class i air quality operating permit to construct · pf1.005 bucker elevator (31a-be01) and...

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Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT Issued to: EP MINERALS, LLC COLADO PLANT (HEREINAFTER REFERRED TO AS PERMITTEE) Mailing Address: 150 COAL CANYON ROAD, LOVELOCK, NEVADA 89419 Physical Address: 9785 Gateway Dr., Reno, Nevada 89521 Driving Directions: 6.5 MILES EAST OF LOVELOCK General Facility Location: SECTION 33, T 28 N, R 32 E, MDB&M HA 73 LOVELOCK VALLEY / PERSHING COUNTY NORTH 4,455,930 M, EAST 381,970 M, UTM ZONE 11, NAD 83 Emission Unit List: A. System 01 – Unit #1 and #2 Ore Crushing Circuit PF1.001 Unloading from Truck to Hopper (31A-HP01) PF1.002 Hopper (31A-HP01) and transfer to Pan Feed (31A-AF01) PF1.003 Pan Feed (31A-AF01) and transfer to Belt Conveyor (31A-BC01), Screw Conveyor (31A-SC01), or Ring Hammermill (31A-HC01) PF1.004 Screw Conveyor (31A-SC01) and transfer to Bucker Elevator (31A-BE01) PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket Elevator (31A-BE02) B. System 02 – Unit #1 and #2 Ore Crushing Unit PF1.007 Ring Hammermill (31A-HC01) and discharge to Bucket Elevator (31A-BE02) C. System 03 – Unit #1 and #2 Ore Crushing Unit PF1.008 Bucket Elevator (31A-BE02) and discharge to Ore Bin (31A-BI01), Ore Bin (31A-BI02), Conveyor (31A-BC02) PF1.009 Conveyor (31A-BC02) and discharge to Ore Bin (31A-BI03) and Ore Bin (31A-BI04) D. System 04 – Unit #1 Classification and Drying PF1.010 Ore Bin (31A-BI01) and discharge to Pan Feeder (311-AF01) PF1.011 Ore Bin (31A-BI02) and discharge to Pan Feeder (311-AF02) PF1.012 Pan Feeder (311-AF01) and discharge to Hopper (311-HP01) PF1.013 Pan Feeder (311-AF02) and discharge to Hopper (311-HP01) Nevada Department of Conservation and Natural Resources Division of Environmental Protection Bureau of Air Pollution Control 901 SOUTH STEWART STREET SUITE 4001 CARSON CITY, NEVADA 89701-5249 p: 775-687-9350 www.ndep.nv.gov/bapc

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Page 1: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Facility ID No. A0456 Permit No. AP1499-3768

CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP MINERALS, LLC – COLADO PLANT (HEREINAFTER REFERRED TO AS PERMITTEE) Mailing Address: 150 COAL CANYON ROAD, LOVELOCK, NEVADA 89419 Physical Address: 9785 Gateway Dr., Reno, Nevada 89521 Driving Directions: 6.5 MILES EAST OF LOVELOCK General Facility Location:

SECTION 33, T 28 N, R 32 E, MDB&M HA 73 – LOVELOCK VALLEY / PERSHING COUNTY

NORTH 4,455,930 M, EAST 381,970 M, UTM ZONE 11, NAD 83 Emission Unit List: A. System 01 – Unit #1 and #2 Ore Crushing Circuit PF1.001 Unloading from Truck to Hopper (31A-HP01) PF1.002 Hopper (31A-HP01) and transfer to Pan Feed (31A-AF01) PF1.003 Pan Feed (31A-AF01) and transfer to Belt Conveyor (31A-BC01), Screw Conveyor (31A-SC01), or Ring Hammermill

(31A-HC01) PF1.004 Screw Conveyor (31A-SC01) and transfer to Bucker Elevator (31A-BE01) PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket Elevator (31A-BE02) B. System 02 – Unit #1 and #2 Ore Crushing Unit PF1.007 Ring Hammermill (31A-HC01) and discharge to Bucket Elevator (31A-BE02) C. System 03 – Unit #1 and #2 Ore Crushing Unit PF1.008 Bucket Elevator (31A-BE02) and discharge to Ore Bin (31A-BI01), Ore Bin (31A-BI02), Conveyor (31A-BC02) PF1.009 Conveyor (31A-BC02) and discharge to Ore Bin (31A-BI03) and Ore Bin (31A-BI04) D. System 04 – Unit #1 Classification and Drying PF1.010 Ore Bin (31A-BI01) and discharge to Pan Feeder (311-AF01) PF1.011 Ore Bin (31A-BI02) and discharge to Pan Feeder (311-AF02) PF1.012 Pan Feeder (311-AF01) and discharge to Hopper (311-HP01) PF1.013 Pan Feeder (311-AF02) and discharge to Hopper (311-HP01)

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control 901 SOUTH STEWART STREET SUITE 4001

CARSON CITY, NEVADA 89701-5249 p: 775-687-9350 • www.ndep.nv.gov/bapc

Page 2: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) E. System 05A – Unit #1 Classification and Drying, Natural Gas (Primary Scenario) Revised Month 2019 S2.001A Hopper (311-HP01) and transfer to Cyclone (311-CN01) S2.002A Cyclone (311-CN01) and solids discharge to Cyclone (311-CN02) S2.003A Cyclone (311-CN02) and solids discharge to Whizzer Separator (311-SR01) and fines transfer to Cyclone (311-CN03) S2.004A Whizzer Separator (311-SR01) and solids discharge to Cyclone (311-CN03) and waste discharge to Screw Conveyor

(361-SC01) S2.005A Cyclone (311-CN03) and discharge to Screw Conveyor (311-SC05) S2.006A Screw Conveyor (361-SC01) and transfer to Waste Bin (361-BI01) S2.007A Screw Conveyor (311-SC05) and transfer to Screw Conveyor (311-SC06) S2.008A Screw Conveyor (311-SC06) and transfer to Rotary kiln (321-KL01) S2.009A Rotary Kiln (321-KL01) and exhaust to Hot Air Furnace (311-HG01) S2.010A Hot Air Furnace (311-HG01) and exhaust to Cyclone (311-CN01), Cyclone (311-CN02), Baghouse (311-BF01) and

Baghouse (311-BF02) S2.011A Baghouse (311-BF01) and transfer to Screw Conveyor (311-SC01) S2.012A Baghouse (311-BF02) and transfer to Screw Conveyor (311-SC02) S2.013A Screw Conveyor (311-SC01) and transfer to Conveyor (311-SC03) S2.014A Screw Conveyor (311-SC02) and transfer to Conveyor (311-SC03) S2.015A Screw Conveyor (311-SC03) and transfer to Screw Conveyor (311-SC04) and Screw Conveyor (361-SC02) S2.016A Screw Conveyor (311-SC04) and transfer to Conveyor (311-SC05) S2.017A Screw Conveyor (361-SC02) and transfer to Screw Conveyor (361-SC01) F. System 05B – Unit #1 Classification and Drying, #2 Fuel Oil (Alternate Scenario) Revised Month 2019 S2.001B Hopper (311-HP01) and transfer to Cyclone (311-CN01) S2.002B Cyclone (311-CN01) and solids discharge to Cyclone (311-CN02) S2.003B Cyclone (311-CN02) and solids discharge to Whizzer Separator (311-SR01) and fines transfer to Cyclone (311-CN03) S2.004B Whizzer Separator (311-SR01) and solids discharge to Cyclone (311-CN03) and waste discharge to Screw Conveyor

(361-SC01) S2.005B Cyclone (311-CN03) and discharge to Screw Conveyor (311-SC05) S2.006B Screw Conveyor (361-SC01) and transfer to Waste Bin (361-BI01) S2.007B Screw Conveyor (311-SC05) and transfer to Screw Conveyor (311-SC06) S2.008B Screw Conveyor (311-SC06) and transfer to Rotary kiln (321-KL01) S2.009B Rotary Kiln (321-KL01) and exhaust to Hot Air Furnace (311-HG01) S2.010B Hot Air Furnace (311-HG01) and exhaust to Cyclone (311-CN01), Cyclone (311-CN02), Baghouse (311-BF01) and

Baghouse (311-BF02) S2.011B Baghouse (311-BF01) and transfer to Screw Conveyor (311-SC01) S2.012B Baghouse (311-BF02) and transfer to Screw Conveyor (311-SC02) S2.013B Screw Conveyor (311-SC01) and transfer to Conveyor (311-SC03) S2.014B Screw Conveyor (311-SC02) and transfer to Conveyor (311-SC03) S2.015B Screw Conveyor (311-SC03) and transfer to Screw Conveyor (311-SC04) and Screw Conveyor (361-SC02) S2.016B Screw Conveyor (311-SC04) and transfer to Conveyor (311-SC05) S2.017B Screw Conveyor (361-SC02) and transfer to Screw Conveyor (361-SC01)

Page 3: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) G. System 05C – Unit #1 Classification and Drying, Waste Oil (Alternate Scenario) Revised Month 2019 S2.001C Hopper (311-HP01) and transfer to Cyclone (311-CN01) S2.002C Cyclone (311-CN01) and solids discharge to Cyclone (311-CN02) S2.003C Cyclone (311-CN02) and solids discharge to Whizzer Separator (311-SR01) and fines transfer to Cyclone (311-CN03) S2.004C Whizzer Separator (311-SR01) and solids discharge to Cyclone (311-CN03) and waste discharge to Screw Conveyor

(361-SC01) S2.005C Cyclone (311-CN03) and discharge to Screw Conveyor (311-SC05) S2.006C Screw Conveyor (361-SC01) and transfer to Waste Bin (361-BI01) S2.007C Screw Conveyor (311-SC05) and transfer to Screw Conveyor (311-SC06) S2.008C Screw Conveyor (311-SC06) and transfer to Rotary kiln (321-KL01) S2.009C Rotary Kiln (321-KL01) and exhaust to Hot Air Furnace (311-HG01) S2.010C Hot Air Furnace (311-HG01) and exhaust to Cyclone (311-CN01), Cyclone (311-CN02), Baghouse (311-BF01) and

Baghouse (311-BF02) S2.011C Baghouse (311-BF01) and transfer to Screw Conveyor (311-SC01) S2.012C Baghouse (311-BF02) and transfer to Screw Conveyor (311-SC02) S2.013C Screw Conveyor (311-SC01) and transfer to Conveyor (311-SC03) S2.014C Screw Conveyor (311-SC02) and transfer to Conveyor (311-SC03) S2.015C Screw Conveyor (311-SC03) and transfer to Screw Conveyor (311-SC04) and Screw Conveyor (361-SC02) S2.016C Screw Conveyor (311-SC04) and transfer to Conveyor (311-SC05) S2.017C Screw Conveyor (361-SC02) and transfer to Screw Conveyor (361-SC01) H. System 06 – Unit #1 Classification and Drying S2.018 Rotary Kiln (321-KL01) product discharge to Delumper (331-LC01) S2.019 Delumper (331-LC01) and discharge to Cyclone (331-CN01) S2.020 Cyclone (331-CN01) and solids discharge to Bucket Elevator (331-BE01) and fines discharge to Cyclone (331-CN02) S2.021 Cyclone (331-CN02) and solids discharge to Main Product Bin (331-BI01), Screen (331-VS03) or Screw Conveyor (331-

SC02) S2.022 Bucket Elevator (331-BE01) and discharge to Screw Conveyor (331-SC01) or Rotex Screen (331-VS01) S2.023 Screw Conveyor (331-SC01) and discharge to Rotex Screen (VS02) S2.024 Rotex Screen (331-VS01) and discharge to Screw Conveyor (331-SC02) or Cyclone (331-CN03) S2.025 Rotex Screen (331-VS02) and discharge to Screw Conveyor (331-SC02) or Cyclone (331-CN03) S2.026 Screw Conveyor (331-SC02) and discharge to Hammermill (331-HC01) and Hammermill (331-HC02) S2.027 Hammermill (331-HC01) and discharge to Cyclone (331-CN03) S2.028 Hammermill (331-HC02) and discharge to Cyclone (331-CN03) S2.029 Cyclone (331-CN03) and discharge to Screw Conveyor (331-SC03), Screw Conveyor (361-SC03) or Cyclone (331-

CN02) S2.030 Screen (331-VS03) and discharge to Main Product Bin (331-BI01) or Bucket Elevator (331-BE01) S2.031 Main Product Bin (331-BI01) and fines discharge to Cyclone (331-CN02)

Page 4: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) I. System 07 – Unit #1 Classification and Drying S2.032 Screw Conveyor (371-SC05) and discharge to Cyclone (331-CN01) S2.033 Main Product Bin (331-BI01) and discharge to Screw Conveyor (331-SC04) S2.034 Screw Conveyor (331-SC04) and discharge to Bucket Elevator (331-BE02) S2.035 Bucket Elevator (331-BE02) and discharge to Main Surge Bin (331-BI03), Main Product Bin (331-BI01), Re-Feed Bin

(371-BI01), or Bulk Loading S2.036 Main Surge Bin (331-BI03) and discharge to Bag Packer (401-PM02) S2.037 Air Slide (331-AS01) and discharge to Bulk Bag Bin (331-BI04) S2.038 Bulk Bag Bin (331-BI04) and discharge to Screw Conveyor (401-SC04) or Bulk Bagger (401-BB02) S2.039 Screw Conveyor (401-SC04) and discharge to Bulk Bagger (401-BB01) S2.040 Screw Conveyor (371-SC02) and discharge to Bucket Elevator (371-BE01) and Re-Feed Bin (371-BI01) S2.041 Bucket Elevator (371-BE01) and discharge to Screw Conveyor (371-SC03) or Bagging Bin (331-BI02) S2.042 Screw Conveyor (371-SC03) and discharge to Screw Conveyor (371-SC04) S2.043 Screw Conveyor (371-SC04) and discharge to Screw Conveyor (361-SC02) or Screw Conveyor (311-SC04) S2.044 Bagging Bin (331-BI02) and discharge to Bag Packer (401-PM01) S2.045 Belt Bag Conveyor (401-FQ01) and discharge to Belt Bag Conveyor (401-BC01) S2.046 Bag Flattener (401-FQ01) S2.047 Belt Bag Conveyor (401-BC01) S2.048 Screw Conveyor (401-SC01) and discharge to Screw Conveyor (401-SC02) S2.049 Screw Conveyor (401-SC02) and discharge to Baghouse (401-BF01) S2.050 Screw Conveyor (401-SC03) and discharge to Baghouse (401-BF01) J. System 08 – Unit #1 Bulk Loading and Packing S2.051 Bag Packer (401-PM01) S2.052 Bag Packer (401-PM02) K. System 09 – Unit #2 Classification and Drying PF1.014 Ore Bin (31A-BI03) and discharge to Pan Feeder (312-AF01) PF1.015 Ore Bin (31A-BI04) and discharge to Pan Feeder (312-AF02) PF1.016 Pan Feeder (312-AF01) and discharge to Conveyor (312-BC01) PF1.017 Pan Feeder (312-AF02) and discharge to Conveyor (312-BC01) PF1.018 Conveyor (312-BC01) and discharge to Cyclone (312-CN01)

Page 5: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) L. System 10A – Unit #2 Classification and Drying, Natural Gas (Primary Scenario) Revised Month 2019 S2.053A Cyclone (312-CN01) and solids discharge to Cyclone (312-CN02) S2.054A Cyclone (312-CN02) and solids discharge to Whizzer Separator (312-SR01) or fines discharge to Cyclone (312-CN03) S2.055A Whizzer Separator (312-SR01) and solids discharge to Cyclone (312-CN03) or waste discharge to Screw Conveyor (362-

SC01) S2.056A Cyclone (312-CN03) and solids discharge to Screw Conveyor (312-SC04) or fines discharge to Cyclone (312-CN01) S2.057A Screw Conveyor (312-SC04) and discharge to Screw Conveyor (312-SC05) S2.058A Screw Conveyor (312-SC05) and discharge to Rotary Kiln (322-KL01) S2.059A Rotary Kiln (322-KL01) and exhaust to Hot Air Furnace (312-HG01) S2.060A Hot Air Furnace (312-HG01) and exhaust to Cyclone (312-CN01), Cyclone (312-CN02), Baghouse (312-BF01) and

Baghouse (312-BF02) S2.061A Screw Conveyor (312-SC03) and discharge to Screw Conveyor (312-SC04) or Screw Conveyor (362-SC02) S2.062A Screw Conveyor (362-SC02) and discharge to Screw Conveyor (362-SC01) S2.063A Screw Conveyor (362-SC01) and discharge to Waste Bin (36A-BI01) M. System 10B – Unit #2 Classification and Drying, #2 Fuel Oil (Alternate Scenario) Revised Month 2019 S2.053B Cyclone (312-CN01) and solids discharge to Cyclone (312-CN02) S2.054B Cyclone (312-CN02) and solids discharge to Whizzer Separator (312-SR01) or fines discharge to Cyclone (312-CN03) S2.055B Whizzer Separator (312-SR01) and solids discharge to Cyclone (312-CN03) or waste discharge to Screw Conveyor (362-

SC01) S2.056B Cyclone (312-CN03) and solids discharge to Screw Conveyor (312-SC04) or fines discharge to Cyclone (312-CN01) S2.057B Screw Conveyor (312-SC04) and discharge to Screw Conveyor (312-SC05) S2.058B Screw Conveyor (312-SC05) and discharge to Rotary Kiln (322-KL01) S2.059B Rotary Kiln (322-KL01) and exhaust to Hot Air Furnace (312-HG01) S2.060B Hot Air Furnace (312-HG01) and exhaust to Cyclone (312-CN01), Cyclone (312-CN02), Baghouse (312-BF01) and

Baghouse (312-BF02) S2.061B Screw Conveyor (312-SC03) and discharge to Screw Conveyor (312-SC04) or Screw Conveyor (362-SC02) S2.062B Screw Conveyor (362-SC02) and discharge to Screw Conveyor (362-SC01) S2.063B Screw Conveyor (362-SC01) and discharge to Waste Bin (36A-BI01)

Page 6: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) N. System 10C – Unit #2 Classification and Drying, Waste Oil (Alternate Scenario) Revised Month 2019 S2.053C Cyclone (312-CN01) and solids discharge to Cyclone (312-CN02) S2.054C Cyclone (312-CN02) and solids discharge to Whizzer Separator (312-SR01) or fines discharge to Cyclone (312-CN03) S2.055C Whizzer Separator (312-SR01) and solids discharge to Cyclone (312-CN03) or waste discharge to Screw Conveyor (362-

SC01) S2.056C Cyclone (312-CN03) and solids discharge to Screw Conveyor (312-SC04) or fines discharge to Cyclone (312-CN01) S2.057C Screw Conveyor (312-SC04) and discharge to Screw Conveyor (312-SC05) S2.058C Screw Conveyor (312-SC05) and discharge to Rotary Kiln (322-KL01) S2.059C Rotary Kiln (322-KL01) and exhaust to Hot Air Furnace (312-HG01) S2.060C Hot Air Furnace (312-HG01) and exhaust to Cyclone (312-CN01), Cyclone (312-CN02), Baghouse (312-BF01) and

Baghouse (312-BF02) S2.061C Screw Conveyor (312-SC03) and discharge to Screw Conveyor (312-SC04) or Screw Conveyor (362-SC02) S2.062C Screw Conveyor (362-SC02) and discharge to Screw Conveyor (362-SC01) S2.063C Screw Conveyor (362-SC01) and discharge to Waste Bin (36A-BI01) O. System 11 – Unit #2 Classification and Drying S2.064 Screw Conveyor (312-SC01) and transfer to Midwesco Baghouse (312-BF03) S2.065 Screw Conveyor (312-SC02) and transfer to Midwesco Baghouse (312-BF03) P. System 12 – Unit #2 Classification and Drying S2.066 Rotary Kiln #2 (322-KL01) and product discharge to Delumper (332-LC01) S2.067 Delumper (332-LC01) and discharge to Cyclone (332-CN01) S2.068 Cyclone (332-CN01) and solids discharge to Bucket Elevator (332-BE01) or fines discharge to Cyclone (332-CN02) S2.069 Bucket Elevator (332-BE01) and discharge to Screw Conveyor (332-SC01) S2.070 Screw Conveyor (332-SC01) and discharge to Rotex Screen (332-VS01) and Rotex Screen (332-VS02) S2.071 Rotex Screen (332-VS01) and discharge to Screw Conveyor (332-SC02) or Cyclone (332-CN03) S2.072 Rotex Screen (332-VS02) and discharge to Screw Conveyor (332-SC02) or Cyclone (332-CN03) S2.073 Screw Conveyor (332-SC02) and discharge to Hammermill (332-HC01) and Hammermill (332-HC02) S2.074 Hammermill (332-HC01) and discharge to Cyclone (332-CN03) S2.075 Hammermill (332-HC02) and discharge to Cyclone (332-CN03) S2.076 Cyclone (332-CN03) and solids discharge to Cyclone (332-CN02) or Air Slide (332-AS01) S2.077 Air Slide (332-AS01) and transfer to Screw Conveyor (332-SC02) S2.078 Cyclone (332-CN02) and solids discharge to Main Product Bin (332-BI01), Rotex Screen (332-VS03) or Screw

Conveyor (332-SC03) S2.079 Rotex Screen (332-VS03) and discharge to Main Product Bin (332-BI01) or Screw Conveyor (332-SC04) S2.080 Screw Conveyor (332-SC03) and discharge to Screw Conveyor (332-SC04) S2.081 Screw Conveyor (332-SC04) and discharge to Screw Conveyor (332-SC02)

Page 7: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) Q. System 13 – Unit #2 Classification and Drying Revised Month 2019 S2.082 Main Product Bin (332-BI01) and discharge to Cyclone (332-CN02) or Screw Conveyor (332-SC05) S2.083 Screw Conveyor (332-SC05) and discharge to Bucket Elevator (332-BE04) S2.084 Bucket Elevator (332-BE04) and discharge to Air Slide (332-AS02), Re-Feed Bin (371-BI01), Main Product Bin (332-

BI01), Main Product Bin (331-BI01), or Bulk Loading S2.085 Air Slide (332-AS02) and discharge to Main Surge Bin (332-BI03) or Air Slide (332-AS03) S2.086 Main Surge Bin (332-BI03) and discharge to Bag Packer (402-PM01) S2.087 Air Slide (332-AS03) and discharge to Main Bulk Bag Bin (332-BI04) S2.088 Screw Conveyor (352-SC01) and discharge to Screw Conveyor (352-SC02) or Re-Feed Bin (371-BI01) S2.089 Screw Conveyor (352-SC02) and discharge to Bucket Elevator (352-BE03) S2.090 Bucket Elevator (352-BE03) and discharge to Classifier (352-SR01) S2.091 Classifier (352-SR01) and fines discharge to Cyclone (332-CN04) or solids discharge to Cyclone (332-CN01) S2.092 Cyclone (332-CN04) and solids discharge to Screw Conveyor (352-SC03) or fines discharge to Classifier (352-SR01) S2.093 Screw Conveyor (352-SC03) and discharge to Bucket Elevator (332-BE02) S2.094 Screw Conveyor (332-SC06) and discharge to Bucket Elevator (332-BE02) or Screw Conveyor (352-SC01) S2.095 Bucket Elevator (332-BE02) and discharge to Screw Conveyor (332-SC09) S2.096 Screw Conveyor (332-SC09) and discharge to Baghouse Bin (402-BI02) S2.097 Baghouse Bin (332-BI02) and discharge to Bag Packer (402-PM02) or Screw Conveyor (402-SC04) S2.098 Screw Conveyor (402-SC04) and discharge to Bulk Bagger (402-BB02) S2.099 Screw Conveyor (371-SC01) and discharge to Re-Feed Bin (371-BI01) S2.100 Bag Product Chute discharge to Belt Bag Conveyor (402-BC01) S2.101 Bag Flattener (402-FQ01) S2.102 Re-Feed Bin (371-BI01) and discharge to Cyclone (311-CN03), Cyclone (331-CN01), Cyclone (312-CN03) or Cyclone

(313-CN03) S2.103 Baghouse (371 -BF01) to Re-Feed Bin (371-BI01) S2.239 Bulk Bag Unloader (371-EH01) R. System 14 – Unit #2 Bulk Loading and Packing Revised Month 2019 S2.104 Main Bulk Bag Bin (332-BI04) and discharge to Main Bin Bulk Bagger (402-BB01) and Main Bin Bulk Bagger (402-

BB03) S2.105 Bulk Bagger (402-BB01) S2.106 Bulk Bagger (402-BB02) S2.107 Bulk Bagger (402-BB03) S2.108 Belt Bag Conveyor (402-BC01) S2.109 Screw Conveyor (402-SC01) S2.110 Screw Conveyor (402-SC02) S2.111 Screw Conveyor (402-SC03) S. System 15 – Unit #2 Bulk Loading and Packing Revised Month 2019 S2.112 Bag Breaker (371- BI02) to Re-Feed Bin (371-BI01)

Page 8: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) T. System 16 – Unit #3 Ore Crushing Unit PF1.019 Unloading from Truck to Hopper (313-HP01) U. System 17 – Unit #3 Ore Crushing Unit Revised Month 2019 S2.113 Hopper (313-HP01) and discharge to Pan Feeder (313-AF01) S2.114 Pan Feeder (313-AF01) and discharge to Crusher (313-HC01) or Belt Conveyor (313-BC01) S2.115 Belt Conveyor (313-BC01) and discharge to Bucket Elevator (313-BE01) S2.116 Crusher (313-HC01) and discharge to Bucket Elevator (313-BE01) S2.117 Bucket Elevator (313-BE01) and discharge to Screw Conveyor (313-SC06) S2.118 Screw Conveyor (313-SC06) and discharge to Ore Bin (313-BI01) and Ore Bin (313-BI02) V. System 18 – Unit #3 Ore Crushing Unit Revised Month 2019 PF1.020 Ore Bin (313-BI01) and discharge to Pan Feeder (313-AF02) PF1.021 Ore Bin (313-BI02) and discharge to Pan Feeder (313-AF03) PF1.022 Pan Feeder (313-AF02) and discharge to Mill 3 Chute PF1.023 Pan Feeder (313-AF03) and discharge to Mill 3 Chute W. System 19A – Unit #3 Classification and Drying, Natural Gas (Primary Scenario) Revised Month 2019 S2.119A Cyclone (313-CN01) and solids discharge to Cyclone (313-CN02) S2.120A Cyclone (313-CN02) and solids discharge to Whizzer Separator (313-SR01) or fines discharge to Cyclone (313-CN03) S2.121A Whizzer Separator (313-SR01) and solids discharge to Cyclone (313-CN03) or waste discharge to Screw Conveyor (363-

SC01) S2.122A Cyclone (313-CN03) and solids discharge to Screw Conveyor (313-SC04) or fines discharge to Cyclone (313-CN01) S2.123A Screw Conveyor (313-SC04) and discharge to Screw Conveyor (313-SC05) S2.124A Screw Conveyor (313-SC05) and discharge to Rotary Kiln (323-KL01) S2.125A Rotary Kiln (323-KL01) and exhaust to Hot Air Furnace (313-HG01) S2.126A Hot Air Furnace (313-HG01) and exhaust to Cyclone (313-CN01), Cyclone (313-CN02), Cyclone (313-CN02),

Baghouse (313-BF01) and Baghouse (313-BF02) S2.127A Baghouse (313-BF01) and discharge to Filter/Receiver (313-BF03) S2.128A Baghouse (313-BF02) and discharge to Filter/Receiver (313-BF03) S2.129A Filter/Receiver (313-BF03) and discharge to Screw Conveyor (313-SC03) S2.130A Screw Conveyor (313-SC03) and discharge to Screw Conveyor (313-SC04) S2.131A Screw Conveyor (363-SC01) discharge to Waste Bin (36A-BI01)

Page 9: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) X. System 19B – Unit #3 Classification and Drying, #2 Fuel Oil (Alternate Scenario) Revised Month 2019 S2.119B Cyclone (313-CN01) and solids discharge to Cyclone (313-CN02) S2.120B Cyclone (313-CN02) and solids discharge to Whizzer Separator (313-SR01) or fines discharge to Cyclone (313-CN03) S2.121B Whizzer Separator (313-SR01) and solids discharge to Cyclone (313-CN03) or waste discharge to Screw Conveyor (363-

SC01) S2.122B Cyclone (313-CN03) and solids discharge to Screw Conveyor (313-SC04) or fines discharge to Cyclone (313-CN01) S2.123B Screw Conveyor (313-SC04) and discharge to Screw Conveyor (313-SC05) S2.124B Screw Conveyor (313-SC05) and discharge to Rotary Kiln (323-KL01) S2.125B Rotary Kiln (323-KL01) and exhaust to Hot Air Furnace (313-HG01) S2.126B Hot Air Furnace (313-HG01) and exhaust to Cyclone (313-CN01), Cyclone (313-CN02), Cyclone (313-CN02),

Baghouse (313-BF01) and Baghouse (313-BF02) S2.127B Baghouse (313-BF01) and discharge to Filter/Receiver (313-BF03) S2.128B Baghouse (313-BF02) and discharge to Filter/Receiver (313-BF03) S2.129B Filter/Receiver (313-BF03) and discharge to Screw Conveyor (313-SC03) S2.130B Screw Conveyor (313-SC03) and discharge to Screw Conveyor (313-SC04) S2.131B Screw Conveyor (363-SC01) discharge to Waste Bin (36A-BI01) Y. System 19C – Unit #3 Classification and Drying, Waste Oil (Alternate Scenario) Revised Month 2019 S2.119C Cyclone (313-CN01) and solids discharge to Cyclone (313-CN02) S2.120C Cyclone (313-CN02) and solids discharge to Whizzer Separator (313-SR01) or fines discharge to Cyclone (313-CN03) S2.121C Whizzer Separator (313-SR01) and solids discharge to Cyclone (313-CN03) or waste discharge to Screw Conveyor (363-

SC01) S2.122C Cyclone (313-CN03) and solids discharge to Screw Conveyor (313-SC04) or fines discharge to Cyclone (313-CN01) S2.123C Screw Conveyor (313-SC04) and discharge to Screw Conveyor (313-SC05) S2.124C Screw Conveyor (313-SC05) and discharge to Rotary Kiln (323-KL01) S2.125C Rotary Kiln (323-KL01) and exhaust to Hot Air Furnace (313-HG01) S2.126C Hot Air Furnace (313-HG01) and exhaust to Cyclone (313-CN01), Cyclone (313-CN02), Cyclone (313-CN02),

Baghouse (313-BF01) and Baghouse (313-BF02) S2.127C Baghouse (313-BF01) and discharge to Filter/Receiver (313-BF03) S2.128C Baghouse (313-BF02) and discharge to Filter/Receiver (313-BF03) S2.129C Filter/Receiver (313-BF03) and discharge to Screw Conveyor (313-SC03) S2.130C Screw Conveyor (313-SC03) and discharge to Screw Conveyor (313-SC04) S2.131C Screw Conveyor (363-SC01) discharge to Waste Bin (36A-BI01)

Page 10: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) Z. System 20 – Unit #3 Classification and Drying Revised Month 2019 S2.132 Rotary Kiln #3 (323-KL01) and product discharge to Delumper 333-LC01) S2.133 Delumper (333-LC01) and discharge to Cyclone (333-CN01) S2.134 Cyclone (333-CN01) and solids discharge to Bucket Elevator (333-BE01) or fines discharge to Cyclone (333-CN02) S2.135 Bucket Elevator (333-BE01) and discharge to Screw Conveyor (333-SC01) S2.136 Screw Conveyor (333-SC01) and discharge to Rotex Screen (333-VS01) and Rotex Screen (333-VS02) S2.137 Rotex Screen (333-VS01) and discharge to Screw Conveyor (333-SC02), Cyclone (333-CN03) or Bucket Elevator (333-

BE02) S2.138 Rotex Screen (333-VS02) and discharge to Screw Conveyor (333-SC02), Cyclone (333-CN03) or Bucket Elevator (333-

BE02) S2.139 Screw Conveyor (333-SC02) and discharge to Hammermill (333-HC01) and Hammermill (333-HC02) S2.140 Hammermill (333-HC01) and discharge to Cyclone (333-CN03) S2.141 Hammermill (333-HC02) and discharge to Cyclone (333-CN03) S2.142 Cyclone (333-CN03) and solids discharge to Cyclone (333-CN02) or Air Slide (333-AS02) S2.143 Air Slide (333-AS02) and discharge to Screw Conveyor (333-SC02) or Bucket Elevator (333-BE02) S2.144 Cyclone (333-CN02) and solids discharge to Screw Conveyor (333-SC03) or fines discharge to Screw Conveyor (333-

SC04) S2.145 Screw Conveyor (333-SC04) and discharge to Screen (333-VS03) S2.146 Screw Conveyor (333-SC03) and discharge to Screw Conveyor (333-SC02), Hammermill (333-HC01) or Hammermill

(333-HC02) S2.147 Bucket Elevator (333-BE02) and discharge to Stream Splitter (333-MW01) S2.148 Stream Splitter (333-MW01) and discharge to Rotex Screen (333-VS04) S2.149 Rotex Screen (333-VS04) and discharge to Screw Conveyor (333-SC03) or Air Slide (333-AS01) S2.150 Screw Conveyor (353-SC02) discharge to Bucket Elevator (353-BE02) S2.151 Bucket Elevator (353-BE02) and discharge to Classifier (353-SR01) S2.152 Bag Flattener (403-FQ01) S2.153 Belt Bag Conveyor (403-BC01) AA. System 21 – Unit #3 Classification and Drying Revised Month 2019 S2.154 Screen (333-VS03) and discharge to Main Product Bin (333-BI01) or Bucket Elevator (333-BE01) S2.155 Re-Feed Screw Conveyor (403-SC01) S2.156 Air Slide (333-AS01) and discharge to Bagging Bin (333-BI04) S2.157 Bagging Bin (333-BI04) and discharge to Bag Packer (403-PM01) S2.158 Main Product Bin (333-BI01) and discharge to Screw Conveyor (353-SC01), Cyclone 333-CN02 or Re-Feed Bin (371-

BI01) S2.159 Screw Conveyor (353-SC01) and discharge to Bucket Elevator (353-BE01) S2.160 Bucket Elevator (353-BE01) and discharge to Main Product Bin (333-BI01) or Screw Conveyor (353-SC02) S2.161 Screw Conveyor (353-SC02) and discharge to Bucket Elevator (353-BE02) S2.162 Classifier (353-SR01) and fines discharge to Classifier (353-CN01) or solids discharge to Bagging Bin (333-BI04) S2.163 Cyclone (353-CN01) and solids discharge to Screw Conveyor (353-SC03) or fines discharge to Classifier (353-SR01)

Page 11: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) AA. System 21 – Unit #3 Classification and Drying (continued) S2.164 Screw Conveyor (353-SC03) and discharge to Screw Conveyor (333-SC08) S2.165 Screw Conveyor (333-SC08) and discharge to Bucket Elevator (333-BE03) S2.166 Bucket Elevator (333-BE03) and discharge to Air Slide (333-AS03), Air Slide (403-AS01), Bagging Bin (333-BI02) or

Bagging Bin (333-BI03) S2.167 Baghouse Packer Bin (333-BI02) and discharge to Bag Packer (403-PM03) or Screw Conveyor (403-SC01) S2.168 Screw Conveyor (403-SC01) and discharge to Bulk Bagger (403-BB01) S2.169 Bulk Bagger (403-BB01) S2.170 Bulk Bagger (403-BB02) S2.171 Air Slide (333-AS03) and discharge to Rotex Screen (333-RS01 ) S2.172 Rotex Screen (333-RS01) discharge to Bulk Bagger Bin (333-BI05) S2.173 Bulk Bagger Bin (333-BI05) and discharge to Bulk Bagger (403-BB02) S2.174 Air Slide (403-AS01) and discharge to Air Slide (403-AS02) S2.175 Air Slide (403-AS02) and discharge to Air Slide (403-AS01), Re-Feed Bin or (371-BI01) Bulk Car S2.176 Bagging Bin (333-BI03) and discharge to Bag Packer (403-PM02) S2.177 Screw Conveyor (333-SC05) and discharge to Screw Conveyor (333-SC08) S2.178 Screw Conveyor (333-SC06) and discharge to Screw Conveyor (333-SC08) S2.179 Screw Conveyor (333-SC07) and discharge to Screw Conveyor (333-SC08) S2.180 Screw Conveyor (373-SC01) and discharge to Cyclone (333-CN01) BB. System 22 – Unit #3 Classification and Drying Revised Month 2019 S2.181 Bag Packer (403-PM01) S2.182 Bag Packer (403-PM02) S2.183 Bag Packer (403-PM03) CC. System 23A – Unit #1 and #2 Soda Ash Bin – Loading S2.184 Soda Ash Bin (341-BI01), Loading by Truck S2.185 Soda Ash Bin (342-BI01), Loading by Truck DD. System 23B – Unit #1 and #2 Soda Ash Bin – Unloading PF1.024 Soda Ash Bin (341-BI01), Unloading to Weigh Feeder (341-WF01) PF1.025 Soda Ash Bin (342-BI01), Unloading to Weigh Feeder (342-WF01) EE. System 24A – Unit #3 Soda Ash Bin – Loading S2.186 Soda Ash Bin (343-BI01), Loading from Truck FF. System 24B – Unit #3 Soda Ash Bin – Unloading PF1.026 Soda Ash Bin (343-BI01), Unloading to Weigh Feeder (343-WF01)

Page 12: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) GG. System 25 – Soda Ash Processing PF1.027 Weigh Feeder (341-WF01) and discharge to Soda Ash Mill (341-HC01) PF1.028 Weigh Feeder (342-WF01) and discharge to Soda Ash Mill (342-HC01) PF1.029 Weigh Feeder (343-WF01) and discharge to Soda Ash Mill (343-HC01) PF1.030 Soda Ash Mill (341-HC01) and discharge to Cyclone (311-CN03) PF1.031 Soda Ash Mill (342-HC01) and discharge to Cyclone (312-CN01) or Cyclone (312-CN03) PF1.032 Soda Ash Mill (343-HC01) and discharge to Cyclone (313-CN03) HH. System 26 – Waste Bin Operation Revised Month 2019 S2.187 Waste Bin (36A-BI01), Loading S2.188 Waste Bin (36A-BI01), Unloading to Truck S2.189 Snorkel (36A-LA01) and Truck Loading of Waste (Includes Loading Building Ventilation) (36A-LA01) II. System 27 – Perlite Sizing and Drying Revised Month 2019 PF1.033 Truck unloading to Perlite Ore Dump (314-HP01) PF1.034 Perlite Ore Dump (314-HP01) and discharge to Vibratory Feeder (314-VF01) PF1.035 Vibratory Feeder (314-VF01) and discharge to Belt Conveyor (314-BC01) JJ. System 28 – Perlite Sizing and Drying Revised Month 2019 S2.190 Ore Belt Conveyor (314-BC01) and discharge to Jaw Crusher (314-JC01) or fines discharge to Cyclone (314-CN01) S2.191 Jaw Crusher (314-JC01) and solids discharge to Bucket Elevator (314-BE01) or fines discharge to Cyclone (314-CN01) S2.192 Bucket Elevator (314-BE01) solids discharge to Surge Bin (314-BI01) or fines discharge to Cyclone (314-CN01) S2.193 Surge Bin (314-BI01) and discharge to Vibrating Feeder (314-SC01) S2.194 Vibrating Feeder (314-SC01) and discharge to Rotary Dryer (314-DR01) S2.195 Rotary Dryer (314-DR01) and exhaust to Cyclone (314-CN01) and solids discharge to Belt Conveyor (314-BC01) S2.196 Belt Conveyor (314-BC01) and discharge to Bucket Elevator (314-BE02) or fines discharge to Cyclone (314-CN01) S2.197 Bucket Elevator (314-BE02) and discharge to Vibrating Screen (314-VS01) S2.198 Vibrating Screen (314-VS01) and discharge to Cyclone (314-CN01), Bucket Elevator (314-BE03) or VSI Impact Mill

(314-IM01) S2.199 VSI Impact Mill (314-IM01) and discharge to Bucket Elevator (314-BE02) S2.200 Bucket Elevator (314-BE03) and fines discharge to Cyclone (314-CN01) or solids discharge to Surge Bin (314-BI02) and

Surge Bin (314-BI03) S2.201 Surge Bin (314-BI02) and discharge to Belt Conveyor (404-BC01) S2.202 Surge Bin (314-BI03) and discharge to Belt Conveyor (404-BC01) S2.203 Cyclone (314-CN01) and discharge to Bucket Elevator (314-BE03) KK. System 29 – Perlite Sizing and Drying Revised Month 2019 S2.204 Belt Conveyor (404-BC01) and discharge to Belt Conveyor (404-BC02) S2.205 Belt Conveyor (404-BC02) and discharge to Diverter (404-MW01), Cross Conveyor (404-BC03) and Bulk Rail Car

(404-LA01) S2.206 Cross Conveyor (404-BC03) and discharge to Shuttle Conveyor (404-BC04) S2.207 Shuttle Conveyor (404-BC04) and discharge to Bulk Car Rail (404-LA02)

Page 13: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) KK. System 29 – Perlite Sizing and Drying (continued) S2.208 Transfer of waste from Baghouse (314-BF01) to Waste Bin (36A-BI01) S2.209 Transfer of waste from Baghouse (334-BF02) to Waste Bin (36A-BI01) S2.210 Transfer of waste from Baghouse (364-BF01) to Waste Bin (36A-BI01) S2.211 Bulk Rail Car (404-LA01) transfer to Bulk Truck S2.212 Bulk Rail Car (404-LA02) transfer to Bulk Truck S2.213 Bulk Truck to Blue Baghouse (404-BF01) LL. System 30 – Perlite Transfer/Perlite Expander and Classification Revised Month 2019 S2.214 Surge Bin (314-BI02) and discharge to Vibrating Conveyor (324-VC01) S2.215 Surge Bin (314-BI03) and discharge to Vibrating Conveyor (324-VC01) S2.216 Vibrating Conveyor (324-VC01) and discharge to Expander Elevator (324-BE01) S2.217 Expander Elevator (324-BE01) and discharge to Ore Feed Bin (324-BI01) S2.218 Ore Feed Bin (324-BI01) and discharge to Screw Conveyor (324-SC01) S2.219 Screw Conveyor (324-SC01) and discharge to M-30 Expander (324-ED01) S2.220 M-30 Expander (324-ED01) and exhaust/product to Cyclone (334-CN01) S2.221 Cyclone (334-CN01) and solids discharge to Expander Degritter (324-DT01) MM. System 31 – Perlite Transfer/Perlite Expander and Classification S2.222 Expander Degritter (334-DT01) and discharge to Milling Fan (334-FN03) S2.223 Milling Fan (334-FN03) and discharge to Air Classifier (334-SR01) S2.224 Air Classifier (334-SR01) and fines discharge to Cyclone (334-CN02) or solids discharge to Finish Degritter (334-DT02) S2.225 Finish Degritter (334-DT02) and discharge to Milling Fan (334-FN03) S2.226 Cyclone (334-CN02) and solids discharge to Screw Conveyor (334-SC01) S2.227 Screw Conveyor (334-SC01) and discharge to Bucket Elevator (334-BE01) and Rail Car S2.228 Bucket Elevator (334-BE01) and discharge to Product Bin (334-BI01) S2.229 Product Bin (334-BI01) and discharge to Packer (404-PM01) and Packer (404-PM02) S2.230 Bag Packer (404-PM01) S2.231 Bag Packer (404-PM02) S2.232 Bulk Bagger (404-BB01) NN. System 32 – Perlite Transfer/Perlite Expander and Classification PF1.036 Expander Degritter (334-DT01) and discharge to Waste PF1.037 Finish Degritter (334-DT02) and discharge to Waste OO. System 33 – Ribbon Blender

S2.233 Raw Material (Cellulose and Calcined Diatomaceous Earth) Hand Loaded to Dual Screw Ribbon Blender (40A-MI01) Dual Screw Ribbon Blender (40A-MI01) and discharge to Screw Conveyor (40A-SC01)

S2.234 Screw Conveyor (40A-SC01) and discharge to Bagger (40A-PM01) S2.235 Bulk Bagger (40A-EH01) to Bulk Bagger (40A-BB01)

Page 14: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee) Emission Unit List: (continued) PP. System 34 – Heating Oil Storage Tank S2.236 Heating Oil Storage Tank (42,301 gallons) QQ. System 35 – Wood Chipping Plant PF1.038 Loader transfer to Chipper Grinder PF1.039 Chipper Grinder and discharge of Stockpile RR. System 36 – Fuel Storage S2.237 Gasoline Fuel Storage Tank (500 gallon) SS. System 37 – Bag Machine S2.238 Bags to Bag Machine

**** End of Emission Unit List****

Page 15: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page I - 1

Section I. General Conditions A. Nevada Revised Statute (NRS) 445B.470

Prohibited Acts The Permittee shall not knowingly: 1. Violate any applicable provision, the terms or conditions of any permit or any provision for the filing of information; 2. Fail to pay any fee; 3. Falsify any material statement, representation or certification in any notice or report; or 4. Render inaccurate any monitoring device or method, required pursuant to the provisions of NRS 445B.100 to 445B.450,

inclusive, or NRS 445B.470 to 445B.640, inclusive, or any regulation adopted pursuant to those provisions. B. Nevada Administrative Code (NAC) 445B.22013

Prohibited Discharge The Permittee shall not cause or permit the discharge into the atmosphere from any stationary source of any hazardous air pollutant or toxic regulated air pollutant that threatens the health and safety of the general public, as determined by the Director.

C. NAC 445B.22017 (Federally Enforceable SIP Requirement)

Maximum Opacity 1. Except as otherwise provided in this section and NAC 445B.2202, no owner or operator may cause or permit the discharge

into the atmosphere from any emission unit which is of an opacity equal to or greater than 20 percent. Opacity must be determined by one of the following methods: a. If opacity is determined by a visual measurement, it must be determined as set forth in Reference Method 9 in

Appendix A of 40 CFR Part 60. b. If a source uses a continuous monitoring system for the measurement of opacity, the data must be reduced to 6-minute

averages as set forth in 40 CFR 60.13(h). 2. The provisions of this section and NAC 445B.2202 do not apply to that part of the opacity that consists of uncombined

water. The burden of proof to establish the application of this exemption is upon the person seeking to come within the exemption.

D. NAC 445B.22037 (Federally Enforceable SIP Requirement)

Fugitive Dust 1. The Permittee may not cause or permit the handling, transporting, or storing of any material in a manner that allows or may

allow controllable particulate matter to become airborne. 2. Except as otherwise provided in subsection 4, the Permittee may not cause or permit the construction, repair, demolition, or

use of unpaved or untreated areas without first putting into effect an ongoing program using the best practical methods to prevent particulate matter from becoming airborne. As used in this subsection, “best practical methods” includes, but is not limited to, paving, chemical stabilization, watering, phased construction, and revegetation.

3. Except as provided in subsection 4, the Permittee may not disturb or cover 5 acres or more of land or its topsoil until the Permittee has obtained an operating permit for surface area disturbance to clear, excavate, or level the land or to deposit any foreign material to fill or cover the land.

4. The provisions of subsections 2 and 3 do not apply to: a. Agricultural activities occurring on agricultural land; or b. Surface disturbances authorized by a permit issued pursuant to NRS 519A.180 which occur on land which is not less

than 5 acres or more than 20 acres. E. NAC 445B.22067 (Federally Enforceable SIP Requirement)

Open Burning The open burning of any combustible refuse, waste, garbage, oil, or for any salvage operations, except as specifically exempted (see NAC 445B.22067(2)), is prohibited.

Page 16: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page I - 2

Section I. General Conditions (continued) F. NAC 445B.22087

Odors The Permittee may not discharge or cause to be discharged, from any stationary source, any material or regulated air pollutant which is or tends to be offensive to the senses, injurious or detrimental to health and safety, or which in any way interferes with or prevents comfortable enjoyment of life or property.

G. NAC 445B.225 (Federally Enforceable SIP Requirement)

Prohibited Conduct: Concealment of Emissions The Permittee may not install, construct or use any device which conceals any emission without reducing the total release of regulated air pollutants to the atmosphere.

H. NAC 445B.252 (Federally Enforceable SIP Requirement)

Testing and Sampling 1. To determine compliance with NAC 445B.001 to 445B.3497, inclusive, before the approval or the continuance of an

operating permit or similar class of permits, the Director may either conduct or order the owner of any stationary source to conduct or have conducted such testing and sampling as the Director determines necessary. Testing and sampling or either of them must be conducted and the results submitted to the Director within 60 days after achieving the maximum rate of production at which the affected facility will be operated, but not later than 180 days after initial start-up of the facility and at such other times as may be required by the Director.

2. Tests of performance must be conducted and data reduced in accordance with the methods and procedures of the test contained in each applicable subsection of this section unless the Director: a. Specifies or approves, in specific cases, the use of a reference method with minor changes in methodology; or b. Waives the requirement for tests of performance because the owner or operator of a stationary source has

demonstrated by other means to the Director’s satisfaction that the affected facility is in compliance with the standard. 3. Tests of performance must be conducted under such conditions as the Director specifies to the operator of the plant based on

representative performance of the affected facility. The owner or operator shall make available to the Director such records as may be necessary to determine the conditions of the test of performance. Operations during periods of start-up, shutdown and malfunction must not constitute representative conditions of a test of performance unless otherwise specified in the applicable standard.

4. The owner or operator of an affected facility shall give notice to the Director 30 days before the test of performance to allow the Director to have an observer present. A written testing procedure for the test of performance must be submitted to the Director at least 30 days before the test of performance to allow the Director to review the proposed testing procedures.

5. Each test of performance must consist of at least three separate runs using the applicable method for that test. Each run must be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic means of results of the runs apply. In the event of forced shutdown, failure of an irreplaceable portion of the sampling train, extreme meteorological conditions or other circumstances with less than three valid samples being obtained, compliance may be determined using the arithmetic mean of the results of the other two runs upon the Director’s approval.

7. The cost of all testing and sampling and the cost of all sampling holes, scaffolding, electric power and other pertinent allied facilities as may be required and specified in writing by the Director must be provided and paid for by the owner of the stationary source.

8. All information and analytical results of testing and sampling must be certified as to their truth and accuracy and as to their compliance with all provisions of these regulations, and copies of these results must be provided to the Director no later than 60 days after the testing or sampling, or both.

Page 17: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page I - 3

Section I. General Conditions (continued) H. NAC 445B.252 (Federally Enforceable SIP Requirement) (continued)

Testing and Sampling (continued) 9. Notwithstanding the provisions of subsection 2, the Director shall not approve an alternative method or equivalent method to

determine compliance with a standard or emission limitation contained in Part 60, 61 or 63 of Title 40 of the Code of Federal Regulations for: a. An emission unit that is subject to a testing requirement pursuant to Part 60, 61 or 63 of Title 40 of the Code of

Federal Regulations; or b. An affected source.

I. NAC 445B.273(1)

Schedules for Compliance The Permittee must comply with NAC 445B.001 to 445B.3689, inclusive. Existing stationary sources are in compliance with those sections and may continue to operate under the provisions of their approved compliance schedules, which may be amended from time to time.

J. NAC 445B.315(3)(i) (Federally Enforceable SIP Requirement) Fees

The Permittee shall pay fees to the Director in accordance with the provisions set forth in NAC 445B.327 and 445B.331. K. NAC 445B.319 (Federally Enforceable SIP Requirement) Administrative Amendment

Any changes to the operating permit to construct will comply with all provisions established under NAC 445B.319. L. NAC 445B.326(1)

Assertion of Emergency as Affirmative Defense to Action for Noncompliance The Permittee may assert an affirmative defense to an action brought for noncompliance with a technology-based emission limitation contained in the operating permit if the holder of the operating permit demonstrates through signed, contemporaneous operating logs or other relevant evidence that: 1. An emergency occurred and the holder of the operating permit can identify the cause of the emergency; 2. The facility was being properly operated at the time of the emergency; 3. During the emergency, the holder of the operating permit took all reasonable steps to minimize excess emissions; and 4. The holder of the operating permit submitted notice of the emergency to the Director within 2 working days after the

emergency. The notice must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective actions taken to restore the normal operation of the facility.

M. NAC 445B.3265

Revocation and Reissuance 1. An operating permit may be revoked if the control equipment is not operating. 2. An operating permit may be revoked by the Director upon determination that there has been a violation of NAC 445B.001 to

445B.3689, inclusive, or the provisions of 40 CFR Part 52.21, or 40 CFR Part 60 or 61, Prevention of Significant Deterioration, New Source Performance Standards, and National Emission Standards for Hazardous Air Pollutants, adopted by reference in NAC 445B.221.

3. The revocation is effective 10 days after the service of a written notice, unless a hearing is requested. N. NAC 445B.3365(2)(c) (Federally Enforceable SIP Requirement)

Severability Each of the conditions and requirements of the operating permit to construct is severable and, if any are held invalid, the remaining conditions and requirements continue in effect.

Page 18: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page I - 4

Section I. General Conditions (continued)

O. NAC 445B.3365(2)(d) (Federally Enforceable SIP Requirement) Noncompliance with Conditions The Permittee shall comply with all conditions of this operating permit to construct. Any noncompliance constitutes a violation and is a ground for: 1. An action for noncompliance; 2. The revoking and reissuing, or the terminating, of the operating permit to construct by the Director; or 3. The reopening or revising of the operating permit to construct by the holder of the operating permit to construct as directed

by the Director. P. NAC 445B.3365(2)(e) (Federally Enforceable SIP Requirement)

Need to Halt or Reduce Activity to Maintain Compliance The need to halt or reduce activity to maintain compliance with the conditions of the operating permit to construct is not a defense to noncompliance with any condition of the operating permit to construct.

Q. NAC 445B.3365(2)(f) (Federally Enforceable SIP Requirement)

Revise, Revoke and Reissue, Reopen and Revise or Terminate The Director may revise, revoke and reissue, reopen and revise, or terminate the operating permit to construct for cause.

R. NAC 445B.3365(2)(g) (Federally Enforceable SIP Requirement)

Property Rights The operating permit to construct does not convey any property rights or any exclusive privilege.

S. NAC 445B.3365(2)(h) (Federally Enforceable SIP Requirement)

Request for Information The Permittee shall provide the Director, in writing and within a reasonable time, with any information that the Director requests to determine whether cause exists for revoking or terminating the operating permit to construct, or to determine compliance with the conditions of the operating permit to construct.

T. NAC 445B.3365(2)(i) (Federally Enforceable SIP Requirement)

Right to Entry The Permittee shall allow the Director or any authorized representative of the Director, upon presentation of credentials, to: 1. Enter upon the premises of the Permittee where:

a. The stationary source is located; b. Activity related to emissions is conducted; or c. Records are kept pursuant to the conditions of the operating permit to construct.

2. Have access to and copy, during normal business hours, any records that are kept pursuant to the conditions of the operating permit to construct;

3. Inspect, at reasonable times, any facilities, practices, operations, or equipment, including any equipment for monitoring or controlling air pollution, that are regulated or required pursuant to the operating permit to construct; and

4. Sample or monitor, at reasonable times, substances or parameters to determine compliance with the conditions of the operating permit to construct or applicable requirements.

U. NAC 445B.3365(2)(j) (Federally Enforceable SIP Requirement)

Certification A responsible official of the Permittee shall certify that, based on information and belief formed after reasonable inquiry, the statements made in any document required to be submitted by any condition of the operating permit to construct are true, accurate and complete.

Page 19: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page I - 5

Section I. General Conditions (continued) V. NAC 445B.342 (Federally Enforceable SIP Requirement)

Notification of Authorized Changes Any changes to the operating permit to construct will comply with all provisions established under NAC 445B.342.

****End of General Conditions****

Page 20: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page II - 1

Section II. General Construction Conditions A. NAC 445B.250 (Federally Enforceable SIP Requirement)

Notification The Permittee subject to the provisions of NAC 445B.001 to 4445B.3689, inclusive, shall furnish the Director written notification of: 1. The date that construction of S2.001 – S2.239 and PF1.001 – PF1.039, each, is commenced, postmarked no later than 30

days after such date. This requirement does not apply in the case of mass-produced facilities which are purchased in completed form.

2. The anticipated date of initial start-up S2.001 – S2.239 and PF1.001 – PF1.039, each, postmarked not more than 60 days and not less than 30 days before such date.

3. The actual date of initial start-up of S2.001 – S2.239 and PF1.001 – PF1.039, each, postmarked within 15 days after such date.

B. 40 CFR 60.7(a)(4)

Notification A notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, unless that change is specifically exempted under an applicable subpart or in §60.14(e). This notice shall be postmarked 60 days or as soon as practicable before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change.

C. NAC 445B.3366 (Federally Enforceable SIP Requirement)

Expiration 1. If construction will occur in one phase, an operating permit to construct for a new or modified stationary source expires if

construction is not commenced within 18 months after the date of issuance thereof or construction of the facility is delayed for 18 months after initiated. The Director may extend the date on which the construction may be commenced upon a showing that the extension is justified.

2. If construction will occur in more than one phase, the projected date of the commencement of construction of each phase of construction must be approved by the Director. An operating permit to construct expires if the initial phase of construction is not commenced within 18 months after the projected date of the commencement of construction approved by the Director. The Director may extend only the date on which the initial phase of construction may be commenced upon a showing that the extension is justified.

3. Except as otherwise provided in this subsection, an operating permit to construct expires if a complete application for a Class I operating permit or modification of an existing Class I operating permit is not submitted within 12 months after the date of initial start-up.

****End of General Construction Conditions****

Page 21: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 1

Section IIA. Specific Construction Requirements A. Initial Opacity Compliance Demonstration and Initial Performance Tests (NAC 445B.22017, NAC 445B.252, and NAC

445B.3405) The Permittee, upon issuance of this operating permit, shall conduct initial performance tests within 90 days after permit issuance. The Permittee shall follow the test methods and procedures referenced in Table IIA-1 and Table IIA-2 below:

Table IIA-1: Initial Opacity Performance Tests

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 01 – Unit #1 and #2 Ore Crushing Circuit PF1.001

Opacity

Method 9 in Appendix A of 40 CFR Part 60 shall be used to determine opacity. Opacity observations shall be conducted

concurrently with the applicable performance test. The minimum total time of observations shall be six minutes (24 consecutive observations recorded at 15 second intervals),

unless otherwise specified by an applicable subpart.

System 16 – Unit #3 Ore Crushing Circuit PF1.019

System 23A – Unit #1 and Unit #2 Soda Ash Bin –

Loading S2.184 and S2.185

System 23B – Unit #1 and Unit #2 Soda Ash Bin –

Unloading

PF1.024 and PF1.025

System 24A – Unit #3 Soda Ash Bin – Loading S2.186

System 24B – Unit 33 Soda Ash Bin – Unloading PF1.026

System 25 – Soda Ash Processing PF1.027 – PF1.032

System 27 – Perlite Sizing and Drying PF1.033

System 29 – Perlite Sizing and Drying S2.204 – S2.213

System 35 – Wood Chipper Plant

PF1.038 and PF1.039

System 01 – Unit #1 and #2 Ore Crushing Circuit PF1.002 – PF1.006

Opacity

Method 9 in Appendix A of 40 CFR Part 60 shall be used to determine opacity. Opacity observations shall be conducted

concurrently with the applicable performance test. The minimum total time of observations shall be 3 hours (30 6-minute averages) in accordance with 40 CFR 60.11 per 40

CFR Part 60, Subpart OOO.

System 02 – Unit #1 and #2 Ore Crushing Circuit PF1.007

System 03 – Unit #1 and #2 Ore Crushing Unit

PF1.008 and PF1.009

System 04 – Unit #1 Classification and Drying PF1.010 – PF1.013

System 05A – Unit #1 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.001A – S2.008A and S2.011A –

S2.017A

System 05B – Unit #1 Classification and Drying ,

#2 Fuel Oil (Alternate Operating Scenario)

S2.001B – S2.008B and S2.011B –

S2.017B

Page 22: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 2

Section IIA. Specific Construction Requirements (continued)

Table IIA-1: Initial Opacity Performance Tests

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 05C – Unit #1 Classification and Drying ,

Waste Oil (Alternate Operating Scenario)

S2.001C – S2.008C and S2.011C –

S2.017C

Opacity

Method 9 in Appendix A of 40 CFR Part 60 shall be used to determine opacity. Opacity observations shall be conducted

concurrently with the applicable performance test. The minimum total time of observations shall be 3 hours (30 6-minute averages) in accordance with 40 CFR 60.11 per 40

CFR Part 60, Subpart OOO.

System 06 – Unit #1 Classification and Drying S2.018 – S2.031

System 08 – Unit #1 Bulk Loading and Packing S2.051 and S2.052

System 09 – Unit #2 Classification and Drying PF1.014 – PF1.018

System 10A – Unit #2 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.053A – S2.058A and S2.061A –

S2.063A

System 10B – Unit #2 Classification and Drying,

#2 Fuel Oil (Alternate Operating Scenario)

S2.053B – S2.058B and S2.061B –

S2.063B

System 10C – Unit #2 Classification and Drying,

Waste Oil (Alternate Operating Scenario)

S2.053C – S2.058C and S2.061C –

S2.063C

System 12 – Unit #2 Classification and Drying S2.066 – S2.081

System 13 – Unit #2 Classification and Drying

S2.082 – S2.103 and S2.239

System 14 – Unit #2 Bulk Loading and Packing S2.104 – S2.111

System 15 – Unit #2 Bulk Loading and Packing S2.112

System 17 – Unit #3 Ore Crushing Unit S2.113 – S2.118

System 18 – Unit #3 Ore Crushing Unit PF1.020 – PF1.023

System 19A – Unit #3 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.119A – S2.124A and S2.127A –

S2.131A

System 19B – Unit #3 Classification and Drying,

#2 Fuel Oil (Alternate Operating Scenario)

S2.119B – S2.124B and S2.127B –

S2.131B

Page 23: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 3

Section IIA. Specific Construction Requirements (continued)

Table IIA-1: Initial Opacity Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 19C – Unit #3 Classification and Drying,

Waste Gas (Alternate Operating Scenario)

S2.119C – S2.124C and S2.127C – S2.131C

Opacity

Method 9 in Appendix A of 40 CFR Part 60 shall be used to determine opacity. Opacity observations shall be

conducted concurrently with the applicable performance test. The minimum total time of observations shall be 3

hours (30 6-minute averages) in accordance with 40 CFR 60.11 per 40 CFR Part 60, Subpart OOO.

System 20 – Unit #3 Classification and Drying S2.132 – S2.153

System 26 – Waste Bin Operation S2.187 –S2.189

System 27 – Perlite Sizing and Drying PF1.034 and PF1.035

System 28 – Perlite Sizing and Drying S2.190 – S2.203

System 30 – Perlite Transfer/Perlite Expander

and Classification S2.214 – S2.221

System 28 – Perlite Sizing and Drying

S2.190 – S2.194 and S2.196 – S2.203

System 37 – Bag Machine S2.238 System 05A – Unit #1

Classification and Drying, Natural Gas (Primary Operating Scenario)

S2.009A and S2.010A

Opacity

Method 9 in Appendix A of 40 CFR Part 60 shall be used to determine opacity. Opacity observations shall be

conducted concurrently with the applicable performance test. The minimum total time of observations shall be 18

minutes (three 6-minute averages) each day in accordance with 40 CFR Part 60, Subpart UUU.

System 05B – Unit #1 Classification and Drying , #2 Fuel Oil (Alternate

Operating Scenario)

S2.009B and S2.010B

System 05C – Unit #1 Classification and Drying

, Waste Oil (Alternate Operating Scenario)

S2.009C and S2.010C

System 10A – Unit #2 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.059A and S2.060A

System 10B – Unit #2 Classification and Drying,

#2 Fuel Oil (Alternate Operating Scenario)

S2.059B and S2.060B

Page 24: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 4

Section IIA. Specific Construction Requirements (continued)

Table IIA-1: Initial Opacity Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 10C – Unit #2 Classification and Drying, Waste Oil

(Alternate Operating Scenario)

S2.059C and S2.060C

Opacity

Method 9 in Appendix A of 40 CFR Part 60 shall be used to determine opacity. Opacity observations shall be conducted

concurrently with the applicable performance test. The minimum total time of observations shall be 18 minutes

(three 6-minute averages) each day in accordance with 40 CFR Part 60, Subpart UUU.

System 19A – Unit #3 Classification and

Drying, Natural Gas (Primary Operating

Scenario)

S2.125A and S2.126A

System 19B – Unit #3 Classification and

Drying, #2 Fuel Oil (Alternate Operating

Scenario)

S2.125B and S2.126B

System 19C – Unit #3 Classification and

Drying, #2 Fuel Oil (Alternate Operating

Scenario)

S2.125C and S2.126C

System 28 – Perlite Sizing and Drying S2.195

System 30 – Perlite Transfer/Perlite Expander

and Classification S2.220

Page 25: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 5

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 05A – Unit #1 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.001A – S2.017A

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.009A and S2.010A

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (311-BF01) and (311-BF02), each, and the static pressure of S2.009A concurrently with the applicable performance tests.

Page 26: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 6

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 05B – Unit #1 Classification and Drying,

#2 Fuel Oil (Alternate Operating Scenario)

S2.001B – S2.017B

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.009B and S2.010B

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to determine the carbon monoxide concentration. Each test will

be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (311-BF01) and (311-BF02), each, and the static pressure of S2.009B concurrently with the applicable performance tests.

Page 27: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 7

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 05C – Unit #1 Classification and Drying,

Waste Oil (Alternate Operating Scenario)

S2.001C – S2.017C

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.009C and S2.010C

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (311-BF01) and (311-BF02), each, and the static pressure of S2.009C concurrently with the applicable performance tests.

Page 28: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 8

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 06 – Unit #1 Classification and Drying

S2.018 – S2.031

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (331-BF01) concurrently with the applicable

performance tests.

System 07 – Unit #1 Classification and Drying

S2.032 – S2.050

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (401-BF01) concurrently with the applicable

performance tests.

System 08 – Unit #1 Bulk Loading and Packing

S2.051 and S2.052

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (401-BF02) concurrently with the applicable

performance tests.

Page 29: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 9

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 10A – Unit #2 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.053A – S2.063A

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.059A and S2.060A

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (312-BF01) and (312-BF02), each, and the static pressure of S2.059A concurrently with the applicable performance tests.

Page 30: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 10

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 10B – Unit #2 Classification and Drying,

#2 Fuel Oil (Alternate Operating Scenario)

S2.053B – S2.063B

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.059B and S2.060B

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (312-BF01) and (312-BF02), each, and the static pressure of S2.059B concurrently with the applicable performance tests.

Page 31: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 11

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 10C – Unit #2 Classification and Drying,

Waste Oil (Alternate Operating Scenario)

S2.053C – S2.063C

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.059C and S2.060C

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (312-BF01) and (312-BF02), each, and the static pressure of S2.059C concurrently with the applicable performance tests.

Page 32: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 12

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 12 – Unit #2 Classification and Drying

S2.066 – S2.081

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (332-BF01) concurrently with the applicable

performance tests.

System 13 – Unit #2 Classification and Drying

S2.082 – S2.103 and S2.239

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (402-BF01) concurrently with the applicable

performance tests.

System 14 – Unit #2 Bulk Loading and Packing

S2.104 – S2.111

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (402-BF02) concurrently with the applicable

performance tests.

Page 33: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 13

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 15 – Unit #2 Bulk Loading and Packing

S2.112

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (371-BF01) concurrently with the applicable

performance tests.

System 17 – Unit #3 Ore Crushing Circuit

S2.113 – S2.118

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (313-BF04) concurrently with the applicable

performance tests.

System 19A – Unit #3 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.119A – S2.131A

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.125A and S2.126A

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

Page 34: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 14

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 19A – Unit #3 Classification and Drying,

Natural Gas (Primary Operating Scenario)

S2.125A and S2.126A

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (313-BF01) and (313-BF02), each, and the static pressure of S2.125A concurrently with the applicable performance tests.

System 19B – Unit #3 Classification and Drying,

#2 Fuel Oil (Primary Operating Scenario)

S2.119B – S2.13B

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.125B and S2.126B

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

Page 35: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 15

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 19B – Unit #3 Classification and Drying,

#2 Fuel Oil (Alternate Operating Scenario)

S2.119B – S2.13B VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (313-BF01) and (313-BF02), each, and the static pressure of S2.125B concurrently with the applicable performance tests.

System 19C – Unit #3 Classification and Drying,

Waste Oil (Alternate Operating Scenario)

S2.125C and S2.126C

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.119C – S2.13C

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (313-BF01) and (313-BF02), each, and the static pressure of S2.125C concurrently with the applicable performance tests.

Page 36: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 16

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 20 – Unit #3 Classification and Drying

S2.132 – S2.153

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (333-BF01) and (333-BF02), and (333-BF03), each,

concurrently with the applicable performance tests.

System 21 – Unit #3 Classification and Drying

S2.154 – S2.180

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (403-BF01) concurrently with the applicable

performance tests.

System 22 – Unit #3 Classification and Drying

S2.181 – S2.183

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (403-BF02) concurrently with the applicable

performance tests.

Page 37: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 17

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 26 – Waste Bin Operation

S2.187 – S2.189

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (36A-BF01) concurrently with the applicable

performance tests.

System 28 – Perlite Sizing and Drying

S2.190 – S2.194 and S2.196 – S2.203

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.195

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

Page 38: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 18

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 28 – Perlite Sizing and Drying

S2.195 VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (314-BF01) of S2.195 with the applicable performance tests.

System 29 – Perlite Sizing and Drying

S2.204 – S2.213

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (364-BF01) concurrently with the applicable

performance tests.

System 30 – Perlite Transfer/Perlite Expander

and Classification

S2.214 – S2.219 and S2.221

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A and Method 202 in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions.

The sample time and sample volume collected for each test run shall be sufficient to collect enough mass to weigh accurately. The Method 201A and 202 test required in this section may be replaced by a Method 5 in Appendix A of 40 CFR Part 60 and

Method 202 in Appendix M of 40 CFR Part 51 test. All particulate captured in the Method 5 and Method 202 test

performed under this provision shall be considered PM2.5 for determination of compliance.

S2.220

SO2 Method 6C in Appendix A of 40 CFR Part 60 shall be used to determine the sulfur dioxide concentration. Each test will be

run for a minimum of one hour.

NOX Method 7E in Appendix A of 40 CFR Part 60 shall be used to determine the nitrogen oxides concentration. Each test will be

run for a minimum of one hour.

Page 39: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 19

Section IIA. Specific Construction Requirements (continued)

Table IIA-2: Initial Performance Tests (continued)

System Emission Unit(s) Pollutants To Be Tested Testing Methods/Procedures

System 30 – Perlite Transfer/Perlite Expander

and Classification

S2.220

CO Method 10 in Appendix A of 40 CFR Part 60 shall be used to

determine the carbon monoxide concentration. Each test will be run for a minimum of one hour.

VOC

Method 25A in Appendix A of 40 CFR Part 60 shall be used to determine the volatile organic compound concentration.

Method 18 in Appendix A of 40 CFR Part 60 or Method 320 in Appendix A of CFR Part 63 may be used in conjunction with Method 25A to break out the organic compounds that are not

considered VOC’s by definition per 40 CFR 51.100(s). Each Method 25A test will be run for a minimum of one hour.

Monitor and record the pressure drop of Baghouse (334-BF01) concurrently with the applicable performance tests.

System 31 – Perlite Transfer/Perlite Expander

and Classification

S2.222 – S2.232

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (334-BF02) concurrently with the applicable

performance tests.

System 33 – Ribbon Blender

S2.233 – S2.235

PM

Method 5 in Appendix A of 40 CFR Part 60 shall be used to determine PM emissions. The sample volume for each test run

shall be at least 1.7 dscm (60 dscf). Test runs must be conducted for up to two hours in an effort to collect this

minimum sample.

PM10/PM2.5

Method 201A in Appendix M of 40 CFR Part 51 shall be used to determine PM10 and PM2.5 emissions. The sample time and sample volume collected for each test run shall be sufficient to

collect enough mass to weigh accurately. Monitor and record the pressure drop of Baghouse (40A-BF02) concurrently with the applicable

performance tests. 2. All initial opacity compliance demonstrations and initial performance tests must comply with the advance notification,

protocol review, operational conditions, reporting, and other requirements of Section I.S. Testing and Sampling (NAC 445B.252) and Section I.T. Testing and Sampling (SIP NAC 445B.252) of this operating permit. Material sampling must be conducted in accordance with protocols approved by the Director. All initial performance test results shall be based on the arithmetic average of three valid runs. (NAC 445B.252(5))

Page 40: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IIA - 20

Section IIA. Specific Construction Requirements (continued)

3. All initial opacity compliance demonstrations and initial performance tests must comply with the advance notification, protocol review, operational conditions, reporting, and other requirements of Section I.S. Testing and Sampling (NAC 445B.252) and Section I.T. Testing and Sampling (SIP NAC 445B.252) of this operating permit. Material sampling must be conducted in accordance with protocols approved by the Director. All initial performance test results shall be based on the arithmetic average of three valid runs. (NAC 445B.252(5))

4. Testing shall be conducted on the exhaust stack (post controls). 5. Initial opacity compliance demonstrations and initial performance tests in Table IIA-1 and Table IIA-2 above, must be

conducted under such conditions as the Director specifies to the operator of the plant based on representative performance of the affected facility. The Permittee shall make available to the Director such records as may be necessary to determine the conditions of the initial opacity compliance demonstrations and initial performance tests. Operations during periods of startup, shutdown and malfunction must not constitute representative conditions of the initial opacity compliance demonstrations and initial performance tests unless otherwise specified in the applicable standard. (NAC 445B.252(3))

6. The Permittee shall give notice to the Director 30 days before the initial opacity compliance demonstrations and initial performance tests to allow the Director to have an observer present. A written testing procedure must be submitted to the Director at least 30 days before the initial opacity compliance demonstrations and initial performance tests to allow the Director to review the proposed testing procedures. (NAC 445B.252(4) and 40 CFR Part 60.7(a)(6))

7. Within 60 days after completing the initial opacity compliance demonstrations and initial performance tests contained in Table IIA-1 and Table IIA-2 of this section, the Permittee shall furnish the Director a written report of the results. All information and analytical results of testing and sampling must be certified as to the truth and accuracy and as to their compliance with NAC 445B.001 to 445B.3689, inclusive. (NAC 445B.252(8))

8. Initial opacity compliance demonstrations and initial performance tests required under this section that are conducted below the maximum allowable throughput, shall be subject to the Director’s review to determine if the throughputs during the initial opacity compliance demonstrations and initial performance tests sufficient to provide adequate compliance demonstration. Should the Director determine that the initial opacity compliance demonstrations and initial performance tests do not provide adequate compliance demonstration, the Director may require additional testing.

****End of Specific Construction Conditions****

Page 41: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page III - 1

Section III. General Operating Conditions A. NAC 445B.227 (Federally Enforceable SIP Requirement)

Prohibited Conduct The Permittee may not: 1. Operate a stationary source of air pollution unless the control equipment for air pollution that is required by applicable

requirements or conditions of the permit is installed and operating. 2. Disconnect, alter, modify or remove any of the control equipment for air pollution or modify any procedure required by an

applicable requirement or condition of the permit. B. NAC 445B.232

Excess Emissions: Schedule Maintenance, Testing or Repairs; Notification of Director 1. Scheduled maintenance or testing or scheduled repairs which may result in excess emissions of regulated air pollutants

prohibited by NAC 445B.001 to 445B.3689, inclusive, must be approved in advance by the Director and performed during a time designated by the Director as being favorable for atmospheric ventilation.

2. Each owner or operator shall notify the Director of the proposed time and expected duration at least 30 days before any scheduled maintenance or testing which may result in excess emissions of regulated air pollutants prohibited by NAC 445B.001 to 445B.3689, inclusive. The scheduled maintenance or testing must not be conducted unless the scheduled maintenance or testing is approved pursuant to subsection 1.

3. Each owner or operator shall notify the Director of the proposed time and expected duration at least 24 hours before any scheduled repairs which may result in excess emissions of regulated air pollutants prohibited by NAC 445B.001 to 445B.3689, inclusive. The scheduled repairs must not be conducted unless the scheduled repairs are approved pursuant to subsection 1.

4. Each owner or operator shall notify the Director of any excess emissions within 24 hours after any malfunction or upset of the process equipment or equipment for controlling pollution or during start-up or shutdown of that equipment. Email to: [email protected]

5. Each owner or operator shall provide the Director, within 15 days after any malfunction, upset, start-up, shutdown or human error which results in excess emissions, sufficient information to enable the Director to determine the seriousness of the excess emissions. The information must include at least the following: a. The identity of the stack or other point of emission, or both, where the excess emissions occurred. b. The estimated magnitude of the excess emissions expressed in opacity or in the units of the applicable limitation on

emission and the operating data and methods used in estimating the magnitude of the excess emissions. c. The time and duration of the excess emissions. d. The identity of the equipment causing the excess emissions. e. If the excess emissions were the result of a malfunction, the steps taken to remedy the malfunction and the steps taken

or planned to prevent the recurrence of the malfunction. f. The steps taken to limit the excess emissions. g. Documentation that the equipment for controlling air pollution, process equipment or processes were at all times

maintained and operated, to a maximum extent practicable, in a manner consistent with good practice for minimizing emissions.

6. Each owner or operator shall ensure that any notification or related information submitted to the Director pursuant to this section is provided in a format specified by the Director.

Page 42: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page III - 2

Section III. General Operating Conditions (continued) C. SIP 445.667 (Federally Enforceable SIP Requirement)

Excess Emissions: Scheduled Maintenance; Testing; Malfunctions 1. Scheduled maintenance or testing approved by the Director or repairs which may result in excess emissions of air

contaminants prohibited by SIP 445.430 to 445.846, inclusive, must be performed during a time designated by the Director as being favorable for atmospheric ventilation.

2. The Director shall be notified in writing on the time and expected duration at least 24 hours in advance of any scheduled maintenance or repairs which may result in excess emissions of air contaminants prohibited by SIP 445.430 to 445.846, inclusive.

3. The Director must be notified within 24 hours after any malfunction, breakdown or upset of process or pollution control equipment or during startup of such equipment.

4. The owner or operator of an affected facility shall provide the Director, within 15 days after any malfunction, breakdown, upset, startup or human error sufficient information to enable the Director to determine the seriousness of the excess emissions. The submission must include as a minimum: a. The identity of the stack and/or other emission point where the excess emission occurred. b. The estimated magnitude of the excess emissions expressed in opacity or in the units of the applicable emission

limitation and the operating data and methods used in estimating the magnitude of the excess emissions. c. The time and duration of the excess emissions. d. The identity of the equipment causing the excess emissions. e. If the excess emissions were the result of a malfunction, steps taken to remedy the malfunction and the steps taken or

planned to prevent the recurrence of the malfunctions. f. The steps taken to limit the excess emissions. g. Documentation that the air pollution control equipment, process equipment or processes were at all times maintained

and operated, to a maximum extent practicable, in a manner consistent with good practice for minimizing emissions. D. SIP Article 2.5.4 (Federally Enforceable SIP Requirement) Scheduled Maintenance, Testing, and Breakdown or Upset Breakdown or upset, determined by the Director to be unavoidable and not the result of careless or marginal operations, shall not

be considered a violation of the regulations.

****End of General Operating Conditions****

Page 43: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 1

Section IV. General Monitoring, Recordkeeping, and Reporting Requirements A. NAC 445B.3365(2)(b) (Federally Enforceable SIP Requirement)

Records The Permittee shall retain records of all required monitoring data and supporting information for 5 years from the date of the sample collection, measurement, report or analysis. Supporting information includes, but is not limited to, all records regarding calibration and maintenance of the monitoring equipment and all original strip-chart recordings for continuous monitoring instrumentation.

B. NAC 445B.3365(2)(h) (Federally Enforceable SIP Requirement)

Reporting The Permittee shall provide the Director, in writing and within a reasonable time, with any information that the Director requests to determine whether cause exists for revoking or terminating the operating permit to construct, or to determine compliance with the conditions of the operating permit to construct. The Permittee will submit yearly reports including, but not limited to, throughput, production, fuel consumption, hours of operation, and emissions. These reports will be submitted on the form provided by the Bureau of Air Pollution Control for all emission units/systems specified on the form. The completed form must be submitted to the Bureau of Air Pollution Control no later than March 1 annually for the preceding calendar year, unless otherwise approved by the Bureau of Air Pollution Control.

C. NAC 445B.265(1) (Federally Enforceable SIP Requirement)

Records of the Occurrence and Duration of Any Start-Up, Shutdown or Malfunction The Permittee subject to the provisions of NAC 445B.256 to 445B.267, inclusive, shall maintain records of the occurrence and duration of any start-up, shutdown or malfunction in the operation of an affected facility and any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative.

****End of General Monitoring, Recordkeeping, and Reporting Requirements****

Page 44: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 2

Section V. Specific Operating Conditions (continued) A. Emission Units PF1.001 – PF1.006

PF1.001 Location: North 4,456,052 m, East 381,837 m, UTM (Zone 11, NAD 83) PF1.002 Location: North 4,456,052 m, East 381,837 m, UTM (Zone 11, NAD 83) PF1.003 Location: North 4,456,051 m, East 381,836 m, UTM (Zone 11, NAD 83) PF1.004 Location: North 4,456,886 m, East 381,856 m, UTM (Zone 11, NAD 83) PF1.005 Location: North 4,455,883 m, East 381,861 m, UTM (Zone 11, NAD 83) PF1.006 Location: North 4,455,897 m, East 381,845 m, UTM (Zone 11, NAD 83)

System 01 – Unit #1 and #2 Ore Crushing Circuit PF1.001 Unloading from Truck to Hopper (31A-HP01) PF1.002 Hopper (31A-HP01) and transfer to Pan Feed (31A-AF01)

PF1.003 Pan Feed (31A-AF01) and transfer to Belt Conveyor (31A-BC01), Screw Conveyor (31A-SC01), or Ring Hammermill (31A-HC01)

PF1.004 Screw Conveyor (31A-SC01) and transfer to Bucker Elevator (31A-BE01) PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket Elevator (31A-BE02)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.001 – PF1.006, each, shall be controlled by Covers and Windscreens. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.001 – PF1.006, each, shall not exceed 50.0 tons of diatomite per any one-hour period, nor more than 171,000.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.001 – PF1.006, each, may operate 24 hours per day. (2) PF1.001 – PF1.006, each, may operate 6,500 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.001 – PF1.006, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.15 pound per hour, nor more than 0.26

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.055 pound per hour, nor more than 0.094 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.008 pound per hour, nor more than 0.014 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.001 – PF1.006, each, shall not

equal or exceed 20 percent.

Page 45: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 3

Section V. Specific Operating Conditions (continued)

A. Emission Units PF1.001 – PF1.006 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.001 – PF1.006, each. b. Monitor and record the total daily hours of operation for PF1.001 – PF1.006, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.001 – PF1.006, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in A.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.001 – PF1.006, each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in A.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.002 – PF1.006, each, will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.002 – PF1.006, each, will not exceed 7 percent opacity. (40 CFR Part

60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under 40 CFR Part 60 Subpart OOO and under subpart A of 40 CFR Part 60 to

demonstrate compliance with 40 CFR Part 60 Subpart OOO need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 46: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 4

Section V. Specific Operating Conditions (continued)

B. Emission Unit PF1.007 Location: North 4,455,897 m, East 381,845 m, UTM (Zone 11, NAD 83)

System 02 – Unit #1 and #2 Ore Crushing Circuit PF1.007 Ring Hammermill (31A-HC01) and discharge to Bucket Elevator (31A-BE02)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.007 shall be controlled by Covers and Windscreens. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.007 shall not exceed 50.0 tons of diatomite per any one-hour period, nor more than 171,000.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.007 may operate 24 hours per day. (2) PF1.007 may operate 6,500 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.007 the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.27 pound per hour, nor more than 0.46

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.12 pound per hour, nor more than 0.21 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.018 pound per hour, nor more than 0.031 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.007 shall not equal or exceed 20

percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.007. b. Monitor and record the total daily hours of operation for PF1.007. c. Record the average hourly throughput rate (in tons per hour) for PF1.007 using the total daily throughput and total

daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in B.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.007 on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

Page 47: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 5

Section V. Specific Operating Conditions (continued) B. Emission Unit PF1.007 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in B.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.007 will be operated, but not

later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.007 will not exceed 12 percent opacity. (40 CFR Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under 40 CFR Part 60 Subpart OOO and under subpart A of 40 CFR Part 60 to

demonstrate compliance with 40 CFR Part 60 Subpart OOO need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 48: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 6

Section V. Specific Operating Conditions (continued) C. Emission Units PF1.008 and PF1.009

PF1.008 Location: North 4,455,897 m, East 381,845 m, UTM (Zone 11, NAD 83) PF1.009 Location: North 4,455,946 m, East 381,851 m, UTM (Zone 11, NAD 83)

System 03 – Unit #1 and #2 Ore Crushing Unit PF1.008 Bucket Elevator (31A-BE02) and discharge to Ore Bin (31A-BI01), Ore Bin (31A-BI02), Conveyor (31A-BC02) PF1.009 Conveyor (31A-BC02) and discharge to Ore Bin (31A-BI03) and Ore Bin (31A-BI04)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.008 and PF1.009, each, shall be controlled by Covers and Windscreens. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.008 and PF1.009, each, shall not exceed 50.0 tons of diatomite per any one-hour period, nor more than 171,000.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.008 and PF1.009, each, may operate 24 hours per day. (2) PF1.008 and PF1.009, each, may operate 6,500 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.008 and PF1.009, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.15 pound per hour, nor more than 0.26

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.055 pound per hour, nor more than 0.094 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.008 pound per hour, nor more than 0.014 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.008 and PF1.009, each, shall not

equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.008 and PF1.009, each. b. Monitor and record the total daily hours of operation for PF1.008 and PF1.009, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.008 and PF1.009, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in C.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.008 and PF1.009, each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

Page 49: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 7

Section V. Specific Operating Conditions (continued) C. Emission Units PF1.008 and PF1.009 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in C.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.008 and PF1.009, each, will

be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.008 and PF1.009, each, will not exceed 7 percent opacity. (40 CFR Part

60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under 40 CFR Part 60 Subpart OOO and under subpart A of 40 CFR Part 60 to

demonstrate compliance with 40 CFR Part 60 Subpart OOO need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 50: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 8

Section V. Specific Operating Conditions (continued) D. Emission Units PF1.010 – PF1.013

PF1.010 Location: North 4,455,891 m, East 381,851 m, UTM (Zone 11, NAD 83) PF1.011 Location: North 4,455,883 m, East 381,861 m, UTM (Zone 11, NAD 83) PF1.012 Location: North 4,455,946 m, East 381,851 m, UTM (Zone 11, NAD 83) PF1.013 Location: North 4,455,946 m, East 381,851 m, UTM (Zone 11, NAD 83)

System 04 – Unit #1 Classification and Drying PF1.010 Ore Bin (31A-BI01) and discharge to Pan Feeder (311-AF01) PF1.011 Ore Bin (31A-BI02) and discharge to Pan Feeder (311-AF02) PF1.012 Pan Feeder (311-AF01) and discharge to Hopper (311-HP01) PF1.013 Pan Feeder (311-AF02) and discharge to Hopper (311-HP01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.010 – PF1.013, each, shall be controlled by Covers and Windscreens. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.010 – PF1.013, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A sulfur analyzer shall be calibrated on PF1.012 and PF1.013, each. The sulfur analyzer shall analyze the sulfur content in the diatomite processed.

c. Hours (1) PF1.010 – PF1.013, each, may operate 24 hours per day. (2) PF1.010 – PF1.013, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.010 – PF1.013, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.030 pound per hour, nor more than

0.13 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.011 pound per hour, nor more than 0.047 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.002 pound per hour, nor more than 0.007 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.010 – PF1.013, each, shall not

equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.010 – PF1.013, each, b. Monitor and record the total daily hours of operation for PF1.010 – PF1.013, each, c. Record the average hourly throughput rate (in tons per hour) for PF1.010 – PF1.013, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in D.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 51: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 9

Section V. Specific Operating Conditions (continued) D. Emission Units PF1.010 – PF1.013 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (controlled)

The Permittee, upon issuance of this operating permit, shall: f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.010 – PF1.013, each, on a

monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Monitor and record the sulfur content in weight percent of diatomite on a dry basis. The sulfur content shall be obtained and analyzed by taking a monthly diatomite sample at PF1.012 and PF1.013, each. Sampling for sulfur will be repeated if a new ore material is loaded into the system.

h. The sulfur analyzer shall undergo a precision check on a daily basis when operated. Independent sulfur standard shall be run once per month and the balance will be calibrated once a quarter. The analyzer shall be operated, maintained and calibrated according to manufacturer’s instructions. All samples will be desiccated at a low temperature to preserve the sample integrity and limit the loss of sulfur and combustibles.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in D.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.010 – PF1.013, each, will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.010 – PF1.013, each, will not exceed 7 percent opacity. (40 CFR Part

60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under 40 CFR Part 60 Subpart OOO and under subpart A of 40 CFR Part 60 to

demonstrate compliance with 40 CFR Part 60 Subpart OOO need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 52: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 10

Section V. Specific Operating Conditions (continued) E. Emission Units S2.001A – S2.017A

Location: North 4,455,900 m, East 381,830 m, UTM (Zone 11, NAD 83)

System 05A – Unit #1 Classification and Drying, Natural Gas (Primary Operating Scenario) Revised Month 2019 S2.001A Hopper (311-HP01) and transfer to Cyclone (311-CN01) S2.002A Cyclone (311-CN01) and solids discharge to Cyclone (311-CN02) S2.003A Cyclone (311-CN02) and solids discharge to Whizzer Separator (311-SR01) and fines transfer to Cyclone (311-CN03)

S2.004A Whizzer Separator (311-SR01) and solids discharge to Cyclone (311-CN03) and waste discharge to Screw Conveyor (361-SC01)

S2.005A Cyclone (311-CN03) and discharge to Screw Conveyor (311-SC05) S2.006A Screw Conveyor (361-SC01) and transfer to Waste Bin (361-BI01) S2.007A Screw Conveyor (311-SC05) and transfer to Screw Conveyor (311-SC06) S2.008A Screw Conveyor (311-SC06) and transfer to Rotary kiln (321-KL01) S2.009A Rotary Kiln (321-KL01) and exhaust to Hot Air Furnace (311-HG01)

S2.010A Hot Air Furnace (311-HG01) and exhaust to Cyclone (311-CN01), Cyclone (311-CN02), Baghouse (311-BF01) and Baghouse (311-BF02)

S2.011A Baghouse (311-BF01) and transfer to Screw Conveyor (311-SC01) S2.012A Baghouse (311-BF02) and transfer to Screw Conveyor (311-SC02) S2.013A Screw Conveyor (311-SC01) and transfer to Conveyor (311-SC03) S2.014A Screw Conveyor (311-SC02) and transfer to Conveyor (311-SC03) S2.015A Screw Conveyor (311-SC03) and transfer to Screw Conveyor (311-SC04) and Screw Conveyor (361-SC02) S2.016A Screw Conveyor (311-SC04) and transfer to Conveyor (311-SC05) S2.017A Screw Conveyor (361-SC02) and transfer to Screw Conveyor (361-SC01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.001A – S2.017A, combined, shall be controlled by Baghouse (311-BF01) and (311-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 88.0 feet Stack Diameter: 2.9 feet Stack Temperature: 241.3°F Exhaust Volume Flow Rate: 14,670.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.001A – S2.017A, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. S2.009A and S2.010A, each, may consume only pipe line natural gas as the primary fuel. c. The maximum allowable natural gas consumption rate for S2.009A shall not exceed 29,411.76 standard cubic feet

(scf) per hour, nor more than 251,470,548.0 scf per year, based on a 12-month rolling period. d. The maximum allowable natural gas consumption rate for S2.010A shall not exceed 19,607.84 standard cubic feet

(scf) per hour, nor more than 167,647,032.0 scf per year, based on a 12-month rolling period. e. The maximum sulfur content of the pipeline quality natural gas will not exceed 20 grains per 100 cubic feet. This

default maximum sulfur content, sulfur content provided by the supplier, or test result of the sulfur analysis of the pipeline quality natural gas will be used in the SO2 calculations.

f. A fuel flow meter shall be installed and calibrated on S2.009A and S2.010A, each, if one is not already installed. The fuel flow meter shall continuously monitor fuel consumption.

Page 53: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 11

Section V. Specific Operating Conditions (continued) E. Emission Units S2.001A – S2.017A (continued)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

g. A pressure gauge shall be installed and calibrated on Baghouse (311-BF01) and (311-BF02), each, if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

h. Hours (1) S2.001A – S2.017A, each, may operate 24 hours per day. (2) S2.001A – S2.017A, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (311-BF01) and (311-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 1.50 pounds per hour, nor more than

6.41 tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 1.50 pounds per hour, nor more than 6.41 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 1.50 pounds per hour, nor more than 6.41 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.89

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 10.0 pounds per hour, nor more than

42.76 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 5.0 pounds per hour, nor more than 21.39

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.79 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.009A and S2.010A, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.009A and S2.010A, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.001A – S2.008A and S2.011A – S2.017A, each, shall not exceed 19.18 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.001A – S2.008A and S2.011A – S2.017A, each, shall not exceed 24.78 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (311-BF01) and (311-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.001A – S2.017A, each. b. Monitor and record the total daily hours of operation for S2.001A – S2.017A, each. c. Record the average hourly throughput rate (in tons per hour) for S2.001A – S2.017A, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of natural gas consumed (in scf) on a daily basis for S2.009A and S2.010A, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of natural gas (in scf) on a cumulative monthly basis, for each 12-month rolling period.

Page 54: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 12

Section V. Specific Operating Conditions (continued) E. Emission Units S2.001A – S2.017A (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in E.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of Baghouse (311-BF01) and (311-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.001A – S2.017A on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (311-BF01) and (311-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.009A and S2.010A, each, begin and end combustion of pipeline quality natural gas.

n. The SO2 emissions in tons per month from Baghouse (311-BF01) and (311-BF02), combined, will be calculated using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.012 and PF1.013, each, as required in V.D.4.g., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in E.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

Page 55: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 13

Section V. Specific Operating Conditions (continued) E. Emission Units S2.001A – S2.017A (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly

emissions shall be determined at the end of each month as the sum of monthly emissions recorded in E.4.n.(2) through (4) of this section.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in E.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (311-BF01) and

(311-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (311-BF01) and (311-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (1.76 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (311-BF01) and (311-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (5.03 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in E.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 56: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 14

Section V. Specific Operating Conditions (continued) F. Emission Units S2.001B – S2.017B

Location: North 4,455,900 m, East 381,830 m, UTM (Zone 11, NAD 83)

System 05B – Unit #1 Classification and Drying, #2 Fuel Oil (Alternate Operating Scenario) Revised Month 2019 S2.001B Hopper (311-HP01) and transfer to Cyclone (311-CN01) S2.002B Cyclone (311-CN01) and solids discharge to Cyclone (311-CN02) S2.003B Cyclone (311-CN02) and solids discharge to Whizzer Separator (311-SR01) and fines transfer to Cyclone (311-CN03)

S2.004B Whizzer Separator (311-SR01) and solids discharge to Cyclone (311-CN03) and waste discharge to Screw Conveyor (361-SC01)

S2.005B Cyclone (311-CN03) and discharge to Screw Conveyor (311-SC05) S2.006B Screw Conveyor (361-SC01) and transfer to Waste Bin (361-BI01) S2.007B Screw Conveyor (311-SC05) and transfer to Screw Conveyor (311-SC06) S2.008B Screw Conveyor (311-SC06) and transfer to Rotary kiln (321-KL01) S2.009B Rotary Kiln (321-KL01) and exhaust to Hot Air Furnace (311-HG01)

S2.010B Hot Air Furnace (311-HG01) and exhaust to Cyclone (311-CN01), Cyclone (311-CN02), Baghouse (311-BF01) and Baghouse (311-BF02)

S2.011B Baghouse (311-BF01) and transfer to Screw Conveyor (311-SC01) S2.012B Baghouse (311-BF02) and transfer to Screw Conveyor (311-SC02) S2.013B Screw Conveyor (311-SC01) and transfer to Conveyor (311-SC03) S2.014B Screw Conveyor (311-SC02) and transfer to Conveyor (311-SC03) S2.015B Screw Conveyor (311-SC03) and transfer to Screw Conveyor (311-SC04) and Screw Conveyor (361-SC02) S2.016B Screw Conveyor (311-SC04) and transfer to Conveyor (311-SC05) S2.017B Screw Conveyor (361-SC02) and transfer to Screw Conveyor (361-SC01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.001B – S2.017B, combined, shall be controlled by Baghouse (311-BF01) and (311-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 88.0 feet Stack Diameter: 2.9 feet Stack Temperature: 241.3°F Exhaust Volume Flow Rate: 14,670.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.001B – S2.017B, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. S2.009B and S2.010B, each, may consume #2 fuel oil as the alternate fuel. c. The maximum allowable #2 fuel oil consumption rate for S2.009B shall not exceed 214.29 gallons per hour, nor more

than 1,832,180.0 gallons per year, based on a 12-month rolling period. d. The maximum allowable #2 fuel oil consumption rate for S2.010B shall not exceed 142.86 gallons per hour, nor more

than 1,221,453.0 gallons per year, based on a 12-month rolling period. e. The maximum sulfur content of #2 fuel oil shall not exceed 0.2 percent by weight. Each vendor delivery shall verify

the sulfur content by certification. f. A fuel flow meter shall be installed and calibrated on S2.009B and S2.010B, each, if one is not already installed. The

fuel flow meter shall continuously monitor fuel consumption. g. A pressure gauge shall be installed and calibrated on Baghouse (311-BF01) and (311-BF02), each, if one is not

already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

Page 57: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 15

Section V. Specific Operating Conditions (continued) F. Emission Units S2.001B – S2.017B (continued)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

h. Hours (1) S2.001B – S2.017B, each, may operate 24 hours per day. (2) S2.001B – S2.017B, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (311-BF01) and (311-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 1.50 pounds per hour, nor more than

6.41 tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 1.50 pounds per hour, nor more than 6.41 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 1.50 pounds per hour, nor more than 6.41 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 10.0 pounds per hour, nor more than

42.75 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 5.0 pounds per hour, nor more than 21.36

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.79 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.009B and S2.010B, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.009B and S2.010B, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.001B – S2.008B and S2.011B – S2.017B, each, shall not exceed 19.18 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.001B – S2.008B and S2.011B – S2.017B, each, shall not exceed 24.78 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (311-BF01) and (311-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.001B – S2.017B, each. b. Monitor and record the total daily hours of operation for S2.001B – S2.017B, each. c. Record the average hourly throughput rate (in tons per hour) for S2.001B – S2.017B, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of #2 fuel oil consumed (in gallons) on a daily basis for S2.009B and S2.010B, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of #2 fuel oil (in gallons) on a cumulative monthly basis, for each 12-month rolling

period.

Page 58: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 16

Section V. Specific Operating Conditions (continued) F. Emission Units S2.001B – S2.017B (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in F.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of Baghouse (311-BF01) and (311-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.001B – S2.017B on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (311-BF01) and (311-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.009B and S2.010B, each, begin and end combustion of #2 fuel oil. n. The SO2 emissions in tons per month from Baghouse (311-BF01) and (311-BF02), combined, will be calculated

using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.012 and PF1.013, each, as required in V.D.4.g., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in F.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

Page 59: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 17

Section V. Specific Operating Conditions (continued) F. Emission Units S2.001B – S2.017B (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly

emissions shall be determined at the end of each month as the sum of monthly emissions recorded in F.4.n.(2) through (4) of this section.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in F.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (311-BF01) and

(311-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (311-BF01) and (311-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (5.03 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (311-BF01) and (311-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (5.03 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in F.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 60: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 18

Section V. Specific Operating Conditions (continued) G. Emission Units S2.001C– S2.017C

Location: North 4,455,900 m, East 381,830 m, UTM (Zone 11, NAD 83)

System 05C – Unit #1 Classification and Drying, Waste Oil (Alternate Operating Scenario) Revised Month 2019 S2.001C Hopper (311-HP01) and transfer to Cyclone (311-CN01) S2.002C Cyclone (311-CN01) and solids discharge to Cyclone (311-CN02) S2.003C Cyclone (311-CN02) and solids discharge to Whizzer Separator (311-SR01) and fines transfer to Cyclone (311-CN03)

S2.004C Whizzer Separator (311-SR01) and solids discharge to Cyclone (311-CN03) and waste discharge to Screw Conveyor (361-SC01)

S2.005C Cyclone (311-CN03) and discharge to Screw Conveyor (311-SC05) S2.006C Screw Conveyor (361-SC01) and transfer to Waste Bin (361-BI01) S2.007C Screw Conveyor (311-SC05) and transfer to Screw Conveyor (311-SC06) S2.008C Screw Conveyor (311-SC06) and transfer to Rotary kiln (321-KL01) S2.009C Rotary Kiln (321-KL01) and exhaust to Hot Air Furnace (311-HG01)

S2.010C Hot Air Furnace (311-HG01) and exhaust to Cyclone (311-CN01), Cyclone (311-CN02), Baghouse (311-BF01) and Baghouse (311-BF02)

S2.011C Baghouse (311-BF01) and transfer to Screw Conveyor (311-SC01) S2.012C Baghouse (311-BF02) and transfer to Screw Conveyor (311-SC02) S2.013C Screw Conveyor (311-SC01) and transfer to Conveyor (311-SC03) S2.014C Screw Conveyor (311-SC02) and transfer to Conveyor (311-SC03) S2.015C Screw Conveyor (311-SC03) and transfer to Screw Conveyor (311-SC04) and Screw Conveyor (361-SC02) S2.016C Screw Conveyor (311-SC04) and transfer to Conveyor (311-SC05) S2.017C Screw Conveyor (361-SC02) and transfer to Screw Conveyor (361-SC01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.001C – S2.017C, combined, shall be controlled by Baghouse (311-BF01) and (311-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 88.0 feet Stack Diameter: 2.9 feet Stack Temperature: 241.3°F Exhaust Volume Flow Rate: 14,670.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.001C – S2.017C, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. S2.009C and S2.010C, each, may consume waste oil as the alternate fuel. c. The maximum allowable waste oil consumption rate for S2.009C shall not exceed 214.29 gallons per hour, nor more

than 1,832,180.0 gallons per year, based on a 12-month rolling period. d. The maximum allowable waste oil consumption rate for S2.010C shall not exceed 142.86 gallons per hour, nor more

than 1,221,453.0 gallons per year, based on a 12-month rolling period. e. The maximum sulfur content of waste oil shall not exceed 0.5 percent by weight. Each vendor delivery shall verify

the sulfur content by certification, and shall provide metals and hazardous component assay. f. A fuel flow meter shall be installed and calibrated on S2.009C and S2.010C, each, if one is not already installed. The

fuel flow meter shall continuously monitor fuel consumption. g. A pressure gauge shall be installed and calibrated on Baghouse (311-BF01) and (311-BF02), each, if one is not

already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

Page 61: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 19

Section V. Specific Operating Conditions (continued) G. Emission Units S2.001C – S2.017C (continued)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

h. Hours (1) S2.001C – S2.017C, each, may operate 24 hours per day. (2) S2.001C – S2.017C, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (311-BF01) and (311-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 1.50 pounds per hour, nor more than

6.41 tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 1.50 pounds per hour, nor more than 6.41 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 1.50 pounds per hour, nor more than 6.41 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 10.0 pounds per hour, nor more than

42.75 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 5.0 pounds per hour, nor more than 21.36

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.79 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.009C and S2.010C, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.009C and S2.010C, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.001C – S2.008C and S2.011C – S2.017C, each, shall not exceed 19.18 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.001C – S2.008C and S2.011C – S2.017C, each, shall not exceed 24.78 pounds per hour. L. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (311-BF01) and (311-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.001C – S2.017C, each. b. Monitor and record the total daily hours of operation for S2.001C – S2.017C, each. c. Record the average hourly throughput rate (in tons per hour) for S2.001C – S2.017C, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of waste oil consumed (in gallons) on a daily basis for S2.009C and S2.010C, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of waste oil (in gallons) on a cumulative monthly basis, for each 12-month rolling

period.

Page 62: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 20

Section V. Specific Operating Conditions (continued) G. Emission Units S2.001C – S2.017C (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in G.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of Baghouse (311-BF01) and (311-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.001C – S2.017C on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (311-BF01) and (311-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.009C and S2.010C, each, begin and end combustion of waste oil. n. The SO2 emissions in tons per month from Baghouse (311-BF01) and (311-BF02), combined, will be calculated

using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.012 and PF1.013, each, as required in V.D.4.g., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in G.2.e of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

Page 63: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 21

Section V. Specific Operating Conditions (continued) G. Emission Units S2.001C – S2.017C (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly

emissions shall be determined at the end of each month as the sum of monthly emissions recorded in G.4.n.(2) through (4) of this section.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in G.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (311-BF01) and

(311-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (311-BF01) and (311-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (1.76 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (311-BF01) and (311-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (5.03 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in G.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 64: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 22

Section V. Specific Operating Conditions (continued) H. Emission Units S2.018 – S2.031

Location: North 4,456,002 m, East 381,757 m, UTM (Zone 11, NAD 83)

System 06 – Unit #1 Classification and Drying S2.018 Rotary Kiln (321-KL01) product discharge to Delumper (331-LC01) S2.019 Delumper (331-LC01) and discharge to Cyclone (331-CN01) S2.020 Cyclone (331-CN01) and solids discharge to Bucket Elevator (331-BE01) and fines discharge to Cyclone (331-CN02)

S2.021 Cyclone (331-CN02) and solids discharge to Main Product Bin (331-BI01), Screen (331-VS03) or Screw Conveyor (331-SC02)

S2.022 Bucket Elevator (331-BE01) and discharge to Screw Conveyor (331-SC01) or Rotex Screen (331-VS01) S2.023 Screw Conveyor (331-SC01) and discharge to Rotex Screen (VS02) S2.024 Rotex Screen (331-VS01) and discharge to Screw Conveyor (331-SC02) or Cyclone (331-CN03) S2.025 Rotex Screen (331-VS02) and discharge to Screw Conveyor (331-SC02) or Cyclone (331-CN03) S2.026 Screw Conveyor (331-SC02) and discharge to Hammermill (331-HC01) and Hammermill (331-HC02) S2.027 Hammermill (331-HC01) and discharge to Cyclone (331-CN03) S2.028 Hammermill (331-HC02) and discharge to Cyclone (331-CN03)

S2.029 Cyclone (331-CN03) and discharge to Screw Conveyor (331-SC03), Screw Conveyor (361-SC03) or Cyclone (331-CN02)

S2.030 Screen (331-VS03) and discharge to Main Product Bin (331-BI01) or Bucket Elevator (331-BE01) S2.031 Main Product Bin (331-BI01) and fines discharge to Cyclone (331-CN02)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.018 – S2.031, combined, shall be ducted to a control system consisting of a Baghouse (331-BF01).

b. Descriptive Stack Parameters Stack Height: 74.3 feet Stack Diameter: 2.3 feet Stack Temperature: 167.2°F Exhaust Volume Flow Rate: 12,199.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.018 – S2.031, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (331-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.018 – S2.031, each, may operate 24 hours per day. (2) S2.018 – S2.031, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (331-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.63 pound per hour, nor more than 2.68

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.63 pound per hour, nor more than 2.68 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.63 pound per hour, nor more than 2.68 tons per 12-month rolling period.

Page 65: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 23

Section V. Specific Operating Conditions (continued) H. Emission Units S2.018 – S2.031 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (331-BF01) the following pollutants in excess of the following specified limits: d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.018 – S2.031, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (331-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.018 – S2.031, each. b. Monitor and record the total daily hours of operation for S2.018 – S2.031, each. c. Record the average hourly throughput rate (in tons per hour) for S2.018 – S2.031, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in H.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (331-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.018 – S2.031 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (331-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in H.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

Page 66: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 24

Section V. Specific Operating Conditions (continued) H. Emission Units S2.018 – S2.031 (continued)

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (331-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (331-BF01) will not exceed 0.032 g/dscm (0.014 gr/dscf) (1.46

pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 67: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 25

Section V. Specific Operating Conditions (continued) I. Emission Units S2.032 – S2.050

Location: North 4,456,008 m, East 381,764 m, UTM (Zone 11, NAD 83)

System 07 – Unit #1 Classification and Drying S2.032 Screw Conveyor (371-SC05) and discharge to Cyclone (331-CN01) S2.033 Main Product Bin (331-BI01) and discharge to Screw Conveyor (331-SC04) S2.034 Screw Conveyor (331-SC04) and discharge to Bucket Elevator (331-BE02)

S2.035 Bucket Elevator (331-BE02) and discharge to Main Surge Bin (331-BI03), Main Product Bin (331-BI01), Re-Feed Bin (371-BI01), or Bulk Loading

S2.036 Main Surge Bin (331-BI03) and discharge to Bag Packer (401-PM02) S2.037 Air Slide (331-AS01) and discharge to Bulk Bag Bin (331-BI04) S2.038 Bulk Bag Bin (331-BI04) and discharge to Screw Conveyor (401-SC04) or Bulk Bagger (401-BB02) S2.039 Screw Conveyor (401-SC04) and discharge to Bulk Bagger (401-BB01) S2.040 Screw Conveyor (371-SC02) and discharge to Bucket Elevator (371-BE01) and Re-Feed Bin (371-BI01) S2.041 Bucket Elevator (371-BE01) and discharge to Screw Conveyor (371-SC03) or Bagging Bin (331-BI02) S2.042 Screw Conveyor (371-SC03) and discharge to Screw Conveyor (371-SC04) S2.043 Screw Conveyor (371-SC04) and discharge to Screw Conveyor (361-SC02) or Screw Conveyor (311-SC04) S2.044 Bagging Bin (331-BI02) and discharge to Bag Packer (401-PM01) S2.045 Belt Bag Conveyor (401-FQ01) and discharge to Belt Bag Conveyor (401-BC01) S2.046 Bag Flattener (401-FQ01) S2.047 Belt Bag Conveyor (401-BC01) S2.048 Screw Conveyor (401-SC01) and discharge to Screw Conveyor (401-SC02) S2.049 Screw Conveyor (401-SC02) and discharge to Baghouse (401-BF01) S2.050 Screw Conveyor (401-SC03) and discharge to Baghouse (401-BF01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.032 – S2.050, combined, shall be ducted to a control system consisting of a Baghouse (401-BF01).

b. Descriptive Stack Parameters Stack Height: 63.0 feet Stack Diameter: 3.0 feet Stack Temperature: 106.27°F Exhaust Volume Flow Rate: 10,287.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.032 – S2.050, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (401-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.032 – S2.050, each, may operate 24 hours per day. (2) S2.032 – S2.050, each, may operate 8,550 hours per year.

Page 68: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 26

Section V. Specific Operating Conditions (continued) I. Emission Units S2.032 – S2.050 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (401-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.44 pound per hour, nor more than 1.88

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.44 pound per hour, nor more than 1.88 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.44 pound per hour, nor more than 1.88 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.032 – S2.050, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (401-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.032 – S2.050, each. b. Monitor and record the total daily hours of operation for S2.032 – S2.050, each. c. Record the average hourly throughput rate (in tons per hour) for S2.032 – S2.050, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in I.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (401-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.032 – S2.050 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (401-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in I.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

Page 69: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 27

Section V. Specific Operating Conditions (continued) I. Emission Units S2.032 – S2.050 (continued)

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (401-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (401-BF01) will not exceed 0.05 g/dscm (0.022 gr/dscf) (1.94

pounds per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 70: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 28

Section V. Specific Operating Conditions (continued) J. Emission Units S2.051 and S2.052

Location: North 4,455,993 m, East 381,754 m, UTM (Zone 11, NAD 83)

System 08 – Unit #1 Bulk Loading and Packing S2.051 Bag Packer (401-PM01) S2.052 Bag Packer (401-PM02)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.051 and S2.052, combined, shall be ducted to a control system consisting of a Baghouse (401-BF02).

b. Descriptive Stack Parameters Stack Height: 24.8 feet Stack Diameter: 2.0 feet Stack Temperature: 110°F Exhaust Volume Flow Rate: 11,641.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.051 and S2.052, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (401-BF02), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.051 and S2.052, each, may operate 24 hours per day. (2) S2.051 and S2.052, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (401-BF02) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.50 pound per hour, nor more than 2.13

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.50 pound per hour, nor more than 2.13 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.50 pound per hour, nor more than 2.13 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.051 and S2.052, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (401-

BF02)) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.051 and S2.052, each. b. Monitor and record the total daily hours of operation for S2.051 and S2.052, each. c. Record the average hourly throughput rate (in tons per hour) for S2.051 and S2.052, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period.

Page 71: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 29

Section V. Specific Operating Conditions (continued) J. Emission Units S2.051 and S5.052 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in J.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (401-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.051 and S2.052 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (401-BF02) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in J.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (401-BF02) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (401-BF02) will not exceed 0.032 g/dscm (0.014 gr/dscf) (1.40

pounds per hour). (40 CFR Part 60.672(b)) b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after

April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 72: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 30

Section V. Specific Operating Conditions (continued) K. Emission Units PF1.014 – PF1.018

Location: North 4,455,949 m, East 381,829 m, UTM (Zone 11, NAD 83)

System 09 – Unit #2 Classification and Drying PF1.014 Ore Bin (31A-BI03) and discharge to Pan Feeder (312-AF01) PF1.015 Ore Bin (31A-BI04) and discharge to Pan Feeder (312-AF02) PF1.016 Pan Feeder (312-AF01) and discharge to Conveyor (312-BC01) PF1.017 Pan Feeder (312-AF02) and discharge to Conveyor (312-BC01) PF1.018 Conveyor (312-BC01) and discharge to Cyclone (312-CN01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.014 – PF1.018, each, shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.014 – PF1.018, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A sulfur analyzer shall be calibrated on PF1.016 and PF1.017, each. The sulfur analyzer shall analyze the sulfur content in the diatomite processed.

c. Hours (1) PF1.014 – PF1.018, each, may operate 24 hours per day. (2) PF1.014 – PF1.018, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.014 – PF1.018, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.015 pound per hour, nor more than

0.064 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.006 pound per hour, nor more than 0.024 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.0008 pound per hour, nor more than 0.004 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.014 – PF1.018, each, shall not

equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.014 – PF1.018, each. b. Monitor and record the total daily hours of operation for PF1.014 – PF1.018, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.014 – PF1.018, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in K.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 73: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 31

Section V. Specific Operating Conditions (continued) K. Emission Unit PF1.014 – PF1.018 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.014 – PF1.018, each, on a

monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the enclosure installed on PF1.014 – PF1.018, each, on a monthly basis to confirm that the enclosure is in place and functioning properly. If the enclosure is in disrepair, the Permittee must perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

h. Monitor and record the sulfur content in weight percent of diatomite on a dry basis. The sulfur content shall be obtained and analyzed by taking a monthly diatomite sample at PF1.016 and PF1.017, each. Sampling for sulfur will be repeated if a new ore material is loaded into the system.

i. The sulfur analyzer shall undergo a calibration and precision check on a daily basis when operated. Independent sulfur standard shall be run once per month and the balance will be calibrated once a quarter. The analyzer shall be operated, maintained and calibrated according to manufacturer’s instructions. All samples will be desiccated at a low temperature to preserve the sample integrity and limit the loss of sulfur and combustibles.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in K.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.014 – PF1.018, each, will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.014 – PF1.018, each, will not exceed 7 percent opacity. (40 CFR Part

60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 74: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 32

Section V. Specific Operating Conditions (continued) L. Emission Units S2.053A– S2.063A

Location: North 4,456,048 m, East 381,687 m, UTM (Zone 11, NAD 83)

System 10A – Unit #2 Classification and Drying, Natural gas (Primary Scenario) Revised Month 2019 S2.053A Cyclone (312-CN01) and solids discharge to Cyclone (312-CN02)

S2.054A Cyclone (312-CN02) and solids discharge to Whizzer Separator (312-SR01) or fines discharge to Cyclone (312-CN03)

S2055A Whizzer Separator (312-SR01) and solids discharge to Cyclone (312-CN03) or waste discharge to Screw Conveyor (362-SC01)

S2.056A Cyclone (312-CN03) and solids discharge to Screw Conveyor (312-SC04) or fines discharge to Cyclone (312-CN01) S2.057A Screw Conveyor (312-SC04) and discharge to Screw Conveyor (312-SC05) S2.058A Screw Conveyor (312-SC05) and discharge to Rotary Kiln (322-KL01) S2.059A Rotary Kiln (322-KL01) and exhaust to Hot Air Furnace (312-HG01)

S2.060A Hot Air Furnace (312-HG01) and exhaust to Cyclone (312-CN01), Cyclone (312-CN02), Baghouse (312-BF01) and Baghouse (312-BF02)

S2.061A Screw Conveyor (312-SC03) and discharge to Screw Conveyor (312-SC04) or Screw Conveyor (362-SC02) S2.062A Screw Conveyor (362-SC02) and discharge to Screw Conveyor (362-SC01) S2.063A Screw Conveyor (362-SC01) and discharge to Waste Bin (36A-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.053A – S2.063A, combined, shall be controlled by Baghouse (312-BF01) and (312-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 73.0 feet Stack Diameter: 2.5 feet Stack Temperature: 227°F Exhaust Volume Flow Rate: 28,615.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.053A – S2.063A, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. S2.059A and S2.060A, each, may consume only natural gas as the primary fuel. c. The maximum allowable natural gas consumption rate for S2.059A shall not exceed 29,411.76 standard cubic feet

(scf) per hour, nor more than 251,470,548.0 scf per year, based on a 12-month rolling period. d. The maximum allowable natural gas consumption rate for S2.060A shall not exceed 19,607.84 standard cubic feet

(scf) per hour, nor more than 167,647,032.0 scf per year, based on a 12-month rolling period. e. The maximum sulfur content of the pipeline quality natural gas will not exceed 20 grains per 100 cubic feet. This

default maximum sulfur content, sulfur content provided by the supplier, or test result of the sulfur analysis of the pipeline quality natural gas will be used in the SO2 calculations.

f. A fuel flow meter shall be installed and calibrated on S2.059A and S2.060A, each, if one is not already installed. The fuel flow meter shall continuously monitor fuel consumption.

g. A pressure gauge shall be installed and calibrated on Baghouse (312-BF01) and (312-BF02), each, if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

h. Hours (1) S2.053A – S2.063A, each, may operate 24 hours per day. (2) S2.053A – S2.063A, each, may operate 8,550 hours per year.

Page 75: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 33

Section V. Specific Operating Conditions (continued) L. Emission Units S2.053A – S2.063A (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stacks of Baghouse (312-BF01) and (312-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 2.0 pounds per hour, nor more than 8.55

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 2.0 pounds per hour, nor more than 8.55 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 2.0 pounds per hour, nor more than 8.55 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 7.83 pounds per hour, nor more than

33.47 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 6.65 pounds per hour, nor more than

28.42 tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.50 pounds per hour, nor

more than 27.8 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.059A and S2.060A, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.059A and S2.060A, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.053A – S2.058A and S2.061A – S2.063A, each, shall not exceed 19.18 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.053A – S2.058A and S2.061A – S2.063A, each, shall not exceed 24.78 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (312-BF01) and Baghouse (312-BF-02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.053A – S2.063A, each. b. Monitor and record the total daily hours of operation for S2.053A – S2.063A, each. c. Record the average hourly throughput rate (in tons per hour) for S2.053A – S2.063A, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of natural gas consumed (in scf) on a daily basis for S2.059A and S2.060A, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of natural gas (in scf) on a cumulative monthly basis, for each 12-month rolling period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in L.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 76: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 34

Section V. Specific Operating Conditions (continued) L. Emission Units S2.053A – S2.063A (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of

Baghouse (312-BF01) and (312-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.053A – S2.063A on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on which Baghouse (312-BF01) and (312-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.059A and S2.060A, each, begin and end combustion of pipeline quality natural gas.

n. The SO2 emissions in tons per month from Baghouse (312-BF01) and (312-BF02), combined, will be calculated using the following formula:

2(OFs- Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.016 and PF1.017, each, as required in V.K.4.h., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in L.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly emissions shall be determined at the end of each month as the sum of monthly emissions recorded in L.4.n.(2) through (4) of this section.

Page 77: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 35

Section V. Specific Operating Conditions (continued) L. Emission Units S2.053A – S2.063A (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in L.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (312-BF01) and

(312-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (312-BF01) and (312-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (3.43 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (312-BF01) and (312-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (9.81 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in L.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 78: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 36

Section V. Specific Operating Conditions (continued) M. Emission Units S2.053B – S2.063B

Location: North 4,456,048 m, East 381,687 m, UTM (Zone 11, NAD 83)

System 10B – Unit #2 Classification and Drying, #2 Fuel Oil (Alternate Scenario) Revised Month 2019 S2.053B Cyclone (312-CN01) and solids discharge to Cyclone (312-CN02)

S2.054B Cyclone (312-CN02) and solids discharge to Whizzer Separator (312-SR01) or fines discharge to Cyclone (312-CN03)

S2055B Whizzer Separator (312-SR01) and solids discharge to Cyclone (312-CN03) or waste discharge to Screw Conveyor (362-SC01)

S2.056B Cyclone (312-CN03) and solids discharge to Screw Conveyor (312-SC04) or fines discharge to Cyclone (312-CN01) S2.057B Screw Conveyor (312-SC04) and discharge to Screw Conveyor (312-SC05) S2.058B Screw Conveyor (312-SC05) and discharge to Rotary Kiln (322-KL01) S2.059B Rotary Kiln (322-KL01) and exhaust to Hot Air Furnace (312-HG01)

S2.060B Hot Air Furnace (312-HG01) and exhaust to Cyclone (312-CN01), Cyclone (312-CN02), Baghouse (312-BF01) and Baghouse (312-BF02)

S2.061B Screw Conveyor (312-SC03) and discharge to Screw Conveyor (312-SC04) or Screw Conveyor (362-SC02) S2.062B Screw Conveyor (362-SC02) and discharge to Screw Conveyor (362-SC01) S2.063B Screw Conveyor (362-SC01) and discharge to Waste Bin (36A-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.053B – S2.063B, combined, shall be controlled by Baghouse (312-BF01) and (312-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 73.0 feet Stack Diameter: 2.5 feet Stack Temperature: 227°F Exhaust Volume Flow Rate: 28,615.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.053B – S2.063B, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. S2.059B and S2.060B, each, may consume #2 fuel oil as the alternate fuel. c. The maximum allowable #2 fuel oil consumption rate for S2.059B shall not exceed 214.29 gallons per hour, nor more

than 1,832,180.0 gallons per year, based on a 12-month rolling period. d. The maximum allowable #2 fuel oil consumption rate for S2.060B shall not exceed 142.86 gallons per hour, nor more

than 1,221,453.0 gallons per year, based on a 12-month rolling period. e. The maximum sulfur content of #2 fuel oil shall not exceed 0.2 percent by weight. Each vendor delivery shall verify

the sulfur content by certification. f. A fuel flow meter shall be installed and calibrated on S2.059B and S2.060B, each, if one is not already installed. The

fuel flow meter shall continuously monitor fuel consumption. g. A pressure gauge shall be installed and calibrated on Baghouse (312-BF01) and (312-BF02), each, if one is not

already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water. h. Hours

(1) S2.053B – S2.063B, each, may operate 24 hours per day. (2) S2.053B – S2.063B, each, may operate 8,550 hours per year.

Page 79: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 37

Section V. Specific Operating Conditions (continued) M. Emission Units S2.053B – S2.063B (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (312-BF01) and (312-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 2.0 pounds per hour, nor more than 8.55

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 2.0 pounds per hour, nor more than 8.55 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 2.0 pounds per hour, nor more than 8.55 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 7.83 pounds per hour, nor more than

33.47 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 6.65 pounds per hour, nor more than

28.43 tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.50 pounds per hour, nor

more than 27.8 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.059B and S2.060B, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.059B and S2.060B, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.053B – S2.058B and S2.061B – S2.063B, each, shall not exceed 19.18 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.053B – S2.058B and S2.061B – S2.063B, each, shall not exceed 24.78 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (312-BF01) and (312-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.053B – S2.063B, each. b. Monitor and record the total daily hours of operation for S2.053B – S2.063B, each. c. Record the average hourly throughput rate (in tons per hour) for S2.053B – S2.063B, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of #2 fuel oil consumed (in scf) on a daily basis for S2.059B and S2.060B, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of #2 fuel oil (in gallons) on a cumulative monthly basis, for each 12-month rolling

period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in M.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 80: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 38

Section V. Specific Operating Conditions (continued) M. Emission Units S2.053B – S2.063B (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of

Baghouse (312-BF01) and (312-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.053B – S2.063B on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (312-BF01) and (312-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.059B and S2.060B, each, begin and end combustion of #2 fuel oil. n. The SO2 emissions in tons per month from Baghouse (312-BF01) and (312-BF02), combined, will be calculated

using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.016 and PF1.017, each, as required in V.K.4.h., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in M.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly emissions shall be determined at the end of each month as the sum of monthly emissions recorded in M.4.n.(2) through (4) of this section.

Page 81: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 39

Section V. Specific Operating Conditions (continued) M. Emission Units S2.053B– S2.063B (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in M.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (312-BF01) and

(312-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (312-BF01) and (312-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (3.43 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (312-BF01) and (312-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (9.81 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in M.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 82: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 40

Section V. Specific Operating Conditions (continued) N. Emission Units S2.053C – S2.063C

Location: North 4,456,048 m, East 381,687 m, UTM (Zone 11, NAD 83)

System 10C – Unit #2 Classification and Drying, Waste Oil (Alternate Scenario) Revised Month 2019 S2.053C Cyclone (312-CN01) and solids discharge to Cyclone (312-CN02)

S2.054C Cyclone (312-CN02) and solids discharge to Whizzer Separator (312-SR01) or fines discharge to Cyclone (312-CN03)

S2055C Whizzer Separator (312-SR01) and solids discharge to Cyclone (312-CN03) or waste discharge to Screw Conveyor (362-SC01)

S2.056C Cyclone (312-CN03) and solids discharge to Screw Conveyor (312-SC04) or fines discharge to Cyclone (312-CN01) S2.057C Screw Conveyor (312-SC04) and discharge to Screw Conveyor (312-SC05) S2.058C Screw Conveyor (312-SC05) and discharge to Rotary Kiln (322-KL01) S2.059C Rotary Kiln (322-KL01) and exhaust to Hot Air Furnace (312-HG01)

S2.060C Hot Air Furnace (312-HG01) and exhaust to Cyclone (312-CN01), Cyclone (312-CN02), Baghouse (312-BF01) and Baghouse (312-BF02)

S2.061C Screw Conveyor (312-SC03) and discharge to Screw Conveyor (312-SC04) or Screw Conveyor (362-SC02) S2.062C Screw Conveyor (362-SC02) and discharge to Screw Conveyor (362-SC01) S2.063C Screw Conveyor (362-SC01) and discharge to Waste Bin (36A-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.053C – S2.063C, combined, shall be controlled by Baghouse (312-BF01) and (312-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 73.0 feet Stack Diameter: 2.5 feet Stack Temperature: 227°F Exhaust Volume Flow Rate: 28,615.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.053C – S2.063C, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. S2.059C and S2.060C, each, may consume waste oil as the alternate fuel. c. The maximum allowable waste oil consumption rate for S2.059C shall not exceed 214.29 gallons per hour, nor more

than 1,832,180.0 gallons per year, based on a 12-month rolling period. d. The maximum allowable waste oil consumption rate for S2.060C shall not exceed 142.86 gallons per hour, nor more

than 1,221,453.0 gallons per year, based on a 12-month rolling period. e. The maximum sulfur content of waste oil shall not exceed 0.5 percent by weight. Each vendor delivery shall verify

the sulfur content by certification, and shall provide metals and hazardous component assay. f. A fuel flow meter shall be installed and calibrated on S2.059C and S2.060C, each, if one is not already installed. The

fuel flow meter shall continuously monitor fuel consumption. g. A pressure gauge shall be installed and calibrated on Baghouse (312-BF01) and (312-BF02), each, if one is not

already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water. h. Hours

(1) S2.053C – S2.063C, each, may operate 24 hours per day. (2) S2.053C – S2.063C, each, may operate 8,550 hours per year.

Page 83: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 41

Section V. Specific Operating Conditions (continued) N. Emission Units S2.053C – S2.063C (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (312-BF01) and (312-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 2.0 pounds per hour, nor more than 8.55

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 2.0 pounds per hour, nor more than 8.55 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 2.0 pounds per hour, nor more than 8.55 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.89

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 7.83 pounds per hour, nor more than

33.47 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 6.65 pounds per hour, nor more than

28.43 tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.8 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.059C and S2.060C, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.059C and S2.060C, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.053C – S2.058C and S2.061C – S2.063C, each, shall not exceed 19.18 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.053C – S2.058C and S2.061C – S2.063C, each, shall not exceed 24.78 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (312-BF01) and (312-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.053C – S2.063C, each. b. Monitor and record the total daily hours of operation for S2.053C – S2.063C, each. c. Record the average hourly throughput rate (in tons per hour) for S2.053C – S2.063C, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of waste oil consumed (in scf) on a daily basis for S2.059C and S2.060C, each, using

the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of waste oil (in gallons) on a cumulative monthly basis, for each 12-month rolling

period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in N.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 84: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 42

Section V. Specific Operating Conditions (continued) N. Emission Units S2.053C – S2.063C (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of

Baghouse (312-BF01) and (312-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.053C – S2.063C on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (312-BF01) and (312-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.059C and S2.060C, each, begin and end combustion of waste oil. n. The SO2 emissions in tons per month from Baghouse (312-BF01) and (312-BF02), combined, will be calculated

using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.016 and PF1.017, each, as required in V.K.4.h., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in N.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly emissions shall be determined at the end of each month as the sum of monthly emissions recorded in N.4.n.(2) through (4) of this section.

Page 85: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 43

Section V. Specific Operating Conditions (continued) N. Emission Units S2.053C – S2.063C (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in N.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (312-BF01) and

(312-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (312-BF01) and (312-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (3.43 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (312-BF01) and (312-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (9.81 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in N.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 86: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 44

Section V. Specific Operating Conditions (continued) O. Emission Units S2.064 and S2.065

Location: North 4,455.960 km, East 381.923 km, UTM (Zone 11, NAD 83)

System 11 – Unit #2 Classification and Drying S2.064 Screw Conveyor (312-SC01) and transfer to Midwesco Baghouse (312-BF03) S2.065 Screw Conveyor (312-SC02) and transfer to Midwesco Baghouse (312-BF03)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.064 and S2.065, combined, shall be controlled by Baghouse (312-BF03). b. Descriptive Stack Parameters

Stack Height: 64.61 feet Stack Dimensions: 0.5 x 0.67 feet Stack Temperature: Ambient Exhaust Volume Flow Rate: 200.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.064 and S2.065, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. Hours (1) S2.064 and S2.065, each, may operate 24 hours per day. (1) S2.064 and S2.065, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (312-BF03) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.009 pound per hour, nor more than

0.037 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.009 pound per hour, nor more than 0.037 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.009 pound per hour, nor more than 0.037 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.064 and S2.065, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (312-

BF03) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.064 and S2.065, each. b. Monitor and record the total daily hours of operation for S2.064 and S2.065, each. c. Record the average hourly throughput rate (in tons per hour) for S2.064 and S2.065, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in O.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 87: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 45

Section V. Specific Operating Conditions (continued) O. Emission Units S2.064 and S2.065 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (312-BF03) on a

monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.064 and S2.065 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in O.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (312-BF03) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (312-BF03) will not exceed 0.05 g/dscm (0.022 gr/dscf) (0.04

pound per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 88: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 46

Section V. Specific Operating Conditions (continued) P. Emission Units S2.066 – S2.081

Location: North 4,456,036 m, East 381,730 m, UTM (Zone 11, NAD 83)

System 12 – Unit #2 Classification and Drying S2.066 Rotary Kiln #2 (322-KL01) and product discharge to Delumper (332-LC01) S2.067 Delumper (332-LC01) and discharge to Cyclone (332-CN01)

S2.068 Cyclone (332-CN01) and solids discharge to Bucket Elevator (332-BE01) or fines discharge to Cyclone (332-CN02)

S2.069 Bucket Elevator (332-BE01) and discharge to Screw Conveyor (332-SC01) S2.070 Screw Conveyor (332-SC01) and discharge to Rotex Screen (332-VS01) and Rotex Screen (332-VS02) S2.071 Rotex Screen (332-VS01) and discharge to Screw Conveyor (332-SC02) or Cyclone (332-CN03) S2.072 Rotex Screen (332-VS02) and discharge to Screw Conveyor (332-SC02) or Cyclone (332-CN03) S2.073 Screw Conveyor (332-SC02) and discharge to Hammermill (332-HC01) and Hammermill (332-HC02) S2.074 Hammermill (332-HC01) and discharge to Cyclone (332-CN03) S2.075 Hammermill (332-HC02) and discharge to Cyclone (332-CN03) S2.076 Cyclone (332-CN03) and solids discharge to Cyclone (332-CN02) or Air Slide (332-AS01) S2.077 Air Slide (332-AS01) and transfer to Screw Conveyor (332-SC02)

S2.078 Cyclone (332-CN02) and solids discharge to Main Product Bin (332-BI01), Rotex Screen (332-VS03) or Screw Conveyor (332-SC03)

S2.079 Rotex Screen (332-VS03) and discharge to Main Product Bin (332-BI01) or Screw Conveyor (332-SC04) S2.080 Screw Conveyor (332-SC03) and discharge to Screw Conveyor (332-SC04) S2.081 Screw Conveyor (332-SC04) and discharge to Screw Conveyor (332-SC02)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.066 – S2.081, combined, shall be ducted to a control system consisting of a Baghouse (332-BF01).

b. Descriptive Stack Parameters Stack Height: 83.67 feet Stack Diameter: 1.9 feet Stack Temperature: 211°F Exhaust Volume Flow Rate: 14,647.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.066 – S2.081, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (332-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.066 – S2.081, each, may operate 24 hours per day. (2) S2.066 – S2.081, each, may operate 8,550 hours per year.

Page 89: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 47

Section V. Specific Operating Conditions (continued) P. Emission Units S2.066 – S2.081 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (332-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.63 pound per hour, nor more than 2.68

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.63 pound per hour, nor more than 2.68 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.63 pound per hour, nor more than 2.68 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.066 – S2.081, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (332-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.066 – S2.081, each. b. Monitor and record the total daily hours of operation for S2.066 – S2.081, each. c. Record the average hourly throughput rate (in tons per hour) for S2.066 – S2.081, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in P.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (332-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.066 – S2.081 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (332-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in P.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

Page 90: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 48

Section V. Specific Operating Conditions (continued) P. Emission Units S2.066 – S2.081 (continued)

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (332-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (332-BF01) will not exceed 0.032 g/dscm (0.014 gr/dscf) (1.76

pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 91: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 49

Section V. Specific Operating Conditions (continued) Q. Emission Units S2.082 – S2.103 and S2.239

Location: North 4,456,031 m, East 381,715 m, UTM (Zone 11, NAD 83)

System 13 – Unit #2 Classification and Drying Revised Month 2019 S2.082 Main Product Bin (332-BI01) and discharge to Cyclone (332-CN02) or Screw Conveyor (332-SC05) S2.083 Screw Conveyor (332-SC05) and discharge to Bucket Elevator (332-BE04)

S2.084 Bucket Elevator (332-BE04) and discharge to Air Slide (332-AS02), Re-Feed Bin (371-BI01), Main Product Bin (332-BI01), Main Product Bin (331-BI01), or Bulk Loading

S2.085 Air Slide (332-AS02) and discharge to Main Surge Bin (332-BI03) or Air Slide (332-AS03) S2.086 Main Surge Bin (332-BI03) and discharge to Bag Packer (402-PM01) S2.087 Air Slide (332-AS03) and discharge to Main Bulk Bag Bin (332-BI04) S2.088 Screw Conveyor (352-SC01) and discharge to Screw Conveyor (352-SC02) or Re-Feed Bin (371-BI01) S2.089 Screw Conveyor (352-SC02) and discharge to Bucket Elevator (352-BE03) S2.090 Bucket Elevator (352-BE03) and discharge to Classifier (352-SR01) S2.091 Classifier (352-SR01) and fines discharge to Cyclone (332-CN04) or solids discharge to Cyclone (332-CN01) S2.092 Cyclone (332-CN04) and solids discharge to Screw Conveyor (352-SC03) or fines discharge to Classifier (352-SR01) S2.093 Screw Conveyor (352-SC03) and discharge to Bucket Elevator (332-BE02) S2.094 Screw Conveyor (332-SC06) and discharge to Bucket Elevator (332-BE02) or Screw Conveyor (352-SC01) S2.095 Bucket Elevator (332-BE02) and discharge to Screw Conveyor (332-SC09) S2.096 Screw Conveyor (332-SC09) and discharge to Baghouse Bin (402-BI02) S2.097 Baghouse Bin (332-BI02) and discharge to Bag Packer (402-PM02) or Screw Conveyor (402-SC04) S2.098 Screw Conveyor (402-SC04) and discharge to Bulk Bagger (402-BB02) S2.099 Screw Conveyor (371-SC01) and discharge to Re-Feed Bin (371-BI01) S2.100 Bag Product Chute discharge to Belt Bag Conveyor (402-BC01) S2.101 Bag Flattener (402-FQ01)

S2.102 Re-Feed Bin (371-BI01) and discharge to Cyclone (311-CN03), Cyclone (331-CN01), Cyclone (312-CN03) or Cyclone (313-CN03)

S2.103 Baghouse (371 -BF01) to Re-Feed Bin (371-BI01) S2.239 Bulk Bag Unloader (371-EH01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.082 – S2.103 and S2.239, combined, shall be controlled by Baghouse (402-BF01). b. Descriptive Stack Parameters

Stack Height: 42.0 feet Stack Diameter: 3.0 feet Stack Temperature: 108.1°F Exhaust Volume Flow Rate: 13,922.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.082 – S2.103 and S2.239, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (402-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.082 – S2.103 and S2.239, each, may operate 24 hours per day. (2) S2.082 – S2.103 and S2.239, each, may operate 8,550 hours per year.

Page 92: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 50

Section V. Specific Operating Conditions (continued) Q. Emission Units S2.082 – S2.103 and S2.239 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (402-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.72 pound per hour, nor more than 3.06

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.72 pound per hour, nor more than 3.06 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.72 pound per hour, nor more than 3.06 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.082 – S2.103 and S2.239, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (402-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.082 – S2.103 and S2.239, each. b. Monitor and record the total daily hours of operation for S2.082 – S2.103 and S2.239, each. c. Record the average hourly throughput rate (in tons per hour) for S2.082 – S2.103 and S2.239, each, using the total

daily throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in Q.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (402-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.082 – S2.103 and S2.239 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (402-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in Q.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

Page 93: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 51

Section V. Specific Operating Conditions (continued) Q. Emission Units S2.082 – S2.103 and S2.239 (continued)

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (402-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (402-BF01) will not exceed 0.032 g/dscm (0.014 gr/dscf) (1.67

pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 94: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 52

Section V. Specific Operating Conditions (continued) R. Emission Units S2.104 – S2.111

Location: North 4,456,034 m, East 381,712 m, UTM (Zone 11, NAD 83)

System 14 – Unit #2 Bulk Loading and Packing Revised Month 2019

S2.104 Main Bulk Bag Bin (332-BI04) and discharge to Main Bin Bulk Bagger (402-BB01) and Main Bin Bulk Bagger (402-BB03)

S2.105 Bulk Bagger (402-BB01) S2.106 Bulk Bagger (402-BB02) S2.107 Bulk Bagger (402-BB03) S2.108 Belt Bag Conveyor (402-BC01) S2.109 Screw Conveyor (402-SC01) S2.110 Screw Conveyor (402-SC02) S2.111 Screw Conveyor (402-SC03)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.104 – S2.111, combined, shall be controlled by Baghouse (402-BF02). b. Descriptive Stack Parameters

Stack Height: 25.0 feet Stack Diameter: 1.25 feet Stack Temperature: 100°F Exhaust Volume Flow Rate: 3,726 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.104 – S2.111, each, shall not exceed 10.0 tons of diatomite per any one-hour period, nor more than 85,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (402-BF02), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.104 – S2.111, each, may operate 24 hours per day. (2) S2.104 – S2.111, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (402-BF02) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.40 pound per hour, nor more than 1.71

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.40 pound per hour, nor more than 1.71 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.40 pound per hour, nor more than 1.71 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.104 – S2.111, each, shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (402-

BF02) shall not equal or exceed 20 percent.

Page 95: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 53

Section V. Specific Operating Conditions (continued) R. Emission Unit S2.104 – S2.111 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.104 – S2.111, each. b. Monitor and record the total daily hours of operation for S2.104 – S2.111, each. c. Record the average hourly throughput rate (in tons per hour) for S2.104 – S2.111, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in R.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (402-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.104 – S2.111 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (402-BF02) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in R.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

7. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (402-BF02) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (402-BF02) will not exceed 0.032 g/dscm (0.014 gr/dscf) (0.45

pound per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

Page 96: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 54

Section V. Specific Operating Conditions (continued) R. Emission Unit S2.104 – S2.111 (continued)

7. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (continued) c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 97: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 55

Section V. Specific Operating Conditions (continued) S. Emission Unit S2.112

Location: North 4,456,002 m, East 381,714 m, UTM (Zone 11, NAD 83)

System 15 – Unit #2 Bulk Loading and Packing Revised Month 2019 S2.112 Bag Breaker (371- BI02) to Re-Feed Bin (371-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.112 shall be controlled by Baghouse (371-BF01). b. Descriptive Stack Parameters

Stack Height: 23.0 feet Stack Diameter: 1.5 feet Stack Temperature: Ambient Exhaust Volume Flow Rate: 3,372.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.112 shall not exceed 5.0 tons of diatomite per any one-hour period, nor more than 17,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (371-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.112 may operate 24 hours per day. (2) S2.112 may operate 3,500 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (371-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.40 pound per hour, nor more than 0.71

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.40 pound per hour, nor more than 0.71 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.40 pound per hour, nor more than 0.71 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 12.05 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (371-

BF01) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.112. b. Monitor and record the total daily hours of operation for S2.112. c. Record the average hourly throughput rate (in tons per hour) for S2.112 using the total daily throughput and total

daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in S.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 98: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 56

Section V. Specific Operating Conditions (continued) S. Emission Unit S2.112 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (371-BF01) on a

monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.112 on an annual basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (371-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in S.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (371-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (371-BF01) will not exceed 0.032 g/dscm (0.014 gr/dscf) (0.40

pound per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 99: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 57

Section V. Specific Operating Conditions (continued) T. Emission Unit PF1.019

Location: North 4,455,878 m, East 381,890 m, UTM (Zone 11, NAD 83)

System 16 – Unit #3 Ore Crushing Unit PF1.019 Unloading from Truck to Hopper (313-HP01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.019 shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.019 shall not exceed 50.0 tons of diatomite per any one-hour period, nor more than 100,000.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.019 may operate 24 hours per day. (2) PF1.019 may operate 6,500 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.019 the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.075 pound per hour, nor more than

0.075 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.028 pound per hour, nor more than 0.028 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.004 pound per hour, nor more than 0.004 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.019 shall not equal or exceed 20

percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.019. b. Monitor and record the total daily hours of operation for PF1.019. c. Record the average hourly throughput rate (in tons per hour) for PF1.019 using the total daily throughput and total

daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in T.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.019 on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the enclosure installed on PF1.019 on a monthly basis to confirm that the enclosure is in place and functioning properly. If the enclosure is in disrepair, the Permittee must perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

Page 100: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 58

Section V. Specific Operating Conditions (continued) T. Emission Unit PF1.019 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in T.4. of this section.

Page 101: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 59

Section V. Specific Operating Conditions (continued) U. Emission Units S2.113 – S2.118

Location: North 4,455,992 m, East 381,820 m, UTM (Zone 11, NAD 83)

System 17 – Unit #3 Ore Crushing Unit Revised Month 2019 S2.113 Hopper (313-HP01) and discharge to Pan Feeder (313-AF01) S2.114 Pan Feeder (313-AF01) and discharge to Crusher (313-HC01) or Belt Conveyor (313-BC01) S2.115 Belt Conveyor (313-BC01) and discharge to Bucket Elevator (313-BE01) S2.116 Crusher (313-HC01) and discharge to Bucket Elevator (313-BE01) S2.117 Bucket Elevator (313-BE01) and discharge to Screw Conveyor (313-SC06) S2.118 Screw Conveyor (313-SC06) and discharge to Ore Bin (313-BI01) and Ore Bin (313-BI02)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.113 – S2.118, combined, shall be controlled by Baghouse (313-BF04). b. Descriptive Stack Parameters

Stack Height: 12.3 feet Stack Diameter: 0.8 feet Stack Temperature: Ambient Exhaust Volume Flow Rate: 2,368.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.113 – S2.118, each, shall not exceed 50.0 tons of diatomite per any one-hour period, nor more than 100,000.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (313-BF04), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.113 – S2.118, each, may operate 24 hours per day. (2) S2.113 – S2.118, each, may operate 6,500 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (313-BF04) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.20 pound per hour, nor more than 0.65

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.20 pound per hour, nor more than 0.65 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.20 pound per hour, nor more than 0.65 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement –The maximum allowable discharge of PM10 to the

atmosphere from S2.113 – S2.118, each, shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (313-

BF04) shall not equal or exceed 20 percent.

Page 102: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 60

Section V. Specific Operating Conditions (continued) U. Emission Units S2.113 – S2.118 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.113 – S2.118, each. b. Monitor and record the total daily hours of operation for S2.113 – S2.118, each. c. Record the average hourly throughput rate (in tons per hour) for S2.113 – S2.118, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in U.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (313-BF04) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.113 – S2.118 on an annual basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (313-BF04) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in U.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (313-BF04) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (313-BF04) will not exceed 0.032 g/dscm (0.014 gr/dscf) (0.28

pound per hour) and 7 percent opacity for dry control device. (40 CFR Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 103: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 61

Section V. Specific Operating Conditions (continued) V. Emission Units PF1.020 – PF1.023

Location: North 4,456,008 m, East 381,807 m, UTM (Zone 11, NAD 83)

System 18 – Unit #3 Ore Crushing Unit Revised Month 2019 PF1.020 Ore Bin (313-BI01) and discharge to Pan Feeder (313-AF02) PF1.021 Ore Bin (313-BI02) and discharge to Pan Feeder (313-AF03) PF1.022 Pan Feeder (313-AF02) and discharge to Mill 3 Chute PF1.023 Pan Feeder (313-AF03) and discharge to Mill 3 Chute

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

PF1.020 – PF1.023, each, has no add-on controls. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.020 – PF1.023, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. A sulfur analyzer shall be calibrated on PF1.022 and PF1.023, each. The sulfur analyzer shall analyze the sulfur content in the diatomite processed.

c. Hours (1) PF1.020 – PF1.023, each, may operate 24 hours per day. (2) PF1.020 – PF1.023, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.020 – PF1.023, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.04 pound per hour, nor more than 0.15

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.013 pound per hour, nor more than 0.056 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.002 pound per hour, nor more than 0.01 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 21.67 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.020 – PF1.023, each, shall not

equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for PF1.020 – PF1.023, each. b. Monitor and record the total daily hours of operation for PF1.020 – PF1.023, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.020 – PF1.023, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in V.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 104: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 62

Section V. Specific Operating Conditions (continued) V. Emission Units PF1.020 – PF1.023 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: f. Monitor and record the sulfur content in weight percent of diatomite on a dry basis. The sulfur content shall be

obtained and analyzed by taking a monthly diatomite sample at PF1.022 and PF1.023, each. Sampling for sulfur will be repeated if a new ore material is loaded into the system.

g. The sulfur analyzer shall undergo a calibration and precision check on a daily basis when operated. Independent sulfur standard shall be run once per month and the balance will be calibrated once a quarter. The analyzer shall be operated, maintained and calibrated according to manufacturer’s instructions. All samples will be desiccated at a low temperature to preserve the sample integrity and limit the loss of sulfur and combustibles.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in V.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.020 – PF1.023, each, will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.020 – PF1.023, each, will not exceed 7 percent opacity. (40 CFR Part

60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 105: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 63

Section V. Specific Operating Conditions (continued) W. Emission Units S2.119A – S2.131A

Location: North 4,456,076 m, East 381,821 m, UTM (Zone 11, NAD 83)

System 19A – Unit #3 Classification and Drying, Natural gas (Primary Scenario) Revised Month 2019 S2.119A Cyclone (313-CN01) and solids discharge to Cyclone (313-CN02)

S2.120A Cyclone (313-CN02) and solids discharge to Whizzer Separator (313-SR01) or fines discharge to Cyclone (313-CN03)

S2.121A Whizzer Separator (313-SR01) and solids discharge to Cyclone (313-CN03) or waste discharge to Screw Conveyor (363-SC01)

S2.122A Cyclone (313-CN03) and solids discharge to Screw Conveyor (313-SC04) or fines discharge to Cyclone (313-CN01) S2.123A Screw Conveyor (313-SC04) and discharge to Screw Conveyor (313-SC05) S2.124A Screw Conveyor (313-SC05) and discharge to Rotary Kiln (323-KL01) S2.125A Rotary Kiln (323-KL01) and exhaust to Hot Air Furnace (313-HG01)

S2.126A Hot Air Furnace (313-HG01) and exhaust to Cyclone (313-CN01), Cyclone (313-CN02), Cyclone (313-CN02), Baghouse (313-BF01) and Baghouse (313-BF02)

S2.127A Baghouse (313-BF01) and discharge to Filter/Receiver (313-BF03) (via 100% enclosed Screw Conveyor 313-SC01) S2.228A Baghouse (313-BF02) and discharge to Filter/Receiver (313-BF03) (via 100% enclosed Screw Conveyor 313-SC02) S2.229A Filter/Receiver (313-BF03) and discharge to Screw Conveyor (313-SC03) S2.230A Screw Conveyor (313-SC03) and discharge to Screw Conveyor (313-SC04) S2.131A Screw Conveyor (363-SC01) discharge to Waste Bin (36A-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.119A – S2.131A, combined, shall be controlled by Baghouse (313-BF01) and (313-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 69.3 feet Stack Diameter: 2.4 feet Stack Temperature: 225°F Exhaust Volume Flow Rate: 22,886.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.119A – S2.131A, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. S2.125A and S2.126A, each, may consume only pipe line natural gas as the primary fuel. c. The maximum allowable natural gas consumption rate for S2.125A shall not exceed 29,411.76 standard cubic feet

(scf) per hour, nor more than 251,470,548.0 scf per year, based on a 12-month rolling period. d. The maximum allowable natural gas consumption rate for S2.0126A shall not exceed 19,607.84 standard cubic feet

(scf) per hour, nor more than 167,647,032.0 scf per year, based on a 12-month rolling period. e. The maximum sulfur content of the pipeline quality natural gas will not exceed 20 grains per 100 cubic feet. This

default maximum sulfur content, sulfur content provided by the supplier, or test result of the sulfur analysis of the pipeline quality natural gas will be used in the SO2 calculations.

f. A fuel flow meter shall be installed and calibrated on S2.125A and S2.126A, each, if one is not already installed. The fuel flow meter shall continuously monitor fuel consumption.

g. A pressure gauge shall be installed and calibrated on Baghouse (313-BF01) and (313-BF02), each, if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

h. Hours (1) S2.053A – S2.063A, each, may operate 24 hours per day. (2) S2.053A – S2.063A, each, may operate 8,550 hours per year.

Page 106: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 64

Section V. Specific Operating Conditions (continued) W. Emission Units S2.119A – S2.131A (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (313-BF01) and (313-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 1.0 pound per hour, nor more than 4.28

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 1.0 pound per hour, nor more than 4.28 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 1.0 pound per hour, nor more than 4.28 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 7.83 pounds per hour, nor more than

33.47 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 12.0 pounds per hour, nor more than 51.3

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.8 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.125A and S2.126A, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.125A and S2.126A, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.119A – S2.124A and S2.127A – S2.131A, each, shall not exceed 21.67 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.119A – S2.124A and S2.127A – S2.131A, each, shall not exceed 29.22 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (312-BF01) and Baghouse (312-BF-02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.119A – S2.131A, each. b. Monitor and record the total daily hours of operation for S2.119A – S2.131A, each. c. Record the average hourly throughput rate (in tons per hour) for S2.119A – S2.131A, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of natural gas consumed (in scf) on a daily basis for S2.125A and S2.126A, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of natural gas (in scf) on a cumulative monthly basis, for each 12-month rolling period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in W.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 107: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 65

Section V. Specific Operating Conditions (continued) W. Emission Units S2.119A – S2.131A (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: h. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (313-BF01) and (313-

BF02), each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.119A – S2.131A on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (313-BF01) and (313-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.125A and S2.126A, each, begin and end combustion of pipeline quality natural gas.

n. The SO2 emissions in tons per month from Baghouse (313-BF01) and (313-BF02), combined, will be calculated using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.022 and PF1.023, each, as required in V.V.4.f., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in W.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly emissions shall be determined at the end of each month as the sum of monthly emissions recorded in W.4.n.(2) through (4) of this section.

Page 108: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 66

Section V. Specific Operating Conditions (continued) W. Emission Units S2.119A – S2.131A (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in W.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (313-BF01) and

(313-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (313-BF01) and (313-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (2.75 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (313-BF01) and (313-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (7.85 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in W.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 109: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 67

Section V. Specific Operating Conditions (continued) X. Emission Units S2.119B – S2.131B

Location: North 4,456,076 m, East 381,821 m, UTM (Zone 11, NAD 83)

System 19B – Unit #3 Classification and Drying, #2 Fuel Oil (Alternate Scenario) Revised Month 2019 S2.119B Cyclone (313-CN01) and solids discharge to Cyclone (313-CN02)

S2.120B Cyclone (313-CN02) and solids discharge to Whizzer Separator (313-SR01) or fines discharge to Cyclone (313-CN03)

S2.121B Whizzer Separator (313-SR01) and solids discharge to Cyclone (313-CN03) or waste discharge to Screw Conveyor (363-SC01)

S2.122B Cyclone (313-CN03) and solids discharge to Screw Conveyor (313-SC04) or fines discharge to Cyclone (313-CN01) S2.123B Screw Conveyor (313-SC04) and discharge to Screw Conveyor (313-SC05) S2.124B Screw Conveyor (313-SC05) and discharge to Rotary Kiln (323-KL01) S2.125B Rotary Kiln (323-KL01) and exhaust to Hot Air Furnace (313-HG01)

S2.126B Hot Air Furnace (313-HG01) and exhaust to Cyclone (313-CN01), Cyclone (313-CN02), Cyclone (313-CN02), Baghouse (313-BF01) and Baghouse (313-BF02)

S2.127B Baghouse (313-BF01) and discharge to Filter/Receiver (313-BF03) (via 100% enclosed Screw Conveyor 313-SC01) S2.228B Baghouse (313-BF02) and discharge to Filter/Receiver (313-BF03) (via 100% enclosed Screw Conveyor 313-SC02) S2.229B Filter/Receiver (313-BF03) and discharge to Screw Conveyor (313-SC03) S2.230B Screw Conveyor (313-SC03) and discharge to Screw Conveyor (313-SC04) S2.131B Screw Conveyor (363-SC01) discharge to Waste Bin (36A-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.119B – S2.131B, combined, shall be controlled by Baghouse (313-BF01) and (313-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 69.3 feet Stack Diameter: 2.4 feet Stack Temperature: 225°F Exhaust Volume Flow Rate: 22,886 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.053B – S2.063B, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. S2.059B and S2.060B, each, may consume #2 fuel oil as the alternate fuel. c. The maximum allowable #2 fuel oil consumption rate for S2.125B shall not exceed 214.29 gallons per hour, nor more

than 1,832,180.0 gallons per year, based on a 12-month rolling period. d. The maximum allowable #2 fuel oil consumption rate for S2.0126B shall not exceed 142.86 gallons per hour, nor

more than 1,221,453.0 gallons per year, based on a 12-month rolling period. e. The maximum sulfur content of #2 fuel oil shall not exceed 0.2 percent by weight. Each vendor delivery shall verify

the sulfur content by certification. f. A fuel flow meter shall be installed and calibrated on S2.125B and S2.126B, each, if one is not already installed. The

fuel flow meter shall continuously monitor fuel consumption. g. A pressure gauge shall be installed and calibrated on Baghouse (313-BF01) and (313-BF02), each, if one is not

already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water. h. Hours

(1) S2.053B– S2.063B, each, may operate 24 hours per day. (2) S2.053B– S2.063B, each, may operate 8,550 hours per year.

Page 110: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 68

Section V. Specific Operating Conditions (continued) X. Emission Units S2.119B – S2.131B (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (313-BF01) and (313-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 1.0 pound per hour, nor more than 4.28

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 1.0 pound per hour, nor more than 4.28 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 1.0 pound per hour, nor more than 4.28 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 7.83 pounds per hour, nor more than

33.47 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 12.0 pounds per hour, nor more than 51.3

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.8 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.125B and S2.126B, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.125B and S2.126B, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.119B – S2.124B and S2.127B – S2.131B, each, shall not exceed 21.67 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.119B – S2.124B and S2.127B – S2.131B, each, shall not exceed 29.22 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (312-BF01) and (312-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.119B – S2.131B, each. b. Monitor and record the total daily hours of operation for S2.119B – S2.131B, each. c. Record the average hourly throughput rate (in tons per hour) for S2.119B – S2.131B, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of #2 fuel oil consumed (in gallons) on a daily basis for S2.125B and S2.126B, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of #2 fuel oil (in gallons) on a cumulative monthly basis, for each 12-month rolling

period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in X.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 111: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 69

Section V. Specific Operating Conditions (continued) X. Emission Units S2.119B – S2.131B (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of

Baghouse (313-BF01) and (313-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.119B – S2.131B on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (313-BF01) and (313-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.125B and S2.126B, each, begin and end combustion of #2 fuel oil. n. The SO2 emissions in tons per month from Baghouse (313-BF01) and (313-BF02), combined, will be calculated

using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.022 and PF1.023, each, as required in V.V.4.f., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in X.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly emissions shall be determined at the end of each month as the sum of monthly emissions recorded in X.4.n.(2) through (4) of this section.

Page 112: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 70

Section V. Specific Operating Conditions (continued) X. Emission Units S2.119B – S2.131B (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in X.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for

Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (313-BF01) and

(313-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (313-BF01) and (313-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (2.75 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (313-BF01) and (313-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (7.85 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in X.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 113: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 71

Section V. Specific Operating Conditions (continued) Y. Emission Units S2.119C – S2.131C

Location: North 4,456,076 m, East 381,821 m, UTM (Zone 11, NAD 83)

System 19C – Unit #3 Classification and Drying, Waste Oil (Alternate Scenario) Revised Month 2019 S2.119C Cyclone (313-CN01) and solids discharge to Cyclone (313-CN02)

S2.120C Cyclone (313-CN02) and solids discharge to Whizzer Separator (313-SR01) or fines discharge to Cyclone (313-CN03)

S2.121C Whizzer Separator (313-SR01) and solids discharge to Cyclone (313-CN03) or waste discharge to Screw Conveyor (363-SC01)

S2.122C Cyclone (313-CN03) and solids discharge to Screw Conveyor (313-SC04) or fines discharge to Cyclone (313-CN01) S2.123C Screw Conveyor (313-SC04) and discharge to Screw Conveyor (313-SC05) S2.124C Screw Conveyor (313-SC05) and discharge to Rotary Kiln (323-KL01) S2.125C Rotary Kiln (323-KL01) and exhaust to Hot Air Furnace (313-HG01)

S2.126C Hot Air Furnace (313-HG01) and exhaust to Cyclone (313-CN01), Cyclone (313-CN02), Cyclone (313-CN02), Baghouse (313-BF01) and Baghouse (313-BF02)

S2.127C Baghouse (313-BF01) and discharge to Filter/Receiver (313-BF03) (via 100% enclosed Screw Conveyor 313-SC01) S2.228C Baghouse (313-BF02) and discharge to Filter/Receiver (313-BF03) (via 100% enclosed Screw Conveyor 313-SC02) S2.229C Filter/Receiver (313-BF03) and discharge to Screw Conveyor (313-SC03) S2.230C Screw Conveyor (313-SC03) and discharge to Screw Conveyor (313-SC04) S2.131C Screw Conveyor (363-SC01) discharge to Waste Bin (36A-BI01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.119C – S2.131C, combined, shall be controlled by Baghouse (313-BF01) and (313-BF02) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 69.3 feet Stack Diameter: 2.4 feet Stack Temperature: 225°F Exhaust Volume Flow Rate: 22,886.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.119C – S2.131C, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. S2.125C and S2.126C, each, may consume waste oil as the alternate fuel. c. The maximum allowable waste oil consumption rate for S2.125C shall not exceed 214.29 gallons per hour, nor more

than 1,832,180.0 gallons per year, based on a 12-month rolling period. d. The maximum allowable waste oil consumption rate for S2.126C shall not exceed 142.86 gallons per hour, nor more

than 1,221,453.0 gallons per year, based on a 12-month rolling period. e. The maximum sulfur content of waste oil shall not exceed 0.5 percent by weight. Each vendor delivery shall verify

the sulfur content by certification, and shall provide metals and hazardous component assay. f. A fuel flow meter shall be installed and calibrated on S2.125C and S2.126C, each, if one is not already installed. The

fuel flow meter shall continuously monitor fuel consumption. g. A pressure gauge shall be installed and calibrated on Baghouse (313-BF01) and (313-BF02), each, if one is not

already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water. h. Hours

(1) S2.053C – S2.063C, each, may operate 24 hours per day. (2) S2.053C – S2.063C, each, may operate 8,550 hours per year.

Page 114: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 72

Section V. Specific Operating Conditions (continued) Y. Emission Units S2.119C – S2.131C (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (313-BF01) and (313-BF02), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 1.0 pound per hour, nor more than 4.28

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 1.0 pound per hour, nor more than 4.28 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 1.0 pound per hour, nor more than 4.28 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 10.50 pounds per hour, nor more than 44.87

tons per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 7.83 pounds per hour, nor more than

33.47 tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 12.0 pounds per hour, nor more than 51.3

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 6.5 pounds per hour, nor

more than 27.8 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.125C and S2.126C, combined, shall not exceed 0.41 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.125C and S2.126C, combined, shall not exceed 35.0 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.119C – S2.124C and S2.127C – S2.131C, each, shall not exceed 21.67 pounds per hour. k. NAC 445B.2205 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.119C – S2.124C and S2.127C – S2.131C, each, shall not exceed 29.22 pounds per hour. l. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (313-BF01) and (313-BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.119C – S2.131C, each. b. Monitor and record the total daily hours of operation for S2.119C – S2.131C, each. c. Record the average hourly throughput rate (in tons per hour) for S2.119C – S2.131C each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of waste oil consumed (in gallons) on a daily basis for S2.125C and S2.126C, each,

using the fuel flow meter. e. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of waste oil (in gallons) on a cumulative monthly basis, for each 12-month rolling

period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in Y.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 115: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 73

Section V. Specific Operating Conditions (continued) Y. Emission Units S2.119C – S2.131C (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued) The Permittee, upon issuance of this operating permit, shall: h. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of

Baghouse (313-BF01) and (313-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouses installed on S2.119C – S2.131C on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (313-BF01) and (313-BF02), each, at least once every shift to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

k. Monitor and record the kiln rear static pressure daily or pursuant to the kiln operations manual, whichever is more frequent. Record any maintenance, repair, or corrective actions taken.

l. Inspect the kiln daily or in accordance to the kiln operation and maintenance manual, whichever is more frequent. Record the results (e.g. improper operation and condition of the rear kiln seals) and any corrective actions taken.

m. Monitor and record the date and time when S2.125C and S2.126C, each, begin and end combustion of waste oil. n. The SO2 emissions in tons per month from Baghouse (313-BF01) and (313-BF02), combined, will be calculated

using the following formula:

2(OFs - Ps +Fs)

Where: OFs = the mass flux of S in the ore kiln feed entering the process Ps = mass flux of S in product Fs = mass flux of S in natural gas, #2 diesel or waste oil fuel. (1) The average hourly SO2 emission rate in pounds per hour shall be calculated from the total monthly SO2

emission rate divided by the total monthly operating hours. (2) The OFs in tons per month shall be calculated using the ore kiln feed throughput (dry basis) multiplied by the

sulfur concentration (percent by weight) in the ore feed. Daily samples of the ore kiln feed and product collected from PF1.022 and PF1.023, each, as required in V.V.4.f., shall be taken, and a monthly composite shall be made from the samples and analyzed for sulfur.

(3) The Ps in tons per month shall be calculated using the product throughput multiplied by the sulfur concentration (percent by weight) in the product.

(4) The Fs in tons per month shall be calculated using the fuel combustion rate of pipeline quality natural gas, #2 fuel oil and waste oil and the sulfur concentration (percent by weight) of each fuel as certified by the vendor. The maximum default S concentration for pipeline quality natural gas listed in Y.2.e. of this section or the sulfur content of the pipeline quality natural gas as provided by supplier will be used.

o. Record the SO2 emissions (in tons) on a cumulative monthly basis, for each 12-month rolling period. The monthly emissions shall be determined at the end of each month as the sum of monthly emissions recorded in Y.4.n.(2) through (4) of this section.

Page 116: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 74

Section V. Specific Operating Conditions (continued) Y. Emission Units S2.119C – S2.131C (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in Y.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (313-BF01) and

(313-BF02), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (313-BF01) and (313-BF02), combined, will not exceed

0.032 g/dscm (0.014 gr/dscf) (2.75 pounds per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(b) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

(2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (313-BF01) and (313-BF02), combined, will not exceed

0.092 g/dscm (0.04 gr/dscf) (7.85 pounds per hour) for calciner and dryers installed in series and 10 percent opacity. (40 CFR 60.732 (a) and (b))

(2) Records of measurements required in Y.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 117: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 75

Section V. Specific Operating Conditions (continued) Z. Emission Units S2.132 – S2.153

Location: North 4,456,016 m, East 381,829 m, UTM (Zone 11, NAD 83)

System 20 – Unit #3 Classification and Drying Revised Month 2019 S2.132 Rotary Kiln #3 (323-KL01) and product discharge to Delumper 333-LC01) S2.133 Delumper (333-LC01) and discharge to Cyclone (333-CN01) S2.134 Cyclone (333-CN01) and solids discharge to Bucket Elevator (333-BE01) or fines discharge to Cyclone (333-CN02) S2.135 Bucket Elevator (333-BE01) and discharge to Screw Conveyor (333-SC01) S2.136 Screw Conveyor (333-SC01) and discharge to Rotex Screen (333-VS01) and Rotex Screen (333-VS02)

S2.137 Rotex Screen (333-VS01) and discharge to Screw Conveyor (333-SC02), Cyclone (333-CN03) or Bucket Elevator (333-BE02)

S2.138 Rotex Screen (333-VS02) and discharge to Screw Conveyor (333-SC02), Cyclone (333-CN03) or Bucket Elevator (333-BE02)

S2.139 Screw Conveyor (333-SC02) and discharge to Hammermill (333-HC01) and Hammermill (333-HC02) S2.140 Hammermill (333-HC01) and discharge to Cyclone (333-CN03) S2.141 Hammermill (333-HC02) and discharge to Cyclone (333-CN03) S2.142 Cyclone (333-CN03) and solids discharge to Cyclone (333-CN02) or Air Slide (333-AS02) S2.143 Air Slide (333-AS02) and discharge to Screw Conveyor (333-SC02) or Bucket Elevator (333-BE02)

S2.144 Cyclone (333-CN02) and solids discharge to Screw Conveyor (333-SC03) or fines discharge to Screw Conveyor (333-SC04)

S2.145 Screw Conveyor (333-SC04) and discharge to Screen (333-VS03)

S2.146 Screw Conveyor (333-SC03) and discharge to Screw Conveyor (333-SC02), Hammermill (333-HC01) or Hammermill (333-HC02)

S2.147 Bucket Elevator (333-BE02) and discharge to Stream Splitter (333-MW01) S2.148 Stream Splitter (333-MW01) and discharge to Rotex Screen (333-VS04) S2.149 Rotex Screen (333-VS04) and discharge to Screw Conveyor (333-SC03) or Air Slide (333-AS01) S2.150 Screw Conveyor (353-SC02) discharge to Bucket Elevator (353-BE02) S2.151 Bucket Elevator (353-BE02) and discharge to Classifier (353-SR01) S2.152 Bag Flattener (403-FQ01) S2.153 Belt Bag Conveyor (403-BC01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.132 – S2.153, combined, shall be controlled by Baghouse (333-BF01), (333-BF02), and (333-BF03) in parallel and ducted to a common exhaust stack.

b. Descriptive Stack Parameters Stack Height: 85.75 feet Stack Diameter: 1.9 feet Stack Temperature: 187°F Exhaust Volume Flow Rate: 14,444.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.132 – S2.153, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (333-BF01), (333-BF02), and (333-BF03), each, if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.132 – S2.153, each, may operate 24 hours per day. (2) S2.132 – S2.153, each, may operate 8,550 hours per year.

Page 118: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 76

Section V. Specific Operating Conditions (continued) Z. Emission Units S2.132 – S2.153 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (333-BF01), (333-BF02), and (333-BF03), combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.80 pound per hour, nor more than 3.42

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.80 pound per hour, nor more than 3.42 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.80 pound per hour, nor more than 3.42 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.132 – S2.153, each, shall not exceed 21.67 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the common exhaust stack of

Baghouse (333-BF01), (333-BF02), and (333-BF03) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.132 – S2.153, each. b. Monitor and record the total daily hours of operation for S2.132 – S2.153, each. c. Record the average hourly throughput rate (in tons per hour) for S2.132 – S2.153, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in Z.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on the common exhaust stack of Baghouse (333-BF01), (333-BF02), and (333-BF03) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.132 – S2.153 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (333-BF01), (333-BF02), and (333-BF03), each, at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

Page 119: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 77

Section V. Specific Operating Conditions (continued) Z. Emission Units S2.132 – S2.153 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in Z.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (333-BF01), (333-

BF02), and (333-BF03), each, will be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (333-BF01), (333-BF02), and (333-BF03), combined, will not

exceed 0.032 g/dscm (0.014 gr/dscf) (1.73 pounds per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b))

b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 120: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 78

Section V. Specific Operating Conditions (continued) AA. Emission Units S2.154 – S2.180

Location: North 4,456,012 m, East 381,834 m, UTM (Zone 11, NAD 83)

System 21 – Unit #3 Classification and Drying Revised Month 2019 S2.154 Screen (333-VS03) and discharge to Main Product Bin (333-BI01) or Bucket Elevator (333-BE01) S2.155 Re-Feed Screw Conveyor (403-SC01) and discharge to Screw Conveyor (403-SC01) S2.156 Air Slide (333-AS01) and discharge to Bagging Bin (333-BI04) S2.157 Bagging Bin (333-BI04) and discharge to Bag Packer (403-PM01)

S2.158 Main Product Bin (333-BI01) and discharge to Screw Conveyor (353-SC01), Cyclone 333-CN02 or Re-Feed Bin (371-BI01)

S2.159 Screw Conveyor (353-SC01) and discharge to Bucket Elevator (353-BE01) S2.160 Bucket Elevator (353-BE01) and discharge to Main Product Bin (333-BI01) or Screw Conveyor (353-SC02) S2.161 Screw Conveyor (353-SC02) and discharge to Bucket Elevator (353-BE02)

S2.162 Classifier (353-SR01) and fines discharge to Classifier (353-CN01) or solids discharge to Bagging Bin (333-BI04)

S2.163 Cyclone (353-CN01) and solids discharge to Screw Conveyor (353-SC03) or fines discharge to Classifier (353-SR01)

S2.164 Screw Conveyor (353-SC03) and discharge to Screw Conveyor (333-SC08) S2.165 Screw Conveyor (333-SC08) and discharge to Bucket Elevator (333-BE03)

S2.166 Bucket Elevator (333-BE03) and discharge to Air Slide (333-AS03), Air Slide (403-AS01), Bagging Bin (333-BI02) or Bagging Bin (333-BI03)

S2.167 Baghouse Packer Bin (333-BI02) and discharge to Bag Packer (403-PM03) or Screw Conveyor (403-SC01) S2.168 Screw Conveyor (403-SC01) and discharge to Bulk Bagger (403-BB01) S2.169 Bulk Bagger (403-BB01) S2.170 Bulk Bagger (403-BB02) S2.171 Air Slide (333-AS03) and discharge to Rotex Screen (333-RS01 ) S2.172 Rotex Screen (333-RS01) discharge to Bulk Bagger Bin (333-BI05) S2.173 Bulk Bagger Bin (333-BI05) and discharge to Bulk Bagger (403-BB02) S2.174 Air Slide (403-AS01) and discharge to Air Slide (403-AS02) S2.175 Air Slide (403-AS02) and discharge to Air Slide (403-AS01), Re-Feed Bin or (371-BI01) Bulk Car S2.176 Bagging Bin (333-BI03) and discharge to Bag Packer (403-PM02) S2.177 Screw Conveyor (333-SC05) and discharge to Screw Conveyor (333-SC08) S2.178 Screw Conveyor (333-SC06) and discharge to Screw Conveyor (333-SC08) S2.179 Screw Conveyor (333-SC07) and discharge to Screw Conveyor (333-SC08) S2.180 Screw Conveyor (373-SC01) and discharge to Cyclone (333-CN01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.154 – S2.180, combined, shall be controlled by Baghouse (403-BF01). b. Descriptive Stack Parameters

Stack Height: 83.0 feet Stack Diameter: 3.2 feet Stack Temperature: 112°F Exhaust Volume Flow Rate: 10,038 dry standard cubic feet per minute (dscfm)

Page 121: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 79

Section V. Specific Operating Conditions (continued) AA. Emission Units S2.154 – S2.180 (continued)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.154 – S2.180, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (403-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.154 – S2.180, each, may operate 24 hours per day. (2) S2.154 – S2.180, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (403-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.43 pound per hour, nor more than 1.84

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.43 pound per hour, nor more than 1.84 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.43 pound per hour, nor more than 1.84 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.154 – S2.180, each, shall not exceed 21.67 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (403-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.154 – S2.180, each. b. Monitor and record the total daily hours of operation for S2.154 – S2.180, each. c. Record the average hourly throughput rate (in tons per hour) for S2.154 – S2.180, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in AA.4.b. for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (403-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.154 – S2.180 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

Page 122: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 80

Section V. Specific Operating Conditions (continued) AA. Emission Units S2.154 – S2.180 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: h. Monitor and record the reading on the pressure gauge on Baghouse (403-BF01) at least once daily to ensure proper

operation. If any of the baghouse pressure drops exceed the optimum range (0.5-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in AA.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (403-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (403-BF01) will not exceed 0.05 g/dscm (0.022 gr/dscf) (1.89

pounds per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 123: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 81

Section V. Specific Operating Conditions (continued) BB. Emission Units S2.181 – S2.183

Location: North 4,456.020 km, East 381.840 km, UTM (Zone 11, NAD 83)

System 22 – Unit #3 Classification and Drying Revised Month 2019 S2.181 Bag Packer (403-PM01) S2.182 Bag Packer (403-PM02) S2.183 Bag Packer (403-PM03)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.181 – S2.183, combined, shall be controlled by Baghouse (403-BF02). b. Descriptive Stack Parameters

Stack Height: 74.42 feet Stack Diameter: 2.0 feet Stack Temperature: 110°F Exhaust Volume Flow Rate: 15,018.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.181 – S2.183, each, shall not exceed 12.0 tons of diatomite per any one-hour period, nor more than 102,600.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (403-BF02), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.181 – S2.183, each, may operate 24 hours per day. (2) S2.181 – S2.183, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (403-BF02) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.64 pound per hour, nor more than 2.75

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.64 pound per hour, nor more than 2.75 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.64 pound per hour, nor more than 2.75 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.181 – S2.183, each, shall not exceed 21.67 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (403-

BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.181 – S2.183, each. b. Monitor and record the total daily hours of operation for S2.181 – S2.183, each. c. Record the average hourly throughput rate (in tons per hour) for S2.181 – S2.183, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period.

Page 124: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 82

Section V. Specific Operating Conditions (continued) BB. Emission Units S2.181 – S2.183 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in BB.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (403-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A

g. Inspect the baghouse installed on S2.181 – S2.183 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (403-BF02) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in BB.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (403-BF02) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (403-BF02) will not exceed 0.05 g/dscm (0.022 gr/dscf) (2.83

pounds per hour). (40 CFR Part 60.672(b)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 125: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 83

Section V. Specific Operating Conditions (continued) CC Emission Units S2.184 and S2.185

Location: North 4,456,037 m, East 381,833 m, UTM (Zone 11, NAD 83)

System 23A – Unit #1 and #2 Soda Ash Bin – Loading S2.184 Soda Ash Bin (341-BI01), Loading by Truck S2.185 Soda Ash Bin (342-BI01), Loading by Truck

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.184 and S2.185, combined, shall be controlled by Baghouse (34A-BF01). b. Descriptive Stack Parameters

Stack Height: 44.0 feet Stack Dimensions: 0.75 x 0.58 feet Stack Temperature: 130°F Exhaust Volume Flow Rate: 5,000.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.184 and S2.185, combined, shall not exceed 30.0 tons of soda ash per any one-hour period, nor more than 15,390.0 tons per year, based on a 12-month rolling period.

b. Hours (1) S2.184 and S2.185, each, may operate 24 hours per day. (2) S2.184 and S2.185, each, may operate 2,000 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from S2.184 and S2.185, combined, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.030 pound per hour, nor more than

0.008 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.010 pound per hour, nor more than 0.003 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.002 pound per hour, nor more than 0.0004 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.184 and S2.185, combined, shall not exceed 39.96 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (34A-

BF01) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of soda ash (in tons) for S2.184 and S2.185, each. b. Monitor and record the total daily hours of operation for S2.184 and S2.185, each. c. Record the average hourly throughput rate (in tons per hour) for S2.184 and S2.185, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of soda ash (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in CC.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 126: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 84

Section V. Specific Operating Conditions (continued) CC. Emission Units S2.184 and S2.185 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: f. Conduct and record an observation of visible emissions (excluding water vapor) on the baghouse controlling S2.184

and S2.185 on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.184 and S2.185 on an annual basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric), and any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in CC.4. of this section.

Page 127: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 85

Section V. Specific Operating Conditions (continued) DD. Emission Units PF1.024 and PF2.025

PF1.024 Location: North 4,456,036 m, East 381,742 m, UTM (Zone 11, NAD 83) PF1.025 Location: North 4,456,037 m, East 381,833 m, UTM (Zone 11, NAD 83)

System 23B – Unit #1 and #2 Soda Ash Bin – Unloading PF1.024 Soda Ash Bin (341-BI01), Unloading to Weigh Feeder (341-WF01) PF1.025 Soda Ash Bin (342-BI01), Unloading to Weigh Feeder (342-WF01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.024 and PF1.025, each, shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.024 and PF1.025, each, shall not exceed 0.9 tons of soda ash per any one-hour period, nor more than 7,695.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.024 and PF1.025, each, may operate 24 hours per day. (2) PF1.024 and PF1.025, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.024 and PF1.025, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.002 pound per hour, nor more than

0.009 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.001 pound per hour, nor more than 0.005 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.0002 pound per hour, nor more than 0.0008 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 3.82 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.024 and PF1.025, each, shall not

equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of soda ash (in tons) for PF1.024 and PF1.025, each. b. Monitor and record the total daily hours of operation for PF1.024 and PF1.025, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.024 and PF1.025, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of soda ash (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in DD.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.024 and PF1.025, each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test shall be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

Page 128: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 86

Section V. Specific Operating Conditions (continued) DD. Emission Units PF1.024 and PF1.025 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: g. Inspect the enclosure installed on PF1.024 and PF1.025, each, on a monthly basis to confirm that the enclosure is in

place and functioning properly. If the enclosure is in disrepair, the Permittee shall perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in DD.4. of this section.

Page 129: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 87

Section V. Specific Operating Conditions (continued) EE. Emission Unit S2.186

Location: North 4,456,037 m, East 381,833 m, UTM (Zone 11, NAD 83)

System 24A – Unit #3 Soda Ash Bin – Loading S2.186 Soda Ash Bin (343-BI01), Loading from Truck

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.186 shall be controlled by Bin Vent (343-BF01). b. Descriptive Stack Parameters

Stack Height: 41.0 feet Stack Dimensions: 0.87 x 0.70 feet Stack Temperature: 130°F Exhaust Volume Flow Rate: 1,000.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.185 shall not exceed 30.0 tons of soda ash per any one-hour period, nor more than 7,695.0 tons per year, based on a 12-month rolling period.

b. Hours (1) S2.186 may operate 24 hours per day. (2) S2.186 may operate 2,000 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from S2.186 the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.030 pound per hour, nor more than

0.004 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.010 pound per hour, nor more than 0.001 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.002 pound per hour, nor more than 0.0002 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 39.96 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from S2.186 shall not equal or exceed 20

percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of soda ash (in tons) for S2.186. b. Monitor and record the total daily hours of operation for S2.186. c. Record the average hourly throughput rate (in tons per hour) for S2.186 using the total daily throughput and total

daily hours of operation. d. Record the throughput rate of soda ash (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in EE.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 130: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 88

Section V. Specific Operating Conditions (continued) EE. Emission Unit S2.186 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: f. Conduct and record an observation of visible emissions (excluding water vapor) on the bin vent on a monthly basis

while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A

g. Inspect the bin vent installed on S2.186 on an annual basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in EE.4. of this section.

Page 131: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 89

Section V. Specific Operating Conditions (continued) FF. Emission Unit PF1.026

Location: North 4,456,037 m, East 381,833 m, UTM (Zone 11, NAD 83)

System 24B – Unit #3 Soda Ash Bin – Unloading PF1.026 Soda Ash Bin (343-BI01), Unloading to Weigh Feeder (343-WF01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.026 shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.026 shall not exceed 0.9 tons of soda ash per any one-hour period, nor more than 7,695.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.026 may operate 24 hours per day. (2) PF1.026 may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.026 the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.002 pound per hour, nor more than

0.009 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.001 pound per hour, nor more than 0.005 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.0002 pound per hour, nor more than 0.0008 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 3.82 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.026 shall not equal or exceed 20

percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of soda ash (in tons) for PF1.026. b. Monitor and record the total daily hours of operation for PF1.026. c. Record the average hourly throughput rate (in tons per hour) for PF1.026 using the total daily throughput and total

daily hours of operation. d. Record the throughput rate of soda ash (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in FF.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.026 on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test shall be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the enclosure installed on PF1.026 on a monthly basis to confirm that the enclosure is in place and functioning properly. If the enclosure is in disrepair, the Permittee shall perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

Page 132: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 90

Section V. Specific Operating Conditions (continued) FF. Emission Unit PF1.026 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in FF.4. of this section.

Page 133: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 91

Section V. Specific Operating Conditions (continued)

GG. Emission Units PF1.027 – PF1.032 PF1.027 Location: North 4,456,036 m, East 381,742 m, UTM (Zone 11, NAD 83) PF1.028 Location: North 4,455,920 m, East 381,932 m, UTM (Zone 11, NAD 83) PF1.029 Location: North 4,456,037 m, East 381,833 m, UTM (Zone 11, NAD 83) PF1.030 Location: North 4,456,036 m, East 381,742 m, UTM (Zone 11, NAD 83) PF1.031 Location: North 4,455,920 m, East 381,932 m, UTM (Zone 11, NAD 83) PF1.032 Location: North 4,455,910 m, East 381,920 m, UTM (Zone 11, NAD 83)

System 25 – Soda Ash Processing PF1.027 Weigh Feeder (341-WF01) and discharge to Soda Ash Mill (341-HC01) PF1.028 Weigh Feeder (342-WF01) and discharge to Soda Ash Mill (342-HC01) PF1.029 Weigh Feeder (343-WF01) and discharge to Soda Ash Mill (343-HC01) PF1.030 Soda Ash Mill (341-HC01) and discharge to Cyclone (311-CN03) PF1.031 Soda Ash Mill (342-HC01) and discharge to Cyclone (312-CN01) or Cyclone (312-CN03) PF1.032 Soda Ash Mill (343-HC01) and discharge to Cyclone (313-CN03)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.027 – PF1.032, each, shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.027 – PF1.032, each shall not exceed 0.9 tons of soda ash per any one-hour period, nor more than 7,695.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.027 – PF1.032, each may operate 24 hours per day. (2) PF1.027 – PF1.032, each may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.027 – PF1.032, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.002 pound per hour, nor more than

0.009 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.001 pound per hour, nor more than 0.005 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.0002 pound per hour, nor more than 0.0008 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 3.82 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.027 – PF1.032, each, shall not

equal or exceed 20 percent.

Page 134: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 92

Section V. Specific Operating Conditions (continued) GG. Emission Units PF1.027 – PF1.032 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of soda ash (in tons) for PF1.027 – PF1.032, each. b. Monitor and record the total daily hours of operation for PF1.027 – PF1.032, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.027 – PF1.032, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of soda ash (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in GG.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.027 – PF1.032, each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the enclosure installed on PF1.027 – PF1.032 on a monthly basis to confirm that the enclosure is in place and functioning properly. If the enclosure is in disrepair, the Permittee must perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in GG.4. of this section.

Page 135: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 93

Section V. Specific Operating Conditions (continued) HH. Emission Units S2.187 – S2.189

Location: North 4,456.011 km, East 381.843 km, UTM (Zone 11, NAD 83)

System 26 – Waste Bin Operation Revised Month 2019 S2.187 Waste Bin (36A-BI01), Loading S2.188 Waste Bin (36A-BI01), Unloading to Truck S2.189 Snorkel (36A-LA01) and Truck Loading of Waste (Includes Loading Building Ventilation) (36A-LA01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.187 – S2.189, combined, shall be controlled by Baghouse (36A-BF01). b. Descriptive Stack Parameters

Stack Height: 63.8 feet Stack Diameter: 1.3 feet Stack Temperature: Ambient Exhaust Volume Flow Rate: 2,506.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.187 – S2.189, each, shall not exceed 42.0 tons of diatomaceous earth and perlite per any one-hour period, nor more than 367,920.0 tons per year, based on a 12-month rolling period.

b. Hours (1) S2.187 – S2.189, each, may operate 24 hours per day.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (36A-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.47 pound per hour, nor more than 2.07

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.47 pound per hour, nor more than 2.07 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.47 pound per hour, nor more than 2.07 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.187 – S2.189, each, shall not exceed 42.97 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (36A-

BF01) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomaceous earth and perlite (in tons) for S2.187 – S2.189, each. b. Monitor and record the total daily hours of operation for S2.187 – S2.189, each. c. Record the average hourly throughput rate (in tons per hour) for S2.187 – S2.189, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomaceous earth and perlite (in tons) on a cumulative monthly basis, for each 12-

month rolling period.

Page 136: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 94

Section V. Specific Operating Conditions (continued) HH. Emission Units S2.187 – S2.189 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: e. Conduct and record an observation of visible emissions (excluding water vapor) on the baghouse controlling S2.187 –

S2.189 on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

f. Inspect the baghouse installed on S2.187 – S2.189 on an annual basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric), and any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in HH.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (36A-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (36A-BF01) will not exceed 0.05 g/dscm (0.022 gr/dscf) (0.47

pounds per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 137: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 95

Section V. Specific Operating Conditions (continued) II. Emission Units PF1.033 – PF1.035

Location: North 4,455.977 km, East 381.994 km, UTM (Zone 11, NAD 83)

System 27 – Perlite Sizing and Drying Revised Month 2019 PF1.033 Truck unloading to Perlite Ore Dump (314-HP01) PF1.034 Perlite Ore Dump (314-HP01) and discharge to Vibratory Feeder (314-VF01) PF1.035 Vibratory Feeder (314-VF01) and discharge to Belt Conveyor (314-BC01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.033 – PF1.035, each, shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.033 – PF1.035, each, shall not exceed 50.0 tons of perlite per any one-hour period, nor more than 427,500.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.033 – PF1.035, each, may operate 24 hours per day. (2) PF1.033 – PF1.035, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.033 – PF1.035, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.08 pound per hour, nor more than 0.32

ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.03 pound per hour, nor more than 0.12 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.004 pound per hour, nor more than 0.018 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.033 – PF1.035, each, shall not

equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of perlite (in tons) for PF1.033 – PF1.035, each. b. Monitor and record the total daily hours of operation for PF1.033 – PF1.035, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.033 – PF1.035, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of perlite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in II.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.033 – PF1.035, each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sum oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

Page 138: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 96

Section V. Specific Operating Conditions (continued) II. Emission Units PF1.033 – PF1.035 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: g. Inspect the enclosure installed on PF1.033 – PF1.035 on a monthly basis to confirm that the enclosure is in place and

functioning properly. If the enclosure is in disrepair, the Permittee shall perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in II.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.034 and PF1.035, each, will

be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.034 and PF1.035, each, will not exceed 7 percent opacity. (40 CFR Part

60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 139: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 97

Section V. Specific Operating Conditions (continued) JJ. Emission Units S2.190 – S2.203

Location: North 4,455.961 km, East 381.965 km, UTM (Zone 11, NAD 83)

System 28 – Perlite Sizing and Drying Revised Month 2019 S2.190 Ore Belt Conveyor (314-BC01) and discharge to Jaw Crusher (314-JC01) or fines discharge to Cyclone (314-CN01)

S2.191 Jaw Crusher (314-JC01) and solids discharge to Bucket Elevator (314-BE01) or fines discharge to Cyclone (314-CN01)

S2.192 Bucket Elevator (314-BE01) solids discharge to Surge Bin (314-BI01) or fines discharge to Cyclone (314-CN01) S2.193 Surge Bin (314-BI01) and discharge to Vibrating Feeder (314-SC01) S2.194 Vibrating Feeder (314-SC01) and discharge to Rotary Dryer (314-DR01) S2.195 Rotary Dryer (314-DR01) and exhaust to Cyclone (314-CN01) and solids discharge to Belt Conveyor (314-BC01) S2.196 Belt Conveyor (314-BC01) and discharge to Bucket Elevator (314-BE02) or fines discharge to Cyclone (314-CN01) S2.197 Bucket Elevator (314-BE02) and discharge to Vibrating Screen (314-VS01)

S2.198 Vibrating Screen (314-VS01) and discharge to Cyclone (314-CN01), Bucket Elevator (314-BE03) or VSI Impact Mill (314-IM01)

S2.199 VSI Impact Mill (314-IM01) and discharge to Bucket Elevator (314-BE02)

S2.200 Bucket Elevator (314-BE03) and fines discharge to Cyclone (314-CN01) or solids discharge to Surge Bin (314-BI02) and Surge Bin (314-BI03)

S2.201 Surge Bin (314-BI02) and discharge to Belt Conveyor (404-BC01) S2.202 Surge Bin (314-BI03) and discharge to Belt Conveyor (404-BC01) S2.203 Cyclone (314-CN01) and discharge to Bucket Elevator (314-BE03)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.190 – S2.203, combined, shall be controlled by Baghouse (314-BF01). b. Descriptive Stack Parameters

Stack Height: 50.0 feet Stack Diameter: 2.1 feet Stack Temperature: 85°F Exhaust Volume Flow Rate: 10,523.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.190 – S2.203, each, shall not exceed 50.0 tons of perlite per any one-hour period, nor more than 427,500.0 tons per year, based on a 12-month rolling period.

b. S2.195 may consume only pipe line natural gas as the primary fuel. c. The maximum allowable natural gas consumption rate for S2.195 shall not exceed 3,029.0 standard cubic feet (scf)

per hour, nor more than 25,897,950.0 scf per year, based on a 12-month rolling period. d. The maximum sulfur content of the pipeline quality natural gas will not exceed 20 grains per 100 cubic feet. This

default maximum sulfur content, sulfur content provided by the supplier, or test result of the sulfur analysis of the pipeline quality natural gas will be used in the SO2 calculations.

e. A fuel flow meter shall be installed and calibrated on S2.195 if one is not already installed. The fuel flow meter shall continuously monitor fuel consumption.

f. A pressure gauge shall be installed and calibrated on Baghouse (314-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

g. Hours (1) S2.190 – S2.203, each, may operate 24 hours per day. (2) S2.190 – S2.203, each, may operate 8,550 hours per year.

Page 140: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 98

Section V. Specific Operating Conditions (continued) JJ. Emission Units S2.190 – S2.203 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (314-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.70 pound per hour, nor more than 2.99

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.70 pound per hour, nor more than 2.99 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.70 pound per hour, nor more than 2.99 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 0.010 pound per hour, nor more than 0.043

ton per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 0.50 pound per hour, nor more than 2.14

tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 1.50 pounds per hour, nor more than 6.41

tons per 12-month rolling period. g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 1.50 pounds per hour, nor

more than 6.41 tons per 12-month rolling period. h. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.195 shall not exceed 2.16 pounds per hour. i. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.190 – S2.203, each, shall not exceed 44.58 pounds per hour. j. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (314-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of perlite (in tons) for S2.190 – S2.203, each. b. Monitor and record the total daily hours of operation for S2.190 – S2.203, each. c. Record the average hourly throughput rate (in tons per hour) for S2.190 – S2.203, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of natural gas consumed (in scf) on a daily basis for S2.195, each, using the fuel flow

meter. e. Record the throughput rate of perlite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of natural gas (in scf) on a cumulative monthly basis, for each 12-month rolling period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in JJ.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

h. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (314-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouse installed on S2.190 – S2.203 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

Page 141: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 99

Section V. Specific Operating Conditions (continued) JJ. Emission Units S2.190 – S2.203 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: j. Monitor and record the reading on the pressure gauge on Baghouse (314-BF01) at least once daily to ensure proper

operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in JJ.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (314-BF01) will

be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (314-BF01) will not exceed 0.032 g/dscm (0.014 gr/dscf)

(1.26 pounds per hour). (40 CFR Part 60.672(b)) (2) The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or

after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

(3) Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, (a) Particulate Matter emissions from Baghouse (314-BF01) will not exceed 0.057 g/dscm (0.025 gr/dscf)

(2.25 pounds per hour) for dryers and 10 percent opacity. (40 CFR 60.732 (a) and (b)) (2) Records of measurements required in JJ.6.b.1.(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 142: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 100

Section V. Specific Operating Conditions (continued) KK. Emission Units S2.204 – S2.213

Location: North 4,455,962 m, East 381,951 m, UTM (Zone 11, NAD 83)

System 29 – Perlite Sizing and Drying Revised Month 2019

S2.204 Belt Conveyor (404-BC02) and discharge to Diverter (404-MW01), Cross Conveyor (404-BC03) and Bulk Rail Car (404-LA01)

S2.205 Belt Conveyor (404-BC02) and discharge to Diverter (404-MW01), Cross Conveyor (404-BC03) and Bulk Rail Car (404-LA01)

S2.206 Cross Conveyor (404-BC03) and discharge to Shuttle Conveyor (404-BC04) S2.207 Shuttle Conveyor (404-BC04) and discharge to Bulk Car Rail (404-LA02) S2.208 Transfer of waste from Baghouse (314-BF01) to Waste Bin (36A-BI01) S2.209 Transfer of waste from Baghouse (334-BF02) to Waste Bin (36A-BI01) S2.210 Transfer of waste from Baghouse (364-BF01) to Waste Bin (36A-BI01) S2.211 Bulk Rail Car (404-LA01) transfer to Bulk Truck S2.212 Bulk Rail Car (404-LA02) transfer to Bulk Truck S2.213 Bulk Truck to Blue Baghouse (404-BF01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.204 – S2.213, combined, shall be controlled by Blue Baghouse (404-BF01). Blue Baghouse (404-BF01) exhausts to Baghouse (364-BF01).

b. Descriptive Stack Parameters Stack Height: 50.0 feet Stack Diameter: 1.83 feet Stack Temperature: Ambient Exhaust Volume Flow Rate: 8,000.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.204 – S2.213, each, shall not exceed 50.0 tons of perlite per any one-hour period, nor more than 427,500.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (364-BF01), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.204 – S2.213, each, may operate 24 hours per day. (2) S2.204 – S2.213, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (314-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.34 pound per hour, nor more than 1.47

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.34 pound per hour, nor more than 1.47 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.34 pound per hour, nor more than 1.47 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.204 – S2.213, each, shall not exceed 44.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (364-

BF01) shall not equal or exceed 20 percent.

Page 143: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 101

Section V. Specific Operating Conditions (continued) KK. Emission Units S2.204 – S2.213 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of perlite (in tons) for S2.204 – S2.213, each. b. Monitor and record the total daily hours of operation for S2.204 – S2.213, each. c. Record the average hourly throughput rate (in tons per hour) for S2.204 – S2.213, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of perlite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in KK4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (364-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.204 – S2.213 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (364-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in KK.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (364-BF01) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (364-BF01) will not exceed 0.05 g/dscm (0.022 gr/dscf) (1.51

pound per hour) and 7 percent opacity for dry control devices on individual enclosed storage bins. (40 CFR Part 60.672(b))

(2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and malfunction. (40 CFR 60.11(c))

b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 144: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 102

Section V. Specific Operating Conditions (continued) LL. Emission Units S2.214 – S2.221

Location: North 4,455,927 m, East 381,942 m, UTM (Zone 11, NAD 83)

System 30 – Perlite Transfer/Perlite Expander and Classification Revised Month 2019 S2.214 Surge Bin (314-BI02) and discharge to Vibrating Conveyor (324-VC01) S2.215 Surge Bin (314-BI03) and discharge to Vibrating Conveyor (324-VC01) S2.216 Vibrating Conveyor (324-VC01) and discharge to Expander Elevator (324-BE01) S2.217 Expander Elevator (324-BE01) and discharge to Ore Feed Bin (324-BI01) S2.218 Ore Feed Bin (324-BI01) and discharge to Screw Conveyor (324-SC01) S2.219 Screw Conveyor (324-SC01) and discharge to M-30 Expander (324-ED01) S2.220 M-30 Expander (324-ED01) and exhaust/product to Cyclone (334-CN01) S2.221 Cyclone (334-CN01) and solids discharge to Expander Degritter (324-DT01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.214 – S2.221, combined, shall be controlled by Baghouse (334-BF01). b. Descriptive Stack Parameters

Stack Height: 55.4 feet Stack Diameter: 1.9 feet Stack Temperature: 260°F Exhaust Volume Flow Rate: 6,231.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.214 – S2.221, each, shall not exceed 2.5 tons of perlite per any one-hour period, nor more than 21,375.0 tons per year, based on a 12-month rolling period.

b. S2.220 may consume only pipe line natural gas as the primary fuel. c. The maximum allowable natural gas consumption rate for S2.220 shall not exceed 7,843.0 standard cubic feet (scf)

per any one-hour period, nor more than 67,057,650.0 scf per year, based on a 12-month rolling period. d. A pressure gauge shall be installed and calibrated on Baghouse (334-BF01), if one is not already installed. The

pressure gauge shall continuously monitor the pressure drop in inches of water. d. Hours

(1) S2.214 – S2.221, each, may operate 24 hours per day. (2) S2.214 – S2.221, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (334-BF01) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.27 pound per hour, nor more than 1.14

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.27 pound per hour, nor more than 1.14 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.27 pound per hour, nor more than 1.14 tons per 12-month rolling period. d. The discharge of SO2 (sulfur dioxide) to the atmosphere shall not exceed 0.020 pound per hour, nor more than 0.086

ton per 12-month rolling period. e. The discharge of NOX (nitrogen oxides) to the atmosphere shall not exceed 0.75 pound per hour, nor more than 3.21

tons per 12-month rolling period. f. The discharge of CO (carbon monoxide) to the atmosphere shall not exceed 0.50 pound per hour, nor more than 2.14

tons per 12-month rolling period.

Page 145: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 103

Section V. Specific Operating Conditions (continued) LL. Emission Units S2.214 – S2.221 (continued)

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (334-BF01) the following pollutants in excess of the following specified limits: g. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 1.50 pounds per hour, nor

more than 6.41 tons per 12-month rolling period. h. NAC 445B.2203 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.190 – S2.203, each, shall not exceed 0.60 pound per MMBtu. i. NAC 445B.22047 Federally Enforceable SIP Requirement – The maximum allowable discharge of sulfur to the

atmosphere from S2.190 – S2.203, each, shall not exceed 5.60 pounds per hour. j. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.190 – S2.203, each, shall not exceed 7.58 pounds per hour. k. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (334-

BF01) shall not equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of perlite (in tons) for S2.190 – S2.203, each. b. Monitor and record the total daily hours of operation for S2.190 – S2.203, each. c. Record the average hourly throughput rate (in tons per hour) for S2.190 – S2.203, each, using the total daily

throughput and total daily hours of operation. d. Monitor and record the amount of natural gas consumed (in scf) on a daily basis for S2.220, using the fuel flow

meter. e. Record the throughput rate of perlite (in tons) on a cumulative monthly basis, for each 12-month rolling period. f. Record the consumption rate of natural gas (in scf) on a cumulative monthly basis, for each 12-month rolling period. g. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in LL.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

h. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (334-BF01) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

i. Inspect the baghouse installed on S2.214 – S2.221 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

j. Monitor and record the reading on the pressure gauge on Baghouse (334-BF01) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

Page 146: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 104

Section V. Specific Operating Conditions (continued) LL. Emission Units S2.214 – S2.221 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in LL.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants (1) On and after the sixtieth day after achieving the maximum production rate at which Baghouse (334-BF01) will

be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from Baghouse (334-BF01) will not exceed 0.032 g/dscm (0.014 gr/dscf)

(0.75 pound per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) (2) Notifications and reports required under this subpart and under subpart A of this part to demonstrate

compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

b. New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart UUU – Standards of Performance for Calciners and Dryers in Mineral Industries (1) On and after the date on which the initial performance test is completed, but not later than 180 days after the

initial startup, whichever date comes first, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (a) Particulate Matter emissions from S2.220 will not exceed 0.057 g/dscm (0.025 gr/dscf) (1.34 pounds per

hour) for dryers and 10 percent opacity. (40 CFR 60.732 (a) and (b)) (2) Records of measurements required in LL.6.b.(1)(a) shall be retained for at least 2 years. (40 CFR 60.735(a)) (3) The Permittee shall submit written reports semiannually of exceedances of control device operating

parameters. (40 CFR 60.735(c))

Page 147: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 105

Section V. Specific Operating Conditions (continued) MM. Emission Units S2.222 – S2.232

Location: North 4,455,913 m, East 381,932 m, UTM (Zone 11, NAD 83)

System 31 – Perlite Transfer/Perlite Expander and Classification S2.222 Expander Degritter (334-DT01) and discharge to Milling Fan (334-FN03) S2.223 Milling Fan (334-FN03) and discharge to Air Classifier (334-SR01)

S2.224 Air Classifier (334-SR01) and fines discharge to Cyclone (334-CN02) or solids discharge to Finish Degritter (334-DT02)

S2.225 Finish Degritter (334-DT02) and discharge to Milling Fan (334-FN03) S2.226 Cyclone (334-CN02) and solids discharge to Screw Conveyor (334-SC01) S2.227 Screw Conveyor (334-SC01) and discharge to Bucket Elevator (334-BE01) and Rail Car S2.228 Bucket Elevator (334-BE01) and discharge to Product Bin (334-BI01) S2.229 Product Bin (334-BI01) and discharge to Packer (404-PM01) and Packer (404-PM02) S2.230 Bag Packer (404-PM01) S2.231 Bag Packer (404-PM02) S2.232 Bulk Bagger (404-BB01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.222 – S2.232, combined, shall be controlled by Baghouse (334-BF02). b. Descriptive Stack Parameters

Stack Height: 58.6 feet Stack Diameter: 1.81 feet Stack Temperature: 132°F Exhaust Volume Flow Rate: 5,535.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.222 – S2.232, each, shall not exceed 2.5 tons of perlite per any one-hour period, nor more than 21,375.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (334-BF02), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.222 – S2.232, each, may operate 24 hours per day. (2) S2.222 – S2.232, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (334-BF02) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.33 pound per hour, nor more than 1.42

tons per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.33 pound per hour, nor more than 1.42 tons per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.33 pound per hour, nor more than 1.42 tons per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere from S2.222 – S2.232, each, shall not exceed 7.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (334-

BF02) shall not equal or exceed 20 percent.

Page 148: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 106

Section V. Specific Operating Conditions (continued) MM. Emission Units S2.222 – S2.232 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of perlite (in tons) for S2.222 – S2.232, each. b. Monitor and record the total daily hours of operation for S2.222 – S2.232, each. c. Record the average hourly throughput rate (in tons per hour) for S2.222 – S2.232, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of perlite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in MM.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (334-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.222 – S2.232 on a quarterly basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (334-BF02) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in MM.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

7. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (334-BF02) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (334-BF02) will not exceed 0.05 g/dscm (0.022 gr/dscf) (1.04

pound per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 149: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 107

Section V. Specific Operating Conditions (continued)

NN. Emission Units PF1.036 and PF1.037 PF1.036 Location: North 4,455,923 m, East 381,935 m, UTM (Zone 11, NAD 83) PF1.037 Location: North 4,455,920 m, East 381,932 m, UTM (Zone 11, NAD 83)

System 32 – Perlite Transfer/Perlite Expander and Classification PF1.036 Expander Degritter (334-DT01) and discharge to Waste PF1.037 Finish Degritter (334-DT02) and discharge to Waste

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.036 and PF1.037, each, shall be controlled by an Enclosure. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.036 and PF1.037, each, shall not exceed 2.5 tons of perlite per any one-hour period, nor more than 21,375.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.036 and PF1.037, each, may operate 24 hours per day. (2) PF1.036 and PF1.037, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.036 and PF1.037, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.004 pound per hour, nor more than

0.016 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.001 pound per hour, nor more than 0.006 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.0002 pound per hour, nor more than 0.0009 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 7.58 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.036 and PF1.037, each, shall not

equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of perlite (in tons) for PF1.036 and PF1.037, each. b. Monitor and record the total daily hours of operation for PF1.036 and PF1.037, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.036 and PF1.037, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of perlite (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in NN.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on PF1.036 and PF1.037, each, on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee will conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

Page 150: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 108

Section V. Specific Operating Conditions (continued) NN. Emission Units PF1.036 and PF1.037 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

The Permittee, upon issuance of this operating permit, shall: g. Inspect the enclosure installed on PF1.036 and PF1.037 on a monthly basis to confirm that the enclosure is in place

and functioning properly. If the enclosure is in disrepair, the Permittee must perform corrective action within 24 hours to ensure that the enclosure is functioning properly.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in NN.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which PF1.036 and PF1.037, each, will

be operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Process fugitive emissions from PF1.036 and PF1.037, each, will not exceed 10 percent opacity. (40 CFR

Part 60.672(b)) (2) The opacity standard set forth in this part shall apply at all times except during period of startup, shutdown, and

malfunction. (40 CFR 60.11(c)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 151: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 109

Section V. Specific Operating Conditions (continued) OO. Emission Units S2.233 – S2.235

Location: North 4,455,935 m, East 381,699 m, UTM (Zone 11, NAD 83)

System 33 – Ribbon Blender

Raw Material (Cellulose and Calcined Diatomaceous Earth) Hand Loaded to Dual Screw Ribbon Blender (40A-MI01)

S2.233 Dual Screw Ribbon Blender (40A-MI01) and discharge to Screw Conveyor (40A-SC01) S2.234 Screw Conveyor (40A-SC01) and discharge to Bagger (40A-PM01) S2.235 Bulk Bagger (40A-EH01) to Bulk Bagger (40A-BB01)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.233 – S2.235, combined, shall be controlled by Baghouse (40A-BF02). b. Descriptive Stack Parameters

Stack Height: 16.0 feet Stack Diameter: 0.75 feet Stack Temperature: 107°F Exhaust Volume Flow Rate: 1,939.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.233 – S2.235, each, shall not exceed 0.8 ton of diatomite per any one-hour period, nor more than 6,840.0 tons per year, based on a 12-month rolling period.

b. A pressure gauge shall be installed and calibrated on Baghouse (40A-BF02), if one is not already installed. The pressure gauge shall continuously monitor the pressure drop in inches of water.

c. Hours (1) S2.233 – S2.235, each, may operate 24 hours per day. (2) S2.233 – S2.235, each, may operate 8,550 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of Baghouse (40A-BF02) the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.083 pound per hour, nor more than

0.36 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.083 pound per hour, nor more than 0.36 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.083 pound per hour, nor more than 0.36 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 3.53 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse (40A-

BF02) shall not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite (in tons) for S2.233 – S2.235, each. b. Monitor and record the total daily hours of operation for S2.233 – S2.235, each. c. Record the average hourly throughput rate (in tons per hour) for S2.233 – S2.235, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of diatomite (in tons) on a cumulative monthly basis, for each 12-month rolling period.

Page 152: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 110

Section V. Specific Operating Conditions (continued) OO. Emission Units S2.233 – S2.235 (continued)

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (controlled)

The Permittee, upon issuance of this operating permit, shall: e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in OO.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

f. Conduct and record an observation of visible emissions (excluding water vapor) on Baghouse (40A-BF02) on a monthly basis while operating. The observer shall stand at a distance sufficient to provide a clear view of the emissions with the sun oriented to their back. If visible emissions are observed, the Permittee shall conduct and record a Method 9 visible emission test. Each Method 9 visible emission test must be conducted by a certified visible emissions reader in accordance with 40 CFR Part 60, Appendix A.

g. Inspect the baghouse installed on S2.233 – S2.235 on an annual basis in accordance with the manufacturer’s operation and maintenance manual and record the results (e.g. the condition of the filter fabric) and any corrective actions taken.

h. Monitor and record the reading on the pressure gauge on Baghouse (40A-BF02) at least once daily to ensure proper operation. If any of the baghouse pressure drops exceed the optimum range (1-7 inches of water), the cleaning mechanisms and compressed air supply must be checked for proper operation and corrected, if necessary. If the baghouse pressure drop cannot be corrected and maintained at the optimum range, the system must be shut down for maintenance, inspection, repair and cleaning. Record the maintenance, inspection, repair, cleaning, or any corrective actions taken.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in OO.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which Baghouse (40A-BF02) will be

operated, but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from Baghouse (40A-BF02) will not exceed 0.05 g/dscm (0.022 gr/dscf) (0.37

pound per hour) and 7 percent opacity for dry control devices. (40 CFR Part 60.672(b)) b. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with

this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

Page 153: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 111

Section V. Specific Operating Conditions (continued) PP. Emission Unit S2.236

Location: North 4,455.847 km, East 382.035 km, UTM (Zone 11, NAD 83)

System 34 – Heating Oil Storage Tank S2.236 Heating Oil Storage Tank (42,301 gallons)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.236 shall be controlled by a submerged fill pipe. b. Descriptive Tank Parameters

Shell Diameter: 20.0 feet Shell Height: 18.0 feet Capacity: 42,301.0 gallons Maximum Vapor Pressure: 0.0066 pound per square inch (psia) (0.045 kPa)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. S2.0236 shall only be used to store #2 fuel oil/recycled oil. b. The maximum allowable throughput rate for S2.236 shall not exceed 250,000.0 gallons per month, nor more than

3,000,000.0 gallons per year, based on a 12-month rolling period. c. S2.236 may operate 24 hours per day.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from S2.236 the following pollutants in excess of the following specified limits: a. The discharge of VOC (volatile organic compounds) to the atmosphere shall not exceed 0.016 ton per 12-month

rolling period. b. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from S2.236 shall not equal or exceed 20

percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the amount of #2 fuel oil/recycled oil (in gallons) loaded into or dispensed from S2.236 on a

monthly basis, as determined from vendor invoices for tank loading or fuel pump non-resettable meter for tank dispensing.

b. Monitor and record the total yearly throughput rate in gallons per 12-month rolling period. The annual throughput shall be determined at the end of each month as the sum of the monthly throughput rates for the year for all previous months of that year.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in PP.4. of this section.

Page 154: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 112

Section V. Specific Operating Conditions (continued) QQ. Emission Units PF1.038 and PF1.039

Location: North 4,456,159 m, East 381,902 m, UTM (Zone 11, NAD 83)

System 35 – Wood Chipper Plant PF1.038 Loader transfer to Chipper Grinder PF1.039 Chipper Grinder and discharge of Stockpile

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

Emissions from PF1.038 and PF1.039, each, shall be controlled by Water Sprays. 2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for PF1.038 and PF1.039, each, shall not exceed 10.0 tons of wood per any one-hour period, nor more than 800.0 tons per year, based on a 12-month rolling period.

b. Hours (1) PF1.038 and PF1.039, each, may operate 24 hours per day. (2) PF1.038 and PF1.039, each, may operate 80 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from PF1.038 and PF1.039, each, the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.88 pound per hour, nor more than

0.035 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.50 pound per hour, nor more than 0.020 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.50 pound per hour, nor more than 0.020 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 19.18 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from PF1.038 and PF1.039, each, shall not

equal or exceed 20 percent. 4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of wood (in tons) for PF1.038 and PF1.039, each. b. Monitor and record the total daily hours of operation for PF1.038 and PF1.039, each. c. Record the average hourly throughput rate (in tons per hour) for PF1.038 and PF1.039, each, using the total daily

throughput and total daily hours of operation. d. Record the throughput rate of wood (in tons) on a cumulative monthly basis, for each 12-month rolling period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in QQ.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in QQ.4. of this section.

Page 155: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 113

Section V. Specific Operating Conditions (continued) RR. Emission Unit S2.237

Location: North 4,455.874 km, East 381.035 km, UTM (Zone 11, NAD 83)

System 36 – Fuel Storage S2.237 Gasoline Fuel Storage Tank (500 gallon)

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.237 shall be controlled by a submerged fill pipe. b. Descriptive Tank Parameters

Shell Diameter: 4.0 feet Stack Height: 5.0 feet Capacity: 500.0 gallons

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) a. S2.237 shall only be used to store gasoline.

b. The maximum allowable throughput rate for S2.237 shall not exceed 233.33 gallons per month, nor more than 2,800.0 gallons per 12-month rolling period.

c. Hours (1) S2.237 may operate a total of 24 hours per day.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from S2.237 the following pollutants in excess of the following specified limits: a. The discharge of VOCs (volatile organic compounds) to the atmosphere shall not exceed 0.097 ton per year. b. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from S2.237 shall not equal or exceed 20

percent.

4. Monitoring, Recordkeeping, and Reporting (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) Monitoring and Recordkeeping The Permittee, upon the issuance date of this permit shall: a. Monitor and record the throughput of gasoline (in gallons) loaded into or dispensed from S2.237 on a monthly basis,

as determined from vendor invoices for tank loading or fuel pump non-resettable meter for tank dispensing. b. Monitor and record the total yearly throughput rate in gallons per 12-month rolling period. The annual throughput

shall be determined at the end of each month as the sum of the monthly throughput rates for the year for all previous months of that year.

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall maintain, in a contemporaneous log, records of monitoring required in RR.4. of this section.

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

National Emission Standards for Hazardous Air Pollutants (NESHAP) – 40 CFR Part 63 Subpart CCCCCC – for Gasoline Dispensing Facilities a. Permittee must, at all times, operate and maintain any affected source, including associated air pollution control

equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (40 CFR 63.11115)

Page 156: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 114

Section V. Specific Operating Conditions (continued) RR. Emission Unit S2.237 (continued)

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) (continued)

National Emission Standards for Hazardous Air Pollutants (NESHAP) – 40 CFR Part 63 Subpart CCCCCC – for Gasoline Dispensing Facilities b. Permittee must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for

extended periods of time. Measures to be taken include, but are not limited to, the following: (1) Minimize gasoline spills. (40 CFR 63.11116(a)(1)). (2) Clean up spills as expeditiously as practicable. (40 CFR 63.11116(a)(2)) (3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use.

(40 CFR 63.11116(a)(3)) (4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and

recycling devices, such as oil/water separators. (40 CFR 63.11116(a)(4)) c. Permittee must have records available within 24 hours of a request by the Administrator to document your gasoline

throughput. (40 CFR 63.11116(b))

Page 157: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 115

Section V. Specific Operating Conditions (continued) SS. Emission Unit S2.238

Location: North 4,455,936 m, East 381,695 m, UTM (Zone 11, NAD 83)

System 37 – Bag Machine S2.238 Bags to Bag Machine

1. Air Pollution Control Equipment (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. Emissions from S2.238 shall be controlled by a Baghouse. b. Descriptive Stack Parameters

Stack Height: 11.0 feet Stack Dimensions: 1.15 x 0.77 feet Stack Temperature: Ambient Exhaust Volume Flow Rate: 1,348.0 dry standard cubic feet per minute (dscfm)

2. Operating Parameters (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

a. The maximum allowable throughput rate for S2.238 shall not exceed 2.0 tons of diatomite or perlite per any one-hour period, nor more than 400.0 tons per year, based on a 12-month rolling period.

b. Hours (1) S2.238 may operate 24 hours per day. (2) S2.238 may operate 200 hours per year.

3. Emission Limits (NAC 445B.305) (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall not discharge or cause the discharge into the atmosphere from the exhaust stack of the Baghouse the following pollutants in excess of the following specified limits: a. The discharge of PM (particulate matter) to the atmosphere shall not exceed 0.058 pound per hour, nor more than

0.006 ton per 12-month rolling period. b. The discharge of PM10 (particulate matter less than or equal to 10 microns in diameter) to the atmosphere shall not

exceed 0.058 pound per hour, nor more than 0.006 ton per 12-month rolling period. c. The discharge of PM2.5 (particulate matter less than or equal to 2.5 microns in diameter) to the atmosphere shall not

exceed 0.058 pound per hour, nor more than 0.006 ton per 12-month rolling period. d. NAC 445B.22033 Federally Enforceable SIP Requirement – The maximum allowable discharge of PM10 to the

atmosphere shall not exceed 6.52 pounds per hour. e. NAC 445B.22017 Federally Enforceable SIP Requirement – The opacity from the exhaust stack of Baghouse shall

not equal or exceed 20 percent.

4. Monitoring (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement) The Permittee, upon issuance of this operating permit, shall: a. Monitor and record the total daily throughput of diatomite or perlite (in tons) for S2.238. b. Monitor and record the total daily hours of operation for S2.238. c. Record the average hourly throughput rate (in tons per hour) for S2.238 using the total daily throughput and total

daily hours of operation. d. Record the throughput rate of diatomite or perlite (in tons) on a cumulative monthly basis, for each 12-month rolling

period. e. Record the monthly hours of operation, and the corresponding annual hours of operation for the year. The monthly

hours of operation shall be determined at the end of each month as the sum of daily hours of operation as determined in SS.4.b. of this section for each day of the month. The annual hours of operation shall be determined at the end of each month as the sum of the monthly hours of operation for the year.

Page 158: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page V - 116

Section V. Specific Operating Conditions (continued) SS. Emission Unit S2.238 (continued)

5. Recordkeeping (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

The Permittee, upon issuance of this operating permit, shall: a. Maintain, in a contemporaneous log, records of monitoring required in SS.4. of this section. b. Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an

affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. (40 CFR Part 60.7(b))

6. Federal Requirements (NAC 445B.3365(3)) (Federally Enforceable SIP Requirement)

New Source Performance Standards (NSPS) – 40 CFR Part 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants a. On and after the sixtieth day after achieving the maximum production rate at which the Baghouse will be operated,

but not later than 180 days after initial startup, the Permittee shall not discharge or cause the discharge into the atmosphere, the following pollutants in excess of the following specified limits: (1) Particulate Matter emissions from the Baghouse will not exceed 0.032 g/dscm (0.014 gr/dscf) (0.16 pound per

hour). (40 CFR Part 60.672(b)) b. The Permittee of any affected facility for which construction, modification, or reconstruction commenced on or after

April 22, 2008, that uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). (40 CFR 60.674(c))

c. Notifications and reports required under this subpart and under subpart A of this part to demonstrate compliance with this subpart need only to be sent to the EPA Region or the State which has been delegated authority according to 40 CFR 60.4(b). (40 CFR 60.676(k))

****End of Specific Operating Conditions****

Page 159: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page VI - 1

Section VI. Emission Caps A. Not Applicable.

****End of Emission Caps****

Page 160: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page VII - 1

Section VII. Surface Area Disturbance Conditions A. Dust Control Plan (NRS 445B.230.6)

The Permittee may not cause or permit the construction, repair, or demolition work, or the use of unpaved or untreated areas without applying all such measures as may be required by the Director to prevent particulate matter from becoming airborne. 1. The Permittee will control fugitive dust in accordance with the dust control plan entitled “Fugitive Dust Control Plan”, dated

May 2, 2016. B. Fugitive Dust (NAC 445B.22037)

1. The permittee may not cause or permit the handling, transporting, or storing of any material in a manner which allows or may allow controllable particulate matter to become airborne.

2. Except as otherwise provided in subsection 4, the permittee may not cause or permit the construction, repair, demolition, or use of unpaved or untreated areas without first putting into effect an ongoing program using the best practical methods to prevent particulate matter from becoming airborne. As used in this subsection, “best practical methods” includes, but is not limited to, paving, chemical stabilization, watering, phased construction, and revegetation.

3. Except as provided in subsection 4, the permittee may not disturb or cover 5 acres or more of land or its topsoil until the permittee has obtained an Permit to construct for surface area disturbance to clear, excavate, or level the land or to deposit any foreign material to fill or cover the land.

4. The provisions of subsections 2 and 3 do not apply to: a. Agricultural activities occurring on agricultural land; or b. Surface disturbances authorized by a permit issued pursuant to NRS 519A.180 which occur on land which is not less than 5

acres or more than 20 acres.

****End of Surface Area Disturbance Conditions****

Page 161: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page VIII - 1

Section VIII. Amendments July 10, 2018 – Air Case 8883 – New Class I Air Quality Operating Permit to Construct (OPTC) Month 2019 – Air Case 9871 – Minor Revision

Systems 05A, 05B, and 5C – Increased PM, PM10, and PM2.5 limits, increased fuel rates, and increased VOC emission limits;

Systems 10A, 10B, and 10C – Increased PM, PM10, and PM2.5 limits, increased fuel rates, and increased VOC emission limits;

System 13 – Added S2.239; System 15 – Increased PM, PM10, and PM2.5 limits and changed baghouse inspection frequency to annual; System 17 – Increased PM, PM10, and PM2.5 limits and changed baghouse inspection frequency to annual; System 18 – Increased throughput, increased PM, PM10, and PM2.5 limits, and corrected UTMs; Systems 19A, 19B, and 19C - Increased PM, PM10, and PM2.5 limits,increased process throughput, increased fuel rates,

increased CO emission limits, and increased VOC emission limits; System 20 – Increased throughput and Increased PM, PM10, and PM2.5 limits; System 21 – Increased throughput; System 22 – Increased throughput; System 26 – Increased annual hours of operation and changed baghouse inspection frequency to annual; System 27 – Increased annual throughput, increased annual emission limits, and corrected UTMs; System 28 – Increased throughput, increased PM, PM10, and PM2.5 limits, and increased VOC emission limits; System 29 – Increased hourly and annual throughput; System 30 – Increased NOx and VOC emission limits; System 33 - Changed baghouse inspection frequency to annual; Inisignificant Activities – Added IA1.017.

This Permit to construct:

1. Is non-transferable. (NAC 445B.287) 2. Will be posted conspicuously at or near the stationary source. (NAC 445B.318) 3. Will expire if construction is not commenced within 18 months after the date of issuance or if construction of the facility

is delayed for 18 months after initiated. (NAC 445B.3366) 4. Will expire if a complete application for a Class I operating permit or modification of an existing Class I operating permit

is not submitted within 12 months after the initial start-up. (NAC 445B.3366) 5. Any party aggrieved by the Department’s decision to issue this permit may appeal to the State Environmental

Commission (SEC) within ten days after the date of notice of the Department’s action. (NRS 445B.340) 6. The Permittee shall submit a complete Class I application within 12 months after the notification date of commencement

of operation as required in this permit to construct. (NAC 445B.3361)

Signature:

Issued by:

Jennifer Schumacher, E.I. Supervisor, Permitting Branch Nevada Division of Environmental Protection

Phone: (775) 687-9551 Date: Month xx, 2019 jm 07/18 ts xx/2019

Page 162: CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT · PF1.005 Bucker Elevator (31A-BE01) and discharge to Pan Feeder (31A-AF01) PF1.006 Belt Conveyor (31A-BC01) and discharge to Bucket

Nevada Department of Conservation and Natural Resources • Division of Environmental Protection

Bureau of Air Pollution Control

Facility ID No. A0456 Permit No. AP1499-3768 CLASS I AIR QUALITY OPERATING PERMIT TO CONSTRUCT

Issued to: EP Minerals, LLC, Colado Plant (as Permittee)

Page IV - 1

Emission Unit # Emission Unit Description

IA1.001 Pan Feed Burner #1

IA1.002 Pan Feed Burner #2

IA1.003 Pan Feed Burner #3

IA1.004 Pan Feed Burner #4

IA1.005 Pan Feed Burner #5

IA1.006 Pan Feed Burner #6

IA1.007 Diesel Tank (10,000 gallon)

IA1.008 Heating Oil Storage Tank (35,000 gallons)

IA1.009 Pallet Cleaning Station PC-3, Enclosure A, Unit #3 Warehouse (403-BN02)

IA1.010 Pallet Cleaning Station PC-3, Enclosure B, Unit #3 Warehouse (403-BN02)

IA1.011 Vacuum Unit, Unit #1 & 2, Hi-Vac Model #825 (40A-VN01)

IA1.012 Vacuum Unit, Unit #1 Blend Area, Hi-Vac Model #825 (402-VN01)

IA1.013 Vacuum Unit, Unit #3, Hi-Vac Model #825 (403-VN01)

IA1.014 Vacuum Unit, Unit #3 Perlite Area, Hi-Vac Model #830 (404-VN01)

IA1.015 Pallet Cleaning Station PC-3, Enclosure A, Unit #2 Warehouse (402-BN02)

IA1.016 Pallet Cleaning Station PC-3, Enclosure B, Unit #2 Warehouse (402-BN02)

IA1.017 Vacuum Unit #4 - Packaging Area

Note: The equipment listed on this attachment are subject to all applicable requirements of the NAC and ASIP.