April 24, 2009 

Eric Ervin 

Plant Manager 

Holcim (US) Inc. 

4070 Trident Road 

Three Forks, MT 59752 

RE: Final Title V Operating Permit #OP0982-02 

Dear Mr. Ervin: 

The Department of Environmental Quality has prepared the enclosed Final Operating Permit #OP0982-

02, for Holcim (US) Inc., located in Three Forks, Montana. Please review the cover page of the attached 

permit for information pertaining to the action taking place on Permit #OP0982-02. 

If you have any questions, please contact Skye Hatten, the permit writer, at (406) 444-5287 or by email at 

shatten@mt.gov. 

Sincerely, 

Vickie Walsh 

Air Permitting Program Supervisor 

Air Resources Management Bureau 

(406) 444-9741 

 Skye Hatten, P.E. 

 Environmental Engineer 

 Air Resources Management Bureau 

 (406) 444-5287 

VW:SH: ob 

Enclosure 

Cc: Christopher Ajayi, US EPA Region VIII 8P-AR 

 Betsy Burns, US EPA Region VIII, Montana Office 

 Greg Gannon, 4070 Trident Road, Three Forks, MT 59752 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

i

STATE OF MONTANA 

Department of Environmental Quality 

Helena, Montana 59620 

AIR QUALITY OPERATING PERMIT OP0982-02 

 

Issued to: Holcim (US), Inc. 

 4070 Trident Road 

Three Forks, MT 59752 

Final Date: April 24, 2009 

Expiration Date: April 24, 2014 

Effective Date: April 24, 2009

Date of Decision: March 24, 2009 

End of EPA 45-day Review: March 23, 2009

Proposed Issue Date: February 6, 2009

Application Deemed Technically Complete: January 6, 2009

Application Deemed Administratively Complete: December 10, 2008

Minor Modification Application Received: November 10, 2008

AFS Number: 030-031-0005A

Permit Issuance and Appeal Processes: In accordance with Montana Code Annotated (MCA) Sections 

75-2-217 and 218 and the Administrative Rules of Montana (ARM), ARM Title 17, Chapter 8, 

Subchapter 12, Operating Permit Program, this operating permit is hereby issued by the Department of 

Environmental Quality (Department) as effective and final on April 24, 2009. This permit must be kept 

on-site at the above named facility. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

i

Montana Air Quality Operating Permit 

Department of Environmental Quality 

SECTION I.GENERAL INFORMATION ..............................................................................................1

SECTION II. SUMMARY OF EMISSION UNITS ...............................................................................2

SECTION III. PERMIT CONDITIONS ..................................................................................................3

A. FACILITY-WIDE........................................................................................................................... 3

B. EMITTING UNITS – EU001 FUGITIVE EMISSIONS: DISTURBED AREAS........................................ 6

 EU003 QUARRY BLASTING .......................................................................... 6

C. EMITTING UNITS – EU006 RAW MATERIAL STORAGE PILES...................................................... 8

 EU007 FUGITIVE EMISSIONS: HAUL ROADS ................................................ 8

D. EMITTING UNITS – EU008 PRIMARY CRUSHER........................................................................... 9

EU009 CRUSHER SCREEN............................................................................. 9

E. EMITTING UNITS – EU005 RAW MATERIALS TRANSFER AND CONVEYING.............................. 11

 EU010 RAW MATERIAL SILO #1: LOADING & UNLOADING....................... 11

 EU011 RAW MATERIAL SILOS #2 AND #3: LOADING & UNLOADING ........ 11

 EU012 RAW MATERIAL SILOS #4 AND #5: LOADING & UNLOADING ........ 11

 EU013 RAW MATERIAL SILOS #6 AND #7: LOADING & UNLOADING ........ 11

F. EMITTING UNITS – EU014 COAL/COKE UNLOADING ............................................................... 13

 EU015 COAL TRANSFER............................................................................. 13

EU018 COAL/COKE PRIMARY CRUSHER.................................................... 13

EU019 COAL SILO LOADING & UNLOADING, AND SECONDARY CRUSHING13

EU020 COKE SILO LOADING & UNLOADING, AND SECONDARY CRUSHING13

G. EMISSION UNIT – EU021 KILN ............................................................................................... 15

KILN ALTERNATE OPERATING SCENARIO #1 ............................................. 20

H. EMITTING UNIT – EU022 CLINKER COOLER ........................................................................... 25

I. EMITTING UNIT – EU023 INSIDE CLINKER TRANSFER FROM COOLER.................................... 27

J. EMITTING UNITS – EU024 CLINKER STORAGE SILOS #1 AND #2 &

INTERSTICE BIN LOAD/UNLOAD................................................................. 29

EU027 OUTSIDE CLINKER BINS LOADING ................................................. 29

EU033 CLINKER TRANSFER TO #2 FINISH MILL & #3 FINISH MILL........... 29

EU035 CLINKER TRANSFER TO #4 FINISH MILL......................................... 29

EU041 GYPSUM UNLOADING AND TRANSFER ........................................... 29

EU043 OUTSIDE CLINKER TRANSFER TO RECLAIM BUILDING .................. 29

K. EMITTING UNIT – EU025 CEMENT KILN DUST SILO LOADING ............................................... 31

L. EMITTING UNITS – EU026 CEMENT KILN DUST SILO UNLOADING TO TRUCK......................... 33

EU028-031 OUTSIDE CLINKER STORAGE SILOS #1-#4 .............................. 33

EU038 DUST DISCHARGE SPOUT BETWEEN KILN AND PRECIPITATOR ...... 33

EU040 IMPORT CLINKER UNLOADING AND TRANSFER.............................. 33

EU059 POST CONSUMER RECYCLED GLASS TRANSFERS........................... 33

EU060 OVERFLOW GYPSUM TRANSFER TO GROUND ................................ 33

EU061 OVERFLOW GYPSUM TRANSFER TO RECLAIM BUILDING............... 33

M. EMISSION UNIT – EU032 #2 FINISH MILL............................................................................... 34

N. EMITTING UNIT – EU034 #3 FINISH MILL ............................................................................... 37

O. EMITTING UNITS – EU036 #4 FINISH MILL PRODUCT SEPARATOR........................................... 39

EU037 #4 FINISH MILL............................................................................... 39

P. EMITTING UNITS – EU044 CEMENT LOADED/UNLOADED AT SILOS #1-#7, #10, #11, & #13 ... 41

EU045 CEMENT LOADED/UNLOADED AT SILOS #8, #9, & #12 .................. 41

Q. EMITTING UNITS – EU046 CEMENT TRANSFERRED FROM SILOS #1 - #13 TO 

BULK LOAD SILOS #14 - #25 ...................................................................... 43

EU0047 CEMENT LOADED/UNLOADED AT SILOS #14 - #25....................... 43

EU049 BULK CEMENT TRUCK TRANSFER/LOADOUT #1............................ 43

EU050 BULK CEMENT TRUCK TRANSFER/LOADOUT #2............................ 43
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

ii

EU051 BULK CEMENT RAILCAR TRANSFER/LOADOUTS #1 AND #2 .......... 43

EU062CKD RECYCLE DUST SCOOPS......................................................... 43

R. EMITTING UNIT – EU048 CEMENT LOADED/UNLOADED AT SILOS #26 - #30 ......................... 44

S. EMISSION UNIT – EU053 CKD AND FLYASH TRANSFERS TO/FROM POZZOLAN SILO ............ 46

T. EMITTING UNIT – EU054 LANDFILLED CEMENT KILN DUST (CKD) HANDLING.................... 48

U. EMITTING UNIT – EU055 MATERIAL HANDLING SYSTEM FOR FEEDING THE FINISH MILLS... 49

V. EMITTING UNIT – EU042 OUTSIDE CLINKER TRANSFER TO PILE............................................ 51

SECTION IV. NON-APPLICABLE REQUIREMENTS .....................................................................53

A. FACILITY-WIDE......................................................................................................................... 53

B. EMISSION UNITS........................................................................................................................ 54

SECTION V. GENERAL PERMIT CONDITIONS............................................................................55

A. COMPLIANCE REQUIREMENTS................................................................................................... 55

B. CERTIFICATION REQUIREMENTS ............................................................................................... 55

C. PERMIT SHIELD ......................................................................................................................... 56

D. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS ......................................... 57

E. PROMPT DEVIATION REPORTING............................................................................................... 58

F. EMERGENCY PROVISIONS.......................................................................................................... 58

G. INSPECTION AND ENTRY ........................................................................................................... 59

H. FEE PAYMENT ........................................................................................................................... 59

I. MINOR PERMIT MODIFICATIONS ............................................................................................... 59

J. CHANGES NOT REQUIRING PERMIT REVISION .......................................................................... 60

K. SIGNIFICANT PERMIT MODIFICATIONS...................................................................................... 61

L. REOPENING FOR CAUSE............................................................................................................. 61

M. PERMIT EXPIRATION AND RENEWAL......................................................................................... 61

N. SEVERABILITY CLAUSE............................................................................................................. 62

O. TRANSFER OR ASSIGNMENT OF OWNERSHIP ............................................................................. 62

P. EMISSIONS TRADING, MARKETABLE PERMITS, ECONOMIC INCENTIVES .................................. 62

Q. NO PROPERTY RIGHTS CONVEYED ........................................................................................... 62

R. TESTING REQUIREMENTS .......................................................................................................... 63

S. SOURCE TESTING PROTOCOL .................................................................................................... 63

T. MALFUNCTIONS ........................................................................................................................ 63

U. CIRCUMVENTION....................................................................................................................... 63

V. MOTOR VEHICLES ..................................................................................................................... 63

W. ANNUAL EMISSIONS INVENTORY .............................................................................................. 63

X. OPEN BURNING ......................................................................................................................... 63

Y. MONTANA AIR QUALITY PERMITS............................................................................................ 63

Z. NATIONAL EMISSION STANDARD FOR ASBESTOS ..................................................................... 64

AA. ASBESTOS.................................................................................................................................. 64

BB. STRATOSPHERIC OZONE PROTECTION – SERVICING OF MOTOR VEHICLE AIR CONDITIONERS 64

CC. STRATOSPHERIC OZONE PROTECTION – RECYCLING AND EMISSION REDUCTIONS .................. 65

DD. EMERGENCY EPISODE PLAN...................................................................................................... 65

EE. DEFINITIONS.............................................................................................................................. 65

APPENDIX A INSIGNIFICANT EMISSION UNITS........................................................................A-1

APPENDIX B DEFINITIONS AND ABBREVIATIONS...................................................................B-1

APPENDIX C NOTIFICATION ADDRESSES ..................................................................................C-1

APPENDIX D AIR QUALITY INSPECTOR INFORMATION .......................................................D-1

APPENDIX E POLLUTION CONTROL DEVICE INSPECTION AND 

 MAINTENANCE PLAN...............................................................................................E-1

APPENDIX F COMPLIANCE ASSURANCE MONITORING (CAM) .......................................... F-1
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

1

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this 

permit have the meaning assigned to them in the referenced regulations. 

SECTION I. GENERAL INFORMATION 

The following general information is provided pursuant to ARM 17.8.1210(1). 

Company Name: Holcim (US), Inc.

Mailing Address: 4070 Trident Road

City: Three Forks State: MT Zip: 59752 

Plant Location: NE 1⁄4 Section 9, SE 1⁄4 Section 4, SW 1⁄4 Section 3, NW 1⁄4 Section 10, Township 2 

North, Range 2 East, Gallatin County, MT

Responsible Official: Eric Ervin, Plant Manager Phone: (406) 285-3985 

Facility Contact Person: Greg Gannon, Environmental Manager Phone: (406) 285-4977

Primary SIC Code: 3241 (plant), 1422 (quarry)

Nature of Business: Portland Cement Manufacturing 

Description of Process: 

The production of Portland cement begins at the quarry. Most of the raw material used in the cement 

process is combined high and low-grade limestone quarried from Holcim’s quarry. Limestone rock and 

other raw materials are blasted and loaded onto trucks and transported to the crusher or to stockpiles. The 

raw materials are conveyed from the primary and secondary crushers to the storage bins. 

From the storage bins, the raw materials are conveyed to the ball mill where the ore is ground with water 

to form slurry and is then sent to storage tanks. In the tanks, the slurry is blended thoroughly before 

entering the kiln. 

The slurry is pumped to the uphill end of the kiln where the slurry is heated, evaporating water (H2O) 

from the slurry and turning it into clinker. The plant uses a combination of natural gas, coal and/or coke 

as fuel sources for the clinker production. 

When the clinker leaves the kiln, it is cooled, transported by drag chains, pan conveyor and bucket 

elevator to the clinker bins or outside storage. From the clinker bins, clinker and gypsum go to the 

“finish” ball mills, where it is ground to produce portland cement. The final cement product is conveyed 

to storage silos where it is loaded into railroad cars or bulk trucks. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

2

SECTION II. SUMMARY OF EMISSION UNITS 

The emission units regulated by this permit are the following (ARM 17.8.1211): 

Emissions Unit 

ID Description Pollution Control Device/Practice 

EU001 Fugitive Emissions: Disturbed Areas None 

EU003 Quarry Blasting None 

EU005 Raw Material Transfer and Conveying Baghouses 

EU006 Raw Material Storage Piles Water and/or Chemical Dust Suppressant 

EU007 Fugitive Emissions: Haul Roads Water and/or Chemical Dust Suppressant 

EU008 Primary Crusher Baghouse 

EU009 Crusher Screen Baghouse 

EU010 Raw Material Silo #1 Loading & Unloading Baghouse 

EU011 Raw Material Silos #2 & #3 Loading & Unloading Baghouse 

EU012 Raw Material Silos #4 & #5 Loading & Unloading Baghouse 

EU013 Raw Material Silos #6 & #7 Loading & Unloading Baghouse 

EU014 Coal/Coke Unloading Baghouse 

EU015 Coal Transfer Baghouse 

EU018 Coal/Coke Primary Crusher Baghouse 

EU019 Coal Silo Loading & Unloading & Secondary Crushing Baghouse 

EU020 Coke Silo Loading & Unloading, & Secondary Crushing Baghouse 

EU021 Kiln ESP 

EU022 Clinker Cooler Baghouse 

EU023 Inside Clinker Transfer from Cooler Baghouse 

EU024 Clinker Storage Silo #1, #2, & Interstice Bin Load/Unload Baghouse 

EU025 Cement Kiln Dust Silo Loading Baghouse 

EU026 Cement Kiln Dust Silo Unloading to Truck Water and/or Chemical Dust Suppressant 

EU027 Outside Clinker Bins Loading Baghouse 

EU028-031 Outside Clinker Storage Silos 1-4 None 

EU032 #2 Finish Mill Baghouse 

EU033 Clinker Transfer to #2 Finish Mill & #3 Finish Mill Baghouse 

EU034 #3 Finish Mill Baghouse 

EU035 Clinker Transfer to #4 Finish Mill Baghouse 

EU036 #4 Finish Mill Product Separator Baghouse 

EU037 #4 Finish Mill Baghouse 

EU038 Dust Discharge Spout between Kiln and Precipitator Baghouse 

EU040 Import Clinker Unloading & Transfer Baghouse 

EU041 Gypsum Unloading & Transfer Baghouse 

EU043 Outside Clinker Transfer to Reclaim Building Baghouse 

EU044 Cement Loaded/Unloaded at Silos #1-7, 10, 11, & 13 2 Baghouses 

EU045 Cement Loaded/Unloaded at Silos #8, 9 , & 12 2 Baghouses 

EU046 Cement Transferred form Silos #1-13 to Bulk Load Silos #14-25 Baghouse 

EU047 Cement Loaded/Unloaded at Silos #14-25 2 Baghouse 

EU048 Cement Loaded/Unloaded at Silos #26-30 Baghouse 

EU049-050 Bulk Cement Truck Transfer/Loadouts 1 & 2 2 Baghouses 

EU051 Bulk Cement Railcar Transfer/Loadouts 1 & 2 Baghouse 

EU053 CKD and Flyash Transfers to/from Pozzolan Silo Baghouse 

EU054 Landfilled Cement Kiln Dust Handling None 

EU055 Material Handling System for Feeding the Finish Mills 3 Baghouses 

EU059 Post Consumer Recycled Glass Transfers None 

EU060 Overflow Gypsum Transfer to Ground None 

EU061 Overflow Gypsum Transfer to Reclaim Building Feed Hopper Enclosed in Building 

EU062 CKD Recycle Dust Scoops 2 Baghouses 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

3

SECTION III. PERMIT CONDITIONS 

The following requirements and conditions are applicable to the facility or to specific emission units 

located at the facility (ARM 17.8.1211, 1212, and 1213). 

A. Facility-Wide 

Conditions Rule Citation Rule Description Pollutant/Parameter Limit 

A.1 ARM 17.8.105 Testing Requirements Testing Requirements ------- 

A.2 ARM 17.8.304(1) Visible Air Contaminants Opacity 40% 

A.3 ARM 17.8.304(2) Visible Air Contaminants Opacity 20% 

A.4 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20% 

A.5 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions ------- 

A.6 ARM 17.8.308 Particulate Matter, Airborne Reasonable Precaution, 

Construction 20% 

A.7 ARM 17.8.309 Particulate Matter, Fuel Burning 

Equipment Particulate Matter E= 0.882 * H-0.1664 Or 

E= 1.026 * H-0.233

A.8 ARM 17.8.310 Particulate Matter, Industrial 

Processes Particulate Matter E= 4.10 * P0.67 or 

E= 55 * P0.11- 40 

A.9 ARM 17.8.322(4) Sulfur Oxide Emissions, Sulfur in 

Fuel 

Sulfur in Fuel (liquid or 

solid fuels) 1 lb/MMBtu fired 

A.10 ARM 17.8.322(5) Sulfur Oxide Emissions, Sulfur in 

Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF 

A.11 ARM 17.8.324(3) Hydrocarbon Emissions, 

Petroleum Products Gasoline Storage Tanks ------- 

A.12 ARM 17.8.324 Hydrocarbon Emissions, 

Petroleum Products 65,000 Gallon Capacity ------- 

A.13 ARM 17.8.324 Hydrocarbon Emissions, 

Petroleum Products 

Oil-effluent Water 

Separator ------- 

A.14 ARM 17.8.340 New Source Performance 

Standards 

All Applicable Provisions 

of Subparts F & Y ------- 

A.15 ARM 17.8.342 NESHAPs General Provisions SSM Plans Submittal 

A.16 ARM 17.8.749 Permit Conditions, Facility 

Clinker Handling Operational Limit 

500,000 tons/rolling 12-

Month Period of Clinker 

Handled 

A.17 40 CFR 63 National Emission Standards for 

Hazardous Air Pollutants 

All Applicable Provisions 

of Subpart LLL ------ 

A.18 ARM 17.8.1212 Reporting Requirements Compliance Monitoring ------- 

A.19 ARM 17.8.1207 Reporting Requirements Annual Certification ------- 

Conditions

A.1. Pursuant to ARM 17.8.105, any person or persons responsible for the emission of any air 

contaminant into the outdoor atmosphere shall, upon written request of the Department, provide 

the facilities and necessary equipment (including instruments and sensing devices) and shall 

conduct test, emission or ambient, for such periods of time as may be necessary using methods 

approved by the Department. 

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 

17.8.105. In addition, for such sources, compliance with limits and conditions listing “as required 

by the Department” as the frequency, is verified annually using emission factors and engineering 

calculations by the Department’s compliance inspectors during the annual emission inventory 

review; in the case of Method 9 tests, compliance is monitored during the regular inspection by the 

compliance inspector. 

A.2. Pursuant to ARM 17.8.304(1), Holcim shall not cause or authorize emissions to be discharged into 

the outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an 

opacity of 40% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule 

or in this permit. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

4

A.3. Pursuant to ARM 17.8.304(2), Holcim shall not cause or authorize emissions to be discharged into 

the outdoor atmosphere from any source installed after November 23, 1968, that exhibit an opacity 

of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in 

this permit. 

A.4. Pursuant to ARM 17.8.308(1), Holcim shall not cause or authorize the production, handling, 

transportation, or storage of any material unless reasonable precautions to control emissions of 

particulate matter are taken. Such emissions of airborne particulate matter from any stationary 

source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless 

otherwise specified by rule or in this permit. 

A.5. Pursuant to ARM 17.8.308(2), Holcim shall not cause or authorize the use of any street, road or 

parking lot without taking reasonable precautions to control emissions of airborne particulate 

matter, unless otherwise specified by rule or in this permit. 

A.6. Pursuant to ARM 17.8.308, Holcim shall not operate a construction site or demolition project 

unless reasonable precautions are taken to control emissions of airborne particulate matter. Such 

emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 

20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this 

permit. 

A.7. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, Holcim shall not 

cause or authorize particulate matter caused by the combustion of fuel to be discharged from any 

stack or chimney into the outdoor atmosphere in excess of the maximum allowable emissions of 

particulate matter for existing fuel burning equipment and new fuel burning equipment calculated 

using the following equations: 

For existing fuel burning equipment (installed before November 23, 1968): 

E =0.882 * H-0.1664

For new fuel burning equipment (installed on or after November 23, 1968): 

E =1.026 * H-0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum 

allowable particulate emissions rate in pounds per MMBtu. 

A.8. Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, Holcim shall not 

cause or authorize particulate matter to be discharged from any operation, process, or activity into 

the outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate 

matter calculated using the following equations: 

For process weight rates up to 30 tons per hour: E = 4.10 * P0.67

For process weight rates in excess of 30 tons per hour: E = 55.0 * P0.11 – 40 

Where E = rate of emissions in pounds per hour and p = process weight rate in tons per hour. 

A.9. Pursuant to ARM 17.8.322(4), Holcim shall not burn liquid or solid fuels containing sulfur in 

excess of 1 pound per million BTU fired, unless otherwise specified by rule or in this permit. 

A.10. Pursuant to ARM 17.8.322(5), Holcim shall not burn any gaseous fuel containing sulfur 

compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen 

sulfide at standard conditions, unless otherwise specified by rule or in this permit. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

5

A.11. Pursuant to ARM 17.8.324(3), Holcim shall not load or permit the loading of gasoline into any 

stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except 

through a permanent submerged fill pipe, unless such tank is equipped with a vapor loss control 

device or is a pressure tank as described in ARM 17.8.324(1), unless otherwise specified by rule 

or in this permit. 

A.12. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, Holcim shall not 

place, store or hold in any stationary tank, reservoir or other container of more than 65,000 gallon 

capacity any crude oil, gasoline or petroleum distillate having a vapor pressure of 2.5 pounds per 

square inch absolute or greater under actual storage conditions, unless such tank, reservoir or other 

container is a pressure tank maintaining working pressure sufficient at all times to prevent 

hydrocarbon vapor or gas loss to the atmosphere, or is designed and equipped with a vapor loss 

control device, properly installed, in good working order and in operation. 

A.13. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, Holcim shall not 

use any compartment of any single or multiple-compartment oil-effluent water separator, which 

compartment receives effluent water containing 200 gallons a day or more of any petroleum 

product from any equipment processing, refining, treating, storing or handling kerosene or other 

petroleum product of equal or greater volatility than kerosene, unless such compartment is 

equipped with a vapor loss control device, constructed so as to prevent emission of hydrocarbon 

vapors to the atmosphere, properly installed, in good working order and in operation. 

A.14. Holcim shall comply with all applicable provisions, as appropriate, of 40 CFR 60, Subpart F – 

Standards of Performance for Portland Cement Plants and Subpart Y – Standards of Performance 

for Coal Preparation Plants (ARM 17.8.340, and 40 CFR 60, Subpart F and Y). 

A.15. Pursuant to ARM 17.8.342 and 40 CFR 63.6, Holcim shall submit to the Department a copy of 

any startup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6(e)(3) within 30 

days of the effective date of this operating permit (if not previously submitted), within 30 days of 

the compliance date of any new National Emission Standard for Hazardous Air Pollutants 

(NESHAPs) or Maximum Achievable Control Technology (MACT) standard, and within 30 days 

of the revision of any such SSM plan, when applicable. The Department requests submittal of 

such plans in electronic form, when possible. 

A.16. Holcim shall limit clinker handling to 500,000 tons during any rolling 12-month period (ARM 

17.8.749). 

A.17. Holcim shall comply with all applicable provisions of 40 CFR 63, Subpart LLL – National 

Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing 

Industry. In 2000, the Trident facility was designated an area source for the purpose of 

determining the applicability of Portland Cement Maximum Achievable Control Technology (PC 

MACT). The compliance date for an owner or operator of an existing affected source subject to 

the provisions of Subpart LLL was June 14, 2002. Holcim shall comply with 40 CFR 63, Subpart 

LLL, which includes but is not limited to: 

a. Notification to the Department within 15 days of a significant change in raw material or 

fuel; 

b. Preparation of a written operations and maintenance plan for the kiln (40 CFR 63.6); and 

c. Development and implementation of a written startup, shutdown, and malfunction plan 

(40 CFR 63.6). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

6

A.18. On or before February 15 and August 15 of each year, Holcim shall submit to the Department the 

compliance monitoring reports required by Section V.D. These reports must contain all 

information required by Section V.D, as well as the information required by each individual 

emissions unit. For the reports due by February 15 of each year, Holcim may submit a single 

report, provided that it contains all the information required by Section V.B & V.D. Per ARM 

17.8.1207, 

any application form, report, or compliance certification submitted 

pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including 

semiannual monitoring reports), shall contain certification by a 

responsible official of truth, accuracy and completeness. This 

certification and any other certification required under ARM Title 17, 

Chapter 8, Subchapter 12, shall state that, “based on information and 

belief formed after reasonable inquiry, the statements and information 

in the document are true, accurate and complete.” 

A.19. By February 15 of each year, Holcim shall submit to the Department the compliance certification 

required by Section V.B. The annual certification required by Section V.B must include a 

statement of compliance based on the information available which identifies any observed, 

documented or otherwise known instance of noncompliance for each applicable requirement. Per 

ARM 17.8.1207, 

any application form, report, or compliance certification submitted 

pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including annual 

certifications), shall contain certification by a responsible official of 

truth, accuracy and completeness. This certification and any other 

certification required under ARM Title 17, Chapter 8, Subchapter 12, 

shall state that, “based on information and belief formed after 

reasonable inquiry, the statements and information in the document 

are true, accurate and complete.” 

B. Emitting Units – EU001 Fugitive Emissions: Disturbed Areas 

EU003 Quarry Blasting 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 

As required by 

the Department 

and Section 

III.A.1. 

Semiannual B.1, B.2, B.3, 

B.4, B.5, B.6, 

B.7 

Opacity 20% 

Visual Surveys Weekly Semiannual 

Conditions

B.1. Holcim shall not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.308(1)). 

Compliance Demonstration

B.2. Once per calendar week during daylight hours, Holcim shall visually survey emissions from the 

emitting units for any sources of excessive emissions. For the purpose of this survey, excessive 

emissions are considered to be any visible emissions, which meet or exceed 15% opacity. The 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

7

person conducting the survey does not have to be an EPA Method 9 certified observer. However, 

the individual must have been certified as a Method 9 observer within the previous 2 years of the 

visual survey being performed. If sources of visible emissions are identified, Holcim shall 

immediately conduct a Method 9 or take corrective action to contain or minimize the source of 

emissions. If corrective actions are taken, then Holcim shall immediately conduct a subsequent 

visual survey to monitor compliance. The person conducting the visual survey shall record the 

results of the survey in a log, including any corrective action taken. Conducting a visual survey 

does not relieve Holcim of a liability for a violation determined using Method 9. 

Method 9 tests must be performed in accordance with the Montana Source Test Protocol and 

Procedures Manual, except that prior notification of the test is not required. Each observation 

period must be a minimum of 6 minutes unless any one reading is 20% or greater, then the 

observation period must be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213). 

Recordkeeping

B.3. Holcim shall maintain a log to verify that the visual surveys were performed as specified in 

Section III.B.2. Each log entry must include the date, time, results of the survey, and observer's 

initials. Whether visual surveys or Method 9 tests are conducted, if any corrective action is 

required, the time, date, observer’s initials, and any preventative or corrective action taken must 

be recorded in the log (ARM 17.8.1212). 

B.4. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212). 

Reporting 

B.5. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

B.6. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

B.7. The semiannual monitoring report shall provide (ARM 18.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

and 

b. Certification that the visual surveys were performed and logged as required in Sections 

III.B.2 and III.B.3. 

c. Identify any instances of excessive fugitive emissions and provide a summary of any 

corrective action taken. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

8

C. Emitting Units – EU006 Raw Material Storage Piles 

EU007 Fugitive Emissions: Haul Roads 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 

As required by 

the Department 

and Section 

III.A.1. 

C.1, C.3, C.4, 

C.5, C.6, C.7, 

C.8 

Opacity 20% 

Visual Survey Weekly 

Semiannual 

C.2, C.3, C.4, 

C.7, C.8 Airborne Particulate Matter Reasonable Precaution 

Water and/or 

Chemical Dust 

Suppressants 

As Needed Semiannual 

Conditions

C.1. Holcim shall not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.308(1)). 

C.2. Holcim shall not cause or authorize the use of any street, road, or parking lot without taking 

reasonable precautions to control emissions of airborne particulate matter (ARM 17.8.308(2)). 

Compliance Demonstration 

C.3. Once per calendar week during daylight hours, Holcim shall visually survey emissions from the 

emitting units for any sources of excessive emissions. For the purpose of this survey, excessive 

emissions are considered to be any visible emissions, which meet or exceed 15% opacity. The 

person conducting the survey does not have to be an EPA Method 9 certified observer. However, 

the individual must have been certified as a Method 9 observer within the previous 2 years of the 

visual survey being performed. If sources of visible emissions are identified, Holcim shall 

immediately conduct a Method 9 or take corrective action to contain or minimize the source of 

emissions. If corrective actions are taken, then Holcim shall immediately conduct a subsequent 

visual survey to monitor compliance. The person conducting the visual survey shall record the 

results of the survey in a log, including any corrective action taken. Conducting a visual survey 

does not relieve Holcim of a liability for a violation determined using Method 9. 

Method 9 tests must be performed in accordance with the Montana Source Test Protocol and 

Procedures Manual, except that prior notification of the test is not required. Each observation 

period must be a minimum of 6 minutes unless any one reading is 20% or greater, then the 

observation period must be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213). 

Recordkeeping

C.4. Holcim shall maintain, on site, a log to verify that the visual surveys were performed as specified 

in Section III.C.3. Each log entry must include the date, time, results of the survey, and observer's 

initials. Whether visual surveys or Method 9 tests are conducted, if any corrective action is 

required, the time, date, observer’s initials, and any preventative or corrective action taken must be 

recorded in the log (ARM 17.8.1212). 

C.5. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

9

Reporting 

C.6. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

C.7. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

C.8. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting 

period; 

b. Certification that the visual surveys were performed and logged as required in Sections 

III.C.3 and III.C.4; and 

c. Identify any instances of excessive fugitive emissions and provide a summary of any 

corrective action taken. 

D. Emitting Units – EU008 Primary Crusher 

EU009 Crusher Screen 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

D.1, D.5, D.9, 

D.12, D.13, 

D.14 

Opacity 20% Method 9 Every 5 years Semiannual 

D.2, D.6, D.9, 

D.12, D.13, 

D.14 

Particulate Matter E= 4.10 * P0.67 or 

E= 55 * P0.11- 40 Method 5 Every 5 years Semiannual 

D.3, D.7, D.10, 

D.13, D.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse(s) 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

D.4, D.8, D.11, 

D.13, D.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

D.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibits an opacity of 20% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(2)). 

D.2. The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 * 

P0.67 for process weight rates up to 30 tons per hour and/or E = 55.0 * P0.11 – 40 for process weight 

rates in excess of 30 tons per hour, where E is the rate of emissions in pounds per hour and P is the 

process weight rate in tons per hour (ARM 17.8.310). 

D.3. Holcim shall operate and maintain baghouse(s) to control emissions from the emitting units (ARM 

17.8.749). 

D.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

10

Compliance Demonstration

D.5. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.D.1 by 

performing a Method 9 test once every 5 years or according to another testing/monitoring 

schedule as may be approved by the Department. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

D.6. Holcim shall monitor compliance with the particulate emission limitation contained in Section 

III.D.2 by performing a Method 5 test, or another test method approved by the Department, once 

every 5 years or according to another testing/monitoring schedule as may be approved by the 

Department. The test methods and procedures shall be conducted in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

D.7. Holcim shall monitor compliance with Section III.D.3 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

D.8. Holcim shall monitor compliance with Section III.D.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

D.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

D.10. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse(s) in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212). 

D.11. Holcim shall maintain the records required by Section III.D.8 on site and submit the information 

to the Department upon request (ARM 17.8.1212). 

Reporting 

D.12. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

D.13. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

D.14 The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse(s) were operated, inspected, and maintained as required by 

Sections III.D.3 and III.D.7; and 

c. Certification that the documentation required in Section III.D.8 was maintained. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

11

E. Emitting Units – EU005 Raw Materials Transfer and Conveying 

EU010 Raw Material Silo #1: Loading & Unloading 

EU011 Raw Material Silos #2 and #3: Loading & Unloading 

EU012 Raw Material Silos #4 and #5: Loading & Unloading 

 EU013 Raw Material Silos #6 and #7: Loading & Unloading 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

E.1, E.5, E.9, 

E.12, E.13, 

E.14 

Opacity 20% Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

E.2, E.6, E.9, 

E.12, E.13, 

E.14 

Particulate Matter E= 4.10 * P0.67 or 

E= 55 * P0.11- 40 Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

E.3, E.7, E10, 

E13, E.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse(s) 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

E.4, E.8, E.11, 

E.13, E.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

E.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibits an opacity of 20% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(2)). 

E.2. The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 * 

P0.67 for process weight rates up to 30 tons per hour and/or E = 55.0 * P0.11 – 40 for process weight 

rates in excess of 30 tons per hour, where E is the rate of emissions in pounds per hour and P is the 

process weight rate in tons per hour (ARM 17.8.310). 

E.3. Holcim shall operate and maintain baghouse(s) to control emissions from the emitting units (ARM 

17.8.749). 

E.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

Compliance Demonstration

E.5. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.E.1 by 

performing a Method 9 test as required by the Department and Section III.A.1. The test methods 

and procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

E.6. Holcim shall monitor compliance with the particulate emission limitation contained in Section 

III.E.2 by performing a Method 5 test, or another test method approved by the Department, as 

required by the Department and Section III.A.1. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

12

E.7. Holcim shall monitor compliance with Section III.E.3 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

E.8. Holcim shall monitor compliance with Section III.E.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

E.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

E.10. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse(s) in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212). 

E.11. Holcim shall maintain the records required by Section III.E.8 on site and submit the information 

to the Department upon request (ARM 17.8.1212). 

Reporting 

E.12. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

E.13. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements ARM 17.8.1212. 

E.14 The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse(s) were operated, inspected, and maintained as required by 

Sections III.E.3 and III.E.7; and 

c. Certification that the documentation required in Section III.E.8 was maintained. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

13

F. Emitting Units – EU014 Coal/Coke Unloading 

 EU015 Coal Transfer 

EU018 Coal/Coke Primary Crusher 

EU019 Coal Silo Loading & Unloading, and Secondary Crushing 

EU020 Coke Silo Loading & Unloading, and Secondary Crushing 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

F.1, F.6, F.9, 

F.12, F.13 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse(s) 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

F.2, F.4, F.8, 

F.11, F.12, 

F.13 

Opacity 20% Method 9 Every 5 years Semiannual 

F.2, F.5, F.8, 

F.11, F.12, 

F.13 

Particulate Matter 0.02 gr/dscf Method 5 Every 5 years Semiannual 

F.3, F.7, F.10, 

F.12, F.13 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

F.1. Holcim shall operate and maintain baghouse(s) to control emissions from the following coal and 

coke handling equipment (ARM 17.8.752): 

 a. Screw conveyor from the coal/coke crusher to the bucket elevator; 

b. “Raw” coke storage silo, 290-ton; 

d. Coke storage silo; 

e. Two diverter valves; 

f. Hammermill; 

g. Bucket elevator; 

h. Coal storage silo; 

i. Belt conveyor with weighing system at the base of the “raw” coke storage silo; 

j. Coke grinding mill; and 

k. “Fine” coke storage silo, 220-ton. 

F.2. Holcim shall not cause or authorize to be discharged into the atmosphere from the coal and coke 

handling baghouse(s): 

a. Particulate matter in excess of 0.02 grains per dry standard cubic foot (gr/dscf) (ARM 

17.8.752); and 

b. Visible emissions that exhibit an opacity of 20% or greater averaged over 6 consecutive 

minutes (ARM 17.8.304). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

14

F.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

Compliance Demonstration

F.4. Holcim shall monitor compliance with the 20% opacity limit in contained in Section III.F.2 by 

performing a Method 9 test once every 5 years or according to another testing/monitoring 

schedule as may be approved by the Department. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

F.5. Holcim shall monitor compliance with the particulate emission limitation in Section III.F.2 by 

performing a Method 5 test or another test method approved by the Department once every 5 

years or according to another testing/monitoring schedule as may be approved by the Department. 

The test methods and procedures shall be conducted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

F.6. Holcim shall monitor compliance with Section III.F.1 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

F.7. Holcim shall monitor compliance with Section III.F.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

F.8. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

F.9. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

F.10. Holcim shall maintain the records required by Section III.F.7 on site and submit the information 

to the Department upon request (ARM 17.8.1212). 

Reporting 

F.11. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

F.12. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

F.13. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

15

b. Certification that the baghouse(s) were operated, inspected, and maintained as required by 

Sections III.F.1 and III.F.6; and 

c. Certification that the documentation required in Section III.F.7 was maintained. 

G. Emission Unit – EU021 Kiln 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

G.1, G.13, 

G.25, G.27, 

G.31, G.33, 

G.34, G.35 

Opacity 20% Continuous 

Monitor Ongoing Semiannual 

G.2, G.14, 

G.26, G.33, 

G.34, G.35 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

ESP 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

G.3, G.15, 

G.27, G.31, 

G.33, G.34, 

G.35 

Particulate Matter 0.77 lb/ton of 

Clinker Method 5 Annually Semiannual 

G.4, G.16, 

G.27, G.31, 

G.33, G.34, 

G.35 

Sulfur Dioxide 

As Allowed in 

ARM 

17.8.322(6)(c) 

Method 6 Every 5 years Semiannual 

G.5, G.17, 

G.27, G.28, 

G.29, G.31, 

G.33, G.34, 

G.35 

Sulfur Dioxide 

124 lb/hr averaged 

over any rolling 30-

Day Period 

Continuous 

Monitor Ongoing Semiannual 

G.6, G.18, 

G.28, G.33, 

G.34, G.35 

Fuel Usage 

100% Natural Gas, 

100% Coal, 100% 

Coke, or Any 

Combination of 

These Fuels

Recordkeeping Monthly Semiannual 

G.7, G.19, 

G.28, G.33, 

G.34, G.35 

Clinker Operational Limit 425,000 tons/rolling 

12-Month Period Recordkeeping Monthly Semiannual 

Method 23 Every 30 

Months Semiannual G.8, G.20, 

G.27, G.28, 

G.31, G.32, 

G.33, G.34, 

G.35 

Dioxins/Furans 

0.20 or 0.40 ng per 

dscm Corrected to 

7% Oxygen—

depending on avg. 

temp of source tests 

Inspection of 

Combustion 

Components 

Annual Annual 

G9, G.21, 

G.29, G.32, 

G.33, G.34, 

G.35 

Operational Limit Inlet Temperatures 

to PMCD 

Continuous 

Monitor Ongoing Semiannual 

G.10, G.22, 

G.27, G28, 

G.29, G.31, 

G.33, G.34, 

G.35 

Nitrogen Oxide 

1,568 lb/hr averaged 

over any rolling 30-

Day Period 

Continuous 

Monitor Ongoing Semiannual 

G.11, G.23, 

G.29, G.33, 

G.34, G.35 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

G.12, G.24, 

G.30, G.34, 

G.35 

PM10 CAM Plan CAM Plan 

Appendix F 

CAM Plan 

Appendix F Ongoing Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

16

Conditions

G.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibits an opacity of 20% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(2)). 

G.2. Holcim shall operate and maintain an electrostatic precipitator (ESP) to control kiln emissions 

(ARM 17.8.749). 

G.3. Particulate emissions from the kiln are limited to 0.77 pound per ton (lb/ton) of clinker produced 

(ARM 17.8.749). 

G.4. Holcim shall comply with the sulfur in fuel rule (ARM 17.8.322(6)(c)). 

G.5. Holcim shall not cause or authorize to be discharged into the atmosphere from the kiln any gases 

that contain sulfur dioxide (SO2) in excess of 124 pounds per hour (lb/hr) averaged over any 

rolling 30-day period (ARM 17.8.749). 

G.6. In the cement kiln, Holcim is authorized to burn up to 100% natural gas, up to 100% coal, up to 

100% coke, or any combination of these fuels within the previously stated limits (ARM 17.8.749). 

G.7. Holcim shall limit kiln production to 425,000 tons of clinker during any rolling 12-month period 

(ARM 17.8.749). 

G.8. Holcim shall not cause to be discharged into the atmosphere from the kiln any gases that contain 

dioxins and furans in excess of: 

 a. 0.20 ng per dscm (8.7x10-11 gr/dscf)(TEQ) corrected to 7% oxygen; or 

 b. 0.40 ng per dscm (1.7x10-10 gr/dscf) (TEQ) corrected to 7% oxygen, when the average of the 

performance test run average temperatures at the inlet to the particulate matter control device 

is 204o

 C (400o F) or less (40 CFR 63.1343). 

 

G.9. Holcim shall operate the kiln such that the temperature of the gas at the inlet of the kiln particulate 

matter control device (PMCD) does not exceed the appropriate temperature limit specified in 40 

CFR 63.1344(b), as applicable (40 CFR 63.1344 and 40 CFR 63.6). 

G.10. Holcim shall not cause or authorize to be discharged into the atmosphere from the kiln any gases 

that contain NOx in excess of 1,568 lb/hr averaged over any rolling 30-day period (ARM 

17.8.749). 

G.11. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

G.12. Holcim shall provide a reasonable assurance of compliance with the emission limitations or 

standards for the operation of the emitting unit by following the Compliance Assurance 

Monitoring (CAM) plan contained in Appendix F of this permit (ARM 17.8.1504). 

Compliance Demonstration

G.13. Within 180 days after Permit #OP0982-01 becomes final, Holcim shall monitor compliance with 

Section III.G.1 by installing, calibrating, operating, and maintaining a Continuous Opacity 

Monitoring System (COMS) in accordance with Appendix B to 40 CFR 60, Performance 

Specification 1. In addition, Holcim shall inspect and audit the COMS annually, using neutral 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

17

density filters. Holcim shall conduct these audits using the applicable procedures and forms in 

the EPA Technical Assistance Document: Performance Audit Procedures for Opacity Monitors 

(EPA-450/4-92-010, April 1992) (ARM 17.8.1213). 

G.14. Holcim shall monitor compliance with Section III.G.2 by inspecting and maintaining the ESP in 

accordance with Appendix E of this permit (ARM 17.8.1213). 

G.15. Holcim shall monitor compliance with Section III.G.3 by annually conducting a Method 5 test or 

another test method approved by the Department. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

G.16. Holcim shall monitor compliance with Section III.G.4 by conducting a Method 6 test or another 

test method approved by the Department once every 5 years. The test methods and procedures 

shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual 

(ARM 17.8.106 and ARM 17.8.1213). 

G.17. Holcim shall monitor compliance with Section III.G.5 by documenting, by day, the lb/hr amount 

of SO2 emissions discharged into the atmosphere from the kiln. Total SO2 emissions shall be 

calculated from 7:00 a.m. to 7:00 a.m. on a daily basis and averaged over 30-day rolling time 

periods. In addition, Holcim shall monitor compliance with Section III.G.5 by calibrating, 

maintaining, and operating Continuous Emission Monitoring System (CEM) monitors. The 

CEMs must be operated while the kiln is operating and must measure the SO2 emissions, 

including the volumetric flow rate. These CEMs shall complete one cycle of operation 

(sampling, analyzing, and data recording) for each successive 15-minute period. The 

performance specification procedures conducted by Holcim must conform to 40 CFR part 60, 

Appendix B, Specification 2 and 6 and be approved by the Department. On-going quality 

assurance requirements must conform to 40 CFR Part 60, Appendix F (ARM 17.8.749 and ARM 

17.8.1213). 

G.18. Holcim shall maintain a log of the daily amount of coal, natural gas, and coke used in the kiln to 

demonstrate compliance with the limit in Section III.G.6. The log must be maintained on site and 

must be submitted to the Department upon request (ARM 17.8.1213). 

G.19. Holcim shall document, by month, the amount of clinker produced in the kiln. By the 25th day of 

each month, Holcim shall total the amount of clinker produced during the previous month. The 

monthly information will be used to verify compliance with the rolling 12-month limitation 

contained in Section III.G.7. The information for each of the previous months shall be submitted 

along with the annual emission inventory (ARM 17.8.749 and ARM 17.8.1213). 

G.20. Holcim shall monitor compliance with Section III.G.8 by conducting a Method 23 (40 CFR 60, 

Appendix A) performance test every 30 months. Holcim shall repeat the performance test for the 

kiln within 90 days of initiating any significant change in the feed or fuel from that used in the 

previous performance test (40 CFR 63.1349 and ARM 17.8.1213). In addition, Holcim shall 

conduct an inspection of the components of the combustion system of the kiln at least once per 

year (40 CFR 63.1350 and ARM 17.8.1213). 

G.21. Holcim shall monitor compliance with Section III.G.9 by calibrating, maintaining, and operating 

a monitor to record the temperature of the exhaust gases from the kiln for monitoring 

Dioxin/Furan emissions. The calibration of all thermocouples and other temperature sensors 

required by 40 CFR 63.1350 shall be verified at least once every 3 months (40 CFR 63.1350 and 

ARM 17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

18

G.22. Holcim shall monitor compliance with Section III.G.10 by documenting, by day, the lb/hr amount 

of NOx emissions discharged into the atmosphere from the kiln. Total NOx emissions shall be 

calculated from 7:00 a.m. to 7:00 a.m. on a daily basis and averaged over rolling 30-day time 

periods (ARM 17.8.749 and 17.8.1213). In addition, Holcim shall monitor compliance with 

Section III.G.10 by calibrating, maintaining, and operating CEM monitors. The CEMS must be 

operated while the kiln is operating and must measure the NOx emissions, including the 

volumetric flow rate. These CEMs shall complete one cycle of operation (sampling, analyzing, 

and data recording) for each successive 15-minute period. The performance specification 

procedures conducted by Holcim must conform to 40 CFR par 60, Appendix B, Specification 2 

and 6 and be approved by the Department. On-going quality assurance requirements must 

conform to 40 CFR Part 60, Appendix F (ARM 17.8.1213). 

G.23. Holcim shall monitor compliance with Section III.G.11 by documenting that conveyor covers, 

transfer point conveyors, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

G.24. Holcim shall monitor compliance with Section III.G.12 by monitoring emissions according to the 

CAM Plan contained in Appendix F of this permit (ARM 17.8.1503 and ARM 17.8.1213). 

Recordkeeping

G.25. Holcim shall maintain a file of all measurements from the COMS, and performance testing 

measurements; all COMS performance evaluations; all COMS or monitoring device calibration 

checks and audits; and adjustments and maintenance performed on these systems or devices, 

recorded in a permanent form suitable for inspection. The file shall be retained on site for at least 

5 years following the date of such measurements and reports. Holcim shall supply these records 

to the Department upon request (ARM 17.8.1212). 

G.26. Holcim shall maintain records of all inspection and maintenance activities performed on the ESP 

in accordance with Appendix E of this permit. All inspection and maintenance records must be 

maintained on site and must be submitted to the Department upon request (ARM 17.8.1212). 

G.27. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

G.28. Holcim shall maintain records as required by Sections III.G.17, III.G.18, III.G.19, III.G.20, 

III.G.22, and III.G.23 on site and submit the information to the Department upon request (ARM 

17.8.1212). 

G.29. Holcim shall maintain calibration records as required by Sections III.G.17, III.G.21, and III.G.22 

on site and submit the information to the Department upon request (ARM 17.8.1212). 

G.30. Holcim shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM 

Plan contained in Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64). 

Reporting 

G.31. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

19

G.32. Holcim shall submit a summary report semiannually, which contains the information specified in 

40 CFR 63.10(e)(3)(vi). In addition, the summary report shall include: 

 

 a. All exceedances of maximum control device inlet gas temperature limits; 

 b. All failures to calibrate thermocouples and other temperature sensors required by 40 CFR 

63.1350; 

 c. The results of any combustion system component inspections conducted within the reporting 

period; and 

 

 d. All failures to comply with any provision of the operation and maintenance plan (40 CFR 

63.1354). 

 

G.33. If any action taken by Holcim during a startup, shutdown, or malfunction is not consistent with 

the procedures specified in the affected source’s startup, shutdown, and malfunction plan, Holcim 

shall record the actions taken for that event and shall report such actions within 2 working days 

after commencing actions inconsistent with the plan, followed by a letter within 7 working days 

after the end of the event (40 CFR 63.6(e)(3)). 

G.34. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

G.35. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the ESP was operated, inspected, and maintained as required by Sections 

III.G.2 and III.G.14; 

c. Certification that the COMS was installed, calibrated, operated, and maintained as required 

by Section III.G.13. 

d. Certification that the tests required in Sections III.G.15, III.G.16, and III.G.20 were 

conducted; 

e. Certification that the documents required in Sections III.G.17, III.G.18, III.G.19, III.G.20, 

III.G.21, III.G.22, III.G.23, III.G.25, and III.G.26 were maintained; 

f. A summary of the amount of post-consumer recycled glass used in the kiln for the 

semiannual period; 

g. A summary of the amount of clinker produced for the semiannual period; 

h. Annual certification that the written report required in Section III.G.32 was submitted; and 

i. Certification that the CAM Plan contained in Appendix F of this permit was followed. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

20

Kiln Alternate Operating Scenario #1 

Firing Post-Consumer Recycled Container Glass 

The use of post-consumer recycled container glass as a raw material substitute in the cement kiln shall be 

considered an alternative-operating scenario pursuant to ARM 17.8.1215. When the revisions to ARM 

17.8.316, adopted by the Board of Environmental Review and effective on July 8, 1997, are incorporated 

into the State Implementation Plan (SIP), the applicability of the version of ARM 17.8.316 currently in 

the SIP will no longer be federally enforceable and this alternative operating scenario will no longer be 

applicable. 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

G.36, G.51, 

G.64, G.66, 

G.70, G.72, 

G.73, G.74 

Opacity 10% Continuous 

Monitor Ongoing Semiannual 

G.37, G.51, 

G.64, G.66, 

G.70, G.72, 

G.73, G.74 

Opacity 20% Continuous 

Monitor Ongoing Semiannual 

G.38, G.52, 

G.65, G.72, 

G.73, G.74 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

ESP 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

G.39, G.53, 

G.66, G.70, 

G.72, G.73, 

G.74 

Particulate Matter 

0.10 gr/dscf of Dry 

Flue Gas, Adjusted to 

12% CO2 & Calculated 

(no Auxiliary Fuel Had 

Been Used) 

Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

G.40, G.53, 

G.66, G.70, 

G.72, G.73, 

G.74 

Particulate Matter 0.77 lb/ton of Clinker Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

G.41, G.54, 

G.66, G.70, 

G.72, G.73, 

G.74 

Sulfur Dioxide As Allowed in ARM 

17.8.322(6)(c) Method 6 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

G.42, G.55, 

G.66, G.67, 

G.68, G.70, 

G.72, G.73, 

G.74 

Sulfur Dioxide 

124 lb/hr averaged 

over any rolling 30-

Day Period 

Continuous 

Monitor Ongoing Semiannual 

G.43, G.56, 

G.67, G.72, 

G.73, G.74 

Post-Consumer 

Recycled Container 

Glass Operational 

Limit 

800 tons/rolling 12-

Month Period Recordkeeping When Using 

Glass Semiannual 

G.44, G.57, 

G.67, G.72, 

G.73, G.74 

Clinker Operational 

Limit 

425,000 tons/rolling 

12-Month Period Recordkeeping Monthly Semiannual 

Method 23 

As Required by 

the Department 

and Section 

III.A.1 

G.45, G.58, Semiannual 

G.66, G.67, 

G.70, G71 G.72, 

G.73, G.74 

Dioxins/Furans 

0.20 or 0.40 ng per 

dscm Corrected to 7% 

Oxygen—depending 

on avg. temp of source 

tests 

Inspection of 

Combustion 

Components 

Annual Semiannual 

G.46, G.59, 

G.68, G.71, 

G.72, G.73, 

G.74 Operational Limit Inlet Temperatures to 

PMCD 

Continuous 

Monitor Ongoing Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

21

G.47, G.60, 

G.66, G.67, 

G.68, G.70, 

G.72, G.73, 

G.74 

Nitrogen Oxide 

1,568 lb/hr averaged 

over any rolling 30-

Day Period 

Continuous 

Monitor Ongoing Semiannual 

G.48, G.61, 

G.67, G.72, 

G.73, G.74 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Annual 

G.49, G.62, 

G.67, G.72, 

G.73, G.74 

Recordkeeping 

Log Operating 

Scenario When 

Switching from One 

Scenario to Another 

Reporting As Required by 

the Department Semiannual 

G.50, G.63, 

G.69, G.73, 

G.74 

PM10 CAM Plan CAM Plan Appendix F CAM Plan 

Appendix F Ongoing Semiannual 

Conditions

G.36. Holcim shall not cause or authorize to be discharged into the outdoor atmosphere, emissions that 

exhibit an opacity of 10% or greater averaged over 6 consecutive minutes (ARM 17.8.316). 

G.37. Holcim may not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(2)) (State Enforceable Only Until SIP Approval). 

G.38. Holcim shall operate and maintain an ESP to control kiln emissions (ARM 17.8.749) (State 

Enforceable Only Until SIP Approval). 

G.39. Holcim shall not cause or authorize to be discharged into the outdoor atmosphere, particulate 

matter in excess of 0.10 gr/dscf of dry flue gas, adjusted to 12% carbon dioxide and calculated as 

if no auxiliary fuel had been used (ARM 17.8.316). 

G.40. Particulate matter emissions from the kiln are limited to 0.77 lb/ton of clinker produced (ARM 

17.8.749). 

G.41. Holcim shall comply with the sulfur in fuel rule (ARM 17.8.322(6)(c)). 

G.42. Holcim shall not cause or authorize to be discharged into the atmosphere from the kiln any gases 

that contain SO2 in excess of 124 lb/hr averaged over any rolling 30-day period (ARM 17.8.749). 

G.43. Holcim is limited to 800 tons of post-consumer glass fired in the cement kiln during any rolling 

12-month period (ARM 17.8.752). 

G.44. Holcim shall limit kiln production to 425,000 tons of clinker during any rolling 12-month period 

(ARM 17.8.749). 

G.45. Holcim shall not cause to be discharged into the atmosphere from the kiln any gases that contain 

dioxins and furans in excess of: 

 

 a. 0.20 ng per dscm (8.7x10-11 gr per dscf)(TEQ) corrected to 7% oxygen; or 

 b. 0.40 ng per dscm (1.7x10-10 gr per dscf) (TEQ) corrected to 7% oxygen, when the average of 

the performance test run average temperatures at the inlet to the particulate matter control 

device is 204o

 C (400o F) or less (40 CFR 63.1343). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

22

G.46. Holcim shall operate the kiln such that the temperature of the gas at the inlet of the kiln PMCD 

does not exceed the appropriate temperature limit specified in 40 CFR 63.1344(b), as applicable 

(40 CFR 63.1344 and 40 CFR 63.6). 

G.47. Holcim shall not cause or authorize to be discharged into the atmosphere from the kiln any gases 

that contain NOx in excess of 1,568 lb/hr averaged over any rolling 30-day period (ARM 

17.8.749). 

G.48. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749) 

G.49. When making a change from one operating scenario to another, Holcim shall contemporaneously 

record, in a log at the permitted facility, a record of the operating scenario under which the 

facility is operating (ARM 17.8.1215). 

G.50. Holcim shall provide a reasonable assurance of compliance with the emission limitations or 

standards for the operation of the emitting unit by following the CAM plan contained in 

Appendix F of this permit (ARM 17.8.1504). 

Compliance Demonstration

G.51. Within 180 days after Permit #OP0982-01 becomes final, Holcim shall monitor compliance with 

Section III.G.36 and Section III.G.37 by installing, calibrating, operating, and maintaining a 

COMS in accordance with Appendix B to 40 CFR 60, Performance Specification 1. In addition, 

Holcim shall inspect and audit the COMS annually, using neutral density filters. Holcim shall 

conduct these audits using the applicable procedures and forms in the EPA Technical Assistance 

Document: Performance Audit Procedures for Opacity Monitors (EPA-450/4-92-010, April 1992) 

(ARM 17.8.1213). 

G.52. Holcim shall monitor compliance with Section III.G.38 by inspecting and maintaining the ESP in 

accordance with Appendix E of this permit (ARM 17.8.1213). 

G.53. Holcim shall monitor compliance with Section III.G.39 and III.G.40 by conducting a Method 5 

test or another test method approved by the Department, as required by the Department and 

Section III.A.1. The test methods and procedures shall be conducted in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

G.54. Holcim shall monitor compliance with Section III.G.41 by conducting, as required by the 

Department, a Method 6 test or another test method approved by the Department. The test 

methods and procedures shall be conducted in accordance with the Montana Source Test Protocol 

and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

G.55. Holcim shall monitor compliance with Section III.G.39 by documenting, by day, the lb/hr amount 

of SO2 emissions discharged into the atmosphere from the kiln. Total SO2 emissions shall be 

calculated from 7:00 a.m. to 7:00 a.m. on a daily basis and averaged over 30-day rolling time 

periods. In addition, Holcim shall monitor compliance with Section III.G.39 by calibrating, 

maintaining, and operating CEM monitors. The CEMs must be operated while the kiln is 

operating and must measure the SO2 emissions, including the volumetric flow rate. These CEMs 

shall complete one cycle of operation (sampling, analyzing, and data recording) for each 

successive 15-minute period. The performance specification procedures conducted by Holcim 

must conform to 40 CFR par 60, Appendix B, Specification 2 and 6 and be approved by the 

Department. On-going quality assurance requirements must conform to 40 CFR Part 60, 

Appendix F (ARM 17.8.749 and ARM 17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

23

G.56. Holcim shall document, by month, the amount of post-consumer recycled container glass used in 

the kiln. By the 25th day of each month, Holcim shall total the amount of recycled glass used for 

the previous month. The monthly information will be used to verify compliance with the rolling 

12-month limitation contained in Section III.G.43. The information for each of the previous 

months shall be submitted along with the annual emission inventory (ARM 17.8.749 and ARM 

17.8.1213). 

G.57. Holcim shall document, by month, the amount of clinker produced in the kiln. By the 25th day of 

each month, Holcim shall total the amount of clinker produced during the previous month. The 

monthly information will be used to verify compliance with the rolling 12-month limitation 

contained in Section III.G.44. The information for each of the previous months shall be 

submitted along with the annual emission inventory (ARM 17.8.749 and ARM 17.8.1213). 

G.58. Holcim shall monitor compliance with Section III.G.45 by conducting a Method 23 (40 CFR 60, 

Appendix A) performance test every 30 months. Holcim shall repeat the performance test for the 

kiln within 90 days of initiating any significant change in the feed or fuel from that used in the 

previous performance test (40 CFR 63.1349 and ARM 17.8.1213). In addition, Holcim shall 

conduct an inspection of the components of the combustion system of the kiln at least once per 

year (40 CFR 63.1350 and ARM 17.8.1213). 

G.59. Holcim shall monitor compliance with Section III.G.46 by calibrating, maintaining, and operating 

a monitor to record the temperature of the exhaust gases from the kiln for monitoring 

Dioxin/Furan emissions. The calibration of all thermocouples and other temperature sensors 

required by 40 CFR 63.1350 shall be verified at least once every 3 months (40 CFR 63.1350 and 

ARM 17.8.1213). 

G.60. Holcim shall monitor compliance with Section III.G.47 by documenting, by day, the lb/hr amount 

of NOx emissions discharged into the atmosphere from the kiln. Total NOx emissions shall be 

calculated from 7:00 a.m. to 7:00 a.m. on a daily basis and averaged over rolling 30-day time 

periods (ARM 17.8.749 and 17.8.1213). In addition, Holcim shall monitor compliance with 

Section III.G.47 by calibrating, maintaining, and operating CEM monitors. The CEMs must be 

operated while the kiln is operating and must measure the NOx emissions, including the 

volumetric flow rate. These CEMs shall complete one cycle of operation (sampling, analyzing, 

and data recording) for each successive 15-minute period. The performance specification 

procedures conducted by Holcim must conform to 40 CFR par 60, Appendix B, Specification 2 

and 6 and be approved by the Department. On-going quality assurance requirements must 

conform to 40 CFR Part 60, Appendix F (ARM 17.8.749 and ARM 17.8.1213). 

G.61. Holcim shall monitor compliance with Section III.G.48 by documenting that conveyor covers, 

transfer point conveyors, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

G.62. Holcim shall monitor compliance with Section III.G.49 by recording, in a log, the date and time 

when Holcim switches to or from using post-consumer recycled glass in the kiln within 24 hours 

of making a change from one operating scenario to another. The log shall be maintained as a 

permanent business record for at least 5 years following the activity, shall be available to the 

Department for inspection, and shall be submitted to the Department upon request (ARM 

17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

24

G.63. Holcim shall monitor compliance with Section III.G.50 by monitoring emissions according to the 

CAM Plan contained in Appendix F of this permit (ARM 17.8.1503 and ARM 17.8.1213). 

Recordkeeping

G.64. Holcim shall maintain a file of all measurements from the COMS, and performance testing 

measurements; all COMS performance evaluations; all COMS or monitoring device calibration 

checks and audits; and adjustments and maintenance performed on these systems or devices, 

recorded in a permanent form suitable for inspection. The file shall be retained on site for at least 

5 years following the date of such measurements and reports. Holcim shall supply these records 

to the Department upon request (ARM 17.8.1212). 

G.65. Holcim shall maintain records of all inspection and maintenance activities performed on the ESP 

in accordance with Appendix E of this permit. All inspection and maintenance records must be 

maintained on site and must be submitted to the Department upon request (ARM 17.8.1212). 

G.66. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

G.67. Holcim shall maintain records as required by Sections III.G.55, III.G.56, III.G.57, III.G.58, 

III.G.60, III.G.61, and III.G.62 on site and submit the information to the Department upon request 

(ARM 17.8.1212). 

G.68. Holcim shall maintain calibration records as required by Sections III.G.55, III.G.59, and III.G.60 

on site and submit the information to the Department upon request (ARM 17.8.1212). 

G.69. Holcim shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM 

Plan contained in Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64). 

Reporting 

G.70. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

G.71. Holcim shall submit a summary report semiannually, which contains the information specified in 

40 CFR 63.10(e)(3)(vi). In addition, the summary report shall include: 

 

 a. All exceedances of maximum control device inlet gas temperature limits; 

 b. All failures to calibrate thermocouples and other temperature sensors required by 40 CFR 

63.1350; 

 c. The results of any combustion system component inspections conducted within the reporting 

period; and 

 

 d. All failures to comply with any provision of the operation and maintenance plan (40 CFR 

63.1354). 

G.72. If any action taken by Holcim during a startup, shutdown, or malfunction is not consistent with 

the procedures specified in the affected source’s startup, shutdown, and malfunction plan, Holcim 

shall record the actions taken for that event and shall report such actions within 2 working days 

after commencing actions inconsistent with the plan, followed by a letter within 7 working days 

after the end of the event (40 CFR 63.6(e)(3)). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

25

G.73. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

G.74. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the ESP was operated, inspected, and maintained as required by Section 

III.G.38; 

c. Certification that the COMS was installed, calibrated, operated, and maintained as required 

by Section III.G.51. 

d. Certification that any tests required in Sections III.G.53, III.G.54, and III.G.58 were 

conducted; 

e. Certification that documents required in Sections III.G.55, III.G.56, III.G.57, III.G.58, 

III.G.59, III.G.60, III.G.61, III.G.64, and III.G.65 were maintained; 

f. A summary of the amount of post-consumer recycled glass used in the kiln for the 

semiannual period; 

g. A summary of the amount of clinker produced for the semiannual period; 

h. Annual Certification that the written report required in Section III.G.71 was submitted; and 

i. Certification that the CAM Plan contained in Appendix F of this permit was followed. 

H. Emitting Unit – EU022 Clinker Cooler 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

H.1, H.7, H.13, 

H.17, H.18, 

H.19 

Opacity 20% Method 9 Every 5 years Semiannual 

H.2, H.8, H.13, 

H.17, H.18, 

H.19 

Particulate Matter E = 55.0P0.11 – 40 Method 5 Every 5 years Semiannual 

H.3, H.9, H.14, 

H.18, H.19 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

H.4, H.10, 

H.15, H.18, 

H.19 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

H.5, H.11, 

H.15, H.18, 

H.19 

Operational Limit 

500,000 tons/rolling 

12-Month Period 

Clinker Handled 

Recordkeeping Monthly Semiannual 

H.6, H.12, 

H.16, H.18, 

H.19 

PM10 CAM Plan CAM Plan 

Appendix F 

CAM Plan 

Appendix F Ongoing Semiannual 

Conditions

H.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

26

H.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

H.3. Holcim shall operate and maintain a baghouse to control emissions from the emitting unit (ARM 

17.8.749). 

H.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

H.5. Holcim shall limit clinker handling to 500,000 tons during any rolling 12-month period (ARM 

17.8.749). 

H.6 Holcim shall provide a reasonable assurance of compliance with the emission limitations or 

standards for the operation of the emitting unit by following the CAM plan contained in Appendix 

F of this permit (ARM 17.8.1504). 

Compliance Demonstration

H.7. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.H.1 by 

performing a Method 9 test once every 5 years or according to another testing/monitoring 

schedule as may be approved by the Department. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

H.8. Holcim shall monitor compliance with the particulate emission limitation contained in Section 

III.H.2 by performing a Method 5 test or another test method approved by the Department once 

every 5 years or according to another testing/monitoring schedule as may be approved by the 

Department. The test methods and procedures shall be conducted in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

H.9. Holcim shall monitor compliance with Section III.H.3 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

H.10. Holcim shall monitor compliance with Section III.H.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

H.11. Holcim shall document, by month, the amount of clinker handled. By the 25th day of each month, 

Holcim shall total the amount of clinker handled during the previous month. The monthly 

information will be used to verify compliance with the rolling 12-month limitation contained in 

Section III.H.5. The information for each of the previous months shall be submitted along with 

the annual emission inventory (ARM 17.8.1213). 

H.12. Holcim shall monitor compliance with Section III.H.6 by monitoring emissions according to the 

CAM Plan contained in Appendix F of this permit (ARM 17.8.1503 and ARM 17.8.1213). 

Recordkeeping

H.13. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

27

H.14. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

H.15. Holcim shall maintain records as required by Sections III.H.10 and III.H.11 on site and submit 

the information to the Department upon request (ARM 17.8.1212). 

H.16. Holcim shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM 

Plan contained in Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64). 

Reporting 

H.17. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

H.18. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

H.19 The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated, inspected, and maintained as required by 

Sections III.H.3 and III.H.9; 

c. Certification that the documents required in Section III.H.10 were maintained; 

d. A summary of the amount of clinker handled during the semiannual period; and 

e. Certification that the CAM Plan contained in Appendix F of this permit was followed. 

I. Emitting Unit – EU023 Inside Clinker Transfer from Cooler 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

I.1, I.6, I.11, 

I.14, I.15, I.16 Opacity 20% Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

I.2, I.7, I.11, 

I.14, I.15, I.16 Particulate Matter E = 55.0P0.11 – 40 Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

I.3, I.8, I.12, 

I.15, I.16 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

I.4, I.9, I.13, 

I.15, I.16 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

I.5, I.10, I.13, 

I.15, I.16 Operational Limit 

500,000 tons/rolling 

12-Month Period 

Clinker Handled 

Recordkeeping Monthly Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

28

Conditions

I.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 

I.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

I.3. Holcim shall operate and maintain a baghouse to control emissions from the emitting unit (ARM 

17.8.749). 

I.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

I.5. Holcim shall limit clinker handling to 500,000 tons during any rolling 12-month period (ARM 

17.8.749). 

Compliance Demonstration

I.6. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.I.1 by 

performing a Method 9 test as required by the Department and Section III.A.1. The test methods 

and procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

I.7. Holcim shall monitor compliance with the particulate emission limitation contained in Section 

III.I.2 by performing a Method 5 test, or another test method approved by the Department, as 

required by the Department and Section III.A.1. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

I.8. Holcim shall monitor compliance with Section III.I.3 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

I.9. Holcim shall monitor compliance with Section III.I.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

I.10. Holcim shall document, by month, the amount of clinker handled. By the 25th day of each month, 

Holcim shall total the amount of clinker handled during the previous month. The monthly 

information will be used to verify compliance with the rolling 12-month limitation contained in 

Section III.I.5. The information for each of the previous months shall be submitted along with 

the annual emission inventory (ARM 17.8.1213). 

Recordkeeping

I.11. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

29

I.12. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

I.13. Holcim shall maintain records as required by Sections III.I.9 and III.I.10 on site and submit the 

information to the Department upon request (ARM 17.8.1212). 

Reporting 

I.14. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

I.15. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

I.16. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated, inspected, and maintained as required by 

Sections III.I.3 and III.I.8; 

c. Certification that the documents required in Section III.I.9 were maintained; and 

d. A summary of the amount of clinker handled during the semiannual period. 

J. Emitting Units – EU024 Clinker Storage Silos #1 and #2 & Interstice Bin Load/Unload 

EU027 Outside Clinker Bins Loading 

EU033 Clinker Transfer to #2 Finish Mill & #3 Finish Mill 

EU035 Clinker Transfer to #4 Finish Mill 

EU041 Gypsum Unloading and Transfer 

EU043 Outside Clinker Transfer to Reclaim Building 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

J.1, J.5, J.9, 

J.10, J.12, J.13, 

J.14 

Opacity 20% Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

J.2, J.6, J.9, 

J.10, J.12, J.13, 

J.14 

Particulate Matter E = 55.0P0.11 - 40 

Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

J.3, J.7, J.11, 

J.13, J.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

J.4, J.8, J.11, 

J.13, J.14 Operational Limit 

500,000 tons/rolling 

12-Month Period 

Clinker Handled 

Recordkeeping Monthly Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

30

Conditions

J.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 

J.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

J.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

J.4. Holcim shall limit clinker handling to 500,000 tons during any rolling 12-month period (ARM 

17.8.749). 

Compliance Demonstration

J.5. Holcim shall monitor compliance with Section III.J.1 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, as 

required by the Department and Section III.A.1, Holcim shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1213). 

J.6. Holcim shall monitor compliance with Section III.J.2 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, as 

required by the Department and Section III.A.1, Holcim shall perform a Method 5 test or another 

test method approved by the Department. The test methods and procedures shall be conducted in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1213). 

J.7. Holcim shall monitor compliance with Section III.J.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

J.8. Holcim shall document, by month, the amount of clinker handled. By the 25th day of each month, 

Holcim shall total the amount of clinker handled during the previous month. The monthly 

information will be used to verify compliance with the rolling 12-month limitation contained in 

Section III.J.4. The information for each of the previous months shall be submitted along with 

the annual emission inventory (ARM 17.8.1213). 

Recordkeeping

J.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

31

J.10. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse(s) in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212). 

J.11. Holcim shall maintain records as required by Sections III.J.7 and III.J.8 on site and submit the 

information to the Department upon request (ARM 17.8.1212). 

Reporting 

J.12. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

J.13. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

J.14. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated, inspected, and maintained as required by Section 

III.J.6; 

c. Certification that the documents required in Section III.J.7 were maintained; and 

d. A summary of clinker handled during the semiannual period. 

K. Emitting Unit – EU025 Cement Kiln Dust Silo Loading 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

K.1, K.5, K.9, 

K.12, K.13, 

K.14 

Opacity 20% Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

K.2, K.6, K.9, 

K12, K13, 

K.14 

Particulate Matter E = 55.0P0.11 - 40 Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

K.3, K.7, K.10, 

K.13, K.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

K.4, K.8, K.11, 

K.13, K.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

K.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

32

K.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

K.3. Holcim shall operate and maintain a baghouse to control emissions from the emitting unit (ARM 

17.8.749). 

K.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

Compliance Demonstration

K.5. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.K.1 by 

performing a Method 9 test as required by the Department and Section III.A.1. The test methods 

and procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

K.6. Holcim shall monitor compliance with the particulate emission limitation contained in Section 

III.K.2 by performing a Method 5 test, or another test method approved by the Department, as 

required by the Department and Section III.A.1. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

K.7. Holcim shall monitor compliance with Section III.K.3 by inspecting and maintaining the 

baghouse in accordance with Appendix E of this permit (ARM 17.8.1213). 

K.8. Holcim shall monitor compliance with Section III.K.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

K.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

K.10. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

K.11. Holcim shall maintain records as required by Section III.K.8 on site and submit the information to 

the Department upon request (ARM 17.8.1212). 

Reporting 

K.12. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

33

K.13. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

K.14. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated, inspected, and maintained as required by 

Sections III.K.3 and III.K.6; and 

c. Certification that the documents required in Section III.K.7 and III.K.8 were maintained. 

L. Emitting Units – EU026 Cement Kiln Dust Silo Unloading to Truck 

EU028-031 Outside Clinker Storage Silos #1-#4 

EU038 Dust Discharge Spout between Kiln and Precipitator 

EU040 Import Clinker Unloading and Transfer 

EU059 Post Consumer Recycled Glass Transfers 

EU060 Overflow Gypsum Transfer to Ground 

EU061 Overflow Gypsum Transfer to Reclaim Building 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

L.1, L.4, L.7, 

L.9, L.10, L.11 Opacity 20% Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

L.2, L.5, L.7, 

L.9, L.10, L.11 Particulate Matter E = 55.0P0.11 - 40 Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

L.3, L.6, L.8, 

L.10, L.11 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

L.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 

L.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

L.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

Compliance Demonstration

L.4. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.L.1 by 

performing a Method 9 test as required by the Department and Section III.A.1. The test methods 

and procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

34

L.5. Holcim shall monitor compliance with the particulate emission limitation contained in Section 

III.L.2 by performing a Method 5 test, or another test method approved by the Department, as 

required by the Department and Section III.A.1. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

L.6. Holcim shall monitor compliance with Section III.L.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

L.7. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

L.8. Holcim shall maintain records as required by Section III.L.6 on site and submit the information to 

the Department upon request (ARM 17.8.1212). 

Reporting 

L.9. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

L.10. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

L.11. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; and 

b. Certification that the document required in Section III.L.6 was maintained. 

M. Emission Unit – EU032 #2 Finish Mill 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

M.1, M.6, 

M.12, M.16, 

M.17, M.18 

Opacity 10% Method 9 Every 5 years Semiannual 

M1, M.7, 

M.12, M.16, 

M.17, M.18 

Particulate Matter 0.02 gr/dscf Method 5 Every 5 years Semiannual 

M.2, M.8, 

M.13, M.17, 

M.18 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

M.3, M.9, 

M.14, M.17, 

M.18 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

M.4, M.10, 

M.14, M.17, 

M.18 

Operational Limit 

245,280 tons/rolling 

12-Month Period 

Clinker Handled 

Recordkeeping Monthly Semiannual 

M.5, M.11, 

M.15, M.17, 

M.18 

PM10 CAM Plan CAM Plan 

Appendix F 

CAM Plan 

Appendix F Ongoing Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

35

Conditions

M.1. Holcim shall not cause or authorize to be discharged into the atmosphere, from the Finish Mill #2 

baghouse: 

a. Particulate matter in excess of 0.02 gr/dscf (ARM 17.8.752); and 

b. Visible emissions that exhibit an opacity of 10% or greater averaged over 6 consecutive 

minutes, as required by 40 CFR Part 60, Subpart F (ARM 17.8.340). 

M.2. Holcim shall operate and maintain baghouse(s) to control emissions from the Finish Mill #2 

sources listed below (ARM 17.8.752): 

a. A replacement air slide; 

b. The clinker/gypsum feed belt via a booster fan; 

c. The Finish Mill #2; 

d. The bucket elevator; and 

e. The product separator. 

M.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

M.4. Holcim shall limit clinker handling to 245,280 tons during any rolling 12-month period (ARM 

17.8.749). 

M.5. Holcim shall provide a reasonable assurance of compliance with the emission limitations or 

standards for the operation of the emitting unit by following the CAM plan contained in Appendix 

F of this permit (ARM 17.8.1504). 

Compliance Demonstration

M.6. Holcim shall monitor compliance with the 10% opacity limit contained in Section III.M.1.b by 

performing a Method 9 test once every 5 years or according to another testing/monitoring 

schedule as may be approved by the Department. The test methods and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

M.7. Holcim shall monitor compliance with the particulate emission limitation in Section III.M.1.a by 

performing a Method 5 test or another test method approved by the Department once every 5 

years or according to another testing/monitoring schedule as may be approved by the Department. 

The test methods and procedures shall be conducted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106, ARM 17.8.340, and ARM 17.8.1213). 

M.8. Holcim shall monitor compliance with Section III.M.2 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

M.9. Holcim shall monitor compliance with Section III.M.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

36

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

M.10. Holcim shall document, by month, the amount of clinker handled. By the 25th day of each month, 

Holcim shall total the amount of clinker handled during the previous month. The monthly 

information will be used to verify compliance with the rolling 12-month limitation contained in 

Section III.M.4. The information for each of the previous months shall be submitted along with 

the annual emission inventory (ARM 17.8.1213). 

M.11. Holcim shall monitor compliance with Section III.M.5 by monitoring emissions according to the 

CAM Plan contained in Appendix F of this permit (ARM 17.8.1503 and ARM 17.8.1213). 

Recordkeeping 

M.12. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

M.13. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

M.14. Holcim shall maintain the records required by Sections III.M.9 and III.M.10 on site and submit 

the information to the Department upon request (ARM 17.8.1212). 

M.15. Holcim shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM 

Plan contained in Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64). 

Reporting 

M.16. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

M.17. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

M.18. The semiannual monitoring reporting shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the documents required in Section III.M.9 were maintained; 

c. A summary of the amount of clinker handled in the semiannual period; and 

d. Certification that the CAM Plan contained in Appendix F of this permit was followed. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

37

N. Emitting Unit – EU034 #3 Finish Mill 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 Every 5 years Semiannual 

N.1, N.6, N.11, 

N.12, N.15, 

N.16, N.17 

Opacity 40% Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Method 5 Every 5 years Semiannual 

N.2, N.7, N.11, 

N.12, N.15, 

N.16, N.17 

Particulate Matter E = 55.0P0.11 – 40 Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

N.3, N.8, N.13, 

N.16, N.17 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

N.4, N.9, N.13, 

N.16, N.17 Operational Limit 

245,280 tons/rolling 

12-Month Period 

Clinker Handled 

Recordkeeping Monthly Semiannual 

N.5, N.10, 

N.14, N.16, 

N.17 

PM10 CAM Plan CAM Plan 

Appendix F 

CAM Plan 

Appendix F Ongoing Semiannual 

Conditions

N.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 40% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(1)). 

N.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

N.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

N.4. Holcim shall limit clinker handling to 245,280 tons during any rolling 12-month period (ARM 

17.8.749). 

N.5. Holcim shall provide a reasonable assurance of compliance with the emission limitations or 

standards for the operation of the emitting unit by following the CAM plan contained in Appendix 

F of this permit (ARM 17.8.1504). 

Compliance Demonstration

N.6. Holcim shall monitor compliance with Section III.N.1 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, once 

every 5 years or according to another testing/monitoring schedule as may be approved by the 

Department, Holcim shall perform Method 9 test in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and 17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

38

N.7. Holcim shall monitor compliance with Section III.N.2 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, once 

every 5 years or according to another testing/monitoring schedule as may be approved by the 

Department, Holcim shall perform a Method 5 test or another Department approved test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

17.8.1213). 

N.8. Holcim shall monitor compliance with Section III.N.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

N.9. Holcim shall document, by month, the amount of clinker handled. By the 25th day of each month, 

Holcim shall total the amount of clinker handled during the previous month. The monthly 

information will be used to verify compliance with the rolling 12-month limitation contained in 

Section III.N.4. The information for each of the previous months shall be submitted along with 

the annual emission inventory (ARM 17.8.1213). 

N.10. Holcim shall monitor compliance with Section III.N.5 by monitoring emissions according to the 

CAM Plan contained in Appendix F of this permit (ARM 17.8.1503 and ARM 17.8.1213). 

Recordkeeping

N.11. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

N.12. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

N.13. Holcim shall maintain records as required by Sections III.N.8 and III.N.9 on site and submit the 

information to the Department upon request (ARM 17.8.1212). 

N.14. Holcim shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM 

Plan contained in Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64). 

Reporting 

N.15. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

N.16. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

N.17. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

39

b. Certification that the baghouse was operated, inspected, and maintained as required by 

Sections III.N.6 and III.N.7; 

c. Certification that the documents required in Section III.N.8 were maintained; 

d. A summary of the amount of clinker handled in the semiannual period; and 

e. Certification that the CAM Plan contained in Appendix F of this permit was followed. 

O. Emitting Units – EU036 #4 Finish Mill Product Separator 

EU037 #4 Finish Mill 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

O.1, O.7, O.13, 

O.17, O.18, 

O.19 

Opacity 10% Method 9 Every 5 years Semiannual 

O.2, O.8, O.13, 

O.17, O.18, 

O.19 

Particulate Matter E = 55.0P0.11 – 40 Method 5 Every 5 years Semiannual 

O.3, O.9, O.14, 

O.18, O.19 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

O.4, O.10, 

O.15, O.18, 

O.19 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

O.5, O.11, 

O.15, O.18, 

O.19 

Operational Limit 

395,000 tons/rolling 

12-Month Period 

Clinker Handled 

Recordkeeping Monthly Semiannual 

O.6, O.12, 

O.16, O.18, 

O.19 

PM10 CAM Plan CAM Plan 

Appendix F 

CAM Plan 

Appendix F Ongoing Semiannual 

Conditions

O.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

the Finish Mill #4 visible emissions that exhibit an opacity of 10% or greater averaged over 6 

consecutive minutes, as required by 40 CFR Part 60, Subpart F (ARM 17.8.340). 

O.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

O.3. Holcim shall operate and maintain baghouse to control emissions from the emitting units (ARM 

17.8.749). 

O.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

O.5. Holcim shall limit clinker handling to 395,000 tons during any rolling 12-month period (ARM 

17.8.749). 

O.6. Holcim shall provide a reasonable assurance of compliance with the emission limitations or 

standards for the operation of the #4 Finish Mill (EU037) by following the CAM plan contained in 

Appendix F of this permit (ARM 17.8.1504). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

40

Compliance Demonstration

O.7. Holcim shall monitor compliance with the 10% opacity limit in Section III.O.1 by performing a 

Method 9 test once every 5 years or according to another testing/monitoring schedule as may be 

approved by the Department. The test methods and procedures shall be conducted in accordance 

with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 17.8.1213). 

O.8. Holcim shall monitor compliance with the particulate emission limitation in Section III.O.2 by 

performing a Method 5 test or another test method approved by the Department once every 5 

years or according to another testing/monitoring schedule as may be approved by the Department. 

The test methods and procedures shall be conducted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106, 17.8.340, and ARM 17.8.1213). 

O.9. Holcim shall monitor compliance with Section III.O.3 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

O.10. Holcim shall monitor compliance with Section III.O.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

O.11. Holcim shall document, by month, the amount of clinker handled. By the 25th day of each month, 

Holcim shall total the amount of clinker handled during the previous month. The monthly 

information will be used to verify compliance with the rolling 12-month limitation contained in 

Section III.O.5. The information for each of the previous months shall be submitted along with 

the annual emission inventory (ARM 17.8.1213). 

O.12. Holcim shall monitor compliance with Section III.O.6 by monitoring emissions from the #4 

Finish Mill (EU037) according to the CAM Plan contained in Appendix F of this permit (ARM 

17.8.1503 and ARM 17.8.1213). 

Recordkeeping

O.13. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

O.14. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

O.15. Holcim shall maintain records as required by Sections III.O.10 and III.O.11 on site and submit 

the information to the Department upon request (ARM 17.8.1212). 

O.16. Holcim shall maintain CAM applicable records in accordance with 40 CFR Part 64 and the CAM 

Plan contained in Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64). 

Reporting 

O.17. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

41

O.18. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

O.19. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated, inspected, and maintained as required by 

Sections III.O.3 and III.O.9; 

c. Certification that the documents required in Section III.O.10 were maintained; 

d. A summary of the amount of clinker handled during the semiannual period; and 

e. Certification that the CAM Plan contained in Appendix F of this permit was followed. 

P. Emitting Units – EU044 Cement Loaded/Unloaded at Silos #1-#7, #10, #11, & #13 

EU045 Cement Loaded/Unloaded at Silos #8, #9, & #12 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

P.1, P.4, P.7, 

P.8, P.10, P.11, 

P.12 

Opacity 40% 

Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

P.2, P.5, P.7, 

P.8, P.10, P.11, 

P.12 

Particulate Matter E = 55.0P0.11 – 40 

Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

P.3, P.6, P.9, 

P.11, P.12 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

P.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 40% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 

P.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

P.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

42

Compliance Demonstration

P.4. Holcim shall monitor compliance with Section III.P.1 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, as 

required by the Department and Section III.A.1, Holcim shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1213). 

P.5. Holcim shall monitor compliance with Section III.P.2 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, as 

required by the Department and Section III.A.1, Holcim shall perform a Method 5 test or another 

test method approved by the Department in accordance with the Montana Source Test Protocol 

and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

P.6. Holcim shall monitor compliance with Section III.P.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

P.7. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

P.8. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse(s) in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212). 

P.9. Holcim shall maintain records as required by Section III.P.6 on site and submit the information to 

the Department upon request (ARM 17.8.1212). 

Reporting 

P.10. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

P.11. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

P.12. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse(s) were operated, inspected, and maintained as required by 

Section III.P.5; and 

c. Certification that the document required in Section III.P.6 was maintained. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

43

Q. Emitting Units – EU046 Cement Transferred From Silos #1 - #13 to Bulk Load Silos #14 - #25 

EU0047 Cement Loaded/Unloaded at Silos #14 - #25 

EU049 Bulk Cement Truck Transfer/Loadout #1 

EU050 Bulk Cement Truck Transfer/Loadout #2 

EU051 Bulk Cement Railcar Transfer/Loadouts #1 and #2 

EU062CKD Recycle Dust Scoops 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 Every 5 years Semiannual 

Q.1, Q.4, Q.7, 

Q.8, Q.10, 

Q.11, Q.12 

Opacity 20% Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Method 5 Every 5 years Semiannual 

Q.2, Q.5, Q.7, 

Q.8, Q.10, 

Q.11, Q.12 

Particulate Matter E = 55.0P0.11 – 40 Operation and 

Maintenance of 

a Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Q.3, Q.6, Q.9, 

Q.11, Q.12 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

Q.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)). 

Q.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

Q.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749). 

Compliance Demonstration

Q.4. Holcim shall monitor compliance with Section III.Q.1 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, once 

every 5 years or according to another testing/monitoring schedule as may be approved by the 

Department, Holcim shall perform a Method 9 test in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

Q.5. Holcim shall monitor compliance with Section III.Q.2 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, once 

every 5 years or according to another testing/monitoring schedule as may be approved by the 

Department, Holcim shall perform a Method 5 test or another test method approved by the 

Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

44

Q.6. Holcim shall monitor compliance with Section III.Q.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

Q.7. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

Q.8. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

Q.9. Holcim shall maintain records as required by Section III.Q.6 on site and submit the information to 

the Department upon request (ARM 17.8.1212). 

Reporting 

Q.10. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

Q.11. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

Q.12. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated and maintained as required by Section III.Q.5; 

and 

c. Certification that the document required in Section III.Q.6 was maintained. 

R. Emitting Unit – EU048 Cement Loaded/Unloaded at Silos #26 - #30 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

R.1, R.5, R.9, 

R.12, R.13, 

R.14 

Opacity 10% Method 9 Every 5 years Semiannual 

R.2, R.6, R.9, 

R.12, R.13, 

R.14 

Particulate Matter E = 55.0P0.11 - 40 Method 5 Every 5 years Semiannual 

R.3, R.7, R.10, 

R.13, R.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

R.4, R.8, R.11, 

R.13, R.14 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

45

Conditions

R.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source, visible emissions that exhibit an opacity of 10% or greater averaged over 6 

consecutive minutes, as required by 40 CFR Part 60, Subpart F (ARM 17.8.340). 

R.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

R.3. Holcim shall operate and maintain baghouse to control emissions from the emitting units (ARM 

17.8.749). 

R.4. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749) 

Compliance Demonstration

R.5. Holcim shall monitor compliance with the 10% opacity limit in Section III.R.1 by performing a 

Method 9 test once every 5 years or according to another testing/monitoring schedule as may be 

approved by the Department. The test methods and procedures shall be conducted in accordance 

with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 17.8.1213). 

R.6. Holcim shall monitor compliance with the particulate emission limitation in Section III.R.2 by 

performing a Method 5 test, or another test method approved by the Department, once every 5 

years or according to another testing/monitoring schedule as may be approved by the Department. 

The test methods and procedures shall be conducted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106, 17.8.340, and ARM 17.8.1213). 

R.7. Holcim shall monitor compliance with Section III.R.3 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

R.8. Holcim shall monitor compliance with Section III.R.4 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

R.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

R.10. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

R.11. Holcim shall maintain records as required by Section III.R.8 on site and submit the information to 

the Department upon request (ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

46

Reporting 

R.12. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

R.13. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

R.14 The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was operated and maintained as required by Section III.R.7; 

and 

c. Certification that the document required in Section III.R.8 was maintained. 

S. Emission Unit – EU053 CKD and Flyash Transfers to/from Pozzolan Silo 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

S.1, S.5, S.10, 

S.13, S.14, 

S.15 

Opacity 20% Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

S.1, S.6, S.10, 

S13, S14, S.15 Particulate Matter 0.02 gr/dscf Method 5 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

S.2, S.7, S.11, 

S.12, S.14, 

S.15 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Baghouse 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

S.3, S.8, S12, 

S14, S.15 Enclosures 

Installation, Use, 

and Maintenance of 

Enclosures 

Use and 

Maintenance 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

S.4, S.9, S.12, 

S.14, S.15 Operational Limit 

50,000 tons/rolling 

12-Month Period 

Pozzolan Material 

Handled 

Recordkeeping Monthly Semiannual 

Conditions

S.1. Holcim shall not cause or authorize to be discharged into the atmosphere, from the pozzolan 

material silo baghouse: 

a. Particulate matter in excess of 0.02 gr/dscf (ARM 17.8.752); and 

b. Visible emissions that exhibit an opacity of 20% or greater averaged over 6 consecutive 

minutes (ARM 17.8.752). 

S.2. Holcim shall operate and maintain baghouse(s) to control emissions from the pozzolan material 

silo (ARM 17.8.752). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

47

S.3. Holcim shall use and maintain enclosures around the pozzolan material system components listed 

below (ARM 17.8.752): 

a. Rotary feeder; 

b. Weighbelt conveyor; and 

c. Screw line (conveyor). 

S.4. Holcim shall not use, in any rolling 12-month period, greater than 50,000 tons of pozzolan 

material in the pozzolan material system (ARM 17.8.752). 

Compliance Demonstration

S.5. Holcim shall monitor compliance with the 20% opacity limit contained in Section III.S.1 by 

performing a Method 9 test as required by the Department and Section III.A.1. The test methods 

and procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and 17.8.1213). 

S.6. Holcim shall monitor compliance with the particulate emission limitation in Section III.S.1 by 

performing a Method 5 test or another test method approved by the Department, as required by 

the Department and Section III.A.1. The test methods and procedures shall be conducted in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106, 

17.8.340, and ARM 17.8.1213). 

S.7. Holcim shall monitor compliance with Section III.S.2 by inspecting and maintaining the 

baghouse(s) in accordance with Appendix E of this permit (ARM 17.8.1213). 

S.8. Holcim shall monitor compliance with Section III.S.3 by documenting that enclosures 

surrounding process equipment were maintained and in place during operation of process 

equipment. The records shall include all repair and maintenance activity to all structural 

enclosures. The records must include, but are not limited to, the date, time, and action(s) taken 

for repair and maintenance (ARM 17.8.1213). 

S.9. Holcim shall document, by month, the amount of pozzolan material used in the pozzolan material 

system. By the 25th day of each month, Holcim shall total the amount of pozzolan material used 

in the pozzolan material system during the previous month. The monthly information will be 

used to verify compliance with the rolling 12-month limitation contained in Section III.S.4. The 

information for each of the previous months shall be submitted along with the annual emission 

inventory (ARM 17.8.1213). 

Recordkeeping 

S.10. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site, 

and shall be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

S.11. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

S.12. Holcim shall maintain records as required by Section III.S.7, III.S.8 and III.S.9 on site and submit 

the information to the Department upon request (ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

48

Reporting 

S.13. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

S.14. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

S.15. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the results of any compliance test conducted during the last reporting period; 

b. Certification that the baghouse was inspected and maintained as required by Section III.S.7; 

c. Certification that the documents required in Section III.S.8 were maintained; and 

d. A summary of the amount of pozzolan material used in the pozzolan material system for the 

semiannual period. 

T. Emitting Unit – EU054 Landfilled Cement Kiln Dust (CKD) Handling 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

T.1, T.4, T.7, 

T.10, T.11 Opacity 20% Water Spray As Needed Semiannual 

T.2, T.5, T.8, 

T.10, T.11 Airborne Particulate Matter Reasonable Precautions 

Water and/or 

Chemical Dust 

Suppressants 

As Needed Semiannual 

T.3, T.6, T.9, 

T.10, T.11 Operational Limit 

85,000 Tons of 

Landfilled 

CKD/Rolling 12-

Month Period 

Recordkeeping Monthly Semiannual 

Conditions

T.1. Holcim shall not cause or authorize emissions to be discharged into the outdoor atmosphere from 

any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.304(2)), 

T.2. Holcim shall not cause or authorize the use of any street, road, or parking lot without taking 

reasonable precautions to control emissions of airborne particulate matter (ARM 17.8.308(2)). 

T.3. Holcim shall not handle more than 85,000 tons of landfilled CKD in any rolling 12-month period 

(ARM 17.8.752). 

Compliance Demonstration

T.4. Holcim shall monitor compliance with Section III.T.1 by using water spray, as necessary, when 

handling landfilled CKD (ARM 17.8.752 and 17.8.1213). 

T.5. Holcim shall monitor compliance with Section III.T.2 by treating all unpaved portions of the haul 

roads, access roads, parking lots, or the general plant area with water and/or chemical dust 

suppressant, as necessary (ARM 17.8.749). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

49

T.6. Holcim shall document, by month, the amount CKD reclaimed from the landfill. By the 25th day 

of each month, Holcim shall total the amount of CKD reclaimed from the landfill during the 

previous month. The monthly information will be used to verify compliance with the rolling 12-

month limitation contained in Section III.T.3. The information for each of the previous months 

shall be submitted along with the annual emission inventory (ARM 17.8.1213). 

Recordkeeping 

T.7. Holcim shall maintain records that water spray was used, as necessary, when handling landfilled 

CKD. The records must include, but are not limited to, the date and time that water spray was 

used (ARM 17.8.1213). 

T.8. Holcim shall maintain records that all unpaved portions of the haul roads, access roads, parking 

lots, or the general plant area were treated with water and/or chemical dust suppressant, as 

necessary. The records must include, but are not limited to, the date and time of the application 

of the water and/or chemical dust suppressant (ARM 17.8.1213). 

T.9. Holcim shall maintain records as required by Sections III.T.6 on site and submit the information 

to the Department upon request (ARM 17.8.1212). 

Reporting 

T.10. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

T.11. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of the water spray use when handling landfilled CKD for the semiannual period; 

b. A summary of the water and/or chemical dust suppressant applications for the semiannual 

period; and 

c. A summary of the amount of CKD reclaimed from the landfill for the semiannual period. 

U. Emitting Unit – EU055 Material Handling System for Feeding the Finish Mills 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

U.1, U.4, U.7, 

U.8, U.10, 

U.11, U.12 

Opacity 20% 

Operation and 

Maintenance of 

a Baghouse(s) 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Method 5 

As Required by 

the Department 

and Section 

U.2, U.5, U.8, III.A.1 

U.11, U.12 Particulate Matter E = 55.0P0.11 - 40 

Operation and 

Maintenance of 

a Baghouse(s) 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

U.3, U.6, U.9, 

U.11, U.12 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

50

Conditions

U.1. Holcim shall not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.308). 

U.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0P0.11 – 40, where E is the rate of emission in pounds per hour and P is the process weight rate 

in tons per hour (ARM 17.8.310). 

U.3. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749) 

Compliance Demonstration

U.4. Holcim shall monitor compliance with Section III.U.1 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, as 

required by the Department and Section III.A.1, Holcim shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

17.8.1213). 

U.5. Holcim shall monitor compliance with Section III.U.2 by operating, and inspecting and 

maintaining the baghouse(s) in accordance with Appendix E of this permit. In addition, as 

required by the Department and Section III.A.1, Holcim shall perform a Method 5 test, or another 

test method approved by the Department, in accordance with the Montana Source Test Protocol 

and Procedures Manual (ARM 17.8.106 and 17.8.1213). 

U.6. Holcim shall monitor compliance with Section III.U.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

U.7. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

U.8. Holcim shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212). 

U.9. Holcim shall maintain records as required by Section III.U.6 and submit the information to the 

Department upon request (ARM 17.8.1212). 

Reporting 

U.10. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

51

U.11. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

U.12. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of any compliance tests conducted during the last reporting period; 

b. Certification that the document required in Sections III.U.6 and III.U.8 were maintained; and 

V. Emitting Unit – EU042 Outside Clinker Transfer to Pile 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

V.1, V.3, V.5, 

V.7, V.8, V.9 Opacity 20% Method 9 

As Required by 

the Department 

and Section 

III.A.1 

Semiannual 

V.2, V.4, V.6, 

V.7, V.8, V.9 

Emission Control 

Equipment 

Operation and 

Maintenance of 

Emission Control 

Equipment 

Covers and 

Enclosures 

Whenever 

Process 

Equipment is 

Operating 

Semiannual 

Conditions

V.1. Holcim shall not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.308). 

V.2. When process equipment is operating, Holcim shall use and maintain, as they were intended, 

conveyor covers, transfer point covers, or structural enclosures surrounding process equipment 

(ARM 17.8.749) 

Compliance Demonstration

V.3. Holcim shall monitor compliance with Section III.V.1 by conducting a Method 9 test, as required 

by the Department and Section III.A.1, in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and 17.8.1213). 

V.4. Holcim shall monitor compliance with Section III.V.3 by documenting that conveyor covers, 

transfer point covers, or structural enclosures surrounding process equipment were maintained 

and in place during operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural enclosures. The 

records must include, but are not limited to, the date, time, and action(s) taken for repair and 

maintenance (ARM 17.8.1213). 

Recordkeeping

V.5. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, shall be maintained on site 

and must be submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212). 

V.6. Holcim shall maintain records as required by Section III.V.4 on site and submit the information to 

the Department upon request (ARM 17.8.1212). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

52

Reporting 

V.7. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106). 

V.8. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

V.9. The semiannual monitoring report shall provide (ARM 17.8.1212): 

a. A summary of any compliance tests conducted during the last reporting period; and 

b. Certification that the document required in Section III.V.4 was maintained. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

53

SECTION IV. NON-APPLICABLE REQUIREMENTS 

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable 

to the facility or to a specific emissions unit at the time of the permit issuance are listed below (ARM 

17.8.1214). The following list does not preclude the need to comply with any new requirements that may 

become applicable during the permit term. 

A. Facility-Wide 

The following table contains non-applicable requirements which are administrated by the Air Resources 

Management Bureau of the Department of Environmental Quality. 

Rule Citation Reason 

ARM 17.8.320 

ARM17.8.324 

These rules are not applicable because the facility does 

not have the specific emissions unit cited in the rules. 

ARM 17.8.321 

ARM 17.8.331 

ARM 17.8.332 

ARM 17.8.333 

ARM 17.8.334 

ARM 17.8.323 

ARM 17.8.610 

40 CFR 57 

These rules are not applicable because the facility is not 

listed in the source category cited in the rules. 

40 CFR 55 

40 CFR 59 

40 CFR 60 Subpart B 

40 CFR 60 Subparts C, Ca, Cb, Cc, Cd, and Ce 

40 CFR 60 Subparts D, Da, Db, Dc 

40CFR 60 Subpart E, Ea, Eb, and Ec 

40 CFR 60 Subparts G, H, I, J 

40 CFR 60 Subparts K, Ka, Kb 

40 CFR 60 Subparts L-X 

40 CFR 60 Subpart Z 

40 CFR 60 Subparts AA-EE 

40 CFR 60 Subparts GG-HH 

40 CFR 60 Subparts KK-NN 

40 CFR 60 Subparts PP-XX 

40 CFR 60 Subparts AAA-BBB 

40 CFR 60 Subparts DDD 

40 CFR 60 Subparts FFF-LLL 

40 CFR 60 Subparts NNN-WWW 

40 CFR 60 Subparts AAAA-DDDD 

40 CFR 60 Subpart HHHH 

40 CFR 60 Appendix G 

40 CFR 60 Appendix I 

40 CFR 61 Subparts B-F 

40 CFR 61 Subparts H-L 

40 CFR 61 Subparts N-R 

40 CFR 61 Subpart T 

40 CFR 61 Subparts V-W 

40 CFR 61 Subpart Y 

40 CFR 61 Subpart BB 

40 CFR 61 Subpart FF 

40 CFR 61 Appendices A-E 

40 CFR 63 Subparts F-J 

40 CFR 63 Subparts L,O 

40 CFR 63 Subpart Q-U 

40 CFR 63 Subparts W-Y 

40 CFR 63 Subparts AA-EE 

40 CFR 63 Subparts GG-MM 

40 CFR 63 Subparts OO-YY 

40 CFR 63 Subparts CCC-EEE 

These requirements are not applicable because the facility 

is not an affected source as defined in these regulations. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

54

40 CFR 63 Subparts GGG-KKK 

40 CFR 63 Subparts MMM-RRR 

40 CFR 63 Subparts TTT-XXX 

40 CFR 63 Subpart AAAA 

40 CFR 63 Subparts CCCC-KKKK 

40 CFR 63 Subparts MMMM-ZZZZ 

40 CFR 63 Subparts AAAAA-TTTTT 

40 CFR 68 

40 CFR 79-80 

40 CFR 85-99 

40 CFR 72 

40 CFR 73 

40CFR 74 

40 CFR 75 

40 CFR 76 

40 CFR 77 

40 CFR 78 

These requirements are not applicable because the facility 

is not an affected source as defined by the acid rain 

regulations. 

40 CFR 82 Subpart A 

40 CFR 82 Subparts C-D 

40 CFR 82 Subparts G-H 

These rules refers to processes, equipment and/or 

activities that are not used at the facility 

B. Emission Units 

The permit application identified applicable requirements: non-applicable requirements for individual or 

specific emission units were not listed. The Department has listed all non-applicable requirements in 

Section IV.A, these requirements relate to each specific unit, as well as facility wide. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

55

SECTION V. GENERAL PERMIT CONDITIONS 

A. Compliance Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)-(c)&(e), §1206(6)(c)&(b)

1. The permittee must comply with all conditions of the permit. Any noncompliance with the 

terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and may 

result in enforcement action, permit modification, revocation and reissuance, or termination, or 

denial of a permit renewal application under ARM Title 17, Chapter 8, Subchapter 12. 

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, or 

termination, or of a notification of planned changes or anticipated noncompliance does not stay 

any permit condition. 

3. 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. If appropriate, this factor may be considered as a mitigating factor in 

assessing a penalty for noncompliance with an applicable requirement if the source 

demonstrates that both the health, safety or environmental impacts of halting or reducing 

operations would be more serious than the impacts of continuing operations, and that such 

health, safety or environmental impacts were unforeseeable and could not have otherwise been 

avoided. 

4. The permittee shall furnish to the Department, within a reasonable time set by the Department 

(not to be less than 15 days), any information that the Department may request in writing to 

determine whether cause exists for modifying, revoking and reissuing, or terminating the 

permit, or to determine compliance with the permit. Upon request, the permittee shall also 

furnish to the Department copies of those records that are required to be kept pursuant to the 

terms of the permit. This subsection does not impair or otherwise limit the right of the 

permittee to assert the confidentiality of the information requested by the Department, as 

provided in 75-2-105, MCA. 

5. Any schedule of compliance for applicable requirements with which the source is not in 

compliance with at the time of permit issuance shall be supplemental to, and shall not sanction 

noncompliance with, the applicable requirements on which it was based. 

6. For applicable requirements that will become effective during the permit term, the source shall 

meet such requirements on a timely basis unless a more detailed plan or schedule is required by 

the applicable requirement or the Department. 

B. Certification Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)-(d)

1. Any application form, report, or compliance certification submitted pursuant to ARM Title 17, 

Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, accuracy 

and completeness. This certification and any other certification required under ARM Title 17, 

Chapter 8, Subchapter 12, shall state that, based on information and belief formed after 

reasonable inquiry, the statements and information in the document are true, accurate and 

complete. 

2. Compliance certifications shall be submitted by February 15 of each year, or more frequently if 

otherwise specified in an applicable requirement or elsewhere in the permit. Each certification 

must include the required information for the previous calendar year (i.e., January 1 – 

December 31). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

56

3. Compliance certifications shall include the following: 

a. The identification of each term or condition of the permit that is the basis of the 

certification; 

b. The identification of the method(s) or other means used by the owner or operator for 

determining the status of compliance with each term and condition during the certification 

period, consistent with ARM 17.8.1212; 

c. The status of compliance with each term and condition for the period covered by the 

certification, including whether compliance during the period was continuous or 

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as 

described above); and 

d. Such other facts as the Department may require to determine the compliance status of the 

source. 

4. All compliance certifications must be submitted to the Environmental Protection Agency, as 

well as to the Department, at the addresses listed in the Notification Addresses Appendix of this 

permit. 

C. Permit Shield 

ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)-(4)

1. The applicable requirements and non-federally enforceable requirements are included and 

specifically identified in this permit and the permit includes a precise summary of the 

requirements not applicable to the source. Compliance with the conditions of the permit shall 

be deemed compliance with any applicable requirements and any non-federally enforceable 

requirements as of the date of permit issuance. 

2. The permit shield described in 1 above shall remain in effect during the appeal of any permit 

action (renewal, revision, reopening, or revocation and reissuance) to the Board of 

Environmental Review (Board), until such time as the Board renders its final decision. 

3. Nothing in this permit alters or affects the following: 

a. The provisions of Sec. 7603 of the FCAA, including the authority of the administrator 

under that section; 

b. The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

c. The applicable requirements of the Acid Rain Program, consistent with Sec. 7651g(a) of 

the FCAA; 

d. The ability of the administrator to obtain information from a source pursuant to Sec. 7414 

of the FCAA; 

e. The ability of the Department to obtain information from a source pursuant to the Montana 

Clean Air Act, Title 75, Chapter 2, MCA; 

f. The emergency powers of the Department under the Montana Clean Air Act, Title 75, 

Chapter 2, MCA; and 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

57

g. The ability of the Department to establish or revise requirements for the use of Reasonably 

Available Control Technology (RACT) as defined in ARM Title 17, Chapter 8. However, 

if the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, 

Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s 

existing permit, shall remain in effect until such time as the Board has rendered its final 

decision. 

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action 

for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 

17.8.106, Source Testing Protocol. 

5. Pursuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in 

these rules shall preclude the use, including the exclusive use, of any credible evidence or 

information relevant to whether a source would have been in compliance. However, when 

compliance or noncompliance is demonstrated by a test or procedure provided by permit or 

other applicable requirements, the source shall then be presumed to be in compliance or 

noncompliance unless that presumption is overcome by other relevant credible evidence. 

6. The permit shield will not extend to minor permit modifications or changes not requiring a 

permit revision (see Sections I & J). 

7. The permit shield will extend to significant permit modifications and transfer or assignment of 

ownership (see Sections K & N). 

D. Monitoring, Recordkeeping, and Reporting Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring 

records that include the following information: 

a. The date, place as defined in the permit, and time of sampling or measurement; 

b. The date(s) analyses were performed; 

c. The company or entity that performed the analyses; 

d. The analytical techniques or methods used; 

e. The results of such analyses; and 

f. The operating conditions at the time of sampling or measurement. 

2. The permittee shall retain records of all required monitoring data and support information for a 

period of at least 5 years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records and all 

original strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by the permit. All monitoring data, support information, and required reports 

and summaries may be maintained in computerized form at the plant site if the information is 

made available to Department personnel upon request, which may be for either hard copies or 

computerized format. Strip-charts must be maintained in their original form at the plant site 

and shall be made available to Department personnel upon request. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

58

3. The permittee shall submit to the Department, at the addresses located in the Notification 

Addresses Appendix of this permit, reports of any required monitoring by February 15 and 

August 15 of each year, or more frequently if otherwise specified in an applicable requirement 

or elsewhere in the permit. The monitoring report submitted on February 15 of each year must 

include the required monitoring information for the period of July 1 through December 31 of 

the previous year. The monitoring report submitted on August 15 of each year must include the 

required monitoring information for the period of January 1 through June 30 of the current year. 

All instances of deviations from the permit requirements must be clearly identified in such 

reports. All required reports must be certified by a responsible official, consistent with ARM 

17.8.1207. 

E. Prompt Deviation Reporting 

ARM 17.8, Subchapter 12, Operating Permit Program §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those attributable 

to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective 

actions or preventive measures taken. To be considered prompt, deviations shall be reported as part 

of the routine reporting requirements under ARM 17.8.1212(3)(b) and, if applicable, in accordance 

with the malfunction reporting requirements under ARM 17.8.110, unless otherwise specified in an 

applicable requirement. 

F. Emergency Provisions 

ARM 17.8, Subchapter 12, Operating Permit Program §1201(13) and §1214(5), (6)&(8)

1. 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 causes the source to exceed a technologybased emission limitation under this permit due to the unavoidable increases in emissions 

attributable to the emergency. An emergency shall not include noncompliance to the extent 

caused by improperly designed equipment, lack of reasonable preventive maintenance, careless 

or improper operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with a 

technology-based emission limitation if the permittee demonstrates through properly signed, 

contemporaneous logs, or other relevant evidence, that: 

a. An emergency occurred and the permittee can identify the cause(s) of the emergency; 

b. The permitted facility was at the time being properly operated; 

c. 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 the 

permit; and 

d. The permittee submitted notice of the emergency to the Department within 2 working days 

of the time when emission limitations were exceeded due to the emergency. This notice 

fulfills the requirements of ARM 17.8.1212(3)(c). This notice must contain a description 

of the emergency, any steps taken to mitigate emissions, and corrective actions taken. 

3. These emergency provisions are in addition to any emergency, malfunction or upset provision 

contained in any applicable requirement. 
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59

G. Inspection and Entry 

ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the 

permittee shall allow the Department, the administrator, or an authorized representative 

(including an authorized contractor acting as a representative of the Department or the 

administrator) to perform the following: 

a. Enter the premises where a source required to obtain a permit is located or emissionsrelated activity is conducted, or where records must be kept under the conditions of the 

permit; 

b. Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of the permit; 

c. Inspect at reasonable times any facilities, emission units, equipment (including monitoring 

and air pollution control equipment), practices, or operations regulated or required under 

the permit; and 

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder, sample or 

monitor, at reasonable times, any substances or parameters at any location for the purpose 

of assuring compliance with the permit or applicable requirements. 

2. The permittee shall inform the inspector of all workplace safety rules or requirements at the 

time of inspection. This section shall not limit in any manner the Department’s statutory right 

of entry and inspection as provided for in 75-2-403, MCA. 

H. Fee Payment 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air 

Quality Permit Application, Operation, and Open Burning Fees §505(3)-(5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Chapter 8, 

Subchapter 5. 

2. Annually, the Department shall provide the permittee with written notice of the amount of the 

fee and the basis for the fee assessment. The air quality operation fee is due 30 days after 

receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any 

portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days after 

receipt of the notice. Any remaining fee, which may be due after the completion of an appeal, 

is due immediately upon issuance of the Board’s decision or upon completion of any judicial 

review of the Board’s decision. 

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 

90 days of the due date of the fee, the Department may impose an additional assessment of 15% 

of the fee (or any required portion of an appealed fee) or $100, whichever is greater, plus 

interest on the fee (or any required portion of an appealed fee), computed at the interest rate 

established under 15-31-510(3), MCA. 

I. Minor Permit Modifications 

ARM 17.8, Subchapter 12, Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the 

permit application that require revision, updating, supplementation, or deletion, and may 

reference any required information that has been previously submitted. 
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60

2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed 

pursuant to ARM 17.8.1226. 

J. Changes Not Requiring Permit Revision 

ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)-(3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided 

the following conditions are met: 

a. The proposed changes do not require the permittee to obtain an air quality preconstruction 

permit under ARM Title 17, Chapter 8, Subchapter 7; 

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in 

ARM Title 17, Chapter 8, Subchapters 8, 9, or 10; 

c. The emissions resulting from the proposed changes do not exceed the emissions allowable 

under this permit, whether expressed as a rate of emissions or in total emissions; 

d. The proposed changes do not alter permit terms that are necessary to enforce applicable 

emission limitations on emission units covered by the permit; and 

e. The facility provides the administrator and the Department with written notification at least 

7 days prior to making the proposed changes. 

2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to 

their respective copies of this permit. 

3. Pursuant to the conditions above, the permittee is authorized to make Section 502(b)(10) 

changes, as defined in ARM 17.8.1201(30), without a permit revision. For each such change, 

the written notification required under 1.e above shall include a description of the change 

within the source, 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. 

4. The permittee may make a change not specifically addressed or prohibited by the permit terms 

and conditions without requiring a permit revision, provided the following conditions are met: 

a. Each proposed change does not weaken the enforceability of any existing permit 

conditions; 

b. The Department has not objected to such change; 

c. Each proposed change meets all applicable requirements and does not violate any existing 

permit term or condition; and 

d. The permittee provides contemporaneous written notice to the Department and the 

administrator of each change that is above the level for insignificant emission units as 

defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each 

such change, including the date of the change, any change in emissions, pollutants emitted, 

and any applicable requirement that would apply as a result of the change. 

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to 

ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases 

and decreases in emissions pursuant to ARM 17.8.1224(4). 
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61

K. Significant Permit Modifications 

ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 below must be used for any application requesting a 

significant modification of this permit. Significant modifications include the following: 

a. Any permit modification that does not qualify as either a minor modification or as an 

administrative permit amendment; 

b. Every significant change in existing permit monitoring terms or conditions; 

c. Every relaxation of permit reporting or recordkeeping terms or conditions that limit the 

Department’s ability to determine compliance with any applicable rule, consistent with the 

requirements of the rule; or 

d. Any other change determined by the Department to be significant. 

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including 

those for applications, public participation, and review by affected states and the administrator, 

as they apply to permit issuance and renewal, except that an application for a significant permit 

modification need only address in detail those portions of the permit application that require 

revision, updating, supplementation or deletion. 

3. The permit shield provided for in ARM 17.8.1214 shall extend to significant modifications. 

L. Reopening for Cause 

ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

This permit may be reopened and revised under the following circumstances: 

1. Additional applicable requirements under the FCAA become applicable to the facility when the 

permit has a remaining term of 3 or more years. Reopening and revision of the permit shall be 

completed not later than 18 months after promulgation of the applicable requirement. No 

reopening is required under ARM 17.8.1228(1)(a) if the effective date of the applicable 

requirement is later than the date on which the permit is due to expire, unless the original 

permit or any of its terms or conditions have been extended pursuant to ARM 17.8.1220(12) or 

17.8.1221(2); 

2. Additional requirements (including excess emission requirements) become applicable to an 

affected source under the Acid Rain Program. Upon approval by the administrator, excess 

emission offset plans shall be deemed incorporated into the permit; 

3. The Department or the administrator determines that the permit contains a material mistake or 

that inaccurate statements were made in establishing the emission standards or other terms or 

conditions of the permit; or 

4. The administrator or the Department determines that the permit must be revised or revoked and 

reissued to ensure compliance with the applicable requirements. 

M. Permit Expiration and Renewal 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of 5 years. 
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62

2. Renewal of this permit is subject to the same procedural requirements that apply to permit 

issuance, including those for application, content, public participation, and affected state and 

administrator review. 

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and 

administratively complete renewal application has been submitted consistent with ARM 

17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been 

submitted, all terms and conditions of the permit, including the application shield, remain in 

effect after the permit expires until the permit renewal has been issued or denied. 

4. For renewal, the permittee shall submit a complete air quality operating permit application to 

the Department not later than 6 months prior to the expiration of this permit, unless otherwise 

specified. If necessary to ensure that the terms of the existing permit will not lapse before 

renewal, the Department may specify, in writing to the permittee, a longer time period for 

submission of the renewal application. Such written notification must be provided at least 1 

year before the renewal application due date established in the existing permit. 

N. Severability Clause 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of 

an initial permit under this subchapter shall not impair in any manner the underlying 

applicability of all applicable requirements, and such requirements continue to apply as if a 

final permit decision had not been reached by the Department. 

2. If any provision of a permit is found to be invalid, all valid parts that are severable from the 

invalid part remain in effect. If a provision of a permit is invalid in one or more of its 

applications, the provision remains in effect in all valid applications that are severable from the 

invalid applications. 

O. Transfer or Assignment of Ownership 

ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, 

the applicant must include in its request to the Department a written agreement containing a 

specific date for the transfer of permit responsibility, coverage and liability between the current 

and new permittee. 

2. The permit shield provided for in ARM17.8.1214 shall not extend to administrative permit 

amendments. 

P. Emissions Trading, Marketable Permits, Economic Incentives 

ARM 17.8, Subchapter 12, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification 

procedures may be used for permit modifications involving the use of economic incentives, 

marketable permits, emissions trading, and other similar approaches, to the extent that such minor 

permit modification procedures are explicitly provided for in the Montana State Implementation Plan 

or in applicable requirements promulgated by the administrator. 

Q. No Property Rights Conveyed 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privilege. 
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63

R. Testing Requirements 

ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105. 

S. Source Testing Protocol 

ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106. 

T. Malfunctions 

ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110. 

U. Circumvention 

ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111. 

V. Motor Vehicles 

ARM 17.8, Subchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325. 

W. Annual Emissions Inventory 

ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 

(STATE ONLY)

The permittee shall supply the Department with annual production and other information for all 

emission units necessary to calculate actual or estimated actual amount of air pollutants emitted 

during each calendar year. Information shall be gathered on a calendar-year basis and submitted to 

the Department by the date required in the emission inventory request, unless otherwise specified in 

this permit. Information shall be in the units required by the Department. 

X. Open Burning 

ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606. 

Y. Montana Air Quality Permits 

ARM 17.8, Subchapter 7, Permit, Construction and Operation of Air Contaminant Sources §745 and 

764 (ARM 17.8.745(1) and 764(1)(b) are STATE ENFORCEABLE ONLY until approval by the 

EPA as part of the SIP) 

1. Except as specified, no person shall construct, install, alter or use any air contaminant source or 

stack associated with any source without first obtaining a permit from the Department or Board. 

A permit is not required for those sources or stacks as specified by ARM 17.8.744(1)(a)-(k). 

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748, and 764. 
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64

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of 

operation at a facility holding an air quality preconstruction permit issued under Chapter 8 that 

does not increase the facility’s potential to emit by more than 15 tons per year of any pollutant, 

except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP): 

a. Any construction or changed condition that would violate any condition in the facility’s 

existing air quality preconstruction permit or any applicable rule contained in Chapter 8 is 

prohibited, except as provided in ARM 17.8.745(2); 

b. Any construction or changed conditions of operation that would qualify as a major 

modification under Subchapters 8, 9 or 10 of Chapter 8; 

c. Any construction or changed condition of operation that would affect the plume rise or 

dispersion characteristic of emissions that would cause or contribute to a violation of an 

ambient air quality standard or ambient air increment as defined in ARM 17.8.804; 

d. Any construction or improvement project with a potential to emit more than 15 tons per 

year may not be artificially split into smaller projects to avoid air quality preconstruction 

permitting; or 

e. Emission reductions obtained through offsetting within a facility are not included when 

determining the potential emission increase from construction or changed conditions of 

operation, unless such reductions are made federally enforceable. 

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the 

Department if the change would include a change in control equipment, stack height, stack 

diameter, stack gas temperature, source location or fuel specifications, or would result in an 

increase in source capacity above its permitted operation or the addition of a new emission unit. 

The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de 

minimis change, or as soon as reasonably practicable in the event of an unanticipated 

circumstance causing the de minimis change, and must include the information requested in 

ARM 17.8.745(1) (STATE ENFORCEABLE ONLY until approval by the EPA as part of the 

SIP). 

Z. National Emission Standard for Asbestos 

40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abatement activities except in accordance with 40 CFR 

61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos). 

AA. Asbestos 

ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq., and ARM 17.74.401, et seq. (State only) 

BB. Stratospheric Ozone Protection – Servicing of Motor Vehicle Air Conditioners 

40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and this service involves ozone-depleting 

substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the 

applicable requirements as specified in 40 CFR 82, Subpart B. 
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65

CC. Stratospheric Ozone Protection – Recycling and Emission Reductions 

40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 82, 

Subpart F, except as provided for MVACs in Subpart B: 

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 technical certification program pursuant to §82.161; 

4. Persons disposing of small appliances, MVACs and MVAC-like (as defined at §82.152) 

appliances must comply with recordkeeping requirements pursuant to §82.166; 

5. Persons owning commercial or industrial process refrigeration equipment must comply with the 

leak repair requirements pursuant to §82.156; and 

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. 

DD. Emergency Episode Plan 

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of Montana 

Air Quality Control Implementation Plan. 

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, shall 

submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP) that details 

how the source will curtail emissions during an air pollutant emergency episode. The industrial 

EEAP shall be in accordance with the Department’s EEAP and shall be submitted according to a 

timetable developed by the Department, following Priority I reclassification. 

EE. Definitions 

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this 

permit, shall have the meaning assigned to them in the referenced regulations. 
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66

APPENDICES 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

A-1

Appendix A INSIGNIFICANT EMISSION UNITS 

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to 

assist Holcim, the permitting authority, inspectors, and the public. 

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emissions unit 

located within a source that: (i) has a potential to emit less than 5 tons per year of any regulated pollutant; 

(ii) has a potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less than 500 

pounds per year of hazardous air pollutants listed pursuant to Sec. 7412 (b) of the FCAA; and (iv) is not 

regulated by an applicable requirement, other than a generally applicable requirement that applies to all 

emission units subject to Subchapter 12. 

List of Insignificant Activities:

The following table of insignificant sources and/or activities were provided by Holcim. Because there are 

no requirements to update such a list, the emission units and/or activities may change from those specified 

in the table. 

Emissions Unit ID Description 

EU002 Quarry Drilling 

EU004 Limestone, Sand and Shale Removal 

EU016 Coal Storage Piles 

EU017 Coke Storage Piles 

EU039 Transfer of Reclaimed Clinker to Ground 

EU052 Fuel Tanks 

EU056 Space Heating 

EU057 Storage Pile for Finish Mill Material Handling System 

EU058 Post Consumer Recycled Glass Piles 

EU063 Emergency Generators 
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Appendix B DEFINITIONS and ABBREVIATIONS 

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq. 

"Administrative permit amendment" means an air quality operating permit revision that: 

(a) Corrects typographical errors; 

(b) Identifies a change in the name, address or phone number of any person identified in the air 

quality operating permit, or identifies a similar minor administrative change at the source; 

(c) Requires more frequent monitoring or reporting by Holcim; 

(d) Requires changes in monitoring or reporting requirements that the Department deems to be 

no less stringent than current monitoring or reporting requirements; 

(e) Allows for a change in ownership or operational control of a source if the Department has 

determined that no other change in the air quality operating permit is necessary, consistent 

with ARM 17.8.1225; or 

(f) Incorporates any other type of change which the Department has determined to be similar to 

those revisions set forth in (a)-(e), above. 

"Applicable requirement" means all of the following as they apply to emission units in a source 

requiring an air quality operating permit (including requirements that have been promulgated or approved 

by the Department or the administrator through rule making at the time of issuance of the air quality 

operating permit, but have future-effective compliance dates, provided that such requirements apply to 

sources covered under the operating permit): 

(a) Any standard, rule, or other requirement, including any requirement contained in a consent 

decree or judicial or administrative order entered into or issued by the Department, that is 

contained in the Montana state implementation plan approved or promulgated by the 

administrator through rule making under Title I of the FCAA; 

(b) Any federally enforceable term, condition or other requirement of any air quality 

preconstruction permit issued by the Department under Subchapters 7, 8, 9 and 10 of this 

chapter, or pursuant to regulations approved or promulgated through rule making under Title 

I of the FCAA, including parts C and D; 

(c) Any standard or other requirement under Sec. 7411 of the FCAA, including Sec. 7411(d); 

(d) Any standard or other requirement under Sec. 7412 of the FCAA, including any requirement 

concerning accident prevention under Sec. 7412(r)(7), but excluding the contents of any risk 

management plan required under Sec. 7412(r); 

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or 

regulations promulgated thereunder; 

(f) Any requirements established pursuant to Sec. 7661c(b) or Sec. 7414(a)(3) of the FCAA; 

(g) Any standard or other requirement governing solid waste incineration, under Sec. 7429 of the 

FCAA; 
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(h) Any standard or other requirement for consumer and commercial products, under Sec. 

7511b(e) of the FCAA; 

(i) Any standard or other requirement for tank vessels, under Sec. 7511b(f) of the FCAA; 

(j) Any standard or other requirement of the regulations promulgated to protect stratospheric 

ozone under Title VI of the FCAA, unless the administrator determines that such 

requirements need not be contained in an air quality operating permit; 

(k) Any national ambient air quality standard or increment or visibility requirement under part C 

of Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to 

Sec. 7661c(e) of the FCAA; or 

(l) Any federally enforceable term or condition of any air quality open burning permit issued by 

the Department under Subchapter 6. 

"Department" means the Montana Department of Environmental Quality. 

“Excess Emissions” means any visible emissions from a stack or source, viewed during the visual 

surveys, that meets or exceeds 15% opacity (or 30% opacity if associated with a 40% opacity limit) 

during normal operating conditions. 

"Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit 

any regulated air pollutant or any pollutant listed under Sec. 7412(b) of the FCAA. This term is not 

meant to alter or affect the definition of the term "unit" for purposes of Title IV of the FCAA. 

"FCAA" means the Federal Clean Air Act, as amended. 

"Federally enforceable" means all limitations and conditions which are enforceable by the 

administrator, including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements 

within the Montana state implementation plan, and any permit requirement established pursuant to 40 

CFR 52.21 or under regulations approved pursuant to 40 CFR Part 51, Subpart I, including operating 

permits issued under an EPA approved program that is incorporated into the Montana state 

implementation plan and expressly requires adherence to any permit issued under such program. 

"Fugitive emissions" means those emissions which could not reasonably pass through a stack, chimney, 

vent, or other functionally equivalent opening. 

"General air quality operating permit" or "general permit" means an air quality operating permit that 

meets the requirements of ARM 17.8.1222, covers multiple sources in a source category, and is issued in 

lieu of individual permits being issued to each source. 

"Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to Sec. 

112(b) of the FCAA. 

"Non-federally enforceable requirement" means the following as they apply to emission units in a 

source requiring an air quality operating permit: 

(a) Any standard, rule, or other requirement, including any requirement contained in a consent 

decree, or judicial or administrative order entered into or issued by the Department, that is not 

contained in the Montana state implementation plan approved or promulgated by the 

administrator through rule making under Title I of the FCAA; 
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(b) Any term, condition or other requirement contained in any air quality preconstruction permit 

issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter that is not federally 

enforceable; 

(c) Does not include any Montana ambient air quality standard contained in Subchapter 2 of this 

chapter. 

"Permittee" means the owner or operator of any source subject to the permitting requirements of this 

subchapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has 

submitted a timely and complete permit application for issuance, renewal, amendment, or modification 

pursuant to this subchapter. 

"Regulated air pollutant" means the following: 

(a) Nitrogen oxides or any volatile organic compounds; 

(b) Any pollutant for which a national ambient air quality standard has been promulgated; 

(c) Any pollutant that is subject to any standard promulgated under Sec. 7411 of the FCAA; 

(d) Any Class I or II substance subject to a standard promulgated under or established by Title VI 

of the FCAA; or 

(e) Any pollutant subject to a standard or other requirement established or promulgated under 

Sec. 7412 of the FCAA, including but not limited to the following: 

(i) Any pollutant subject to requirements under Sec. 7412(j) of the FCAA. If the 

administrator fails to promulgate a standard by the date established in Sec. 7412(e) of the 

FCAA, any pollutant for which a subject source would be major shall be considered to be 

regulated on the date 18 months after the applicable date established in Sec. 7412(e) of 

the FCAA; 

(ii) Any pollutant for which the requirements of Sec. 7412(g)(2) of the FCAA have been met 

but only with respect to the individual source subject to Sec. 7412(g)(2) requirement. 

"Responsible official" means one of the following: 

(a) For a corporation: a president, secretary, treasurer, or vice-president of the corporation in 

charge of a principal business function, or any other person who performs similar policy or 

decision-making functions for the corporation, or a duly authorized representative of such 

person if the representative is responsible for the overall operation of one or more 

manufacturing, production, or operating facilities applying for or subject to a permit and 

either: 

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures 

exceeding $25 million (in second quarter 1980 dollars); or 

(ii) The delegation of authority to such representative is approved in advance by the 

Department. 

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively. 
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(c) For a municipality, state, federal, or other public agency: either a principal executive officer 

or ranking elected official. For the purposes of this part, a principal executive officer of a 

federal agency includes the chief executive officer having responsibility for the overall 

operations of a principal geographic unit of the agency (e.g., a regional administrator of the 

environmental protection agency). 

(d) For affected sources: the designated representative in so far as actions, standards, 

requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated 

thereunder are concerned, and the designated representative for any other purposes under this 

subchapter. 
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B-5

Abbreviations:

ARM Administrative Rules of Montana 

ASTM American Society of Testing Materials 

BACT Best Available Control Technology 

BDT bone dry tons 

BTU British Thermal Unit 

CFR Code of Federal Regulations 

CO carbon monoxide 

DEQ Department of Environmental Quality 

dscf dry standard cubic foot 

dscfm dry standard cubic foot per minute 

EEAP Emergency Episode Action Plan 

EPA U.S. Environmental Protection Agency 

EPA Method Test methods contained in 40 CFR 60, Appendix A 

EU emissions unit 

FCAA Federal Clean Air Act 

gr grains 

HAP hazardous air pollutant 

IEU insignificant emissions unit 

Mbdft thousand board feet 

Method 5 40 CFR 60, Appendix A, Method 5 

Method 9 40 CFR 60, Appendix A, Method 9 

MMbdft million board feet 

MMBTU million British Thermal Units 

NOx oxides of nitrogen 

NO2 nitrogen dioxide 

O2 oxygen 

Pb lead 

PM particulate matter 

PM10 particulate matter less than 10 microns in size 

psi pounds per square inch 

scf standard cubic feet 

SIC Source Industrial Classification 

SO2 sulfur dioxide 

SOx oxides of sulfur 

TPY tons per year 

U.S.C. United States Code 

VE visible emissions 

VOC volatile organic compound 
OP0982-02 Date of Decision: 03/24/09 

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C-1

Appendix C NOTIFICATION ADDRESSES 

Compliance Notifications: 

Montana Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

P.O. Box 200901 

Helena, MT 59620-0901 

United States EPA 

Air Program Coordinator 

Region VIII, Montana Office 

10 W. 15th Street, Suite 3200 

Helena, MT 59626 

Permit Modifications: 

Montana Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

P.O. Box 200901 

Helena, MT 59620-0901 

Office of Partnerships and Regulatory Assistance 

Air and Radiation Program 

US EPA Region VIII 8P-AR 

1595 Wynkoop Street 

Denver, CO 80202-1129 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

D-1

Appendix D AIR QUALITY INSPECTOR INFORMATION 

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to 

assist Holcim, permitting authority, inspectors, and the public. 

1. Direction to Plant: 

Exit Interstate 90 at the Three Forks/Trident, Montana exit. Proceed north towards the Missouri 

River Headwaters Park. The facility is located north of the Headwaters Park with the main office 

located just east of the railroad tracks. 

2. Safety Equipment Required:

Anyone entering the Holcim facility shall, at a minimum, have and utilize the following personnel 

protective equipment: 

a. Hard Hat, 

b. Safety Glasses, 

c. Hearing Protection, and 

d. Protective Footwear. 

Additional personnel protective equipment may be required at the direction of a Holcim 

representative. 

3. Facility Plot Plan:

A copy of the facility Plot Plan is on file with the Department or may be received by contacting a 

Holcim representative. 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

E-1

Appendix E POLLUTION CONTROL DEVICE INSPECTION AND MAINTENANCE PLAN 

Although the hard copy of Appendix E has been removed from the permit, the contents of Appendix E, 

Pollution Control Device Inspection and Maintenance Plan, remain as applicable requirements as stated in 

the Title V Operating Permit #0982-02. To receive a hard copy of this appendix, please contact one of 

the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, MT 59620-0901 

Bureau Telephone # (406) 444-3490 

OR 

Holcim (US), Inc. 

4070 Trident Road 

Three Forks, MT 59752
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

F-1

Appendix F COMPLIANCE ASSURANCE MONITORING (CAM) 

I. Emitting Unit: EU021 – Kiln 

Pollutant: PM10

Control Device: ESP 

Emission Limit: 0.77 lb/ton Clinker 

Monitoring Approach: Key elements of the monitoring approach for this CAM applicable 

emitting unit are contained in Table I. A complete CAM plan is contained in Holcim’s application 

for Title V operating permit renewal (#0982-01) and is on file with the Department. Complete 

copies of this CAM plan are available from the Department upon request. 

Table I 

A. General Criteria 

Indicator ESP Power 

Measurement Approach 

Electrical power input is measured using a voltmeter and an 

ammeter. The total power (P) input to the ESP is the sum of the 

products of the secondary voltage (V) and current (I) in each 

field. (P = V1I1 + V2I2). 

Indicator Range 

Due to the nature of ESP’s, only a lower end value will be 

established for power input. An excursion occurs if the hourly 

average power input drops below its respective hourly average 

indicator value. The indicator value will be established during a 

source test (See stack test below). An excursion triggers an 

inspection, corrective action, and a reporting requirement. 

B. Performance Criteria 

Data Representativeness 

The voltage and current are measured using the instrumentation 

(voltmeter and ammeter) specifically designed and installed on 

the ESP to measure and control the performance of the ESP.. 

Verification of Operational Status Continuous monitoring of total ESP power input (kW). 

Quality Assurance/Quality Control Validate voltmeter and ammeter output on an annual basis in 

accordance with good engineering practices. 

Monitoring Frequency Continuous (at least every minute) 

Data Collection Procedures 

The secondary voltage monitor and current monitor will 

measure their respective values on a one minute or less basis. 

The plant will calculate a one-hour block kW arithmetic mean 

value based on the available values. The data will be 

permanently stored in the plant data historian.

Averaging Period One-hour block average. 

Stack Test/Monitoring Initiation 

After Department approval of the CAM Plan, Holcim will 

schedule and conduct Method 5 testing to establish a suitable 

minimum power indicator value. The indicator value shall be 

80% of the lowest average power (kW) applied to the ESP over 

the duration of any one run that resulted in emissions less than 

the emission limit during the afore mentioned test. The 

indicator value shall be established as expeditiously as 

practicable after Department approval (Department Decision on 

OP0982-01) but in no case shall the establishment of the 

indicator value prevent monitoring from beginning within 180 

days after Department approval of the permit (ARM 

17.8.1508(4)). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

F-2

II. Emitting Unit: EU022 – Clinker Cooler 

Pollutant: PM10

Control Device: Baghouse 

Emission Limit: E = 55.0P0.11-40 

Monitoring Approach: Key elements of the monitoring approach for this CAM applicable 

emitting unit are contained in Table II. A complete CAM plan is contained in Holcim’s application 

for Title V operating permit renewal (#0982-01) and is on file with the Department. Complete 

copies of this CAM plan are available from the Department upon request. 

Table II 

A. General Criteria 

Indicator Baghouse differential pressure. 

Measurement Approach 

Inlet and outlet of the baghouse is monitored using a differential 

pressure transducer. The signal from the pressure transducer is 

recorded using a data acquisition system. One-minute 

differential pressure values collected will be summed and 

averaged every 24 hours. 

Indicator Range 

An excursion is defined as a daily average differential pressure 

of below 1.0 or above 10 inches of water pressure. An 

excursion triggers an inspection and possible corrective action. 

B. Performance Criteria 

Data Representativeness 

Pressure drop across the baghouse is measured across the tube 

sheet. The minimum accuracy of the device is ± 1 inch of 

water. 

Verification of Operational Status Pressure drop is continuously monitored and recorded. 

Quality Assurance/Quality Control Pressure transducer is calibrated in accordance with 

manufacturer’s recommendations. 

Monitoring Frequency Every minute 

Data Collection Procedures 

Inlet and outlet of the baghouse is monitored using a differential 

pressure transducer. The signal from the pressure transducer is 

recorded using a data acquisition system. The data will be 

permanently stored in the plant data historian. 

Averaging Period 24-hour 

Monitoring Initiation 

The monitoring shall commence as expeditiously as practicable 

after Department approval (Department Decision on OP0982-

01) but no later than 180 days after Department approval of the 

permit (ARM 17.8.1508(4)). 
OP0982-02 Date of Decision: 03/24/09 

Effective Date: 04/24/09 

F-3

III. Emitting Units: EU032, EU034, and EU037 – Finish Mills #2, #3, and #4 

Pollutant: PM10

Control Device: Pulse Jet Baghouses 

Emission Limit: 0.02 gr/dscm (EU032 only), E = 55.0P0.11-40 (EU034 and EU037 only) 

Monitoring Approach: Key elements of the monitoring approach for this CAM applicable 

emitting unit are contained in Table III. A complete CAM plan is contained in Holcim’s application 

for Title V operating permit renewal (#0982-01) and is on file with the Department. Complete 

copies of this CAM plan are available from the Department upon request. 

Table III 

A. General Criteria 

Indicator Baghouse differential pressure. 

Measurement Approach 

Inlet and outlet of the baghouses is monitored using a 

differential pressure transducer. The signal from the pressure 

transducer is recorded using a data acquisition system. Oneminute differential pressure values collected will be summed 

and averaged every 24 hours. 

Indicator Range 

An excursion is defined as a daily average differential pressure 

of below 2.5 or above 10 inches of water pressure. An 

excursion triggers an inspection and possible corrective action. 

B. Performance Criteria 

Data Representativeness 

Pressure drop across the baghouses is measured across the tube 

sheet. The minimum accuracy of the device is ± 1 inch of 

water. 

Verification of Operational Status Pressure drop is continuously monitored and recorded. 

Quality Assurance/Quality Control Pressure transducer is calibrated in accordance with 

manufacturer’s recommendations. 

Monitoring Frequency Every minute 

Data Collection Procedures 

Inlet and outlet of the baghouses is monitored using a 

differential pressure transducer. The signal from the pressure 

transducer is recorded using a data acquisition system. The data 

will be permanently stored in the plant data historian. 

Averaging Period 24-hour 

Monitoring Initiation 

The monitoring shall commence as expeditiously as practicable 

after Department approval (Department Decision on OP0982-

01) but no later than 180 days after Department approval of the 

permit (ARM 17.8.1508(4)).