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DAQ-2025-000098
DAQE-AN146030003-24 {{$d1 }} Brandon Burton BMCA Cedar City LLC 5080 West Highway 56 Cedar City, UT 84720 brandon.burton@gaf.com Dear Mr. Burton: Re: Approval Order: Modification of Approval Order DAQE-AN146030002-15 to Add a Fluidized Sand Bath and an Off-line Custom Cut Saw Project Number: N146030003 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on September 25, 2024. BMCA Cedar City LLC must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Christine Bodell, who can be contacted at (385) 290-2690 or cbodell@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:CB:jg cc: Southwest Utah Public Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director January 6, 2025 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN146030003-24 Modification of Approval Order DAQE-AN146030002-15 to Add a Fluidized Sand Bath and an Off-line Custom Cut Saw Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to BMCA Cedar City LLC - Insulation Board and Roofing Membrane Production Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality January 6, 2025 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 4 Source Classification .............................................................................................................. 4 Applicable Federal Standards ................................................................................................. 4 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ..................................................................................................................... 9 ACRONYMS ............................................................................................................................... 10 DAQE-AN146030003-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name BMCA Cedar City LLC BMCA Cedar City LLC - Insulation Board and Roofing Membrane Production Plant Mailing Address Physical Address 5080 West Highway 56 5080 West Highway 56 Cedar City, UT 84720 Cedar City, UT 84720 Source Contact UTM Coordinates Name: Brandon Burton 310,102 m Easting Phone: (435) 216-6546 4,173,443 m Northing Email: brandon.burton@gaf.com Datum NAD83 UTM Zone 12 SIC code 3086 (Plastics Foam Products) SOURCE INFORMATION General Description BMCA Cedar City LLC (BMCA) is the owner and operator of an insulation board and roofing membrane production plant in Cedar City, Iron County. The facility operates three separate manufacturing lines for the production of polyisocyanurate (ISO) insulation board, thermoplastic polyolefin (TPO) roofing membranes, and polyvinyl chloride (PVC) roofing membranes. The ISO insulation board production line utilizes methylene diphenyl diisocyanate (MDI), polyol, and a blowing agent (e.g., pentane). The MDI and blended polyol/blowing agent material is transferred onto a bottom facer material. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed-cell foam. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to a regenerative thermal oxidizer (RTO) to control VOCs. The TPO and PVC roofing membrane production lines utilize a pneumatic conveyance system to convey the raw materials to feeder bins that meter the raw materials into the extruders. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calendar rolls that press the core onto the scrim. The sheet then passes to the cap extruder die, where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calendar rolls are employed to assist with bonding the cap to the scrim. DAQE-AN146030003-24 Page 4 NSR Classification Minor Modification at Minor Source Source Classification Located in Attainment Area Iron County Airs Source Size: B Applicable Federal Standards None Project Description BMCA has requested to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC cut saw) for supplementing its operations in the ISO plant. The new equipment will generate emissions of particulate matter, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 7725.00 Carbon Monoxide 0 5.41 Nitrogen Oxides 0 6.44 Particulate Matter - PM10 0.37 12.77 Particulate Matter - PM2.5 0.37 4.96 Sulfur Dioxide 0 0.04 Volatile Organic Compounds 1.02 30.78 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) 1,4-Dioxane (1,4-Diethyleneoxide) (CAS #123911) 0 5489 Ethylene Glycol (CAS #107211) 2 5510 Generic HAPs (CAS #GHAPS) 23 323 Hexane (CAS #110543) 59 1759 Vinyl Chloride (CAS #75014) 0 320 Change (TPY) Total (TPY) Total HAPs 0.03 6.70 DAQE-AN146030003-24 Page 5 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Insulation Board & Roofing Membrane Production Plant II.A.2 RTO Rating: 10 MMBtu/hr Fuel: Natural gas II.A.3 ISO Foam Line DAQE-AN146030003-24 Page 6 II.A.4 ISO Foam Line Baghouse Rating: 27,300 cfm Controls: ISO foam line PM emissions II.A.5 Steam Generator Electric steam generator Listed for informational purposes only II.A.6 Thermal Heaters Rating: Less than 5.0 MMBtu/hr, each Fuel: Natural gas II.A.7 ISO Off-Line CNC Cut Saw (New) II.A.8 TPO Line II.A.9 One (1) TPO Fluidized Sand Bath (New) II.A.10 PVC Line Max extruder rating: 7,500 lbs/hr Number of extruders: Two (2) II.A.11 TPO and PVC Lines Baghouse Max rating: 3,550 cfm Filter efficiency: Equal to or greater than 98% II.A.12 Silo Bin Vent Rating: 1,300 cfm each Number: Four (4) per silo Controls: Silo PM emissions II.A.13 Polypropylene Silo Rating: 10 cfm Number: Three (3) Control: Bin vent filters II.A.14 PVC Silos Number: Two (2) Control: Bin vent filter II.A.15 One (1) Storage Tank 35,000-gallon Pentane Tank Control: RTO II.A.16 Indoor Storage Tanks Three (3) 20,000-gallon MDI tanks Three (3) 20,000-gallon Polyol tanks One (1) 7,500-gallon K-Oct tank One (1) 7,500-gallon TCPP tank Listed for informational purposes only. All above tanks vent internally. DAQE-AN146030003-24 Page 7 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Insulation Board and Roofing Membrane Production Plant II.B.1.a The owner/operator shall not allow visible emissions from any stationary source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall use only natural gas as fuel in the stationary equipment on site. [R307-401-8] II.B.2 Storage Tank Requirements II.B.2.a The owner/operator shall equip each MDI storage tank with coalescing or equivalent-type filters. [R307-401-8] II.B.2.b The owner/operator shall control VOC emissions during tank loading operations at all times by using a vapor recovery system or equivalent filter-type system. [R307-401-8] II.B.3 Baghouse/Bin Vent Requirements II.B.3.a The owner/operator shall route all emissions from the TPO and PVC lines raw material handling sources and the offline CNC cut saw through their designated operating baghouse prior to emitting to the atmosphere. [R307-401-8] II.B.3.b The owner/operator shall route all emissions from the polypropylene and PVC silos through an operating bin vent prior to emitting to the atmosphere. [R307-401-8] II.B.4 RTO Requirements II.B.4.a The owner/operator shall control emissions from the ISO Foam Line with a unit RTO. All emissions from the ISO Foam Line shall be routed through the RTO before being vented to the atmosphere. [R307-401-8] II.B.4.b The owner/operator shall install an RTO that is equipped to handle no less than 29,182 standard cubic feet per minute (SCFM). [R307-401-8] II.B.4.c At all times while operating the RTO, the owner/operator shall maintain a temperature at or above 1,500oF in the RTO. [R307-401-8] II.B.4.c.1 The owner/operator shall monitor the operating temperature with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.4.c.2 The owner/operator shall continuously monitor the operating temperature with a thermocouple located in the oxidizer chamber. [R307-401-8] II.B.4.c.3 The minimum temperature reading of the thermocouple shall not be less than 1,488.75oF. The minimum electronic data historian sensitivity (minor division) is 20oF or as approved by the Director. [R307-401-8] II.B.4.d At least once every 12 months, the owner/operator shall have a third party calibrate the thermocouple in accordance with the manufacturer's recommendation. [R307-401-8] II.B.4.e The owner/operator shall operate and maintain the data acquisition system in accordance to the manufacturer's recommendations. [R307-401-8] DAQE-AN146030003-24 Page 8 II.B.4.f The owner/operator shall: A. Inspect the electronic data historian on a daily basis B. Inspect the RTO on a weekly basis. [R307-401-8] II.B.4.f.1 The owner/operator shall: A. Maintain records of the inspections B. Keep the inspection records for all periods the plant is in operation. [R307-401-8] II.B.5 ISO Line Off-Line CNC Cut Saw Baghouse Requirements II.B.5.a The owner/operator shall use a baghouse to control particulate emissions from the ISO offline CNC cut saw. All exhaust air from the sawing operations shall be vented to the baghouse prior to being vented to the atmosphere. [R307-401-8] II.B.5.b The owner/operator shall install a baghouse that is certified to meet a particulate matter control efficiency of no less than 95%. [R307-401-8] II.B.5.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed baghouse. [R307-401-8] II.B.5.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the baghouse. [R307-401-8] II.B.5.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.5.d During operation of the baghouse, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.5.d.1 The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] II.B.5.d.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended static pressure differential for the unit; C. Daily static pressure differential readings; D. Date of reading. [R307-401-8] II.B.5.e At least once every 12 months, the owner/operator shall calibrate the pressure gauge in accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8] II.B.5.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] DAQE-AN146030003-24 Page 9 II.B.6 Fugitive Dust Requirements II.B.6.a The owner/operator shall pave all hauls roads, parking lots, and loading/unloading areas on site. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN146030002-15 dated November 18, 2015 Is Derived From NOI dated September 25, 2024 DAQE-AN146030003-24 Page 10 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE-IN146030003-24 November 18, 2024 Brandon Burton BMCA Cedar City LLC 5080 West Highway 56 Cedar City, UT 84720 brandon.burton@gaf.com Dear Mr. Burton: Re: Intent to Approve: Modification of Approval Order DAQE-AN146030002-15 to Add a Fluidized Sand Bath and an Off-line Custom Cut Saw Project Number: N146030003 The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is subject to public review. Any comments received shall be considered before an Approval Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO. Future correspondence on this ITA should include the engineer's name, Christine Bodell, as well as the DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell, can be reached at (385) 290-2690 or cbodell@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:CB:jg cc: Southwest Utah Public Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN146030003-24 Modification of Approval Order DAQE-AN146030002-15 to Add a Fluidized Sand Bath and an Off-line Custom Cut Saw Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to BMCA Cedar City LLC - Insulation Board and Roofing Membrane Production Plant Issued On November 18, 2024 {{$s }} New Source Review Section Manager Alan D. Humpherys {{#s=Sig_es_:signer1:signature}} TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 4 Source Classification .............................................................................................................. 4 Applicable Federal Standards ................................................................................................. 4 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 5 PUBLIC NOTICE STATEMENT............................................................................................... 5 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 8 PERMIT HISTORY ................................................................................................................... 10 ACRONYMS ............................................................................................................................... 11 DAQE-IN146030003-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name BMCA Cedar City LLC BMCA Cedar City LLC - Insulation Board and Roofing Membrane Production Plant Mailing Address Physical Address 5080 West Highway 56 5080 West Highway 56 Cedar City, UT 84720 Cedar City, UT 84720 Source Contact UTM Coordinates Name: Brandon Burton 310,102 m Easting Phone: (435) 216-6546 4,173,443 m Northing Email: brandon.burton@gaf.com Datum NAD83 UTM Zone 12 SIC code 3086 (Plastics Foam Products) SOURCE INFORMATION General Description BMCA Cedar City LLC (BMCA) is the owner and operator of an insulation board and roofing membrane production plant in Cedar City, Iron County. The facility operates three (3) separate manufacturing lines for the production of polyisocyanurate (ISO) insulation board, thermoplastic polyolefin (TPO) roofing membranes, and polyvinyl chloride (PVC) roofing membranes. The ISO insulation board production line utilizes methylene diphenyl diisocyanate (MDI), polyol, and a blowing agent (e.g., pentane). The MDI and blended polyol/blowing agent material is transferred onto a bottom facer material. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed cell-foam. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to a regenerative thermal oxidizer (RTO) to control VOCs. The TPO and PVC roofing membrane production lines utilize a pneumatic conveyance system to convey the raw materials to feeder bins that meter the raw materials into the extruders. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calendar rolls that press the core onto the scrim. The sheet then passes to the cap extruder die, where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calendar rolls are employed to assist with bonding the cap to the scrim. DAQE-IN146030003-24 Page 4 NSR Classification Minor Modification at Minor Source Source Classification Located in Attainment Area Iron County Airs Source Size: B Applicable Federal Standards None Project Description BMCA has requested to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC cut saw) for supplementing its operations in the ISO plant. The new equipment will generate emissions of particulate matter, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). BMCA is the owner and operator of an insulation board and roofing membrane production plant in Cedar City, Iron County. The facility operates three (3) separate manufacturing lines for the production of ISO insulation board, TPO roofing membranes, and PVC roofing membranes. The ISO insulation board production line utilizes MDI, polyol, and a blowing agent (e.g., pentane). The MDI and blended polyol/blowing agent material is transferred onto a bottom facer material. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed-cell foam. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to a RTO to control VOCs. The TPO and PVC roofing membrane production lines utilize a pneumatic conveyance system to convey the raw materials to feeder bins that meter the raw materials into the extruders. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calendar rolls that press the core onto the scrim. The sheet then passes to the cap extruder die, where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calendar rolls are employed to assist with bonding the cap to the scrim. BMCA has requested to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC cut saw) for supplementing its operations in the ISO plant. The new equipment will generate emissions of particulate matter, VOCs, and HAPs. DAQE-IN146030003-24 Page 5 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 7725.00 Carbon Monoxide 0 5.41 Nitrogen Oxides 0 6.44 Particulate Matter - PM10 0.37 12.77 Particulate Matter - PM2.5 0.37 4.96 Sulfur Dioxide 0 0.04 Volatile Organic Compounds 1.02 30.78 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) 1,4-Dioxane (1,4-Diethyleneoxide) (CAS #123911) 0 5489 Ethylene Glycol (CAS #107211) 2 5510 Generic HAPs (CAS #GHAPS) 23 323 Hexane (CAS #110543) 59 1759 Vinyl Chloride (CAS #75014) 0 320 Change (TPY) Total (TPY) Total HAPs 0.03 6.70 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Daily Spectrum on November 21, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] DAQE-IN146030003-24 Page 6 I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT II.A.1 Insulation Board & Roofing Membrane Production Plant II.A.2 RTO Rating: 10 MMBtu/hr Fuel: Natural gas II.A.3 ISO Foam Line II.A.4 ISO Foam Line Baghouse Rating: 27,300 cfm Controls: ISO foam line PM emissions II.A.5 Steam Generator Electric steam generator Listed for informational purposes only DAQE-IN146030003-24 Page 7 II.A.6 Thermal Heaters Rating: Less than 5.0 MMBtu/hr, each Fuel: Natural gas II.A.7 ISO Off-Line CNC Cut Saw (New Equipment) II.A.8 TPO Line II.A.9 One (1) TPO Fluidized Sand Bath (New Equipment) II.A.10 PVC Line Max extruder rating: 7,500 lbs/hr Number of extruders: Two (2) II.A.11 TPO and PVC Lines Baghouse Max rating: 3,550 cfm Filter efficiency: Equal to or greater than 98% II.A.12 Silo Bin Vent Rating: 1,300 cfm, each Number: Four (4) per silo Controls: Silo PM emissions II.A.13 Polypropylene Silo Rating: 10 cfm Number: Three (3) Control: Bin vent filters II.A.14 PVC Silos Number: Two (2) Control: Bin vent filter II.A.15 One (1) Storage Tank 35,000-gallon Pentane Tank Control: RTO II.A.16 Indoor Storage Tanks Three (3) 20,000-gallon MDI tanks Three (3) 20,000-gallon Polyol tanks One (1) 7,500-gallon K-Oct tank One (1) 7,500-gallon TCPP tank Listed for informational purposes only. All above tanks vent internally. DAQE-IN146030003-24 Page 8 SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Insulation Board and Roofing Membrane Production Plant II.B.1.a The owner/operator shall not allow visible emissions from any stationary source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall use only natural gas as fuel in the stationary equipment on site. [R307-401-8] II.B.2 Storage Tank Requirements II.B.2.a The owner/operator shall equip each MDI storage tank with coalescing or equivalent-type filters. [R307-401-8] II.B.2.b The owner/operator shall control VOC emissions during tank loading operations at all times by using a vapor recovery system or equivalent filter-type system. [R307-401-8] II.B.3 Baghouse/Bin Vent Requirements II.B.3.a The owner/operator shall route all emissions from the TPO and PVC lines raw material handling sources and the off-line CNC cut saw through their designated operating baghouse prior to emitting to the atmosphere. [R307-401-8] II.B.3.b The owner/operator shall route all emissions from the polypropylene and PVC silos through an operating bin vent prior to emitting to the atmosphere. [R307-401-8] II.B.4 RTO Requirements II.B.4.a The owner/operator shall control emissions from the ISO Foam Line with a unit RTO. All emissions from the ISO Foam Line shall be routed through the RTO before being vented to the atmosphere. [R307-401-8] II.B.4.b The owner/operator shall install an RTO that is equipped to handle no less than 29,182 standard cubic feet per minute (SCFM). [R307-401-8] II.B.4.c At all times while operating the RTO, the owner/operator shall maintain a temperature at or above 1,500oF in the RTO. [R307-401-8] II.B.4.c.1 The owner/operator shall monitor the operating temperature with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.4.c.2 The owner/operator shall continuously monitor the operating temperature with a thermocouple located in the oxidizer chamber. [R307-401-8] II.B.4.c.3 The minimum temperature reading of the thermocouple shall not be less than 1,488.75oF. The minimum electronic data historian sensitivity (minor division) is 20oF or as approved by the Director. [R307-401-8] II.B.4.d At least once every 12 months, the owner/operator shall have a third party calibrate the thermocouple in accordance with the manufacturer's recommendation. [R307-401-8] DAQE-IN146030003-24 Page 9 II.B.4.e The owner/operator shall operate and maintain the data acquisition system in accordance to the manufacturer's recommendations. [R307-401-8] II.B.4.f The owner/operator shall: A. Inspect the electronic data historian on a daily basis. B. Inspect the RTO on a weekly basis. [R307-401-8] II.B.4.f.1 The owner/operator shall: A. Maintain records of the inspections. B. Keep the inspections records for all periods the plant is in operation. [R307-401-8] II.B.5 ISO Line Off-Line CNC Cut Saw Baghouse Requirements II.B.5.a The owner/operator shall use a baghouse to control particulate emissions from the ISO off-line CNC cut saw. All exhaust air from the sawing operations shall be vented to the baghouse prior to being vented to the atmosphere. [R307-401-8] II.B.5.b The owner/operator shall install a baghouse that is certified to meet a particulate matter control efficiency of no less than 95%. [R307-401-8] II.B.5.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed baghouse. [R307-401-8] II.B.5.c The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the baghouse. [R307-401-8] II.B.5.c.1 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.5.d During operation of the baghouse, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.5.d.1 The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] II.B.5.d.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended static pressure differential for the unit; C. Daily static pressure differential readings; D. Date of reading. [R307-401-8] II.B.5.e At least once every 12 months, the owner/operator shall calibrate the pressure gauge in accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8] DAQE-IN146030003-24 Page 10 II.B.5.e.1 The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.6 Fugitive Dust Requirements II.B.6.a The owner/operator shall pave all hauls roads, parking lots, and loading/unloading areas on site. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN146030002-15 dated November 18, 2015 Is Derived From NOI dated September 25, 2024 DAQE-IN146030003-24 Page 11 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds Spectrum Publication Name: Spectrum Publication URL: www.thespectrum.com/ Publication City and State: St. George, UT Publication County: Washington Notice Popular Keyword Category: Notice Keywords: bmca Notice Authentication Number: 202411211251050013645 1761527881 Notice URL: Back Notice Publish Date: Thursday, November 21, 2024 Notice Content NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: BMCA Cedar City LLC Location: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant – 5080 West Highway 56, Cedar City, UT Project Description: BMCA Cedar City LLC (BMCA) is the owner and operator of an insulation board and roofing membrane production plant in Cedar City, Iron County. The facility operates three separate manufacturing lines for the production of polyisocyanurate (ISO) insulation board, thermoplastic polyolefin (TPO) roofing membranes, and polyvinyl chloride (PVC) roofing membranes. The ISO insulation board production line utilizes methylene diphenyl diisocyanate (MDI), polyol, and a blowing agent (e.g., pentane). The MDI and blended polyol/blowing agent material is transferred onto a bottom facer material. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed-cell foam. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to a regenerative thermal oxidizer (RTO) to control VOCs. The TPO and PVC roofing membrane production lines utilize a pneumatic conveyance system to convey the raw materials to feeder bins that meter the raw materials into the extruders. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calendar rolls that press the core onto the scrim. The sheet then passes to the cap extruder die, where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calendar rolls are employed to assist with bonding the cap to the scrim. BMCA has requested to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC cut saw) for supplementing its operations in the ISO plant. The new equipment will generate emissions of particulate matter, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before December 21, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at cbodell@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19- 1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Pub#10782481 Published November 21, 2024 The Spectrum UPAXLP Back DAQE-NN146030003-24 November 18, 2024 Daily Spectrum Legal Advertising Department 275 E Street St. George, UT 84770 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Daily Spectrum on November 21, 2024. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Five County Association of Governments cc: Iron County 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN146030003-24 Page 2 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: BMCA Cedar City LLC Location: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant – 5080 West Highway 56, Cedar City, UT Project Description: BMCA Cedar City LLC (BMCA) is the owner and operator of an insulation board and roofing membrane production plant in Cedar City, Iron County. The facility operates three separate manufacturing lines for the production of polyisocyanurate (ISO) insulation board, thermoplastic polyolefin (TPO) roofing membranes, and polyvinyl chloride (PVC) roofing membranes. The ISO insulation board production line utilizes methylene diphenyl diisocyanate (MDI), polyol, and a blowing agent (e.g., pentane). The MDI and blended polyol/blowing agent material is transferred onto a bottom facer material. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed-cell foam. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to a regenerative thermal oxidizer (RTO) to control VOCs. The TPO and PVC roofing membrane production lines utilize a pneumatic conveyance system to convey the raw materials to feeder bins that meter the raw materials into the extruders. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calendar rolls that press the core onto the scrim. The sheet then passes to the cap extruder die, where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calendar rolls are employed to assist with bonding the cap to the scrim. BMCA has requested to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC cut saw) for supplementing its operations in the ISO plant. The new equipment will generate emissions of particulate matter, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before December 21, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at cbodell@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: November 21, 2024 {{#s=Sig_es_:signer1:signature}} Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 1 State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper RN146030003 October 17, 2024 Brandon Burton BMCA Cedar City LLC 5080 West Highway 56 Cedar City, UT 84720 brandon.burton@gaf.com Dear Brandon Burton, Re: Engineer Review: Modification of Approval Order DAQE-AN146030002-15 to Add a Fluidized Sand Bath and an Off-line Custom Cut Saw Project Number: N146030003 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. BMCA Cedar City LLC should complete this review within 10 business days of receipt. BMCA Cedar City LLC should contact Christine Bodell at (385) 290-2690 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at cbodell@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 2 completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If BMCA Cedar City LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If BMCA Cedar City LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 3 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N146030003 Owner Name BMCA Cedar City LLC Mailing Address 5080 West Highway 56 Cedar City, UT, 84720 Source Name BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant Source Location 5080 West Highway 56 Cedar City, UT 84720 UTM Projection 310,102 m Easting, 4,173,443 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3086 (Plastics Foam Products) Source Contact Brandon Burton Phone Number (435) 216-6546 Email brandon.burton@gaf.com Billing Contact Brandon Burton Phone Number (435) 216-6546 Email brandon.burton@gaf.com Project Engineer Christine Bodell, Engineer Phone Number (385) 290-2690 Email cbodell@utah.gov Notice of Intent (NOI) Submitted September 25, 2024 Date of Accepted Application October 3, 2024 Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 4 Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 5 SOURCE DESCRIPTION General Description BMCA Cedar City LLC (BMCA) is the owner and operator of an insulation board and roofing membrane production plant in Cedar City, Iron County. The Facility operates three separate manufacturing lines for the production of polyisocyanurate (ISO) insulation board, thermoplastic polyolefin (TPO) roofing membranes, and polyvinyl chloride (PVC) roofing membranes. The ISO insulation board production line utilizes methylene diphenyl diisocyanate (MDI), polyol, and a blowing agent (e.g., pentane). The MDI and blended polyol/blowing agent material is transferred onto a bottom facer material. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed cell foam. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to a regenerative thermal oxidizer (RTO) to control VOCs. The TPO and PVC roofing membrane production lines utilize a pneumatic conveyance system to convey the raw materials to feeder bins that meter the raw materials into the extruders. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calendar rolls that press the core onto the scrim. The sheet then passes to the cap extruder die where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calendar rolls are employed to assist with bonding the cap to the scrim. NSR Classification: Minor Modification at Minor Source Source Classification Located in Attainment Area Iron County Airs Source Size: B Applicable Federal Standards None Project Proposal Modification of Approval Order DAQE-AN146030002-15 to Add a Fluidized Sand Bath and an Off-line Custom Cut Saw Project Description BMCA Cedar City LLC (BMCA) has requested to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC cut saw) for supplementing its operations in the ISO plant. The new equipment will generate emissions of particulate matter, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). EMISSION IMPACT ANALYSIS BMCA does not exceed the criteria pollutant or HAPs modeling thresholds outlined in R307-410-4 and R307-410-5, respectively. Therefore, no modeling is required at this time. [Last updated September 30, 2024] Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 6 Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 7 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 7725.00 Carbon Monoxide 0 5.41 Nitrogen Oxides 0 6.44 Particulate Matter - PM10 0.37 12.77 Particulate Matter - PM2.5 0.37 4.96 Sulfur Dioxide 0 0.04 Volatile Organic Compounds 1.02 30.78 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) 1,4-Dioxane (1,4-Diethyleneoxide) (CAS #123911) 0 5489 Ethylene Glycol (CAS #107211) 2 5510 Generic HAPs (CAS #GHAPS) 23 323 Hexane (CAS #110543) 59 1759 Vinyl Chloride (CAS #75014) 0 320 Change (TPY) Total (TPY) Total HAPs 0.03 6.70 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 8 Review of BACT for New/Modified Emission Units 1. BACT review regarding New Electrically Heated Fluidized Sand Bath The fluidized sand bath will be used solely for cleaning and maintenance purposes. PM10/PM2.5, and VOC emissions are estimated at approximately 1.2E-05 tons/year and 3.2E-05 tons/year, respectively. Due to the infrequent and low volume of emissions from the fluidized sand bath, the addition of a collection system or back-end control device is considered cost prohibitive. As such, the BMCA will utilize best design and operating practices as the BACT. Specifically, BMCA will operate the fluidized sand bath in accordance with the manufacturer's specifications and conduct routine maintenance on the equipment to ensure the optimal performance of the fluidized sand bath. BACT is also limiting visible emissions from the fluidized sand bath to 10% opacity. [Last updated October 17, 2024] 2. BACT review regarding New ISO Off-line CNC Cut Saw Emissions from the off-line CNC saw will consist of emissions of approximately 0.15 tpy of PM10/PM2.5, 1.03 tpy of VOCs, and 0.03 tpy of HAPs. Control technologies identified for controlled PM10 and PM2.5 emissions include a wet scrubber and a baghouse. A wet scrubber typically removes particulates from a gas stream by spraying it with a scrubbing liquid or by forcing it through a pool of liquid to remove particulates and other pollutants. Based on literature research, wet scrubbers generally provide a control efficiency around 80%. During use of a baghouse, particulates are removed from a gas stream by forcing the exhaust through a series of bags that are typically made of woven or felted fabric. Most baghouses can easily achieve a particulate control efficiency greater than 95%. Baghouses are therefore more effective at capturing fine particulates than wet scrubbers. In addition, wet scrubbers produce a wet sludge requiring disposal and have higher operating costs and lower removal efficiencies compared to baghouses/fabric filters. Therefore, BACT to control PM10 and PM2.5 from the off-line CNC saw is the use of a baghouse capable of achieving a particulate control efficiency of no less than 95%. The produced ISO boards are partially comprised of foam bubbles that contain VOCs and HAPs. The VOCs and HAPs are released when the ISO boards are cut with the off-line CNC saw. The non-fugitive emissions are estimated to be 0.77 tpy of VOCs and 0.02 tpy of HAPs. Due to the low volumes and infrequent VOC and HAPs emissions, additional add-on control technologies are considered cost prohibitive. Therefore, BACT to control VOCs and HAPs from the new off-line CNC saw is best design and operation practices. BMCA will operate the saw in accordance with the manufacturer's specifications and will conduct routine maintenance activities to ensure optimal performance of the CNC saw. BACT is also limiting visible emissions from the off-line CNC cut saw to 10% opacity. [Last updated October 17, 2024] SECTION I: GENERAL PROVISIONS Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 9 The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 10 II.A.1 Insulation Board & Roofing Membrane Prod. Plant II.A.2 Regenerative Thermal Oxidizer (RTO) Rating: 10 MMBtu/hr Fuel: Natural gas II.A.3 ISO Foam Line II.A.4 ISO Foam Line Baghouse Rating: 27,300 cfm Controls: ISO foam line PM emissions II.A.5 Steam Generator Electric steam generator Listed for informational purposes only II.A.6 Thermal Heaters Rating: Less than 5.0 MMBtu/hr, each Fuel: Natural gas II.A.7 NEW ISO Off-Line CNC Cut Saw (New Equipment) II.A.8 TPO Line II.A.9 NEW One (1) TPO Fluidized Sand Bath (New Equipment) II.A.10 PVC Line Max extruder rating: 7,500 lbs/hr Number of extruders: Two (2) II.A.11 TPO and PVC Lines Baghouse Max rating: 3,550 cfm Filter efficiency: Equal to or greater than 98% II.A.12 Silo Bin Vent Rating: 1,300 cfm, each Number: Four (4) per silo Controls: Silo PM emissions II.A.13 Polypropylene Silo Rating: 10 cfm Number: Three (3) Control: Bin vent filters II.A.14 PVC Silos Number: Two (2) Control: Bin vent filter II.A.15 NEW One (1) Storage Tank Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 11 35,000-gallon Pentane Tank Control: RTO II.A.16 NEW Indoor Storage Tanks Three (3) 20,000-gallon MDI tanks Three (3) 20,000-gallon Polyol tanks One (1) 7,500-gallon K-Oct tank One (1) 7,500-gallon TCPP tank Listed for informational purposes only. All above tanks vent internally. SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Insulation Board and Roofing Membrane Production Plant II.B.1.a NEW The owner/operator shall not allow visible emissions from any stationary source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b NEW The owner/operator shall use only natural gas as fuel in the stationary equipment on site. [R307-401-8] II.B.2 NEW Storage Tank Requirements II.B.2.a NEW The owner/operator shall equip each MDI storage tank with coalescing or equivalent-type filters. [R307-401-8] II.B.2.b NEW The owner/operator shall control VOC emissions during tank loading operations at all times by using a vapor recovery system or equivalent filter-type system. [R307-401-8] II.B.3 NEW Baghouse/Bin Vent Requirements II.B.3.a NEW The owner/operator shall route all emissions from the TPO and PVC lines raw material handling sources and the off-line CNC cut saw through their designated operating baghouse prior to emitting to the atmosphere. [R307-401-8] II.B.3.b NEW The owner/operator shall route all emissions from the polypropylene and PVC silos through an operating bin vent prior to emitting to the atmosphere. [R307-401-8] II.B.4 NEW Regenerative Thermal Oxidizer (RTO) Requirements Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 12 II.B.4.a NEW The owner/operator shall control emissions from the ISO Foam Line with a regenerative thermal oxidizer unit (RTO). All emissions from the ISO Foam Line shall be routed through the RTO before being vented to the atmosphere. [R307-401-8] II.B.4.b NEW The owner/operator shall install an RTO that is equipped to handle no less than 29,182 standard cubic feet per minute (SCFM). [R307-401-8] II.B.4.c NEW At all times while operating the RTO, the owner/operator shall maintain a temperature at or above 1,500oF in the RTO. [R307-401-8] II.B.4.c.1 NEW The owner/operator shall monitor the operating temperature with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8] II.B.4.c.2 NEW The owner/operator shall continuously monitor the operating temperature with a thermocouple located in the oxidizer chamber. [R307-401-8] II.B.4.c.3 NEW The minimum temperature reading of the thermocouple shall not be less than 1,488.75oF. The minimum electronic data historian sensitivity (minor division) is 20oF or as approved by the Director. [R307-401-8] II.B.4.d NEW At least once every 12 months, the owner/operator shall have a third party calibrate the thermocouple in accordance with the manufacturer's recommendation. [R307-401-8] II.B.4.e NEW The owner/operator shall operate and maintain the data acquisition system in accordance to the manufacturer's recommendations. [R307-401-8] II.B.4.f NEW The owner/operator shall: A. Inspect the electronic data historian on a daily basis B. Inspect the RTO on a weekly basis [R307-401-8] II.B.4.f.1 NEW The owner/operator shall: A. Maintain records of the inspections B. Keep the inspections records for all periods the plant is in operation. [R307-401-8] II.B.5 NEW ISO Line Off-Line CNC Cut Saw Baghouse Requirements II.B.5.a NEW The owner/operator shall use a baghouse to control particulate emissions from the ISO off-line CNC cut saw. All exhaust air from the sawing operations shall be vented to the baghouse prior to being vented to the atmosphere. [R307-401-8] II.B.5.b NEW The owner/operator shall install a baghouse that is certified to meet a particulate matter control efficiency of no less than 95%. [R307-401-8] Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 13 II.B.5.b.1 NEW To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed baghouse. [R307-401-8] II.B.5.c NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the static pressure differential across the baghouse. [R307-401-8] II.B.5.c.1 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.5.d NEW During operation of the baghouse, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.5.d.1 NEW The owner/operator shall record the static pressure differential at least once per operating day while the baghouse is operating. [R307-401-8] II.B.5.d.2 NEW The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended static pressure differential for the unit; C. Daily static pressure differential readings; D. Date of reading [R307-401-8] II.B.5.e NEW At least once every 12 months, the owner/operator shall calibrate the pressure gauge in accordance with the manufacturer's instructions or replace the pressure gauge. [R307-401-8] II.B.5.e.1 NEW The owner/operator shall maintain records of the pressure gauge calibrations and replacements. [R307-401-8] II.B.6 NEW Fugitive Dust Requirements II.B.6.a NEW The owner/operator shall pave all hauls roads, parking lots, and loading/unloading areas on site. [R307-401-8] Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 14 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN146030002-15 dated November 18, 2015 Is Derived From NOI dated September 25, 2024 REVIEWER COMMENTS 1. Comment regarding Source Emission Estimates and DAQ Acceptance: Off-Line Cut Saw: The volume removed per cycle is 0.21 ft3. A solids density of 1.98 lb/ft3 and rate of 3 cycles per hour results in a PM10/PM2.5 rate of 1.89 lb/hour. The saw will operate for 4,680 cycles per hour and emit 1.48 tpy pf PM10/PM2.5. PM emissions from the saw are controlled with a fabric filter that has a PM10/PM2.5 90% capture efficiency and a PM10/PM2.5 85% control efficiency. The resulting emissions are 0.45 lb/hour and 0.35 tpy of PM10 and PM2.5, each. VOC/HAPs emissions from the off-line CNC cut saw are based on worst-case chemical composition by weight in the raw material and data from raw material safety data sheet (SDS) information. Sand Bath: Emissions are based on 365 lbs of resin removed per year. Emission factors for the polymers present in the resin are based on the papers "Development of Emission Factors for Polypropylene Processing-1999" and "Development of Emission Factors for Polyethylene Processing-1996" from the Journal of the Air & Waste Management Associate. [Last updated October 2, 2024] 2. Comment regarding Additional Changes to 2015 Approval Order: According to a Compliance Inspection (see memorandum DAQE-CI14603-22, dated April 5, 2022), the following information was gathered at the time of inspection: - Equipment ID# II.A.6 (one (1) natural gas-fired thermal heater rated at 5.0 MMBtu/hr) in the 2015 AO: This thermal heater is actually two separate heaters rated at a total of 1.875 MMBtu/hr each. The current AO has been updated to reflect this change. - A single 35,000-gallon pentane tank, located outside on the north end of the building, is in use at the source location. The source indicated this tank has no external emission points and is used as a blowing agent in the process. The process area was observed to be completely enclosed within the building with all emissions being routed through the RTO prior to discharging to the atmosphere. This tank has been added to the AO approved equipment list. Emissions from the tank are expected to be negligible (<0.01 tpy VOCs). - The source maintains several product tanks inside the building as follows: -Three 20,000-gallon MDI tanks -Three 20,000-gallon Polyol tanks -One 7,500-gallon K-Oct tank -One 7,500-gallon TCPP tank Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 15 The above tanks are all located indoors and do not vent to the atmosphere. The tanks have been added to the AO for informational purposes. BMCA also indicated in its NOI that the facility no longer uses a chart recorder, as referenced in Conditions I.B.1.e.1 and I.B.1.e.2 of the 2015 AO. Instead, it uses an electronic data historian to record the applicable operating parameters for the RTO. Therefore, the current AO has been revised to replace "chart recorder" with "electronic data historian." Condition II.B.1.e.1 in the 2015 AO specifies that "The minimum tolerance of the thermocouple is ±10.5oF or ±0.75%.". This equates to a temperature tolerance of between 1489.5oF and 1510.5oF or 1488.75oF and 1511.25oF, respectively. The minimum acceptable temperature is therefore equal to 1488.75oF. The condition has been updated accordingly. BMCA also indicated that the facility currently uses an activated carbon filter on the MDI tank which is capable of equivalent or better control compared to coalescing filters. The facility also currently uses activated carbon filters on the loading/unloading tanks. These filters provide equivalent or better control than a vapor recovery system. Therefore, Conditions II.B.1.i and II.B.1.j in the 2015 AO have been updated to allow for these physical changes. [Last updated October 17, 2024] 3. Comment regarding Federal Standard and Title V Applicability: The NSPS and MACT federal standards were reviewed, and none were determined to be applicable to the Facility. Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. Therefore, Title V does not apply to this facility. [Last updated September 30, 2024] Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 16 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code Engineer Review N146030003: BMCA Cedar City LLC- Insulation Board and Roofing Membrane Production Plant October 17, 2024 Page 17 VOC Volatile organic compounds Criteria Pollutant AO PTE Project Total New PTE NOX 6.44 0 6.44 CO 5.41 0 5.41 PM10 12.4 2.14E-01 12.61 PM2.5 4.59 2.14E-01 4.80 VOC 29.76 1.00E+00 30.76 SO2 0.04 0 0.04 HAP 6.66 0.04 6.70 HAPs tab more de CO2E 7725 0 7725.00 **matches NOI within tolerance Off-Line Saw: Particulate Emission Calculations Process Information Hours of Operation Anually Volume Removed per Cycle (ft3) [1] Density (lb/ft3) [2] No. cycles per Hour No. cycles per Year [3] Weight per Hour (lb/hr) [4] Weight per Year (tpy) [5] 780 0.21 1.98 3 4680 1.89 1.48 PTE SummaryUncontrolled PM10/PM2 5 Uncontrolled PM10/PM2 5 Controlled PM10 Emissions Controlled PM10 Controlled PM2 5 Controlled PM2 5 Controlled PM10 Controlled PM10 1.89 1.48 0.09 0.07 0.09 0.07 0.19 0.15 [1] Provided by the facility. The volume of cut is based on the following: Cutting blade kerf = 0.125 in. ; total cut path comprised of half cuts [2] Provided by facility [3] 10 min/ cycle, 3 cycles/hour, 30 hours/week, 90 cycles/week, 52 weeks/year [4][5] Safety factors of 1.5 has been applied [6][7] Dust collector PM10 eff = 95%, capture efficiency = 90% [8][9] Dust collector PM2.5 eff = 95%, capture efficiency = 90% Off-Line Saw: VOC Emission Calculations Process Information Hours of Operation Maximum Foam Percent Pentane (%) Hexane (%) 1,4-Dioxane (%) Ethylene Glycol Diethylene Glycol 5.7 5 0.1 Raw Material C Non-Fugitive Fu Blowing Agent Polyol Con 29.39 Release Ra 1560 25,000 98.6 100 3 0.10 1 5 PTE Summary [13]Pentane Emissions Pentane Emissions Hexane Emissions Hexane Emissions 1,4-Dioxane Emissions 1,4-Dioxane Emissions Ethylene Glycol Ethylene Glycol1.25 0.97 0.04 0.03 0.00 0.00 0.00 0.00 TotalsHAPs Emisisons (lbs/hr) HAPs Emissions (tpy) VOC Emisisons (lbs/hr) VOC Emissions0.05 0.04 1.29 1.00 [10] Based on product composition data [11] Release rate used at GAF Gainesville, TX and Statesboro, GA plants [12] Worst-case composition by weight in raw material. Data from raw material SDS information. [13] 1.25 safety factor Off-Line Saw: Total Emisisons PM10 Emissions PM2.5 Emissions HAPs Emissions (tpy) VOC Emissions *matches NOI within 0.21 0.21 0.04 1.00 Controlled PM2 5 Controlled PM2 50.19 0.15 and angled cuts = 1469.95in. ; Average cut thickness = 2 in. Flame MDI Catalyst 2.94 0.64 0.025 0 1 Triethylene Glycol Tetraethylene Glycol tris(2-chloro-1- methylethyl) MDI (%) VOC (%) Composition [12] ugitive ntent ate (%) [11] 2.00 1 99.5 100.00 41 Diethylene Glycol Diethylene Glycol Triethylene Glycol Triethylene Glycol Tetraethylene Glycol Tetraethylene Glycol TCPP Emissions TCPP Emissions MDI Emissions (lbs/hr) 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 MDI Emissions VOC Emissions VOC Emissions0.00 0.01 0.01 Process Information Parts Cleaned per Day Resin Removed per Part Resin Removed Resin 1 1.00 1 365 Highest PM Content (lb/lb resin) Highest VOC Content (lb/lb resin) Highest Formaldehyde Highest Acrolein Highest Acetaldehyde Highest Propionaldehyde Highest Methyl Ethyl Ketone 6.84E-05 1.77E-04 1.38E-06 5.00E-08 5.40E-07 7.00E-08 2.40E-07 PTE SummaryPM Emissions (lb/hr) PM Emissions (tpy) VOC Emissions (lb/hr) VOC Emissions Formaldehyde Emissions Formaldehyde Emissions Acrolein Emissions2.85E-06 1.25E-05 7.38E-06 3.23E-05 5.75E-08 2.52E-07 2.08E-09 HAPs Emisisons (lbs/hr) HAPs Emissions (tpy)0.00 0.00 Highest Acrylic Acid Content8.00E-08 Acrolein Emissions Acetaldehyde Emissions Acetaldehyde Emissions Propionaldehyde Emissions Propionaldehyde Emissions Methyl Ethyl Ketone Methyl Ethyl Ketone Acrylic Acid Emissions9.13E-09 2.25E-08 9.86E-08 2.92E-09 1.28E-08 1.00E-08 4.38E-08 3.33E-09 Acrylic Acid Emissions1.46E-08 Off-Line Saw Hexane 2.21E-02 7.36E-03 1,4-Dioxane 7.59E-05 2.53E-05 Ethylene Glycol 7.59E-04 2.53E-04 Diethylene Glycol 3.80E-03 1.27E-03 Triethylene Glyco 1.52E-03 5.06E-04 Tetraethylene Gly 7.59E-04 2.53E-04 tris(2-chloro-1-me 1.89E-03 6.30E-04 MDI 4.36E-04 1.45E-04 Total HAPs 3.13E-02 1.04E-02 Fluidized Sand Bath Formaldehyde Acrolein Acetaldehyde Propionaldehyde Methyl Ethyl Ketone Acrylic Acid Total HAPs Tpy lb/year 0.029460 58.92 0.000101 0.20 0.001012 2.02 0.005070 10.14 AO New PTE 0.002026 4.05 Hexane 0.001012 2.02 0.85 0.879460 0.002520 5.04 Ethylene Glycol 0.000581 1.16 2.7539 2.754912 0.041782 83.56 General HAPs 0.15 0.161310 0.000000 0.00 0.000000 0.00 0.000000 0.00 0.000000 0.00 0.000000 0.00 0.000000 0.00 0.000000 0.00 BMCA Cedar City LLC Approval Order Application i Prepared for: 5080 West Highway 56 Cedar City, Utah 84720 Prepared By: Tora Consulting, LLC 1320 Main St, Ste. 300 Columbia, SC 29201 Tora Project No. 23-024 September 2024 BMCA Cedar City LLC Approval Order Application BMCA Cedar City LLC Approval Order Application ii TABLE OF CONTENTS 1 EXECUTIVE SUMMARY .............................................................................................. 1 2 PROJECT DESCRIPTION .............................................................................................. 2 3 PROCESS DESCRIPTION ............................................................................................. 4 3.1 TPO & PVC ROOFING MEMBRANE PRODUCTION LINES .......................... 4 Fluidized Sand Bath ................................................................................. 4 3.2 ISO FOAM BOARD PRODUCTION LINE ......................................................... 4 Off-Line CNC saw ................................................................................... 5 4 EMISSION CALCULATIONS ....................................................................................... 6 4.1 FLUIDIZED SAND BATH ................................................................................... 6 4.2 OFF-LINE CNC SAW ........................................................................................... 7 5 REGULATORY APPLICABILITY ................................................................................ 8 5.1 PERMITTING PROGRAMS ................................................................................. 8 Title V (Part 70) Operating Permit Program ............................................ 8 Prevention of Significant Deterioration ................................................... 8 Nonattainment Area New Source Review ............................................... 8 Utah Permitting ........................................................................................ 8 5.2 NEW SOURCE PERFORMANCE STANDARDS .............................................. 8 5.3 NATIONAL EMISSION STANDARDS FOR HAPS .......................................... 9 5.4 UTAH REGULATIONS & EMISSION STANDARDS ....................................... 9 Emission Standards: Fugitive Emissions and Fugitive Dust (UAC R307- 205) .......................................................................................................... 9 Permits: New and Modified Sources (UAC R307-401) .......................... 9 Visibility (UAC R307-406) ................................................................... 10 Permits: Emissions Impact Analysis (UAC R307-410) ......................... 10 Permits: Ozone Offset Requirements in Davis and Salt Lake Counties (UAC R 307-420) .................................................................................. 11 Permits: Ozone Offset Requirements in Davis and Salt Lake Counties (UAC R307-421) ................................................................................... 11 6 BACT ANALYSIS ........................................................................................................ 12 6.1 BACT ANALYSIS METHODOLOGY .............................................................. 12 6.2 BACT ANALYSIS FOR FLUIDIZED SAND BATH (PM/PM10/PM2.5 & VOCs) .............................................................................................................................. 14 6.3 BACT ANALYSIS FOR OFF-LINE CNC SAW (PM/PM10/PM2.5) ................... 14 BMCA Cedar City LLC Approval Order Application iii Step 1 – Identify Available Control Options ......................................... 14 Step 2 – Eliminate Technically Infeasible Options ................................ 15 Step 3 – Rank Control Options .............................................................. 15 Step 4 – Evaluate Impact of Control Options ........................................ 15 Step 5 – Select BACT ............................................................................ 15 6.4 BACT ANALYSIS FOR OFF-LINE CNC SAW (VOCs) .................................. 15 Step 1 – Identify Available Control Options ......................................... 15 Step 2 – Eliminate Technically Infeasible Options ................................ 15 Step 3 – Rank Control Options .............................................................. 15 Step 4 – Evaluate Impact of Control Options ........................................ 16 Step 5 – Select BACT ............................................................................ 16 LIST OF TABLES Table 1-1 | Approval Order Administrative Revisions Table 2-1 | New Emission Units Table 4-1 | Facility-Wide Potential Emissions Summary Table 5-1 | NAAQS Impacts Analysis Table 5-2 | Summary of HAP Impact Analysis LIST OF FIGURES Figure 2-1 | General Facility Location LIST OF APPENDICES A: Utah DEQ Approval Order Application Forms B: Emission Calculations C: Safety Data Sheets D: RBLC Database Results BMCA Cedar City LLC Approval Order Application 1 1 EXECUTIVE SUMMARY BMCA Cedar City LLC (BMCA), dba GAF Materials Corporation, operates a roofing materials manufacturing facility located at 5080 West Highway 56 in Cedar City, Utah (Facility). The Facility operates three separate manufacturing lines for the production of polyisocyanurate (ISO) insulation board, thermoplastic polyolefin (TPO) roofing membranes, and polyvinyl chloride (PVC) roofing membranes. The Facility operates under Approval Order DAQE-AN146030002-l5 (Approval Order) issued by the Utah Department of Environmental Quality (DEQ) on 18 November 2015. The Facility plans to install one (1) new fluidized sand bath for maintenance purposes in the TPO plant and one (1) new off-line CNC custom cut saw (off-line CNC saw) for supplementing its operations in the ISO plant (Project). The new equipment will generate minor emissions of particulates, volatile organic compounds (VOCs), and federally listed hazardous air pollutants (HAPs). Emission calculations demonstrate that the new equipment will not cause Facility-wide potential emissions to exceed the Title V major source threshold of 100 tons per year (tons/year) for any criteria pollutant, 10 tons/year of a single HAP, or 25 tons/year of aggregate HAP emissions. As a result, this application is being submitted as a Notice of Intent (NOI) in accordance with Rule 307-401-5 of the Utah Administrative Code (UAC R307- 401-5) to request authorization to construct the new process equipment. The required Utah DEQ application forms are included in Appendix A. Emission calculations and raw material safety data sheets (SDSs) are included in Appendices B and C, respectively. In addition to the Project described above, the Facility is requesting a few minor administrative revisions to its current Approval Order as summarized in Table 1-1 below. Table 1-1 | Approval Order Administrative Revisions Permit Condition Requested Revision Notes II.A.6 Revise to: Thermal Heaters Number of Heaters: Two (2) Rating: 2.5 MMBtu/hr per heater [1] II.B.1.e.1 Revise “chart recorder” to “electronic data historian.” [2] II.B.1.e.2 Revise “chart recorder” to “electronic data historian.” [2] II.B.1.e.2 Remove “and replacement of the circular chart.” [2] II.B.1.I Revise to: The MDI tanks shall be equipped with coalescing or equivalent-type filters. [3] II.B.1.j Revise to: “All loading and unloading tanks shall be equipped with a vapor recovery or equivalent filter-type system.” [4] Notes: [1] The Facility operates two separate thermal heaters with a combined maximum heat input of 5 MMBtu/hr. [2] The Facility no longer uses a chart recorder. Instead, it uses an electronic data historian to record the applicable operating parameters for the RTO. [3] The Facility currently uses an activated carbon filter on the MDI tank which is capable of equivalent or better control compared to coalescing filters. [4] The Facility currently uses activated carbon filters on the loading/unloading tanks. These filters provide equivalent or better control than a vapor recovery system. BMCA Cedar City LLC Approval Order Application 2 2 PROJECT DESCRIPTION BMCA manufactures foam insulation board and plastic membranes for use primarily in the roofing industry at its plant located at 5080 West Highway 56 in Cedar City, Utah. The approximate location of the Facility is depicted in Figure 2-1. The North American Datum of 1983 (NAD83) coordinates of the site are (approximately) 37° 42’ 20.98’’ N latitude and 113° 09’ 13.01’’ W longitude. The activities at the Facility generally fall under Standard Industrial Classification (SIC) code 3086 Plastic Foam Products, and North American Industrial Classification System (NAICS) code 326130 Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing. Figure 2-1 | General Facility Location The Facility operates a variety of existing process equipment including, but not limited to, extruders, storage silos and natural gas-fired heaters. As part of the Project, the Facility plans to install the following equipment identified in Table 2-1. BMCA Cedar City LLC Approval Order Application 3 Table 2-1 | New Emission Units Equipment Description Emission Unit ID Control Device Description Control Device ID Electrically Heated Fluidized Sand Bath SB01 -- -- Off-Line CNC Saw VS01 Baghouse[1] BH02 Notes: [1] Particulate emissions from the off-line CNC saw will be controlled using a new baghouse. No controls will be used for VOC emissions. No changes to the Facility’s maximum throughput or production rates will occur as a result of the Project. A generalized description of the Facility’s production operations is provided in Section 3. The development of the emission calculations for the new emission sources is discussed in Section 4. BMCA Cedar City LLC Approval Order Application 4 3 PROCESS DESCRIPTION The Facility operates three separate production lines identified in its Approval Order as (1) ISO Foam Line, (2) TPO Line, and (3) PVC Line. As no changes are occurring to the Facility’s primary production operations, the process descriptions provided herein contain only a high-level account of the various operations. Refer to the Facility’s latest Approval Order application for additional process-specific details. 3.1 TPO & PVC ROOFING MEMBRANE PRODUCTION LINES Raw materials are received via truck and rail and stored in Gaylord boxes, sacks, and silos equipped with bin vents for collection of pellets that may be displaced by pneumatic air during loading events. A pneumatic conveyance system is employed to convey the raw materials to feeder bins that meter the raw materials into the extruders at the appropriate rate. In the extruders, polymers and additives are blended and heated. The core extrudate passes through a die and is applied directly to a scrim reinforcement sheet, typically woven polyester material. After application of the core (bottom of the roofing membrane) onto the scrim, the sheet passes through a series of calender rolls that press the core onto the scrim. The sheet then passes to the cap extruder die where the cap (top of the roofing membrane) extrudate is applied to the other side of the scrim. Additional calender rolls are employed to assist with bonding the cap to the scrim. Emissions generated from the TPO & PVC roofing membrane production lines are captured and routed first through a baghouse for particulate control and then to a regenerative thermal oxidizer (RTO) to control VOCs. Fluidized Sand Bath The Facility plans to install a fluidized sand bath to remove cured resin from various mechanical parts. The fluidized sand bath is an electrically heated bath consisting of small, loosely packed, solid aluminum oxide particles. A flow of hot air is passed upwards through the bath, mobilizing the particles into a fluidized state. Mechanical parts are then placed within the bath for a specified time allowing the fluidized aluminum to melt the resin from the metal substrate. As the bath is composed of tiny, inert aluminum oxide particles, evaporation/volatilization does not occur. Therefore, air emissions are only generated from melting the resin. 3.2 ISO FOAM BOARD PRODUCTION LINE The foam board manufacturing process utilizes three (3) primary raw materials: methylene diphenyl diisocyanate (MDI), polyol, and a blowing agent (e.g., pentane). These liquid raw materials are received via truck or railcar and are stored onsite in aboveground storage tanks. The MDI and blended polyol/blowing agent material is pumped through the spray heads at the pour table onto a bottom facer material in evenly spaced intervals. Upon contact, the materials exothermically react, polymerize, and cross-link to rapidly form rigid closed cell foam. The blowing agent is trapped within the foam’s closed cells to form the void spaces. Once the initial reaction occurs, the blowing agent is “locked” into the foam and cannot be released unless void spaces are destroyed. The foam board is ultimately transferred to a series of enclosures to be cut to final dimensions. Emissions generated from the ISO foam board production line are captured and routed first through a baghouse for particulate control and then to an RTO to control VOCs. BMCA Cedar City LLC Approval Order Application 5 Off-Line CNC saw The Facility plans to install one off-line CNC saw to enhance its cutting operations. The CNC saw will be used to cut ISO board into various shapes for certain specialized products. Particulate emissions generated during operation of the saw will be captured via an exhaust hood and routed to a new baghouse. Minor quantities of volatile organic compounds (VOCs) will also be produced when cutting the pentane foam bubbles contained within the ISO board. However, VOC controls will not be used, as VOC emissions are estimated to be insignificant. BMCA Cedar City LLC Approval Order Application 6 4 EMISSION CALCULATIONS Emissions from this Project have been estimated as described in this section. Facility-wide potential emissions are summarized in Table 4-1. Detailed emission calculations are provided in Appendix B. Table 4-1 | Facility-Wide Potential Emissions Summary Pollutant Pre-Project Facility-Wide Emissions Project-Only Emissions Post-Project Facility-Wide Emissions tons/year tons/year tons/year PM 12.40 0.22 12.62 PM10 12.40 0.22 12.62 PM2.5 4.59 0.37 4.96 NOx 6.44 -- 6.44 SO2 0.04 -- 0.04 CO 5.41 -- 5.41 VOCs 29.76 1.02 30.78 CO2e 7,725 -- 7,725 Total HAPs 6.66 0.03 6.69 A discussion of the calculation methodologies for the Facility’s new Project equipment is provided in the following sections. 4.1 FLUIDIZED SAND BATH Emissions from the fluidized sand bath are only generated via the melting of the plastic polymer and will comprise trivial quantities of particulates, VOCs, and HAPs. The maximum quantity of polymer to be removed was estimated based on the following process information: • The Facility plans to clean a maximum of one part per day (parts/day) which could contain a maximum of 0.5 pounds (lb) of cured polymer. • This number was doubled to conservatively account for potential variability in the cleaning operation (i.e., maximum daily quantity of polymer removed = 1 lb/day). • A maximum annual quantity of 365 lb/year was then calculated by assuming the fluidized sand bath operates continuously for 365 days/year. Using the maximum annual quantity of removed polymer, emissions were estimated assuming the polymer removal operations could be mathematically modeled as a plastic extrusion operation. Emission factors for plastic extrusion were obtained from the Journal of the Air & Waste Management Association for polyethylene and polypropylene and the maximum emission factor between the two polymers was selected for conservatism. The emission factors were coupled with the estimated maximum quantity of removed polymer to calculate hourly and annual emissions. Detailed emission calculations are provided in Appendix B-5. BMCA Cedar City LLC Approval Order Application 7 4.2 OFF-LINE CNC SAW Emissions associated with the foam board manufacturing process (L01) include particulates, VOCs, and HAPs. Exhaust from the new off-line CNC saw will be captured and routed to a baghouse prior to discharging to the atmosphere. Emissions were estimated by calculating a maximum weight of material to be removed by the CNC saw and incorporating the appropriate control efficiency1 provided by the new baghouse. Detailed calculations for particulate emissions are provided in Appendix B-2. Minor quantities of VOC and HAP emissions will be generated when the ISO board is cut to dimension, as the cutting operation will liberate gaseous bubbles entrapped within the foam. Emissions were estimated based on the maximum foam production rate, the maximum content of each raw material in the foam product, the maximum content of each chemical in the raw material2, and estimated chemical release rates. A final emission rate for the off-line CNC saw was calculated based on 98.6% of the total VOC emissions generated from the ISO foam line being emitted from other process sources such as, but not limited to, the pour table.3 Therefore, approximately 1.4% of total VOC emissions were assumed to be emitted from the off-line CNC saw. Detailed emission calculations are provided in Appendix B-3. A summary of total emissions generated from the off-line CNC saw is provided in Appendix B-4. 1 The baghouse will utilize MERV 15 ultra web filters. Estimated control efficiencies for a MERV 15 filter were taken from the USEPA’s website at: https://www.epa.gov/indoor-air-quality-iaq/what-merv-rating 2 Determined from review of the material’s SDS. 3 This percentage was determined from a recent engineering study conducted at GAF’s sister-facility in Statesboro, Georgia. BMCA Cedar City LLC Approval Order Application 8 5 REGULATORY APPLICABILITY An air quality regulatory applicability analysis has been conducted for the Facility. The applicability of federal and state regulations is discussed below. 5.1 PERMITTING PROGRAMS Title V (Part 70) Operating Permit Program The Title V (Part 70) Operating Permit Program requires facilities that meet the definition of a major source to obtain a Title V Operating Permit. According to 40 CFR Part 70.2, a major source is defined as a stationary source that has the potential to emit 100 tons/year or more of any criteria pollutant,4 10 tons/year or more of a single HAP, and/or 25 tons/year or more of total combined HAPs. Post-Project potential emissions from the Facility will remain below these thresholds. Therefore, the Facility is not subject to the Title V Operating Permit program and will continue to operate as a minor source. Prevention of Significant Deterioration The federal Prevention of Significant Deterioration (PSD) program, codified in 40 CFR §52.21, requires any new major stationary source or major modification at an existing major stationary source to obtain a major source air quality construction permit before commencing construction operations. The Utah DEQ has incorporated the federal PSD program by reference at UAC R307-405. The Facility does not fall into one of the 28 PSD source categories specified at 40 CFR §52.21(b)(1)(i); therefore, the applicable PSD major source threshold is 250 tons/year of any regulated new source review (NSR) pollutant. As indicated in Appendix B-1, post-Project potential emissions from the Facility are less than the PSD major source threshold. Therefore, the PSD program does not apply. Nonattainment Area New Source Review The non-attainment new source review (NNSR) program applies to a facility located in a nonattainment area that emits or has the potential to emit greater than threshold quantities of nonattainment pollutants. The Utah DEQ has incorporated the federal NNSR provisions at UAC R307-403. The Facility is located in Iron County, which is listed as either being in attainment or unclassifiable status5 with all National Ambient Air Quality Standards (NAAQS). Therefore, the provisions of the NNSR program do not apply to the Facility. Utah Permitting This application is being submitted as a NOI, in accordance with UAC R307-401-5, to request a minor modification to the Facility’s existing Approval Order for the installation of new process equipment. 5.2 NEW SOURCE PERFORMANCE STANDARDS New Source Performance Standards (NSPS), codified in 40 CFR Part 60, establish pollutant emission limits and monitoring, reporting, and recordkeeping requirements for various emission sources based on source 4 Does not include PM but includes PM10 and PM2.5. 5 https://www3.epa.gov/airquality/greenbook/ancl.html. BMCA Cedar City LLC Approval Order Application 9 type and size. The EPA has delegated authority to the Utah DEQ for most NSPS subparts6 which have been incorporated by reference at UAC R307-210.7 The NSPS applies to new, modified, or reconstructed sources. NSPS standards are developed for particular industrial source categories. The applicability of a particular NSPS to a facility can be ascertained based on the industrial source category covered. The NSPS were reviewed, and none were determined to be applicable to the Project. 5.3 NATIONAL EMISSION STANDARDS FOR HAPS National Emissions Standards for Hazardous Air Pollutants (NESHAP), codified in 40 CFR Parts 61 and 63, regulate HAP emission from various affected sources. Similar to the NSPS, the Utah DEQ has been delegated authority for certain NESHAPs.8 Note that the Facility will remain an area source (i.e., not a major source) of HAPs as defined in 40 CFR §63.2 following completion of the Project as post-Project potential emissions will remain less than the major source thresholds of 10 tons/year for each individual HAP and 25 tons/year for aggregate HAP emissions. The NESHAPs were reviewed, and none were determined to be applicable to the Project. 5.4 UTAH REGULATIONS & EMISSION STANDARDS Emission Standards: Fugitive Emissions and Fugitive Dust (UAC R307-205) This Rule applies statewide to all sources of fugitive emissions and fugitive dust, except for agricultural or horticultural activities specified in 19-2-114(1)-(3), and any source listed in section IX, Part H of the state implementation plan or located in a nonattainment or maintenance area for particulate matter with an aerodynamic diameter of 10 microns or less (PM10). Pursuant to UAC R307-205-4, fugitive emissions from Project sources will not exceed an opacity of 20%. In addition, the Facility will comply with the applicable fugitive dust provisions of UAC R307-205-5. Permits: New and Modified Sources (UAC R307-401) Pursuant to UAC R307-401-3, an approval order is required prior to the installation of any new air pollution sources at existing permitted facilities. As such, this NOI application has been prepared to request authorization from the Utah DEQ to install a new fluidized sand bath and off-line CNC saw. Post-Project Facility-wide potential emissions will not exceed the Title V major source thresholds. Therefore, the Facility will remain a minor source. This NOI application has been prepared in accordance with the NOI criteria outlined in UAC R307-401-5. The required NOI application forms are provided in Appendix A. A technology review has been performed to establish best available control technology (BACT) from Project sources, as required by UAC R307- 401-5(d). The results of the BACT analysis are summarized in Section 6. 6 US EPA Region 8 Delegation Summary published April 20, 2021. 7 According to UAC 307-210-1 published July 15, 2025, the only NSPS not incorporated into the AUC regulations are Subparts Cb, Cc, Cd, Ce, BBBB, DDDD, and HHHH. None of which are applicable to the Facility. 8 US EPA Region 8 Delegation Summary of 40 CFR Part 61 published April 18, 2016. Also, US EPA Region 8 Delegation Summary of 40 CFR Part 63 published September 28, 2020. BMCA Cedar City LLC Approval Order Application 10 Visibility (UAC R307-406) The provisions of this Rule describe visibility impact analyses and apply to any new major source or major modification proposed in either an attainment area or area of nonattainment area. The Facility is not a major source and therefore this Rule does not apply. Permits: Emissions Impact Analysis (UAC R307-410) This rule establishes the procedures and requirements for evaluating the emissions impact of new or modified sources that require an approval order under UAC R307-401. The purpose of this Rule is to ensure that the source will not interfere with the attainment or maintenance of any NAAQS. The rule also establishes the procedures and requirements for evaluating the impact of HAP emissions. Project emissions of criteria pollutants were compared to the relevant air dispersion modeling thresholds specified in UAC R307-410-4. The results, summarized in Table 5-1, demonstrate that the increase in criteria pollutant emissions will not exceed their respective air dispersion modeling thresholds. Table 5-1 | NAAQS Impacts Analysis Pollutant Project Emissions Increase Modeling Threshold Modeling Required? tons/year tons/year PM10 - Fugitives 0.22 5 No PM10 - Non-Fugitives 0.07 15 No PM2.5 - Combined (fugitives + non-fugitives) 0.44 10 No NOx -- 40 No SO2 -- 40 No CO -- 100 No Lead -- 0.6 No The Project will result in minor increases of various HAPs. As a result, HAP emissions increases associated with the Project were used to conduct the HAP Impact Analysis described in UAC R307-410-5. The results of the analysis, summarized in Table 5-2, demonstrate that emission increases of HAPs will not exceed the corresponding emission threshold value calculated in accordance with the methodology specified at UAC R307-410-5(1)(c)(i)(C). Therefore, air dispersion modeling is not required for HAP emissions. BMCA Cedar City LLC Approval Order Application 11 Table 5-2 | Summary of HAP Impact Analysis Pollutant Category Type of Release Project Emissions Increase (lb/hr) Emission Threshold Value (lb/hr) Hexane Chronic Stack 2.83E-02 34.89 Fugitive 9.44E-03 8.99 1,4-Dioxane Chronic Stack 9.74E-05 14.27 Fugitive 3.25E-05 3.68 Ethylene Glycol Acute Stack 9.74E-04 9.77 Fugitive 3.25E-04 2.41 Methylene Diphenyl Diisocyanate Chronic Stack 5.59E-04 0.01 Fugitive 1.86E-04 0.003 Formaldehyde Acute Fugitive 5.75E-08 0.014 Acrolein Acute Fugitive 2.08E-09 0.009 Acetaldehyde Acute Fugitive 2.25E-08 1.71 Propionaldehyde Chronic Fugitive 2.92E-09 2.42 Acrylic Acid Chronic Fugitive 1.00E-08 0.30 Detailed calculations prepared for completing the HAP Impact Analysis are provided in Appendix B-6. Permits: Ozone Offset Requirements in Davis and Salt Lake Counties (UAC R 307- 420) The purpose of this Rule is to maintain the offset provisions of the nonattainment area new source review permitting program in Salt Lake and Davis Counties. As discussed in Section 5.1.3, the Facility is located in Iron County. Therefore, this Rule does not apply. Permits: Ozone Offset Requirements in Davis and Salt Lake Counties (UAC R307-421) The purpose of UAC R307-421 is to require emission reductions from existing sources to offset emission increases from new or modified sources of PM10 precursors in Salt Lake and Utah Counties. As discussed in Section 5.1.3, the Facility is located in Iron County. Therefore, this Rule does not apply. BMCA Cedar City LLC Approval Order Application 12 6 BACT ANALYSIS Pursuant to UAC R307-401-5(2)(d), a BACT analysis is required for all proposed sources or modifications to existing sources. BACT is defined at UAC R307-401-2 as: "Best available control technology" means an emissions limitation (including a visible emissions standard) based on the maximum degree of reduction for each air pollutant which would be emitted from any proposed stationary source or modification which the director, on a case-by- case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutant. In no event shall application of best available control technology result in emissions of any pollutant which would exceed the emissions allowed by any applicable standard under 40 CFR parts 60 and 61. If the director determines that technological or economic limitations on the application of measurement methodology to a particular emissions unit would make the imposition of an emissions standard infeasible, a design, equipment, work practice, operational standard or combination thereof, may be prescribed instead to satisfy the requirement for the application of best available control technology. Such standard shall, to the degree possible, set forth the emissions reduction achievable by implementation of such design, equipment, work practice or operation, and shall provide for compliance by means which achieve equivalent results. A BACT analysis was conducted for the new fluidized sand bath and off-line CNC saw in accordance with the methodology described in Section 6.1. 6.1 BACT ANALYSIS METHODOLOGY BACT is evaluated using a “top-down” approach that involves the following five steps.9 Step 1 – Identify Available Control Options The first step in BACT review is to identify all available control options for the emission unit and pollutant under evaluation. As this Project only involves the installation of minor emissions emitting equipment, available control options were identified through a limited review of the United States Environmental Protection Agency’s (USEPA) RACT/BACT/LAER Clearinghouse database.10 Control options may include back-end control devices, work practices, routine maintenance activities, etc. The USEPA defines “available control options” as air pollution control technologies or techniques with a practical potential for application to the emissions unit and the regulated pollutant under evaluation.11 A control option that has never been used in practice for the emission unit (or similar emission unit) and pollutant under evaluation is not considered an available control option. Also, a control option that is 9 New Source Review Workshop Manual: Prevention of Significant Deterioration and Nonattainment Area Permitting. USEPA. October 1990 (Draft). 10 The database review was limited to entries over the past 10 years. 11 Top-Down Best Available Control Technology Guidance Document, USEPA OAQPS, 15 March 1990 (Draft). BMCA Cedar City LLC Approval Order Application 13 theoretical, in research and development, only deployed at pilot or test scale, or otherwise not commercially available is not considered an available control option. This step in the process may identify a broad array of control options that have been applied to similar emission sources but may not be applicable to this Project. Per EPA guidance, While Step 1 is intended to capture a broad array of potential options for pollution control, this step of the process is not without limits. EPA has recognized that a Step 1 list of options need not necessarily include inherently lower polluting processes that would fundamentally redefine the nature of the source proposed by the permit applicant. BACT should generally not be applied to regulate the applicant’s purpose or objective for the proposed facility. In assessing whether an option would fundamentally redefine a proposed source, EPA recommends that permitting authorities apply the analytical framework recently articulated by the Environmental Appeals Board. Under this framework, a permitting authority should look first at the administrative record to see how the applicant defined its goal, objectives, purpose, or basic design for the proposed facility in its application. The underlying record will be an essential component of a supportable BACT determination that a proposed control technology redefines the source. Accordingly, control options that would prevent the Project from fulfilling its intended purpose or fundamentally redefine the nature of the Project need not be considered in Step 1. Step 2 – Eliminate Technically Infeasible Options The second step in the BACT analysis is to evaluate the technical feasibility of control technologies identified in Step 1. EPA states the following with regard to technical feasibility: A demonstration of technical infeasibility should be clearly documented and should show, based on physical, chemical, and engineering principles, that technical difficulties would preclude the successful use of the control option on the emissions unit under review.11 Identified control options that are demonstrated to be technically infeasible may be eliminated from further consideration. Step 3 – Rank Control Options Identified control technologies deemed technically feasible under Step 2 are ranked in order of overall control effectiveness for the air pollutant under review. If the most effective control technology identified in Step 3 is selected as BACT, the analysis is complete. Otherwise, the process proceeds to Step 4. Step 4 – Evaluate Impacts of Control Options Under Step 4, remaining control options are evaluated on the basis of energy, environmental, and/or economic impacts. The energy impact analysis is based on the amount of energy that would be consumed (e.g., BTU, kWh) to implement the control option. The environmental impact analysis considers emissions BMCA Cedar City LLC Approval Order Application 14 of air pollutants as well as non-air environmental impacts (water, waste, etc.) associated with the use of the control option. The economic impact analysis assesses the cost effectiveness of the control option. Control options with excessive energy, environmental, and/or economic impacts may be eliminated. Step 5 – Select BACT The most effective control option remaining following Step 4 is considered BACT for the air pollutant and emission unit under review. 6.2 BACT ANALYSIS FOR FLUIDIZED SAND BATH (PM/PM10/PM2.5 & VOCS) The fluidized sand bath will be used on a limited basis solely for cleaning and maintenance purposes and will generate trivial quantities of regulated air pollutants. Specifically, particulate and VOC emissions are estimated at approximately 1.2E-05 tons/year and 3.2E-05 tons/year, respectively. Since emissions will be insignificant, no collection system or back-end control device is necessary as the cost to install an exhaust collection and control system would far outweigh any benefit realized from controlling such a minor quantity of emissions. As such, the Facility will utilize good design and operating practices as the BACT. Specifically, the Facility will operate the fluidized sand bath in accordance with the manufacturer’s specifications and conduct routine maintenance on the equipment to ensure the optimal performance of the fluidized sand bath. For completeness, a review of the RBLC was conducted for the polymer and resin production industry and no results identified a fluidized sand bath or similar piece of equipment. As a result, the description provided above serves as sufficient justification for completing the BACT analysis for the fluidized sand bath.12 6.3 BACT ANALYSIS FOR OFF-LINE CNC SAW (PM/PM10/PM2.5) Emissions from the off-line CNC saw will comprise minor emissions of particulates and VOCs, including trivial quantities of HAPs. Particulates are captured in the same exhaust system as VOC emissions. Particulate emissions will be controlled by a new baghouse. No controls will be implemented for VOCs. A review of the RBLC was conducted for CNC saws and similar sources in the polymer and resin production industry. However, the search did not produce any results for a process representative of sawing operations. As a result, a search was conducted for the board product finishing industry as the description for this category included sanders, saws, and trimmers. Step 1 – Identify Available Control Options The database review identified the following technologies for particulate control: 1. Wet Scrubber: A wet scrubber typically removes particulates from a gas stream by spraying it with a scrubbing liquid or by forcing it through a pool of liquid to remove particulates and other pollutants. Based on literature research, wet scrubbers generally provide a control efficiency around 80%. 12 A condensed BACT analysis for equipment with very low emissions was communicated as acceptable on a phone call with Christine Bodell of the Utah DEQ on 06 August 2024. BMCA Cedar City LLC Approval Order Application 15 2. Baghouse/Fabric Filter: Particulates are removed from a gas stream by forcing the exhaust through a series of bags that are typically made of woven or felted fabric. Most baghouses can easily achieve a particulate control efficiency greater than 95%. The results of the RBLC database search are provided in Appendix D. Step 2 – Eliminate Technically Infeasible Options Both control technologies identified in Step 1 are considered technically feasible. Step 3 – Rank Control Options Baghouses are more effective at capturing fine particulates than wet scrubbers. In addition, wet scrubbers produce a wet sludge requiring disposal and have higher operating costs and lower removal efficiencies compared to baghouses/fabric filters. Based on the control effectiveness, baghouses rank at the top, followed by wet scrubbers. The Facility will install a new baghouse to control particulates from the off-line CNC saw. As such, the Facility has chosen the most effective control option. Step 4 – Evaluate Impact of Control Options The most effective control options were selected in Step 3. Therefore, further evaluation is unnecessary. Step 5 – Select BACT The BACT selected for this project is a baghouse/fabric filter capable of achieving a particulate control efficiency of at least 95%. 6.4 BACT ANALYSIS FOR OFF-LINE CNC SAW (VOCS) Minor emissions of VOCs are generated from the off-line CNC saw when cutting the pentane foam bubbles contained within the ISO board. As shown in Appendix B-4, VOC emissions from the off-line CNC saw are estimated at less than 1 ton/year. No back-end controls are planned for VOC emissions from the off- line CNC saw as it would not be economically feasible to implement controls for such low quantities of VOCs. The same search described in Section 6.3 was used to identify potential BACT for VOCs from process saws. Step 1 – Identify Available Control Options The search identified good design and operation practices as the only control options for VOC emissions from sanding and sawing operations. The results of the RBLC database search are provided in Appendix D. Step 2 – Eliminate Technically Infeasible Options The use of good design and operation practices is considered technically feasible for the off-line CNC saw. Step 3 – Rank Control Options BMCA Cedar City LLC Approval Order Application 16 As only one control option was identified, ranking is unnecessary. The Facility will apply good design and operation practices when operating the off-line CNC saw. Step 4 – Evaluate Impact of Control Options The most effective control options were selected in Step 3. Therefore, further evaluation is unnecessary. Step 5 – Select BACT Good design and operation practices is selected as BACT. The Facility will operate the saw in accordance with the manufacturer’s specifications and will conduct routine maintenance activities to ensure optimal performance of the CNC saw. Appendix A Utah DEQ Approval Order Application Forms Form 1 Date __________________ Notice of Intent (NOI) Application Checklist Company __________________ Utah Division of Air Quality New Source Review Section Source Identification Information [R307-401-5] 1. Company name, mailing address, physical address and telephone number 2. Company contact (Name, mailing address, and telephone number) 3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates 5. Source Standard Industrial Classification (SIC) code 6.Area designation (attainment, maintenance, or nonattainment) 7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.) 8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers NOI Application Information: [R307-401] N/A N/A A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 1.Detailed description of the project and source process 2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule 4.Description of changes to the process, production rates, etc. 5.Site plan of source with building dimensions, stack parameters, etc. 6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment 7.Emissions Related Information: [R307-401-2(b)] A.Emission calculations for each new/modified unit and site-wide (Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant C.All speciated HAP emissions (list in lbs/hr) 8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410] A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations) 9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403] A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements B.Alternative site analysis, Major source ownership compliance certification 10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] B.Visibility impact analysis, Class I area impact 11.Signature on Application N/A Note: The Division of Air Quality will not accept documents containing confidential information or data. Documents containing confidential information will be returned to the Source submitting the application. 1 of 1 Form 2 Date ____________ Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: □ Initial Approval Order □Approval Order Modification General Owner and Source Information 1.Company name and mailing address: ____________________________ ____________________________ ____________________________ Phone No.: ( ) Fax No.: ( ) 2.Company** contact for environmental matters: ____________________________ Phone no.: ( ) Email: _______________________ ** Company contact only; consultant or independent contractor contact information can be provided in a cover letter 3.Source name and physical address (if different from above):____________________________ ____________________________ ____________________________ Phone no.: ( ) Fax no.: ( ) 4.Source Property Universal Transverse Mercator coordinates (UTM), including System and Datum: UTM:_________________________ X:____________________________ Y:____________________________ 5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC) __ __ __ __ 7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____ 8.Brief (50 words or less) description of process. Electronic NOI 9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal X Electronic Copy Submittal □ Both Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Title: _______________________________________ Name (Type or print) Telephone Number: ( ) Email: Date: Page 1 of 1 Form 4 Company____________________________ Project Information Site ______________________________ Utah Division of Air Quality New Source Review Section Process Data - For Modification/Amendment ONLY 1. Permit Number_______________________________ If submitting a new permit, then use Form 3 Requested Changes 2. Name of process to be modified/added: _______________________________ End product of this process: _______________________________ 3. Permit Change Type: New Increase* Equipment Process Condition Change ____________________ Other ______________________________ Other ______________________________ Other ______________________________ 4. Does new emission unit affect existing permitted process limits? Yes No 5. Condition(s) Changing: 6. Description of Permit/Process Change** 7. New or modified materials and quantities used in process. ** Material Quantity Annually 8. New or modified process emitting units ** Emitting Unit(s) Capacity(s) Manufacture Date(s) *If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an emissions increase and a public comment period. **If additional space is required, please generate a document to accommodate and attach to form. Page 1 of 1 Company___________________________ Site _____________________________ Form 5 Emissions Information Criteria/GHGs/ HAP’s Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Appendix B Emission Calculations Pre-Project Emissions Project Only Emissions Post-Project Emissions PM 12.40 2.22E-01 12.62 PM10 12.40 2.22E-01 12.62 PM2.5 4.59 3.70E-01 4.96 NOx 6.44 --6.44 SO2 0.04 --0.04 CO 5.41 --5.41 VOCs 29.76 1.02E+00 30.78 Total HAPs 6.66 3.11E-02 6.69 CO2e 7,725.00 --7725.00 End of Table Appendix B-1 Facility-Wide Emissions Summary BMCA Cedar City LLC | Cedar City, Utah September 2024 Pollutant Potential Emissions (tons/year) A. Facility-Wide Emissions Summary 780 hrs/yr 90% 3,000 scfm 95% 95% 85% 0.21 ft3 1.98 lb/ft3 0.42 lb/cycle 10.00 min/cycle 3.00 cycles/hr 30.00 hrs/week 90.00 cycles/week 4,680 cycles/year 1.27 lb/hr 1,973.74 lb/year 0.99 tons/year 1.5 1.9 lb/hr 1.5 tons/year (lb/hr)[2](tpy)[3](lb/hr)[4](tpy)[5](lb/hr)[6](tpy)[7] PM 1.90 1.48 0.09 0.07 0.19 0.15 PM10 1.90 1.48 0.09 0.07 0.19 0.15 PM2.5 1.90 1.48 0.26 0.22 0.19 0.15 End of Calculation (0.42 lb/cycle × 3 cycles/hr) (0.42 lb/cycle × 4680 cycles/year) Expected No. of Cycles per Hour = Convert lbs to tons Maximum Weight Removed per Hour = Maximum Weight Removed per Year = (1.27 lb/hr × 1.5 ) (0.99 tons/year × 1.5 ) Expected No. of Cycles per Year = Appendix B-2 Off-Line Saw: Particulate Emission Calculations BMCA Cedar City LLC | Cedar City, Utah September 2024 Provided by facility. Provided by facility. (3 cycles/hr × 30 hrs/week) Provided by facility. Dust Collector PM10 Control Efficiency = Dust Collector PM2.5 Control Efficiency = Volume Removed per Cycle = A. Off-Line Saw Process Information C. Notes [2] Uncontrolled Emissions (lb/hr) = Maximum Weight Removed per Hour (lb/hr). See calculations in Table A for details. [3] Uncontrolled Emissions (tons/year) = Maximum Weight Removed per Year (tons/year). See calculations in Table A for details. [4] Controlled Emission (lb/hr) = Uncontrolled Emissions (lb/hr) × Capture Efficiency (%) × {1 - Dust Collector Control Efficiency (%)}. Control efficiency varies for PM vs PM10 vs. PM2.5. [5] Controlled Emission (tons/year) = Uncontrolled Emissions (tons/year) × Capture Efficiency (%) × {1 - Dust Collector Control Efficiency (%)}. Control efficiency varies for PM vs PM10 vs. PM2.5. [1] Provided by the facility. The volume of cut is based on the following: Cutting blade kerf = 0.125 in. ; total cut path comprised of half cuts and angled cuts = 1469.95in. ; Average cut thickness = 2 in. Dust Collector (DC) Air Flow = Dust Collector PM Control Efficiency =(MERV 15 Ultra Web Filter) [6] Fugitive Emissions (lb/hr) = Uncontrolled Emissions (lb/hr) × {1 - Capture Efficiency (%)} Pollutant Uncontrolled Emissions Controlled Emissions (MERV 15 Ultra Web Filter) (MERV 15 Ultra Web Filter) [1] Expected No. of Hrs per Week = Expected No. of Cycles per Week = Expected Weight Removed per Hour = Expected Weight Removed per Year = Typical Density = Weight Removed per Cycle = [7] Fugitive Emissions (tons/year) = Uncontrolled Emissions (tons/year) × {1 - Capture Efficiency (%)} (15 hrs/wk × 52 wks/yr) (Design airflow rate) Estimated Capture Efficiency = Conservative estimate For uncontrolled emissions, PM is assumed equal to PM 10 and PM2.5 . ReferenceFugitive Emissions (90 cycles/week × 52 weeks/year) Safety Factor B. Total Particulate Emissions Provided by facility. (0.21 ft3 ×1.98 lb/ft3) Cycle Time = Maximum Operating Schedule = 8,760 hrs/yr 75% 25,000 lbs/hr 5.70% 5% 29.39% 0.1% 2.94% 0.025% 59.07% 1.77% 0.03% 0.12% 0.1% 1.25 30 hrs/week 1560 hrs/year 98.6% Reference (lb/hr)[2](tpy)[3](lb/hr)[4](tpy)[5] Pentane 100%0.94 0.74 0.31 0.25 Hexane 3%0.03 0.02 0.009 0.007 VOC -0.97 0.76 0.32 0.25 Based on 100% VOC Content. 1,4-Dioxane 0.1%0.0001 0.0001 0.00003 0.00003 Ethylene Glycol 1%0.001 0.001 0.00032 0.00025 Diethylene Glycol 5%0.005 0.004 0.00162 0.00127 Triethylene Glycol 2%0.002 0.002 0.00065 0.00051 Tetraethylene Glycol 1%0.001 0.001 0.00032 0.00025 VOC -0.01 0.01 0.003 0.002 See Note 6 tris(2-chloro-1-methylethyl) phosphate (TCPP)99.5%0.002 0.002 0.0008 0.0006 See Note 10 VOC --0.002 0.002 0.0008 0.0006 Assume same as TCPP MDI 100%5.59E-04 4.36E-04 1.86E-04 1.45E-04 See Note 7 VOC --5.59E-04 4.36E-04 1.86E-04 1.45E-04 Assume same as MDI VOC 15%8.79E-04 6.86E-04 2.93E-04 2.29E-04 See Note 8 VOC 100%9.61E-05 7.49E-05 3.20E-05 2.50E-05 See Note 8 VOC 8%3.13E-05 2.44E-05 1.04E-05 8.13E-06 See Note 8 Total VOC --0.99 0.77 0.33 0.26 See Note 8 Highest HAP --0.03 0.02 0.009 0.007 (Hexane is the highest HAP) Total HAP --0.03 0.02 0.010 0.008 See Note 9 Continued on Next Page Flame Retardant Content (%) =(Based on product composition data) Flame Retardant Release Rate (%) =(Based on EU Risk Assessment, See Note 8) Maximum Foam Production =(Based on process design) Appendix B-3 Off-Line Saw: VOC Emission Calculations BMCA Cedar City LLC | Cedar City, Utah September 2024 Polyol Release Rate (%) =(Release rate used at GAF Gainesville, TX and Statesboro, GA plants) A. Foam Board Manufacturing Process Information Maximum Operating Schedule =(24 hrs/day × 365 days/yr) Catalyst 1 Content (%) =(Based on product composition data) Catalyst 2 Content (%) =(Based on product composition data) (Based on product composition data) Catalyst 2 Catalyst 3 Catalyst 3 Content (%) =(Based on product composition data) Flame Retardant MDI VOC/HAP Uncontrolled Stack Emissions Fugitive Emissions Percent Released from Production Line Sources (%)(Remainder of VOC is released from off-line saws, per GAF Statesboro, GA engineering test data. Polyol (Assumed same as Polyol Release Rate, See Note 11) Safety Factor = Catalyst 1 C. Off-Line Saw VOC Emissions Pollutant Composition in Raw Material (%)[1] Foam MDI Content (%) = Estimated Capture Efficiency =Conservative estimate Blowing Agent Blowing Agent Content (%) =(Based on product composition data) Blowing Agent Release Rate (%) =(Release rate used at GAF Gainesville, TX and Statesboro, GA plants) Polyol Content (%) =(Based on product composition data) B. Off-Line Saw Process Information Expected operating time of 30 hrs/week provided by facility (conservative estimate).Expected Operating Schedule = Catalyst Combined Release Rate (%) = W = Where, W =the evaporation losses from the open process in grams per day u =the airflow speed in m/sec VPMDI =tbe vapor pressure of MDI in atmospheres @ process temperature SA =the exposed surface area in m2 Tproc =the process temperature in K tTF =the tack-free time in seconds MW =the molecular weight of MDI These values summarized below are based on GAF information: Parameter Value Units Value Units Assumptions VPMDI 4.07E-03 mm Hg 5.36E-06 atm 1 atm = 760 mm Hg MW 250.26 lb/lb-mol 250.26 g/g-mol 1 lb/lb-mol = 1 g/g-mol Tproc 180 °F 355.37 K K = ((°F-32)*(5/9)) + 273.15 u 5 m/sec 5 m/sec N/A SA 18,942,737 ft2/yr 4,821.47 m2/day 1 m = 3.28084 ft (Assume 365 days per year) tTF 5 sec 5 sec N/A Evaporation Losses, W =8.11 gram/day (Calculated using Equation above) =1.79E-02 lb/day (1 lb = 453.592 g) =7.45E-04 lb/hr (1 day = 24 hr) End of Calculation [2] Uncontrolled Stack Emissions (lb/hr) = Maximum Foam Production (lb/hr) × Raw Material Content (%) × Raw Material Release Rate (%) × Composition in Raw Material (%) × Safety Factor D. Notes [1] Worst-case composition by weight in raw material. Data from raw material SDS information. [10] The European Union (EU) Risk Assessment Report for TCPP (2008) quantifies the release rate of TCPP to air from rigid foam manufacturing operations, including due to volatilization from the foam while at elevated temperatures (curing), at 0.025%. [11] Based on the comparison of vapor pressures of Catalysts 1, 2, & 3 (10-4 psi to 10-3 psi) and Polyol (10-2 psi) at standard conditions as noted on the SDSs, it seems reasonable to assume that Polyol and the Catalysts have the same release rates. This is a conservative assumption, given that Polyol has higher vapor pressure than the catalysts. [8] Uncontrolled Emissions = Maximum Foam Production (lb/hr) × Raw Material Content (%) × Composition in Raw Material (%) × Safety Factor [9] Uncontrolled Total HAP Emissions (lb/hr) = ΣUncontrolled Emissions (Hexane + ƩGlycol Ethers + 1,4-Dioxane + MDI) Controlled Total HAP Emissions (lb/hr) = ΣControlled Emissions (Hexane + ƩGlycol Ethers + 1,4-Dioxane + HCl + MDI) [3] Uncontrolled Stack Emissions (tpy) = Uncontrolled Emissions (lb/hr) × Maximum Operating Schedule ÷ 2,000 (lb/ton) [6] Uncontrolled VOC Emissions (lb/hr and tpy) = ΣUncontrolled Emissions (1,4-Dioxane + Ethylene Glycol + Diethylene Glycol + Triethylene Glycol + Tetraethylene Glycol) [7] Uncontrolled MDI emissions are calculated based on the following evaporation equation listed on Page 5-2 of "MDI Emissions Reporting Guidelines for the Polyurethane Industry," dated May 2012: 25.4 × VP MDI × (MW / T proc ) × (u)0.78 × S A × t TF [4] Fugitive Emissions (lb/hr) = Uncontrolled Emissions (lb/hr) ÷ Capture Efficiency (%) × {1 - Capture Efficiency (%)} [5] Fugitive Emissions (tpy) = Uncontrolled Emissions (tpy) ÷ Capture Efficiency (%) × {1 - Capture Efficiency (%)} (lb/hr)(tpy)(lb/hr)(tpy) PM 0.09 0.07 0.19 0.15 PM10 0.09 0.07 0.19 0.15 PM2.5 0.26 0.22 0.19 0.15 VOCs 0.99 0.77 0.33 0.26 Hexane 2.83E-02 2.21E-02 9.44E-03 7.36E-03 1,4-Dioxane 9.74E-05 7.59E-05 3.25E-05 2.53E-05 Ethylene Glycol 9.74E-04 7.59E-04 3.25E-04 2.53E-04 Diethylene Glycol 4.87E-03 3.80E-03 1.62E-03 1.27E-03 Triethylene Glycol 1.95E-03 1.52E-03 6.49E-04 5.06E-04 Tetraethylene Glycol 9.74E-04 7.59E-04 3.25E-04 2.53E-04 tris(2-chloro-1-methylethyl) phosphate (TCPP)2.42E-03 1.89E-03 8.07E-04 6.30E-04 MDI 5.59E-04 4.36E-04 1.86E-04 1.45E-04 Total HAP 3.00E-02 2.34E-02 9.98E-03 7.79E-03 End of Table ReferencePollutant [1] Emissions from off-line saw are captured and routed to a baghouse prior to discharging to the atmosphere. Therefore, particulate emissions are the only pollutant that is controlled. B. Notes Appendix B-4 Off-Line Saw: Total Emissions BMCA Cedar City LLC | Cedar City, Utah September 2024 Values taken from Table 3. VOC controls are not used for the off-line saw. A. Off Line Saw: Total Emissions[1] Stack Emissions Values taken from Table 2. Fugitive Emissions Potential Emissions Maximum No. of Parts Cleaned per Day = 1 Estimated Resin Removed per Part = 0.5 Safety Factor = 100% Maximum Resin Removed per Part = 1.00 Maximum Resin Removed per Day = 1.00 Maximum Resin Removed per Year = 365.0 Continued on Next Page lb/year Calculations part/day lb/part lb/part lb/day Appendix B-5 Fluidized Sand Bath Emission Calculations BMCA Cedar City LLC | Cedar City, Utah September 2024 A.Fluidized Sand Bath General Information[1] Polymers to be Removed in Sand Bath = Polyisocyanurate Thermoplastic Polyolefin Polyvinyl Chloride Continued on Next Page 1.77E-04 Acrylonitrile -- Ethylbenzene -- Styrene -- B.Emission Factors Polypropylene[2] Pollutant lb/lb resin PM 6.84E-05 VOCs Acrolein 5.00E-08 Acetaldehyde 5.40E-07 Propionaldehyde 7.00E-08 Cumene -- Acetophenone -- Formaldehyde 1.38E-06 PM 3.09E-05 VOCs 3.53E-05 Acrylonitrile -- Methyl Ethyl Ketone 2.40E-07 Acrylic Acid 8.00E-08 Polyethylene[3] Pollutant lb/lb resin Acetophenone -- Formaldehyde 1.00E-07 Acrolein 1.00E-08 Ethylbenzene -- Styrene -- Cumene -- Acrylic Acid 2.00E-08 Maximum Emission Factors[4] PM VOCs Acetaldehyde 1.20E-07 Propionaldehyde 7.00E-08 Methyl Ethyl Ketone 1.00E-07 6.84E-05 1.77E-04 Methyl Ethyl Ketone Acrylic Acid Formaldehyde Acrolein Acetaldehyde Propionaldehyde 1.38E-06 5.00E-08 5.40E-07 7.00E-08 2.40E-07 8.00E-08 PM VOCs Formaldehyde Acrolein Acetaldehyde Propionaldehyde Methyl Ethyl Ketone[7] Acrylic Acid Total HAP End of Calculation D.Notes [1] The fluidized sand bath is electrically heated. The bath consists of small, loosely packed, solid aluminum oxide particles through which an upward flow of air is passed. In the fluidized state, the aluminum oxide particles become mobile, and the bath displays many of the properties of a liquid. However, since the bath is composed of tiny, inert aluminum oxide particles, evaporation/volatilization does not occur. Therefore, the only air emissions produced would be from melting the resin. Pollutant [2] Emission factors for polypropylene based on Controlled Rheology Homopolymer at 510 °F published in Table 5 of the attached paper from the Journal of the Air & Waste Management Associate (Development of Emission Factors for Polypropylene Processing-1999). [3] Emission factors for polyethylene based on LDPE Extrusion Coating at 500 °F published in Table 7 of the attached paper from the Journal of the Air & Waste Management Associate (Development of Emission Factors for Polyethylene Processing-1996). [4] Emission factors for PVC extrusion were not available. As a result, two sets of representative emission factors for polypropylene and polyethylene were reviewed. For conservatism, the final emission factors used in the emission calculations are based on the maximum emission factor between polypropylene and polyethylene. C.Speciated Emission Rates [7] Methyl ethyl ketone is not a federally listed HAP. However, it is included for completeness. Estimated Emissions lb/hr[5] 2.85E-06 7.38E-06 5.75E-08 2.08E-09 2.25E-08 2.92E-09 1.00E-08 3.33E-09 8.83E-08 [6] Hourly Emissions (lb/hr) = Annual Emissions (tons/year) × (2,000 lb / 1 ton) × (1 year / 8,760 hrs) [6] Annual Emissions (tons/year) = Emission Factor (lb/lb resin) × Maximum Resin Removed per Day (lb/year) × 1 ton / 2,000 lb 3.87E-07 tons/year[6] 1.25E-05 3.23E-05 2.52E-07 9.13E-09 9.86E-08 1.28E-08 4.38E-08 1.46E-08 Molecular Weight ACGIH Threshold Limit Value[1] ACGIH Threshold Limit Value[2] Total Emissions[4] Maximum Release Duration g/mol ppm mg/m3 Type of Release lb/hr Type of Release lb/hr lb/hr min/hr Stack 0.194 Stack 2.83E-02 2.22E-01 60 ----Fugitive 9.44E-03 9.44E-03 60 Stack 0.627 Stack 9.74E-05 6.27E-01 60 ----Fugitive 3.25E-05 ---- Stack 0.629 Stack 9.74E-04 6.30E-01 60 ----Fugitive 3.25E-04 ---- Stack 0.00002 Stack 5.59E-04 5.81E-04 60 ----Fugitive 1.86E-04 ---- Formaldehyde 30.03 0.3 0.37 ----Fugitive 5.75E-08 5.75E-08 60 Acrolein 56.06 0.1 0.23 ----Fugitive 2.08E-09 2.08E-09 60 Acetaldehyde 44.05 25.0 45.04 ----Fugitive 2.25E-08 2.25E-08 60 Propionaldehyde 58.1 20.0 47.53 ----Fugitive 2.92E-09 2.92E-09 60 Acrylic Acid 72.06 2.0 5.89 ----Fugitive 1.00E-08 1.00E-08 60 Emission Threshold Factor[6] Release Height from Ground[8] Building Height Approximate Distance to Property Line m3 lb/mg-hr ft ft ft Stack 0.198 No 12 20 Fugitive 0.051 No 10 20 Stack 0.198 No 12 20 Fugitive 0.051 No 10 20 Stack 0.154 No 12 20 Fugitive 0.038 No 10 20 Stack 0.198 No 12 20 Fugitive 0.051 No 10 20 Formaldehyde Acute Fugitive 0.038 No 10 20 Acrolein Acute Fugitive 0.038 No 10 20 250 Acetaldehyde Acute Fugitive 0.038 No 10 20 250 Propionaldehyde Chronic Fugitive 0.051 No 10 20 250 Acrylic Acid Chronic Fugitive 0.051 No 10 20 250 End of Calculation [4] For existing facilities currently operating under an Approval Order, the emissions increases associated with the project are compared to the modeling thresholds. Total Facility-wide HAP emissions are presented for informational purposes only. 0.050.005250.26 [8] All fugitive sources are assumed to release at half the building height. [5] Category taken from the health classification column in the ACGIH tables provided by Jason Krebs of the Utah DEQ on 08/07/2024. [6] All stack releases are vertically unrestricted. Therefore, for stack releases, all emission threshold factors conservatively correspond to the 50 meters or less category in Table 2 of UAC R307-410-5. For all fugitive releases, the emission threshold factors conservatively correspond to the 20 meters or less category in Table 2 of UAC R307-410-5. In reality, releases may be further away from the property line. Acute Chronic [7] Emission Threshold Value (lb/hr) = Emission Threshold Factor (m 3-lb/mg-hr) × ACGIH Threshold Limit Value (mg/m3) [2] Time Weighted Average (mg/m 3) = {Time Weighted Average (ppm) × Molecular Weight (g/mol)} ÷ 24.45 L. 24.45 L is the molar volume of air at 25 C and 760 Torr. Equation provided on page 29 of the 2023 Threshold Limit Values and Biological Exposure Indices document. 1.712 2.424 0.301 0.01 0.014 25.062.07 72.0720.088.1 A. Criteria Pollutant Impacts Analysis No Modeling Required?Pollutant No No No No No No 40 Project Emissions Increase tons/year 0.15 0.07 [3] Existing emission rates taken from the 2015 application. All HAP emissions from existing sources are assumed to be from vertically unrestricted point sources. Project Emissions Increase[4] Modeling Required? Methylene Diphenyl Diisocyanate Ethylene Glycol 1,4-Dioxane Existing Facility-Wide Emissions[3] C. HAP Impacts Analysis Part 2 Category[5] Chronic D. Notes [1] Values taken from the 2023 Threshold Limit Values and Biological Exposure Indices document published by the American Conference of Governmental Industrial Hygenists. 0.009 Hexane 176.24 2.41 0.37 Modeling Threshold tons/year 5 15 10 40 100 0.6 -- -- -- Appendix B-6 Air Dispersion Modeling Impact Analyses GAF Materials Corporation | Cedar City, Utah September 2024 Ethylene Glycol 1,4-Dioxane Lead Emission Threshold Value[7] lb/hr 34.89 8.99 14.27 PM10 - Fugitives PM10 - Non-Fugitives PM2.5 - Combined (fugitives + non-fugitives) 3.68 0.003 9.77 NOx SO2 CO -- Hexane Chronic 50.086.18 Pollutant Pollutant Type of Release B. HAP Impacts Analysis Part 1 Methylene Diphenyl Diisocyanate 63.47 Appendix C Safety Data Sheets Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 1. Identification of the substance & the company Product identifier FYROL PCF Chemical name Tris(2-chloro-1-methylethyl) phosphate (TCPP) Synonym(s)2-Propanol, 1-chloro-, phosphate (3:1). Tris(2-chloroisopropyl) phosphate. 2-Propanol, 1-chloro-, 2,2',2''-phosphate. Reaction mass of tris(2-chloropropyl) phosphate and tris(2-chloro-1-methylethyl) phosphate and Phosphoric acid, bis(2-chloro-1-methylethyl) 2-chloropropyl ester and Phosphoric acid, 2-chloro-1-methylethyl bis(2-chloropropyl) ester. Chemical formula C9H18Cl3O4P Chemical family Alkyl phosphate Molecular weight ca.328 Type of product and use Flame retardant Supplier ICL-IP America Inc. 622 Emerson Road - Suite 500 St Louis, Missouri 63141, USA Tel:(314)983-7884 Fax:(314)983-7607 e-mail:msdsinfo@icl-group.com Emergency Telephone Chemtrec: (800) 424-9300 Medical: PROSAR 1-888-875-1685 (24HRS) 2. Hazards identification GHS classification Acute Tox. 4, H302 Harmful if swallowed Signal Word WARNING Hazard statements { Page 1 of 8 } H302 - Harmful if swallowed Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 Precautionary statements P264 - Wash hands thoroughly after handling P270 - Do not eat, drink or smoke when using this product P301 + P312 - IF SWALLOWED: Call a POISON CENTER or doctor/physician if you feel unwell P330 - Rinse mouth P501 - Dispose of contents/container in accordance with national and international regulations NFPA Ratings (Scale 0-4)Health = 1, Fire = 1, Reactivity = 0 HMIS Ratings (Scale 0-4)Health = 1, Fire =1, Reactivity = 0. 3. Composition / information on ingredients Components CAS No.Weight % 2-Propanol, 1-chloro-, 2,2',2''-phosphate 13674-84-5 99.5 4. First-aid measures Eye contact Holding the eyelids apart, flush eyes promptly with copious flowing water for at least 20 minutes. Get medical attention immediately. Skin contact Remove contaminated clothing. Wash skin thoroughly with mild soap and plenty of water for at least 15 minutes. Wash clothing before reuse. Get medical attention if irritation occurs. Inhalation In case of inhalation, remove person to fresh air. Keep him quiet and warm. Apply artificial respiration if necessary and get medical attention immediately. Ingestion If swallowed, wash mouth thoroughly with plenty of water. Get medical attention immediately. ------------------------------------------------------------------------------------- NOTE: Never give an unconscious person anything to drink -------------------------------------------------------------------------------------- Most important symptoms and effects, acute or delayed Harmful if swallowed Notes to the physician { Page 2 of 8 } Treat symptomatically and supportively. Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 5. Fire - fighting measures Suitable extinguishing media Material is not combustible. Use extinguishing media appropriate to surrounding fire conditions. Unusual fire and explosion hazards When heated to decomposition, may release poisonous and corrosive fumes of Carbon Dioxide, Carbon Monoxide, Hydrogen Chloride and Phosphorus Oxides. Fire fighting procedure Fire fighters should wear full protective clothing and self-contained breathing apparatus (SCBA). Contain runoff to prevent entry into water or drainage systems. 6. Accidental release measures Personal precautions Wear appropriate safety clothing and eye/face protection (see Section 8). Methods for cleaning up Soak up with sand or other suitable absorbent and dispose of as solid waste. Collect in suitable and properly labeled containers. Ventilate area and wash spill site after material pickup is complete. Environmental precautions Prevent product from entering drains, ditches and rivers. Avoid access to streams, lakes or ponds. 8. Exposure controls / personal protection Exposure Limits : Components ACGIH-TLV Data Korea OEL OSHA (PEL) Data 2-Propanol, 1-chloro-, 2,2',2''-phosphate 13674-84-5 Not determined Not determined Not determined Ventilation requirements Provide adequate ventilation. Personal protective equipment: 7. Handling and storage Handling Keep containers tightly closed. Avoid bodily contact. { Page 3 of 8 } Storage Store in a dry, cool, well-ventilated area away from incompatible materials (see "materials to avoid"). Maximum recommended storage temperature of 50°C (122°F) Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 - Respiratory protection In case of insufficient ventilation wear suitable respiratory equipment. - Hand protection Rubber gloves - Eye protection Chemical safety goggles - Skin and body protection Use protective clothing impervious to this material. Hygiene measures Do not eat, smoke or drink where material is handled, processed or stored. Wash hands thoroughly after handling and before eating or smoking. Safety shower and eye bath should be provided. 9. Physical and chemical properties Appearance Clear colorless liquid Odor Slightly sweetish. Melting point/range -20°C Boiling point/range 288°C (decomposes) Flash point >245°C (closed cup) Flammable/Explosion limits Not flammable/Not explosive Vapor pressure 1.4x10(-5)hPa (25°C) Density 1.290 (20°C) Solubility: - Solubility in water 1.08 g/l at 20°C Partition coefficient (n-octanol/water) Log Pow : 2.68 Auto-ignition temperature > 400°C Decomposition temperature 245°C Viscosity 68.5 cP (20°C) Explosive properties There are no chemical groups associated with explosive properties present in the molecule Oxidising properties The structure indicates non oxidizing properties 10. Stability and reactivity Stability Stable under normal conditions Conditions to avoid Heating above decomposition temperature. Materials to avoid Strong oxidizers, strong acids and strong alkalis. It hydrolyzes slowly at normal temperatures in acidic or alkaline aqueous solutions. Hazardous decomposition products { Page 4 of 8 } Carbon dioxide and carbon monoxide. Hydrogen Chloride,. Phosphorus oxides. Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 12. Ecological information Aquatic toxicity : - 96 Hour-LC50, Fish 56.2 mg/L 11. Toxicological information Acute toxicity: - Rat oral LD50 630 - 2000 mg/kg - Rabbit dermal LD50 > 2000 mg/kg - Rat dermal LD50 >2000 mg/kg - Rat inhalation LC50 > 7 mg/l (4-hr) Skin corrosion/irritation Not irritant Serious eye damage/ irritation Not irritant Respiratory or skin sensitisation Not a skin sensitizer Sub-chronic toxicity: - NOEL > 20,000 ppm (13 weeks oral rat) Chronic toxicity No data available Mutagenicity Not mutagenic by the Ames Test. Mutagenic in the mouse lymphoma L5178Y test system. Non genotoxic in an in-vivo micronucleus test in mice Carcinogenicity Not included in NTP 14th Report on Carcinogens Not classified by IARC Not classified as a carcinogen by USA OSHA Reproductive toxicity No significant adverse effects on the reproductive parameters evaluated. Specific Target Organ Toxicity (STOT) - Repeat exposure No effects on specific target organs have been identified. Neurotoxicity { Page 5 of 8 } Not neurotoxic Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 - 48 Hour-EC50, Daphnia magna 131 mg/L - EC50, Freshwater algae 47 mg/l (96 hr) - 72 Hour-EC50, Freshwater algae 82 mg/L Chronic toxicity The No Observed Effect Concentration (NOEC) in Daphnia magna is 32 mg/l. Biodegradation Not readily biodegradable. Inherently biodegradable Bioaccumulative potential The bioaccumulation potential is expected to be low Measured BCF of 0.8- <14 Mobility in soil Based on measured results the adsorption coefficient for TCPP is derived to be 174, indicating a moderate adsorption potential. Note:Does not meet the criteria for PBT or vPvB assessment 13. Disposal considerations Waste disposal Observe all federal, state and local environmental regulations when disposing of this material 14. Transportation information UN No.Not regulated DOT Not regulated IMDG Not regulated ICAO/IATA Not regulated 15. Regulatory information USA Reported in the EPA TSCA Inventory. - SARA 313 This product does not contain a chemical listed at or above de minimis concentrations - California-Prop 65 { Page 6 of 8 } WARNING: This product contains a chemical(s) known to the State of California to cause cancer, or birth defects or other reproductive harm (concentration < 0.1%) Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 Canada Listed in DSL EU Reported in EINECS Australia Listed in AICS China - China inventory Listed in IECSC Japan Listed in ENCS Korea listed in KECI Mexico Listed in the National Inventory of Chemical Substances (INSQ). New Zealand Inventory Listed in NZIoC Philippines Listed in PICCS Taiwan Listed (TCSI) Vietnam Listed Thailand Listed 16. Other information This data sheet contains changes from the previous version in section(s) 1, 2, 3, 9, 11, 12, 15 Health, Safety & Environment Policy We will strive to ensure that our operations and products meet the needs of the present global community without compromising the ability of future generations to meet their needs We accept that the success of our business is dependent on the supply of products and services that will benefit society whilst ensuring human safety and protection of the environment and natural resources Within the framework of our commitment to the Responsible Care program, we will provide a healthy and safe work environment for employees and will responsibly manage our products at all stages of their life cycle in order to protect human health and the environment whilst maintaining high production standards of operation { Page 7 of 8 } TO MEET THIS COMMITMENT WE WILL: Comply with or exceed applicable national and international regulatory requirements and other requirements to which we subscribe Communicate openly and actively encourage dialogue with employees, customers and community concerning our products and operations Implement documented management systems consistent with and for promotion of the Responsible Care ethics Supersedes 10/06/2014 ________________________________________________________________________________________ SAFETY DATA SHEET According to OSHA Hazard Communication Standard 29 CFR 1910.1200 (GHS) According to Canada WHMIS 2015 ________________________________________________________________________________________ Product name FYROL PCF Product id 7002 Revision date 07/08/2017 Revision: 7 Develop and supply products that can be manufactured, transported, used and disposed of safely whilst best meeting the needs of our customers Regularly assess, continually improve and responsibly manage health, safety and environmental risks associated with products and processes throughout their life-cycles Share knowledge and expertise with others and seek to learn from and incorporate improved practices into our own operations Educate and train employees, contractors and customers to improve their HSE performance Communicate up-to-date information to enable our workers, customers and other interested parties to handle our products in a safe and environmentally responsible manner Endeavor to work with customers, suppliers, distributors and contractors to foster the safe use, transport and disposal of our chemicals Support Product Stewardship programs in cooperation with customers, distributors and transporters Although the information and recommendations set forth herein (hereinafter "information") are presented in good faith and believed to be correct as of the date hereof, we make no representations as to the completeness or accuracy thereof. Information is supplied to you upon the condition that the persons receiving the information will make their own determination as to its safety and suitability for their purposes prior to use. In no event will we be responsible for damages of any nature whatsoever resulting from the use of or reliance upon the information. In addition, we shall not be liable for any damage or injury resulting from abnormal use, from any failure to adhere to recommended practices or from any hazards inherent in the nature of the product. NO REPRESENTATIONS OR WARRANTIES, EITHER EXPRESSED OR IMPLIED, OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR OF ANY OTHER NATURE, ARE MADE HEREUNDER WITH RESPECT TO THIS INFORMATION OR THE PRODUCT TO WHICH THE INFORMATION REFERS. Prepared by HERA Division telephone: +/972-8-6297835 telefax: +/972-8-6297832 www.icl-ip.com e-mail:msdsinfo@icl-group.com { Page 8 of 8 } End of safety data sheet ® ™ Trademark of The Dow Chemical Company ("Dow") or an affiliated company of Dow Page 1 of 16 SAFETY DATA SHEET THE DOW CHEMICAL COMPANY Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Print Date: 03/19/2020 THE DOW CHEMICAL COMPANY encourages and expects you to read and understand the entire (M)SDS, as there is important information throughout the document. We expect you to follow the precautions identified in this document unless your use conditions would necessitate other appropriate methods or actions. 1. IDENTIFICATION Product name: PAPI™ 580N Polymeric MDI Recommended use of the chemical and restrictions on use Identified uses: For industrial use. Component(s) for the manufacture of urethane polymers. We recommend that you use this product in a manner consistent with the listed use. If your intended use is not consistent with the stated use, please contact your sales or technical service representative. COMPANY IDENTIFICATION THE DOW CHEMICAL COMPANY 2211 H.H. DOW WAY MIDLAND MI 48674 UNITED STATES Customer Information Number: 800-258-2436 SDSQuestion@dow.com EMERGENCY TELEPHONE NUMBER 24-Hour Emergency Contact: CHEMTREC +1 800-424-9300 Local Emergency Contact: 800-424-9300 2. HAZARDS IDENTIFICATION Hazard classification GHS classification in accordance with 29 CFR 1910.1200 Acute toxicity - Category 4 - Inhalation Skin irritation - Category 2 Eye irritation - Category 2B Respiratory sensitisation - Category 1 Skin sensitisation - Category 1 Specific target organ toxicity - single exposure - Category 3 Specific target organ toxicity - repeated exposure - Category 2 - Inhalation Label elements Hazard pictograms Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 2 of 16 Signal word: DANGER! Hazards Causes skin and eye irritation. May cause an allergic skin reaction. Harmful if inhaled. May cause allergy or asthma symptoms or breathing difficulties if inhaled. May cause respiratory irritation. May cause damage to organs (Respiratory Tract) through prolonged or repeated exposure if inhaled. Precautionary statements Prevention Do not breathe dust/ fume/ gas/ mist/ vapours/ spray. Wash skin thoroughly after handling. Use only outdoors or in a well-ventilated area. Contaminated work clothing must not be allowed out of the workplace. Wear protective gloves. In case of inadequate ventilation wear respiratory protection. Response IF ON SKIN: Wash with plenty of soap and water. IF INHALED: Remove person to fresh air and keep comfortable for breathing. Call a POISON CENTER/ doctor if you feel unwell. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If skin irritation or rash occurs: Get medical advice/ attention. If eye irritation persists: Get medical advice and/or attention. If experiencing respiratory symptoms: Call a POISON CENTER/ doctor. Take off contaminated clothing and wash before reuse. Storage Store in a well-ventilated place. Keep container tightly closed. Store locked up. Disposal Dispose of contents/ container to an approved waste disposal plant. Other hazards No data available 3. COMPOSITION/INFORMATION ON INGREDIENTS This product is a mixture. Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 3 of 16 Component CASRN Concentration Diphenylmethane Diisocyanate, isomers and homologues 9016-87-9 100.0% 4,4'-Methylenediphenyl diisocyanate 101-68-8 > 25.0 - < 35.0 % Note Note: CAS 101-68-8 is an MDI isomer that is part of CAS 9016-87-9. 4. FIRST AID MEASURES Description of first aid measures General advice: First Aid responders should pay attention to self-protection and use the recommended protective clothing (chemical resistant gloves, splash protection). If potential for exposure exists refer to Section 8 for specific personal protective equipment. Inhalation: Move person to fresh air and keep comfortable for breathing. If not breathing, give artificial respiration; if by mouth to mouth use rescuer protection (pocket mask, etc). If breathing is difficult, oxygen should be administered by qualified personnel. Call a physician or transport to a medical facility. Skin contact: Remove material from skin immediately by washing with soap and plenty of water. Remove contaminated clothing and shoes while washing. Seek medical attention if irritation or rash occurs. Wash clothing before reuse. An MDI skin decontamination study demonstrated that cleaning very soon after exposure is important, and that a polyglycol-based skin cleanser or corn oil may be more effective than soap and water. Discard items which cannot be decontaminated, including leather articles such as shoes, belts and watchbands. Suitable emergency safety shower facility should be available in work area. Eye contact: Immediately flush eyes with water; remove contact lenses, if present, after the first 5 minutes, then continue flushing eyes for at least 15 minutes. Obtain medical attention without delay, preferably from an ophthalmologist. Suitable emergency eye wash facility should be immediately available. Ingestion: If swallowed, seek medical attention. Do not induce vomiting unless directed to do so by medical personnel. Most important symptoms and effects, both acute and delayed: Aside from the information found under Description of first aid measures (above) and Indication of immediate medical attention and special treatment needed (below), any additional important symptoms and effects are described in Section 11: Toxicology Information. Indication of any immediate medical attention and special treatment needed Notes to physician: Maintain adequate ventilation and oxygenation of the patient. May cause respiratory sensitization or asthma-like symptoms. Bronchodilators, expectorants and antitussives may be of help. Treat bronchospasm with inhaled beta2 agonist and oral or parenteral corticosteroids. Respiratory symptoms, including pulmonary edema, may be delayed. Persons receiving significant exposure should be observed 24-48 hours for signs of respiratory distress. If you are sensitized to Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 4 of 16 diisocyanates, consult your physician regarding working with other respiratory irritants or sensitizers. Treatment of exposure should be directed at the control of symptoms and the clinical condition of the patient. Excessive exposure may aggravate preexisting asthma and other respiratory disorders (e.g. emphysema, bronchitis, reactive airways dysfunction syndrome). 5. FIREFIGHTING MEASURES Extinguishing media Suitable extinguishing media: Water fog or fine spray.. Dry chemical fire extinguishers.. Carbon dioxide fire extinguishers.. Foam.. Alcohol resistant foams (ATC type) are preferred. General purpose synthetic foams (including AFFF) or protein foams may function, but will be less effective.. Unsuitable extinguishing media: Do not use direct water stream.. May spread fire.. Special hazards arising from the substance or mixture Hazardous combustion products: During a fire, smoke may contain the original material in addition to combustion products of varying composition which may be toxic and/or irritating.. Combustion products may include and are not limited to:. Nitrogen oxides.. Isocyanates.. Hydrogen cyanide.. Carbon monoxide.. Carbon dioxide.. Unusual Fire and Explosion Hazards: Product reacts with water. Reaction may produce heat and/or gases.. This reaction may be violent.. Container may rupture from gas generation in a fire situation.. Violent steam generation or eruption may occur upon application of direct water stream to hot liquids.. Dense smoke is produced when product burns.. Advice for firefighters Fire Fighting Procedures: Keep people away. Isolate fire and deny unnecessary entry.. Stay upwind. Keep out of low areas where gases (fumes) can accumulate.. Water is not recommended, but may be applied in large quantities as a fine spray when other extinguishing agents are not available.. Do not use direct water stream. May spread fire.. Fight fire from protected location or safe distance. Consider the use of unmanned hose holders or monitor nozzles.. Immediately withdraw all personnel from the area in case of rising sound from venting safety device or discoloration of the container.. Move container from fire area if this is possible without hazard.. Use water spray to cool fire-exposed containers and fire-affected zone until fire is out.. Contain fire water run-off if possible. Fire water run-off, if not contained, may cause environmental damage.. Review the "Accidental Release Measures" and the "Ecological Information" sections of this (M)SDS.. Special protective equipment for firefighters: Wear positive-pressure self-contained breathing apparatus (SCBA) and protective fire fighting clothing (includes fire fighting helmet, coat, trousers, boots, and gloves).. Avoid contact with this material during fire fighting operations. If contact is likely, change to full chemical resistant fire fighting clothing with self- contained breathing apparatus. If this is not available, wear full chemical resistant clothing with self-contained breathing apparatus and fight fire from a remote location.. For protective equipment in post-fire or non-fire clean-up situations, see Section 8 of the safety data sheet.. Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 5 of 16 6. ACCIDENTAL RELEASE MEASURES Personal precautions, protective equipment and emergency procedures: Isolate area. Keep unnecessary and unprotected personnel from entering the area. Refer to section 7, Handling, for additional precautionary measures. Keep personnel out of low areas. Keep upwind of spill. Spilled material may cause a slipping hazard. Ventilate area of leak or spill. If available, use foam to smother or suppress. See Section 10 for more specific information. Use appropriate safety equipment. For additional information, refer to Section 8, Exposure Controls and Personal Protection. Environmental precautions: Prevent from entering into soil, ditches, sewers, waterways and/or groundwater. See Section 12, Ecological Information. Methods and materials for containment and cleaning up: Do NOT use absorbent materials such as: Do not place in sealed containers. Contain spilled material if possible. Absorb with materials such as: Dirt. Vermiculite. Sand. Clay. Cement powder (Note: may generate heat). Collect in suitable and properly labeled open containers. Suitable containers include: Metal drums. Plastic drums. Polylined fiber pacs. Wash the spill site with large quantities of water. Attempt to neutralize by adding suitable decontaminant solution: Formulation 1: sodium carbonate 5 - 10%; liquid detergent 0.2 - 2%; water to make up to 100%, OR Formulation 2: concentrated ammonia solution 3 - 8%; liquid detergent 0.2 - 2%; water to make up to 100%. If ammonia is used, use good ventilation to prevent vapor exposure. Contact your supplier for clean-up assistance. See Section 13, Disposal Considerations, for additional information. 7. HANDLING AND STORAGE Precautions for safe handling: Avoid contact with eyes. Avoid prolonged or repeated contact with skin. Wash thoroughly after handling. Avoid breathing vapor. Use with adequate ventilation. This material is hygroscopic in nature. Keep container tightly closed. See Section 8, EXPOSURE CONTROLS AND PERSONAL PROTECTION. Spills of these organic materials on hot fibrous insulations may lead to lowering of the autoignition temperatures possibly resulting in spontaneous combustion. Conditions for safe storage: Do not store product contaminated with water to prevent potential hazardous reaction. Store in a dry place. Protect from atmospheric moisture. See Section 10 for more specific information. Additional storage and handling information on this product may be obtained by calling your sales or customer service contact. Storage stability Storage temperature: Storage Period: 24 - 35 °C (75 - 95 °F) 6 Month 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Control parameters If exposure limits exist, they are listed below. If no exposure limits are displayed, then no values are applicable. Component Regulation Type of listing Value 4,4'-Methylenediphenyl diisocyanate Dow IHG TWA 0.005 ppm Dow IHG STEL 0.02 ppm Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 6 of 16 ACGIH TWA 0.005 ppm Further information: resp sens: Respiratory sensitization OSHA Z-1 C 0.2 mg/m3 0.02 ppm Further information: (b): The value in mg/m3 is approximate.; ©: Ceiling limit is to be determined from breathing-zone air samples. Exposure controls Engineering controls: Use only with adequate ventilation. Local exhaust ventilation may be necessary for some operations. Provide general and/or local exhaust ventilation to control airborne levels below the exposure guidelines. Exhaust systems should be designed to move the air away from the source of vapor/aerosol generation and people working at this point. The odor and irritancy of this material are inadequate to warn of excessive exposure. Individual protection measures Eye/face protection: Use chemical goggles. Skin protection Hand protection: Use gloves chemically resistant to this material. Examples of preferred glove barrier materials include: Butyl rubber. Polyethylene. Chlorinated polyethylene. Ethyl vinyl alcohol laminate ("EVAL"). Examples of acceptable glove barrier materials include: Viton. Neoprene. Polyvinyl chloride ("PVC" or "vinyl"). Nitrile/butadiene rubber ("nitrile" or "NBR"). NOTICE: The selection of a specific glove for a particular application and duration of use in a workplace should also take into account all relevant workplace factors such as, but not limited to: Other chemicals which may be handled, physical requirements (cut/puncture protection, dexterity, thermal protection), potential body reactions to glove materials, as well as the instructions/specifications provided by the glove supplier. Other protection: Use protective clothing chemically resistant to this material. Selection of specific items such as face shield, boots, apron, or full body suit will depend on the task. Respiratory protection: Atmospheric levels should be maintained below the exposure guideline. When atmospheric levels may exceed the exposure guideline, use an approved air- purifying respirator equipped with an organic vapor sorbent and a particle filter. For situations where the atmospheric levels may exceed the level for which an air-purifying respirator is effective, use a positive-pressure air-supplying respirator (air line or self-contained breathing apparatus). For emergency response or for situations where the atmospheric level is unknown, use an approved positive-pressure self-contained breathing apparatus or positive- pressure air line with auxiliary self-contained air supply. The following should be effective types of air-purifying respirators: Organic vapor cartridge with a particulate pre-filter. 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance Physical state Liquid. Color Brown Odor Musty Odor Threshold 0.4 ppm Based on Literature for MDI. Odor is inadequate warning of excessive exposure. pH Not applicable Melting point/range No test data available Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 7 of 16 Freezing point No test data available Boiling point (760 mmHg) 210 °C ( 410 °F) Literature Flash point closed cup >204 °C ( 399 °F) ASTM D 93 Evaporation Rate (Butyl Acetate = 1) No test data available Flammability (solid, gas) Not Applicable Flammability (liquids) Not expected to be a static-accumulating flammable liquid. Lower explosion limit No test data available Upper explosion limit No test data available Vapor Pressure < 0.00001 mmHg at 25 °C (77 °F) Literature Relative Vapor Density (air = 1) 8.5 Literature Relative Density (water = 1) 1.24 at 20 °C (68 °F) / 20 °C Literature Water solubility insoluble Partition coefficient: n- octanol/water Reacts with water. Auto-ignition temperature > 600 °C (> 1,112 °F) Literature Decomposition temperature >230 °C (446 °F) Literature Kinematic Viscosity No test data available Explosive properties Not explosive Oxidizing properties No Molecular weight No test data available NOTE: The physical data presented above are typical values and should not be construed as a specification. 10. STABILITY AND REACTIVITY Reactivity: Diisocyanates react with many materials and the rate of reaction increases with temperature as well as increased contact; these reactions can become violent. Contact is increased by stirring or if the other material mixes with the diisocyanate. Diisocyanates are not soluble in water and sink to the bottom, but react slowly at the interface. The reaction forms carbon dioxide gas and a layer of solid polyurea. Reaction with water will generate carbon dioxide and heat. Chemical stability: Stable under recommended storage conditions. See Storage, Section 7. Possibility of hazardous reactions: Can occur. Exposure to elevated temperatures can cause product to decompose and generate gas. This can cause pressure build-up and/or rupturing of closed containers. Polymerization can be catalyzed by: Strong bases. Water. Conditions to avoid: Exposure to elevated temperatures can cause product to decompose. Generation of gas during decomposition can cause pressure in closed systems. Pressure build-up can be rapid. Avoid moisture. Material reacts slowly with water, releasing carbon dioxide which can cause pressure buildup and rupture of closed containers. Elevated temperatures accelerate this reaction. Incompatible materials: Avoid contact with: Acids. Alcohols. Amines. Water. Ammonia. Bases. Metal compounds. Moist air. Strong oxidizers. Diisocyanates react with many materials and the rate of reaction increases with temperature as well as increased contact; these reactions can become Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 8 of 16 violent. Contact is increased by stirring or if the other material mixes with the diisocyanate. Diisocyanates are not soluble in water and sink to the bottom, but react slowly at the interface. The reaction forms carbon dioxide gas and a layer of solid polyurea. Reaction with water will generate carbon dioxide and heat. Avoid contact with metals such as: Aluminum. Zinc. Brass. Tin. Copper. Galvanized metals. Avoid contact with absorbent materials such as: Moist organic absorbents. Avoid unintended contact with polyols. The reaction of polyols and isocyanates generate heat. Hazardous decomposition products: Decomposition products depend upon temperature, air supply and the presence of other materials.. Gases are released during decomposition.. 11. TOXICOLOGICAL INFORMATION Toxicological information appears in this section when such data is available. Information on likely routes of exposure Ingestion, Inhalation, Skin contact, Eye contact. Acute toxicity (represents short term exposures with immediate effects - no chronic/delayed effects known unless otherwise noted) Acute oral toxicity Low toxicity if swallowed. Small amounts swallowed incidentally as a result of normal handling operations are not likely to cause injury; however, swallowing larger amounts may cause injury. Typical for this family of materials. LD50, Rat, > 10,000 mg/kg Information for components: Diphenylmethane Diisocyanate, isomers and homologues Typical for this family of materials. LD50, Rat, > 10,000 mg/kg 4,4'-Methylenediphenyl diisocyanate LD50, Rat, > 2,000 mg/kg No deaths occurred at this concentration. Acute dermal toxicity Prolonged skin contact is unlikely to result in absorption of harmful amounts. Typical for this family of materials. LD50, Rabbit, > 9,400 mg/kg Information for components: Diphenylmethane Diisocyanate, isomers and homologues Typical for this family of materials. LD50, Rabbit, > 9,400 mg/kg 4,4'-Methylenediphenyl diisocyanate LD50, Rabbit, > 9,400 mg/kg Acute inhalation toxicity At room temperature, vapors are minimal due to low volatility. However, certain operations may generate vapor or mist concentrations sufficient to cause respiratory irritation and other Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 9 of 16 adverse effects. Such operations include those in which the material is heated, sprayed or otherwise mechanically dispersed such as drumming, venting or pumping. Excessive exposure may cause irritation to upper respiratory tract (nose and throat) and lungs. May cause pulmonary edema (fluid in the lungs.) Effects may be delayed. Decreased lung function has been associated with overexposure to isocyanates. Typical for this family of materials. LC50, Rat, 4 Hour, dust/mist, 0.49 mg/l For similar material(s): 4,4'-Methylenediphenyl diisocyanate (CAS 101-68-8). LC50, Rat, 1 Hour, Aerosol, 2.24 mg/l For similar material(s): 2,4'-Diphenylmethane diisocyanate (CAS 5873-54-1). LC50, Rat, 4 Hour, Aerosol, 0.387 mg/l Information for components: Diphenylmethane Diisocyanate, isomers and homologues LC50, Rat, 4 Hour, dust/mist, 0.49 mg/l For similar material(s): 4,4'-Methylenediphenyl diisocyanate (CAS 101-68-8). LC50, Rat, 1 Hour, Aerosol, 2.24 mg/l For similar material(s): 2,4'-Diphenylmethane diisocyanate (CAS 5873-54-1). LC50, Rat, 4 Hour, Aerosol, 0.387 mg/l 4,4'-Methylenediphenyl diisocyanate LC50, Rat, 1 Hour, dust/mist, 2.24 mg/l Skin corrosion/irritation Based on testing for product(s) in this family of materials: Prolonged contact may cause slight skin irritation with local redness. May stain skin. Information for components: Diphenylmethane Diisocyanate, isomers and homologues Prolonged contact may cause slight skin irritation with local redness. May stain skin. 4,4'-Methylenediphenyl diisocyanate Prolonged contact may cause moderate skin irritation with local redness. Repeated contact may cause moderate skin irritation with local redness. May stain skin. Serious eye damage/eye irritation Based on testing for product(s) in this family of materials: May cause moderate eye irritation. May cause slight temporary corneal injury. Information for components: Diphenylmethane Diisocyanate, isomers and homologues May cause moderate eye irritation. May cause slight temporary corneal injury. 4,4'-Methylenediphenyl diisocyanate Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 10 of 16 May cause moderate eye irritation. May cause slight temporary corneal injury. Sensitization For this family of materials: Skin contact may cause an allergic skin reaction. Animal studies have shown that skin contact with isocyanates may play a role in respiratory sensitization. For this family of materials: May cause allergic respiratory reaction. Reexposure to extremely low isocyanate concentrations may cause allergic respiratory reactions in individuals already sensitized. Asthma-like symptoms may include coughing, difficult breathing and a feeling of tightness in the chest. Occasionally, breathing difficulties may be life threatening. Effects may be delayed. Information for components: Diphenylmethane Diisocyanate, isomers and homologues For skin sensitization: Skin contact may cause an allergic skin reaction. Animal studies have shown that skin contact with isocyanates may play a role in respiratory sensitization. For respiratory sensitization: May cause allergic respiratory reaction. MDI concentrations below the exposure guidelines may cause allergic respiratory reactions in individuals already sensitized. Asthma-like symptoms may include coughing, difficult breathing and a feeling of tightness in the chest. Occasionally, breathing difficulties may be life threatening. 4,4'-Methylenediphenyl diisocyanate For skin sensitization: Skin contact may cause an allergic skin reaction. Animal studies have shown that skin contact with isocyanates may play a role in respiratory sensitization. For respiratory sensitization: May cause allergic respiratory reaction. MDI concentrations below the exposure guidelines may cause allergic respiratory reactions in individuals already sensitized. Asthma-like symptoms may include coughing, difficult breathing and a feeling of tightness in the chest. Occasionally, breathing difficulties may be life threatening. Specific Target Organ Systemic Toxicity (Single Exposure) May cause respiratory irritation. Route of Exposure: Inhalation Target Organs: Respiratory Tract Information for components: Diphenylmethane Diisocyanate, isomers and homologues May cause respiratory irritation. Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 11 of 16 Route of Exposure: Inhalation Target Organs: Respiratory Tract 4,4'-Methylenediphenyl diisocyanate May cause respiratory irritation. Route of Exposure: Inhalation Target Organs: Respiratory Tract Aspiration Hazard Based on physical properties, not likely to be an aspiration hazard. Information for components: Diphenylmethane Diisocyanate, isomers and homologues Based on physical properties, not likely to be an aspiration hazard. 4,4'-Methylenediphenyl diisocyanate Based on physical properties, not likely to be an aspiration hazard. Chronic toxicity (represents longer term exposures with repeated dose resulting in chronic/delayed effects - no immediate effects known unless otherwise noted) Specific Target Organ Systemic Toxicity (Repeated Exposure) For this family of materials: Tissue injury in the upper respiratory tract and lungs has been observed in laboratory animals after repeated excessive exposures to MDI/polymeric MDI aerosols. Information for components: Diphenylmethane Diisocyanate, isomers and homologues Tissue injury in the upper respiratory tract and lungs has been observed in laboratory animals after repeated excessive exposures to MDI/polymeric MDI aerosols. 4,4'-Methylenediphenyl diisocyanate Tissue injury in the upper respiratory tract and lungs has been observed in laboratory animals after repeated excessive exposures to MDI/polymeric MDI aerosols. Carcinogenicity For this family of materials: Lung tumors have been observed in laboratory animals exposed to respirable aerosol droplets of MDI/Polymeric MDI (6 mg/m3) for their lifetime. Tumors occurred concurrently with respiratory irritation and lung injury. Current exposure guidelines are expected to protect against these effects reported for MDI. Information for components: Diphenylmethane Diisocyanate, isomers and homologues Lung tumors have been observed in laboratory animals exposed to respirable aerosol droplets of MDI/Polymeric MDI (6 mg/m3) for their lifetime. Tumors occurred concurrently with respiratory irritation and lung injury. Current exposure guidelines are expected to protect against these effects reported for MDI. 4,4'-Methylenediphenyl diisocyanate Lung tumors have been observed in laboratory animals exposed to respirable aerosol droplets of MDI/Polymeric MDI (6 mg/m3) for their lifetime. Tumors occurred concurrently with Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 12 of 16 respiratory irritation and lung injury. Current exposure guidelines are expected to protect against these effects reported for MDI. Teratogenicity For this family of materials: In laboratory animals, MDI/polymeric MDI did not cause birth defects; other fetal effects occurred only at high doses which were toxic to the mother. Information for components: Diphenylmethane Diisocyanate, isomers and homologues In laboratory animals, MDI/polymeric MDI did not cause birth defects; other fetal effects occurred only at high doses which were toxic to the mother. 4,4'-Methylenediphenyl diisocyanate Has been toxic to the fetus in laboratory animals at doses toxic to the mother. Did not cause birth defects in laboratory animals. Reproductive toxicity No specific, relevant data available for assessment. Information for components: Diphenylmethane Diisocyanate, isomers and homologues No relevant data found. 4,4'-Methylenediphenyl diisocyanate No relevant data found. Mutagenicity For this family of materials: Genetic toxicity data on MDI are inconclusive. MDI was weakly positive in some in vitro studies; other in vitro studies were negative. Animal mutagenicity studies were predominantly negative. Information for components: Diphenylmethane Diisocyanate, isomers and homologues Genetic toxicity data on MDI are inconclusive. MDI was weakly positive in some in vitro studies; other in vitro studies were negative. Animal mutagenicity studies were predominantly negative. 4,4'-Methylenediphenyl diisocyanate Genetic toxicity data on MDI are inconclusive. MDI was weakly positive in some in vitro studies; other in vitro studies were negative. Animal mutagenicity studies were predominantly negative. 12. ECOLOGICAL INFORMATION Ecotoxicological information appears in this section when such data is available. Toxicity Acute toxicity to fish Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 13 of 16 The measured ecotoxicity is that of the hydrolyzed product, generally under conditions maximizing production of soluble species. Material is practically non-toxic to aquatic organisms on an acute basis (LC50/EC50/EL50/LL50 >100 mg/L in the most sensitive species tested). LC50, Danio rerio (zebra fish), static test, 96 Hour, > 1,000 mg/l, OECD Test Guideline 203 or Equivalent Acute toxicity to aquatic invertebrates EC50, Daphnia magna (Water flea), static test, 24 Hour, > 1,000 mg/l, OECD Test Guideline 202 or Equivalent Acute toxicity to algae/aquatic plants NOEC, Desmodesmus subspicatus (green algae), static test, 72 Hour, Growth rate inhibition, 1,640 mg/l, OECD Test Guideline 201 or Equivalent Toxicity to bacteria EC50, activated sludge, static test, 3 Hour, Respiration rates., > 100 mg/l Toxicity to soil-dwelling organisms EC50, Eisenia fetida (earthworms), 14 d, > 1,000 mg/kg Toxicity to terrestrial plants EC50, Avena sativa (oats), Growth inhibition, 1,000 mg/l EC50, Lactuca sativa (lettuce), Growth inhibition, 1,000 mg/l Persistence and degradability Biodegradability: In the aquatic and terrestrial environment, material reacts with water forming predominantly insoluble polyureas which appear to be stable. In the atmospheric environment, material is expected to have a short tropospheric half-life, based on calculations and by analogy with related diisocyanates. 10-day Window: Not applicable Biodegradation: 0 % Exposure time: 28 d Method: OECD Test Guideline 302C or Equivalent Bioaccumulative potential Bioconcentration factor (BCF): 92 Cyprinus carpio (Carp) 28 d Diphenylmethane Diisocyanate, isomers and homologues Bioaccumulation: Bioconcentration potential is low (BCF < 100 or Log Pow < 3). Reacts with water. In the aquatic and terrestrial environment, movement is expected to be limited by its reaction with water forming predominantly insoluble polyureas. Bioconcentration factor (BCF): 92 Cyprinus carpio (Carp) 28 d 4,4'-Methylenediphenyl diisocyanate Bioaccumulation: Bioconcentration potential is low (BCF < 100 or Log Pow < 3). Reacts with water. In the aquatic and terrestrial environment, movement is expected to be limited by its reaction with water forming predominantly insoluble polyureas. Bioconcentration factor (BCF): 92 Cyprinus carpio (Carp) 28 d Mobility in soil Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 14 of 16 In the aquatic and terrestrial environment, movement is expected to be limited by its reaction with water forming predominantly insoluble polyureas. 13. DISPOSAL CONSIDERATIONS Disposal methods: DO NOT DUMP INTO ANY SEWERS, ON THE GROUND, OR INTO ANY BODY OF WATER. All disposal practices must be in compliance with all Federal, State/Provincial and local laws and regulations. Regulations may vary in different locations. Waste characterizations and compliance with applicable laws are the responsibility solely of the waste generator. AS YOUR SUPPLIER, WE HAVE NO CONTROL OVER THE MANAGEMENT PRACTICES OR MANUFACTURING PROCESSES OF PARTIES HANDLING OR USING THIS MATERIAL. THE INFORMATION PRESENTED HERE PERTAINS ONLY TO THE PRODUCT AS SHIPPED IN ITS INTENDED CONDITION AS DESCRIBED IN MSDS SECTION: Composition Information. FOR UNUSED & UNCONTAMINATED PRODUCT, the preferred options include sending to a licensed, permitted: Recycler. Reclaimer. Incinerator or other thermal destruction device. For additional information, refer to: Handling & Storage Information, MSDS Section 7 Stability & Reactivity Information, MSDS Section10 Regulatory Information, MSDS Section 15 14. TRANSPORT INFORMATION DOT Proper shipping name Environmentally hazardous substance, liquid, n.o.s.(MDI) UN number UN 3082 Class 9 Packing group III Reportable Quantity MDI Classification for SEA transport (IMO-IMDG): Not regulated for transport Transport in bulk according to Annex I or II of MARPOL 73/78 and the IBC or IGC Code Consult IMO regulations before transporting ocean bulk Classification for AIR transport (IATA/ICAO): Not regulated for transport This information is not intended to convey all specific regulatory or operational requirements/information relating to this product. Transportation classifications may vary by container volume and may be influenced by regional or country variations in regulations. Additional transportation system information can be obtained through an authorized sales or customer service representative. It is the responsibility of the transporting organization to follow all applicable laws, regulations and rules relating to the transportation of the material. Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 15 of 16 15. REGULATORY INFORMATION Superfund Amendments and Reauthorization Act of 1986 Title III (Emergency Planning and Community Right-to-Know Act of 1986) Sections 311 and 312 Acute toxicity (any route of exposure) Respiratory or skin sensitisation Specific target organ toxicity (single or repeated exposure) Skin corrosion or irritation Serious eye damage or eye irritation Superfund Amendments and Reauthorization Act of 1986 Title III (Emergency Planning and Community Right-to-Know Act of 1986) Section 313 This product contains the following substances which are subject to the reporting requirements of Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 and which are listed in 40 CFR 372. Components CASRN Diphenylmethane Diisocyanate, isomers and homologues 9016-87-9 4,4'-Methylenediphenyl diisocyanate 101-68-8 Pennsylvania Worker and Community Right-To-Know Act: To the best of our knowledge, this product does not contain chemicals at levels which require reporting under this statute. California Prop. 65 This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. United States TSCA Inventory (TSCA) All components of this product are in compliance with the inventory listing requirements of the U.S. Toxic Substances Control Act (TSCA) Chemical Substance Inventory. 16. OTHER INFORMATION Revision Identification Number: 38202 / A001 / Issue Date: 03/18/2020 / Version: 10.0 Most recent revision(s) are noted by the bold, double bars in left-hand margin throughout this document. Legend ACGIH USA. ACGIH Threshold Limit Values (TLV) C Ceiling Dow IHG Dow Industrial Hygiene Guideline OSHA Z-1 USA. Occupational Exposure Limits (OSHA) - Table Z-1 Limits for Air Contaminants STEL Short term exposure limit TWA Time weighted average Full text of other abbreviations Product name: PAPI™ 580N Polymeric MDI Issue Date: 03/18/2020 Page 16 of 16 AICS - Australian Inventory of Chemical Substances; ASTM - American Society for the Testing of Materials; bw - Body weight; CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act; CMR - Carcinogen, Mutagen or Reproductive Toxicant; DIN - Standard of the German Institute for Standardisation; DOT - Department of Transportation; DSL - Domestic Substances List (Canada); ECx - Concentration associated with x% response; EHS - Extremely Hazardous Substance; ELx - Loading rate associated with x% response; EmS - Emergency Schedule; ENCS - Existing and New Chemical Substances (Japan); ErCx - Concentration associated with x% growth rate response; ERG - Emergency Response Guide; GHS - Globally Harmonized System; GLP - Good Laboratory Practice; HMIS - Hazardous Materials Identification System; IARC - International Agency for Research on Cancer; IATA - International Air Transport Association; IBC - International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk; IC50 - Half maximal inhibitory concentration; ICAO - International Civil Aviation Organization; IECSC - Inventory of Existing Chemical Substances in China; IMDG - International Maritime Dangerous Goods; IMO - International Maritime Organization; ISHL - Industrial Safety and Health Law (Japan); ISO - International Organisation for Standardization; KECI - Korea Existing Chemicals Inventory; LC50 - Lethal Concentration to 50 % of a test population; LD50 - Lethal Dose to 50% of a test population (Median Lethal Dose); MARPOL - International Convention for the Prevention of Pollution from Ships; MSHA - Mine Safety and Health Administration; n.o.s. - Not Otherwise Specified; NFPA - National Fire Protection Association; NO(A)EC - No Observed (Adverse) Effect Concentration; NO(A)EL - No Observed (Adverse) Effect Level; NOELR - No Observable Effect Loading Rate; NTP - National Toxicology Program; NZIoC - New Zealand Inventory of Chemicals; OECD - Organization for Economic Co-operation and Development; OPPTS - Office of Chemical Safety and Pollution Prevention; PBT - Persistent, Bioaccumulative and Toxic substance; PICCS - Philippines Inventory of Chemicals and Chemical Substances; (Q)SAR - (Quantitative) Structure Activity Relationship; RCRA - Resource Conservation and Recovery Act; REACH - Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals; RQ - Reportable Quantity; SADT - Self-Accelerating Decomposition Temperature; SARA - Superfund Amendments and Reauthorization Act; SDS - Safety Data Sheet; TCSI - Taiwan Chemical Substance Inventory; TSCA - Toxic Substances Control Act (United States); UN - United Nations; UNRTDG - United Nations Recommendations on the Transport of Dangerous Goods; vPvB - Very Persistent and Very Bioaccumulative Information Source and References This SDS is prepared by Product Regulatory Services and Hazard Communications Groups from information supplied by internal references within our company. THE DOW CHEMICAL COMPANY urges each customer or recipient of this (M)SDS to study it carefully and consult appropriate expertise, as necessary or appropriate, to become aware of and understand the data contained in this (M)SDS and any hazards associated with the product. The information herein is provided in good faith and believed to be accurate as of the effective date shown above. However, no warranty, express or implied, is given. Regulatory requirements are subject to change and may differ between various locations. It is the buyer's/user's responsibility to ensure that his activities comply with all federal, state, provincial or local laws. The information presented here pertains only to the product as shipped. Since conditions for use of the product are not under the control of the manufacturer, it is the buyer's/user's duty to determine the conditions necessary for the safe use of this product. Due to the proliferation of sources for information such as manufacturer- specific (M)SDSs, we are not and cannot be responsible for (M)SDSs obtained from any source other than ourselves. If you have obtained an (M)SDS from another source or if you are not sure that the (M)SDS you have is current, please contact us for the most current version. US Safety Data Sheet According to OSHA HCS 2012 (29 CFR 1910.1200) SECTION 1: Identification Product Identifier n-Pentane Other means of identification N-Pentane, Pure Grade N-Pentane, Technical Grade Pentane (B) Comm. Grade Pentane Pure (B) N-Pentane, Borger Comm Normal Pentane, Technical Grade SDS Number 001967 Relevant identified uses Solvent Uses advised against All others 24 Hour Emergency Phone Number CHEMTREC 1-800-424-9300 CHEMTREC Mexico 01-800-681-9531 SECTION 2: Hazard identification Manufacturer/Supplier Phillips 66 Specialty Solvents PO Box 358 Borger, Texas 79008-0358 SDS Information Phone: 800-762-0942 Email: SDS@P66.com URL: www.Phillips66.com Customer Service 800-696-4240 http://solvents.phillips66.com Technical Information 1-800-696-4240 Classified Hazards Hazards Not Otherwise Classified (HNOC) H224 -- Flammable liquids -- Category 1 H304 -- Aspiration Hazard -- Category 1 H336 -- Specific target organ toxicity (single exposure) -- Category 3H411 -- Hazardous to the aquatic environment, chronic toxicity -- Category 2 PHNOC: Electrostatic charge may be generated during pumping and other operations HHNOC: None known Label Elements DANGER Extremely flammable liquid and vapor May be fatal if swallowed and enters airways May cause drowsiness or dizziness Toxic to aquatic life with long lasting effects Keep away from heat/sparks/open flames/hot surfaces. - No smoking; Keep container tightly closed; Ground/bond container and receiving equipment; Use only non-sparking tools; Take precautionary measures against static discharge; Avoid breathing dust/fume/gas/mist/vapours/spray; Use only outdoors or in a well-ventilated area; Avoid release to the environment; Wear protective gloves/protective clothing and eye/face protection; IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician; Do NOT induce vomiting; IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower; IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing; Call a POISON CENTER or doctor/physician if you feel unwell; In case of fire: Use CO2, dry chemical, or foam for extinction; Collect spillage; Store in a well-ventilated place. Keep cool; Dispose of contents/container to an approved waste disposal plant _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 1/7 Issue Date: 30-Sep-2016 Status: FINAL _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 2/7 Issue Date: 30-Sep-2016 Status: FINAL SECTION 4: First aid measures Eye Contact: If irritation or redness develops from exposure, flush eyes with clean water. If symptoms persist, seek medical attention. Skin Contact: Remove contaminated shoes and clothing and cleanse affected area(s) thoroughly by washing with mild soap and water or a waterless hand cleaner. If irritation or redness develops and persists, seek medical attention. Inhalation: First aid is not normally required. If breathing difficulties develop, move victim away from source of exposure and into fresh air in a position comfortable for breathing. Seek immediate medical attention. Ingestion: Aspiration hazard: Do not induce vomiting or give anything by mouth because this material can enter the lungs and cause severe lung damage. If victim is drowsy or unconscious and vomiting, place on the left side with the head down. If possible, do not leave victim unattended and observe closely for adequacy of breathing. Seek medical attention. Most important symptoms and effects, both acute and delayed: Effects of overexposure can include slight irritation of the respiratory tract, nausea, vomiting, and signs of nervous system depression (e.g., headache, drowsiness, dizziness, loss of coordination, disorientation and fatigue). Continued exposure to high concentrations can result in vomiting, cardiac irregularities and sudden loss of consciousness. Prolonged or repeated contact may dry skin and cause irritation. Notes to Physician: Epinephrine and other sympathomimetic drugs may initiate cardiac arrhythmias in persons exposed to high concentrations of hydrocarbon solvents (e.g., in enclosed spaces or with deliberate abuse). The use of other drugs with less arrhythmogenic potential should be considered. If sympathomimetic drugs are administered, observe for the development of cardiac arrhythmias. SECTION 5: Firefighting measures NFPA 704 Hazard Class Extinguishing Media: Dry chemical, carbon dioxide, or foam is recommended. Water spray is recommended to cool or protect exposed materials or structures. Carbon dioxide can displace oxygen. Use caution when applying carbon dioxide in confined spaces. Simultaneous use of foam and water on the same surface is to be avoided as water destroys the foam. Water may be ineffective for extinguishment, unless used under favorable conditions by experienced fire fighters. Specific hazards arising from the chemical Unusual Fire & Explosion Hazards: Extremely flammable. This material can be ignited by heat, sparks, flames, or other sources of ignition (e.g., static electricity, pilot lights, mechanical/electrical equipment, and electronic devices such as cell phones, computers, calculators, and pagers which have not been certified as intrinsically safe) Vapors may travel considerable distances to a source of ignition where they can ignite, flash back, or explode. May create vapor/air explosion hazard indoors, in confined spaces, outdoors, or in sewers. This product will float and can be reignited on surface water. Vapors are heavier than air and can accumulate in low areas. If container is not properly cooled, it can rupture in the heat of a fire. Hazardous Combustion Products: Combustion may yield smoke, carbon monoxide, and other products of incomplete SECTION 3: Composition/information on ingredients Chemical Name CASRN Concentration¹ Pentane 109-66-0 >95 Cyclopentane 287-92-3 <5 Isopentane 78-78-4 <5 Other Hexanes VARIOUS <3 ¹ All concentrations are percent by weight unless ingredient is a gas. Gas concentrations are in percent by volume. Health: 1 Flammability: 4 Instability: 0 0 (Minimal) 1 (Slight) 2 (Moderate) 3 (Serious) 4 (Severe) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 3/7 Issue Date: 30-Sep-2016 Status: FINAL combustion. Special protective actions for fire-fighters: For fires beyond the initial stage, emergency responders in the immediate hazard area should wear protective clothing. When the potential chemical hazard is unknown, in enclosed or confined spaces, a self contained breathing apparatus should be worn. In addition, wear other appropriate protective equipment as conditions warrant (see Section 8). Isolate the hazard area and deny entry to unnecessary and unprotected personnel. Stop spill/release if it can be done safely. Move undamaged containers from immediate hazard area if it can be done safely. Water spray may be useful in minimizing or dispersing vapors and to protect personnel. Cool equipment exposed to fire with water, if it can be done safely. Avoid spreading burning liquid with water used for cooling purposes. See Section 9 for Flammable Properties including Flash Point and Flammable (Explosive) Limits SECTION 6: Accidental release measures Personal precautions, protective equipment and emergency procedures: Extremely flammable. Spillages of liquid product will create a fire hazard and may form an explosive atmosphere. Keep all sources of ignition and hot metal surfaces away from spill/release if safe to do so. The use of explosion-proof electrical equipment is recommended. Stay upwind and away from spill/release. Avoid direct contact with material. For large spillages, notify persons down wind of the spill/release, isolate immediate hazard area and keep unauthorized personnel out. Wear appropriate protective equipment, including respiratory protection, as conditions warrant (see Section 8). See Sections 2 and 7 for additional information on hazards and precautionary measures. Environmental Precautions: Stop and contain spill/release if it can be done safely. Prevent spilled material from entering sewers, storm drains, other unauthorized drainage systems, and natural waterways. Use foam on spills to minimize vapors Use water sparingly to minimize environmental contamination and reduce disposal requirements. If spill occurs on water notify appropriate authorities and advise shipping of any hazard. Spills into or upon navigable waters, the contiguous zone, or adjoining shorelines that cause a sheen or discoloration on the surface of the water, may require notification of the National Response Center (phone number 800-424-8802). Methods and material for containment and cleaning up: Notify relevant authorities in accordance with all applicable regulations. Immediate cleanup of any spill is recommended. Dike far ahead of spill for later recovery or disposal. Absorb spill with inert material such as sand or vermiculite, and place in suitable container for disposal. If spilled on water remove with appropriate methods (e.g. skimming, booms or absorbents). In case of soil contamination, remove contaminated soil for remediation or disposal, in accordance with local regulations. Recommended measures are based on the most likely spillage scenarios for this material; however local conditions and regulations may influence or limit the choice of appropriate actions to be taken. SECTION 7: Handling and storage Precautions for safe handling: Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking. Take precautionary measures against static discharge. Use only non-sparking tools. Wash thoroughly after handling. Use good personal hygiene practices and wear appropriate personal protective equipment (see section 8). Extremely Flammable. May vaporize easily at ambient temperatures. The vapor is heavier than air and may create an explosive mixture of vapor and air. Beware of accumulation in confined spaces and low lying areas. Open container slowly to relieve any pressure. The use of explosion-proof electrical equipment is recommended and may be required (see appropriate fire codes). Refer to NFPA-70 and/or API RP 2003 for specific bonding/grounding requirements. Do not enter confined spaces such as tanks or pits without following proper entry procedures such as ASTM D-4276 and 29CFR 1910.146. Do not wear contaminated clothing or shoes. Keep contaminated clothing away from sources of ignition such as sparks or open flames. Static Accumulation Hazard: Electrostatic charge may accumulate and create a hazardous condition when handling this material. To minimize this hazard, bonding and grounding of tanks, transfer piping, and storage tank level floats are necessary but may not, by themselves, be sufficient. Review all operations which have the potential of generating and accumulating an electrostatic charge and/or a flammable atmosphere (including tank and container filling, splash filling, tank cleaning, sampling, gauging, switch loading, filtering, mixing, agitation, and vacuum truck operations) and use appropriate mitigating procedures. Special care should be given to ensure that special slow load procedures for "switch loading" are followed to avoid the static ignition hazard that can exist when higher flash point material (such as fuel oil or diesel) is loaded into tanks previously containing low flash point products (such as gasoline or naphtha). For more information, refer to OSHA Standard 29 CFR 1910.106, 'Flammable and Combustible Liquids', National Fire Protection Association (NFPA 77, 'Recommended Practice on Static Electricity', and/or the American Petroleum Institute (API) Recommended Practice 2003, 'Protection Against Ignitions Arising Out of Static, Lightning, and Stray Currents'. Conditions for safe storage: Keep container(s) tightly closed and properly labeled. Use and store this material in cool, dry, well-ventilated areas away from heat, direct sunlight, hot metal surfaces, and all sources of ignition. Store only in approved containers. Post area "No Smoking or Open Flame." Keep away from any incompatible material (see Section 10). Protect _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 4/7 Issue Date: 30-Sep-2016 Status: FINAL container(s) against physical damage. Outdoor or detached storage is preferred. Indoor storage should meet OSHA standards and appropriate fire codes. "Empty" containers retain residue and may be dangerous. Do not pressurize, cut, weld, braze, solder, drill, grind, or expose such containers to heat, flame, sparks, or other sources of ignition. They may explode and cause injury or death. "Empty" drums should be completely drained, properly bunged, and promptly shipped to the supplier or a drum reconditioner. All containers should be disposed of in an environmentally safe manner and in accordance with governmental regulations. Before working on or in tanks which contain or have contained this material, refer to OSHA regulations, ANSI Z49.1, and other references pertaining to cleaning, repairing, welding, or other contemplated operations. SECTION 8: Exposure controls/personal protection Chemical Name ACGIH OSHA Phillips 66 Pentane TWA-8hr: 1000 ppm Pentane, all isomers TWA-8hr: 1000 ppm TWA-8hr: 2950 mg/m3 --- Cyclopentane TWA-8hr: 600 ppm ------ Isopentane TWA-8hr: 1000 ppm Pentane, all isomers ------ Note: State, local or other agencies or advisory groups may have established more stringent limits. Consult an industrial hygienist or similar professional, or your local agencies, for further information. Engineering controls: If current ventilation practices are not adequate to maintain airborne concentrations below the established exposure limits, additional engineering controls may be required. Eye/Face Protection: The use of eye protection that meets or exceeds ANSI Z.87.1 is recommended to protect against potential eye contact, irritation, or injury. Depending on conditions of use, a face shield may be necessary. Skin/Hand Protection: The use of gloves impervious to the specific material handled is advised to prevent skin contact. Users should check with manufacturers to confirm the breakthrough performance of their products. Suggested protective materials: Nitrile Respiratory Protection: Where there is potential for airborne exposure above the exposure limit a NIOSH certified air purifying respirator equipped with organic vapor cartridges/canisters may be used. A respiratory protection program that meets or is equivalent to OSHA 29 CFR 1910.134 and ANSI Z88.2 should be followed whenever workplace conditions warrant a respirator's use. Air purifying respirators provide limited protection and cannot be used in atmospheres that exceed the maximum use concentration (as directed by regulation or the manufacturer's instructions), in oxygen deficient (less than 19.5 percent oxygen) situations, or under conditions that are immediately dangerous to life and health (IDLH). Suggestions provided in this section for exposure control and specific types of protective equipment are based on readily available information. Users should consult with the specific manufacturer to confirm the performance of their protective equipment. Specific situations may require consultation with industrial hygiene, safety, or engineering professionals. SECTION 9: Physical and chemical properties Note: Unless otherwise stated, values are determined at 20°C (68°F) and 760 mm Hg (1 atm). Data represent typical values and are not intended to be specifications. SECTION 10: Stability and reactivity Reactivity: Not chemically reactive. Appearance: Colorless Flash Point: -40 °F / -40 °C Physical Form: Liquid Test Method: Tag Closed Cup (TCC), ASTM D56 Odor: Gasoline Initial Boiling Point/Range: 95 °F / 35 °C Odor Threshold: No data Vapor Pressure: 15.5 psia (Reid VP) @ 100°F / 37.8°C pH: Not applicable Partition Coefficient (n-octanol/water) (Kow): 3.4 Vapor Density (air=1): 2.48 Melting/Freezing Point: -201.5 °F / -130 °C Upper Explosive Limits (vol % in air): 8.0 Auto-ignition Temperature: 544 °F / 284 °C Lower Explosive Limits (vol % in air): 1.4 Decomposition Temperature: No data Evaporation Rate (nBuAc=1): >1 Specific Gravity (water=1): 0.63 @ 60ºF (15.6ºC) Particle Size: Not applicable Bulk Density: 5.26 lbs/gal Percent Volatile: 100%Viscosity: 0.234 cP @ 68°F (20°C) Flammability (solid, gas): Not applicable Solubility in Water: Negligible _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 5/7 Issue Date: 30-Sep-2016 Status: FINAL Chemical stability: Stable under normal ambient and anticipated conditions of use. Possibility of hazardous reactions: Hazardous reactions not anticipated. Conditions to avoid: Avoid high temperatures and all sources of ignition. Prevent vapor accumulation. Incompatible materials: Avoid contact with strong oxidizing agents and strong reducing agents. Hazardous decomposition products: Not anticipated under normal conditions of use. SECTION 11: Toxicological information Information on Toxicological Effects Substance / Mixture Aspiration Hazard: May be fatal if swallowed and enters airways Skin Corrosion/Irritation: Causes mild skin irritation. Repeated exposure may cause skin dryness or cracking. Serious Eye Damage/Irritation: Causes mild eye irritation. Skin Sensitization: No information available on the mixture, however none of the components have been classified for skin sensitization (or are below the concentration threshold for classification). Respiratory Sensitization: No information available. Specific Target Organ Toxicity (Single Exposure): May cause drowsiness and dizziness. Specific Target Organ Toxicity (Repeated Exposure): No information available on the mixture, however none of the components have been classified for target organ toxicity (or are below the concentration threshold for classification). Carcinogenicity: No information available. Germ Cell Mutagenicity: No information available on the mixture, however none of the components have been classified for germ cell mutagenicity (or are below the concentration threshold for classification). Reproductive Toxicity: No information available on the mixture, however none of the components have been classified for reproductive toxicity (or are below the concentration threshold for classification). Other Comments: Reports have associated repeated and prolonged occupational overexposure to solvents with permanent brain and nervous system damage (sometimes referred to as Solvent or Painters' Syndrome). Intentional misuse by deliberately concentrating and inhaling this material may be harmful or fatal. Information on Toxicological Effects of Components Other Hexanes Target Organ(s): A mixture of hexane isomers, free of n-hexane, did not produce neurotoxic effects in rats exposed to 500 ppm for six months. SECTION 12: Ecological information Toxicity: Acute aquatic toxicity studies on samples of n-pentane show acute toxicity values greater than 1 mg/L and mostly in the Acute Toxicity Hazard Additional Information LC50/LD50 Data Inhalation Unlikely to be harmful > 20 mg/L (vapor, estimated) Dermal Unlikely to be harmful > 2 g/kg (estimated) Oral Unlikely to be harmful >2 g/kg GHS Classification: H411 -- Hazardous to the aquatic environment, chronic toxicity -- Category 2 Toxic to aquatic life with long lasting effects. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 6/7 Issue Date: 30-Sep-2016 Status: FINAL range 1-10 mg/L. n-Pentane will readily evaporate from the surface and would not be expected to have significant adverse effects in the aquatic environment. Persistence and Degradability: n-Pentane is expected to be inherently biodegradable. In practice, it is not likely to remain in solution long enough for biodegradation to be a significant loss process. Bioaccumulative Potential: The Log Kow value measured for n-pentane is 3.4 and it is expected to have a low potential for bioaccumulation. Mobility in Soil: Because of n-pentane's extreme volatility, air is the only environmental compartment in which this hydrocarbon will be found. In air, n-pentane can readily undergo photodegradation by reaction with hydroxyl radicals. Its chemical half life is approximately 4 days. Other adverse effects: None anticipated. SECTION 13: Disposal considerations The generator of a waste is always responsible for making proper hazardous waste determinations and needs to consider state and local requirements in addition to federal regulations. This material, if discarded as produced, would not be a federally regulated RCRA "listed" hazardous waste. However, it would likely be identified as a federally regulated RCRA hazardous waste for the following characteristic(s) shown below. See Sections 7 and 8 for information on handling, storage and personal protection and Section 9 for physical/chemical properties. It is possible that the material as produced contains constituents which are not required to be listed in the SDS but could affect the hazardous waste determination. Additionally, use which results in chemical or physical change of this material could subject it to regulation as a hazardous waste.Container contents should be completely used and containers should be emptied prior to discard. Container residues and rinseates could be considered to be hazardous wastes. EPA Waste Number(s) • D001 - Ignitability characteristic SECTION 14: Transport information U.S. Department of Transportation (DOT) UN Number: UN1265 UN proper shipping name: Pentanes Transport hazard class(es): 3 Packing Group: I Environmental Hazards: Marine pollutant - Environmentally Hazardous Special precautions for user: Container(s) greater than 5 liters (liquids) or 5 kilograms (solids), shipped by water mode and ALL bulk shipments may require the shipping description to contain the "Marine Pollutant" notation [49 CFR 172.203(l)] and the container(s) to display the [Marine Pollutant Mark] [49 CFR 172.322]. Transport in bulk according to Annex II of MARPOL 73/78 and the IBC Code: Not applicable SECTION 15: Regulatory information CERCLA/SARA - Section 302 Extremely Hazardous Substances and TPQs (in pounds): This material does not contain any chemicals subject to the reporting requirements of SARA 302 and 40 CFR 372. CERCLA/SARA - Section 311/312 (Title III Hazard Categories) Acute Health Hazard:Yes Chronic Health Hazard:No Fire Hazard:Yes Pressure Hazard:No Reactive Hazard:No CERCLA/SARA - Section 313 and 40 CFR 372: This material does not contain any chemicals subject to the reporting requirements of SARA 313 and 40 CFR 372. EPA (CERCLA) Reportable Quantity (in pounds): EPA's Petroleum Exclusion applies to this material - (CERCLA 101(14)). _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 001967 - n-Pentane Page 7/7 Issue Date: 30-Sep-2016 Status: FINAL California Proposition 65:This material does not contain any chemicals which are known to the State of California to cause cancer, birth defects or other reproductive harm at concentrations that trigger the warning requirements of California Proposition 65. International Hazard Classification Canada: This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the SDS contains all the information required by the Regulations. International Inventories All components are either listed on the US TSCA Inventory, or are not regulated under TSCA. All components are either on the DSL, or are exempt from DSL listing requirements. SECTION 16: Other information Guide to Abbreviations: ACGIH = American Conference of Governmental Industrial Hygienists; CASRN = Chemical Abstracts Service Registry Number; CEILING = Ceiling Limit (15 minutes); CERCLA = The Comprehensive Environmental Response, Compensation, and Liability Act; EPA = Environmental Protection Agency; GHS = Globally Harmonized System; IARC = International Agency for Research on Cancer; INSHT = National Institute for Health and Safety at Work; IOPC = International Oil Pollution Compensation; LEL = Lower Explosive Limit; NE = Not Established; NFPA = National Fire Protection Association; NTP = National Toxicology Program; OSHA = Occupational Safety and Health Administration; PEL = Permissible Exposure Limit (OSHA); SARA = Superfund Amendments and Reauthorization Act; STEL = Short Term Exposure Limit (15 minutes); TLV = Threshold Limit Value (ACGIH); TWA = Time Weighted Average (8 hours); UEL = Upper Explosive Limit; WHMIS = Worker Hazardous Materials Information System (Canada) Disclaimer of Expressed and implied Warranties: The information presented in this Safety Data Sheet is based on data believed to be accurate as of the date this Safety Data Sheet was prepared. HOWEVER, NO WARRANTY OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE, OR ANY OTHER WARRANTY IS EXPRESSED OR IS TO BE IMPLIED REGARDING THE ACCURACY OR COMPLETENESS OF THE INFORMATION PROVIDED ABOVE, THE RESULTS TO BE OBTAINED FROM THE USE OF THIS INFORMATION OR THE PRODUCT, THE SAFETY OF THIS PRODUCT, OR THE HAZARDS RELATED TO ITS USE. No responsibility is assumed for any damage or injury resulting from abnormal use or from any failure to adhere to recommended practices. The information provided above, and the product, are furnished on the condition that the person receiving them shall make their own determination as to the suitability of the product for their particular purpose and on the condition that they assume the risk of their use. In addition, no authorization is given nor implied to practice any patented invention without a license. Revised Sections or Basis for Revision: Precautionary Statement(s) (Section 2); Exposure limits (Section 8); Toxicological (Section 11); Regulatory information (Section 15) Issue Date:Previous Issue Date:SDS Number Status: 30-Sep-2016 31-Mar-2015 001967 FINAL Appendix D RBLC Database Results RBLCID Facility Name Facility State Permit Isuance Date Process Name Primary Fuel Pollutant Control Method Description Emission Limit 1 Emission Limit Unit Case-By-Case Basis MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Particulate matter, total < 10 µ (TPM10)Baghouse, dry ESP, RTO. Bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.08 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse, Dry ESP, RTO. Bypass of Dry ESP and RTO is allowed for up to 460 hours per year.1.08 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Volatile Organic Compounds (VOC)RTO for VOC as well as baghouse and dry ESP. Bypass of RTO is allowed for up to 460 hours per year.76 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Particulate matter, filterable (FPM)Baghouse, Dry ESP, RTO. Bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.08 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices 0 BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices 0.0004 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices. Natural gas only.5254 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Volatile Organic Compounds (VOC)Good design and operating/combustion practices.0.0054 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Carbon Monoxide Good design and operation 0.082 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Nitrogen Oxides (NOx)Low NOx burners and good design and combustion practices.0.05 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFLTOS1 in FGTOH (Thermal Oil System for Thermally Fused Lamination Lines)Natural gas Particulate matter, filterable (FPM)Good combustion practices.0.0075 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFCOS in FGFINISH (Flying Cutoff Saw)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFCOS in FGFINISH (Flying Cutoff Saw)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFCOS in FGFINISH (Flying Cutoff Saw)Volatile Organic Compounds (VOC)Good design and operation practices.1.4 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFCOS in FGFINISH (Flying Cutoff Saw)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSANDING in FGFINISH (Sanding Operations)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 1.27 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSANDING in FGFINISH (Sanding Operations)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 1.27 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSANDING in FGFINISH (Sanding Operations)Volatile Organic Compounds (VOC)Good design and operation practices 3.32 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSANDING in FGFINISH (Sanding Operations)Particulate matter, filterable (FPM)Baghouse/fabric filters.1.27 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices.0.0005 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices.0.0004 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices, natural gas only.17438 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Volatile Organic Compounds (VOC)Good design and operating/combustion practices.0.0054 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Carbon Monoxide Good design and operation 0.082 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Nitrogen Oxides (NOx)Low NOx burners and good design and combustion practices.0.05 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUTOH (In FGTOH)--Thermal Oil Heater Natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCTPSAW--Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Particulate matter, total < 10 µ (TPM10)Baghouse/Fabric filter 0.56 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCTPSAW--Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.56 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCTPSAW--Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Volatile Organic Compounds (VOC)Good design and operation practices.1.4 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCTPSAW--Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Particulate matter, filterable (FPM)Baghouse/Fabric filter 0.56 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCOOLING in FGPRESSCOOL (Board Cooling System)Particulate matter, total < 10 µ (TPM10)Wet scrubber 2.2 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCOOLING in FGPRESSCOOL (Board Cooling System)Particulate matter, total < 2.5 µ (TPM2.5)Wet scrubber 2.2 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCOOLING in FGPRESSCOOL (Board Cooling System)Volatile Organic Compounds (VOC)Good design and operation practices 49.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCOOLING in FGPRESSCOOL (Board Cooling System)Carbon Monoxide Good design and operation practices 2.85 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCOOLING in FGPRESSCOOL (Board Cooling System)Nitrogen Oxides (NOx)Good design and operation practices 2.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUCOOLING in FGPRESSCOOL (Board Cooling System)Particulate matter, filterable (FPM)Wet scrubber 12.2 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFORMING in FGBLNDFRM (core and surface forming)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFORMING in FGBLNDFRM (core and surface forming)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFORMING in FGBLNDFRM (core and surface forming)Volatile Organic Compounds (VOC)Good design and operation practices 9.34 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFORMING in FGBLNDFRM (core and surface forming)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPRESS in FGPRESSCOOL (continuous press system)Particulate matter, total < 10 µ (TPM10)Wet scrubber 2.2 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPRESS in FGPRESSCOOL (continuous press system)Particulate matter, total < 2.5 µ (TPM2.5)Wet scrubber 2.2 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPRESS in FGPRESSCOOL (continuous press system)Volatile Organic Compounds (VOC)Good design and operation practices.49.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPRESS in FGPRESSCOOL (continuous press system)Carbon Monoxide Good design and operation practices 2.85 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPRESS in FGPRESSCOOL (continuous press system)Nitrogen Oxides (NOx)Good design and operation practices.2.5 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPRESS in FGPRESSCOOL (continuous press system)Particulate matter, filterable (FPM)Wet scrubber 12.2 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 0.12 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filter 0.12 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Volatile Organic Compounds (VOC)Good design and operation practices 0.54 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.12 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices 0.0005 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices 0.0004 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices, natural gas only.3502 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Volatile Organic Compounds (VOC)Good design and operating practices and low VOC coatings.4.3 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Carbon Monoxide Good design and operation 0.082 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Nitrogen Oxides (NOx)Low NOx burners and good design and combustion practices.0.05 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUPTL1 and EUPTL2 in FGPTL (2 paper treating lines)natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 0.44 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filter 0.44 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Volatile Organic Compounds (VOC)Good design and operation practices 0.05 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Particulate matter, filterable (FPM)Baghouse/fabric filter 0.44 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Emergency Diesel Generator Engine (EUEMRGRICE in FGRICE)Diesel Particulate matter, total < 10 µ (TPM10)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.1.41 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Emergency Diesel Generator Engine (EUEMRGRICE in FGRICE)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.1.41 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Emergency Diesel Generator Engine (EUEMRGRICE in FGRICE)Diesel Carbon Dioxide Equivalent (CO2e)Good combustion and design practices.223 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Emergency Diesel Generator Engine (EUEMRGRICE in FGRICE)Diesel Carbon Monoxide Good design and combustion practices.3.5 G/KW-H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Emergency Diesel Generator Engine (EUEMRGRICE in FGRICE)Diesel Nitrogen Oxides (NOx)Certified engines, limited operating hours.22.6 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Emergency Diesel Generator Engine (EUEMRGRICE in FGRICE)Diesel Particulate matter, filterable (FPM)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.1.41 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Dieself fire pump engine (EUFIREPUMP in FGRICE)Diesel Particulate matter, total < 10 µ (TPM10)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.18 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Dieself fire pump engine (EUFIREPUMP in FGRICE)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.18 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Dieself fire pump engine (EUFIREPUMP in FGRICE)Diesel Carbon Dioxide Equivalent (CO2e)Good combustion and design practices.56 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Dieself fire pump engine (EUFIREPUMP in FGRICE)Diesel Carbon Monoxide Good design and combustion practices.3.5 G/KW-H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Dieself fire pump engine (EUFIREPUMP in FGRICE)Diesel Nitrogen Oxides (NOx)Certified engines, limited operating hours.3.53 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Dieself fire pump engine (EUFIREPUMP in FGRICE)Diesel Particulate matter, filterable (FPM)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.0.18 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Particulate matter, total < 10 µ (TPM10)Good combustion practices, dry ESP, RTO.28.4 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices, dry ESP, RTO.16.55 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Carbon Dioxide Equivalent (CO2e)Good operating and maintenance practices 205655 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Volatile Organic Compounds (VOC)Good combustion practices, RTO.7.1 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Carbon Monoxide Good combustion practices and RTO1.36.3 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Nitrogen Oxides (NOx)Good combustion practices and low NOx burners.95 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT Thermal Energy Plant (EUENERGY in FGDRYERRTO)derived fuel & Particulate matter, filterable (FPM)Good combustion practices, dry ESP and RTO.29.1 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Overs mills (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.59 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Overs mills (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.59 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Overs mills (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Volatile Organic Compounds (VOC)Good design and operating practices 0.75 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 3 Overs mills (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.59 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFINES in FGMTRLHNDL Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFINES in FGMTRLHNDL Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFINES in FGMTRLHNDL Volatile Organic Compounds (VOC)Good design and operating practices 1.93 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUFINES in FGMTRLHNDL Particulate matter, filterable (FPM)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSIFTER in FGMTRLHNDL Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSIFTER in FGMTRLHNDL Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUSIFTER in FGMTRLHNDL Particulate matter, filterable (FPM)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBARKSTG in FGMTRLHNDL Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.12 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBARKSTG in FGMTRLHNDL Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.12 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBARKSTG in FGMTRLHNDL Volatile Organic Compounds (VOC)Good design and operating practices 0.55 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBARKSTG in FGMTRLHNDL Particulate matter, filterable (FPM)Baghouse/fabric filters 0.12 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBLENDING in FGBLNDFRM Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.99 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBLENDING in FGBLNDFRM Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.99 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBLENDING in FGBLNDFRM Volatile Organic Compounds (VOC)Good design and operating practices 2.43 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT EUBLENDING in FGBLNDFRM Particulate matter, filterable (FPM)Baghouse/fabric filters 0.99 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices and RTO.28.4 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices and RTO.16.55 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Carbon Dioxide Equivalent (CO2e)Good operating and maintenance practices, natural gas only.205655 T/YR BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Volatile Organic Compounds (VOC)Good combustion practices and RTO.7.1 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Carbon Monoxide Good combustion practices and RTO1.36.3 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Nitrogen Oxides (NOx)Good combustion practices and low NOx burners.95 LB/H BACT-PSD MI-0421 GRAYLING PARTICLEBOARD MI 08/26/2016 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)Natural gas Particulate matter, filterable (FPM)Good combustion practices and RTO.29.1 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTFL1, EUTFL2 & EUTFL3 in FGTFL (3 Thermally Fused Lamination Lines)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 0.33 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTFL1, EUTFL2 & EUTFL3 in FGTFL (3 Thermally Fused Lamination Lines)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTFL1, EUTFL2 & EUTFL3 in FGTFL (3 Thermally Fused Lamination Lines)Volatile Organic Compounds (VOC)Good design and operation practices.0.05 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTFL1, EUTFL2 & EUTFL3 in FGTFL (3 Thermally Fused Lamination Lines)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE1 in FGRICE (Emergency diesel generator engine)Diesel Particulate matter, total < 10 µ (TPM10)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.0.66 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE1 in FGRICE (Emergency diesel generator engine)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.0.66 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE1 in FGRICE (Emergency diesel generator engine)Diesel Carbon Dioxide Equivalent (CO2e)Good combustion and design practices.209 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE1 in FGRICE (Emergency diesel generator engine)Diesel Carbon Monoxide Good design and combustion practices.3.5 G/KW-H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE1 in FGRICE (Emergency diesel generator engine)Diesel Nitrogen Oxides (NOx)Certified engines, limited operating hours.21.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE1 in FGRICE (Emergency diesel generator engine)Diesel Particulate matter, filterable (FPM)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.0.66 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices and RTO.28.4 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices and RTO.16.55 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Carbon Dioxide Equivalent (CO2e)Good operating and maintenance practices, natural gas only.205655 TON/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Volatile Organic Compounds (VOC)Good combustion practices and RTO.7.1 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Carbon Monoxide Good combustion practices and RTO1.36.3 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Nitrogen Oxides (NOx)Good combustion practices and low NOx burners 95 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGDRYERRTO (2 Natural Gas Fired Rotary Dryers Natural gas Particulate matter, filterable (FPM)Good combustion practices and RTO.29.1 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Particulate matter, total < 10 µ (TPM10)Good combustion practices, dry ESP, RTO.28.4 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices, dry ESP and RTO.16.55 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Carbon Dioxide Equivalent (CO2e)Good operating and maintenance practices.205655 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Volatile Organic Compounds (VOC)Good combustion practices and RTO.7.1 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Carbon Monoxide Good combustion practices and RTO1.36.3 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Nitrogen Oxides (NOx)Good combustion practices and low NOx burners 95 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUENERGY in FGDRYERRTO (Thermal Energy Plant) erived fuel and Particulate matter, filterable (FPM)Good combustion practices, dry ESP, RTO.29.1 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGMTRLHNDL (3 Overs mills EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, total < 10 µ (TPM10)Baghouse/Fabric filters 0.61 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGMTRLHNDL (3 Overs mills EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/Fabric filters 0.61 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGMTRLHNDL (3 Overs mills EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Volatile Organic Compounds (VOC)Good design and operating practices 0.75 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT FGMTRLHNDL (3 Overs mills EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, filterable (FPM)Baghouse/Fabric filters 0.61 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFINES in FGMTRLHNDL Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFINES in FGMTRLHNDL Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFINES in FGMTRLHNDL Volatile Organic Compounds (VOC)Good design and operating practices.1.93 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFINES in FGMTRLHNDL Particulate matter, filterable (FPM)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSIFTERS in FGMTRLHNDL Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSIFTERS in FGMTRLHNDL Particulate matter, filterable (FPM)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSIFTERS in FGMTRLHNDL Particulate matter, filterable < 2.5 µ (FPM2.5)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBARKSTG in FGMTRLHNDL Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBARKSTG in FGMTRLHNDL Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBARKSTG in FGMTRLHNDL Volatile Organic Compounds (VOC)Good design and operating practices.0.55 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBARKSTG in FGMTRLHNDL Particulate matter, filterable (FPM)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBLENDING in FGBLNDFRM Particulate matter, total < 10 µ (TPM10)Bathouse/fabric filters 0.41 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBLENDING in FGBLNDFRM Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBLENDING in FGBLNDFRM Volatile Organic Compounds (VOC)Good design and operation practices.2.43 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUBLENDING in FGBLNDFRM Particulate matter, filterable (FPM)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFORMING in FGBLNDFRM Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 1.05 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFORMING in FGBLNDFRM Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 1.058 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFORMING in FGBLNDFRM Volatile Organic Compounds (VOC)Good design and operation practices.9.34 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFORMING in FGBLNDFRM Particulate matter, filterable (FPM)Baghouse/fabric filters 1.05 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPRESS in FGPRESSCOOL Particulate matter, total < 10 µ (TPM10)Wet scrubber 2.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPRESS in FGPRESSCOOL Particulate matter, total < 2.5 µ (TPM2.5)Wet scrubber 2.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPRESS in FGPRESSCOOL Volatile Organic Compounds (VOC)Good design and operation practices.49.5 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPRESS in FGPRESSCOOL Carbon Monoxide Good design and operation practices.2.85 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPRESS in FGPRESSCOOL Nitrogen Oxides (NOx)Good design and operation practices.2.5 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPRESS in FGPRESSCOOL Particulate matter, filterable (FPM)Wet scrubber 12.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCOOLING in FGPRESSCOOL Particulate matter, total < 10 µ (TPM10)Wet scrubber 2.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCOOLING in FGPRESSCOOL Particulate matter, total < 2.5 µ (TPM2.5)Wet scrubber 2.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCOOLING in FGPRESSCOOL Volatile Organic Compounds (VOC)Good design and operation practices.49.5 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCOOLING in FGPRESSCOOL Carbon Monoxide Good design and operation practices.2.85 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCOOLING in FGPRESSCOOL Nitrogen Oxides (NOx)Good design and operation practices.2.5 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCOOLING in FGPRESSCOOL Particulate matter, filterable (FPM)Wet scrubber 12.2 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices.0.0005 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices.0.0004 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices, natural gas only.19490 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Volatile Organic Compounds (VOC)Good design and operating/combustion practices.0.0054 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Carbon Monoxide Good design and operation.0.082 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Nitrogen Oxides (NOx)Good design and combustion practices, Low NOx burners.0.05 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUTOH in FGTOH Natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices.0.0005 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices, natural gas only.5254 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Volatile Organic Compounds (VOC)Good design and operating/combustion practices.0.0054 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Carbon Monoxide Good design and operation.0.082 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Nitrogen Oxides (NOx)Good design and combustion practices, low NOx burners.0.05 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFLTOS1 in FGTOH Natural gas Particulate matter, filterable < 2.5 µ (FPM2.5)Good combustion practices 0.0004 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFCOS in FGFINISH Particulate matter, total < 10 µ (TPM10)Baghouse/Fabric filter 0.55 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFCOS in FGFINISH Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.55 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFCOS in FGFINISH Volatile Organic Compounds (VOC)Good design and operation practices.1.4 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFCOS in FGFINISH Particulate matter, filterable (FPM)Baghouse/fabric filters 0.55 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE2 in FGRICE (Emergency Diesel Generator Engine)Diesel Particulate matter, total < 10 µ (TPM10)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.22 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE2 in FGRICE (Emergency Diesel Generator Engine)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.22 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE2 in FGRICE (Emergency Diesel Generator Engine)Diesel Carbon Dioxide Equivalent (CO2e)Good combustion and design practices.70 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE2 in FGRICE (Emergency Diesel Generator Engine)Diesel Carbon Monoxide Good design and combustion practices.3.5 G/KW-H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE2 in FGRICE (Emergency Diesel Generator Engine)Diesel Nitrogen Oxides (NOx)Certified engines, limited operating hours 4.4 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUEMRGRICE2 in FGRICE (Emergency Diesel Generator Engine)Diesel Particulate matter, filterable (FPM)Certified engines, good design, operation and combustion practices. Operational restrictions/limited use.0.22 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFIREPUMP in FGRICE (Diesel fire pump engine)Diesel Particulate matter, total < 10 µ (TPM10)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.18 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFIREPUMP in FGRICE (Diesel fire pump engine)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.18 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFIREPUMP in FGRICE (Diesel fire pump engine)Diesel Carbon Dioxide Equivalent (CO2e)Good combustion and design practices.56 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFIREPUMP in FGRICE (Diesel fire pump engine)Diesel Carbon Monoxide Good design and combustion practices.3.5 G/KW-H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFIREPUMP in FGRICE (Diesel fire pump engine)Diesel Nitrogen Oxides (NOx)Certified engines. Limited operating hours.3.53 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUFIREPUMP in FGRICE (Diesel fire pump engine)Diesel Particulate matter, filterable (FPM)Certified engines. Good design, operation and combustion practices. Operational restrictions/limited use.0.18 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSANDING in FGFINISH Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 1.43 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSANDING in FGFINISH Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 1.43 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSANDING in FGFINISH Volatile Organic Compounds (VOC)Good design and operation practices.3.32 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUSANDING in FGFINISH Particulate matter, filterable (FPM)Baghouse/fabric filters 1.43 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCTPSAW in FGFINISH Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 0.44 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCTPSAW in FGFINISH Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.44 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCTPSAW in FGFINISH Volatile Organic Compounds (VOC)Good design and operation practices.1.4 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUCTPSAW in FGFINISH Particulate matter, filterable (FPM)Baghouse/fabric filter 0.44 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Volatile Organic Compounds (VOC)Good design and operation practices.0.54 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EURMSILO in FGFINISH (Raw material sawdust silo)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices 0.0005 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices.0.0004 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices, natural gas only.3502 T/YR BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Volatile Organic Compounds (VOC)Good design and operating practices and low VOC coatings.4.3 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Carbon Monoxide Good design and operation.0.082 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Nitrogen Oxides (NOx)Good design and combustion practices, low NOx burners.0.05 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EUPTL1 & EUPTL2 in FGPTL (2 paper treating lines)Natural gas Particulate matter, filterable (FPM)Good combustion practices.0.0075 LB/MMBTU BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EU-FLAKERS (7 Green flakers with baghouse, dry ESP and RTO Control)Particulate matter, total < 10 µ (TPM10)Baghouse, dry ESP, RTO. Bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.01 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EU-FLAKERS (7 Green flakers with baghouse, dry ESP and RTO Control)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse, dry ESP and RTO. Bypass of dry ESP and RTO is allowed up to 460 hours per year.1.01 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EU-FLAKERS (7 Green flakers with baghouse, dry ESP and RTO Control)Volatile Organic Compounds (VOC)RTO for VOC as well as baghouse and dry ESP. Bypass of RTO is allowed for up to 460 hours per year.76 LB/H BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 ACT EU-FLAKERS (7 Green flakers with baghouse, dry ESP and RTO Control)Particulate matter, filterable (FPM)Baghouse, dry ESP, RTO. Bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.01 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Particulate matter, total < 10 µ (TPM10)Baghouse, dry ESP, RTO. Bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.01 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse, dry ESP, RTO, bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.01 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Volatile Organic Compounds (VOC)RTO for VOC as well as Baghouse and Dry ESP. Bypass of RTO is allowed for up to 460 hours per year.76 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT EUFLAKERS (7 green flakers with baghouse, dry ESP and RTO control)Particulate matter, filterable (FPM)Baghouse, Dry ESP, RTO. Bypass of dry ESP and RTO is allowed for up to 460 hours per year.1.01 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices and RTO 28.4 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices, RTO 16.55 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Carbon Dioxide Equivalent (CO2e)Good operating and maintenance practices, natural gas only.257292 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Volatile Organic Compounds (VOC)Good combustion practices, RTO 7.1 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Carbon Monoxide Good combustion practices and RTO1 36.3 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Nitrogen Oxides (NOx)Good combustion practices and low NOx burners 170 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Natural gas fired rotary dryers (EUDRYER1, EUDRYER2 in FGDRYERRTO)natural gas Particulate matter, filterable (FPM)Good combustion practices, RTO 29.1 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Particulate matter, total < 10 µ (TPM10)Good combustion practices, dry ESP, RTO 28.4 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices, dry ESP, RTO 16.55 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Carbon Dioxide Equivalent (CO2e)Good operating and maintenance practices 257292 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Volatile Organic Compounds (VOC)Good combustion practices and RTO 7.1 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Carbon Monoxide Good combustion practices and RTO1 36.3 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Nitrogen Oxides (NOx)Good combustion practices and low NOx burners 170 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal energy plant (EUENERGY in FGDRYERRTO)erived fuel and Particulate matter, filterable (FPM)Good combustion practices, dry ESP, RTO 29.1 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of fines from screening to Energy Plant Dust Silo (EUFINES in FGMTRLHNDL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of fines from screening to Energy Plant Dust Silo (EUFINES in FGMTRLHNDL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of fines from screening to Energy Plant Dust Silo (EUFINES in FGMTRLHNDL)Volatile Organic Compounds (VOC)Good design and operating practices 1.93 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of fines from screening to Energy Plant Dust Silo (EUFINES in FGMTRLHNDL)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.03 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of material to bark storage (EUBARKSTG in FGMTRLHNDL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of material to bark storage (EUBARKSTG in FGMTRLHNDL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of material to bark storage (EUBARKSTG in FGMTRLHNDL)Volatile Organic Compounds (VOC)Good design and operating practices 0.55 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Conveyance of material to bark storage (EUBARKSTG in FGMTRLHNDL)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Blending (EUBLENDING in FGBLNDFRM)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Blending (EUBLENDING in FGBLNDFRM)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Blending (EUBLENDING in FGBLNDFRM)Volatile Organic Compounds (VOC)Good design and operation practices.17.3 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Blending (EUBLENDING in FGBLNDFRM)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Forming (EUFORMING in FGBLNDFRM)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 1.05 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Forming (EUFORMING in FGBLNDFRM)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 1.058 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Forming (EUFORMING in FGBLNDFRM)Volatile Organic Compounds (VOC)Good design and operation practices 9.34 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Forming (EUFORMING in FGBLNDFRM)Particulate matter, filterable (FPM)Baghouse/fabric filters 1.05 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Continuous Press System (EUPRESS in FGPRESSCOOL)Particulate matter, total < 10 µ (TPM10)Wet scrubber 4.74 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Continuous Press System (EUPRESS in FGPRESSCOOL)Particulate matter, total < 2.5 µ (TPM2.5)Wet scrubber 4.74 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Continuous Press System (EUPRESS in FGPRESSCOOL)Volatile Organic Compounds (VOC)Good design and operation practices 49.5 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Continuous Press System (EUPRESS in FGPRESSCOOL)Carbon Monoxide Good design and operating practices.2.85 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Continuous Press System (EUPRESS in FGPRESSCOOL)Nitrogen Oxides (NOx)Good design and operation practices 2.5 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Continuous Press System (EUPRESS in FGPRESSCOOL)Particulate matter, filterable (FPM)wet scrubber 4.74 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Board Cooling System (EUCOOLING in FGPRESSCOOL)Particulate matter, total < 10 µ (TPM10)Wet scrubber 4.74 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Board Cooling System (EUCOOLING in FGPRESSCOOL)Particulate matter, total < 2.5 µ (TPM2.5)Wet scrubber 4.74 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Board Cooling System (EUCOOLING in FGPRESSCOOL)Volatile Organic Compounds (VOC)Good design and operation practices 49.5 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Board Cooling System (EUCOOLING in FGPRESSCOOL)Carbon Monoxide Good design and operation practices 2.85 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Board Cooling System (EUCOOLING in FGPRESSCOOL)Nitrogen Oxides (NOx)Good design and operation practices 2.5 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Board Cooling System (EUCOOLING in FGPRESSCOOL)Particulate matter, filterable (FPM)Wet scrubber 4.74 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices 0.0005 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices 0.0004 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Carbon Dioxide Equivalent (CO2e)Good combustion and maintenance practices, natural gas only.19490 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Volatile Organic Compounds (VOC)Good design and operating/combustion practices 0.0054 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Carbon Monoxide Good design and operation 0.082 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Nitrogen Oxides (NOx)Good design and combustion practices, low NOx burners 0.05 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil heater (EUTOH in FGTOH)Natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Particulate matter, total < 10 µ (TPM10)Good combustion practices 0.0005 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good combustion practices 0.0004 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Carbon Dioxide Equivalent (CO2e)Good Combustion and Maintenance Practices, Natural Gas Only 5254 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Volatile Organic Compounds (VOC)Good Design and Operating/Combustion Practices 0.0054 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Carbon Monoxide Good design and operation 0.082 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Nitrogen Oxides (NOx)Good design and combustion practices, low NOx burners 0.05 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)Natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Flying cutoff saw (EUFCOS in FGFINISH)Particulate matter, total < 10 µ (TPM10)Baghouse/Fabric Filter 0.55 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Flying cutoff saw (EUFCOS in FGFINISH)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/Fabric Filters 0.55 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Flying cutoff saw (EUFCOS in FGFINISH)Volatile Organic Compounds (VOC)Good Design and Operation Practices 10.3 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Flying cutoff saw (EUFCOS in FGFINISH)Particulate matter, filterable (FPM)Baghouse/Fabric Filters 0.55 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Sanding operations (EUSANDING in FGFINISH)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 1.43 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Sanding operations (EUSANDING in FGFINISH)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 1.43 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Sanding operations (EUSANDING in FGFINISH)Volatile Organic Compounds (VOC)Good Design and Operation Practices 6.9 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Sanding operations (EUSANDING in FGFINISH)Particulate matter, filterable (FPM)Baghouse/fabric filters 1.43 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Particulate matter, total < 10 µ (TPM10)Baghouse/Fabric Filter 0.44 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/Fabric Filters 0.44 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Volatile Organic Compounds (VOC)Good Design and Operation Practices 3 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Cut to Panel Saw Line (EUCTPSAW in FGFINISH)Particulate matter, filterable (FPM)Baghouse/Fabric Filter 0.44 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Raw material sawdust silo (EURMSILO in FGFINISH)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 0.06 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Raw material sawdust silo (EURMSILO in FGFINISH)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Raw material sawdust silo (EURMSILO in FGFINISH)Volatile Organic Compounds (VOC)Good Design and Operation Practices 0.54 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Raw material sawdust silo (EURMSILO in FGFINISH)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.06 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Particulate matter, total < 10 µ (TPM10)Good Combustion Practices 0.0005 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Particulate matter, total < 2.5 µ (TPM2.5)Good Combustion Practices 0.0004 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Carbon Dioxide Equivalent (CO2e)Good Combustion and Maintenance Practices, Natural Gas Only 3502 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Volatile Organic Compounds (VOC)Good Design and Operating Practices and Low VOC Coatings 4.3 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Carbon Monoxide Good design and operation 0.082 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Nitrogen Oxides (NOx)Good Design and Combustion Practices, Low NOx Burners 0.05 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 2 Paper Treating Lines (EUPTL1 and EUPTL2 in FGPTL)Natural gas Particulate matter, filterable (FPM)Good combustion practices 0.0075 LB/MMBTU BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filter 0.33 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.33 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Volatile Organic Compounds (VOC)Good design and operation practices 0.05 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 Thermally Fused Lamination Lines (EUTFL1, EUTFL2, EUTFL3 in FGTFL)Particulate matter, filterable (FPM)Baghouse/fabric filter 0.33 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE1 in FGRICE)Diesel Particulate matter, total < 10 µ (TPM10)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.66 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE1 in FGRICE)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.66 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE1 in FGRICE)Diesel Carbon Dioxide Equivalent (CO2e)Good Combustion and Design Practices 590 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE1 in FGRICE)Diesel Carbon Monoxide Good design and combustion practices 3.5 G/KW-H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE1 in FGRICE)Diesel Nitrogen Oxides (NOx)Certified engines, limited operating hours 21.2 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE1 in FGRICE)Diesel Particulate matter, filterable (FPM)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.66 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE2 in FGRICE)Diesel Particulate matter, total < 10 µ (TPM10)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.22 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE2 in FGRICE)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.22 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE2 in FGRICE)Diesel Carbon Dioxide Equivalent (CO2e)Good Combustion and Design Practices 209 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE2 in FGRICE)Diesel Carbon Monoxide Good Design and Combustion Practices 3.5 G/KW-H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE2 in FGRICE)Diesel Nitrogen Oxides (NOx)Certified Engines, Limited Operating Hours 4.4 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Emergency diesel generator engine (EUEMRGRICE2 in FGRICE)Diesel Particulate matter, filterable (FPM)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.22 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Diesel fire pump engine (EUFIREPUMP in FGRICE)Diesel Particulate matter, total < 10 µ (TPM10)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.18 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Diesel fire pump engine (EUFIREPUMP in FGRICE)Diesel Particulate matter, total < 2.5 µ (TPM2.5)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.18 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Diesel fire pump engine (EUFIREPUMP in FGRICE)Diesel Carbon Dioxide Equivalent (CO2e)Good Combustion and Design Practices 56 T/YR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Diesel fire pump engine (EUFIREPUMP in FGRICE)Diesel Carbon Monoxide Good Design and Combustion Practices 3.5 G/KW-H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Diesel fire pump engine (EUFIREPUMP in FGRICE)Diesel Nitrogen Oxides (NOx)Certified Engines, Limited Operating Hours 3.53 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Diesel fire pump engine (EUFIREPUMP in FGRICE)Diesel Particulate matter, filterable (FPM)Certified Engines, Good Design, Operation, and Combustion Practices, Operational Restrictions/Limited Use 0.18 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 overs mills in FGMTRLHNDL (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.61 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 overs mills in FGMTRLHNDL (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.61 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 overs mills in FGMTRLHNDL (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Volatile Organic Compounds (VOC)Good design and operating practices.20.6 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT 3 overs mills in FGMTRLHNDL (EUOVERS1, EUOVERS2, EUOVERS3 in FGMTRLHNDL)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.61 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Sifter/Shaker (EUSIFTERS in FGMTRLHNDL)Particulate matter, total < 10 µ (TPM10)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Sifter/Shaker (EUSIFTERS in FGMTRLHNDL)Particulate matter, total < 2.5 µ (TPM2.5)Baghouse/fabric filters 0.41 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Sifter/Shaker (EUSIFTERS in FGMTRLHNDL)Volatile Organic Compounds (VOC)Good design and operating practices.18 LB/H BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 ACT Core and Surface Sifter/Shaker (EUSIFTERS in FGMTRLHNDL)Particulate matter, filterable (FPM)Baghouse/fabric filters 0.41 LB/H BACT-PSD