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					                                                DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION

MEMORANDUM                                                                     February 13, 2006

TO:                   Dawson F. Lasseter, Chief Engineer, Permits Section

THROUGH:              Grover Campbell, P.E., Existing Source Permits Section

THROUGH:              Phil Martin, P.E., New Source Permits Section

THROUGH:              Peer Review

FROM:                 David Schutz, P. E., New Source Permits Section

SUBJECT:              Evaluation of Permit Application No. 2005-203-TVR
                      U. S. Silica Company, Mill Creek North Plant
                      Industrial Sand Processing Facility
                      Mill Creek, Johnston County

SECTION I. INTRODUCTION

The U. S. Silica Company has requested renewal of their current Part 70 operating permit for their
Mill Creek North Plant (SIC 1446). The plant is currently operating under Permit No. 99-108-TV
(M-1) issued December 13, 2004. The North Plant is one of two plants operated in the area by U.
S. Silica; they are located approximately 6 miles from each other.

Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Title V
permitting requirements. Emission units (EUs) have been arranged into Emission Unit Groups
(EUGs) in the following outline.

SECTION II. PROCESS DESCRIPTION

Sand is removed from the quarry hydraulically. The quarry face is sprayed with a high-pressure
water stream which loosens uncemented or weakly-cemented sand grains from each other. (No
acids are used.) This water stream results in a slurry of 75% water and 25% sand. The slurry is
pumped to a screen where oversized material is removed from the materials that are transported
to the plant for further processing. Screened sand is pumped to a wet stockpile or to the raw sand
tank. The wet stockpile stores sand for when the quarry is not operating but the rest of the plant
is, supplying the plant with sand feed. When the quarry is inactive, front-end loaders are used to
move sand from the wet stockpile to a screening tank; there, the sand is slurried with water and
pumped to the raw sand tank.
PERMIT MEMORANDUM 2005-203-TVR                                  DRAFT                               2

Wet sand from the raw sand tank is transferred to various slurry tanks and/or hydrosizers
depending on product size desired. Sized wet sand slurries are pumped to two vacuum filter
tables for preliminary dewatering, after which bucket elevators transfer sand to damp sand
storage bins.

There are two drying circuits, designated No. 1 and No. 2. Each consists of a belt conveyor,
fluidized bed dryer, and a bucket elevator. The dryers are each rated at 31 MMBTUH apiece.
Exhausts from the No. 1 dryer are processed by a cyclonic separator and a wet scrubber prior to
discharge, while exhausts from the No. 2 dryer are processed by a wet scrubber. Dried sand is
moved by bucket elevator to two dry screening operations. The No. 2 dryer was authorized under
Permit No. 79-087-O to burn liquid fuel and became subject to NSPS Subpart UUU under Permit
No. 99-108-TV (M-1) by removal of a cyclone prior to the wet scrubber.

The screening operations sort dried sand into various size ranges. Sorted (“graded”) sand is
moved by bucket elevator to “Whole Grain” storage silos or to the sand cooler. Air emissions
from the screening operations are vented to Drying Circuit No. 1’s wet scrubber. “Whole Grain”
sand is moved by belt conveyor to the railcar loading station. Loading snorkles are used to
conduct the sand from bins into railcars. Displaced air from railcar loading is vented to a wet
scrubber with a PM emissions control efficiency of 95%. In addition to the railcar loading, there
are units for loading trucks. Fines materials are conveyed to the No. 4 silo for “OK-100 Fines”,
and to Whole Grain Silos 2 and 3.

No crushing or grinding of sand/sandstone is conducted at the facility. All sand-handling
operations prior to the drying, screening and loading units are wet. The facility has a maximum
annual process rate of 3,241,200 tons per year sand.

The facility includes two large fuel oil storage tanks. The first is 60,000 gallons and was
constructed prior to 1972. The second is 100,000 gallons and was also constructed prior to 1972.
Since the liquid fuel will have a maximum true vapor pressure of 0.008 psia, these tanks are
included as “insignificant activities.”

SECTION III. EQUIPMENT

Equipment was organized into emissions unit groups depending on date of installation and
function.

EUG “SCREENING”
   EU ID            Point ID                   EU Name/Model                Construction Date
SCREENING          8Rotex #1            Vibrating screen #1 Type 522A             1992
                   8Rotex #2            Vibrating screen #2 Type 522A             1992
Emissions from these units are controlled by a Torit Dust Collector, “8TORITDC”, and discharged
from Stack 5.
PERMIT MEMORANDUM 2005-203-TVR                              DRAFT                                3


EUG “DRYING1”
  EU ID       Point ID                        EU Name/Model              Construction Date
 DRYING1        8FD1                     No. 1 fluidized bed dryer             Pre-1972
                8BC1                          Feed belt to dryer               Pre-1972
               8BE2N                   No. 1 fluid bed dryer discharge         Pre-1972
                                                   elevator
Emissions from these units are controlled by a cyclone and wet scrubber in series, “8SB1” and
“8CY1”, and discharged from Stack 1.

EUG “DRYING2”
  EU ID       Point ID                       EU Name/Model                  Construction/
                                                                           Modification Date
 DRYING2              8FD2                 No. 2 fluidized bed dryer             2005
                     8BC1A                     Feed belt to dryer                1979
                     8BE2A              No. 2 fluid bed dryer discharge          1979
                                                    elevator
Emissions from these units are controlled by a wet scrubber and discharged from Stack 4.

EUG “FUGITIVE PRE-1972”

  EU ID             Point ID                   EU Name/Model                 Construction Date
FUGITIVE1        8AUTOMON1              Automatic monitor #1 - Stang              Pre-1972
                  8STOCKPILE                  Wet sand stockpile                  Pre-1972
                8STOCKSCREEN               Stockpile screening vat                Pre-1972
                    8FL988B               Caterpiller front end loader            Pre-1972
                  8PITSCREEN                  Tyler screening vat                 Pre-1972
                     8RST1              Raw sand tank 1100 Ton/Mine               Pre-1972
                    8NSILO3                     Cool sand tank                    Pre-1972
                     8RST2                     Fines slurry tank                  Pre-1972
                      8ST1                    Slurry tank #1 slide                Pre-1972
                      8VT1                  Vacuum filter table #1                Pre-1972
                      8DS1                Damp sand storage Silo #1               Pre-1972
                     8BE1N             Vacuum table discharge elevator            Pre-1972
                                                    #1 side
Emissions from these units are controlled by the wetness of the materials handled.
PERMIT MEMORANDUM 2005-203-TVR                              DRAFT                              4


EUG “FUGITIVE POST-1972”
  EU ID        Point ID                      EU Name/Model                 Construction Date
FUGITIVE2      8 RCT1                  Rising current tank hydrosizers           1995
              8HYDRO1                           Hydrosizer 1                     1995
              8HYDRO2                           Hydrosizer 2                     1995
              8HYDRO3                           Hydrosizer 3                     1995
                8ST1A                       Slurry Tank #2 side                  1979
               8VT1A                    Vacuum filter Table #2 side              1979
                8DS1A                  Damp sand storage silo #2 side            1979
                8BE1A                 Vacuum table discharge elevator            1979
                                                   #2 side
Emissions from these units are controlled by the wetness of the materials handled, and some of
these operations are completely submerged in liquid.

EUG “LOADOUT”
   EU ID            Point ID                  EU Name/Model                 Construction Date
 LOADOUT              8BC2             Belt Conveyor #2 Rail Load-out             Pre-1972
                   8TLONLS4            North track load-out snorkle #4            Pre-1972
                   8TLONLS5             South track load-out snorkle              Pre-1972
                  8NTLONLS1                Truck load-out spout #1                Pre-1972
                  8NTLONLS2                Truck load-out spout #2                Pre-1972
                8LTOCOOLSND            Cool sand truck load-out spout             Pre-1972
The railcar load-out snorkles are vented to “8SB4” and discharged from Stack 3, while the truck
load-out snorkles are vented to “8SB3” and discharged from Stack 2. Each stack is equipped with a
dry filter.

EUG “LOADOUT2”
   EU ID            Point ID                  EU Name/Model            Construction Date
LOADOUT2             8NDC5            Conveyor for No. 2 truck loadout       9/99
                     8NDC4                      Truck loadout                9/99
The two new truck loadouts (8NDC4 and 8NDC5) are discharged through Stacks 7 and 8,
respectively. Each stack is equipped with a dry filter.

EUG “STORAGE1”
   EU ID      Point ID                      EU Name/Model                 Construction Date
 STORAGE1      8BE3N                 #1 Side Rotex Screen discharge           Pre-1972
                                                 elevator
                   8NSILO#1               North whole grain silo              Pre-1972
                   8NSILO#2               Middle whole grain silo             Pre-1972
Emissions from these units are vented to the No. 1 Dryer wet scrubber, “8SB1”, and discharged
from Stack 1.
PERMIT MEMORANDUM 2005-203-TVR                              DRAFT                               5



EUG “STORAGE2”
   EU ID      Point ID                     EU Name/Model                   Construction Date
 STORAGE2      8BE3A                #2 Side Rotex Screen discharge                1995
                                                elevator
                    8NPB1                 OK-100 product silo                     1995
                    8SC3N        #3 Dry Sand Storage discharge screw              1995
                   8NSILO#4             South whole grain silo                    1995
                    8BE4N                  Cool sand elevator                     1995
                    8BC3N          Transfer conveyor from BE3A to                 1995
                                             OK-100 silo
                    8SC2N         #2 dry sand storage discharge screw             1995
                    8SC1N                   Discharge screw                       1995
                    8BC4N            OK80/90 conveyor atop silos                  1995
                 8NTLOOK100         Truck load-out for OK-100 silo                1995
Emissions from the OK-100 silo are controlled by a dry cartridge dust collector, and discharged
from Stack 6.

EUG “ROADS”
   EU ID             Point ID              EU Name/Model                    Construction Date
 FUGITIVE            ROADS                Unpaved facility roads                Pre-1972

EUG “TANKS”: Fuel Storage Tanks
Unit ID  Point          EU Description                      Capacity       Construction Date
  A      Tank 1            Diesel tank                     60,000 gal.         pre-1972
  B      Tank 2            Diesel tank                    100,000 gal.           1977
  C     Gasoline      Vehicle gasoline tank                 250 gal.               --

SECTION IV. AIR EMISSIONS

Based on U. S. Silica’s measurement and estimate, the maximum process capacity of the facility
downstream from raw material unloading is 370 tons/hour. The PM collectors are reported to
have an efficiency of at least 99% for PM collection. A 70% control efficiency was claimed for
units enclosed in buildings and 50% for outdoor enclosures. Based on 8,760 hours/year
continuous operation and AP-42 (1/95), Section 13.2-4 (aggregate handling and storage); and
Section 11.19.1 (sand and aggregate transfer to elevated bin), the PM emissions are listed in the
following tables.

Dryer emissions shown are worst-case, based on liquid fuel usage except for CO, with emissions
calculated from AP-42 (10/98), Section 1.3 (fuel oil combustion), assuming 0.7% by weight
sulfur in the liquid fuel used in the No. 2 Dryer and 1.28% by weight sulfur in the No. 1 Dryer.
CO emissions were calculated from factors for natural gas in AP-42 (9/98), Section 1.4. PM10
emissions were based on the limits of NSPS Subpart UUU (0.025 gr/DSCF) and a flow of 53,000
SCFM.
 PERMIT MEMORANDUM 2005-203-TVR                              DRAFT                           6

 There are two operating scenarios for the plant, gas fuel and liquid fuel. Except for CO
 emissions, liquid fuel constitutes the worst-case emissions. Emissions limitations were
 established on that basis.

 EUG “SCREENING”
  Discharge    Unit ID                         EU Name/Model                PM10 Emissions
    Point                                                                  lb/hr      TPY
   Stack 5    8Rotex #1                  Vibrating screen #1 Type 522A      0.26      1.13
              8Rotex #2                  Vibrating screen #2 Type 522A

 EUG “DRYING1” AND EUG “STORAGE1”
Point           Unit ID                 PM10        SO2         NOx        VOC        CO
 ID                                 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY
Stack   No. 1 fluidized bed dryer   11.36 49.74 41.50 181.9 12.16 53.24 0.25 1.09 2.55 11.18
  1         feed belt to dryer
        dryer discharge elevator
         31 MMBTUH Heater
        #1 Side Rotex Screen
         discharge elevator
       North whole grain silo
       Middle whole grain silo
 The two EUGs share a discharge point. Both EUGs consist of grandfathered equipment.

 EUG “DRYING2”
Point           Unit ID                 PM10        SO2         NOx        VOC        CO
 ID                                 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY
Stack      Sand Dryer No. 2         11.36 49.74 22.01 96.40 12.16 53.24 0.25 1.09 2.55 11.18
  4       Product Silo No. 1
          Product Silo No. 2
         31 MMBTUH Heater

 EUG “FUGITIVE POST-1972”
  Discharge  Point ID             EU Name/Model                             PM10 Emissions
    Point                                                                  lb/hr      TPY
 FUGITIVE2   8 RCT1         Rising current tank hydrosizers                 0.01      0.01
            8HYDRO1                  Hydrosizer 1                           0.01      0.01
            8HYDRO2                  Hydrosizer 2                           0.01      0.01
            8HYDRO3                  Hydrosizer 3                           0.01      0.01
              8ST1A               Slurry tank #2 side                       0.01      0.01
             8VT1A           Vacuum filter table #2 side                    1.07      4.70
              8DS1A         Damp sand storage silo #2 side                  0.06      0.24
              8BE1A     Vacuum table discharge elevator #2 side             0.06      0.24
  TOTALS                                                                    1.24      5.23
 PERMIT MEMORANDUM 2005-203-TVR                         DRAFT                          7


 EUG “FUGITIVE PRE-1972”
 Point ID    Unit ID                   EU Name/Model                  PM10 Emissions
                                                                     lb/hr      TPY
FUGITIVE1    8AUTOMON1       Automatic monitor #1 - Stang             0.11      0.49
              8STOCKPILE          Wet sand stockpile                  0.11      0.49
            8STOCKSCREEN        Stockpile screening vat               0.06      0.24
                8FL988B       Caterpiller front end loader            0.06      0.24
              8PITSCREEN          Tyler screening vat                 0.11      0.49
                 8RST1       Raw sand tank 1100 Ton/Mine              0.06      0.24
                8NSILO3             Cool sand tank                    0.06      0.24
                 8RST2             Fines slurry tank                  0.06      0.24
                  8ST1            Slurry tank #1 slide                0.53      2.35
                  8VT1          Vacuum filter table #1                1.07      4.70
                  8DS1        Damp sand storage Silo #1               0.06      0.24
                 8BE1N   Vacuum table discharge elevator #1 side      0.06      0.24
TOTALS                                                               2.35     10.20

 EUG “LOADOUT”
 Discharge     Unit ID                   EU Name/Model                PM10 Emissions
   Point                                                             lb/hr     TPY
  Stack 3       8BC2              Belt Conveyor #2 Rail Load-out      0.40     1.75
              8TLONLS4            North track load-out snorkle #4
              8TLONLS5             South track load-out snorkle
  Stack 2    8NTLONLS1                Truck load-out spout #1        0.29       1.27
             8NTLONLS2                Truck load-out spout #2
           8LTOCOOLSND            Cool sand truck load-out spout
 TOTALS                                                              0.69       3.02

 EUG “LOADOUT2”
 Discharge   Unit ID                     EU Name/Model                PM10 Emissions
   Point                                                             lb/hr     TPY
  Stack 7    8NDC5                Conveyor for No. 2 truck loadout    0.13     0.57
  Stack 8    8BC6N                        Truck loadout               0.13     0.57
 TOTALS                                                               0.26     1.14
PERMIT MEMORANDUM 2005-203-TVR                               DRAFT                            8


EUG “STORAGE2”
Discharge   Unit ID                EU Name/Model                             PM10 Emissions
  Point                                                                      lb/hr    TPY
 Stack 6     8BE3A      #2 Side Rotex Screen discharge elevator               3.63   15.91
             8NPB1                OK-100 product silo
             8SC3N       #3 Dry Sand Storage discharge screw
           8NSILO#4             South whole grain silo
             8BE4N                 Cool sand elevator
            8BC3N    Transfer conveyor from BE3A to OK-100 silo
             8SC2N        #2 dry sand storage discharge screw
             8SC1N                  Discharge screw
            8BC4N            OK80/90 conveyor atop silos
          8NTLOOK100        Truck load-out for OK-100 silo

EUG “ROADS”
  Discharge        Point ID                EU Name/Model                  PM10 Emissions
    Point                                                                lb/hr      TPY
   ROADS           ROADS               Unpaved facility roads             2.33      9.75

EUG “TANKS”
  Discharge        Point ID                EU Name/Model                  VOC Emissions
    Point                                                                lb/hr     TPY
      A             Tank 1                 Diesel tank                    0.01     0.01
      B             Tank 2                 Diesel tank                    0.01     0.01
      C            Gasoline            Vehicle gasoline tank              0.10     0.44
  TOTALS                                                                  0.12     0.46

                              TOTAL FACILITY EMISSIONS

Emission        PM10           SO2              NOx               VOC               CO
 Point       lb/hr TPY    lb/hr TPY         lb/hr TPY         lb/hr TPY        lb/hr TPY
 Stack 1     11.36 49.74 41.50    181.91    12.16    53.24     0.25   1.09     2.55   11.18
 Stack 2      0.29   1.17 --        --        --      --        --     --       --      --
 Stack 3      0.4    1.75 --        --        --      --        --     --       --      --
 Stack 4     11.36 49.74 22.01     96.40    12.16    53.24     0.25   1.09     2.55   11.18
 Stack 5      0.26   1.13 --        --        --      --        --     --       --      --
 Stack 6      3.63 15.91 --         --        --      --        --     --       --      --
 Stack 7      0.13   0.57 --        --        --      --        --     --       --      --
 Stack 8      0.13   0.57 --        --        --      --        --     --       --      --
Fugitive 1    2.35 10.20 --         --        --      --        --     --       --      --
Fugitive 2    1.24   5.23 --        --        --      --        --     --       --      --
  Tanks          --  --    --       --        --      --       0.12   0.44      --      --
 Roads        2.23   9.75 --        --        --      --        --     --       --      --
TOTALS       33.38 145.76 63.51   278.31    24.32   106.48     0.62   2.62     5.10   22.36
PERMIT MEMORANDUM 2005-203-TVR                                 DRAFT                               9


SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application and listed in OAC 252:100-
8, Appendix I, are listed following. Recordkeeping for activities indicated with “*” is listed in the
Specific Conditions.

-   Space heaters, boilers, process heaters, and emergency flares less than or equal to 5
    MMBTUH heat input (commercial natural gas). This category includes office and building
    space heating, which are actually “trivial activities”.

-   * Emissions from fuel storage/dispensing equipment operated solely for facility owned
    vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period.
    The vehicle fueling operation is in this category.

-   Gasoline and aircraft fuel handling facilities, equipment, and storage tanks except those
    subject to New Source Performance Standards and standards in OAC 252:100-37-15, 39-30,
    39-41, and 39-48. The 100,000 gallon diesel fuel tank is in this category.

-   Cold degreasing operations utilizing solvents that are denser than air. These activities are
    conducted as part of maintenance.

-   Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per
    year of electrodes. These activities are actually part of maintenance, which is a “trivial
    activity”, therefore no recordkeeping will be required.

-   Sanitary sewage collection and treatment facilities other than incinerators and Publicly
    Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are also
    included (i.e., lift station).

-   * Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant.
    This last category includes the sand loading operations.

SECTION VI. FEDERAL REGULATIONS

PSD, 40 CFR Part 52                                                [Not Applicable At This Time]
Total facility emissions are above the threshold of 250 TPY of any single regulated pollutant. Any
future increases of emissions must be evaluated for PSD if they exceed a significance level (100
TPY CO, 40 TPY NOx, 40 TPY SO2, 40 TPY VOC, 25 TPY PM, 15 TPY PM10, or 0.6 TPY lead).

NSPS, 40 CFR Part 60                                                     [Subpart UUU Applicable]
Subparts K, Ka, and Kb (Petroleum Liquids Storage Vessels). Subpart K affects vessels constructed
between June 11, 1973, and May 19, 1979; Subpart Ka affects vessels constructed between May 19,
1979 and July 23, 1984; and Subpart Kb affects vessels constructed after July 23, 1984. The facility
includes one 60,000 gallon tank constructed prior to 1972, therefore prior to Subpart K, and another
PERMIT MEMORANDUM 2005-203-TVR                                DRAFT                              10

constructed in 1977, while Subpart K was in effect. Subpart K specifically exempted storage of
distillate fuel oils No. 1 and No. 2, and residual fuel oils No. 4 and 5.
Subpart OOO (Nonmetallic Mineral Processing Plants) affects plants which either (1) are in a fixed
location and have a capacity of 25 TPH or more, or (2) are portable and have a capacity of 150 TPH
or more, or (3) common clay plants and pumice plants with a capacity of 10 TPH or more which
commenced construction, reconstruction, or modification after August 31, 1983. “Nonmetallic
mineral processing plant” is defined as “any combination of equipment that is used to crush or
grind any nonmetallic mineral wherever located, including lime plants, power plants, steel mills,
asphalt concrete plants, portland cement plants, or any other facility processing nonmetallic
minerals except as provided in 60.670 (b) and (c).” There is no crushing nor grinding conducted at
the Mill Creek North Plant, therefore associated screen, conveyors, storage bins, and enclosed
loading stations are not subject to Subpart OOO.
Subpart UUU (Dryers and Calciners in the Mineral Products Industry) affects calciners and dryers
which commenced construction, reconstruction, or modification after April 23, 1986. Modification
of the No. 2 Dryer (by removal of a cyclone) made the unit subject to the standards of Subpart
UUU: no PM emissions greater than 0.025 gr/DSCF nor discharges greater than 10% opacity. The
standards of Subpart UUU have been incorporated into the permit.

NESHAP, 40 CFR Part 61                                                            [Not Applicable]
No pollutants subject to regulation under 40 CFR 61 are emitted in this facility: arsenic, asbestos,
benzene, beryllium, coke oven emissions, mercury, radionuclides, and vinyl chloride.

NESHAP, 40 CFR Part 63                                                       [Not Applicable]
No MACTs are promulgated under 40 CFR 63 for non-metallic minerals processing.
Subpart DDDDD for “Industrial, Commercial, and Institutional Boilers and Process Heaters” was
promulgated on September 13, 2004. The subpart affects only major sources of HAPs. Although
there will be formaldehyde emissions from the dryers, total VOC emissions (2.62 TPY) are less
than the 10 TPY threshold for being a major source of HAPs.

Compliance Assurance Monitoring, 40 CFR 64                                           [Applicable]
Compliance Assurance Monitoring, applies to a facility if it meets all the following criteria:

      It is subject to an emission limit or standard for an applicable regulated air pollutant.
      It uses a control device to achieve compliance with the applicable emission limit or
       standard.
      It has potential emissions, prior to the control device, of the applicable regulated air
       pollutant of 100 TPY.

This facility has potential emissions of particulate matter from both dryers greater than the major
source threshold, is subject to an emission limitation, and uses a control device to achieve
compliance with that limitation. CAM for the wet scrubbers will follow NSPS Subpart UUU
standards, which require monitoring of pressure differential and liquor flow, for the dryers
(stacks 1 and 4). CAM will follow baghouse standards of monitoring pressure differential for
filters on stacks 5 and 6.
PERMIT MEMORANDUM 2005-203-TVR                                DRAFT                            11

Chemical Accident Prevention Provisions, 40 CFR Part 68                         [Not Applicable]
This facility does not store any regulated substance above the applicable threshold limits. More
information on this federal program is available at the web site: http://www.epa.gov/ceppo/.

Stratospheric Ozone Protection, 40 CFR Part 82                       [Subpart A and F Applicable]
These standards require phase out of Class I & II substances, reductions of emissions of Class I
& II substances to the lowest achievable level in all use sectors, and banning use of nonessential
products containing ozone-depleting substances (Subparts A & C); control servicing of motor
vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D); require warning labels on products made with or
containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon
disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons
(Subpart H).
Subpart A identifies ozone-depleting substances and divides them into two classes. Class I
controlled substances are divided into seven groups; the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform
(Class I, Group V). A complete phase-out of production of Class I substances is required by
January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are
hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.
Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,
scheduled in phases starting by 2002, is required by January 1, 2030.

This facility does not utilize any Class I & II substances.

SECTION VII. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions)                                                   [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-3 (Air Quality Standards and Increments)                              [Applicable]
Subchapter 3 enumerates the primary and secondary ambient air quality standards and the
significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these
standards.

OAC 252:100-4 (New Source Performance Standards)                                     [Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002,
except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart
C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix
G. These requirements are covered in the “Federal Regulations” section.
PERMIT MEMORANDUM 2005-203-TVR                                 DRAFT                              12

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees)      [Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission
inventories annually, and pay annual operating fees based upon total annual emissions of
regulated pollutants. Emission inventories were submitted and fees paid for previous years as
required.

OAC 252:100-8 (Permits for Part 70 Sources)                                           [Applicable]
Part 5 includes the general administrative requirements for Part 70 permits. Any planned
changes in the operation of the facility that result in emissions not authorized in the permit and
that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior
notification to AQD and may require a permit modification. Insignificant activities refer to those
individual emission units either listed in Appendix I or whose actual calendar year emissions do
not exceed the following limits.

          5 TPY of any one criteria pollutant
          2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20%
           of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure compliance with all
applicable requirements for all sources are taken from the permit application, or developed from
the applicable requirement.

OAC 252:100-9 (Excess Emissions Reporting Requirements)                              [Applicable]
In the event of any release which results in excess emissions, the owner or operator of such
facility shall notify the Air Quality Division as soon as the owner or operator of the facility has
knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10)
working days after the immediate notice is given, the owner or operator shall submit a written
report describing the extent of the excess emissions and response actions taken by the facility.
Part 70/Title V sources must report any exceedance that poses an imminent and substantial
danger to public health, safety, or the environment as soon as is practicable. Under no
circumstances shall notification be more than 24 hours after the exceedance.

OAC 252:100-13 (Prohibition of Open Burning)                                      [Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the
specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter)                                                    [Applicable]
This subchapter limits emissions of particulate matter. Emission limitations for direct-fired
processes are based on process weight rates. The emission rate in pounds per hour (E) is not to
exceed the rate calculated using the process weight rate in tons per hour (P), for process rates
above 60,000 lb/hr, the formula in appendix G is E = 55*P(0.11) - 40. Based on a process weight
rate of 370 TPH for the operations other than raw materials receipt, the allowable emissions rate is
65.4 lb/hr. Controlled emissions for total suspended particles have been estimated at 33.07 lb/hr for
the entire facility. This emission rate is in compliance with Appendix G.
PERMIT MEMORANDUM 2005-203-TVR                                  DRAFT                               13

OAC 252:100-25 (Visible Emissions and Particulate Matter)                         [Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences which
consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed
three such periods in any consecutive 24 hours. In no case shall the average of any six-minute
period exceed 60% opacity. Subchapter 25 exempts any source subject to an opacity limit under
NSPS; the No. 2 dryer is subject a 10% opacity limit under NSPS Subpart UUU. All other
emission units are subject to Subchapter 25.

OAC 252:100-29 (Fugitive Dust)                                                             [Applicable]
Subchapter 29 prohibits the handling, transportation, or disposition of any substance likely to
become airborne or windborne without taking “reasonable precautions” to minimize emissions of
fugitive dust. No person shall cause or permit the discharge of any visible fugitive dust emissions
beyond the property line on which the emissions originate in such a manner as to damage or to
interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to
interfere with the maintenance of air quality standards. Operation of this source with enclosed
transfer points, dust collectors, etc. is in compliance with the "reasonable precautions" requirement.

OAC 252:100-31 (Sulfur Compounds)                                                     [Applicable]
Part 2 limits the impact of sulfur dioxide emissions from existing equipment. The No. 1 Dryer,
constructed prior to 1972, is subject to ambient impacts limitations of Part 2. Air dispersion
modeling conducted using ISCST3 was used to show the impacts of the facility on the ambient
air as shown below. SO2 emissions for modeling were calculated based on 0.7% by weight sulfur
in fuel oil in the No. 2 Dryer and 1.28% by weight sulfur in the No. 1 dryer. The limit of sulfur in
the No. 1 Dryer was back-calculated from the ambient impacts to provide the maximum sulfur
content which would comply with Subchapter 31.

                                    SO2 AMBIENT IMPACTS

       Averaging Time               Subchapter 31 Limitation,         Maximum Facility Ambient
                                             ug/m3                         Impacts, ug/m3
            1 hour                           1,200                             323
           3 hours                            650                              291
           24 hours                           130                              130
            Annual                             80                               32

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,
1972). The No. 2 Dryer, constructed in 1979, is subject to Part 5. For gaseous fuels the limit is
0.2 lb/MMBTU heat input. This is equivalent to approximately 0.2 weight percent sulfur in the
fuel gas which is equivalent to 2,000 ppm sulfur. For liquid fuels the limit is 0.8 lb/MMBTU.
The permit limits fuel to commercial-grade natural gas with a maximum of 343 ppm sulfur or
fuel oil with a maximum sulfur content of 0.6 % sulfur by weight. (All liquid fuel presently
combusted at the facility is low-sulfur fuel oil with a maximum sulfur content of 0.1 percent.)
AP-42 (9/98), Chapter 1.3, Table 1.3-1, gives an emission factor of 142*S pound of SO2 per
1,000 gallons which is approximately 0.71 lb/MMBTU when S = 0.7% by weight sulfur in the
fuel oil. This emission rate is in compliance with the limitation of 0.8 lb/MMBTU.
PERMIT MEMORANDUM 2005-203-TVR                                DRAFT                              14



OAC 252:100-33 (Nitrogen Oxides)                                           [Not Applicable]
This subchapter limits NOx emissions from new fuel-burning equipment with a rated heat input
greater than 50 MMBTUH. Both dryers are rated at 31 MMBTUH, which is below the de
minimis level.

OAC 252:100-35 (Carbon Monoxide)                                                  [Not Applicable]
None of the following affected processes are part of this facility: gray iron cupola, blast furnace,
basic oxygen furnace, petroleum catalytic reforming unit, or petroleum catalytic cracking unit.

OAC 252:100-37 (Volatile Organic Compounds)                                        [Applicable]
Part 3 requires storage tanks constructed after December 28, 1974, with a capacity between 400
and 40,000 gallons holding an organic liquid with a true vapor pressure greater than 1.5 psia to
be operated with a submerged fill pipe. This requirement does not affect the gasoline storage
tank, whose volume is below 400-gallons, or the diesel tanks, which have a vapor pressure less
than the 1.5 psia de minimis level.
Part 5 limits the VOC content of coating or other operations. This facility does not normally
conduct coating or painting operations except for routine maintenance of the facility and
equipment which is exempt.
Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize
emissions. Temperature and available air must be sufficient to provide essentially complete
combustion. The permit will require compliance.

OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants)            [Not Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on September 1, 2004, with the exception of Subparts B, H, I, K, Q, R,
T, W and Appendices D and E, all of which address radionuclides. In addition, General
Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control
Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O,
Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR,
SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN,
OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF,
GGGG, HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS,
TTTT, UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE,
FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP,
QQQQQ, RRRRR, SSSSS and TTTTT are hereby adopted by reference as they exist on
September 1, 2004. These standards apply to both existing and new sources of HAPs. These
requirements are covered in the “Federal Regulations” section.
Part 5 is a state-only requirement governing toxic air contaminants. Part 5 regulates sources of
toxic air contaminants that have emissions exceeding a de minimis level. However, Part 5 of
Subchapter 41 has been superseded by OAC 252:100-42. The Air Quality Council approved
Subchapter 42 for permanent rulemaking on April 20, 2005. The Environmental Quality Board
approved Subchapter 42 as both a permanent and emergency rule on June 21, 2005. The
emergency Subchapter 42 was sent for Gubernatorial signature on June 30, 2005, and became
effective by emergency August 11, 2005. Subchapter 42 is expected to become permanently
PERMIT MEMORANDUM 2005-203-TVR                                DRAFT                              15

effective on June 15, 2006. Because Subchapter 41, Part 5 has been superseded, the
requirements of Part 5 will not be reviewed in this memorandum. Should Subchapter 42 fail to
take effect, this permit will be reopened to address the requirements of Subchapter 41, Part 5.

OAC 252:100-42 (Toxic Air Contaminants (TAC))                                      [Applicable]
All parts of OAC 252:100-41, with the exception of Part 3, shall be superseded by this
subchapter. Any work practice, material substitution, or control equipment required by the
Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification is
approved by the Director.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping)                                [Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and
applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.
To determine compliance with emissions limitations or standards, the Air Quality Director may
require the owner or operator of any source in the state of Oklahoma to install, maintain and
operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant
source. All required testing must be conducted by methods approved by the Air Quality Director
and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol
shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.
Emissions and other data required to demonstrate compliance with any federal or state emission
limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and
submitted as required by this subchapter, an applicable rule, or permit requirement. Data from
any required testing or monitoring not conducted in accordance with the provisions of this
subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive
use, of any credible evidence or information relevant to whether a source would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11                   Alternative Reduction             not eligible
OAC 252:100-15                   Mobile Sources                    not in source category
OAC 252:100-17                   Incinerators                      not type of emission unit
OAC 252:100-23                   Cotton Gins                       not type of emission unit
OAC 252:100-24                   Feed & Grain Facility             not in source category
OAC 252:100-39                   Nonattainment Areas               not in a subject area
OAC 252:100-47                   Landfills                         not type of source category
PERMIT MEMORANDUM 2005-203-TVR                                DRAFT                             16


SECTION VIII. COMPLIANCE

Inspection

A full compliance inspection was conducted on April 27, 2005, by Kevin Carter and Jason
Carlisle of AQD accompanied by Mr. Clendon Babb (Maintenance Supervisor) of U. S. Silica.
Records indicated that the facility was operating as described in the permit application and
supplemental materials, and that all emission units were in compliance with all applicable
regulations.

Tier Classification And Public Review

This application has been determined to be Tier II based on the request for renewal of a Part 70
operating permit.

The applicant published the “Notice of Filing a Tier II Application” in the Tishomingo Johnston
County Capital-Democrat, a weekly newspaper of general circulation in Johnston County, on
January 19, 2006,. The notice said that the application was available for public review at the
AQD office and at the Johnston County Courthouse, 403 W. Main, Tishimingo, OK. A draft of
this permit will also be made available for public review for a period of thirty days as will be
stated in another published announcement. This facility is located within 50 miles of the border
with the state of Texas; that state will be notified of the draft permit.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any
operation upon land owned by others without their knowledge. The affidavit certifies that the
applicant owns the property.

Information on all permit actions is available for review by the public in the Air Quality section
of the DEQ Web page:http://www.deq.state.ok.us/

Fees Paid

Title V operating permit renewal fee of $1,000.

SECTION IX. SUMMARY

The facility was constructed and operated as described in the permit application. Ambient air
quality standards are not threatened at this site. There are no active Air Quality compliance or
enforcement air quality issues. Issuance of the permit is recommended, contingent on public and
EPA review.
                                               DRAFT

                                 PERMIT TO OPERATE
                           AIR POLLUTION CONTROL FACILITY
                                 SPECIFIC CONDITIONS

 U. S. Silica Company                                                  Permit No. 2005-203-TVR
 Mill Creek North Plant

 The permittee is authorized to operate in conformity with the specifications submitted to Air
 Quality on October 4, 2005. The Evaluation Memorandum dated February 13, 2006, explains the
 derivation of applicable permit requirements and estimates of emissions; however, it does not
 contain operating limitations or permit requirements. Continuing operations under this permit
 constitutes acceptance of, and consent to, the conditions contained herein:

 1. Points of emissions and emission limitations for each point:            [OAC 252:100-8-6(a)]

 EUG “SCREENING”: Emissions are estimated based on existing equipment items and the
 emissions are insignificant (less than 5 TPY).

   Point ID            Point ID                  EU Name/Model               Construction Date
    Stack 1           8Rotex #1           Vibrating screen #1 Type 522A            1992
                      8Rotex #2           Vibrating screen #2 Type 522A            1992

 EUG “DRYING1”: These units are “grandfathered” (constructed prior to any applicable rule).

    EU ID              Point ID                  EU Name/Model               Construction Date
    Stack 1              8FD1               No. 1 fluidized bed dryer            Pre-1972
                         8BC1                    Feed belt to dryer              Pre-1972
                        8BE2N             No. 1 fluid bed dryer discharge        Pre-1972
                                                      elevator

 A. The sulfur content of liquid fuels used in the No. 1 Dryer shall not exceed 1.28% by weight.
                                                                                 [OAC 252:100-31]

 EUG “DRYING2”

Point           Unit ID               PM10        SO2         NOx        VOC        CO
 ID                               lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY
Stack      Sand Dryer No. 2       11.36 49.74 22.01 96.40 12.16 53.24 0.25 1.09 2.55 11.18
  4       Product Silo No. 1
          Product Silo No. 2
         31 MMBTUH Heater
                                                                   DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                                2

A. Liquid fuels used to operate Sand Dyer No. 2 shall have a sulfur content no greater than 0.7% by
weight. Gas fuels shall not contain more than 343 ppmv sulfur.            [OAC 252:100-31-25(b)]

B. The No. 2 Dryer is subject to NSPS Subpart UUU and shall comply with all applicable
standards:                                                    [40 CFR Part 60.730-737]

   i.      The opacity of discharges shall not exceed 10%.                    [40 CFR 60.732(b)]
   ii.     PM in discharges from the dryer shall not exceed 0.025 gr/DSCF. [40 CFR 60.732(a)]
   iii.    Devices shall be maintained which measure the pressure differential across the wet
           scrubber and liquor flow rate to the scrubber. The pressure drop monitoring device shall
           be certified by the manufacturer to be accurate within 5% of the gauge pressure. The
           liquor flow monitoring device shall be certified by the manufacturer to be accurate
           within 5% of the flow rate.                                        [40 CFR 60.734(d)]
   iv.     The operating pressure differential of the wet scrubber and liquor flow rate shall be
           continuously recorded. At least once every operating day, an arithmetic average of each
           over a two-hour period shall be recorded.                          [40 CFR 60.735(b)]

EUG “FUGITIVE PRE-1972”: These units are “grandfathered” (constructed prior to any
applicable rule). There are no emission limits applied to this unit under Title V but it is limited to
the existing equipment as it is.

  EU ID              Point ID                  EU Name/Model                    Construction Date
FUGITIVE1         8AUTOMON1              Automatic monitor #1 - Stang               Pre-1972
                   8STOCKPILE                 Wet sand stockpile                    Pre-1972
                 8STOCKSCREEN               Stockpile screening vat                 Pre-1972
                     8FL988B              Caterpiller front end loader              Pre-1972
                   8PITSCREEN                 Tyler screening vat                   Pre-1972
                      8RST1             Raw sand tank 1100 Ton/Mine                 Pre-1972
                     8NSILO3                    Cool sand tank                      Pre-1972
                      8RST2                    Fines slurry tank                    Pre-1972
                       8ST1                   Slurry tank #1 slide                  Pre-1972
                       8VT1                 Vacuum filter table #1                  Pre-1972
                       8DS1               Damp sand storage Silo #1                 Pre-1972
                      8BE1N             Vacuum table discharge elevator             Pre-1972
                                                    #1 side
                                                                DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                            3


EUG “FUGITIVE POST-1972”: Emissions are estimated based on existing equipment items
and the emissions are insignificant (less than 5 TPY).

  EU ID              Point ID               EU Name/Model                   Construction Date
FUGITIVE2            8 RCT1           Rising current tank hydrosizers             1995
                    8HYDRO1                    Hydrosizer 1                       1995
                    8HYDRO2                    Hydrosizer 2                       1995
                    8HYDRO3                    Hydrosizer 3                       1995
                      8ST1A                Slurry Tank #2 side                    1979
                     8VT1A              Vacuum filter Table #2 side               1979
                      8DS1A           Damp sand storage silo #2 side              1979
                      8BE1A           Vacuum table discharge elevator             1979
                                                  #2 side

EUG “LOADOUT”: These units are “grandfathered” (constructed prior to any applicable rule).
There are no emission limits applied to this unit under Title V but it is limited to the existing
equipment as it is.

  EU ID            Point ID                  EU Name/Model                  Construction Date
  Stack 3           8BC2              Belt Conveyor #2 Rail Load-out            Pre-1972
                  8TLONLS4            North track load-out snorkle #4           Pre-1972
                  8TLONLS5             South track load-out snorkle             Pre-1972
  Stack 2        8NTLONLS1                Truck load-out spout #1               Pre-1972
                 8NTLONLS2                Truck load-out spout #2               Pre-1972
               8LTOCOOLSND            Cool sand truck load-out spout            Pre-1972

EUG “LOADOUT2”: Emissions are estimated based on existing equipment items and the
emissions are insignificant (less than 5 TPY).

  EU ID            Point ID                EU Name/Model                    Construction Date
LOADOUT2           8NDC5             Conveyor for No. 2 truck loadout             9/99
                   8NDC4                     Truck loadout                        9/99

EUG “STORAGE1”: These units are “grandfathered” (constructed prior to any applicable rule).
There are no emission limits applied to this unit under Title V but it is limited to the existing
equipment as it is.
                                                                   DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                               4

    EU ID             Point ID                EU Name/Model                    Construction Date
    Stack 1            8BE3N            #1 Side Rotex Screen discharge             Pre-1972
                                                   elevator
                     8NSILO#1               North whole grain silo                  Pre-1972
                     8NSILO#2               Middle whole grain silo                 Pre-1972

EUG “STORAGE2”

Discharge        Unit ID                      EU Name/Model                       PM10 Emissions
  Point                                                                           lb/hr    TPY
 Stack 6         8BE3A      #2 Side Rotex Screen discharge elevator                3.63   15.91
                 8NPB1                OK-100 product silo
                 8SC3N       #3 Dry Sand Storage discharge screw
               8NSILO#4             South whole grain silo
                 8BE4N                 Cool sand elevator
                8BC3N    Transfer conveyor from BE3A to OK-100 silo
                 8SC2N        #2 dry sand storage discharge screw
                 8SC1N                  Discharge screw
                8BC4N            OK80/90 conveyor atop silos
              8NTLOOK100        Truck load-out for OK-100 silo

2. The permittee shall be authorized to operate the facility 8,760 hours per year at a process weight
rate of up to 370 TPH through the bulk receiving equipment and a total facility process rate of
3,241,200 tons per year (12-month rolling total) silica sand.                 [OAC 252:100-8-6(a)]

3. The permittee shall not cause or permit the discharge of any visible fugitive dust emissions
beyond the property line on which the emissions originate in such a manner as to damage or
interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or
interfere with the maintenance of air quality standards.                       [OAC 252:100-29]

4. The following emissions units shall be operated with the stated air pollution controls, or
equivalent methods approved by AQD.                                   [OAC 252:100-8-6(a)]
                                                   DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                             5


EU ID       Point ID       EU Name/Model                     Air Pollution Control
SCREENING   8Rotex #1      Vibrating screen #1 Type 522A     Torit Dust Collector
            8Rotex #2      Vibrating screen #2 Type 522A     Torit Dust Collector
DRYING1     8FD1           No. 1 fluidized bed dryer         Cyclone/wet scrubber
            8BC1           Feed belt to dryer                Cyclone/wet scrubber
            8BE2N          No. 1 fluid bed dryer discharge   Cyclone/wet scrubber
                           elevator
DRYING2     8FD2           No. 2 fluidized bed dryer         Wet scrubber
            8BC1A          Feed belt to dryer                Wet scrubber
            8BE2A          No. 2 fluid bed dryer discharge   Wet scrubber
                           elevator
FUGITIVE – 8AUTOMON1       Automatic monitor #1 – Stang      Wet material
Pre-1972   8STOCKPILE      Wet sand stockpile                Wet material
           8STOCKSCREEN    Stockpile screening vat           Wet material
           8FL988B         Caterpiller front end loader      Wet material
           8PITSCREEN      Tyler screening vat               Wet material
           8RST1           Raw sand tank 1100 Ton/Mine       Wet material
           8NSILO3         Cool sand tank                    Wet material
           8RST2           Fines slurry tank                 Wet material
           8ST1            Slurry tank #1 slide              Wet material
           8VT1            Vacuum filter table #1            Wet material
           8DS1            Damp sand storage Silo #1         Wet material
           8BE1N           Vacuum table discharge elevator   Wet material
                           #1 side
FUGITIVE – 8 RCT1          Rising current tank hydrosizers   Wet material
Post 1972  8HYDRO1         Hydrosizer 1                      Wet material
           8HYDRO2         Hydrosizer 2                      Wet material
           8HYDRO3         Hydrosizer 3                      Wet material
           8ST1A           Slurry Tank #2 side               Wet material
           8VT1A           Vacuum filter Table #2 side       Wet material
           8DS1A           Damp sand storage silo #2 side    Wet material
           8BE1A           Vacuum table discharge elevator   Wet material
                           #2 side
LOADOUT     8BC2           Belt Conveyor #2 Rail Load-out    Wet scrubber
            8TLONLS4       North track load-out snorkle #4   Wet scrubber
            8TLONLS5       South track load-out snorkle      Wet scrubber
            8NTLONLS1      Truck load-out spout #1           Wet scrubber
            8NTLONLS2      Truck load-out spout #2           Wet scrubber
            8LTOCOOLSND    Cool sand truck load-out spout    Wet scrubber
                                                                DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                             6


EU ID           Point ID              EU Name/Model                       Air Pollution Control
LOADOUT2        8NDC5                 No. 2 Truck loadout conveyor        dry cartridge
                8NDC4                 No. 2 Truck loadout                 dry cartridge
STORAGE1        8BE3N                 #1 Side Rotex Screen discharge      Wet scrubber
                                      elevator
                8NSILO#1              North whole grain silo              Wet scrubber
                8NSILO#2              Middle whole grain silo             Wet scrubber
STORAGE2        8BE3A                 #2 Side Rotex Screen discharge      Dry cartridge filter
                                      elevator
                8NPB1                 OK-100 product silo                 Dry cartridge filter
                8SC3N                 #3 Dry Sand Storage discharge       Dry cartridge filter
                                      screw
                8NSILO#4              South whole grain silo              Dry cartridge filter
                8BE4N                 Cool sand elevator                  Dry cartridge filter
                8BC3N                 Transfer conveyor from BE3A to      Dry cartridge filter
                                      OK-100 silo
                8SC2N                 #2 dry sand storage discharge       Dry cartridge filter
                                      screw
                8SC1N                 Discharge screw                     Dry cartridge filter
                8BC4N                 OK80/90 conveyor atop silos         Dry cartridge filter
                8NTLOOK100            Truck load-out for OK-100 silo      Dry cartridge filter

5. Except for Stack 4 (Dryer No. 2), no discharge of greater than 20% opacity is allowed except
for short-term occurrences which consist of not more than one six-minute period in any
consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case
shall the average of any six-minute period exceed 60% opacity.               [OAC 252:100-25]

6. The permittee shall conduct Method 22 or Method 9 visual observations of emissions from the
stacks for Dryer No. 1 and Dryer No. 2 on the first day of any period during which liquid fuels
are burned and at least once per day thereafter during periods when liquid fuels are burned in a
dryer. In no case shall the observation period be less than six minutes in duration. If visible
emissions are observed for six minutes in duration for any observation period and such emissions
are not the result of a malfunction, then the permittee shall conduct, for the identified points,
within 24 hours, a visual observation of emissions, in accordance with 40 CFR Part 60,
Appendix A, Method 9.                                                         [OAC 252:100-43]
                                                                    DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                              7

    a.        When four consecutive daily visible emission observations or Method 9
              observations show no visible emissions, or no emissions of a shade or density
              greater than twenty (20) percent equivalent opacity, respectively, the frequency may
              be reduced to weekly visual observations, as above. Upon any showing of non-
              compliance the observation frequency shall revert to daily.
    b.        If a Method 9 observation exceeds 20% opacity the permittee shall conduct at least
              two additional Method 9 observations within the next 24-hours.
    c.        If more than one six-minute Method 9 observation exceeds 20% opacity in any
              consecutive 60 minutes; or more than three six-minute Method 9 observations in any
              consecutive 24 hours exceeds 20% opacity; or if any six-minute Method 9
              observation exceeds 60% opacity; the owner or operator shall comply with the
              provisions for excess emissions during start-up, shut-down, and malfunction of air
              pollution control equipment.                                          [OAC 252:100-25]

7. At least once per week when Stacks 2, 3, 5, 6, 7 or 8 are operated, the permittee shall measure
and record the pressure differential across the air pollution control devices. If any pressure
differential is less than 0.5” WC, the permittee shall conduct Method 9 testing of the opacity of
discharges to the atmosphere.

8. The following records shall be maintained on-site to verify Insignificant Activities. All such
records shall be made available to regulatory personnel upon request. These records shall be
maintained for a period of at least five years after the time they are made. [OAC 252:100-8-6(a)]

         a. Fuel dispensing to facility owned vehicles (daily average throughputs over 30-day
            periods).
         b. Vapor pressures of materials stored and throughputs for diesel tanks (monthly and
            cumulative annual).

9. The permittee shall keep records of operations as listed. These records shall be maintained on-
site for inspection by regulatory personnel upon request. Required records shall be retained for a
period of at least five years following dates of recording.                     [OAC 252:100-45]

         a.        Production of sand product (monthly and 12-month rolling totals).
         b.        Inspection and maintenance of all air pollution control devices (weekly).
         c.        Visible emissions testing of each stack (weekly/monthly).
         d.        Dryer auxiliary liquid fuel sulfur content.
         e.        Pressure differentials on air pollution controls for Stacks 2, 3, 5, 6, 7, and 8
                   (weekly when operated).
         f.        Records of pressure differential and liquor flow for Stack 4 as required by NSPS
                   Subpart UUU (daily when operated).
         g.        Records of pressure differential and liquor flow for Stack 1 and 4 as required by
                   CAM (each shift when each dryer is operated).
                                                                  DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                               8

10. This permit supersedes all previous air quality permits. Those permits are now null and void

11. No later than 30 days after each anniversary date of the issuance of the initial Part 70
operating permit (April 2, 2001), the permittee shall submit to Air Quality Division of DEQ, with
a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of
this permit. The following specific information is required to be included:
                                                              [OAC 252:100-8-6 (c)(5)(A) & (D)]

       a. Production of sand product (monthly and 12-month rolling totals).
       b. Inspection and maintenance of all air pollution control devices (weekly).
       c. Pressure differentials of each wet scrubber (daily when operating).
       d. Liquid fuel usage volumes.
       e. Liquid fuel sulfur content for each heater.
       f. Records of pressure differential and liquor flow for Stack 4 as required by NSPS
          Subpart UUU (daily when operated).
       g. Records of pressure differential and liquor flow for Stack 1 and 4 as required by CAM
          (each shift when each dryer is operated).

12. The Permit Shield (Standard Conditions, Section VI) is extended to the following
requirements that have been determined to be inapplicable to this facility.
                                                                         [OAC 252:100-8-6(d)(2)]

       a.      OAC 252:100-11         Alternative Emissions Reduction
       b.      OAC 252:100-15         Mobile Sources
       c.      OAC 252:100-23         Cotton Gins
       d.      OAC 252:100-24         Grain Elevators
       e.      OAC 252:100-47         Landfills

13. Reasonable precautions shall be taken to minimize fugitive dust emissions from loading and
unloading operations, haul roads, and stockpiles. These precautions shall include, but not be
limited to:                                                                  [OAC 252:100-29]

       a.      Use of water and/or chemical stabilizers on roads and stockpiles.
       b.      Application of other coatings or coverings to substances susceptible to becoming
               air-borne or wind-borne.
       c.      Covering or wetting material in trucks.
       d.      Planting and maintaining vegetation coverings or windbreaks.
       e.      Locate stockpiles as to provide minimum exposure to high winds and avoid open
               spaces in line with neighboring homes and businesses.

14. Compliance Assurance Monitoring Requirements and Specifications:             [40 CFR Part 64]

       A. CAM for wet scrubbers.
                                                                    DRAFT
SPECIFIC CONDITIONS NO. 2005-203-TVR                                                                 9


                         Indicator No. 1                        Indicator No. 2
Indicator                Scrubber pressure differential         Scrubber liquor flow
Measurement              Differential pressure transducer or    Scrubber liquid flow is measured
Approach                 u-tube manometer                       using a magnetic flow tube element
Indicator Range          An excursion is defined as a 1-hour    An excursion is defined as an
                         average pressure differential below    hourly scrubber liquid flow less
                         8 inches water column. Excursions      than 80 GPM. Excursions trigger
                         trigger an inspection, corrective      an inspection, corrective actions,
                         actions, and a reporting               and a reporting requirement.
                         requirement.
Data                     The differential pressure transducer   The scrubber liquid flow rate
Representativeness       or manometer monitors the static       sensor is located on the scrubber
Performance              pressures upstream and                 liquid recirculation line.
Criteria                 downstream of the wet scrubber
QA/QC Practices          Monthly comparison to U-tube           Monitoring equipment and process
and Criteria             manometer. Acceptability criterion     downtime is recorded in a log. The
                         is 0.5 inches WC.                      flow sensor is calibrated at least
                                                                annually in accordance with
                                                                manufacturer specifications.
Monitoring               Measured at least once per shift       Measured at least once per shift
Frequency                when unit is operated                  when unit is operated
Data Collection          Recorded at least once per shift       Recorded at least once per shift
Procedure                either in a log or by computer.        either in a log or by computer.
Averaging Period         12-hours                               12-hours

B. CAM for dry filters

                               Indicator
Indicator                      Baghouse pressure differential
Measurement Approach           Differential pressure transducer or manometer
Indicator Range                An excursion is defined as a 1-hour average pressure differential
                               below 0.5 inches water column or above 5 inches water column.
                               Excursions trigger an inspection, corrective actions, and a
                               reporting requirement.
Data Representativeness        The pressure transducer or manonmeter monitors the static
Performance Criteria           pressures upstream and downstream of the baghouse.
QA/QC Practices and            Monthly comparison to U-tube manometer. Acceptability criterion
Criteria                       is 0.5 inches WC.
Monitoring Frequency           Measured at least once per shift when unit is operated
Data Collection Procedure      Data are recorded by computer or manually and recorded in log
Averaging Period               12-hours
Mr. Jack M. Pryor, P.E., P.S., QEP, CES
Corporate EHS Department
U. S. Silica Company
P. O. Box 187
Berkeley Springs, WV 25411

SUBJECT:       Operating Permit No. 2005-203-TVR
               U. S. Silica Company, Mill Creek North Plant
               Mill Creek, Johnston County, Oklahoma

Dear Mr. Pryor:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this
permit is issued subject to standard and specific conditions, which are attached. These conditions
must be carefully followed since they define the limits of the permit and will be confirmed by
periodic inspections.

Also note that you are required to annually submit an emissions inventory for this facility. An
emissions inventory must be completed on approved AQD forms and submitted (hardcopy or
electronically) by March 1st of every year. Any questions concerning the form or submittal
process should be referred to the Emissions Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If I may be of further service, or you have any
questions about this permit, please call me at (405) 702-4198.

Sincerely,


David S. Schutz, P.E.
Environmental Engineer
New Source Permit Section
AIR QUALITY DIVISION

Copy: Johnston County DEQ Office


Enclosures
                             PART 70 PERMIT
                      AIR QUALITY DIVISION
                      STATE OF OKLAHOMA
             DEPARTMENT OF ENVIRONMENTAL QUALITY
                    707 N. ROBINSON, SUITE 4100
                            P. O. BOX 1677
               OKLAHOMA CITY, OKLAHOMA 73105-3483


                            Permit No. 2005-203-TVR

                                   U. S. Silica Company                                  ,
having complied with the requirements of the law, is hereby granted permission to operate
an industrial sand processing plant (Mill Creek North Plant), in Mill Creek, Johnston
County, Oklahoma,


[X] Standard Conditions Dated July 1, 2005
[X] Specific Conditions


This permit shall expire five (5) years from the date below, except as authorized under
Section VIII of the Standard Conditions.



_________________________________
Division Director, Air Quality Division                             Date


DEQ Form #100-890                                                          Revised 2/25/04
              TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT
                            STANDARD CONDITIONS
                                  (July 1, 2005)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with Title V of the
federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean
Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ). The permit does not relieve the holder of the
obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or
ordinances.                                      [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance
shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement
action, for revocation of the approval to operate under the terms of this permit, or for denial of an
application to renew this permit. All terms and conditions (excluding state-only requirements)
are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act.
This permit is valid for operations only at the specific location listed.
                              [40 CFR §70.6(b), OAC 252:100-8-1.3 and 8-6 (a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of the permit.                                        [OAC 252:100-8-6 (a)(7)(B)]

SECTION II.       REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from emergency conditions and/or posing an imminent and
substantial danger to public health, safety, or the environment shall be reported in accordance
with Section XIV.                                              [OAC 252:100-8-6 (a)(3)(C)(iii)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.
                                                              [OAC 252:100-8-6 (a)(3)(C)(iv)]

C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as
the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m.
the next working day the permittee becomes aware of the exceedance. Within ten (10) working
days after the immediate notice is given, the owner operator shall submit a written report
describing the extent of the excess emissions and response actions taken by the facility. Every
written report submitted under OAC 252:100-8-6 (a)(3)(C)(iii) shall be certified by a responsible
official.                                                        [OAC 252:100-8-6 (a)(3)(C)(iii)]
TITLE V PERMIT STANDARD CONDITIONS                                                               2
July 1, 2005

SECTION III.      MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. Unless a different retention
period or retention conditions are set forth by a specific term in this permit, these records,
including monitoring data and necessary support information, shall be retained on-site or at a
nearby field office for a period of at least five years from the date of the monitoring sample,
measurement, report, or application, and shall be made available for inspection by regulatory
personnel upon request. Support information includes all original strip-chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this permit. Where
appropriate, the permit may specify that records may be maintained in computerized form.
                                    [OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]

B. Records of required monitoring shall include:
   (1) the date, place and time of sampling or measurement;
   (2) the date or dates analyses were performed;
   (3) the company or entity which performed the analyses;
   (4) the analytical techniques or methods used;
   (5) the results of such analyses; and
   (6) the operating conditions as existing at the time of sampling or measurement.
                                                                 [OAC 252:100-8-6 (a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the
original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any
required monitoring. All instances of deviations from permit requirements since the previous
report shall be clearly identified in the report.          [OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or
operator shall comply with the provisions of Section II of these standard conditions.
                                                                  [OAC 252:100-8-6 (a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this
permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,
Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean
Air Act or Oklahoma Clean Air Act.

F. Submission of quarterly or semi-annual reports required by any applicable requirement that
are duplicative of the reporting required in the previous paragraph will satisfy the reporting
requirements of the previous paragraph if noted on the submitted report.

G. Every report submitted under OAC 252:100-8-6 and OAC 252:100-43 shall be certified by a
responsible official.                                    [OAC 252:100-8-6 (a)(3)(C)(iv)]
TITLE V PERMIT STANDARD CONDITIONS                                                               3
July 1, 2005

H. Any owner or operator subject to the provisions of NSPS shall maintain records of the
occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected
facility or any malfunction of the air pollution control equipment.           [40 CFR 60.7 (b)]

I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by the subpart recorded in a permanent file suitable
for inspection. This file shall be retained for at least two years following the date of such
measurements, maintenance, and records.                                      [40 CFR 60.7 (d)]

J. The permittee of a facility that is operating subject to a schedule of compliance shall submit
to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for
achieving the activities, milestones or compliance required in the schedule of compliance and the
dates when such activities, milestones or compliance was achieved. The progress reports shall
also contain an explanation of why any dates in the schedule of compliance were not or will not
be met, and any preventative or corrective measures adopted.            [OAC 252:100-8-6 (c)(4)]

K. All testing must be conducted by methods approved by the Division Director under the
direction of qualified personnel. All tests shall be made and the results calculated in accordance
with standard test procedures. The use of alternative test procedures must be approved by EPA.
When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated
in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the
requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method
approved by Air Quality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR
§70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]

L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required
by 40 CFR Part 60, 61, and 63, for all equipment constructed or operated under this permit
subject to such standards.                       [OAC 252:100-4-5 and OAC 252:100-41-15]

SECTION IV.       COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70
operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a
certification of compliance with the terms and conditions of this permit and of any other
applicable requirements which have become effective since the issuance of this permit. The
compliance certification shall also include such other facts as the permitting authority may
require to determine the compliance status of the source.
                                                    [OAC 252:100-8-6 (c)(5)(A), (C)(v), and (D)]

B. The certification shall describe the operating permit term or condition that is the basis of the
certification; the current compliance status; whether compliance was continuous or intermittent;
TITLE V PERMIT STANDARD CONDITIONS                                                              4
July 1, 2005

the methods used for determining compliance, currently and over the reporting period; and a
statement that the facility will continue to comply with all applicable requirements.
                                                               [OAC 252:100-8-6 (c)(5)(C)(i)-(iv)]

C. Any document required to be submitted in accordance with this permit shall be certified as
being true, accurate, and complete by a responsible official. This certification shall state that,
based on information and belief formed after reasonable inquiry, the statements and information
in the certification are true, accurate, and complete.
                                                [OAC 252:100-8-5 (f) and OAC 252:100-8-6 (c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions
units or stationary sources that are not in compliance with all applicable requirements. This
schedule shall include a schedule of remedial measures, including an enforceable sequence of
actions with milestones, leading to compliance with any applicable requirements for which the
emissions unit or stationary source is in noncompliance. This compliance schedule shall
resemble and be at least as stringent as that contained in any judicial consent decree or
administrative order to which the emissions unit or stationary source is subject. Any such
schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the
applicable requirements on which it is based, except that a compliance plan shall not be required
for any noncompliance condition which is corrected within 24 hours of discovery.
                                      [OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8-6 (c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE
PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the
permit term and that are applicable to the facility. Compliance with all new requirements shall
be certified in the next annual certification.                        [OAC 252:100-8-6 (c)(6)]

SECTION VI.       PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions
established for alternate operating scenarios, emissions trading, and emissions averaging, but
excluding terms and conditions for which the permit shield is expressly prohibited under OAC
252:100-8) shall be deemed compliance with the applicable requirements identified and included
in this permit.                                                      [OAC 252:100-8-6 (d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific
Conditions of this permit. Those requirements that the applicant requested be determined as not
applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]
TITLE V PERMIT STANDARD CONDITIONS                                                               5
July 1, 2005

SECTION VII.       ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees
based on emissions inventories. The methods used to calculate emissions for inventory purposes
shall be based on the best available information accepted by AQD.
                                        [OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8-6 (a)(8)]

SECTION VIII.       TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date
of issuance.                                                      [OAC 252:100-8-6 (a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely
and complete renewal application has been submitted at least 180 days before the date of
expiration.                                                        [OAC 252:100-8-7.1 (d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if
work is suspended for more than 18 months after it is commenced.       [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified
operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX.       SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application
of any provision of this permit to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit, shall not be affected thereby.
                                                                        [OAC 252:100-8-6 (a)(6)]

SECTION X.       PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.
                                                                    [OAC 252:100-8-6 (a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon
which the equipment is located and does not release the permittee from any liability for damage
to persons or property caused by or resulting from the maintenance or operation of the equipment
for which the permit is issued.                                        [OAC 252:100-8-6 (c)(6)]
TITLE V PERMIT STANDARD CONDITIONS                                                               6
July 1, 2005

SECTION XI.       DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty
(60) days of the request unless the DEQ specifies another time period, any information that the
DEQ may request to determine whether cause exists for modifying, reopening, revoking,
reissuing, terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the DEQ copies of records required to be kept by the permit.
                                                                     [OAC 252:100-8-6 (a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted
pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and
shall be separable from the main body of the document such as in an attachment.
                                                                   [OAC 252:100-8-6 (a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and
shall be made in writing within 10 days after such date.
                                               [Oklahoma Clean Air Act, 27A O.S. § 2-5-112 (G)]

SECTION XII.       REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.
Except as provided for minor permit modifications, the filing of a request by the permittee for a
permit modification, revocation, reissuance, termination, notification of planned changes, or
anticipated noncompliance does not stay any permit condition.
                                      [OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]

B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in
the following circumstances:             [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

    (1) Additional requirements under the Clean Air Act become applicable to a major source
        category three or more years prior to the expiration date of this permit. No such
        reopening is required if the effective date of the requirement is later than the expiration
        date of this permit.
    (2) The DEQ or the EPA determines that this permit contains a material mistake or that the
        permit must be revised or revoked to assure compliance with the applicable
        requirements.
    (3) The DEQ or the EPA determines that inaccurate information was used in establishing
        the emission standards, limitations, or other conditions of this permit. The DEQ may
        revoke and not reissue this permit if it determines that the permittee has submitted false
        or misleading information to the DEQ.
TITLE V PERMIT STANDARD CONDITIONS                                                                 7
July 1, 2005

C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it
shall only apply under the following circumstances:                      [OAC 252:100-5-1.1]

    (1) It only applies to that specific item by serial number or some other permanent
        identification.
    (2) Grandfathered status is lost if the item is significantly modified or if it is relocated
        outside the boundaries of the facility.

D. To make changes other than (1) those described in Section XVIII (Operational Flexibility),
(2) administrative permit amendments, and (3) those not defined as an Insignificant Activity
(Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes
may require a permit modification.                                      [OAC 252:100-8-7.2 (b)]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that
are not specifically approved by this permit are prohibited.              [OAC 252:100-8-6 (c)(6)]

SECTION XIII.        INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow authorized regulatory officials to perform the following (subject to the
permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)
for confidential information submitted to or obtained by the DEQ under this section):

    (1) enter upon the permittee's premises during reasonable/normal working hours where a
        source is located or emissions-related activity is conducted, or where records must be
        kept under the conditions of the permit;
    (2) have access to and copy, at reasonable times, any records that must be kept under the
        conditions of the permit;
    (3) inspect, at reasonable times and using reasonable safety practices, any facilities,
        equipment (including monitoring and air pollution control equipment), practices, or
        operations regulated or required under the permit; and
    (4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times
        substances or parameters for the purpose of assuring compliance with the permit.
                                                                      [OAC 252:100-8-6 (c)(2)]

SECTION XIV.        EMERGENCIES

A. Any emergency and/or exceedance that poses an imminent and substantial danger to public
health, safety, or the environment shall be reported to AQD as soon as is practicable; but under
no circumstance shall notification be more than 24 hours after the exceedance.
                                                             [OAC 252:100-8-6 (a)(3)(C)(iii)(II)]
TITLE V PERMIT STANDARD CONDITIONS                                                              8
July 1, 2005

B. An "emergency" means any situation arising from sudden and reasonably unforeseeable
events beyond the control of the source, including acts of God, which situation requires
immediate corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency.                                    [OAC 252:100-8-2]

C. An emergency shall constitute an affirmative defense to an action brought for noncompliance
with such technology-based emission limitation if the conditions of paragraph D below are met.
                                                                       [OAC 252:100-8-6 (e)(1)]

D. The affirmative defense of emergency shall be demonstrated through properly signed,
contemporaneous operating logs or other relevant evidence that:

    (1) an emergency occurred and the permittee can identify the cause or causes of the
        emergency;
    (2) the permitted facility was at the time being properly operated;
    (3) during the period of the emergency the permittee took all reasonable steps to minimize
        levels of emissions that exceeded the emission standards or other requirements in this
        permit;
    (4) the permittee submitted timely notice of the emergency to AQD, pursuant to the
        applicable regulations (i.e., for emergencies that pose an “imminent and substantial
        danger,” within 24 hours of the time when emission limitations were exceeded due to
        the emergency; 4:30 p.m. the next business day for all other emergency exceedances).
        See OAC 252:100-8-6(a)(3)(C)(iii)(I) and (II). This notice shall contain a description of
        the emergency, the probable cause of the exceedance, any steps taken to mitigate
        emissions, and corrective actions taken; and
    (5) the permittee submitted a follow up written report within 10 working days of first
        becoming aware of the exceedance.
                                              [OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency shall have the burden of proof.                        [OAC 252:100-8-6 (e)(3)]

SECTION XV.       RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop
and register with the appropriate agency a risk management plan by June 20, 1999, or the
applicable effective date.                                             [OAC 252:100-8-6 (a)(4)]
TITLE V PERMIT STANDARD CONDITIONS                                                                9
July 1, 2005

SECTION XVI.        INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate individual emissions units that are either on the list in Appendix I to OAC Title 252,
Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.
Any activity to which a State or federal applicable requirement applies is not insignificant even if
it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]

    (1) 5 tons per year of any one criteria pollutant.
    (2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an
        aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per
        year for single HAP that the EPA may establish by rule.

SECTION XVII.        TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate any individual or combination of air emissions units that are considered inconsequential
and are on the list in Appendix J. Any activity to which a State or federal applicable requirement
applies is not trivial even if included on the trivial activities list.        [OAC 252:100-8-2]

SECTION XVIII.        OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the
need for any permit revision or any notification to the DEQ (unless specified otherwise in the
permit). When an operating scenario is changed, the permittee shall record in a log at the facility
the scenario under which it is operating.                 [OAC 252:100-8-6 (a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

    (1) result in no net emissions increases,
    (2) are not modifications under any provision of Title I of the federal Clean Air Act, and
    (3) do not cause any hourly or annual permitted emission rate of any existing emissions unit
        to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required
below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for
emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall
attach each such notice to their copy of the permit. For each such change, the written notification
required above shall include a brief description of the change within the permitted facility, the
date on which the change will occur, any change in emissions, and any permit term or condition
that is no longer applicable as a result of the change. The permit shield provided by this permit
does not apply to any change made pursuant to this subsection.          [OAC 252:100-8-6 (f)(2)]
TITLE V PERMIT STANDARD CONDITIONS                                                            10
July 1, 2005


SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility
unless elsewhere covered by a more restrictive requirement:

    (1) No person shall cause or permit the discharge of emissions such that National Ambient
        Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility.
                                                                               [OAC 252:100-3]
    (2) Open burning of refuse and other combustible material is prohibited except as
        authorized in the specific examples and under the conditions listed in the Open Burning
        Subchapter.                                                           [OAC 252:100-13]
    (3) No particulate emissions from any fuel-burning equipment with a rated heat input of 10
        MMBTUH or less shall exceed 0.6 lb/MMBTU.                             [OAC 252:100-19]
    (4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part
        60, NSPS, no discharge of greater than 20% opacity is allowed except for short-term
        occurrences which consist of not more than one six-minute period in any consecutive 60
        minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall
        the average of any six-minute period exceed 60% opacity.              [OAC 252:100-25]
    (5) No visible fugitive dust emissions shall be discharged beyond the property line on which
        the emissions originate in such a manner as to damage or to interfere with the use of
        adjacent properties, or cause air quality standards to be exceeded, or interfere with the
        maintenance of air quality standards.                                 [OAC 252:100-29]
    (6) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2
        lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur
        dioxide.                                                              [OAC 252:100-31]
    (7) Volatile Organic Compound (VOC) storage tanks built after December28, 1974, and
        with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia
        or greater under actual conditions shall be equipped with a permanent submerged fill
        pipe or with a vapor-recovery system.                           [OAC 252:100-37-15(b)]
    (8) All fuel-burning equipment shall at all times be properly operated and maintained in a
        manner that will minimize emissions of VOCs.                      [OAC 252:100-37-36]

SECTION XX.       STRATOSPHERIC OZONE PROTECTION

A.      The permittee shall comply with the following standards for production and consumption
of ozone-depleting substances.                                          [40 CFR 82, Subpart A]

   (1) Persons producing, importing, or placing an order for production or importation of certain
       class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the
       requirements of §82.4.
TITLE V PERMIT STANDARD CONDITIONS                                                             11
July 1, 2005

   (2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain
       class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping
       requirements at §82.13.
   (3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,
       HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane
       (Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include
       HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an
ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air
conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term
“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the
vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the
air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger
buses using HCFC-22 refrigerant.                                           [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions
reduction except as provided for MVACs in Subpart B.             [40 CFR 82, Subpart F]

   (1) Persons opening appliances for maintenance, service, repair, or disposal must comply
       with the required practices pursuant to § 82.156.
   (2) Equipment used during the maintenance, service, repair, or disposal of appliances must
       comply with the standards for recycling and recovery equipment pursuant to § 82.158.
   (3) Persons performing maintenance, service, repair, or disposal of appliances must be
       certified by an approved technician certification program pursuant to § 82.161.
   (4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply
       with record-keeping requirements pursuant to § 82.166.
   (5) Persons owning commercial or industrial process refrigeration equipment must comply
       with leak repair requirements pursuant to § 82.158.
   (6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant
       must keep records of refrigerant purchased and added to such appliances pursuant to §
       82.166.

SECTION XXI.        TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is
not inconsistent with Federal requirements, to provide for incorporation of requirements
established through construction permitting into the Sources’ Title V permit without causing
redundant review. Requirements from construction permits may be incorporated into the Title V
permit through the administrative amendment process set forth in Oklahoma Administrative
Code 252:100-8-7.2(a) only if the following procedures are followed:
TITLE V PERMIT STANDARD CONDITIONS                                                         12
July 1, 2005

     (1) The construction permit goes out for a 30-day public notice and comment using the
         procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This
         public notice shall include notice to the public that this permit is subject to
         Environmental Protection Agency (EPA) review, EPA objection, and petition to
         EPA, as provided by 40 CFR § 70.8; that the requirements of the construction permit
         will be incorporated into the Title V permit through the administrative amendment
         process; that the public will not receive another opportunity to provide comments
         when the requirements are incorporated into the Title V permit; and that EPA
         review, EPA objection, and petitions to EPA will not be available to the public when
         requirements from the construction permit are incorporated into the Title V permit.
     (2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR
         § 70.8(a)(1).
     (3) A copy of the draft construction permit is sent to any affected State, as provided by
         40 CFR § 70.8(b).
     (4) A copy of the proposed construction permit is sent to EPA for a 45-day review period
         as provided by 40 CFR § 70.8(a) and (c).
     (5) The DEQ complies with 40 CFR § 70.8 (c) upon the written receipt within the 45-day
         comment period of any EPA objection to the construction permit. The DEQ shall
         not issue the permit until EPA’s objections are resolved to the satisfaction of EPA.
     (6) The DEQ complies with 40 CFR § 70.8 (d).
     (7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8
         (a).
     (8) The DEQ shall not issue the proposed construction permit until any affected State and
         EPA have had an opportunity to review the proposed permit, as provided by these
         permit conditions.
     (9) Any requirements of the construction permit may be reopened for cause after
         incorporation into the Title V permit by the administrative amendment process, by
         DEQ as provided in OAC 252:100-8-7.3 (a), (b), and (c), and by EPA as provided in
         40 CFR § 70.7 (f) and (g).
     (10) The DEQ shall not issue the administrative permit amendment if performance tests
         fail to demonstrate that the source is operating in substantial compliance with all
         permit requirements.

  B. To the extent that these conditions are not followed, the Title V permit must go through
     the Title V review process.
TITLE V PERMIT STANDARD CONDITIONS                                                          13
July 1, 2005

SECTION XXII.       CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person
has violated or is in violation of any provision of the Oklahoma implementation plan, nothing
shall preclude the use, including the exclusive use, of any credible evidence or information,
relevant to whether a source would have been in compliance with applicable requirements if the
appropriate performance or compliance test or procedure had been performed.
                                                                          [OAC 252:100-43-6]
 TITLE V PERMIT STANDARD CONDITIONS                                                             14
 July 1, 2005


 EUG “SCREENING”
 Discharge  Unit ID            Process Rate Emission Factor Control Effic.       PM10 Emissions
   Point                          TPH                                            lb/hr   TPY
  Stack 5  8Rotex #1
           8Rotex #2
 TOTALS

  Discharge             Unit ID                  EU Name/Model                 PM10 Emissions
    Point                                                                     lb/hr      TPY
   Stack 5             8Rotex #1           Vibrating screen #1 Type 522A       0.26      1.13
                       8Rotex #2           Vibrating screen #2 Type 522A

 EUG “DRYING1” AND EUG “STORAGE1”
 Point Unit ID                   Process Pollutant            Emission      Cont.    Emissions
 ID                              Rate                         Factor        Effic.   lb/hr TPY
 Stack No. 1 fluidized bed dryer         PM10
 1         feed belt to dryer
           dryer discharge elevator
           #1 Side Rotex Screen
            discharge elevator
          North whole grain silo
          Middle whole grain silo
            31 MMBTUH Heater           221 GPH PM10           15 lb/Mgal
                                       No. 5 fuel SO2         201 lb/Mgal
                                       oil        NOx         55 lb/Mgal
                                                  VOC         0.28
                                                              lb/Mgal
                                                  CO          5 lb/Mgal

 The two EUGs share a discharge point. Both EUGs consist of grandfathered equipment.

Point           Unit ID                   PM10        SO2         NOx        VOC        CO
 ID                                   lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY
Stack   No. 1 fluidized bed dryer     11.36 49.74 41.50 181.9 12.16 53.24 0.25 1.09 2.55 11.18
  1         feed belt to dryer
        dryer discharge elevator
         31 MMBTUH Heater
         #1 Side Rotex Screen
          discharge elevator
        North whole grain silo
        Middle whole grain silo
 TITLE V PERMIT STANDARD CONDITIONS                                                       15
 July 1, 2005


 EUG “DRYING2”

 Point   Unit ID                    Process    Pollutant   Emission      Cont.    Emissions
 ID                                 Rate                   Factor        Effic.   lb/hr TPY
 Stack        Sand Dryer No. 2                 PM10
 4           Product Silo No. 1
             Product Silo No. 2
            31 MMBTUH Heater        221 GPH PM10           9.7 lb/Mgal
                                    No. 2 fuel SO2         126 lb/Mgal
                                    oil        NOx         55 lb/Mgal
                                               VOC         0.28
                                                           lb/Mgal
                                               CO          5 lb/Mgal

Point          Unit ID                PM10        SO2         NOx        VOC        CO
 ID                               lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY
Stack      Sand Dryer No. 2       11.36 49.74 22.01 96.40 12.16 53.24 0.25 1.09 2.55 11.18
  4       Product Silo No. 1
          Product Silo No. 2
         31 MMBTUH Heater

 EUG “FUGITIVE POST-1972”

Discharge       Unit ID        Process Rate Emission Factor Control Effic.    PM10 Emissions
  Point                           TPH                                         lb/hr   TPY
FUGITIVE       8 RCT1
    2         8HYDRO1
              8HYDRO2
              8HYDRO3
               8ST1A
               8VT1A
               8DS1A
               8BE1A
TOTALS
 TITLE V PERMIT STANDARD CONDITIONS                                                       16
 July 1, 2005

  Discharge    Point ID              EU Name/Model                       PM10 Emissions
    Point                                                               lb/hr      TPY
 FUGITIVE2      8 RCT1         Rising current tank hydrosizers           0.01      0.01
               8HYDRO1                  Hydrosizer 1                     0.01      0.01
               8HYDRO2                  Hydrosizer 2                     0.01      0.01
               8HYDRO3                  Hydrosizer 3                     0.01      0.01
                8ST1A               Slurry Tank #2 side                  0.01      0.01
                8VT1A           Vacuum filter Table #2 side              1.07      4.70
                8DS1A          Damp sand storage silo #2 side            0.06      0.24
                8BE1A      Vacuum table discharge elevator #2 side       0.06      0.24
  TOTALS                                                                 1.23      5.23

 EUG “FUGITIVE PRE-1972”

 Discharge       Unit ID     Process Rate     Emission        Control     PM10 Emissions
   Point                        TPH            Factor          Effic.     lb/hr   TPY
FUGITIVE1      8AUTOMON1
                8STOCKPILE
              8STOCKSCREEN
                  8FL988B
                8PITSCREEN
                   8RST1
                  8NSILO3
                   8RST2
                    8ST1
                    8VT1
                    8DS1
                   8BE1N
TOTALS
 TITLE V PERMIT STANDARD CONDITIONS                                                     17
 July 1, 2005

 Point ID        Unit ID                EU Name/Model                  PM10 Emissions
                                                                      lb/hr      TPY
FUGITIVE1     8AUTOMON1       Automatic monitor #1 - Stang             0.11      0.49
               8STOCKPILE          Wet sand stockpile                  0.11      0.49
             8STOCKSCREEN        Stockpile screening vat               0.06      0.24
                 8FL988B       Caterpiller front end loader            0.06      0.24
               8PITSCREEN          Tyler screening vat                 0.11      0.49
                  8RST1       Raw sand tank 1100 Ton/Mine              0.06      0.24
                 8NSILO3             Cool sand tank                    0.06      0.24
                  8RST2             Fines slurry tank                  0.06      0.24
                   8ST1            Slurry tank #1 slide                0.53      2.35
                   8VT1          Vacuum filter table #1                1.07      4.70
                   8DS1        Damp sand storage Silo #1               0.06      0.24
                  8BE1N   Vacuum table discharge elevator #1 side      0.06      0.24
TOTALS                                                                2.35     10.20

 EUG “LOADOUT”

 Discharge        Unit ID      Process Rate   Emission      Control     PM10 Emissions
   Point                          TPH          Factor        Effic.     lb/hr   TPY
  Stack 5          8BC2
                 8TLONLS4
                 8TLONLS5
  Stack 2       8NTLONLS1
                8NTLONLS2
              8LTOCOOLSND
 TOTALS

 EUG “LOADOUT2”

 Discharge        Unit ID      Process Rate   Emission      Control     PM10 Emissions
   Point                          TPH          Factor        Effic.     lb/hr   TPY
  Stack 7         8NDC5
  Stack 8         8BC6N
 TOTALS
TITLE V PERMIT STANDARD CONDITIONS                                                      18
July 1, 2005

Discharge       Unit ID                EU Name/Model                    PM10 Emissions
  Point                                                                lb/hr     TPY
 Stack 3          8BC2          Belt Conveyor #2 Rail Load-out          0.40     1.75
               8TLONLS4          North track load-out snorkle #4
               8TLONLS5           South track load-out snorkle
  Stack 2     8NTLONLS1             Truck load-out spout #1            0.29      1.27
              8NTLONLS2             Truck load-out spout #2
            8LTOCOOLSND          Cool sand truck load-out spout
 Stack 7         8NDC5          Conveyor for No. 2 truck loadout       0.13      0.57
 Stack 8         8BC6N                    Truck loadout                0.13      0.57
TOTALS                                                                 0.95      4.16

EUG “STORAGE2”

Discharge       Unit ID      Process Rate    Emission        Control     PM10 Emissions
  Point                         TPH           Factor          Effic.     lb/hr   TPY
 Stack 6        8BE3A
                8NPB1
                8SC3N
              8NSILO#4
                8BE4N
               8BC3N
                8SC2N
                8SC1N
               8BC4N
             8NTLOOK100
TOTALS

Discharge     Unit ID                 EU Name/Model                     PM10 Emissions
  Point                                                                 lb/hr    TPY
 Stack 6       8BE3A      #2 Side Rotex Screen discharge elevator        3.63   15.91
               8NPB1                OK-100 product silo
               8SC3N       #3 Dry Sand Storage discharge screw
             8NSILO#4             South whole grain silo
               8BE4N                 Cool sand elevator
              8BC3N    Transfer conveyor from BE3A to OK-100 silo
               8SC2N        #2 dry sand storage discharge screw
               8SC1N                  Discharge screw
              8BC4N            OK80/90 conveyor atop silos
            8NTLOOK100        Truck load-out for OK-100 silo
TITLE V PERMIT STANDARD CONDITIONS                                     19
July 1, 2005

EUG “ROADS”
  Discharge   Point ID        EU Name/Model           PM10 Emissions
    Point                                            lb/hr      TPY
   ROADS      ROADS         Unpaved facility roads    2.33      9.75

EUG “TANKS”
  Discharge   Point ID        EU Name/Model           VOC Emissions
    Point                                            lb/hr     TPY
      A        Tank 1           Diesel tank           0.01     0.01
      B        Tank 2           Diesel tank           0.01     0.01
      C       Gasoline      Vehicle gasoline tank     0.10     0.44
  TOTALS                                              0.12     0.46

				
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