AIREMISSION PERMITNO.13900013-007 Shakopee, Scott County, MN 55379 · 2013-06-05 · Emission units...

AIR EMISSION PERMIT NO. 13900013-007Major Amendment

IS ISSUEDTO

CertainTeed Corp

CERTAINTEED CORP3303 East 4th Avenue

Shakopee, Scott County, MN 55379

The emission units, control equipment and emission stacks at the stationary source authorized in thispermit amendment are as described in the Permit Applications Table.

This permit amendment supersedes Air Emission Permit NO.13900013-006 authorizes the Permittee tooperate and construct the stationary source at the address listed above unless otherwise noted in Table A.The Permittee must comply with all the conditions of the permit. Any changes or modifications to thestationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used inthe permit are as defined in the state air pollution control rules unless the term is explicitly defined in thepermit.

Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporatedinto the State Implementation Plan (SIP) under 40 CFR9 52.1220 and as such are enforceable by U.S.Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Part 70/Limits to Avoid NSR; Limits to Avoid NSROp'erating Permit Issue Date: September 28, 2000Stage 1 Issue Date - Authorization to Construct and Operate: May 6, 2013Stage 2 Issue Date - Major Amendment: May 29, 2013Operating Permit Expiration: September 28,2005* -- All Title I Conditions do not expire.* The Permittee may continue to operate this facility after the expiration date of the permit, per the provisionunder Minn. R. 7007.0450, subp. 3. (Title V Reissuance Application was received March 29, 2005.)

Stage 2 Issuance:Stage 1 Issuance:

D~Air Quality Permits SectionIndustrial Division

for John Linc StineCommissionerMinnesota Pollution Control Agency

for

xc= S~Don Smith, P.E., ManagerAir Quality Permits SectionIndustrial DivisionJohn Linc StineCommissionerMinnesota Pollution Control Agency

TDD (for hearing and speech impaired only): (651) 282-5332Printed on recycled paper cantaining at least 10%fibers from paper recycled by consumers

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit March 11, 1996 001

Major Amendment November 29, 2001 002

Major Amendment July 30, 2003 003

Major Amendment August 19, 2005 004

Major Amendment January 16, 2007 005

Major Amendment March 25,2011

supplemented May 10, 2011 006

Major Amendment November 30, 2012

April 2, 2013 007

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Appendix A: Insignificant Activities and General Applicable Requirements Appendix B: Estimates of Air Emissions from Asphalt Storage Tanks and Truck Loading

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651‐296‐6300 Outside Metro Area 1‐800‐657‐3864 TTY 651‐282‐5332 The rules governing these programs are contained in Minn. R. chs. 7000‐7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155‐4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION: The Shakopee Plant manufactures asphalt‐roofing materials. The facility has accepted limits such that it’s potential to emit remains below major source thresholds. The equipment authorized by this permit action, once constructed will make the facility a major source of Hazardous Air Pollutants (HAPs). AMENDMENT DESCRIPTION:

This amendment is a major amendment. The application requests several changes to the asphalt blowing operation that was originally permitted in 2006. The asphalt blowing equipment has not yet been constructed, but the Permittee has gained knowledge from an operational asphalt blowing line at another CertainTeed facility in Oxford, North Carolina. Based on the process knowledge from Oxford, the Permittee proposes the following changes:

‐ Installation of a new 1,000,000 gallon asphalt flux storage tank.

‐ Increase in the capacity of a pre‐heat tank and installation of a pre‐mix tank that is interchangeable with the pre‐heat tank.

‐ Increase in the capacity of the blow stills, but annual throughput limit remains unchanged.

‐ Installation of four railcar spurs (total of 28 railcars) for asphalt flux unloading. Addition of Emission units representing emission from asphalt flux unloading from railcars, asphalt flux unloading from trucks, and asphalt flux loading into trucks.

‐ Increase in capacity of thermal oxidizer.

‐ Installation of an asphalt heater, a finished coating storage tank, three additional tanks that qualify as insignificant activities under Minn. R. 7007.1300, and three heaters that qualify as insignificant activities under Minn. R. 7007.1300.

In addition to the changes to the asphalt blowing line, the Permittee has requested changes to emission factors and calculations methodologies for a number of permitted

The Permittee also requested the following changes:

‐ Removal of boilers EU 035, 036, and 110 and associated permit conditions

‐ Addition of language clarifying that the requirements of 40 CFR pt. 63, subp. AAAAAAA are only valid for three years after the facility becomes a major source of HAPs, at which point the facility must comply with the requirements of 40 CFR pt. 63, subp. LLLLL for existing affected sources.

‐ Changes to emission limits for cooling section stacks

DESCRIPTION OF AMENDMENTS SINCE THE LAST PART 70 REISSUANCE

PERMIT ACTION 002:

This amendment authorized numerous changes and additions to the facility to increase production of fiberglass laminated shingles. Changes included the addition of a third asphalt shingle manufacturing line and shutdown of the Line 1 saturator. This amendment also updated the emission data for some emission units by using new emission factors and incorporated a number of emission units into the total facility permit that were omitted by the Permittee in the Title V permit application.

PERMIT ACTION 003:

PER 002 authorized replacement of the Born Asphalt Heater No. 3 (EU 010) 14.3 mmBtu/hr burner with a 4.5 mmBtu/hr burner. The Permittee has requested retention of the 14.3 mmBtu/hr burner in EU 010, and installation of the 4.5 mmBtu/hr burner in a new Asphalt Heater No. 4 (EU 087). The overall change is an increase in the total facility indirect heating equipment heat input by 14.3 mmBtu/hr. Permitted operating hours for roofing lines #1, #2, and #3 were not changed by this permit action

Also, fuel oil language in the permit was revised, the Line 1 Saturator was retained, the York‐Shipley hot oil heater was removed, EU012 and EU043 testing requirements were revised, clarifying language was added to the 8200 hr/yr limit stating the limit applied to each unit individually.

PERMIT ACTION 004:

This major amendment installed three blowing stills (EU 091, EU 092, and EU 093), and an asphalt flux preheat tank (TK 018). An existing one million gallon No. 6 fuel oil storage tank (TK 009) was converted to an asphalt flux storage tank. The permit action reorganized control of emission units and tanks. Operational changes were made to reduce Particulate Matter Smaller than 10 microns (PM10) and Sulfur Dioxide (SO2) ambient air impacts by eliminating No. 6 fuel oil combustion and restricting the main steam boiler operation to 30 percent of maximum capacity and numerous other operational changes to the facility.

PERMIT ACTION 005:

This amendment included a variety of changes to the permit including amending permit limits, updating calculation methodologies to estimate HAP, Volatile Organic Compound (VOC), Carbon Monoxide (CO) and SO2 emissions from the cooling section lines, nomenclature updates for emission units and stack vents, added stack vents to cooling lines 2 and 3, replacement of exhaust fans, corrected emissions calculations and prohibited the facility from operating the paper mill sources.

PERMIT ACTION 006:

This major amendment will replace two boilers (EU035/036) which incurred induced draft fan failures in late 2009 due to them being operated below their designed load. The new boilers (EU099/100) will be limited to a maximum of 20.4 mmBtu/hr each and burn natural gas or No. 2 fuel oil. A limit of 40.8 mmBtu/hr for both boilers will keep the facility‐wide CO2 emissions below 100,000 tons/year and the facility will remain a minor source for CO2e under PSD.

This amendment will also revise operating requirements for the Regenerative thermo Oxidizer (CE004) to be shut down when manufacturing lines 1 through 3 are not in operation. The Permittee has several tanks that route their emissions to CE004, but none of these tanks are subject to the requirements of Minn. R. 7011.1505, subp. 3(C) and do not need to be equipped with a vapor recovery system or equivalent.

The Permittee is revising potential emission calculations with this permit action. These revisions will remove inaccuracies and improve calculation methodologies of certain units. Other updates will allow the facility to reflect current operations such as removal of all paper mill sources, removal of No. 6 fuel oil use and refinement of emission limits for cooling section units.

TABLE A: LIMITS AND OTHER REQUIREMENTSCertainTeed Corp

13900013 - 007

Facility Name:

Permit Number:

05/28/13A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itA. NESHAP REQUIREMENTS hdr

The Permittee shall comply with all applicable requirements of 40 CFR Part 63Subpart DDDDD by the compliance date listed below.

For an area source that increases its emissions or its potential to emit such that itbecomes a major source of HAP, the Permittee shall,(1) for any new or reconstructed boiler or process heater at the existing source bein compliance with 40 CFR pt. 63, subp. DDDDD upon startup.(2) for any existing boiler or process heater at the existing source must be incompliance with 40 CFR pt. 63, subp. DDDDD within 3 years after the startup of theGP 015 asphalt blowing operation (as defined in GP 015 of this permit).

The Permittee shall apply for the appropriate permit amendment as applicable toincorporate the requirements of 40 CFR pt. 63, subp. DDDDD by the compliancedate of the standard.

40 CFR pt. 63, subp. DDDDD; 40 CFR Section63.7495(c)

B. SOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendix: This permit contains 2 appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices.

Minn. R. 7007.0800, subp. 2

C. OPERATIONAL REQUIREMENTS hdr

Ambient Air Quality Standards: The Permittee shall comply with and upon writtenrequest demonstrate compliance with National Primary and Secondary Ambient AirQuality Standards in Title 40 CFR part 50, and the Minnesota Ambient Air QualityStandards at Minn. R. 7009.0010 to 7009.0080.

40 CFR part 50; Minn. Stat. Sec. 116.07, subds. 4aand 9; Minn. R. 7007.0100, subps. 7A, 7L and 7M;Minn. R. 7007.0800, subps. 1, 2, and 4; Minn. R.7009.0010-7009.0080

Operating Hours: less than or equal to 8,200 hours/year for each of the threePost-Modification Roofing Lines (#1, #2, and #3) and associated emission units, ona 12-month rolling sum basis. This limit does not apply to combustion units orasphalt storage tanks. As of permit issuance, this limit applies to EUs 011-012,020-026, 043, 044, 046-051, 052-055, 057, 071, 072, 075-081, and 094-098.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000

Hours of Operation: If the Permittee modifies, replaces, or adds new units to any ofthe three Post-Modification Roofing Lines (Lines #1, #2, or #3) that are notcombustion units or storage tanks, such equipment is subject to the hours ofoperation limit as well as all of the associated hours of operation recordkeepingrequirements listed in the Total Facility subject item of this permit. Prior to makingsuch a change, the Permittee shall apply for and obtain the appropriate permitamendment, as applicable. The Permittee may use the hours of operation limit inthe calculations described in Minn. R. 7007.1200, subp. 2. A permit amendmentwill still be needed regardless of the emissions increase if the change will besubject to a new applicable requirement or requires revisions to the limits ormonitoring and recordkeeping in this permit.


No. 2 Fuel Oil Usage: less than or equal to 845,000 gallons/year on a 12-monthrolling sum, with a sulfur content not to exceed 0.05 percent by weight.


If the Permittee modifies, replaces, or adds new No. 2 fuel oil combustion units,such equipment is subject to the applicable No. 2 fuel oil usage limit as well as allof the associated No. 2 fuel oil requirements in the Total Facility subject item of thispermit. Prior to making such a change, the Permittee shall apply for and obtain theappropriate permit amendment, as applicable. However, when calculating theemissions increase, only the hourly emissions increase (calculated per Minn. R.7007.1200, subp. 3) shall be determined.

A permit amendment will still be needed regardless of the emissions increase if thechange will be subject to a new applicable requirement or requires revisions to thelimits or monitoring and recordkeeping in this permit.


No. 6 Fuel Oil Usage: The Permittee is prohibited from using No. 6 fuel oil in anycombustion unit at the facility.

Minn. R. 7007.0800, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-2

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne.

Minn. Stat. Section 116.07, subd. 4a; Minn. R.7007.0100; Minn. R. 7007.0800, subp. 2; Minn. R.7011.0150; Minn. R. 7009.0020

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

Inspections: Upon presentation of credentials and other documents as may berequired by law, allow the Agency, or its representative, to enter the Permittee'spremises to have access to and copy any records required by this permit, to inspectat reasonable times (which include any time the source is operating) any facilities,equipment, practices or operations, and to sample or monitor any substances orparameters at any location.

Minn. R. 7007.0800, subp. 9(A)

D. NOTIFICATION REQUIREMENTS

See Table B For Additional Notification and Submittal Requirements

hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3, or as outlined in CE 004 requirements.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-3

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

E. TESTING REQUIREMENTS hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-Test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy or CD: due 105 days after eachPerformance Test.

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Note: For EU 091, EU 092, EU 093, and TK 018, the performance test report due45 days after each performance test meets the requirement for submittal ofperformance test results 60 days after each test required by 40 CFR Section63.10(d)(2).

Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2018,and Minn. R. 7017.2035, subps. 1-2

F. MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

G. RECORDKEEPING REQUIREMENTS hdr

Recordkeeping - Hours of operation of Lines #1, #2, and #3: Keep daily records ofthe number of hours per day of operation of each of the three Post-ModificationRoofing Lines (#1, #2, and #3) and the associated emission units.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 &5

Recordkeeping - Hours of operation of Lines #1, #2, and #3By the 15th day of each month:1) calculate and record the number of hours of operation for each line during theprevious month;2) calculate and record the number of hours of operation for each line during theprevious 12-month period by summing the monthly hours of operation data for theprevious 12 months (12-month rolling sum).

Minn. R. 7007.0800, subp. 4 and 5

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-4

Recordkeeping - Fuel Usage. The Permittee shall maintain records of the totalamount of No. 2 fuel oil combusted onsite, including in insignificant activities, on amonthly basis.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 &5

Recordkeeping - Fuel UsageBy the 15th day of each month:1) calculate and record the number of gallons of No. 2 fuel oil used during theprevious month using the monthly fuel records;2) calculate and record the number of gallons of No. 2 fuel oil used during theprevious 12-month period by summing the monthly No. 2 fuel oil usage data for theprevious 12 months (12-month rolling sum).

Minn. R. 7007.0800, subp. 4 and 5

Recordkeeping - Fuel Oil Supplier Certification: The Permittee shall obtain acertification from the fuel supplier for each fuel oil delivery specifying the sulfurcontent of the oil, in percent by weight. Certification records shall be maintained fora minimum of five years from the date of receipt.

Title I Condition: To avoid major source status under40 CFR Section 52.21 and Minn. R. 7007.3000; Minn.R. 7007.0800, subp. 4 & 5

When the Permittee determines that no permit amendment or notification isrequired prior to making a change, the Permittee must retain records of allcalculations required under Minn. R. 7007.1200. For expiring permits, theserecords shall be kept for a period of five years from the date the change was madeor until permit reissuance, whichever is longer. For nonexpiring permits, theserecords shall be kept for a period of five years from the date that the change wasmade. The records shall be kept at the stationary source for the current calendaryear of operation and may be kept at the stationary source or office of thestationary source for all other years. The records may be maintained in eitherelectronic or paper format.

Minn. R. 7007.1200, subp. 4

H. REPORTING REQUIREMENTS hdr

Application for Permit Amendment: If a permit amendment is needed, submit anapplication accordance with the requirements of Minn. R. 7007.1150 through Minn.R. 7007.1500. Submittal dates vary, depending on the type of amendment needed.

Minn. R. 7007.1150 - 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment toextend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).Performance testing deadlines from the General Provisions of 40 CFR pt. 60 andpt. 63 are examples of deadlines for which the MPCA does not have authority togrant extensions and therefore do not meet the requirements of Minn. R.7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Reporting - Changes of No. 2 Fuel Oil Combustion Units: For all No. 2 fuel oilcombustion unit equipment changes made at the facility, the Permittee shall submitan annual report of such changes by January 31st of each year. The report shalldescribe changes made at the facility during the previous calendar year regardlessif the change required a permit amendment. For all changes that didn't require apermit amendment, the changes shall be described by the Permittee using currentapplicable MPCA application forms for the new or replaced emission units,stack/vents, groups, and control equipment. The report shall be submitted with theannual Compliance Certification listed in Table B of this permit, and include thetwelve monthly-calculated 12-month rolling sum No. 2 fuel oil usage values for theprevious calendar year.

Minn. R. 7007.0800, subp. 4, 5, & 6

Emissions Inventory Report: due on or before April 1 of each calendar yearfollowing permit issuance. To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 - 7019.3010

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-5

Subject Item: GP 001 Existing Indirect Heating Equipment

Associated Items: EU 008 Born Asphalt Heater No. 1

EU 009 Born Asphalt Heater No. 2

EU 010 Born Asphalt Heater No. 3

EU 013 Line 1 Hot Oil Heater

EU 014 Line 2 Hot Oil Heater

What to do Why to do itThe following emission limits apply individually to each emission unit in GP 001. hdr

Fuels Permitted: Natural gas and No. 2 fuel oil only.

Refer to the Total Facility subject item in Table A of this permit for applicable No. 2fuel oil usage, sulfur content, recordkeeping, and fuel oil certification requirements.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input .Potential emissions based on current EPA AP-42 emission factors and equipmentdesign are 0.0075 lb/mmBtu when combusting natural gas and 0.024 lb/mmBtuwhen combusting No. 2 fuel oil.

Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . Potentialemissions based on current EPA AP-42 emission factors and equipment design are0.05 lb/mmBtu when combusting No. 2 fuel oil.

Minn. R. 7011.0510, subp. 1

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

Minn. R. 7011.0510, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-6

Subject Item: GP 002 New Indirect Heating Equipment

Associated Items: EU 015 Mod Asphalt Hot Oil Heater #3

EU 056 Line #3 Hot Oil Heater

EU 087 Asphalt Heater No. 4

EU 111 Asphalt Heater #5





Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input .Potential emissions based on current EPA AP-42 emission factors and equipmentdesign are 0.0075 lb/mmBtu when combusting natural gas and 0.024 lb/mmBtuwhen combusting No. 2 fuel oil.

Minn. R. 7011.0515, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . Potentialemissions based on current EPA AP-42 emission factors and equipment design are0.05 lb/mmBtu when combusting No. 2 fuel oil.

Minn. R. 7011.0515, subp. 1


Minn. R. 7011.0515, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-7

Subject Item: GP 003 Industrial Process Equipment

Associated Items: EU 011 Line #1 Saturator/Coater/Mixers

EU 012 Line #2 Saturator/Coater/Mixers

EU 016 Sealant Pan/Independence Windseal Applicator

EU 020 Sand Truck Rec & storage; back surfacing silo

EU 021 Line #1 Back Surfacer Use Bin & Transfer System

EU 023 Line #1 Surfacing Section

EU 024 Lines #1 & #2 Filler Use Bin

EU 025 Line #2 Surfacing Section

EU 026 Line #2 Back Surfacer Use Bin & Transfer System

EU 028 Line #2 Filler Heater

EU 043 Line #3 Coater

EU 044 Line #3 Laminant Adhesive Applicator

EU 046 Line #3 Windseal Applicator

EU 051 Line #3 Back surfacer Use Bin & Transfer System

EU 052 Line #3 Surfacing section

EU 053 Line #3 Filler Heater System

EU 054 Line #3 Horizontal Mixer

EU 055 Line #3 Vertical Mixer

EU 057 Windseal Mixer

EU 066 Modified Room Line #3 Laminant/Windseal Mixer

EU 068 Independence Laminant Adhesive Applicator

EU 070 Horizon Asphalt Applicator SV 047 - 052, SV 060 - 064



EU 075 EF3A Cooling Section Line #1 SV 047

EU 076 EF3B Cooling Section Line #1 SV 048

EU 077 EF37 Cooling Section Line #2 SV 049


EU 079 CS1 Cooling Section Line #3 SV 051


EU 081 Line #3 Dry Mat Looper

EU 088 Line #3 Nail Line Paint Applicator

EU 089 Line #1 Filler Heater (indoor vented FF)


Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity . Minn. R. 7011.0715, subp. 1(B)

The pollution control equipment requirements for the following GP 003 emissionunits are located in the following subject items in Table A of this permit:

EU 011, EU012, EU 043, EU 044, EU 046, EU 054, EU 055, EU 057, EU 066, 071,072: CE 004 (RTO)EU 016: CE 010 (mist eliminator)EU 020, EU 021, EU 023 - 026, EU 028, EU 030, EU 051 - 053: GP 008 (fabricfilters)

hdr


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-8

At any time that any of the following emissions units are in operation, the Permitteeshall vent that emission unit to a piece of control equipment as designated below.

EUs 020, 021, 023 - 026, 028, 030, and 051 - 053 shall vent to a fabric filtermeeting the requirements of GP 008 (fabric filters).

EUs 071 and 072 shall vent to a thermal oxidizer meeting the requirements of CE004 (thermal oxidizer) upon startup of the GP 015 asphalt blowing operation (asdefined in GP 015 of this permit).

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-9

Subject Item: GP 008 Fabric Filter Requirements

Associated Items: CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F













SV 011 Line #1 Back Surfacer Use Bin & Transfer System

SV 013 Line #1 Surfacing Section

SV 017 Sand Truck Rec & storage

SV 018 Sand Truck Rec & storage

SV 019 Line #2 Surfacing Section

SV 020 Line #2 Back Surfacer Use Bin & Transfer System

SV 022 Line #2 Filler Heater

SV 040 Dust Collector DC-1, Filler Silo #1

SV 041 Dust Collector DC-2, Filler Silo #2

SV 042 Dust Collector DC-3, Line #3 Filler Use Bin

SV 043 Dust Collector DC-8, Line #3 Back Surfacer Use Bin

SV 044 Dust Collector DC-7, Line #3 Surfacing Headlap and Dry Mat Looper, Headlap Silo and Transfer System

SV 045 Dust Collector DC-4, Line #3 Filler Heater

SV 046 Dust Collector DC-11, Lines #1 and #2 Filler Use Bin

What to do Why to do itThe following requirements apply individually to each fabric filter in GP 008. hdr

The Permittee shall operate and maintain each fabric filter at all times that the unitcontrolled by the filter, as indicated below, is in operation:

CE 011/SV 011: EU 021 Line #1 Back Surfacer Use Bin/Transfer SystemCE 013/SV 013: EU 023 Line #1 Surfacing SectionCE 017&018/SV 017&018: EU 020 Sand Truck Receiving & StorageCE 019/SV 019: EU 025 Line #2 Surfacing SectionCE 020/SV 020: EU 026 Line #2 Back Surfacer Use Bin/Transfer SystemCE 022/SV 022: EU 028 Line #2 Filler HeaterCE 038/SV 040: EU 047 Filler Silo #1 w/Transfer SystemCE 039/SV 041: EU 048 Filler Silo #2 w/Transfer SystemCE 040/SV 042: EU 049 Line #3 Filler Use Bin/Transfer SystemCE 041/SV 043: EU 051 Line #3 Back Surfacer Use Bin/Transfer SystemCE 042/SV 044: EU 052 Line #3 Surfacing Section, EU 050 Headlap Silo/TransferSystem, & Line #3 Dry Mat LooperCE 043/SV 045: EU 053 Line #3 Filler Heater SystemCE 044/SV 046: EU 024 Lines #1 & #2 Filler Use Bin


Total Particulate Matter: less than or equal to 0.010 grains/dry standard cubic footfor each fabric filter stack/vent.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-10

PM < 10 micron: less than or equal to 0.010 grains/dry standard cubic foot for eachfabric filter stack/vent.


PM < 2.5 micron: less than or equal to 0.010 grains/dry standard cubic foot for eachfabric filter stack/vent.


The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Total Particulate Matter: greater than orequal to 99 percent control efficiency

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for PM < 10 micron: greater than or equal to99 percent control efficiency


The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for PM < 2.5 micron: greater than or equal to93 percent control efficiency


Visible Emissions Check: Once each day of operation, the Permittee shall observeSV 011(CE 011), SV 013 (CE 013), SV 017 (CE 017), SV 018 (CE 018), SV 019(CE 019), SV 020 (CE 020), SV 022 (CE 022), SV 040 (CE 038), SV 041 (CE 039),SV 042 (CE 040), SV 043 (CE 041), SV 044 (CE 042), SV 045 (CE 043), and SV046 (CE 044) during daylight hours to determine if there are any visible emissions(VEs) from each stack/vent. If any VEs are observed, the Permittee shall follow theO&M plan for CE 011, CE 013, CE 017, CE 018, CE 019, CE 020, CE 022, CE038, CE 039, CE 040, CE 041, CE 042, CE 043, or CE 044 as applicable, in orderto eliminate the VEs as soon as possible.

Each time visible emissions are observed is a deviation that must be reported inthe semiannual deviations report.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2,4, & 14

Recordkeeping: The Permittee shall keep a record of all VE checks, whether or notany VEs were observed, and of any corrective actions taken. Each record shallspecify the corresponding stack/vent number and shall be generated on the sameday as the VE check and/or corrective action.


Given the characteristics of the inlet gas streams, If the Permittee is required toconduct performance test(s) on the units in GP 008, the Permittee shall test forcompliance with the gr/DSCF limits and not the control efficiency limits.

Minn. R. 7007.0800, subp. 2

Operation and Maintenance of control equipment: The Permittee shall operate andmaintain the fabric filters according to the facility O&M plan and the controlequipment manufacturer's specifications.

Minn. R. 7007.0800, subp. 2

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

Minn. R. 7007.0800, subps. 4, 5 and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- visible emissions are observed; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall eliminate visible emissions, and/or include completion ofnecessary repairs identified during the inspection, as applicable. Corrective actionsinclude, but are not limited to, those outlined in the O & M Plan for the fabric filter.The Permittee shall keep a record of the type and date of any corrective actiontaken for each filter.

Minn. R. 7007.0800, subps. 4, 5, and 14


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-11

Subject Item: GP 010 Boilers Requirements

Associated Items: EU 099 Steam Boiler #1

EU 100 Steam Boiler #2

What to do Why to do itA. OPERATIONAL REQUIREMENTS hdr

Fuels Permitted:

Natural gas and No. 2 fuel oil only.

Refer to the Total Facility subject item of Table A of this permit for applicable fuel oilusage, sulfur content, recordkeeping, and fuel oil certification requirements.


The SO2 emission limits, fuel oil sulfur limits, and percent reduction requirementsapply at all times, including periods of startup, shutdown, and malfunction.

40 CFR Section 60.42c(i); Minn. R. 7011.0570

B. EMISSION LIMITS (apply to each unit separately, unless otherwise noted) hdr

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight for No. 2 fuel oilbeing burned at the facility. This is more stringent than the 0.50 weight percentsulfur limit from 40 CFR Section 60.42c(d).

This requirement also appears at in the Total Facility subject item of Table A.


Sulfur Content of Fuel: less than or equal to 0.50 percent by weight for No. 2 fuel oilbeing burned at the facility. Compliance with this limit is met by meeting the morestringent limit of 0.05 percent by weight.

40 CFR Section 60.42c(d); Minn. R. 7011.0570

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input 40 CFR Section 60.42c(d); Minn. R. 7011.0570

C. RECORDKEEPING AND REPORTING REQUIREMENTS hdr

Recordkeeping: The Permittee shall keep daily records of the No. 2 fuel oil used inGP 010 boilers. These records shall be used in the 12-month rolling sumcalculations required in the Total Facility subject item of Table A of this permit.


The Permittee of each affected facility subject to the SO2 emission limits, fuel oilsulfur limits, or percent reduction requirements under 40 CFR Section 60.42c shallsubmit reports to the Administrator.

40 CFR Section 60.48c(d); Minn. R. 7011.0570; Minn.R. 7007.0800, subp. 6

The Permittee of each affected facility subject to the SO2 emission limits, fuel oilsulfur limits, or percent reduction requirements under 40 CFR Section 60.42c shallkeep records and submit reports as required under paragraph (d) of this section,including the following information:-calendar dates covered in the reporting period-records of fuel supplier certification as described in GP 010 of this permit-certified statement signed by the owner or operator of the affected facility that therecords of fuel supplier certifications submitted represent all of the fuel combustedduring the reporting period.

40 CFR Section 60.48c(e); Minn. R. 7011.0570; Minn.R. 7007.0800, subps. 5 & 6

Fuel supplier certification shall include the following information:

1) for distillate oil:i. The name of the oil supplier;ii. A statement from the oil supplier that the oil complies with the specificationsunder the definition of distillate oil in 40 CFR Section 60.41c; andiii. The sulfur content of the oil.

2) for other fuels:i. The name of the supplier of the fuel;ii. The potential sulfur emissions rate of the fuel in ng/J heat input; andiii. The method used to determine the potential sulfur emissions rate of the fuel.

40 CFR Section 60.48c(f); Minn. R. 7011.0570

As an alternative to meeting the requirements of paragraph (g)(1) of this section,the Permittee of an affected facility that combusts only natural gas, wood, fuelsusing fuel certification in 40 CFR Section 60.48c(f) to demonstrate compliance withthe SO2 standard, fuels not subject to an emissions standard (excluding opacity),or a mixture of these fuels may elect to record and maintain records of the amountof each fuel combusted during each calendar month.

40 CFR Section 60.48c(g)(2); Minn. R. 7011.0570;Minn. R. 7007.0800, subp. 5


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-12

As an alternative to meeting the requirements of paragraph (g)(1) of this section,the Permittee of an affected facility or multiple affected facilities located on acontiguous property until where the only fuels combusted in any steam generatingunit (including steam generating units not subject to this subpart) at that propertyare natural gas, wood, distillate oil meeting the most current requirements in 40CFR Section 60.42c to use fuel certification to demonstrate compliance with theSO2 standard, and/or fuels, excluding coal and residual oil, not subject to anemissions standard (excluding opacity) may elect to record and maintain records ofthe total amount of each steam generating unit fuel delivered to that property duringeach calendar month.

40 CFR Section 60.48c(g)(3); Minn. R. 7011.0570;Minn. R. 7007.0800, subp. 5

All records required under this section shall be maintained by the Permittee for aperiod of two (2) years following the date of such record.

40 CFR Section 60.48c(i); Minn. R. 7011.0570; Minn.R. 7007.0800, subp. 5

The reporting period for the reports required under this subpart is each six-monthperiod. All reports shall be submitted to the Administrator and shall be postmarkedby the 30th day following the end of the reporting period.

40 CFR Section 60.48c(j); Minn. R. 7011.0570; Minn.R. 7007.0800, subp. 6

D. PERFORMANCE TESTING hdr

For affected facilities subject to 40 CFR Section 60.42c(h)(1), (2), or (3) where thePermittee seeks to demonstrate compliance with the SO2 standards based on fuelsupplier certification, the performance test shall consist of the certification, thecertification from the fuel supplier, as described under 40 CFR Section 60.48c(f), asapplicable.

40 CFR Section 60.44c(h); Minn. R. 7011.0570

The Permittee with an affected facility seeking to demonstrate compliance under 40CFR Section 60.43c(e)(4) shall follow the applicable procedures under 40 CFRSection 60.48c(f).

40 CFR Section 60.45c(d); Minn. R. 7011.0570


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-13

Subject Item: GP 011 Standards of Performance for Storage Vessels

Associated Items: TK 001 Asphalt CAS # 8052-42-4

TK 002 Asphalt CAS # 8052-42-4






TK 008 No. 2 fuel oil CAS # 68476-30-2

TK 010 Plasticizer CAS # 64742-52-5

TK 011 Line #3 Asphalt Storage Tank

TK 018 Asphalt Flux Preheat Tank

TK 025 Asphalt Flux Storage #1

TK 026 Asphalt Flux Storage #2

TK 027 Asphalt Flux Premix Tank

TK 028 Finished Coating Storage Tank

What to do Why to do itThe Permittee is authorized to install and operate TKs 018, 025, and 027, asdefined by permit, at any time during the life of Air Emissions Permit No.13900013-007. These units shall meet all the requirements of this permit.

Minn. R. 7007.0800, subp. 2

The requirements in GP 011 apply individually to each tank in GP 011. hdr

Process Throughput: less than or equal to 200,000 tons/year to be calculated bythe 15th day of each month for the previous 12-month period as described in GP015 of this permit.

This limit applies to the combined asphalt flux throughput for TK 025, and theasphalt flux throughput for TK 018 and TK 027 individually.

Recordkeeping associated with this limit appears at GP 015.


MINNESOTA STANDARDS FOR LIQUID PETROLEUM AND VOLATILEORGANIC LIQUID STORAGE VESSELS

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This requirement applies to TKs 001-007, 010, and 011.

For storage vessels with a storage capacity of greater than 2,000 gallons but lessthan or equal to 40,000 gallons the Permittee shall equip each storage vessel(tank) with a permanent submerged fill pipe or comply with the followingrequirements:

(1) If the true vapor pressure of the petroleum liquid, as stored, is equal to orgreater than 78 mm Hg (1.5 psia) but not greater than 570 mm Hg (11.1 psia), thestorage vessel shall be equipped with a floating roof, a vapor recovery system, ortheir equivalents.(2) If the true vapor pressure of the petroleum liquid as stored is greater than 570mm Hg (11.1 psia), the storage vessel shall be equipped with a vapor recoverysystem or its equivalent.

Minn. R. 7011.1505, subps. 3(B) and 3(C)

As of permit issuance, this requirement applies only to TK 028

For storage vessels with a storage capacity of greater than 40,000 gallons thePermittee shall comply with the following requirements:

(1) If the true vapor pressure of the petroleum liquid, as stored, is equal to orgreater than 78 mm Hg (1.5 psia) but not greater than 570 mm Hg (11.1 psia), thestorage vessel shall be equipped with a floating roof, a vapor recovery system, ortheir equivalents.(2) If the true vapor pressure of the petroleum liquid as stored is greater than 570mm Hg (11.1 psia), the storage vessel shall be equipped with a vapor recoverysystem or its equivalent.

Minn. R. 7011.1505, subp. 3(C)


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-14

This requirement applies to TKs 008, 018, 025, 027, and 028.

For storage vessels with a storage capacity of greater than 40,000 gallons thePermittee shall maintain the following records:

A. Maintain a file of each type of petroleum liquid stored, of the typical Reid vaporpressure of each type of petroleum liquid stored, the dates of storage andwithdrawals, and of the date on which the storage vessel is empty;

Minn. R. 7011.1510, subp. 1

For storage vessels with a storage capacity of greater than 40,000 gallons thePermittee shall maintain the following records as applicable:

B. Determine and record the average monthly storage temperature and true vaporpressure of the petroleum liquid stored at such temperature if:(1) the petroleum liquid has a true vapor pressure, as stored, greater than 26 mmHg (0.5 psia) but less than 78 mm Hg (1.5 psia) and is stored in a storage vesselother than one equipped with a floating roof, a vapor recovery system or theirequivalents; or(2) the petroleum liquid has a true vapor pressure, as stored, greater than 470 mmHg (9.1 psia) and is stored in a storage vessel other than one equipped with avapor recovery system or its equivalent

Minn. R. 7011.1510, subp. 1

For the calculation required by Minn. R. 7011.1510, subp 1(B), the average monthlystorage temperature is an arithmetic average calculated for each calendar month,or portion thereof if storage is for less than a month, from bulk liquid storagetemperatures determined at least once every seven days.

Minn. R. 7011.1510, subp. 2

For the calculation required by Minn. R. 7011.1510, subp 1(B), the true vaporpressure shall be determined by the procedure in American Petroleum InstituteBulletin 2517. This procedure is dependent upon determination of the storagetemperature and the Reid vapor pressure, which requires sampling of thepetroleum liquids in the storage vessels. Unless the agency or the commissionerrequires in specific cases that the stored petroleum liquid be sampled, the truevapor pressure may be determined by using the average monthly storagetemperature and the typical Reid vapor pressure. For those liquids for whichcertified specifications limiting the Reid vapor pressure exist, that Reid vaporpressure may be used. For other liquids, supporting analytical data must be madeavailable on request of the agency or the commissioner when typical Reid vaporpressure is used.

Minn. R. 7011.1510, subp. 3

For asphalt storage tanks only, as an alternative to the methods for determiningtrue vapor pressure in Minn. R. 7011.1510, the Permittee may use the methodsprovided by "Estimates of Air Emissions from Asphalt Storage Tanks and TruckLoading" (Environmental Progress, Vol. 18 No. 4, 25--259, Trumbore, Davide C.,Winter 1999) which is contained in Appendix B of this permit

The Permittee is still required to maintain the records specified in Minn. R.7011.1510 as applicable; however, for asphalt storage tanks, the Permittee maymaintain records of the vapor pressure determined according to Appendix B of thispermit in place of the Reid vapor pressure.

Minn. R. 7007.0800, subp. 2

CONTROL EQUIPMENT REQUIREMENTS hdr

The Permittee shall vent the emissions from TKs 018, 025, and 027 to a misteliminator meeting the requirements of GP 019.

Minn. R. 7007.0800, subp. 2 and 14

NESHAP LLLLL: ASPHALT PROCESSING AND ASPHALT ROOFINGMANUFACTURING REQUIREMENTS

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For all new or reconstructed tanks, with the exception of TK 028, the Permitteeshall comply with the requirements of 40 CFR part 63, subpart LLLLL upon startup.As of permit issuance this applies to tanks TKs 018, 025, and 027

For all existing tanks meeting the applicability criteria of 40 CFR part 63, subpartLLLLL, the Permittee shall comply with the requirements of 40 CFR part 63,subpart LLLLL by 3 years after startup of the GP 015 asphalt blowing operation, asdefined in GP 015 of this permit.

40 CFR Section 63.8683 and Minn. R. 7011.7940


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-15

TKs 018, 025, and 027 are a Group 2 asphalt storage tank under part 63 subpartLLLLL as they are asphalt storage tanks with a capacity of 1.93 megagrams (Mg) ofasphalt or greater that are not a Group 1 asphalt storage tanks.

The following requirements are for Group 2 asphalt storage tanks. The Permitteeshall determine if any of the tanks in GP 011 are Group 1 asphalt storage tanks bythe compliance date for these tanks indicated in GP 011. The Permittee shallmaintain records of this determination. If any of the GP 011 tanks are subject toGroup 1 requirements the Permittee shall apply for the appropriate permitamendment as applicable to incorporate the Group 1 requirements within 60 daysafter the compliance date for these tanks.

40 CFR Section 63.8698 and Minn. R. 7011.7940;Minn. R. 7007.0800, subp. 2

Applicability of 40 CFR Part 60 Subpart UU and Part 63 Subpart LLLLL: TK 018,025, 026, and 027 are subject to 40 CFR pt. 60, subp. UU, and 40 CFR pt. 63,subp. LLLLL. Therefore the tanks are required to comply only with the provisions ofpt. 63, subp. LLLLL.

40 CFR Sections 63.8681(b) and 63.8683(c)(2) andMinn. R. 7011.7940

Opacity: less than or equal to 0 percent opacity except for one consecutive15-minute period in any 24-hour period when the storage tank transfer lines arebeing cleared. During this 15-minute period, the control device must not bebypassed. If the emissions from the asphalt storage tank are ducted to thesaturator control device, the combined emissions from the saturator and storagetank must meet the 20 percent opacity limit (specified in 4.a of table 1) during this15-minute period. At any other time, the opacity limit applies to Group 2 asphaltstorage tanks.

40 CFR Section 63.8684(a) & part 63 subp. LLLLLTable 1 and Minn. R. 7011.7940

Emission limitations (including operating limits) in subpart LLLLL apply at all times,except during periods of startup, shutdown, and malfunction.

40 CFR Section 63.8685(a) and Minn. R. 7011.7940

Site-Specific Monitoring Plan: develop and implement a written site-specificmonitoring plan according to the provisions in Sections 63.8688(g) and (h).

40 CFR Section 63.8685(d) and Minn. R. 7011.7940

Startup, Shutdown, and Malfunction Plan (SSMP): the Permittee shall develop andimplement a written SSMP according to the provisions in Section 63.6(e)(3).

40 CFR Section 63.8685(c) and Minn. R. 7011.7940

Performance Test: due 180 days after Initial Startup of TK 018, 025, 027, and 028 .Testing shall be conducted for opacity from the exhaust gases of each tank andshall meet the requirements of 40 CFR Section 63.8687, and Table 3 in subp.LLLLL.

40 CFR Sections 63.8686(c) & 63.8687 & part 63subp. LLLLL Table 3 and Minn. R. 7011.7940

Continuous Compliance Demonstration: The Permittee shall follow the proceduresin Section 63.8691 and Table 5 of subp. LLLLL to continuously determinecompliance.


Notifications: The Permittee shall submit notifications required by Section 63.8692,including the following:

1. all applicable notifications in Sections 63.6(h)(4) and (5), 63.7(b) and (c), 63.8(f),and 63.9(b) through (f) and (h) by the dates specified;2. notification of the actual date of startup of the affected facility not later than 15calendar days after the startup date as required by Section 63.9(b)(4)(v);3. initial notification not later than 120 calendar days after becoming subject to thissubpart as required by Section 63.9(b)(3);4. notification of intent to conduct a performance test at least 60 calendar daysbefore the performance test is scheduled to begin, as required in Section 63.7(b)(1);5. submit a notification of compliance status according to Section 63.9(h)(2)(ii),including the performance test results, before the close of business on the 60thcalendar day following the completion of the performance test according to Section63.10(d)(2).


Reports: The Permittee shall submit applicable reports required by Section63.8693 and subp. LLLLL Table 6. See also GP 015 subject item of Table A andTable B for 40 CFR pt. 63, subp. LLLLL reporting requirements.


Recordkeeping: The Permittee shall keep copies of all notifications and reports,startup/shutdown/malfunction records, performance test results, and recordsdemonstrating continuous compliance as required by Sections 63.8694.


The Permittee shall maintain records in a form suitable and readily available forexpeditious review. The Permittee shall keep each record for 5 years following thedate of each occurrence, measurement, maintenance corrective action, report, orrecord. The Permittee shall keep each record on site for at least the first 2 years,and the records may be kept offsite for the remaining 3 years.


General Provisions: Follow the requirements of subp. LLLLL Table 7 to meet therequirements of part 63 subpart A.


See TK 028 subject item of Table A for additional requirements for TK 028. hdr


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-16

Subject Item: GP 012 Premodification Permit 002 NSPS Subject Units

Associated Items: CE 004 RTO (SV 004)

TK 015 Plant Windseal Day Tank

TK 016 Horizon Circulation Tank

TK 017 Horizon Batch Mixer

What to do Why to do itThe following limits apply to each tank or unit separately. hdr

The Permittee shall vent emissions from the tanks in GP 012 to a control devicemeeting the requirements of CE 004.

Minn. R. 7007.0800, subp. 2 and 14

For all existing tanks meeting the applicability criteria of 40 CFR part 63, subpartLLLLL, the Permittee shall comply with the requirements of 40 CFR part 63,subpart LLLLL by 3 years after startup of the GP 015 asphalt blowing operation, asdefined in GP 015 of this permit.

Upon compliance with 40 CFR pt. 63, subp. LLLLL, the units in GP 012 are still anaffected facility under 40 CFR pt. 60, subp. UU, but are no longer required tocomply with the requirements of subp. UU.

The Permittee shall apply for the appropriate permit amendment as applicable toincorporate the requirements for 40 CFR pt. 63, supb. LLLLL for the units in GP 012

40 CFR Section 63.8681(b); Minn. R. 7011.7940

Opacity: less than or equal to 0 percent opacity except for one consecutive15-minute period in any 24-hour period when the transfer lines are being blown forclearing. CE 004 shall not be bypassed during this 15-minute period.

40 CFR Section 60.472(c); Minn. R. 7011.0950


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-17

Subject Item: GP 013 Postmodification Permit 002 NSPS Subject Units

Associated Items: EU 047 Filler Silo #1 With Transfer System

EU 048 Filler Silo #2 With Transfer System

EU 049 Line #3 Filler Use Bin & Transfer System

EU 050 Headlap Silo & Transfer System

EU 082 Colored Granule Silo #21





TK 012 Line #3 Windseal Use Tank

TK 013 Line #3 Laminant Use Tank

TK 014 Line #3 Laminant Day Tank

What to do Why to do itThe following limits apply to each emission unit or tank separately.

EU 047, EU 048, EU 049, and EU 050 control equipment requirements (CE 038,CE 039, CE 040, and CE 042, respectively) are listed under GP 008 in table A ofthis permit.

TK 012-014 control equipment requirements (CE 001 and CE 004) are listed underCE 004 in Table A of this permit.

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At any time that any of the following emissions units are in operation, the Permitteeshall vent that emission unit to a piece of control equipment as designated below.

EU 047-050 to a piece of control equipment meeting the requirements of GP 008TK 012-014 to a piece of control equipment meeting the requirements of CE 004


Opacity: less than or equal to 1 percent opacity . 40 CFR Section 60.472(d); Minn. R. 7011.0950


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-18

Subject Item: GP 014 Line 1 and Line 2 Saturators



What to do Why to do itEU 011 and EU 012 Operating Prohibition: The Permittee is prohibited fromsimultaneously operating EU 011 and EU 012. Startup and shutdown operation ofEU 011 and EU 012 are also included in this prohibition.


The Permittee shall vent emissions to control equipment that meets therequirements of CE 004 at all times that EU 011 and/or EU 012 are in operation.


Recordkeeping (if applicable, see condition below): The Permittee shall record andkeep a log of the time and date of each startup and shutdown event for each periodof operation of EU 011 (Line 1 Saturator) and EU 012 (Line 2 Saturator). Data shallbe entered into the log at the time of each startup and each shutdown for eachemission unit.

Records shall specify:

1. clock time to the nearest minute including AM or PM (or 24-hr military time) atthe beginning of the startup and at the end of the shutdown;2. month, day, and year of the startup or shutdown;3. emission unit (EU 011 or EU 012) undergoing startup or shutdown;4. the type of event (startup or shutdown).


If an emission unit is out of service the Recordkeeping requirement listed abovedoes not apply. Instead, a tag with the following information is required (a) out ofservice date and an estimated duration, and (b) a brief note with explanation. Thistag must remain with the applicable unit while it's out of service.


EU 011 and EU 012 are subject to additional requirements in this permit. Refer toTable A Subject Items GP 003 and CE 004 for additional requirements for EU 011,and refer to Table A Subject Items GP 003, CE 004 and EU 012 for additionalrequirements for EU 012.

hdr

NESHAP SUBPART LLLLL REQUIREMENTS hdr

For the units in GP 014, the Permittee shall comply with the requirements 40 CFRpt. 63, subp. LLLLL by 3 years after startup of the GP 015 asphalt blowingoperation, as defined in GP 015 of this permit. Until the Permittee is in compliancewith 40 CFR pt. 63, subp. LLLLL the Permittee shall be in compliance with theapplicable requirements of 40 CFR pt. 63, subp. AAAAAAA for the units in GP 014.

Upon compliance with 40 CFR pt. 63, subp. LLLLL, the Permittee is no longersubject to the requirements of 40 CFR pt. 63, subp. AAAAAAA.

Upon compliance with 40 CFR pt. 63, subp. LLLLL, EU 012 is still an affectedfacility under 40 CFR pt. 60, subp. UU, but is no longer required to comply with therequirements of subp. UU.

The Permittee shall apply for the appropriate permit amendment as applicable toincorporate the requirements of 40 CFR pt. 63, subp. LLLLL for the units in GP 014

40 CFR Section 63.8683; Minn. R. 7011.7940


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-19

Subject Item: GP 015 Blowstills and New Thermal Oxidizer

Associated Items: CE 047 Thermal Oxidizer

EU 091 Blowing Still #1



SV 058 Thermal Oxidizer (CE 047) Stack

What to do Why to do itThe Permittee is authorized to install and operate EUs 091, 092 and 093, and CE047 as defined by this permit, at any time during the life of Air Emissions Permit No.13900013-007.

Minn. R. 7007.0800, subp. 2

Upon startup of the GP 015 units (blow stills and oxidizer), the facility becomes amajor source of HAPs and the GP 015 units must be in compliance with 40 CFR pt.63 subp. LLLLL (40 CFR Section 63.8683(c)(1)).

Definition of "startup of the GP 015 asphalt blowing operation": The date on whichthe first unit of GP 015 starts up, is considered the startup date of the GP 015blowing operation. Three (3) years after the facility becomes a major source ofHAPs (3 years after the startup of the GP 015 asphalt blowing operation), the partsof the facility which are an existing affected source as defined by 40 CFR pt. 63subp. LLLLL must be in compliance with 40 CFR pt. 63 Subpart LLLLL (40 CFRSection 63.8683 (c)(2)). No 40 CFR pt. 63 regulations for major sources of HAPsapply to the facility until after startup of the GP 015 units.

40 CFR Section 63.8683(c) and Minn. R. 7011.7940and Minn. R. 7007.0800, subp. 2

OPERATING AND EMISSION LIMITS hdr

Process Throughput: less than or equal to 200,000 tons/year using 12-monthRolling Sum . This limit is on the total amount of asphalt blown in EUs 091, 092,and 093 combined.


Recordkeeping - Asphalt Blowing: The Permittee shall maintain monthly records ofthe following:1) The amount of asphalt flux received by railcar during the previous month, basedon purchase records;2) The amount of asphalt flux received by tank truck during the previous month,based on purchase records;3) The amount of oxidized asphalt received by tank truck during the previousmonth, based on purchase records;4) The amount of asphalt shipped offsite via tank truck, based on shipping records;and5) The amount of asphalt conatined in TKs 025, 027, and 018 on the last operatingday of the month.


Recordkeeping - Asphalt Blowing: By the 15th day of each month the Permitteeshall calculate and record the total tons of asphalt blown in the previous monthbased on the formula below

AB = ((CI)-(PI))+PR+PT-STAB = Amount of asphalt blown (tons/month)CI = Current inventory, based on monthly record of the amount of asphalt in TKs025, 027, and 018PI = Previous month's inventory, based on the records of the amount of asphalt inTKs 025, 027, and 018 from the month priorPR = Amount of asphalt flux received via railcar, based on purchase recordsPT = Amount of asphalt flux received via tank truck, based on purchase recordsST = Amount of asphalt flux shipped off-site via tank truck, based on shippingrecords

Minn. R. 7007.0800, subps. 4 and 5

Recordkeeping - Asphalt Blowing: By the 15th day of each month the Permitteeshall calculate and record he 12-month rolling sum of tons of asphalt blown duringthe previous 12-month period by summing the monthly tons of asphalt blowndetermined according to the equpation above for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5

Blowing Still Usage: The Permittee shall not be blowing asphalt in more than twoblowing stills at any time.


Recordkeeping - Blowing Still Usage: The Permittee shall keep records of thestartup and shutdown date and time for each blowing still. Records shall specifythe emission unit/blowing still identification number.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-20




The Permittee shall vent EUs 091, 092, and 093 to a thermal oxidizer meeting therequirement of CE 047 at all times that EUs 091, 092, or 093 are operating.


CE 047 Operation, Shutdown, and Breakdown: The Permittee shall not blowasphalt when CE 047 is not in operation. During CE 047 shutdowns andbreakdowns, emissions from the blowing stills shall continue to be routed throughthe knockout tank for PM, PM10, and PM2.5 control.


NESHAP SUBPART LLLLL REQUIREMENTS (see CE 047 for additionalrequirements)

hdr

Applicability of 40 CFR Part 60, Subpart UU: EU 091, EU 092, and EU 093 aresubject to 40 CFR pt. 60, subp. UU, and 40 CFR pt. 63, subp. LLLLL. Thereforethese emission units are required to comply only with the provisions of pt. 63, subp.LLLLL.



40 CFR Section 63.8685(a); Minn. R. 7011.7940


40 CFR Section 63.8685(c) ; Minn. R. 7011.7940

Continuous Compliance Demonstration: The Permittee shall follow the proceduresin Section 63.8691 and Table 5 of subp. LLLLL to continuously determinecompliance.


NEHSAP Notifications and Reports (see Table B for additional requirements) hdr

Notifications: The Permittee shall submit notifications required by Section 63.8692,including the following (Notifications are also listed in Table B):

1. all applicable notifications in Sections 63.6(h)(4) and (5), 63.7(b) and (c), 63.8(f),and 63.9(b) through (f) and (h) by the dates specified;2. submit a notification of the actual date of startup of the affected facility not laterthan 15 calendar days after the startup date as required by Section 63.9(b)(4)(v);3. submit a notification of intent to conduct a performance test at least 60 calendardays before the performance test is scheduled to begin, as required in Section63.7(b)(1);4. submit a notification of compliance status according to Section 63.9(h)(2)(ii),including the performance test results, before the close of business on the 60thcalendar day following the completion of the performance test according to Section63.10(d)(2).


Reports: The Permittee shall submit applicable reports required by Section63.8693 and subp. LLLLL Table 6 (See also Table B).

The compliance report shall contain the following information:1) company name and address;2) statement by a responsible official with that official's name, title, and signature,certifying the truth accuracy, and completeness of the content of the report;3) date of report and beginning and ending dates of the reporting period;4) If you had a startup, shutdown, or malfunction during the reporting period andyou to action consistent with you SSMP, the compliance report must include theinformation in Section 63.10(d)(5)(i);5) If there are no deviations from any emission limitations (emission limit, operatinglimit, opacity limit, and visible emission limit) that apply to you, a statement thatthere were no deviations from the emission limitations during the reporting period;

40 CFR Section 63.8693(c) and (d); Minn. R.7011.7940


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-21

Content of Compliance Report Continued:6) If there were no period during which the CPMS was out-of-control as specified inSection 63.8(c)(7), a statement that there were no periods during which the CPMSwas out-of-control during the reporting period;7) For each deviation from an emission limitation (emission limit, operating limit,opacity limit, and visible emissions limit), you must also include the information initems 8-19.8) the date and time that each malfunction started and stopped;9) the date and time that each CPMS was inoperative, except for zero (low-level)and high-level checks;10) the date and time that each CPMS was out-of-control, including the informationin Section 63.8(c)(8);11) the date and time that each deviation started and stopped, and whether eachdeviation occurred during a period of startup, shutdown, or malfunction or duringanother period;


Content of Compliance Report Continued12) a summary of the total duration of the deviation during the reporting period andthe total duration as a percent of the total source operating time during thatreporting period;13) a breakdown of the total duration of the deviations during the reporting periodinto those that are due to startup, shutdown, control equipment problems, processproblems, other known causes, and other unknown causes;14) a summary of the total duration of CPMS downtime during the reporting periodand the total duration of CPMS downtime as a percent of the total source operatingtime during that reporting period;15) an identification of each air pollution that was monitored at the affected source;16) a brief description of the process units;17) a brief description of the CPMS;18) the date of the latest CPMS certification or audit; and19) a description of any changes in CPMS processes or controls since the lastreporting period.


General Provisions: Follow the requirements of subp. LLLLL Table 7 to meet therequirements of part 63 subpart A.

40 CFR Section 63.8696

NESHAP Recordkeeping hdr

Recordkeeping: The Permittee shall keep copies of all notifications and reports,startup/shutdown/malfunction records, performance test results, and recordsdemonstrating continuous compliance as required by Sections 63.8694 and63.8695.

40 CFR Sections 63.8694 & 63.8695; Minn. R.7011.7940


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-22

Subject Item: GP 016 Cooling Sections Limits

Associated Items: EU 075 EF3A Cooling Section Line #1 SV 047

EU 076 EF3B Cooling Section Line #1 SV 048





EU 094 Line #2 Cooling Section Stack 3 SV 060





SV 047 EF3A Exhaust Fan Vent

SV 048 EF3B Exhaust Fan Vent

SV 049 EF37 Exhaust Fan Vent


SV 051 CS1 Cooling Section Line #3


SV 060 Cooling Section Line 2 Stack 3





What to do Why to do itTotal Particulate Matter: less than or equal to 2.47 lbs/hour from SV 047. Title I Condition: To limit emissions to less than the

major source threshold under 40 CFR Section 52.21and Minn. R. 7007.3000

PM < 10 micron: less than or equal to 2.47 lbs/hour from SV 047. Title I Condition: To limit emissions to less than themajor source threshold under 40 CFR Section 52.21and Minn. R. 7007.3000

PM < 2.5 micron: less than or equal to 2.47 lbs/hour from SV 047 Title I Condition: To limit emissions to less than themajor source threshold under 40 CFR Section 52.21and Minn. R. 7007.3000

Total Particulate Matter: less than or equal to 2.00 lbs/hour from SV 048. Title I Condition: To limit emissions to less than themajor source threshold under 40 CFR Section 52.21and Minn. R. 7007.3000


PM < 2.5 micron: less than or equal to 2.00 lbs/hour from SV 048. Title I Condition: To limit emissions to less than themajor source threshold under 40 CFR Section 52.21and Minn. R. 7007.3000






13900013 - 007

Facility Name:

Permit Number:

05/28/13A-23























13900013 - 007

Facility Name:

Permit Number:

05/28/13A-24



Visible Emissions Check: Once each day of operation, the Permittee shall observeeach GP 016 stack/vent (SV 047, SV 048, SV 049, SV 050, SV 051, SV 052, SV060, SV 061, SV 062, SV 063 and SV 064) during daylight hours while theequipment vented to that stack is in operation to determine if there are any visibleemissions (VEs) from each stack/vent. If any VEs are observed, the Permitteeshall take corrective action in order to eliminate the VEs as soon as possible.

Title I Condition: To avoid major source status under40 CFR Section 52.21 and Minn. R. 7007.3000; Minn.R. 7007.0800, subps. 2, 4, & 14

Recordkeeping: The Permittee shall keep a record of all VE checks, whether or notany VEs were observed, and of any corrective actions taken. All records shallspecify the corresponding stack/vent number.

Title I Condition: To avoid major source status under40 CFR Section 52.21 and Minn. R. 7007.3000; Minn.R. 7007.0800, subp. 5

TESTING REQUIREMENTS hdr

Performance Test: due before end of each calendar 60 months starting 08/12/2009to measure the emission rate of particulate matter from SV 052 of Cooling SectionLine 3 Each test date starts a new calendar 60-month period during which testingmust be performed and the Permittee shall not exceed 60 months between tests.

Title I Condition: To avoid major source status under40 CFR Section 52.21 and Minn. R. 7007.3000; Minn.R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 08/12/2009to measure the emission rate of particulate matter less than 10 microns from SV052 of Cooling Section Line 3 Each test date starts a new calendar 60-monthperiod during which testing must be performed and the Permittee shall not exceed60 months between tests.


Performance Test: due before end of each calendar 60 months starting 08/12/2009to measure the emission rate of particulate matter less than 2.5 microns from SV052 of Cooling Section Line 3 Each test date starts a new calendar 60-monthperiod during which testing must be performed and the Permittee shall not exceed60 months between tests.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-25

Subject Item: GP 017 Roadway Fugitive Emission Sources

Associated Items: FS 001 Paved facility road between south end of plant and off-site road

FS 002 Paved facility road to west of plant

FS 003 Paved employee parking south of plant

FS 004 Paved facility road to north of plant

FS 005 Paved facility road to northeast of plant

FS 006 Paved truck staging east of FS 007

FS 007 Paved facility road to southeast of plant

What to do Why to do itThe Permittee shall develop and implement a fugitive dust control plan for FS 001,FS 002, and FS 004. The plan shall include measures to ensure 80% control offugitive PM10 emissions from these sources. The fugitive dust control plan andprogram must be implemented upon startup of any GP 015 emission unit.

Minn. R. 7007.0800, subp. 2

Fugitive Emissions: The Permittee shall not allow any road, driveway, or open areato be used without applying all such reasonable measures as may be required toprevent particulate matter from becoming airborne. The Permittee shall takereasonable precautions to prevent the discharge of visible fugitive dust emissionsbeyond the facility property line. Reasonable measures include but are not limitedto paving or frequent clearing of roads, driveways, and parking lots; application ofdust-free surfaces; or the application of water.

Minn. R. 7011.0150


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-26

Subject Item: GP 018 Make Up Air Units

Associated Items: EU 101 Make up air #1 roofing manufacturing

EU 102 Make up air #2 roofing dry end

EU 103 Make up air #3 roofing packaging area

EU 104 Make up air #4 dry felt warehouse

EU 105 Make up air #5 roofing fin prod looper

EU 106 Make up air #6 felt mill stock prep

EU 107 Make up air #7 felt mill machine room

EU 108 Make up air #9 line 3 coater

EU 109 Make up air #10 line 3 laminator


Permitted Fuel: natural gas only Minn. R. 7007.0800, subp. 2


Minn. R. 7011.0610, subp. 1(A)(1)


Minn. R. 7011.0610, subp. 1(A)(2)

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . The potential toemit from each unit is 0.00059 lb/mmBtu due to equipment design and allowablefuel.

Minn. R. 7011.0610, subp. 2(A)


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-27

Subject Item: GP 019 Mist Eliminators

Associated Items: CE 049 Mist Eliminator - Low Velocity, i.e., V<250 Ft/Min

CE 050 Mist Eliminator - Low Velocity, i.e., V<250 Ft/Min

What to do Why to do itThe Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Total Particulate Matter: greater than orequal to 90 percent control efficiency

Minn. R. 7007.0800, subps 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for PM < 10 micron: greater than or equal to90 percent control efficiency

Minn. R. 7007.0800, subps 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for PM < 2.5 micron: greater than or equal to90 percent control efficiency

Minn. R. 7007.0800, subps 2 and 14

Pressure Drop: The Permittee shall maintain the pressure drop across the misteliminators according to the manufacturers specifications, unless a new range isset pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded duringthe most recent MPCA-approved performance test where compliance wasdemonstrated. The new range shall be implemented upon receipt of the Notice ofCompliance letter granting preliminary approval. The range is final upon issuanceof a permit amendment incorporating the change. The Permittee shall record thepressure drop at least once every 24 hours when in operation.

Minn. R. 7007.0800, subps. 2 and 14

Recordkeeping of Pressure Drop. The Permittee shall record the time and date ofeach pressure drop reading and whether or not the recorded pressure drop waswithin the range specified in this permit.

Minn. R. 7007.0800, subps. 4 and 5

The Permittee shall operate and maintain the mist eliminators at all times that anyemission unit controlled by the mist eliminators in operation. For the purposes ofGP 019 only, operation of the tanks does not include idle time when there is nothroughput of material and the tanks are maintained at a constant temperature. ThePermittee shall document periods of non-operation of the control equipment.

Minn. R. 7007.0800, subps. 2 and 14

Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

Minn. R. 7007.0800, subps. 4, 5 and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted range,and/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the fabric filter. The Permittee shall keep a record of the type and dateof any corrective action taken for each filter.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain the fabric filter in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-28

Subject Item: GP 020 Asphalt Rail Unloading and Truck Loading/Unloading

Associated Items: EU 112 Asphalt Flux Rail Car Unloading

EU 113 Asphalt Flux Truck Unloading

EU 114 Asphalt Flux Truck Loading

What to do Why to do itThe Permittee is authorized to install and operate equipment described by EU 112,113, and 114, at any time during the life of Air Emissions Permit No.13900013-007.

Minn. R. 7007.0800, subp. 2

Process Throughput: less than or equal to 200,000 tons/hour to be calculated bythe 15th day of each month for the previous 12-month period as described in GP015 of this permit.

This limit applies individually to the throughput of asphalt flux for each EU 112 andEU 113 the throughput of oxidized asphalt for EU 114.

See GP 015 for recordkeeping associated with these activities.



The following emission limits apply individually to each emission unit in GP 020.The emission limits apply to the loading activities only and not to the fugitive roaddust from the truck traffic. Emissions from those activities are addressed in GP017.

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Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity . Minn. R. 7011.0715, subp. 1(B)

At any time EU 114 is in operation, the Permittee shall vent the emissions from EU114 to a piece of control equipment meeting the requirements of GP 019 (MistEliminators).

Minn. R. 7007.0800, subp. 2 and 14


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-29

Subject Item: EU 012 Line #2 Saturator/Coater/Mixers


CE 004 RTO (SV 004)

GP 003 Industrial Process Equipment

GP 014 Line 1 and Line 2 Saturators

SV 002 CE 002 mist eliminator

SV 004 CE 004 RTO stack

What to do Why to do itSee GP 014 and CE 004 for additional requirements. hdr

A. EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.06 lbs/ton (0.03 kilograms permegagram) of asphalt shingle or mineral-surfaced roll roofing produced. Thisemission limit applies to the process that involves only the Coater. See monitoringand recordkeeping requirements at CE 004.

40 CFR pt. 63, subp. AAAAAAA Table 2

Total Particulate Matter: less than or equal to 0.30 lbs/ton (0.15 kilograms permegagram) of saturated felt or smooth-surfaced roll roofing produced. Thisemission limit applies to the Saturator only. See monitoring and recordkeepingrequirements at CE 004.


PM < 10 micron: less than or equal to 0.08 lbs/ton (0.04 kilograms per megagram)of asphalt shingle or mineral-surfaced roll roofing produced. This emission limitapplies to the process that involves only the Coater.

Title I Condition: Limit to avoid major source statusunder 40 CFR Section 52.21 and Minn. R. 7007.3000;Minn. R. 7007.0800, subp. 2

PM < 10 micron: less than or equal to 0.8 lbs/ton (0.4 kilograms per megagram) ofsaturated felt or smooth-surfaced roll roofing produced. This emission limit appliesto the Saturator only.


Saturator exhaust gases Opacity: less than or equal to 20 percent opacity 40 CFR Section 60.472(a)(2); Minn. R. 7011.0950

Visible Emissions: Do not exhibit any visible emissions from the saturator capturesystem for not more than 20 percent of any period of consecutive validobservations totaling 60 minutes.

40 CFR Section 60.472(a)(3); Minn. R. 7011.0950

B. PERFORMANCE TEST REQUIREMENTS hdr

Performance Test: due before end of each 60 months starting 03/19/2007 tomeasure emissions of total particulate matter from EU 012. Each test date starts anew calendar 60-month period during which testing must be performed and thePermittee shall not exceed 60 months between tests.

Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 03/19/2007to measure emissions of particulate matter less than 10 microns from EU 012.Each test date starts a new calendar 60-month period during which testing must beperformed and the Permittee shall not exceed 60 months between tests.

Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 03/19/2007to measure opacity from EU 012 (SV 004). Each test date starts a new calendar60-month period during which testing must be performed and the Permittee shallnot exceed 60 months between tests.

Minn. R. 7017.2020, subp. 1

NESHAP SUBPART LLLLL REQUIREMENTS hdr

The Permittee shall comply with the requirements 40 CFR pt. 63, subp. LLLLL forthis unit by 3 years after startup of the GP 015 asphalt blowing operation, asdefined in GP 015 of this permit. Until the Permittee is in compliance with 40 CFRpt. 63, subp. LLLLL the Permittee shall be in compliance with the applicablerequirements of 40 CFR pt. 63, subp. AAAAAAA for this unit.



The Permittee shall apply for the appropriate permit amendment as applicable toincorporate the requirements of 40 CFR pt. 63, subp. LLLLL for EU 012.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-30

Subject Item: EU 037 Emergency Generator

Associated Items: SV 037 Emergency Generator stack

What to do Why to do itOperating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum Minn. R. 7005.0100, subp. 35a; Minn. R. 7007.0800,

subp. 2

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R. 7011.2300, subp. 2

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Recordkeeping: By the 15th day of each month, calculate and record the EU 037operating hours during the previous month and for the previous 12-month period(12-month Rolling Sum).

Minn. R. 7005.0100, subp. 35a; Minn. R. 7007.0800,subp. 5

Performance Test: Upon the request of the Commissioner, testing shall beconducted in accordance with Minn. R. 7017.2001 - 7017.2060.

Minn. R. 7017.2020, subp. 1

Visible Emissions (VE) Check: Once each day of operation, the Permittee shallobserve the generator stack/vent during daylight hours to determine if there are anyvisible emissions.

Minn. R. 7007.0800, subp. 4

Recordkeeping: The Permittee shall keep a record of all VE checks, whether or notany VEs were observed, and of any corrective actions taken.

Minn. R. 7007.0800, subp. 5

Stack Requirements: Prior to the startup of any GP 015 emission unit thePermittee shall modify SV 037 from the current horizontal vent to an uncappedvertical vent so that emissions are discharged upward.

Minn. R. 7007.0800, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-31

Subject Item: EU 043 Line #3 Coater


CE 004 RTO (SV 004)

GP 003 Industrial Process Equipment

SV 004 CE 004 RTO stack

What to do Why to do itSee CE 004 for additional requirements hdr

The Permittee shall vent EU 043 to a control device meeting the requirements ofCE 004 at all times that EU 043 is operating.

Title I Condition: Limit to avoid major source statusunder 40 CFR Section 52.21 and Minn. R. 7007.3000

Total Particulate Matter: less than or equal to 0.08 lbs/ton (0.04 kilograms permegagram) of asphalt shingle or mineral-surfaced roll roofing produced. Thisemission limit applies to the Coater only.

Title I Condition: Limit to avoid major source statusunder 40 CFR Section 52.21 and 7007.3000; 40 CFRSection 60.472(a)(1)(i); Minn. R. 7011.0950

PM < 10 micron: less than or equal to 0.08 lbs/ton (0.04 kilograms per megagram)of asphalt shingle or mineral-surfaced roll roofing produced. This emission limitapplies to the Coater only.


Opacity: less than or equal to 20 percent opacity from EU 043. 40 CFR Section 60.472(a)(2); Minn. R. 7011.0950

Visible Emissions: Do not exhibit any visible emissions from the saturator capturesystem for not more than 20 percent of any period of consecutive validobservations totaling 60 minutes.

40 CFR Section 60.472(a)(3); Minn. R. 7011.0950

B. PERFORMANCE TEST REQUIREMENTS hdr

Performance Test: due before end of each 60 months starting 02/10/2009 tomeasure emissions of total particulate matter from EU 043. Each test date starts anew calendar 60-month period during which testing must be performed and thePermittee shall not exceed 60 months between tests.

Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 02/10/2009to measure emissions of particulate matter less than 10 microns from EU 043.Each test date starts a new calendar 60-month period during which testing must beperformed and the Permittee shall not exceed 60 months between tests.

Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 02/10/2009to measure opacity from EU 043 (SV 004). Each test date starts a new calendar60-month period during which testing must be performed and the Permittee shallnot exceed 60 months between tests.

Minn. R. 7017.2020, subp. 1

NESHAP LLLLL REQUIREMENTS hdr

The Permittee shall comply with the requirements 40 CFR pt. 63, subp. LLLLL by 3years after startup of the GP 015 asphalt blowing operation, as defined in GP 015of this permit. Until the Permittee is in compliance with 40 CFR pt. 63, subp. LLLLLthe Permittee shall be in compliance with the requirements of 40 CFR pt. 63, subp.AAAAAAA of EU 043



The Permittee shall apply for the appropriate permit amendment as applicable toincorporate the requirements of 40 CFR pt. 63, subp. LLLLL for EU 043.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-32

Subject Item: EU 074 Line #3 Mat Preheater

Associated Items: CE 042 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 044 Dust Collector DC-7, Line #3 Surfacing Headlap and Dry Mat Looper, Headlap Silo and Transfer System

What to do Why to do itTotal Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

Minn. R. 7011.0610, subp. 1(A)(1)


Minn. R. 7011.0610, subp. 1(A)(2)

Permitted Fuel: natural gas only Minn. R. 7007.0800, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-33

Subject Item: EU 088 Line #3 Nail Line Paint Applicator

Associated Items: GP 003 Industrial Process Equipment

SV 048 EF3B Exhaust Fan Vent





What to do Why to do itMaterial Usage: less than or equal to 35000 gallons/year using 12-month RollingSum to be calculated by the 15th day of each month for the previous 12-monthperiod as described later in this permit.

This limit applies to the paint used at EU 088

Minn. R. 7007.0800, subp. 2; Minn. R. 7005.0100,subp. 35a

The Permittee shall maintain monthly records of the total quantity of paint used atEU 088. This record shall be based on purchase records.

Minn. R. 7007.0800, subps. 4 and 5

Monthly Recordkeeping -- Paint Usage.By the 15th of the month, the Permittee shall calculate and record the following:1) The total usage of paint for the previous calendar month using the monthlypurchase records. This record shall also include the VOC contents of each paint asdetermined by the Material Content requirement of this permit;2) The 12-month rolling sum paint usage for the previous 12-month period bysumming the monthly paint usage data for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5

Material Content. VOC contents in coating materials shall be determined by theMaterial Safety Data Sheet (MSDS) provided by the supplier for each materialused. If a material content range is given on the MSDS, the highest number in therange shall be used in all compliance calculations. Other alternative methodsapproved by the MPCA may be used to determine the VOC contents. TheCommissioner reserves the right to require the Permittee to determine the VOCcontents of any material, according to EPA or ASTM reference methods. If an EPAor ASTM reference method is used for material content determination, the dataobtained shall supersede the MSDS.

Minn. R. 7007.0800, subps. 4 and 5

Maximum Contents of Materials: The Permittee assumed a VOC contents of 54.4g/L when determining the short term potential to emit of EU 088. This VOC contentis not a limit, but changing to a material that has a higher content of VOC isconsidered a change in method of operation that must be evaluated under Minn. R.7007.1200, subp. 3 to determine if a permit amendment or notification is requiredunder Minn. R. 7007.1150.

Minn. R. 7005.0100, subp. 35a


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-34

Subject Item: CE 004 RTO (SV 004)



EU 043 Line #3 Coater

EU 044 Line #3 Laminant Adhesive Applicator


EU 054 Line #3 Horizontal Mixer

EU 055 Line #3 Vertical Mixer

EU 057 Windseal Mixer

EU 066 Modified Room Line #3 Laminant/Windseal Mixer

EU 070 Horizon Asphalt Applicator SV 047 - 052, SV 060 - 064



GP 012 Premodification Permit 002 NSPS Subject Units








TK 011 Line #3 Asphalt Storage Tank

TK 012 Line #3 Windseal Use Tank

TK 013 Line #3 Laminant Use Tank

TK 014 Line #3 Laminant Day Tank

TK 015 Plant Windseal Day Tank

TK 016 Horizon Circulation Tank

TK 017 Horizon Batch Mixer

TK 019 Line 1 Presidential Laminate Batch Tank

TK 020 Line 1 Presidential Laminate Day Tank

TK 021 Line 1 Presidential Laminate Use Tank

TK 022 Line 1 Presidential Sealant Use Tank

TK 023 Line 2 Presidential/ Splinter Circulation Tank

TK 024 Line 1 Splinter Off-Line Use Tank

TK 028 Finished Coating Storage Tank

What to do Why to do itA. EMISSION LIMITS

Limits apply to combined emissions of RTO (CE 004) and Mist Eliminators (CE001, CE 002, CE 003) vented through SV 004.

hdr

Total Particulate Matter: less than or equal to 7.82 lbs/hour for SV 004. Thisemission limit is for the pollution control equipment (mist eliminator and RTOcombined). During the performance test, each of the gas streams emissions (lb/hr)from the emission units and/or tanks to all three of the mist eliminators must becombined to come up with the total inlet concentration.


PM < 10 micron: less than or equal to 7.82 lbs/hour for SV 004. This emission limitis for the pollution control equipment (mist eliminator and RTO combined). Duringthe performance test, each of the gas streams emissions (lb/hr) from the emissionunits and/or tanks to all three of the mist eliminators must be combined to come upwith the total inlet concentration.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-35

Volatile Organic Compounds: less than or equal to 5.88 lbs/hour for SV 004. Thisemission limit is for the pollution control equipment (mist eliminator and RTOcombined). During the performance test, each of the gas streams emissions (lb/hr)from the emission units and/or tanks to all three of the mist eliminators must becombined to come up with the total inlet concentration.


B. OPERATIONAL REQUIREMENTS: RTO (CE 004) and Mist Eliminators (CE001, CE 002, CE 003) Combined

hdr

Routing Of EU 071 and EU 072 Emissions: Prior to startup of any GP 015emission unit, the Permittee shall vent all EU 071 and EU 072 emissions to CE004.


Operate and maintain control equipment (mist eliminators and RTO) for TotalParticulate Matter: greater than or equal to 90 percent control efficiency


Operate and maintain control equipment (mist eliminators and RTO) for ParticulateMatter < 10 micron: greater than or equal to 90 percent control efficiency


Operate and maintain control equipment (mist eliminators and RTO) for VolatileOrganic Compounds: greater than or equal to 90 percent control efficiency


Operation and Maintenance of control equipment: The Permittee shall operate andmaintain the mist eliminators (CE 001, CE 002, and CE 003) and the regenerativethermal oxidizer (CE 004) according to the facility O&M plan and the controlequipment manufacturer's specifications. The Permittee shall document periods ofnon-operation of the control equipment.

Minn. R. 7007.0800, subp. 2

Temperature: greater than or equal to 1440.0 degrees F in the CE 004 combustionchamber as a three-hour rolling average calculated every hour. A new minimumtemperature may be set pursuant to Minn. R. 7017.2025, subp. 3, based on theaverage temperature recorded during the most recent MPCA-approvedperformance test for PM, PM10, and VOC where compliance was demonstrated. Ifthe three-hour rolling average temperature drops below the minimum temperaturelimit, the PM, PM10, and VOC emissions shall be considered uncontrolled until theaverage minimum temperature limit is once again achieved. This shall be reportedas a deviation.


CE 004 Corrective Action: If the combustion temperature in CE 004 falls below1440.0 degrees F, the Permittee shall take corrective action as soon as possibleaccording to the manufacturer's specifications, and the facility O&M plan. ThePermittee shall keep a log of all corrective actions taken with records entered uponcompletion of each corrective action.


CE 004 Operation, Breakdowns, and Emergency Maintenance: The Permitteeshall vent all emissions sources listed in the CE 004 Associated Items, to CE 004at all times except during CE 004 breakdown or emergency maintenance or whenthe three manufacturing lines are shut down. During CE 004 breakdown oremergency maintenance or when the three manufacturing lines are shut down, tankemissions shall be vented to and controlled by CE 003, and coater emissions shallbe vented to and controlled by CE 001 and CE 002. CE 001, CE 002, and CE 003shall be operating when emissions are vented to them.

Emergency maintenance is defined as maintenance that must be conducted assoon as possible to avoid imminent damage to process or control equipment.

The Permittee shall keep a log of start and stop times for all periods of CE 004downtime that occur when any of the CE 004 Associated Items are operating. Thelog shall specify the cause of the CE 004 downtime.

Minn. R. 7007.0800, subp. 2



Title I Condition: Limit to avoid major source statusunder 40 CFR Section 52.21; Minn. R. 7007.3000;Minn. R. 7007.0800, subp. 2

C. MONITORING AND RECORDKEEPING hdr

Temperature Monitoring: The Permittee shall continuously monitor and record thetemperature in the combustion zone of the pollution control equipment. Themonitoring instrument shall have an accuracy of +/-18 F over its range. Themonitor shall operate at all times when these pollution control equipment areoperating.

40 CFR Section 60.473(b); Minn. R. 7007.0800, subp.4

Temperature Recordkeeping: The Permittee shall record and maintain all CE 004,temperature records at this facility. The records shall be composed of a continuoushard copy readout or manual readings taken every 15 minutes when CE 004 is inoperation.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-36

Daily Monitoring: The Permittee shall physically verify the operation of thetemperature recording device at least once each operating day to verify that it isworking and recording properly. The Permittee shall maintain a written record of thedaily verifications.

Minn. R. 7007.0800, subps. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain thermocouples toconduct temperature monitoring required by this permit. The monitoring equipmentmust be installed, in use, and properly maintained whenever operation of themonitored control equipment is required.

Minn. R. 7007.0800, subp. 4

Quarterly Inspections: At least once per calendar quarter, the Permittee shallinspect the control equipment internal and external system components, includingbut not limited to the refractory, heat exchanger, and electrical systems. ThePermittee shall maintain a written record of the inspection and any correctiveactions taken resulting from the inspection.

Minn. R. 7007.0800, subps. 4, 5, and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall maintain the operating parameters established under 40 CFRSections 63.11562(a)(2), (b)(2), (b)(3), and (c)(2) as specified in Table 4 of thissubpart.

40 CFR Section 63.11563(a)

The Permittee shall develop and make available for inspection by the delegatedauthority, upon request, a site-specific monitoring plan for each monitoring systemthat addresses the following:

1. Installation of the CPMS probe or other interface at a measurement locationrelative to each affected process unit such that the measurement is representativeof control of the exhaust emissions (e.g., on or downstream of the last controldevice);

2. Performance and equipment specifications for the probe or interface, thepollutant concentration or parametric signal analyzer, and the data collection andreduction system; and

3. Performance evaluation procedures and acceptance criteria (e.g., calibrations).

40 CFR Section 63.11563(b)

The site-specific monitoring plan must address the following:

1. Ongoing operation and maintenance procedures in accordance with the generalrequirements of Sections 63.8(c)(1), (c)(3), (c)(4)(ii), (c)(7), and (c)(8);

2. Ongoing data quality assurance procedures in accordance with the generalrequirements of Section 63.8(d); and

3. Ongoing recordkeeping and reporting procedures in accordance with the generalrequirements of Sections 63.10(c), (e)(1), and (e)(2)(i).

40 CFR Section 63.11563(b) (continued)

The Permittee shall install, operate, and maintain a continuous parametermonitoring system (CPMS).

1. The CPMS must complete a minimum of one cycle of operation for eachsuccessive 15-minute period.

2. To determine the 3-hour average: (i) have a minimum of four successive cyclesof operation to have a valid hour of data; (ii) have valid data from at least three offour equally spaced data values for that hour from a CPMS that is not out-of-controlaccording to the site-specific monitoring plan; (iii) determine the 3-hour average ofall recorded readings for each operating day, except as stated in paragraph (g) ofthis section. The Permittee must have at least two of the three hourly averages forthat period using only hourly average values that are based on valid data (i.e., notfrom out-of-control periods).

3. The Permittee shall record the results of each inspection, calibration, andvalidation check of the CPMS.

40 CFR Section 63.11563(c)


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-37

For each temperature monitoring device, the Permittee shall meet the CPMSrequirements in paragraphs (c)(1) through (c)(3) of this section and the followingrequirements:

1. Locate the temperature sensor in a position that provides a representativetemperature.

2. For a noncryogenic temperature range, use a temperature sensor with aminimum measurement sensitivity of 2.8 degree C or 1.0 percent of thetemperature value, whichever is larger.

3. If a chart recorder is used, the recorder sensitivity in the minor division must beat least 20 degree F.

40 CFR Section 63.11563(d)

4. Perform an accuracy check at least semiannually or following an operatingparameter deviation:(i) According to the procedures in the manufacturer's documentation; or(ii) By comparing the sensor output to redundant sensor output; or(iii) By comparing the sensor output to the output from a calibrated temperaturemeasurement device; or(iv) By comparing the sensor output to the output from a temperature simulator.

5. Conduct accuracy checks any time the sensor exceeds the manufacturer'sspecified maximum operating temperature range or install a new temperaturesensor.

6. At least quarterly or following an operating parameter deviation, perform visualinspections of components if redundant sensors are not used.

40 CFR Section 63.11563(d) (continued)

The Permittee shall conduct a performance evaluation of each CPMS inaccordance with the site-specific monitoring plan.

40 CFR Section 63.11563(j)

The Permittee shall operate and maintain the CPMS in continuous operationaccording to the site-specific monitoring plan.

40 CFR Section 63.11563(k)

At all times the Permittee shall operate and maintain any affected source, includingassociated air pollution control equipment and monitoring equipment, in a mannerconsistent with safety and good air pollution control practices for minimizingemissions. The general duty to minimize emissions does not require the Permitteeto make any further efforts to reduce emissions if levels required by this standardhave been achieved. Determination of whether such operation and maintenanceprocedures are being used will be based on information available to theAdministrator which may include, but is not limited to, monitoring results, review ofoperation and maintenance procedures, review of operation and maintenancerecords, and inspection of the source.

40 CFR Section 63.11563(n)

The Permittee shall submit the notifications specified in paragraphs (a)(1) through(a)(6) of this section.

40 CFR Section 63.11564(a)

The Permittee shall submit a compliance report as specified in paragraphs (b)(1)through (b)(4) of this section.

40 CFR Section 63.11564(b)

The Permittee shall maintain the records specified in paragraphs (c)(1) through(c)(10) of this section.

40 CFR Section 63.11564(c)

The Permittee shall comply with the requirements of the General Provisions (40CFR pt. 63, subp. A) according to Table 5 of this subpart.

40 CFR Section 63.11565

Total Particulate Matter: less than or equal to 0.06 lbs/ton of asphalt roofing productmanufactured, orPolycyclic Aromatic Hydrocarbons (PAH): less than or equal to 0.0002 lbs/ton ofasphalt roofing product manufactured. This limit applies to coater-only productionlines (Line 3).


Total Particulate Matter: less than or equal to 0.36 lbs/ton of asphalt roofing productmanufactured or,Polycyclic Aromatic Hydrocarbons (PAH): less than or equal to 0.0009 lbs/ton ofasphalt roofing product manufactured. This limit applies to combinedsaturator/coater production lines (Lines 1 and 2).


D. PERFORMANCE TESTING hdr

Given the characteristics of the inlet gas streams, If the Permittee is required toconduct performance test(s) on CE 004 the Permittee shall not conductperformance test(s) for control efficiency.

Minn. R. 7007.0800, subp. 2

E. NESHAP LLLLL REQUIREMENTS hdr


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-38

The Permittee shall comply with the requirements 40 CFR pt. 63, subp. LLLLL by 3years after startup of the GP 015 asphalt blowing operaiton, as defined in GP 015of this permit. Until the Permittee is in compliance with 40 CFR pt. 63, subp. LLLLLthe Permittee shall be in compliance with the requirements of 40 CFR pt. 63, subp.AAAAAAA of CE 004.


Upon compliance with 40 CFR pt. 63, subp. LLLLL, the CE 004 is still an affectedfacility under 40 CFR pt. 60, subp. UU, but is no longer required to comply with therequirements of subp. UU.

The Permittee shall apply for the appropriate permit amendment as applicable toincorporate the requirements of 40 CFR pt. 63, subp. LLLLL for the units in CE 004.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-39

Subject Item: CE 010 Mist Eliminator - Low Velocity, i.e., V<250 Ft/Min

Associated Items: EU 016 Sealant Pan/Independence Windseal Applicator

What to do Why to do itOperate and maintain control equipment for Total Particulate Matter: greater thanor equal to 92 percent control efficiency


Operate and maintain control equipment for Particulate Matter < 10 micron: greaterthan or equal to 92 percent control efficiency


Operation and Maintenance of control equipment: The Permittee shall operate andmaintain the mist eliminators according to the facility O&M plan and the controlequipment manufacturer's specifications.

Minn. R. 7007.0800, subp. 2


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-40

Subject Item: CE 047 Thermal Oxidizer

Associated Items: EU 091 Blowing Still #1



GP 015 Blowstills and New Thermal Oxidizer

What to do Why to do itThe Permittee is authorized to install and operate equipment described by CE 047,at any time during the life of Air Emissions Permit No. 13900013-007.

Minn. R. 7007.0800, subp. 2

The Permittee shall operate CE 047 at all times that EU 091, 092, or 093 areoperating.


CE 047 Operation, Shutdown, and Breakdown: The Permittee shall not blowasphalt when CE 047 is not in operation. During CE 047 shutdowns andbreakdowns, emissions from the blowing stills shall continue to be routed throughthe knockout tank for PM10 control.


The Permittee shall comply with one of the two following limits (combustionefficiency limit or total hydrocarbons limit). The Permittee shall maintain recordson-site at all times documenting the limit with which they are complying.

40 CFR Section 63.8684(a) & part 63 subp. LLLLLTable 1; Minn. R. 7011.7940

Combustion efficiency: greater than or equal to 99.5% for CE 047. 40 CFR Section 63.8684(a) & part 63 subp. LLLLLTable 1; Minn. R. 7011.7940

THC (Total Hydrocarbons): less than or equal to 20 parts per million volumetric drybasis at 3% oxygen at SV 058.

40 CFR Section 63.8684(a) & part 63 subp. LLLLLTable 1; Minn. R. 7011.7940

CE 047 Combustion Zone Temperature: maintain the 3-hour average combustionzone temperature at or above the temperature measured during the most recentperformance test. If the 3-hour combustion zone temperature falls below the valuemeasured during the most recent performance test, the Permittee shall takecorrective action as soon as possible to restore the temperature to at least therequired minimum, according to the Startup, Shutdown, and Malfunction Plan(SSMP). Prior to the first performance test, the Permittee shall maintain the 3-houraverage combustion zone temperature at or above the minimum temperature limitprovided by the manufacturer.

The Permittee has two options (see below) to calculate the 3-hour averagecombustion zone temperature.

Option1: install and use an automatic system to measure, give warning, andcalculate the 3-hour average temperatures, or

Option 2: manually record and calculate the 3-hour average temperatures.

40 CFR Section 63.8684(b) & part 63 subp. LLLLLTable 2; Minn. R. 7011.7940; Section 63.6(e)(1)(ii)


40 CFR Section 63.8685(a); Minn. R. 7011.7940


40 CFR Section 63.8685(c) ; Minn. R. 7011.7940

Monitoring: The Permittee shall install, operate, and maintain a continuousparameter monitoring system (CPMS) to measure CE 047 combustion zonetemperature on a 3-hour average according to the requirements of Section63.8688(a) and (b).

40 CFR Section 63.8688(a) and (b); Minn. R.7011.7940

Site-Specific Monitoring Plan: develop and implement a written site-specificmonitoring plan according to the provisions in Section 63.8688(g) and (h).The monitoring plan must address:- The installation of the CPMS sampling probe or other interface at a measurementlocation relative to each affected process unit such that the measurement isrepresentative of control of the exhaust emissions;- performance and equipment specifications for the sample interface, the pollutantconcentration or parametric signal analyzer, and data collection and reductionsystem;- performance evaluation procedures and acceptance criteria;- ongoing operation and maintenance procedures in accordance with the generalrequirements of Section 63.8(c)(1), (c)(3), (c)(4)(ii), (c)(7), and (c)(8);-ongoing data quality assurance procedures in accordance with the generalrequirements of Section 63.8(d); and

40 CFR Section 63.8685(d) and 63.8688(g) and (h);Minn. R. 7011.7940


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-41

Site-Specific Monitoring Plan Continued:-On-going recordkeeping and reporting procedures in accordance with the generalrequirements of Section 63.10(c), (e)(1), and (e)(2)(i);

40 CFR Section 63.8685(d) and 63.8688(g) and (h);Minn. R. 7011.7940

The Permittee shall conduct a performance evaluation of the CPMS in accordancewith Section 63.8688(i) and the site-specific monitoring plan, and operate andmaintain the CPMS in continuous operation according to the site-specificmonitoring plan.

40 CFR Section 63.8688(i) and (j); Minn. R. 7011.7940

Except for monitor malfunctions, associated repairs, and required quality assuranceor control activities, the Permittee shall monitor continuously (or collect data at allrequired intervals) at all times that the affected source is operating. This includesperiods of startup, shutdown, and malfunctions when the affected source isoperating

The Permittee shall not use data recorded during monitoring malfunctions,associated repairs, and required quality assurance or control activities in dataaverages and calculations used to report emission or operating levels, nor maysuch data be used in fulfilling a minimum data availability requirement, if applicable.The Permittee shall use all the data collected during all other periods in assessingthe operation of the control device and associated control system.

40 CFR Section 63.8690(b) and (c); Minn. R.7011.7940

Daily Monitoring: The Permittee shall physically verify the operation of thetemperature recording device at least once each operating day to verify that it isworking and recording properly. The Permittee shall maintain a written record of thedaily verifications.

Minn. R. 7007.0800, subps. 4 and 5

The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records the combustion chamber temperature of thethermal oxidizer. The monitoring device shall have a margin of error less than thegreater of +/- 0.75 percent of the temperature being measured or +/- 2.5 degreesCelsius. The recording device shall also calculate the three-hour rolling averagecombustion chamber temperature.

Minn. R. 7007.0800, subps. 4 and 5

Quarterly Inspections: At least once per calendar quarter, the Permittee shallinspect the control equipment internal and external system components, includingbut not limited to the refractory, heat exchanger, and electrical systems. ThePermittee shall maintain a written record of the inspection and any correctiveactions taken resulting from the inspection.

Minn. R. 7007.0800, subps. 4, 5, and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain the thermal oxidizer in accordance withthe Operation and Maintenance (O & M) Plan. The Permittee shall keep copies ofthe O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

Performance Test: due 180 days after Initial Startup of EU 091, EU 092, or EU 093(whichever starts up first). Testing shall be for total hydrocarbon emissions fromSV 058 or percent combustion efficiency of CE 047 and shall meet therequirements of 40 CFR Section 63.8687 and table 3 in subp. LLLLL. Refer topage A-2 for additional requirements pertaining to performance testing.

40 CFR Sections 63.8686(c) & 63.8687 & pt. 63, subp.LLLLL Table 3; Minn. R. 7011.7940; Minn. R.7007.0800, subp. 2

Oxidizer Fuel Usage hdr




Applicability of 40 CFR Part 60, Subpart UU: CE 047 is subject to 40 CFR pt. 60,subp. UU, and 40 CFR pt. 63, subp. LLLLL. Therefore these emission units arerequired to comply only with the provisions of pt. 63, subp. LLLLL.



13900013 - 007

Facility Name:

Permit Number:

05/28/13A-42

Subject Item: TK 028 Finished Coating Storage Tank

Associated Items: CE 004 RTO (SV 004)

GP 011 Standards of Performance for Storage Vessels

What to do Why to do itThe Permittee is authorized to install and operate TK 028, as defined by permit, atany time during the life of Air Emissions Permit No. 13900013-007. These unitsshall meet all the requirements of this permit.

Minn. R. 7007.0800, subp. 2

Process Throughput: less than or equal to 200,000 tons/year to be calculated bythe 15th day of each month for the previous 12-month period as described in GP015 of this permit.

This limit applies to the asphalt throughput for TK 028.



The Permittee shall vent emissions from TK 028 to a control device meeting therequirements of CE 004 for this permit at all times that TK 028 is in operation.

40 CFR Section 60.112b(a); Minn. R. 7011.1520(C);Minn. R. 7007.0800, subps. 2 and 14

NSPS Subpart Kb Requirements hdr

The storage vessel shall be equipped with a closed vent system and control deviceas described below and meeting the requirements of 40 CFR Section60.112b(a)(3).

40 CFR Section 60.112b(a); Minn. R. 7011.1520(C)

The closed vent system shall be designed to collect all VOC vapors and gassesdischarged from the storage vessel and operated with no detectable emissions asindicated by an instrument reading of less than 500 ppm above background andvisual inspections, as determined in part 60, subpart VV, Section 60.485(b).

40 CFR Section 60.112b(a)(3)(i); Minn. R.7011.1520(C)

The control device shall be designed and operated to reduce inlet VOC emissionsby 95 percent or greater.

40 CFR Section 60.112b(a)(3)(ii); Minn. R.7011.1520(C)

Control Device Operating Plan -The Permittee is exempt from the requirements of Section 60.8, but shall submit forapproval by the Administrator as an attachment to the notification required bySection 60.7(a)(1) an operating plan containing the following information:1) documentation demonstrating that the control device will achieve the requiredcontrol efficiency during maximum loading conditions, including flow and VOCcontent under varying liquid level conditions (dynamic and static) andmanufacturer's design specifications for the control device. If the control device orthe closed vent capture system receives vapors, gases, or liquids other than fuelsfrom sources that are not designated sources under this subpart, the efficiencydemonstration is to include consideration of all vapors, gases, and liquids receivedby the closed vent capture system and control device.

40 CFR Section 60.112b(c)(1); Minn. R. 7011.1520(C)

Control Device Operating Plan Continued -If an enclosed combustion device with a minimum residence time of 0.75 secondsand a minimum temperature of 816 degrees Celsius is used to meet the 95 percentrequirement, documentation that those conditions will exist is sufficient to meet therequirements or this paragraph.2) A description of the parameter or parameters to be monitored to ensure that thecontrol device will be operated in conformance with its design and explanation ofthe criteria used for selection of that parameter (or parameters).


The Permittee shall operate the closed vent system and control device and monitorthe parameters of the closed vent system and control device in accordance with theoperating plan submitted to the Administrator described above and in accordancewith Section 60.112b(c)(1), unless the plan was modified by the Administratorduring the review process. In this case, the modified plan applies.


The Permittee shall maintain copies of all reports and records required by 40 CFRsubp. Kb, except for the records required by 40 CFR Section 60.115b(c)(1) for atleast 2 years. The record required by Section 60.115b(c)(1) will be kept for the lifeof the control equipment.

40 CFR Section 60.115b; Minn. R. 7011.1520(C)

The Permittee shall maintain a record of the operating plan for the life of the controlequipment.


The Permittee shall maintain records of the measured values of the parametersmonitored in accordance with Section 60.113b(c)(2).


For the life of the source, the Permittee shall keep readily accessible recordsshowing the dimension of the storage vessel and an analysis showing the capacityof the storage vessel.

40 CFR Section 60.116b(b); Minn. R. 7011.1520(C)


13900013 - 007

Facility Name:

Permit Number:

05/28/13A-43

The Permittee may use available data on the storage temperature to determine themaximum true vapor pressure as determined below:

For vessels operated above or below ambient temperatures, the maximum truevapor pressure is calculated based upon the highest expected calendar-monthaverage of the storage temperature. For vessels operated at ambienttemperatures, the maximum true vapor pressure is calculated based upon themaximum local monthly average ambient temperature as reported by the NationalWeather Service.

40 CFR Section 60.115b(e)(1); Minn. R. 7011.1520(C)

For crude oil or refined petroleum products the vapor pressure may be obtained bythe following:1) Available data on the Reid vapor pressure and the maximum expected storagetemperature based on the highest expected calendar-month average temperatureof the stored product may be used to determine the maximum true vapor pressurefrom nomographs contained in API Bulletin 2517, unless the Administratorspecifically requests that the liquid be sampled, the actual storage temperaturedetermined, and the Reid vapor pressured determined from the samples(s).2) The true vapor pressure of each type of crude oil with a Reid vapor pressure lessthan 13.8 kPa or with physical properties that preclude determination by therecommended method is to be determined from available data and recorded if theestimated maximum true vapor pressure is greater than 3.5 kPa.


For other liquids, the vapor pressure, the Permittee shall determine the vaporpressure using one of the following:1) standard reference texts;2) ASTM D2879-83, 96, or 973) an appropriate method approved by the Administrator; or4) calculated by an appropriate method approve by the Administrator.


NSPS Subpart UU Requirements hdr

Opacity: less than or equal to 0 percent opacity from exhaust gases from TK 028(SV 004), except for one consecutive 15- minute period in any 24-hour period whenthe transfer lines are being blown for cleaning. The control device shall not bebypassed during this 15-minue period.

This limit applies within 60 days after achieving the maximum production rate atwhich the affected facility will be operated, but no later than 180 days after initialstartup of such facility.

40 CFR Section 60.472(c); Minn. R. 7011.0950

TABLE B: SUBMITTALSFacility Name: CertainTeed Corp

Permit Number: 13900013 - 007

05/28/13B-1

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: CertainTeed Corp


05/28/13B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Notification of compliance status due 60 days after Performance Test. ThePermittee shall submit the Notification ofCompliance Status and results of theperformance tests according to 40 CFRSection 63.9(h)(2)(ii).

GP015

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of any GP015 emission unit.

GP015

Notification due 120 days after Startup of GP 015 units.

The Permittee shall submit an InitialNotification in accordance with 40 CFRSection 63.9(b).

GP015

Performance Test Notification (written) due 60 days before Performance Test isscheduled to begin, as required in 40 CFRSection 63.7(b)(1).

GP015

Testing Frequency Plan due 60 days after Performance Test todetermine CE 047 total hydrocarbonemissions or percent combustion efficiency.The plan shall specify a testing frequencybased on the initial CE 047 performance testresults and MPCA guidance. Futureperformance tests based on 12-month,36-month, and 60-month intervals, or asapplicable, shall be required upon writtenapproval of the MPCA.

CE047

TABLE B: RECURRENT SUBMITTALSFacility Name: CertainTeed Corp


05/28/13B-3

What to send When to send Portion of Facility AffectedSemiannual Compliance Report due 31 days after end of each calendar

half-year following Startup of any GP 015units.

The Report shall contain the information listedin Table A under GP 015 and Section63.8693(c) and (d).

The first compliance report must cover theperiod beginning on the compliance (start upof GP 015 units) and ending on June 30 orDecember 21, whichever date is the first datefollowing the end of the first calendar half yearafter the compliance date.

Each subsequent compliance report mustcover the semiannual reporting period fromJanuary 1 through June 30 or the semiannualreporting period from July 1 throughDecember 31.

This report may be submitted with theSemiannual Deviations Report required by 40CFR Part 70 and contained in Table B.

GP015

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 09/28/2000 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationsoccurred, the Permittee shall submit the reportstating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 09/28/2000 (for the previous calendaryear). The certification shall be submitted ona form approved by the Commissioner, both tothe Commissioner, and to the U.S. EPAregional office in Chicago. This certificationcovers all deviations experienced during thecalendar year.

Total Facility

Report due 31 days after end of each calendar yearstarting 02/03/2004. The report shall describeall No. 2 fuel oil combustion unit equipmentchanges made at the facility. This report shallbe submitted with the annual compliancecertification submitted to the Commissioner.See the requirement titled "Reporting -Changes of No. 2 Fuel Oil Combustion Units"in subject item Total Facility in Table A of thispermit for more information regarding thecontent of this report.

Total Facility

APPENDIX A: Insignificant Activities Required to be Listed and General Applicable Requirements Facility Name: CertainTeed Corp Permit Number: 13900013‐007

Minn. R. 7007.1300, subp.

Rule Description of the Activity General Applicable Requirement

3(A) Fuel Use: Space heaters fueled by kerosene, natural gas, or propane

Minn. R. 7011.0515

Two space heaters (natural gas fuel): 200,000 Btu/hr

3(I)(2), (3) Individual emission units at a stationary source, each of which have the potential to emit the following pollutants in amounts less than: 2,000 pounds per year of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, VOCs (including hazardous air pollutant‐containing VOCs), and ozone, and less than 1,000 tons per year of CO2e.

Line #1/#2 & Line #3 shrink wrap heaters Direct fired make up air unit # 8 (natural gas fuel): Sum = 3.0 MMBtu/hr Line #3 Mat Pre‐heater

Minn. R. 7011.0610

Horizon Concentrate Mixer Line #1 & Line #2 Windseal Use Tanks Inkjet Printers Line #1 & Line #2 Dry Mat Loopers Line #2 Nail Line Paint Applicator Felt Mill Paint Applicator Laminant/Windseal Mixer Windseal Mixer Independence Laminant Adhesive Applicator Horizon Asphalt Applicator Horizon Batch Mixer Granule Truck Dump Headlap Truck Dump Granule Silos #1‐#20 Off‐road Equipment Diesel Tank 6 Part Washers Polymer “Super Sack” unloading Line 1 Laminate Pans Line 2 Sealant Pan

Minn. R. 7011.0715

Minn. R. 7007.1300, subp.

Rule Description of the Activity General Applicable Requirement

Offline Laminate Pan Emergency Generator Diesel Tank

Gluing Operations Laminant Swell Tank Ferric Chloride Storage and Use Tank 3 Natrual Gas Fired Heaters (for TKs 025, 026, and 028)

3(J) Fugitive dust emissions from unpaved entrance roads and parking lots, except from a stationary source applying for an Option D registration permit under part 7007.1130.

Minn. R. 7011.0150

Roads and parking lots: Class 5 gravel

4 Line 1 and Line 2 Paint Applicators Minn. R. 7011.0710/0715

APPENDIX B: Estimates of Air Emissions from Asphalt Storage Tanks and Truck Loading Facility Name: CertainTeed Corp Permit Number: 13900013‐007

Estimates of Air Emissions from AsphaltStorage Tanks and Truck Loading

David C. TrumboreAsphalt Technology Laboratory. Owens Corning, Summit, IL 60501

Title V of the 1990 Clean Air Act requires the accurateestimation of emissionsprocesses, and places theburden

rom all U.S. manufacturing of proof for that estimate

on the process owner. This paper is published as a tool to assist in the estimation of air emissions from hot asphaltstorage tanks and asphalt truck Loading operations. Dataare presented on asphalt vapor pressure, vapor molecularweight, and the emission split between volatile organiccompounds and particulate emissions that can be usedwith AP-42 calculation techniques to estimate airemissions from asphalt storage tanks and truck loadingoperations. Since current AP-42 techniques are not validin asphalt tanks with active fume removal, a differenttechnique for estimation of air emissions in those tanks,based on direct measurement of vapor space combustiblegas content, is proposed. Likewise, since AP-42 does notaddress carbon monoxide or hydrogen sulfide emissionsthat are known to be present in asphalt operations, thispaper proposesFinally,

techniques for estimation of those emissions.data are presented on the effectiveness of fiber bed

jilters in reducing air emissions in asphalt operations.

INTRODUCTIONThe use of asphalt is prevalent throughout recorded

history. It is produced in refinery distillation towers andsolvent extraction units. Asphalt is modified by severalmeans: reacting with oxygen in blowing operations toproduce roofing asphalts, emulsifying to produce anaqueous liquid at ambient temperature, blending withsolvents to make asphalt cutback, or blending or evenreacting with polymers to make polymer modified asphalt.In all these cases the asphalt is stored in tanks, usuallyfixed roof tanks, and is loaded into trucks to ship tocustomers.

Title V of the 1990 Clean Air Act required the accurateestimation of emissions from all U.S. manufacturingprocesses, and placed the burden of proof for that estimateon the process owner. In response to Title V, OwensCorning analyzed options for estimating emissions from

250 Winter 1999

asphalt tanks and loading operations and this paper is theresult of that study. In particular, attempts have been madeto develop data to be used with existing calculationmethods to estimate air emissions in asphalt operations, todevelop calculation schemes that work when existingmethods cannot be used, and to expand the number ofpollutants estimated. The techniques described in thispaper have been used by Owens Corning to estimateasphalt emissions from their asphalt plants for many Title Vpermit applications.

Owens Corning also evaluated appropriate emissionfactors for the asphalt blowing process and that analysis hasbeen published [I].

The Emission Factor and Inventory Group in the U. S.Environmental Protection Agency’s (EPA) Office of AirQuality Planning and Standards develops and maintains adatabase of emission factors and a series of calculationmethods for estimating air emissions from manufacturingprocesses. These emission factors are published in a seriesknown as AP-42 [2]. One technique published in AP-42calculates hydrocarbon emissions from a fixed roof tankstoring petroleum products [3], and another calculatesemissions for loading trucks with petroleum products [4].These techniques require data on asphalt vapor pressureand the molecular weight of the -asphalt vapor. Thecalculations result in an estimate of the amount ofhydrocarbons emitted from the process. To complete theemission estimate, these hydrocarbons need to be split intoparticulate emissions (PM) and volatile organic compounds(VOC), and any control device collection or destructionefficiencies need to be applied.

In the AP-42 calculation of emissions from fixed rooftanks it is assumed that the motive force pushing vapor outof the tank comes from either the pumping of liquid intothe tank or the expansion of tank contents due totemperature changes. For tanks with an active ventilationsystem this assumption is invalid and a different method ofemission estimation is required. This is especially true if anair sweep is used to control the vapor space composition to

Environmental Progress (Vol.18, No.4)

No.4)

prevent explosive conditions [5,6]. A technique to estimateemissions from these actively controlled tanks is describedin the section of this paper on non AP-42 estimates.

AP-42 EMISSION ESTIMATING TECHNIQUES FOR ASPHALT EQUIPMENTPassive vented hot asphalt tanks: AP-42 for fixed roof

petroleum tanks can be used to calculate total hydrocarbonemissions from asphalt and oil tanks that are passivelyvented to the atmosphere. This AP-42 calculation, simplystated, determines the amount of hydrocarbon in the tankvapor space from the vapor pressure of the material in thetank at the liquid surface temperature, and then calculatesthe amount of vapor forced out of the tank due to liquidbeing actively pumped into the tank (working losses), ordue to thermal expansion or contraction of tank contentsdriven by ambient temperature changes (breathing losses).The result is an actual weight of hydrocarbon emissions ina specified time period. A detailed description of the tankcalculations is available from th e EPA web site [3]. The AP-42 calculation requires a vapor pressure versus temperaturecurve for the asphalt, and also estimates of the vapor phasemolecular weight and partition of hydrocarbons into VOC and particulate, in addition to process data like asphaltthroughput. temperature. and tank level. If the tankpassively breathes through a control device, then theappropriate control efficiency is applied to the VOC andparticulate emissions calculated from AP-42.

Hot Asphalt Loading: The AP-42 calculation forhydrocarbon emissions from truck or rail tank car loadingof asphalt is done by estimating the amount of evaporationduring the loading process. The estimate takes into accountthe turbulence and vapor liquid contact induced by themethod of loading, i.e . submerged versus splash loading.The calculation result is an emission related to the numberof tons of material loaded into the truck. Vapor pressureversus temperature c urve s, , temperature of loading, andthroughputs are key variables in this calculation. Again, thehydrocarbon emission resulting from this calculation needsto be split into pa rticu la tes s and VOCs and control devicecollection and destruction efficiencies need to be applied. Adetailed description of the loading calculations is availablefrom the EPA web site [4].

DATA NEEDED FOR APPLICATION OF AP-42 TO ASPHALT EQUIPMENTVapor Pressure: Information on asphalt vapor pressure as a

function of temperature is not readily available in theliterature and its measurement is not common. However,these data are essential to use AP-42 calculations forestimating asphalt tank and loading emissions. Asphaltsfrom different crude oil sources and from differentprocesses will differ in composition and vapor pressure. Inthe extreme, every residual material used in asphaltprocessing would need to be measured for vapor pressureat multiple temperatures. This would entail a prohibitive

estimates. To provide a cost effective solution to thisproblem for its emission calculations, Owens Corning has

Environmental Progress (Vol. 18 , No.4)

characterized the vapor pressure of three basic classes ofasphalt materials. chosen by their processing history. Anestimate of the vapor pressure of each asphalt class wasmade by measuring asphalts from multiple crude oilsource s in each class and using the average vapor pressureat each temperature in a regression to generate one vaporpressure equation for tha t class. The three classes of asphaltchosen for this analysis follow.

Flux asphalts. or vacuum tower bottoms that can bein the asphalt blowing process to make

specification roofing asphalts. These materials generallyhave a higher vapor pressure than paving asphalts.Paving asphalts, or vacuum tower bottoms that meetpaving specifications.Oxidized asphalt, or vacuum tower bottoms that havebeen reacted with oxygen in the asphalt blowing processto increase their softening point and viscosity. Typicalsoftening points are greater than 19 0°F (88°C) Thesematerials are also called air blown asphalts and are usedextensively in the roofing industry. They generally havelower vapor pressure than the other two classes.

Va por pressure measurements described in this paper wereclone by the Phoenix Chemical Lab in Chicago using theIsoteniscope (ASTM D2879).

To facilitate computer calculations it is desirable to developan equation that accurately describes the relationship of vaporpressure and temperature. Thermodynamic treatment of thedependence of vapor pressure on temperature has led to theClausius modification of the Clapeyron equation [7].

Clausius Clapeyron Treatment of Vapor Pressure Data

In P = a + b/T

Where: P is the equilibrium vapor pressureof the liquid in question,a & b are constants. andT is the absolute temperature of the liquidin question.Values of a & b depend on the choice ofpressure and temperature units.

Table 1 and Figure 1 give an example of the agreement ofthis equation with vapor pressure data for oxidized asphaltsfrom 13 sources around the country. In Figure 1 , vaporpressure of each asphalt is plotted versus temperature to show

each individual asphalt’s data to the Clausius Clapeyronrela tionship .. The correlation coefficients in Table 1 indicatethat the agreement of this equation to all individual asphaltvapor pressure ve rsus temperature data is excellent, withcorrelation coefficients for the individual asphalts greater than0.9999. The agreement is also excellent for the individualasphalts making up the other two asphalt classes. Table 1 also presents the methodology to choose constants to use with the

Winter 19 99 251

amount of testing for minimal gain in accuracy of emission

the differences between asphalt's data to the Clausius Clapeyron

used

Table l.Vapor Pressure Data for Oxidized Asphalts

Temperature (°F1) All Data in mm Hg2

200 250 350 400 450 500 600 r value3

Plant A 0.39 2 7.9 26 77 550Plant C 0.42 2 7.9 26 670

H 0.43 2 7.7 25z: 180

165 410 590Plant I 0.44 1.9 7.2 22 59 140 340 680PlantK 0.43 1.7 6.1 18.5 50 115 205 510 680PlantM 0.28 1.2 4.6 15 41 97 210 640PlantN 0.19 0.88 3.5 12 34 85 190 430 590PlantP 0.46 1.8 6 44 96 195 410 710Plant0 0.11 0.47 1.7 13.2 34 74 142Plant J 0.16 0.64 2.2 6.2 14.8 36 72 135PlantS 0.28 1.05 3.3 9.4 23 50 105 200 350PlantS 0.28 1 3.2 10 25 58PlantX 0.1 0.4 1.5 4.7 12.5 33 75 152Class Standard 0.22 0.91 3.2 9.5 24.9 58.8 127 254 351 477Average 0.33 0.75 2.6 7.9 22.3 54.7 122 284 634 347

13459 b in Clausius Clapeyron curve for average vapor pressure data

1. 1 °C = (°F - 32) * 5/9 2. 1 Pa = 0.0075 mm Hg

the r value is for the fit of the vapor pressure data to the Clausius Clapeyron Equation

-0.999922929-0.999934558-0.999939281-0.999945804-0.999660554-0.999948167-0.999965421-0.999948079-0.999916578-0.999838114-0.999986213-0.999875798-0.999930649

-0.994026635

1000

100

FIGURE 1.Oxidized Asphalt Vapor Pressure Data in Clausius Clapeyron Format

9 10 11 12 13 14 16

Asphalt 300 550 575

225400

460

5.217.5

Plant

Vp

18.86 a in Clausius Clapeyron curve for average vapor pressure data

10,000 * 1/T (°R)215

0.1

Environmental Progress (Vol.18, No.4)252 Winter 1999

I II I

A Plant A tI w-e I I

I I II I

A Plant H0 Plant Ix Plant K0 Plant M+ Plant N- Plant P- Plant 0l Plant Jm Plant S

1

0.1

2. 1 ° C = (° F-32)*5/9I / II AI .

Temperature (°F2)

1000

FIGURE 2. Oxidized Asphalt Vapor Pressure Data in Double Log Format

Clausius Clapeyron equation to calculate 3 representativevapor pressure at any temperature for the class of oxidizedasphalts. Essentially the technique consists of averaging thevapor pressures of the 13 asphalts at each temperature andthen using those averages to curve fit the data to the desiredequation. This gives higher values and is more conservativethan averaging the vapor pressures after the log transformationis made. The standard curve is developed by using thisregression equation to calculate vapor pressures at differenttemperatures. and for the oxidized class that data is indicated

in Table 1 and also by the straight line in Figure 1.The form of the Clausius Clapeyron equation is somewhat

cumbersome to use, especially in graphical form, and so analternative equation was developed which used a log/logrelationship to characterize the data.

Log Log Treatment of Vapor Pressure Data

log Vp = A * log(T) + B

Vp is the vapor pressure.T is the temperature (not absoluteA & B are constants

Analyses of oxidized asphalts using this equation toestablish the standard curve are presented in Figure 2. Theagreement is also very good. w ith correlation coefficients forthe individual asphalts greater than 0.999. Again all three

Class ofAsphalt a

Averagen correlation

coefficient

FluxPavingOxidized

18.2891 12725.60 10 -0.9997620.7962 15032.54 8 -0.9998518.8642 -0.99991

For a log log Equationlog Vp (mm Hg) = A * log T (°F 3) + B

Class ofAsphalt a

Averagen correlation

coefficient

Flux 7.0850 -16.8999 10 0.99736Paving 7.8871 -19.0600 8 0.99965Oxidized 7.0607 -16.9570 13 0.99981

Table 2. Vapor Pressure Correlations for Asphalts

For the Clausius Clapeyron EquationIn Vp (mm Hg1) = a - b/T( R 2

Environmental Progress (Vol.18, No.4) Winter 1999 253

13458.56 13

where

100

55

classes of asphalts show similar agreement, Pressure Summary: Table 2 gives a summary of the

regression constants to be used in either of the equationsdiscussed above to calculate the vapor pressure for the threeclasses of asphalt at any temperature. Also indicated are thenumber of asphalts that were used to develop the equationfor each class. and the average correlation coefficientcharacterizing the agreement of the data to the form of theequation for each individual asphalt in the class.

In AP-42 for tanks, the correct temperature to use in theTable 2 equations is the asphalt surface temperature in thetank. Since the surface temperature is rarely. if ever, knownwith certainty, the bulk temperature should be used toestimate emissions. In a well mixed tank the bulktemperature will be a good approximation of the surfacetemperature. Where mixing is not effective the surface will belower in temperature than the bulk and the use of the bulktemperature will give a conservative estimate of emissions. In

for loading trucks, the bulk temperature of the tankfrom which material is being loaded provides a good estimateof the actual loading temperature.

Asphalt Vapor Molecular Weight: Asphalt vapor molecularweight was determined by separation and analysis of theorganic species in the vapor spaces of 12 tanks storingdifferent types of asphalt. These profiles were obtained bydrawing known volumes of the tank vapor space through acharcoal tube, sealing and freezing the tube to limit loss ofthe sample, and then desorbing the organic material from thecharcoal with carbon disulfide and analyzing with gaschromatography using packed columns and flame ionizationdetectors. Analyses were performed by CHEMIR Laboratoryin St. Louis. Quantitative standards were used to identify theamount of individual normal alkanes from n-pentane to n-pentadecane. Peaks eluting between the normal alkanes wereassumed to he isomers of the hordering alkanes, especiallycyclic isomers of the lower carbon number alkane, andbranched or unsaturated isomers of the higher carbonnumber alkane. The molecular weights for the n-alkanespecies and molecular weight estimates for the intermediatespecies were used with the amount of that material measuredto calculate a weighted average vapor molecular weight foreach tank, and then the twelve tanks were averaged togetherto get the molecular weight used for hot asphalt vapors in theAP-42 calculations. The result was a molecular weight of 84,which is used with all three classes of asphalts. This analysisis detailed in Table 3. Not enough data were available toassign different values to the three asphalt classes,however, from the table the unblown flux material in twotanks gave molecular weights which bracketed theaverage. as did the two paving blend stocks.

This analysis gave a lower molecular weight for thevapor space of asphalt tanks than for several petroleumsolvents and fuel oils. This seems like a contradictionconsidering the nature of asphalt as the residuum materialcollected upon distillation. This contradiction is resolvedby considering that asphalt is not a uniform materialchemically and that the lower molecular weight materials

AP-42

Vapor

Environmental Progress (Vol.18, No.4)254 Winter 1999

Table 4. PM/VOC Partition Data fromOwens Corning Testing

AsphaltPlant 0

Tank A Tank B Tank c

VOC Test 0.73PM Test 0.21VOC Fraction 0.78

1.16 0.980.38 0.300.75 0.77

lb/hr1

lb/hr

Koofing Plant S Coater Results:Measured at different points. Data indicated 22% of total

emission (VOC + PM) was PM and 78% was VOC

1. 1 kg/sec = 0.0076 * lb/hr

are preferentially evaporated More importantly. it has alsobeen established that thermal cracking of asphalt in hotstorage tanks creates low molecular weight materials whichaccumulate in the tank vapor spaces [5,6].

Asphalt Liquid Molecular Weight: The actual bulk asphaltmolecular weight is not needed for AP-42 calculations ofemissions from tanks or loading racks. but is useful in somecalculations that are beyond the scope of this paper, forexample using Raoult's law for crude estimates of emissionsfrom mixtures of asphalt and other materials. Molecularweight of bulk asphalt is not a well defined materialproperty, both because asphalt is such a complex mixtureand because intermolecular interactions in the asphaltcreate the appearance of high molecular weight in manymeasurement techniques. The measured molecular weightis usually not truly representative of the covalently bondedmolecules, The difficulty in getting accurate asphaltmolecular weight measurements is extensively discussed inthe literature [8, 9, 10]. The use of Gel PermeationChromatography[8], Field-Ionization Mass Spectrometry [8].Vapor Pressure Osmometry [8,9,10], and Freezing PointDepression [10] have all been evaluated as methods formeasuring the molecular weight of asphalt or itscomponents. The topic is further complicated for emissioncalculations by the fact that many of the measurementshave been made on fractions of the asphalt and not on theneat asphalt. In general. for very rough estimates, a valueof 1000 [8] can be used for the molecular weight of bulkasphalt. This value should be used with the understandingthat there is much variation in the true molecular weightand in the tendency for intermolecular interaction due topetroleum crude source and processing conditions.

Partition of hydrocarbon emissions that are particulate and VOC:Because of its heterogeneous nature, asphalt fumes arevaried and may have components that are classified ascondensed particulates (PM) or as volatile organiccompounds (VOCs). It m-as evident in analyzing asphaltfume results that the difference between these two classesof criteria pollutants is really defined by the method used to

test for the pollutants. Estimation schemes described in thispaper calculate the sum of both (AP-42) or just the VOCcomponent (non-AP-42 technique described below), andthe partition needs to be understood to provide the bestestimated values of the two pollutants. To that end. testshave been done on both asphalt tank exhausts in anOwens Corning asphalt plant and on the asphalt shinglecoater exhausts in an Owens Corning roofing plant usingEPA Methods 5 & 25A sampling protocols which defineVOC and PM emissions in hydrocarbon fumes. Underconditions specified by the test method some fraction ofthe fume is captured on a filter and this is defined as aparticulate emission, while a fraction of the hydrocarbonemission passes through the filter and this is defined as aVOC emission. The results of the split in the totalhydrocarbon fume between VOC and particulate wereapproximately 78% VOC and 22% particulate in the asphaltequipment. in spite of the basic difference between ashingle coater and a storage tank. Data from these tests aregiven in Table 4.

NON AP-42 CALCULATIONS TECHNIQUES:Estimation of VOC and particulate emissions from tanks with

fume control: Many asphalt tanks have their fumes activelycollected and treated in a control device, either a fiber bedfilter or an incinerator. In these tanks it is common atOwens Corning to allow some air to pass through the tankvapor spaces to create an air sweep that controlscombustible fumes well below the lower explosion limit(LEL) in order to prevent explosions. Because of the activeremoval of fumes in these systems, and the bleeding of airinto the vapor space. the assumptions underlying the AP-42tank calculations no longer apply. Specifically the drivingforce for the flow of fumes out of the tank is no longer justthe working and breathing losses. and an alternativemethod of emission calculation is needed.

Several years ago safety concerns with asphalt tanksprompted Owens Corning to institute the periodicmeasurement of the combustible gas concentration in allasphalt tank vapor spaces [5]. With the advent of Title V itwas recognized that these measurements could be used toestimate VOC emissions. As part of the safety program.techniques were developed to make this routinemeasurement simple and easy. and the result was the useof Mine Safety Appliance (MSA) combustion meters toquantify the hydrocarbon concentration in terms of thefraction (or %) of the LEL. This technique and the validationof its accuracy has been described in detail in a separatepublication [6]. In addition to the combustible gasmeasurement, a slightly more complicated technique is alsodescribed and validated that gives the concentration ofethane, methane. and other light combustible gasesseparate from propane and larger hydrocarbons. Thistechnique involves using a charcoal tube in the linebetween the tank and the MSA meter. The charcoal tubeadsorbs all propane and higher hydrocarbons [6], with theresultant reading at the MSA meter due only to the lighter


Table 5. Fraction of Measured Combustible Gasthat is not VOC or Particulate

Asphalt Type

Number tanks measuredOxidized Unoxidized

109 47

Fraction combustible gas that is non-VOC/PM

Average 0.52 0.23Standard Deviation 0.12 0.23

materials. The charcoal tube technique was developed totroubleshoot excessive thermal cracking in asphalt tanks asa cause of high combustible gas levels in tank vaporspaces, and it is not routinely performed. It is important foremission calculations since the smaller combustibles foundin the tank vapor spaces and measured with the charcoaltube in place (ethane, methane. hydrogen sulfide. andcarbon monoxide) are not classified asVOCs because theydo not react with ozone in the atmosphere. Nor are theyparticulate. The other hydrocarbons trapped by the tubeand only measured when the charcoal tube is not present.are VOCs or particulate. Table 5 gives the results of testingof vapor spaces of oxidized and unoxidized asphalts for

these two types of combustible gas measurements. Thisanalysis was done to see if the routine combustible gasnumbers should be adjusted for significant and predictablenon-VOC/PM components. For the average tank storingoxidized asphalt. 52% of the combustible gas is non-VOC/PM anti this value n-as used for this class of asphalt.For unoxidized asphalts, both paving and flux,the non-VOC/PM % LEL varied widely and was not nearly as large afraction of the total. For these asphalts, all of thecombustible gas measurement was considered to be eitherVOC or particulate.

Calculation of VOC & PM from combustible gas readings: Giventhis background the actual calculation of VOC emissionsfrom combustion meter measurements is as follows:

Combustion meter measurements from tank vaporspaces read in %LEL are adjusted for the fraction of thatreading that is non-VOC/PM. This value depends on thetype of asphalt in the tank.The adjusted %LEL is then turned into a weight pervolume concentration. Hydrocarbons have a relativelyconstant actual LEL concentration. 45 mg/liter, whenexpressed on 3 weight per volume basis [11], and thisconstant is used to make this calculation.The weight per volume concentration from step 2 ismultiplied by the fume removal flow (in volume/time) inthe tank to get the VOC emission (n-eight/time) going to

Calc CO = 142 l LEL + 800

8000 -II II

6000 --

0 20 40 60 80 100 120

% LEL

256

Winter 1 9 9 9

FIGURE 3. Relation of CO with % LEL Data for Oxidized AsphaltsEnvironmental Progress (Vol.18, No.4)

2500

2000

1500

1000

500

0

I

I

I I

0 20 40 60 80 100 120

% LELFIGURE 4. Relation of H2S with % LEL Data for Oxidized Asphalts

a control device. It is consistent that the %LEL methodmeasures VOC and not total hydrocarbon since the fumeis drawn through a cotton filter prior to entering thecombustion meter, and particulate will be filtered out.

The particulate emission going to the control device isestimated from the constant ratio of 22%PM/78%VOC outlined in Table 4.

The control device destruction efficiency is applied toboth VOC and particulate emissions separately to get thefinal hydrocarbon based emissions from the tank. This isdone after the calculation of PM emissions since thecontrol efficiency for particulate and VOCs can bedifferent depending on the control device.This methodology’s accuracy has been confirmed by

tests in an Owens Corning asphalt plant on several

Table 6. Owens Corning Tank FumeSampling Results - VOC Emissions

Tank A Tank B Tank C

VOC Method 2jA Test 0.73 1.16 0.98 LEL Based Estimate 0.72 0.91 0.83

AP-42 Based Estimate 3.17 4.5 3.39

= 0.0076 *lb/hr

passively vented tanks while material was pumped into thetank and vapors forced out by the known pumping rate.Emissions calculated with the method outlined above werecompared to tank emissions calculated using AP-42 (validin theory in this case due to the lack of a ventilationsystem), and to emissions measured using EPA Method 25A.As can be seen in Table 6 the method based on actualcombustion meter tests is similar to the measured VOCswhile AP-42 estimates are 3 to 5 times higher.

Estimation of CO and H2S emissions from asphalt tanks: As partof the safety monitoring program mentioned above. OwensCorning has also used detector tubes in asphalt tanks tomeasure the vapor space concentration of carbonmonoxide and hydrogen sulfide [6]. These emissions areusually ignored in asphalt tanks, however. the data OwensCorning has taken clearly indicates their presence in tankvapor spaces and therefore their emission [il. These gasesare not routinely measured in Owens Corning asphalttanks. unlike combustible gas measurements, and thus freshdata are not available for current calculation. nor are dataavailable for every one of our tanks. To apply these data toall tanks. a surrogate measurement is necessary. Since thesame mechanism, thermal cracking, that produces lighthydrocarbons in asphalt tank vapor spaces also producescarbon monoxide and hydrogen sulfide, the periodiccombustion meter measurement of tank vapor spaces was

4.

5.

%

1. 1 kg/sec

H2S

(ppm

)

3000

H2S

Calc H2S

Calc H2S = 12.43 * LEL + 400.5


Table 7. Asphalt Plant 0:Tank Emissions of H2S and CO

Tank A Tank B Tank C

DataActual Test

% LEL based estimate0.06 0.12 0.15 lb/hr1

0.19 0.18 0.20 lb/hr

CO DataActual Test

% LEL based estimate0.20 0.17 0.23 lb/hr0.74 0.85 0.83

1. 1 kg/sec = 0.0076 * lb/hr

investigated as a surrogate for CO and Data for COand are plotted in Figures 3 and 4. Because of thescatter of data in the correlations a representative line waschosen for each material that was more conservative thannearly all of the data, in other words a line that defined amaximum concentration of CO and that could beexpected in an asphalt tank from the combustion metermeasurement. The equations used in the calculation of COand concentrations from combustion meter results

CO (ppm) = 142 *%LEL + 800 for oxidized asphalt = 12.43 *%LEL + 400.5 for oxidized asphalt

In unoxidized asphalt no such correlation was seen and values of 500 ppm are used for both species.

To estimate an emission from this correlation the CO and concentrations are multiplied by the flow out of the tank

to get emissions. and conversion factors are used to transformthis into a weight per time emission. Any control devicedestruction efficiency is then applied. The emissions usingthese techniques can be significant. Limited directmeasurement in an Owens Corning asphalt plant wasconsistent with this approach. at least in so far as that the

approach was conservative. was the closer of thetwo estimates. Data are presented in Table 7.

One consequence of fume incineration is that one mole of in the fumes is oxidized to one mole of The amount

of oxidized to SO, is the amount of generated minusboth the amount that escapes at the source and the amountthat is not incinerated at the control device. or in effect thetotal uncontrolled H2S emissions minus the emissions

g after control. Because of the reaction with oxygenand the molecular weight differences between H2S and SO2,every pound (2.2 kg) of H2S emission is oxidized to 1.88pounds (4.14 kg) of SO2 emission.

LoadingRack emissions of CO and H2S: As in the tanks. %LELversus CO and H2S correlations are used to estimate thesecomponents in loading rack emissions. Again, withincineration, the H2S is oxidized to SO2. Flow out of thetank truck during loading is needed for CO and H2S calculations. When fumes are collected, that flow can be

either the more conservative flow induced by the fume fan, or the lower and more realistic displacement of air by theasphalt being loaded. When no collection takes place thatflow is the displacement of air by asphalt being loaded.Combustion meter measurements of %LELs from the tanks

for loading are used for these calculations.

EFFECTIVENESS OF FIBER BED FILTERS FOR ASPHALT FUME EMISSIONCONTROL

One device used extensively to control asphalt fumes isa fiber bed filter. Fumes are actively pulled through thesefilters or passively hreathe through these filters. Their firstuse at Owens Corning was to control opacity to comply

NSPS regulations, and for this application they haveproven to he quite effective.

Testing was done on both asphalt tanks and on aroofing line center to determine the control efficiency offiber bed filters for both VOC and particulate emissions.Data from the testing are summarized in Table 8. In allcases. the particulate collection in the filter exceeded 90%of the emissions in the input stream. This value agrees well

manufacturer’s estimate of 95% and with theobservation that these devices can eliminate opacity.However, VOC removal varied widely in the tests. With theaverage removal near zero, and a very large variation, it

decided that no removal of VOC by these filters could assumed. Although organic oil is collected. this oil is

considered part of the particulate fraction of thehydrocarbons in the fumes and not the VOC fraction.Indeed the lack of removal of VOCs by these filters isconsistent with the method of partitioning hydrocarbonsinto VOC and particulate described above -- namely VOCspass through a testing filter and particulate do not. Basedon the effectiveness of these control devices to eliminateopacity it is assumed that particulate greater than 10 micronis captured by the fiber bed filter so that the totalparticulate emissions from the fiber bed filter are

to be PM10 emissions.Fiber bed filters are not considered to he a control

device for CO and H2S in tank or loading rack fumestreams.

Table 8. Effectiveness of Fiber Bed Filtersfor Emission Control from Asphalt Tanks

Equipment Pollutant Control Efficiency

0 Tank 1

Tank 57

Tank 1

Asphalt 0 0 Tank 1 0 57

Roofing I Coater

0Asphalt 0Asphalt 0Asphalt 0

Tank 1 Total ParticulateTank 57 Total Particulate 90.7%

Tank 1 Filterable Particulate 100.0% Filterable 100.0%

H2S

lb/br

with

used

was

with

considered

be

Plant

Asphalt

AsphaltAsphalt

Asphalt

Tank

VOCVOCVOCVOCVOC

-35.7%5.7%

43.4% 5.3% 0.0%

95.7%

remaining

H2S

H2S

H2S

H2S

H2SH2S

H2S

H2S

H2S

H2S SO2

%LEL

conservative

(ppm)

258 Winter 1999 Environmental Progress (Vol.18, No.4)

Table 9. Summary of Data for Calculating Asphalt Tank Emissions

Data Type Flux Asphalt Paving Asphalt Oxidized Asphalt

Clausius Clapeyron constant a for vapor pressure 1 18.2891 20.7962 18.8642Clausius Clapeyron constant b for vapor pressure 1 12725.6 15032.54 13458.56Log Log constant A for vapor pressure 2 7.085 7.8871 7.0607Log Log constant B for vapor pressure 2 -16.8999 -19.06 -16.957Asphalt vapor molecular weight use 84 for all types of asphaltAsphalt liquid molecular weight very rough estimate - 1000Partition of hydrocarbon fumes into particulate and VOC use 22% particulate, 78% VOC for all types% fumes that are VOC or particulate, versus non VOC/PM100% 100% 48%Vapor space carbon monoxide (conservative estimate)ppm500 500 142* % LEL + 800Vapor space hydrogen sulfide (conservative estimate) ppm500 500 12.43*%LEL + 400.5Fiber bed filter control of VOC use 0% for all asphalt typesFibe4r bed filter control of particulate use 90% for all asphalt types

1.In Vp(mm Hg) = a + b/T( °R) 1 Pa = 0.0075mm Hg, 1 °K = (°R-492)*5/9 +2732.log Vp (mm Hg) = A*log T( °F) + B1 °C = (°F - 32)* 5/9

CONCLUSIONS Estimation of air emissions for asphalt tanks and loadingracks can be done using AP-42 calculation methods given appropriate data on asphalt properties. More preciseestimates of emissions, or estimates for tanks usingventilation schemes that compromise the AP-42assumptions, can be done using a simple measurement ofthe combustible gas in the vapor space. Methods to do thisare outlined in the paper. Data that is useful with all thesemethods are summarized in Table 9. These data are givenfor three major classes of asphalt: paving, flux andoxidized

LITERATURE CITED1. Trumbore, D.C., "The magnitude and source of air emissions from asphalt blowing operations," Environmental Progress,17, (1), pp. 53-59 (Spring 1998).2. U.S.Environmental Protection Agency, "Introduction to 5th edition of AP-42 Emission Factors," U. S. EPA, January,1995,from the Internet at http://www.epa.gov/ ttn/chief/ap42.html (accessed May 14, 1998). 3. U.S Environmental Protection Agency, Chapter 7.1 of the 5th edition of AP-42 Emission Factors, U.S.EPA, "Organic Liquid Storage Tanks," September, 1997, from the Internet at http://www.epa.gov/ttn/chief/ap42.html (accessed May 14, 1998).4. U.S.Envoironmental Protection Agency, Chapter 5.2 of the

5th edition of AP-42 Emission Factors, U.S. EPA,"Transportation and Marketing of Petroleum Liquids,"January, 1995, from the Internet at http://www.epa.gov/ttn/chief/ap42.html (accessed May 14, 1998).

5. Trumbore, D.C. and C.R.Wilkinson, "Better understanding needed for asphalt tank-explosion hazards," Oil Gas J., 87, pp.38-41 (September 18, 1989).6. Trumbore, D.C., C.R.Wilkinson, and S.Wolfersberger, "Evaluation of techniques for in situ determination of explosion hazards in asphalt tanks," J.Loss Prev. Process Ind., 4, pp. 230-235 (July,1991).7. Schmidt, A.X. and H.L. List, "Material and Energy Balance," Prentice Hall, Inc., Englewood Cliffs, New Jersey, pp. 40-41 (1962).8. Boduszynski, M.M., "Asphaltenes in petroleum Asphalt: Composition and Formation," Chapter 7, in "The Chemistry of Asphaltenes," American Chemical Society, Washington, D.C., pp. 119-135 (1981).9. Storm, D.A., et al., "Upper bound on number average molecular weight of asphaltenes," Fuel, 69, pp. 735-738 (June, 1990).10. Speight, J.G., and S.E.Moschopedis, "Asphaltene molecular weights by a cryoscopic method," Fuel, 56, pp 344-345 (July, 1977).11. Bodurtha, F.T., "Industrial Explosion Prevention and Protection," McGraw Hill, Inc, New york, New York, page 11 (1980).


AIREMISSION PERMITNO.13900013-007 Shakopee, Scott County, MN 55379 · 2013-06-05 · Emission units...

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