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1 Facility Name: PyraMax Ceramics, LLC City: Wrens County: Jefferson AIRS #: Application #: TV Date Application Received: August 20, 2014 Date Application Deemed Administratively Complete: August 20, 2014 Date of Draft Permit: Permit No: V-02-0 Program Review Engineers Review Managers SSPP Claudette Ayanaba Hamid Yavari ISMP Dan McCain Dave Sheffield SSCP Fred Francis Farhana Yasmin Toxics n/a n/a Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70 operating permit. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Georgia Air Quality Act, O.C.G.A , et seq. and (2) Georgia Rules for Air Quality Control, Chapter , and (3) Title V of the Clean Air Act Amendments of Section (10) of the Georgia Rules for Air Quality Control incorporates requirements of Part 70 of Chapter I of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal Clean Air Act. The primary purpose of this permit is to consolidate and identify existing state and federal air requirements applicable to PyraMax Ceramics, LLC and to provide practical methods for determining compliance with these requirements. The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. It initially describes the facility receiving the permit, the applicable requirements and their significance, and the methods for determining compliance with those applicable requirements. This narrative is intended as an adjunct for the reviewer and to provide information only. It has no legal standing. Any revisions made to the permit in response to comments received during the public participation and EPA review process will be described in an addendum to this narrative. Printed: February 17, 2016 Page 1 of 26

2 I. Facility Description A. Facility Identification 1. Facility Name: PyraMax Ceramics, LLC 2. Parent/Holding Company Name PyraMax Ceramics, LLC 3. Previous and/or Other Name(s) None applicable. 4. Facility Location 1300 Commerce Connector Wrens, Georgia Attainment or Non-attainment Area Location B. Site Determination The facility is located in an attainment area. There are no other facilities which could possibly be contiguous or adjacent and under common control. C. Existing Permits Table 1: List of Current Permits as Amended Permit Number and/or Purpose of Issuance Date of Issuance and Date of Amendments (if any) P-01-0 January 27, P-01-1 February 11, 2013 Comments Yes No P-01-2 August 21, 2014 Table 2: Comments on Specific Permits Permit Number Comments P-01-0 PSD Construction permit for construction of Lines 1 and P-01-1 PSD Construction permit for construction of Lines 3 and P-01-2 Approve extension of Title V application submittal deadline for Lines 3 and 4. Printed: February 17, 2016 Page 2 of 26

3 D. Process Description 1. SIC Codes(s) Description of Product(s) PyraMax Ceramics, LLC manufactures ceramic proppants. 3. Overall Facility Process Description This ceramic proppant manufacturing facility is capable of processing 1,270,000 tons per year of clay slurry (mixture of water, grit and additives). The facility will consist of four identical process/kiln lines which can be operated independently. As of the date of issuance of this permit, Lines 1 and 2 are operational and Lines 3 and 4 are scheduled for construction. The manufacturing processes along the process/kiln lines are described briefly below: Raw Material Handling The facility will receive locally mined raw clay as feedstock via trucks to any of twelve (12) covered bays for Lines1 and 2. Twelve additional covered bays are planned to be constructed for Lines 3 and 4. Expected emissions from this operation are particulate matter (PM), particulate matter less than 10 microns in diameter (PM 10 ) and particulate matter less than 2.5 microns in diameter (PM 2.5 ) as fugitive clay particles scattering from the working area. However, due to the high moisture content of the clay (approximately 20 percent by weight [wt%]), emissions from raw material handling are presumed to be negligible. Feedstock/Slurry Preparation The raw feedstock materials are moved from the storage bays to the feeder by a front-end loader. The feeder transfers the material into a round tank with a mixer via a partially covered conveyor. The purpose of the mix tank is for the conversion of feedstock clay into a stable suspended mixture by mixing clay with water and a small amount of dispersant. The material is agitated and then ph balanced using aqueous ammonia. The mixture is then stored in open top storage tanks under constant agitation to keep the mixture suspended. Recycled slurry and dust are reclaimed into the system, and mixed with a small amount of dispersant and process water. The material is then agitated and aqueous ammonia is added to balance ph. The recycled slurry is then fed into the open top storage tank with the raw material mixture. Some screening of the wet material with a wet screen is completed. The mixture is then pumped to the three spray fluidizer zones. Expected emissions from this process include VOC (impurities in the additive), PM, PM 10 and PM 2.5. Similar to raw material handling, the emissions will be insignificant because only wet materials and materials with high moisture content are involved in the operation. Printed: February 17, 2016 Page 3 of 26

4 Pelletization/Spray Drying Pelletization occurs in the pelletization process. As coated green pellets dry, additional layers are added until the desired bead size is achieved. Pelletizers are heated by burning natural gas (propane as backup fuel) air heater in which the entire volume of drying air is heated to the desired temperature by means of combustion gases from the gas burner. Each of the process/kiln lines has one (1) spray dryer/pelletizer. Each spray dryer/pelletizer is heated to a desirable temperature by low NO x natural gas burners with a total heat input rate of approximately 75 MMBtu/hr. Expected emissions from this process include PM, PM 10 and PM 2.5, combustion byproducts (CO, NO x, SO 2, PM, PM 10 and PM 2.5, VOC and GHG/CO 2 ), and VOC when volatile organics in the additives are evaporated (negligible). All the emissions will be carried by spent drying air/exhaust gas through a baghouse for removal of particulate matter, and then discharged into the atmosphere via a stack. Green Pellet Screening In this process multiple-stack screens will separate green pellets conveyed from spray dryers/pelletizers according to their sizes. On-sized pellets are conveyed to calciners/kilns for further processing. Oversized pellets are diverted to a cage mill for size reduction and then re-fed to the pelletizer feed bin for reprocessing; while undersized pellets are sent directly back to the pelletizer feed bin. Only PM, PM 10 and PM 2.5 are emitted from this process, and controlled by baghouses and bin vent filters depending on the operation involved. Calcining/Sintering On-sized green pellets are conveyed to the calciner/kiln bins via conveyors and bucket elevators, and metered into the charging end of each counter flow dry-process rotary calciner/kiln where they are slowly heated, dried and then calcined/sintered, releasing moisture and other impurities in the process. The calciner/kiln rotates as heated by a low NO x burner fired by natural gas with propane as backup fuel. The burner fires directly onto the kiln feed/green pellets streaming in so that hot exhaust gases travel counter flow to the incoming green proppant pellets/beads. The capacity of the kiln burner is 65 MMBtu/hr and can heat the kiln up to 3,000 F. Each rotary kiln/calciner is closely followed by a separate rotary cooler which introduces cooling air in the discharge end of the cooler. Expected emissions from the calcination/sintering include criteria pollutants (CO, NO x, PM, PM 10 and PM 2.5, SO 2 and VOC), greenhouse gas (GHG), and hazardous air pollutants (HAPs). Majority of the HAPs emissions are hydrogen chloride (HCl) and hydrogen fluoride (HF) converted from naturally existing chlorides and fluorides contained in the clay and released at high temperature. Almost all the SO 2 emissions are from the conversion of element sulfur and sulfur compounds contained naturally in the clay, which could vary significantly among different mining sites or even geographical locations/formations with the same mining site. Most of the PM, PM 10 and PM 2.5 Printed: February 17, 2016 Page 4 of 26

5 emissions are from tumbling action of the clay pellets inside the kiln and the rest from fuel combustion. Fuel combustion generates almost all the CO and NO x emissions. Due to the use of clean fuels, particulate matter, SO 2, and VOC emissions from fuel combustion are insignificant. VOC emissions from conversion of naturally occurring carbon compounds in kiln feedstock are minimum because the clay pellets being processed contains little such compounds. Kiln and cooler exhaust gas streams carrying these emissions are routed to a catalytic baghouse for multi-pollutant control. The catalytic baghouse itself utilizes, instead of fabric filters bags, an array of rigid porous ceramic tubes to filter/capture the particulate matter. In addition, nano-sized fine particles of catalysts are impregnated across the wall of the ceramic tubes to facilitate the reduction of NO x to nitrogen (N 2 ) in the presence of appropriate reducing agents such as ammonia (NH 3 ), which is injected into the exhaust gas strategically upstream of the catalytic baghouse. Consequently, the ceramic filtration tubes will function together as a selective catalytic reactor (SCR) for NO x emission control. To reduce acid gas emissions, predominantly SO2, HCl and HF, calcium or sodium based powdery alkaline sorbents such as sodium bicarbonate (NaHCO3) are injected strategically into the kiln/cooler exhaust air upstream of the catalytic baghouse to neutralize the gaseous acids by forming sodium salts such as Na2SO4, NaCl and NaF. These powdery solids are then captured along with other particulate matters by the catalytic baghouse /ceramic filter tube system downstream. Finishing The calcined/sintered ceramic pellets/proppants are conveyed from the kiln cooler to the final product screens. On-sized pellets/proppants are transferred to quality control bins and off-sized pellets/proppant recycled back to the kiln for further processing. On-size ceramic pellets/proppants are tested for quality and those passing the testing are sent to storage silos awaiting for shipping. Dust collection will occur at transfer points pneumatically and diverted to a common baghouse. Each of the storage silos and bins is equipped with a vent filter to control particulate matter. Finished pellets/proppants are conveyed to a rail car loading spout and into railcars for delivery to customers. Dusts generated during railcar loading are controlled via pneumatic collection at transfer points and then a common baghouse. Supporting operations The proposed ceramic proppant manufacturing facility will have the following supporting operations/equipment: On-site research and development and QA/QC labs; One (1) 15,227 gallon storage tank for dispersant; One (1) 27,635 gallon storage tank for binder; Four (4) 30,000 gallon storage tanks for propane as backup fuel for all natural gasfired units; One (1) 706 gallon storage tank for the emergency generator; One (1) 469 hp diesel fired emergency generator; One (1) 115 hp diesel fired fire pump (for emergency purposes); One (1) 15,000 gallon storage tank for diesel fuel for facility equipment; and Printed: February 17, 2016 Page 5 of 26

6 Two (2) 33,000 gallon aqueous ammonia storage tanks for process ph control and control device operation. As part of Lines 3 and 4, additional supporting operations including a new emergency generator and fuel /ammonia storage tanks will be added. 4. Overall Process Flow Diagram (optional) E. Regulatory Status The facility provided a process flow diagram in their Title V permit application. 1. PSD/NSR This facility is a major PSD source because it has the potential to emit more than 250 tons per year (tpy) of particulate matter (PM), particulate matter with an aerodynamic diameter of 10 (PM 10 ), carbon monoxide (CO), and nitrogen oxides (NO x ). The facility is located in Jefferson County. Jefferson County is classified as attainment for SO 2, PM 2.5 and PM 10, NO x, CO, and VOC. An analysis was performed and PM, PM 10, CO, and NO x were found to exceed the PSD significant level threshold. Limits have been placed on specific equipment and operating procedures contained in Conditions The facility must comply with the Best Available Control Technology (BACT) limits in Condition Title V Major Source Status by Pollutant Table 3: Title V Major Source Status Pollutant Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the pollutant? Major Source Status PM PM 10 SO 2 VOC NO x CO Individual HAP Total HAPs Major Source Requesting SM Status Non-Major Source Status 3. MACT Standards The facility has the potential to emit total hazardous air pollutants (HAPs) in excess of 25 tpy and individual HAPs in excess of 10 tpy. Major HAPs emitted include hydrogen chloride (HCl) and hydrogen fluoride (HF). Printed: February 17, 2016 Page 6 of 26

7 40 CFR 63 Subpart B (Sections 112(g) and 112(j)) Due to the facility being a major source for HAPs emissions but no National Emissions Standards for Hazardous Air Pollutants (NESHAP) promulgated for that industry, the facility performed a Case-by-Case MACT according to NESHAP Subpart B. The Preliminary Determination of the original PSD Permit No P-01-0 contains these procedures. The MACT determination will be incorporated into this permit. The PSD determination included MACT limits on the proposed binder materials methanol and methyl acetate. A different liquid binder material is being used and its emissions are negligible. HF and HCl emissions will remain the same and the MACT determination for HF and HCl will not change. 40 CFR 63 Subpart ZZZZ (Reciprocating Internal Combustion Engines) The facility operates a 469 horsepower (hp) diesel-fired emergency generator and a 115 hp diesel-fired fire pump. A second emergency generator will be added with Lines 3 and 4 to make a total of two emergency generators and one fire pump. 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines is for stationary RICE with a site rating of equal to or less than 500 brake hp, located at a major source of HAP emissions, and construction commenced on the stationary RICE on or after June 12, PyraMax Ceramics new emergency stationary diesel generators with 350 kw diesel engines will only need to comply by following 40 CFR, Part 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines according to (c)(6). This provision states that if an emergency generator complies with Subpart IIII then it has fulfilled its requirements for Subpart ZZZZ. 4. Program Applicability Program Code Program Code 6 - PSD Program Code 8 Part 61 NESHAP Program Code 9 - NSPS Program Code M Part 63 NESHAP Program Code V Title V Applicable (y/n) Yes No Yes Yes Yes Printed: February 17, 2016 Page 7 of 26

8 Regulatory Analysis II. Facility Wide Requirements A. Emission and Operating Caps: On August 21, 2014, the company was issued an 18-month extension, Permit No P-2, for the construction of Lines 3 and 4. Construction has not yet commenced and therefore as a carryover, Condition requires that Lines 3 and 4 must begin construction by February 1, B. Applicable Rules and Regulations None applicable. C. Compliance Status The facility did not indicate that they were/are out of compliance with any equipment-specific applicable rules and regulations in this application. D. Operational Flexibility None applicable. E. Permit Conditions In addition to the conditions mentioned above, there are two conditions associated with facilitywide requirements, Condition which requires all equipment at the facility subject to an NSPS to follow the General Provision located in 40 CFR 60 Subpart A "General Provisions" and Condition which requires the facility to install and limit public access to the ambient air monitors. Printed: February 17, 2016 Page 8 of 26

9 III. Regulated Equipment Requirements A. Brief Process Description PyraMax Ceramics is a major source ceramic proppant manufacturing facility. Identical Lines 1-4 will consist of slurry preparation, spray dryers/pelletizers, kiln/calciners, material handling, and associated equipment. Lines 1 and 2 have been constructed and Lines 3 and 4 are scheduled for construction. B. Equipment List for the Process The original PSD permits list two 9.8 MMBtu/hr boilers in Permit No P-01-0 and a 5 MMBtu/hr boiler in Permit No P This equipment will not be constructed at the facility. The equipment and its associated conditions have been removed. Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Description Applicable Corresponding ID Requirements/Standards Permit Conditions No. Description PS1 Slurry Preparation Line (2)(p) (2)(e) 3.3.4, 3.3.5, 3.4.3, PS1 PS2 Slurry Preparation Line (2)(p) (2)(e) PS3 Slurry Preparation Line (2)(p) (2)(e) PS4 Slurry Preparation Line (2)(p) (2)(e) PEL1, SC1a PEL2, SC2a PEL3, SC3a Spray Dryer/Pelletizer No. 1(Pelletizer, Screw Conveyor) Spray Dryer/Pelletizer No. 2 (Pelletizer, Screw Conveyor) Spray Dryer/Pelletizer No. 3 (Pelletizer, Screw Conveyor) (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B 3.3.4, 3.3.5, 3.4.3, , 3.3.5, 3.4.3, 3.4.5, , 3.3.5, 3.4.3, 3.4.5, , 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , 3.4.2, 3.4.3, 3.4.4, 4.2.9, 5.2.1, 5.2.4, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , 3.4.2, 3.4.3, 3.4.4, 4.2.9, 5.2.1, 5.2.4, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , 3.4.2, 3.4.3, 3.4.4, 4.2.1, 4.2.5, 4.2.6, 4.2.9, 5.2.1, 5.2.2, 5.2.4, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , PS2 PS3 PS4 BHP1 BHP2 BHP2 Printed: February 17, 2016 Page 9 of 26

10 ID No. PEL4, SC4a Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Applicable Corresponding ID Requirements/Standards Permit Conditions No. Description Spray Dryer/Pelletizer No. BHP2 4 (Pelletizer, Screw Conveyor) (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B GPS1 Green Pellet Screen (2)(p)1 RB1 Reversing Belt Conveyor 1 KE1 Kiln Feed Elevator (2)(e) VC1 Vibratory Conveyor 1 BC1a Belt Conveyor 1 SC1b Screw Conveyor 1 FH1 Feed Hopper 1 SE1 Seed Bin Elevator 1 GPS1 Green Pellet Screen (2)(p)1 RB1 Reversing Belt Conveyor 2 KE1 Kiln Feed Elevator 2 VC1 Vibratory Conveyor 2 BC1a Belt Conveyor 2 SC1b Screw Conveyor 2 FH1 Feed Hopper SE1 Seed Bin Elevator (2)(e) GPS3 Green Pellet Screen (2)(p)1 RB3 Reversing Belt Conveyor 3 KE3 Kiln Feed Elevator (2)(e) VC3 Vibratory Conveyor 3 BC3a Belt Conveyor 3 SC3b Screw Conveyor 3 FH3 Feed Hopper 3 SE3 Seed Bin Elevator 3 GPS4 Green Pellet Screen (2)(p)1 RB4 Reversing Belt Conveyor 4 KE4 Kiln Feed Elevator 4 VC4 Vibratory Conveyor 4 BC4a Belt Conveyor 4 SC4b Screw Conveyor 4 FH4 Feed Hopper 4 SE4 Seed Bin Elevator (2)(e) FS1 Final Product Screen (2)(p) (2)(e) FS2 Final Product Screen (2)(p) (2)(e) 3.3.1, 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , 3.4.2, 3.4.3, 3.4.4, 4.2.1, 4.2.5, 4.2.6, 4.2.9, 5.2.1, 5.2.2, 5.2.4, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , , 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, , 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, , 4.2.2, 4.2.3, 4.2.4, 4.2.5, 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, 6.2.6, , 4.2.2, 4.2.3, 4.2.4, 4.2.5, 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, 6.2.6, , 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, , 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, BHG1 BHG2 BHG3 BHG4 BHF1 BHF2 Printed: February 17, 2016 Page 10 of 26

11 Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Description Applicable Corresponding ID Requirements/Standards Permit Conditions No. Description FS3 Final Product Screen (2)(p) (2)(e) 3.4.5, 4.2.2, 4.2.3, 4.2.4, 4.2.5, 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, 6.2.6, BHF3 FS4 Final Product Screen (2)(p) (2)(e) KLN1 Calciner/Kiln No. 1 KC1 Calciner/Kiln Cooler No. 1 KLN2 Calciner/Kiln No. 2 KC2 Calciner/Kiln Cooler No. 2 KLN3 KC3 Calciner/Kiln No. 3 Calciner/Kiln Cooler No (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B , 4.2.2, 4.2.3, 4.2.4, 4.2.5, 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.5, 6.2.6, , 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , , , , , , 3.4.2, 3.4.3, 3.4.4, 4.2.7, 4.2.8, 4.2.9, , , , 5.2.1, 5.2.4, 5.2.8, 5.2.9, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , , , , , , 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , , , , , , 3.4.2, 3.4.3, 3.4.4, 4.2.7, 4.2.8, 4.2.9, , , , 5.2.1, 5.2.4, 5.2.8, 5.2.9, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , , , , , , 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , , , , , , 3.4.2, 3.4.3, 3.4.4, 4.2.1, 4.2.5, 4.2.6, 4.2.7, 4.2.8, 4.2.9, , , , 5.2.1, 5.2.2, 5.2.4, 5.2.8, 5.2.9, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , , , , , , BHF4 BHK1 BHK2 BHK3 Catalytic Catalytic Catalytic Printed: February 17, 2016 Page 11 of 26

12 ID No. KLN4 KC4 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Applicable Corresponding ID Requirements/Standards Permit Conditions No. Description BHK4 Catalytic Calciner/Kiln No. 4 Calciner/Kiln Cooler No (2)(p) (2)(g) 40 CFR Part 60, Subpart UUU 112(g) case-by-case MACT/40 CFR 63, Subpart B BC1, Belt Conveyor 1 & 2 BC2 LE1, Loading Elevator LE2 WB1, Weigh Bin WB2 LS1, Loading Spout LS2 BC3, Belt Conveyor 3 & 4 BC4 LE3, Loading Elevator LE4 WB3, Weigh Bin WB4 LS3, Loading Spout LS4 S1a Unused Sorbent Silo (2)(p)1 S2a Spent Sorbent Silo (2)(p) (2)(e) (2)(p) (2)(e) (2)(e) S3a Unused Sorbent Silo (2)(p)1 S4a Spent Sorbent Silo (2)(e) FP1 Fire Pump 1 40 CFR 63, Subpart ZZZZ 40 CFR 60, Subpart IIII EG1 350 kw Emergency Generator 1 40 CFR 63, Subpart ZZZZ 40 CFR 60, Subpart IIII 3.3.1, 3.3.2, 3.3.4, 3.3.5, 3.3.6, 3.3.8, , , , , , , 3.4.2, 3.4.3, 3.4.4, 4.2.1, 4.2.5, 4.2.6, 4.2.7, 4.2.8, 4.2.9, , , , 5.2.1, 5.2.2, 5.2.4, 5.2.8, 5.2.9, , 6.1.7, 6.2.1, 6.2.3, 6.2.4, , , , , , , , 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.4, 6.2.5, , 4.2.2, 4.2.3, 4.2.4, 4.2.5, 5.2.3, 5.2.4, 5.2.7, 6.1.7, 6.2.1, 6.2.4, 6.2.5, 6.2.6, , 6.2.1, 6.2.4, 6.2.5, , 4.2.2, 4.2.3, 4.2.4, 4.2.5, 6.2.1, 6.2.5, 6.2.6, , 3.3.2, 3.3.6, 3.3.9, , , , , , , 3.4.2, 5.2.6, , 6.1.7, 6.2.1, 6.2.7, 6.2.8, 6.2.9, , , 3.3.2, 3.3.6, 3.3.9, , , , , , , 3.4.2, 5.2.6, , 6.1.7, 6.2.1, 6.2.7, 6.2.8, 6.2.9, , BHL1 BHL2 S1a S2a S1a S2a None None Bin Vent Filter Bin Vent Filter None None Printed: February 17, 2016 Page 12 of 26

13 ID No. EG2 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Applicable Corresponding ID Requirements/Standards Permit Conditions No. Description 350 kw Emergency None None Generator 1 40 CFR 63, Subpart ZZZZ 40 CFR 60, Subpart IIII 3.3.1, 3.3.2, 3.3.6, 3.3.9, , , , , , , , 3.4.2, 5.2.6, , 6.1.7, 6.2.7, 6.2.8, 6.2.9, , , C. Equipment & Rule Applicability Emission and Operating Caps Significant emissions triggered PSD/BACT review for the following pollutants: CO, GHG, NO x, PM, PM 10, PM 2.5, SO 2 and VOC. The following table summarizes the final BACT requirements from Permit Nos P-01-0 and P Table 4: BACT Requirements Operation Emission [1] Emission Limit Compliance Method Each calciner/kiln Filterable PM/PM 10 PM/PM 10 & CPM combined PM 2.5 & CPM combined [1] gr./dscf 8.53 lbs./hr 6.98 lbs./hr Methods 5 (Method 201/ 201A) Methods 5 & 202 (Method 201/201A and Method 202) Methods 5 & 202 (Method 201/201A and Method 202) Averaging Time 3 hours Each spray dryer/pelletizer Each spray dryer/ pelletizer and calciner/kiln PM/PM gr./dscf gr./dscf Methods 5 & 202 (Method 201 or 201A in conjunction with Method 202 if necessary) PM 2.5 Visible 10% opacity COMS 3 hours 6-minute average Each of the emission units with baghouse control excluding spray dryers/ pelletizers and calciners/kilns PM/PM 10 /PM 2.5 Visible gr./dscf Method 5 (Method 201/201A) 7% opacity Method 9 All fugitive sources Fugitive 10% opacity Method 22 and/or Method 9 Each calciner/kiln SO 2 NO x No less than 90% by weight overall control Not to exceed lbs/hr. No less than 80% by weight overall control Method 6 or 6C; Daily Analysis of Clay Sulfur Content Method 7 or 7E 3 hours 6-minute average Per Method 22 or Method 9 3 hours; Daily average 3 hours Printed: February 17, 2016 Page 13 of 26

14 Operation Emission [1] Emission Limit Compliance Method Not to exceed 36.3 lbs/hr. CO 33.0 lbs/hr. Method 10 Averaging Time 3 hours Each spray dryer/pelletizer Each Emergency Diesel Generator VOC CO 2 e NO x CO VOC CO 2 e CO 2 e 0.71 lbs/hr lbs/ton cooler product Not to exceed 2.25 lbs/hr. Not to exceed lbs/hr. Not to exceed lbs/hr. 44,446 tons 153 tons Method 25 or 25A Mass balance calculation based on Division-approved emission factors Method 7 or 7E Method 10 Mass balance calculation Mass balance calculation based on Division-approved emission factors Mass balance calculation based on Division-approved emission factors 3 hours 12-month rolling 3 hours 3 hours Monthly Average 12-month rolling total 12-month rolling total As previously described, MACT requirements were placed on the Calciner/Kiln to limit HCl and HF emissions. The following lists the final limits from Permit Nos P-01-0 and P Affected Source Table 5: MACT Requirements HAP Emission Limit lbs/ton of kiln feed and no less than 90% by weight reduction Averaging Time 3 hours Compliance Method Method 26 or 26A HCl Not to exceed 2.96 tons per year 12-month rolling Calculation based on annual testing result & production records Each Calciner/Kiln lbs/ton of kiln feed and no less than 90% by weight reduction 3 hours Method 26 or 26A HF Not to exceed 4.49 tons per year 12-month rolling Calculation based on annual testing result & production records Printed: February 17, 2016 Page 14 of 26

15 Applicable Rules and Regulations - Federal Rules: 40 CFR Part 60, Subpart A - General Provisions, imposes generally applicable provisions for initial notifications, initial compliance testing, monitoring, and recordkeeping requirements for equipment at the facility subject to a specific NSPS standard, as indicated by the pertinent NSPS standard. PyraMax must comply with 40 CFR, Part 60, Subpart UUU, "Standards of Performance for Calciners and Dryers in Mineral Industries." Mineral processing facilities that use calciners and dryers that were constructed, modified, or reconstructed after April 23, 1986 may not emit more than 0.04 grains/dscf for calciners and dryers in series and grains/dscf for dryers. The regulation includes a 10 % opacity limit. Calciners/Kilns, spray dryer/pelletizers for Lines 1and 2 have tested and are in compliance with Subpart UUU. Calciners/Kilns, spray dryer/pelletizers for Lines 3 and 4 will need to test within days of startup. The facility must comply with the provisions of 40 CFR 60 Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. On April 28, 2009, NSPS OOO was amended to include stricter limits. Equipment such as crushers will be limited to 12% opacity of fugitives, while screens, conveyor points, bins, and all other applicable sources will be limited to 7% fugitive visible emissions. Method 9 visible emissions testing will be required. A PM limit is set at g/dscm (0.014 gr/dscf). Special notification and record keeping is also required. Material handling equipment for Lines 1 and 2 have been tested and are in compliance with Subpart OOO. Equipment for Lines 3 and 4 will need to be tested within days of startup. The emergency stationary diesel generators are rated less than 500 brake horsepower and located at a major stationary source for HAPs emissions, therefore must comply with 40 CFR, Part 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. The Permittee is only required to submit an initial notification and a statement that the generator is for emergency use only. This permit establishes conditions to limit the use of the diesel generator to emergency situations only. Emergency generator (EG1) and fire pump (FP1) have tested and is in compliance. Emergency generator (EG2) must also test for compliance once it has started operating. State Rules: Unless there is a more stringent regulation, the facility cannot allow from each source, PM that exceeds the amounts calculated in State Rule (2)(e). According to State Rule (2)(b), visible emissions from each source cannot be equal to or greater than 40%. State Rule (2)(p) contain allowable PM emissions for facilities that process kaolin or Fuller s earth. The facility meets these requirements by employing the use of baghouses that reduce PM and visible emissions. Reasonable precautions as listed in State Rule (2)(n)1, must be taken to reduce fugitive dust. In addition, opacity from any fugitive dust source cannot equal or exceed 20%. The facility employs the use of water spray and is able to comply with these conditions. Printed: February 17, 2016 Page 15 of 26

16 D. Compliance Status The facility did not indicate that they were/are out of compliance with any equipment-specific applicable rules and regulations in this application. E. Operational Flexibility Not applicable. F. Permit Conditions General PSD Requirements BACT requirements for the facility are located in Conditions NSPS Requirements Condition is 40 CFR Subpart A General Provisions that any NSPS equipment must comply with. Condition incorporates the applicable PM and visible emission limits under NSPS Subpart OOO as amended by EPA on April 28, These emission limits apply to affected facilities constructed, modified and reconstructed on or after April 22, The condition also list process units/equipment subject to the emission limits. Condition incorporates the applicable PM and visible emission limits under NSPS Subpart UUU. These emission limits apply to spray dryers/pelletizers and calciners/kiln at this facility. Conditions 3.3.9, , and require compliance of Subpart IIII of Part 60 on the emergency generators. The generator s manufacturer is required to certify with EPA that the unit is in compliance with applicable emission limits under Subpart IIII before marketing the diesel generator/engine. The same standards and requirements also are deemed as BACT for all the emergency stationary diesel generators. A description of facility compliance for NSPS OOO, UUU, and IIII can be found under the previous section, Federal Rules. Condition specifies the numerical BACT limit, compliance method, and averaging time for emissions of PM, PM 10, PM 2.5 from each calciner/kiln, spray dryer/pelletizer, each emission unit with baghouse control; visible emissions from each spray dryer/pelletizer and calciner/kiln, each emission unit with baghouse control, and all fugitive sources; SO 2 emissions from each calciner/spray dryer; NO x emissions from each calciner/kiln, and spray dryer/pelletizer; CO emissions from each calciner/kiln; spray dryer/pelletizer; and VOC emissions from each spray dryer/pelletizer. The facility is in compliance and the compliance description can be found under the section for Testing Requirements. To ensure performance of the catalytic baghouses functioning as a SCR for controlling NO x emissions from calciners/kilns, Conditions and establish the temperature range and ammonia usage rate for normal operation of the catalytic baghouses. The working temperature range in Condition prevents the SCR temperature from dropping below that established Printed: February 17, 2016 Page 16 of 26

17 during the most recent EPD-approved performance test so that the NO x control efficiency could be maintained at no less than the BACT level. The upper limit of the SCR working temperature range, as specified by the manufacture, would presumably prevent the nano catalysts embedded in ceramic filters from heat damage. Condition ensures the maintenance of the proper molar ratio between ammonia and NO x, and prevents control efficiency from falling below the BACT level due to ammonia underdosage, or ammonia slip due to ammonia over-dosage. A set-point to achieve 87% NOx reduction was found to be sufficient for the hand held monitor in order to stay within the safe range. In a letter dated February 26, 2015, PyraMax requested that Condition require a parameter range set by the ammonia set-point on the inlet of the NOx ppm monitor to the Tri-Mer catalytic baghouse system. Therefore instead of setting a range for the ammonia injection rate, the testing will establish a range for the NOx ppm monitor set-point. An excursion is considered any threehour block that falls outside of 5% of the set-point. The facility must retest Lines 1 and 2 in order to set the parameter ranges and ensure compliance with BACT limits. Testing must repeat in order to set the temperature operating range for the Calciner/Kiln 1 and 2 in Condition The facility would like to lower the minimum temperature required. The facility will retest in order to set the temperature range. To maintain the SO 2 control efficiency of each catalytic baghouse at the BACT level, Condition requires PyraMax Ceramics to maintain the injection rate of sodium bicarbonate to the catalytic baghouses at a level that would allow the molar ratio between sodium bicarbonate and SO 2 to remain at or greater than the level established during the most recent EPD-approved performance test. SO 2 emissions testing is required annually by Condition and therefore the facility will utilize the most current injection rate. Condition incorporates the fuel standards under NSPS Subpart IIII which are applicable to each of the 350 kw stationary emergency diesel generators as BACT for SO 2 emissions. Condition specifies the annual operating limit for each stationary emergency diesel generator. The emergency generator (EG1) complies with Subpart IIII and (EG2) will need to be in compliance. NESHAP and Case-By-Case MACT Conditions Conditions and establish the case-by-case MACT emission standards under Section 112(g) of CAA Amendment of 1990 for HCl and HF from calciners/kilns. Dry scrubbing via the catalytic baghouses is deemed case-by-case MACT for the HCl and HF from calciners/kilns. MACT emission standards for methanol emissions were removed from the table since the facility will no longer use the originally planned additives, methanol and methyl acetate. Lines 1 and 2 are in compliance with these provisions and Lines 3 and 4 will need to comply once they are online. Because the facility is a major source for HAP emission, Condition incorporates the applicable operating requirements/limitations for all the stationary emergency diesel generators subject to 40 CFR Part 63, Subpart ZZZZ, i.e., the NESHAP MACT standard for stationary reciprocating internal combustion engines. Emergency Generator (EG1) and future Emergency Printed: February 17, 2016 Page 17 of 26

18 Generator (EG2) remain emergency status and will only need to comply with this section of the rule. To allow each of the stationary diesel generators in the generator sets to retain the status of an emergency unit under SIP regulation, Condition limits the accumulated annual operating time for each generator/engine to no more than 500 hours per year. Original Condition of Permit No P-01-0 and Amendment Permit No P-01-1, applies to stationary generator/engine (EG2) for notification of start-up. Originally the facility was to be permitted for a 9.8 MMBtu boiler. PyraMax will not install the boiler because a heat exchanger unit has been installed and will be sufficient for the needs of the plant. Therefore original Conditions and of Permit No P-01-0 will not be needed and will be removed. Calciners/Kilns 3 and 4 have not established operating parameters and therefore must comply with Conditions once they are fully operational. Equipment SIP Rule Standards Condition incorporate measures for minimizing fugitive emissions under Georgia Rule (n). The Permittee shall make efforts to implement the measures which are considered feasible. State Rules (g), (p), (b), and (e) are contained in Conditions 3.4.2, 3.4.3, 3.4.4, and 3.4.5, respectively. A description of facility compliance measures can be found under section, State Rules. Printed: February 17, 2016 Page 18 of 26

19 IV. Testing Requirements (with Associated Record Keeping and Reporting) A. General Testing Requirements There are no exceptions to the General Testing Requirements located in Section 4.1. B. Specific Testing Requirements The following Conditions , are performance test requirements that were conducted on Lines 1 and 2. The tests need to be conducted on Lines 3 and 4, once operation begins, and therefore some of these conditions will remain in the permit. Condition No. Completion Date Regulatory Requirement Condition March 2014 & April 2014 NSPS UUU Condition 4.2.2, & March 2014 & May 2014 NSPS OOO Condition & March 2014 & May 2014 BACT, MACT, SIP Condition of PSD Permit No P-01-0 has been removed because a 30-day notice is the standard requirement. After initial performance tests were done, repeat testing on the calciners/kilns must be done annually as written in Conditions of the current permit. Repeat annual testing is required for the following pollutants; HF, HCl, CO, PM, NO x, and SO 2. Condition and outline the parameters that must be measured during the performance tests. During performance tests the following must be determined; ammonia set-point on the inlet of the NOx monitor, sorbent injection rate, inlet temperature, pollutant control efficiencies, and molar ratio between sorbent and SO 2. Printed: February 17, 2016 Page 19 of 26

20 V. Monitoring Requirements (with Associated Record Keeping and Reporting) A. General Monitoring Requirements Condition contains general requirements for the operation of continuous monitoring system. B. Specific Monitoring Requirements The COMS monitoring requirements in Condition is incorporated from NSPS Subpart UUU, and therefore spray dryers/pelletizers and calciners/kilns, i.e., the two main PM emission sources at the facility, will comply with the 10% opacity limit. To prevent thermal damage to the fabric filtration bags, Condition requires continuous monitoring of inlet temperature or surrogate temperature for baghouses working at elevated temperature. These have been installed on Lines 1 and 2 and need to be installed on Lines 3 and 4 when they become operational. Conditions and establish daily visible emission (VE) check requirements for point/stack sources with visible emissions and for sources with fugitive emissions. Representing a BACT requirement, Condition is more stringent than the similar VE daily check condition in SIP standard condition vault. To ensure proper function of the baghouses and thus minimize emissions, Condition requires the Permittee to perform routine operation and maintenance check according a Preventive Maintenance Program approved by EPD. Condition establishes the monitoring requirements under NSPS Subpart IIII for using a nonresettable hour meter to track the number of hours operated for each of the stationary emergency diesel generators during any type of operation. This condition allows for the diesel generators to remain as emergency units and therefore exempt from certain regulations. Condition requires quarterly Method 22 visible emission inspections on affected facilities that use baghouse to control PM emissions. This is a new monitoring requirement under 40 CFR Part 60, Subpart OOO as amended on April 28, When the quarterly 30-minute visible emissions inspection has been conducted on any affected baghouse during the day, no daily VE check on the same baghouse is necessary for that day. Condition establishes detailed procedures for routine monitoring of the NOx emissions from each calciner/kiln using a portable NOx analyzer. The NOx emission data from the monitoring will be used to determine the ammonia injection rates to the catalytic baghouses until the next monitoring event. The flow monitor specified in Condition would provide instant exhaust flow rate data required in the NOx emission determination specified in Condition Condition requires the Permittee to monitor and record specified operating parameters and production data to ensure and demonstrate emission compliance. Lines 1 and 2 have already performed an initial measurement and must continue to perform weekly measurements. Lines 3 and 4 shall conduct weekly measurements after an initial measurement is conducted within 60 days of startup. Printed: February 17, 2016 Page 20 of 26

21 Additional quality assurance practices were added in Conditions These periodic calibration and maintenance checks will be added to make sure that the data used to calculate the injection rate for the set point chosen during the test approved in Condition is verified. Printed: February 17, 2016 Page 21 of 26

22 VI. Other Record Keeping and Reporting Requirements A. General Record Keeping and Reporting Requirements Conditions through respectively contain general requirements for the record keeping type and duration, reporting of deviations, excess emissions, exceedances, or excursions, quarterly report, sampling records, and record keeping of measurements for monitoring systems (monitoring, calibration, adjustment and maintenance) and performance testing. Condition incorporates the applicable reporting requirements for excess emissions, exceedances, excursions or additional information to be included in the PSD/BACT quarterly reports required by Condition Requirements concerning methane emissions and boiler limits have been removed. B. Specific Record Keeping and Reporting Requirements Condition incorporates the applicable notification requirements under NSPS Subpart OOO. These requirements establish time frames for milestones such as record keeping, reporting, performance testing, maintenance and emission/compliance calculation. Condition ensures the compliance with the fugitive emission limits and minimization of such emissions. Condition asks the facility to keep records of any materials containing VOCs. Since methanol will no longer be used at the facility, Conditions and originally established the record keeping, emission calculation/compliance demonstration and reporting requirements for compliance with the case-by-case MACT emission limits were removed. Original Condition now Condition 6.2.4, establishes the applicable record keeping, emission calculation/compliance demonstration and reporting requirements for compliance with the BACT VOC emission limit. Condition contains the requirements for submitting testing results as specified by NSPS Subpart OOO. Condition specifies how to submit the written notification of the actual date of initial startup of each affected facility/source in case of new construction or modification. Conditions through establish the applicable record keeping, compliance demonstration, notification and reporting requirement necessary for demonstrating compliance with the operating and fuel usage limitations under NSPS Subpart IIII for the emergency diesel generators. Conditions , and establish detailed requirements and procedures showing how to determine daily SO 2 emission rate and the current injection rate for sodium bicarbonate and ammonia. The current injection rate could maintain respectively the NaHCO 3 /SO 2 and NH 3 /NO x molar ratio thus the SO 2 and NO x control efficiency at the level established during the most recent Division-approved performance test(s). Printed: February 17, 2016 Page 22 of 26

23 Conditions and establish the record keeping, emission calculation/compliance demonstration and reporting requirements for compliance with the case-by-case MACT emission limits for emissions of HCl and HF. Condition ensures the reduction of fugitive emissions and compliance with the BACT requirements by requiring relevant operating records. The facility must also comply with CO 2e BACT limits by calculating emissions according to Condition Printed: February 17, 2016 Page 23 of 26

24 VII. Specific Requirements A. Operational Flexibility Not applicable. B. Alternative Requirements Not applicable. C. Insignificant Activities Refer to for the Online Title V Application. Refer to the following forms in the Title V permit application: Form D.1 (Insignificant Activities Checklist) Form D.2 (Generic Emissions Groups) Form D.3 (Generic Fuel Burning Equipment) Form D.6 (Insignificant Activities Based on Emission Levels of the Title V permit application) D. Temporary Sources Not applicable. E. Short-Term Activities Not applicable. F. Compliance Schedule/Progress Reports Not applicable. G. Emissions Trading Not applicable. H. Acid Rain Requirements Not applicable. I. Prevention of Accidental Releases Not applicable. J. Stratospheric Ozone Protection Requirements Printed: February 17, 2016 Page 24 of 26

25 Not applicable. K. Pollution Prevention Not applicable. L. Specific Conditions Within six (6) months Lines 3 and 4 must commence construction and within 12 months of commencing operation, Lines 3 and 4 must apply for a Title V operating permit. Printed: February 17, 2016 Page 25 of 26

26 VIII. General Provisions Generic provisions have been included in this permit to address the requirements in 40 CFR Part 70 that apply to all Title V sources, and the requirements in Chapter of the Georgia Rules for Air Quality Control that apply to all stationary sources of air pollution. Printed: February 17, 2016 Page 26 of 26

27 Addendum to Narrative The 30-day public review started on August 20, 2015 and ended on September 21, No comments were received from EPA or the public. Written comments were received from PyraMax Ceramics, LLC on September 23, Comments 1 6 (Facility Comments 1-6 on the narrative) suggest changes to the language in the Narrative. Comments 7-28 (Facility Comments 1-63 on the permit) suggest changes to the language in the Permit. Comments are consolidated where like changes are requested or related changes that focus on a single rule. New text is underlined (underlined) and removed text is highlighted using strikethrough (strikethrough). The facility s comments and the Division s responses are summarized below. Narrative Comments: Note: The Division does not change the Narrative due to comments received during the Public Notice period. Rather, the changes to the Narrative are appended to the end of the Narrative, along with the changes to the draft permit. Comment 1 Section I.A.2. (page 2) Change Parent/Holding Company Name from PyraMax Ceramics, LLC to Imerys USA. Response: The Division agrees with PyraMax s comment. Comment 2 Section I.D.3. Overall Facility Process Description (page 3) Please see comments in the draft permit with requested changes to the overall facility process description that PyraMax is requesting to be incorporated here. Response: The Division notes PyraMax s proposed changes. Please refer to Comment 8. Comment 3 Section II.E. Permit Conditions (page 8) In addition to the conditions mentioned above, there are two conditions associated with facility-wide requirements, Condition which requires all equipment at the facility subject to an NSPS to follow the General Provision located in 40 CFR 60 Subpart A "General Provisions" and Condition which requires the facility to install and limit public access to the ambient air monitors. Request removal of Condition as it is redundant to Condition Response: The Division agrees with PyraMax s comment. Comment 4 Section III.B. Equipment List for the Process (page 9) Printed: February 17, 2016 Addendum Page 1 of 18