrachloride, and methyl chloroform 

(specific affected controlled substances are listed in 40 CFR Part 82, Subpart A, appendices 

A {Class I) and B {Class 11)). 

Page 28 of 38 
The following subparts and sections of 40 CFR Part 82 are conditions of this permit: 

Subpart A - Production and Consumption Controls 

Subpart B - Servicing of Motor Vehicle Air Conditioners 

Subpart E - Labeling of Products Using Ozone-Depleting Substances: Sections; 82.106 

Warning statement requirements, 82.108 Placement of warning statement, 

82.1 10 Form of label bearing warning statement, and 82.1 12 Removal of 

label bearing warning statement 

Subpart F - Recycling and Emissions Reduction: Sections; 82.1 56 Required practices, 

82.158 Standards for recycling and recovery equipment, 82.16 1 Technician 

certification, and 82.166 Reporting and recordkeeping requirements 

Subpart G Significant New Alternatives Policy Program 

Opacitv Limitations and Monitoring 

Except as otherwise provided in K.A.R. 28-19-9, K.A.R. 28-19-1 1, K.A.R. 28-19-650(c) or 

as otherwise identified in the applicable requirements portion of this permit, K.A.R. 28-19- 

650(a)(3) limits visible air emissions from each emission unit to 20%. K.A.R. 28-19- 

3 1(b)(2) limits air emissions from any indirect heating equipment to less than 20%. 

Except as otherwise provided in the applicable requirements portion of this permit, 

emissions from the following or similar activities do not require routine periodic 

monitoring: emissions vented inside an enclosed building or structure, from cooling towers 

and from evaporative VOC sources; and when burning natural gas, propaneILPG, or 

refinery gas, emissions from turbines, reciprocating internal combustion engines, burners in 

indirect heating applications and space heaters. 

Routine periodic monitoring requirements: Except as otherwise provided in the applicable 

requirements portion of this permit or as provided above, the owner or operator shall 

perform a qualitative assessment at least once per calendar month, with at least one week 

between assessments. The monthly qualitative assessment shall include each activity at the 

facility, which is operating at the time scheduled. For each activity from which the opacity 

of visible emissions appears to exceed the limit, the permittee shall take appropriate action 

to correct process operating parameters, after which the permittee shall perform an 

additional qualitative assessment for that unit. If, at the end of ten operating days from the 

date of the possible exceedance, opacity of visible emissions appears to continue to exceed 

the limit, the owner or operator shall notify the agency. Within seven days of the end of 

the ten operating day period, a test of visible emissions from the unit shall be scheduled. 

The test shall occur within 30 days of the end of the ten operating day period and shall 

utilize EPA Method 9. 

Page 29 of 38 
The person responsible for making qualitative opacity assessments shall be knowledgeable 

about the effects on visibility of emissions caused by background contrast, ambient 

lighting, observer position relative to lighting and wind, and the presence of uncombined 

water in the plume.' The permittee shall keep records of each qualitative assessment, 

which shall include the time and date of the assessment, a description of the emission point 

from which any unusual emissions emanated, the steps taken to correct any abnormal 

emissions, and the name of the person conducting the assessment. 

BAR does not consider a qualitative assessment in which emissions appear to exceed the 

applicable opacity limits to be a violation or deviation subject to reporting in accordance 

with the Reporting of Deviations from Permit Terms portion of this permit. A Method 9 

evaluation that shows opacity exceeding the emission limit would be subject to reporting in 

accordance with the Reporting of Deviation from Permit Terms portion of this permit. 

\ 

Requirements Which Will Become Applicable During the Permit Term 

The owner or operator, in accordance with the provisions of K.A.R. 28-1 9-5 1 1 (b) (1 6) (C) 

(ii) and K.A.R. 28-1 9-5 12(a) (23) shall comply in a timely manner with those applicable 

requirements that become effective during the permit term, unless a detailed schedule is 

expressly required by the applicable requirement. 

40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazard Air Pollutants 

(NESHAP) for Reciprocating Internal Combustion Engines (RICE) became effective 

during the initial permit term. Units at this facility are not subject at this time. However, in 

the EPA Federal register 74 FR 9697dated March 5,2009, EPA outlines its proposed 

standards for existing RICE units at Area and Major Sources of HAPS. Should you become 

subject to subsequently promulgated state or federal MACT requirements, the owner or 

operator shall comply with the applicable provisions. 

Permit Shield 

Compliance with the conditions of this permit shall be deemed in compliance with the 

applicable requirements of the Kansas air quality program as of the date of permit issuance. 

This shield applies only to: 

a. applicable requirements included, and specifically identified in the permit; and 

b. applicable requirements that KDHE has specifically identified' in writing as not being 

applicable to the emissions unit or stationary sources and the determination or a concise 

summary thereof is included in the permit. 

' For basic information about opacity observations, refer to 40 CFR Part 60 Appendix A, Method 9. 

Page 30 of 38 
Nothing in this permit shall alter or affect: 

a. the liability of a permittee for any violation of an applicable requirement occurring 

prior to or at the time of issuance of this permit; 

b. U.S. EPA's ability to obtain information under Section 114 of the Clean Air Act; or 

c. the provisions of Section 303, Emergency orders, of the Clean Air Act, including the 

authority of the administrator of the U.S. EPA under that section or the air pollution 

emergency provisions of the Kansas air quality program regulations, K.A.R. 28-19-55 

through 28-1 9-58; or 

d. the applicable requirements of the acid rain program, consistent with section 408(a) of 

the Act. 

[K.A.R. 28-1 9-512(b)] 

Testing, Monitoring;, Recordkeeping, & Reporting 

Testing, monitoring, recordkeeping and reporting requirements sufficient to assure 

compliance with the terms and conditions of the permit are required. 

In addition to any testing, monitoring, recordkeeping or reporting requirement contained in 

the "Applicable Requirements" section of this permit, monitoring and reporting may be 

required under the provisions of K.A.R. 28- 19- 12, "Measurement of emissions", or as 

required by any other provision of the federal Clean Air Act. 

Records to support all monitoring and copies of all reports required by the permit must be 

maintained for a period of at least five years from the date of the activity. Summary reports 

of any routine, continuous or periodic monitoring must continue to be submitted at sixmonth intervals, 30 days after each subsequent six month period for the duration of the 

permit. All instances of deviations from permit requirements, including perceived opacity 

exceedances, shall be clearly identified in the report. [K.A.R. 28- 19-5 12(a)(1 l)(A)] 

Submission of quarterly or semi-annual reports required by any applicable requirement 

which are duplicative of the reporting required in the previous paragraph will satisfy the 

reporting requirements of the previous paragraph if noted on the submitted report. 

[K.A.R. 28-1 9-5 12(a)(9)] 

Records of required monitoring shall include: 

a. the date, place and time of sampling or measurement; 

b. the date or dates. analyses were performed; 

c. the company or entity which performed the analyses; 

d. the analytical techniques or methods used; 

e. the results of the analyses; and 

Page 3 1 of 38 
f. the operating conditions that existed at the time of sampling or measurement. 

g. the retention of records of all required monitoring data and support information for a 

period of at least 5 years from the date of the monitoring sample, measurement, report, 

or application. Support information shall include all calibration and maintenance 

records and all original strip-chart recordings for continuous monitoring 

instrumentation, and copies of all reports required by the permit. 

[K.A.R. 28-1 9-5 12(a)(10)] 

Reporting of Deviations from Permit Terms 

Unless a different time period is specified in this permit, deviations from the requirements 

of this permit shall be reported to KDHE as follows: 

a. Deviations which result in emissions exceeding those allowed in this permit shall be 

reported the next business day following the discovery of the release, with follow-up 

written notice within five business days following discovery of the release. The report 

shall include the probable cause of such deviations and any corrective actions or 

preventive measures taken. 

b. Deviations which do not result in emissions exceeding those allowed in this permit 

shall be reported in writing within 10 business days following discovery of the 

deviation. 

Oral notifications may be made to the air program field staff at the North Central District 

Office in Salina or to the KDHE central office in Topeka. Written notifications shall be 

made to the KDHE central office with a copy to the North Central District Office 

[K.A.R. 28-19-5 12(a)(1 l)] 

General Provisions 

1. K.A.R. 28-1 9- 1 1, Exceptions Due to Breakdowns or Scheduled Maintenance 

a. Abnormal operating conditions resulting from malfunction, breakdown or necessary 

repairs to control or processing equipment and appurtenances which cause emissions 

in excess of the limitations specified at K.A.R. 28-1 9-30 through 28- 19-32 and K.A.R. 

28- 19-650 shall not be deemed violations provided that: 

i. The person responsible for the operation of the emission source notifies the 

department of the occurrence and nature of such malfunctions, breakdown or 

repairs, in writing, within 10 days of noted occurrence. 

Page 32 of 38 
ii. The number of occurrences of such breakdowns is not deemed excessive by the 

department and appropriate reasonable action is taken to initiate and complete any 

necessary repairs and place the equipment back in operation as quickly as possible. 

b. Emissions in excess of the limitations specified at K.A.R. 28-19-30 through 28-19-32 

and K.A.R. 28-1 9-650 resulting from scheduled maintenance of control equipment 

and appurtenances will be permitted only on the basis of prior approval by the 

department and upon demonstration that such maintenance cannot be accomplished 

by maximum reasonable effort, including off-shift labor where required, during 

periods of shutdown of any related equipment. 

2. K.A.R. 28-19-752a. Hazardous Air Pollutants; Limitations Applicable to Construction of 

New Maior Sources or Reconstruction of Existing Maior Sources 

This regulation shall continue in effect for an emissions unit or stationary source until a 

standard has been promulgated which is applicable to such source pursuant to section 

112(d) of the federal Clean Air Act. 

This regulation shall apply whenever construction of a new major source or reconstruction 

of an existing major source of hazardous air pollutants is proposed. 

3. Permit Term and Renewal 

This permit has a term of five years unless otherwise stated in this permit. A complete 

application, as defined in K.A.R. 28-19-5 18, and any applicable fee must be submitted to 

KDHE not less than six months and not more than 18 months prior to the expiration date. 

This operating permit shall not expire on the expiration date if a complete and timely 

application has been filed with the KDHE. [K.A.R. 28-19-5 12(a)(8) and K.A.R. 28-19- 

5 141 

4. Severability 

The provisions of this permit are severable, and if any portion of this permit, or the 

application of any provision of this permit to any circumstance, is held invalid, the 

application of such provision to other circumstance, and the remainder of this permit, shall 

not be affected thereby. [K.A.R. 28-1 9-5 12(a)(13)] 

5. Property Rights 

This permit does not convey any property rights of any sort or any exclusive privilege. 

[K.A.R. 28-1 9-5 12(a)(l4)(D)] 

Page 33 of 38 
6. Compliance 

The owner or operator shall comply with all conditions of the permit and shall continue to 

comply with applicable requirements with which the owner or operator is in compliance. 

Any permit noncompliance shall constitute a violation of the Kansas Air Quality Act and 

shall be grounds for enforcement action, for permit revocation or amendment, or for denial 

of a permit renewal application. All permit terms and conditions are federally enforceable. 

It shall not be a defense for a permittee in an enforcement action to contend that it would 

have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of the permit. 

This permit may contain provisions which require that specific test methods, monitoring, or 

recordkeeping be used as a demonstration of compliance with permit limits. On February 

24, 1997, the U.S. EPA promulgated revisions to the following federal regulations: 40 CFR 

Part 51.212; 40 CFR Part 52, Sec.52.12; 40 CFR Part 52, Sec 52.30; 40 CFR Part 60, Sec 

60.1 1 and 40 CFR Part 6 1, Sec 6 1.12, that allow the use of credible evidence to establish 

compliance with applicable requirements. At the issuance of this permit, the State of 

Kansas has incorporated these provisions in its air quality regulations K.A.R. 28- 19-2 12 (c) 

and (d), K.A.R. 28-19-350, K.A.R. 28-19-720 and K.A.R. 28-19-735. [K.A.R. 28-19- 

5 12(a)( 14)l 

7. Compliance Certification 

The permittee shall annually submit to the Air Enforcement and Compliance Section of the 

KDHE, and a copy to the Air Permitting and Compliance Branch of the U.S. EPA, Region 

7, a certification of compliance (Form CR-02, Annual Certification). The due date of the 

certification is July 15 of each year, for the annual period beginning June 15 of the 

previous year and ending June 14 of the current year.. 

The certification shall include the permit term or condition that is the basis of the 

certification; the current compliance status; whether compliance was continuous or 

intermittent; the method or methods used for determining the compliance, currently and 

over the reporting period; and such other facts as KDHE may require to determine the 

compliance status of the source. The certification shall state that, based on information and 

belief formed after reasonable inquiry, the statements and information in the certification 

are true, accurate and complete. [K.A.R. 28-1 9-5 12(a)(26) and K.A.R. 28-1 9-5 12(a)(27)] 

Page 34 of 38 
8. Emergency 

a. An emergency means any situation arising from sudden and reasonably unforeseeable 

events beyond the control of the source, including acts of God, which situation 

requires immediate corrective action to restore normal operation, and that causes the 

source to exceed a technology-based emission limitation under this permit, due to 

unavoidable increases in emissions attributable to the emergency. An emergency shall 

not include noncompliance to the extent caused by improperly designed equipment, 

lack of preventative maintenance, improper operation or operator error. 

b. An emergency shall constitute an affirmative defense to an action brought for 

noncompliance with such technology-based emission limitation if the conditions of 

paragraph (c) below are met. 

c. The affirmative defense of emergency shall be demonstrated through properly signed, 

contemporaneous operating logs or relevant evidence that: 

i. an emergency occurred and that the permittee can identify the cause or causes of 

the emergency; 

ii. the permitted facility was at the time being properly operated; 

iii. during the period of the emergency the permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emission standards or other 

requirements in the permit; and 

iv. the permittee submitted notice of the emergency, containing a description of the 

emergency, any steps taken to mitigate emissions, and corrective actions taken, to 

KDHE within two working days of the time when emission limitations were 

exceeded due to the emergency. 

d. In any enforcement proceeding, the permittee seeking to establish the occurrence of an 

emergency shall have the burden of proof. 

e. These emergency provisions are in addition to any emergency or upset provisions 

contained in any applicable requirement. Whenever these emergency provisions 

conflict with the provisions of K.A.R. 28-19-1 1, these emergency provisions shall 

control. 

[K.A.R. 28- 19-5 12(d)] 

9. Inspection and Entry 

Upon presentation of credentials and other documents as may be required by law, 

representatives of KDHE, including authorized contractors of KDHE, shall be allowed by 

the permittee to: 

Page 35 of 38 
a. enter upon the premises where a regulated facility or activity is located or conducted 

and where records are kept under conditions of this document; 

b. have access to and copies of, at reasonable times, any records that must be kept under 

conditions of this document; 

c. inspect at reasonable times, any facilities, equipment (including monitoring and 

control equipment), practices or operations regulated or required under this document; 

and 

d. as authorized by the Kansas Air Quality Act, sample or monitor at reasonable times 

substances or parameters for the purpose of assuring compliance with the permit or 

applicable requirements. 

[K.A.R. 28-1 9-5 12(a)(22) 

10. Permit Amendment, Modification, Reopening and Changes Not Requiring a Permit Action 

a. The permit may be modified, revoked, reopened, reissued or terminated for cause. 

The filing of a request by the permittee for a permit modification, revocation, reissuance or termination, or of a notification of planned changes or anticipated 

noncompliance does not stay any permit condition. 

b. The permitting authority will reopen and revise or revoke this permit as necessary to 

remedy deficiencies in the following circumstances: 

i. Additional requirements under the Clean Air Act become applicable to the source 

three or more years prior to the expiration date of this permit. Such a reopening 

shall be completed no later than 18 months after promulgation of the applicable 

requirement. No such reopening is required if the effective date of the requirement 

is later than the expiration date of this permit. 

ii. KDHE determines that this permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or 

conditions of this permit. 

iii. KDHE determines that it is necessary to revise or revoke this permit in order to 

assure compliance with applicable requirements. 

c. This document is subject to periodic review and amending as deemed necessary to 

fulfill the intent and purpose of the Kansas Air Quality statutes and the Kansas Air 

Quality Regulations. 

d. No permit revision shall be required under any approved economic incentives, 

pollution prevention incentives, marketable permits, emissions trading and other 

similar programs or processes for changes that are provided for in the permit. 

[K.A.R. 28- 19-5 131 

Page 36,of 38 
1 1. Duty to Provide Information 

Unless a different time frame is specified in this permit, the permittee shall furnish to the 

KDHE any information that the KDHE may request in writing within 60 days of the 

request, unless the KDHE specifies another time period. Submittal of confidential business 

information must be in accordance with KDHE procedures. 

[K.A.R. 28-19-5 18(c) and K.A.R. 28-1 9-5 12(a)(14)(E)] 

12. Duty to Supplement 

The permittee, upon becoming aware that any relevant facts were omitted or incorrect 

information was submitted in any submittal, shall promptly submit such supplementary 

facts or corrected information. 

[K.A.R. 28-1 9-5 18(e)] 

13. Other Permits and Approvals; Applicability 

a. A construction permit or approval must be obtained from KDHE prior to commencing 

any construction or modification of equipment or processes which results in potential 

emission increases equal to or greater than the thresholds specified at K.A.R. 28-19- 

300. 

b. This document does not relieve the permittee of the obligation to obtain other 

approvals, permits, licenses or documents of sanction which may be required by other 

federal, state or local government agencies. 

[42 U.S.C. 7661e(a) and K.A.R. 28-19-5 12(a)(29)] 

14. Submissions 

All reports, notifications, information and other correspondence (including submission of 

the Annual Certification Form CR-02) shall be submitted to: 

Air Enforcement and Compliance Section 

Bureau of Air and Radiation 

Kansas Department of Health and Environment 

1000 S W Jackson, Suite 3 10 

Topeka, KS 66612-1 366 

(785) 296-1 570 

A copy of each Annual Certification Form CR-02 shall be submitted to: 

Kansas Compliance Officer 

Air Permitting and Compliance Branch 

U.S. EPA, Region VII 

901 N. 5th Street 

Kansas City, KS 66 10 1 

Page 37 of 38 
The Annual Certification shall be certified by a responsible official. This certification shall 

state that, based on the information and belief formed after reasonable inquiry, the 

statements and information in the certification are true, accurate and complete. This 

certification shall be submitted with original signatures. 

[K.A.R. 28-19-5 12(a)(21) and K.A.R. 28-19-5 12(a)(27)] 

When specified in the permit, contact the local office at: 

North Central District Office 

250 1 Market Place 

Suite D 

Salina, Kansas 67401 

(785) 827-9639 

Permit Engineer 

Air Permitting Section 

LMS :saw 

c: NCDO 

0-8223 

Page 38 of 38 
Attachment A 

Site Diagrams 

See Site Diagrams in Initial Class I Operating Permit issued June 15,2004 
Attachment B 

LIST OF ACRONYMS and SYMBOLS 

ACRONYM or SYMBOL 

< 

> 

Acfm 

AP-42 

BACT 

BAR 

Btu 

CAA 

CAAA 

CAS 

CDE 

CEM 

CFC 

Cfm 

CFR 

CMS 

co 

COM 

CTG 

Dscf 

Dscm 

EG 

EPA 

EU 

FGR 

G 

GOP 

GP~ 

GP~ 

Gr 

HAP 

HC 

HP 

KDHE 

HON 

I A 

JCED 

K.A.R. 

K.S.A. 

DESCRIPTION 

Less than 

greater than 

actual cubic feet per minute 

U.S. EPA publication of emission factors 

Best Available Control Technology 

Bureau of Air and Radiation 

British thermal unit 

Federal Clean Air Act 

Clean Air Act Amendments of 1990 

Chemical Abstract Service 

Control Device Efficiency 

Continuous Emission Monitor 

Chlorofluorocarbon 

cubic feet per minute 

Code of Federal Regulations 

Continuous Monitoring System 

Carbon Monoxide 

Continuous Opacity Monitor 

Control Techniques Guideline 

Dry standard cubic feet 

Dry standard cubic meters 

Emission Guideline 

Environmental Protection Agency 

Emission Unit 

Flue Gas Recirculation 

gram 

General Operating Permit 

gallons per hour 

gallons per minute 

grains 

Hazardous Air Pollutant 

Hydrocarbon 

horsepower 

Kansas Department of Health and Environment 

Hazardous Organic NESHAP 

Insignificant Activity 

Johnson County Environmental Department 

Kansas Administrative Regulation 

Kansas Statutes Annotated 
ACRONYM or SYMBOL 

kW 

LAER 

MACT 

MBtu 

Mg 

MMBtu 

MON 

MSDS 

MWC 

MWI 

NAAQS 

NCDO 

NED0 

NESHAP 

NMOC 

NOX 

NSPS 

NSR 

NWDO 

OAQPS 

P2 

PAL 

PM 

PMlO 

PCD 

Ppmv 

ppmw 

PSD 

Psia 

Psig 

PTE 

QAIQC plan 

RACT 

RMP 

SCDO 

SCHA 

SEDO 

SIC 

SIP 

Sox 

DESCRIPTION 

Kilo watt 

Lowest Achievable Emission Rate 

Maximum Achievable Control Technology 

Thousand Btu 

Megagrams 

Million Btu 

Miscellaneous Organic hTESHAP 

Material Safety Data Sheet 

Municipal Waste Combustor 

Medical Waste Incinerator 

National Ambient Air Quality Standards 

North Central District Office 

Northeast District Office 

National Emission Standards for Hazardous Air Pollutants 

Non-Methane Organic Compound 

Nitrogen Oxides 

New Source Performance Standard 

New Source Review 

Northwest District Office 

Office of Air Quality Planning and Standards 

Pollution Prevention 

Plant wide Applicability Limitation 

Particulate Matter 

PM with an aerodynamic diameter of less than or equal to 10 

microns 

PM with an aerodynamic diameter of less than or equal to 2.5 

microns 

Pollution Control Device 

parts per million, volumetric basis 

parts per million, weight basis 

Prevention of Significant Deterioration 

pounds per square inch, absolute 

pounds per square inch, gage 

Potential to Emit 

Quality Assurance/Quality Control plan 

Reasonable Available Control Technology 

Risk Management Plan 

South Central District Office 

Shawnee County Health Agency 

Southeast District Office 

Standard Industrial Classification 

State Implementation Plan 

Oxides of Sulfur 
ACRONYM or SYMBOL 

SOCMI 

STP 

SWDO 

TOC 

TP~ 

TPY 

TRS 

TSP 

VOC 

VOL 

WCHD 

WSCDCH 

DESCRIPTION 

Synthetic Organic Chemical Manufacturing Industry 

Standard Temperature and Pressure 

Southwest District Office 

Total Organic Carbon 

tons per hour 

tons per year 

Total Reduced Sulfur 

Total Suspended Particulate 

Volatile Organic Compound 

Volatile Organic Liquid 

Wyandotte County Health Department 

Wichita-Sedgwick County Department of Community Health 
Attachment C 

Compliance Assurance Monitoring (CAM) Plan 
JM McPherson Plant CAM Analysis and Plan 

Attachment C - CAM Analysis and Plan 

CAM Analysis 

This portion of the operating permit application is included to meet the requirements of 

the compliance assurance monitoring (CAM) regulation (40 CFR Part 64) as it applies to 

pollutant-specific emission units at the Johns Manville McPherson Fiberglass 

Manufacturing Plant. To be subject to CAM, an emission unit must meet the following 

three criteria: (1) an emission limitation or standard for the applicable regulated air 

pollutant (or a surrogate thereof); (2) it uses an emission control device to comply with 

the limitation or standard; and (3) its potential pre-control device emissions of the 

pollutant are "major" as defined by 40 CFR Part 70. 

JM operates the emissions units provided in Table C-1 which also summarizes the CAM 

Analysis. The table includes the potential hours of operation and pound per hour (Iblhr) 

throughputs for most sources. The throughput values represent baghouse cubic feet 

per minute (cfm) for sources that used flow and grain loading for emissions estimates 

and includes: the Slitting Operations (EU-122010 and EU-123013), Waste Edge Trim 

(EU-122011 and EU-123014) and K& S Windup (EU-122013a&b and EU-123016a&b) 

sources. The throughput operations values are in units of million standard cubic feet 

(MMscf) of natural gas for the following natural gas combustion sources: Space Heaters 

(IA-SPCHTERa-h), Hot Rolls (EU-122012 and EU123-015) and Heat Shrink (EU-122015). 

Sources that are not controlled are included on Table C-1 and are not subject to CAM. 

These uncontrolled sources include all fossil fuel combustion sources and the following 

sources: collection and forming, cooling, hot rolls, heat shrink wrapping, and glue and 

paint application. 

Material handling sources use the AP42, Chapter 11.12 Table 11.12-2 controlled and 

uncontrolled unloading emission factors. All other sources use updated controlled 

emission factors developed from recent stack testing at the McPherson facility on 

October 24, 2006 and December 4, 2007. Control emission rates are calculated by 

dividing the controlled emission factor by 1 minus the control efficiency ratio. The 

control efficiency of the cyclones, HEAF and material loading boot were set at 20 

percent, while baghouse efficiencies are set at 99 percent. 

The Line 122 and Line 123 '~elterstack testing -results do not represent unabated 

emissions. Therefore the CAM analysis for the Lines 122 and 123 Melters (EU-122004, 

EU-122005 and EU-123004, EU-123005 and EU-123006) uses the updated controlled 

emission factors from the two recent stack tests, and a material balance of particulate 

matter (PM) captured by the baghouses and the amount of glass produced. Table C-2 

provides these calculations. The first two Rows provide the amount of batch material 

input to the system and the calculated amount of glass produced, allowing for fusion 
JM McPherson Plant CAM Analysis and Plan 

loss of 6 percent, from this year (2008) from January through September. The control 

units dust capture emission factor is calculated by dividing the amount of dust captured 

in the baghouse by the amount of glass produced and is shown in Row 4. The abated 

emission factors (lb of PM per lb glass) based on the stack test results in lblhr divided by 

amount of glass produced for each line are presented in Rows 5 and 6. The total dust 

capture emission factor per manufacturing line is calculated by adding Row 4 to the 

either Rows 5 or 6 and are presented in Row 8 for the manufacturing Line 122 and Row 

13 for the Manufacturing Line 123. Each line's unabated emission rates are next 

calculated by multiplying the total capture emission rates by the potential annual 

amount of glass produced annually (Rows 9 and 14) and are presented in Rows 10 and 

15a. Line 122 unabated PM is 213.2 tpy per melter (Row 10) and Line 123 unabated PM 

is 636.6 tpy for all three melters (Row 15a), because they exhaust from a single stack, or 

about 212.2 tpy (Row 15b) per Line 123 melter. 

The results represent total particulate or total suspended particulates, but the ambient 

air quality standards are for particles with diameter sizes of 10 micrometers (pm) or less 

(PMlo) and particles of less than 2.5 pm (PM2.5). A representative particle size 

distribution applicable to this application can be found in AP-42, Chapter 17 for Lime 

Manufacturing (EPA February 1998). The other components used in the batch have 

particle sizes that are greater than 10 pm, so the lime distributions provide conservative 

results. Table 11.17-7 provides mass percent for particles of 2.5 micrometer or less as 1.4 

percent of the total PM. The mass percent for particles of 10 pm is 12 percent of total 

PM. Applying these particle distribution percentage results in unabated PMlo and PM2.5 

annual potential emission rates of 25.6 (Row 11) and 2.98 tpy (Row 12), respectively. 

The Line 123 unabated PMio and PM2.5 annual potential emission rates for all melters is 

76.4 (Row 16a) and 8.91 (Row 17a). Dividing these annual unabated emission rates by 3 

melters results in unabated PMlo and PM2.5 annual potential emission rates for each 

melter is 25.47 (Row 16b) and 2.97 (Row 1%) tpy. These unabated emission rates from 

all five melters are greater then 100 tpy for TSP per K.A.R 28-19-20, and therefore, CAM 

does apply to the Melters. All five Melters unabated PM emissions are greater than 100 

tpy, and a CAM plan for PM for those sources follows. 
JM McPherson Plant CAM Analysis and Plan 

-. . - ~ " ~ ...,. ~ ?~.. ~. ~.~ ~- ~-~ A.....2..-.-. - .. 

JM McPherson Plant CAM Plan 

The CAM regulation specifies the information that an owner/operator must submit with 

a Part 70 application for subject pollutant-specific emission units. The basic elements 

required of a source subject to CAM are listed below. 

Proposed indicators of performance relevant to compliance; 

Indicator ranges or conditions, or the process by which such indicators will be 

established; 

Performance criteria that satisfy 40 CFR 64.3(b); 

Indicator ranges and performance criteria for any predictive emission monitoring. 

At a minimum, the rule requires a source to select for monitoring at least one indicator 

of performance per control device and to make at least one observation per 24 hours of 

the relevant parameter. A source is required to submit information that justifies its 

proposed monitoring for compliance. 

This portion of the operating permit application identifies the subject emission units and 

the federally-enforceable emission limits applicable to each unit. This Plan presents the 

CAM that JM will perform for the baghouse units on the five Melters as required by 40 

CFR 64. This Plan also presents justification for the proposed elements of its monitoring, 

as required by section 64.4(b). 

CAM-Subject Emission Units and Control Devices: 

Emission 

Unit 

Description Emission Control Device 1 (PM) 

EU-122004 

EU-122005 

EU-123004 

EU-123005 

EU-123006 

Line 122 Melter 

Line 122 Melter 

Line 123 Melter 

Line 123 Melter 

Line 123 Melter 

Wheelabrator Model 120 3015 

RAP Fabric Filter Baghouse 

Wheelabrator Model 120 3015 

RAP Fabric Filter Baghouse 

Aero Pulse 2C-432 Cloth 

Baghouse 

Aero Pulse 2C-432 Cloth 

Baghouse 

Aero Pulse 2C-432 Cloth 

Ba~house 
JM McPherson l'lant CAM Analysis and Plan 

....,..,+x,-.. ~" .~. -" . .. -. .-A,..-.A. 

Applicable Emission Limitations: 

Current Monitoring Requirements: 

I 

1 

1 

A qualitative opacity assessment is required monthly. Performance stack testing for PM 

is required whenever modifications to the lines are made. 

CAM Approach 

Emission Unit 

EU-122004 

EU-122005 

EU-123004 

EU-123005 

EU-123006 

* Excursions trigger investigation, corrective action, logging, and reporting in 

semiannual report. 

Description 

Line 122 Melter 

Line 122 Melter 

Line 123 Melter 

Line 123 Melter 

Line 123 Melter 

Control 

The Melter 

Baghouses 

Rationale for Using Pressure Drop as a Performance Indicator 

PM Emission Limit (tpy) 

1.47 

1.47 

1.44 

1.44 

1.44 

The baghouse is operated under negative pressure. If the pressure is less than 2 inches 

or greater than 9 inches then the baghouse is not operating correctly, and an 

investigation and corrective action are required. 

Parameter 

Water Pressure 

Drop 

CAM Implementation 

Each baghouse is equipped with a pressure drop indicator. JM personnel will read the 

indicator once per day and manually record the pressure drop and report any data that 

is outside of the range. 

Frequency 

Daily 

Establishing the Pressure Drop Indicator Range 

JM is currently monitoring baghouse pressure drop on a routine basis. This range has 

been established from this monitoring program. 

Range 

2.0 to 9.0 inches 

Excursions and 

Exceedences 

Response Steps" 
Table C-I 

Facility-Wide CAM Analysis 

MCPHERSON, KS 

Facility ID 11 30036 

JOHNS MANVILLE 

CONTROLLED AND UNCONTROLLED EMISSION SUMMARY 

Notes: 

1. Throughputs in cfm for baghouse flow on Slitting Ops, Waste Edge Trim and K&S Windup 

and MMscf for natural gas combustion sources (Space Heaters, Hot Rolls and Heat Shrink. 

Control Efficiencies: Baghouses are 99%. HEAF Efficiencies is 20%, Cyclone is 20%, Boot is 20% 
aql Jaqto spnpo~d q3ns ss puss pus xs~oq aJaqM sap!~ed ads ~le ~alsa~6 ueql 'OCW~ 

'C ZP~Q ~aldeq3 LC ap!usd az!S uo!lnq!qs!a s! pasn asnmaq aql qqsg s! Al!~sluyd 'auolsaw!l pus s!ql pnpo~d sap!Ao~d e aJou a~!le~asum uo!lnqyp!p usql 

WON 

6'68 % pap!AoJd) JOJ IsUO!lEUJJOJUl sasodnd (A~uo au!l EZC s~alla~ II~J~AO 10~1~03 % (S'Z~d) 

8'86 % pap!AOJd) JOJ IsUO!lEUJJOJUl sasodnd (A~UO au!l EZC s~atla~ II~J~AO 10~1~03 % (OLwd) 

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MOU 'ON 
Kansas Department of Health and Environment 

Bureau of Air and Radiation 

CLASS I OPERATING PERMIT 

ANNUAL CERTIFICATION CR-02 

Source ID No.: 1 130036 Source Name: Johns Manville International, Inc. 

The period of time for which compliance is certified began at 12:Ol a.m. on Y 

and ended at 1 1 :59 p.m. on Y 

Certifications of compliance are required to be submitted at least annually. The period of time 

covered by each certification document can not exceed one year and there can be no period of time 

during the term of the permit for which compliance is not certified. 

The terms or conditions of the permit that is the basis for this certification are those specified in the 

Class I Operating Permit issued by the Secretary of Health and Environment on Y 

Compliance status of each term or condition of the permit during the certification period: 

1. In continuous compliance with all applicable requirements during the entire certification 

period. 

2. - Not in continuous compliance with all applicable requirements during the entire 

certification period. 

If not in continuous compliance with all applicable requirements during the entire 

certification period, mark the applicable description below. 

One or more instances of non-compliance with any applicable requirement during the 

certification period. 

Continuous non-compliance with any applicable requirement during the certification 

period. 

Provide a summary of the nature, duration, and frequency of the noncompliance that 

occurred, including the applicable requirement(s) and enission unit(s). 

Compliance status of each term or condition of the permit at the time the certification is signed: 

1. - In compliance with all applicable requirements at the time of certification. 

2. Not in compliance with all applicable requirements at the time of certification. 

Provide a description of the nature, duration, and frequency of the noncompliance that 

occurred, including the applicable requirement(s) and emission unit(s). 

DUPLICATE THIS FORM AS NECESSARY 

69 

Form CR-02 Page 69 of 2 
Kansas Department of Health and Environment 

Bureau of Air and Radiation 

CLASS I OPERATING PERMIT 

ANNUAL CERTIFICATION CR-02 

Methods used to determine compliance during the certification period and at the time of signing the 

certification: 

1. In accordance with compliance demonstration methods specified in the Class I Operating Permit. 

2. Other - In accordance with attachments. 

I certify under penalty of lawthat this document and all attachments were prepared under my direction or 

supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate 

the information submitted. Based on information and belief formed f er reasonable inquiry, including the person 

or persons who manage the system, or those persons directly responsible for gathering the information, the stated 

information in this document is true, accurate, and complete. 

Name of Responsible Official (prnt or type): 

Title: 

Signature: Date: I I 

"Responsible official" means one of the following (From K.A.R. 28 19-200 General provisions; definitions): 

(1) For a corporation, a president, secretary, treasurer or vicepresident in charge of a principal business function, or any 

other person who performs similar policy or decisionmaking functions for the corporation, or a duly authorized 

representative of such person if the representative is responsible for the overall operation of one or more 

manufacturing, production or operating facilities applying for or subject to permit or other relevant regulatory 

requirement and either: 

(A) the facilities employ moE than 250 persons or have gross annual sales or expenditures exceeding $25 million, in 

second quarter, 1980 dollars; or 

(B) the delegation of authority to such representative is approved in advance by the department; 

(2) for a partnership or sole proprietorship, a general partner or the proprietor, respectively; 

(3) for a municipality, or a state, federal or other public agency, a principal executive officer or ranking elected official. 

For purposes of this definition, a principal executive officer of a kderal agency shall include the chief executive 

officer having responsibility for the overall operations of a principal geographic unit of the agency; or 

(4) for affected sources, the designated representative under title IV, acid deposition control, of tk federal clean air act, 

42 USC 740 1 et seq. 

Send certification with original signatures to: Send a copy of certification to: 

Air Compliance & Enforcement Section Kansas Compliance Officer 

Bureau of Air and Radiation Air Permitting and Compliance Branch 

Kansas Department of Health and Environment U.S. EPA, Region 7 

1000 S W Jackson, Suite 3 10 901 N. 5th Street. 

Topeka, KS 66612-1 366 Kansas City, KS 66 10 1 

DUPLICATE THIS FORM AS NECESSARY 

69 

Form CR-02 Page 70 of 2 
EXTERNAL CULLET INCREASE CONTRUCTION PERMIT 
DEPARTMENT OF HEALTH 

AND ENVIRONMENT 

Kathleen Sebelius, Governor 

Roderick I. Brernb~, Secretary 

www. kd heks.gov 

Division of Environrneni 

March 12,2009 1 RECEIVED HAii 16 2009 

- ..- - +- 

Source ID No. 1 13003 6 

Mr. Bill Eccles, Environmental Coordinator 

Johns Manville International, Inc. 

P.O. Box 1287 

McPherson, Kansas 67460-1287 

RE: Increased use of External Glass Cullet on Lines 122 and 123 

Dear Mr. Eccles: 

Enclosed is the Air Emission Source Construction Approval for the increased use of a 

recycled material, External Glass Cullet, on lines 122 and 123 at Johns Manville International, Inc.'s 

McPherson plant. 

Please review the enclosed approval carefully since it obligates your company to certain 

requirements. 

In October 2007 KDHE began addressing green house gas (GHG) emissions in Kansas to 

protect the health and environment of Kansans. To accomplish this task, KDHE will engage 

industries and stakeholders to establish goals for reducing GHG emissions and strategies to 

achieve them. Therefore, in accordance with K.S.A. 65-3005(j), KDHE is seeking your 

cooperation to voluntarily implement strategies, including the development and use of innovative 

technologies, market-based principles and other private initiatives to reduce or prevent GHG 

emissions. 

The Performance Test Protocol required by the enclosed approval should be directed to Mr. 

Russ Brichacek in our Topeka office. Also, contact Mr. Jeremy Duis at (785) 296-1 542 to arrange 

the pre-performance test meeting at least thirty (30) days in advance of the date that testing is to be 

conducted. Mr. Brichacek may be reached at (785) 296-1544. 

Please notify the Air Program Field Staff at the North Central District Office at (785)827- 

9639, when increased usage of External Glass Cullet commences so that an initial evaluation can be 

conducted. 

DIVISION OF ENVIRONMENT 

Bureau of Air & Radiation 

Air Permitting Section 

CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE. 3 10, TOPEKA, KS 666 12-1 366 

, Voice 785-296-1570 Fax 785-291-3953 
Page 2 

Mr. Bill Eccles 

March 12,2009 

If you have any questions, please contact me at (785) 296-1719. 

Sincerely, n 

LMS:saw 

Enclosure 

c: IVCDO 

C-8329 

Air Permitting Section 
Kathleen Sebelius, Governor 

Roderick I. Bremby, Secretary 

DEPARTMENT OF HEALTH 

AND ENVIRONMENT www.kdheks.gov 

Division of Environment 

AIR EMISSION SOURCE 

CONSTRUCTION APPROVAL 

Source ID No.: 1 130036 

Effective Date: March 12,2009 

Source Name: Johns Manville International, Inc. 

SIC Code: 3296; Mineral Wool 

NAICS Code: 327993; Mineral Wool Manufacturing 

Source Location: 1 465 1 7th venue 

McPherson, Kansas 67460-1287 

Mailing Address: P.O. Box 1287 

McPherson, Kansas 67460- 1287 

This approval is issued pursuant to K.S.A. 65-3008 as amended. 

Description of Activitv Subiect to Air Pollution Control Regulations 

Johns Manville International, Inc is proposing to increase the amount of recycled glass material used, 

External Glass Cullet, in its glass manufacturing process on Lines 122 and 123. Based on 

information submitted, the increased use of the External Glass Cullet will not result in an increase in 

throughput and no modification or reconstruction to existing units will be performed. 

This change in operations has been reviewed for air quality requirements. Representative actual 

emissions to future projected emissions were performed for the proposed activity. Potential 

emissions of sulfw: oxides (SO2) were evaluated as part of the review process. The proposed activity 

is subject to the provisions of K.A.R. 28-19-300 (Construction permits and approvals; 

applicability) because the unit's potential-to-emit of SO2 in pounds per hour exceeds the threshold 

for approvals. The purpose of this approval is to limit the Sulfw: Dioxide emissions to below major 

source thresholds. 

DIVISION OF ENVIRONMENT 

Bureau of Air PL Radiation 

Air Permitting Section 

CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE. 310, TOPEKA, KS 66612-1366 

Voice 785-296-1570 Fax 785-291-3953 
Significant Applicable Air Pollution Control Regulations 

This activity is subject to Kansas Administrative Regulations relating to air pollution control. The 

following air quality regulations were determined to be applicable to this source: 

1. K.A.R. 28-1 9-300(a) Construction permits and approvals, applicability. 

2. K.A.R. 28-19-650(a)(3), limits the opacity of visible emissions to less than 20 %. 

Air Emission Unit Technical Specifications 

The following change or equivalent is approved: 

1. Increased use of External Glass Cullet (recycled glass) on Lines 122 and 123. 

Air Emissions Estimates from the Proposed Activity 

Air Emission Limitations 

Pollutant type 

Sulfur Dioxide 

(S02) 

1. K.A.R. 28-19-650(a)(3), limits the opacity of visible emissions to less than 20 %. 

Permit Conditions 

Actual Emissions 

(tons per year) 

0.42 

1. Emissions from the glass melters on lines 122 and 123 shall continue to be vented to 

emission control equipment. 

2. All emission control equipment shall be operated and maintained according to the 

manufacturers' recommendations. 

Projected Projected 

Potential-To- Potential-ToEmit Emit 

(pounds per (tons per year) 

hour) 

7.64 33.47 

3. On and after the effective date of this permit; increased external glass cullet usage shall 

be limited such that the combined emissions of sulfur dioxides (SO2) from Lines 122 and 

Line 123 shall not exceed 40 tons during any consecutive twelve (1 2) month period, 

calculated monthly by the following inequality: 

Projected 

Increase 

Potential-ToEmit 

(tons per year) 

33.04 

[3.15 x x (A) + 2.142 x 1o4x (B)] 12000 < 40 tons of ~02: 

Page 2 of 5 
Where: 

A = amount of External Glass Cullet (in lbs) processed on Line 122 

B = amount of External Glass Cullet (in lbs) processed on Line 123 ' 

4. The sulfur dioxide emission rates from each melter on Line 122 and Line 123 shall be 

verified by a performance test approved by the Department. 

Performance Testing; and Compliance 

1. Performance testing shall be accomplished for both manufacturing lines within 180 

days of the commencement of the project permitted by this approval. 

a. Sulfur dioxide emission rates for the melting operations shall be determined using 

EPA Method 6C. 

2. Testing shall be performed while melting External Glass Cullet at the highest expected 

percentage rate intended to be melted at the facility on each line. If the initial testing-is 

performed at a lower External Glass Cullet percentage rate than indicated in the approval 

application, a second performance test will be conducted when External Glass Cullet 

percentage is increased to the highest expected percentage rate intended to be melted at the 

facility on each line. 

3. During the performance tests, the amounts (in lbs/hr) and percentages of External Glass 

Cullet melted shall be recorded. 

4. During the performance tests, the production rate of each line shall be recorded. 

5. Notify KDHE of the schedule for the performance tests at least 30 days before the 

performance tests. 

Record Keeping Requirements 

1. Records of monthly External Glass Cullet usage rates (in lbs) for each line shall be 

maintained and updated monthly no later than the last day of the month following the 

month to which the record relates. 

2. Records of the 12 month consecutive total of Sulfur Dioxide emissions shall be 

maintained and updated monthly, no later than the last day of the month following the 

month to which the record relates. 

Page 3 of 5 
Notification 

1. Notify Stan Marshall of the North Central District Office at (785) 827-9639 when 

operations commence so an evaluation may be conducted to verify compliance with 

applicable regulations. 

General Provisions 

1. This document shall become void if the construction or modification has not commenced 

within 18 months of the effective date, or if the construction or modification is interrupted 

for a period of 18 months or longer. 

2. A construction permit or approval must be issued by KDHE prior to commencing any 

construction or modification of equipment or processes which results in an increase of 

potential-to-emit equal to or greater than the thresholds specified by K.A.R. 28-19-300. 

3. Upon presentation of credentials and other documents as may be required by law, 

representatives of KDHE (including authorized contractors of KDHE) shall be allowed to: 

a. enter upon the premises where a regulated facility or activity is located or conducted 

or where records must be kept under conditions of this document; 

b. have access to and copy, at reasonable times, any records that must be kept under 

conditions of this document; 

c. inspect at reasonable times, any facilities, equipment (including monitoring and 

control equipment) practices or operations regulated or required under this document; 

and 

d. sample or monitor, at reasonable times, for the purposes of assuring compliance with 

this document or as otherwise authorized by the Secretary of KDHE, any substances 

or parameters at any location. 

4. The emission unit or stationary source which is the subject of this document shall be operated 

in compliance with all applicable requirements of the Kansas Air Quality Act and the federal 

Clean Air Act. 

5. This document is subject to periodic review and amendment as deemed necessary to fulfill 

the intent and purpose of the Kansas Air Quality Statutes and Regulations and rules 

promulgated in accordance therewith. 

6. This document does not relieve the facility of the obligation to obtain other approvals, 

permits, licenses or documents of sanction which may be required by other federal, state 

or local government agencies. 

Page 4 of 5 
Permit Engineer 

Air Permitting Section 

LMS :saw 

c: NCDO 

C-8329 

Page 5 of 5