ATTACHMENT A – KDHE JULY 21, 2009 TITLE V PERMIT AND MARCH 12, 2009 EXTERNAL CULLET INCREASE CONTRUCTION PERMIT FOR JM MCPHERSON PLANTMCPHERSON TITLE V PERMITDEPARTMENT 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 submittedto the Kansas Department of Health and Environment (KDHEJoyJuly 15, for each calendar year the permit is in effect Please use copies ofthe enclosed form for the required certifications, retaining the original blank form for subsequent certifications. This form wibtbe 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 afteraffirmation,modificationor reversal of a permit decision pursuantto subsection(b) of K.S.A. 65-3008a. In theRequest for Hearing,the owner or operator shall specify the provision of this act or rule and regulation allegedly violated,the facts constitutingthe alleged violation and secretary's intended action. Such request must be submittedto: Director, Office ofAdministrativeHearings, 1020 S. Kansas Avenue, Topeka, Kansas 66612-1327. Failure to submit a timely request shall result in a waiver ofthe right to hearing. In October 2007 KDHEbegan addressing greenhouse gas (GHG) emissionsin Kansastoprotectthe health and environment of Kansans. To accomplish this task, KDHE will engage industriesand stakeholders to establish goals for reducingGHG emissionsand strategiesto achieve them. Therefore,in accordancewith K.S.A. 65-3005Cj), KDHE is seeking your cooperationto voluntarily implement strategies, including the development and use of innovativetechnologies,market-based principles and otherprivate initiativestoreduce or prevent GHG emissions.

DIVISION OF ENVIRONMENT Bureau of Air & Radiation

Air Permitting Section CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE 310, TOPEKA, KS 666 12-1 366 Voice 785-296- 1570 Fax 785-291-3953Page 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)2961719. Sincerely,

Air Permitting Section LMS:saw Enclosures c: NCDO 0-8223Mark Parkinson, Governor Roderick L. Breemby, Sectetary DEPARTMENT OF HEALTH AND ENVIRONMENT www. 

### kdheks.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 67460-1287

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 785-291-3953Authority This permit, developed in accordancewith 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 applicableto each source as of the effective date of this permit. At the time ofpermit issuance, this facility required a Class 

### I OperatingPermit 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 (18) 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. 28-19-20

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) 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 StacWVentID



### 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


### 123Blender

123 Melter Day Bins (3) (a-c) 123 Spare Storage Bins (1) (4
123Module #I Melter

123Module #2 Melter StacWVentID



### 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. 28-19-20

K.A.R. 28-19- 650(a)(3) 40 CFR Part 64 Construction Permit (713 1/02) Construction Permit (3112/09) K.A.R. 28-19-20

K.A.R. 28-19- 650(4(3) 40 CFR Part 64 Construction Permit (713 1/02) Construction Permit (3112/09)Page 7 of 38 

### Emission SourceID
EU-123006

EU- 123 007

EU-123008

EU-123009 

### Emission Source Description
123Module #3 Melter

123 Module #1 Fiber Forming/Collecti on

123Module #2 Fiber Forming/Collecti on

123 Module #3 Fiber FormingICollecti on 

### StacWVentID

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

NIA 

### 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 (3112/09) 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. 28-19- 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,

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. 28-19-20

K.A.R. 28-19- 650(a)(3) 40 CFR Part 60, Subpart A 40 CFR Part 60,

Subpart PPP Construction Permit (713 1102 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

CyclonePage 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) StacWentID

SV-123014

SV-OMMI 1

SV-123015
SV-123016a(UL)

SV-123016b(LL)

EU-123018

EU-123019 Control Equipment ID

CE-1230 14

CE-OMMIlb

N/A

CE-123016a

CE-123016b

123 CPW Pkg .(vents inside)

123ARB 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- 19-501 (d) 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)

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. 28-19-

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- 122001

EU- 122002

EU-122003a

EU-122003b

EU-122003~ Emission Source Description
122Blender Receiver Hopper

122Blender

122M-1 Melter Day Bin

122 M-2 Melter Day Bin

122 Spare Day Bin StacWentID

SV-122001

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. 28-19-20

K.A.R. 28-19- 650(a)(3) K.A.R.28-19-501(d) Construction Permit (713 1/02) K.A.R. 28- 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. 28-19-20

K.A.R. 28-19- 650(a)(3) K.A.R.28-19-50 1 (d) Construction Permit (713 1102) K.A.R. 28-19-20

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.28-19-501 (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

122Module #1 North Forming & 

### Collection

122 Module #l South Forming & 

### Collection StacWentID

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 (3112/09) 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 (3112/09) K.A.R. 28-19-20

K.A.R. 28-19- 650(4(3) 40 CFR Part 60, SubpartA 40 CFR Part 60,

SubpartPPP Construction Permit (713 1/02) K.A.R. 28-19-20

K.A.R. 28-19- 65O(a)(3 40 CFR Part 60, SubpartA 40 CFR Part 60,

SubpartPPP 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


### 122Module #2 North Forming & 

### Collection

122 Module #2 South Forming & 

### Collection

Construction Permit StacWentID



### 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

122Hot Roll Laminator (vents inside)
1 22 K&SVacuum 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. 28-19-20

K.A.R. 28- 19- 65o(a)(3
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- 19-20

K.A.R. 28-19- 650(a)(3) K.A.R.28-19-501(d)

K.A.R. 28- 19-20 

# 1

K.A.R. 28-19- 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-BWOO 1 a

EU-BWOOlb

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 StacWentID

SV-122013b



### ----- SV- 1220 14
N/A

SV-BW001a

SV-B WOO 1 b

SV-OMMI1 a

SV-OMMI 1 b Control Equipment ID

CE-1220 13b

N/A
N/A

CE-BWOO 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. 28-19- 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) ConstructionPermit (713 1/02) K.A.R. 28-19- 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. 28-19.650, 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 subjectto the requirementlisted below: 

### IA-SPCHTRa-h1SV-SPCHTRa-h eight (8) 12.8mmBTU/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 1.7mmBTU/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. 28-19-3l(a)]:

Where: A =the allowable emission rate in lb1106BTU I =the total heat input in 1 

## o6BTU/hr [K.A.R. 28-19-3 1 (a)]
The allowable emission rate in lb/106BTU for indirect heating equipment with total heat input less than ten (10) million BTUhis 0.6 lbll

## o6BTU. 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- 122011 a1SV-OMMI 1/CE-OMMI1 a EU-B WOOla-b/SV-BWOO 1 a-b1CE-BWOO1a-b EU-123014lSV-123014lCE-123014 

### EU-122011lSV-1220111CE-12201 1 EU-ONIMI 1 a-b/SV-OMMI1 a-b/CE-OMMI1 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 operatingthe 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 ofthe 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- 1Collection 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 sourceperformance standards, which adopts by reference40 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 determinedby 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 insulationmanufacturing 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 occurrenceand duration of any start-up, shutdown, or malfunction in the operation of Lines 122and 123and the associated control equipment are to be maintained [40 CFR 60.7(b); Construction Permit dated 713 1120021.

Page 18 of 38Records of the glass pull rates (in lbhour) shall be maintained for the life ofthe permit. In the eventthe owner or operator ofthe rotary spin wool fiberglass insulation manufacturing lines elects to utilize either a wet scrubber or electrostatic precipitator control device in operatingthe 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-BOO1 

### 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- 122012lSV-122012 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- 122010 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 SpareDay 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- 122015/SV-1220 15 EU- 123014dSV-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 =

### 4.1

### PO.^^) 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 

### I30 tonslhr

for: Process weight > 

### 30 tonsh
Monitoring: Compliance Assurance Monitoring Monitoring shall be performed in compliance with 40 CFR Part 64, ComplianceAssurance 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 CAMPlan, 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<40tons 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 (ConstructionApproval 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. (ConstructionApproval dated March 12,2009) External Glass Cullet usage rates (in lbs) for each line shall be calculated monthly no later than the last day ofthe month followingthe 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 followingthe month to which the record relates. Records ofthe 12month 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 followingemission 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- 1North Collection EU-122007dSV- 122007a M-2 North Collection Page 22 of 38EU- 122007blSV-122007b EU- 122009lSV-122009 EU- 1220111SV-122011 EU-123003a-d1SV-l23003a-d EU- 1230011SV-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- 1220011SV-122001 EU-122006bISV-122006b EU-122008lSV-122008 EU-123006lSV-123006 EU-123008lSV-123008 EU-l23011lSV-123011 EU-BWOOlaISV-BWOOla EU-BWOO1blSV-BWOO 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- 1Melter 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 122and 123, including raw material handling, fiberglass production, and finished product handling shall be less than the following mass emission rates: [Construction Permit effective713 1/02]

a. Carbon monoxide 225.0 lbsh b. Nitrogen oxides 20.5 lbsh c. Particulate matter 116.9lbsh d. Particulate matter (< 10microns) 116.9lbslhr e. Volatile organic compounds 74.1 lbsh
Page 23 of 38Monitoring 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, demonstrationof 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 .lomicrons emissionrates for the melting, forming, curing and cooling operations shall be determined using EPA Method 5 for the determinationof 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 changeto 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 includethe following information: 1. The pre cise nature ofthe change; 2. Present and proposed emission control systems; 3. The production capacity ofthe unit before and after the change; and 4. The expected completion date ofthe change.

Page 24 of 38Notification ofperformance testing shall be given to the JSDHE no less than 30 daysprior to testing. 

### A written report of the results ofperformance 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) shallbe 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 ofthe 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 ofthis permit. The glass pull rates of Lines 122 and 123may 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- 122001 ISV- 12200 1 EU- 122002lSV-122002 EU- 1220 1 OISV- 122010 EU- 1 220 1 1 ISV- 12201 1 Melter Day Bins M-1 Melter Blender Receiver Blender Slitting Cyclone Waste Edge Removal
Page 25 of 38EU-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 sectionon lines 122 and 123 shall be vented to emission control equipment. [K.A.R. 28-19- 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 ofpermit 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. 28-19-501(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, Recordkeepingand Reporting Section 

### of this permit for the submittal dates of these reports.

Page 26 of 38StacMVent 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- 19-30through 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(106)BTUhand 10,000(1 06)BTUh,the allowable emission rate may be determined by the equation provided at K.A.R. 28-1 9-3l(a). Records shall be maintained of any recalculations and evaluations. These records shall includethe design rate capacity ofthe 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 ifthe 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 9-210, 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. 28-19-5 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 approvedby the KDHE. At the time ofpermit 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, SubpartA, General Provisions and SubpartM, National Emission Standard for Asbestos, adoptedby 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 substancein 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 ofthe 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 {ClassI) 

### 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, 82.110Form of label bearing warning statement, and 82.1 12Removal 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, 82.161Technician certification, and 82.166 Reporting and recordkeeping requirements Subpart G SignificantNew 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- 31(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 ofthe ten operating day period and shall utilize EPA Method 9.

Page 29 of 38

### The person responsible for making qualitative opacity assessments shallbe 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 ofthe person conductingthe assessment. BAR does not consider a qualitative assessment in which emissions appearto exceed the applicable opacity limits to be a violation or deviation subject to reporting in accordance with the Reporting of Deviations from Permit Termsportion of this permit. A Method 9 evaluation that shows opacity exceeding the emission limit would be subjectto reporting in accordance with the Reporting of Deviation from Permit Terms portion ofthis permit.

\ 

### Requirements Which Will Become Applicable During the Permit Term The owner or operator, in accordance with the provisions of K.A.R. 28-19-5 1 1 (b) (16) (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 Compliancewith the conditions ofthis permit shall be deemed in compliance with the applicable requirements ofthe 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 114of the Clean Air Act; or c. the provisions of Section 303, Emergency orders, ofthe Clean Air Act, including the authority ofthe 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 28-19-58; or d. the applicable requirements ofthe acid rain program, consistent with section 408(a) of the Act. [K.A.R. 28-19-512(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 additionto any testing, monitoring, recordkeeping or reporting requirement contained in the "Applicable Requirements" section ofthis 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 ofthe 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 ofthe permit. All instances of deviations from permit requirements, including perceived opacity exceedances, shall be clearly identified in the report. [K.A.R. 28- 19-512(a)(1l)(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.28-19-5 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 analyticaltechniques or methods used;
e. the results of the analyses; and Page 

### 31 of 38f. 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 ofDeviations from Permit Terms Unless a differenttime 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 emissionsexceeding 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 ofthe 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 emissionsexceedingthose allowed in this permit shall be reported in writing within 10business days following discovery of the deviation. Oral notifications may be made to the air program field staff at the North CentralDistrict 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)(1l)]
General Provisions 1. K.A.R. 28-19- 11, Exceptions Due to Breakdowns or ScheduledMaintenance

a. Abnormal operating conditionsresulting 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 operationof the emission source notifies the department of the occurrence and nature of such malfunctions,breakdown or repairs, in writing, within 10days ofnoted occurrence.
Page 32 of 38

### ii. The number of occurrences of such breakdowns is not deemed excessiveby 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 ofprior 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 ofhazardous 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 18months 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 ofthis 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 ofthis permit, shall not be affected thereby. [K.A.R. 28-1 9-512(a)(13)] 5. Property Rights This permit does not convey any property rights of any sort or any exclusive privilege. [K.A.R. 28-19-5 12(a)(l4)(D)]

Page 33 of 386. 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- 19-212 (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 ofthe current year.. The certification shall include the permit term or conditionthat is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the method or methods used for determiningthe 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. 28-19-5 12(a)(26)and K.A.R. 28-19-5 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 ifthe 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 exceededthe emission standards or other requirements in the permit; and iv. the permittee submitted notice of the emergency, containing a description ofthe emergency, any steps taken to mitigate emissions, and corrective actions taken, to KDHE within two working days ofthe 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 ofproof.
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- 19-512(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 38a. 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 authorizedby 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 18months 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 shallbe 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 inthe permit. [K.A.R. 28- 19-5131
Page 36,of3811.Duty to Provide Information Unless a different time frame is specified in this permit, the permittee shall furnish to the KDHE any informationthat the KDHE may request in writing within 60 days ofthe 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 9-512(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 9-518(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 obligationto 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 CertificationForm 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 6610

### 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 SuiteD 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 

### IA 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 QAIQCplan RACT RMP SCDO SCHA SEDO SIC SIP Sox DESCRIPTION Kilowatt Lowest Achievable Emission Rate Maximum Achievable Control Technology Thousand Btu Megagrams Million Btu Miscellaneous OrganichTESHAP 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 equalto 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/QualityControl 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 CommunityHealth

## Attachment 

## C ComplianceAssurance Monitoring 

### (CAM) PlanJM 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 summarizesthe 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-122012and 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 '~elters tack 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 fusionJMMcPherson 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 dividingthe 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 122unabated PM is 213.2 tpy per melter (Row 10) and Line 123unabated 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 123melter. The results represent total particulate or total suspended particulates, but the ambient air quality standards are for particles with diameter sizes of 10micrometers (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 11.17-7provides 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 distributionpercentage 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 123unabated 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 sourcesfollows.

### JMMcPherson Plant CAMAnalysis and 

### Plan

-. . - ~ " ~...,. ~ ?~.. ~. ~.~ ~- ~-~ A.....2..-.-. - .. JMMcPherson 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 emissionunits 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 presentsjustification for the proposed elements of its monitoring, as required by section 64.4(b). CAM-SubjectEmission Units and Control Devices: Emission Unit Description Emission Control Device 

# 1 (PM) EU-122004 EU-122005 EU-123004 EU-123005 EU-123006 Line 122Melter Line 122Melter Line 123Melter Line 123Melter Line 123Melter 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~houseJMMcPherson 

### l'lant CAM Analysis and 

### Plan

....,..,+x,-.. ~" .~. -" . ..-. .-A,..-.A. Applicable EmissionLimitations:

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. CAMApproach 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 122Melter Line 123 Melter Line 123 Melter Line 123 Melter

Control The Melter Baghouses

Rationale for Using Pressure Drop as aPerformanceIndicator 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

Establishingthe 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 9.0inches Excursions and Exceedences Response Steps"Table C-I Facility-Wide CAM Analysis MCPHERSON, KS Facility ID 11 30036 JOHNS MANVILLE CONTROLLEDAND 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%'OCW~ ueql~alsa~6 ~le ads sap!~ed aJaqM xs~oq pus puss ss q3ns spnpo~d Jaqto aql usql uo!lnqyp!p a~!le~asum aJou e sap!Ao~d pnpo~d s!ql pus 'auolsaw!lAl!~sluyd s! qqsg aql asnmaq pasn s! uo!lnq!qs!a az!S ap!usd LC ~aldeq3 ZP~Q 'C WON (A~uo sasodnd IsUO!lEUJJOJUlJOJ pap!AoJd) % 6'68 (S'Z~d) % 10~1~03 II~J~AO s~alla~ EZC au!l (A~UO sasodnd IsUO!lEUJJOJUl JOJ pap!AOJd) % 8'86 (OLwd)% 10~1~03 II~J~AO s~atla~ EZC au!l (A~uo sasodnd l'2UO!lEUJJOJUl JOJ pap!AoJd) % 6'66 (~d) % lo~luo3 II~J~AO s~alla~ EZLau!l (/((uo sasodnd leUO!lEUJJOJUlJOJ pap!AoJd) % L'LG (S'Z~d) % lo~luo3 II~J~AO s~alla~ zzc au!l (A~UO sasodnd IsUO!JEUJJOJUl JOJ pap!AoJd) % C'G6 (OLwd) % 10~lu03 II~J~AO s~alla~ zzcawl (A~uo saiodnd IsUO!lEUJJOJUlJOJ pap!Ao~d) % P'66 (~d) % loJluo3 IIeJaAOSJatlaWZZC au!l J~II~W~zn43ea~dl LKZ = (ua~~aw ~1~6'8) suo!ss!w paleqeun S'zwd (L-L 1.1c alqel-zvdv uo pas^ %P' 140 uo!~ ~SI OJ 'Wd Gu!~~nsse) SJ~JI~W EZ~ ~ea-~dl 16'8 = (PLO-o + LS-6~9) suo!ss!ur3 paleqeun Szwd J~JI~W EZ~ 43ea dl LP'PZ = (SJ~JI~W EIP'SL) suo!ss!w pa~eqeun OLwd (L-LL'LL alqel-zpdv uo paseq%ZL 40 uo!lw ~SI 01 OLwdGu!wnsse) wlawIIV EZ~ dl OV~L = (~1.0 + 1s-6~9) suo!ss!w pawqeun OLwd JallaW EZCl L(3eaJo4Ad1 CZ'ZCZ = (s~allaw E I

Kdl ~9'9~9) suo!ss!u3 ~allaw lenuuv paleqeun cz~i s~alla~ EZC~ II~

~04 hdl€9'9~9 = (a~nlde3 lelol. ssel6 ~Klql) suo!ss!uq sJallayy lenuuv paleqeun ~~11 ~A/sql 000'089'~~ c JAM pa3npo~d sss19 ~enuuv ~aww EZC~ 166PL0800'0 = aJnlde3 Iwl EZ1 au!l (1-LL'CC -ZPdV uo Paseq %P'C40 uo!leJ dSloJ'"~d 6u!wnsse) JqlaW ZZC143eSAdl86'Z = (~10'0 + LL'ELZ) suo!ss!~ paleqeun ="(ryd - (L-~1.1~ a~qel -zvdv uo paseq %ZC 40 uo!~ ds~ 01 OLwdGu!wnsse) J~WW zzn49ea-lrdl 8s'~~ = (~1.0 * LL'ELZ) suo!ss!w paleqeun OLwd - Jallaw ZZC~ va-hdlLC'ECZ = (a~nlde3 lelol. ssel6 ~Klq1) suo!ss!u3JalIaw lenuuv paleqeun 1-w ~~11 Z-WIC-w JAIS~I 000'09G'ZS ~Al~allaw ad pa3npodd sse19 unw!xew z-wIc-~.~ ZZC~ ssel6-ql~snp-ql' C~PL c ~800'0 = arn~de3 IWJ.ZZL au!i (ale8 uo!ss!uq +JopejSIOJ)UO~ Kq pa~nldeg pna) a~nlde3 lelol sse16-qllwd-q1 Gc COOOO'O LOIPIZ c uo lsal WQS (slo~tum ~a~e) FZc au!i atetl uo!ss!wi SS~I~-~IIW~-~I ~POOOO'O ~OIPZIO~ uo lsaly3sls (SIOJIU~~a~e) zzcau!i aletl uo!ss!w S~~I~-~I/IS~P-~I 16PE90800'0 (ssel9hsna) ~opej slo~luo3 Aq pa~nlds3 tsna 41 G69'88C'C 8016 - 801~ slo~luo3 paJnlde3tsna @soluo!sn4 %9 6u!wnsse)ql 8'616'91~'~~~ 8016 - 8011 PanPoJdsssl9 uoSJaqd3W 41 GE6' 19Z19G 1 8016 - 8011 paw 43le9 uoflaqd3~ EZ zz cz oz 61 8C ~LC ELL q91 e91 qp 1 89 1 PL El ~1 11 01 6 8 L 9 p p E Z 1 'ON MOUKansas Department of Health and Environment Bureau ofAir and Radiation CLASS I OPERATING PERMIT ANNUAL CERTIFICATION CR-02
Source ID No.: 1130036 SourceName: Johns Manville International, Inc.
The period of time for which compliance is certifiedbegan 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 oftime covered by each certification document can not exceed one year and there can be no period of time duringthe term of the permit for which complianceis not certified. The terms or conditions of the permit that is the basis for this certification are those specifiedin 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 certificationperiod: 1. In continuous compliance with all applicable requirements during the entire certification period. 2. - Not in continuous compliancewith all applicablerequirements during the entire certificationperiod. 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-compliancewith any applicablerequirement during the certification period. Continuousnon-compliance with any applicable requirement duringthe 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 conditionof the permitat the time the certification is signed: 1. - In compliance with all applicablerequirements 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 69of2Kansas Department ofHealth and Environment Bureau ofAir 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. 2819-200 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 representativeis responsible for the overall operation of one or more manufacturing, production or operating facilities applying for or subject to permit or other relevantregulatory 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 representativeis approved in advance by the department; (2) for a partnership or sole proprietorship, a generalpartner 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 representativeunder title IV, acid deposition control, oftkfederal clean air act, 42 USC 740 1et seq. Send certification with original signaturesto: Send a copy of certification to: Air Compliance & Enforcement Section Kansas ComplianceOfficer Bureau ofAir and Radiation Air Permitting and ComplianceBranch Kansas Department of Health and Environment U.S. EPA, Region 

### 7 1000 S 

### W Jackson, Suite 310 901 

### N. 5th Street. Topeka, KS 66612-1 366 Kansas City, KS 66 101

DUPLICATE THIS FORM AS NECESSARY 69 Form CR-02 Page 70 of2EXTERNAL CULLET INCREASE CONTRUCTION PERMIT

### DEPARTMENT OF HEALTH AND ENVIRONMENT Kathleen Sebelius, Governor Roderick I. Brernb~, Secretary

www.

### kdheks.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 123atJohns ManvilleInternational,Inc.'s McPherson plant. Please review the enclosed approval carefully sinceit obligatesyour companyto 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 directedto Mr. Russ Brichacekin our Topeka office. Also, contact Mr. Jeremy Duis at (785) 296-1542to arrange the pre-performancetest meeting at least thirty (30) days in advance ofthe date that testing is to be conducted. Mr. Brichacek may be reached at (785) 296-1544. Please notify the Air Program Field Staffat the North Central District Office at (785)827- 9639, when increased usage of External Glass Cullet commences sothat an initial evaluation canbe conducted.
DIVISION OF ENVIRONMENT Bureau ofAir & Radiation

Air Permitting Section CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE. 3 10,TOPEKA, KS 666 12-1366

, Voice 785-296-1570 Fax 785-291-3953Page 2 Mr. Bill Eccles March 12,2009


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

## n

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### IVCDO C-8329 Air Permitting SectionKathleen 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 approvalis issued pursuant to K.S.A. 65-3008 as amended. Description ofActivitv Subiect to Air Pollution Control Regulations JohnsManvilleInternational,Inc is proposing to increasethe amountof recycled glassmaterial used, External Glass Cullet, in its glass manufacturing process on Lines 122 and 123. Based on information submitted, the increased use ofthe External Glass Culletwill 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 aspart ofthereview 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 SO2inpounds per hour exceedsthe threshold for approvals. The purpose ofthis approval isto limitthe Sulfw:Dioxide emissionsto below major source thresholds. DIVISION OF ENVIRONMENT Bureau ofAir PL Radiation

Air Permitting Section CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE. 310, TOPEKA, KS 66612-1366 Voice 785-296-1570 Fax 785-291-3953Significant Applicable Air Pollution Control Regulations This activity is subjectto Kansas Administrative Regulations relating to air pollution control. The following air quality regulations were determined to be applicableto this source: 1. K.A.R. 28-19-300(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 (poundsper (tons per year) hour) 7.64 33.47

3. On and after the effective date ofthis permit; increased external glass cullet usage shall be limited such that the combined emissionsof sulfur dioxides (SO2) from Lines 122and Line 123 shall not exceed 40 tons during any consecutive twelve (12) month period, calculated monthly by the following inequality: Projected IncreasePotential-ToEmit (tonsper year) 33.04

[3.15 x x (A) 

### +2.142 x 1o4x (B)] 12000 

### <40 tons of ~02: Page 2 of 5Where: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 ofthe 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. Ifthe 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 percentageis increased to the highest expectedpercentage rate intendedtobemelted atthe facility on each line. 3. During the performance tests, the amounts (in lbs/hr) and percentages ofExternal 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 ofthe month following the month to which the record relates.
Page 3 of 

### 5Notification 1. Notify Stan Marshall of the North Central District Office at (785) 827-9639when operations commence so an evaluationmay 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 specifiedby 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 uponthe premises where a regulated facilityor activityis 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 underthis document; and d. sample or monitor, atreasonable times, forthe purposes of assuringcompliance with this document or as otherwise authorizedby the Secretary of KDHE, any substances or parameters at any location. 

### 4. The emission unit or stationarysourcewhich is the subjectof this document shallbe operated in compliance with all applicable requirements of the Kansas Air QualityAct andthe 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 ofthe 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 

### 5Permit Engineer

Air Permitting Section
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### NCDO C-8329

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