TEXAS COMMISSION ON ENVIRONMENTAL QUALITYTEXAS COMMISSION ON ENVIRONMENTAL QUALITY May 1, 2017 . Bridget Bohac, Chief Clerk . Texas Commission on Environmental Quality . P.O. Box 13087,

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

May 1, 2017 Bridget Bohac, Chief Clerk Texas Commission on Environmental Quality P.O. Box 13087, MC 105 Austin, Texas 78711-3087 Re: Backup Material for Executive Director’s Response to Hearing Requests Brief for

Saint-Gobain Ceramics & Plastics, Inc. Air Quality Permit No. 20006 TCEQ Docket No. 2017-0533-AIR

Dear Ms. Bohac: Enclosed please find a copy of the following documents for inclusion in the background material for this permit application:

• The final draft permit, including any special conditions or provisions

• Maximum Allowable Emission Rate Table (MAERT)

• The summary of the technical review of the permit application

• The modeling audit for the permit.

• The compliance summary of the applicant.

If you have any questions, please do not hesitate to call me at extension 1320. Sincerely, Nicolas Parke Staff Attorney Environmental Law Division Enclosure

Special Conditions

Permit Number 20006

1. This permit covers only those sources of emissions listed in the attached table entitled “Emission Sources - Maximum Allowable Emission Rates (MAERT),” and those sources are limited to the emission limits on that table and other conditions specified in this permit.

Building A – Equipment/Operating Limitations

2. The following equipment shall not exceed the following firing rates in million British thermal units per hour (MMBtu/hr). (xx/ 16)

Combustion Device EPN Heat Input (MMBtu/Hr)

Line 5 Dryer A2 2.2

Line 6 Dryer A3-1

0.8 A3-2

Tunnel Kiln No. 1 H 7.6

Tunnel Kiln No. 2 N 7.6

Tunnel Kiln No. 3 D(1) 7.8

Tunnel Kiln No. 4 AB1 7.6

Tunnel Kiln No. 5 AC1 7.6

Tunnel Kiln No. 6 AD1 7.6

Bldg A Boiler G 2.4

3. Each Tunnel Kiln (Nos. 1 through 6) shall each be limited to a maximum raw material feed rate of 563 pounds per hour (lb/hr). (xx/17)

4. Products received from Building D shall be treated in either of the dryers [Emission Point Numbers (EPNs): E and X] prior to being fired in any tunnel kiln. (xx/16)

Building D – Equipment/Operating Limitations

5. The U1 Dryer Scrubber (EPN: E), U1 Kiln Scrubber/Wet Cyclone (EPN: C), and the U2 Dryer Scrubber (EPN: X) must be operational while each unit is processing material that may emit hydrogen fluoride (HF), ammonia (NH3), or formic acid. (5/15)

6. The U1 Rotary Kiln (EPN: B) shall be limited to a maximum raw material hourly feed rate of 550 lb/hr. (5/15)

7. The following equipment shall not exceed the following firing rates in MMBtu/hr. (5/ 15)

Special Conditions Permit Number 20006 Page 2

Combustion Device EPN Heat Input (MMBtu/hr)

U1 Dryer E 0.44

U2 Dryer X 2.5

U1 Rotary Kiln B 1.8

Bldg D Boiler A5 2.4

8. The scrubbers and cyclones shall operate in such a manner that the removal efficiency is at least: (5/15)

Device EPN Ammonia Formic Acid Hydrogen Fluoride

U1 Dryer Scrubber E - 95.0 % -

U2 Dryer Scrubber X 97.3 % 95.9 %

U1 Rotary Kiln C - - 99.8 %

9. The following actions shall be taken to insure the performance standards of the scrubbers are continuously achieved:

A. U1 Process Line

(1) The pH of the U1 Dryer Scrubber (EPN: E) shall be maintained within the following ranges:

(a) 5.0 to 9.0 when materials containing acid and NH3 are dried.

(b) 4.0 to 8.0 when materials containing only acids are dried. (5/15)

(2) The pH of the U1 Kiln Scrubber/Wet cyclone (EPN: C) shall be maintained within the following ranges: (8/07)

(a) First Stage: 2.5 to 8.5.

(b) Second Stage: 6.5 to 8.5.

B. The pH of the U2 Dryer Scrubber (EPN: X) shall be maintained within the following ranges:

(1) 4.0 and 8.0 when materials that produce formic acid and NH3 are being processed.

(2) 5.0 and 9.0 when materials that only produce formic acid are being processed.


C. A continuous pH monitoring system shall record pH levels for each scrubber.

D. Routine pH controller calibration shall be performed per the manufacturer’s specifications. (8/07)

Building E – Equipment/Operating Requirements (5/15)

10. The Bldg E Rotary Kiln (EPN: EkC) shall not exceed 4.5 MMBtu/hr.

11. The Bldg E Rotary Kiln (EPN: EkP) shall not exceed a maximum hourly raw material hourly feed rate of 860 lb/hr.

12. The Kiln Scrubber (EPN: EkP) must be operational while each unit is processing material that may emit HF, NH3, or formic acid.

13. The pH of the Kiln Scrubber (EPN: EkP) shall be determined during stack testing.

A. A continuous pH monitoring system shall record pH levels for the scrubber.

B. Routine pH controller calibration shall be performed per the manufacturer’s specifications.

14. The permit holder shall install and operate a pressure monitoring device to measure the differential pressure across the fabric filter unit at least once per day. The differential pressure should not be less than 1.0 or greater than 4 inches of water gauge pressure. The monitoring device shall be calibrated at a frequency in accordance with the manufacturer’s specifications, or at least annually, whichever is more frequent, and shall be accurate to within one of the following: 0.5 inches water gauge pressure (± 125 pascals) or ± 5 % of span.

General Operating Requirements and Fuel Specifications

15. Opacity of emissions from each kiln and steam generating boilers shall not exceed 5 percent averaged over a six minute period, and opacity of emissions from each dryer authorized by this permit shall not exceed 10 percent averaged over a six-minute period. The permit holder shall demonstrate compliance with this Special Condition in accordance with the following procedures: (8/13)

A. Visible emissions observations shall be conducted at least once per quarter.

B. The source shall be operating when the visible emissions observation is made. Visible emissions observations shall be for at least 15 seconds for each emission point. Observations shall be made at least 15 feet and no more than 0.25 miles from the emission point(s). Up to three emissions points may be read concurrently, provided that all three emissions points


are within a 70 degree viewing sector or angle in front of the observer. The proper sun position (i.e., at the observer’s back) shall be maintained for all emission points, even when viewing multiple emission points.

C. Visible emissions observations shall be recorded when they are conducted and each observation must be recorded as either visible emissions observed or no visible emissions observed. Contributions from uncombined water shall not be included in determining compliance with this condition.

D. If visible emissions are observed at an emission point, opacity shall be determined for that emission point, by 40 CFR Part 60, Appendix A, Reference Method 9 by a certified opacity reader.

16. Fuel used in the kilns, boilers, and dryers shall be limited to natural gas containing no more than 0.25 grain of hydrogen sulfide and 5 grains of total sulfur per 100 dry standard cubic feet (100/dscf). Use of any other fuel will require authorization from the Texas Commission on Environmental Quality (TCEQ). (7/08)

17. The holder of this permit shall physically identify and mark in a conspicuous location all equipment that has the potential of emitting air contaminants as follows:

A. The facility identification number as submitted to the Emissions Inventory Section of the TCEQ.

B. The emission point number as listed on the maximum allowable emission rates table (MAERT).

Initial Determination of Compliance

18. The holder of this permit shall perform initial stack sampling and other testing to establish the actual quantities of air contaminants being emitted into the atmosphere from Tunnel Kiln No. 1 (EPN: H), Tunnel Kiln No. 5 (EPN: AC1), Tunnel Kiln No. 6 (EPN: AD1), and Rotary Kiln (EPN: EkC). The holder of this permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense as specified in the attachment entitled “Chapter 2, Stack Sampling Facilities,” or an alternate design may be required at a later date if determined necessary by the appropriate TCEQ Waco Regional Director. Adequate advance notice shall be provided by TCEQ if an alternate design is required. (5/15)

A. Sampling shall be conducted in accordance with the appropriate procedures of the TCEQ Sampling Procedures Manual, EPA Methods in Title 40 Code of Federal Regulations (40 CFR) Part 60, Appendix A and 40 CFR Part 51, Appendix M, EPA Conditional Test Methods, and American Society for


Testing and Materials (ASTM). Front-half catch (filterable) and back half catch (condensibles) shall be collected for PM and PM10. Results shall be based on 3 one-hour runs of at least 60 minutes each.

(1) Air contaminants to be sampled and analyzed include (but are not limited to) nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compounds (VOC), particulate matter (PM), particulate matter with diameters of 10 microns (PM10), sulfur dioxide (SO2), HF, hydrogen chloride (HCl), NH3. For EPN: EkC the air contaminants to be sampled and analyzed are NOx, CO, VOC, PM, PM10, and SO2. For EPN: EkP the air contaminants to be sampled and analyzed are PM, PM10, HF, HCl, and NH3. Other parameters to be measured include stack gas flow rate and heat input rate. Diluents to be measured include oxygen (O2) or carbon dioxide (CO2). (5/15)

(2) Demonstrate compliance with the opacity performance standards of Special Condition No. 16 applicable to normal operation, using the average of 30 six minute readings as provided in 40 CFR § 60.11(b).

(3) Sampling shall be completed within 60 days after achieving maximum production rate, but no later than 180 days after start-up.

B. The TCEQ shall be afforded the opportunity to observe such sampling. The TCEQ Waco Regional Office shall be given notice as soon as testing is scheduled but not less than 30 days prior to sampling to schedule a pretest meeting.

(1) The notice shall include:

(a) Date for pretest meeting.

(b) Date sampling will occur.

(c) Name of firm conducting sampling.

(d) Type of sampling equipment to be used.

(e) Method or procedure to be used in sampling.

(f) Fuel mixture to be fired during the test.

(2) The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for submitting the test reports.

(3) Prior to the pretest meeting, a written proposed description of any deviation from sampling procedures specified in permit conditions or TCEQ, EPA, or ASTM sampling procedures shall be made available to


the TCEQ. The TCEQ Waco Regional Director shall approve or disapprove of any deviation from specified sampling procedures.

C. Sampling reports shall comply with the attached conditions of Chapter 14 of the TCEQ Sampling Procedures Manual.

Information in the test report shall include the following data for each test run:

(1) hourly fuel firing rate (in tons and MMBtu/hr);

(2) hourly throughput of fired ceramic materials;

(3) emissions in the units of the limits of this permit;

(4) removal efficiency, if measured;

(5) any additional records deemed necessary during the stack sampling pre-test meeting; and

(6) opacity in percent (%) opacity.

(7) One copy of the final sampling report shall be forwarded to the TCEQ Waco Regional Office within 60 days after sampling is completed.

19. The holder of this permit shall perform stack sampling and other testing, using the procedures of Special Condition No. 19, to establish the actual quantities of air contaminants being emitted into the atmosphere from any operating emission source, or the efficiency of any control device covered by this permit, if requested in writing by the TCEQ Waco Regional Director or the Executive Director of the TCEQ. Sampling shall be completed within 90 days after receiving such a request. (7/08)

20. The holder of this permit shall perform quarterly stack sampling and testing for carbon monoxide from Tunnel Kiln No. 5 (EPN: AC1) during the first year of its operation to establish the actual annual quantity being emitted into the atmosphere. Sampling shall use the procedures of Special Condition No. 19. (7/08)

21. The initial emission testing requirement of this condition was completed on the following dates: (5/15)

A. Tunnel Kiln No. 5 – June 2011


Continuous Demonstration of Compliance

22. Continuous demonstration of compliance with hourly emission limits and the operational limitations of this permit shall be based upon records required in Special Condition No. 24. (5/15)

23. The permit holder shall additionally install, calibrate, maintain, and operate a continuous monitoring system to monitor and record the fuel usage of Tunnel Kiln No. 6 (EPN: AD1). The monitoring device shall be accurate to ± 5 %, maintained, calibrated, and operated in accordance with the manufacturer’s specifications. The monitoring device shall be calibrated in accordance with the manufacturer’s recommendations or at least annually. (xx/17)

Recordkeeping and Reporting Requirements

24. A copy of this permit and the material balance tables shall be kept at the plant site and made available upon request to any TCEQ representative or to any pollution control authority representative with jurisdiction. (5/15)

25. The following information shall be maintained by the source for a period of five years and shall be made available upon request:

A. Building A

(1) Records of the natural gas fired in each kiln and the boiler. The records shall be converted to the appropriate units to demonstrate compliance with firing rate limitations in this permit. (xx/16)

(2) Records of hours of operation for each kiln and the boiler.

(3) Records of the raw material feed rate per kiln.

B. Building D

(1) Records of the natural gas fired in each kiln, each dryer, and the boiler. The records shall be converted to the appropriate units to demonstrate compliance with the firing rate limitations of this permit. (xx/17)

(2) Records of the hours of operation for each kiln, each dryer, each scrubber, and the boiler.

(3) Records of the raw material feed rate on the kiln.

(4) U1/U2 Scrubbers

(a) Records of the pH levels.

(b) Records of the pH controller calibrations.


(c) If either scrubber is not operational, the permit holder must maintain records to demonstrate that materials processed will not result in HF or formic acid emissions. (8/07)

C. Building E (5/15)

(1) Records of the natural gas fired in the kiln.

(2) Records of the hours of operation for the kiln.

(3) Records of the raw material feed rate.

(4) Kiln Scrubber

(a) Records of the pH levels.

(b) Records of the pH controller calibrations.

(c) If the scrubber is not operational, the permit holder must maintain records to demonstrate that materials processed will not result in HF or formic acid emissions.

(5) Records of differential pressure across the baghouse and calibrations of the monitoring device as required by this permit. (xx/17)

D. Records of visible emissions readings, opacity observations, and any corrective actions. (5/15)

Additional Authorizations (5/15)

26. The following operations are authorized through Permit by Rule (PBR) under 30 TAC Chapter 106 and are listed here for reference purposes only:

Source EPN Authorization/Registration

No.

Thermal Processing Unit/Baghouse

PK-1 106.182

Calciner PK-2 106.182

Dryer 3 U 106.183

Dryer 2 V 106.183

Dryer 1 W 106.183

Test X 124873

27. The holder of this permit shall submit an alteration to reflect the final pH specifications on the scrubbers (EPNs: E, X, and EkP) no later than 30 days after


testing is complete. This will require changes to Special Condition Nos. 9 and 13. (5/15)

Date:

Project Number: 248542

Emission Sources - Maximum Allowable Emission Rates

Permit Number 20006

This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant’s property covered by this permit. The emission rates shown are those derived from information submitted as part of the application for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit.

Air Contaminants Data

Emission Point No.

(1) Source Name (2)

Air Contaminant

Name (3)

Emission Rates

lbs/hour TPY (4)

Building A

A2 Dryer Line 5 Stack NOx 0.112 0.50

CO 0.05 0.22

VOC 0.003 0.014

PM 0.011 0.048

SO2 0.0005 0.003

A3-1 Dryer Line 6 Vent 1 NOx 0.112 0.50

CO 0.05 0.22

VOC 0.003 0.014

PM 0.011 0.048

SO2 0.0005 0.003

A3-2 Dryer Line 6 Vent 2 NOx 0.112 0.50

CO 0.05 0.22

VOC 0.003 0.014

PM 0.011 0.048

SO2 0.001 0.003

Permit Number 20006 Page 2



Emission Point No.

(1) Source Name (2)

Air Contaminant

Name (3)

Emission Rates

lbs/hour TPY (4)

AB1 Tunnel Kiln No. 4 Stack NOx 3.00 13.14

CO 13.10 57.4

VOC 1.68 7.4

PM 4.25 18.6

SO2 1.60 7.0

HCl 0.42 1.82

HF 0.06 0.27

NH3 2.7 9.4

Pb 0.0002 0.0007

AC1 Tunnel Kiln No. 5 Stack NOx 3.00 13.14

CO 13.10 57.4

VOC 1.68 7.4

PM 3.00 12.20

PM10 2.10 8.50

PM2.5 1.58 6.40

SO2 1.21 5.30

HCl 0.22 1.00

HF 0.06 0.27




Emission Point No.

(1) Source Name (2)

Air Contaminant

Name (3)

Emission Rates

lbs/hour TPY (4)

AD1 Tunnel Kiln No. 6 Stack NOx 3.00 13.14

CO 13.10 57.4

VOC 1.68 7.4

PM 3.00 12.2

PM10 2.10 8.5

PM2.5 1.58 6.4

SO2 1.21 5.30

HCl 0.22 1.00

HF 0.06 0.27

D(1) Tunnel Kiln No. 3 Stack NOx 3.00 13.14

CO 13.10 57.4

VOC 1.68 7.4

PM 4.25 18.6

SO2 1.60 7.0

HCl 0.42 1.82

HF 0.11 0.47

NH3 2.7 9.4

Pb 0.0002 0.0007

G Bldg A – Boiler NOx 0.20 0.876

CO 0.08 0.351

VOC 0.01 0.044

PM 0.02 0.088

SO2 0.01 0.044




Emission Point No.

(1) Source Name (2)

Air Contaminant

Name (3)

Emission Rates

lbs/hour TPY (4)

H Tunnel Kiln No. 1 Stack NOx 3.10 13.14

CO 13.10 57.2

VOC 1.68 7.4

PM10 2.50 11.0

SO2 1.21 5.3

HCl 0.22 0.04

HF 0.36 0.66

Pb 0.0002 0.0007

N Tunnel Kiln No. 2 Stack NOx 3.00 13.14

CO 13.10 57.4

VOC 1.68 7.4

PM 4.25 11.0

SO2 1.21 5.3

HCl 0.22 0.04

HF 0.36 0.66

Pb 0.0002 0.0007




Emission Point No.

(1) Source Name (2)

Air Contaminant

Name (3)

Emission Rates

lbs/hour TPY (4)

Building D

A5 Bldg D - Boiler NOx 0.4 1.75

CO 0.16 0.70

VOC 0.02 0.09

PM10 0.04 0.18

PM2.5 0.04 0.18

SO2 0.02 0.09

B Bldg D - Rotary Kiln Stack NOx 0.20 0.876

CO 0.08 0.351

VOC 0.01 0.044

PM 0.02 0.088

SO2 0.01 0.044

C Bldg D - Rotary Kiln Scrubber Stack HF 0.024 0.109

NH3 0.02 0.088

NH4F 0.138 0.43

E Bldg D – U1 Dryer Scrubber Stack NOx 0.5 2.19

CO 0.7 3.07

VOC 0.15 0.66

PM 0.4 1.75

PM10 0.2 0.88

PM2.5 0.1 0.44

SO2 0.13 0.57

CH2O2 2.0 8.76

HF 0.4 1.75

NH3 1.6 7.01




Emission Point No.

(1) Source Name (2)

Air Contaminant

Name (3)

Emission Rates

lbs/hour TPY (4)

X Bldg D – U2 Dryer Scrubber Stack NOx 0.8 3.50

CO 0.7 3.07

VOC 0.2 0.88

PM 0.4 1.75

PM10 0.2 0.88

PM2.5 0.1 0.44

SO2 0.13 0.57

CH2O2 3.0 13.14

HF 0.6 2.63

NH3 2.6 11.39

Building E

EkC Bldg E – Rotary Kiln Stack NOx 0.8 3.50

CO 0.24 1.05

VOC 0.5 0.22

PM 1.0 4.38

PM10 0.2 0.88

PM2.5 0.02 0.09

SO2 0.3 1.31

EkP Bldg E – Rotary Kiln - Baghouse-Scrubber Stack

PM 1.0 4.38

PM10 0.2 0.88

PM2.5 0.02 0.09

HCl 0.15 0.66

HF 0.2 0.88

NH3 0.06 0.26

(1) Emission point identification - either specific equipment designation or emission point number from plot plan.

(2) Specific point source name. For fugitive sources, use area name or fugitive source name.




(3) NOx - total oxides of nitrogen CH2O2 - formic acid

CO - carbon monoxide VOC - volatile organic compounds as defined in Title 30 Texas Administrative Code §

101.1 PM - total particulate matter, suspended in the atmosphere, including PM10 and PM2.5 PM10 - total particulate matter equal to or less than 10 microns in diameter, including

PM2.5 PM2.5 - particulate matter equal to or less than 2.5 microns in diameter SO2 - sulfur dioxide HCl - hydrogen chloride HF - hydrogen fluoride NH3 - ammonia NH4F - ammonium fluoride Pb - lead

(4) Compliance with annual emission limits (tons per year) is based on a 12 month rolling period.

Date:

1

Permit Amendment Source Analysis & Technical Review

Company Saint-Gobain Ceramics & Plastics,

Inc. Permit Number 20006

City Bryan Project Number 248542 County Brazos Account Number BM-0026-Q Project Type Amend Regulated Entity Number RN100213859 Project Reviewer Ruth Alvírez Customer Reference

Number CN600125587

Site Name Bryan Ceramics Plant

Project Overview Saint-Gobain Ceramics & Plastics Inc. (SGN) owns and operates the Bryan Ceramics Plant, which produces ceramic ware used in the chemical process industry, located in Bryan, Brazos County, Texas. SGN is requesting to construct a new tunnel kiln [Emission Point Number (EPN): AD1] and to rebuild Tunnel Kiln No. 1 (EPN: H). Maintenance, startup, and shutdown emissions/activities will be addressed by Permit by Rule (PBR). The consultant, Phil Cadarette, for Saint-Gobain notified me in an email dated April 26, 2016, that the phrase “construction of” instead of modification to” was used in Examples A and B of the NAPD package. This amended notice is to correct that error and an additional item found by me. A timely contested case hearing request was received after the NAPD package had been reviewed but the NAPD package was not updated to include the required language regarding receipt of the contested case hearing request. The amended NAPD contains the information concerning the receipt of the hearing request. The amended notice was mailed April 29, 2016.

Emission Summary

Air Contaminant Current Allowable

Emission Rates (tpy) Proposed Allowable Emission Rates (tpy)

Change in Allowable Emission Rates (tpy)

NOX 68.08 81.22 13.14 CO 287.81 345.21 57.40 VOC 37.09 44.49 7.40 PM 60.63 72.83 12.20 PM10 19.50 28.00 8.50 PM2.5 6.40 12.80 6.40 SO2 29.95 35.25 5.30 HCl 4.72 5.72 1.00 HF 2.33 2.60 0.27 NH3 18.80 18.80 0.00 Pb 0.0028 0.0028 0.00

Federal Applicability

The Bryan Ceramics Plant is located in Brazos County which is classified as an attainment county. The site is currently considered to be a major stationary source with respect to the Prevention of Significant Deterioration (PSD) program. The project actual increases, not considering increases or decreases at the site, did not trigger netting as demonstrated in the following chart. Federal Applicability

Pollutant Project

Increase

(tpy)

PSD Netting Trigger

(tpy)

Netting Required

(Y/N)

Net Emission Change

(tpy)

PSD Major Mod Trigger

(tpy)

PSD Review Triggered

(Y/N)

NOx 13.14 40 N - 40 - CO 57.40 100 N - 100 -


Permit No. 20006 Regulated Entity No. RN100213859 Page 2

2

Pollutant Project

Increase

(tpy)

PSD Netting Trigger

(tpy)

Netting Required

(Y/N)

Net Emission Change

(tpy)

PSD Major Mod Trigger

(tpy)

PSD Review Triggered

(Y/N)

VOC 7.40 40 N - 40 - PM 12.20 25 N - 25 - PM10 8.50 15 N - 15 - PM2.5 6.40 10 N - 10 - SO2 5.30 40 N - 40 -

Compliance History Evaluation - 30 TAC Chapter 60 Rules

A compliance history report was reviewed on: February 27, 2016 Site rating & classification: 8.18 Satisfactory Company rating & classification: 4.54 Satisfactory Has the permit changed on the basis of the compliance history or rating? No

Public Notice Information - 30 TAC Chapter 39 Rules Rule Citation Requirement 39.403 Is Public Notice Required? Yes Date Application Received: February 17, 2016 Date Administratively Complete: February 22, 2016 Small Business Source? No Date Leg Letters mailed: February 22, 2016 39.603 Date Published: February 27, 2016 Publication Name: The Eagle Pollutants: NOx, CO, PM, PM10, PM2.5, SO2, HAPS, organic

compounds Date Affidavits/Copies

Received: March 3, 2016 Is bilingual notice required? Yes Language: Spanish Date Published: February 26, 2016 Publication Name: La Voz Hispana Date Affidavits/Copies

Received: March 3, 2016 Date Certification of Sign Posting /

Application Availability Received: March 30, 2016 39.604 Public Comments Received? Yes Hearing Requested? Yes Meeting Request? No Date Response to Comments sent to

OCC: Consideration of Comments: Is 2nd Public Notice required? Yes 39.602(c) Date SB 709 Legislative Notification

Sent: March 24, 2016 39.419 Date 2nd Public Notice/Preliminary

Decision Letter Mailed: April 25, 2016



3

Rule Citation Requirement 39.413 Date Cnty Judge, Mayor, and COG

letters mailed: April 25, 2016 Date Federal Land Manager letter

mailed: 39.605 Date affected states letter mailed: 39.603 Date Published: May 6, 2016 Publication Name: The Eagle Pollutants: NOx, CO, PM, PM10, PM2.5, SO2, HAPS, organic

compounds Date Affidavits/Copies

Received: May 10, 2016 Is bilingual notice required? Yes Language: Spanish Date Published: May 6, 2016 Publication Name: La Voz Hispana Date Affidavits/Copies

Received: May 17, 2016 Date Certification of Sign Posting /

Application Availability Received: June 8, 2016 Public Comments Received? Yes Meeting Request? Yes Date Meeting Held: July 28, 2016 Hearing Request? Yes Date Hearing Held: Request(s) withdrawn? Date Withdrawn: Consideration of Comments: 39.421 Date RTC, Technical Review & Draft

Permit Conditions sent to OCC: Request for Reconsideration Received? Final Action: Are letters Enclosed?

Construction Permit & Amendment Requirements - 30 TAC Chapter 116 Rules Rule Citation Requirement 116.111(a)(2)(G) Is the facility expected to perform as represented in the application? Yes 116.111(a)(2)(A)(i)

Are emissions from this facility expected to comply with all TCEQ air quality Rules & Regulations, and the intent of the Texas Clean Air Act?

Yes

116.111(a)(2)(B) Emissions will be measured using the following method:

Emissions will be calculated based on fuel usage, feed rates, emission factors,

and recordkeeping. 116.111(a)(2)(D) Subject to NSPS? No 116.111(a)(2)(E) Subject to NESHAP? No 116.111(a)(2)(F) Subject to NESHAP (MACT) for source categories? No 116.111(a)(2)(H) Nonattainment (NA) review applicability: The Bryan Ceramics Plant is not located in a

nonattainment county; therefore, a NA review is not required. 116.111(a)(2)(I) PSD review applicability: See discussion above in Federal Applicability Section.



4

Rule Citation Requirement 116.111(a)(2)(L) Is Mass Emissions Cap and Trade applicable to the new or modified

facilities? No 116.140 - 141 Permit Fee: $ 75,000 Fee certification: M618509

Title V Applicability - 30 TAC Chapter 122 Rules Rule Citation Requirement 122.10(14) Title V applicability: The Bryan Ceramics Plant operates under O-2804.

122.602 Periodic Monitoring (PM) applicability: Periodic monitoring is applicable because this site is subject to 30 TAC Chapter 122. The

natural gas firing rate and the raw material feed rate are continuously monitored, and the opacity is monitored quarterly - by visible emission observation followed by an opacity observation if any visible emissions are observed.

122.604 Compliance Assurance Monitoring (CAM) applicability: CAM is applicable at a major source subject to 30 TAC Chapter 122 which has control

devices. This facility has scrubbers to control emissions of ammonia, formic acid, and hydrogen fluoride. The scrubbers are equipped with continuous pH monitoring systems.

Request for Comments Received From Program/Area Name Reviewed By/Date Comments Region: 9 Lori Farr No issues. City: Bryan County: Brazos ADMT: Ahmed Omar

March 24, 2016 AQA approved.

EB&T: NA Toxicology: NA Compliance: NA Legal: NA Comment resolution and/or unresolved issues:

Project Description SGN is requesting to construct a new tunnel kiln and rebuild an existing tunnel kiln.

Process Description

The Bryan Ceramics Plant consists of three manufacturing processes housed in Bldgs A, B, and D. Bldgs A and D processes are authorized under this permit and under Title 30 of the Texas Administrative Code (30 TAC), Chapter 106. Bldg B processes are authorized under 30 TAC, Chapter 106. The three manufacturing processes are somewhat similar, but there are distinct differences. In general the three manufacturing processes consist of the following: pre-thermal process and/or thermal treatment process. Bldg A - Conventional Lines Pre-thermal Process The pre-thermal process involves the forming and drying of the product. The forming process involves the combining of powdered ingredients (organic and inorganic) and liquid raw materials. Dust generated during the mixing process is sent to a dust collection system with 99% particulate removal efficiency and the discharge air is routed back into the system. After the raw materials are blended, the product (ceramic ware) passes



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through the forming process. The blended raw materials are then extruded into shapes and transferred to the drying process line which uses mild temperature dryers fired with natural gas or a combination of natural gas and steam. The dryers primarily emit water and the products of combustion (POCs) which are vented directly to the atmosphere through stacks. After the product has been dried it is then thermally treated.

Bldg A - Emission Points in the Pre-thermal Process Description EPN

Dryer W Dryer V Dryer U Dryer A2 Dryers A3-1 and A3-2

Bldg A - Boiler G Thermal Treatment The dried ceramic ware is then passed through one of the five gas-fired thermal process units (tunnel kilns). Each thermal process unit has three zones: preheat, hot, and cooling. The product passes through the preheat zone and the hot zone which is equipped with burners to complete the thermal process. This exhaust contains products of combustion (POC) and air contaminants such as particulates which are driven off from the ceramic ware as they are fired. The emissions are vented to atmosphere through a POC Stack. In the final step the products exit the hot zone and enter the cooling zone where the product is cooled with ambient air and subsequently the waste heat is discharged to the atmosphere out the cooling stack.

Bldg A - Emission Points in the Thermal Treatment Process Description EPN

Tunnel Kiln No. 1 H Tunnel Kiln No. 2 N Tunnel Kiln No. 3 D(1) Tunnel Kiln No. 4 AB1 Tunnel Kiln No. 5 AC1 Tunnel Kiln No. 6 AD1

Changes made to Bldg A include the following: 1. Construct new Tunnel Kiln. The engineering plans for the new Tunnel Kiln are identical to the existing

Tunnel Kiln No. 5 with the following exceptions: a dual fan system and flame safety controls will be installed on each burner. These two new design add-ons will enhance kiln control function and help to avoid kiln upsets.

2. Rebuild Tunnel Kiln 1. The rebuild plan includes the following:

A. Convert the kiln roof from an arch roof to a flat roof. B. Replace burners with high efficiency burners with flame safety control. C. Improve combustion air system to recover more waste heat. D. Replace critical fans with a duel fan system. E. Replace worn bricks. F. Replace worn tracks. G. Rework kiln car pusher system.

Bldg D - Unconventional Lines (U1 and U2) Pre-thermal Process – U1 The U1 process involves the forming, drying, and firing of the product. The forming process involves the combining of powdered ingredients (organic and inorganic) and liquid raw materials. Dust generated during the mixing process is sent to a dust collection system with 99% particulate removal efficiency and the discharge



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air is routed back into the system. After the raw materials are blended, the product is extruded for shaping. The formed product is then dried in the U1 dryer and the exhaust from this process is captured and routed to a scrubber (EPN: E) for acid and ammonia removal. After the product has been dried it is then thermally treated in the Bldg D rotary kiln, Bldg A tunnels kilns, or Bldg E rotary kiln.

Thermal Treatment The dried ceramic ware from the U1 pre-thermal process, is then passed through the rotary kiln (EPN: B) for thermal treatment. The off-gasses produced from indirectly firing the ceramic ware are captured and routed to a wet cyclone/scrubber system (EPN: C) and then vented out the stack. The POCs are emitted via the POC stack (EPN: B) at the end of the thermal treatment process.

Bldg D – U 1

Description EPN U1 Dryer Scrubber E

Rotary Kiln B Rotary Kiln Wet Cyclone/Scrubber C

Pre-thermal Process - U2 The U2 pre-thermal process is similar to the U1. The U2 drying process is equipped with a scrubber (EPN: X) to remove ammonia, formic acid, and fluoride emissions. Dust/fumes generated during the mixing, forming, and drying process are routed to a scrubber for acid and ammonia removal. The dry formed material is then thermally processed in one or more of the plants kilns.

Bldg D – U2 Description EPN

U2 Dryer Scrubber X No changes requested in Bldg D. Bldg B - Unconventional Lines Thermal Treatment Process Building B is authorized under 30 TAC § 106.182. The process in the building consists of thermal process capabilities for powders and dry formed shapes. The byproducts associated with this process include water vapor and organic acids. During the processing of the powder up to 5% of the feed powder can be entrained in the water vapor and is routed to a hot baghouse to control particulate matter. The dry form shapes do not emit particulate but can contain as much as 10% organic acids, which decomposes to carbon dioxide when thermally treated.

Bldg B - Emission Points in the Thermal Treatment Process Description EPN Rotary Kiln

PK1 Baghouse

Calciner (POC) PK2 No changes requested in Bldg B. Bldg E Thermal Treatment The dried ceramic ware from the U1 and U2 pre-thermal processes and ceramic powder, is passed through the rotary kiln (EPN: EkC) for thermal treatment. The off-gasses and particulate matter produced from indirectly firing the ceramic ware are captured and routed to a Baghouse Scrubber system (EPN: EkP) and then vented out the stack. The POCs are emitted via the POC stack (EPN: EkC) at the end of the thermal treatment process.

Bldg E



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Description EPN Rotary Kiln EkC

Rotary Kiln Baghouse Scrubber EkP No changes requested in Bldg E. Additional changes – SC No. 5 is being deleted as it contradicts SC No. 4. The products containing fluoride coming from Building (Bldg) D may be fired in the any of tunnel kilns in Bldg A provided the products are treated in the dryers first.

Pollution Prevention, Sources, Controls and BACT- [30 TAC 116.111(a)(2)(C)] Currently there are no add-on controls being utilized in this type of industry for a unit of this size. Newer technology is currently being developed by the tunnel kiln manufacturer; however, it is not currently available. Good combustion practices represent BACT. The design changes and upgrades to Tunnel Kiln No. 1 will be equal to or better than the existing components and are not expected to increase emissions.

Impacts Evaluation - 30 TAC 116.111(a)(2)(J) Was modeling conducted? Yes Type of Modeling: ISC-Prime Will GLC of any air contaminant cause violation of NAAQS? No Is this a sensitive location with respect to nuisance? No [§116.111(a)(2)(A)(ii)] Is the site within 3000 feet of any school? No

Summary of Modeling Results The air quality analysis is acceptable for all review types and pollutants. The results are summarized below. Minor Source NSR and Air Toxics Analysis Project-Related Modeling Results for State Property Line

Pollutant Averaging Time GLCmax (µg/m3)

De Minimis (µg/m3)

SO2 1-hr 6.3 20.4

Modeling Results for Minor NSR De Minimis

Pollutant Averaging Time GLCmax

(µg/m3)

De Minimis

(µg/m3)

SO2 1-hr 6.3 7.8

SO2 3-hr 4.5 25

SO2 24-hr 1.8 5

SO2 Annual 0.3 1

PM10 24-hr 3.1 5

PM2.5 24-hr 2.3 1.2

PM2.5 Annual 0.296 0.3

NO2 1-hr 12.5 7.5

NO2 Annual 0.5 1



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Pollutant Averaging Time GLCmax

(µg/m3)

De Minimis

(µg/m3)

CO 1-hr 68 2000

CO 8-hr 40 500

The annual PM2.5 GLCmax is based on the highest five-year average of the maximum predicted concentrations over five years of meteorological data. For all other analyses, the GLCmax are the maximum predicted concentrations associated with five years of meteorological data. The justification for selecting the EPA’s interim 1-hr NO2 and 1-hr SO2 De Minimis levels was based on the assumptions underlying EPA’s development of the 1-hr NO2 and 1-hr SO2 De Minimis levels. As explained in EPA guidance memoranda1,2, the EPA believes it is reasonable as an interim approach to use a De Minimis level that represents 4% of the 1-hr NO2 and 1-hr SO2 NAAQS. The applicant performed an evaluation of ambient PM2.5 monitoring data, consistent with EPA guidance for PM2.5

3, for using the PM2.5 De Minimis levels. If background monitoring data shows that the difference between the PM2.5 NAAQS and the monitored PM2.5 background concentrations in the area is greater than the EPA’s PM2.5 De Minimis level, then a proposed source with a PM2.5 impact below the PM2.5 De Minimis level would not cause or contribute to a violation of the PM2.5 NAAQS. Background concentrations for PM2.5 were obtained from the EPA AIRS monitor 481130069 located at 1415 Hinton St., Dallas, Dallas County. The applicant used a three-year average (2012-2014) of the annual mean concentrations for the annual value (9.6 µg/m3). See the discussion below for additional information on the evaluation of 24-hr monitoring data and the appropriateness of the selected monitor Total Concentrations for Minor NSR NAAQS (Concentrations > De Minimis)

Pollutant Averaging

Time GLCmax (µg/m3)

Background

(µg/m3)

Total Conc. = [Background + GLCmax] (µg/m3)

Standard (µg/m3)

PM2.5 24-hr 12.8 22 34.8 35 NO2 1-hr 97.9 35.8 133.7 188

The GLCmax represent the maximum high, sixth high (H6H) predicted concentrations over five years of meteorological data. Using the maximum H6H is a conservative representation of the 24-hr PM2.5 and 1-hr NO2 design values (based on five-year averages of the high, eighth high [H8H] predicted concentrations). Background concentrations for PM2.5 were obtained from the EPA AIRS monitor 481130069 located at 1415 Hinton St., Dallas, Dallas County. The applicant used a three-year average (2012-2014) of the 98th percentile of the annual distribution of the 24-hr concentrations for the 24-hr value. The use of this monitor is reasonable based on the applicant’s quantitative review of emissions sources in the surrounding area of the monitor site relative to the project site. Background concentrations for NO2 were obtained from the EPA AIRS monitor 480391016 located at 109B Brazoria Hwy 332 West, Lake Jackson, Brazoria County. The three-year average (2012-2014) of the 98th percentile of the annual distribution of the daily maximum 1-hr concentrations was used for the 1-hr value. The use of this monitor was not fully justified by the applicant; however, the selection of the monitor will not significantly affect the overall modeling results since other representative monitors are available that would continue to demonstrate that the total predictions would meet the NAAQS.

1 www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf 2 www.epa.gov/nsr/documents/20100629no2guidance.pdf 3 www.epa.gov/ttn/scram/guidance/guide/Guidance_for_PM2.5_Permit_Modeling.pdf

http://www.epa.gov/ttn/scram/guidance/guide/Guidance_for_PM



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Minor NSR Production Project-Related Modeling Results for Health Effects

Pollutant & CAS# Averaging Time GLCmax (µg/m3)

10% ESL (µg/m3)

Hydrogen fluoride 7664-39-3

1-hr 0.25 1.8

Hydrogen fluoride 7664-39-3

Annual 0.01 0.87

hydrogen fluoride (agricultural areas)

7664-39-3 1-hr 0.25 0.3


7664-39-3 Annual 0.01 0.06

Hydrogen chloride 7647-01-0

1-hr 0.9 19

Hydrogen chloride 7647-01-0

Annual 0.04 0.79

The 1-hr GLCmax are located approximately 350 meters from the property line towards the west. The annual GLCmax are located approximately 275 meters from the property line towards the north. The modeling results all pollutants indicate the predicted concentrations from the project will not result in any adverse effects on the environment and human health

Permit Concurrence and Related Authorization Actions Is the applicant in agreement with special conditions? Yes Company representative(s): Phil Cardette Contacted Via: Email Date of contact: April 7, 2016 Other permit(s) or permits by rule affected by this action: No

Ruth Alvirez Project Reviewer

Date Daniel Guthrie Team Leader/Section Manager/Backup

Date

TCEQ Interoffice Memorandum

Texas Commission on Environmental Quality Page 1 of 5

To: Ruth Alvirez Energy/Combustion Section Thru: Dianne Anderson, Team Leader Air Dispersion Modeling Team (ADMT) From: Ahmed Omar ADMT Date: March 24, 2016

Subject: Air Quality Analysis Audit – Saint-Gobain Ceramics & Plastics, Inc. (RN100213859)

1. Project Identification Information

Permit Application Number: 20006 NSR Project Number: 248542 ADMT Project Number: 4881 NSRP Document Number: 560364 County: Brazos ArcReader Published Map: \\\tceq4apmgisdata\GISWRK\APD\MODEL PROJECTS\4881\4881.pmf Air Quality Analysis: Submitted by Spirit Environmental, February 2016, on behalf of Saint-Gobain Ceramics & Plastics, Inc. Additional information and modeling files were provided March 2016.

2. Report Summary The air quality analysis is acceptable for all review types and pollutants. The results are summarized below.

A. Minor Source NSR and Air Toxics Analysis

Table 1. Project-Related Modeling Results for State Property Line

Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)

SO2 1-hr 6.3 20.4



Table 2. Modeling Results for Minor NSR De Minimis

Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)

SO2 1-hr 6.3 7.8

SO2 3-hr 4.5 25

SO2 24-hr 1.8 5

SO2 Annual 0.3 1

PM10 24-hr 3.1 5

PM2.5 24-hr 2.3 1.2

PM2.5 Annual 0.296 0.3

NO2 1-hr 12.5 7.5

NO2 Annual 0.5 1

CO 1-hr 68 2000

CO 8-hr 40 500

The annual PM2.5 GLCmax is based on the highest five-year average of the maximum predicted concentrations over five years of meteorological data. For all other analyses, the GLCmax are the maximum predicted concentrations associated with five years of meteorological data. The justification for selecting the EPA’s interim 1-hr NO2 and 1-hr SO2 De Minimis levels was based on the assumptions underlying EPA’s development of the 1-hr NO2 and 1-hr SO2 De Minimis levels. As explained in EPA guidance memoranda1,2, the EPA believes it is reasonable as an interim approach to use a De Minimis level that represents 4% of the 1-hr NO2 and 1-hr SO2 NAAQS. The applicant performed an evaluation of ambient PM2.5 monitoring data, consistent with EPA guidance for PM2.5

3, for using the PM2.5 De Minimis levels. If background monitoring data shows that the difference between the PM2.5 NAAQS and the monitored PM2.5 background concentrations in the area is greater than the

1 www.epa.gov/region07/air/nsr/nsrmemos/appwso2.pdf 2 www.epa.gov/nsr/documents/20100629no2guidance.pdf 3 www.epa.gov/ttn/scram/guidance/guide/Guidance_for_PM25_Permit_Modeling.pdf



EPA’s PM2.5 De Minimis level, then a proposed source with a PM2.5 impact below the PM2.5 De Minimis level would not cause or contribute to a violation of the PM2.5 NAAQS. Background concentrations for PM2.5 were obtained from the EPA AIRS monitor 481130069 located at 1415 Hinton St., Dallas, Dallas County. The applicant used a three-year average (2012-2014) of the annual mean concentrations for the annual value (9.6 µg/m3). See the discussion below for additional information on the evaluation of 24-hr monitoring data and the appropriateness of the selected monitor.

Table 3. Total Concentrations for Minor NSR NAAQS (Concentrations > De Minimis)

Pollutant Averaging Time

GLCmax (µg/m3)

Background (µg/m3)

Total Conc. = [Background +

GLCmax] (µg/m3)

Standard (µg/m3)

PM2.5 24-hr 12.8 22 34.8 35

NO2 1-hr 97.9 35.8 133.7 188

The GLCmax represent the maximum high, sixth high (H6H) predicted concentrations over five years of meteorological data. Using the maximum H6H is a conservative representation of the 24-hr PM2.5 and 1-hr NO2 design values (based on five-year averages of the high, eighth high [H8H] predicted concentrations).

Background concentrations for PM2.5 were obtained from the EPA AIRS monitor 481130069 located at 1415 Hinton St., Dallas, Dallas County. The applicant used a three-year average (2012-2014) of the 98th percentile of the annual distribution of the 24-hr concentrations for the 24-hr value. The use of this monitor is reasonable based on the applicant’s quantitative review of emissions sources in the surrounding area of the monitor site relative to the project site. Background concentrations for NO2 were obtained from the EPA AIRS monitor 480391016 located at 109B Brazoria Hwy 332 West, Lake Jackson, Brazoria County. The three-year average (2012-2014) of the 98th percentile of the annual distribution of the daily maximum 1-hr concentrations was used for the 1-hr value. The use of this monitor was not fully justified by the applicant; however, the selection of the monitor will not significantly affect the overall modeling results since other representative monitors are available that would continue to demonstrate that the total predictions would meet the NAAQS.



Table 4. Minor NSR Production Project-Related Modeling Results for Health Effects

Pollutant & CAS# Averaging Time GLCmax (µg/m3) 10% ESL (µg/m3)

Hydrogen fluoride 7664-39-3 1-hr 0.25 1.8

Hydrogen fluoride 7664-39-3 Annual 0.01 0.87


7664-39-3 1-hr 0.25 0.3


7664-39-3 Annual 0.01 0.06

Hydrogen chloride 7647-01-0 1-hr 0.9 19

Hydrogen chloride 7647-01-0 Annual 0.04 0.79

The 1-hr GLCmax are located approximately 350 meters from the property line towards the west. The annual GLCmax are located approximately 275 meters from the property line towards the north.

3. Model Used and Modeling Techniques

ISC-PRIME (Version 04269) was used. A. Land Use

Rural dispersion coefficients and elevated terrain were used in the modeling analysis. These selections are consistent with the topographic map, DEMs, and aerial photography.

B. Meteorological Data Surface Station and ID: Austin, TX (Station #: 13958) Upper Air Station and ID: Victoria, TX (Station #: 12912) Meteorological Dataset: 1988 for the health effects analyses and 1983, 1984, 1986, 1987, and 1988 for all other analyses. Anemometer Height: 10 meters

C. Receptor Grid The grid modeled was sufficient in density and spatial coverage to capture representative maximum ground-level concentrations.



D. Building Wake Effects (Downwash)

Input data to Building Profile Input Program Prime (Version 04274) are consistent with the aerial photography, plot plan, and modeling report.

4. Modeling Emissions Inventory The modeled emission point source parameters and rates were consistent with the modeling report. The source characterization used to represent the sources was appropriate. NOx to NO2 conversion factors of 0.75 and 0.8 were applied to the annual and 1-hr predicted NOx concentrations, respectively, which is consistent with guidance for combustion sources. Maximum allowable hourly emission rates were used for both the short-term and the annual averaging time analyses.

The TCEQ is committed to accessibility. To request a more accessible version of this report, please contact the TCEQ Help Desk at (512) 239-4357.

Compliance History ReportCompliance History Report for CN600125587, RN100213859, Rating Year 2016 which includes Compliance History (CH) components from September 1, 2011, through August 31, 2016.

NOT NULLNOT NULLCustomer, Respondent, or Owner/Operator:

CN600125587, Saint-Gobain Ceramics & Plastics, Inc.

Classification: SATISFACTORY Rating: 3.79

Regulated Entity: RN100213859, BRYAN CERAMICS PLANT Classification: SATISFACTORY Rating: 6.75

Complexity Points: Repeat Violator: 9 NO

CH Group: 05 - Chemical Manufacturing

Location: 1500 INDEPENDENCE AVE BRYAN, TX 77803-2001, BRAZOS COUNTY

TCEQ Region: REGION 09 - WACO

ID Number(s):AIR OPERATING PERMITS ACCOUNT NUMBER BM0026Q AIR OPERATING PERMITS PERMIT 2804

AIR OPERATING PERMITS ACCOUNT NUMBER BM0026Q AIR NEW SOURCE PERMITS PERMIT 4636

AIR NEW SOURCE PERMITS PERMIT 20006 AIR NEW SOURCE PERMITS ACCOUNT NUMBER BM0026Q

AIR NEW SOURCE PERMITS AFS NUM 4804100027 AIR NEW SOURCE PERMITS REGISTRATION 124873

STORMWATER PERMIT TXR05AH68 STORMWATER PERMIT TXR05DA29

AIR EMISSIONS INVENTORY ACCOUNT NUMBER BM0026Q

INDUSTRIAL AND HAZARDOUS WASTE EPA ID TXD089743769

INDUSTRIAL AND HAZARDOUS WASTE SOLID WASTE REGISTRATION # (SWR) 33129

POLLUTION PREVENTION PLANNING ID NUMBER P00474

Compliance History Period: September 01, 2011 to August 31, 2016 Rating Year: 2016 Rating Date: 09/01/2016

Date Compliance History Report Prepared: April 20, 2017

Agency Decision Requiring Compliance History: Permit - Issuance, renewal, amendment, modification, denial, suspension, or revocation of a permit.

Component Period Selected: September 01, 2011 to August 31, 2016

TCEQ Staff Member to Contact for Additional Information Regarding This Compliance History.

Name: Phone: Ruth Alvirez (512) 239-5220

Site and Owner/Operator History:

1) Has the site been in existence and/or operation for the full five year compliance period? YES

2) Has there been a (known) change in ownership/operator of the site during the compliance period? NO

Components (Multimedia) for the Site Are Listed in Sections A - J

A. Final Orders, court judgments, and consent decrees:Effective Date: 09/12/2013 ADMINORDER 2013-0294-AIR-E (1660 Order-Agreed Order With Denial) 1

Classification: Moderate

Citation: 30 TAC Chapter 116, SubChapter B 116.115(c)

5C THSC Chapter 382 382.085(b)

Rqmt Prov: Special Condition 9(A) PERMIT

Description: Failure to maintain daily records.

Classification: Moderate

Citation: 30 TAC Chapter 122, SubChapter B 122.145(2)(C)

5C THSC Chapter 382 382.085(b)

Rqmt Prov: General Terms & Conditions OP

Description: Failure to submit a semi-annual deviation report witin 30 days after the end of the reporting period.

B. Criminal convictions:N/A

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C. Chronic excessive emissions events:N/A

D. The approval dates of investigations (CCEDS Inv. Track. No.):Item 1 December 09, 2011 (969415)

Item 2 October 24, 2014 (1203334)

Item 3 January 15, 2015 (1217899)

Item 4 November 09, 2015 (1288971)

Item 5 March 31, 2016 (1321365)

Item 6 July 26, 2016 (1288654)

E. Written notices of violations (NOV) (CCEDS Inv. Track. No.):A notice of violation represents a written allegation of a violation of a specific regulatory requirement from the commission to a regulated entity. A notice of violation is not a final enforcement action, nor proof that a violation has actually occurred.

N/A

F. Environmental audits:N/A

G. Type of environmental management systems (EMSs):N/A

H. Voluntary on-site compliance assessment dates:N/A

I. Participation in a voluntary pollution reduction program:N/A

J. Early compliance:N/A

Sites Outside of Texas:N/A

Compliance History Report for CN600125587, RN100213859, Rating Year 2016 which includes Compliance History (CH) components from September 01, 2011, through August 31, 2016.

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Documents

TEXAS COMMISSION ON ENVIRONMENTAL QUALITYTEXAS COMMISSION ON ENVIRONMENTAL QUALITY May 1, 2017 . Bridget Bohac, Chief Clerk . Texas Commission on Environmental Quality . P.O. Box 13087,