ADEQ 

OPERATING 

AIR PERMIT

Pursuant to the Regulations of the Arkansas Operating 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 PERMITTEE TO INSTALL, 

OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS 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 CONDITIONS CONTAINED 

HEREIN. 

Signed: 

 

Mike Bates Date Modified

Chief, Air Division
Ash 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 Storage 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......................................................................................................................................... 3 
Ash 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 Plan
Ash 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 

NOx Nitrogen Oxide 

PM Particulate Matter 

PM10 Particulate Matter Smaller Than Ten Microns 

SNAP Significant New Alternatives Program (SNAP) 

SO2 Sulfur Dioxide 

SSM Startup, Shutdown, and Malfunction Plan 

Tpy Tons Per Year 

UTM Universal Transverse Mercator 

VOC Volatile Organic Compound 
Ash 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, Plant Manager 

TELEPHONE NUMBER: (501) 542-6217 

 

REVIEWING ENGINEER: Wesley Crouch 

 

UTM North South (Y): Zone 15: 3728.9 

 

UTM East West (X): Zone 15: 368.35 
Ash 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 additional PM emissions of 0.5 tpy and PM10 

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 portland cement clinker. 

4. Grinding of a mixture of clinker and gypsum into various 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 structure. Sand and iron ore are received from off 

site and stored in separate outdoor piles. The chalk, 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 ball mill and ground into a slurry. The slurry 

is pumped and metered into three rotary cement kilns in which chemical reactions occur to form 

clinker, an intermediate product that ultimately becomes portland cement. 

From time-to-time, spent kiln brick removed from the 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 materials. 

The raw material slurry is fed to the rotary kiln pyroprocessing 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 slurry is fed to the kiln at the upper, or feed, end. 

Fuel generally is introduced at the lower, or burning, end of the kiln. The slope and rotation of 

the kiln allows the slurry to flow by gravity through 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 particulate 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 at a material temperature of about 2700 °F. 

The clinker exits at the burning end of the kiln and falls into clinker coolers in which the clinker 

is air cooled. A portion of this air is used for combustion 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 series of conveyors to clinker storage silos. The 

clinker can also be transported by conveyor to an enclosed storage dome or by truck to an 

outside storage pile. 

Clinker taken from storage is sent to finish milling. During finish milling, clinker is ground with 

gypsum and/or other additives to produce portland cement and masonry cement. Gypsum is 

delivered to the plant from off site sources and stored in an outdoor pile adjacent to the raw 

material storage areas. Gypsum is withdrawn from the 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 mills to several storage silos. From these 

silos, the cement is loaded into rail cars and trucks or packed into bags for shipment. 

The fuel sources used to produce clinker at the Foreman 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 kiln through a multichannel burner pipe. 

Containerized solid hazardous waste-derived fuel (SWDF) and TDF are fed directly into the 

calcining zone within the kilns. This location generally is midway between the feed end and 

burning end of the kiln. 

The primary fossil fuel used to fire the kilns is coal. 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 trucks 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-kiln location. 

Regulations 

The following table contains the regulations applicable 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 Program, 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 Liquid 

Storage Vessels(Including Petroleum Liquid Storage Vessels) for Which Construction, 

Reconstruction, or Modification commenced After July 23, 1984

40 CFR Part 61, Subpart FF, National Emission Standards for Benzene Waste Operations

40 CFR Part 63, Subpart DD, National Emission Standards for Hazardous Air Pollutants 

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 Industry

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 

PM10 135.67 562.45 

SO2 2563.4 5736.1 

VOC 81.4 285.1 

CO 551.0 1214.9 

Total Allowable Emissions 

NOX 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 

0.2 
Ash 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 

0.11 
Ash 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 

PM10

SO2

VOC 

CO 

NOx 

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 

0.05 
Ash 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 

0.04 
Ash 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 

PM10

SO2

VOC 

CO 

NOx 

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 

0.02 
Ash 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 

0.08 
Ash 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 

0.06 
Ash 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 

PM10

SO2

VOC 

CO 

NOx 

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 

0.02 
Ash 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 

0.01 
Ash 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 

PM10

0.1 

0.1 

0.2 

0.1 

P5 Discharge from Kiln 

#1 to #1 Bucket 

Conveyor 

PM 

PM10

0.2 

0.1 

0.8 

0.3 

P6 3 Clinker Cooler 

Baghouse 

PM 

PM10

25.0 

25.0 

110.0 

110.0 

P7 Discharge into Coal 

Mill #2 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

P8 Discharge from Kiln 

#2 to #2 Bucket 

Conveyor 

PM 

PM10

0.2 

0.1 

0.8 

0.3 

P9 Discharge into Coal 

Mill #3 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

P10 Discharge from Kiln 

#3 to #3 Bucket 

Conveyor 

PM 

PM10

0.6 

0.2 

2.3 

0.8 

P11 Discharge from Bin 

#48 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

P12 Discharge from Bin 

#48 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

P13 Discharge from Bin 

#47 

PM 

PM10

0.1 

0.1 

0.1 

0.1 
Ash 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 

PM10

0.4 

0.2 

1.6 

0.6 

P16 Baghouse Discharge 

to #3 Bucket 

Conveyor 

PM 

PM10

0.4 

0.2 

1.6 

0.6 

P17 Bin #49 Sock Filter PM 

PM10

0.5 

0.5 

1.9 

1.9 

P20 Truck Loading of 

CKD 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

P21 Truck Unloading of 

CKD 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

P22 Trailer Unloading of 

CKD 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

P23 CKD Pile PM 

PM10

1.2 

0.6 

5.2 

2.6 

P24 Transfer from 

Main Coal Pile 

PM 

PM10

0.2 

0.1 

0.6 

0.2 

P32 1500 Ton CKD 

Storage Bin 

PM 

PM10

0.4 

0.4 

1.6 

1.6 

P33 CKD Handling Screw 

Conveyor Bin Vent 

PM 

PM10

0.1 

0.1 

0.4 

0.4 

P34 Kiln #3 Dust Scoop 

Bin Vent 

PM 

PM10

0.2 

0.2 

0.5 

0.5 

P35 

P39 

CKD Handling 500 

Ton Silo Baghouse 

PM 

PM10

0.3 

0.3 

1.1 

1.1 

P36 Truck Loading of 

CKD (North of Hwy. 

108) 

PM 

PM10

0.1 

0.1 

0.3 

0.1 

P37 1500 ton CKD 

Storage Bin 

PM 

PM10

0.3 

0.3 

1.2 

1.2 

P38 CKD Truck Loadout PM 

PM10

0.2 

0.2 

0.6 

0.6 

M3 Gypsum Discharge 

into Finish Mill #4 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M4 Gypsum Discharge to 

Gypsum Elevator 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M9 Tripper Discharge 

into Bins 

PM 

PM10

0.1 

0.1 

0.2 

0.1 
Ash 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 

PM10

0.1 

0.1 

0.1 

0.1 

M11 Discharge into Bin 

#43 

PM 

PM10

0.3 

0.1 

1.0 

0.4 

M12 Discharge from Bin 

#44 

PM 

PM10

0.1 

0.1 

0.4 

0.2 

M13 Discharge from Bin 

#43 

PM 

PM10

0.3 

0.1 

1.0 

0.4 

M14 Transfer from Admix 

Weigh Feeder to B 

Belt 

PM 

PM10

0.3 

0.1 

1.0 

0.4 

M15 Transfer from Bin #42 

Feeder to B Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M16 #2 Finish Mill 

Baghouse 

PM 

PM10

0.7 

0.7 

3.0 

3.0 

M17 #2 Finish Mill 

Baghouse-Mill Sweep 

PM 

PM10

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 

PM10

1.1 

1.1 

4.7 

4.7 

M19 #4 Finish Mill 

Discharge BaghouseMill Sweep 

PM 

PM10

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 

PM10

SO2

VOC 

CO 

NOx

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 

PM10

0.1 

0.1 

0.1 

0.1 

M22 Discharge from Bin 

#41 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M23 Transfer from Bin #41 

Conveyor Belt to A1 

PM 

PM10

0.1 

0.1 

0.1 

0.1 
Ash 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 

PM10

0.1 

0.1 

0.1 

0.1 

M25 Discharge from D 

Belt into Chalk Dryer 

PM 

PM10

0.2 

0.1 

0.6 

0.2 

M26 Transfer to D Belt PM 

PM10

0.1 

0.1 

0.1 

0.1 

M27 Discharge from Bin 

#39 

PM 

PM10

0.1 

0.1 

0.4 

0.2 

M28 Transfer to Dry Feed 

Belt 

PM 

PM10

0.1 

0.1 

0.4 

0.2 

M29 Transfer to Dry Feed 

Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M30 Transfer from #1 

Clinker Bin to Dry 

Feed Belt 

PM 

PM10

0.4 

0.2 

1.6 

0.6 

M31 Discharge from Bin 

#38 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M32 Discharge from Bin 

#38 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M33 Discharge from Bin 

#37 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M34 Transfer from Bin #37 

to 

A1 Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M35 Discharge from Bin 

#36 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

M36 Transfer to A1 Belt PM 

PM10

0.1 

0.1 

0.1 

0.1 

M37 Transfer to A1 Belt PM 

PM10

0.1 

0.1 

0.1 

0.1 

M38 Transfer to A1 Belt PM 

PM10

0.1 

0.1 

0.1 

0.1 

M39 Discharge Into Raw 

Mill #3 

PM 

PM10

0.2 

0.1 

0.5 

0.2 

M40 Discharge from 

Gypsum Elevator into 

Feed Mill #4 

PM 

PM10

0.1 

0.1 

0.1 

0.1 
Ash 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 

PM10

0.3 

0.3 

0.9 

0.9 

M43 Bin #37 Dust 

Collector 

PM 

PM10

0.3 

0.3 

0.9 

0.9 

M44 Bin #39 Dust 

Collector 

PM 

PM10

0.3 

0.3 

0.9 

0.9 

M45 Bin #44 Dust 

Collector 

PM 

PM10

0.3 

0.3 

0.9 

0.9 

M46 Transfer from 

Limestone Feeder to 

Belt Conveyor 

PM 

PM10

0.2 

0.1 

0.5 

0.2 

F4 Long Term Coal Pile PM 

PM10

0.2 

0.1 

0.9 

0.5 

F5 Active Coal Pile PM 

PM10

0.2 

0.1 

0.6 

0.3 

F6 Discharge into Feed 

Hopper #5 

PM 

PM10

0.6 

0.3 

1.7 

0.6 

F8 Transfer from #208 

Belt to #210 Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

F9 Discharge into Feed 

Hopper #4 

PM 

PM10

0.6 

0.3 

1.7 

0.6 

F11 Discharge from 

Hopper #4 Vibrating 

Feeder to #206 Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

F12 Discharge from 

Hopper #5 Vibrating 

Feeder to #206 Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

F13 Transfer from #206 

Belt 

to #208 Belt 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

F14 Transfer from Stacker 

Belt to Active Coal 

Pile 

PM 

PM10

0.6 

0.3 

1.7 

0.6 

F15 Unloading into Long 

Term Coal Pile 

PM 

PM10

0.5 

0.2 

1.2 

0.5 

F16 Transfer from Long 

Term Coal Pile to 

Active Pile 

PM 

PM10

0.5 

0.2 

1.2 

0.5 

F17 Transfer from Coal PM 0.2 0.6 
Ash 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 PM10 0.1 0.2 

F18 Railcar Unloading 

into Coal Hoppers 4 

and 5 

PM 

PM10

0.6 

0.3 

2.7 

1.0 

F19, 

F20 

LWDF Tanks 

Thermal Oxidizer and 

Carbon Adsorption 

System 

PM 

PM10

SO2

VOC 

CO 

NOx

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 

PM10

0.2 

0.2 

0.8 

0.8 

S3 Truck Loadout DC 

#49 

PM 

PM10

0.7 

0.7 

3.0 

3.0 

S4 Kaiser Silos DC #21 PM 

PM10

0.5 

0.5 

2.1 

2.1 

S5 Kaiser Silos DC #22 PM 

PM10

0.2 

0.2 

0.7 

0.7 

S6 Delta Silo DC #23 PM 

PM10

0.6 

0.6 

2.5 

2.5 

S7 Rail Silos DC #24 PM 

PM10

0.7 

0.7 

3.0 

3.0 

S8 Kaiser Silos DC #29 PM 

PM10

0.2 

0.2 

0.8 

0.8 

S9 Kaiser Silos DC #30 PM 

PM10

0.2 

0.2 

0.7 

0.7 

S10 Rail Silos DC #25 PM 

PM10

0.4 

0.4 

1.6 

1.6 

S11 Packer DC #26 PM 

PM10

0.7 

0.7 

3.0 

3.0 
Ash 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 

PM10

0.6 

0.6 

2.5 

2.5 

S13 Truck Loadout DC 

#28 

PM 

PM10

0.5 

0.5 

2.0 

2.0 

S14 Bins 26 and 27 Dust 

Collector 

PM 

PM10

1.1 

1.1 

4.5 

4.5 

C1 Clinker Transfer 

Tower Baghouse 

PM 

PM10

1.8 

1.8 

7.6 

7.6 

C2 Outside Clinker Truck 

Unloading 

PM 

PM10

1.3 

0.5 

5.4 

1.9 

C3 Outside Clinker 

Reclaim Hopper 

Loading 

PM 

PM10

0.6 

0.2 

2.3 

0.8 

C4 Outside Clinker 

Storage Pile 

PM 

PM10

0.1 

0.1 

0.3 

0.2 

C5 Discharge from 

Clinker Reclaim 

Hopper 

PM 

PM10

0.6 

0.2 

2.3 

0.8 

C6 Clinker Railcar and 

Truck Hopper 

Loading 

PM 

PM10

0.2 

0.1 

0.8 

0.3 

C7 Clinker Discharge to 

Railcar/Truck 

PM 

PM10

0.2 

0.1 

0.8 

0.3 

C8 Transfer from 

Reclaim Belt to #7 

Belt 

PM 

PM10

0.6 

0.2 

2.3 

0.8 

C9 Transfer to #7 Belt PM 

PM10

0.2 

0.1 

0.6 

0.2 

C10 Transfer from #7 Belt 

to #8 Belt 

PM 

PM10

0.7 

0.3 

2.8 

1.0 

C11 Transfer from #8 Belt 

to #9 Belt 

PM 

PM10

0.9 

0.3 

3.6 

1.3 

C14 B Belt Dust Collector PM 

PM10

0.1 

0.1 

0.4 

0.4 

C15 Discharge from #2 

Clinker Bin to B Belt 

PM 

PM10

0.1 

0.1 

0.4 

0.2 

C16 Discharge into #2 

Clinker Bin 

PM 

PM10

0.9 

0.3 

3.6 

1.3 

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

Permit #: 75-AOP-R6 

AFIN: 41-00001 

25

EMISSION SUMMARY 

Emission Rates Source 

Number Description Pollutant 

lb/hr tpy 

PM10 0.3 1.3 

C18 Clinker Dust Elevator 

Collector 

PM 

PM10

0.1 

0.1 

0.4 

0.4 

C19 Discharge from #1 

Clinker Bin 

PM 

PM10

0.1 

0.1 

0.4 

0.2 

C20 Transfer to Belt 

Conveyor 

PM 

PM10

0.1 

0.1 

0.4 

0.2 

C21 Discharge into #1 

Clinker Bin 

PM 

PM10

0.1 

0.1 

0.4 

0.4 

C26 West Clinker Silo 

Dust Collector 

PM 

PM10

0.8 

0.8 

3.2 

3.2 

C27 4A2 Belt Dust 

Collector 

PM 

PM10

0.6 

0.6 

2.7 

2.7 

C28 Transfer to 4A Belt PM 

PM10

0.2 

0.1 

0.7 

0.3 

C32 East Clinker Silo Dust 

Collector 

PM 

PM10

0.8 

0.8 

3.2 

3.2 

C34 West Clinker Tank 

Dust Collector 

PM 

PM10

0.2 

0.2 

0.8 

0.8 

C36 Discharge into 

Clinker Elevator 

PM 

PM10

1.7 

0.6 

7.4 

2.6 

C37 Discharge into 

Clinker Elevator 

PM 

PM10

0.2 

0.1 

0.5 

0.2 

C41 Off-SPEC Bin and 

Ancillary Equipment 

Dust Collector 

PM 

PM10

0.4 

0.4 

1.4 

1.4 

C42 Clinker Dome Dust 

Collector 

PM 

PM10

0.6 

0.6 

1.9 

1.9 

C43 Reclaim Belt Dust 

Collector 

PM 

PM10

0.2 

0.2 

0.5 

0.5 

C44 Off-Spec Bin Dust 

Collector 

PM 

PM10

0.17 

0.17 

0.75 

0.75 

C45 Clinker Silo Baghouse PM 

PM10

0.3 

0.3 

1.2 

1.2 

C46 Clinker Silo Baghouse PM 

PM10

0.3 

0.3 

1.2 

1.2 

R1 Truck Unloading for 

Sand/Iron Ore 

PM 

PM10

1.9 

0.7 

8.0 

2.8 
Ash 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 

PM10

0.1 

0.1 

0.3 

0.2 

R3 Discharge from Chalk 

Feeder 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

R4 Discharge from 

Gypsum Feeder 

PM 

PM10

0.3 

0.1 

1.0 

0.4 

R5 Gypsum Storage Pile PM 

PM10

0.1 

0.1 

0.1 

0.1 

R6 Discharge from 

Sand/Iron-ore Feeder 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

R8 Sand/Iron Ore Storage 

Transfer 

PM 

PM10

0.4 

0.2 

1.5 

0.5 

R9 Discharge from 

Emergency Feeder 

PM 

PM10

0.3 

0.1 

1.0 

0.4 

R10 Discharge of Gypsum 

Belt 

PM 

PM10

0.8 

0.3 

3.2 

1.2 

R11 Discharge into 

Secondary Crusher 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

R12 Secondary Crusher PM 

PM10

0.2 

0.2 

0.8 

0.8 

R13 Secondary Crusher 

Discharge 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

R14 Transfer to #2 Belt PM 

PM10

0.1 

0.1 

0.2 

0.1 

R15 Discharge from 

Gypsum Hopper 

PM 

PM10

0.1 

0.1 

0.2 

0.1 

R16 Gypsum Truck 

Discharge into 

Hopper 

PM 

PM10

0.8 

0.3 

3.2 

1.2 

R17 Long Term Sand Pile PM 

PM10

0.1 

0.1 

0.4 

0.2 

R18 Iron Ore Storage Pile PM 

PM10

0.2 

0.1 

0.6 

0.3 

R19 Sand Storage Pile PM 

PM10

0.1 

0.1 

0.1 

0.1 

R20 Emissions from Haul 

Roads 

PM 

PM10

13.1 

3.6 

47.2 

13.4 

R22 Portable Crusher PM 

PM10

0.3 

0.3 

1.3 

1.0 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

27

EMISSION SUMMARY 

Emission Rates Source 

Number Description Pollutant 

lb/hr tpy 

SO2

VOC 

CO 

NOx

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 

PM10

0.3 

0.2 

1.3 

0.5 

R25 Emergency Gypsum 

Storage Pile 

PM 

PM10

0.1 

0.1 

0.1 

0.1 

Q1 Quarry Haul Road PM 

PM10

23.5 

5.133 

102.8 

22.5 

Q2 Primary Crusher PM 

PM10

0.5 

0.5 

1.9 

1.9 

Q3 Quarry Belt Turning 

Point 

Transfer from 2N to 

1N 

PM 

PM10

0.1 

0.1 

0.4 

0.4 

Q4 Transfer from Belt 1N 

to Tripper Belt 

PM 

PM10

0.1 

0.1 

0.4 

0.4 

Q5 Discharge of Tripper 

Belt to Chalk Storage 

PM 

PM10

0.1 

0.1 

0.4 

0.4 

Q6 Scraper Dumping to 

Auxiliary System 

PM 

PM10

0.1 

0.1 

0.2 

0.2 

Q7 Hopper 3 Discharge to 

1.12 Belt (Auxiliary 

System) 

PM 

PM10

0.1 

0.1 

0.2 

0.2 

Q8 Auxiliary Crusher PM 

PM10

1.1 

0.5 

4.7 

2.2 

Q9 Discharge of Belt 1 to 

Tripper Belt 

PM 

PM10

0.1 

0.1 

0.2 

0.2 

*HAPs included in the VOC totals. Other HAPs are not included in any other totals unless 

specifically stated. 

**Air Contaminants such as ammonia, acetone, and certain 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 cement, Ash Grove was not able to calculate an 

emission rate. Ash Grove requests the use of the particulate 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 HWC 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

28

NESHAP (September 29, 1999, 64 FR 52879) preamble be 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 Corporation Foreman Production facilities on or 

about September 21, 1971. This permit allowed the installation of three "Precipitair" 

electrostatic precipitators and supporting equipment 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 September 15, 1976. 

Permit #75-A (modification) was issued on March 26, 1982. This modification allowed 

Arkansas Cement to install a gravel bed filter to control particulate discharge from the clinker 

coolers to replace the multiclone that was being used. 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 install a Fuller fabric filter with heat recovery 

instead of the gravel bed filter. This modification also included the replacement of part of the 

clinker handling system and the installation of a baghouse to control emissions generated at this 

crossover point. This modification added 1 lb/hr of particulate emissions. 

Permit #75-AR-4 was issued on January 29, 1988. This modification changed the name of the 

facility to Ash Grove Cement Company and consolidated 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 of SO2, 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 allowed emissions of 92.2 lb/hr TSP, 1574 

lb/hr of SO2, 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 permit 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. This 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 SO2, 721 tpy HCl, 0.964 tpy lead, and 1.39 tpy chromium. 

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 modified so that the Air Permit monitoring 

requirements for SO2, NOx, and CO could be satisfied by the new CEMS. This modification also 

added two product storage silos and related materials handling equipment to improve the loading 

and shipping of finished product, and modified four existing dust control baghouses in a manner 
Ash 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 nitrogen 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. This modification authorized Ash Grove to 

burn waste tires as fuel. Emission rates for SO2 were increased and emission rates for NOx and 

CO were added. Emission totals listed in this permit were 567 tpy PM10, 5,740 tpy SO2, 1,183 

tpy CO, 9,080 tpy NOx, 0.964 tpy lead, and 3.0 tpy VOC. 

Permit 1235-AR-1 was issued on November 7, 1995. This permit is for the limestone quarry 

located at the Ash Grove site. The requirements for this quarry are being incorporated into this 

permit. The quarry is permitted to emit 4.3 lb/hr and 19.0 tpy of PM/PM10. 

Permit 75-AOP-R0 was the initial Title V permit issued 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 installed 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, National Emission Standards for Hazardous 

Air Pollutants From the Portland Cement Manufacturing 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 system (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 modification resulted in net PM/PM10 emissions 

increases of 0.8 lb/hr and 2.6 tpy from the CKD handling equipment and 4 proposed new fabric 

filter dust collectors. Also, Ash Grove constructed a baghouse (SN-C44). This change resulted 

in an increase of PM/PM10 emissions of 0.17 lb/hr and 0.75 tpy. Finally, Ash Grove Cement 

Company added 3 drag conveyors and replaced 2 bucket 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 the 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 modification combined and incorporated 

several requests for minor modifications to the Title 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 conveying air. This modification also allowed 

Ash Grove to install a belt conveyor with integrated 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 increase 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 of 1.5 tpy of PM and 3.1 tpy PM10 emissions 

from this facility. 

Permit 75-AOP-R3 was issued on August 29, 2005. This 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 PM10. This 

modification also corrected typographical errors found in 75-AOP-R2. 

Permit 75-AOP-R4 was issued on January 12, 2006. Hydrogen 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 performance test. The new minimum 3-hour 

rolling average kVa values are 198, 202, and 101 for 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-46) to the clinker silos. These changes 

resulted in a permitted emissions increase of 2.4 tpy PM/PM10. 
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-derived fuel. This kiln can produce up to 50 tons 

per hour of clinker. Particulate emissions are controlled by an electrostatic precipitator with an 

efficiency of 99%. 

Specific Conditions 

1. The permittee shall not exceed the emission rates set forth in the following table. The 

permittee shall demonstrate compliance with this condition 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 

PM10 19.5 85.4 

VOC 9.6 42.1 

2. The permittee shall not exceed the emission rates set forth in the following table. The 

permittee shall demonstrate compliance with this condition 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 

SO2 849.0 1960.0 

CO 172.0 368.0 

NOx 889.0 2405.0 

3. The permittee shall not exceed the emission rates set forth in the following table. The 

permittee shall demonstrate compliance with this condition by Specific Condition 8. 

[Regulation 18, §18.801, effective February 15, 1999, 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 38.5 
Ash 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 0.03 
Ash 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 0.05 
Ash 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 cement, Ash Grove was not able to calculate an 

emission rate. Ash Grove requests the use of the particulate matter emission rate as limits for 

nickel and cobalt. 

4. The permittee shall maintain continuous emission monitors (CEMs) to record SO2, CO, 

and NOx emissions at this source. These CEMs shall be operated in accordance with all 

applicable conditions of the Department's Continuous 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 precipitators used to control particulate 

emissions at this source at a minimum kVA of electrical 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 Department, 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 demonstrated through compliance with Specific 

Condition #10. [Regulation 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] 

6. The permittee shall not produce more than 37,200 tons of clinker per month at this 

source. Compliance shall be demonstrated through compliance with the record keeping 

requirements set forth in Specific Condition 7. [Regulation 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] 

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 submitted 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, Subpart E] 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

37

8. The permittee shall not exceed the feed rates set forth in the following table. Compliance 

shall be demonstrated through compliance with Specific Condition 9. [Regulation 19, 

§19.705, Regulation 18, §18.1004, 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 294.6 MMft3

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 and 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 submitted 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 and §8-4-311] 

10. The permittee shall record the sum of the electrical power input in kilovolt-amperes 

(kVA) to each field of the electrostatic precipitator used to control particulate emissions 

from this source. A reading of the electrical power input to each field of the electrostatic 

precipitator shall be taken a minimum of once per day of operation. These records shall 

be kept on site and made available to Department personnel 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 demonstrated with a continuous opacity 

monitor. Until installation and certification of the continuous opacity monitor occurs, the 

permittee shall continue to demonstrate compliance through compliance with Plantwide 

Condition #10. [§19.703 of Regulation 19, 40 CFR Part 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-derived fuel. This kiln can produce up to 50 tons 

per hour of clinker. Particulate emissions are controlled by an electrostatic precipitator with an 

efficiency of 99%. 

Specific Conditions 

12. The permittee shall not exceed the emission rates set forth in the following table. The 

permittee shall demonstrate compliance with this condition by Specific Conditions 16, 17 

and 18. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E] 

Pollutant lb/hr tpy 

PM10 19.5 85.4 

VOC 9.6 42.1 

13. The permittee shall not exceed the emission rates set forth in the following table. The 

permittee shall demonstrate compliance with this condition by Specific Condition 15. 

[Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E] 

Pollutant lb/hr tpy 

SO2 753.0 1690.0 

CO 152.0 333.0 

NOx 882.0 2450.0 

14. The permittee shall not exceed the emission rates set forth in the following table. The 

permittee shall demonstrate compliance with this condition by Specific Condition 18. 

[Regulation 18, §18.801, 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 19.5 85.4 

1,1,1-trichloroethane 0.01 0.02 

1,1,2,2-tetrachloroethane 0.01 0.03 
Ash 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 0.00123 
Ash 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 0.05 
Ash 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 1.91 
Ash 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 cement, Ash Grove was not able to calculate an 

emission rate. Ash Grove requests the use of the particulate matter emission rate as limits for 

nickel and cobalt. 

15. The permittee shall maintain continuous emission monitors (CEMs) to record SO2, CO, 

and NOx emissions at this source. These CEMs shall be operated in accordance with all 

applicable conditions of the Department's Continuous 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 referenced by A.C.A. §8-4-304 and §8-4-

311] 

16. The permittee shall operate the electrostatic precipitators used to control particulate 

emissions at this source at a minimum kVA of electrical 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 Department, 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 demonstrated 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 tons of clinker per month at this 

source. Compliance shall be demonstrated through compliance 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 forth in the following table. Compliance 

shall be demonstrated through compliance with Specific 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 MMft3

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 submitted 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 and 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 submitted 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 referenced by A.C.A. §8-4-304 and §8-

4-311] 

21. The permittee shall record the sum of the electrical power input in kilovolt-amperes 

(kVA) to each field of the electrostatic precipitator used to control particulate emissions 

from this source. A reading of the electrical power input to each field of the electrostatic 

precipitator shall be taken a minimum of once per day of operation. These records shall 

be kept on site and made available to Department personnel 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 demonstrated with a continuous opacity 

monitor. Until installation and certification of the continuous opacity monitor occurs, the 

permittee shall continue to demonstrate compliance through compliance with Plantwide 

Condition #10. [§19.703 of Regulation 19, 40 CFR Part 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-derived fuel. This kiln can produce up to 70 tons 

per hour of clinker. Particulate emissions are controlled 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

PM10 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 52, Subpart E] 

Pollutant lb/hr Tpy

SO2 961.0 2090.0 

CO 220.0 482.0 

NOx 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 referenced 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 0.01 
Ash 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 27.0 118.3 
Ash 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 cement, Ash Grove was not able to calculate an 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

47

emission rate. Ash Grove requests the use of the particulate 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 HWC NESHAP 

(September 29, 1999, 64 FR 52879) preamble be incorporated as limits for nickel and cobalt. 

26. The permittee shall maintain continuous emission monitors (CEMs) to record SO2, CO, 

and NOx emissions at this source. These CEMs shall be operated in accordance with all 

applicable conditions of the Department's Continuous 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 referenced by A.C.A. §8-4-304 and §8-4-

311] 

27. The permittee shall operate the electrostatic precipitators used to control particulate 

emissions at this source at a minimum kVA of electrical 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 Department, 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 demonstrated 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 tons of clinker per month at this 

source. Compliance shall be demonstrated through compliance 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 and 40 CFR Part 70.6] 

29. The permittee shall not exceed the feed rates set forth in the following table. Compliance 

shall be demonstrated through compliance with Specific 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 MMft3

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 Fuel

 
Ash 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 submitted 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 and 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 submitted 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 referenced by A.C.A. §8-4-304 and §8-

4-311] 

32. The permittee shall record the sum of the electrical power input in kilovolt-amperes 

(kVA) to each field of the electrostatic precipitator used to control particulate emissions 

from this source. A reading of the electrical power input to each field of the electrostatic 

precipitator shall be taken a minimum of once per day of operation. These records shall 

be kept on site and made available to Department personnel 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 demonstrated with a continuous opacity 

monitor. Until installation and certification of the continuous opacity monitor occurs, the 

permittee shall continue to demonstrate compliance through compliance with Plantwide 

Condition #9. [§19.703 of Regulation 19, 40 CFR Part 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 the pyroprocessing unit. Emissions from these 

points are considered uncontrolled and were calculated based on equipment maximum capacity 

using the formula contained in AP-42 §13.2.4-3 as found 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 40 CFR Part 52, Subpart E] 

Source Source Name Pollutant lb/hr tpy

P4 Discharge into Coal Mill #1 PM10 0.1 0.1 

P5* Discharge from Kiln #1 

to #1 Bucket Conveyor 

PM10 0.2 0.3 

P7 Discharge into Coal Mill #2 PM10 0.1 0.1 

P8* Discharge from Kiln #2 

to #2 Bucket Conveyor 

PM10 0.1 0.3 

P9 Discharge into Coal Mill #3 PM10 0.1 0.1 

P10* Discharge from Kiln #3 

to #3 Bucket Conveyor 

PM10 0.2 0.8 

P11* Discharge from Bin #48 PM10 0.1 0.1 

P12* Discharge from Bin #48 PM10 0.1 0.1 

P13* Discharge from Bin #47 PM10 0.1 0.1 

P15* Baghouse Discharge to 

 #2 Bucket Conveyor 

PM10 0.2 0.6 

P16* Baghouse Discharge to 

 #3 Bucket Conveyor 

PM10 0.2 0.6 

P20* Truck Loading of CKD PM10 0.1 0.1 

P21 Truck Unloading of CKD PM10 0.1 0.1 

P22 Trailer Unloading of CKD PM10 0.1 0.1 

P24 Transfer from 

Main Coal Pile 

PM10 0.1 0.2 

P32* 1500 Ton CKD Storage Bin PM10 0.4 1.6 

P33* CKD Handling Screw 

Conveyor Bin Vent 

PM10 0.1 0.4 
Ash 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 PM10 0.2 0.5 

P35* 

P391

CKD Handling 500 Ton Silo 

Baghouse 

PM10 0.3 1.1 

P36* Truck Loading of CKD 

(North of Hwy. 108) 

PM10 0.1 0.3 

P37* 1500 ton CKD Storage Bin PM10 0.3 1.2 

P38* CKD Truck Loadout PM10 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 set 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 0.6 
Ash 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 

Baghouses1

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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 From the Portland Cement 

Manufacturing Industry] 

37. SN-P21 and SN-P22 shall be operated so that unnecessary 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 tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 not exceed 20 percent opacity. The 

permittee shall demonstrate compliance with this specific 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 observations. 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 opacity reading in accordance with the 
Ash 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 the 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 52, Subpart E] 

Pollutant lb/hr Tpy

PM10 25.0 110.0 

41. The permittee shall not exceed the emission rates set 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 referenced 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 associated with this source in a manner 

consistent with good air pollution control practices 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 contain particulate matter in excess of 0.050 

kg per Mg (0.l lb per ton) of feed (dry basis) to the 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 monitor. [40 CFR 63.1345, §19.503 of 

Regulation 19 and 40 CFR 52, Subpart E] 

44. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 resulting 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 52, Subpart E] 

Pollutant lb/hr Tpy

PM10 0.5 1.9 

46. The permittee shall not exceed the emission rates set 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 referenced 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 associated with this source in a manner 

consistent with good air pollution control practices 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% opacity. This source is subject to all 

applicable requirements listed in Plantwide Condition #12. Compliance with the opacity 

standard shall be demonstrated through compliance with Plantwide Condition #15. 

[§19.304 of Regulation 19 and 40 CFR Part 63, Subpart LLL, National Emission 

Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing 

Industry] 

49. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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. Emissions 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 52, Subpart E] 

Pollutant lb/hr Tpy

PM10 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 referenced 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 storage pile at or below 40 acres. 

Compliance shall be demonstrated by surveying the boundary 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 calendar year, the permittee shall 

certify in the facility record that the footprint of 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 Regulation 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 air contaminants do not become 

airborne. Compliance shall be demonstrated through a monthly visual observation of 

operations at this source in accordance with EPA Method 22. The permittee shall 

maintain records of the observations performed. These records shall be maintained on 

site and made available to Department personnel upon request. A copy of these records 

shall be submitted in accordance with General Provision #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 formula 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 40 CFR Part 52, Subpart E] 

SN Source Name Pollutant lb/hr tpy

M3 Gypsum Discharge into 

Finish Mill #4 

PM10 0.1 0.1 

M4 Gypsum Discharge to 

Gypsum Elevator 

PM10 0.1 0.1 

M9 Tripper Discharge into Bins PM10 0.1 0.1 

M10 Discharge from Bin #45 PM10 0.1 0.1 

M11 Discharge into Bin #43 PM10 0.1 0.4 

M12 Discharge from Bin #44 PM10 0.1 0.2 

M13 Discharge from Bin #43 PM10 0.1 0.4 

M14 Transfer to B Belt PM10 0.1 0.4 

M15 Transfer to B Belt PM10 0.1 0.1 

M21 Discharge from Bin #42 PM10 0.1 0.1 

M22 Discharge from Bin #41 PM10 0.1 0.1 

M23 Transfer from Bin #41 PM10 0.1 0.1 

M24 Discharge from Bin #40 PM10 0.1 0.1 

M25 Discharge from D Belt into 

Chalk Dryer 

PM10 0.1 0.2 

M26 Transfer to D Belt PM10 0.1 0.1 

M27 Discharge from Bin #39 PM10 0.1 0.2 

M28 Transfer to Dry Feed Belt PM10 0.1 0.2 

M29 Transfer to Dry Feed Belt PM10 0.1 0.1 
Ash 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 

PM10 0.2 0.6 

M31 Discharge from Bin #38 PM10 0.1 0.1 

M32 Discharge from Bin #38 PM10 0.1 0.1 

M33 Discharge from Bin #37 PM10 0.1 0.1 

M34 Transfer to A1 Belt PM10 0.1 0.1 

M35 Discharge from Bin #36 PM10 0.1 0.1 

M36 Transfer to A1 Belt PM10 0.1 0.1 

M37 Transfer to A1 Belt PM10 0.1 0.1 

M38 Transfer to A1 Belt PM10 0.1 0.1 

M39 Discharge Into Raw Mill #3 PM10 0.1 0.2 

M40 Discharge from Gypsum 

Elevator into Feed Mill #4 

PM10 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 set 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 0.1 
Ash 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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 From the Portland Cement 

Manufacturing Industry] 

57. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. Any of the affected sources 
Ash 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 mill. Emissions are estimated to be 0.01 

grains/ft3. 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.7 3.0 

59. The permittee shall not exceed the emission rates set 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 referenced 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 associated with this source in a manner 

consistent with good air pollution control practices 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% opacity. This source is subject to all 

applicable requirements listed in Plantwide Condition #12. Compliance with the opacity 

standard shall be demonstrated through daily visible emissions observations using 

Method 22, corrective action and subsequent visible emissions observations in 

accordance with 40 CFR 63.1350(e). The visible observation requirement will be 

superseded if the permittee chooses the use of a continuous opacity monitor or bag leak 

detection system in place of the visible observations in accordance with 40 CFR 

63.1350(m). The permittee shall notify the Department, in writing, of the date a COM or 

BLDS is put into service at this facility. [§19.304 of Regulation 19 and 40 CFR Part 63, 

Subpart LLL, National Emission Standards for Hazardous Air Pollutants 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 tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 discharge 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.5 2.0 

VOC 3.8 16.3 

64. The permittee shall not exceed the emission limit set 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 associated with this source in a manner 

consistent with good air pollution control practices 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% opacity. This source is subject to all 

applicable requirements listed in Plantwide Condition #12. Compliance with the opacity 

standard shall be demonstrated through daily visible emissions observations using 

Method 22, corrective action and subsequent visible emissions observations in 

accordance with 40 CFR 63.1350(e). The visible observation requirement will be 

superceded if the permittee chooses the use of a continuous opacity monitor or bag leak 

detection system in place of the visible observations in accordance with 40 CFR 

63.1350(m). The permittee shall notify the Department, in writing, of the date a COM or 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

64

BLDS is put into service at this facility. [§19.304 of Regulation 19 and 40 CFR Part 63, 

Subpart LLL, National Emission Standards for Hazardous Air Pollutants From the 

Portland Cement Manufacturing Industry] 

67. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 1.1 4.7 

69. The permittee shall not exceed the emission rates set 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 referenced 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 associated with this source in a manner 

consistent with good air pollution control practices 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% opacity. This source is subject to all 

applicable requirements listed in Plantwide Condition #12. Compliance with the opacity 

standard shall be demonstrated through daily visible emissions observations using 

Method 22, corrective action and subsequent visible emissions observations in 

accordance with 40 CFR 63.1350(e). The visible observation requirement will be 

superceded if the permittee chooses the use of a continuous opacity monitor or bag leak 

detection system in place of the visible observations in accordance with 40 CFR 

63.1350(m). The permittee shall notify the Department, in writing, of the date a COM or 

BLDS is put into service at this facility. [§19.304 of Regulation 19 and 40 CFR Part 63, 

Subpart LLL, National Emission Standards for Hazardous Air Pollutants 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 tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 discharge 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 40 CFR Part 52, Subpart E] 

Pollutant lb/hr tpy

PM10 1.6 6.7 

VOC 27.8 122.0 

74. The permittee shall not exceed the emission limit set 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 associated with this source in a manner 

consistent with good air pollution control practices 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 or equal to 2 mg/m3

. The permittee 

shall not use more than 196,910 lb of grinding aid per month. Compliance shall be 

demonstrated through compliance with Specific Condition 77. [§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 

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 form 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 records shall be updated on a monthly basis 

and made available to Department personnel upon request. [§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% opacity. This source is subject to all 

applicable requirements listed in Plantwide Condition #12. Compliance with the opacity 

standard shall be demonstrated through daily visible emissions observations using 

Method 22, corrective action and subsequent visible emissions observations in 

accordance with 40 CFR 63.1350(e). The visible observation requirement will be 

superceded if the permittee chooses the use of a continuous opacity monitor or bag leak 

detection system in place of the visible observations in accordance with 40 CFR 

63.1350(m). The permittee shall notify the Department, in writing, of the date a COM or 

BLDS is put into service at this facility. [§19.304 of Regulation 19 and 40 CFR Part 63, 

Subpart LLL, National Emission Standards for Hazardous Air Pollutants From the 

Portland Cement Manufacturing Industry] 

79. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 combustion and additional particulate matter. 

Particulate matter is controlled using a wet scrubber with an efficiency of 95%. This scrubber 

operates at a gas flow of 18,000 ft3/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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.2 0.9 

SO2 0.1 0.2 

VOC 0.5 1.9 

CO 6.3 27.6 

NOx 7.5 32.9 

81. The permittee shall not exceed the emission rates set 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 referenced 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% opacity. This source is subject to all 

applicable requirements listed in Plantwide Condition #12. Compliance with the opacity 

standard shall be demonstrated by observations of opacity from SN-M20 at least once 

each calendar week in which the dryer is in operation. These observations shall be 

performed using EPA Reference Method 22. Records of the operating periods of the 

dryer and the opacity observations shall be maintained 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 MMft3

 of natural gas per month at this source. 

Compliance shall be demonstrated through compliance with the requirements set forth in 
Ash 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 basis and updated by the 15th day of the 

month following the month to which the records pertain. 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 accordance with General Provision #7. 

[§19.705 of Regulation 19 and 40 CFR Part 52, Subpart E] 

85. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 resulting 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 52, Subpart E] 

SN Pollutant lb/hr Tpy

M42 PM10 0.3 0.9 

M43 PM10 0.3 0.9 

M44 PM10 0.3 0.9 

M45 PM10 0.3 0.9 

87. The permittee shall not exceed the emission rates set 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 referenced 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 associated with these sources in a 

manner consistent with good air pollution control practices 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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 
Ash 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 From the Portland Cement 

Manufacturing Industry] 

90. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 the 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.5 

92. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

94. Within thirty days of the effective date of this operating air permit, the permittee shall 

survey a boundary perimeter to the long term coal pile that encompasses an area no 

greater than 3.0 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 footprint of the pile exceeds the 

established perimeter at any location, the permittee shall survey the pile to ascertain the 

true area of the pile and make appropriate notations in the facility 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 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 air contaminants do not become 

airborne. Compliance shall be demonstrated through a monthly visual observation of 

operations at this source in accordance with EPA Method 22. The permittee shall 

maintain records of the observations performed. These records shall be maintained on 

site and made available to Department personnel upon request. A copy of these records 

shall be submitted in accordance with General Provision #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 transferred. 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.3 

97. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

99. Within thirty days of the effective date of this operating 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 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 permittee shall survey the pile to ascertain the true area of 

the pile and make appropriate notations in the facility 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 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 

76

100. This source shall be operated so that unnecessary air contaminants do not become 

airborne. Compliance shall be demonstrated through a monthly visual observation of 

operations at this source in accordance with EPA Method 22. The permittee shall 

maintain records of the observations performed. These records shall be maintained on 

site and made available to Department personnel upon request. A copy of these records 

shall be submitted in accordance with General Provision #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 formula 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 40 CFR Part 52, Subpart E] 

SN Source Description Pollutant lb/hr tpy

F6 Discharge into Feed Hopper 

#5 

PM10 0.3 0.6 

F8 Coal Stacker Belt PM10 0.1 0.1 

F9 Discharge into Feed Hopper 

#4 

PM10 0.3 0.6 

F11 Transfer to #206 Belt PM10 0.1 0.1 

F12 Transfer to #206 Belt PM10 0.1 0.1 

F13 Transfer to #208 Belt PM10 0.1 0.1 

F14 Transfer to Stacker Belt PM10 0.3 0.6 

F15 Unloading into Long Term 

Coal Pile 

PM10 0.2 0.5 

F16 Transfer from Long Term 

Coal Pile to Active Pile 

PM10 0.2 0.5 

F17 Coal Feeders PM10 0.1 0.2 

F18 Railcar Unloading into Coal 

Hoppers 4 and 5 

PM10 0.3 1.0 

 

102. The permittee shall not exceed the emission rates set forth in the following. 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 Description Pollutant lb/hr Tpy

F6 Discharge into Feed Hopper 

#5 

PM 0.6 1.7 

F8 Coal Stacker Belt PM 0.1 0.1 
Ash 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 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 observations. 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 opacity reading in accordance with the 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. [§19.503 of Regulation 19 and 40 CFR Part 52, Subpart E] 

104. SN-F15 and SN-F16 shall be operated so that unnecessary 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 trucks and stored in above ground storage tanks 

before being transferred to the kilns. There are ten above ground storage tanks. To control VOC 

emissions, tanks are vented to a thermal oxidizer with 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.2 

SO2 0.1 0.2 

VOC 16.9 3.0 

CO 0.5 2.0 

NOx 0.6 2.4 

106. The permittee shall not exceed the emission rates set 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 referenced 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 0.1 
Ash 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 

(m3) that is used to store volatile organic liquids (VOLs) for which construction, 

reconstruction, or modification is commenced after July 23, 1984. [§19.304 of 

Regulation 19 and 40 CFR Part 60, Subpart Kb, Standards of Performance for Volatile 

Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which 

Construction, Reconstruction, or Modification Commenced after July 23, 1984, 

§60.110b(a)] 

108. Each storage vessel with a design capacity greater than or equal to 151 m3

 containing a 

VOL that, as stored, has a maximum true vapor pressure equal to or greater than 5.2 kPa, 

but less than 76.6 kPa or with a design capacity greater than or equal to 75 m3, but less 

than 151 m3 containing a VOL that, as stored, has a maximum true 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 CFR 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 operated with no detectable 

emissions as indicated by an instrument reading of less than 500 ppm 

above background and visual inspections as determined in Part 60, 

Subpart VV, §60.485(b). 

ii. The control device shall be designed and operated to reduce inlet VOC 

emissions by 95 percent or greater. 

109. Each source that is equipped with a closed vent system 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 shall meet the following requirements. 

[§19.304 of Regulation 19 and 40 CFR Part 60, §60.113b(c)] 

a. Submit for approval by the Administrator as an attachment to the notification 

required by §60.7(a)(1) or, if the facility is exempt 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 gas stream which enters 

the control device, including flow and VOC content under varying liquid 

level conditions (dynamic and static) and manufacturer's design 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

81

specifications for the control device. If the control device or the closed 

vent capture system receives vapors, gases, or liquids other than fuel types 

from sources that are not designated sources under this subpart, the 

efficiency demonstration is to include consideration of all vapors, gases, 

and liquids received by the closed vent capture system and control device. 

If an enclosed combustion device with a minimum residence time of 0.75 

seconds and a minimum temperature of 816°C is used to meet the 95 

percent requirement, documentation that those conditions will exist is 

sufficient to meet the requirements of this paragraph. 

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 that parameter (or 

parameters). 

b. Operate the closed vent system and control device and monitor the parameters of 

the closed vent system and control device in accordance with paragraph (c)(1) of 

this section, unless the plan was modified by the Administrator during the review 

process. In this case, the modification applies. 

110. The permittee shall maintain records and furnish reports as required by paragraphs (a), 

(b), or (c) of this section depending upon the control equipment installed to meet the 

requirements of §60.112b. The owner or operator shall keep copies of all reports and 

records required by this section, except for the record 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 with §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 monitored in accordance with 

§60.112b(c)(2). 

112. The permittee shall keep copies of all records required by this section, except for records 

required by paragraph (b) of this section, for at least 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 m3

 is subject to no provision of this subpart other than 

those required by this paragraph. [§19.304 of Regulation 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 temperatures, the maximum true vapor 

pressure is calculated based on the highest expected calendar month average of the 

storage temperature. For vessels operated at ambient temperatures, the maximum true 

vapor pressure is calculated based on the maximum local monthly average ambient 

temperature as reported by the National Weather Service. [§19.304 of Regulation 19 and 

40 CFR 60, §60.116b(e)] 

115. The owner or operator of each vessel storing a waste mixture of indeterminate or variable 

composition shall be subject to the following requirements. [§19.304 of Regulation 19 

and 40 CFR 60, §60.116b(f)] 

a. Prior to the initial filling of the vessel, the highest 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 this section. 

b. For vessels in which the vapor pressure of the anticipated liquid composition is 

above the cutoff for controls as defined in §60.112b(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 following 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 the 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 efficiency 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 minimum of once every five years. The 

initial test shall be performed no later than 180 days after the initial startup date. This test 

shall be performed with this unit operating at or above 90% of its design capacity. This 

unit shall achieve a VOC destruction rate of not less than 95%. If engineering 

calculations are used, the permittee shall maintain a complete design analysis of the unit 

which shall contain documentation necessary to demonstrate the performance of the unit. 

[§19.702 of Regulation 19 and 40 CFR Part 52, Subpart E] 

118. The permittee shall maintain the temperature in the combustion chamber of the thermal 

oxidizer at or above 1500°F. To demonstrate compliance, the permittee shall install, 

calibrate, and maintain a continuous temperature recorder on the catalytic oxidizer used 

to control emissions from these sources. These records shall be maintained on site and 

made available to Department personnel upon request. [§19.703 of Regulation 19, 40 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

83

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] 

119. During operation of the dual carbon canister system as a replacement for thermal oxidizer 

at this source, the permittee shall use good engineering judgment and/or vendor 

recommendations to determine the frequency to observe 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 breakthrough indicators and the recharging of 

the carbon canisters. These records shall be maintained on site and made available to 

Department personnel upon request. [§19.703 of Regulation 19, 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 

84

SN-S1, S3, S13, S14 

Truck Loadout Dust Collectors 

Source Description 

Trucks are loaded at these points. Emissions are controlled 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 52, Subpart E] 

SN Pollutant lb/hr tpy

S1, DC #31 PM10 0.2 0.8 

S3, DC#49 PM10 0.7 3.0 

S13, DC #28 PM10 0.5 2.0 

S14 PM10 1.1 4.5 

121. The permittee shall not exceed the emission rates set 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 referenced 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 associated with these sources in a 

manner consistent with good air pollution control practices 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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 
Ash 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 From the Portland Cement 

Manufacturing Industry] 

124. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 resulting 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 52, Subpart E] 

SN Pollutant lb/hr Tpy

S4, DC #21 PM10 0.5 2.1 

S5, DC #22 PM10 0.2 0.7 

S6, DC #23 PM10 0.6 2.5 

S7, DC #24 PM10 0.7 3.0 

S8, DC #29 PM10 0.2 0.8 

S9, DC #30 PM10 0.2 0.7 

S10, DC #25 PM10 0.4 1.6 

S11, DC #26 PM10 0.7 3.0 

S12, DC #27 PM10 0.6 2.5 

126. The permittee shall not exceed the emission rates set 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 referenced 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 0.7 
Ash 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 associated with these sources in a 

manner consistent with good air pollution control practices 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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 From the Portland Cement 

Manufacturing Industry] 

129. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 resulting 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 1.8 7.6 

131. The permittee shall not exceed the emission rates set 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 referenced 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 associated with this source in a manner 

consistent with good air pollution control practices 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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 From the Portland Cement 

Manufacturing Industry] 

134. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 40 CFR Part 52, Subpart E] 

SN Source Name Pollutant lb/hr tpy

C2 Outside Clinker Belt 

Discharge 

PM10 0.5 1.9 

C3 Outside Clinker Reclaim 

Hopper Loading 

PM10 0.2 0.8 

C4 Discharge from Clinker 

Reclaim Hopper 

PM10 0.029 0.13 

C5* Clinker Railcar and Truck 

Hopper Loading 

PM10 0.180 0.79 

C6 Clinker Discharge to 

Railcar/Truck 

PM10 0.1 0.3 

C7* Transfer from Reclaim Belt 

to #7 Belt 

PM10 0.060 0.26 

C8* Transfer to #7 Belt PM10 0.180 2.26 

C9* Transfer from #7 Belt to #8 

Belt 

PM10 0.042 0.18 

C10* Transfer from #8 Belt to #9 

Belt 

PM10 0.222 0.97 

C11* Discharge from #2 Clinker 

Bin 

PM10 0.282 1.24 

C15* Discharge into #2 Clinker 

Bin 

PM10 0.030 0.13 

C16* Transfer from #9 Belt PM10 0.282 1.24 

C17* Discharge from #1 Clinker 

Bin 

PM10 0.282 1.24 

C19* Transfer to Belt Conveyor PM10 0.030 0.13 

C20* Discharge into #1 Clinker 

Bin 

PM10 0.030 0.13 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

91

SN Source Name Pollutant lb/hr tpy

C21* Transfer to 4A Belt PM10 0.086 0.38 

C28* Discharge into Clinker 

Elevator 

PM10 0.055 0.24 

C36* Discharge into Clinker 

Elevator 

PM10 0.589 2.58 

 *Subject to 40 CFR 63, Subpart LLL 

136. The permittee shall not exceed the emission rates set 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 0.4 
Ash 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% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 

opacity standard shall be demonstrated through compliance 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 From 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 shall 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 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] 

139. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 transported 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.029 0.13 

141. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

143. Within thirty days of the effective date of this operating 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 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 footprint of the pile exceeds the 

established perimeter at any location, the permittee shall survey the pile to ascertain the 

true area of the pile and make appropriate notations in the facility 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 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 air contaminants do not become 

airborne. Compliance shall be demonstrated through a monthly visual observation of 

operations at this source in accordance with EPA Method 22. The permittee shall 

maintain records of the observations performed. These records shall be maintained on 

site and made available to Department personnel upon request. A copy of these records 

shall be submitted in accordance with General Provision 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 resulting 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, Subpart E] 

SN Source Name Pollutant Lb/hr tpy

C14* B Belt 

Dust Collector 

PM10 0.1 0.4 

C18* Clinker Elevator 

Dust Collector 

PM10 0.1 0.4 

C26* West Clinker Silo 

Dust Collector 

PM10 0.8 3.2 

C27* 4A2 Belt Dust Collector PM10 0.6 2.7 

C32* East Clinker Silo 

Dust Collector 

PM10 0.8 3.2 

C34* West Clinker Tank 

Dust Collector 

PM10 0.2 0.8 

C41* Off-spec Bin and 

Ancillary Equipment 

Dust Collector 

PM10 0.4 1.4 

C42* Clinker Dome 

 Dust Collector 

PM10 0.6 1.9 

C43* Reclaim Belt 

Dust Collector 

PM10 0.2 0.5 

C44* Off-Spec Bin Dust 

Collector 

PM10 0.17 0.75 

C45* Clinker Silo Baghouse PM10 0.3 1.2 

C46* Clinker Silo Baghouse PM10 0.3 1.2 

 *Subject to 40 CFR 63, Subpart LLL 

146. The permittee shall not exceed the emission rates set 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 referenced 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 

PM10 0.4 1.4 

C42* Clinker Dome 

 Dust Collector 

PM10 0.6 1.9 

C43* Reclaim Belt 

Dust Collector 

PM10 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 associated with these sources in a 

manner consistent with good air pollution control practices 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-42, and SN-43 more than 7,250 hours 

per year based on a rolling twelve month total. Compliance shall be demonstrated by 

maintaining records of the hours of operation of these sources. These records shall be 

maintained on a weekly basis and updated weekly. These records shall be maintained on 

site and made available to Department 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] 

149. Emissions from these sources shall not exceed 10% opacity. These sources are subject to 

all applicable requirements listed in Plantwide Condition #12. Compliance with the 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

97

opacity standard shall be demonstrated through compliance 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 From the Portland Cement 

Manufacturing Industry] 

150. The permittee shall conduct initial compliance tests for all affected sources for which an 

initial compliance test has not been previously performed. 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 Storage Area 

Source Description 

The Raw Material Storage 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 

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 40 CFR Part 52, Subpart E] 

SN Source Name Pollutant lb/hr tpy

R1 Truck Unloading for 

Sand/Iron Ore 

PM10 0.7 2.8 

R3 Discharge from Chalk 

Feeder 

PM10 0.1 0.1 

R4 Discharge from Gypsum 

Feeder 

PM10 0.1 0.4 

R6 Discharge from Sand/Ironore Feeder PM10 0.1 0.1 

R8 Sand/Iron Ore Storage 

Transfer 

PM10 0.2 0.5 

R9 Discharge from Emergency 

Feeder 

PM10 0.1 0.4 

R10 Discharge of Gypsum Belt PM10 0.3 1.2 

R11 Discharge into Secondary 

Crusher 

PM10 0.1 0.1 

R13 Secondary Crusher 

Discharge 

PM10 0.1 0.1 

R14 Transfer to #2 Belt PM10 0.1 0.1 

R24 Transfer from Portable 

Crusher to Main Conveyor 

PM10 0.2 0.5 

 

152. The permittee shall not exceed the emission rates set 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 through compliance with Plantwide 

Condition #10. [§19.503 of Regulation 19 and 40 CFR 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 unnecessary 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 is 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.2 

157. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

159. Within thirty days of the effective date of this operating air permit, the permittee shall 

survey a boundary perimeter to the sand storage pile 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 footprint of the pile exceeds the established 

perimeter at any location, the permittee shall survey the pile to ascertain the true area of 

the pile and make appropriate notations in the facility 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 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 

101

160. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be 

demonstrated through compliance with Plantwide Condition #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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.1 

162. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

164. Within thirty days of the effective date of this operating air permit, the permittee shall 

survey a boundary perimeter to the gypsum storage pile that encompasses an area no 

greater than 0.22 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 footprint of the pile exceeds the 

established perimeter at any location, the permittee shall survey the pile to ascertain the 

true area of the pile and make appropriate notations in the facility 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 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 Condition #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 used at this facility. Chalk, sand, and iron ore are 

crushed and then transported to the mill building by 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.2 0.8 

167. The permittee shall not exceed the emission rates set 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 referenced 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 Condition #10. [§19.503 of Regulation 

19, §18.901 of Regulation 18 and, A.C.A § 8-4-230 as referenced by A.C.A. §8-4-304 

and §8-4-311] 

169. The permittee shall not crush more than 744,000 tons of material per month at this 

source. Compliance shall be demonstrated through compliance with Specific Condition 

#170. [§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] 

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 request. 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 tests for this source provided an initial 

compliance test has not been previously performed. Any sources for which the facility 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

105

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. [§19.503 of Regulation 19, 

§18.901 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 

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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.2 

173. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

175. Within thirty days of the effective date of this operating air permit, the permittee shall 

survey a boundary perimeter to the long term sand storage pile that encompasses an area 

no greater than 1.0 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 footprint of the pile exceeds the 

established perimeter at any location, the permittee shall survey the pile to ascertain the 

true area of the pile and make appropriate notations in the facility 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 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 Condition #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 facility 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.3 

178. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

180. Within thirty days of the effective date of this operating 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 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 footprint of the pile exceeds the 

established perimeter at any location, the permittee shall survey the pile to ascertain the 

true area of the pile and make appropriate notations in the facility 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 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 Condition #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 clinker. 

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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.1 

183. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

185. Within thirty days of the effective date of this operating air permit, the permittee shall 

survey a boundary perimeter to the sand storage pile 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 footprint of the pile exceeds the established 

perimeter at any location, the permittee shall survey the pile to ascertain the true area of 

the pile and make appropriate notations in the facility 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 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 

111

186. Visible emissions from this source shall not exceed 20% opacity. Compliance shall be 

demonstrated through compliance with Plantwide Condition #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 via 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 3.6 13.4 

188. The permittee shall not exceed the emission rates set 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 referenced 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 fugitive dust control plan contained in 

Appendix H of the permit. [§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 

113

SN-R22 & R23 

Portable Crusher Diesel Engine and Portable Crusher

Source Description 

This crusher is powered by a diesel engine and is used to crush spent kiln brick so that it may be 

added to the raw materials stored in the mill building, 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 52, Subpart E] 

SN Pollutant lb/hr Tpy

PM10 0.2 0.8 

SO2 0.2 0.8 

VOC 0.2 0.9 

CO 0.6 2.3 

R-22 

NOx 2.5 10.6 

R-23 PM10 0.5 0.5 

191. The permittee shall not exceed the emission rates set 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 referenced 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 exceed 20% opacity. The permittee shall 

demonstrate compliance with this Specific Condition by conducting a visible opacity 

observation of these sources at least once each calendar week in which these sources 

operate and keep a record of these observations. If visible 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 conduct a 6-minute opacity reading in accordance with EPA Reference Method #9. 

The records of visible emission observations and results of any Method #9 readings shall 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

114

be kept on site for five years and made available to Department personnel upon request. 

[§19.503 of Regulation 19, and 40 CFR Part 52, Subpart 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 referenced 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 request. 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. §8-4-304 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 gypsum 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.1 0.1 

197. The permittee shall not exceed the emission rates set 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 referenced 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 storage 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 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] 

199. Within thirty days of the construction of this source, 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 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 footprint of the pile exceeds the 

established perimeter at any location, the permittee shall survey the pile to ascertain the 

true area of the pile and make appropriate notations in the facility record. These records 

shall be kept on site and made available to Department 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 §8-4-311 
Ash 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 via 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 5.2 22.5 

201. The permittee shall not exceed the emission rates set 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 referenced 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 accordance with a haul road watering plan. 

This plan shall be designed to minimize emissions from this source. A copy of this plan 

shall be kept on site and made available to Department 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 being hauled to the raw materials storage area. 

This source was installed prior to the applicability 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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.5 1.9 

204. The permittee shall not exceed the emission rates set 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 referenced 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 tons per month at this source. 

Compliance shall be demonstrated through compliance with Specific Condition 206. 

[§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] 

206. The permittee shall maintain records of the amount of material crushed at this source. 

These records shall be maintained on a monthly basis and updated by the 15th day of the 

month following the month to which the records pertain. These records shall be kept on 

site and made available to Department personnel upon 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 Condition #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 equipment. Emissions sources primarily consist of 

transfer points. The uncontrolled emission rates were 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 40 CFR Part 52, Subpart E] 

SN Source Name Pollutant lb/hr tpy

Q3 Transfer from Belt 2N to 

Belt 1N 

PM10 0.1 0.4 

Q4 Transfer from Belt 1N to 

Tripper Belt 

PM10 0.1 0.4 

Q5 Discharge from Tripper Belt 

to Chalk Storage 

PM10 0.1 0.4 

Q6 Scraper Dumping to 

Auxiliary Crusher 

PM10 0.1 0.2 

Q7 Hopper 3 Discharge to 1.12 

Belt (Auxiliary System) 

PM10 0.1 0.2 

Q9 Discharge from Belt 1 to 

Tripper Belt (Auxiliary 

System) 

PM10 0.1 0.2 

209. The permittee shall not exceed the emission rates set 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 0.2 
Ash 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 Condition #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 52, Subpart E] 

Pollutant lb/hr tpy

PM10 0.5 2.2 

212. The permittee shall not exceed the emission rates set 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 referenced 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 tons per month at this source. 

Compliance shall be demonstrated through compliance with Specific Condition 214. 

[§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] 

214. The permittee shall maintain records of the amount of material crushed at this source. 

These records shall be maintained on a monthly basis and updated by the 15th day of the 

month following the month to which the records pertain. These records shall be kept on 

site and made available to Department personnel upon 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 referenced 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 calendar week in which the source operates 

and keep a record of these observations. If visible 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 conduct 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

121

a 6-minute opacity reading in accordance with EPA Reference 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 Department 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 in compliance with those identified 

regulatory provisions. The facility will examine and analyze future regulations that may apply 

and determine their applicability with any necessary 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, first placing the equipment and/or 

facility in operation, and reaching the equipment and/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 Director 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 regulated requirements, within the following 

time frames: (1) new equipment or newly modified equipment 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 according to the time frames set forth by 

the Department or within 180 days of permit issuance if no date is specified. The 

permittee must notify the Department of the scheduled date of compliance testing at least 

fifteen (15) days in advance of such test. The permittee shall submit the compliance test 

results to the Department within thirty (30) days after 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, §19.702 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] 

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 apparatus and emission monitoring 

equipment within the design limitations. The permittee shall maintain the equipment in 

good condition at all times. [Regulation 19, §19.303 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 previously 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 compliance with the requirements of this 

subpart and exempt from the requirements of paragraph (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 follows: 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

124

i. The treatment process is a hazardous waste incinerator for which the 

owner or operator has been issued a final permit under 40 CFR Part 270 

and complies with the requirements of 40 CFR Part 264, Subpart O; 

ii. The treatment process is an industrial furnace or boiler burning hazardous 

waste for energy recovery for which the owner or operator has been issued 

a final permit under 40 CFR Part 270 and complies with the requirements 

of 40 CFR Part 266, Subpart D. 

[A.C.A. §8-4-203 as referenced by A.C.A. §8-4-203 and §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 to 40 CFR Part 63, Subpart FF, National 

Emission Standards for Hazardous Air Pollutants from 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 personnel 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 (closed vent/containment devices) 

because the unit is subject to equivalent requirements imposed pursuant to 40 CFR 61, 

Subpart FF, Benzene Waste Operations. [40 CFR Part 63, Subpart DD, National 

Emission Standards for Hazardous Air Pollutants from Off-Site Waste and Recovery 

Operations] 

10. Visible emission observations shall be used as a method of compliance verification for 

the opacity limits assigned for the sources whose Specific 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 detected which appear to be in 

excess of the permitted opacity limit, the permittee 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 the 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 site and made available to 

Department personnel upon request. These records shall contain: 

i. The time and date of each observation/reading any observance 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 limits, corrective actions 

taken, and results of the reassessment, and 

iii. The name of the person conducting the observation/reading. 

[§18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced 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 requirements will also include the applicable 

Subpart EEE NESHAP amendments promulgated by the EPA and as incorporated in the 

Code of Federal Regulations. Alternatives to the requirements contained in this permit 

must be approved by the Administrator. Once the Department has received written 

notification of approval of alternative requirements, the alternate requirements may be 

implemented. These requirements shall not be in effect for existing affected sources until 

September 30, 2003, unless an extension of this deadline is granted by the Administrator. 

[§19.304 of Regulation 19 and 40 CFR 63, Subpart EEE, National Emission Standards 

for Hazardous Air Pollutants From Hazardous Waste Combustors] 

Emission Limits 

a. The permittee shall not discharge or cause combustion 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 to 7 percent 

oxygen; or 

2. Emissions in excess of 0.40 ng TEQ/dscm corrected to 7 percent 

oxygen provided that the combustion gas temperature at the inlet to 

the initial dry particulate matter control device is 400 °F or lower 

based on the average of the test run average temperatures; 

ii. Mercury in excess of 120 μg/dscm corrected to 7 percent 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 gas 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 oxygen, and 

hydrocarbons in the by-pass duct 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 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 sampling 

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 propane; 

2. For kilns not equipped with a by-pass duct or midkiln 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 (monitored 

continuously with a continuous emissions monitoring

system), dry basis and corrected to 7 percent oxygen, 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 and 

reported as propane, at any time during the DRE test 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 determine the kiln raw 

material feedrate. 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

127

2. Except as provided in paragraph (a)(7)(iii) of this section, the 

permittee must compute the particulate matter emission rate, E, 

from the following equation: 

E = (Cs × Qsd)/P 

Where: 

E = emission rate of particulate matter, kg/Mg of raw material 

feed; 

Cs= concentration of particulate matter, kg/dscm 

Qsd= 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, Ec, from the following 

equation: 

Ec = (Csk × Qsdk + Csb × Qsdb)/P 

Where: 

Ec = the combined emission rate of particulate matter from the kiln 

and bypass stack, kg/Mg of raw material feed; 

Csk = concentration of particulate matter in the kiln effluent, 

kg/dscm; 

Qsdk = volumetric flowrate of kiln effluent gas, dscm/hr; 

Csb = concentration of particulate matter in the bypass stack 

effluent, kg/dscm; 

Qsdb = 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 section, the permittee must 

achieve a destruction and removal efficiency of 99.99% for each principle 

organic hazardous constituent (POHC) designated under paragraph (c)(3) of 

this section. The permittee must calculate DRE for each POHC from the 

following equation: 

DRE = [1-(Wout/Win)]×100% 

Where: 

Win=mass feedrate of one POHC in a waste feedstream; and 

Wout= mass emission rate of the same POHC present in exhaust emissions prior to 

release to the atmosphere. 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

128

[§63.1204(c)(1)] 

c. If the permittee burns dioxin-listed hazardous wastes 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 designated under paragraph 

(c)(3) of this section. The permittee must demonstrate 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 DRE for each POHC. In 

addition, the permittee must notify the Administrator of the intent to burn 

hazardous wastes FO20, FO21, FO22, FO23, FO26, or FO27. 

[§63.1204(c)(2)] 

d. The permittee must treat the POHCs in the waste feed 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 the list of hazardous air 

pollutants established by 42 U.S.C. 7412(b)(1), excluding caprolactam (CAS 

number 105602) as provided by §63.60, for each waste to be burned. The 

permittee must base this specification on the degree of difficulty of 

incineration of the organic constituents in the waste 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 forth in this subpart no later 

than September 30, 2003 unless the Administrator grants an extension of time 

under §63.6(i) or §63.1213. [§63.1206(a)(1)] 

g. The emission standards and operating requirements set 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 hazardous waste feed to the 

combustor has been cutoff for a period time not less than the hazardous 

waste residence time) during those periods of operation, as provided by 

paragraph (c)(2)(ii) of this section; and 

ii. When hazardous waste is not in the combustion chamber (i.e., the 

hazardous waste feed to the combustor has been cutoff 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 Administrator 

documenting compliance with all applicable requirements and 

standards promulgated under authority of the Clean Air Act, 

including sections 112 and 129; and 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

129

2. Documented in the operating record that you are complying with 

such applicable requirements in lieu of the emission standards and 

operating requirements of this subpart. 

[§63.1206(b)(1)] 

Applicability of particulate matter and opacity standards 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 hazardous waste combustors to 

insure compliance with any particulate matter or opacity standard of parts 60, 

61, 63, 264, 265, and 266 of this chapter (i.e., any title 40 particulate or opacity 

standards) applicable to hazardous waste combustor do not apply while the 

permittee conducts particulate matter continuous emissions monitoring system 

(CEMS) correlation tests. [§63.1206(b)(8)(i) and (ii)] 

i. For provisions of this section to apply, the permittee must develop a particulate 

matter CEMS correlation test plan that includes the following information. 

This test plan may be included as part of the comprehensive performance test 

plan required under §§63.1207(e) and (f): 

i. Number of test conditions and number of runs for each test condition; 

ii. Target particulate matter emission level for each test condition; 

iii. How you plan to modify operations to attain the desired particulate matter 

emission levels; and 

iv. Anticipated normal emission levels; and 

v. Submit the test plan to the Administrator for approval 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), the plan is considered 

approved, unless the Administrator has requested additional information. 

[§63.1206(b)(8)(iv)] 

k. The particulate matter and associated operating limits 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 more time is approved by the 

Administrator. [§63.1206(b)(8)(v)] 

l. The permittee must return to operating conditions indicative 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 recommend alternative 

semivolatile, low volatile metal, mercury, and/or hydrochloric acid/chlorine 

gas emission standards if: 

i. The permittee cannot achieve one or more of the standards while using 

MACT because of raw material contributions to emissions of the regulated 

metals or hydrochloric acid/chlorine gas; or 

ii. The permittee determines that mercury is not present at detectable levels 

in the raw material. 

[§63.1206(b)(10)(i)] 

n. The alternative standard recommended under paragraph (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 emission 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 residence 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 under §63,1211(d) and the 

Notification of Compliance under §§63.1207(j) and 63.1210(d). 

[§63.1206(b)(11)] 

Documenting compliance with the standard based on performance 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)] 
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s. The permittee must document compliance with the emission standards based 

on the arithmetic average of the emission results of each run, except that the 

permittee must document compliance with the destruction and removal 

efficiency standard for each run of the comprehensive performance test 

individually. [§63.1206(b)(12)(ii)] 

Cement kilns which feed hazardous waste at a location other than the end where products are 

normally discharged and where fuels are normally fired. 

t. Cement kilns that feed hazardous waste at a location other than the end where 

products are normally discharged and where fuels are normally fired must 

comply with the carbon monoxide and hydrocarbon standards 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) or the Notification of 

Compliance under §§63.1207(j) and 63.1210(d), except: 

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 Notification of 

Compliance must contain operating requirements including, 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 is failure to 

ensure compliance with the emissions standards of this subpart. 

[§63.1206(c)(1)(i)(B)(iii)] 

3. Operating requirements in the Notification of Compliance are 

applicable requirements for purposes of parts 70 and 71 of this 

chapter. [§63.1206(c)(1)(i)(B)(iv)] 

4. The operating requirements specified in the Notification of 

Compliance will be incorporated in the Title V permit. 

[§63.1206(c)(1)(i)(B)(v)] 
Ash Grove Cement Company 

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AFIN: 41-00001 

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[§63.1206(c)(1)(i)] 

v. Except as provided in by paragraph (c)(2)(ii) of this section, the permittee is 

subject to the startup, shutdown, and malfunction plan 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 follows the startup and 

shutdown procedures and the corrective measures upon malfunction that 

are prescribed in the startup, shutdown, and malfunction plan, the 

emission combustion chamber. [§63.1206(c)(2)(ii)] 

ii. The permittee must identify in the plan the projected oxygen correction 

factor based on normal operations to use during periods 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 operate the combustor with a 

functioning system that immediately and automatically 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 combustion chamber 

pressure; [§63.1206(c)(3)(i)(A)] 

ii. When the span value of any CMS detector, except a CEMS, is met or 

exceeded; [§63.1206(c)(3)(i)(B)] 

iii. Upon malfunction of a CMS monitoring an operating parameter 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 cutoff system fails. 

[§63.1206(c)(3)(i)(D)] 

[§63.1206(c)(3)(i)] 

x. During an automatic waste feed cutoff (AWFCO) the permittee must continue 

to duct combustion gases to the air pollution control system while hazardous 

waste remains in the combustion chamber. [§63.1206(c)(3)(ii)] 

y. The permittee must continue to monitor during the cutoff the operating 

parameters for which limits are established under §63.1209 and the emissions 

required under that section to be monitored by a CEMS, and the permittee shall 

not restart the hazardous waste feed until the operating parameters and 

emission levels are within specified limits. [§63.1206(c)(3)(iii)] 
Ash Grove Cement Company 

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AFIN: 41-00001 

133

z. If the AWFCO system fails to automatically and immediately cutoff the flow 

of hazardous waste upon exceedance of a parameter required to be interlocked 

with the AWFCO system under paragraph (c)(3)(i) of this section, the 

permittee has failed to comply with the AWFCO requirements 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 appropriate 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 standard or operating 

requirement while hazardous waste remains in the combustion chamber during 

a 60-day block period, the permittee must submit to the Administrator a written 

report within 5 calendar days of the 10th exceedance documenting the 

exceedances and the results of the investigation and corrective measures taken. 

[§63.1206(c)(3)(vi)(A)] 

cc. On a case-by-case basis, the Administrator may require excessive exceedance 

reporting when fewer than 10 exceedances occur during a 60-day block period. 

[§63.1206(c)(3)(vi)(B)] 

dd. The AWFCO system and associated alarms must be tested at least weekly to 

verify operability, unless the permittee documents in the operating record that 

weekly inspections will unduly restrict or upset operations 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 test procedures and results. 

[§63.1206(c)(3)(vii)] 

ee. The permittee shall use a COMS to demonstrate and monitor compliance with 

the opacity standard under §§63.1204(a)(7) and (b)(7) at each point where 

emissions are vented from these affected sources including the bypass stack of 

a preheater/precalciner kiln with dual stacks. [§63.1209(a)(1)(ii)] 

ff. The permittee is subject to the combustion system leak control system 

operating and reporting requirements set forth in this section. 

[§63.1206(c)(5)(i through ii)] 

gg. The permittee is subject to the operator training and certification standards set 

forth in this section. [§63.1206(c)(6)(i through v)] 
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AFIN: 41-00001 

134

hh. The permittee must prepare and at all times operate according to an operation 

and maintenance plan which complies with the requirements set forth in these 

sections. [§63.1206(c)(7)(i)(A-D)] 

Performance Testing Requirements 

ii. The permittee must conduct performance testing in accordance with the 

applicable requirements contained in this section. [§63.1207(a-n)] 

jj. The permittee must commence the initial comprehensive performance test not 

later than six months after the compliance date. [§63.1207(c)(1)] 

kk. The permittee may request that previous emissions test data serve as 

documentation of conformance with the emission standards of this subpart 

provided that the previous testing: 

i. Results in data that meet quality assurance objectives (determined on a 

site-specific basis) such that the results adequately demonstrate 

compliance with the applicable standard; 

ii. Was in conformance with the requirements of paragraph (g)(1) of this 

section; and, 

iii. Was sufficient to establish the applicable operating 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 commencement of the initial 

comprehensive performance test is the basis for establishing 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. The deadline for commencing 

subsequent confirmatory and comprehensive performance testing is based on 

the date of commencement of the previous comprehensive performance test. 

i. The permittee must commence testing no later than 61 months after the 

date of commencing the previous comprehensive performance test. 

ii. The permittee must commence confirmatory performance testing no later 

than 31 months after the date of commencing the previous comprehensive 

performance test. To insure that the confirmatory test is conducted 

approximately midway between comprehensive performance tests, the 

Administrator will not approve a test plan that schedules testing within 18 

months of commencing the previous comprehensive performance test. 

iii. The permittee must complete performance testing within 60 days after the 

date of commencement, unless the Administrator determines that a time 

extension is warranted based on documentation in writing of factors 
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135

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 notification of intent to 

conduct a comprehensive performance test and CMS performance evaluation 

and a site specific test plan and CMS performance evaluation plan at least one 

year before the performance test and performance evaluation are scheduled to 

begin. [§63.1207(e)(i)] 

nn. The permittee must submit to the Administrator a notification 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 notification of intent to 

conduct a confirmatory performance test and CMS performance 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 monitoring requirements contained in 

these sections. [§63.1209 (a-q)] 

rr. The permittee must use a CEMS to demonstrate and monitor compliance with 

the carbon monoxide and hydrocarbon standards under this subpart. The 

permittee must also use an oxygen CEMS to continuously correct the carbon 

monoxide and hydrocarbon levels to 7 percent oxygen. [§63.1209(a)(1)(i)] 

ss. The permittee must install, calibrate, maintain, and 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 promulgates all performance 

specifications and operational requirements applicable to PM CEMS. 

[§63.1209(a)(1)(iii)] 
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AFIN: 41-00001 

136

tt. The permittee must install, calibrate, maintain, and continuously operate the 

COMS and CEMS in compliance with the quality assurance procedures 

provided in the appendix to this subpart and Performance 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 obtain an analysis of each 

feedstream that is sufficient to document compliance with the applicable 

feedrate limits provided in this section. [§63.1209(c)(1)] 

vv. The permittee must develop and implement a feedstream analysis plan and 

record it in the operating record. [§63.1209(c)(2)] 

ww. The permittee must submit the feedstream analysis plan to the Administrator 

for review and approval, if requested. [§63.1209(c)(3)] 

xx. To comply with the applicable feedrate limits of this 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 feedstream 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 parameter per unit time. 

[§63.1209(c)(4)] 

yy. The requirements of §§63.8(d) (Quality control program) 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 performance tests as provided 

by §63.1207. [§63.1209(d)(1)] 

zz. To remain in compliance with the destruction and removal efficiency (DRE) 

standards, the permittee must establish operating limits during the 

comprehensive performance test (or during a previous DRE test under 

provisions of §63.1206(b)(7)) for the following parameters, unless the limits 

are based on manufacturer specifications and comply with those limits at all 

times that hazardous waste remains in the combustion 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 the 
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137

combustion zone. The permittee must document the temperature 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 control device, the permittee must 

establish and comply with a limit on the maximum flue 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 furans emission standard by 

establishing and complying with the following operating parameter limits. 

You must base the limits on operations during the comprehensive performance 

test, unless the limits are based on manufacturer specifications. [§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 average. The permittee must 

establish the hourly rolling average limit as the average 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 temperature measurement 

location in the test plan. [§63.1209(k)(2)(i)] 

hhh. As an indicator of gas residence time in the control device, the permittee must 

establish and comply with a limit on the maximum flue gas flowrate, the 

maximum production rate , or another parameter which 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 matter emission standard by 

establishing and complying with the operating parameter limits found in 

§63.1209(m) of this subpart. [§63.1209(m)] 
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AFIN: 41-00001 

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kkk. If the combustor is equipped with a baghouse, the permittee must establish a 

limit on the minimum pressure drop and the maximum pressure drop across 

each baghouse cell based on manufacturer’s specifications. The permittee 

must comply with the limit on an hourly rolling average. [§63.1209(m)(1)(ii)] 

lll. The permittee must comply with the semivolatile metal (cadmium and lead) 

and low volatile metal (arsenic, beryllium, and chromium) emission standards 

by establishing and complying with the following operating 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 semivolatile metals and 

low volatile metals. [§63.1209(n)(2)(i)] 

iii. The permittee must establish operating parameter limits 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 average limit for the 

feedrate of total chlorine and chloride in all feedstreams 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 chamber zone pressure lower 

than ambient pressure, the permittee must monitor the 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 notifications prior to the 

deadlines established in this subpart. [§63.1210(a)(1)] 

ooo. The permittee must submit the required notifications outlined in this section to 

the Administrator in order to request or elect to comply with the alternative 

requirements contained in this subpart. [§63.1210(a)(2)] 

ppp. Upon postmark of the Notification of Compliance, the operating parameter 

limits identified in the Notification of Compliance, as applicable, shall be 

complied with, the limits identified in the Document of Compliance or a 

previous Notification of Compliance are no longer applicable. 

[§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 this subpart. [§63.1211] 

Procedure for Extending the Compliance Date 

rrr. The permittee may request an extension of the compliance 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 and is subject, but not limited to, the 

following requirements. The referenced requirements will also include the applicable 

Subpart LLL NESHAP amendments promulgated by the EPA and as incorporated in the 

Code of Federal Regulations. [§19.304 of Regulation 19 and 40 CFR Part 63, Subpart 

LLL, National Emission Standards for Hazardous Air Pollutants 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 kg per Mg (0.30 lb per 

ton) of feed (dry basis) to the kiln. When there is an alkali bypass 

associated with a kiln or in-line kiln/raw mill, the 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 particulate 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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AFIN: 41-00001 

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 per 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 finish mill any gases which 

exhibit opacity in excess of ten percent. [§63.1347] 

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 material, clinker or finished 

product storage bin; conveying system transfer point; 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 provision of this subpart shall 

not cause to be discharged any gases from these affected sources which exhibit 

opacity in excess of ten percent. [§63.1348] 

Performance testing requirements 

g. The permittee shall use the test methods and procedures contained in this 

section to demonstrate compliance with the emissions 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 subpart, a written operations 

and maintenance plan. The permittee shall also comply 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 reconstruction after March 24, 

1998 is immediately upon start of operations. [§63.1351(b)] 

Notification requirements 

k. The permittee shall comply with all applicable notification requirements set 

forth in this section. [§63.1353(a)] 

Reporting Requirements 

l. The permittee shall comply with all applicable reporting requirements set forth 

in this section. [§63.1354(a)] 

Recordkeeping Requirements

m. The permittee shall comply with all applicable recordkeeping 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 Combustors. 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 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 Manufacturing 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 upon 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 whose Specific Conditions reference this 

Plantwide Condition. The monthly observations shall be conducted by someone familiar 

with the facility’s visible emissions. 

a. If during the observations, visible emissions are detected which appear to be in 

excess of the permitted opacity limit, the permittee shall: 

i. Take immediate action to identify the cause of the visible emissions, 
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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 certified in the reference 

method. If the opacity reading exceeds the 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. 

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 site and made available to 

Department personnel upon request. These records shall contain: 

i. The time and date of each observation/reading any observance 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 limits, corrective actions 

taken, and results of the reassessment, and 

iii. The name of the person conducting the observation/reading. 

[§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 emission 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 cutoff for a period time not less than the 

hazardous waste residence time). The permittee must document in the facility record 

when they are operating under 40 CFR 63, Subpart LLL. 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 labeling of products using ozonedepleting substances. [40 CFR Part 82, Subpart E] 

a. All containers containing a class I or class II substance stored or transported, 

all products containing a class I substance, and all products directly 

manufactured with a class I substance must bear the required warning 

statement if it is being introduced to interstate commerce pursuant to §82.106. 

b. The placement of the required warning statement must 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 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

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 recycling 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, repair, or disposal of 

appliances must comply with the standards for recycling and recovery 

equipment pursuant to §82.158. 

c. Persons performing maintenance, service repair, or disposal of appliances must 

be certified by an approved technician certification program pursuant to 

§82.161. 

d. Persons disposing of small appliances, MVACs, and MVAC like appliances 

must comply with record keeping requirements pursuant to §82.166. (“MVAC 

like appliance” as defined at §82.152) 

e. Persons owning commercial or industrial process refrigeration equipment must 

comply with leak repair requirements pursuant to §82.156. 

f. Owners/operators of appliances normally containing 50 or more pounds of 

refrigerant must keep records of refrigerant purchased and added to such 

appliances pursuant to §82.166. 

19. If the permittee manufactures, transforms, destroys, imports, or exports a class I or class 

II substance, the permittee is subject to all requirements 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 subject to all the applicable 

requirements as specified in 40 CFR part 82, Subpart 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. The term “MVAC” as used in Subpart 

B does not include the air tight sealed refrigeration system used as refrigerated cargo, or 

the system used on passenger buses using HCFC 22 refrigerant. 

21. The permittee can switch from any ozone depleting substance to any alternative listed in 

the Significant New Alternatives Program (SNAP) promulgated 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 issuance, 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 1996, 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 Performance 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 Regulations of the 

Arkansas State Implementation Plan for 

Air Pollution Control 
Ash 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 significant activity even if this activity meets the 

criteria of §26.304 of Regulation 26 or listed in the 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, #3 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

147

SECTION VIII: GENERAL PROVISIONS 

1. Any terms or conditions included in this permit which specify and reference Arkansas 

Pollution Control & Ecology Commission Regulation 18 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 Clean Air Act or any of its applicable 

requirements, and are not federally enforceable under the Clean Air Act. Arkansas 

Pollution Control & Ecology Commission Regulation 18 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 and reference Arkansas Pollution 

Control & Ecology Commission Regulation 18 or the Arkansas 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 statute. [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 Permit Program (Regulation 26), effective 

August 10, 2000] 

3. The permittee must submit a complete application for 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 renewal 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 Department takes final action on the 

renewal application. The Department will not necessarily notify the permittee when the 

permit renewal application is due. [Regulation 26, §26.406] 

4. Where an applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et 

seq. (Act) is more stringent than an applicable requirement 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 provisions. [40 CFR 70.6(a)(1)(ii) and 

Regulation 26, §26.701(A)(2)] 

5. The permittee must maintain the following records of monitoring information as required 

by this permit. [40 CFR 70.6(a)(3)(ii)(A) and Regulation 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 sampling or measurement. 

6. The permittee must retain the records of all required monitoring data and support 

information for at least five (5) years from the date of the monitoring sample, 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

148

measurement, report, or application. Support information includes all calibration and 

maintenance records and all original strip chart recordings for continuous monitoring 

instrumentation, and copies of all reports required by 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 monitoring every six (6) months. If 

permit establishes no other reporting period, the reporting period shall end on the last day 

of the anniversary month of the initial Title V permit. 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 responsible official as defined in Regulation 

No. 26, §26.2 must certify all required reports. The permittee will send the reports to the 

address below: [40 C.F.R. 70.6(a)(3)(iii)(A) and Regulation 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 deviations from permit requirements, 

including those attributable to upset conditions as defined in the permit. 

a. For all upset conditions (as defined in Regulation19, § 19.601), the permittee will 

make an initial report to the Department by the next 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 pollutants, 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 to 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 schedule 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. The 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

149

permittee may submit a full report in writing (by facsimile, 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 report must include all the 

information as required by the initial and full reports 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 thereof 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 or application, and to this end, 

provisions of this Regulation are declared to be separable 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 this Part 70 permit. Any permit 

noncompliance with applicable requirements as defined 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, revocation and reissuance, for permit 

modification; or for denial of a permit renewal application. [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 enforcement 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 reissue the permit or terminate the 

permit for cause. The filing of a request by the permittee for a permit modification, 

revocation and reissuance, termination, or of a notification 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 writing to determine whether cause exists for 

modifying, revoking and reissuing, or terminating the permit or to determine compliance 

with the permit. Upon request, the permittee must also furnish to the Director copies of 

records required by the permit. For information the permittee claims confidentiality, the 

Department may require the permittee to furnish such records directly to the Director 
Ash 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 accordance 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 approved economic incentives, 

marketable permits, emissions trading and other similar 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 scenario. [40 CFR 70.6(a)(9)(i) and 

Regulation 26, §26.701(I)(1)] 

18. The Administrator and citizens may enforce under the 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 conditions of the permit as being federally 

unenforceable under the Act or under any of its applicable requirements. [40 CFR 

70.6(b) and Regulation 26, §26.702(A) and (B)] 

19. Any document (including reports) required by this permit 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 representative of the Department, upon 

presentation of credentials, to perform the following: [40 CFR 70.6(c)(2) and Regulation 

26, §26.703(B)] 

a. Enter upon the permittee’s premises where the permitted source is located or 

emissions related activity is conducted, or where records must be kept under the 

conditions of this permit; 

b. Have access to and copy, at reasonable times, any records required under the 

conditions of this permit; 

c. Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under 

this permit; and 

d. As authorized by the Act, sample or monitor at reasonable times substances or 

parameters for assuring compliance with this permit or applicable requirements. 

21. The permittee shall submit a compliance certification with the terms and conditions 

contained in the permit, including emission limitations, 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 Title V permit. The permittee must also 
Ash Grove Cement Company 

Permit #: 75-AOP-R6 

AFIN: 41-00001 

151

submit the compliance certification to the Administrator as well as to the Department. 

All compliance certifications required by this permit 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 intermittent; 

d. The method(s) used for determining the compliance status of the source, currently 

and over the reporting period established by the monitoring requirements of this 

permit; 

e. and Such other facts as the Department may require 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 following: [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 program, consistent with §408(a) of 

the Act or, 

d. The ability of EPA to obtain information from a source pursuant to §114 of the 

Act. 

23. This permit authorizes only those pollutant emitting activities addressed in this permit. 

[A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]