United States Environmental Protection Agency

General Permit for New or Modified Minor Sources of Air 

Pollution in Indian Country

http://www.epa.gov/air/tribal/tribalnsr.html

Background Document: General Air Quality Permit for New or Modified True 

Minor Source Concrete Batch Plants

Version 1.0

Last Modified: July 2, 2014

1. Concrete Batch Plant Source Category Definition

A concrete batch plant is an operation that combines various ingredients to form concrete. Some of these inputs 

include sand, water, aggregate (rocks, gravel, etc.), fly ash, potash, and cement. There are two types of concrete 

batch plants: ready mix plants and central mix plants. A concrete batch plant can have a variety of parts and 

equipment, including, but not limited to: mixers (either tilt-up or horizontal or in some cases both), cement 

batchers, aggregate batchers, conveyors, radial stackers, aggregate bins, cement bins, heaters, chillers, cement 

silos, batch plant controls, and dust collectors. The proposed General Air Quality Permit for New or Modified 

True Minor Source Concrete Batch Plants only covers concrete batch operations that are located at true minor 

New Source Review (NSR) sources.

2. Source Category Characterization

The operations and equipment at a typical concrete batch plant facility are described in AP 42, Chapter 11.12, 

Concrete Batching.1 Concrete is composed essentially of water, cement, sand (fine aggregate) and coarse 

aggregate. Coarse aggregate may consist of gravel, crushed stone or iron blast furnace slag. Some specialty 

aggregate products could be either heavyweight aggregate (of barite, magnetite, limonite, ilmenite, iron or 

steel) or lightweight aggregate (with sintered clay, shale, slate, diatomaceous shale, perlite, vermiculite, slag 

pumice, cinders, or sintered fly ash). Supplementary cementitious materials, also called mineral admixtures or

pozzolan minerals, may be added to make the concrete mixtures more economical, reduce permeability, 

increase strength, or influence other concrete properties. Typical examples are natural pozzolans, fly ash, 

ground granulated blast-furnace slag, and silica fume, which can be used individually with portland or blended 

cement or in different combinations. Chemical admixtures are usually liquid ingredients that are added to 

concrete to entrain air, reduce the water required to reach a required slump, retard or accelerate the setting 

rate, to make the concrete more flowable, or other more specialized functions. 

Approximately 75 percent of the U.S. concrete manufactured is produced at plants that store, convey, measure 

and discharge these constituents into trucks for transport to a job site. At most of these plants, sand, aggregate, 

cement and water are all gravity fed from the weigh hopper into the mixer trucks. The concrete is mixed on the 

way to the site where the concrete is to be poured. At some of these plants, the concrete may also be 

manufactured in a central mix drum and transferred to a transport truck. Most of the remaining concrete 

manufactured is cast as products in a factory setting. Precast products range from concrete bricks and paving 

stones to bridge girders, structural components, and panels for cladding. Concrete masonry, another type of 

manufactured concrete, may be best known for its conventional 8 x 8 x 16-inch block. In a few cases concrete is 

dry batched or prepared at a building construction site. 

 

1 AP-42, Chapter 11.12, Concrete Batching, http://www.epa.gov/ttn/chief/ap42/ch11/index.html.
Page 2 of 25

Raw materials for concrete batch operations can be delivered to a plant by rail, truck or barge. The cement is 

transferred to elevated storage silos pneumatically or by bucket elevator. The sand and coarse aggregate are 

transferred to elevated bins by front end loader, clamshell crane, belt conveyor, or bucket elevator. From these 

elevated bins, the constituents are fed by gravity or screw conveyor to weigh hoppers, which combine the 

proper amounts of each material.

Particulate matter (PM), consisting primarily of cement and pozzolan dust, but including some aggregate and 

sand dust emissions, is the primary pollutant of concern. In addition, there are emissions of metals that are 

associated with this PM. Point source emissions include the transfer of cement and pozzolan material to silos

that are usually vented to a fabric filter. Fugitive sources include the transfer of sand and aggregate, truck 

loading, mixer loading, vehicle traffic, and wind erosion from sand and aggregate storage piles. The amount of 

fugitive emissions generated during the transfer of sand and aggregate depends primarily on the surface 

moisture content of these materials. 

The extent of fugitive emission control varies widely from plant to plant. Types of controls used may include 

water sprays, enclosures, hoods, curtains, shrouds, movable and telescoping chutes, central duct collection 

systems, and the like. A major source of potential emissions, the movement of heavy trucks over unpaved or 

dusty surfaces in and around the plant, can be controlled by good maintenance and wetting of road surfaces. 

3. State Minor Source Permit Programs

The U.S. Environmental Protection Agency (EPA) researched state air quality permitting websites for examples of 

permits by rule and general permits for concrete batch plants. The EPA examined these documents for their 

applicability in developing a general permit for Indian country. The EPA incorporated elements from these 

permits in developing the documents and regulations in the general permit for concrete batch facilities. The EPA 

examined permits by rule and general permit documents for concrete batch operations in Arizona, Florida, 

Idaho, Illinois, Indiana, Iowa, Maine, Maryland, Mississippi, New Mexico, Ohio, Oregon, South Carolina, and 

Texas in developing this general permit. The EPA chose general permits from these states because of 

characteristics they possess:

 Readily available; 

 Clear throughput limits; and 

 Organization of the regulations followed the typical form for federal NSR permits:

o Limitations and standards, and 

o Monitoring, testing, recordkeeping, and reporting requirements.

The state general permits and permits by rule for concrete batch plants vary from the streamlined (Indiana at 

two pages) to the extremely detailed and complex (Arizona at 108 pages). 

The state concrete batch plant permits limit emissions with either concrete production limits or pollutant 

emission limits. Only a few of the state concrete batch plant permits (Florida, Maryland, Maine) restrict issuance 

to true minor sources whose potential to emit (PTE) of criteria pollutants is less than 100 tons per year (tpy). The 

other states issue their concrete batch plant permits to sources to control emissions to minor source levels. 

These production limits, and boiler/heater size, and engine displacement limits, are intended to keep emissions 

below the major source thresholds, making the source a synthetic minor. The state permits that limit production 

and engine displacement (Idaho, Illinois, Indiana, Iowa, Ohio, and Texas) use these limits as a surrogate for 

limiting emissions through individual numerical limits on individual pollutants.
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Only the Arizona, Idaho, Iowa, Maine, New Mexico, South Carolina, and Texas state permits regulate emissions 

from engines. The regulations limit combustion emissions by limiting either fuel sulfur content, engine 

displacement, or both. 

All of the state concrete batch plant permits require control of particulate emissions, and the requirements are 

fairly standardized. Emissions from silos, weigh hoppers and mixers are required to be controlled with fabric 

filters or baghouses, fugitive emissions from materials handling and loading are required to be controlled with 

shrouds, suction, wetting, or best management practices (BMPs), and fugitives from storage piles and roadways 

are required to be controlled with wetting, dust suppressants, or sweeping. In general, all of the state concrete 

batch plant permits require BMPs for control of fugitives, and have monitoring and recordkeeping requirements 

adequate to enforce these measures. Visible emissions and opacity requirements are present in all of the state 

permits, but vary from state to state. Setbacks are present in most of the state permits, but they also vary state 

by state. 

Only the Arizona2state permit incorporates the requirements of New Source Performance Standards (NSPS) 

Subpart IIII and Subpart JJJJ, and National Emissions Standards for Hazardous Air Pollutants (NESHAP) Subpart 

ZZZZ for engines into the text of the permit. Several other states (Florida, Idaho, Iowa, Maine, South Carolina, 

and Texas) mention that sources must comply with these requirements, or incorporate the NSPS and NESHAP 

requirements by reference. The other state permits do not mention the federal requirements.

Table 7 in Section 5.2.3 contains a summary of the concrete batch plant permit requirements by state.

4. Requirements for General Permit

4.1 Documents for General Permit

The EPA developed a standardized set of permit documents in support of a general permit for concrete batch 

plants located in Indian country. These consist of the following documents: 

 Questionnaire: Assists the facility owner or operator in determining whether they are eligible for a 

General Air Quality Permit;

 Request for Coverage under the General Air Quality Permit: States the criteria for qualification, gathers 

information on the source, facility location, and source contact, and requests technical information on 

facility equipment, concrete production, and attainment status;

 Instructions: Guides the applicant in filling out the Request for Coverage under the General Air Quality 

Permit;

 General Air Quality Permit, Terms and Conditions: Contains the requirements and regulations with 

which the source must comply. The emission limitations, monitoring, recordkeeping and reporting 

requirements are in the permit; and

 PTE Calculator Spreadsheet: Allows applicants to calculate their PTE, based on owner inputs of either 

the specific equipment and throughput capacity or the plant’s maximum production capacity, assuming 

 

2 Arizona Department of Environmental Quality, General Permits, General Concrete Batch Plant Permit, 

http://www.azdeq.gov/environ/air/permits/download/gncbppermit.pdf.
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continuous operation throughout the year. The PTE Calculator spreadsheet generates potential 

emissions, based on these inputs. The spreadsheet illustrates the correlation between equipment, raw 

material throughput, concrete production and emissions.

4.2 Exemption and Qualification for General Permits

Facilities applying for the proposed general permit must meet the following criteria:

 Must be a true minor NSR source;

 Must be minor source for hazardous air pollutants (HAPs); and

 Be below the emission limitations established for the general permit.

New facilities with a PTE or modifications to existing facilities with an emissions increase lower than the minor 

NSR thresholds specified in Table 1 of Indian Country Minor NSR rule (40 CFR 49.153) are exempt from the 

minor NSR program. The exemption thresholds for PM and criteria pollutants are listed in Table 1 below. 

Facilities applying for the proposed general permit may calculate their PTE using the PTE calculator to determine 

if they are exempt from the minor NSR program. 

 Table 1: Minor NSR Thresholds in 40 CFR 49.153

Pollutant Attainment Area Nonattainment Area

Carbon Monoxide (CO) 10 tpy 5 tpy

PM 10 tpy 5 tpy

PM10 5 tpy 1 tpy

PM2.5 3 tpy 0.6 tpy

Sulfur Dioxide (SO2) 10 tpy 5 tpy

Nitrogen Oxides (NOX) 10 tpy 5 tpy

Volatile Organic 

Compounds (VOC) 5 tpy 2 tpy

Under current EPA policy, only true NSR minor sources qualify for the proposed general permit. Therefore, 

facilities will be required to compare their PTE to the NSR major source thresholds to determine if they qualify 

for the proposed general permit. For this source category – concrete batch plants – the NSR major source 

threshold for attainment areas is 250 tpy of any criteria pollutant. The NSR major source thresholds for 

nonattainment areas are summarized in Table 2 below:

Table 2: NSR Major Source Thresholds for Nonattainment Areas

Pollutant Nonattainment Classification NSR Major Source Threshold

Ozone

Marginal 100 tpy of VOC or NOX

Moderate 100 tpy of VOC or NOX

Serious 50 tpy of VOC or NOX

Severe 25 tpy of VOC or NOX

Extreme 10 tpy of VOC or NOX

PM10 Moderate 100 tpy

Serious 70 tpy
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Pollutant Nonattainment Classification NSR Major Source Threshold

CO Moderate 100 tpy

Serious 50 tpy

SO2, NOX, PM2.5 No nonattainment classification 100 tpy

If the facility’s PTE is above the NSR major source threshold of 250 tpy, or above the applicable nonattainment 

area thresholds listed in Table 2 (for any pollutant that is designated nonattainment in the area the source will 

locate), then the facility does not qualify for the proposed general permit. The following documents are 

available to assist sources in the screening and application process: 

 Questionnaire; and

 Request for Coverage under the General Air Quality Permit.

The questionnaire and the application for the concrete batch plants permit contain questions designed to limit 

the availability of this general permit to true minor source concrete batch plants. For facilities not exempt from 

the minor NSR program and having a PTE below the NSR major source thresholds, the facilities will further 

evaluate if they can meet the emission limitations established in this general permit. The specific requirements 

for the proposed general permit are discussed in Sections 4.3, 4.4, 4.5, and 4.6. Section 5 provides background 

on the surrogate emissions limitations provided in the proposed concrete batch plants general permit.

4.3 Specific Permit Requirements for General Permits and Permits by Rule

The terms and conditions of the general permit were established according to the required permit content and 

analyses in the Indian Country Minor NSR rule. The required permit content is listed in 40 CFR 49.155(a) – What 

information must my permit include? Below we describe the basis for the permit conditions.

40 CFR 49.155(a)(1) – General Requirements

The rule establishes general requirements that each permit must identify: the effective date of the permit; the 

date by which the owner/operator must commence construction in order for the permit to remain valid; the 

emission units subject to the permit and their associated emission limitations; and monitoring, recordkeeping, 

and reporting requirements to assure compliance with the emission limitations. 

The proposed general permit contains all of this required information, except for the emission units subject to 

the permit. Because of the nature of general permits we believe it is more appropriate to identify the emission 

units covered by the general permit in the Approval of the Request for Coverage. The general permit 

incorporates the Approval of the Request for Coverage into the general permit. Each permit contains a separate 

section that specifically identifies the emission limitations and standards, monitoring and testing, recordkeeping, 

and reporting and notification requirements.

CFR 49.155(a)(2) – Emission Limitations

The permit must contain the emission limitations determined by the reviewing authority under 40 CFR 49.154(c) 

for each affected emissions unit. In this General Permit for concrete batch plants, limits on the annual concrete 

production of the concrete batch plant is used to limit emissions of all criteria pollutants to below the NSR major 

source thresholds. 40 CFR 49.154(c) – How will the reviewing authority determine the emission limitations that 

will be required in my permit? – identifies the case-by-case control technology review that must be used by the 

reviewing authority to determine the appropriate level of control. In carrying out the case-by-case control 

technology review, the reviewing authority must consider the following factors:
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1. Local air quality conditions;

2. Typical control technology or other emission reduction measures used by similar sources in surrounding 

areas;

3. Anticipated economic growth in the area; and

4. Cost-effective emission reduction alternatives.

In addition, the reviewing authority must require a numerical limit on the quantity, rate or concentration of 

emissions for each regulated NSR pollutant emitted by each affected emissions unit, for which such a limit is 

technically feasible. The emission limitation required may also be included as pollution prevention techniques, 

design standards, equipment standards, work practices, operational standards or any combination thereof. 

However, the emission limitations must assure that each affected emission unit will comply with all 

requirements of 40 CFR parts 60, 61, and 63, as well as any federal or tribal implementation plans that apply to 

the unit. Finally, the emission limitations required may not rely on a stack height that exceeds good engineering 

practice or any other dispersion technique, except as allowed by 40 CFR 51.118(b). 

To address the requirements for establishing emission limitations the following considerations were used for 

setting the limits in the general permit for concrete batch plants:

1. Local air quality conditions – To address this requirement, the general permit requires all sources to 

utilize fabric or cartridge filters to control PM emissions from point sources such as silos, weigh hoppers, 

and storage bins. The general permit also requires that all sources utilize work practice standards 

(sometimes referred to as BMPs) to minimize fugitive emissions from materials handling, loading, 

storage piles, and roadways. The permit contains a requirement to take corrective action if fugitive dust 

is visible beyond the property line. This will aid in reducing local PM air quality impacts.

2. Typical control technology or other emission reduction measures used by similar sources in surrounding 

areas – For sources locating in attainment areas the EPA looked at the control requirements required by 

40 CFR parts 60, 61 and 63. These regulations establish minimum technology and emission limitations 

that must be met nationally and also meet the requirements of 40 CFR 49.154(c)(4) to ensure 

compliance with parts 60, 61, and 63. For this general permit the EPA considered regulations that apply 

to the equipment at concrete batch plants:

a. 40 CFR 60 Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing 

Facilities;

b. 40 CFR 60 Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal 

Combustion Engines; 

c. 40 CFR 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal 

Combustion Engines; and

d. 40 CFR 63 Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutions for 

Stationary Reciprocating Internal Combustion Engines.

These regulations cover emissions from the following equipment at concrete batch plants:

 Mixers;

 Silos, weigh hoppers, and storage bins;

 Material handling equipment; and

 Emergency engines.
Page 7 of 25

The derivation of the surrogate emissions limitations in the general permit are discussed fully in Section 

5. The minor NSR thresholds are based on provisions of the Review of New Sources and Modifications in 

Indian Country rule at 40 CFR 49.153 and are provided in Table 1. 

Review of the regulations and other existing general permits resulted in permit conditions requiring 

emissions from all mixers, silos, weigh hoppers, and storage bins be controlled by fabric or cartridge

filters, while fugitive emissions from materials handling, drop points, loading, storage piles, roadways, 

and other possible release points to be controlled by shrouds, wet suppression, and work practices 

standards. The permit also requires fugitive emissions to be controlled by a fugitive dust control plan. 

Non-emergency and emergency engines are required to meet the applicable NSPS or NESHAP emission 

requirements. In addition, liquid fuels in the engines are limited to using ultra low sulfur fuels with no 

more than 0.0015 percent sulfur by weight. These conditions represent the standard fuels used for this 

equipment and the standard sulfur content these fuels must attain. Although we reviewed the NSPS 

requirements for tanks, we did not include any limits in the permit as the fuel storage tanks used by 

concrete batch plants are not expected to need to meet the control requirements of the NSPS. 

3. Anticipated economic growth in the area – The Reviewing Authority may consider anticipated economic 

growth when determining whether coverage under the proposed general permit is justifiable. 

Considering, however, that the proposed general permit sets emission standards that are consistent 

with what is required by concrete batch plants across the country in both attainment and 

nonattainment areas, we expect that this will rarely be a factor. 

4. Cost-effective emission reduction alternatives – The proposed general permit sets emission standards 

that are consistent with what is required by concrete batch plants across the country, based on the 

particular attainment status where the source is locating. As such, the chosen technologies are 

considered widely available and consideration of more cost-effective alternatives is not necessary at this 

time. We intend to periodically review technology costs in the future to determine when more stringent, 

cost-effective technologies become widely available.

40 CFR 49.155(a)(3) – Monitoring Requirements

The proposed general permit must include monitoring that is sufficient to assure compliance with the emission 

limitations that apply to the source. The proposed general permit requires monitoring that assures that the 

particulate control systems are operating properly, that a visible emissions survey is conducted on a weekly 

basis, and that fugitive emissions surveys are conducted weekly. Also, certain emergency engines are required 

to conduct performance testing to demonstrate compliance with the applicable emission limitations.

40 CFR 49.155(a)(4) – Recordkeeping Requirements

The proposed general permit must include recordkeeping that is sufficient to assure compliance with the 

emission limitations and monitoring requirements, including certain statements listed in 40 CFR 49.155(a)(4)(i) 

and (ii). In addition to the recordkeeping requirements in 40 CFR 49.155(a)(4)(i), the proposed general permit 

also requires records of the amount of concrete produced each day, control equipment inspections, visible 

emission surveys, fugitive emission surveys, corrective actions taken, results of corrective actions taken, 

maintenance activities of stationary engines, and fuel supplier certifications. For emergency engines, the 

permittee must maintain a log of the hours of operation, including the date, time, duration, and reason(s) for 

use.
Page 8 of 25

40 CFR 49.155(a)(5) – Reporting Requirements

The proposed general permit includes the reporting requirements listed in 40 CFR 49.1559(a)(5)(i) and (ii) 

related to annual reports and reporting of deviations.

40 CFR 49.155(a)(6) – Severability Clause

The proposed general permit includes a severability clause to ensure the continued validity of the other portions 

of the permit in the event of a challenge to a portion of the permit. This condition is found in the General 

Provisions of the proposed general permit.

40 CFR 49.155(a)(7) – Additional Provisions

The proposed general permit contains the additional provision required for each permit. These conditions are 

found in the General Provisions, Changes to this General Permit, and Obtaining Coverage under this General 

Permit sections of the proposed general permit.

4.4 Requirements for Sources Located in Nonattainment Areas

We did not include any additional requirements for sources locating in air quality nonattainment areas. We are 

not aware of any more stringent state/local control requirements for concrete batch plants in nonattainment 

areas. The limits on concrete production and the equipment control requirements will ensure that the general 

permit only applies to true minor sources locating or expanding in these nonattainment areas.

4.5 Additional Permit Requirements

The EPA added a 150 foot setback requirement from the nearest property boundary and a 1,000 foot setback 

requirement between the concrete batch plant and the nearest residence. Permits from Arizona, Idaho, Iowa, 

Mississippi, New Mexico, and Texas include setback requirements, and, along with Maryland, also require that 

no visible emissions cross the property boundary.

4.6 Requirements of the Endangered Species Act and National Historic Preservation Act

Prior to seeking coverage under this general permit, sources must satisfactorily address the permitting 

requirements related to the Endangered Species Act and National Historic Preservation Act. Attached to the 

request for coverage document for the concrete batch plant general permit, the EPA provides guidance to assist

sources in complying with these two statutes.

5. Emission Limitations3 and Surrogate Throughput Limits 

5.1 Developing the Surrogate Limits and Limitations

In order to limit emissions to below the NSR major source thresholds, the EPA has chosen to limit the yearly 

concrete production of the concrete batch plant. The draft general permit includes the annual concrete 

production limit that applies to all sources in both attainment and nonattainment areas (see Table 4). The 

concrete production limit for attainment and nonattainment areas is set at the same level because the EPA has 

selected the same emissions limitations for attainment and nonattainment areas. The production limit serves as 

 

3 The definition of emission limitation used in this background document is the one provided in the Indian Country Minor 

NSR rule (described in Section 4.3) and includes requirements established by the reviewing authority that relate to the 

operation of a source, which allows for the use of production throughput limits.
Page 9 of 25

a surrogate emissions limitation. (The general permit also includes requirements to control emissions from 

storage silos, mixers, and weigh hoppers.) The production limit and control requirements were established as 

surrogate emissions limitations in order to limit emissions below the thresholds for the Title V and major NSR 

permitting programs. In addition, PM/PM10/PM2.5 are the pollutants of concern emitted by concrete batch 

plants. However, the general permit also includes a limit on the quantity of total annual cold cleaning solvent 

makeup not to exceed 500 gallons per year based on a 12-month rolling total. Degreasing operations can be 

found at concrete batch plants that clean engine parts in trucks used to transport concrete to job sites.

The tpy emission rates provided in Table 3 used to determine eligibility for the general permit for sources 

located in attainment and nonattainment areas correspond to the source-wide annual concrete production limit 

intended to prevent a plant from becoming a major source and subject to Title V permitting (referred to 

hereafter as “the Title V major source threshold”). In attainment areas, the Title V major source threshold is 100 

tpy for any criteria pollutant. The emissions thresholds for facilities located in nonattainment areas are set at the 

thresholds in Table 2 for each pollutant and nonattainment status, which serve as the thresholds for both the 

major NSR and Title V permitting programs. The threshold is 50 tpy for PM10 in moderate PM10 nonattainment 

areas.

The EPA evaluated the emission rates at which a new or modified source would become a major source under 

Title V. The EPA developed a PTE Calculator spreadsheet that allows applicants to calculate pollutant emissions 

for the emission units at a concrete batching plant using AP 42 emission factors. Using the PTE calculator, the 

EPA back-calculated the throughput of materials (production of concrete) that yielded the emissions rate in 

Table 3 by using an equipment configuration based on the description of a typical concrete batch plant, 8,760 

hours of production, and emission factors from AP 42, Chapter 11.12.

4 Equipment configurations and any 

controls present have a significant impact on the level of pollutants emitted. 

As an example, an owner wanting to construct a new concrete batch plant utilizing controls on point source and 

fugitive PM emissions would be limited to producing 2,000,000 cubic yards of concrete per year. By using the 

PTE calculator provided by the EPA at http://www.epa.gov/air/tribal/tribalnsr.html, an applicant can determine 

whether emissions from their concrete batch plant would exceed the major source thresholds.

Table 3: Emission Rates Used to Determine Emission Limitations 

for Concrete Batch Plants 

Pollutant of Concern Attainment, Unclassifiable or

Attainment/Unclassifiable Areas Nonattainment Areas

PM10 20 tpy 20 tpy

(moderate and serious areas)

PM2.5 5 tpy 5 tpy

 

4 AP-42, Chapter 11.12, Concrete Batching, http://www.epa.gov/ttn/chief/ap42/ch11/index.html.
Page 10 of 25

Table 4: Surrogate Concrete Production Limits

Attainment Status Upper Concrete Production Limit 

(cubic yards/year)

PM10 Attainment, Unclassifiable 

or Attainment/Unclassifiable

Areas and Nonattainment Areas

2,000,000

PM10 Attainment, Unclassifiable 

or Attainment/Unclassifiable

Areas and Moderate and Serious 

Nonattainment Areas

2,000,000

5.2 Emission Limitations

Three considerations form the basis for the upper eligibility emission limitations for general permits and permits 

by rule:

1. Are there any EPA regulation-based emission limitations?

2. What do actual emissions data from the 2011 National Emissions Inventory (NEI)5indicate about the size 

profile of the source category? 

3. Where do state programs establish eligibility limits? 

5.2.1 EPA Regulation-Based Emissions Limitations 

The surrogate emissions limitation on concrete production was established to keep permitted sources emissions 

below the thresholds for the major NSR and Title V permitting programs. For PM10, the production limit was set 

to correspond to emission rates at below 20 tpy for PM2.5 and below 5 tpy (see Table 3). 

5.2.2 Analysis of NEI Data

The EPA analyzed 2011 NEI data for existing concrete batch plants across the U.S. to evaluate the emission 

limitations established in the general permit. Although the NEI does not include potential emissions information 

for sources in Indian country, it reflects the actual emissions from concrete batch plants in 50 states. In order to 

analyze facilities whose emissions are similar to those for sources potentially subject to the Indian Country 

Minor NSR rule, the EPA selected facilities for analysis with the North American Industry Classification System 

(NAICS) codes listed in Table 5. For sources in these four NAICS codes, the EPA selected actual emissions6 within 

the ranges listed in Table 6. 

Table 5: NAICS Codes Selected for Concrete Manufacturing Facilities

NAICS Code Description

327320 Central Mixed Concrete Manufacturing

327320 Concrete Batch Plants (including temporary)

327320 Ready Mix Concrete Manufacturing and Distributing 

 

5

For more information, go to: http://www.epa.gov/ttnchie1/net/2011inventory.html.

6 Only point source NEI data were used for this analysis. The point source inventory does not include emissions from 

nonroad engines. 
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NAICS Code Description

327320 Transit Mixed Concrete Manufacturing

327320 Truck Mixed Concrete Manufacturing 

327331 Concrete Manufacturing: All Types of Blocks and Bricks

327332 Concrete Manufacturing: All Types of Pipe and Conduit

327390 Concrete Manufacturing: All Structural Forms

Table 6: Emission Ranges Selected for Concrete Manufacturing Facilities

Criteria Pollutants PM10 PM2.5

Attainment Area

 Min. Emissions (tpy) 5 3

 Max. Emissions (tpy) 250 250

Nonattainment Area

 Min. Emissions (tpy) 1 0.6

 Max. Emissions (tpy) 250 250

The 2008 NEI data does not include emissions information for total PM. The EPA analyzed the emissions rates

listed in Table 3 that were used to establish the surrogate throughput emissions limitations and selected the 

facilities with emission levels similar to the facilities potentially subject to the minor NSR program, i.e., the 

facilities with emissions greater than the minor NSR applicability thresholds in Table 1 of 40 CFR 49.153 (Indian 

Country Minor NSR Rule) and less than the PSD major source threshold of 250 tpy. For purposes of this analysis, 

facilities located in nonattainment areas are defined as facilities located in counties that are designated 

nonattainment for the pollutant being analyzed. 

With the NAICS codes listed in Table 5 and the emission ranges defined in Table 6, the EPA identified the 

concrete manufacturing facilities located in attainment and nonattainment areas for PM10 and PM2.5. The EPA is 

providing the number of facilities (and average emissions) under the proposed emissions limitations and above 

the minor source thresholds. 

Table 6: Number of Facilities and Average Emissions for Concrete Manufacturing Facilities Selected

Criteria Pollutants Number of Facilities

Attainment Areas

PM2.5

Facilities >3 tpy and < 5 tpy 16 (2% of facilities covered)

Average Emissions (tpy) 4

Facilities > 3 tpy and < 250 tpy 24

Average Emissions (tpy) 13

PM10

Facilities >5 tpy and < 20 tpy 81 (8% of facilities covered)

Average Emissions (tpy) 9

Facilities > 5 tpy and < 250 tpy 12

Average Emissions (tpy) 52

Nonattainment Areas

PM2.5
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Criteria Pollutants Number of Facilities

Facilities >0.6 tpy and < 5 tpy 60 (24% of facilities covered)

Average Emissions (tpy) 2

Facilities >0.6 tpy and < 250 tpy 5

Average Emissions (tpy) 26

PM10 (moderate and serious)

Facilities >1 tpy and < 20 tpy 69 (34 % of facilities covered)

Average Emissions (tpy) 4

Facilities > 20 tpy and < 250 tpy 2

Average Emissions (tpy) 35

5.2.3 State Program Limits

Table 7 presents the limits in general permits and permits by rule for concrete batch plants issued by states. 

These state permits limit emissions by limiting: concrete production, fuel usage, fuel sulfur content, total 

pollutant emissions, pollutant emission rates, boiler capacity, engine capacity, co-location, or by requiring 

controls for particulate and fugitive emissions. Most state permits utilize combinations of the above limits to 

control the various pollutants. The Indiana permit is the simplest in that it limits annual concrete production to 

300,000 cubic yards per year. The Iowa permit is perhaps the most complex. It limits everything mentioned 

above except for individual pollutant emission rates. A comparison of requirements for attainment and 

nonattainment areas is not possible due to lack of a distinction made in most state programs, except for Arizona. 

The Arizona permit is an example of a concrete batch plant permit designed for an area designated as 

nonattainment for PM10. The Arizona general permit7 places limits on concrete production based on the 

attainment/nonattainment status of the concrete batch plant’s location. This distinction is necessary, as nearly 

half of the counties in Arizona have been designated nonattainment for PM10. 

 

7 Arizona Department of Environmental Quality, General Permits, General Concrete Batch Plant Permit, 

http://www.azdeq.gov/environ/air/permits/download/gncbppermit.pdf.
Page 13 of 25

Table 7: State Program Limits

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

Arizona

Attainment 

areas: 

1,280 yards/day 

if using 

generator 

power, 

1310 yards/day 

if using line 

power and 

nonattainment 

areas: 

930 yards/day if 

using generator 

power,

960 yards/day if 

using line 

power.

Each engine 

must limit 

hours of 

operation to 

the limits in the 

individual 

Authorizations 

to Operates.

Limit CO, NOX, SO2

emissions from 

concrete batch plant

to < 90 tpy; engine 

PM10 emissions: 

< 1.02 Q^0.769 

lb/hour, where 

Q=million British 

thermal units 

(MMBtu) of engine; 

and engine SO2

emissions: 

< 1 lb/MMBtu.

Boilers limited to 10 

MMBtu total and 

engine fuel sulfur: 

< 0.9%.

Cannot 

collocate 

with hot mix 

asphalt or 

rock 

crushing 

facility; and 

storage 

piles must 

be > 25 feet 

from 

boundary.

Water sprays 

required for 

mobile 

sources and

fugitives 

must be 

controlled by 

water spray 

and other 

reasonable 

precautions.

Yes; 

emissions 

from silos 

must be 

controlled by 

baghouses.

Yes;

no visible 

emissions 

(VE) beyond 

property 

line

Florida None specified.

Annual Use 

< 250,000 gal 

diesel fuel;

< 23,000 gal 

gasoline; and

< 44 million 

standard cubic 

feet natural 

gas.

General permit

issued to sources w/ 

PTE < major source 

levels

(< 100 tpy).

Total boiler capacity 

< 250 MMBtu.

A concrete 

batch plant

can be 

collocated 

with a 

nonmetallic 

mineral 

processing 

plant.

Water sprays 

required for 

mobile 

sources and

fugitives 

must be 

controlled by 

water spray, 

dust 

suppressant.

Yes;

emissions 

from 

enclosed 

operations 

must be 

controlled by 

baghouses to 

keep opacity 

less than 5%.

Yes;

5% opacity 

for 

emissions 

from 

enclosed 

equipment.
Page 14 of 25

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

Idaho 150,000 cubic

yards/year.

There are limits 

for water 

heaters, but 

these are not 

specified.

PM from fuel burning 

equipment must be < 

than 0.050 grains per 

standard cubic foot 

(gr/dscf) for diesel 

and < 0.015 gr/dscf 

for natural gas and 

there are no explicit 

limits in general 

permit, but this is a 

synthetic minor 

permit (actual 

emissions < 100 tpy).

Fuel for heaters and 

engines must be < 

0.0015% sulfur and

Any engine fuel 

must be No.1 or 2 

distillate oil.

Yes; varies 

depending 

upon engine 

size and 

concrete 

production 

rate.

Fugitives 

must be 

controlled by 

water spray, 

dust 

suppressant, 

or paving;

95% control 

of storage 

piles, use 3-

sided 

enclosures;

and 75% 

control Best 

Management

Practices 

(BMPs) must 

be used.

Emissions 

from 

enclosed 

operations 

must be 

controlled by 

baghouses 

with 99% 

control;

transfer 

operations 

must be 

controlled 

with water 

spray; and 

load out

controlled 

95-99%.

Yes; no VE

beyond 

property 

line.

Illinois

167,000 –

2,200,000 cubic

yards/year, 

depending upon 

equipment and 

controls used.

None specified.

24 – 79.6 tpy PM, 

depending upon 

equipment and 

controls used.

None specified.

Cannot 

collocate 

with hot mix 

asphalt or 

rock 

crushing 

facility.

Yes. Yes. Unknown.
Page 15 of 25

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

Indiana 300,000 cubic

yards/year.

None specified.

Actual emissions 

limited to < 100 tpy.

None specified.

No fugitive 

emissions 

beyond 

property 

boundary.

Apply water 

to storage 

piles and 

roads as 

needed to 

control 

visible 

emissions to 

less than 

20%.

All cement 

transfer 

operations 

must be 

enclosed and 

controlled by 

baghouse 

with visible 

emissions < 

20%.

Yes; less 

than 20%.

Iowa

Limit on 

production rate 

varies; there are 

five levels from: 

648 cubic 

yards/day for 

dry mix without

load out control 

to 

5,790 cubic

yards/day for 

wet mix with

load out 

controls.

Less than 35 

gal/hour for 

generators ≤

600 hp and less 

than 50 

gal/hour for 

generators > 

600 hp; and

generators may 

operate no 

more than 

4,850 

hours/year.

Permit issued to 

sources with PTE > 

major source levels 

but actual emissions 

< 50% of major 

source levels and 

actual emissions:

< 50 tpy criteria poll.

< 5/12.5 tpy HAPs.

Engines must use 

No. 1 or 2 diesel fuel 

with 0.5% or less 

sulfur; maximum

boiler heat input 

may not exceed 10 

MMBtu/hour; and

boiler shall fire only 

natural gas or 

propane.

1,000 feet 

from 

another 

concrete 

batch plant, 

any 

aggregate 

processing 

plant, or any 

hot mix 

asphalt

facility.

Utilize BMPs 

to minimize 

fugitives, 

watering 

roads and 

storage piles, 

enclose 

conveyors, 

drop points, 

and storage 

piles.

Emissions 

from silos, 

mixer, and 

truck load 

out must be 

controlled 

with a 

baghouse.

Less than 

25% from 

equipment 

and no VE 

beyond 

property 

boundary.
Page 16 of 25

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

Maine None specified.

Less than 

65,000 

gallons/year of 

diesel, #2, #4, 

or #6 fuel, or 

equivalent of 

natural gas or 

propane.

Less than 100 tpy and

engine PM emissions 

shall not exceed 0.12 

lb/MMBtu.

Engine size/ heat 

input shall not 

exceed 5 

MMBtu/hour or 700 

hp

Engine fuel sulfur 

content must not 

exceed 15 parts per 

million

None 

specified

Yes;

BMPs 

required for 

concrete 

batch plant

equipment

Concrete 

batch plant

and all 

material 

handling 

equipment 

must be 

controlled w/ 

baghouses

Engine VE 

and 

concrete 

batch plant

VE may not 

exceed 20%;

VE from 

transfer 

points shall 

not exceed 

7%

Maryland None specified. None specified.

General permit

issued to true minor 

sources;

PM emissions must 

be < 0.03 gr/dscf or < 

0.05 gr/dscf, 

depending upon 

location.

None specified. None 

specified.

Reasonable 

precautions 

must be 

taken to 

prevent 

fugitive dust 

from 

becoming 

airborne.

Emissions 

must meet 

standard, so 

a baghouse 

would be 

required.

No VE 

beyond 

property 

boundary

and

VE may not 

exceed 0% 

or 20%, 

depending 

upon 

location.

Mississippi None specified. None specified.

Emissions limited to 

synthetic minor 

levels (< 100 tpy).

None specified.

150 ft from 

nearest 

residence.

Fugitives 

must be kept 

to minimum

and roads 

must be 

wetted.

Mixer and 

silo must be 

equipped 

with

baghouse.

Yes; opacity 

limited to 

less than 

40%.
Page 17 of 25

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

New 

Mexico

Less than 2,400 

cubic yards/day.

None specified.

NOX, CO, VOC, & TSP: 

< 95 tpy; SO2: < 50 

tpy; single HAP: < 8 

tpy; and total HAP: <

23 tpy.

Heaters must have

heat input rate less 

than 25 

MMBtu/hour and 

fuel sulfur content 

for engines and 

heaters must be less 

than 0.05%.

Any 

emission 

unit must be 

located a 

minimum of 

42 feet from 

boundary

and located 

a minimum 

of 3 miles 

from Class 1 

area.

Control 

storage piles 

and haul 

roads with

watering, use 

enclosure 

during 

loading, use 

controls 

during truck 

loading.

Emissions 

from silos 

must be 

filtered to at 

least 95%.

No VE 

beyond 

property 

boundary

and no VE 

from silo 

exhausts.

Ohio –

Truck Mix 

Ready Mix

Less than 200 cu 

yards/hour and

less than 

250,000 cubic

yards/year.

None specified.

TSP emissions 

< 0.03 gr/dscf and 

each piece of 

equipment has 

separate emission 

limits and total 

allowed emissions 

after controls is 

about 12 tpy of total 

suspended 

particulate (TSP).

Boilers and heaters 

each have max heat 

input rating 

< 10 MMBtu/hour

and fuel sulfur 

content 

< 0.5%.

N/A

Truck loading 

must be 

enclosed and 

vented to 

filters.

Silos and 

mixers and 

hoppers 

must be 

vented to 

filters.

No VE from 

filters and

VE of 

fugitives 

shall not 

exceed 10%.
Page 18 of 25

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

Ohio –

Central Mix 

Ready Mix

Less than 300 

cubic

yards/hour

and

Less than 

300,000 cubic

yards/year.

None specified.

TSP emissions 

< 0.03 gr/dscf; each 

piece of equipment 

has separate 

emission limits; and 

total allowed 

emissions after 

controls is about 5.3 

tpy of TSP

Boilers and heaters 

must each have 

maximum heat 

input rating 

< 10 MMBtu/hour

and fuel sulfur 

content 

< 0.5%.

None 

specified.

Must use 

BMPs, 

minimize 

drop heights, 

add moisture 

to 

aggregates, 

and enclose 

mixing 

equipment 

and vent to 

filter.

Silos and 

mixers and 

hoppers 

must be 

vented to 

filters and 

Best 

Available 

Control 

Technology

must be used 

for materials 

transfer.

Yes. No VE 

from filters; 

VE of 

fugitives 

shall not 

exceed 10%.

Oregon None specified. None specified.

PM: 24 tpy;

PM10: 14 tpy;

SO2: 39 tpy;

NOX: 39 tpy;

CO: 99 tpy;

VOC: 39 tpy; and

PM10 in MedfordAshland AQMA: 4.5 

tpy

Fuel oil sulfur 

content specs:

No. 1 oil: < 0.3%;

No. 2 oil: < 0.5%;

Residual oil: < 

1.75%; and

Used oil: < 0.5%.

None 

specified.

Must control 

vehicle 

speeds, 

control 

fugitive dust 

from all 

processes, 

treat storage 

piles, and 

clean roads.

Silo 

emissions 

must be 

filtered and

truck loading 

must use 

water sprays.

VE must not 

exceed 20%

and no 

deposition 

of PM on 

nearby 

property.
Page 19 of 25

State

Concrete 

Throughput 

Limits

Fuel Usage 

Limits?

Criteria Pollutant 

Emission 

Limitations?

Boiler or Engine 

Fuel or Size 

Limitation?

Setback 

Required?

Fugitive Dust 

Controls 

Required?

PM

Emissions 

Controls 

Required?

Visible 

Emissions 

Limitation?

South 

Carolina None specified. None specified.

PM emissions from 

fuel burning must be 

less than 0.6 

lbs/MMBtu

and

NOX emissions from 

fuel burning must be 

less than 0.036 

lb/MMBtu for natural 

gas and less than 

0.15 lb/MMBtu for 

distillate oil.

Engines and heaters 

must have 

maximum heat 

input less than 30 

MMBtu/hour and 

burn fuel w/ sulfur 

content less than 

0.5% and there are 

HAP metal limits for 

fuel.

None 

specified.

Must not 

violate 

NAAQS at 

property 

boundary

and must 

maintain 

dust control 

on storage 

piles and 

roadways 

with

watering, 

sweeping.

Silos must be 

controlled 

with filter.

Opacity 

must be less 

than 20%.

Texas

Less than 300 

cubic

yards/hour

and

Less than 6,000 

cubic yards/day.

None specified.

PM emissions

< 0.01 gr/dscf.

Engines limited to 

total of 1,000 hp

and sulfur content 

of fuel shall be less 

than 0.0015%.

Storage 

piles and 

equipment 

at least 50 

feet from 

property 

boundary

and 

baghouse 

exhaust at 

least 100 

feet from 

boundary 

and 440 

yards from 

the nearest 

residence.

Storage piles, 

roadways, 

must be 

controlled; 

must 

construct 

dustsuppressing 

fencing 

around site 

to height of 

12 feet; and 

3-sided 

enclosures 

around piles.

Must use 

suction 

shroud for 

truck loading

and silos and 

hoppers 

must be 

controlled 

with a filter 

at 99.5% 

control.

No visible 

emissions 

beyond 

property 

boundary.
Page 20 of 25

References

40 CFR 49.151 – 40 CFR 49.173, Indian Country Air Quality Planning and Management. http://www.ecfr.gov/cgibin/text-idx?tpl=/ecfrbrowse/Title40/40cfr49_main_02.tpl

40 CFR Part 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion 

Engines. http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&sid=f2c4f71bd50d2a8883adafec36732010&rgn=div6&view=text&node=40:6.0.1.1.1.98&idno=40

40 CFR Part 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion 

Engines. http://www.ecfr.gov/cgi-bin/textidx?SID=093578d89c2100a85b3bd00b188a5413&node=40:7.0.1.1.1.98&rgn=div6

40 CFR Part 63, Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary 

Reciprocating Internal Combustion Engines. http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&rgn=div6&view=text&node=40:13.0.1.1.1.1&idno=40

AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, 

Chapter 11.12, Mineral Products Industry, Concrete Batching.

http://www.epa.gov/ttn/chief/ap42/ch11/index.html

Federal Register Vol. 76, No. 127, July 1, 2011, Pages 38748-38808, “Review of New Sources and Modifications 

in Indian Country; Final Rule” (Indian Country NSR Rule). 

https://www.federalregister.gov/articles/2011/07/01/2011-14981/review-of-new-sources-and-modifications-inindian-country

Arizona Department of Environmental Quality, General Permits, General Concrete Batch Plant Permit.

http://www.azdeq.gov/environ/air/permits/class.html#general, 

http://www.azdeq.gov/function/forms/appsair.html#source, 

http://www.azdeq.gov/environ/air/permits/download/gncbppermit.pdf

Florida Department of Environmental Protection, Emission Sources, Air General Permits – Concrete Batching 

Plants. http://www.dep.state.fl.us/air/emission/concrete.htm, 

http://www.dep.state.fl.us/air/emission/air_gp.htm

Idaho Department of Environmental Quality, Air Quality Permitting, Air Quality Operating Permitting Forms and 

Checklists. http://www.deq.idaho.gov/permitting/air-quality-permitting/tier-ii.aspx, 

http://www.deq.idaho.gov/permitting/air-quality-permitting/forms-checklists.aspx#tier-ii

Illinois Environmental Protection Agency, Air Permit Programs, Air Permit Applications and Guidance, Lifetime 

Permits. http://www.epa.state.il.us/air/permits/ , http://www.epa.state.il.us/air/permits/concrete-batchapplication-guidance.pdf

Indiana Department of Environmental Management, IDEM Permit Guide, Source Specific Operating Agreements 

(SSOAs), 326 IAC 2-9-9 Ready-mix Concrete Batch Plants. http://www.in.gov/idem/5886.htm , 

http://www.in.gov/legislative/iac/T03260/A00020.PDF? 
Page 21 of 25

Iowa Department of Natural Resources, Regulatory – Air, Operating Permits, Operating Permit Forms and 

Instructions, Small Source (50%). 

http://www.iowadnr.gov/InsideDNR/RegulatoryAir/OperatingPermits/FormsInstructions.aspx#LiveTabsContent

255618-lt, 

http://www.iowadnr.gov/portals/idnr/uploads/air/insidednr/conpermit/concrete_batch_template.doc

Maine Department of Environmental Protection, Air Quality, Air Permits, General Permits, Concrete Batch 

Plants. http://www.maine.gov/dep/air/permits/index.html, 

http://www.maine.gov/dep/air/permits/conc_batch_plant.html

Maryland Department of the Environment, Permits, Air Quality General Permits to Construct.

http://www.mde.maryland.gov/programs/Permits/AirManagementPermits/AirQualityGeneralPermit/Pages/ind

ex.aspx

Mississippi Department of Environmental Quality, General Permits.

http://deq.state.ms.us/Mdeq.nsf/page/epd_epdgeneral?OpenDocument, 

http://deq.state.ms.us/Mdeq.nsf/pdf/epd_ReadyMixConcreteGeneralPermit/$File/RMCGPFinalPermit.pdf?Ope

nElement

New Mexico Environment Department, Air Quality Bureau, Permitting Section, GCP-5 General Construction 

Permit for Concrete Batch Plants. http://www.nmenv.state.nm.us/aqb/permit/Permit_Apps/Permitting_6_GCP5.html

Ohio Environmental Protection Agency, General Permit Program, Ready Mix Concrete Batch Plants.

http://www.epa.ohio.gov/dapc/genpermit/genpermits.aspx, 

http://www.epa.ohio.gov/dapc/genpermit/rmcbp.aspx

Oregon Department of Environmental Quality, Air Quality, General Air Contaminant Discharge Permits.

http://www.deq.state.or.us/aq/permit/acdp/general.htm, 

http://www.deq.state.or.us/aq/permit/acdp/general/AQGP-009.pdf

South Carolina Department of Health and Environmental Control, Air Quality, Air Permitting, General Permits.

Concrete Plants.

http://www.scdhec.gov/environment/baq/Permitting/OperatingPermits/GeneralPermits/concrete.asp, 

http://www.scdhec.gov/environment/baq/docs/permitting/GCMOperation/GSOP-Concrete.pdf

Texas Commission on Environmental Quality, Permitting, Air Permits, Standard Air Permits.

http://www.tceq.texas.gov/permitting/air/nav/standard.html, 

http://www.tceq.texas.gov/permitting/air/newsourcereview/mechanical/cbp_enhanced.html
Page 22 of 25

Attachment A:

Emissions Calculations for Concrete Batch Production Limits

Assume that plant production capacity is 2,000,000 cubic yards of concrete per year.

Assume that plant emissions are controlled with control devices and work practice standards.

For PM10 emissions:

Railcar/Barge/Truck Sand Unloading:

2,000,000 yards/year x 0.0007 (lbs/yard) x 1 ton/2,000 yards = 0.7 tpy PM10/year

Railcar/Barge/Truck Aggregate Unloading:

2,000,000 yards/year x 0.0031 (lbs/yard) x 1 ton/2,000 yards = 3.1 tpy PM10/year

Cement - Unloading to Elevated Storage:

2,000,000 yards/year x 0.0001 (lbs/yard) x 1 ton/2,000 yards = 0.1 tpy PM10/year

Cement Supplement - Unloading to Elevated Storage:

2,000,000 yards/year x 0.0002 (lbs/yard) x 1 ton/2,000 yards = 0.2 tpy PM10/year

Sand - Transfer to Conveyor:

2,000,000 yards/year x 0.0007 (lbs/yard) x 1 ton/2,000 yards = 0.7 tpy PM10/year

Aggregate - Transfer to Conveyor:

2,000,000 yards/year x 0.0031 (lbs/yard) x 1 ton/2,000 yards = 3.1 tpy PM10/year

Sand - Transfer to Elevated Storage:

2,000,000 yards/year x 0.00007 (lbs/yard) x 1 ton/2,000 yards = 0.07 tpy PM10/year

Aggregate - Transfer to Elevated Storage:

2,000,000 yards/year x 0.00031 (lbs/yard) x 1 ton/2,000 yards = 0.31 tpy PM10/year

Weigh Hopper Loading:

2,000,000 yards/year x 0.00038 (lbs/yard) x 1 ton/2,000 yards = 0.38 tpy PM10/year

Mixer Loading:

2,000,000 yards/year x 0.001551 (lbs/yard) x 1 ton/2,000 yards = 1.551 tpy PM10/year

Truck Loading:

2,000,000 yards/year x 0.0074166 (lbs/yard) x 1 ton/2,000 yards = 7.4166 tpy PM10/year

Total PM10 emissions = 17.6 tpy