# ADEQ

OPERATING AIR PERMIT

Pursuant to the Regulations of the Arkansas Operati ng Air Permit Program, Regulation 26:



## Permit No. : 75-AOP-R6 Renewal #1 IS ISSUED TO: Ash Grove Cement Company 4457 Highway 108 Foreman, AR 71836 Little River County AFIN: 41-00001

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITT EE TO INSTALL, OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UN ITS DESCRIBED IN THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS VALID BETWEEN:

October 2, 2002 AND October 1, 2007

THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIO NS CONTAINED HEREIN.

Signed:

Mike Bates Date Modified Chief, Air DivisionAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

2 Table of Contents

SECTION I: FACILITY INFORMATION

................................................... ........................... 3 SECTION II: INTRODUCTION

................................................... ............................................ 3 Summary of Permit Activity

................................................... ................................................. 3 Process Description

................................................... ................................................... ............. 3 Regulations

................................................... ................................................... .......................... 3 Emission Summary

................................................... ................................................... ............. 3 SECTION III: PERMIT HISTORY

................................................... ....................................... 3 SECTION IV: SPECIFIC CONDITIONS

................................................... ............................. 3 SN-P1

................................................... ................................................... .................................... 3 SN-P2

................................................... ................................................... .................................... 3 SN-P3

................................................... ................................................... .................................... 3 Transfer points for Pyroprocessing Unit

................................................... ............................. 3 SN-P6

................................................... ................................................... .................................... 3 SN-P17

................................................... ................................................... .................................. 3 Uncontrolled Transfer points in the Mill Area

................................................... ................... 3 SN-M16

................................................... ................................................... ................................ 3 SN-M17

................................................... ................................................... ................................ 3 SN-M18

................................................... ................................................... ................................ 3 SN-M19

................................................... ................................................... ................................ 3 SN-M20

................................................... ................................................... ................................ 3 SN-M42, M43, M44, M45

................................................... ................................................... ... 3 SN-F4

................................................... ................................................... .................................... 3 SN-F5

................................................... ................................................... .................................... 3 Uncontrolled Emission Points in the Fuel Area

................................................... .................. 3 SN-F19, F20

................................................... ................................................... ......................... 3 SN-S1, S3, S13, S14

................................................... ................................................... ............. 3 SN-S4, S5, S6, S7, S8, S9, S10, S11, S12

................................................... ............................... 3 SN-C1

................................................... ................................................... ................................... 3 Uncontrolled Emission Points in the Clinker Area

................................................... ............. 3 SN-C4

................................................... ................................................... ................................... 3 SN-C14, C18, C26, C27, C32, C34, C41, C42, C43, C44 , C45, C46 ..................................... 3 Uncontrolled Emission Points in the Raw Material St orage Area ....................................... 3 SN-R2

................................................... ................................................... ................................... 3 SN-R5

................................................... ................................................... ................................... 3 SN-R12

................................................... ................................................... ................................. 3 SN-R17

................................................... ................................................... ................................. 3 SN-R18

................................................... ................................................... ................................. 3 SN-R19

................................................... ................................................... ................................. 3 SN-R20

................................................... ................................................... ................................. 3 SN-R22 & R23

................................................... ................................................... ..................... 3 SN-R25

................................................... ................................................... ................................. 3 SN-Q1

................................................... ................................................... ................................... 3Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

3 SN-Q2

................................................... ................................................... ................................... 3 Uncontrolled Emission Points in the Quarry

................................................... ...................... 3 SN-Q8

................................................... ................................................... ................................... 3 SECTION V: COMPLIANCE PLAN AND SCHEDULE

................................................... .... 3 SECTION VI: PLANTWIDE CONDITIONS

................................................... ....................... 3 Title VI Provisions

................................................... ................................................... .............. 3 Permit Shield

................................................... ................................................... ....................... 3 SECTION VII: INSIGNIFICANT ACTIVITIES

................................................... .................. 3 SECTION VIII: GENERAL PROVISIONS

................................................... .......................... 3 Appendix A – Continuous Emission Monitoring Systems Conditions Appendix B – AP-42 Section 13.2.4 Appendix C – 40 CFR 63 Subpart LLL Appendix D - 40 CFR 63 Subpart EEE Appendix E - 40 CFR 60 Subpart F Appendix F - 40 CFR 60 Subpart Kb Appendix G - 40 CFR 63 Subpart DD Appendix H - Plant Haul Road Fugitive Dust Control PlanAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

4 List of Acronyms and Abbreviations

A.C.A. Arkansas Code Annotated AFIN ADEQ Facility Identification Number

CFR Code of Federal Regulations

CO Carbon Monoxide

HAP Hazardous Air Pollutant

lb/hr Pound Per Hour

MVAC Motor Vehicle Air Conditioner

No. Number

NO x Nitrogen Oxide

PM Particulate Matter

PM10 Particulate Matter Smaller Than Ten Microns SNAP Significant New Alternatives Program (SNAP)

SO 2 Sulfur Dioxide SSM Startup, Shutdown, and Malfunction Plan

Tpy Tons Per Year

UTM Universal Transverse Mercator

VOC Volatile Organic CompoundAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

5 SECTION I: FACILITY INFORMATION

PERMITTEE: Ash Grove Cement Company

AFIN: 41-00001

PERMIT NUMBER: 75-AOP-R66

FACILITY ADDRESS: 4457 Highway 108 Foreman, AR 71836

MAILING ADDRESS: 4457 Highway 108 Foreman, Arkansas 71836

COUNTY: Little River

CONTACT POSITION: Dan Peterson, Plant Manager, Plan t Manager

TELEPHONE NUMBER: (501) 542-6217

REVIEWING ENGINEER: Wesley Crouch

UTM North South (Y): Zone 15: 3728.9

UTM East West (X): Zone 15: 368.35Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

6 SECTION II: INTRODUCTION

Summary of Permit Activity

Ash Grove operates a portland cement plant located at 4457 Hwy 108 West in Foreman, Arkansas 71836. This modification will allow Ash Grove to replace an existing screw conveyor with a weigh belt (SN-M12) and add a conveyor belt to allow the addition of limestone to Mill No. 4 (SN-M46). This project will result in additio nal PM emissions of 0.5 tpy and PM 10 emissions of 0.2 tpy.

Process Description

For informational purposes only, this section does not contain enforceable conditions.

Ash Grove Cement Company operates a portland cement plant near Foreman, Arkansas. The manufacture of portland cement at this facility is a five step process.

1. Acquisition of raw materials from nearby quarrying and crushing and from off-site

sources.

2. Preparation of the raw materials for pyroprocessing by grinding with water into a slurry.

3. Pyroprocessing of the slurried raw materials into p ortland cement clinker.

4. Grinding of a mixture of clinker and gypsum into va rious portland cement products.

5. Cement storage and shipment of finished cement.

Raw materials consist of chalk, sand, and iron ore. Chalk is received by belt conveyor from the plant quarry and stock-piled in an A-framed structu re. Sand and iron ore are received from off site and stored in separate outdoor piles. The cha lk, sand, and iron ore are crushed and then transported to the mill building by a conveyor belt

. Within the mill building, the chalk, sand, and iron ore are stored in separate bins. These raw materials are proportioned, mixed with water in a b all mill and ground into a slurry. The slurry is pumped and metered into three rotary cement kiln s in which chemical reactions occur to form clinker, an intermediate product that ultimately be comes portland cement.

From time-to-time, spent kiln brick removed from th e rotary kilns is used to replace a portion of the raw materials fed to kiln #3. The spent brick is crushed in a portable crusher before being transferred to the mill building with other raw mat erials.

The raw material slurry is fed to the rotary kiln p yroprocessing system. The kilns are slowlyrotating steel tubes lined with various refractory materials (e.g. kiln brick). Each kiln slopes at an angle of about 5 degrees. The raw material slur ry is fed to the kiln at the upper, or feed, end. Fuel generally is introduced at the lower, or burni ng, end of the kiln. The slope and rotation of the kiln allows the slurry to flow by gravity throu gh the various reaction zones within the kiln.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

7 Combustion gases and the slurry flow countercurrent to each other. Each kiln is equipped with an electrostatic precipitator to control particulat e emissions.

Within the rotary kilns, the chemical constituents of the raw materials react with each other and are fused into nodules of portland cement clinker a t a material temperature of about 2700 °F. The clinker exits at the burning end of the kiln an d falls into clinker coolers in which the clinker is air cooled. A portion of this air is used for c ombustion air in the kilns. The balance of the air is vented to the atmosphere through a fabric filter

. After cooling, the clinker is transported by a seri es of conveyors to clinker storage silos. The clinker can also be transported by conveyor to an e nclosed storage dome or by truck to an outside storage pile.

Clinker taken from storage is sent to finish millin g. During finish milling, clinker is ground with gypsum and/or other additives to produce portland c ement and masonry cement. Gypsum is delivered to the plant from off site sources and st ored in an outdoor pile adjacent to the raw material storage areas. Gypsum is withdrawn from t he pile by an underpile feeder which is located in a tunnel. The gypsum is transported to mill feed bins in the mill building. Chalk for masonry cement is dried in a rotary drier equipped with a wet scrubber control device.

Cement is pneumatically conveyed from the finish mi lls to several storage silos. From these silos, the cement is loaded into rail cars and truc ks or packed into bags for shipment.

The fuel sources used to produce clinker at the For eman plant include fossil fuels, including coal and natural gas, tire-derived fuel (TDF), hazardous waste-derived fuel (HWDF), and used oils from on and off site sources. These fuels are used in varying combinations and in varying percentages of the total fuel input.

Fuels are fed to the clinker discharge end of the k iln through a multichannel burner pipe. Containerized solid hazardous waste-derived fuel (S WDF) and TDF are fed directly into the calcining zone within the kilns. This location gen erally is midway between the feed end and burning end of the kiln.

The primary fossil fuel used to fire the kilns is c oal. Coal is received from off-site sources and is stored in an outdoor storage pile.

TDF is received at the plant from off site sources. Tires may be fed to the kilns by hand or using automated equipment.

LWDF is received in rail tank cars and in tank truc ks and stored in above ground storage tanks before being transferred to the kilns. Currently, Ash Grove operates three above ground LWDF storage tanks. In the near future, Ash Grove will operate seven above ground LWDF storage tanks. To control VOC emissions, the LWDF storage tanks are vented to a thermal oxidizer with a back up carbon adsorption system.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

8 Containerized SWDF is received in van trailers and flat bed trailer trucks. Each individual container of SWDF is mechanically fed at the mid-ki ln location.

Regulations

The following table contains the regulations applic able to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective February 15, 1999 Regulations of the Arkansas Plan of Implementation for Air Pollution Control, Regulation 19, effective May 28, 2006 Regulations of the Arkansas Operating Air Permit Pr ogram, Regulation 26, effective September 26, 2002 40 CFR Part 60 Subpart F, Standards of Performance for Portland Cement Plants

, 40 CFR Part 60 Subpart Kb, Standards of Performance for Volatile Organic Liqui d Storage Vessels(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification commenced After Jul y 23, 1984 40 CFR Part 61, Subpart FF, National Emission Standards for Benzene Waste Opera tions 40 CFR Part 63, Subpart DD, National Emission Standards for Hazardous Air Pollu tants from Off-Site Waste and Recovery Operations 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing I ndustry 40 CFR Part 63, Subpart EEE, National Emission Standards for Hazardous Air Pollutants From Hazardous Waste Combustors

The following table is a summary of emissions from the facility. This table, in itself, is not an enforceable condition of the permit.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

9 Emission Summary

EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

PM 416.07 1112.45

PM 10 135.67 562.45

SO 2 2563.4 5736.1

VOC 81.4 285.1

CO 551.0 1214.9 Total Allowable Emissions

NO X 3337.1 9097.0

HAPs* 1,1,1-trichloroethane*

1,1,2,2-tetrachloroethane* 1,1,2-trichloroethane* 1,1-dichloroethane* 1,1-dichloroethene* 1,2,4-trichlorobenzene* 1,2-dichloroethane* 1,2-dichloropropene* 1,2-epoxybutane* 1,3-butadiene* 1,4-dichlorobenzene* 1,4-phenylene-diamine* 2,4,5-trichlorophenol* 2,4,6-trichlorophenol* 2,4-dinitrophenol* 2,4-dinitrotoluene* 2-butanone* 3,3-dichlorobenzidine* 3,3-dimethoxybenzidine* 4-methyl-2-pentanone* 4-nitrophenol* acrylonitrile* allyl chloride* aniline* antimony arsenic benzene* benzidine* 0.03 0.03 0.03 0.03 0.33 0.17 1.69 0.03 0.09 0.53 0.39 0.08 0.03 0.19 0.07 0.014 0.62 0.03 0.03 0.03 0.05 0.09 0.53 0.02 30.5 0.00566 0.81 0.05 0.05

0.10 0.11 0.05 1.40 0.72 7.42 0.10 0.32 2.27 1.63 0.32 0.08 0.86 0.25 0.03 2.69 0.09 0.1 0.21 0.17 0.40 2.34 0.06 57.37 0.02459 3.56 0.2Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

10 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy beryllium bis(2-chloroethyl)ether* bis(2-ethylhexyl)phthalate* bromodichloromethane* bromoform* bromomethane* cadmium carbon disulfide carbon tetrachloride* chlorine chlorobenzene* chloroethane* chloroform* chloromethane* chromium cis-1,3-dichloropropene* cobalt‡ cumene* diethanolamine* dimethylphthalate* ethyl acrylate* ethylbenzene* ethylene dibromide* ethylene glycol* hexachlorobenzene* hexachlorobutadiene* hexachlorocyclopentadiene* hexachloroethane* hydrogen chloride hydroquinone* iodomethane* lead

manganese mercury methyl methacrylate* methylene chloride* naphthalene* n-hexane* nickel nitrobenzene* 0.00063 0.03 0.748 0.04 0.03 0.78 0.06513 0.17 0.03 1.3432 0.35 2.11 0.24 2.19 0.01559 0.03 66.0 0.03 1.1 0.014 0.35 0.21 0.03 0.35 0.03 0.03 0.03 0.03 171 0.04 0.07 1.42 0.1462 0.2147 0.03 4.72 0.96 0.19 66.0 0.03 0.002734

0.08 3.28 0.13 0.12 3.43 0.2843 0.75 0.06 5.8656 1.52 9.19 1.07 9.55 0.0683 0.18 289.12 0.10 4.6 0.03 1.5 0.87 0.04 1.6 0.05 0.09 0.08 0.1 749.0 0.17 0.29 .9640 0.64 0.94 0.15 20.63 4.26 0.87 289.12 0.11Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

11 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy N-nitrosoddiphenylamine* N-nitrosomorpholine* ortho-anisidine* ortho-toluidine* o-xylene* pentachlorophenol* phenol* selenium styrene* tert-butyl methyl ether* tetrachloroethene* toluene* trans-1,3-dichloropropene* trichloroethene* vinyl acetate* vinyl bromide* vinyl chloride* xylene* 0.016

0.03 0.03 0.018 0.36 0.05 0.19 0.0255 0.07 0.03 0.03 0.16 0.03 0.13 0.03 0.13 0.89 1.45 0.03

0.13 0.11 0.05 1.56 0.15 0.82 0.1118 0.26 0.05 0.16 0.76 0.12 0.59 0.06 0.61 3.83 3.83

Air Contaminants ** None

P1 Kiln #1 PM PM 10 SO 2 VOC CO NO x 1,1,1-trichloroethane 1,1,2,2-tetrachloroethane 1,1,2-trichloroethane 1,1-dichloroethane 1,1-dichloroethene 1,2,4-trichlorobenzene 1,2-dichloroethane 1,2-dichloropropane 1,2-epoxybutane 1,3-butadiene 1,4-dichlorobenzene 1,4-phenylene-diamine 2,4,5-trichlorophenol 2,4,6-trichlorophenol 19.5 19.5 849.0 9.6 172.0 889.0 0.01 0.01 0.01 0.01 0.16 0.08 0.01 0.01 0.01 0.02 0.19 0.01 0.01 0.01 85.4

85.4 1960.0 42.1 368.0 2400.0 0.02 0.03 0.04 0.02 0.69 0.35 0.05 0.04 0.01 0.07 0.81 0.03 0.03 0.05Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

12 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy 2,4-dinitrophenol 2,4-dinitrotoluene 2-butanone 3,3-dichlorobenzidine 3,3-dimethoxybenzidine 4-methyl-2-pentanone 4-nitrophenol acrylonitrile allyl chloride aniline antimony arsenic benzene benzidine beryllium bis(2-chloroethyl)ether bis(2-ethylhexyl)phthalate bromodichloromethane bromoform bromomethane cadmium carbon disulfide carbon tetrachloride chlorine chlorobenzene chloroethane chloroform chloromethane chromium cis-1,3-dichloropropene cobalt ‡

cumene dimethylphthalate ethyl acrylate ethyl benzene ethylene dibromide hexachlorobenzene hexachlorobutadiene hexachlorocyclopentadiene hexachloroethane 0.03 0.002 0.21 0.01 0.01 0.01 0.02 0.03 0.19 0.005 8.8 0.00258 0.22 0.02 0.00028 0.01 0.004 0.01 0.01 0.26 0.0307 0.08 0.01 0.0016 0.17 1.05 0.01 0.12 0.00578 0.02 19.5 0.01 0.002 0.11 0.1 0.01 0.01 0.01 0.01 0.01 0.11

0.01 0.91 0.04 0.04 0.09 0.07 0.11 0.84 0.02 38.5 0.0112 0.95 0.07 0.00123 0.03 0.02 0.02 0.03 1.15 0.134 0.37 0.02 0.0078 0.73 4.59 0.06 0.51 0.0253 0.08 85.41 0.03 0.01 0.46 0.41 0.01 0.02 0.03 0.03 0.04Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

13 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy hydrogen chloride hydroquinone iodomethane lead

manganese mercury methyl methacrylate methylene chloride naphthalene n-hexane nickel ‡

nitrobezene N-nitrosoddiphenylamine n-nitrosomorpholine ortho-aniside ortho-toluidine o-xylene pentachlorophenol phenol selenium styrene tert-butyl methyl ether tetrachloroethene toluene trans-1,3-dichloropropene trichloroethene vinyl acetate vinyl bromide vinyl chloride m/p xylene 50.0 0.01 0.03 0.06 0.043 0.0694 0.01 2.24 0.29 0.06 19.5 19.5 0.003 0.01 0.01 0.004 0.08 0.02 0.05 0.0075 0.03 0.01 0.02 0.04 0.01 0.06 0.01 0.01 0.44 0.21 219.0

0.05 0.13 0.263 0.188 0.304 0.05 9.8 1.29 0.27 85.41 0.02 0.01 0.04 0.04 0.02 0.35 0.07 0.22 0.0329 0.12 0.02 0.07 0.19 0.05 0.28 0.02 0.06 1.91 0.92

P2 Kiln #2 PM PM 10 SO 2 VOC CO NO x 1,1,1-trichloroethane 1,1,2,2-tetrachloroethane 1,1,2-trichloroethane 1,1-dichloroethane 19.5 19.5 753.0 9.6 152.0 882.0 0.01 0.01 0.01 0.01 85.4

85.4 1690.0 42.1 333.0 2453.0 0.02 0.03 0.04 0.02Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

14 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

1,1-dichloroethene 1,2,4-trichlorobenzene 1,2-dichloroethane 1,2-dichloropropane 1,2-epoxybutane 1,3-butadiene 1,4-dichlorobenzene 1,4-phenylene-diamine 2,4,5-trichlorophenol 2,4,6-trichlorophenol 2,4-dinitrophenol 2,4-dinitrotoluene 2-butanone 3,3-dichlorobenzidine 3,3-dimethoxybenzidine 4-methyl-2-pentanone 4-nitrophenol acrylonitrile allyl chloride aniline antimony arsenic benzene benzidine beryllium bis(2-chloroethyl)ether bis(2-ethylhexyl)phthalate bromodichloromethane bromoform bromomethane cadmium carbon disulfide carbon tetrachloride chlorine chlorobenzene chloroethane chloroform chloromethane chromium cis-1,3-dichloropropene 0.16 0.08 0.01 0.01 0.01 0.02 0.19 0.01 0.01 0.01 0.03 0.002 0.21 0.01 0.01 0.01 0.02 0.03 0.19 0.005 8.80 0.00258 0.22 0.02 0.00028 0.01 0.004 0.01 0.01 0.26 0.0307 0.08 0.01 0.0016 0.17 1.05 0.01 0.12 0.00578 0.02 0.69

0.35 0.05 0.04 0.01 0.07 0.81 0.03 0.03 0.05 0.11 0.01 0.91 0.04 0.04 0.09 0.07 0.11 0.84 0.02 38.5 0.0112 0.95 0.07 0.00123 0.03 0.02 0.02 0.03 1.15 0.134 0.37 0.02 0.0078 0.73 4.59 0.06 0.51 0.0253 0.08Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

15 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

cobalt ‡

cumene dimethylphthalate ethyl acrylate ethyl benzene - listed twice ethyl benzene - listed twice ethylene dibromide hexachlorobenzene hexachlorobutadiene hexachlorocyclopentadiene hexachloroethane hydrogen chloride hydroquinone iodomethane lead

manganese mercury methyl methacrylate methylene chloride naphthalene n-hexane nickel ‡

nitrobezene N-nitrosoddiphenylamine n-nitrosomorpholine ortho-aniside ortho-toluidine o-xylene pentachlorophenol phenol selenium Silver - in Application styrene tert-butyl methyl ether tetrachloroethene toluene trans-1,3-dichloropropene trichloroethene vinyl acetate vinyl bromide 19.5 0.01 0.002 0.11 0.09 0.01 0.01 0.01 0.01 0.01 0.01 50 0.01 0.03 0.06 0.043 0.0694 0.01 2.24 0.29 0.06 19.50 0.005 0.003 0.01 0.01 0.004 0.08 0.02 0.05 0.0075

0.03 0.01 0.01 0.01 0.01 0.06 0.01 0.01 85.41

0.03 0.01 0.46 0.38 0.03 0.01 0.02 0.03 0.03 0.04 219.0 0.05 0.13 0.263 0.188 0.304 0.05 9.8 1.29 0.27 85.41 0.02 0.01 0.04 0.04 0.02 0.35 0.07 0.22 0.0329

0.12 0.02 0.07 0.19 0.05 0.28 0.02 0.06Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

16 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy vinyl chloride m/p xylene 0.44 0.21 1.91

0.92

P3 Kiln #3 PM PM 10 SO 2 VOC CO NO x 1,1,1-trichloroethane 1,1,2,2-tetrachloroethane 1,1,2-trichloroethane 1,1-dichloroethane 1,1-dichloroethene 1,2,4-trichlorobenzene 1,2-dichloroethane 1,2-dichloropropane 1,2-epoxybutane 1,3-butadiene (cis/trans)1,3- dichloropropene 1,4-dichlorobenzene 1,4-phenylene-diamine 2,4,5-trichlorophenol 2,4,6-trichlorophenol 2,4-dinitrophenol 2,4-dinitrotoluene 2-butanone 3,3-dichlorobenzidine 3,3-dimethoxybenzidine 4-dinitrophenol 4-methyl-2-pentanone acrylonitrile allyl chloride aniline antimony arsenic benzene benzidine beryllium bis(2-chloroethyl)ether 27.0 27.0 961.0 13.4 220.0 1568.0 0.01 0.01 0.01 0.01 0.01 0.01 1.67 0.01 0.07 0.49

0.01 0.01 0.06 0.01 0.17 0.01 0.01 0.20 0.01 0.01 0.01 0.01 0.03 0.15 0.01 12.9 0.0005 0.37 0.02 0.00007 0.01 118.3

118.3 2090.0 58.87 482.0 4230.0 0.01 0.04 0.03 0.01 0.02 0.02 7.32 0.02 0.3 2.13

0.02 0.01 0.26 0.02 0.76 0.03 0.01 0.87 0.01 0.02 0.03 0.03 0.14 0.66 0.02 56.6 0.00219 1.63 0.07 0.000274 0.02Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

17 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy bis(2-ethylhexyl)phthlate bromodichloromethane bromoform bromomethane cadmium carbon disulfide carbon tetrachloride chlorine chlorobenzene chloroethane chloroform chloromethane chromium cobalt ‡

cumene dimethylphthalate ethyl acrylate ethylbenzene ethylene dibromide hexachlorobenzene hexachlorobutadiene hexachlorocyclopentadiene hexachloroethane hydrogen chloride hydroquinone iodomethane lead m/p xylene

manganese mercury methyl methacrylate methylene chloride naphthalene n-hexane nickel ‡

nitrobenzene N-nitrosoddiphenylamine N-nitrosomorpholine ortho-anisidine ortho-toluidine 0.74 0.02 0.01 0.26 0.00373 0.01 0.01 1.34 0.01 0.01 0.22 1.95 0.00403 27.0 0.01 0.01 0.13 0.01 0.01 0.01 0.01 0.01 0.01 71.0 0.02 0.01 0.10 0.43 0.0602 0.0759 0.01 0.24 0.38 0.07 27.0 0.02 0.01 0.01 0.01 0.01 3.24

0.09 0.06 1.13 0.0163 0.01 0.02 5.85 0.06 0.01 0.95 8.53 0.0177 118.3 0.04 0.01 0.58 0.05 0.02 0.01 0.03 0.02 0.02 311.0 0.07 0.03 0.438 1.89 0.264 0.332 0.05 1.03 1.68 0.33 118.3 0.07 0.01 0.05 0.03 0.01Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

18 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy o-xylene pentachlorophenol phenol selenium Silver - In Application styrene tert-butyl methyl ether tetrachloroethene toluene trichloroethene vinyl acetate vinyl bromide vinyl chloride 4-Nitrophenol 0.20 0.01 0.09 0.0105

0.01 0.01 0.01 0.04 0.01 0.01 0.11 0.03 0.01 0.86

0.01 0.38 0.046

0.02 0.01 0.02 0.18 0.03 0.02 0.49 0.14 0.03

P4 Discharge into Coal

Mill #1 PM PM 10 0.1

0.1 0.2

0.1 P5 Discharge from Kiln

#1 to #1 Bucket Conveyor PM PM 10 0.2

0.1 0.8

0.3

P6 3 Clinker Cooler

Baghouse PM PM 10 25.0

25.0 110.0

110.0 P7 Discharge into Coal

Mill #2 PM PM 10 0.1

0.1 0.1

0.1 P8 Discharge from Kiln

#2 to #2 Bucket Conveyor PM PM 10 0.2

0.1 0.8

0.3

P9 Discharge into Coal

Mill #3 PM PM 10 0.1

0.1 0.1

0.1 P10 Discharge from Kiln

#3 to #3 Bucket Conveyor PM PM 10 0.6

0.2 2.3

0.8

P11 Discharge from Bin

#48 PM PM 10 0.1

0.1 0.1

0.1 P12 Discharge from Bin

#48 PM PM 10 0.1

0.1 0.1

0.1 P13 Discharge from Bin

#47 PM PM 10 0.1

0.1 0.1

0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

19 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy P15 Baghouse Discharge

to #2 Bucket Conveyor PM PM 10 0.4

0.2 1.6

0.6

P16 Baghouse Discharge

to #3 Bucket Conveyor PM PM 10 0.4

0.2 1.6

0.6

P17 Bin #49 Sock Filter PM PM 10 0.5

0.5 1.9

1.9 P20 Truck Loading of

CKD PM PM 10 0.1

0.1 0.2

0.1 P21 Truck Unloading of

CKD PM PM 10 0.1

0.1 0.2

0.1 P22 Trailer Unloading of

CKD PM PM 10 0.1

0.1 0.2

0.1 P23 CKD Pile PM PM 10 1.2

0.6 5.2

2.6 P24 Transfer from

Main Coal Pile PM PM 10 0.2

0.1 0.6

0.2 P32 1500 Ton CKD

Storage Bin PM PM 10 0.4

0.4 1.6

1.6 P33 CKD Handling Screw

Conveyor Bin Vent PM PM 10 0.1

0.1 0.4

0.4 P34 Kiln #3 Dust Scoop

Bin Vent PM PM 10 0.2

0.2 0.5

0.5 P35 P39 CKD Handling 500

Ton Silo Baghouse PM PM 10 0.3

0.3 1.1

1.1 P36 Truck Loading of CKD (North of Hwy. 108) PM PM 10 0.1

0.1 0.3

0.1

P37 1500 ton CKD

Storage Bin PM PM 10 0.3

0.3 1.2

1.2

P38 CKD Truck Loadout PM PM 10 0.2

0.2 0.6

0.6 M3 Gypsum Discharge

into Finish Mill #4 PM PM 10 0.1

0.1 0.1

0.1 M4 Gypsum Discharge to

Gypsum Elevator PM PM 10 0.1

0.1 0.1

0.1 M9 Tripper Discharge

into Bins PM PM 10 0.1

0.1 0.2

0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

20 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy M10 Discharge from Bin

#45 PM PM 10 0.1

0.1 0.1

0.1 M11 Discharge into Bin

#43 PM PM 10 0.3

0.1 1.0

0.4 M12 Discharge from Bin

#44 PM PM 10 0.1

0.1 0.4

0.2 M13 Discharge from Bin

#43 PM PM 10 0.3

0.1 1.0

0.4 M14 Transfer from Admix

Weigh Feeder to B Belt PM PM 10 0.3

0.1 1.0

0.4

M15 Transfer from Bin #42

Feeder to B Belt PM PM 10 0.1

0.1 0.1

0.1 M16 #2 Finish Mill

Baghouse PM PM 10 0.7

0.7 3.0

3.0 M17 #2 Finish Mill Baghouse-Mill Sweep PM PM 10 VOC Diethanolamine Ethylene Glycol 0.5 0.5 3.8 0.2 0.1 2.0

2.0 16.3 0.6 0.2 M18 #4 Finish Mill

Baghouse PM PM 10 1.1

1.1 4.7

4.7 M19 #4 Finish MillDischarge BaghouseMill Sweep PM PM 10 VOC Diethanolamine Ethylene Glycol 1.6 1.6 27.8 1.0 0.4 6.7

6.7 122.0 4.1 1.4 M20 Dryer Scrubber PM PM 10 SO 2 VOC CO NO x 0.4

0.2 0.1 0.5 6.3 7.5 1.8

0.9 0.2 1.9 27.6 32.9 M21 Discharge from Bin

#42 to Feeder PM PM 10 0.1

0.1 0.1

0.1 M22 Discharge from Bin

#41 PM PM 10 0.1

0.1 0.1

0.1 M23 Transfer from Bin #41 Conveyor Belt to A1 PM PM 10 0.1

0.1 0.1

0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

21 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

Conveyor Belt

M24 Discharge from Bin

#40 PM PM 10 0.1

0.1 0.1

0.1 M25 Discharge from D Belt into Chalk Dryer PM PM 10 0.2

0.1 0.6

0.2 M26 Transfer to D Belt PM PM 10 0.1

0.1 0.1

0.1 M27 Discharge from Bin

#39 PM PM 10 0.1

0.1 0.4

0.2 M28 Transfer to Dry Feed

Belt PM PM 10 0.1

0.1 0.4

0.2 M29 Transfer to Dry Feed

Belt PM PM 10 0.1

0.1 0.1

0.1 M30 Transfer from #1

Clinker Bin to Dry Feed Belt PM PM 10 0.4

0.2 1.6

0.6

M31 Discharge from Bin

#38 PM PM 10 0.1

0.1 0.1

0.1 M32 Discharge from Bin

#38 PM PM 10 0.1

0.1 0.1

0.1 M33 Discharge from Bin

#37 PM PM 10 0.1

0.1 0.1

0.1 M34 Transfer from Bin #37

to A1 Belt PM PM 10 0.1

0.1 0.1

0.1

M35 Discharge from Bin

#36 PM PM 10 0.1

0.1 0.1

0.1 M36 Transfer to A1 Belt PM PM 10 0.1

0.1 0.1

0.1 M37 Transfer to A1 Belt PM PM 10 0.1

0.1 0.1

0.1 M38 Transfer to A1 Belt PM PM 10 0.1

0.1 0.1

0.1 M39 Discharge Into Raw

Mill #3 PM PM 10 0.2

0.1 0.5

0.2 M40 Discharge from Gypsum Elevator into Feed Mill #4 PM PM 10 0.1

0.1 0.1

0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

22 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

M42 Bin #36 Dust

Collector PM PM 10 0.3

0.3 0.9

0.9 M43 Bin #37 Dust

Collector PM PM 10 0.3

0.3 0.9

0.9 M44 Bin #39 Dust

Collector PM PM 10 0.3

0.3 0.9

0.9 M45 Bin #44 Dust

Collector PM PM 10 0.3

0.3 0.9

0.9 M46 Transfer from Limestone Feeder to Belt Conveyor PM PM 10 0.2

0.1 0.5

0.2

F4 Long Term Coal Pile PM PM 10 0.2

0.1 0.9

0.5 F5 Active Coal Pile PM PM 10 0.2

0.1 0.6

0.3 F6 Discharge into Feed

Hopper #5 PM PM 10 0.6

0.3 1.7

0.6 F8 Transfer from #208

Belt to #210 Belt PM PM 10 0.1

0.1 0.1

0.1 F9 Discharge into Feed

Hopper #4 PM PM 10 0.6

0.3 1.7

0.6 F11 Discharge from Hopper #4 Vibrating Feeder to #206 Belt PM PM 10 0.1

0.1 0.1

0.1

F12 Discharge from Hopper #5 Vibrating Feeder to #206 Belt PM PM 10 0.1

0.1 0.1

0.1

F13 Transfer from #206

Belt to #208 Belt PM PM 10 0.1

0.1 0.1

0.1

F14 Transfer from Stacker

Belt to Active Coal Pile PM PM 10 0.6

0.3 1.7

0.6

F15 Unloading into Long

Term Coal Pile PM PM 10 0.5

0.2 1.2

0.5 F16 Transfer from Long

Term Coal Pile to Active Pile PM PM 10 0.5

0.2 1.2

0.5

F17 Transfer from Coal PM 0.2 0.6Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

23 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

Feeders to Underbelt PM 10 0.1 0.2

F18 Railcar Unloading into Coal Hoppers 4 and 5 PM PM 10 0.6

0.3 2.7

1.0

F19, F20 LWDF Tanks Thermal Oxidizer and Carbon Adsorption System PM PM 10 SO 2 VOC CO NO x Xylene Toluene Methylene Chloride Ethyl Benzene Styrene Tetrachloroethane 1,1,2-trichloroethane Benzene 0.1 0.1 0.1 16.9 0.5 0.6 1.3 0.7 0.1 0.2 0.1 0.1 0.1 0.1 0.2

0.2 0.1 3.0 2.0 2.4 0.3 0.2 0.1 0.1 0.1 0.1 0.1 0.1 S1 Truck Loadout DC

#31 PM PM 10 0.2

0.2 0.8

0.8 S3 Truck Loadout DC

#49 PM PM 10 0.7

0.7 3.0

3.0 S4 Kaiser Silos DC #21 PM PM 10 0.5

0.5 2.1

2.1 S5 Kaiser Silos DC #22 PM PM 10 0.2

0.2 0.7

0.7 S6 Delta Silo DC #23 PM PM 10 0.6

0.6 2.5

2.5 S7 Rail Silos DC #24 PM PM 10 0.7

0.7 3.0

3.0 S8 Kaiser Silos DC #29 PM PM 10 0.2

0.2 0.8

0.8 S9 Kaiser Silos DC #30 PM PM 10 0.2

0.2 0.7

0.7 S10 Rail Silos DC #25 PM PM 10 0.4

0.4 1.6

1.6 S11 Packer DC #26 PM PM 10 0.7

0.7 3.0

3.0Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

24 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

S12 Packer DC #27 PM PM 10 0.6

0.6 2.5

2.5 S13 Truck Loadout DC

#28 PM PM 10 0.5

0.5 2.0

2.0

S14 Bins 26 and 27 Dust

Collector PM PM 10 1.1

1.1 4.5

4.5 C1 Clinker Transfer

Tower Baghouse PM PM 10 1.8

1.8 7.6

7.6 C2 Outside Clinker Truck

Unloading PM PM 10 1.3

0.5 5.4

1.9 C3 Outside Clinker

Reclaim Hopper Loading PM PM 10 0.6

0.2 2.3

0.8

C4 Outside Clinker

Storage Pile PM PM 10 0.1

0.1 0.3

0.2 C5 Discharge from

Clinker Reclaim Hopper PM PM 10 0.6

0.2 2.3

0.8

C6 Clinker Railcar and

Truck Hopper Loading PM PM 10 0.2

0.1 0.8

0.3

C7 Clinker Discharge to

Railcar/Truck PM PM 10 0.2

0.1 0.8

0.3 C8 Transfer from Reclaim Belt to #7 Belt PM PM 10 0.6

0.2 2.3

0.8

C9 Transfer to #7 Belt PM PM 10 0.2

0.1 0.6

0.2 C10 Transfer from #7 Belt

to #8 Belt PM PM 10 0.7

0.3 2.8

1.0 C11 Transfer from #8 Belt

to #9 Belt PM PM 10 0.9

0.3 3.6

1.3 C14 B Belt Dust Collector PM PM 10 0.1

0.1 0.4

0.4 C15 Discharge from #2 Clinker Bin to B Belt PM PM 10 0.1

0.1 0.4

0.2 C16 Discharge into #2

Clinker Bin PM PM 10 0.9

0.3 3.6

1.3 C17 Transfer from #9 Belt PM 0.9 3.6Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

25 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

PM 10 0.3 1.3

C18 Clinker Dust Elevator

Collector PM PM 10 0.1

0.1 0.4

0.4 C19 Discharge from #1

Clinker Bin PM PM 10 0.1

0.1 0.4

0.2 C20 Transfer to Belt

Conveyor PM PM 10 0.1

0.1 0.4

0.2 C21 Discharge into #1

Clinker Bin PM PM 10 0.1

0.1 0.4

0.4 C26 West Clinker Silo

Dust Collector PM PM 10 0.8

0.8 3.2

3.2 C27 4A2 Belt Dust

Collector PM PM 10 0.6

0.6 2.7

2.7 C28 Transfer to 4A Belt PM PM 10 0.2

0.1 0.7

0.3 C32 East Clinker Silo Dust

Collector PM PM 10 0.8

0.8 3.2

3.2 C34 West Clinker Tank

Dust Collector PM PM 10 0.2

0.2 0.8

0.8 C36 Discharge into

Clinker Elevator PM PM 10 1.7

0.6 7.4

2.6 C37 Discharge into

Clinker Elevator PM PM 10 0.2

0.1 0.5

0.2 C41 Off-SPEC Bin and Ancillary Equipment Dust Collector PM PM 10 0.4

0.4 1.4

1.4

C42 Clinker Dome Dust

Collector PM PM 10 0.6

0.6 1.9

1.9 C43 Reclaim Belt Dust

Collector PM PM 10 0.2

0.2 0.5

0.5 C44 Off-Spec Bin Dust

Collector PM PM 10 0.17

0.17 0.75

0.75 C45 Clinker Silo Baghouse PM PM 10 0.3

0.3 1.2

1.2 C46 Clinker Silo Baghouse PM PM 10 0.3

0.3 1.2

1.2 R1 Truck Unloading for

Sand/Iron Ore PM PM 10 1.9

0.7 8.0

2.8Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

26 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy R2 Chalk Storage Pile PM PM 10 0.1

0.1 0.3

0.2 R3 Discharge from Chalk

Feeder PM PM 10 0.1

0.1 0.2

0.1 R4 Discharge from

Gypsum Feeder PM PM 10 0.3

0.1 1.0

0.4 R5 Gypsum Storage Pile PM PM 10 0.1

0.1 0.1

0.1 R6 Discharge from Sand/Iron-ore Feeder PM PM 10 0.1

0.1 0.1

0.1 R8 Sand/Iron Ore Storage

Transfer PM PM 10 0.4

0.2 1.5

0.5

R9 Discharge from Emergency Feeder PM PM 10 0.3

0.1 1.0

0.4 R10 Discharge of Gypsum

Belt PM PM 10 0.8

0.3 3.2

1.2 R11 Discharge into

Secondary Crusher PM PM 10 0.1

0.1 0.2

0.1 R12 Secondary Crusher PM PM 10 0.2

0.2 0.8

0.8 R13 Secondary Crusher

Discharge PM PM 10 0.1

0.1 0.2

0.1 R14 Transfer to #2 Belt PM PM 10 0.1

0.1 0.2

0.1 R15 Discharge from

Gypsum Hopper PM PM 10 0.1

0.1 0.2

0.1 R16 Gypsum Truck

Discharge into Hopper PM PM 10 0.8

0.3 3.2

1.2

R17 Long Term Sand Pile PM PM 10 0.1

0.1 0.4

0.2 R18 Iron Ore Storage Pile PM PM 10 0.2

0.1 0.6

0.3 R19 Sand Storage Pile PM PM 10 0.1

0.1 0.1

0.1 R20 Emissions from Haul

Roads PM PM 10 13.1

3.6 47.2

13.4 R22 Portable Crusher PM PM 10 0.3

0.3 1.3

1.0Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

27 EMISSION SUMMARY

Emission Rates Source Number Description Pollutant lb/hr tpy

SO 2 VOC CO NO x 0.2

0.2 0.6 2.5 0.8

0.9 2.3 10.6 R24 Transfer from

Portable Crusher to Main Conveyor PM PM 10 0.3

0.2 1.3

0.5

R25 Emergency Gypsum

Storage Pile PM PM 10 0.1

0.1 0.1

0.1 Q1 Quarry Haul Road PM PM 10 23.5

5.133 102.8

22.5 Q2 Primary Crusher PM PM 10 0.5

0.5 1.9

1.9 Q3 Quarry Belt Turning

Point Transfer from 2N to 1N PM PM 10 0.1

0.1 0.4

0.4

Q4 Transfer from Belt 1N

to Tripper Belt PM PM 10 0.1

0.1 0.4

0.4 Q5 Discharge of Tripper Belt to Chalk Storage PM PM 10 0.1

0.1 0.4

0.4 Q6 Scraper Dumping to

Auxiliary System PM PM 10 0.1

0.1 0.2

0.2 Q7 Hopper 3 Discharge to 1.12 Belt (Auxiliary System) PM PM 10 0.1

0.1 0.2

0.2

Q8 Auxiliary Crusher PM PM 10 1.1

0.5 4.7

2.2 Q9 Discharge of Belt 1 to

Tripper Belt PM PM 10 0.1

0.1 0.2

0.2 *HAPs included in the VOC totals. Other HAPs are n ot included in any other totals unless specifically stated. **Air Contaminants such as ammonia, acetone, and ce rtain halogenated solvents are not VOCs or HAPs. ‡ While it is assumed that these metals are indeed emitted, as they are naturally occurring metals present in the raw materials used to manufacture ce ment, Ash Grove was not able to calculate an emission rate. Ash Grove requests the use of the p articulate matter emission rate of 19.5 lb/hr and 85.41 tpy for Kiln 1 and 2, 27.0 lb/hr and 118. 3 tpy for Kiln 3, as stated in the HWCAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

28 NESHAP (September 29, 1999, 64 FR 52879) preamble b e incorporated as limits for nickel and cobalt.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

29 SECTION III: PERMIT HISTORY

Permit #75-A was issued to Arkansas Cement Corporat ion Foreman Production facilities on or about September 21, 1971. This permit allowed the installation of three "Precipitair" electrostatic precipitators and supporting equipmen t at the existing facility. Proposed emissions were 29.58 lb/hr of particulates.

Permit #75-A (modification) allowed the facility to use coal instead of natural gas as the primary fuel to fire the three cement kilns and to replace the three previously approved electrostatic precipitators. This amendment was issued on Septem ber 15, 1976.

Permit #75-A (modification) was issued on March 26, 1982. This modification allowed Arkansas Cement to install a gravel bed filter to c ontrol particulate discharge from the clinker coolers to replace the multiclone that was being us ed. Permitted emission rates dropped from 475 lb/hr to 25 lb/hr of particulate.

Permit #75-AR-3 was issued on May 27, 1983, and it rescinded the modification issued on March 26, 1982, because the facility decided to ins tall a Fuller fabric filter with heat recovery instead of the gravel bed filter. This modificatio n also included the replacement of part of the clinker handling system and the installation of a b aghouse to control emissions generated at this crossover point. This modification added 1 lb/hr o f particulate emissions.

Permit #75-AR-4 was issued on January 29, 1988. Th is modification changed the name of the facility to Ash Grove Cement Company and consolidat ed the existing emissions sources into one permit and placed restrictions on the use of waste- derived fuel at this facility. This permit allowed emissions of 99.9 lb/hr of TSP, 787 lb/hr o f SO 2 , 39 lb/hr of chlorine, 0.048 lb/hr of lead, and 0.006 lb/hr of chromium.

Permit #75-AR-5 was issued on June 30, 1989. This permit allowed Ash Grove to burn solid hazardous waste in the cement kilns. This permit a llowed emissions of 92.2 lb/hr TSP, 1574 lb/hr of SO 2 , 164.6 lb/hr of HCl, 0.22 lb/hr of lead, and 0.316 lb/hr of chromium.

Permit #75-AR-6 was issued on July 8, 1991. This p ermit allowed Ash Grove to change the outlet nozzles of the ESPs so that each kiln could vent to a single stack. Emissions were not increased due to this modification.

Permit #75-AR-7 was issued on November 13, 1991. T his modification allowed all sources, regardless of size, to be permitted. No changes in operation were made. Emissions consisted of 553 tpy TSP, 6,894.1 tpy SO 2 , 721 tpy HCl, 0.964 tpy lead, and 1.39 tpy chromiu m.

Permit #75-AR-8 was issued on June 15, 1994. This permit covered the installation of CEMS required by the BIF rule. Permit #75-AR-7 was modi fied so that the Air Permit monitoring requirements for SO 2 , NO x , and CO could be satisfied by the new CEMS. This modification also added two product storage silos and related materia ls handling equipment to improve the loading and shipping of finished product, and modified four existing dust control baghouses in a mannerAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

30 that resulted in four new point discharge stacks. The carbon adsorption system on the liquid waste fuel storage tanks was replaced by a liquid n itrogen recovery condenser. These changes did not result in any changes to the emission rates at this facility.

Permit #75-AR-9 was issued on February 11, 1998. T his modification authorized Ash Grove to burn waste tires as fuel. Emission rates for SO 2 were increased and emission rates for NO x and CO were added. Emission totals listed in this perm it were 567 tpy PM 10 , 5,740 tpy SO 2 , 1,183 tpy CO, 9,080 tpy NO x , 0.964 tpy lead, and 3.0 tpy VOC.

Permit 1235-AR-1 was issued on November 7, 1995. T his permit is for the limestone quarry located at the Ash Grove site. The requirements fo r this quarry are being incorporated into this permit. The quarry is permitted to emit 4.3 lb/hr and 19.0 tpy of PM/PM 10

. Permit 75-AOP-R0 was the initial Title V permit iss ued to Ash Grove Cement in Foreman, Arkansas. This permit allowed for several changes at this facility. The portable crusher (SNR22) was permitted for the first time. Ash Grove i nstalled 10 new LWDF tanks and changed the control device to a thermal oxidizer with a carbon adsorption backup system. A clinker storage dome was added to the facility and the ESPs used to control emissions from the kilns were refurbished. Also, the quarry (formerly permitted under permit #1235-AR-1) which supplies limestone for use in the cement kilns was included in this permit. The permit also incorporated the requirements of 40 CFR Part 63, Subpart LLL, Na tional Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturi ng Industry, and 40 CFR Part 63, Subpart EEE, National Emission Standards for Hazardous Air Pollutants From Hazardous Waste Combustors.

Permit 75-AOP-R1 was issued on May 30, 2003. This modification allowed Ash Grove to construct a new cement kiln dust (CKD) handling sys tem (SN-P32, SN- P33, SN-P34, SN-P35 and SN-P36) and remove baghouses P18 and P19. This system allowed the CKD to be pneumatically conveyed across the highway to a new CKD landfill and it also allowed some of the CKD to be recycled to kiln #3. This modificati on resulted in net PM/PM 10 emissions increases of 0.8 lb/hr and 2.6 tpy from the CKD han dling equipment and 4 proposed new fabric filter dust collectors. Also, Ash Grove constructe d a baghouse (SN-C44). This change resulted in an increase of PM/PM 10 emissions of 0.17 lb/hr and 0.75 tpy. Finally, As h Grove Cement Company added 3 drag conveyors and replaced 2 bucke t conveyors and a belt conveyor that were part of the clinker handling system. The two bucket conveyors were the number 6 and number 7 bucket conveyors. The belt conveyor was t he 440 belt. These conveyors are subject to all applicable sections of 40 CFR 63, Subpart LLL. No additional emissions are resulted from this modification.

Permit 75-AOP-R2 was issued on May 4, 2005. This m odification combined and incorporated several requests for minor modifications to the Tit le V permit. This modification allowed for a redesign of the CKD handling system (SN-P32 through SN-P36) and the addition of P37. It was discovered that the system required additional conv eying air. This modification also allowed Ash Grove to install a belt conveyor with integrate d dust collector (SN-P38) to the CKD handling system.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

31 Ash Grove has been given approval to manufacture a new product named DURACEM OW. Manufacture of this product will result in no incre ase in process emissions, however; there will be an increase in fugitive emissions from the haul roads (SN-R20). Finally, the facility replaced a bucket elevator in the Chalk Dryer System with a drag conveyor. No additional emissions occurred as a result of this change.

These changes resulted in net emissions increases o f 1.5 tpy of PM and 3.1 tpy PM 10 emissions from this facility.

Permit 75-AOP-R3 was issued on August 29, 2005. Th is modification allowed Ash Grove to install an additional baghouse for bins 26 and 27. The increased air flow resulting from installation of this new baghouse caused potential emissions increased by 4.5 tpy PM 10 . This modification also corrected typographical errors fo und in 75-AOP-R2.

Permit 75-AOP-R4 was issued on January 12, 2006. H ydrogen chloride emissions were increased to match the emission rates allowed by 40 CFR 63, Subpart EEE. Other HAP emission rates were increased based on recent stack testing. Permitted increases were 597.7 tpy hydrogen chloride, 0.16 tpy acrylonitrile, 1.55 tpy benzene , 0.15 tpy bezidine, 0.11 tpy toluene, 0.16 tpy vinyl chloride. Ash Grove also changed the minimum kVa for each electrostatic precipitator based on data collected during the comprehensive pe rformance test. The new minimum 3-hour rolling average kVa values are 198, 202, and 101 fo r kilns 1, 2, and 3 respectively.

Permit 75-AOP-R5 was issued on May 12, 2006. This modification allowed Ash Grove to install an additional baghouse (SN-P-39) on the 500 ton CKD Bin (SN-P35) and to replace a conveyor belt and add two baghouses (SN-C45 and C-4 6) to the clinker silos. These changes resulted in a permitted emissions increase of 2.4 t py PM/PM 10

.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

32 SECTION IV: SPECIFIC CONDITIONS

SN-P1 Kiln #1

Source Description

This kiln is used to produce the clinker product. It may be fired by coal, natural gas, tire-derived fuel, liquid waste-derived fuel, or solid waste-der ived fuel. This kiln can produce up to 50 tons per hour of clinker. Particulate emissions are con trolled by an electrostatic precipitator with an efficiency of 99%.

Specific Conditions

1. The permittee shall not exceed the emission rates s et forth in the following table. The permittee shall demonstrate compliance with this co ndition by Specific Conditions 5, 6 and 8. [Regulation 19, §19.501 et seq., effective December 19, 2004 and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM 10 19.5 85.4

VOC 9.6 42.1

2. The permittee shall not exceed the emission rates s et forth in the following table. The permittee shall demonstrate compliance with this co ndition by Specific Condition 4. [Regulation 19, §19.501 et seq., effective December 19, 2004 and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

SO 2 849.0 1960.0

CO 172.0 368.0

NO x 889.0 2405.0

3. The permittee shall not exceed the emission rates s et forth in the following table. The permittee shall demonstrate compliance with this co ndition by Specific Condition 8. [Regulation 18, §18.801, effective February 15, 199 9, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

33 Pollutant lb/hr tpy

PM 19.5 85.4

1,1,1-trichloroethane 0.01 0.02

1,1,2,2-tetrachloroethane 0.01 0.03

1,1,2-trichloroethane 0.01 0.04

1,1-dichloroethane 0.01 0.02

1,1-dichloroethene 0.16 0.69

1,2,4-trichlorobenzene 0.08 0.35

1,2-dichloroethane 0.01 0.05

1,2-dichloropropane 0.01 0.04

1,2-epoxybutane 0.01 0.01

1,3-butadiene 0.02 0.07

1,4-dichlorobenzene 0.19 0.18

1,4-phenylene-diamine 0.01 0.03

2,4,5-trichlorophenol 0.01 0.03

2,4,6-trichlorophenol 0.01 0.05

2,4-dinitrophenol 0.03 0.11

2,4-dinitrotoluene 0.02 0.01

2-butanone 0.21 0.91

3,3-dichlorobenzidine 0.01 0.04

3,3-dimethoxybenzidine 0.01 0.04

4-methyl-2-pentanone 0.02 0.09

4-nitrophenol 0.02 0.07

Acrylonitrile 0.03 0.11

allyl chloride 0.19 0.84

Aniline 0.005 0.02

Antimony 8.80 38.5Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

34 Pollutant lb/hr tpy

Arsenic 0.00258 0.00112

Benzene 0.22 0.95

Benzidine 0.02 0.07

Beryllium 0.00028 0.00123

bis(2-chloroethyl)ether 0.01 0.03

bis(2-ethylhexyl)phthalate 0.004 0.02

Bromodichloromethane 0.01 0.02

Bromoform 0.01 0.03

Bromomethane 0.26 1.15

Cadmium .0307 0.134

carbon disulfide 0.08 0.37

carbon tetrachloride 0.01 0.02

Chlorine 0.00162 0.00780

Chlorobenzene 0.17 0.73

Chloroethane 1.05 4.59

Chloroform 0.01 0.06

Chloromethane 0.12 0.51

Chromium 0.00578 0.0253

cis-1,3-dichloropropene 0.01 0.05

cobalt _ 19.5 85.41

Cumene 0.01 0.03

Dimethylphthalate 0.002 0.01

ethyl acrylate 0.11 0.46

Ethylbenzene 0.09 0.38

ethylene dibromide 0.01 0.01

Hexachlorobenzene 0.01 0.02

Hexachlorobutadiene 0.01 0.03Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

35 Pollutant lb/hr tpy Hexachlorocyclopentadiene 0.01 0.03

Hexachloroethane 0.01 0.04

hydrogen chloride 50.0 219.0

Hydroquinone 0.01 0.05

Iodomethane 0.03 0.13

Lead 0.06 0.263

Manganese 0.0430 0.188

Mercury 0.0694 0.304

methyl methacrylate 0.01 0.05

methylene chloride 2.24 9.80

Naphthalene 0.29 1.29

n-hexane 0.06 0.27

nickel _ 19.5 85.41

Nitrobenzene 0.005 0.02

N-nitrosoddiphenylamine 0.03 0.01

N-nitrosomorpholine 0.01 0.04

ortho-anisidine 0.01 0.04

ortho-toluidine 0.04 0.02

o-xylene 0.08 0.35

Pentachlorophenol 0.02 0.07

Phenol 0.05 0.22

Selenium 0.0075 0.0329

Styrene 0.03 0.12

tert-butyl methyl ether 0.01 0.02

Tetrachloroethene 0.06 0.020.28

Toluene 0.04 0.19

trans-1,3-dichloropropene 0.01 0.05Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

36 Pollutant lb/hr tpy

Trichloroethene 0.06 0.28

vinyl acetate 0.01 0.02

vinyl bromide 0.01 0.06

vinyl chloride 0.44 1.91

xylene 0.21 0.92

‡ While it is assumed that these metals are indeed emitted, as they are naturally occurring metals present in the raw materials used to manufacture ce ment, Ash Grove was not able to calculate an emission rate. Ash Grove requests the use of the p articulate matter emission rate as limits for nickel and cobalt.

4. The permittee shall maintain continuous emission mo nitors (CEMs) to record SO 2 , CO, and NO x emissions at this source. These CEMs shall be ope rated in accordance with all applicable conditions of the Department's Continuou s Emission Monitoring Systems Conditions as found in Appendix A of this permit. [Regulation 19, §19.703, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

5. The permittee shall operate the electrostatic preci pitators used to control particulate emissions at this source at a minimum kVA of electr ical power input to the electrostatic precipitator. This minimum kVA rating shall be the sum of the kVA levels for the individual field of the ESP and shall be the level determined by the most recent passing stack test performed. Ash Grove shall notify the D epartment, in writing, when the kVA level is changed. This notification shall include a copy of the test results and the new value for the rating. Compliance shall be demonstr ated through compliance with Specific Condition #10. [Regulation 19, §19.705 of Regulati on 19, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 and 40 C FR Part 70.6]

6. The permittee shall not produce more than 37,200 to ns of clinker per month at this source. Compliance shall be demonstrated through c ompliance with the record keeping requirements set forth in Specific Condition 7. [R egulation 19, §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-30 4 and §8-4-311 and 40 CFR Part 70.6]

7. The permittee shall maintain records of the amount of clinker produced at this source. These records shall be kept on a monthly basis and updated by the 15th day of the month following the month to which the records pertain. A rolling twelve month total of these amounts shall be kept on site and be made available to Department personnel upon request. A report of these records shall be submit ted to the Department in accordance with General Provision 7. [Regulation 19, §19.705, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, and CFR Part 52, Subp art E]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

37 8. The permittee shall not exceed the feed rates set f orth in the following table. Compliance shall be demonstrated through compliance with Speci fic Condition 9. [Regulation 19, §19.705, Regulation 18, §18.1004, A.C.A. §8-4-203 a s referenced by A.C.A. §8-4-304 and §8-4-311, and 40 CFR Part 70.6]

Fuel Monthly Amount

Natural Gas 294.6 MMft 3

Coal 11,160 ton

Tire-derived Fuel 1,488 ton

LWDF 11,160 ton

SWDF 3,720 ton

LWDF = Liquid Waste-derived Fuel

SWDF = Solid Waste-derived Fuel

9. The permittee shall maintain records of the types a nd amounts of fuel used at this source. These records shall be kept on a monthly basis and updated by the 15th day of the month following the month to which the records pertain. A rolling twelve month total of these amounts shall be kept on site and be made available to Department personnel upon request. A report of these records shall be submit ted to the Department in accordance with General Provision #7. [§19.705 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 an d §8-4-311]

10. The permittee shall record the sum of the electrica l power input in kilovolt-amperes (kVA) to each field of the electrostatic precipitat or used to control particulate emissions from this source. A reading of the electrical powe r input to each field of the electrostatic precipitator shall be taken a minimum of once per d ay of operation. These records shall be kept on site and made available to Department pe rsonnel upon request. [§19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A .§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

11. Visible emissions from this source shall not exceed 20% opacity. No later than September 30, 2002, compliance shall be demonstrate d with a continuous opacity monitor. Until installation and certification of t he continuous opacity monitor occurs, the permittee shall continue to demonstrate compliance through compliance with Plantwide Condition #10. [§19.703 of Regulation 19, 40 CFR P art 52, Subpart E, 40 CFR Part 63.1209(a)(1), and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

38 SN-P2 Kiln #2

Source Description

This kiln is used to produce the clinker product. It may be fired by coal, natural gas, tire-derived fuel, liquid waste-derived fuel, or solid waste-der ived fuel. This kiln can produce up to 50 tons per hour of clinker. Particulate emissions are con trolled by an electrostatic precipitator with an efficiency of 99%.

Specific Conditions

12. The permittee shall not exceed the emission rates s et forth in the following table. The permittee shall demonstrate compliance with this co ndition by Specific Conditions 16, 17 and 18. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM 10 19.5 85.4

VOC 9.6 42.1

13. The permittee shall not exceed the emission rates s et forth in the following table. The permittee shall demonstrate compliance with this co ndition by Specific Condition 15. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

SO 2 753.0 1690.0

CO 152.0 333.0

NO x 882.0 2450.0

14. The permittee shall not exceed the emission rates s et forth in the following table. The permittee shall demonstrate compliance with this co ndition by Specific Condition 18. [Regulation 18, §18.801, and A.C.A. §8-4-203 as ref erenced by A.C.A. §8-4-304 and §8- 4-311]

Pollutant lb/hr tpy

PM 19.5 85.4

1,1,1-trichloroethane 0.01 0.02

1,1,2,2-tetrachloroethane 0.01 0.03Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

39 Pollutant lb/hr tpy

1,1,2-trichloroethane 0.01 0.04

1,1-dichloroethane 0.01 0.02

1,1-dichloroethene 0.16 0.69

1,2,4-trichlorobenzene 0.08 0.35

1,2-dichloroethane 0.01 0.05

1,2-dichloropropene 0.01 0.02

1,2-epoxybutane 0.01 0.01

1,3-butadiene 0.02 0.07

1,4-dichlorobenzene 0.19 0.18

1,4-phenylene-diamine 0.01 0.03

2,4,5-trichlorophenol 0.01 0.03

2,4,6-trichlorophenol 0.01 0.05

2,4-dinitrophenol 0.03 0.11

2,4-dinitrotoluene 0.02 0.01

2-butanone 0.21 0.91

3,3-dichlorobenzidine 0.01 0.04

3,3-dimethoxybenzidine 0.01 0.04

4-methyl-2-pentanone 0.02 0.09

4-nitrophenol 0.02 0.07

acrylonitrile 0.03 0.11

allyl chloride 0.19 0.84

aniline 0.005 0.02

antimony 8.80 38.5

arsenic 0.00258 0.00112

benzene 0.22 0.95

benzidine 0.02 0.07

beryllium 0.00028 0.00123Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

40 Pollutant lb/hr tpy bis(2-chloroethyl)ether 0.01 0.03

bis(2-ethylhexyl)phthlate 0.004 0.02

bromodichloromethane 0.01 0.02

bromoform 0.01 0.03

bromomethane 0.26 1.15

cadmium 0.0307 0.134

carbon disulfide 0.08 0.37

carbon tetrachloride 0.01 0.02

chlorine 0.00162 0.00780

chlorobenzene 0.17 0.73

chloroethane 1.05 4.59

chloroform 0.01 0.06

chloromethane 0.12 0.51

chromium 0.00578 0.0253

cis-1,3-dichloropropene 0.01 0.05

cobalt _ 19.5 85.41

cumene 0.01 0.03

dimethylphthalate 0.002 0.01

ethyl acrylate 0.11 0.46

ethylbenzene 0.09 0.38

ethylene dibromide 0.01 0.01

hexachlorobenzene 0.01 0.02

hexachlorobutadiene 0.01 0.03

hexachlorocyclopentadiene 0.01 0.03

hexachloroethane 0.01 0.04

hydrogen chloride 50.0 219.0

hydroquinone 0.01 0.05Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

41 Pollutant lb/hr tpy

iodomethane 0.03 0.13

manganese 0.0430 0.188

lead 0.06 0.263

mercury 0.0694 0.304

methyl methacrylate 0.01 0.05

methylene chloride 2.24 9.80

naphthalene 0.29 1.29

n-hexane 0.06 0.27

nickel _ 19.5 85.41

nitrobenzene 0.005 0.02

N-nitrosoddiphenylamine 0.03 0.01

N-nitrosomorpholine 0.01 0.04

ortho-anisidine 0.01 0.04

ortho-toluidine 0.04 0.02

o-xylene 0.08 0.35

pentachlorophenol 0.02 0.07

phenol 0.05 0.22

selenium 0.0075 0.0329

styrene 0.03 0.12

tert-butyl methyl ether 0.01 0.02

tetrachloroethene 0.06 0.28

toluene 0.04 0.19

trans-1,3-dichloropropene 0.01 0.05

trichloroethene 0.06 0.28

vinyl acetate 0.01 0.02

vinyl bromide 0.01 0.06

vinyl chloride 0.44 1.91Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

42 Pollutant lb/hr tpy xylene 0.21 0.92

‡ While it is assumed that these metals are indeed emitted, as they are naturally occurring metals present in the raw materials used to manufacture ce ment, Ash Grove was not able to calculate an emission rate. Ash Grove requests the use of the p articulate matter emission rate as limits for nickel and cobalt.

15. The permittee shall maintain continuous emission mo nitors (CEMs) to record SO 2 , CO, and NO x emissions at this source. These CEMs shall be ope rated in accordance with all applicable conditions of the Department's Continuou s Emission Monitoring Systems Conditions as found in Appendix A of this permit. [§19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenc ed by A.C.A. §8-4-304 and §8-4- 311]

16. The permittee shall operate the electrostatic preci pitators used to control particulate emissions at this source at a minimum kVA of electr ical power input to the electrostatic precipitator. This minimum kVA rating shall be the sum of the kVA levels for the individual field of the ESP and shall be the level determined by the most recent passing stack test performed. Ash Grove shall notify the D epartment, in writing, when the kVA level is changed. This notification shall include a copy of the test results and the new value for the rating. Compliance shall be demonstr ated through compliance with Specific Condition #21. [§19.705 of Regulation 19, A.C.A. § 8-4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311 and 40 CFR Part 70.6]

17. The permittee shall not produce more than 37,200 to ns of clinker per month at this source. Compliance shall be demonstrated through c ompliance with the record keeping requirements set forth on Specific Condition 19. [ §19.705 of Regulation 19, A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 and 40 CFR Part 70.6]

18. The permittee shall not exceed the feed rates set f orth in the following table. Compliance shall be demonstrated through compliance with Speci fic Condition 20. [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311 and 40 CFR Part 70.6]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

43 Fuel Monthly Amount

Natural Gas 294.6 MMft 3

Coal 11,160 ton

Tire-derived Fuel 1,488 ton

LWDF 11,160 ton

SWDF 3,720 ton

LWDF = Liquid Waste-derived Fuel

SWDF = Solid Waste-derived Fuel

19. The permittee shall maintain records of the amount of clinker produced at this source. These records shall be kept on a monthly basis and updated by the 15th day of the month following the month to which the records pertain. A rolling twelve month total of these amounts shall be kept on site and be made available to Department personnel upon request. A report of these records shall be submit ted to the Department in accordance with General Provision #7. [§19.705 of Regulation 19 and 40 CFR Part 52, Subpart E]

20. The permittee shall maintain records of the types a nd amounts of fuel used at this source. These records shall be kept on a monthly basis and updated by the 15th day of the month following the month to which the records pertain. A rolling twelve month total of these amounts shall be kept on site and be made available to Department personnel upon request. A report of these records shall be submit ted to the Department in accordance with General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as refe renced by A.C.A. §8-4-304 and §8- 4-311]

21. The permittee shall record the sum of the electrica l power input in kilovolt-amperes (kVA) to each field of the electrostatic precipitat or used to control particulate emissions from this source. A reading of the electrical powe r input to each field of the electrostatic precipitator shall be taken a minimum of once per d ay of operation. These records shall be kept on site and made available to Department pe rsonnel upon request. [§19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A . §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

22. Visible emissions from this source shall not exceed 20% opacity. No later than September 30, 2002, compliance shall be demonstrate d with a continuous opacity monitor. Until installation and certification of t he continuous opacity monitor occurs, the permittee shall continue to demonstrate compliance through compliance with Plantwide Condition #10. [§19.703 of Regulation 19, 40 CFR P art 52, Subpart E, 40 CFR Part 63.1209(a)(1), and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

44 SN-P3 Kiln #3

Source Description

This kiln is used to produce the clinker product. It may be fired by coal, natural gas, tire-derived fuel, liquid waste-derived fuel, or solid waste-der ived fuel. This kiln can produce up to 70 tons per hour of clinker. Particulate emissions are con trolled by an electrostatic precipitator with an efficiency of 99%.

Specific Conditions

23. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Conditions 27, 28, and 29. [§19.501 et seq. Regulation 19 and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM 10 27.0 118.3

VOC 13.44 58.87

24. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 26. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr Tpy SO 2 961.0 2090.0

CO 220.0 482.0

NO x 1568.0 4231.0

25. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 29. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 27.0 118.3

1,1,1-trichloroethane 0.01 0.01 1,1,2,2-tetrachloroethane 0.01 0.04 1,1,2-trichloroethane 0.01 0.03 1,1-dichloroethane 0.01 0.01Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

45 Pollutant lb/hr tpy

1,1-dichloroethene 0.01 0.02 1,2,4-trichlorobenzene 0.01 0.02 1,2-dichloroethane 1.67 7.32 1,2-dichloropropane 0.01 0.04 1,2-epoxybutane 0.07 0.3 1,3-butadiene 0.49 2.13 (cis, trans)1,3- dichloropropene 0.03 0.13

1,4-dichlorobenzene 0.01 0.01 1,4-phenylene-diamine 0.06 0.26 2,4,5-trichlorophenol 0.01 0.02 2,4,6-trichlorophenol 0.17 0.76 2,4-dinitrophenol 0.01 0.03 2,4-dinitrotoluene 0.01 0.01 2-butanone 0.2 0.87 3,3-dichlorobenzidine 0.01 0.01 3,3-dimethoxybenzidine 0.01 0.02 4-methyl-2-pentanone 0.01 0.03 4-dinitrophenol 0.01 0.03 acrylonitrile 0.03 0.14 allyl chloride 0.15 0.66 Aniline 0.01 0.02 antimony 12.9 56.6 arsenic 0.0005 0.00219 benzene 0.37 1.63 benzidine 0.02 0.07 beryllium 0.00007 0.000274 bis(2-chloroethyl)ether 0.01 0.02 bis(2-ethylhexyl)phthlate 0.74 3.24 bromodichloromethane 0.02 0.09 bromoform 0.01 0.06 bromomethane 0.26 1.13 cadmium 0.00373 0.0163 carbon disulfide 0.01 0.01 carbon tetrachloride 0.01 0.02 chlorine 1.34 5.85 chlorobenzene 0.01 0.06 chloroethane 0.01 0.01 chloroform 0.22 0.95 chloromethane 1.95 8.53 chromium 0.00403 0.0177 Cobalt  27.0 118.3Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

46 Pollutant lb/hr tpy

cumene 0.01 0.04 dimethylphthalate 0.01 0.01 ethyl acrylate 0.13 0.58 ethylbenzene 0.01 0.05 ethylene dibromide 0.01 0.02 hexachlorobenzene 0.01 0.01 hexachlorobutadiene 0.01 0.03 hexachlorocyclopentadiene 0.01 0.02 hexachloroethane 0.01 0.02 hydrogen chloride 71.0 311.0 hydroquinone 0.02 0.07 iodomethane 0.01 0.03 Lead 0.10 0.438 m/p xylene 0.43 1.89 manganese 0.0602 0.264 mercury 0.0759 0.332 methyl methacrylate 0.01 0.05 methylene chloride 0.24 1.03 naphthalene 0.38 1.68 n-hexane 0.07 0.33 nickel 27.0 118.3 nitrobenzene 0.02 0.07 N-nitrosoddiphenylamine 0.01 0.01 N-nitrosomorpholine 0.01 0.05 ortho-anisidine 0.01 0.03 ortho-toluidine 0.01 0.01 o-xylene 0.2 0.86 pentachlorophenol 0.01 0.01 phenol 0.09 0.38 selenium 0.0105 0.046 styrene 0.01 0.02 tert-butyl methyl ether 0.01 0.01 tetrachloroethene 0.01 0.02 toluene 0.04 0.18 trans-1,3-dichloropropene 0.01 0.02 trichloroethene 0.01 0.03 vinyl acetate 0.01 0.02 vinyl bromide 0.11 0.49 vinyl chloride 0.03 0.14

‡ While it is assumed that these metals are indeed emitted, as they are naturally occurring metals present in the raw materials used to manufacture ce ment, Ash Grove was not able to calculate anAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

47

emission rate. Ash Grove requests the use of the p articulate matter emission rate of 19.5 lb/hr and 85.41 tpy for Kiln 1 and 2, 27.0 lb/hr and 118.3 tp y for Kiln 3, as stated in the HWC NESHAP (September 29, 1999, 64 FR 52879) preamble be incor porated as limits for nickel and cobalt.

26. The permittee shall maintain continuous emission mo nitors (CEMs) to record SO 2 , CO, and NO x emissions at this source. These CEMs shall be ope rated in accordance with all applicable conditions of the Department's Continuou s Emission Monitoring Systems Conditions as found in Appendix A of this permit. [§19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenc ed by A.C.A. §8-4-304 and §8-4- 311]

27. The permittee shall operate the electrostatic preci pitators used to control particulate emissions at this source at a minimum kVA of electr ical power input to the electrostatic precipitator. This minimum kVA rating shall be the sum of the kVA levels for the individual field of the ESP and shall be the level determined by the most recent passing stack test performed. Ash Grove shall notify the D epartment, in writing, when the kVA level is changed. This notification shall include a copy of the test results and the new value for the rating. Compliance shall be demonstr ated through compliance with Specific Condition 32. [§19.705 of Regulation 19, A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311 and 40 CFR Part 70.6]

28. The permittee shall not produce more than 52,080 to ns of clinker per month at this source. Compliance shall be demonstrated through c ompliance with the record keeping requirements set forth in Specific Condition 30. [ §19.705 of Regulation 19, A.C.A. §8-4- 203 as referenced by A.C.A. §8-4-304 and §8-4-311 a nd 40 CFR Part 70.6]

29. The permittee shall not exceed the feed rates set f orth in the following table. Compliance shall be demonstrated through compliance with Speci fic Condition 31. [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311 and 40 CFR Part 70.6]

Fuel Monthly Amount

Natural Gas 412.2 MMft 3

Coal 18,600 tons

Tire-derived Fuel 2,231 ton

LWDF 11,160 ton

SWDF 3,720 ton

LWDF = Liquid Waste-derived Fuel

SWDF = Solid Waste-derived FuelAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

48 30. The permittee shall maintain records of the amount of clinker produced at this source. These records shall be kept on a monthly basis and updated by the 15th day of the month following the month to which the records pertain. A rolling twelve month total of these amounts shall be kept on site and be made available to Department personnel upon request. A report of these records shall be submit ted to the Department in accordance with General Provision# 7. [§19.705 of Regulation 19 and 40 CFR Part 52, Subpart E]

31. The permittee shall maintain records of the types a nd amounts of fuel used at this source. These records shall be kept on a monthly basis and updated by the 15th day of the month following the month to which the records pertain. A rolling twelve month total of these amounts shall be kept on site and be made available to Department personnel upon request. A report of these records shall be submitt ed to the Department in accordance with General Provision 7. [§19.705 of Regulation 1 9, §18.1004 of Regulation 18, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as refe renced by A.C.A. §8-4-304 and §8- 4-311]

32. The permittee shall record the sum of the electrica l power input in kilovolt-amperes (kVA) to each field of the electrostatic precipitat or used to control particulate emissions from this source. A reading of the electrical powe r input to each field of the electrostatic precipitator shall be taken a minimum of once per d ay of operation. These records shall be kept on site and made available to Department pe rsonnel upon request. [§19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A . §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

33. Visible emissions from this source shall not exceed 20% opacity. No later than September 30, 2002, compliance shall be demonstrate d with a continuous opacity monitor. Until installation and certification of t he continuous opacity monitor occurs, the permittee shall continue to demonstrate compliance through compliance with Plantwide Condition #9. [§19.703 of Regulation 19, 40 CFR Pa rt 52, Subpart E, 40 CFR Part 63.1209(a)(1), and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

49 Transfer points for Pyroprocessing Unit

Source Description

These are various transfer points associated with t he pyroprocessing unit. Emissions from these points are considered uncontrolled and were calcula ted based on equipment maximum capacity using the formula contained in AP-42 §13.2.4-3 as f ound in Appendix B.

Specific Conditions

34. The permittee shall not exceed the emission limits set forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

Source Source Name Pollutant lb/hr tpy

P4 Discharge into Coal Mill #1 PM 10 0.1 0.1

P5* Discharge from Kiln #1

to #1 Bucket Conveyor PM 10 0.2 0.3

P7 Discharge into Coal Mill #2 PM 10 0.1 0.1

P8* Discharge from Kiln #2

to #2 Bucket Conveyor PM 10 0.1 0.3

P9 Discharge into Coal Mill #3 PM 10 0.1 0.1

P10* Discharge from Kiln #3

to #3 Bucket Conveyor PM 10 0.2 0.8

P11* Discharge from Bin #48 PM 10 0.1 0.1

P12* Discharge from Bin #48 PM 10 0.1 0.1

P13* Discharge from Bin #47 PM 10 0.1 0.1

P15* Baghouse Discharge to

#2 Bucket Conveyor PM 10 0.2 0.6

P16* Baghouse Discharge to

#3 Bucket Conveyor PM 10 0.2 0.6

P20* Truck Loading of CKD PM 10 0.1 0.1

P21 Truck Unloading of CKD PM 10 0.1 0.1

P22 Trailer Unloading of CKD PM 10 0.1 0.1

P24 Transfer from

Main Coal Pile PM 10 0.1 0.2

P32* 1500 Ton CKD Storage Bin PM 10 0.4 1.6

P33* CKD Handling Screw

Conveyor Bin Vent PM 10 0.1 0.4Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

50 Source Source Name Pollutant lb/hr tpy

P34* Kiln #3 Dust Scoop Bin Vent PM 10 0.2 0.5

P35* P39 1 CKD Handling 500 Ton Silo

Baghouse PM 10 0.3 1.1

P36* Truck Loading of CKD

(North of Hwy. 108) PM 10 0.1 0.3

P37* 1500 ton CKD Storage Bin PM 10 0.3 1.2

P38* CKD Truck Loadout PM 10 0.2 0.6

*Subject to 40 CFR 63, Subpart LLL 1. These baghouses are interlocked so only one may operate at any time.

35. The permittee shall not exceed the emission rates s et forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§18.801 of Regulation 18 and A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311]

Source Source Name Pollutant lb/hr tpy P4 Discharge into Coal Mill #1 PM 0.1 0.2 P5* Discharge from Kiln #1

to #1 Bucket Conveyor PM 0.2 0.8

P7 Discharge into Coal Mill #2 PM 0.1 0.1 P8* Discharge from Kiln #2

to #2 Bucket Conveyor PM 0.2 0.8

P9 Discharge into Coal Mill #3 PM 0.1 0.1 P10* Discharge from Kiln #3

to #3 Bucket Conveyor PM 0.6 2.3

P11* Discharge from Bin #48 PM 0.1 0.1 P12* Discharge from Bin #48 PM 0.1 0.1

P13* Discharge from Bin #47 PM 0.1 0.1 P15* Baghouse Discharge to

#2 Bucket Conveyor PM 0.4 1.6

P16* Baghouse Discharge to

#3 Bucket Conveyor PM 0.4 1.6

P20* Truck Loading of CKD PM 0.1 0.2 P21 Truck Unloading of CKD PM 0.1 0.2 P22 Trailer Unloading of CKD PM 0.1 0.2

P24 Transfer from

Main Coal Pile PM 0.2 0.6Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

51 Source Source Name Pollutant lb/hr tpy P32* 1500 Ton CKD Storage Bin PM 0.4 1.6 P33* CKD Handling Screw

Conveyor Bin Vent PM 0.1 0.4

P34* Kiln #3 Dust Scoop Bin Vent PM 0.2 0.5

P35* P39* CKD Handling 500 Ton Silo

Baghouses 1 PM 0.3 1.1

P36* Truck Loading of CKD

(North of Hwy. 108) PM 0.1 0.1

P37* 1500 ton CKD Storage Bin PM 0.3 1.2

P38* CKD Truck Loadout PM 0.2 0.6

*Subject to 40 CFR 63, Subpart LLL 1. These baghouses are interlocked so only one may operate at any time.

36. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

37. SN-P21 and SN-P22 shall be operated so that unneces sary air contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at SN-P21 and SN-P22 and the recording of the findings of the visual observations in the facility record. These records shall be kept on site and made available to Department personnel upon request. [§ 18.901 of Regulation 18]

38. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

39. Visual emissions for SN-P4, P7, P9, and P24 shall n ot exceed 20 percent opacity. The permittee shall demonstrate compliance with this sp ecific condition by conducting a visible opacity observation of the source at least once each calendar week in which the source operates, and keep a record of these observa tions. If visible emissions appear to exceed 20 percent opacity, the permittee shall take corrective action, and perform and record the observation again. If visible emissions still appear to exceed 20 percent opacity, the permittee shall conduct a six-minute o pacity reading in accordance with theAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

52 EPA reference method No. 9. The records of visible emission observations and results of any method No. 9 reading shall be kept on site for five years and made available to Department personnel upon request. [Regulation 19 §19.503 and 40 CFR 52, Subpart E]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

53 SN-P6 3 Clinker Coolers Baghouse

Source Description

This baghouse controls particulate emissions from t he clinker coolers. Efficiency is assumed to be 99%.

Specific Conditions

40. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 42. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr Tpy

PM 10 25.0 110.0

41. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 42. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 25.0 110.0

42. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

43. Emissions from this clinker cooler shall not contai n particulate matter in excess of 0.050 kg per Mg (0.l lb per ton) of feed (dry basis) to t he kiln and visible emissions from this source shall not exceed 10% opacity. Pursuant to 40 CFR 63.1350(d)(1), compliance shall be demonstrated with a continuous opacity mon itor. [40 CFR 63.1345, §19.503 of Regulation 19 and 40 CFR 52, Subpart E]

44. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

54 SN-P17 Bin #49 Sock Filter

Source Description

This filter controls particulate emissions resultin g from material transfer in and out of this bin. Efficiency is assumed to be 95%.

Specific Conditions

45. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 47. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr Tpy

PM 10 0.5 1.9

46. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 47. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.5 1.9

47. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by §8-4- 304 and §8-4-311]

48. Emissions from this source shall not exceed 10% opa city. This source is subject to all applicable requirements listed in Plantwide Conditi on #12. Compliance with the opacity standard shall be demonstrated through compliance w ith Plantwide Condition #15. [§19.304 of Regulation 19 and 40 CFR Part 63, Subpa rt LLL, National Emission Standards for Hazardous Air Pollutants From the Por tland Cement Manufacturing Industry ]

49. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

55 [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

56 SN-P23 CKD Pile

Source Description

This storage pile has a total area of 40 acres. Em issions from the cement kiln dust pile are controlled by surface watering.

Specific Conditions

50. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 52. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr Tpy

PM 10 0.6 2.6

51. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 52. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 1.2 5.2

52. The permittee shall maintain the area of this stora ge pile at or below 40 acres. Compliance shall be demonstrated by surveying the b oundary perimeter of this pile. The permittee shall demarcate and record the perimeter of this pile with a global positioning system (GPS) instrument. A minimum of once per cal endar year, the permittee shall certify in the facility record that the footprint o f the pile is within the confines of the established perimeter. These records shall be kept on site and made available to Department personnel upon request. A copy of these records shall be submitted in accordance with General Provision 7. [§19.705 of R egulation 19, §18.1004 of Regulation 18, 40 CFR Part 70.6 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

53. This source shall be operated so that unnecessary a ir contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at this source in accordance with EPA Me thod 22. The permittee shall maintain records of the observations performed. Th ese records shall be maintained on site and made available to Department personnel upo n request. A copy of these records shall be submitted in accordance with General Provi sion #7. [§18.901 of Regulation 18]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

57

Uncontrolled Transfer points in the Mill Area

Source Description

The Mill area consists of many different pieces of equipment. The uncontrolled emission rates were found based on equipment maximums using a form ula contained in AP-42 page 13.2.4-3 as found in Appendix B.

Specific Conditions

54. The permittee shall not exceed the emission limits set forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

SN Source Name Pollutant lb/hr tpy M3 Gypsum Discharge into

Finish Mill #4 PM 10 0.1 0.1

M4 Gypsum Discharge to

Gypsum Elevator PM 10 0.1 0.1

M9 Tripper Discharge into Bins PM 10 0.1 0.1

M10 Discharge from Bin #45 PM 10 0.1 0.1

M11 Discharge into Bin #43 PM 10 0.1 0.4

M12 Discharge from Bin #44 PM 10 0.1 0.2

M13 Discharge from Bin #43 PM 10 0.1 0.4

M14 Transfer to B Belt PM 10 0.1 0.4

M15 Transfer to B Belt PM 10 0.1 0.1

M21 Discharge from Bin #42 PM 10 0.1 0.1

M22 Discharge from Bin #41 PM 10 0.1 0.1

M23 Transfer from Bin #41 PM 10 0.1 0.1

M24 Discharge from Bin #40 PM 10 0.1 0.1

M25 Discharge from D Belt into

Chalk Dryer PM 10 0.1 0.2

M26 Transfer to D Belt PM 10 0.1 0.1

M27 Discharge from Bin #39 PM 10 0.1 0.2

M28 Transfer to Dry Feed Belt PM 10 0.1 0.2

M29 Transfer to Dry Feed Belt PM 10 0.1 0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

58

SN Source Name Pollutant lb/hr tpy M30 Transfer from #1 Clinker Bin

to Dry Feed Belt PM 10 0.2 0.6

M31 Discharge from Bin #38 PM 10 0.1 0.1

M32 Discharge from Bin #38 PM 10 0.1 0.1

M33 Discharge from Bin #37 PM 10 0.1 0.1

M34 Transfer to A1 Belt PM 10 0.1 0.1

M35 Discharge from Bin #36 PM 10 0.1 0.1

M36 Transfer to A1 Belt PM 10 0.1 0.1

M37 Transfer to A1 Belt PM 10 0.1 0.1

M38 Transfer to A1 Belt PM 10 0.1 0.1

M39 Discharge Into Raw Mill #3 PM 10 0.1 0.2

M40 Discharge from Gypsum

Elevator into Feed Mill #4 PM 10 0.1 0.1

M46 Transfer from Limestone

Feeder to Belt Conveyor PM 0.1 0.2

55. The permittee shall not exceed the emission rates s et forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§18.801 of Regulation 18 and A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311]

SN Source Name Pollutant lb/hr tpy M3 Gypsum Discharge into

Finish Mill #4 PM 0.1 0.1

M4 Gypsum Discharge to

Gypsum Elevator PM 0.1 0.1

M9 Tripper Discharge into Bins PM 0.1 0.2

M10 Discharge from Bin #45 PM 0.1 0.1

M11 Discharge into Bin #43 PM 0.3 1.0

M12 Discharge from Bin #44 PM 0.1 0.4

M13 Discharge from Bin #43 PM 0.3 1.0

M14 Transfer to B Belt PM 0.3 1.0

M15 Transfer to B Belt PM 0.1 0.1

M21 Discharge from Bin #42 PM 0.1 0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

59

SN Source Name Pollutant lb/hr tpy M22 Discharge from Bin #41 PM 0.1 0.1

M23 Transfer from Bin #41 PM 0.1 0.1

M24 Discharge from Bin #40 PM 0.1 0.1

M25 Discharge from D Belt into

Chalk Dryer PM 0.2 0.6

M26 Transfer to D Belt PM 0.1 0.1

M27 Discharge from Bin #39 PM 0.1 0.4

M28 Transfer to Dry Feed Belt PM 0.1 0.4

M29 Transfer to Dry Feed Belt PM 0.1 0.1

M30 Transfer from #1 Clinker Bin

to Dry Feed Belt PM 0.4 1.6

M31 Discharge from Bin #38 PM 0.1 0.1

M32 Discharge from Bin #38 PM 0.1 0.1

M33 Discharge from Bin #37 PM 0.1 0.1

M34 Transfer to A1 Belt PM 0.1 0.1

M35 Discharge from Bin #36 PM 0.1 0.1

M36 Transfer to A1 Belt PM 0.1 0.1

M37 Transfer to A1 Belt PM 0.1 0.1

M38 Transfer to A1 Belt PM 0.1 0.1

M39 Discharge Into Raw Mill #3 PM 0.2 0.5

M40 Discharge from Gypsum

Elevator into Feed Mill #4 PM 0.1 0.1

M46 Transfer from Limestone

Feeder to Belt Conveyor PM 0.2 0.5

56. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

57. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sourcesAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

60 for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

61 SN-M16 #2 Finish Mill Baghouse

Source Description

This baghouse controls emission from the finish mil l. Emissions are estimated to be 0.01 grains/ft 3 . Efficiency is assumed to be 99%.

Specific Conditions

58. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 60. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.7 3.0

59. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 60. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.7 3.0

60. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

61. Emissions from this source shall not exceed 10% opa city. This source is subject to all applicable requirements listed in Plantwide Conditi on #12. Compliance with the opacity standard shall be demonstrated through daily visibl e emissions observations using Method 22, corrective action and subsequent visible emissions observations in accordance with 40 CFR 63.1350(e). The visible obs ervation requirement will be superseded if the permittee chooses the use of a co ntinuous opacity monitor or bag leak detection system in place of the visible observatio ns in accordance with 40 CFR 63.1350(m). The permittee shall notify the Departm ent, in writing, of the date a COM or BLDS is put into service at this facility. [§19.30 4 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollu tants From the Portland Cement Manufacturing Industry ]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

62 62. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

63 SN-M17 #2 Finish Mill Discharge Baghouse

Source Description

After milling, the cement is discharged. Grinding aids containing HAPs and VOC are used in these mills. Particulate emissions from this disch arge are controlled by a baghouse with an assumed efficiency of 99%.

Specific Conditions

63. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 65. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.5 2.0

VOC 3.8 16.3

64. The permittee shall not exceed the emission limit s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 65 and 76. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-203 and §8-3-311]

Pollutant lb/hr tpy

PM 0.5 2.0

Diethanolamine 0.2 0.6

Ethylene Glycol 0.1 0.2

65. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

66. Emissions from this source shall not exceed 10% opa city. This source is subject to all applicable requirements listed in Plantwide Conditi on #12. Compliance with the opacity standard shall be demonstrated through daily visibl e emissions observations using Method 22, corrective action and subsequent visible emissions observations in accordance with 40 CFR 63.1350(e). The visible obs ervation requirement will be superceded if the permittee chooses the use of a co ntinuous opacity monitor or bag leak detection system in place of the visible observatio ns in accordance with 40 CFR 63.1350(m). The permittee shall notify the Departm ent, in writing, of the date a COM orAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

64 BLDS is put into service at this facility. [§19.30 4 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollu tants From the Portland Cement Manufacturing Industry ]

67. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

65 SN-M18 #4 Finish Mill Baghouse

Source Description

After milling, the cement is discharged. Emissions from this discharge are controlled by a baghouse with an assumed efficiency of 99%.

Specific Conditions

68. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 70. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 1.1 4.7

69. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 70. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 1.1 4.7

70. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

71. Emissions from this source shall not exceed 10% opa city. This source is subject to all applicable requirements listed in Plantwide Conditi on #12. Compliance with the opacity standard shall be demonstrated through daily visibl e emissions observations using Method 22, corrective action and subsequent visible emissions observations in accordance with 40 CFR 63.1350(e). The visible obs ervation requirement will be superceded if the permittee chooses the use of a co ntinuous opacity monitor or bag leak detection system in place of the visible observatio ns in accordance with 40 CFR 63.1350(m). The permittee shall notify the Departm ent, in writing, of the date a COM or BLDS is put into service at this facility. [§19.30 4 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollu tants From the Portland Cement Manufacturing Industry ]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

66 72. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

67 SN-M19 #4 Finish Mill Discharge Baghouse

Source Description

After milling, the cement is discharged. Grinding aids containing HAPs and VOC are used in these mills. Particulate emissions from this disch arge are controlled by a baghouse with an assumed efficiency of 99%.

Specific Conditions

73. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 75. [Pursuant to §19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM 10 1.6 6.7

VOC 27.8 122.0

74. The permittee shall not exceed the emission limit s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Conditions 75 and 76. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 1.6 6.7

Diethanolamine 1.0 4.1

Ethylene Glycol 0.4 1.4

75. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

76. The grinding aid used at this facility shall have a density less than or equal to 9.996 lb/gal and shall not contain more than 90% VOC or 4.0% HAP by weight. The HAPs contained in the grinding aid shall have a TLV greater than o r equal to 2 mg/m 3 . The permittee shall not use more than 196,910 lb of grinding aid per month. Compliance shall be demonstrated through compliance with Specific Condi tion 77. [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8-4-203 as r eferenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR Part 70.6]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

68 77. The permittee shall maintain records of the density , VOC content and HAP content of the grinding aid used. These records shall be in the f orm of an MSDS or the equivalent and shall be updated as necessary. The permittee shall maintain records of the amount of grinding aid used on a monthly basis. These record s shall be updated on a monthly basis and made available to Department personnel upon req uest. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

78. Emissions from this source shall not exceed 10% opa city. This source is subject to all applicable requirements listed in Plantwide Conditi on #12. Compliance with the opacity standard shall be demonstrated through daily visibl e emissions observations using Method 22, corrective action and subsequent visible emissions observations in accordance with 40 CFR 63.1350(e). The visible obs ervation requirement will be superceded if the permittee chooses the use of a co ntinuous opacity monitor or bag leak detection system in place of the visible observatio ns in accordance with 40 CFR 63.1350(m). The permittee shall notify the Departm ent, in writing, of the date a COM or BLDS is put into service at this facility. [§19.30 4 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollu tants From the Portland Cement Manufacturing Industry ]

79. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

69 SN-M20 Dryer Scrubber

Source Description

Emissions from the dryer consist of products of com bustion and additional particulate matter. Particulate matter is controlled using a wet scrubb er with an efficiency of 95%. This scrubber operates at a gas flow of 18,000 ft 3 /min and a liquid flow rate of 10 gal/min.

Specific Conditions

80. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 83. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.2 0.9

SO 2 0.1 0.2

VOC 0.5 1.9

CO 6.3 27.6

NO x 7.5 32.9

81. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 83. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.4 1.8

82. Emissions from this source shall not exceed 10% opa city. This source is subject to all applicable requirements listed in Plantwide Conditi on #12. Compliance with the opacity standard shall be demonstrated by observations of o pacity from SN-M20 at least once each calendar week in which the dryer is in operati on. These observations shall be performed using EPA Reference Method 22. Records o f the operating periods of the dryer and the opacity observations shall be maintai ned in the facility record. These records shall be kept on site and made available to Department personnel upon request. [§19.304 of Regulation 19 and 40 CFR 63.1348]

83. The permittee shall not use more than 55.8 MMft 3 of natural gas per month at this source. Compliance shall be demonstrated through compliance with the requirements set forth inAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

70 Specific Condition #84. [§19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR 70.6]

84. The permittee shall maintain records of the amount of natural gas used at this source. These records shall be maintained on a monthly basi s and updated by the 15th day of the month following the month to which the records pert ain. The records shall be maintained on site and made available to Department personnel upon request. A report of these records shall be submitted to the Department in acc ordance with General Provision #7. [§19.705 of Regulation 19 and 40 CFR Part 52, Subpa rt E]

85. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

71 SN-M42, M43, M44, M45 Bin Dust Collectors

Source Description

These baghouses are used to control emissions resul ting from material transfer to storage bins. The efficiency of each baghouse is assumed to be 99 %.

Specific Conditions

86. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 88. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

SN Pollutant lb/hr Tpy

M42 PM 10 0.3 0.9

M43 PM 10 0.3 0.9

M44 PM 10 0.3 0.9

M45 PM 10 0.3 0.9

87. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 88. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

SN Pollutant lb/hr tpy

M42 PM 0.3 0.9

M43 PM 0.3 0.9

M44 PM 0.3 0.9

M45 PM 0.3 0.9

88. The permittee shall operate the control equipment a ssociated with these sources in a manner consistent with good air pollution control p ractices in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

89. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 andAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

72 §8-4-311, §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

90. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

73 SN-F4 Long Term Coal Pile

Source Description

Coal is stored in this pile until it is moved to th e active coal pile and fed to the kilns.

Specific Conditions

91. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 93. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.5

92. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 93. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.2 0.9

93. The permittee shall maintain the area of this stora ge pile at or below 3.0 acres. Compliance shall be demonstrated through compliance with Specific Condition 94. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

94. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the long term coal p ile that encompasses an area no greater than 3.0 acres. The permittee shall demarc ate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the footprint of the pile exceeds the established perimeter at any location, the permitte e shall survey the pile to ascertain the true area of the pile and make appropriate notation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. A copy of these records shall be submitted in accordance w ith General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

74 95. This source shall be operated so that unnecessary a ir contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at this source in accordance with EPA Me thod 22. The permittee shall maintain records of the observations performed. Th ese records shall be maintained on site and made available to Department personnel upo n request. A copy of these records shall be submitted in accordance with General Provi sion #7. [§18.901 of Regulation 18]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

75 SN-F5 Active Coal Pile

Source Description

This is where the coal from the long term pile is t ransferred. Coal is fed to the kilns from this pile.

Specific Conditions

96. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 98. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.3

97. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 98. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.2 0.6

98. The permittee shall maintain the area of this stora ge pile at or below 1.0 acre. Compliance shall be demonstrated through compliance with Specific Condition 99. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

99. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the active coal pile that encompasses an area no greater than 1.0 acre. The permittee shall demarcate the p erimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the foot print of the pile exceeds the established perimeter at any location, the permittee shall surv ey the pile to ascertain the true area of the pile and make appropriate notations in the faci lity record. These records shall be kept on site and made available to Department personnel upon request. A copy of these records shall be submitted in accordance with Gener al Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

76 100. This source shall be operated so that unnecessary a ir contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at this source in accordance with EPA Me thod 22. The permittee shall maintain records of the observations performed. Th ese records shall be maintained on site and made available to Department personnel upo n request. A copy of these records shall be submitted in accordance with General Provi sion #7. [§18.901 of Regulation 18]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

77

Uncontrolled Emission Points in the Fuel Area

Source Description

The fuel area consists of many different pieces of equipment. The uncontrolled emission rates were found based on equipment maximums using a form ula contained in AP-42 page 13.2.4-3 as found in Appendix B.

Specific Conditions

101. The permittee shall not exceed the emission limits set forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

SN Source Description Pollutant lb/hr tpy F6 Discharge into Feed Hopper

#5 PM 10 0.3 0.6

F8 Coal Stacker Belt PM 10 0.1 0.1

F9 Discharge into Feed Hopper

#4 PM 10 0.3 0.6

F11 Transfer to #206 Belt PM 10 0.1 0.1

F12 Transfer to #206 Belt PM 10 0.1 0.1

F13 Transfer to #208 Belt PM 10 0.1 0.1

F14 Transfer to Stacker Belt PM 10 0.3 0.6

F15 Unloading into Long Term

Coal Pile PM 10 0.2 0.5

F16 Transfer from Long Term

Coal Pile to Active Pile PM 10 0.2 0.5

F17 Coal Feeders PM 10 0.1 0.2

F18 Railcar Unloading into Coal

Hoppers 4 and 5 PM 10 0.3 1.0

102. The permittee shall not exceed the emission rates s et forth in the following. Compliance is based on the maximum capacity of the equipment a nd continuous operation. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

SN Source Description Pollutant lb/hr Tpy F6 Discharge into Feed Hopper

#5 PM 0.6 1.7

F8 Coal Stacker Belt PM 0.1 0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

78

SN Source Description Pollutant lb/hr Tpy F9 Discharge into Feed Hopper

#4 PM 0.6 1.7

F11 Transfer to #206 Belt PM 0.1 0.1

F12 Transfer to #206 Belt PM 0.1 0.1

F13 Transfer to #208 Belt PM 0.1 0.1

F14 Transfer to Stacker Belt PM 0.6 1.7

F15 Unloading into Long Term

Coal Pile PM 0.5 1.2

F16 Transfer from Long Term

Coal Pile to Active Pile PM 0.5 1.2

F17 Coal Feeders PM 0.2 0.6

F18 Railcar Unloading into Coal

Hoppers 4 and 5 PM 0.6 2.7

103. Visual emissions for these sources shall not exceed 20 percent opacity. The permittee shall demonstrate compliance with this specific con dition by conducting a visible opacity observation of the source at least once each calend ar week in which the source operates, and keep a record of these observations. If visibl e emissions appear to exceed 20 percent opacity, the permittee shall take corrective action , and perform and record the observation again. If visible emissions still appear to exceed 20 percent opacity, the permittee shall conduct a six minute opacity reading in accordance with the EPA reference method No. 9. The records of visible emission observations an d results of any method No. 9 reading shall be kept on site for five years and made avail able to Department personnel upon request. [§19.503 of Regulation 19 and 40 CFR Part 52, Subpart E]

104. SN-F15 and SN-F16 shall be operated so that unneces sary air contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at SN-F15 and SN-F16 and the recording of the findings of the visual observations in the facility record. These records shall be kept on site and made available to Department personnel upon request. [§ 18.901 of Regulation 18]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

79 SN-F19, F20 Liquid Waste-derived Fuel Tanks

Source Description

LWDF is received in rail tank cars and in tank truc ks and stored in above ground storage tanks before being transferred to the kilns. There are te n above ground storage tanks. To control VOC emissions, tanks are vented to a thermal oxidizer w ith a back up carbon adsorption system.

Specific Conditions

105. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 117. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.2

SO 2 0.1 0.2

VOC 16.9 3.0

CO 0.5 2.0

NO x 0.6 2.4

106. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 117. [§18.8 of Regulation 18 and A.C.A. §8-3-203 as refe renced by A.C.A. §8-4-304 and §8- 4-311]

Pollutant lb/hr tpy

PM 0.1 0.2 Xylene (mixed isomers) 1.26 0.2

Toluene 0.7 0.2

Methylene Chloride 0.1 0.1

Ethyl Benzene 0.33 0.1

Styrene 0.20 0.1

Tetrachloroethene 0.1 0.1Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

80 Pollutant lb/hr tpy 1,1,2 trichloroethane 0.1 0.1

Benzene 0.1 0.1

107. This subpart applies to each storage vessel with a capacity greater than 40 cubic meters (m 3 ) that is used to store volatile organic liquids (V OLs) for which construction, reconstruction, or modification is commenced after July 23, 1984. [§19.304 of Regulation 19 and 40 CFR Part 60, Subpart Kb, Stand ards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Comme nced after July 23, 1984, §60.110b(a)]

108. Each storage vessel with a design capacity greater than or equal to 151 m 3 containing a VOL that, as stored, has a maximum true vapor press ure equal to or greater than 5.2 kPa, but less than 76.6 kPa or with a design capacity gr eater than or equal to 75 m 3 , but less than 151 m 3 containing a VOL that, as stored, has a maximum tr ue vapor pressure equal to or greater than 27.6 kPa, but less than 76.6 kPa , shall equip each storage vessel with the following: [§19.304 of Regulation 19 and 40 CF R Part 60, §60.112b(a)]

a. These vessels shall be equipped with a closed vent system and control device meeting the following specifications: [§60.112b(a) (3)] i. The closed vent system shall be designed to collect all VOC vapors and gases discharged from the storage vessel and operat ed with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background and visual inspections as determin ed in Part 60, Subpart VV, §60.485(b). ii. The control device shall be designed and operated t o reduce inlet VOC emissions by 95 percent or greater.

109. Each source that is equipped with a closed vent sys tem and control device (the thermal oxidizer at this facility) as required in §60.112b( a)(3) or (b)(2) (other than a flare) is exempt from §60.8 of the General Provisions and sha ll meet the following requirements. [§19.304 of Regulation 19 and 40 CFR Part 60, §60.1 13b(c)]

a. Submit for approval by the Administrator as an atta chment to the notification required by §60.7(a)(1) or, if the facility is exem pt from §60.7(a)(1), as an attachment to the notification required by §60.7(a) (2), an operating plan containing the information listed below.

i. Documentation demonstrating that the control device will achieve the required control efficiency during maximum loading conditions. This documentation is to include a description of the ga s stream which enters the control device, including flow and VOC content under varying liquid level conditions (dynamic and static) and manufactu rer's designAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

81

specifications for the control device. If the cont rol device or the closed vent capture system receives vapors, gases, or liqu ids other than fuel types from sources that are not designated sources under this subpart, the efficiency demonstration is to include consideratio n of all vapors, gases, and liquids received by the closed vent capture sys tem and control device. If an enclosed combustion device with a minimum res idence time of 0.75 seconds and a minimum temperature of 816°C is used to meet the 95 percent requirement, documentation that those condi tions will exist is sufficient to meet the requirements of this paragra ph.

ii. A description of the parameter or parameters to be monitored to insure that the control device will be operated in conformance with its design and an explanation of the criteria used for selection of t hat parameter (or parameters).

b. Operate the closed vent system and control device a nd monitor the parameters of the closed vent system and control device in accord ance with paragraph (c)(1) of this section, unless the plan was modified by the A dministrator during the review process. In this case, the modification applies.

110. The permittee shall maintain records and furnish re ports as required by paragraphs (a), (b), or (c) of this section depending upon the cont rol equipment installed to meet the requirements of §60.112b. The owner or operator sh all keep copies of all reports and records required by this section, except for the re cord required by (c)(1), for at least two years. The record required by (c)(1) will be kept for the life of the control equipment. [§19.304 of Regulation 19 and 40 CFR 60, §60.115b]

111. After installing control equipment in accordance wi th §60.112b(a)(3) or (b)(1) (closed vent system and control device other than a flare), the permittee shall keep the following records. [§19.304 of Regulation 19 and 40 CFR 60, §60.115b(c)]

a. A copy of the operating plan. b. A record of the measured values of the parameters m onitored in accordance with §60.112b(c)(2).

112. The permittee shall keep copies of all records requ ired by this section, except for records required by paragraph (b) of this section, for at l east 2 years. The record required by paragraph (b) of this section shall be kept for the life of the source. [§19.304 of Regulation 19 and 40 CFR 60, §60.116b(a)]

113. The permittee shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. Each storage tank with a design capacity less than 75 m 3 is subject to no provision of this subpart other t han those required by this paragraph. [§19.304 of Regu lation 19 and 40 CFR 60, §60.116b(b)]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

82 114. For vessels operated above or below ambient tempera tures, the maximum true vapor pressure is calculated based on the highest expecte d calendar month average of the storage temperature. For vessels operated at ambie nt temperatures, the maximum true vapor pressure is calculated based on the maximum l ocal monthly average ambient temperature as reported by the National Weather Ser vice. [§19.304 of Regulation 19 and 40 CFR 60, §60.116b(e)]

115. The owner or operator of each vessel storing a wast e mixture of indeterminate or variable composition shall be subject to the following requi rements. [§19.304 of Regulation 19 and 40 CFR 60, §60.116b(f)]

a. Prior to the initial filling of the vessel, the hig hest maximum true vapor pressure for the range of anticipated liquid compositions to be stored will be determined using the methods described in paragraph (e) of thi s section.

b. For vessels in which the vapor pressure of the anti cipated liquid composition is above the cutoff for controls as defined in §60.112 b(a), an initial physical test of the vapor pressure is required; and a physical test at least once every 6 months thereafter is required as determined by the followi ng methods:

i. ASTM Method D2879-83 (incorporated by reference-see §60.17); or ii. ASTM Method D323-82 (incorporated by reference-see §60.17); or iii. As measured by an appropriate method as approved by the Administrator.

116. Visible emissions from this source shall not exceed 10% opacity. Compliance shall be demonstrated by using only natural gas as fuel in t he thermal oxidizer. [§18.501 of Regulation 18 and A.C.A. §8-4-230 as referenced by A.C.A. §8-4-304 and §8-4-311]

117. The permittee shall determine the destruction effic iency of the thermal oxidizing unit either using an appropriate test method or through the use of engineering calculations. If testing is used, the test shall be performed a mini mum of once every five years. The initial test shall be performed no later than 180 d ays after the initial startup date. This test shall be performed with this unit operating at or a bove 90% of its design capacity. This unit shall achieve a VOC destruction rate of not le ss than 95%. If engineering calculations are used, the permittee shall maintain a complete design analysis of the unit which shall contain documentation necessary to demo nstrate the performance of the unit. [§19.702 of Regulation 19 and 40 CFR Part 52, Subpa rt E]

118. The permittee shall maintain the temperature in the combustion chamber of the thermal oxidizer at or above 1500°F. To demonstrate compli ance, the permittee shall install, calibrate, and maintain a continuous temperature re corder on the catalytic oxidizer used to control emissions from these sources. These rec ords shall be maintained on site and made available to Department personnel upon request . [§19.703 of Regulation 19, 40Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

83 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as refe renced by A.C.A. §8-4-304 and §8- 4-311]

119. During operation of the dual carbon canister system as a replacement for thermal oxidizer at this source, the permittee shall use good engine ering judgment and/or vendor recommendations to determine the frequency to obser ve the condition of the breakthrough indicators on the carbon canisters in the absorption train. Observation of the breakthrough indicators on the carbon canisters shall occur no less often than the conclusion of each operating shift in which working losses were directed through the carbon canister absorption train. If breakthrough is detected, the system shall be reconfigured and, as necessary, canisters shall be recharged. The permittee shall maintain a log of the observations of the breakthro ugh indicators and the recharging of the carbon canisters. These records shall be maint ained on site and made available to Department personnel upon request. [§19.703 of Reg ulation 19, 40 CFR 52, Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-30 4 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

84 SN-S1, S3, S13, S14 Truck Loadout Dust Collectors

Source Description

Trucks are loaded at these points. Emissions are c ontrolled using baghouses assumed to be 99% efficient.

Specific Conditions

120. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 122. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

SN Pollutant lb/hr tpy S1, DC #31 PM 10 0.2 0.8

S3, DC#49 PM 10 0.7 3.0

S13, DC #28 PM 10 0.5 2.0

S14 PM 10 1.1 4.5

121. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 122. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

SN Pollutant lb/hr tpy S1, DC #31 PM 0.2 0.8

S3, DC#49 PM 0.7 3.0

S13, DC #28 PM 0.5 2.0

S14 PM 1.1 4.5

122. The permittee shall operate the control equipment a ssociated with these sources in a manner consistent with good air pollution control p ractices in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

123. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 andAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

85 §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

124. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

86 SN-S4, S5, S6, S7, S8, S9, S10, S11, S12

Silo Dust Collectors

Source Description

These baghouses control particulate emissions resul ting from material transfer in and out of silos. Efficiencies are assumed to be 99%.

Specific Conditions

125. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 127. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

SN Pollutant lb/hr Tpy S4, DC #21 PM 10 0.5 2.1

S5, DC #22 PM 10 0.2 0.7

S6, DC #23 PM 10 0.6 2.5

S7, DC #24 PM 10 0.7 3.0

S8, DC #29 PM 10 0.2 0.8

S9, DC #30 PM 10 0.2 0.7

S10, DC #25 PM 10 0.4 1.6

S11, DC #26 PM 10 0.7 3.0

S12, DC #27 PM 10 0.6 2.5

126. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 127. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

SN Pollutant lb/hr tpy

S4, DC #21 PM 0.5 2.1

S5, DC #22 PM 0.2 0.7

S6, DC #23 PM 0.6 2.5

S7, DC #24 PM 0.7 3.0

S8, DC #29 PM 0.2 0.8

S9, DC #30 PM 0.2 0.7Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

87 SN Pollutant lb/hr tpy S10, DC #25 PM 0.4 1.6

S11, DC #26 PM 0.7 3.0

S12, DC #27 PM 0.6 2.5

127. The permittee shall operate the control equipment a ssociated with these sources in a manner consistent with good air pollution control p ractices in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

128. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

129. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

88 SN-C1 Clinker Transfer Tower Baghouse

Source Description

This baghouse controls particulate emissions result ing from material transfer at this source. Efficiency is assumed to be 99%.

Specific Conditions

130. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 132. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 1.8 7.6

131. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 132. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 1.8 7.6

132. The permittee shall operate the control equipment a ssociated with this source in a manner consistent with good air pollution control practice s in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C .A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

133. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

134. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

89 [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

90

Uncontrolled Emission Points in the Clinker Area

Source Description

The clinker area consists of many different pieces of equipment. The uncontrolled emission rates were found based on equipment maximums using a formula contained in AP-42 page 13.2.4-3 as found in Appendix B.

Specific Conditions

135. The permittee shall not exceed the emission limits set forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

SN Source Name Pollutant lb/hr tpy C2 Outside Clinker Belt

Discharge PM 10 0.5 1.9

C3 Outside Clinker Reclaim

Hopper Loading PM 10 0.2 0.8

C4 Discharge from Clinker

Reclaim Hopper PM 10 0.029 0.13

C5* Clinker Railcar and Truck

Hopper Loading PM 10 0.180 0.79

C6 Clinker Discharge to

Railcar/Truck PM 10 0.1 0.3

C7* Transfer from Reclaim Belt

to #7 Belt PM 10 0.060 0.26

C8* Transfer to #7 Belt PM 10 0.180 2.26

C9* Transfer from #7 Belt to #8

Belt PM 10 0.042 0.18

C10* Transfer from #8 Belt to #9

Belt PM 10 0.222 0.97

C11* Discharge from #2 Clinker

Bin PM 10 0.282 1.24

C15* Discharge into #2 Clinker

Bin PM 10 0.030 0.13

C16* Transfer from #9 Belt PM 10 0.282 1.24

C17* Discharge from #1 Clinker

Bin PM 10 0.282 1.24

C19* Transfer to Belt Conveyor PM 10 0.030 0.13

C20* Discharge into #1 Clinker

Bin PM 10 0.030 0.13Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

91

SN Source Name Pollutant lb/hr tpy C21* Transfer to 4A Belt PM 10 0.086 0.38 C28* Discharge into Clinker

Elevator PM 10 0.055 0.24

C36* Discharge into Clinker

Elevator PM 10 0.589 2.58

*Subject to 40 CFR 63, Subpart LLL

136. The permittee shall not exceed the emission rates s et forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§18.801 of Regulation 18 and A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311]

SN Source Name Pollutant lb/hr tpy C2 Outside Clinker Belt

Discharge PM 1.3 5.4

C3 Outside Clinker Reclaim

Hopper Loading PM 0.6 2.3

C4 Outside Clinker Storage Pile PM 0.1 0.3

C5* Discharge from Clinker

Reclaim Hopper PM 0.6 2.3

C6 Clinker Railcar and Truck

Hopper Loading PM 0.2 0.8

C7* Clinker Discharge to

Railcar/Truck PM 0.2 0.8

C8* Transfer from Reclaim Belt

to #7 Belt PM 0.6 2.3

C9* Transfer to #7 Belt PM 0.2 0.6

C10* Transfer from #7 Belt to #8

Belt PM 0.7 2.8

C11* Transfer from #8 Belt to #9

Belt PM 0.9 3.6

C15* Discharge from #2 Clinker

Bin PM 0.1 0.4

C16* Discharge into #2 Clinker

Bin PM 0.9 3.6

C17* Transfer from #9 Belt PM 0.9 3.6

C19* Discharge from #1 Clinker

Bin PM 0.1 0.4

C20* Transfer to Belt Conveyor PM 0.1 0.4Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

92

SN Source Name Pollutant lb/hr tpy C21* Discharge into #1 Clinker

Bin PM 0.1 0.4

C28* Transfer to 4A Belt PM 0.2 0.7

C36* Discharge into Clinker

Elevator PM 1.7 7.4

C37 Discharge into Clinker

Elevator PM 0.2 0.5

*Subject to 40 CFR 63, Subpart LLL

137. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with the opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

138. SN-C2, SN-C3, SN-C6 and SN-C37 shall be operated so that unnecessary air contaminants do not become airborne. Compliance sh all be demonstrated through a monthly visual observation of operations at SN-C2, SN-C3, SN-C6 and SN-C37 and the recording of the findings of the visual observation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. [§18.901 of Regulation 18]

139. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

93 SN-C4 Outside Clinker Storage Pile

Source Description

Clinker is stored in this pile prior to being trans ported by conveyors to mill feed bins.

Specific Conditions

140. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 142. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.029 0.13

141. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 142. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.058 0.25

142. The permittee shall maintain the area of this stora ge pile at or below 2.0 acres. Compliance shall be demonstrated through compliance with Specific Condition 143. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

143. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the outside clinker storage pile that encompasses an area no greater than 2.0 acres. The permittee shall dem arcate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the footprint of the pile exceeds the established perimeter at any location, the permitte e shall survey the pile to ascertain the true area of the pile and make appropriate notation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. A copy of these records shall be submitted in accordance w ith General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

94 144. This source shall be operated so that unnecessary a ir contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at this source in accordance with EPA Me thod 22. The permittee shall maintain records of the observations performed. Th ese records shall be maintained on site and made available to Department personnel upo n request. A copy of these records shall be submitted in accordance with General Provi sion 7. [§18.901 of Regulation 18]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

95

SN-C14, C18, C26, C27, C32, C34, C41, C42, C43, C44 , C45, C46

Clinker Handling Dust Collectors

Source Description

These baghouses control particulate emissions resul ting from material transfer in the clinker portion of this facility. Efficiencies are assumed to be 99%.

Specific Conditions

145. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 147. [§19.501 of Regulation 19 and 40 CFR Part 52, Subpa rt E]

SN Source Name Pollutant Lb/hr tpy C14* B Belt

Dust Collector PM 10 0.1 0.4

C18* Clinker Elevator

Dust Collector PM 10 0.1 0.4

C26* West Clinker Silo

Dust Collector PM 10 0.8 3.2

C27* 4A2 Belt Dust Collector PM 10 0.6 2.7

C32* East Clinker Silo

Dust Collector PM 10 0.8 3.2

C34* West Clinker Tank

Dust Collector PM 10 0.2 0.8

C41* Off-spec Bin and

Ancillary Equipment Dust Collector PM 10 0.4 1.4

C42* Clinker Dome

Dust Collector PM 10 0.6 1.9

C43* Reclaim Belt

Dust Collector PM 10 0.2 0.5

C44* Off-Spec Bin Dust

Collector PM 10 0.17 0.75

C45* Clinker Silo Baghouse PM 10 0.3 1.2

C46* Clinker Silo Baghouse PM 10 0.3 1.2

* Subject to 40 CFR 63, Subpart LLL

146. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 147. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

96

SN Source Name Pollutant lb/hr tpy C14* B Belt

Dust Collector PM 0.1 0.4

C18* Clinker Elevator

Dust Collector PM 0.1 0.4

C26* West Clinker Silo

Dust Collector PM 0.8 3.2

C27* 4A2 Belt Dust Collector PM 0.6 2.7

C32* East Clinker Silo

Dust Collector PM 0.8 3.2

C34* West Clinker Tank

Dust Collector PM 0.2 0.8

C41* Off-spec Bin and

Ancillary Equipment Dust Collector PM 10 0.4 1.4

C42* Clinker Dome

Dust Collector PM 10 0.6 1.9

C43* Reclaim Belt

Dust Collector PM 10 0.2 0.5

C44* Off-Spec Bin Dust

Collector PM 0.17 0.75

C45* Clinker Silo Baghouse PM 0.3 1.2

C46* Clinker Silo Baghouse PM 0.3 1.2

*Subject to 40 CFR 63, Subpart LLL

147. The permittee shall operate the control equipment a ssociated with these sources in a manner consistent with good air pollution control p ractices in order to comply with the applicable emission limits. [§19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

148. The permittee shall not operate sources SN-41, SN-4 2, and SN-43 more than 7,250 hours per year based on a rolling twelve month total. Co mpliance shall be demonstrated by maintaining records of the hours of operation of th ese sources. These records shall be maintained on a weekly basis and updated weekly. T hese records shall be maintained on site and made available to Department personnel upo n request. [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8-4-203 as r eferenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR Part 70.6]

149. Emissions from these sources shall not exceed 10% o pacity. These sources are subject to all applicable requirements listed in Plantwide Con dition #12. Compliance with theAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

97 opacity standard shall be demonstrated through comp liance with Plantwide Condition #15. [§18.501 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , §19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants Fro m the Portland Cement Manufacturing Industry ]

150. The permittee shall conduct initial compliance test s for all affected sources for which an initial compliance test has not been previously per formed. Any of the affected sources for which the facility has already tested need not be tested again, provided that the facility has documentation and the results of these tests. A copy of this documentation must accompany the results of the initial tests required by this Specific Condition. [§63.1349(a) of 40 CFR Part 63, Subpart LLL and A.C .A.. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

98

Uncontrolled Emission Points in the Raw Material St orage Area

Source Description

The Raw Material Storage area consists of many diff erent pieces of equipment. The uncontrolled emission rates were found based on equ ipment maximums using a formula contained in AP-42 page 13.2.4-3 as found in Append ix B.

Specific Conditions

151. The permittee shall not exceed the emission limits set forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

SN Source Name Pollutant lb/hr tpy R1 Truck Unloading for

Sand/Iron Ore PM 10 0.7 2.8

R3 Discharge from Chalk

Feeder PM 10 0.1 0.1

R4 Discharge from Gypsum

Feeder PM 10 0.1 0.4

R6 Discharge from Sand/Ironore Feeder PM 10 0.1 0.1

R8 Sand/Iron Ore Storage

Transfer PM 10 0.2 0.5

R9 Discharge from Emergency

Feeder PM 10 0.1 0.4

R10 Discharge of Gypsum Belt PM 10 0.3 1.2

R11 Discharge into Secondary

Crusher PM 10 0.1 0.1

R13 Secondary Crusher

Discharge PM 10 0.1 0.1

R14 Transfer to #2 Belt PM 10 0.1 0.1

R24 Transfer from Portable

Crusher to Main Conveyor PM 10 0.2 0.5

152. The permittee shall not exceed the emission rates s et forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§18.801 of Regulation 18 and A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

99

SN Source Name Pollutant lb/hr tpy R1 Truck Unloading for

Sand/Iron Ore PM 1.9 8.0

R3 Discharge from Chalk

Feeder PM 0.1 0.2

R4 Discharge from Gypsum

Feeder PM 0.3 1.0

R6 Discharge from Sand/Ironore Feeder PM 0.1 0.1

R8 Sand/Iron Ore Storage

Transfer PM 0.4 1.5

R9 Discharge from Emergency

Feeder PM 0.3 1.0

R10 Discharge of Gypsum Belt PM 0.8 3.2

R11 Discharge into Secondary

Crusher PM 0.1 0.2

R13 Secondary Crusher

Discharge PM 0.1 0.2

R14 Transfer to #2 Belt PM 0.1 0.2

R24 Transfer from Portable

Crusher to Main Conveyor PM 0.3 1.3

153. The opacity from sources R3, R4, R11, R13, and R14 shall not exceed 40%. Compliance with the opacity standard shall be demonstrated thr ough compliance with Plantwide Condition #10. [§19.503 of Regulation 19 and 40 CF R Part 52, Subpart E]

154. The opacity from sources R6, R9, R10, and R24 shall not exceed 20%. Compliance with the opacity standard shall be demonstrated through compliance with Plantwide Condition #10. [§19.503 of Regulation 19 and 40 CFR Part 52, Subpart E]

155. SN-R1 and SN-R8 shall be operated so that unnecessa ry air contaminants do not become airborne. Compliance shall be demonstrated through a monthly visual observation of operations at SN-R1 and SN-R8 and the recording of the findings of the visual observations in the facility record. These records shall be kept on site and made available to Department personnel upon request. [§18.901 of Regulation 18]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

100 SN-R2 Chalk Storage Pile

Source Description

Chalk used to create the clinker at this facility i s stored in a pile.

Specific Conditions

156. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 158. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.2

157. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 158. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.1 0.3

158. The permittee shall maintain the area of this stora ge pile at or below 1.50 acres. Compliance shall be demonstrated through compliance with Specific Condition 159. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

159. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the sand storage pil e that encompasses an area no greater than 1.50 acres. The permittee shall demarcate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the foot print of the pile exceeds the established perimeter at any location, the permittee shall surv ey the pile to ascertain the true area of the pile and make appropriate notations in the faci lity record. These records shall be kept on site and made available to Department personnel upon request. A copy of these records shall be submitted in accordance with Gener al Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

101 160. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [18.901(A) of Regulation 18 and A.C.A § 8-4-230 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

102 SN-R5 Gypsum Storage Pile

Source Description

Gypsum used to manufacture Portland cement at this facility is stored in a pile.

Specific Conditions

161. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 163. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.1

162. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 163. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.1 0.1

163. The permittee shall maintain the area of this stora ge pile at or below 0.22 acre. Compliance shall be demonstrated through compliance with Specific Condition 164. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

164. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the gypsum storage p ile that encompasses an area no greater than 0.22 acre. The permittee shall demarc ate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the footprint of the pile exceeds the established perimeter at any location, the permitte e shall survey the pile to ascertain the true area of the pile and make appropriate notation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. A copy of these records shall be submitted in accordance w ith General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

103 165. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [18.901(A) of Regulation 18 and A.C.A § 8-4-230 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

104 SN-R12 Secondary Crusher

Source Description

This crusher is used to crush the raw materials use d at this facility. Chalk, sand, and iron ore are crushed and then transported to the mill building b y a conveyor belt.

Specific Conditions

166. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 169. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.2 0.8

167. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 169. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.2 0.8

168. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [§19.503 of Regulation 19, §18.901 of Regulation 18 and, A.C.A § 8-4-230 a s referenced by A.C.A. §8-4-304 and §8-4-311]

169. The permittee shall not crush more than 744,000 ton s of material per month at this source. Compliance shall be demonstrated through c ompliance with Specific Condition #170. [§19.705 of Regulation 19, A.C.A. §8-4-203 a s referenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR 70.6]

170. The permittee shall maintain records of the amount of material crushed at this source. These records shall be maintained on a weekly basis . These records shall be kept on site and made available to Department personnel upon req uest. A report of these records shall be submitted to the Department in accordance with General Provision #7. [§19.705 of Regulation 19 and 40 CFR Part 52, Subpart E]

171. The permittee shall conduct initial compliance test s for this source provided an initial compliance test has not been previously performed. Any sources for which the facilityAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

105 has already tested need not be tested again, provid ed that the facility has documentation and the results of these tests. A copy of this doc umentation must accompany the results of the initial tests required by this Specific Cond ition. [§19.503 of Regulation 19, §18.901 of Regulation 18 and A.C.A. §8-4-203 as ref erenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

106 SN-R17 Long Term Sand Pile

Source Description

Sand used to create the clinker at this facility is stored in a pile.

Specific Conditions

172. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 174. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.2

173. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 174. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.1 0.4

174. The permittee shall maintain the area of this stora ge pile at or below 1.0 acre. Compliance shall be demonstrated through compliance with Specific Condition 175. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

175. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the long term sand s torage pile that encompasses an area no greater than 1.0 acre. The permittee shall dema rcate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the footprint of the pile exceeds the established perimeter at any location, the permitte e shall survey the pile to ascertain the true area of the pile and make appropriate notation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. A copy of these records shall be submitted in accordance w ith General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

107 176. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [18.901(A) of Regulation 18 and A.C.A § 8-4-230 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

108 SN-R18 Iron Ore Storage Pile

Source Description

Iron ore used to create the clinker at this facilit y is stored in a pile.

Specific Conditions

177. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 179. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.3

178. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 179. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.2 0.6

179. The permittee shall maintain the area of this stora ge pile at or below 0.5 acre. Compliance shall be demonstrated through compliance with Specific Condition 180. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

180. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the iron ore storage pile that encompasses an area no greater than 0.5 acre. The permittee shall demarca te the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the footprint of the pile exceeds the established perimeter at any location, the permitte e shall survey the pile to ascertain the true area of the pile and make appropriate notation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. A copy of these records shall be submitted in accordance w ith General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

109 181. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [18.901(A) of Regulation 18 and A.C.A § 8-4-230 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

110 SN-R19 Sand Storage Pile

Source Description

Sand used to create the clinker at this facility is stored in this pile after being moved from the long term storage pile until it is fed to the clink er.

Specific Conditions

182. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 184. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.1

183. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 184. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.1 0.1

184. The permittee shall maintain the area of this stora ge pile at or below 0.25 acre. Compliance shall be demonstrated through compliance with Specific Condition 185. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

185. Within thirty days of the effective date of this op erating air permit, the permittee shall survey a boundary perimeter to the sand storage pil e that encompasses an area no greater than 0.25 acre. The permittee shall demarcate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the foot print of the pile exceeds the established perimeter at any location, the permittee shall surv ey the pile to ascertain the true area of the pile and make appropriate notations in the faci lity record. These records shall be kept on site and made available to Department personnel upon request. A copy of these records shall be submitted in accordance with Gener al Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52 , Subpart E and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

111 186. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [18.901(A) of Regulation 18 and A.C.A § 8-4-230 as referenced by A.C.A. §8-4-304 and §8-4-311]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

112 SN-R20 Fugitive Emissions from Plant Haul Roads

Source Description

Equipment and material are moved around the plant v ia a series of unpaved haul roads. Emissions from these roads were calculated using an equation contained in AP-42 §13.2.2 for unpaved roads.

Specific Conditions

187. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 189. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 3.6 13.4

188. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 189. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 13.1 47.2

189. The permittee shall follow the plant haul road fugi tive dust control plan contained in Appendix H of the permit. [§19.705 of Regulation 1 9, §18.1004 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 an d §8-4-311 , and 40 CFR Part 70.6]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

113 SN-R22 & R23 Portable Crusher Diesel Engine and Portable Crusher

Source Description

This crusher is powered by a diesel engine and is u sed to crush spent kiln brick so that it may be added to the raw materials stored in the mill build ing, then fed to Kiln #3.

Specific Conditions

190. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 193. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

SN Pollutant lb/hr Tpy

PM 10 0.2 0.8

SO 2 0.2 0.8

VOC 0.2 0.9

CO 0.6 2.3 R-22

NO x 2.5 10.6

R-23 PM 10 0.5 0.5

191. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 193. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

SN Pollutant lb/hr tpy

R-22 PM 0.2 0.8

R-23 PM 0.5 0.5

192. Visible emissions from these sources shall not exce ed 20% opacity. The permittee shall demonstrate compliance with this Specific Condition by conducting a visible opacity observation of these sources at least once each cal endar week in which these sources operate and keep a record of these observations. I f visible emissions appear to exceed 20% opacity, the permittee shall take corrective ac tion, and perform and record the observation again. If visible emissions still appea r to exceed 20% opacity, the permittee shall conduct a 6-minute opacity reading in accorda nce with EPA Reference Method #9. The records of visible emission observations and re sults of any Method #9 readings shallAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

114 be kept on site for five years and made available t o Department personnel upon request. [§19.503 of Regulation 19, and 40 CFR Part 52, Subp art E]

193. The permittee shall not crush more than 59,520 tons of material per month at SN-R23. Compliance shall be demonstrated through compliance with Specific Condition #194. [§19.705 of Regulation 19, A.C.A. §8-4-203 as refer enced by A.C.A. §8-4-304 and §8-4- 311 , and 40 CFR 70.6]

194. The permittee shall maintain records of the amount of material crushed at SN-R23. These records shall be maintained on a weekly basis . These records shall be kept on site and made available to Department personnel upon req uest. A report of these records shall be submitted to the Department in accordance with General Provision #7. [§19.705 of Regulation 19 and 40 CFR Part 52, Subpart E]

195. The permittee shall use only #2 fuel oil as fuel at SN-R22. [§19.§19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-30 4 and §8-4-311 , and 40 CFR 70.6]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

115 SN-R25 Emergency Gypsum Storage Pile

Source Description

This pile is in place to allow for storage of gypsu m so that production may continue if gypsum deliveries are interrupted.

Specific Conditions

196. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 198. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.1 0.1

197. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 198. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.1 0.1

198. The permittee shall maintain the area of this stora ge pile at or below 0.28 acre. Compliance shall be demonstrated through compliance with Specific Condition 199. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, 40 CFR Part 70.6 and A.C.A. §8- 4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

199. Within thirty days of the construction of this sour ce, the permittee shall survey a boundary perimeter to the emergency gypsum storage pile that encompasses an area no greater than 0.28 acre. The permittee shall demarc ate the perimeter on the ground by stakes, monuments or other permanent markers. At a minimum of once every three months, the permittee shall certify in the facility record that the footprint of the pile is within the confines of the established perimeter. If the footprint of the pile exceeds the established perimeter at any location, the permitte e shall survey the pile to ascertain the true area of the pile and make appropriate notation s in the facility record. These records shall be kept on site and made available to Departm ent personnel upon request. [§19.705 of Regulation 19, §18.1004 of Regulation 18, 40 CFR 52, Subpart E and A.C.A. §8-4- 203 as referenced by A.C.A. §8-4-304 and §8-4-311Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

116 SN-Q1 Quarry Haul Road

Source Description

Quarried material is hauled to the crushing area vi a this road.

Specific Conditions

200. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 202. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 5.2 22.5

201. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 202. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 23.5 102.8

202. The permittee shall water this haul road in accorda nce with a haul road watering plan. This plan shall be designed to minimize emissions f rom this source. A copy of this plan shall be kept on site and made available to Departm ent personnel upon request. [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR Part 70.6]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

117 SN-Q2 Primary Crusher

Source Description

Quarried chalk is crushed at this source before bei ng hauled to the raw materials storage area. This source was installed prior to the applicabilit y date of NSPS Subpart OOO.

Specific Conditions

203. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 205. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.5 1.9

204. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 205. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.5 1.9

205. The permittee shall not crush more than 1,116,000 t ons per month at this source. Compliance shall be demonstrated through compliance with Specific Condition 206. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR Part 70.6 ]

206. The permittee shall maintain records of the amount of material crushed at this source. These records shall be maintained on a monthly basi s and updated by the 15 th day of the month following the month to which the records pert ain. These records shall be kept on site and made available to Department personnel upo n request. A report of these records shall be submitted to the Department in accordance with General Provision #7. [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR Part 52, Subpart E]

207. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [§19.501 of Regulation 19 and 40 CFR part 52, Subpart E]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

118 Uncontrolled Emission Points in the Quarry

Source Description

The quarry contains many different pieces of equipm ent. Emissions sources primarily consist of transfer points. The uncontrolled emission rates w ere found based on equipment maximums using emission factors contained in AP-42 table 11. 19.2-2. These sources were installed prior to the applicability date of NSPS Subpart OOO.

Specific Conditions

208. The permittee shall not exceed the emission limits set forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§19.501 et seq. of Regulation 19 and 4 0 CFR Part 52, Subpart E]

SN Source Name Pollutant lb/hr tpy Q3 Transfer from Belt 2N to

Belt 1N PM 10 0.1 0.4

Q4 Transfer from Belt 1N to

Tripper Belt PM 10 0.1 0.4

Q5 Discharge from Tripper Belt

to Chalk Storage PM 10 0.1 0.4

Q6 Scraper Dumping to

Auxiliary Crusher PM 10 0.1 0.2

Q7 Hopper 3 Discharge to 1.12

Belt (Auxiliary System) PM 10 0.1 0.2

Q9 Discharge from Belt 1 to

Tripper Belt (Auxiliary System) PM 10 0.1 0.2

209. The permittee shall not exceed the emission rates s et forth in the following table. Compliance is based on the maximum capacity of the equipment and continuous operation. [§18.801 of Regulation 18 and A.C.A. §8 -4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311]

SN Source Name Pollutant lb/hr tpy Q3 Transfer from Belt 2N to

Belt 1N PM 0.1 0.4

Q4 Transfer from Belt 1N to

Tripper Belt PM 0.1 0.4

Q5 Discharge from Tripper Belt

to Chalk Storage PM 0.1 0.4

Q6 Scraper Dumping to

Auxiliary Crusher PM 0.1 0.2Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

119

SN Source Name Pollutant lb/hr tpy Q7 Hopper 3 Discharge to 1.12

Belt (Auxiliary System) PM 0.1 0.2

Q9 Discharge from Belt 1 to

Tripper Belt (Auxiliary System) PM 0.1 0.2

210. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be demonstrated through compliance with Plantwide Cond ition #10. [§19.501 of Regulation 19 and 40 CFR part 52, Subpart E]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

120 SN-Q8 Auxiliary Crusher

Source Description

This crusher serves as a backup to SN-Q2.

Specific Conditions

211. The permittee shall not exceed the emission limits set forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 213. [§19.501 et seq. of Regulation 19 and 40 CFR Part 5 2, Subpart E]

Pollutant lb/hr tpy

PM 10 0.5 2.2

212. The permittee shall not exceed the emission rates s et forth in the following table. Compliance shall be demonstrated through compliance with Specific Condition 213. [§18.801 of Regulation 18 and A.C.A. §8-4-203 as re ferenced by A.C.A. §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 1.1 4.7

213. The permittee shall not crush more than 632,400 ton s per month at this source. Compliance shall be demonstrated through compliance with Specific Condition 214. [§19.705 of Regulation 19, §18.1004 of Regulation 1 8, A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 , and 40 CFR Part 70.6 ]

214. The permittee shall maintain records of the amount of material crushed at this source. These records shall be maintained on a monthly basi s and updated by the 15 th day of the month following the month to which the records pert ain. These records shall be kept on site and made available to Department personnel upo n request. This source was installed prior to the applicability date of NSPS Subpart OOO . [§19.705 of Regulation 19, §18.1004 of Regulation 18, A.C.A. §8-4-203 as refer enced by A.C.A. §8-4-304 and §8-4- 311 , and 40 CFR Part 52, Subpart E]

215. Visible emissions from this source shall not exceed 20% opacity. The permittee shall demonstrate compliance with this Specific Condition by conducting a visible opacity observation of the source at least once each calend ar week in which the source operates and keep a record of these observations. If visibl e emissions appear to exceed 20% opacity, the permittee shall take corrective action , and perform and record the observation again. If visible emissions still appear to exceed 20% opacity, the permittee shall conductAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

121 a 6-minute opacity reading in accordance with EPA R eference Method #9. The records of visible emission observations and results of any Method #9 readings shall be kept on site for five years and made available to Departmen t personnel upon request. [§19.501 of Regulation 19 and 40 CFR Part 52, Subpart E]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

122

SECTION V: COMPLIANCE PLAN AND SCHEDULE

Ash Grove Cement Company will continue to operate i n compliance with those identified regulatory provisions. The facility will examine a nd analyze future regulations that may apply and determine their applicability with any necessar y action taken on a timely basis.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

123

SECTION VI: PLANTWIDE CONDITIONS

1. The permittee shall notify the Director in writing within thirty (30) days after commencing construction, completing construction, f irst placing the equipment and/or facility in operation, and reaching the equipment a nd/or facility target production rate. [Regulation 19, §19.704, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

2. If the permittee fails to start construction within eighteen months or suspends construction for eighteen months or more, the Direc tor may cancel all or part of this permit. [Regulation 19, §19.410(B) and 40 CFR Part 52, Subpart E]

3. The permittee must test any equipment scheduled for testing, unless stated in the Specific Conditions of this permit or by any federally regul ated requirements, within the following time frames: (1) new equipment or newly modified eq uipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start up of the permitted source or (2) operating equipment acc ording to the time frames set forth by the Department or within 180 days of permit issuanc e if no date is specified. The permittee must notify the Department of the schedul ed date of compliance testing at least fifteen (15) days in advance of such test. The per mittee shall submit the compliance test results to the Department within thirty (30) days a fter completing the testing. [Regulation 19, §19.702 and/or Regulation 18 §18.1002 and A.C.A . §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

4. The permittee must provide: [Regulation 19, §19.70 2 and/or Regulation 18, §18.1002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-30 4 and §8-4-311]

a. Sampling ports adequate for applicable test methods ; b. Safe sampling platforms;

c. Safe access to sampling platforms; and d. Utilities for sampling and testing equipment.

5. The permittee must operate the equipment, control a pparatus and emission monitoring equipment within the design limitations. The permi ttee shall maintain the equipment in good condition at all times. [Regulation 19, §19.3 03 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

6. This permit subsumes and incorporates all previousl y issued air permits for this facility. [Regulation 26 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

7. A treatment process or waste stream is in complianc e with the requirements of this subpart and exempt from the requirements of paragra ph (c) of this section provided that the owner or operator documents that the treatment process or waste stream is in compliance with other regulatory requirements as fo llows:Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

124

i. The treatment process is a hazardous waste incinera tor for which the owner or operator has been issued a final permit un der 40 CFR Part 270 and complies with the requirements of 40 CFR Part 2 64, Subpart O;

ii. The treatment process is an industrial furnace or b oiler burning hazardous waste for energy recovery for which the owner or op erator has been issued a final permit under 40 CFR Part 270 and complies w ith the requirements of 40 CFR Part 266, Subpart D.

[A.C.A. §8-4-203 as referenced by A.C.A. §8-4-203 a nd §3-4-311 and 40 CFR Part 61, Subpart FF, Benzene Waste Operations, §61.348(d)]

8. The facility shall develop and implement a written startup, shutdown, and malfunction plan for those sources indicated as being subject t o 40 CFR Part 63, Subpart FF, National Emission Standards for Hazardous Air Pollutants fro m Benzene Waste Operations . The plan shall include those items listed in 40 CFR 63. 6(e)(3) et seq. The plan shall be maintained on site and be available to Department p ersonnel upon request. [§19.304 of Regulation 19 and 40 CFR 63.6(e)(3)(i)]

9. The permittee is exempted from certain requirements of this subpart, specifically §§ 63.685 (tanks), 63.688 (containers) and 63.693 (clo sed vent/containment devices) because the unit is subject to equivalent requireme nts imposed pursuant to 40 CFR 61, Subpart FF, Benzene Waste Operations. [40 CFR Part 63, Subpart DD, National Emission Standards for Hazardous Air Pollutants fro m Off-Site Waste and Recovery Operations ]

10. Visible emission observations shall be used as a me thod of compliance verification for the opacity limits assigned for the sources whose S pecific Conditions reference this Plantwide Condition. The weekly observations shall be conducted by someone familiar with the facility’s visible emissions.

a. If during the observations, visible emissions are d etected which appear to be in excess of the permitted opacity limit, the permitte e shall:

i. Take immediate action to identify the cause of the visible emissions, ii. Implement corrective action, and iii. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds t he permitted limit, further corrective measures shall be taken. iv. If no excessive visible emissions are detected, the incident shall be noted in the records as described below.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

125

b. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an asperformed basis. These records shall be kept on si te and made available to Department personnel upon request. These records s hall contain:

i. The time and date of each observation/reading any o bservance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, ii. The cause of any observed exceedance of opacity lim its, corrective actions taken, and results of the reassessment, and iii. The name of the person conducting the observation/r eading.

[§18.1004 of Regulation 18 and A.C.A. §8-4-203 as r eferenced by A.C.A. §8-4-304 and §8-4-311]

11. This facility is considered an affected source and is subject, but not limited to, the following requirements. The referenced requirement s will also include the applicable Subpart EEE NESHAP amendments promulgated by the EP A and as incorporated in the Code of Federal Regulations. Alternatives to the r equirements contained in this permit must be approved by the Administrator. Once the De partment has received written notification of approval of alternative requirement s, the alternate requirements may be implemented. These requirements shall not be in ef fect for existing affected sources until September 30, 2003, unless an extension of this dea dline is granted by the Administrator. [§19.304 of Regulation 19 and 40 CFR 63, Subpart EE E, National Emission Standards for Hazardous Air Pollutants From Hazardous Waste C ombustors ]

Emission Limits

a. The permittee shall not discharge or cause combusti on gases to be emitted into the atmosphere that contain Pursuant to §63.1204(a) ,: i. For dioxins and furans: 1. Emissions in excess of 0.20 ng TEQ/dscm corrected t o 7 percent

oxygen; or 2. Emissions in excess of 0.40 ng TEQ/dscm corrected t o 7 percent oxygen provided that the combustion gas temperature at the inlet to the initial dry particulate matter control device i s 400 °F or lower based on the average of the test run average temper atures; ii. Mercury in excess of 120 μg/dscm corrected to 7 per cent oxygen; iii. Lead and cadmium in excess of 330 μg/dscm, combined emissions, corrected to 7 percent oxygen; iv. Arsenic, beryllium, and chromium in excess of 56 μg /dscm, combined emissions, corrected to 7 percent oxygen;

v. Carbon monoxide and hydrocarbons.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

126 1. For kilns equipped with a by-pass duct or midkiln g as sampling system, either:

a. Carbon monoxide in the by-pass duct or midkiln gas sampling system in excess of 100 parts per million by volume, over an hourly rolling average (monitored continuously with a continuous emissions monitoring system), dry basis and corrected to 7 percent oxyge n, and hydrocarbons in the by-pass duct in excess of 10 pa rts per million by volume over an hourly rolling average (monitored continuously with a continuous emissions monitoring system), dry basis, corrected to 7 perce nt oxygen, and reported as propane, at any time during the destruction and removal efficiency (DRE) test runs or their equivalent as provided by §63.1206(b)(7); or b. Hydrocarbons in the by-pass duct or midkiln gas sam pling system in excess of 10 parts per million by volume, over an hourly rolling average (monitored continuously with a continuous emissions monitoring system), dry basis, corrected to 7 percent oxygen and reported as propa ne; 2. For kilns not equipped with a by-pass duct or midki ln gas sampling system, either;

a. Hydrocarbons in the main stack in excess of 20 ppm by volume, over an hourly rolling average (monitored continuously with a continuous emissions monitoring system), dry basis, corrected to 7 percent oxygen, and reported as propane; or b. Carbon monoxide in the main stack in excess of 100 ppm by volume, over an hourly rolling average (monitore d continuously with a continuous emissions monitoring system), dry basis and corrected to 7 percent oxyg en, and hydrocarbons in the main vent stack in excess of 20 ppm by volume over an hourly rolling average (monitored continuously with a continuos emissions monitoring system), dry basis, corrected to 7 percent oxygen a nd reported as propane, at any time during the DRE tes t runs or their equivalent as provided by §63.1206(b)(7). vi. Hydrochloric acid and chlorine gas in excess of 130 ppm by volume, combined emissions, expressed as hydrochloric acid equivalents, dry basis, corrected to 7 percent oxygen; and vii. Particulate matter in excess of 0.15 kg/Mg dry feed and opacity greater than 20 percent. 1. The permittee must use suitable methods to determin e the kiln raw material feedrate.Ash Grove Cement Company

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127 2. Except as provided in paragraph (a)(7)(iii) of this section, the permittee must compute the particulate matter emiss ion rate, E, from the following equation:

E = (C s × Q sd )/P

Where: E = emission rate of particulate matter, kg/Mg of r aw material feed; C s = concentration of particulate matter, kg/dscm Q sd = volumetric flowrate of effluent gas, dscm/hr P = total kiln raw material feed (dry basis), Mg/hr

. 3. If the permittee operates a preheater or preheater/ precalciner kiln with dual stacks, they must test simultaneously and compute the combined particulate matter emission rate, E c , from the following equation:

E c = (C sk × Q sdk + C sb × Q sdb )/P

Where:

E c = the combined emission rate of particulate matter from the kiln and bypass stack, kg/Mg of raw material feed; C sk = concentration of particulate matter in the kiln effluent, kg/dscm; Q sdk = volumetric flowrate of kiln effluent gas, dscm/h r; C sb = concentration of particulate matter in the bypas s stack effluent, kg/dscm; Q sdb = volumetric flowrate of bypass stack effluent gas , dscm/hr; P = total kiln raw material feed (dry basis), Mg/hr

Destruction and removal efficiency (DRE) standard

b. Except as provided in paragraph (c)(2) of this sect ion, the permittee must achieve a destruction and removal efficiency of 99. 99% for each principle organic hazardous constituent (POHC) designated und er paragraph (c)(3) of this section. The permittee must calculate DRE for each POHC from the following equation:

DRE = [1-(W out

/W in )]×100% Where: W in =mass feedrate of one POHC in a waste feedstream; a nd W out = mass emission rate of the same POHC present in ex haust emissions prior to release to the atmosphere.Ash Grove Cement Company

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128

[§63.1204(c)(1)]

c. If the permittee burns dioxin-listed hazardous wast es FO20, FO21, FO22, FO23, FO26, or FO27 (see §261.31 of this chapter), the permittee must achieve a DRE of 99.9999% for each POHC that is des ignated under paragraph (c)(3) of this section. The permittee must demonst rate this DRE performance on POHCs that are more difficult to incinerate than tetro-, penta, and hexachlorodibenzo-p-dioxins and dibenzofurans. The equation in paragraph (c)(1) of this section shall be used to calculate D RE for each POHC. In addition, the permittee must notify the Administrat or of the intent to burn hazardous wastes FO20, FO21, FO22, FO23, FO26, or F O27. [§63.1204(c)(2)]

d. The permittee must treat the POHCs in the waste fee d that are specified under paragraph (c)(3)(ii) of this section to the extent required by paragraphs (c)(1) and (c)(2) of this section. [§63.1204(c)(3)(i)]

e. The permittee must specify one or more POHCs from t he list of hazardous air pollutants established by 42 U.S.C. 7412(b)(1), exc luding caprolactam (CAS number 105602) as provided by §63.60, for each wast e to be burned. The permittee must base this specification on the degre e of difficulty of incineration of the organic constituents in the was te and on their concentration or mass in the waste feed, considering the results of waste analyses or other data and information. [§63.1204(c)(3)(ii)]

Compliance Date:

f. The permittee must comply with the standards set fo rth in this subpart no later than September 30, 2003 unless the Administrator gr ants an extension of time under §63.6(i) or §63.1213. [§63.1206(a)(1)]

g. The emission standards and operating requirements s et forth in this subpart apply at all times except: i. During startup, shutdown, and malfunction, provided that hazardous waste is not in the combustion chamber (i.e., the hazardo us waste feed to the combustor has been cutoff for a period time not les s than the hazardous waste residence time) during those periods of opera tion, as provided by paragraph (c)(2)(ii) of this section; and ii. When hazardous waste is not in the combustion chamb er (i.e., the hazardous waste feed to the combustor has been cuto ff for a period time not less than the hazardous waste residence time) , and the permittee has 1. submitted a written, one-time notice to the Adminis trator documenting compliance with all applicable requirem ents and standards promulgated under authority of the Clean Air Act, including sections 112 and 129; andAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

129 2. Documented in the operating record that you are com plying with such applicable requirements in lieu of the emissio n standards and operating requirements of this subpart. [§63.1206(b)(1)]

Applicability of particulate matter and opacity sta ndards during particulate matter correlation

tests

h. Any particulate matter and opacity standards or any permit or other emissions

operating parameter limits or conditions, including any limitation on workplace practices, that are applicable to hazardo us waste combustors to insure compliance with any particulate matter or op acity standard of parts 60, 61, 63, 264, 265, and 266 of this chapter (i.e., an y title 40 particulate or opacity standards) applicable to hazardous waste combustor do not apply while the permittee conducts particulate matter continuous em issions monitoring system (CEMS) correlation tests. [§63.1206(b)(8)(i) and ( ii)]

i. For provisions of this section to apply, the permit tee must develop a particulate matter CEMS correlation test plan that includes the following information. This test plan may be included as part of the compr ehensive performance test plan required under §§63.1207(e) and (f): i. Number of test conditions and number of runs for ea ch test condition; ii. Target particulate matter emission level for each t est condition; iii. How you plan to modify operations to attain the des ired particulate matter emission levels; and iv. Anticipated normal emission levels; and

v. Submit the test plan to the Administrator for appro val at least 90 calendar days before the correlation test is scheduled to be conducted.

[§63.1206(b)(8)(iii)(A) and (B)]

j. If the Administrator fails to approve or disapprove the correlation test plan with the time period specified by §63.7(c)(3)(i), t he plan is considered approved, unless the Administrator has requested ad ditional information. [§63.1206(b)(8)(iv)]

k. The particulate matter and associated operating lim its and conditions will not be waived for more than 96 hours, in the aggregate, for a correlation test, including all runs of all test conditions, unless m ore time is approved by the Administrator. [§63.1206(b)(8)(v)]

l. The permittee must return to operating conditions i ndicative of compliance with the applicable particulate matter and opacity standards as soon as possible after correlation testing is completed. [§63.1206( b)(8)(vii)]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

130 Alternative Standards for Existing Hazardous Waste Burning Cement Kilns Using MACT

m. The permittee may petition the Administrator to rec ommend alternative semivolatile, low volatile metal, mercury, and/or h ydrochloric acid/chlorine gas emission standards if: i. The permittee cannot achieve one or more of the sta ndards while using MACT because of raw material contributions to emiss ions of the regulated metals or hydrochloric acid/chlorine gas; or ii. The permittee determines that mercury is not presen t at detectable levels in the raw material.

[§63.1206(b)(10)(i)]

n. The alternative standard recommended under paragrap h (b)(10)(i)(A) of this section may be an operating requirement, such as a hazardous waste feedrate limitation for metals and/or chlorine and/or an emi ssion limitation. [§63.1206(b)(10)(ii)]

o. The alternative standard must include a requirement to use MACT, or better, applicable to the standard for which the source is seeking relief, as defined in paragraphs (b)(10)(viii) and (ix) of this section. [§63.1206(b)(10)(iii)]

p. The alternative standard petitions submitted under this section must include data or information required by this section. [§63 .1206(b)(10)(iv)(A) through §63.1206(b)(10)(ix)(D)]

Calculation of hazardous waste residence time

q. The permittee must calculate the hazardous waste re sidence time and include the calculation in the performance test plan under §63.1207(f) and the operating record. The permittee must also provide the hazardous waste residence time in the Documentation of Compliance u nder §63,1211(d) and the Notification of Compliance under §§63.1207(j) and 6 3.1210(d). [§63.1206(b)(11)]

Documenting compliance with the standard based on p erformance testing

r. The permittee must conduct a minimum of three runs of a performance test required under §63.1207 to document compliance with the emission standards of this subpart. [§63.1206(b)(12)(i)]Ash Grove Cement Company

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s. The permittee must document compliance with the emi ssion standards based on the arithmetic average of the emission results o f each run, except that the permittee must document compliance with the destruc tion and removal efficiency standard for each run of the comprehensi ve performance test individually. [§63.1206(b)(12)(ii)]

Cement kilns which feed hazardous waste at a locati on other than the end where products are normally discharged and where fuels are normally fi red.

t. Cement kilns that feed hazardous waste at a locatio n other than the end where products are normally discharged and where fuels ar e normally fired must comply with the carbon monoxide and hydrocarbon sta ndards of §63.1204 as follows: i. Existing sources must comply with the 20 parts per million by volume hydrocarbon limit, over an hourly rolling average ( monitored continuously with a continuous emissions monitoring system), dry basis, corrected to 7% oxygen, and reported as propane.

[§63.1206(b)(13)(i)]

General Operating Requirements

u. The permittee must operate only under the operating requirements specified in the Documentation of Compliance under §63.1211(d) o r the Notification of Compliance under §§63.1207(j) and 63.1210(d), excep t:

i. During performance tests under approved test plans according to §63.1207(e), (f), and (g), and [§63.1206(c)(1)(i)( A)]

ii. Under the conditions of paragraph (b)(1)(i) or (ii) of this section [§63.1206(c)(1)(i)(B)(i)] 1. The Documentation of Compliance and the Notificatio n of Compliance must contain operating requirements incl uding, but not limited to, the operating requirements of this section and §63.1209. [§63.1206(c)(1)(i)(B)(ii)] 2. Failure to comply with the operating requirements i s failure to ensure compliance with the emissions standards of t his subpart. [§63.1206(c)(1)(i)(B)(iii)] 3. Operating requirements in the Notification of Compl iance are applicable requirements for purposes of parts 70 an d 71 of this chapter. [§63.1206(c)(1)(i)(B)(iv)] 4. The operating requirements specified in the Notific ation of Compliance will be incorporated in the Title V perm it. [§63.1206(c)(1)(i)(B)(v)]Ash Grove Cement Company

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[§63.1206(c)(1)(i)]

v. Except as provided in by paragraph (c)(2)(ii) of th is section, the permittee is subject to the startup, shutdown, and malfunction p lan requirements of §63.6(e)(3).

i. The permittee is subject to the startup, shutdown, and malfunction plan requirements of §63.6(e)(3) even if the permittee f ollows the startup and shutdown procedures and the corrective measures upo n malfunction that are prescribed in the startup, shutdown, and malfun ction plan, the emission combustion chamber. [§63.1206(c)(2)(ii)] ii. The permittee must identify in the plan the project ed oxygen correction factor based on normal operations to use during per iods of startup and shutdown. [§63.1206(c)(2)(iii)] iii. The permittee must record the plan in the operating record. [§63.1206(c)(2)(iv)]

[§63.1206(c)(2)(i)]

w. Upon the compliance date, the permittee must operat e the combustor with a functioning system that immediately and automatical ly cuts off the hazardous waste feed, except as provided by paragraph (c)(3)( viii) of this section, when the following conditions apply:

i. When operating parameter limits specified under §63 .1209; an emission standard monitored by CEMS; and the allowable combu stion chamber pressure; [§63.1206(c)(3)(i)(A)] ii. When the span value of any CMS detector, except a C EMS, is met or exceeded; [§63.1206(c)(3)(i)(B)] iii. Upon malfunction of a CMS monitoring an operating p arameter limit specified under §63.1209 or an emission level; or [§63.1206(c)(3)(i)(C)] iv. When any component of the automatic waste feed cuto ff system fails. [§63.1206(c)(3)(i)(D)]

[§63.1206(c)(3)(i)]

x. During an automatic waste feed cutoff (AWFCO) the p ermittee must continue to duct combustion gases to the air pollution contr ol system while hazardous waste remains in the combustion chamber. [§63.1206 (c)(3)(ii)]

y. The permittee must continue to monitor during the c utoff the operating parameters for which limits are established under § 63.1209 and the emissions required under that section to be monitored by a CE MS, and the permittee shall not restart the hazardous waste feed until the oper ating parameters and emission levels are within specified limits. [§63. 1206(c)(3)(iii)]Ash Grove Cement Company

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z. If the AWFCO system fails to automatically and imme diately cutoff the flow of hazardous waste upon exceedance of a parameter r equired to be interlocked with the AWFCO system under paragraph (c)(3)(i) of this section, the permittee has failed to comply with the AWFCO requi rements of paragraph (c)(3) of this section. [§63.1206(c)(3)(iv)]

aa. If, after any AWFCO, there is an exceedance of any emission standard or operating requirement, irrespective of whether the exceedance occurred while hazardous waste remained in the combustion chamber, the permittee shall investigate the cause of the AWFCO, take appropriat e corrective measures to minimize future AWFCOs and record the findings and corrective measures in the operating record. [§63.1206(c)(3)(v)]

bb. For each set of 10 exceedances of an emissions stan dard or operating requirement while hazardous waste remains in the co mbustion chamber during a 60-day block period, the permittee must submit to the Administrator a written report within 5 calendar days of the 10 th exceedance documenting the exceedances and the results of the investigation an d corrective measures taken. [§63.1206(c)(3)(vi)(A)]

cc. On a case-by-case basis, the Administrator may requ ire excessive exceedance reporting when fewer than 10 exceedances occur duri ng a 60-day block period. [§63.1206(c)(3)(vi)(B)]

dd. The AWFCO system and associated alarms must be test ed at least weekly to verify operability, unless the permittee documents in the operating record that weekly inspections will unduly restrict or upset op erations and that less frequent inspection will be adequate. At a minimum , the permittee must conduct operability testing at least monthly. The permittee must document and record in the operating record AWFCO operability te st procedures and results. [§63.1206(c)(3)(vii)]

ee. The permittee shall use a COMS to demonstrate and m onitor compliance with the opacity standard under §§63.1204(a)(7) and (b)( 7) at each point where emissions are vented from these affected sources in cluding the bypass stack of a preheater/precalciner kiln with dual stacks. [§6 3.1209(a)(1)(ii)]

ff. The permittee is subject to the combustion system l eak control system operating and reporting requirements set forth in t his section. [§63.1206(c)(5)(i through ii)]

gg. The permittee is subject to the operator training a nd certification standards set forth in this section. [§63.1206(c)(6)(i through v )]Ash Grove Cement Company

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hh. The permittee must prepare and at all times operate according to an operation and maintenance plan which complies with the requir ements set forth in these sections. [§63.1206(c)(7)(i)(A-D)]

Performance Testing Requirements

ii. The permittee must conduct performance testing in a ccordance with the applicable requirements contained in this section. [§63.1207(a-n)]

jj. The permittee must commence the initial comprehensi ve performance test not later than six months after the compliance date. [ §63.1207(c)(1)]

kk. The permittee may request that previous emissions t est data serve as documentation of conformance with the emission stan dards of this subpart provided that the previous testing: i. Results in data that meet quality assurance objecti ves (determined on a site-specific basis) such that the results adequate ly demonstrate compliance with the applicable standard; ii. Was in conformance with the requirements of paragra ph (g)(1) of this section; and, iii. Was sufficient to establish the applicable operatin g parameter limits under §63.1209.

[§63.1207(C)(2)(i)]

ll. The permittee must conduct testing periodically as described in paragraphs (d)(1) through (3) of this section. The date of co mmencement of the initial comprehensive performance test is the basis for est ablishing the deadline to commence the initial confirmatory performance test and the next comprehensive performance test. The permittee may conduct performance testing at any time prior to the required date. Th e deadline for commencing subsequent confirmatory and comprehensive performan ce testing is based on the date of commencement of the previous comprehens ive performance test.

i. The permittee must commence testing no later than 6 1 months after the date of commencing the previous comprehensive perfo rmance test. ii. The permittee must commence confirmatory performanc e testing no later than 31 months after the date of commencing the pre vious comprehensive performance test. To insure that the confirmatory test is conducted approximately midway between comprehensive performa nce tests, the Administrator will not approve a test plan that sch edules testing within 18 months of commencing the previous comprehensive per formance test. iii. The permittee must complete performance testing wit hin 60 days after the date of commencement, unless the Administrator dete rmines that a time extension is warranted based on documentation in wr iting of factorsAsh Grove Cement Company

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beyond the permittee’s control that prevent testing from being completed within 60 days.

[§63.1207(d)(1) through (3)]

mm. The permittee must submit to the Administrator a no tification of intent to conduct a comprehensive performance test and CMS pe rformance evaluation and a site specific test plan and CMS performance e valuation plan at least one year before the performance test and performance ev aluation are scheduled to begin. [§63.1207(e)(i)]

nn. The permittee must submit to the Administrator a no tification of intent to conduct the comprehensive performance test at least 60 calendar days before the test is scheduled to begin. [§63.1207(e)(i)(B) ]

oo. The permittee must submit to the Administrator a no tification of intent to conduct a confirmatory performance test and CMS per formance evaluation and a test plan and CMS performance evaluation plan at least 60 calendar days before the performance test is scheduled to begin. [§63.1207(e)(ii)]

Test Methods

pp. The permittee shall use the test methods contained in this section when determining compliance with the emissions standards of this subpart. [§63.1208(a-b)]

Monitoring Requirements

qq. The permittee is subject to the applicable monitori ng requirements contained in these sections. [§63.1209 (a-q)]

rr. The permittee must use a CEMS to demonstrate and mo nitor compliance with the carbon monoxide and hydrocarbon standards under this subpart. The permittee must also use an oxygen CEMS to continuou sly correct the carbon monoxide and hydrocarbon levels to 7 percent oxygen . [§63.1209(a)(1)(i)]

ss. The permittee must install, calibrate, maintain, an d operate a particulate matter CEMS to demonstrate and monitor compliance with the particulate matter standards under this subpart. However, compliance with the requirements in their section to install, calibrate, maintain, and operate the PM CEMS is not required until such time that the Agency promulgate s all performance specifications and operational requirements applica ble to PM CEMS. [§63.1209(a)(1)(iii)]Ash Grove Cement Company

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tt. The permittee must install, calibrate, maintain, an d continuously operate the COMS and CEMS in compliance with the quality assura nce procedures provided in the appendix to this subpart and Perfor mance Specifications 1 (opacity), 4B (carbon monoxide and oxygen), and 8A (hydrocarbons) in Appendix B, Part 60 of this chapter. [§63.1209(a)( 2)]

uu. Prior to feeding the material, the permittee must o btain an analysis of each feedstream that is sufficient to document complianc e with the applicable feedrate limits provided in this section. [§63.120 9(c)(1)]

vv. The permittee must develop and implement a feedstre am analysis plan and record it in the operating record. [§63.1209(c)(2) ]

ww. The permittee must submit the feedstream analysis p lan to the Administrator for review and approval, if requested. [§63.1209(c )(3)]

xx. To comply with the applicable feedrate limits of th is section, the permittee must monitor and record the feedrates as follows: i. Determine and record the value of the parameter for each feedstream by sampling and analysis or other method; ii. Determine and record the mass or volume flowrate of each stream by a CMS. If the permittee determines flowrate of a fee dstream by volume, the permittee must determine and record the density of the feedstream by sampling and analysis (unless the permittee reports the constituent concentration in units of weight per volume); and iii. Calculate and record the mass feedrate of the param eter per unit time.

[§63.1209(c)(4)]

yy. The requirements of §§63.8(d) (Quality control prog ram) and (e) (Performance evaluation of continuous monitoring systems) apply, except that the permittee must conduct performance evaluations components of the CMS under the frequency and procedures (for example, submittal of performance evaluation test plan for review and approval) applicable to pe rformance tests as provided by §63.1207. [§63.1209(d)(1)]

zz. To remain in compliance with the destruction and re moval efficiency (DRE) standards, the permittee must establish operating l imits during the comprehensive performance test (or during a previou s DRE test under provisions of §63.1206(b)(7)) for the following par ameters, unless the limits are based on manufacturer specifications and comply with those limits at all times that hazardous waste remains in the combustio n chamber. [§63.1209(j)]

aaa. The permittee must measure the temperature of each combustion chamber at a location that best represents, as practicable, the bulk gas temperature in theAsh Grove Cement Company

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combustion zone. The permittee must document the t emperature measurement location in the test plan submitted under §63.1207( e). [§63.1209(j)(1)(i)]

bbb. As an indicator of gas residence time in the contro l device, the permittee must establish and comply with a limit on the maximum fl ue gas flowrate, the maximum production rate, or another parameter that is documented in the sitespecific test plan as an appropriate surrogate for gas residence time, as the average of the maximum hourly rolling averages for each run. [§63.1209(j)(2)(i)]

ccc. The permittee must establish limits on the maximum pumpable and total (i.e., pumpable and nonpumpable) hazardous waste feedrate for each location where hazardous waste is fed. [§63.1209(j)(3)(i)]

ddd. The permittee must specify operating parameters and limits to insure that good operation of each hazardous waste firing system is maintained. [§63.1209(j)(4)]

eee. The permittee must comply with the dioxin and furan s emission standard by establishing and complying with the following opera ting parameter limits. You must base the limits on operations during the c omprehensive performance test, unless the limits are based on manufacturer s pecifications. [§63.1209(k)]

fff. The permittee must establish a limit on the maximum temperature of the gas at the inlet to the device on an hourly rolling averag e. The permittee must establish the hourly rolling average limit as the a verage of the test run averages. [§63.1209(k)(1)(i)]

ggg. The permittee must measure the temperature of each combustion chamber at a location that best represents, as practicable, the bulk gas temperature in the combustion zone. The permittee must document the t emperature measurement location in the test plan. [§63.1209(k)(2)(i)]

hhh. As an indicator of gas residence time in the contro l device, the permittee must establish and comply with a limit on the maximum fl ue gas flowrate, the maximum production rate , or another parameter whic h is an appropriate surrogate for residence time. [§63.1209(k)(3)(i)]

iii. The permittee must establish limits on the maximum pumpable and total (pumpable and nonpumpable) waste feedrate for each location where waste is fed. [§63.1209(k)(4)(i)]

jjj. The permittee must comply with the particulate matt er emission standard by establishing and complying with the operating param eter limits found in §63.1209(m) of this subpart. [§63.1209(m)]Ash Grove Cement Company

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kkk. If the combustor is equipped with a baghouse, the p ermittee must establish a limit on the minimum pressure drop and the maximum pressure drop across each baghouse cell based on manufacturer’s specific ations. The permittee must comply with the limit on an hourly rolling ave rage. [§63.1209(m)(1)(ii)]

lll. The permittee must comply with the semivolatile met al (cadmium and lead) and low volatile metal (arsenic, beryllium, and chr omium) emission standards by establishing and complying with the following op erating parameter limits.

i. The permittee must establish a limit on the maximum inlet temperature to the primary dry metals emissions control device on an hourly rolling basis as the average of the test run averages. [§63.1209 (n)(1)] ii. The permittee must establish feedrate limits for se mivolatile metals and low volatile metals. [§63.1209(n)(2)(i)] iii. The permittee must establish operating parameter li mits on the particulate matter control device as specified by paragraph 63. 1209(m)(1). [§63.1209(n)(3)] iv. The permittee must establish a 12-hour rolling aver age limit for the feedrate of total chlorine and chloride in all feed streams as the average of the average hourly rolling averages for each run. [§63.1209(n)(4)]

[§63.1209(n)]

mmm. If the permittee complies with the requirements for combustion system leaks under §63.1206(c)(5) by maintaining combustion cham ber zone pressure lower than ambient pressure, the permittee must monitor t he pressure instantaneously and the automatic waste feed cutoff system must be engaged when negative pressure is not maintained at any time. [§63.1209( p)]

Notification Requirements

nnn. The permittee shall submit all of the applicable no tifications prior to the deadlines established in this subpart. [§63.1210(a )(1)]

ooo. The permittee must submit the required notification s outlined in this section to the Administrator in order to request or elect to c omply with the alternative requirements contained in this subpart. [§63.1210( a)(2)]

ppp. Upon postmark of the Notification of Compliance, th e operating parameter limits identified in the Notification of Compliance , as applicable, shall be complied with, the limits identified in the Documen t of Compliance or a previous Notification of Compliance are no longer a pplicable. [§63.1210(d)(2)]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

139 Recordkeeping and Reporting Requirements

qqq. The permittee shall submit the reports required by this subpart to the Administrator prior to the deadlines set forth in t his subpart. [§63.1211]

Procedure for Extending the Compliance Date

rrr. The permittee may request an extension of the compl iance date to install pollution prevention or waste minimization controls provided that the conditions outlined in this section are met. [§63. 1213]

12. This facility is considered an affected facility an d is subject, but not limited to, the following requirements. The referenced requirement s will also include the applicable Subpart LLL NESHAP amendments promulgated by the EP A and as incorporated in the Code of Federal Regulations. [§19.304 of Regulatio n 19 and 40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollu tants from the Portland Cement Manufacturing Industry ]

Standards for kilns

a. The permittee shall not cause to be discharged into the atmosphere from these affected sources any gases which: i. Contain particulate matter (PM) in excess of 0.15 k g per Mg (0.30 lb per ton) of feed (dry basis) to the kiln. When there i s an alkali bypass associated with a kiln or in-line kiln/raw mill, th e combined particulate matter emissions from the kiln or in-line kiln/raw mill and the alkali bypass are subject to this emission limit. ii. Exhibit opacity greater than 20 percent. iii. Contain D/F in excess of: 1. 0.20 ng per dscm (8.7 x 10 -11 gr per dscf) (TEQ) corrected to seven percent oxygen; or 2. 0.40 ng per dscm (1.7 x 10 -10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the average of the performance test run average temperatures at the inlet to the particulat e matter control device is 204 °C (400 °F) or less. [§63.1343(b)]

b. A kiln subject to the D/F limitation under §63.1343 must operate the kiln such that the temperature of the gas at the inlet to the kiln particulate matter control device (PMCD) and alkali bypass PMCD, if applicable , does not exceed the applicable temperature limit specified in paragraph (b) of this section. [§63.1344(a)]Ash Grove Cement Company

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140

c. The temperature limit for affected sources meeting the limits of paragraph (a) of this section or paragraphs (a)(1) through (a)(3) of this section is determined in accordance with §63.149(b)(3)(iv). [§63.1344(b) ]

Standards for Clinker Coolers

d. The permittee shall not cause to be discharged into the atmosphere from any clinker cooler any gases which: i. Contain particulate matter in excess of 0.050 kg pe r Mg (0.10 lb per ton) of feed (dry basis) to the kiln. ii. Exhibit opacity greater than 10 percent.

[§63.1345(a)] Standards for Raw and Finish Mills

e. The permittee shall not cause to be discharged from the mill sweep or air separator air pollution control devices for each fi nish mill any gases which exhibit opacity in excess of ten percent. [§63.134 7]

Standards for affected sources other than kilns; in -line kilns/raw mills; new and reconstructed raw material dryers; and raw and finish mills

f. The owner or operator of each new or existing raw m aterial, clinker or finished product storage bin; conveying system transfer poin t; bagging system; and bulk loading or unloading system; and each existing raw material dryer, at a facility which is a major source subject to the pro vision of this subpart shall not cause to be discharged any gases from these aff ected sources which exhibit opacity in excess of ten percent. [§63.1348]

Performance testing requirements

g. The permittee shall use the test methods and proced ures contained in this section to demonstrate compliance with the emission s limits set forth by this subpart. [§63.1349]

Monitoring requirements

h. The owner or operator of each portland cement plant shall prepare for each affected source subject to the provisions of this s ubpart, a written operations and maintenance plan. The permittee shall also com ply with all applicable monitoring requirements contained in this section. [§63.1350]Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

141 Compliance dates

i. Existing sources shall comply with this subpart no later than June 14, 2002. [§63.1351(a)]

j. The compliance date for new construction or reconst ruction after March 24, 1998 is immediately upon start of operations. [§63 .1351(b)]

Notification requirements

k. The permittee shall comply with all applicable noti fication requirements set forth in this section. [§63.1353(a)]

Reporting Requirements

l. The permittee shall comply with all applicable repo rting requirements set forth in this section. [§63.1354(a)]

Recordkeeping Requirements

m. The permittee shall comply with all applicable reco rdkeeping requirements set forth in this section. [§63.1355(a)]

13. The facility shall develop and implement a written startup, shutdown, and malfunction plan for sources subject to 40 CFR 63, Subpart EEE, National Emission Standards for Hazardous Air Pollutants From Hazardous Waste Combu stors . The plan shall include those items listed in 40 CFR 63.6(e)(3) et seq. Th e plan shall be maintained on site and be available to Department personnel upon request. [§19.304 and 40 CFR 63.6(e)(3)(i)]

14. The facility shall develop and implement a written startup, shutdown, and malfunction plan for sources subject to 40 CFR 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants From the Portland Cement M anufacturing Industry . The plan shall include those items listed in 40 CFR 63.6(e)( 3) et seq. The plan shall be maintained on site and be available to Department personnel up on request. [§19.304 and 40 CFR 63.6(e)(3)(i)]

15. The visible emission observations shall be used as a method of compliance verification for the opacity limits assigned for the sources who se Specific Conditions reference this Plantwide Condition. The monthly observations shal l be conducted by someone familiar with the facility’s visible emissions.

a. If during the observations, visible emissions are d etected which appear to be in excess of the permitted opacity limit, the permitte e shall:

i. Take immediate action to identify the cause of the visible emissions,Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

142

ii. Implement corrective action, and iii. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 . This reading shall be conducted by a person trained and certifie d in the reference method. If the opacity reading exceeds the permitt ed limit, further corrective measures shall be taken. iv. If no excessive visible emissions are detected, the incident shall be noted in the records as described below.

b. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an asperformed basis. These records shall be kept on si te and made available to Department personnel upon request. These records s hall contain:

i. The time and date of each observation/reading any o bservance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, ii. The cause of any observed exceedance of opacity lim its, corrective actions taken, and results of the reassessment, and iii. The name of the person conducting the observation/r eading.

[§18.1004 of Regulation 18, 40 CFR Part 63, Subpart LLL and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

16. The permittee may choose to comply with the emissio n standards set forth in 40 CFR part 63, Subpart LLL when hazardous waste is not in the combustion chamber (i.e., the hazardous waste feed to the combustor has been cuto ff for a period time not less than the hazardous waste residence time). The permittee mus t document in the facility record when they are operating under 40 CFR 63, Subpart LL L. These records shall be maintained on site and made available to Department personnel upon request. [§19.304 of Regulation 19, and 40 CFR Part 63, Subpart EEE, §63.1206(b)(1)]

Title VI Provisions

17. The permittee must comply with the standards for la beling of products using ozonedepleting substances. [40 CFR Part 82, Subpart E]

a. All containers containing a class I or class II sub stance stored or transported, all products containing a class I substance, and al l products directly manufactured with a class I substance must bear the required warning statement if it is being introduced to interstate c ommerce pursuant to §82.106. b. The placement of the required warning statement mus t comply with the requirements pursuant to §82.108.

c. The form of the label bearing the required warning must comply with the requirements pursuant to §82.110.Ash Grove Cement Company

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143

d. No person may modify, remove, or interfere with the required warning statement except as described in §82.112.

18. The permittee must comply with the standards for re cycling and emissions reduction, except as provided for MVACs in Subpart B. [40 CFR Part 82, Subpart F]

a. Persons opening appliances for maintenance, service , repair, or disposal must comply with the required practices pursuant to §82. 156. b. Equipment used during the maintenance, service, rep air, or disposal of appliances must comply with the standards for recyc ling and recovery equipment pursuant to §82.158.

c. Persons performing maintenance, service repair, or disposal of appliances must be certified by an approved technician certificatio n program pursuant to §82.161. d. Persons disposing of small appliances, MVACs, and M VAC like appliances must comply with record keeping requirements pursua nt to §82.166. (“MVAC like appliance” as defined at §82.152)

e. Persons owning commercial or industrial process ref rigeration equipment must comply with leak repair requirements pursuant to §8 2.156. f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purcha sed and added to such appliances pursuant to §82.166.

19. If the permittee manufactures, transforms, destroys , imports, or exports a class I or class II substance, the permittee is subject to all requi rements as specified in 40 CFR Part 82, Subpart A, Production and Consumption Controls.

20. If the permittee performs a service on motor (fleet ) vehicles when this service involves ozone depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is su bject to all the applicable requirements as specified in 40 CFR part 82, Subpar t B, Servicing of Motor Vehicle Air Conditioners.

The term “motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. Th e term “MVAC” as used in Subpart B does not include the air tight sealed refrigerati on system used as refrigerated cargo, or the system used on passenger buses using HCFC 22 re frigerant.

21. The permittee can switch from any ozone depleting s ubstance to any alternative listed in the Significant New Alternatives Program (SNAP) pro mulgated pursuant to 40 CFR Part 82, Subpart G.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

144 Permit Shield

22. Compliance with the conditions of this permit shall be deemed compliance with all applicable requirements, as of the date of permit i ssuance, included in and specifically identified in the following table of this condition . The permit specifically identifies the following as applicable requirements based upon the information submitted by the permittee in an application dated dated October 199 6, as amended in September 1997, December 1998, April 1999, and October 2000.

Applicable Regulations

Source No. Regulation Description

F19, F20 40 CFR 60, Subpart Kb Standards of Perform ance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced after July 23,

1984 P1, P2, P3 40 CFR 63, Subpart EEE Emission Standards for Hazardous Waste Combustors P5, P6, P8, P10, P11, P12, P13, P15, P16, P17, P18, P19, P20, P26, P27, P28, P29, P30, P31, M1, M3, M4, M8, M9, M10, M11, M12, M13, M14, M15, M16, M17, M18, M19, M20, M21, M22, M23, M24, M25, M26, M27, M28, M29, M30, M31, M32, M33, M34, M35, M36, M37, M38, M39, M40, M42, M43, M44, M45, S1, S3-S13, C1- C11, C13-C21, C26- C28, C32-C37, C41- C44 40 CFR 63, Subpart LLL Emission Standards for Portland Cement Plants

F19, F20 Facility 40 CFR 61, Subpart FF

40 CFR 63, Subpart DD Benzene Waste Operations

Facility Arkansas Regulation 19 Compilation of Regu lations of the Arkansas State Implementation Plan for Air Pollution ControlAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

145 Source No. Regulation Description Facility Arkansas Regulation 26 Regulations of the Arkansas Operating Air Permit Program

The permit specifically identifies the following as inapplicable based upon information submitted by the permittee in an application dated October 1996, as amended September 1997, December 1998, and April 1999.

Inapplicable Regulations

Description of Regulation Regulatory

Citation Affected

Source Basis for Determination

New Source Performance Standards 40 CFR 60, Subpart F P1, P2, P3, P6,

M16, M17, M18, M19, M20, M42, M43, M44, S4, S6, S7, S8, S9, S10, S11, S12, S13, C13, C14, C18 Units were constructed prior to the

effective date of the subpart

New Source Performance Standards 40 CFR 60, Subpart Y P4, P7, P9, P24 Final Direct Rule (April 5, 2002) [FR-7168-1] New Source Performance Standards 40 CFR 60, Subpart OOO Facility Sources installed before applicability date or subject to Subpart F are exempt from OOO. National Emission Standards for Hazardous Air Pollutants 40 CFR 61,

Subpart DD Facility Facility subject to FF exempt from requirements of this subpart.Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

146

SECTION VII: INSIGNIFICANT ACTIVITIES

The following sources are insignificant activities. Any activity that has a state or federal applicable requirement shall be considered a signif icant activity even if this activity meets the criteria of §26.304 of Regulation 26 or listed in t he table below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated October 30, 2000. [Regulation 26, §26.304]

Description Category

Piles associated with clean-up Group A, #13

Auxiliary drive to turn kilns Group A, #13

11,000 gallon oil tank Group A, #13

11,000 gallon oil tank Group A, #13

250 gallon fuel tank Group A, #2

10,000 gallon diesel UST Group A, #3

10,000 gallon unleaded UST Group A, #13

8,000 diesel tank Group A, #3

600 gallon tank Group A, #3Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

147 SECTION VIII: GENERAL PROVISIONS

1. Any terms or conditions included in this permit whi ch specify and reference Arkansas Pollution Control & Ecology Commission Regulation 1 8 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the sole origin of and authority for the terms or conditions are not required under the Clea n Air Act or any of its applicable requirements, and are not federally enforceable und er the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 1 8 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A . §8-4-101 et seq.). Any terms or conditions included in this permit which specify an d reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the A rkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority for the terms or conditions are enforceable under this Arkansas stat ute. [40 CFR 70.6(b)(2)]

2. This permit shall be valid for a period of five (5) years beginning on the date this permit becomes effective and ending five (5) years later. [40 CFR 70.6(a)(2) and §26.701(B) of the Regulations of the Arkansas Operating Air Permi t Program (Regulation 26), effective August 10, 2000]

3. The permittee must submit a complete application fo r permit renewal at least six (6) months before permit expiration. Permit expiration terminates the permittee’s right to operate unless the permittee submitted a complete r enewal application at least six (6) months before permit expiration. If the permittee submits a complete application, the existing permit will remain in effect until the Dep artment takes final action on the renewal application. The Department will not neces sarily notify the permittee when the permit renewal application is due. [Regulation 26, §26.406]

4. Where an applicable requirement of the Clean Air Ac t, as amended, 42 U.S.C. 7401, et seq. (Act) is more stringent than an applicable req uirement of regulations promulgated under Title IV of the Act, the permit incorporates both provisions into the permit, and the Director or the Administrator can enforce both prov isions. [40 CFR 70.6(a)(1)(ii) and Regulation 26, §26.701(A)(2)]

5. The permittee must maintain the following records o f monitoring information as required by this permit. [40 CFR 70.6(a)(3)(ii)(A) and Regu lation 26, §26.701(C)(2)]

a. The date, place as defined in this permit, and time of sampling or measurements; b. The date(s) analyses performed;

c. The company or entity performing the analyses; d. The analytical techniques or methods used;

e. The results of such analyses; and f. The operating conditions existing at the time of sa mpling or measurement.

6. The permittee must retain the records of all requir ed monitoring data and support information for at least five (5) years from the da te of the monitoring sample,Ash Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

148 measurement, report, or application. Support infor mation includes all calibration and maintenance records and all original strip chart re cordings for continuous monitoring instrumentation, and copies of all reports required by this permit. [40 CFR 70.6(a)(3)(ii)(B) and Regulation 26, §26.701(C)(2)( b)]

7. The permittee must submit reports of all required m onitoring every six (6) months. If permit establishes no other reporting period, the r eporting period shall end on the last day of the anniversary month of the initial Title V per mit. The report is due within thirty (30) days of the end of the reporting period. Although the reports are due every six months, each report shall contain a full year of data. The report must clearly identify all instances of deviations from permit requirements. A responsi ble official as defined in Regulation No. 26, §26.2 must certify all required reports. T he permittee will send the reports to the address below: [40 C.F.R. 70.6(a)(3)(iii)(A) and Re gulation 26, §26.701(C)(3)(a)]

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box 8913 Little Rock, AR 72219

8. The permittee shall report to the Department all de viations from permit requirements, including those attributable to upset conditions as defined in the permit.

a. For all upset conditions (as defined in Regulation1 9, § 19.601), the permittee will make an initial report to the Department by the nex t business day after the discovery of the occurrence. The initial report my be made by telephone and shall include:

i. The facility name and location ii. The process unit or emission source deviating from the permit limit, iii. The permit limit, including the identification of p ollutants, from which deviation occurs, iv. The date and time the deviation started,

v. The duration of the deviation, vi. The average emissions during the deviation, vii. The probable cause of such deviations, viii. Any corrective actions or preventive measures taken or being taken to prevent such deviations in the future, and ix. The name of the person submitting the report.

The permittee shall make a full report in writing t o the Department within five (5) business days of discovery of the occurrence. The report must include, in addition to the information required by the initial report, a s chedule of actions taken or planned to eliminate future occurrences and/or to minimize the amount the permit’s limits were exceeded and to reduce the length of time the limits were exceeded. TheAsh Grove Cement Company

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149

permittee may submit a full report in writing (by f acsimile, overnight courier, or other means) by the next business day after discovery of the occurrence, and the report will serve as both the initial report and full report.

b. For all deviations, the permittee shall report such events in semi-annual reporting and annual certifications required in this permit. This includes all upset conditions reported in 8a above. The semi-annual r eport must include all the information as required by the initial and full rep orts required in 8a.

[Regulation 19, §19.601 and §19.602, Regulation 26, §26.701(C)(3)(b), and 40 CFR 70.6(a)(3)(iii)(B)]

9. If any provision of the permit or the application t hereof to any person or circumstance is held invalid, such invalidity will not affect other provisions or applications hereof which can be given effect without the invalid provision o r application, and to this end, provisions of this Regulation are declared to be se parable and severable. [40 CFR 70.6(a)(5), Regulation 26, §26.701(E), and A.C.A. § 8-4-203 as referenced by A.C.A. §8- 4-304 and §8-4-311]

10. The permittee must comply with all conditions of th is Part 70 permit. Any permit noncompliance with applicable requirements as defin ed in Regulation 26 constitutes a violation of the Clean Air Act, as amended, 42 U.S. C. §7401, et seq. and is grounds for enforcement action; for permit termination, revocat ion and reissuance, for permit modification; or for denial of a permit renewal app lication. [40 CFR 70.6(a)(6)(i) and Regulation 26, §26.701(F)(1)]

11. It shall not be a defense for a permittee in an enf orcement action that it would have been necessary to halt or reduce the permitted activity to maintain compliance with the conditions of this permit. [40 CFR 70.6(a)(6)(ii) and Regulation 26, §26.701(F)(2)]

12. The Department may modify, revoke, reopen and reiss ue the permit or terminate the permit for cause. The filing of a request by the p ermittee for a permit modification, revocation and reissuance, termination, or of a not ification of planned changes or anticipated noncompliance does not stay any permit condition. [40 CFR 70.6(a)(6)(iii) and Regulation 26, §26.701(F)(3)]

13. This permit does not convey any property rights of any sort, or any exclusive privilege. [40 CFR 70.6(a)(6)(iv) and Regulation 26, §26.701(F )(4)]

14. The permittee must furnish to the Director, within the time specified by the Director, any information that the Director may request in writin g to determine whether cause exists for modifying, revoking and reissuing, or terminating t he permit or to determine compliance with the permit. Upon request, the permittee must also furnish to the Director copies of records required by the permit. For information th e permittee claims confidentiality, the Department may require the permittee to furnish suc h records directly to the DirectorAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

150 along with a claim of confidentiality. [40 CFR 70. 6(a)(6)(v) and Regulation 26, §26.701(F)(5)]

15. The permittee must pay all permit fees in accordanc e with the procedures established in Regulation 9. [40 CFR 70.6(a)(7) and Regulation 26 , §26.701(G)]

16. No permit revision shall be required, under any app roved economic incentives, marketable permits, emissions trading and other sim ilar programs or processes for changes provided for elsewhere in this permit. [40 CFR 70.6(a)(8) and Regulation 26, §26.701(H)]

17. If the permit allows different operating scenarios, the permittee shall, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted facility a record of the operational scen ario. [40 CFR 70.6(a)(9)(i) and Regulation 26, §26.701(I)(1)]

18. The Administrator and citizens may enforce under th e Act all terms and conditions in this permit, including any provisions designed to limit a source’s potential to emit, unless the Department specifically designates terms and condit ions of the permit as being federally unenforceable under the Act or under any of its app licable requirements. [40 CFR 70.6(b) and Regulation 26, §26.702(A) and (B)]

19. Any document (including reports) required by this p ermit must contain a certification by a responsible official as defined in Regulation 26, §26.2. [40 CFR 70.6(c)(1) and Regulation 26, §26.703(A)]

20. The permittee must allow an authorized representati ve of the Department, upon presentation of credentials, to perform the followi ng: [40 CFR 70.6(c)(2) and Regulation 26, §26.703(B)]

a. Enter upon the permittee’s premises where the permi tted source is located or emissions related activity is conducted, or where r ecords must be kept under the conditions of this permit; b. Have access to and copy, at reasonable times, any r ecords required under the conditions of this permit;

c. Inspect at reasonable times any facilities, equipme nt (including monitoring and air pollution control equipment), practices, or operati ons regulated or required under this permit; and d. As authorized by the Act, sample or monitor at reas onable times substances or parameters for assuring compliance with this permit or applicable requirements.

21. The permittee shall submit a compliance certificati on with the terms and conditions contained in the permit, including emission limitat ions, standards, or work practices. The permittee must submit the compliance certification annually within 30 days following the last day of the anniversary month of the initial Ti tle V permit. The permittee must alsoAsh Grove Cement Company

Permit #: 75-AOP-R6 AFIN: 41-00001

151 submit the compliance certification to the Administ rator as well as to the Department. All compliance certifications required by this perm it must include the following: [40 CFR 70.6(c)(5) and Regulation 26, §26.703(E)(3)]

a. The identification of each term or condition of the permit that is the basis of the certification; b. The compliance status; c. Whether compliance was continuous or intermitten t; d. The method(s) used for determining the complianc e status of the source, currently and over the reporting period established by the mo nitoring requirements of this permit; e. and Such other facts as the Department may requi re elsewhere in this permit or by §114(a)(3) and §504(b) of the Act.

22. Nothing in this permit will alter or affect the fol lowing: [Regulation 26, §26.704(C)]

a. The provisions of Section 303 of the Act (emergency orders), including the authority of the Administrator under that section; b. The liability of the permittee for any violation of applicable requirements prior to or at the time of permit issuance;

c. The applicable requirements of the acid rain progra m, consistent with §408(a) of the Act or, d. The ability of EPA to obtain information from a sou rce pursuant to §114 of the Act.

23. This permit authorizes only those pollutant emittin g activities addressed in this permit. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 a nd §8-4-311]