TRC
 TRC Environmental Corporation

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      MODEL OPERATING  PERMIT FOR PM10 EMISSIONS
FROM CALCINERS AND DRIERS  IN THE MINERAL  INDUSTRIES
                     DRAFT REPORT
                    November 1992
                      Prepared by

            TRC ENVIRONMENTAL CORPORATION
             100 Europa  Drive, Suite  150
                Chapel Hill, NC 27514
             EPA Contract No. 68-DO-0121
              Work Assignment No.  11-91

    EPA Work Assignment Manager:   W.  Stephen Fruh
             Emission  Standards Division
    Office  of  Air Quality  Planning and Standards
        U.S.  Environmental  Protection Agency
          Research Triangle Park,  NC 27711
        THIS DOCUMENT HAS NOT BEEN PEER OR ADMINISTRATIVELY
       REVIEWED WITHIN EPA AND IS FOR AGENCY USE/DISTRIBUTION
            ONLY.  DO NOT QUOTE, CITE OR DISTRIBUTE.
                       (CH-91-16u)

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                                  DISCLAIMER

      This Draft Final Report was prepared for the  Emission  Standards Division,
U.S. Environmental Protection Agency, Research Triangle Park,  North  Carolina  by
Alliance Technology  Corporation, operating  under  the  name TRC  Environmental
Corporation, 100  Europa  Drive,  Chapel  Hill,  North  Carolina  27514, in  partial
fulfillment of Contract No. 68-DO-0121, Work Assignment No. 11-91.  The opinions,
findings and conclusions expressed are those  of the authors  and  not  necessarily
those of the Environment Protection Agency.
CH-91-16u                                11

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                              TABLE OF  CONTENTS

Section                                                                   Page

List of Tables	   iv

1.0   Introduction	1-1

2.0   Sources of Emissions	2-1
   2.1 General	2-1
   2.2 Dryers	2-1
   2.3 Calciners	2-3
   2.4 References   	2-5

3.0   Model Permit for Calciners and Dryers in the Mineral Industries .  .  3-1
   3.1 Introduction   	3-1
   3.2 Specific Conditions  	  3-2
      3.2.1  Example  of  Specific  Conditions for  Calciners  and  for
             Calciners and Dryers Installed in Series 	  3-2
      3.2.2  Example of Specific Conditions for Dryers  	  3-2
   3.3 Control Equipment  Operating Parameters  	  3-4
      3.3.1  Fabric Filter Operating Parameters 	  3-4
      3.3.2  Electrostatic Precipitator Operating Parameters  	  3-4
      3.3.3  Mechanical Collectors Operating  Parameters 	  3-4
      3.3.4  Scrubber Operating Parameters  	  3-4
   3.4 Monitoring Requirements  	  3-5
   3.5 Testing Requirements   	  3-6
   3.6 Recordkeeping  Requirements   	  3-7
   3.7 Reporting Requirements   	  3-8
   3.8 References   	3-9
CH-91-16u                               i i i

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                                 LIST OF TABLES
Number                                                                      Page
2-1   Types of Dryers  and Calciners used by  Industry   	  2-2
CH-91-16U                                 IV

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                               1.0   INTRODUCTION
      Title V of  the  1990 Clean Air Act Amendments  (CAAA)  requires  States to
adopt  operating  permit  programs to  be administered  by State  or  local  air
pollution control  agencies.  The programs are to issue operating permits to major
stationary sources of criteria and hazardous air pollutants, sources covered by
new source performance standards  (NSPS), sources  covered by national emission
standards for hazardous air pollutants (NESHAP), sources regulated under the acid
rain program  (Title IV Acid  Deposition Control)  and  the  stratospheric ozone
program (Title VI Stratospheric Ozone Protection), and  sources  covered by State
implementation plans.

      The permits  must meet several requirements.   They must contain  all  the
applicable pollution control  obligations of a  source such  as those imposed by
State implementation plans and NSPS under the  authority of Title  I of the CAAA,
under  the  air toxics program  of Title III of  the  CAAA, under  the  acid rain
program of Title  IV of the CAAA, or  under other  applicable provisions of the
CAAA.   As necessary,  the operating  permits  are  to establish maximum source
operating  rates,  maximum  pollutant emission  rates and/or  pollutant  control
methods,  and  methods for determining  compliance  with  the  emission  limits or
control methods.

       Emissions from many sources of particulate matter (PM)  are regulated under
the above titles of the CAAA including State implementation  plans for particles
with an aerodynamic diameter less than  or equal to a nominal  10 microns (PM,0).
Therefore, operating permits will be required  for  several categories  of sources
that emit PM.  The processes and operations for calciners and dryers used  in the
mineral industries which cause  PM emissions are discussed in this document, and
an operating permit for this source category is presented as a model that may be
used  in implementing  a  permit  program.   This model  permit  covers only the
particulate  matter aspects of  this source category;  it does not  cover other
pollutants for which the  source may be  regulated.
CH-91-16u                               1-1

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                           2.0   SOURCES  OF  EMISSIONS

2.1  GENERAL

      The source  category for  mineral  dryers  and calciners  includes  process
equipment used to  dry and  calcine seventeen types of minerals,  as shown in Table
2-1.'   Drying is the  removal of uncombined  (free)  water from mineral  material
through direct or indirect heating, while calcining is the removal of combined
(chemically  bound)  water  and/or  gases  through direct  or  indirect  heating.
Processing plants for these mineral  industries  are located domestically in 43
States and in the  Virgin Islands.  Several of the mineral processes are composed
of a large number  of individual  facilities  located  in many States, while others
are limited  to relatively few plants  located   near  natural  deposits  of the
minerals  being  processed.  The mineral  industries considered in  this  source
category use a wide  variety of processing equipment for the  drying and calcining
of raw materials.

2.2  DRYERS

      Dryers are used by the mineral  industries  to  remove uncombined water from
mineral materials.   In  general, dryers use  either a  convection  (direct)  or  a
conduction (indirect) method  of drying.   In the convection  method,  a heating
medium, usually air or  combustion  products,  is  in direct contact with the wet
material.  In  the conduction  method,  heat  is transmitted indirectly through  a
heated surface which  directly contacts the wet material.2

      Rotary  dryers are  the  most  frequently used dryer type in  the mineral
industries.  A rotary dryer consists of a cylindrical shell, ranging in length
from 4 to 10  times its diameter, into which  wet charge  is fed at one end and from
which dried product is discharged at the other end.  Material is moved through
the dryer by the combined  effects of horizontal  shell  inclination  and the action
of lifting flights within the shell.   As the  shell  rotates, the lifting flights
pick up the material and shower  it as a curtain in the path of hot  gases.  Direct
rotary dryers are used when the  materials to be dried  can be safely brought into
contact with  heated air or combustion gases and when volatile,  flammable, or
noxious components  are  entirely absent  or  present only in small  amounts.  The
drying medium, heated air  or combustion gas, is fed into  the dryer at one  end and
is  drawn  out the  other end, coming  into contact with the mineral as it  flows
through the dryer.   The gases may move  either concurrently or countercurrently
with the  movement of the  process material.2

CH-91-16U                               2-1

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                             TABLE 2-1.   TYPES OF DRYERS  AND CALCINERS USED BY INDUSTRY*
no
I
ro
Mineral Type
Alumina
Ball clay
Bentonite
Diatomite
Feldspar
Fire clay
Fuller's earth
Gypsum
Industrial sand
Kaolin
Lightweight
aggregate
Magnesium
compounds
Perlite
Roofing granules
Talc
Titanium dioxide
Vermiculite

Rotary Rotary
direct Indirect

X
X
X
X
X
X
X
X
X




X
X
X
X X
X
Dryers
Fluid Vibrating Flash Spray
bed grate

X
X
X
X
X
X

X
X





X
X
X XX
X

Rotary Flash
X X


X

X
X
X

X X
X

X



X
X

Calciners
Hearth Kettle Expansion
furnace furnace







X

X


X

X



X
    "Reference 1.

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      Fluid bed dryers are also commonly used by the mineral industries.  In a
typical fluidized bed dryer, wet feed material is charged in  batch or continuous
mode to  the  dryer above the  bed.   The wet  feed bed expands due  to  the high
velocity of the hot gas stream rising from beneath the bed of  particulate solids.
The solid particles  become  suspended, thus creating a fluidized bed.  In a fluid
bed dryer, efficient  mixing of the solid  particles results  in uniform drying.
Thus, the  gas  stream velocity is  controlled to yield  optimum  conditions for
drying with regard to particle size and density.  Product discharge rate and gas
temperature are also monitored to obtain the desired product moisture  content.2
Dried product is removed near the base  of  the vessel.  Gas is exhausted through
the top of the dryer  to a control device.
      Other dryer types used in the mineral  industries include indirect rotary,
flash,  spray,  and vibrating  grate.   Indirect  rotary  dryers are  used  if the
process material  cannot be  exposed to combustion gases,  if excessive dust carry-
over  may occur  through  entrainment,   if  low-cost  steam is available,  or if
volatile  components  desirable for  recovery  are present.2   Flash  dryers are
designed to dry  material and  convey it  by a stream of hot gases from the feed
point  to a  point of delivery.2   Separation  of  the  dried product  from the
conveying air usually takes place in a cyclone,  followed by further separation
in other cyclones or baghouses.   Spray  dryers are used to dry liquids, slurries
and  pastes.    Vibrating-grate  dryers   are   suitable  for free-flowing  solids
containing mostly surface moisture.  They are not effective on fibrous materials
that form a mat,  or  on sticky solids that agglomerate or adhere to the deck.

2.3  CALCINERS

      Calciners  are  designed  to remove the majority of combined  moisture in the
process  material  and are  operated at  higher temperatures than the dryers.  In
general,  a calciner has  up  to  four zones  of  heating,  each of  which has  a
different heat transfer rate.  These include a feed drying zone,  a  heating zone
where charge is heated to the reaction temperature,  a reaction zone where  process
material is reacted and  bound  moisture is removed, and the soaking zone  (wet-feed
calciners only)  where reacted charge is super-heated or "soaked" at the  desired
temperature or cooled before discharge.3  Rotary and flash calciners are the most
common  types of  calciners  used in the mineral  industries.

      A rotary calciner consists of a cylindrical  shell into which wet  charge
(wet feed) or predried (dry feed) material  is fed at the elevated end by  various
methods including  chutes,  overhung  screw  conveyors,  and  slurry  pipes.    The
material  is heated, reacted and  super-heated.   The primary  source of  heat
transfer in  rotary  calciners is  radiation from  the refractory  to  the material
bed.   Since  most rotary calciners  have  countercurrent  air and material  flow to

CH-91-16U                               2-3

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achieve the most energy efficient reduction  in moisture content, secondary heat
transfer occurs  by convection from  the hot gas  to the exposed  material  bed
surface.3   Natural gas,  oil,  or  pulverized coal  may  be used as  fuel  for the
heating source.  The calcined product is discharged at  the other end into quench
tanks, conveyors, or cooling devices.

      Flash calciners  are  similar to flash dryers  in  principle  and operation
except that flash calciners operate at higher temperatures.  Both multi-stage and
direct contact flash calciners are used in  the  mineral  industries.   A typical
flash calcining unit consists of a two-stage  cyclone, a  preheater, a venturi-type
flash dryer, the calciner, a multi-stage cyclone cooler, and a secondary fluid
bed cooler.  Partly calcined material formed in  the  cylindrical heating zone of
the calciner  is  discharged into  the reactor just above the fuel  inlet.   The
calcined material is retained for a few seconds and is then separated from hot
gases  in the  separation cyclone, prior to  being discharged into  the primary
cooler.  Natural gas and distillate fuel oil are the primary heating fuels used
in flash calciner installations.

      Other calciner types used in the mineral industries include multiple hearth
furnaces,  kettle calciners,  and  expansion  furnaces.  Multiple hearth furnaces
handle granular  material  and provide a long countercurrent  path  between flue
gases and  process material.  Kettle calciners are constructed from cylindrical
metal shells, which are set in masonry  brick and surrounded by a steel jacket.
Although some kettle calciners are designed to operate in only a batch mode, most
kettle calciners can be operated  in either batch or continuous modes.  Expansion
furnaces are  used  to  process ore that  "expand" up  to  20 times  their original
volume when exposed to high temperatures.

      Particulate  matter  emissions  from   drying  and  calcining  result  from
entrainment of dust and fly ash particles in the gas stream passing through the
equipment,  with subsequent carryover  to the  exhaust system. The variables that
affect emissions from calciners  include the gas velocity through the unit; the
characteristics  of the feed material; and the fuel  type.1
CH-91-16u                               2-4

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2.4  REFERENCES

 1.   U.S. Environmental  Protection  Agency.   Calciners  and  Dryers in Mineral
      Industries - Background Information for Proposed Standards.  EPA-450/3-85-
      025a.  Office  of Air Quality Planning  and  Standard,   Research Triangle
      Park, NC, October 1985.

2.    Williams-Gardner,  A.   Industrial  Drying.    Gulf Publishing  Company,
      Houston,  TX, 1977.

3.    Porter, H.F., G.A. Schurr,  D.F. Wells, and K.T. Semrau.  Solids Drying and
      Gas-Solid Systems.  In: Chemical  Engineers'  Handbook. 6th Edition, Perry,
      R.H., D.W. Green, and J.O. Maloney (eds.).  McGraw-Hill, New York, 1984.
CH-91-16U                               2-5

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   3.0   MODEL PERMIT FOR CALCINERS  AND  DRYERS  USED  IN THE MINERAL  INDUSTRIES
3.1  INTRODUCTION


      Section 190 of Title I of the Clean Air Act Amendments of 1990 requires the
Administrator of the U.S. Environmental Protection Agency to provide guidance to
State  and  local  agencies  on  categories  of  sources  that  contribute  to
nonattainment of the PM,0 national  ambient air quality standard.  As part of that
guidance,  Section  3.5  provides  specific  conditions that  may  be  included  in
operating permits that  would apply  to  PM]0  emission sources from calciners and
dryers used  in the mineral  industries.   These specific  conditions  should  be
considered as guides for States to use in designing their own operating permit
programs.


      Individual facilities should be permitted on a case-by-case basis, and the
emission limits included in the permit should be based on State implementation
plan (SIP) regulations applicable  in the area where the source is located.  Where
applicable, the mass and visible emission limits on an emission source and the
operating conditions  should  be  sufficiently detailed  in the  permit to allow a
clear determination of whether the source  is  or  is not  in  compliance.   At a
minimum, the permit should contain the following components:

  •   A fixed term, not to exceed five years [Section 502(b)(5)(B)];

  •   Limits   and   conditions   to  ensure  compliance   with  all   applicable
      requirements  under the  Act,  including  requirements of  the  applicable
      implementation plan [Section 504(a)];

  •   A  schedule of  compliance,  which is defined  as  a  schedule  of remedial
      measures,  including  an enforceable  sequence of  actions  or operations,
      leading to compliance with applicable requirements under the Act  [Sections
      504(a) and 501(3)];

  •   Inspection, entry, monitoring, compliance certification, recordkeeping and
      reporting  requirements to  ensure  compliance with the  permit  terms and
      conditions consistent with any monitoring regulations that EPA promulgates
      under Section 504(b)  [Section 504(c)];

  •   A  provision describing conditions  under which  any permit for a major
      source with a term of three or more years must be  reopened to incorporate
      any  new  standard or  regulation promulgated under the  Clean  Air Act
      [Section  502(b)(9)];
CH-91-16U                               3-1

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  •   Provisions under which the permit can be revised,  terminated, modified, or
      reissued for cause [Section 502(b)(5)(D)]; and

  •   Provisions  ensuring   operational  flexibility  within  a  permit  so  that
      certain  changes   can  be   made  without  a   permit   revision,   if  no
      "modification"  (as defined  in Title I  of the Act) would  occur  and the
      changes do not  exceed the emissions  allowable under the permit  (whether
      expressed as a rate or in terms of total  emissions)  provided that  a notice
      is sent to the permitting authority at  least  seven  days  in  advance of the
      change [Section 502(b)(10)].

      Examples of the following sections of a typical operating permit will be
provided in a separate document:

            Source Identification
            Findings of Fact, Conclusions of Law, Decisions
            General Conditions
            Compliance Conditions, and
            Operational Flexibility
CH-91-16U                        '       3-2

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3.2   SPECIFIC CONDITIONS

3.2.1 Example of Specific Conditions for Calciners and for Calciners and Dryers
      Installed in Series

      1.    The  permittee  shall  not  jcause  or, allow  the  [ipeHfyrijpVf||]
            processing rate to exceed [^"^p^Yfr;T|^^ayy^d^-w^^
            .      I   -   •+? * ••"• "* •.     ' *i*ff!*mW ***^ f  *  V""lri'H" f S i.  "V  4*.t*  '"*'A JJ**?^W.A W.WA* WV.*
            in  each  [cafcuwfr^wro cslcfiTer^ ^;^^r^--^1«st^1|f3[ ^-^$e|fs$j
            (maximum design  capacity  as specified in uies "permitsvappVfcatToii)T

      2.    The permittee shall determine the [spetlfyWriemf] processing rate
            daily by weight.                          s  "' ".""

      3.    The permittee  shall not cause  or allow to  be discharged into the
            atmosphere from  the outlet of any control  device for calciners and
            for calciners and dryers installed in_seriesAjnymjase^tJ)at £onta
            particulate  emissions  in  excess of [["''T""tJK^-""'*"*"'"*' - ™3™-^-
      4.    The  permittee shall not cause  or allow to  be  discharged into the
            atmosphere  from the outlet of any dry control device for calciners
            and  for calciners  and  dryers  installed  in series  any  gases that
            exhibit visible emissions  greater than [T^rifr^enf] opacity.
      5.    This  section should contain  operating parameters  for the control
            equipment  applied  at  this  emission  point  (See  Section  3.3 for
            example  operating  parameters).

3.2.2 Example of  Specific Conditions for  Dryers

      1.    The  permittee  shall  not %cause  or  allqw_the [^Vecify^ifpefil]
            processing rate to exceed L %  J^ffiay { " ".'."tos$/3ayH rdryVe fgKt ,
            in  each  dryer (maximum design  capacity as  specified in the permit
            application).
      2.    The permittee  shall determine the  [^ecify~4W%rat] processing rate
            daily  by  weight.

      3.    The  permittee shall not  cause  or allow to  be discharged into  the
            atmosphere from the outlet  of  a control device  for  any dryer  any
            gases  that contain particulate  emissions in excess of  ["^vv ¥-">^--~
      4.     The  permittee shall not  cause or allow to  be discharged into  the
             atmosphere from  the outlet of a dry control device for anyjdryerany
             gases  that  exhibit  visible emissions  greater  than  [^^I^i^^^ni]
             opacity.

      5.     This section should contain operating parameters  for the  control
             equipment  applied  at   this  emission  point  (See Section  3.3  for
             example operating parameters).
                                                 Note:  Specific control,  performance and reporting
                                                 information contained in thie model permit • provided solely
                                                 for akwtrative purpome and ie not intended to ectabRth
CH-91-16U                                3~3        ndmtriaj norm* or national itandanh.

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3.3   CONTROL  EQUIPMENT OPERATING PARAMETERS
      The parameters  listed in this section are provided  as  examples of typical
      control  equipment operating  conditions that  should be specified.   There
      may be other important parameters  not listed below.1
3.3.1 Fabric Filter Operating Parameters
      Air/Cloth  Ratio:  	
      Pressure  Drop Across Baghouse:  	 in.  H20  (MIN)    	 in. H20 (MAX)
      Inlet Air Temperature:  	(MIN)    	(MAX)
      Outlet  Air Temperature:  	(MIN)    	(MAX)
      Inlet Air Flow Rate:    	
3.3.2 Electrostatic Preclpitator Operating  Parameters
      Pressure  Drop:	
      Inlet Air Temperature:  	(MIN)    	(MAX)
      Outlet  Air Temperature:          (MIN)    	(MAX)
      Gas  Velocity through (ESP):  	 ft/sec
      Conditioning Agent Additions:   	gr/ft3
      Voltage and Current Readings for  each Transformer-Rectifier (T-R) Set:
                               Example:     first 3 fields - 3 at  50 KVA
                                            (55 kVp,  35 kV8V,  500 mA)
                                            last 2 fields - 4  at 64 KVA
                                            (70 kVp,  45 kVw,  500 mA)
3.3.3 Mechanical Collectors Operating Parameters
       Gas Flow Rate:  	 ft3/nrin
       Pressure Drop:  	 in. H20 (MIN)   	 in.  H20  (MAX)
       Inlet  Velocity:  	 ft/sec
       Inlet  Air Temperature:  	(MIN)    	(MAX)
       Outlet Air Temperature:  	(MIN)   	(MAX)
3.3.4  Scrubber Operating Parameters
       Scrubbing Liquor:
        Gas Flow Rate:  	 ft3/min
        Liquor Flow Rate:  	gal/min
        Gas Pressure Drop Across  Unit:   	 in. H20 (MIN)   	  in.  H20  (MAX)
        Liquid Pressure Drop Across Unit:  	 psi.(MIN)    	 psi (MIN).
        Inlet Air Temperature:  	(MIN)   	(MAX)
        Outlet Air Temperature:   	(MIN)   	(MAX)
        Solids Content of Recirculated  Scrubber Water: 	gr/gal
                                                  Note:  Specific  control,  performance  and reporting
                                                  information contained in thi> modal permit ia provided toMy
                                                  for iouatrativa purpoaaa and • not intended to evtabfoh
CH-91-16U                                 3-4        hdurtrial noima or national (tandardt.

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3.4    MONITORING REQUIREMENTS

       1.   The  permittee shall install,  calibrate,  maintain, and continuously
            operate for each dryer and  calciner that uses a fabric filter or a
            dry  ESP control device, a continuous monitoring system to measure
            and  record the opacity of emissions discharged into the  atmosphere
            from the control device.  The continuous monitoring device  shall
            be calibrated on a semiannual  basis; or

       2.   If the facility employs a dry control device together with  a
            gypsum flash or kettle calciner or a perlite rotary dryer or
            expansion furnace, the permittee may, in lieu of a continuous
            opacity monitoring system,  observe and record three six-minute
            averages of the opacity of  visible emissions from the control
            device, once per week of operation.

       3.   When a wet scrubber is used to control particulate emissions, the
            permittee shall install, calibrate, maintain, and operate
            monitoring devices that continuously measure and record  the
            pressure loss of the gas stream through the scrubber and the
            scrubbing liquid flow rate.   The pressure_loss..jpjjtorijj3 device
            shall be accurate to within plus/minus [^"^'tepiCliefgrl
            i rr^flncBeV)"wat¥r,^asig^].   The 1 iquid ^Tbw*""ritT"inonft^ring
            device shall be accurate to within plus or minus [^^"fHffCfrt£] of
            the  design scrubbing liquid flow rate.  Both monitorTrig  devices
            shall be calibrated on a semiannual basis.
                                                  Note:  Specific  control, performance  and reporting
                                                  information contained in thfe model permit » provided tolery
                                                  for JhjrtratJve purpoeee and " not intended to artafaish
CH-91-16U                                3-5        industrial norm* or national ttandard*.

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3.5    TESTING REQUIREMENTS

Section  504(b) of the Clean Air Act,  as  amended, requires  procedures and
methods  for  determining compliance  and for monitoring and  analyzing pollutants
regulated  under the Act.  An example  of  testing requirements  that should be
included in  the permit is provided  below.

       1.    The permittee shall perform  a  compliance test  for each emission
             point from a stack or vent within 60 days of achieving the maximum
             production rate at the  facility, but no later  than 180 days after
             the initial start-up, and annually thereafter.  EPA Reference
             Method 5 shall be used  to perform each compliance test on each
             emission point from a stack.  The s^ampljjig time and sample volume
             for each run shall be at  least [ ^Tho'urs] and [   - '3-J      t IIIJl.l.^Z.T.T.jE.
             {"\.d$cf}], respectively.   Emissions testing  shaTT be
             •* .......... <**.~..tm.p* '    '    .  .         Jvt^-.fVmv. ,. ,•.•.•. v^s   >  . |       . . .   .
             accomplished at a minimum of [^ j^r^epi] of  the permitted
             c|RaS.J.|l^J/ testing is  performed 'at If rate of less than
             [S7^jpifc¥ni;] of the permitted capacity, operation is restricted
             tcTthe process input rate of testing at such level until  a
             subsequent compliance test  is  performed at a minimum of
                           capacity.
        2.    EPA Reference Method  9  and the procedures  in  40 CFR 60.11 shall be
             used to determine opacity.

        3.    During the initial  performance test of a wet  scrubber, the
             permittee shall measure and record an arithmetic average of both
             the change in pressure  of the gas stream across the scrubber and
             the liquid flow rate.
             At least Q __ ^^JMlJ prior to performing a test, the owner
             or operator sR'aTT""siiBm"if"a""test plan to the  permitting authority
             that describes the  test duration, test locations,  test methods,
             source operation  and  other parameters that may affect test
             results.
                                                  Note:   Specific control, performance and repotting
                                                  information contained h this model permit ta provided tolely
                                                  for Murtrativu purpoMe and • not intended to ectabfith
CH-91-16U                                 3-6       Industrial norm* or national •tandard*.

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3.6    RECORDKEEPING REQUIREMENTS

Section  504(c)  of the Clean Air Act,  as amended, requires permits to contain
inspection,  entry, monitoring, compliance certification,  and reporting
requirements to ensure compliance  with permit terms  and conditions.  Provided
below are  examples of recordkeeping requirements.

  1.   Records  shall be maintained for five years  from the date of sample,
       measurement, report, or application;

  2.   The permittee shall maintain the following  records:

             a.     Compliance  test  reports for each affected vent;

             b.     For facilities which operate  a gypsum flash or kettle
                   calciner or a perlite rotary  dryer or expansion furnace,
                   weekly  observances of three six-minute averages of the
                   opacity of  visible emissions  to  the atmosphere from the  dry
                   control device;

             c.     Daily pressure drop readings  across control equipment  (e.g.,
                   fabric  filter,  ESP, or wet scrubber);

             d.     Daily readings  of liquid flow rate to the wet scrubber,
                   where applicable;

             e.     Daily mineral processing rate;  and

             f.     Operating  schedule.
                                                   Note:  Specific  control,  performance  and  repmtng
                                                   Information contained h thii model permit • provided toWy
                                                   for iBuetrative purpoce* and « not intended to ertahfch
 CH-91-16U                                 3-7        industrial norm or national (tandardi.

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3.7    REPORTING REQUIREMENTS

Provided below  are  examples of reporting requirements.

  1.   Records  of any  required monitoring shall be  submitted at least every
       six months and  shall clearly identify all  instances of deviations from
       the permit requirements.

             "The total  mineral processing rate, in  tons  per day, shall be
             recorded and submitted each quarter to  the permitting authority."

  2.   Deviations from permit requirements, including those attributable to
       upsets,  shall be reported promptly, and the  report shall include the
       cause of such deviations and any corrective  actions or preventive
       measures taken.  Corrective actions may include a  requirement for
       additional stack testing, or more frequent monitoring, or could trigger
       implementation  of a corrective action plan.

  3.   Exceedances  that must be reported are defined as  all six-minute periods
       during^wMdhJthj average opacity from a dry  control device is greater
       than  [^ ~ ~lif^£|&] > or any we* scrubber pressure  drop or wet scrubber
       liquid"Trow"jrat¥%that deviates more than plus or  minus [,,,m,,"pferffiBi]
       and [   Jjefceal], respectively, from the  average value recoTdeOuring
       initiaTTpe'rfol'ma'nce testing as specified in  Section 3.5.4.3.

  4.   Definitions  of  deviations that trigger additional reporting
       requirements should be as specific as possible.

             "If the mineral processing rate exceeds the  allowable rate as
             specified  in this permit, the permit  holder  shall immediately
             notify  the permitting authority and shall submit all records
             specified  under the Monitoring. Recordkeepinq and Reporting
             subsections above within two days."

  5.   The permittee shall send $.w.9. C.P.P).?.S. °.f all reports required above to
       the [|>sriifg&i"pt^^
  6.   Any  document (including reports) required  to be submitted by this
       permit  shall be certified as being true, accurate, and complete by  a
       responsible corporate official.
                                                  Note:   Specific control, performance and reporting
                                                  Information contained in this modal permit '• provided soWy
                                                  for iduetrativa purposes and '• not intended to establish
CH-91-16U                                3-8        industrial norm, or national standards.

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3.8  REFERENCES
       U.S. Environmental Protection Agency.  Technical Assistance Document:
       Recommended Recordkeeping Systems for air Pollution Control Equipment
       Part 1.  Particulate Hatter Controls.  EPA-340/1-86-021.  Stationary
       Source Compliance Division.  Washington, DC.  August 1987.
 CH-91-16U                               3-9

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