24-013-00012 

 

Mr. Wallace Brown, Jr. 

Environmental Engineer 

Lehigh Portland Cement Company 

675 Quaker Hill Road 

Union Bridge, MD 21791 

Re: Part 70 Operating Permit Renewal 

Dear Mr. Brown: 

 Enclosed please find the Title V Operating Permit and Fact Sheet for the Union 

Bridge facility. The permit will expire on September 30, 2008. 

The Code of Maryland Regulations (COMAR) 26.11.03.11 states the following: 

If the Department denies a Part 70 permit or issues it with terms and 

conditions that are objectionable to the applicant, the applicant may request 

that a contested case hearing be held regarding the permit. This request shall 

be made to the Department in writing not later than 15 days after the 

applicant receives notice that the permit has been denied or of the 

objectionable terms and conditions. The request shall include the basis for 

the request and refer to any objectionable terms and conditions. 

If you have any questions, please feel free to call Mr. George Beerli, the Permit 

Manager for this facility, at (410) 537-3225. 

 Sincerely, 

 Karen G. Irons, P.E., Administrator 

 Air Quality Permits Program 

 Air & Radiation Management Administration 

KGI/jm 

Enclosures 

cc: Dave Campbell, EPA Region III, with enclosures 

 Kathleen Anderson, EPA Region III 
Bcc: Shannon, George B, Dave
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 1 of 64 

BACKGROUND 

Lehigh Cement Company operates a Portland cement manufacturing plant in Union Bridge, 

Maryland. The plant is located in both Carroll and Frederick Counties. The quarry is located in Frederick 

County while the main part of the plant is located in Carroll County. The original plant at Union Bridge 

was built in 1910 and has been modernized several times including the recent modernization/expansion 

where the four existing long-dry kilns were replaced with one pre-heater/kiln system. A permit to construct 

and New Source Review (NSR) and Prevention of Significant Deterioration (PSD) Approvals were issued 

to Lehigh Cement Company on April 8, 1999 for the plant modernization and expansion. The permit to 

construct and the PSD Approval were modified on June 7, 2000. 

The following is a description of the processes at the Union Bridge facility. 

Quarry

The principal raw materials used for the Union Bridge plant are limestone, shale, sand, and mill 

scale. The limestone and shale are taken from the main quarry site near the crushing plant and are 

processed through the same crushing plant. The sand, mill scale and fly ash/bottom ash are purchased. 

Rock Crushing

Trucks dump the rock into the hopper of an apron feeder, which feeds a gyratory crusher where it 

is broken down into fragments less than six inches in size. The crushed rock is conveyed to a surge bin that 

provides a steady feed for a series of two cone crushers. The cone crushers are in closed circuit with 

vibrating screens so that all the material that leaves the crushing plant is finer than one inch. The three 

crushers are controlled by a baghouse. 

Rock Storage

After the rock has been crushed, it travels on a system of belt conveyors to the storage/blending 

dome. The dome is 400 feet in diameter and 126 feet high and has a storage capacity of 50,000 metric tons 

of rock.

Raw Material Storage and Handling 

Iron-based and silica based raw materials are housed on a partially enclosed raw material storage 

building. Solid fossil fuels are located in outdoor storage piles. Alumina-bearing ash raw materials are 

pneumatically conveyed to a storage tank. Raw material transfer throughout the plant is done by covered 

conveyor systems and transfer towers, which have dust collectors venting all transfers. 

Vertical Roller Mill (Raw Mill) 

The Lehigh plant includes an in-line Loesche vertical raw mill system. The in-line raw mill 

utilizes recycled heated gases from the precalciner exhaust to dry and separate the raw meal. This provides 

for greater fuel efficiency in the kiln system. An additional benefit of an in-line raw mill is that the 

limestone (in the raw materials) acts as a scrubber to remove some of the sulfur compounds from the 

precalciner exhaust gases. The exhaust gases from the raw mill are vented through a dust collector to the 

main kiln stack. The raw mill runs most, but not all, of the time the kiln operates. 

Blending Silo
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 2 of 64 

In this operation, all the raw materials are blended to the proper proportions for introducing into 

the preheater tower/kiln system. Particulate emissions from the silos and raw material handling systems are 

controlled with baghouses. 

Coal Storage

Coal is the primary fuel and is stockpiled outside on the ground near the preheater tower/kiln 

system. 

Coal Mill

Coal from the stockpiles is crushed to a fine size for use in the preheater tower/kiln system. The 

coal mill utilizes heated gases from the precalciner exhaust to dry and separate the coal. Exhaust gases 

from the coal mill are vented through a dust collector to the main kiln stack. 

Kiln, Raw Meal Feed, and Coal Mill Feed Systems

The preheater/precalciner kiln system allows higher production with a smaller kiln and more 

efficient fuel use. The process of making cement involves chemical reactions in three zones: preheating, 

calcining, and sintering. The primary combustion air system provides combustion air to burn fuel used in 

the rotary kiln. The combustion gases from the rotary kiln vent through the calciner and the precalciner. 

The secondary combustion air system provides combustion air to burn fuel introduced directly into the 

precalciner to reduce NOx emissions. In the preheater section, the heated combustion gases from the 

precalciner are used to warm the feed and evaporate any remaining water. The Lehigh plant has a 

precalciner located at the base of the preheater tower. The function of the calciner is to allow the majority 

of the calcination reaction of the raw meal to occur before the feed enters the kiln. Calcination is the 

process by which carbon dioxide is driven from the limestone leaving lime. In the sintering, or burning 

zone, the lime combines with other raw materials to form clinker.

Lehigh monitors the emissions of NOx, SO2, CO and THC with continuous emissions monitors 

that are installed on the main kiln stack. There is also a continuous opacity monitor installed in the stack. 

Clinker Cooler

Clinker from the kiln drops into reciprocating grate coolers, where cooling air blows up through 

the clinker. The clinker is then transported to the clinker storage silo. Emissions are controlled by a 

baghouse. There is a continuous opacity monitor installed in the stack from the cooler.

Roll Press

The roll press is used to pre-grind the clinker for feeding to the finish mills. The product from the 

press is a flat powdery cake form, rather than the clinker, which was in the form of a ball. The finished 

product from the roll press is conveyed to the finish mills for further grinding and size reduction. The 

system is controlled by baghouses.

Finish Mill System

This is the final grinding operation for the cement. Just before the finish grinding, gypsum is 

mixed with the cement to control the rate at which the cement will set after it is mixed into concrete. The 

finished cement is pumped to the storage silo. The finish mill system includes existing finish mills #4, #5, 

#6 and #7 in addition to conversion of the old raw mill system to #8 finish mill. The finish mills are 

controlled by baghouses. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 3 of 64 

Cement Loadout and Waste Dust Handling

A total of 32 existing product silos continue to be used at the plant. A new day silo was added for 

more flexibility and to increase safety of the bulk loadout system. Cement is shipped offsite by trucks and 

rail. Both packaged and bulk products are shipped. 

 

The following table summarizes the actual emissions from Lehigh Cement Company based on its 

Emission Certification Reports. 

Table 1: Actual Emissions 

Year NOX

(TPY) 

SOX

(TPY) 

PM10

(TPY) 

CO 

(TPY) 

VOC 

(TPY) 

HAP 

(TPY) 

1999 4547 1513 770 340 41 132 

2000 4344 1683 752 383 42 135 

2001 4133 1411 704 323 38 121 

The major source threshold for triggering Title V permitting requirements in Carroll County is 25 

tons per year for NOX, 25 tons per year for VOCs, 100 tons per year for any other criteria pollutants, 10 

tons per year for any single hazardous air pollutant (HAP) and 25 tons per year for combined HAPs. Since 

the actual emissions of NOx, SOx, PM10, CO, VOC, and HAPs from the facility are greater than the major 

source threshold, Lehigh Cement Company is required to obtain a Title V-Part 70 Operating Permit under 

COMAR 26.11.03.01. 

Lehigh did not receive a Part 70 permit for the Union Bridge plant as of December 1,2001, the 

date Maryland’s interim approval of its Part 70 program expired. As a consequence, Lehigh was required 

to submit a Part 71 permit application by May 31,2002. The Department received Lehigh’s Part 71 

application on May 31, 2002. An administrative completeness review was conducted and the application 

was deemed to be administratively complete. A letter was sent to Lehigh granting an application shield. 

The Part 71 application serves as a revised Part 70 application for this Part 70 permit. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 4 of 64 

EMISSION UNIT IDENTIFICATION

Lehigh has identified the following emission units as being subject to the Title V permitting requirements 

and having applicable requirements. 

Table 2: Emissions Unit Identification 

1. Quarry 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources - not subject to MACT requirements 

HR1 Quarry Haul Roads Fugitive Emission Source Modified in 

2002 

SP1 Limestone Storage Pile Fugitive Emission Source Modified in 

2002 

TLU1 Limestone truck 

loading/unloading 

Fugitive Emission Source 1970 

TLU2 Truck loading/unloading Fugitive Emission Source 2002 

Point Sources - not subject to MACT requirements 

A01-009 

A01-018 

Gyratory Crusher 

Belt Conveyor #1 

Discharging through Dust Collector A01-

012 - EP1 

1957 

A01-021 Surge Bin Discharging to Dust Collector A01-025 – 

EP2 

1955 

A02-005 

A02-006 

A02-010 

A02-017 

A02-018 

A02-019 

A02-021 

Belt Conveyor #2 

Secondary Crusher 

Belt Conveyor #3 

Belt Conveyor #6 

Belt Conveyor #5 

Tertiary Crusher 

Belt Conveyor #4 

Discharging to Dust Collector A02-008 – 

EP3 

1970 

A02-011 

A02-022 

A02-023 

Vibrating Screens and Transfer 

System 

Discharging to automatic bag-type dust 

arrester A02-015 &A02-012 – EP4 & 5 

1970 

A02-024 Belt Conveyor #7 Discharging to dust collector A02-012 & 

A02-025 – EP5 & 6 

1970 with 

New DC 

B01-017 Belt Conveyor #8 Discharging to dust collector A02- 025 – 

EP6 

1970 with 

New DC 

2. Raw Material Handling 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources - not subject to MACT requirements 

B01-011 Enclosed Limestone Dome Between TT#3 and TT #8/9 2001 

TU1 Iron & silica truck unloading Fugitive Emissions 2002 

SP4 Silica Storage Pile Fugitive Emissions 2002 

SP5 Iron Storage Pile Fugitive Emissions 2002 

Fugitive Sources - subject to MACT requirements 

H04-001 Gypsum Bin 409 Fugitive Emissions 1970 

H04-003 Limestone Tank 416 Fugitive Emissions 1970 

H05-001 Gypsum Bin 509 Fugitive Emissions 1970 

H06-001 Gypsum Bin 609 Fugitive Emissions 1970 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 5 of 64 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

H07-001 Gypsum Bin Fugitive Emissions 2001 

H08-001 Gypsum Bin Fugitive Emissions 2001 

Point Sources – not subject to MACT requirements 

B02-007 

B02-011 

B02-012 

B02-017 

Belt Conveyor 

Silica Bearing Material Bin 

Iron Bearing Material Bin 

Reversible Belt Conveyor 

Discharging to dust collector B02-008 – 

EP7 

2001 

C01-002 

C01-004 

C01-006 

C01-011 

Limestone Weighfeeder 

Iron Weighfeeder 

Silica Weighfeeder 

Belt Conveyor 

Discharging to dust collector C01-007 – 

EP8 

2001 

B03-004 Fly ash Blending Silo System Discharging to dust collector B03-008 – 

EP9 

2002 

C01-015 Fly ash Weigh bin Discharging to dust collector C01-019 – 

EP10 

2002 

C02-001 Bucket Elevator Discharging to dust collector C02-011 & 

C02-021 – EP12 & 15 

2001 

C02-002 

C02-006 

C02-014 

Belt Conveyor 

100T Bin 

15 T Bin 

Discharging to dust collector C02-011 – 

EP12 

2001 

TT3 Transfer Tower #3 Discharges to dust collector B04-016&B04-

011 – EP17 & 18 

2002 

B04-019 Limestone Bin Discharging to dust collector B04-016 – 

EP17 

2002 

TT4 Transfer Tower #4 Discharging to dust collector B02-019 – 

EP19 

2002 

TT8/9 Transfer Tower #8/9 Discharging to dust collector B01-

018&G02-041 – EP42 & 72 

2001 

Point Sources – subject to MACT requirements 

C02-061 Belt Conveyor Discharging to dust collector C01-007 – 

EP8 

2001 

C02-038 Rejects Belt Conveyor Discharging to dust collector C01-007 & 

C02-021 – EP8 & 15 

2001 

C02-060 Reversible Belt Conveyor (to 

Raw Mill) 

Discharging to dust collector C02-011 – 

EP12 

2001 

C02-017 Belt conveyor (from 15 T Bin) Discharging to dust collector C02-021 – 

EP15 

2001 

3. Coal Feed System – (not subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Emissions 

F01-034/F01-

037 

Belt Conveyor #11/14 Fugitive Emissions 1970 

RU1 Coal Rail Unloading Fugitive Emissions 1970 

SP2 

SP3 

Coal Storage Pile 

Coal Storage Pile 

Controlled by Stockpile Sprinklers (F#01-

008) 

2002 

TT1 Transfer Tower #1 Controlled by a Dust Suppression System 

(#F01-036) 

1970 

TT2 Transfer Tower #2 Controlled by a Dust Suppression System 2002 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 6 of 64 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

(#F01-027) 

TU2 Truck unloading Controlled by Water Spray F01-012 2002 

Points Sources 

F02-018 Belt Conveyor Discharging to dust collector F02-033 – 

EP11 

2002 

F02-019 Belt Conveyor Discharging to dust collector F02-030 & 

F02-033 – EP11 & 14 

2002 

TT5 

F02-006 

Transfer Tower #5 

Reclaim Elevator 

Discharging to dust collector F02-027 – 

EP16 

2002 

F02-020 Reversible Belt Conveyor Discharging to dust collector F02-010 – EP 

23 

2002 

 F03-001 

F03-002 

F03-003 

Belt Conveyor 

Coal Bin weighfeeder 

Coke Bin Weighfeeder 

Discharging to dust collector F03-058 – EP 

25 

2002 

TT6 Transfer Tower #6 Discharging to dust collector G02-025 – 

EP41 

2002 

4. Raw Meal Feed (subject to MACT requirements)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

C03-034 

C03-035 

C03-040 

C03-042 

Airslide 

Airslide 

Airslide 

Airslide 

Discharging to dust collector C03-001 – 

EP20 

2002 

C03-045 Airslide Discharging to dust collector C03-047/C03-

050 – EP 21 & 22 

2002 

C03-008 

C03-054 

C04-066 

Airslide 

Airslide 

Airslide 

Discharging to dust collector C03-050 – 

EP22 

2002 

C03-046 Bucket Elevator Discharging to dust collector D01-037 & 

C03-030 – EP 24 & 26 

2002 

C03-017 

D01-001 

D01-003 

D01-002 

Airslide 

Blending Silo 

Recirculation Airslide 

Recirculation Airslide 

Discharging to dust collector D01-037 –

EP24 

2002 

C03-010 

C03-013 

Airslide 

Airslide 

Discharging to dust collector C03-030 – 

EP26 

2002 

D01-020 

D02-004 

D02-006 

D02-017 

D02-019 

185 MT Feed Bin 

Airslide 

Flow Meter 

Airslide 

Flow Meter 

Discharging to dust collector D01-034 – 

EP27 

2002 

D01-023 

D01-026 

D02-007 

D02-020 

Airslide 

Airslide 

Airslide 

Airslide 

Discharging to dust collector D01-040 – 

EP28 

2002 

D02-010 

D02-023 

D02-049 

Airslide 

Airslide 

Airslide 

Discharging to dust collector D02-041 – EP 

29 

2002 

D02-025 Bucket Elevator Discharging to dust collector D02-041/D02- 2002 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 7 of 64 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

D02-026 Bucket Elevator 027 – EP 29 and 31 

D02-033 

D02-045 

D02-047 

Airslide 

Airslide 

Airslide 

Discharging to dust collector D02-027 – 

EP31 

2002 

5. Kiln, Raw and Coal Mill – Point Sources (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

C02-025 

E02-001 

E01-001 

Raw Mill 

Kiln 

Precalciner/preheater 

Discharging to dust collector C04-014 – 

EP13 

2001 

F03-016 Coal Mill System Discharging to dust collectors F03-028, 

032, 036, 040, 044, & 048 – EP13 

2001 

6. Clinker Cooler and Main Pan Conveyor – Point Sources (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

E03-001 

G01-001 

Clinker Cooler 

Pan conveyor 

Discharging to Dust Collector #E04-016 – 

EP32 

2001 

7. Clinker Handling and Craneway (subject to MACT requirements)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources 

CWAY Craneway Fugitive emission source 1970 

G04-040 Drag Conveyor B2 Fugitive emission source 1970 

H04-004 Clinker Bin 403 Fugitive emission source 1970 

H05-004 Clinker Bin 503 Fugitive emission source 1970 

H06-004 Clinker Bin 603 Fugitive emission source 1970 

H07-004 Clinker Bin Fugitive emission source New 

TU3 Gypsum Truck Unloading Fugitive emission source New 

TU4 Truck Unloading Fugitive emission source New 

Point Sources 

G04-014 

G04-020 

750 MT Clinker Bin 

Belt Conveyor 

Discharging to Dust Collector G04-011 – 

EP33 

2001 

H09-000 Semifinish Grinding System Discharging to Collector H09-059 – EP33 2001 

H09-028 Bucket Elevator Discharging to Dust Collector H09-051 – 

EP33 

2000 

H09-047 

H09-058 

Bucket Elevator 

Belt Conveyor 

Discharging to Collector H09-059 – EP33 2000 

G04-010 Bucket Elevator Discharging to dust collector G04-011 & 

G04-034– EP33 & 34 

2001 

H09-062 Reversible Belt Conveyor Discharging to dust collector H09-051 & 

H09-082 – EP33 & 36 

2000 

H09-031 Belt Conveyor Discharging to Dust Collector H09-059 & 

H09-033 – EP33 and 44 

2000 

G04-009 

G04-016 

G04-056 

Belt Conveyor 

Belt Feeder 

100 MT Clinker Bin 

Weighfeeder 

Discharging to dust collector G04-034 EP34 2002 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 8 of 64 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

H09-019 

H09-023 

H09-024 

Weighfeeder 

100 MT Gypsum Bin 

Weighfeeder 

Belt Conveyor (from weigh 

feeders) 

Discharging to dust collector H09-025 – 

EP35 

2001 

H09-021 

H09-066 

H09-020 

100 MT Clinker Bin 

Weighfeeder 

Belt Conveyor 

100 MT Slag/Clinker Bin 

Weighfeeder 

Discharging to dust collector H09-082 – 

EP36 

2002 

G01-012 Clinker Storage Silo Discharging to Dust Collector G01-009 – 

EP37 

2001 

G02-002 Transfer Tower #13 

Belt Conveyor 

Discharging to dust collector G02-047 – 

EP38 

2002 

G02-002 Transfer Tower #12 

Belt Conveyor 

Discharging to dust collector G02-044 – 

EP39 

2002 

G02-002 Transfer Tower #11 

Belt Conveyor 

Discharging to dust collector G02-021 – 

EP40 

2002 

TT6 Transfer Tower #6 Discharging to dust collector G02-025 – 

EP41 

New 

TT8/9 Transfer Tower #8/9 Discharging to dust collector B01-018 & 

G02-041– EP42 & 72 

New 

TL1 Clinker Truck/Rail Loadout Discharging to dust collector G02-053 – 

EP43 

New 

 H09-036 

H09-041 

H09-046 

Bin 

Roll Press 

Belt Conveyor 

Discharging to dust collector H09-033 – 

EP44 

New 

TT9/10 Transfer Tower #9/10 Discharging to dust collector G03-011 – 

EP45 

New 

TT7 Transfer Tower #7 Discharging to dust collector G03-004 – 

EP46 

New 

H09-091 Metal Reclamation System Discharging to dust collector H09-094 – 

EP47 

New 

8. Finish Mill Systems (subject to MACT requirements)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

H04-006 

H04-014 

Belt Conveyor (FM #4) 

Finish Mill #4 System 

Discharging to Dust Collector H04-044 – 

EP48 

1970 

H06-014 

H06-017 

H06-037 

Finish Mill #6 System 

Cyclone 642 (FM#6 System) 

Separator 627 (FM#6 System) 

Discharging to Dust Collector H06-044 – 

EP49 

1970 

H07-014 Finish Mill #7 System Discharging to Baghouse H07-056/H07-057 

– EP50 

2002 

H07-018 

H07-069 

H07-070 

Finished Cement Transfer 

System 

Bucket Elevator 

Airslide 

Discharging to Baghouse H07-056/H07-057 

– EP50 

2001 

H05-014 Finish Mill #5 System Discharging to dust collector H05-044 - 

EP51 

1970 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 9 of 64 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

H08-014 

H08-017 

H08-037 

H08-067 

Finish Mill #8 System 

Separator (FM #8 System) 

Cyclone (FM#8 System) 

Cyclone (FM#8 System) 

Discharging to dust collector H08-056 – 

EP52 

2002 

9. Cement Loadout (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

H07-040 

H07-071 

H08-040 

H08-064 

H10-001 

H10-006 

Cement Cooler 

Airslide 

Cement Cooler 

Airslide 

Airslide 

Bucket Elevator 

Discharging to dust collector H10-113 – 

EP53 

2002 

H10-167 

H10-176 

Airslide 

Bucket Elevator 

Discharging to dust collector H10-181 – 

EP54 

2002 

H10-177 

I01-033 

Airslide 

Day Tank 

Discharging to dust collector H10-179 – 

EP55 

2002 

F1-F8, G1-G8, 

H1-H8, J1-J8 

Product Silos Discharging to dust collectors H10-221, 

H10-224, H10-252 & H10-254 – EP 58, 60, 

61, 74 and 75 

1970 

I02-289 

TL2 

Feed Bin 

Truck Day Tank Loadout 

Discharging to #I02-290 – EP56 2002 

I03/I04 Packaging and Pelletizing Discharging to the Existing Baghouse 

EASTPKHS - EP61 

1970 

H10-007 

H10-010 

H10-124 

H10-125 

Airslide 

Bucket Elevator 

Airslide 

Airslide 

Discharging to Dust Collector H10-119 – 

EP62 

2001 

TL4 Bulk Loadout System Discharging to the dust collectors I02-204, 

-208, -224, -228, -244, -248, -264, &-268 – 

EP 64, 65, 66, 67, 68, 69, 70, & 71 

1970 

10. Waste Dust Handling – ( not subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

C04-037 Bucket Elevator Discharging to dust collector C04-

050&C04-075 – EP 57 & 63 

2002 

C04-038 

C04-068 

600 T Bin 

Airslide 

Discharging to #C04-050 – EP57 2002 

C04-070 

C04-072 

C04-074 

TL3 

Airslide 

Airslide 

Airslide 

Truck Waste Dust Loadout 

Discharging to dust collector C04-075 – 

EP63 

2002 

11. Miscellaneous Sources Venting Inside Building (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

G04-018 Belt conveyor Venting through Dust Collector G04-037 

located inside – NP1 

New 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 10 of 64 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

G04-019 CE2 Bucket Elevator Venting through Dust Collector G04-037 

located inside – NP1 

1970 

G04-031 Drag Conveyor B3 Venting through Dust Collector H09-073 

located inside – NP2 

1970 

H09-058 Belt Conveyor Venting through Dust Collector H09-073 

located inside – NP2 

2000 

H09-075 90T Bin Venting through Dust Collector H09-073 

located inside – NP2 

2000 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 11 of 64 

AN OVERVIEW OF THE PART 70 PERMIT

Section I of the Part 70 Permit contains a brief description of the facility and an inventory list of 

the emissions units for which applicable requirements are identified in Section IV of the permit. 

Section II of the Part 70 Permit contains the general requirements that relate to administrative 

permit actions. This section includes the procedures for renewing, amending, reopening, and transferring 

permits, the relationship to permits to construct and approvals, and the general duty to provide information 

and to comply with all applicable requirements. 

Section III of the Part 70 Permit contains the general requirements for testing, record keeping and 

reporting; and requirements that affect the facility as a whole, such as open burning, air pollution episodes, 

particulate matter from construction and demolition activities, asbestos provisions, ozone depleting 

substance provisions, general conformity, and acid rain permit. This section includes the requirement to 

report excess emissions and deviations, to submit an annual emissions certification report and an annual 

compliance certification report, and results of sampling and testing. 

Section IV of the Part 70 Permit identifies the emissions standards, emissions limitations, 

operational limitations, and work practices applicable to each emissions unit located at the facility. For each 

standard, limitation, and work practice, the permit identifies the basis upon which the Permittee will 

demonstrate compliance. The basis will include testing, monitoring, record keeping, and reporting 

requirements. The demonstration may include one or more of these methods. 

Section V of the Part 70 Permit contains a list of insignificant activities. These activities emit very 

small quantities of regulated air pollutants and do not require a permit to construct or registration with the 

Department. For insignificant activities that are subject to a requirement under the Clean Air Act, the 

requirement is listed under the activity. 

Section VI of the Part 70 Permit contains State-only enforceable requirements. Upon issuance of 

the Part 70 Permit, the facility's current State Permit to Operate is superceded by the Part 70 Permit. 

Section VI identifies requirements that are not based on the Clean Air Act, but solely on Maryland air 

pollution regulations. These requirements generally relate to the prevention of nuisances and 

implementation of Maryland's Air Toxics Program. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 12 of 64 

REGULATORY REVIEW/TECHNICAL REVIEW/COMPLIANCE METHODOLOGY

Overview 

Portland Cement MACT- 40 CFR Part 63 Subpart LLL

The Lehigh Union Bridge plant is a major hazardous air pollutant (HAP) emission source. The Lehigh Union 

Bridge Plant is subject to the Portland Cement MACT standards found at 40 CFR Part 63, Subpart A and Subpart 

LLL. At the time the permit to construct was issued for the plant modernization, 40 CFR Part 63, Subpart LLL was 

not yet finalized. Therefore, the Department made a case-by-case MACT determination (112(g)) based on the 

proposed Portland Cement MACT rule. The Portland Cement MACT was promulgated effective June 14, 1999. 

The final Portland cement MACT supercedes the case by case MACT determination that was made in 1999; the 

Title V permit, therefore, incorporates the MACT requirements of Subpart LLL and not the case-by-case MACT 

requirements contained in Permit to Construct # 06-6-0256 issued on April 8, 1999. Since the new kiln was 

constructed at the same premises as the old plant, the new kiln is considered a New Brownfield Site, not a 

Greenfield site. The following sources at a Portland cement plant are subject to Subpart A and Subpart LLL: 

(1) All kilns and in-line kiln/raw mills at major sources; 

(2) All clinker coolers at major source; 

(3) All raw mills at major source 

(4) All finish mills at major source; 

(5) All raw material dryers at major sources. 

(6) All raw material, clinker or finished product storage bins at major sources; 

(7) All conveying system transfer points at major sources starting with the transfer point associated with the 

conveyor transferring material from the raw material storage to the raw mill; and 

(8) All bagging and bulk loading and unloading systems for a major source. 

The first affected source in the material handling sequence at a plant with on-site mineral processing is the first 

transfer point associated with the conveyor transferring material from the raw material storage bins immediately 

prior to the raw mill. Crushers and any other equipment which precede the raw material storage are not subject to 

this rule. The first affected source at the Lehigh plant is the transfer of material from the 100-ton bin (C02-006) to 

the belt conveyor (C02-060) that brings the material to the raw mill, controlled by dust collector C02-011. The first 

conveyor system transfer point subject to the MACT is the transfer point associated with the conveyor transferring 

material from the raw material storage to the raw mill. Conveyor system transfer points prior to this conveyor are 

not affected sources. The MACT does not apply to emissions from cement kiln dust storage facilities and coal 

conveyance equipment before the coal mill. Lehigh has on-site mineral processing (the quarry). Operations at the 

quarry are not subject to the MACT. 

On April 5, 2002, EPA issued a direct final rule amending the Portland Cement MACT with regard to applicability, 

compliance dates and monitoring, among other issues. 67 Fed. Reg. 16614 (Apr. 5, 2002). Portions of the rule, 

relating to the applicability to crushers and certain monitoring and performance testing requirements, were 

withdrawn due to the receipt of adverse comments in July 2002. 67 Fed. Reg. 44371 (July 2, 2002). After following 

formal rulemaking procedures, EPA ultimately adopted the withdrawn portions of the April 5, 2002 direct final rule 

and at the same time made a few changes to the rule. 67 Fed. Reg. 72580 (Dec. 6, 2002). The changes relate to 

enclosures for transfer points and the elimination of monitoring requirements for certain sources. 

The Portland Cement MACT limits particulate matter as a surrogate for HAP metal emissions as well as opacity and 

dioxin/furan (D/F) emissions. However, monitoring of particulate matter has been deferred, as per 40 CFR 

63.1350(k). 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 13 of 64 

Under the MACT, Lehigh was required to prepare for each affected source, a written operations and maintenance 

plan and include it in the Title V permit application. Lehigh’s Part 71 application includes an Operation and 

Maintenance Plan. 

New Portland cement plants (constructed or reconstructed after March 24, 1998) must demonstrate compliance with 

Subpart LLL. 

New Source Performance Standards (NSPS)

Under 40 CFR §63.1356(a), any affected source subject to the provisions of Subpart LLL of Part 63 is exempt from 

any otherwise applicable new source performance standards contained in Subpart F or Subpart OOO of Part 60. 

Certain raw material handling constructed or modified after August 31,1983, which are not subject to the PC 

MACT, is subject to Subparts OOO- Standards of Performance for Nonmetallic Mineral Processing Plant. The raw 

material storage equipment constructed or modified after August 17, 1971, which is not subject to the PC MACT, is 

subject to Subparts F - Standards of Performance for Portland Cement Plant. Under 40 CFR §63.1356(a), the coal 

feed system including the coal mill is subject to Subpart Y of Part 60 - Standards of Performance for Coal 

Preparation Plants. 

Operations at the quarry are not subject to NSPS requirements found at Subpart OOO (nonmetallic mineral 

processing plants) since these standards apply to facilities which commenced construction, reconstruction, or 

modification after August 31, 1983. The quarry operations date back to the 1950’s. 

In addition, the affected sources subject to the provisions of the Portland Cement MACT are exempt from any new 

source performance standard contained in 40 CFR Part 60, Subpart F. Also, the requirements of subpart Y of Part 

60, “Standards of Performance for Coal Preparation Plants”, do not apply to conveying system transfer points used 

to convey coal from the mill to the kiln that are associated with coal preparation. (See § 63.1356) 

Prevention of Significant Deterioration(PSD)/Non-Attainment New Source Review (NSR)Approvals

On April 8, 1999, the Department issued Permit to Construct #06-6-0256, PSD Approval #PSD-97-01, and NSR 

Approval #97-02 to Lehigh for the modernization and expansion of the Lehigh Union Bridge facility. The PSD 

Approval and the permit to construct were modified on June 7, 2000. Conditions from these permits are included in 

the Title V operating permit. 

The modernization and expansion project triggered PSD for carbon monoxide (CO) and triggered non-attainment 

major NSR for volatile organic compounds (VOC). Lehigh submitted a netting analysis for PM, PM10, SO2, and 

NOx that demonstrated that the net increase in emissions of these pollutants did not exceed the PSD/NSR significant 

level. In addition, the potential new emissions of lead and fluorides were less than the PSD significance level. 

Compliance Tables of Section IV of the Part 70 permit:

1A. Quarry- Fugitive Sources (Not subject to MACT Requirements)

Note: The quarry is located in Frederick County 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 14 of 64 

HR1- Quarry Haul Roads 

SP1- Limestone Storage Pile 

TLU1- Limestone truck loading/unloading 

TLU2- Truck loading/unloading 

Applicable Standards and limitations

(1) COMAR 26.11.06.03C(1) - Particulate matter Emissions. A person may not cause or permit 

emissions from an unconfined source without taking reasonable precautions to prevent particulate 

matter from becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and Construction. A person 

may not cause or permit any material to be handled, transported, or stored, or a building, its 

appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking 

reasonable precautions to prevent particulate matter from becoming airborne. 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

The Permittee shall comply with and update as needed the best management plan that describes the 

procedures and methods that will be used to take reasonable precautions. The management plan may 

be included in the written operation and maintenance plan required under the Portland Cement MACT. 

[COMAR 26.11.03.06C]

The Permittee shall perform an inspection at a minimum of one minute once a month or when weather 

conditions are favorable to cause particulate matter becoming airborne to verify that best management 

practices are being implemented. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

The Permittee shall maintain the best management plan and records of the dates and inspection results 

for at least five (5) years and make them available to the Department upon request. At a minimum, the 

most recent two years of data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

None 

Notes: The record keeping requirement for the most recent two years data to be retained on site and the 

remaining three years of data may be off-site comes from the requirements for the Portland 

Cement MACT. Although these emissions sources are not subject to MACT, in order to avoid 

confusion with an alternate record keeping requirement, the MACT strategy was applied. Lehigh 

Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration

The applicable emission standard for these fugitive sources requires the implementation of reasonable 

precautions to prevent particulate matter from becoming airborne. The Permittee is required to prepare a 

best management plan in which the reasonable precautions that the Permittee will implement are listed and 

described. To document that reasonable precautions are being implemented, the Permittee is required to 

perform a monthly inspection and maintain records of the results. Inspections are required at times when 

weather conditions are favorable for particulate to become airborne. The plan is required to be updated 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 15 of 64 

when it is determined that additional or different procedures are needed to prevent particulate matter from 

becoming airborne. 

1B. Quarry- Point Sources (Not subject to MACT Requirements)

Note: The quarry is located in Frederick County 

Baghouse Emission Unit

A01-012 A01-009- Gyratory Crusher 

A01-018- Belt Conveyor #1 

A01-025 A01-021- Surge Bin 

A02-008 A02-005- Belt Conveyor #2 

A02-006- Secondary Crusher 

A02-010- Belt Conveyor #3 

A02-017-Belt Conveyor #6 

A02-018- Belt Conveyor #5 

A02-019- Tertiary Crusher 

A02-021- Belt Conveyor #4 

A02-012 A02-011- Vibrating Screens and Transfer System 

A02-022- Vibrating Screens and Transfer System 

A02-023- Vibrating Screens and Transfer System 

A02-024- Raw Material Transfer 

A02-015 A02-011- Vibrating Screens and Transfer System 

 A02-022- Vibrating Screens and Transfer System 

A02-023- Vibrating Screens and Transfer System 

A02-025 A02-024- Raw Material Transfer 

B01-017- Raw Material Transfer 

Applicable Standards and Regulations

A. Visible Emissions 

COMAR 26.11.06.02C(1) - A person may not cause or permit the discharge of emissions from 

any installation or building, other than water in an uncombined form, which is greater than 20 

percent opacity. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(1)(b)(ii) - A person may not cause or permit particulate matter to be 

discharged from any installation in excess of 0.05 gr/SCFD (114.5 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 –The 

following equipment shall be equipped with a dust collector designed to reduce particulate 

matter emissions to 0.01 gr/SCFD (22.9 mg/dscm): 

(a) A01-021 – Surge Bin; 

(b) A02-024 & B01-017 - Raw Material Transfer; and 

(c) A02-011, A02-023, and A02-022 - Vibrating Screens and Transfer System. 

(3) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 - The 

following equipment shall be equipped with a dust collector designed to reduce particulate 

matter emissions to 0.015 gr/SCFD (34.3 mg/dscm): 

(a) A01-009- Gyratory Crusher; 

(b) A01-018- Belt Conveyor #1; 

(c) A02-005- Belt Conveyor #2; 

(d) A02-006- Secondary Crusher; 

(e) A02-010- Belt Conveyor #3; 

(f) A02-017-Belt Conveyor #6; 

(g) A02-018- Belt Conveyor #5; 

(h) A02-019- Tertiary Crusher; and 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 16 of 64 

(i) A02-021- Belt Conveyor #4. 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test must be conducted 

while the emission unit is in operation. If no visible emissions are observed in six consecutive 

monthly tests for the exhaust stack of any emission unit, the Permittee may decrease the frequency 

of testing from monthly to semi-annually for the exhaust stack of that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. If no visible emissions are observed 

during the semi-annual test for the exhaust stack of any emission unit, the Permittee may decrease 

the frequency of testing from semi-annually to annually for the exhaust stack of that emission unit. 

If visible emissions are observed during any annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis until no visible emissions are observed in 

six consecutive monthly tests. 

 If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the preventive maintenance plan or the 

best management plan. Within 24 hours at the end of the Method 22 test, the Permittee shall 

conduct a follow-up Method 22 test of each stack from which visible emissions were observed 

during the previous Method 22 test. If visible emissions are still observed, conduct a visual 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test and the duration of 

the Method 9 test shall be at least six minutes. 

[COMAR 26.11.03.06C] 

B1. The exhaust gas from each equipment shall vent through a dust collector designed to meet the 

particulate matter emissions before discharging into the atmosphere. 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update the preventative maintenance plan for each baghouse 

that describes the maintenance activity and time schedule for completing each activity. The 

preventative maintenance plan may be included in a written operation and maintenance plan 

required under the Portland Cement MACT. The Permittee shall perform maintenance activities 

within the timeframes established in the plan and shall maintain a log with records of the dates 

maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections for at least five (5) 

years and make them available to the Department upon request At a minimum, the most recent 

two years of data shall be retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[COMAR 26.11.03.06C] 

B. The log of inspection and maintenance records shall be kept for at least five (5) years and shall be 

made available to the Department upon request. At a minimum, the most recent two years of data 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 17 of 64 

shall be retained on site. The remaining three years of data may be retained off site. The files may 

be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirement

None 

Notes: The monitoring and record keeping requirements are based upon the Portland Cement MACT. 

Although these emissions sources are not subject to MACT, in order to avoid confusion with an 

alternate monitoring and record-keeping requirement, the MACT strategy was applied. Lehigh 

Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited from causing or allowing visible emissions in the exhaust of the 

baghouses that are used for controlling emissions of particulate matter from the emission units. To 

demonstrate compliance, the Permittee is required to perform visible emissions observations of the exhaust 

from each baghouse. The frequency of observations begins at once a month and reduces in frequency if no 

visible emissions are observed during the monthly observations. If visible emissions are observed during 

the less frequent observation period, then the observation requirement starts over again at once a month. 

This strategy mirrors the requirement for similar type emissions sources subject to the Portland cement 

MACT. The Department selected the MACT monitoring strategy to satisfy the requirement for periodic 

monitoring, COMAR 26.11.03.06C. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(1)(b)(ii). In addition, the emission units are subject to a more restrictive limit based on 

permit to construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate 

emission standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 

emissions from the modernization/expansion project, to below the PSD significance level, the Permittee 

agreed to vent the emissions units through baghouses designed to meet a specified emission rate. 

The Permittee provided information with the PSD application that the baghouses were designed to satisfy 

the emissions limitation. No stack testing was required. If properly maintained, the baghouses are likely to 

continue to achieve the emissions limitation. The Permittee is required implement a preventative 

maintenance plan to maintain the baghouses in a manner to achieve its design control efficiency. The 

Permittee is also required to maintain inspection and maintenance records for the baghouses to demonstrate 

that a preventative plan is being implemented. 

2A. Raw Material Handling- Fugitive Sources (Not subject to MACT Requirements)

B01-011- Enclosed Limestone Dome 

TU1- Iron and silica truck unloading 

SP4- Silica Storage Pile 

SP5- Iron Ore Storage Pile 

Applicable Standards and Regulations

(1) COMAR 26.11.06.03C(1) - Particulate matter Emissions. A person may not cause or permit 

emissions from an unconfined source without taking reasonable precautions to prevent particulate 

matter from becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and Construction. A person 

may not cause or permit any material to be handled, transported, or stored, or a building, its 

appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking 

reasonable precautions to prevent particulate matter from becoming airborne. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 18 of 64 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

The Permittee shall comply with and update as needed the best management plan that describes the 

procedures and methods that will be used to take reasonable precautions. The best management plan 

may be included in the written operation and maintenance plan required under the Portland Cement 

MACT. 

The Permittee shall perform an inspection at a minimum of one minute once a month or when weather 

conditions are favorable to create particulate matter becoming airborne to verify that best management 

practices are being implemented. 

Record Keeping Requirements

The Permittee shall maintain the best management plan and records of the dates and inspection results 

for at least five (5) years and make them available to the Department upon request. At a minimum, the 

most recent two years of data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche.

[COMAR 26.11.03.06C] 

Reporting Requirements

None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

The applicable emission standards for these fugitive sources require the implementation of reasonable 

precautions to prevent particulate matter from becoming airborne. The Permittee is required to prepare a 

best management plan in which the reasonable precautions that the Permittee will implement are listed and 

described. To document that reasonable precautions are being implemented, the Permittee is required to 

perform a monthly inspection and maintain records of the results. Inspections are required at times when 

weather conditions are favorable for particulate to become airborne. The plan is required to be updated 

when it is determined that additional or different procedures are needed to prevent particulate matter from 

becoming airborne. 

2B. Raw Material Handling- Fugitive Sources (Subject to MACT Requirements)

H04-001 – Gypsum Bin 409 

H04-003 – Limestone Tank 416 

H05-001 – Gypsum Bin 509 

H06-001 – Gypsum Bin 609 

H07-001 – Gypsum Bin 

H08-001 – Gypsum Bin 

Applicable Standards/Limits:

A. Visible Emissions 

40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system.
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 19 of 64 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03C(1) - Particulate Matter from Unconfined Sources - A person may not 

cause or permit emissions from an unconfined sources without taking reasonable precautions 

to prevent particulate matter from becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate Matter from Materials Handling and Construction. A 

person may not cause or permit any material to be handled, transported, or stored, or a 

building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished 

without taking reasonable precautions to prevent particulate matter from becoming airborne.

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of each emission unit in 

accordance with Method 22 of Appendix A to part 60. The test must be conducted while the 

emission unit is in operation. If no visible emissions are observed in six consecutive monthly tests 

for any emission unit, the Permittee may decrease the frequency of testing from monthly to semiannually for that emission unit. If visible emissions are observed during any semi-annual test, the 

Permittee must resume testing of that emission unit on a monthly basis and maintain that schedule 

until no visible emissions are observed in six consecutive monthly tests. If no visible emissions 

are observed during the semi-annual test for any emission unit, the Permittee may decrease the 

frequency of testing from semi-annually to annually for that emission unit. If visible emissions are 

observed during any annual test, the Permittee must resume testing of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed in six 

consecutive monthly tests. 

If visible emissions are observed during any Method 22 test, the Permittee shall initiate the 

corrective actions specified in the written operations and maintenance plan and conduct the 

follow-up Method 22 test until the problem is resolved. 

[40 CFR §63.1350(a)(4)(i)-(iii and(l)] 

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

Record Keeping Requirements

The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two 

years of data shall be retained on site. The remaining three years of data may be retained off site. The 

files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. 

[40 CFR §63.1355] 

Reporting Requirements

The Permittee shall submit a summary report semiannually which contains all failures to comply with 

any provision of the operation and maintenance plan developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004.

Discussion of compliance demonstration:
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 20 of 64 

The applicable emission standards for these fugitive sources require the implementation of reasonable 

precautions to prevent particulate matter from becoming airborne. The Permittee is required to implement

the reasonable precautions described in the written operations and maintenance plan. To document that 

reasonable precautions are being implemented, the Permittee is required to perform a monthly inspection 

and maintain records of the results. Inspections are required at times when weather conditions are 

favorable for particulate to become airborne. The plan is required to be updated when it is determined that 

additional or different procedures are needed to prevent particulate matter from becoming airborne. 

2C. Raw Material Handling - Point Sources (Not subject to MACT Requirements)

Baghouse Emission Unit

B02-008 B02-007- Belt Conveyor 

B02-011- Silica Bearing Material Bin 

B02-012- Iron Bearing Material Bin 

B02-017- Reversible Belt Conveyor 

C01-007 C01-002- Limestone Weighfeeder 

C01-004- Iron Weighfeeder 

C01-006- Silica Weighfeeder 

C01-011- Belt Conveyor 

B03-008 B03-004- Fly ash Blending System 

C01-019 C01-015- Fly ash Weigh bin 

C02-011 C02-001- Bucket elevator 

C02-011 C02-002- Belt Conveyor 

 C02-006- 100 T Bin 

 C02-014- 15 T Bin 

B04-016 TT3- Transfer Tower #3 

B04-011 TT3- Transfer Tower #3 

B04-016 B04-019 Limestone bin 

B02-019 TT4- Transfer Tower #4 

B01-018 TT8/9- Transfer Tower #8/9 

G02-041 TT8/9- Transfer Tower #8/9 

Applicable Standards and Regulations

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - Visible Emissions. In Areas III and IV a person may not cause 

or permit the discharge of emissions from any installation or building, other than water in an 

uncombined form, which is visible to human observers. 

(2) 40 CFR Part 60, Subpart F, §60.60(c) - Which limits the opacity of any gas from raw 

material storage to 10 percent. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit to be discharged in to the 

outdoor atmosphere from any other installation, particulate matter in excess of 0.03 gr/SCFD 

(68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 – Each 

equipment shall be equipped with a dust collector designed to reduce particulate matter 

emissions to 0.01 gr/SCFD (22.9 mg/dscm). 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 21 of 64 

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test must be conducted 

while the emission unit is in operation. If no visible emissions are observed in six consecutive 

monthly tests for the exhaust stack of any emission unit, the Permittee may decrease the frequency 

of testing from monthly to semi-annually for the exhaust stack of that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. If no visible emissions are observed 

during the semi-annual test for the exhaust stack of any emission unit, the Permittee may decrease 

the frequency of testing from semi-annually to annually for the exhaust stack of that emission unit. 

If visible emissions are observed during any annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis until no visible emissions are observed in 

six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the preventive maintenance plan or the 

best management plan. Within 24 hours at the end of the Method 22 test, the Permittee shall 

conduct a follow-up Method 22 test of each stack from which visible emissions were observed 

during the previous Method 22 test. If visible emissions are still observed, conduct a visual 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test and the duration of 

the Method 9 test shall be at least six minutes. 

 [COMAR 26.11.03.06C] 

B1. The exhaust gas from each emissions unit shall vent through a dust collector designed to meet the 

particulate matter emissions limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

B2. The Permittee shall comply with and update the preventative maintenance plan for each baghouse 

that describes the maintenance activity and time schedule for completing each activity. The 

Permittee shall perform maintenance activities within the timeframes established in the plan and 

shall maintain a log with records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections for at least five (5) 

years and make them available to the Department upon request. At a minimum, the most recent 

two years of data shall be retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[COMAR 26.11.03.06C] 

B. The log of inspection and maintenance records shall be kept for at least five (5) years and shall be 

made available to the Department upon request. At a minimum, the most recent two years of data 

shall be retained on site. The remaining three years of data may be retained off site. The files may 

be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

None

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 22 of 64 

For opacity, the Permittee is prohibited from causing or allowing visible emissions in the exhaust of the 

baghouses that are used for controlling emissions of particulate matter from the emission units. To 

demonstrate compliance, the Permittee is required to perform visible emissions observations of the exhaust 

from each baghouse. The frequency of observations begins at once a month and reduces in frequency if no 

visible emissions are observed during the monthly observations. If visible emissions are observed during 

the less frequent observation period, then the observation requirement starts over again at once a month. 

This strategy mirrors the requirement for similar type emissions sources subject to the Portland cement 

MACT. The Department selected the MACT monitoring strategy to satisfy the requirement for periodic 

monitoring, COMAR 26.11.03.06C. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(1)(b)(ii). In addition, the emission units are subject to a more restrictive limit based on 

permit to construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate 

emission standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 

emissions from the modernization/expansion project, to below the PSD significance level, the Permittee 

agreed to vent the emissions units through baghouses designed to meet a specified emission rate. 

The Permittee provided information with the PSD application that the baghouses were designed to satisfy 

the emissions limitation. No stack testing was required. If properly maintained, the baghouses are likely to 

continue to achieve the emissions limitation. The Permittee is required implement a preventative 

maintenance plan to maintain the baghouses in a manner to achieve its design control efficiency. The 

Permittee is also required to maintain inspection and maintenance records for the baghouses to demonstrate 

that a preventative plan is being implemented. 

2D. Raw Material Handling- Point Sources (Subject to MACT Requirements)

Baghouse Emission Unit

C01-007 C02-061- Belt Conveyor 

 C02-038- Rejects Belt Conveyor 

C02-011 C02-060- Reversible Belt Conveyor (to Raw Mill) 

C02-021 C02-017- Belt Conveyor (from 15 T Bin) 

 

Applicable Standards and Regulations

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - Visible Emissions. In Areas III and IV a person may not cause 

or permit the discharge of emissions from any installation or building, other than water in an 

uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system. 

B. Particulate Matter Emissions

(1) COMAR 26.11.06.03B(2) - Particulate matter Emissions. A person may not cause or permit 

to be discharged in to the outdoor atmosphere from any other installation, particulate matter in 

excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 – Each equipment 

shall be equipped with a dust collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm). 

Compliance Demonstration

Testing requirements

None 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 23 of 64 

Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

affected source in accordance with Method 22 of Appendix A to part 60. The test must be 

conducted while the affected source is in operation. If no visible emissions are observed in six 

consecutive monthly tests for the exhaust stack of any affected source, the Permittee may decrease 

the frequency of testing from monthly to semi-annually for the exhaust stack of that affected 

source. If visible emissions are observed during any semi-annual test, the Permittee shall resume 

testing of the exhaust stack of that affected source on a monthly basis and maintain that schedule 

until no visible emissions are observed in six consecutive monthly tests. If no visible emissions 

are observed during the semi-annual test for the exhaust stack of any affected source, the Permittee 

may decrease the frequency of testing from semi-annually to annually for the exhaust stack of that 

affected source. If visible emissions are observed during any annual test, the Permittee shall 

resume testing of the exhaust stack of that affected source on a monthly basis until no visible 

emissions are observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the written operations and maintenance 

plan. Within 24 hours at the end of the Method 22 test, the Permittee shall conduct a follow-up 

Method 22 test of each stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are still observed, conduct a visual opacity test in accordance 

with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test shall be conducted within 

one-hour of the end of the follow-up Method 22 test and the duration of the Method 9 test shall be 

at least six minutes. 

[40 CFR §63.1350(a)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources.

[40 CFR §63.1350(a) and (b)] 

B. The exhaust gases from each emissions unit shall vent a dust collector designed to meet the particulate 

matter emissions limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years 

of data shall be retained on site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance records for at least five (5) years and 

make it available to the Department upon request. At a minimum, the most recent two years of data shall 

be retained on site. The remaining three years of data may be retained off site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

A. The Permittee shall submit a summary report semiannually, which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 24 of 64 

B. None

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited by COMAR from causing or allowing visible emissions in the 

exhaust of the baghouses that are used for controlling emissions of particulate matter from the emission 

units. The Portland Cement MACT limits opacity to 10 percent. The MACT requires the Permittee to 

perform visible emissions observations of the exhaust from each baghouse. The frequency of observations 

begins at once a month and reduces in frequency if no visible emissions are observed during the monthly 

observations. If visible emissions are observed during the less frequent observation period, then the 

observation requirement starts over again at once a month. No additional monitoring is required for 

sources subject to MACT requirements therefore there is no periodic monitoring proposed for the 

emissions units. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(2). In addition, the emission units are subject to a more restrictive limit based on permit to 

construct #06-6-0256N dated April 8, and revised June 7,2000. The lower particulate emission standard 

was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 emissions from the 

modernization/expansion project, to below the PSD significance level, the Permittee agreed to vent the 

emissions units through baghouses designed to meet a specified emission rate. The Permittee provided 

information with the PSD application that the baghouses were designed to satisfy the emissions limitation. 

No stack testing was required. 

The Portland Cement MACT requires the Permittee to comply with a written operations and maintenance 

plan. The plan plans contains the procedures for proper operation and maintenance of the baghouses and 

emissions units in order to comply with the opacity limitation. By properly operating and maintaining the 

baghouses, the baghouses are likely to continue to achieve the designed control efficiency and therefore 

comply with the opacity and particulate matter emission limitation. 

3A. Coal Feed System- Fugitive Sources (Not subject to MACT Requirements)

F01-034/F01-037 – Belt Conveyor #11/14 

RU1 – Coal Rail Unloading 

SP2 – Coal Storage Pile 

SP3 – Coal Storage Pile 

TT1 – Transfer Tower #1 

TT2 – Transfer Tower #2 

TU2 – Truck Unloading 

Applicable Standards and Regulations

(1) COMAR 26.11.06.03C(1) - Particulate matter Emissions. A person may not cause or permit 

emissions from an unconfined source without taking reasonable precautions to prevent particulate 

matter from becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and Construction. A person 

may not cause or permit any material to be handled, transported, or stored, or a building, its 

appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking 

reasonable precautions to prevent particulate matter from becoming airborne. 

Compliance Demonstration

Testing Requirements

None 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 25 of 64 

Monitoring Requirements

The Permittee shall comply with and update as needed the best management plan that describes the 

procedures and methods that will be used to take reasonable precautions. The best management plan 

may be included in the written operation and maintenance plan required under the Portland Cement 

MACT. 

The Permittee shall perform an inspection at a minimum of one minute once a month or when weather 

conditions are favorable to create particulate matter becoming airborne to verify that best management 

practices are being implemented. 

Record Keeping Requirements

The Permittee shall maintain the best management plan and records of the dates and inspection results 

for at least five (5) years and make them available to the Department upon request. At a minimum, the 

most recent two years of data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche.

[COMAR 26.11.03.06C] 

Reporting Requirements

None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

The applicable emission standards for these fugitive sources require the implementation of reasonable 

precautions to prevent particulate matter from becoming airborne. The Permittee is required to prepare a 

best management plan in which the reasonable precautions that the Permittee will implement are listed and 

described. To document that reasonable precautions are being implemented, the Permittee is required to 

perform a monthly inspection and maintain records of the results. Inspections are required at times when 

weather conditions are favorable for particulate to become airborne. The plan is required to be updated 

when it is determined that additional or different procedures are needed to prevent particulate matter from 

becoming airborne. 

3B. Coal Feed System- Point Sources (Not subject to MACT Requirements)

Baghouse Emission Unit 

F02-033 F02-018 – Belt Conveyor 

F02-033 F02-019 – Belt Conveyor 

F02-030 F02-019 – Belt Conveyor 

F02-027 TT5- Transfer Tower #5 

 F02-006 – Reclaim Elevator 

F02-010 F02-020 – Belt Conveyor 

F03-058 F03-001- Belt Conveyor 

 F03-002- Coal Bin weighfeeder 

 F03-003- Coke Bin Weighfeeder 

G02-025 TT6- Transfer Tower #6 

 

Applicable Standards and Regulations

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2)- Visible Emissions. In Areas III and IV a person may not cause or 

permit the discharge of emissions from any installation or building, other than water in an 

uncombined form, which is visible to human observers. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 26 of 64 

(2) 40 CFR Part 60, Subpart Y, §60.252(c) - Which limits the opacity of any gas from coal 

processing and conveying equipment, coal storage system, or coal transfer and loading to 20 

percent. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit to be discharged in to the 

outdoor atmosphere from any other installation, particulate matter in excess of 0.03 gr/SCFD 

(68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 – Each 

equipment shall be equipped with a dust collector designed to reduce particulate matter 

emissions to 0.01 gr/SCFD (22.9 mg/dscm). 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test must be conducted 

while the emission unit is in operation. If no visible emissions are observed in six consecutive 

monthly tests for the exhaust stack of any emission unit, the Permittee may decrease the frequency 

of testing from monthly to semi-annually for the exhaust stack of that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. If no visible emissions are observed 

during the semi-annual test for the exhaust stack of any emission unit, the Permittee may decrease 

the frequency of testing from semi-annually to annually for the exhaust stack of that emission unit. 

If visible emissions are observed during any annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis until no visible emissions are observed in 

six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the preventive maintenance plan or the 

best management plan. Within 24 hours at the end of the Method 22 test, the Permittee shall 

conduct a follow-up Method 22 test of each stack from which visible emissions were observed 

during the previous Method 22 test. If visible emissions are still observed, conduct a visual 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test and the duration of 

the Method 9 test shall be at least six minutes. 

 [COMAR 26.11.03.06C] 

B1. The exhaust gas from each equipment shall vent through a dust collector designed to meet 

particulate matter emissions before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

B2. The Permittee shall comply with and update the preventative maintenance plan for each baghouse 

that describes the maintenance activity and time schedule for completing each activity. The 

Permittee shall perform maintenance activities within the timeframes established in the plan and 

shall maintain a log with records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections for at least five (5) 

years and make them available to the Department upon request. At a minimum, the most recent 

two years of data shall be retained on site. The remaining three years of data may be retained off 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 27 of 64 

site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[COMAR 26.11.03.06C] 

B. The log of inspection and maintenance records shall be kept for at least five (5) years and shall be 

made available to the Department upon request. At a minimum, the most recent two years of data 

shall be retained on site. The remaining three years of data may be retained off site. The files may 

be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

None

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited from causing or allowing visible emissions in the exhaust of the 

baghouses that are used for controlling emissions of particulate matter from the emission units. To 

demonstrate compliance, the Permittee is required to perform visible emissions observations of the exhaust 

from each baghouse. The frequency of observations begins at once a month and reduces in frequency if no 

visible emissions are observed during the monthly observations. If visible emissions are observed during 

the less frequent observation period, then the observation requirement starts over again at once a month. 

This strategy mirrors the requirement for similar type emissions sources subject to the Portland cement 

MACT. The Department selected the MACT monitoring strategy to satisfy the requirement for periodic 

monitoring, COMAR 26.11.03.06C. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(1)(b)(ii). In addition, the emission units are subject to a more restrictive limit based on 

permit to construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate 

emission standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 

emissions from the modernization/expansion project, to below the PSD significance level, the Permittee 

agreed to vent the emissions units through baghouses designed to meet a specified emission rate. 

The Permittee provided information with the PSD application that the baghouses were designed to satisfy 

the emissions limitation. No stack testing was required. If properly maintained, the baghouses are likely to 

continue to achieve the emissions limitation. The Permittee is required implement a preventative 

maintenance plan to maintain the baghouses in a manner to achieve its design control efficiency. The 

Permittee is also required to maintain inspection and maintenance records for the baghouses to demonstrate 

that a preventative plan is being implemented. 

4. Raw Meal Feed Systems (Subject to MACT Requirements)

Baghouse Emission Unit

C03-001 C03-034, C03-035, C03-040, &C03-042 - Airslide 

C03-047 C03-045- Airslide 

C03-050 C03-008, C03-045, C03-054, & C04-066 - Airslide 

C03-030 C03-010 & C03-013 - Airslide and C03-046- Bucket Elevator 

D01-037 C03-046- Bucket Elevator 

 C03-017-Airslide 

 D01-001- Blending Silo 

 D01-003 & D01-002 - Recirculation Airslide 

C03-030 C03-010 & C03-013- Airslide 

D01-034 D01-020- 185 MT Feed Bin 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 28 of 64 

 D02-004 & D02-017- Airslide 

 D02-006 & D02-019- Flow Meter 

D01-040 D01-023, D01-026, D02-007, &D02-020 - Airslide 

D02-041 D02-010, D02-023, & D02-049 - Airslide 

D02-041 D02-025- Bucket Elevator and D02-026- Bucket Elevator 

D02-027 D02-025- Bucket Elevator and D02-026- Bucket Elevator 

D02-027 D02-033, D02-045, & D02-047- Airslide 

Applicable Standards and Regulations

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - In Areas III and IV a person may not cause or permit the 

discharge of emissions from any installation or building, other than water in an uncombined 

form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system. 

B. Particulate matter Emissions

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit to be discharged in to the 

outdoor atmosphere from any other installation, particulate matter in excess of 0.03 gr/SCFD 

(68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 – Each 

equipment shall be equipped with a dust collector designed to reduce particulate matter 

emissions to 0.01 gr/SCFD (22.9 mg/dscm). 

Compliance Demonstration

Testing Requirements

A and B. None 

Monitoring Requirements

A. Visible Emissions 

(1) The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack 

of each affected source in accordance with Method 22 of Appendix A to part 60. The test 

must be conducted while the affected source is in operation. If no visible emissions are 

observed in six consecutive monthly tests for the exhaust stack of any affected source, the 

Permittee may decrease the frequency of testing from monthly to semi-annually for the 

exhaust stack of that affected source. If visible emissions are observed during any semiannual test, the Permittee shall resume testing of the exhaust stack of that affected source on 

a monthly basis and maintain that schedule until no visible emissions are observed in six 

consecutive monthly tests. If no visible emissions are observed during the semi-annual test 

for the exhaust stack of any affected source, the Permittee may decrease the frequency of 

testing from semi-annually to annually for the exhaust stack of that affected source. If 

visible emissions are observed during any annual test, the Permittee shall resume testing of 

the exhaust stack of that affected source on a monthly basis until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee 

shall initiate, within one hour, the corrective actions specified in the written operations and 

maintenance plan. Within 24 hours at the end of the Method 22 test, the Permittee shall 

conduct a follow-up Method 22 test of each stack from which visible emissions were 

observed during the previous Method 22 test. If visible emissions are still observed, 

conduct a visual opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 

60. The Method 9 test shall be conducted within one-hour of the end of the follow-up 

Method 22 test and the duration of the Method 9 test shall be at least six minutes. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 29 of 64 

 

 [40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

(2) The Permittee shall comply with and update as needed the written operations and 

maintenance plan which includes the following information: 

(a) Procedures for proper operation and maintenance of the affected source and air 

pollution control devices in order to meet the emission limits and operating limits of 

§§63.1348; and 

 (b) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)] 

 

B. Particulate matter Emissions 

The exhaust gas from each equipment shall vent a dust collector designed to meet the particulate 

matter emissions limit of 0.01 gr/SCFD (22.9 mg/dscm) before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years 

of data shall be retained on site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance records for at least five (5) 

years and make it available to the Department upon request. At a minimum, the most recent two 

years of data shall be retained on site. The remaining three years of data may be retained off site. 

The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)]

B. None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited by COMAR from causing or allowing visible emissions in the 

exhaust of the baghouses that are used for controlling emissions of particulate matter from the emission 

units. The Portland Cement MACT limits opacity to 10 percent. The MACT requires the Permittee to 

perform visible emissions observations of the exhaust from each baghouse. The frequency of observations 

begins at once a month and reduces in frequency if no visible emissions are observed during the monthly 

observations. If visible emissions are observed during the less frequent observation period, then the 

observation requirement starts over again at once a month. No additional monitoring is required for 

sources subject to MACT requirements therefore there is no periodic monitoring proposed for the 

emissions units. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 30 of 64 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(2). In addition, the emission units are subject to a more restrictive limit based on permit to 

construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate emission 

standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 emissions 

from the modernization/expansion project, to below the PSD significance level, the Permittee agreed to 

vent the emissions units through baghouses designed to meet a specified emission rate. The Permittee 

provided information with the PSD application that the baghouses were designed to satisfy the emissions 

limitation. No stack testing was required. 

The Portland Cement MACT requires the Permittee to comply with a written operations and maintenance 

plan. The plan plans contains the procedures for proper operation and maintenance of the baghouses and 

emissions units in order to comply with the opacity limitation. By properly operating and maintaining the 

baghouses, the baghouses are likely to continue to achieve the designed control efficiency 

and therefore comply with the opacity and particulate matter emission limitation. 

5. Kiln, Raw and Coal Mills (Subject to MACT Requirements)

Baghouse Emission Unit 

C04-014 E01-001/E02-001- Preheater-Precalciner/Kiln System 

C02-025- Raw Mill 

F03-028 F03-016- Coal Mill 

F03-032 F03-016- Coal Mill 

F03-036 F03-016- Coal Mill 

F03-040 F03-016- Coal Mill 

F03-044 F03-016- Coal Mill 

F03-048 F03-016- Coal Mill 

The pyroprocessing system consists of an in-line raw mill and 5-stage preheater kiln system. The kiln line 

consists of an in-line raw mill, preheater-precalciner, kiln, clinker cooler, baghouse, stack and associated 

duct work. Gases from the Preheater-Precalciner/Kiln system are split between the coal mill system and 

the raw mill system for drying. Gases from the kiln not needed for the mill processes, as well as the 

existing raw mill gases, are vented through the main baghouse and stack. Gases from the coal mill are 

vented directly to the main stack. Although the coal mill feed system, including the coal mill, is not subject 

to MACT requirements, the coal mills are addressed here with Preheater-Precalciner/Kiln system because 

they utilize the exhaust gases from the Preheater-Precalciner/Kiln system for coal drying. 

Applicable Regulations and Standards

A. Visible Emissions 

(1) COMAR 26.11.06.02C (2) - A person may not cause or permit the discharge of emissions 

from any installation or building, other than water in an uncombined form, which is visible to 

human observers. 

(2) 40 CFR §63.1343(b)(2) which limits opacity from the kiln and raw mill to 20% or less. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - Particulate Matter. A person may not cause or permit particulate 

matter to be discharged from any installation in excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000 which 

limits particulate matter emissions from the main exhaust stack to 0.0158 gr/scfd (36.2 

mg/dscm). 

(3) 40 CFR §63.1343(b)(1) which limits particulate matter emissions from the kiln and raw mill 

to 0.15 kg per MG (0.3 lb per ton) of feed (dry basis) . 

C. Dioxins/Furans (D/F) 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 31 of 64 

40 CFR §63.1343(b)(3) which prohibits D/F in excess of 

(1) 0.2 ng per dscm (8.7 X 10 –11 gr per dscf)(TEQ) corrected to seven percent oxygen; or 

(2) 0.4 ng per dscm (1.7 x 10-10 gr dscf)(TEQ) corrected to seven percent oxygen, when the 

temperature at the inlet to the particulate matter air pollution control device is 204°C (400° F) 

or less. 

D. NOx Emissions 

(1) COMAR 26.11.09.08H(2)(b) which limits NOx emissions to 1,800 pounds per hour on a 30-

day rolling average.

(2) Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000 which 

states that NOx emissions from the entire premises shall not exceed 4,871 tons for any 12-

month period, rolling monthly. 

(3) COMAR 26.11.29.15C(1) which requires a person who owns or operates a cement 

manufacturing facility to either meet the applicable emission standards in §C(2) of this 

regulation or implement one of the following control measures: 

(a) Install low NOx burners on each kiln; or 

(b) Modify each kiln to implement mid-kiln firing 

Note: The kiln has low a NOx burner installed. Compliance with the facility’s NOx emissions 

limit will be determined according to the NOx emissions collected on the main kiln stack. 

E. SOx Emissions 

(1) Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000 which 

states that SO2 emissions from the entire premises shall not exceed 1,041 tons for any 12-

month period, rolling monthly.

(2) COMAR 26.11.06.05C(1) which limits the sulfur dioxide concentration in the exhaust gases 

not to exceed 500 parts per million by volume corrected to 7 percent oxygen. 

(3) COMAR 26.11.06.05C(2) which limits the content of sulfuric acid, sulfur trioxide, or any 

combination not to exceed 35 milligrams reported as sulfuric acid per cubic meter of gas 

corrected to 7 percent oxygen. 

Note: Compliance with the facility’s SOx emissions limit will be determined according to the 

SOx emissions collected from the main kiln stack. 

F. CO Emissions 

Prevention of Significant Deterioration (PSD) Approval #PSD-97-01R dated April 8, 1999 

and revised June 7, 2000 which states that the premises-wide carbon monoxide (C0) emissions 

from the Pyroprocessing Portland cement plant and the existing Portland cement plant shall not 

exceed 3,328 tons for any 12-month period, rolling monthly. Note: Compliance with the facility’s CO emissions limit will be determined according to the CO 

emissions collected from the main kiln stack. 

G. VOC Emissions 

New Source Review Approval #NSR-97-02 issued April 8, 1999 which states that premiseswide emissions shall not exceed 165 tons of VOC for any 12-month period, rolling monthly. In 

determining compliance with VOC emission limits, VOC emissions shall be determined by 

calculating the numerical difference between the measured values of total hydrocarbon (THC) 

emissions and non-VOC emissions (i.e., methane and ethane) measured during the most recent 

performance test. 

Note: Compliance with the facility’s VOC emissions limit will be determined according to the 

VOC emissions collected from the main kiln stack. 

H. Lead Emissions

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000 which states that 

the emissions from the entire premises, including the existing Portland cement plant and the 
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Pyroprocessing Portland cement plant, shall not exceed 0.6 tons of lead for any 12-month period, 

rolling monthly. 

Note: The majority of facility’s lead emissions are exhausted through the main kiln stack. (For the 

compliance demonstration see the discussion of compliance on page 42 of this Fact Sheet.) 

I. Fluoride Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000 which states that 

the emissions from the entire premises, including the existing Portland cement plant and the 

Pyroprocessing Portland cement plant, shall not exceed 3.0 tons of fluoride for any 12-month 

period, rolling monthly. 

Note: The majority of facility’s fluoride emissions are exhausted through the main kiln stack. (For 

the compliance demonstration see the discussion of compliance on page 42 of this Fact 

Sheet.) 

Compliance Demonstration

Testing Requirements

A, D thru I. None 

B. The Permittee shall conduct a particular matter emissions test at the interval stipulated in Subpart LLL 

(once every 5 years) using Method 5 of 40 CFR Part 60, Appendix A. Each performance test shall consist 

of three separate runs under the conditions that exist when the affected source is operating under 

representative performance conditions in accordance with 40 CFR Part 63, Subpart LLL. Each run shall be 

conducted for at least one hour, and the minimum sample volume shall be 0.85 dscm (30dscf). The average 

of the three runs shall be used to determine compliance. 

[40 CFR §63.1349(b)(1) and (c)] 

C. The Permittee shall conduct a dioxins/furans emission test at the interval stipulated in Subpart 

LLL (once every 2 1/2 years) using Method 23 of 40 CFR Part 60, Appendix A. 

(1) Each performance test shall consist of three separate runs; each run shall be conducted under 

the conditions that exist when the affected source is operating under representative 

performance conditions in accordance with 40 CFR Part 63, Subpart LLL. The duration of 

each run shall be at least three hours and the sample volume for each run shall be at least 2.5 

dscm (90 dscf). The concentration shall be determined for each run and the arithmetic average 

of the concentrations measured for the three runs shall be calculated and used to determine 

compliance. 

(2) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD must be continuously 

recorded during the period of the Method 23 test, and the continuous temperature record(s) 

must be included in the performance test report. 

(3) One-minute average temperatures must be calculated for each minute of each run of the test. 

(4) The run average temperature must be calculated for each run, and the average of the run 

average temperatures must be determined and included in the performance test report and will 

determine the applicable temperature limit in accordance with §63.1344(b). 

[40 CFR §63.1349(b)(3) and (d)]

Monitoring Requirements

A1. The Permittee shall install, calibrate, maintain, and continuously operate a continuous opacity 

monitor (COM) located at the outlet of the PM control device to continuously monitor the opacity. 

The COM shall be installed, maintained, calibrated, and operated as required by 40 CFR Part 63, 

Subpart A (general provision) and 40 CFR Part 60, Appendix B, Performance Specification 1.

 [40 CFR §63.1350 (c)(1)] and [COMAR 26.11.01.11B(2)(d)]

A2. The COM shall automatically reduce all data to 6 minute block average calculated from 36 or more 

equally spaced data points. 

[COMAR 26.11.01.11A(3) and .10G(2)(a)]
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A, B, and C. 

The Permittee shall comply with and update the written operations and maintenance plan, which 

includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §63.1344; and 

(2) Procedures to be used to during an inspection of the components of the combustion system of 

each kiln and each in-line kiln located at the facility at least once per year. 

[40 CFR §63.1350(a) and (b)] 

B. The exhaust gas from emissions unit shall vent through a dust collector designed to meet the particulate 

matter emissions limit before discharging into the atmosphere: 

[COMAR 26.11.03.06C] 

C1. The Permittee shall conduct an inspection of the components of the combustion system of each kiln 

or in-line kiln raw mill at least once a year. 

[40 CFR §63.1350(i)] 

C2. The Permittee shall calibrate, maintain, and continuously operate a continuous monitor to record 

the temperature of the exhaust gases from the kiln and the in-line kiln/raw mill, if applicable, at 

the inlet to or upstream of the PM control devices. 

(1) The recorder response range must include zero and 1.5 times either of the average temperature 

established according to the requirements in §63.1349(b)(3)(iv). 

(2) The reference method must be a National Institute of Standards and Technology calibrated 

reference thermocouple-potentiometer system or alternate reference, subject to approval by 

the Administrator. 

(3) The three-hour rolling average temperature shall be calculated as the average of 180 

successive one-minute average temperatures. 

(4) The period of time when one-minute averages are not available shall be ignored when 

calculating three-hour rolling averages. When one-minute averages become available, the 

first one-minute average is added to the previous 179 values to calculate the three-hour rolling 

average. 

(5) When the operating status of the raw mill of the in-line kiln/raw mill is changed from off to 

on, or from on to off the calculation of the three-hour rolling average temperature must begin 

anew, without considering previous recordings. 

(6) The calibration of all thermocouples and other temperature sensors shall be verified at least 

once every three months. 

[40 CFR §63.1350(f)] 

D. NOx Emissions 

The Permittee shall use a continuous emissions monitoring system, (CEM) to monitor NOx emissions 

from the main exhaust stack. The Permittee shall install, operate, maintain, and calibrate the CEM in 

accordance with the Performance Specifications under 40 CFR Part 60, Appendix B and the Quality 

Assurance Procedures under 40 CFR Part 60, Appendix F. 

[COMAR 26.11.09.08H(1) and Permit to Construct #06-6-0256 issued April 8, 1999 and revised 

June 7, 2000]

E. Sulfur Dioxide Emissions 

The Permittee shall use a continuous emissions monitoring system, (CEM) to monitor SO2 emissions 

from the main exhaust stack. The Permittee shall install, operate, maintain, and calibrate the CEM in 

accordance with the Performance Specifications under 40 CFR Part 60, Appendix B and the Quality 

Assurance Procedures under 40 CFR Part 60, Appendix F. 

[Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000] and [COMAR 

26.11.01.11C] 
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F. Carbon Monoxide Emissions 

The Permittee shall use a CEM to monitor CO emissions from the main exhaust stack. The Permittee 

shall install, operate, maintain, and calibrate the CEM in accordance with the Performance 

Specifications under 40 CFR Part 60, Appendix B and the Quality Assurance Procedures under 40 

CFR Part 60, Appendix F. 

[Prevention of Significant Deterioration (PSD) Approval #PSD-97-01 issued April 8, 1999 and 

revised June 7, 2000] and [COMAR 26.11.01.11C] 

G. VOC Emissions 

The Permittee shall use continuous emission monitoring system (CEM) to monitor total hydrocarbon 

(THC) emissions from the main exhaust stack. The Permittee shall install, operate, maintain, and 

calibrate the CEM in accordance with the Performance Specifications 8A of Appendix B to Part 60 and 

comply with all of the requirements from CEM found in the general provisions, subpart A of this part. 

[New Source Review Approval #NSR-97-02 issued April 8, 1999] and [COMAR 26.11.01.11C]

D thru G. 

For each CEM used to monitor a gas concentration, the Permittee shall equip the CEM to record not 

less than four equally spaced data points per hour and to automatically reduce data in terms of 

averaging times consistent with applicable emission standard. 

[COMAR 26.11.01.11D(3)] 

H and I. None 

Record Keeping Requirements 

A, B, and C. 

The Permittee shall maintain all records collected from both testing and monitoring requirements for at least 

five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. 

At a minimum, the most recent two years of data shall be retained on site; the remaining three years of data may 

be retained offsite. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic 

tape, or on microfiche. 

[40 CFR §63.1355] 

D and E. 

The Permittee shall maintain all records collected from both testing and monitoring requirements for at 

least five years following the date of each occurrence, measurement, maintenance, corrective action, 

report, or record. At a minimum, the most recent two years of data shall be retained on site. The 

remaining three years of data may be retained off site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

F and G. 

The following records with supporting documentation shall be maintained for at least 5 years and made 

available to the Department upon request: 

(1) Emissions for each calendar month and each rolling 12-month period; 

(2) Monthly usage of each raw material and each type of fuel used in the pyroprocessing plant; 

(3) All required stack emission test reports; 

(4) All processed CEM emission monitoring data; 

(5) All CEM certification and calibration results; and 

(6) Records of any repairs made to equipment affecting CO or THC emissions and to CEM for 

CO or THC. 
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At a minimum, the most recent two years of data shall be retained on site. The remaining three years 

of data may be retained off site. The files may be maintained on microfilm, on a computer, on floppy 

disks, on magnetic tape, or on microfiche. 

[New Source Review Approval #NSR-97-02 issued April 8, 1999 and Prevention of Significant 

Deterioration (PSD) Approval #PSD-97-01 issued April 8, 1999 and revised June 7, 2000 ] 

H and I. None 

Reporting Requirements 

A. If the total continuous monitoring system downtime for any CEM or any continuous monitoring 

system (CMS) for the reporting period is ten percent or greater of the total operating time for the 

reporting period, the Permittee shall submit an excess emissions and continuous monitoring 

system performance report along with the summary report. 

[40 CFR §63.1354(b)(10)]

A and C. 

The Company shall submit to the Department semiannually a Summary Report - Gaseous and 

Opacity Excess Emissions and Continuous Monitoring System (CMS) Performance on January 

31st and July 31st of each year. The Summary Report shall include the following items: 

(1) Company name and address; 

(2) Identification of the hazardous pollutant; 

(3) A brief description of the process; 

(4) The emissions limit; 

(5) Name, title and signature of responsible party; 

(6) Date of report; 

(7) All exceedances of the three hour average inlet temperature limit to the Particulate matter 

control device; 

(8) All failures to calibrate thermocouples; 

(9) The results of any burner inspections; 

(10) All failures to comply with the operations and maintenance plan; 

(11) The date of the latest CMS certification or audit; 

(12) The total operating time of the affected source during the reporting period; and 

(13) A CMS performance summary, including: 

(a) the total CMS downtime during the operating period (in minutes); 

(b) the total CMS downtime expressed as a percent of the total operating time; and 

(c) a breakdown of total CMS downtime into periods due to: 

i. Monitoring equipment malfunctions; 

ii. Non monitoring equipment malfunctions; 

iii. Quality assurance/quality control calibrations 

iv. Other known causes; and 

v. Other unknown causes. 

[40 CFR §63.1354b(9) and §63.10(e)(3)(vi)] 

A, D thru G. 

The Permittee shall submit a quarterly summary report to the Department not later than 30 days 

following each calendar quarter. The report shall be in a format approved by the Department, 

and shall include the following: 

(1) The cause, time periods, and magnitude of all emissions which exceed the applicable 

emission standards; 

(2) The source downtime including the time and date of the beginning and end of each downtime 

period and whether the source downtime was planned or unplanned; 

(3) The time periods and cause of all CEM downtime including records of any repairs, 

adjustments, or maintenance that may affect the validity of emission data; 
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(4) Quarterly totals of excess emissions, installation downtime, and CEM downtime during the 

calendar quarter; 

(5) Quarterly quality assurance activities; 

(6) Daily calibration activities that include reference values, actual values, absolute or percent of 

span differences, and drift status; and 

(7) Other information required by the Department that is determined to be necessary to evaluate 

the data, to ensure that compliance is achieved, or to determine the applicability of this 

regulation. 

[COMAR 26.11.01.11A(3) and COMAR26.11.01.10G(2)(d)]

B and C. 

(1) The Permittee shall submit the results of performance tests before the close of business on 

the 60th day following the completion of the performance test. 

[40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] 

(2) At least 30 days prior to each stack emissions testing, the Permittee shall submit to the 

Department a stack test protocol for review and approval. 

[Part D(7) of Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000]

D. 

The Permittee shall submit emissions data to the Department for each control period by 

November 30 beginning with the 2002 control period. 

[COMAR 26.11.29.15B(1)(c)] 

D and E. 

The Permittee shall submit to the Department, a report no later than 30 days after the end of each 

calendar quarter, which shall include a summary of the following information: 

(1) Emissions for each calendar month and each rolling 12-month period; 

(2) All required stack emission test reports; 

(3) All processed CEM emission monitoring data; 

(4) All CEM certification and calibration results; and 

(5) Records of any repairs made to equipment affecting NOx or SO2 emissions and to CEM for 

NOx or SO2. 

[COMAR 26.11.03.06C]

F and G. 

The Permittee shall submit to the Department, a report no later than 30 days after the end of each 

calendar quarter, which shall include a summary of the following information: 

(1) Emissions for each calendar month and each rolling 12-month period; 

(2) All required stack emission test reports; 

(3) All processed CEM emission monitoring data; 

(4) All CEM certification and calibration results; and 

(5) Records of any repairs made to equipment affecting CO or THC emissions and to CEM for 

CO or THC. 

[New Source Review Approval #NSR-97-02 issued April 8, 1999 and Prevention of Significant 

Deterioration (PSD) Approval #PSD-97-01 issued April 8, 1999 and revised June 7, 2000 ] 

H and I. None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004.

Background information:

Lehigh conducted the compliance testing for particulate matter from the Main Kiln exhaust stack on 

September 10 through September 13, 2002. The testing with the Raw Mill on indicated a particulate matter 
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concentration of 0.00029 grains/dscf and 0.0014 lb/ton dry feed. The testing with the Raw Mill off 

indicated a particulate matter concentration of 0.00057 grains/dscf and 0.0027 lb/ton dry feed. These tests 

have demonstrated that the emissions of the main kiln stack meet the emission limits of 0.0158 gr/scfd and 

0.3 lb/ton of dry feed. 

Notes: (1) MACT requirements for PM testing, once every 5 years, will supersede the annual emission 

test required under Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 

2000. 

(2) MACT testing report requirements for PM, “on the 60th day following the completion of the 

performance test”, will supersede the “45 days” requirement under Permit to Construct #06-6-

0256N dated April 8, 1999 and revised June 7, 2000. 

The latest dioxin/furan testing was conducted on November 20 and 21, 2003. The testing with the Raw 

Mill on indicated a dioxin/furan concentration of 0.0013 ng per dscm corrected to seven percent oxygen at 

an average temperature of 185°C (365° F). The testing with the Raw Mill off indicated a dioxin/furan 

concentration of 0.0169 ng per dscm corrected to seven percent oxygen at an average temperature of 

124.4°C (224° F). 

Lehigh also conducted the tests for Lead emissions from the main stack on February 11, 2004, which indicated that a 

Lead emissions rate of 0.02 pounds per hour or 0.07 tons per year. Since the Lead emission is well below the limit 

of 0.6 tons for each 12-month period rolling monthly, the Department has decided not to require Lehigh to repeat 

Lead emissions test. 

The use of several alternative kiln raw materials, fuels, and additives has been approved by the Department under 

Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000, which is federally enforceable. 

Since the use of the allowable alternative material including scrap tires would not alter the emissions limits regulated 

under this Section, the condition to use alternative material is restated in the State-only Section, which contains 

some State-only provisions. 

6. Clinker Cooler and Main Pan Conveyor (Subject to MACT Requirements)

E04-016 E03-001 - Clinker Cooler 

E04-016 G01-001 - Main Pan Conveyor 

The clinker cooler is used to cool the kiln product and exhaust from the clinker cooler is passed through the clinker 

cooler baghouse then to the cooler exhaust stack. 

Applicable Regulations and Standards

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the discharge of emissions 

from any installation or building, other than water in an uncombined form, which is visible to 

human observers. 

(2) 40 CFR §63.1345a(2) which limits opacity from the clinker cooler to 10 percent or less. 

B. Particulate matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit particulate matter to be 

discharged from any installation in excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 which limits 

particulate matter from the clinker cooler exhaust stack to 0.0129 gr/scfd (29.5 mg/dscm). 

(3) 40 CFR §63.1345a(1) which limits particulate matter from the clinker cooler to 0.050 kg per Mg (0.10 

lb per ton) of feed (dry basis) to the kiln. 
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Compliance Demonstration

Testing Requirements

A. None 

B. The Permittee shall conduct a particulate matter emissions test at the interval stipulated in Subpart 

LLL using Method 5 of 40 CFR Part 60, Appendix A. Each performance test shall consist of three 

separate runs under the conditions that exist when the affected source is operating under 

representative performance conditions in accordance with 40 CFR Part 63, Subpart LLL. Each run 

shall be conducted for at least one hour, and the minimum sample volume shall be 0.85 dscm (30 

dscf). The average of the three runs shall be used to determine compliance.

[40 CFR §63.1349(b) and (c)] 

 

Monitoring Requirements

A1. The Permittee shall install, calibrate, maintain, and continuously operate a continuous opacity 

monitor (COM) located at the outlet of the PM control device to continuously monitor the opacity. 

The COM shall be installed, maintained, calibrated, and operated as required by 40 CFR Part 63, 

Subpart A (general provision) and 40 CFR Part 60, Appendix B, Performance Specification 1. 

[40 CFR §63.1350(d)(1)] 

A2. The COM shall automatically reduce all data to 6-minute block average calculated from 36 or more equally 

spaced data points. 

[COMAR 26.11.01.10G(2)(a)]

B. The exhaust gases from E-03-001-Clinker Cooler and G01-001- Main Pan Conveyor shall vent through a 

dust collector designed to meet the particulate matter emissions limit before discharging into the 

atmosphere.

[COMAR 26.11.03.06C] 

A and B. 

The Permittee shall comply with and update as needed the written operations and maintenance plan, 

which includes the procedures for proper operation and maintenance of the affected source and air 

pollution control devices in order to meet the emission limits and operating limits of §63.1345. 

[40 CFR §63.1350(a) and (b)] 

Record Keeping Requirements

A and B. 

The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years of 

data shall be retained on site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or no microfiche. 

[40 CFR §63.1355]

Reporting Requirements

A1. If the total continuous monitoring system downtime for any CEM or any continuous monitoring system 

(CMS) for the reporting period is ten percent or greater of the total operating time of the reporting period, 

the Permittee shall submit an excess emissions and continuous monitoring system performance report along 

with the summary report. 

[40 CFR §63.1354(b)(10)] 

A2. The Permittee shall submit a quarterly summary report to the Department not later than 30 days 

following each calendar quarter. The report shall be in a format approved by the Department, and 

shall include the following: 
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(1) The cause, time periods, and magnitude of all emissions which exceed the applicable emission 

standards; 

(2) The source downtime including the time and date of the beginning and end of each downtime 

period and whether the source downtime was planned or unplanned; 

(3) The time periods and cause of all CEM downtime including records of any repairs, 

adjustments, or maintenance that may affect the validity of emission data; 

(4) Quarterly totals of excess emissions, installation downtime, and CEM downtime during the 

calendar quarter; 

(5) Quarterly quality assurance activities; 

(6) Daily calibration activities that include reference values, actual values, absolute or percent of 

span differences, and drift status; and 

(7) Other information required by the Department that is determined to be necessary to evaluate 

the data, to ensure that compliance is achieved, or to determine the applicability of this 

regulation. 

[COMAR 26.11.01.11A(3) and COMAR26.11.01.10G(2)(d)] 

B1. The Permittee shall submit the results of performance tests before the close of business on the 60th

day following the completion of the performance test. 

[40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] 

B2. At least 30 days prior to each stack emissions testing, the Permittee shall submit to the Department 

a stack test protocol for review and approval. 

[Part D(7) of Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000]

A and B. 

The Permittee shall submit a summary report semiannually, which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004.

Background information:

Lehigh conducted stack testing on the dust collector associated with the clinker cooler on August 20, 2002. The 

particulate matter emissions during the stack testing were 0.00278 gr/dscf and 0.0091 lb/ton dry feed, which 

demonstrated compliance with the emissions limits of 0.0129 gr/dscf and 0.1 lb/ton dry feed. 

Note: The duration of particulate matter emission testing requirements for the clinker under the permit to 

construct has been revised from annual to once every 5 years so that it is consistent with the MACT testing 

requirements for kilns and clinker coolers.

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited by COMAR from causing or allowing visible emissions in the 

exhaust of the baghouses that are used for controlling emissions of particulate matter from the emission 

units. The Portland Cement MACT limits opacity to 10 percent. The MACT requires the Permittee to 

install, operate, and maintain a continuous opacity monitor. The Permittee is required to submit a quarterly 

summary report that includes the cause, time periods, and magnitude of all emissions which exceed the 

standards of 10 percent opacity. The report also includes the time periods and causes for all continuous 

opacity monitor downtime as well as results of daily calibration activities and quality assurance activities. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(2) and a MACT standard. In addition, the emission units are subject to a more restrictive 

limit based on permit to construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower 

particulate emission standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase 
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of PM-10 emissions from the modernization/expansion project, to below the PSD significance level, the 

Permittee agreed to vent the clinker cooler through a baghouse designed to meet a specified emission rate. 

The Permittee shall perform a stack test of the exhaust from the baghouse once during the term of the 

permit to demonstrate compliance with the emission limitations. 

The Portland Cement MACT requires the Permittee to comply with a written operations and maintenance 

plan. The plan contains the procedures for proper operation and maintenance of the baghouse and clinker 

cooler in order to comply with the opacity and particulate matter emission limitation. By properly 

operating and maintaining the baghouses, the baghouses are likely to continue to achieve the designed 

control efficiency and therefore comply with the opacity and particulate matter limitations. 

7A. Clinker Handling and Craneway- Fugitive Sources (Subject to MACT Requirements)

CWAY – Craneway 

G04-040 – Drag Conveyor B2 

H04-004 – Clinker Bin 403 

H05-004 – Clinker Bin 503 

H06-004 – Clinker Bin 603 

H07-004 – Clinker Bin 703 

TU3 – Gypsum Truck Unloading 

TU4 – Truck Unloading 

Applicable Standards/Limits:

(1) COMAR 26.11.06.03C(1) - Particulate Matter from Unconfined Sources - A person may not 

cause or permit emissions from an unconfined sources without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate Matter from Materials Handling and Construction. A person 

may not cause or permit any material to be handled, transported, or stored, or a building, its 

appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking 

reasonable precautions to prevent particulate matter from becoming airborne.

(3) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system. 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of each emission unit in 

accordance with Method 22 of Appendix A to part 60. The test must be conducted while the 

emission unit is in operation. If no visible emissions are observed in six consecutive monthly tests 

for any emission unit, the Permittee may decrease the frequency of testing from monthly to semiannually for that emission unit. If visible emissions are observed during any semi-annual test, the 

Permittee must resume testing of that emission unit on a monthly basis and maintain that schedule 

until no visible emissions are observed in six consecutive monthly tests. If no visible emissions 

are observed during the semi-annual test for any emission unit, the Permittee may decrease the 

frequency of testing from semi-annually to annually for that emission unit. If visible emissions are 

observed during any annual test, the Permittee must resume testing of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed in six 

consecutive monthly tests. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 41 of 64 

If visible emissions are observed during any Method 22 test, the Permittee shall initiate the 

corrective actions specified in the preventive maintenance plan and conduct the follow-up Method 

22 test until the problem is resolved. 

 [40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

Record Keeping Requirements

The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two 

years of data shall be retained on site. The remaining three years of data may be retained off site. The 

files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. 

[40 CFR §63.1355] 

Reporting Requirements

The Permittee shall submit a summary report semiannually which contains all failures to comply with 

any provision of the operation and maintenance plan developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

The applicable emission standards for these fugitive sources require the implementation of reasonable 

precautions to prevent particulate matter from becoming airborne. The Permittee is required to prepare a 

best management plan in which the reasonable precautions that the Permittee will implement are listed and 

described. To document that reasonable precautions are being implemented, the Permittee is required to 

perform a monthly inspection and maintain records of the results. Inspections are required at times when 

weather conditions are favorable for particulate to become airborne. The plan is required to be updated 

when it is determined that additional or different procedures are needed to prevent particulate matter from 

becoming airborne. 

7B. Clinker Handling and Craneway- Point Sources (Subject to MACT Requirements)

Baghouse Emission Unit

G04-011 G04-010- Bucket Elevator 

 G04-014- 750 MT Clinker Bin 

 G04-020- Belt Conveyor 

H09-051 H09-028- Bucket Elevator 

 H09-062- Reversible Belt Conveyor 

H09-059 H09-047- Bucket Elevator 

H09-058- Belt Conveyor 

H09-000- Semifinish Grinding System 

G04-034 G04-009 & G04-016 - Belt Conveyor 

 G04-010- Bucket Elevator 

 G04-056- 100 MT Clinker Bin Weighfeeder 

H09-025 H09-019- Weighfeeder 

 H09-023- 100 MT Gypsum Bin Weighfeeder 

H09-024- Belt Conveyor (from Weighfeeder) 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 42 of 64 

H09-082 H09-021- 100 MT Clinker Bin Weighfeeder 

H09-066- Belt Conveyor 

 H09-020- 100 MT Slag/Clinker Bin Weighfeeder 

G01-009 G01-012- Clinker Storage Silo 

G02-047 G02-002-Transfer Tower #13 

Belt Conveyor 

G02-044 G02-002- Transfer Tower #12 

 Belt Conveyor 

G02-021 G02-002-Transfer Tower #11 

Belt Conveyor 

G02-025 TT6- Transfer Tower #6 

B01-018 TT8/9- Transfer Tower #8/9 

G02-053 TL1- Clinker Truck/Rail Loadout 

H09-033 H09-031 & H09-046 - Belt Conveyor 

H09-036 & H09-041 - Bin & Roll Press 

G03-011 TT9/10- Transfer Tower #9/10 

G03-004 TT7- Transfer Tower #7 

H09-094 H09-091- Metal Reclamation System Belt Conveyor 

Applicable Regulations and Standards

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the discharge of emissions 

from any installation or building, other than water in an uncombined form, which is visible to 

human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system. 

B. Particulate matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit particulate matter to be 

discharged from any installation in excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 – Each 

emissions unit equipped with a dust collector designed to reduce particulate matter emissions 

to 0.01 gr/SCFD (22.9 mg/dscm) except TT9/10- Transfer Tower #9/10 which is required to 

meet the particulate matter emissions limit of 0.0108 gr/SCFD (24.7 mg/dscm). 

 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

affected source in accordance with Method 22 of Appendix A to part 60. The test must be 

conducted while the affected source is in operation. If no visible emissions are observed in six 

consecutive monthly tests for the exhaust stack of any affected source, the Permittee may decrease 

the frequency of testing from monthly to semi-annually for the exhaust stack of that affected 

source. If visible emissions are observed during any semi-annual test, the Permittee shall resume 

testing of the exhaust stack of that affected source on a monthly basis and maintain that schedule 

until no visible emissions are observed in six consecutive monthly tests. If no visible emissions 

are observed during the semi-annual test for the exhaust stack of any affected source, the Permittee 

may decrease the frequency of testing from semi-annually to annually for the exhaust stack of that 

affected source. If visible emissions are observed during any annual test, the Permittee shall 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 43 of 64 

resume testing of the exhaust stack of that affected source on a monthly basis until no visible 

emissions are observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the written operations and maintenance 

plan. Within 24 hours at the end of the Method 22 test, the Permittee shall conduct a follow-up 

Method 22 test of each stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are still observed, conduct a visual opacity test in accordance 

with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test shall be conducted within 

one-hour of the end of the follow-up Method 22 test and the duration of the Method 9 test shall be 

at least six minutes. 

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

B. The exhaust gas from each emission unit shall vent through a dust collector to meet the emissions limit 

before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years 

of data shall be retained on site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or no microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance records for at least five (5) 

years and make it available to the Department upon request. At a minimum, the most recent two 

years of data shall be retained on site. The remaining three years of data may be retained off site. 

The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)]

B. None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Background information:

Lehigh conducted compliance testing for particulate matter emissions from Dust Collector #H09-033 (Emission 

Units #H09-031, #H09-036, #H09-041, and #H09-046) on September 4 and 6, 2002, which indicated a particulate 

matter emission concentration of 0.0038 grs/dscf. Lehigh conducted compliance testing for particulate matter 

emissions from Dust Collector #H09-082 (Emission Units #H09-021, #H09-066, and #H09-068) on September 19, 

2002, which indicated a particulate matter emission concentration of 0.0004 grs/dscf. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 44 of 64 

These stack tests on this representative set of dust collectors demonstrated that the dust collectors used throughout 

the plant were all designed to meet the emissions limits of 0.01 grs/dscf or higher. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited by COMAR from causing or allowing visible emissions in the 

exhaust of the baghouses that are used for controlling emissions of particulate matter from the emission 

units. The Portland Cement MACT limits opacity to 10 percent. The MACT requires the Permittee to 

perform visible emissions observations of the exhaust from each baghouse. The frequency of observations 

begins at once a month and reduces in frequency if no visible emissions are observed during the monthly 

observations. If visible emissions are observed during the less frequent observation period, then the 

observation requirement starts over again at once a month. No additional monitoring is required for 

sources subject to MACT requirements therefore there is no periodic monitoring proposed for the 

emissions units. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(2). In addition, the emission units are subject to a more restrictive limit based on permit to 

construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate emission 

standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 emissions 

from the modernization/expansion project, to below the PSD significance level, the Permittee agreed to 

vent the emissions units through baghouses designed to meet a specified emission rate. The Permittee 

provided information with the PSD application that the baghouses were designed to satisfy the emissions 

limitation. No stack testing was required. 

The Portland Cement MACT requires the Permittee to comply with a written operations and maintenance 

plan. The plan plans contains the procedures for proper operation and maintenance of the baghouses and 

emissions units in order to comply with the opacity limitation. By properly operating and maintaining the 

baghouses, the baghouses are likely to continue to achieve the designed control efficiency 

and therefore comply with the opacity and particulate matter emission limitation. 

8. Finish Mill Systems (Subject to MACT Requirements)

H04-044 H04-006- Belt Conveyor 

 H04-014- Finish Mill #4 System 

H06-044 H06-014- Finish Mill #6 System 

 H06-017- Cyclone 642 (FM#6 System) 

 H06-037- Separator 627 (FM#6 System) 

H07-056 H07-014- Finish Mill #7 System and H07-018, H07-069, & H07-070 – Finished Cement 

Transfer System 

H07-057 H07-018, H07-069, & H07-070 – Finished Cement Transfer System 

H05-044 H05-014- Finish Mill #5 System 

H08-056 H08-014- Finish Mill #8 System, H08-017- Separator (FM#8 System), H08-037- Cyclone 

(FM#8 System), and H08-067- Cyclone (FM#8 System) 

Applicable Regulations and Standards

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the discharge of emissions 

from any installation or building, other than water in an uncombined form, which is visible to 

human observers. 

(2) 40 CFR §63.1347 which limits opacity from the finish mills to 10 percent or less. 

B. Particulate matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit particulate matter to be 

discharged from any installation in excess of 0.03 gr/SCFD (68.7 mg/dscm). 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 45 of 64 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000, which 

limits particulate matter from each exhaust stack of H04-014 Finish Mill #4 and H04-006 Belt 

Conveyor, H05-014 Finish Mill #5, and H06-014 Finish Mill #6 to 0.0132 gr/scfd (30.2 

mg/dscm). 

(3) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000, which 

limits particulate matter from each exhaust stack of H07-014 Finish Mill #7, H08-014 Finish 

Mill #8, and H07-018, H07-019, & H07-070 – Finished Cement Transfer System to 0.01 

gr/scfd (22.9 mg/dscm). 

Compliance Demonstration

Testing Requirements

A. None 

B. The Permittee shall conduct a particulate matter emissions test for each mill at least once every 5-year 

period in accordance with AMA Technical Memorandum 91-01 or using Method 5 of 40 CFR Part 60, 

Appendix A. Each performance test shall consist of three separate runs under the conditions that exist 

when the affected source is operating under representative performance conditions in accordance with 40 

CFR Part 63, Subpart LLL. Each run shall be conducted for at least one hour, and the minimum sample 

volume shall be 0.85 dscm (30 dscf). The average of the three runs shall be used to determine compliance. 

[Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000] 

Monitoring Requirements

A1. The Permittee shall monitor opacity by conducting daily visual emission observations of the mill sweep and 

air separator PMCDs of these affected sources, in accordance with the procedures of Method 22 of 

appendix A of part 60 of this chapter. The Method 22 test shall be conducted while the source is operating 

under representative performance conditions in accordance with 40 CFR 63.7(e). The duration of the 

Method 22 test shall be six minutes. If visible emissions are observed during any Method 22 visible 

emissions test, the Permittee shall: 

(1) Initiate, within one-hour, the corrective actions specified in the site specific operating and maintenance 

plan; 

(2) Within 24 hours of the end of the Method 22 test in which visible emissions were observed, conduct a 

follow-up Method 22 test of each stack from which visible emissions were observed during the 

previous Method 22 test; and 

(3) If visible emissions are observed during the follow-up Method 22 test, conduct a visual opacity test of 

each stack from which visible emissions were observed in accordance with Method 9 of appendix A of 

40 CFR Part 60. The Method 9 test shall be conducted within one-hour of the end of the follow-up 

Method 22 test and the duration of the Method 9 test shall be thirty minutes. 

[40 CFR §63.1350(e)] 

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan. The plan shall include the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §63.1347; and 

(2) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)] 

B. The exhaust gases from each emission unit shall vent through a dust collector designed to meet the 

particulate matter emissions limit before discharging to the atmosphere. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 46 of 64 

of data shall be retained on site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or no microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain all the records of particulate matter emissions test results for at least 

five years and make them available to the Department upon request. At a minimum, the most 

recent two years of data shall be retained on site; the remaining three years of data may be retained 

offsite. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic 

tape, or no microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)]

B1. At least 30 days prior to each stack emissions testing, the Permittee shall submit to the Department 

a stack test protocol for review and approval. 

B2. Within 60 days after each stack emissions testing, the Permittee shall submit to the Department the 

stack emissions test reports and compliance demonstration with emissions limits. 

[Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000] 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004.

Background information:

Lehigh conducted stack testing on the dust collectors associated with Finish Mills #4, #5, #6, #7, and #8 to 

determine compliance with the particulate matter emission requirements of Permit to Construct #06-6-0256. Testing 

was conducted on Dust Collectors for Finish Mills #6 and #7 on August 21 and August 22, 2002 and on Dust 

Collectors on Finish Mill #4 and #5 on September 4 and 18, 2002, and on Finish Mill #8 on June 9,2003. The 

particulate matter concentration for Finish Mill #4 was 0.0038 gr/SCFD. The particulate matter concentration for 

Finish Mill #5 was 0.0066 gr/SCFD. The particulate matter concentration for Finish Mill #6 was 0.0103 gr/SCFD. 

The particulate matter concentration for Finish Mill #7 was 0.0011gr/SCFD. The particulate matter concentration 

for Finish Mill #8 was 0.0044gr/SCFD. 

From these test results, all the finish mills and finished cement transfer systems have been operated in compliance 

with the emission limit of 0.0132 gr/scfd (30.2 mg/dscm) for finish mill # 4, 5, and 6 and 0.01 gr/scfd (22.9 

mg/dscm) for finish mill #7 and 8 and the finished cement transfer systems. 

Notes: (1) The duration of particulate matter emission testing requirements for each finish mill under the permit 

to construct has been revised from annual to once every 5 years so that it is consistent with the MACT 

testing requirements for kilns and clinker coolers. 

(2) Within “45 days” after each stack emissions testing to submit to the Department the stack emissions 

test reports and compliance demonstration with emissions limits has been revised to “60 days.’ 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited by COMAR from causing or allowing visible emissions in the 

exhaust of the baghouses that are used for controlling emissions of particulate matter from the emission 

units. The Portland Cement MACT limits opacity to 10 percent. The MACT requires the Permittee to 

perform daily visible emissions observations of the exhaust from each baghouse or to install, operate, and 

maintain a continuous opacity monitor. The Permittee selected the daily observation option. No additional 

monitoring is required for sources subject to MACT requirements therefore there is no periodic monitoring 

proposed for the emissions units. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 47 of 64 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(2). In addition, the emission units are subject to a more restrictive limit based on permit to 

construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate emission 

standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 emissions 

from the modernization/expansion project, to below the PSD significance level, the Permittee agreed to 

vent the emissions units through baghouses designed to meet a specified emission rate. The Permittee shall 

perform a stack test on the exhaust from the baghouse on each mill once during the term of the permit to 

demonstrate compliance with the emissions limitation. 

The Portland Cement MACT requires the Permittee to comply with a written operations and maintenance 

plan. The plan contains the procedures for proper operation and maintenance of the baghouses and 

emissions units in order to comply with the opacity limitation. By properly operating and maintaining the 

baghouses, the baghouses are likely to continue to achieve the designed control efficiency 

and therefore comply with the opacity and particulate matter emission limitation. 

9. Cement Load-out (Subject to MACT Requirements) 

Baghouse Emission Unit

H10-113 H07-040- Cement Cooler 

 H07-071- Airslide 

H08-040-Cement Cooler 

H08-064- Airslide 

H10-001- Airslide 

H10-006- Bucket Elevator 

H10-181 H10-167- Airslide 

H10-176- Bucket Elevator 

H10-179 H10-177- Airslide 

I01-033- Day Tank 

I02-290 I02-289 – Feed Bin 

TL2 – Truck Day Tank Loadout 

H10-221 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

H10-224 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

H10-252 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

H10-254 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

Eastpkhs I03/I04 - Packaging and Palletizing 

H10-119 H10-007, H10-124, and H10-125- Airslide 

H10-010- Bucket Elevator 

I02-204 TL4 - Truck/ Rail and Bulk Loadout System 

I02-208 TL4 - Truck/ Rail and Bulk Loadout System 

I02-224 TL4 - Truck/ Rail and Bulk Loadout System 

I02-228 TL4 - Truck/ Rail and Bulk Loadout System 

I02-244 TL4 - Truck/ Rail and Bulk Loadout System 

I02-264 TL4 - Truck/ Rail and Bulk Loadout System 

I02-268 TL4 - Truck/ Rail and Bulk Loadout System 

Applicable Standards and Regulations

A. Visible Emissions

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the discharge of emissions 

from any installation or building, other than water in an uncombined form, which is visible to 

human observers. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 48 of 64 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system. 

B. Particulate matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit particulate matter to be 

discharged from any installation in excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000, which 

limits particulate matter emissions from each emissions unit to 0.01 gr/scfd (22.9 mg/dscm) 

except 32 product silos, I01-001 through I01-032, which are required to meet to 0.021 gr/scfd 

(48.1 mg/dscm). 

 Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

affected source in accordance with Method 22 of Appendix A to part 60. The test must be 

conducted while the affected source is in operation. If no visible emissions are observed in six 

consecutive monthly tests for the exhaust stack of any affected source, the Permittee may decrease 

the frequency of testing from monthly to semi-annually for the exhaust stack of that affected 

source. If visible emissions are observed during any semi-annual test, the Permittee shall resume 

testing of the exhaust stack of that affected source on a monthly basis and maintain that schedule 

until no visible emissions are observed in six consecutive monthly tests. If no visible emissions 

are observed during the semi-annual test for the exhaust stack of any affected source, the Permittee 

may decrease the frequency of testing from semi-annually to annually for the exhaust stack of that 

affected source. If visible emissions are observed during any annual test, the Permittee shall 

resume testing of the exhaust stack of that affected source on a monthly basis until no visible 

emissions are observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the written operations and maintenance 

plan. Within 24 hours at the end of the Method 22 test, the Permittee shall conduct a follow-up 

Method 22 test of each stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are still observed, conduct a visual opacity test in accordance 

with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test shall be conducted within 

one-hour of the end of the follow-up Method 22 test and the duration of the Method 9 test shall be 

at least six minutes. 

 [40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)] 

B. The exhaust gases from each emissions shall vent through a dust collector to meet the particulate 

matter emissions limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 49 of 64 

A. The Permittee shall maintain all records for at least five years following the date of each 

occurrence, measurement, maintenance, corrective action, report or record. At a minimum, the 

most recent two years of data shall be retained on site; the remaining three years of data may be 

retained offsite. The files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche. 

[40 CFR §63.1355]

B. The Permittee shall maintain the log of inspection and maintenance records for at least five (5) 

years and make it available to the Department upon request. At a minimum, the most recent two 

years of data shall be retained on site. The remaining three years of data may be retained off site. 

The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited by COMAR from causing or allowing visible emissions in the 

exhaust of the baghouses that are used for controlling emissions of particulate matter from the emission 

units. The Portland Cement MACT limits opacity to 10 percent. The MACT requires the Permittee to 

perform visible emissions observations of the exhaust from each baghouse. The frequency of observations 

begins at once a month and reduces in frequency if no visible emissions are observed during the monthly 

observations. If visible emissions are observed during the less frequent observation period, then the 

observation requirement starts over again at once a month. No additional monitoring is required for 

sources subject to MACT requirements therefore there is no periodic monitoring proposed for the 

emissions units. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(2). In addition, the emission units are subject to a more restrictive limit based on permit to 

construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate emission 

standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 emissions 

from the modernization/expansion project, to below the PSD significance level, the Permittee agreed to 

vent the emissions units through baghouses designed to meet a specified emission rate. The Permittee 

provided information with the PSD application that the baghouses were designed to satisfy the emissions 

limitation. No stack testing was required. 

The Portland Cement MACT requires the Permittee to comply with a written operations and maintenance 

plan. The plan plans contains the procedures for proper operation and maintenance of the baghouses and 

emissions units in order to comply with the opacity limitation. By properly operating and maintaining the 

baghouses, the baghouses are likely to continue to achieve the designed control efficiency 

and therefore comply with the opacity and particulate emission limitation. 

10. Waste Dust Handling (Not subject to MACT Requirements) 

Baghouse Emission Unit
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 50 of 64 

C04-050 C04-037- Bucket Elevator 

C04-075 C04-037- Bucket Elevator 

C04-050 C04-038- 600T Bin and C04-068- Airslide 

C04-075 C04-070, C04-072, and C04-074- Airslide 

 TL3 – Truck Waste Dust Loadout 

Applicable Standards and Regulations

A. Visible Emissions 

COMAR 26.11.06.02C(2)- Visible Emissions. In Areas III and IV a person may not cause or 

permit the discharge of emissions from any installation or building, other than water in an 

uncombined form, which is visible to human observers. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit to be discharged in to the 

outdoor atmosphere from any other installation, particulate matter in excess of 0.03 gr/SCFD 

(68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000 – Each 

equipment shall be equipped with a dust collector designed to reduce particulate matter 

emissions to 0.01 gr/SCFD (22.9 mg/dscm). 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test must be conducted 

while the emission unit is in operation. If no visible emissions are observed in six consecutive 

monthly tests for the exhaust stack of any emission unit, the Permittee may decrease the frequency 

of testing from monthly to semi-annually for the exhaust stack of that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. If no visible emissions are observed 

during the semi-annual test for the exhaust stack of any emission unit, the Permittee may decrease 

the frequency of testing from semi-annually to annually for the exhaust stack of that emission unit. 

If visible emissions are observed during any annual test, the Permittee shall resume testing of the 

exhaust stack of that emission unit on a monthly basis until no visible emissions are observed in 

six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the preventive maintenance plan or the 

best management plan. Within 24 hours at the end of the Method 22 test, the Permittee shall 

conduct a follow-up Method 22 test of each stack from which visible emissions were observed 

during the previous Method 22 test. If visible emissions are still observed, conduct a visual 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test and the duration of 

the Method 9 test shall be at least six minutes. 

 [COMAR 26.11.03.06C] 

B1. The exhaust gas from each equipment shall vent through a dust collector designed to reduce 

particulate matter emissions to 0.01 gr/SCFD (22.9 mg/dscm) before discharging into the 

atmosphere. 

[COMAR 26.11.03.06C] 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 51 of 64 

B2. The Permittee shall comply with and update the preventative maintenance plan for each baghouse 

that describes the maintenance activity and time schedule for completing each activity. The 

Permittee shall perform maintenance activities within the timeframes established in the plan and 

shall maintain a log with records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections for at least five (5) 

years and make them available to the Department upon request. At a minimum, the most recent 

two years of data shall be retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[COMAR 26.11.03.06C] 

B. The log of inspection and maintenance records shall be kept for at least five (5) years and shall be 

made available to the Department upon request. At a minimum, the most recent two years of data 

shall be retained on site. The remaining three years of data may be retained off site. The files may 

be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

Reporting Requirements

None

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited from causing or allowing visible emissions in the exhaust of the 

baghouses that are used for controlling emissions of particulate matter from the emission units. To 

demonstrate compliance, the Permittee is required to perform visible emissions observations of the exhaust 

from each baghouse. The frequency of observations begins at once a month and reduces in frequency if no 

visible emissions are observed during the monthly observations. If visible emissions are observed during 

the less frequent observation period, then the observation requirement starts over again at once a month. 

This strategy mirrors the requirement for similar type emissions sources subject to the Portland cement 

MACT. The Department selected the MACT monitoring strategy to satisfy the requirement for periodic 

monitoring, COMAR 26.11.03.06C. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(1)(b)(ii). In addition, the emission units are subject to a more restrictive limit based on 

permit to construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate 

emission standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 

emissions from the modernization/expansion project, to below the PSD significance level, the Permittee 

agreed to vent the emissions units through baghouses designed to meet a specified emission rate. 

The Permittee provided information with the PSD application that the baghouses were designed to satisfy 

the emissions limitation. No stack testing was required. If properly maintained, the baghouses are likely to 

continue to achieve the emissions limitation. The Permittee is required implement a preventative 

maintenance plan to maintain the baghouses in a manner to achieve its design control efficiency. The 

Permittee is also required to maintain inspection and maintenance records for the baghouses to demonstrate 

that a preventative plan is being implemented. 

11. Miscellaneous Sources Venting Inside Building (Subject to MACT Requirements)

Baghouse Emission Unit
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 52 of 64 

G04-037 G04-018-Belt Conveyor 

G04-037 G04-019-CE2 Bucket Elevator 

H09-073 G04-031-Drag Conveyor B3 

H09-073 H09-058-Belt Conveyor 

H09-073 H09-075-90T Bin 

Applicable Standards and Regulations

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the discharge of emissions 

from any installation or building, other than water in an uncombined form, which is visible to 

human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing raw material, 

clinker, or finished product storage bin; conveying system transfer point; bagging system; and 

bulk loading or unloading system. 

B. Particulate Emissions

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit particulate matter to be 

discharged from any installation in excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000- Each emissions 

unit shall be equipped with a dust collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm). 

Compliance Demonstration

Testing Requirements

 None

Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the exhaust stack of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test must be conducted 

while the emission unit is in operation. If no visible emissions are observed in six consecutive 

monthly tests for the exhaust stack of any emission unit, the Permittee may decrease the frequency 

of testing from monthly to semi-annually for the exhaust stack of that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee must resume testing of the 

exhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. If no visible emissions are observed 

during the semi-annual test for the exhaust stack of any emission unit, the Permittee may decrease 

the frequency of testing from semi-annually to annually for the exhaust stack of that emission unit. 

If visible emissions are observed during any annual test, the Permittee must resume testing of the 

exhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. If visible emissions are observed on each stack during any Method 22 test, the Permittee shall 

initiate, within one hour, the corrective actions specified in the written operations and maintenance 

plan. Within 24 hours at the end of the Method 22 test, the Permittee shall conduct a follow-up 

Method 22 test of each stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are still observed, conduct a visual opacity test in accordance 

with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test shall be conducted within 

one-hour of the end of the follow-up Method 22 test and the duration of the Method 9 test shall be 

at least six minutes. 

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

The Permittee have the option to conduct a Method 22 visible emissions test according to the 

requirements of 40 CFR §63.1350(a)(4)(i)-(iii) and (l) for each emissions unit located within the 

building, or for the building itself. If visible emissions from the building are monitored, the 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 53 of 64 

requirements of 40 CFR §63.1350(a)(4)(i)-(iii) and (l) apply to monitoring the building, and the 

Permittee must also test visible emissions from each side, roof, and vent of the building for at least 

1 minute. The test must be conducted under normal operating conditions.

[40 CFR §63.1350(a)(4)(vi)-(vii)]

A2. The Permittee shall comply with and update as needed the written operations and maintenance 

plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)]

B. The exhaust gas from each emissions unit shall vent through a dust collector designed to meet the 

particulate matter emissions limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date of each 

occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the 

most recent two years of data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche. 

[40 CFR §63.1355]

B. The Permittee shall maintain the log of inspection and maintenance records for at least five (5) 

years and make it available to the Department upon request. At a minimum, the most recent two 

years of data shall be retained on site. The remaining three years of data may be retained off site. 

The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. 

[COMAR 26.11.03.06C]

Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all failures to comply 

with any provision of the operation and maintenance plan developed in accordance with 

§63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

Discussion of compliance demonstration:

For opacity, the Permittee is prohibited from causing or allowing visible emissions in the exhaust of the baghouses 

that are used for controlling emissions of particulate matter from the emission units. To demonstrate compliance, 

the Permittee is required to perform visible emissions observations of the exhaust from each baghouse. The 

frequency of observations begins at once a month and reduces in frequency if no visible emissions are observed 

during the monthly observations. If visible emissions are observed during the less frequent observation period, then 

the observation requirement starts over again at once a month. This strategy mirrors the requirement for similar type 

emissions sources subject to the Portland cement MACT. The Department selected the MACT monitoring strategy 

to satisfy the requirement for periodic monitoring, COMAR 26.11.03.06C. 

For particulate matter, the Permittee is subject to the general emission standard of COMAR 

26.11.06.03B(1)(b)(ii). In addition, the emission units are subject to a more restrictive limit based on 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 54 of 64 

permit to construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000. The lower particulate 

emission standard was set as part of a PSD analysis for PM-10. To limit facility-wide increase of PM-10 

emissions from the modernization/expansion project, to below the PSD significance level, the Permittee 

agreed to vent the emissions units through baghouses designed to meet a specified emission rate. 

The Permittee provided information with the PSD application that the baghouses were designed to satisfy the 

emissions limitation. No stack testing was required. If properly maintained, the baghouses are likely to continue to 

achieve the emissions limitation. The Permittee is required implement a preventative maintenance plan to maintain 

the baghouses in a manner to achieve its design control efficiency. The Permittee is also required to maintain 

inspection and maintenance records for the baghouses to demonstrate that a preventative plan is being implemented. 

Since all emissions units are located inside the building, the Permittee could only monitor the visible emissions from 

the building in accordance with 40 CFR §63.1350(a)(4)(i)-(iv) for opacity compliance demonstration. 

12. Facility-Wide 

Applicable Standards and Regulations

A. NOx Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000, which states that the 

NOx emissions from the entire premises, including the existing Portland cement plant and the 

Pyroprocessing Portland cement plant shall not exceed 4,871 tons for any 12-month period, rolling 

monthly. 

Note: . The NOx limitation is based on the emissions number in the PSD application for the total new 

potential emissions of NOx from the modernization/expansion project. At this level of emissions the net 

increase of emissions would be less than the PSD/NSR significance level for NOx. 

B. Particulate matter Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000, which states that “The 

emissions from the entire premises, including the existing Portland cement plant and the Pyroprocessing 

Portland cement plant, shall not exceed the following limits for any 12-month period, rolling monthly: 

(1) 925 tons of PM; 

(2) 716 tons of PM10; and 

(3) 586 tons of PM10 stack emissions. 

Note: The PM and PM10 limitations are based on the emissions number in the PSD application for the total 

new potential emissions of PM and PM10 from the modernization/expansion project. At this level of 

emissions the net increase of emissions would be less than the PSD/NSR significance level for PM and 

PM10. 

C. Sulfur Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000, which states that The 

emissions from the entire premises, including the existing Portland cement plant and the Pyroprocessing 

Portland cement plant, shall not exceed the following limits for any 12-month period, rolling monthly1,041 tons of SO2. 

Note: The SO2 limitation is based on the emissions number in the PSD application for the total new 

potential emissions of SO2 from the modernization/expansion project. At this level of emissions the net 

increase of emissions would be less than the PSD/NSR significance level for SO2. 

D. Carbon Monoxide Emissions 

Prevention of Significant Deterioration (PSD) Approval #PSD-97-01R dated April 8, 1999 and 

revised on June 7, 2000 which states that “The premises-wide carbon monoxide (C0) emissions from the 

Pyroprocessing Portland cement plant and the existing Portland cement plant shall not exceed 3,328 tons 

for any 12-month period, rolling monthly.” 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 55 of 64 

Note: The CO limitation is the PSD limit that was established as a result of the PSD review for the 

modernization/expansion project.

E. Volatile Organic Compound (VOC) Emissions 

New Source Review (NSR) Approval #NSR-97-02 dated April 8, 1999 which states that “The premiseswide emissions from the Pyroprocessing Portland cement plant and the existing Portland cement plant shall 

not exceed 165 tons of VOC for any 12-month period, rolling monthly. In determining compliance with 

VOC emission limits, VOC emission shall be determined by calculating the numerical difference between 

the measured values of total hydrocarbon (THC) emissions and non-VOC emissions.” 

Note: The VOC limitation is the non-attainment major NSR limit that was established as a result of the 

NSR review for the modernization/expansion project.

F. Lead Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000 which states that the 

emissions from the entire premises, including the existing Portland cement plant and the Pyroprocessing 

Portland cement plant, shall not exceed 0.6 tons of lead for any 12-month period, rolling monthly. 

Note: The emission limit is the PSD significance level for lead. The projected potential increase in 

emissions of lead submitted in the PSD application were less than the significance level. The permit 

condition clarifies that the net increase in emissions must be less than the significance level. 

G. Fluoride Emissions 

(1) Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000 which states that the 

emissions from the entire premises, including the existing Portland cement plant and the 

Pyroprocessing Portland cement plant, shall not exceed 3.0 tons of fluoride for any 12-month period, 

rolling monthly. 

Note: The emission limit is the PSD significance level for fluorides. The projected potential increase in 

emissions of fluorides submitted in the PSD application were less than the significance level. The permit 

condition clarifies that the net increase in emissions must be less than the significance level. 

(2) COMAR 26.11.03.06C which prevents the discharge of fluorides into the atmosphere that causes a 

violation of any applicable ambient air quality standards for fluorides set forth in COMAR 26.11.04. 

Compliance Demonstration

Testing Requirements

A thru G. None 

Monitoring Requirements

A thru G. 

The Permittee shall calculate premises-wide emissions for each month and each 12-month period, 

rolling monthly, to demonstrate compliance with the facility-wide emissions limits of NOx, 

Particulate matter, SO2 , CO, VOC, Lead, and Fluoride. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A thru G 

The Permittee shall maintain the following records with supporting documentation for at least five 

years and make these records available to the Department upon request: 

(1) Premises-wide emissions for each month and each 12-month period, rolling monthly; and 

(2) Any violation of any emission limit required for each rolling 12-month period. 

At a minimum, the most recent two years of data shall be retained on site. The remaining three 

years of data may be retained off site. The files may be maintained on microfilm, on a computer, 

on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C]

Reporting Requirements
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 56 of 64 

A through G 

(1) The Permittee shall include the emissions of NOx, Particulate matter, SO2 , CO, VOC, Lead, 

and Fluoride for each month and each 12-month period, rolling monthly, in the required 

quarterly report, the semiannual summary report, and the annual emission certification. 

(2) The Permittee shall submit to the Department a written report, no later than 30 days after a 

detection of any violation of any emission limit required for each rolling 12-month period. 

[COMAR 26.11.03.06C] 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004.

Background information:

The Permittee will calculate PM emissions based on the results of compliance stack tests. The emissions of NOx, 

SO2, CO, and THC will be based on data from the continuous emissions monitors. Lead and fluoride emissions will 

be calculated based on the results of stack testing in November 2003, or subsequent stack testing. 

The NOx CEM was certified on August 14, 2002. Based on the CEM collected data for NOx during the 12 month 

period, September 2002 to August 2003, the total emissions were 2625 tons per year. The NOx emissions limit is 

4,871 tons for any 12-month rolling period. 

The SO2 CEM was certified on August 14, 2002. Based on the CEM collected data for SO2 during the 12 month 

period, September 2002 to August 2003, the total emissions were 9 tons per year. The SO2 emissions limit is 1,041 

tons for any 12-month rolling period.

The CO CEM was certified on August 14, 2002. Based on the CEM collected data for CO during the 12 month 

period, September 2002 to August 2003, the total emissions were 825 tons per year. The CO emissions limit is 3328 

tons for any 12-month rolling period. 

The THC CEM was certified on August 14, 2002. Based on the CEM collected data for THC during the 12 month 

period, September 2002 to August 2003, the total emissions were 21tons per year. The VOC emissions limit is 165 

tons for any 12-month rolling period. 

The lead emissions stated in the 2002 Emissions Certification Report were 1.6 pounds per day and 0.284 tons per 

year, which is well below the limit of 0.6 tons for any 12-month period, rolling monthly. 

The hydrogen fluoride emissions stated in the 2002 Emissions Certification Report were 10 pounds per day and 1.2 

tons per year, which is well below the limit of 3.0 tons for any 12-month period, rolling monthly. 

MACT Requirements

(Applies to MACT Sources Only)

Applicable Standards and Regulations

The Permittee shall comply with the following sections of the General Provisions. The provisions which do not 

apply have been deleted. 

Table 1 to Subpart LLL of Part 63—Applicability of General Provisions 

General Provisions 

40 CFR Citation 

Requirement Comment 

63.1(a)(1) through (4) Applicability 

63.1(a)(6) through (a)(8) Applicability 

63.1(a)(10) through (14) Applicability 

63.1(b)(2) and (3) Initial Applicability Determination 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 57 of 64 

63.1(c)(1) Applicability after Standard 

 Established 

63.1(c)(2) Permit Requirements Area Sources Must Obtain Title V 

Permits 

63.1(c)(4) and (5) Extensions, Notifications 

63.1(e) Applicability of Permit Program 

63.2 Definitions Additional Definitions in §63.1341 

63.3(a) through (c) Units and Abbreviations 

63.4(a)(1) through (a)(3) Prohibited Activities 

63.4(a)(5) Compliance Date 

63.4(b)and (c) Circumvention, Severability 

63.5(a)(1) and (2) Construction/Reconstruction 

63.5(b)(1) Compliance Dates 

63.5(b)(3) through (6) Construction Approval. 

Applicability 

63.5(d)(1) through (4) Approval of Construction/ 

Reconstruction 

63.5(e) Approval of Construction/ 

Reconstruction 

63.5(f)(1) and (2) Approval of Construction/ 

Reconstruction 

63.6(a) Compliance for Standards and 

Maintenance 

63.6(b)(1) through (5) Compliance Dates 

63.6(b)(7) Compliance Dates 

63.6(c)(1) and (2) Compliance Dates 

63.6(c)(5) Compliance Dates 

63.6(e)(1) and (e)(2) Operation & Maintenance 

63.6(e)(3) Start-up, Shut-Down and 

 Malfunction 

63.6(f)(1) through (3) Compliance with Emission 

Standards 

63.6(g)(1) through (g)(3) Alternative Standard 

63.6(h)(1) and (2) Opacity/VE Standards 

63.6(h)(4) and (h)(5)(i) Opacity/VE Standards 

63.6(h)(6) Opacity/VE Standards 

63.6(h)(7) Opacity/VE Standards 

63.6(i)(1) through (i)(14) Extension of Compliance 

63.6(i)(16) Extension of Compliance 

63.6(j) Exemption from Compliance 

63.7(a)(1) through (a)(3) Performance Testing 

Requirements 

§63.1349 has specific requirements 

63.7(b) Notification 

63.7(c) Quality Assurance/Test Plan 

63.7(d) Testing Facilities 

63.7(e)(1) through (4) Conduct of Tests 

63.7(f) Alternative Test Method 

63.7(g) Data Analysis 

63.7(h) Waiver of Tests 

63.8(a)(1) Monitoring Requirements 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 58 of 64 

63.8(b)(1) through (3) Conduct of Monitoring 

63.8(c)(1) through (8) CMS Operation/Maintenance Performance specification supersedes 

requirements for THC CEM. Temperature 

and activated carbon injection monitoring 

data reduction requirements given in subpart 

LLL. 

63.8(d) Quality Control 

63.8(e) Performance Evaluation for CMS Performance Specification supersedes 

requirements for THC 

63.8(f)(1) through (f)(5) Alternative Monitoring Method Additional requirements in §1350(l) 

63.8(f)(6) Alternative to RATA Test 

63.8(g) Data Reduction 

63.9(a) Notification Requirements 

63.9(b)(1) through (5) Initial Notifications 

63.9(c) Request for Compliance Extension 

63.9(d) New Source Notification for 

Special Compliance Requirements 

63.9(e) Notification of Performance Test 

63.9(f) Notification of VE/Opacity Test Notification not required for VE/opacity test 

under §63.1350(e) and (j) 

63.9(g) Additional CMS Notifications 

63.9(h)(1) through (h)(3) Notification of Compliance Status 

63.9(h)(5) and (h)(6) Notification of Compliance Status 

63.9(i) Adjustment of Deadlines 

63.9(j) Change in Previous Information 

63.10(a) Record keeping/Reporting 

63.10(b) General Requirements 

63.10(c)(1) Additional CMS Record Keeping PS-8A applies instead of requirements for 

THC CEM 

63.10(c)(5) through (c)(8) Additional CMS Record Keeping PS-8A applies instead of requirements for 

THC CEM 

63.10(c)(10) through (15) Additional CMS Record Keeping 

63.10(d)(1) General Reporting Requirements 

63.10(d)(2) Performance Test Results 

63.10(d)(3) Opacity or VE Observations 

63.10(d)(4) Progress Reports 

63.10(d)(5) Startup, Shutdown, Malfunction 

Reports 

63.10(e)(1) and (e)(2) Additional CMS Reports 

63.10(e)(3) Excess Emissions and CMS 

Performance Reports 

Exceedances are defined in subpart LLL 

63.10(f) Waiver for Record Keeping/ 

Reporting 

63.12(a)-(c) State Authority and Delegations 

63.13(a)-(c) State/Regional Addresses 

63.14(a) and (b) Incorporation by Reference 

63.15(a) and (b) Availability of Information 

Applicable Standards and Regulations

40 CFR §63.6(e)(3)(i) which requires that the Permittee comply with the written startup, shutdown, and 

malfunction plan that describes, in detail, procedures for operating and maintaining the source during 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 59 of 64 

periods of startup, shutdown, and malfunction; a program of corrective action for malfunctioning process; 

and air pollution control and monitoring equipment used to comply with the relevant standard. 

40 CFR §63.6(e)(3)(viii) which states that the Permittee may periodically revise the startup, shutdown, and 

malfunction plan for the affected source as necessary to satisfy the requirements of this part or to reflect 

changes in equipment or procedures at the affected source. Unless the permitting authority provides 

otherwise, the Permittee may make such revisions to the startup, shutdown, and malfunction plan without 

prior approval by the Administrator or the permitting authority. However, each revision to a startup, 

shutdown, and malfunction plan must be reported in the semiannual report required by §63.10(d)(5). If the 

startup, shutdown, and malfunction plan fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction but was not included in the startup, shutdown, and malfunction plan at the 

time the Permittee developed the plan, the Permittee must revise the startup, shutdown, and malfunction 

plan within 45 days after the event to include detailed procedures for operating and maintaining the source 

during similar malfunction events and a program of corrective action for similar malfunctions of process or 

air pollution control and monitoring equipment. In the event that the Permittee makes any revision to the 

startup, shutdown, and malfunction plan which alters the scope of the activities at the source which are 

deemed to be a startup, shutdown, and malfunction, or otherwise modifies the applicability of any emission 

limit, work practice requirement, or other requirement in a standard established under this part, the revised 

plan shall not take effect until after the Permittee has provided a written notice describing the revision to 

the permitting authority. 

Compliance Demonstration

Testing Requirements

40 CFR 63.1349(c) requires the Permittee to repeat performance test for particulate matter emissions 

required under 40 CFR 63.1349(b)(1) and (b)(2) at least once every five years. 40 CFR 63.1349(d) requires 

the Permittee to repeat performance test for dioxin/furan emissions required under 40 CFR 63.1349(b)(3) at 

least once every 30 months. 40 CFR 63.1349(e)(1) requires that if a source plans to undertake a change in 

operations that may adversely affect compliance with an applicable D/F standard under this subpart, the 

source must conduct a performance test and establish new temperature limit(s) as specified in paragraph 

(b)(3) of this section. 40 CFR 63.1349(e)(2) requires that If a source plans to undertake a change in 

operations that may adversely affect compliance with an applicable PM standard under § 63.1343, the 

source must conduct a performance test as specified in paragraph (b)(1) of this section.

[40 CFR 63.1349(c), (d), and (e)] 

Monitoring Requirements

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain any 

affected source, including associated air pollution control equipment and monitoring equipment, in a manner 

consistent with safety and good air pollution control practices for minimizing emissions to the levels required by the 

relevant standards, i.e., meet the emission standard or comply with the startup, shutdown, and malfunction plan. 

Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup, 

shutdown, and malfunction plan. To the extent that an unexpected event arises during a start-up, shutdown, and 

malfunction, the Permittee shall comply by minimizing emissions during such a startup, shutdown, or malfunction 

event consistent with safety and good air pollution control practices. 

[40 CFR §63.6(e)(1)(i -ii)] 

For any affected source located inside a building, the Permittee has the option to monitor visible emissions 

for each conveying system transfer point or the building in accordance with 40 CFR §63.1350(a)(4)(i - iii) 

and (l). If visible emissions from a building are monitored, the Permittee must also test visible emissions 

from each side, roof, and vent of the building for at least 1 minute. The test must be conducted under 

normal operating condition. 

[40 CFR §63.1350(a)(4)(vi – vii)] 

Record Keeping Requirements
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 60 of 64 

When actions taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) are consistent with the procedures specified in the affected source’s start-up, shutdown, and 

malfunction plan, the Permittee shall keep records for that event which demonstrate the procedures specified in the 

plan were followed. These records may take the form of a “checklist”, or other effective form of record keeping that 

confirms conformance with the startup, shutdown, and malfunction plan for that event. In addition, the Permittee 

shall keep records of these events as specified in §63.10(b), including records of the occurrence and duration of each 

startup, shutdown, or malfunction of operation and each malfunction of the air pollution control and monitoring 

equipment. Furthermore, the Permittee shall confirm that action taken during the relevant reporting period during 

periods of startup, shutdown, or malfunction were consistent with the affected source’s startup, shutdown, and 

malfunction plan in the semiannual (or more frequent) start-up, shutdown, and malfunction report required in 

§63.10(d)(5). 

If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a 

malfunction) is not consistent with the procedures specified in the affected source’s startup, shutdown, and 

malfunction plan, and the source exceeds the relevant emission standard, then the Permittee shall record the actions 

taken for that event and shall report such actions within 2 working days after commencing actions inconsistent with 

the plan, followed by a letter within 7 working days after the end of the event, in accordance with §63.10(d)(5) 

(unless the Permittee makes alternative reporting arrangements , in advance, with the Administrator). 

The Permittee shall maintain at the affected source a current startup, shutdown, and malfunction plan and shall make 

the plan available upon request for inspection and copying by the Administrator. In addition, if the startup, 

shutdown, and malfunction plan is subsequently revised, the Permittee shall maintain at the affected source each 

previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, and must make each such 

previous version available for inspection and copying by the Administrator for a period of 5 years after revision of 

the plan. If at any time after adoption of a startup, shutdown, and malfunction plan the affected source ceases 

operation or is otherwise no longer subject to the provisions of this part, the Permittee shall retain a copy of the most 

recent plan for 5 years from the date the source ceases operation or is no longer subject to this part and shall make 

the plan available upon request for inspection and copying by the Administrator. 

[40 CFR §63.6(e)(3)(iii – v)] 

 

Reporting Requirements

The Permittee shall, if actions taken are consistent with the procedures specified in the start-up, shutdown, or 

malfunction plan, during a start-up, shut down, or malfunction of an affected source (including actions taken to 

correct a malfunction), state such information in a semiannual report. Reports shall only be required if a start-up, 

shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may 

be submitted simultaneously with the excess emissions and continuous monitoring system performance reports. 

Any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to 

correct a malfunction) is not consistent with the procedures in the startup, shutdown, or malfunction plan, the 

Permittee shall make an immediate report of the actions taken for that event within 2 working days, by telephone 

call or fax transmission. The immediate report shall be followed by a letter, certified by the Permittee explaining the 

circumstances of the event, the reasons for not following the startup, shutdown, or malfunction plan, and whether 

any excess emissions and/or parameter monitoring exceedances are believed to have occurred. 

[40 CFR §63.1354(b)(4 – 5)] 

Notes: Lehigh Cement Company did request a permit shield on February 26, 2004. 

COMPLIANCE SCHEDULE
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 61 of 64 

Lehigh Cement Company is in compliance with air quality requirements. 

TITLE IV – ACID RAIN

Lehigh Cement Company is not subject to the Acid Rain Program requirements. 

TITLE VI – OZONE DEPLETING SUBSTANCES

The Permittee shall comply with the standards for recycling and emission reductions pursuant to 40 CFR 

Part 82, Subpart F. 

SECTION 112(r) – ACCIDENTAL RELEASES

Lehigh Cement Company is not subject to the requirements of Section 112 (r). 

PERMIT SHIELD

Lehigh Cement Company did request a permit shield on February 26, 2004. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 62 of 64 

INSIGNIFICANT ACTIVITIES

The following emissions units and activities are exempt from Part 70 permit requirements: 

(1) No.__3__ Stationary internal combustion engines with an output less than 500 brake horsepower 

(373 kilowatt) and which are not generate electricity for sale or for peak or for load 

shaving; 

(a) Emissions During Idle Mode (COMAR 26.11.09.05B(2)). The Permittee may not 

cause or permit the discharge of emissions from any engine, operating at other than 

idle conditions, greater than 10 percent opacity. 

(b) Emissions During operating Mode (COMAR 26.11.0905b(3)). The Permittee may 

not cause or permit the discharge of emissions from any engine, operating at other 

than idle conditions greater than 40 percent opacity. 

(c) Exceptions: 

(i) COMAR 26.11.09.5B(2) does not apply for a period of 2 consecutive minutes 

after a period of idling of 15 consecutive minutes for the purpose of clearing e 

exhaust system. 

(ii) COMAR 26.11.09.5B(3) does not apply to emissions resulting directly from 

cold engine start-up and warm-up for the following maximum periods: 

(1) Engines that are idled continuously when not in service: 30 minutes; and 

(2) All other engines: 15 minutes. 

(iii) COMAR 26.11.09.05B(2) & (3) does not apply while maintenance, repair or 

testing is being performed by qualified mechanics. 

(2) __X__ Water cooling towers and water cooling ponds unless used for evaporative cooling of 

water from barometric jets or barometric condensers, or used in conjunction with an 

installation requiring a permit to operate; 

(3) No. _4__ Unheated VOC dispensing containers or unheated VOC rinsing containers of 60 gallons 

(227 liters) capacity or less; 

(a) The Permittee shall not use any VOC degreasing material that exceeds a vapor 

pressure of 1mmHg at 20° Celsius (COMAR 26.11.19.09D(2)(b)). 

(b) The Permittee shall implement good operating practices to minimize spills and 

evaporation of VOC degreasing material. These practices shall include covers 

(including water covers), lids, or other methods of minimizing evaporative losses, 

and reducing the time and frequency during which parts are cleaned (COMAR 

26311.19.09D(3)(a-d)). 

(c) The Permittee shall not use a halogenated substance that is a VOC in any cold 

degreasing operations (COMAR 263.11.19.09D(3)(a-d)). 

The Permittee shall maintain the following records of operating data at the sire for at least 

five (5) years and shall make available to the Department upon request: 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 63 of 64 

(a) Monthly records of the total VOC degreasing material used (COMAR 

26.11.19.09F); and 

(b) The good operating practices established by COMAR 26.11.19.09D established in 

Writing and displayed so they are clearly visible to the operator at the facility 

(COMAR 26.11.19.09D(3)(a-d)). 

(4) __X_ Equipment for drilling, carving, cutting, routing, turning, sawing, planing, spindle 

sanding, or disc sanding of wood or wood products; 

Containers, reservoirs, or tanks used exclusively for: 

(5) __X_ Storage of butane, propane, or liquefied petroleum, or natural gas; 

 

(19) __X_ Storage of lubricating oils: 

(a) constructed before July 23, 1984, or 

(b) constructed after July 23, 1984 and are less than 10,000 gals. 

(20) _X_ Storage of lubricating oils greater than 10,000 gals. and constructed after July 23, 1984; 

(NOTE: tanks may have applicable requirements in 40CFR60) 

(23) No._2_ Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation jet engine fuel; 

(a) constructed before July 23, 1984, or 

(b) constructed after July 23, 1984 and are less than 10,000 gals. 

(24) No._1_ Storage of Numbers 1,2,4,5, and 6 fuel oil and aviation jet engine fuel greater than 

10,000 gals. and constructed after July 23, 1984; (NOTE: this condition has applicable 

requirements in 40CFR60) 

(25) No._X_ Storage of motor vehicle gasoline, having an individual tank capacity of 2,000 gallons or 

less; 

(36) _X_ First aid and emergency medical care provided at the facility, including related 

activities such as sterilization and medicine preparation used in support of a 

manufacturing or production process: 

(38) _X_ Potable water treatment equipment, not including air-stripping equipment; 

(39) _X_ Noncontact water (i.e, water that has not been in direct contact with process fluids) 

cooling towers except as regulated under Section 112 of the Clean Air Act; 

(41) _X_ Emissions resulting from the use of explosives for blasting at quarrying operations and 

from the required disposal of boxes used to ship the explosive; 

(42) _X_ Comfort air conditioning subject to requirements of title VI the Clean Air Act; and 
LEHIGH CEMENT COMPANY 

UNION BRIDGE PLANT 

PART 70 OPERATING PERMIT FACT SHEET 

OPERATING PERMIT NO. 24-013-00012

Page 64 of 64 

(46) _X_ Laboratory fume hoods and vents. 

STATE ONLY ENFORCEABLE REQUIREMENTS

Facility-wide 

Applicable Standard and limits: 

(1) COMAR 26.11.01.11B(7), which requires installation of a data telemetry system for all required 

CEMs. This system shall be designed and installed in accordance with specifications approved by the 

Department and shall be operational by the date specified in Regulation .10D(1) of this chapter. 

(2) COMAR 26.11.06.08 and COMAR 26.11.06.09 which generally prohibit the discharge of emissions 

beyond the property line in such a manner that a nuisance or air pollution is created. 

(3) COMAR 26.11.15.05, which requires the installation and operation of T-BACT for new installations or 

sources discharging a toxic air pollutant to the atmosphere. 

(4) COMAR 26.11.15.06, which states that new sources or installations must comply with the allowable 

emissions of toxic air pollutants. Existing sources of installation must demonstrate compliance with 

the list of toxic air pollutants for existing sources. 

Compliance:

(1) The Permittee shall submit certification of compliance with COMAR 26.11.15 in the annual Emission 

Certification Report. 

(2) The Permittee shall not use any alternative kiln raw material, fuel, or additive except the following: 

(a) Quarried stone, sand and shale; 

(b) Iron-bearing materials, such as pyrites and millscale; 

(c) Cat fines; 

(d) Bottom ash and fly ash from coal-fired fuel burning equipment; 

(e) Coal; 

(f) Scrap tires; 

(g) Petroleum coke; 

(h) Used oil generated on site; and 

(i) Other materials which are included in the Permittee’s current operating permit or may 

have been approved by the Department in the past under separate action. Any alternative kiln raw material, fuel, or additive not approved under authority of this permit or under 

any previous action may not be used unless it is demonstrated to the Department's satisfaction that the 

use of any substitute raw material, fuel or additive does not violate the Department’s air toxics 

screening levels and does not increase air emissions beyond the allowable limits stated in the permit to 

construct, the PSD approval, or the NSR approval. 

[Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000]
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 2 of 91 

SECTION I SOURCE IDENTIFICATION.............................................................. 4 

1. DESCRIPTION OF FACILITY................................................................................ 4 

2. FACILITY INVENTORY LIST............................................................................... 4 

SECTION II GENERAL CONDITIONS................................................................. 12 

1. DEFINITIONS........................................................................................................ 12 

2. ACRONYMS.......................................................................................................... 12 

3. EFFECTIVE DATE................................................................................................ 13 

4. PERMIT EXPIRATION ......................................................................................... 13 

5. PERMIT RENEWAL.............................................................................................. 13 

6. CONFIDENTIAL INFORMATION ...................................................................... 14 

7. PERMIT ACTIONS................................................................................................ 14 

8. PERMIT AVAILABILITY..................................................................................... 15 

9. REOPENING THE PART 70 PERMIT FOR CAUSE BY THE EPA .................... 15 

10. TRANSFER OF PERMIT....................................................................................... 15 

11. REVISION OF PART 70 PERMITS—GENERAL CONDITIONS....................... 15 

12. SIGNIFICANT PART 70 OPERATING PERMIT MODIFICATIONS ................ 16 

13. MINOR PERMIT MODIFICATIONS ................................................................... 17 

14. ADMINISTRATIVE PART 70 OPERATING PERMIT AMENDMENTS........... 20 

15. OFF-PERMIT CHANGES TO THIS SOURCE ..................................................... 21 

16. ON-PERMIT CHANGES TO SOURCES .............................................................. 22 

17. FEE PAYMENT ..................................................................................................... 24 

18. REQUIREMENTS FOR PERMITS TO CONSTRUCT AND APPROVALS ....... 24 

19. CONSOLIDATION OF PROCEDURES FOR PUBLIC PARTICIPATION......... 25 

20. PROPERTY RIGHTS............................................................................................. 26 

21. SEVERABILITY.................................................................................................... 26 

22. INSPECTION AND ENTRY.................................................................................. 26 

23. DUTY TO PROVIDE INFORMATION ................................................................ 26 

24. COMPLIANCE REQUIREMENTS....................................................................... 27 

25. CREDIBLE EVIDENCE ........................................................................................ 28 

26. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE .......................... 28 

27. CIRCUMVENTION............................................................................................... 28 

28. PERMIT SHIELD................................................................................................... 28 

29. ALTERNATE OPERATING SCENARIOS .......................................................... 29 

SECTION III PLANT WIDE CONDITIONS ........................................................... 30 

1. PARTICULATE MATTER FROM CONSTRUCTION AND DEMOLITION..... 30 

2. OPEN BURNING ................................................................................................... 30 

3. AIR POLLUTION EPISODE ................................................................................. 30 

4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS ................................... 30 

5. ACCIDENTAL RELEASE PROVISIONS ............................................................ 31 

6. GENERAL TESTING REQUIREMENTS............................................................. 32 

7. EMISSIONS TEST METHODS............................................................................. 32 

8. EMISSIONS CERTIFICATION REPORT ............................................................ 32 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 3 of 91 

9. COMPLIANCE CERTIFICATION REPORT ....................................................... 34 

10. CERTIFICATION BY RESPONSIBLE OFFICIAL.............................................. 34 

11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING ........................ 35 

12. GENERAL RECORDKEEPING............................................................................ 35 

13. GENERAL CONFORMITY................................................................................... 36 

14. ASBESTOS PROVISIONS .................................................................................... 36 

15. OZONE DEPLETING REGULATIONS ............................................................... 36 

16. ACID RAIN PERMIT............................................................................................. 37 

SECTION IV PLANT SPECIFIC CONDITIONS.................................................... 38 

SECTION V INSIGNIFICANT ACTIVITIES........................................................ 87 

SECTION VI STATE ONLY ENFORCEABLE CONDITIONS............................ 90 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 4 of 91 

SECTION I SOURCE IDENTIFICATION

1. Lehigh Cement Company operates a Portland cement manufacturing plant in 

Union Bridge, Maryland. The plant is located in both Carroll and Frederick 

Counties. The quarry is located in Frederick County while the main part of the 

plant is located in Carroll County. The original plant at Union Bridge was built in 

1910 and has been modernized several times including the recent 

modernization/expansion where the four existing long-dry kilns were replaced 

with one pre-heater/kiln system. 

2. FACILITY INVENTORY LIST 

1. Quarry 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

Fugitive Sources - not subject to MACT requirements 

HR1 Quarry Haul Roads Fugitive Emission Source Modified in 

2002 

SP1 Limestone Storage Pile Fugitive Emission Source Modified in 

2002 

TLU1 Limestone truck 

loading/unloading 

Fugitive Emission Source 1970 

TLU2 Truck loading/unloading Fugitive Emission Source 2002 

Point Sources - not subject to MACT requirements 

A01-009 

A01-018 

Gyratory Crusher 

Belt Conveyor #1 

Discharging through Dust Collector 

A01-012 - EP1 

1957 

A01-021 Surge Bin Discharging to Dust Collector A01-

025 – EP2 

1955 

A02-005 

A02-006 

A02-010 

A02-017 

A02-018 

A02-019 

A02-021 

Belt Conveyor #2 

Secondary Crusher 

Belt Conveyor #3 

Belt Conveyor #6 

Belt Conveyor #5 

Tertiary Crusher 

Belt Conveyor #4 

Discharging to Dust Collector A02-

008 – EP3 

1970 

A02-011 

A02-022 

A02-023 

Vibrating Screens and 

Transfer System 

Discharging to automatic bag-type 

dust arrester A02-015 &A02-012 – 

EP4 & 5 

1970 

A02-024 Belt Conveyor #7 Discharging to dust collector A02-

012 & A02-025 – EP5 & 6 

1970 with 

New DC 

B01-017 Belt Conveyor #8 Discharging to dust collector A02- 1970 with 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 5 of 91 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

025 – EP6 New DC 

2. Raw Material Handling 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

Fugitive Sources - not subject to MACT requirements 

B01-011 Enclosed Limestone Dome Between TT#3 and TT #8/9 2001 

TU1 Iron & silica truck unloading Fugitive Emissions 2002 

SP4 Silica Storage Pile Fugitive Emissions 2002 

SP5 Iron Storage Pile Fugitive Emissions 2002 

Fugitive Sources - subject to MACT requirements 

H04-001 Gypsum Bin 409 Fugitive Emissions 1970 

H04-003 Limestone Tank 416 Fugitive Emissions 1970 

H05-001 Gypsum Bin 509 Fugitive Emissions 1970 

H06-001 Gypsum Bin 609 Fugitive Emissions 1970 

H07-001 Gypsum Bin Fugitive Emissions 2001 

H08-001 Gypsum Bin Fugitive Emissions 2001 

Point Sources – not subject to MACT requirements 

B02-007 

B02-011 

B02-012 

B02-017 

Belt Conveyor 

Silica Bearing Material Bin 

Iron Bearing Material Bin 

Reversible Belt Conveyor 

Discharging to dust collector B02-

008 – EP7 

2001 

C01-002 

C01-004 

C01-006 

C01-011 

Limestone Weighfeeder 

Iron Weighfeeder 

Silica Weighfeeder 

Belt Conveyor 

Discharging to dust collector C01-

007 – EP8 

2001 

B03-004 Fly ash Blending Silo 

System 

Discharging to dust collector B03-

008 – EP9 

2002 

C01-015 Fly ash Weigh bin Discharging to dust collector C01-

019 – EP10 

2002 

C02-001 Bucket Elevator Discharging to dust collector C02-

011 & C02-021 – EP12 & 15 

2001 

C02-002 

C02-006 

C02-014 

Belt Conveyor 

100T Bin 

15 T Bin 

Discharging to dust collector C02-

011 – EP12 

2001 

TT3 Transfer Tower #3 Discharges to dust collector B04-

016&B04-011 – EP17 & 18 

2002 

B04-019 Limestone Bin Discharging to dust collector B04-

016 – EP17 

2002 

TT4 Transfer Tower #4 Discharging to dust collector B02-

019 – EP19 

2002 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 6 of 91 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

TT8/9 Transfer Tower #8/9 Discharging to dust collector B01-

018&G02-041 – EP42 & 72 

2001 

Point Sources – subject to MACT requirements 

C02-061 Belt Conveyor Discharging to dust collector C01-

007 – EP8 

2001 

C02-038 Rejects Belt Conveyor Discharging to dust collector C01-

007 & C02-021 – EP8 & 15 

2001 

C02-060 Reversible Belt Conveyor (to 

Raw Mill) 

Discharging to dust collector C02-

011 – EP12 

2001 

C02-017 Belt conveyor (from 15 T 

Bin) 

Discharging to dust collector C02-

021 – EP15 

2001 

3. Coal Feed System – (not subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Emissions 

F01-034/F01-

037 

Belt Conveyor #11/14 Fugitive Emissions 1970 

RU1 Coal Rail Unloading Fugitive Emissions 1970 

SP2 

SP3 

Coal Storage Pile 

Coal Storage Pile 

Controlled by Stockpile 

Sprinklers(F#01-008) 

2002 

TT1 Transfer Tower #1 Controlled by a Dust Suppression 

System (#F01-036) 

1970 

TT2 Transfer Tower #2 Controlled by a Dust Suppression 

System (#F01-027) 

2002 

TU2 Truck unloading Controlled by Water Spray F01-012 2002 

Points Sources 

F02-018 Belt Conveyor Discharging to dust collector F02-

033 – EP11 

2002 

F02-019 Belt Conveyor Discharging to dust collector F02-

030 & F02-033 – EP11 & 14 

2002 

TT5 

F02-006 

Transfer Tower #5 

Reclaim Elevator 

Discharging to dust collector F02-

027 – EP16 

2002 

F02-020 Reversible Belt Conveyor Discharging to dust collector F02-

010 – EP 23 

2002 

F03-001 

F03-002 

F03-003 

 Belt Conveyor 

Coal Bin weigh feeder 

Coke Bin Weighfeeder

Discharging to dust collector F03-

058 – EP 25 

2002 

TT6 Transfer Tower #6 Discharging to dust collector G02-

025 – EP41 

2002 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 7 of 91 

4. Raw Meal Feed (subject to MACT requirements)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

C03-034 

C03-035 

C03-040 

C03-042 

Airslide 

Airslide 

Airslide 

Airslide 

Discharging to dust collector C03-

001 – EP20 

2002 

C03-045 Airslide Discharging to dust collector C03-

047/C03-050 – EP 21 & 22 

2002 

C03-008 

C03-054 

C04-066 

Airslide 

Airslide 

Airslide 

Discharging to dust collector C03-

050 – EP22 

2002 

C03-046 Bucket Elevator Discharging to dust collector D01-

037 & C03-030 – EP 24 & 26 

2002 

C03-017 

D01-001 

D01-003 

D01-002 

Airslide 

Blending Silo 

Recirculation Airslide 

Recirculation Airslide 

Discharging to dust collector D01-

037 –EP24 

2002 

C03-010 

C03-013 

Airslide 

Airslide 

Discharging to dust collector C03-

030 – EP26 

2002 

D01-020 

D02-004 

D02-006 

D02-017 

D02-019 

185 MT Feed Bin 

Airslide 

Flow Meter 

Airslide 

Flow Meter 

Discharging to dust collector D01-

034 – EP27 

2002 

D01-023 

D01-026 

D02-007 

D02-020 

Airslide 

Airslide 

Airslide 

Airslide 

Discharging to dust collector D01-

040 – EP28 

2002 

D02-010 

D02-023 

D02-049 

Airslide 

Airslide 

Airslide 

Discharging to dust collector D02-

041 – EP 29 

2002 

D02-025 

D02-026 

Bucket Elevator 

Bucket Elevator 

Discharging to dust collector D02-

041/D02-027 – EP 29 and 31 

2002 

D02-033 

D02-045 

D02-047 

Airslide 

Airslide 

Airslide 

Discharging to dust collector D02-

027 – EP31 

2002 

5. Kiln, Raw and Coal Mill – Point Sources (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

C02-025 

E02-001 

E01-001 

Raw Mill 

Kiln 

Precalciner/preheater 

Discharging to dust collector C04-

014 – EP13 

2001 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 8 of 91 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

F03-016 Coal Mill System Discharging to dust collector dust 

collectors F03-028, 032, 036, 040, 

044, & 048 – EP13 

2001 

6. Clinker Cooler and Main Pan Conveyor – Point Sources (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

E03-001 

G01-001 

Clinker Cooler 

Pan conveyor 

Discharging to Dust Collector #E04-

016 – EP32 

2001 

7. Clinker Handling and Craneway (subject to MACT requirements)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

Fugitive Sources 

CWAY Craneway Fugitive emission source 1970 

G04-040 Drag Conveyor B2 Fugitive emission source 1970 

H04-004 Clinker Bin 403 Fugitive emission source 1970 

H05-004 Clinker Bin 503 Fugitive emission source 1970 

H06-004 Clinker Bin 603 Fugitive emission source 1970 

H07-004 Clinker Bin Fugitive emission source New 

TU3 Gypsum Truck Unloading Fugitive emission source New 

TU4 Truck Unloading Fugitive emission source New 

Point Sources 

G04-014 

G04-020 

750 MT Clinker Bin 

Belt Conveyor 

discharging to Dust Collector G04-

011 – EP33 

2001 

H09-000 Semifinishing Grinding 

System 

Discharging to Collector H09-059 – 

EP33 

2001 

H09-028 Bucket Elevator Discharging to Dust Collector H09-

051 – EP33 

2000 

H09-047 

H09-058 

Bucket Elevator 

Belt Conveyor 

Discharging to Collector H09-059 – 

EP33 

2000 

G04-010 Bucket Elevator Discharging to dust collector G04-

011 & G04-034– EP33 & 34 

2001 

H09-062 Reversible Belt Conveyor Discharging to dust collector H09-

051 & H09-082 – EP33 & 36 

2000 

H09-031 Belt Conveyor Discharging to Dust Collector H09-

059 & H09-033 – EP33 and 44 

2000 

G04-009 

G04-016 

G04-056 

Belt Conveyor 

Belt Feeder 

100 MT Clinker Bin 

Weighfeeder 

Discharging to dust collector G04-

034 EP-34 

2002 

H09-019 Weighfeeder Discharging to dust collector H09- 2001 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 9 of 91 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

H09-023 

H09-024 

100 MT Gypsum Bin 

Weighfeeder 

Belt Conveyor (from weigh 

feeders) 

025 – EP35 

H09-021 

H09-066 

H09-020 

100 MT Clinker Bin 

Weighfeeder 

Belt Conveyor 

100 MT Slag/Clinker Bin 

Weighfeeder 

Discharging to dust collector H09-

082 – EP36 

2002 

G01-012 Clinker Storage Silo Discharging to Dust Collector G01-

009 – EP37 

2001 

G02-002 Transfer Tower #13 

Belt Conveyor 

Discharging to dust collector G02-

047 – EP38 

2002 

G02-002 Transfer Tower #12 

Belt Conveyor 

Discharging to dust collector G02-

044 – EP39 

2002 

G02-002 Transfer Tower #11 

Belt Conveyor 

Discharging to dust collector G02-

021 – EP40 

2002 

TT6 Transfer Tower #6 Discharging to dust collector G02-

025 – EP41 

New 

TT8/9 Transfer Tower #8/9 Discharging to dust collector B01-

018 & G02-041– EP42 & 72 

New 

TL1 Clinker Truck/Rail 

Loadout 

Discharging to dust collector G02-

053 – EP43 

New 

H09-036 

H09-041 

H09-046

Bin 

Roll Press 

Belt Conveyor

Discharging to dust collector H09-

033 – EP44 

New 

TT9/10 Transfer Tower #9/10 Discharging to dust collector G03-

011 – EP45 

New 

TT7 Transfer Tower #7 Discharging to dust collector G03-

004 – EP46 

New 

H09-088 Metal Reclamation System 

Belt Conveyor 

Discharging to dust collector G09-

094 – EP47 

New 

8. Finish Mill Systems (subject to MACT requirements)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

H04-006 

H04-014 

Belt Conveyor (FM #4) 

System 

Finish Mill #4 System 

Discharging to Dust Collector H04-

044 – EP48 

1970 

H06-014 

H06-017 

H06-037 

Finish Mill #6 System 

Cyclone 642 (FM#6 

System) 

Discharging to Dust Collector H06-

044 – EP49 

1970 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 10 of 91 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

Separator 627 (FM#6 

System) 

H07-014 Finish Mill #7 System Discharging to Baghouse H07-

056/H07-057 – EP50 

2002 

H07-018 

H07-069 

H07-070 

Finished Cement Transfer 

System 

Bucket Elevator 

Airslide 

Discharging to Baghouse H07-

056/H07-057 – EP50 

2001 

H05-014 Finish Mill #5 System Discharging to dust collector H05-

044 - EP51 

1970 

H08-014 

H08-017 

H08-037 

H08-067 

Finish Mill #8 System 

Separator (FM #8 System) 

Cyclone (FM#8 System) 

Cyclone (FM#8 System) 

Discharging to dust collector H08-

056 – EP52 

2002 

9. Cement Loadout (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

H07-040 

H07-071 

H08-040 

H08-064 

H10-001 

H10-006 

Cement Cooler 

Airslide 

Cement Cooler 

Airslide 

Airslide 

Bucket Elevator 

Discharging to dust collector H10-

113 – EP53 

2002 

H10-167 

H10-176 

Airslide 

Bucket Elevator 

Discharging to dust collector H10-

181 – EP54 

2002 

H10-177 

I01-033 

Airslide 

Day Tank 

Discharging to dust collector H10-

179 – EP55 

2002 

F1-F8, G1-G8, 

H1-H8, J1-J8 

Product Silos Discharging to dust collectors H10-

221, H10-224, H10-252 & H10-254 

– EP 58, 60, 61, 74 and 75 

1970 & 

2003 

I02-289 

TL2 

Feed Bin 

Truck Day Tank Loadout 

Discharging to #I02-290 – EP56 2002 

I03/I04 Packaging and Palletizing Discharges to the Existing Baghouse 

EASTPKHS - EP61 

1970 

H10-007 

H10-010 

H10-124 

H10-125 

Airslide 

Bucket Elevator 

Airslide 

Airslide 

Discharging to Dust Collector H10-

119 – EP62 

2001 

TL4 Bulk Loadout System Discharging to dust collectors I02-

204, -208, -224, -228, -244, -248, 

-264, & -268 – EP 64, 65, 66, 67, 

1970 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 11 of 91 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation

68, 69, 70, & 71 

10. Waste Dust Handling – ( not subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

C04-037 Bucket Elevator Discharging to dust collector C04-

050&C04-075 – EP 57 & 63 

2002 

C04-038 

C04-068 

600 T Bin 

Airslide 

Discharging to #C04-050 – EP57 2002 

C04-070 

C04-072 

C04-074 

TL3 

Airslide 

Airslide 

Airslide 

Truck Waste Dust Loadout 

Discharges to dust collector C04-

075 – EP63 

2002 

11. Miscellaneous Sources Venting Inside Building (subject to MACT requirements) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

G04-018 Belt conveyor Venting through Dust Collector 

G04-037 located inside – NP1 

New 

G04-019 CE2 Bucket Elevator Venting through Dust Collector 

G04-037 located inside – NP1 

1970 

G04-031 Drag Conveyor B3 Venting through Dust Collector 

H09-073 located inside – NP2 

1970 

H09-058 Belt Conveyor Venting through Dust Collector 

H09-073 located inside – NP2 

2000 

H09-075 90T Bin Venting through Dust Collector 

H09-073 located inside – NP2 

2000 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 12 of 91 

SECTION II GENERAL CONDITIONS

1. DEFINITIONS 

[COMAR 26.11.01.01] and [COMAR 26.11.02.01-26] 

The words or terms in this Part 70 permit shall have the meaning established in 

COMAR 26.11.01 and .02 unless otherwise stated in this permit. 

2. ACRONYMS 

ARMA Air and Radiation Management Administration 

BACT Best Available Control Technology 

Btu British Thermal Unit 

CAAA Clean Air Act (amended) 

CAM Compliance Assured Monitoring 

CEM Continuous Emission Monitor 

CFR Code of Federal Regulations 

CO Carbon Monoxide 

COMAR Code of Maryland Regulations 

EPA Environmental Protection Agency 

FR Federal Register 

gr grains 

HAP Hazardous Air Pollutant 

MACT Maximum Achievable Control Technology 

MDE Maryland Department of the Environment 

NESHAPS National Emission Standards for Hazardous Air Pollutants 

NOx Nitrogen Oxides 

NSPS New Source Performance Standards 

NSR New Source Review 

OTR Ozone Transport Region 

PM Particulate Matter 

PM10 Particulate Matter with Nominal Aerodynamic Diameter 

 of 10 micrometers or less 

ppm Parts per Million 

ppb Parts per Billion 

PSD Prevention of Significant Deterioration 

PTC Permit to Construct 

PTO Permit to Operate (State) 

SIC Standard Industrial Classification 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

TAP Toxic Air Pollutant 

tpy Tons Per Year 

VE Visible Emissions 

VOC Volatile Organic Compounds 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 13 of 91 

3. EFFECTIVE DATE 

The effective date of the conditions in this Part 70 permit is the date of permit 

issuance, unless otherwise stated in the permit. 

4. PERMIT EXPIRATION 

[COMAR 26.11.03.13B(2)]

Upon expiration of this permit, the terms of the permit will automatically continue 

to remain in effect until a new Part 70 permit is issued for this facility provided 

that the Permittee has submitted a timely and complete application and has paid 

applicable fees under COMAR 26.11.02.16. 

Otherwise, upon expiration of this permit the right of the Permittee to operate this 

facility is terminated. 

5. PERMIT RENEWAL 

[COMAR 26.11.03.02B(3)] and [COMAR 26.11.03.02E] 

The Permittee shall submit to the Department a complete application for renewal 

of this Part 70 permit at least 6 months, but not more than 12 months, before the 

expiration of the permit. Upon submitting a completed application, the Permittee 

may continue to operate this facility pending final action by the Department on 

the renewal. 

The Permittee, upon becoming aware that any relevant facts were omitted or 

incorrect information was submitted in the permit application, shall promptly 

submit such supplementary facts or corrected information no later than 10 days 

after becoming aware that this occurred. The Permittee shall also provide 

additional information as necessary to address any requirements that become 

applicable to the facility after the date a complete application was submitted, but 

prior to the release of a draft permit. This information shall be submitted to the 

Department no later than 20 days after a new requirement has been adopted. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 14 of 91 

6. CONFIDENTIAL INFORMATION 

[COMAR 26.11.02.02G]

In accordance with the provisions of the State Government Article, Sec. 10-611 et 

seq., Annotated Code of Maryland, all information submitted in an application 

shall be considered part of the public record and available for inspection and 

copying, unless the Permittee claims that the information is confidential when it is 

submitted to the Department. At the time of the request for inspection or copying, 

the Department will ascertain the confidentiality of the information. The 

Permittee, when requesting confidentiality, shall identify the information in a 

manner specified by the Department and, when requested by the Department, 

promptly provide specific reasons supporting the claim of confidentiality. 

Information submitted to the Department without a request that the information be 

deemed confidential may be made available to the public. Subject to approval of 

the Department, the Permittee may provide a summary of confidential 

information that is suitable for public review. The contents of this Part 70 permit 

are not subject to confidential treatment. 

7. PERMIT ACTIONS 

[COMAR 26.11.03.06E(3)] and [COMAR 26.11.03.20A] 

This Part 70 permit may be revoked or reopened and revised for cause. The filing 

of an application by the Permittee for a permit revision or renewal; or a 

notification of termination, planned changes or anticipated noncompliance by the 

facility, does not stay a term or condition of this permit. 

The Department shall reopen and revise, or revoke the Permittee's Part 70 permit 

under the following circumstances: 

a. Additional requirements of the Clean Air Act become applicable to this 

facility and the remaining permit term is 3 years or more; 

b. The Department or the EPA determines that this Part 70 permit contains a 

material mistake, or is based on false or inaccurate information supplied 

by or on the behalf of the Permittee; 

c. The Department or EPA determines that this Part 70 permit must be 

revised or revoked to assure compliance with applicable requirements of 

the Clean Air Act; or 

d. Additional requirements become applicable to an affected source under 

the Federal Acid Rain Program. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 15 of 91 

8. PERMIT AVAILABILITY 

[COMAR 26.11.02.13G]

The Permittee shall maintain this Part 70 permit in the vicinity of the facility for 

which it was issued, unless it is not practical to do so, and make this permit 

immediately available to officials of the Department upon request. 

9. REOPENING THE PART 70 PERMIT FOR CAUSE BY THE EPA 

[COMAR 26.11.03.20B]

The EPA may terminate, modify, or revoke and reissue a permit for cause as 

prescribed in 40 CFR § 70.7(g). 

10. TRANSFER OF PERMIT 

[COMAR 26.11.02.02E]

The Permittee may not transfer this Title V (Part 70) permit except as provided in 

COMAR 26.11.03.15. 

11. REVISION OF PART 70 PERMITS—GENERAL CONDITIONS 

[COMAR 26.11.03.14] and[COMAR 26.11.03.06A(8)]

a. The Permittee shall submit an application to the Department to revise a 

Part 70 permit when required under COMAR 26.11.03.15-.17. 

b. When applying for a revision to a Part 70 permit, the Permittee shall 

comply with the requirements of COMAR 26.11.03.02 and .03 except that 

the application for a revision need only include information listed that is 

related to the proposed change to the source and revision to the permit. 

This information shall be sufficient to evaluate the proposed change and to 

determine whether it will comply with all applicable requirements of the 

Clean Air Act. 

c. The Permittee may not change any provision of a compliance plan or 

schedule in a Part 70 permit as an administrative permit amendment or as 

a minor permit modification unless the change has been approved by the 

Department in writing. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 16 of 91 

d. A permit revision is not required for a change that is provided for in this 

permit relating to approved economic incentives, marketable permits, 

emissions trading, and other similar programs. 

12. SIGNIFICANT PART 70 OPERATING PERMIT MODIFICATIONS 

[COMAR 26.11.03.17] 

The Permittee may apply to the Department to make a significant modification to 

its Part 70 Permit as provided in COMAR 26.11.03.17 and in accordance with the 

following conditions: 

a. A significant modification is a revision to the federally enforceable 

provisions in the permit that is not an administrative or minor permit 

modification, as defined in COMAR 26.11.03.15 or 26.11.03.16. 

b. This permit does not preclude the Permittee from making changes, 

consistent with the provisions of COMAR 26.11.03.17, that would make 

the permit or particular terms and conditions of the permit irrelevant, such 

as by shutting down or reducing the level of operation of a source or of an 

emission unit within the source. Air pollution control equipment may not 

be shut down or its level of operation reduced if doing so would violate 

any term of this permit. 

c. Significant permit modifications are subject to all requirements of 

COMAR 26.11.03 as they apply to permit issuance and renewal, including 

the requirements for applications, public participation, and review by 

affected states and EPA, except: 

(1) An application needs only to include information pertaining to the 

proposed change to the source and modification of this permit, 

including a description of the change and modification, the 

emissions resulting from the change and modification, and any 

new applicable requirements of the Clean Air Act that will apply if 

the change occurs; 

(2) Public participation, and review by affected states and EPA, is 

limited to only the application and those federally enforceable 

terms and conditions of the Part 70 permit that are affected by the 

significant permit modification. 

d. As provided in COMAR 26.11.03.15B(5), an administrative permit 

amendment may be used to make a change that would otherwise require a 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 17 of 91 

significant permit modification if procedures for enhanced preconstruction 

review of the change are followed that satisfy the requirements of 40 CFR 

Sec. 70.7(d)(1)(v). 

e. Before making a change that qualifies as a significant permit modification, 

the Permittee shall obtain all permits to construct and approvals required 

by COMAR 26.11.02. 

f. The Permittee may not make a significant permit modification that results 

in a violation of any applicable requirement of the Clean Air Act. 

g. The permit shield in COMAR 26.11.03.23 applies to a final significant 

permit modification that has been issued by the Department, to the extent 

applicable under COMAR 26.11.03.23. 

13. MINOR PERMIT MODIFICATIONS 

[COMAR 26.11.03.16] 

The Permittee may apply to the Department to make a minor modification to the 

federally enforceable provisions of this Part 70 permit as provided in COMAR 

26.11.03.16 and in accordance with the following conditions: 

a. A minor permit modification is a Part 70 permit revision that: 

(1) Does not result in a violation of any applicable requirement of the 

Clean Air Act; 

(2) Does not significantly revise existing federally enforceable 

monitoring, including test methods, reporting, record keeping, or 

compliance certification requirements except by: 

(a) Adding new requirements, 

(b) Eliminating the requirements if they are rendered 

meaningless because the emissions to which the 

requirements apply will no longer occur, or 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 18 of 91 

(c) Changing from one approved test method for a pollutant 

and source category to another; 

(3) Does not require or modify a: 

(a) Case-by case determination of a federally enforceable 

emission standard, 

(b) Source specific determination for temporary sources of 

ambient impacts, or 

(c) Visibility or increment analysis; 

(4) Does not seek to establish or modify a federally enforceable permit 

term or condition for which there is no corresponding underlying 

applicable requirement of the Clean Air Act, but that the Permittee 

has assumed to avoid an applicable requirement to which the 

source would otherwise be subject, including: 

(a) A federally enforceable emission standard applied to the 

source pursuant to COMAR 26.11.02.03 to avoid 

classification as a Title I modification; and 

(b) An alternative emission standard applied to an emissions 

unit pursuant to regulations promulgated under Sec. 

112(i)(5) of the Clean Air Act; 

(5) Is not a Title I modification; and 

(6) Is not required under COMAR 26.11.03.17 to be processed as a 

significant modification to this Part 70 permit. 

b. Application for a Minor Permit Modification. 

The Permittee may submit to the Department an application for a minor 

permit modification that satisfies the requirements of COMAR 26.11.03 

which includes the following: 

(1) A description of the proposed change, the emissions resulting from 

the change, and any new applicable requirements that will apply if 

the change is made; 

(2) The proposed minor permit modification; 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 19 of 91 

(3) Certification by a responsible official, in accordance with COMAR 

26.11.02.02F that: 

(a) The proposed change meets the criteria for a minor permit 

modification, and 

(b) The Permittee has obtained or applied for all required 

permits to construct required by COMAR 26.11.03.16 with 

respect to the proposed change; 

(4) Completed forms for the Department to use to notify the EPA and 

affected states, as required by COMAR 26.11.03 .07--.12. 

c. Permittee’s Ability to Make Change 

(1) For changes proposed as minor permit modifications to this permit 

that will require the applicant to obtain a permit to construct, the 

permit to construct must be issued prior to the new change. 

(2) During the period of time after the Permittee applies for a minor 

modification but before the Department acts in accordance with 

COMAR 26.11.03.16F(2): 

(a) The Permittee shall comply with applicable requirements of 

the Clean Air Act related to the change and the permit 

terms and conditions described in the application for the 

minor modification. 

(b) The Permittee is not required to comply with the terms and 

conditions in the permit it seeks to modify. If the Permittee 

fails to comply with the terms and conditions in the 

application during this time, the terms and conditions of 

both this permit and the application for modification may 

be enforced against it. 

d. The Permittee is subject to enforcement action if it is determined at any 

time that a change made under COMAR 26.11.03.16I is not within the 

scope of this regulation. 

e. Minor permit modification procedures may be used for the use of 

economic incentives, marketable permits, emissions trading, and other 

similar approaches, but only to the extent that the minor permit 

modification procedures provide as part of the Maryland SIP or other 

applicable requirements of the Clean Air Act. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 20 of 91 

14. ADMINISTRATIVE PART 70 OPERATING PERMIT AMENDMENTS 

[COMAR 26.11.03.15]

The Permittee may apply to the Department to make an administrative permit 

amendment as provided in COMAR 26.11.03.15 and in accordance with the 

following conditions: 

a. An application for an administrative permit amendment shall: 

(1) Be in writing; 

(2) Include a statement certified by a responsible official that the 

proposed amendment meets the criteria in COMAR 26.11.03.15 

for an administrative permit amendment, and 

(3) Identify those provisions of this part 70 permit for which the 

amendment is requested, including the basis for the request. 

b. An administrative permit amendment: 

(1) Is a correction of a typographical error; 

(2) Identifies a change in the name, address, or phone number of a 

person identified in this permit, or a similar administrative change 

involving the Permittee or other matters which are not directly 

related to the control of air pollution; 

(3) Requires more frequent monitoring or reporting by the Permittee; 

(4) Allows for a change in ownership or operational control of a 

source for which the Department determines that no other revision 

to the permit is necessary and is documented as per COMAR 

26.11.03.15B(4); 

(5) Incorporates into this permit the requirements from preconstruction 

review permits or approvals issued by the Department in 

accordance with COMAR 26.11.03.15B(5), but only if it satisfies 

40CFR70.7(d)(1)(v); 

(6) Incorporates any other type of change, as approved by the EPA, 

which is similar to those in COMAR 26.11.03.15B(1)--(4); 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 21 of 91 

(7) Notwithstanding COMAR 26.11.03.15B(1)--(6) for purposes of 

the acid rain portion of a Part 70 permit, are governed by 

regulations promulgated under Title IV of the Clean Air Act; or 

(8) Incorporates any change to a term or condition specified as 

State-only enforceable, if the Permittee has obtained all necessary 

permits to construct and approvals that apply to the change. 

c. The Permittee may make the change addressed in the application for an 

administrative amendment upon receipt by the Department of the 

application, if all permits to construct or approvals otherwise required by 

COMAR 26.11.02 prior to making the change have first been obtained 

from the Department. 

d. The permit shield in COMAR 26.11.03.23 applies to administrative permit 

amendments made under Sec. B(5) of COMAR 26.11.03.15, but only after 

the Department takes final action to revise the permit. 

e. The Permittee is subject to enforcement action if it is determined at any 

time that a change made under COMAR 26.11.03.15 is not within the 

scope of this regulation. 

15. OFF-PERMIT CHANGES TO THIS SOURCE 

[COMAR 26.11.03.19]

The Permittee may make off-permit changes to this facility as provided in 

COMAR 26.11.03.19 and in accordance with the following conditions: 

a. The Permittee may make a change to this permitted facility that is not 

addressed or prohibited by the federally enforceable conditions of this Part 

70 permit without obtaining a Part 70 permit revision if: 

(1) The Permittee has obtained all permits and approvals required by 

COMAR 26.11.02 and .03; 

(2) The change is not subject to any requirements under Title IV of the 

Clean Air Act; 

(3) The change is not a Title I modification; and 

(4) The change does not violate an applicable requirement of the Clean 

Air Act or a federally enforceable term or condition of the permit. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 22 of 91 

b. For a change that qualifies under COMAR 26.11.03.19, the Permittee shall 

provide contemporaneous written notice to the Department and the EPA, 

except for a change to an emissions unit or activity that is exempt from the 

Part 70 permit application, as provided in COMAR 26.11.03.04. This 

written notice shall describe the change, including the date it was made, 

any change in emissions, including the pollutants emitted, and any new 

applicable requirements of the Clean Air Act that apply as a result of the 

change. 

c. Upon satisfying the requirements of COMAR 26.11.03.19, the Permittee 

may make the proposed change. 

d. The Permittee shall keep a record describing: 

(1) Changes made at the facility that result in emissions of a regulated 

air pollutant subject to an applicable requirement of the Clean Air 

Act, but not otherwise regulated under this permit; and 

(2) The emissions resulting from those changes. 

e. Changes that qualify under COMAR 26.11.03.19 are not subject to the 

requirements for Part 70 revisions. 

f. The Permittee shall include each off-permit change under COMAR 

26.11.03.19 in the application for renewal of the Part 70 permit. 

g. The permit shield in COMAR 26.11.03.23 does not apply to off-permit 

changes made under COMAR 26.11.03.19. 

h. The Permittee is subject to enforcement action if it is determined that an 

off-permit change made under COMAR 26.11.03.19 is not within the 

scope of this regulation. 

16. ON-PERMIT CHANGES TO SOURCES 

[COMAR 26.11.03.18]

The Permittee may make on-permit changes that are allowed under Section 

502(b)(10) of the Clean Air Act as provided in COMAR 26.11.03.18 and in 

accordance with the following conditions: 

a. The Permittee may make a change to this facility without obtaining a 

revision to this Part 70 permit, if: 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 23 of 91 

(1) The change is not a Title I modification; 

(2) The change does not result in emissions in excess of those 

expressly allowed under the federally enforceable provisions of 

this Part 70 permit for the permitted facility or for an emissions 

unit within the facility, whether expressed as a rate of emissions or 

in terms of total emissions; 

(3) The Permittee has obtained all permits and approvals required by 

COMAR 26.11.02 and .03; 

(4) The change does not violate an applicable requirement of the Clean 

Air Act; 

(5) The change does not violate a federally enforceable permit term or 

condition related to monitoring, including test methods, record 

keeping, reporting, or compliance certification requirements; 

(6) The change does not violate a federally enforceable permit term or 

condition limiting hours of operation, work practices, fuel usage, 

raw material usage, or production levels if the term or condition 

has been established to limit emissions allowable under this 

permit; 

(7) If applicable, the change does not modify a federally enforceable 

provision of a compliance plan or schedule in this Part 70 permit 

unless the Department has approved the change in writing; and 

(8) This permit does not expressly prohibit the change under COMAR 

26.11.03.18. 

b. The Permittee shall notify the Department and the EPA in writing of a 

proposed on-permit change under COMAR 26.11.03.18 not later than 7 

days before the change is made. The written information shall include the 

following information: 

(1) A description of the proposed change; 

(2) The date on which the change is proposed to be made; 

(3) Any change in emissions resulting from the change, including the 

pollutants emitted; 

(4) Any new applicable requirement of the Clean Air Act; and 
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UNION BRIDGE MARYLAND 

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(5) Any permit term or condition that would no longer apply. 

c. The responsible official of this facility shall certify in accordance with 

COMAR 26.11.02.02F that the proposed change meets the criteria for the 

use of on-permit changes under COMAR 26.11.03.18. 

d. The Permittee shall attach a copy of each notice required by condition b. 

above to this Part 70 permit. 

e. On-permit changes that qualify under COMAR 26.11.03.18 are not subject 

to the requirements for Part 70 permit revisions. 

f. Upon satisfying the requirements under COMAR 26.11.03.18, the 

Permittee may make the proposed change. 

g. The permit shield in COMAR 26.11.03.23 does not apply to on-permit 

changes under COMAR 26.11.03.18. 

h. The Permittee is subject to enforcement action if it is determined that a onpermit change made under COMAR 26.11.03.18 is not within the scope of 

the regulation or violates any requirement of the State air pollution control 

law. 

17. FEE PAYMENT 

[COMAR 26.11.02.16A(2) & (5)(b)] 

a. The fee for this Part 70 permit is as prescribed in Regulation .19 of 

COMAR 26.11.02. 

b. The fee is due on and shall be paid on or before each 12-month 

anniversary date of the permit. 

c. Failure to pay the annual permit fee constitutes cause for revocation of the 

permit by the Department. 

18. REQUIREMENTS FOR PERMITS TO CONSTRUCT AND APPROVALS 

[COMAR 26.11.02.09] 

The Permittee may not construct or modify or cause to be constructed or modified 

any of the following sources without first obtaining, and having in current effect, 

the specified permits to construct and approvals: 
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a. New Source Review source, as defined in COMAR 26.11.01.01, approval; 

b. Prevention of Significant Deterioration source, as defined in COMAR 

26.11.01.01, approval; 

c. New Source Performance Standard source, as defined in COMAR 

26.11.01.01, permit to construct; 

d. National Emission Standards for Hazardous Air Pollutants source, as 

defined in COMAR 26.11.01.01, permit to construct; 

e. A stationary source of lead that discharges one ton per year or more of 

lead or lead compounds measured as elemental lead, permit to construct; 

f. All stationary sources of air pollution, including installations and air 

pollution control equipment, except as listed in COMAR 26.11.02.10, 

permit to construct. 

g. In the event of a conflict between the applicability of (a-e) above and an 

exemption listed in COMAR 26.11.02.10, the provision that requires a 

permit applies. 

h. Approval of a PSD or NSR source by the Department does not relieve the 

Permittee obtaining an approval from also obtaining all permits to 

construct required by (c-g) above. 

19. CONSOLIDATION OF PROCEDURES FOR PUBLIC PARTICIPATION 

[COMAR 26.11.02.11C] and [COMAR 26.11.03.01K]

The Permittee may request the Department to authorize special procedures for the 

Permittee to apply simultaneously, to the extent possible, for a permit to construct 

and a revision to this permit. 

These procedures may provide for combined public notices, informational 

meetings, and public hearings for both permits but may not adversely affect the 

rights of a person, including EPA and affected states, to obtain information about 

the application for a permit, to comment on an application, or to challenge a 

permit that is issued. 

These procedures may not alter any existing permit procedures or time frames. 
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20. PROPERTY RIGHTS 

[COMAR 26.11.03.06E(4)]

This Part 70 permit does not convey any property rights of any sort, or any 

exclusive privileges. 

21. SEVERABILITY 

[COMAR 26.11.03.06A(5)]

If any portion of this Part 70 permit is challenged, or any term or condition 

deemed unenforceable, the remainder of the requirements of the permit continues 

to be valid. 

22. INSPECTION AND ENTRY 

[COMAR 26.11.03.06G(3)]

The Permittee shall allow employees and authorized representatives of the 

Department, the EPA, and the local Health Department, upon presentation of 

credentials or other documents as may be required by law, to: 

a. Enter at a reasonable time without delay and without prior notification the 

Permittee's property where a Part 70 source is located, emissions-related 

activity is conducted, or records required by this permit are kept; 

b. Have access to and make copies of records required by the permit; 

c. Inspect all emissions units within the facility subject to the permit and all 

related monitoring systems, air pollution control equipment, and practices 

or operations regulated or required by the permit; and 

d. Sample or monitor any substances or parameters at or related to the 

emissions units at the facility for the purpose of determining compliance 

with the permit. 

23. DUTY TO PROVIDE INFORMATION 

[COMAR 26.11.03.06E(5)]
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The Permittee shall furnish to the Department, within a reasonable time specified 

by the Department, information requested in writing by the Department in order 

to determine whether the Permittee is in compliance with the federally 

enforceable conditions of this Part 70 permit, or whether cause exists for revising 

or revoking the permit. Upon request, the Permittee shall also furnish to the 

Department records required to be kept under the permit. 

For information claimed by the Permittee to be confidential and therefore 

potentially not discloseable to the public, the Department may require the 

Permittee to provide a copy of the records directly to the EPA along with a claim 

of confidentiality. 

The Permittee shall also furnish to the Department, within a reasonable time 

specified by the Department, information or records requested in writing by the 

Department in order to determine if the Permittee is in compliance with the Stateonly enforceable conditions of this permit. 

24. COMPLIANCE REQUIREMENTS 

[COMAR 26.11.03.06.E(1)], [COMAR 26.11.03.06A(11)] and 

[COMAR 26.11.02.05] 

The Permittee shall comply with the conditions of this Part 70 permit. 

Noncompliance with the permit constitutes a violation of the Clean Air Act, 

and/or the Environmental Article Title 2 of the Annotated Code of Maryland and 

may subject the Permittee to: 

a. Enforcement action, 

b. Permit revocation or revision, 

c. Denial of the renewal of a Part 70 permit, or 

d. Any combination of these actions. 

The conditions in this Part 70 permit are enforceable by EPA and citizens under 

the Clean Air Act except for the State-only enforceable conditions. 

Under Environmental Article Sec. 2-609, Annotated Code of Maryland, the 

Department may seek immediate injunctive relief against a person who violates 

this permit in such a manner as to cause a threat to human health or the 

environment. 
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25. CREDIBLE EVIDENCE 

Nothing in this permit shall be interpreted to preclude the use of credible evidence 

to demonstrate noncompliance with any term of this permit. 

26. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE 

[COMAR 26.11.03.06E(2)]

The need to halt or reduce activity in order to comply with the conditions of this 

permit may not be used as a defense in an enforcement action. 

27. CIRCUMVENTION 

[COMAR 26.11.01.06]

The Permittee may not install or use any article, machine, equipment or other 

contrivance, the use of which, without resulting in a reduction in the total weight 

of emissions, conceals or dilutes an emission which would otherwise constitute a 

violation of any applicable air pollution control regulation. 

28. PERMIT SHIELD 

[COMAR 26.11.03.23]

A permit shield as described in COMAR 26.11.03.23 shall only apply to terms 

and conditions in this Part 70 permit that have been specifically identified as 

covered by the permit shield. Neither this permit nor COMAR 26.11.03.23 alters 

the following: 

a. The emergency order provisions in Sec. 303 of the Clean Air Act, 

including the authority of EPA under that section; 

b. The liability of the Permittee for a violation of an applicable requirement 

of the Clean Air Act before or when this permit is issued or for a violation 

that continues after issuance; 

c. The requirements of the Acid Rain Program, consistent with Sec. 408(a) 

of the Clean Air Act; 
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d. The ability of the Department or EPA to obtain information from a source 

pursuant to Maryland law and Sec. 114 of the Clean Air Act; or 

e. The authority of the Department to enforce an applicable requirement of 

the State air pollution control law that is not an applicable requirement of 

the Clean Air Act. 

29. ALTERNATE OPERATING SCENARIOS 

[COMAR 26.11.03.06A(9)] 

For all alternate operating scenarios approved by the Department and contained 

within this permit, the Permittee, while changing from one approved scenario to 

another, shall contemporaneously record in a log maintained at the facility each 

scenario under which the emissions unit is operating and the date and time the 

scenario started and ended. 
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SECTION III PLANT WIDE CONDITIONS 

1. PARTICULATE MATTER FROM CONSTRUCTION AND 

DEMOLITION 

[COMAR 26.11.06.03D]

The Permittee shall not cause or permit any building, its appurtenances, or a road 

to be used, constructed, altered, repaired, or demolished without taking reasonable 

precautions to prevent particulate matter from becoming airborne. 

2. OPEN BURNING 

[COMAR 26.11.07] 

Except as provided in COMAR 26.11.07.04, the Permittee may not cause or 

permit an open fire from June 1 through August 31 of any calendar year. Prior to 

any open burning, the Permittee must request and receive approval from the 

Department. 

3. AIR POLLUTION EPISODE 

[COMAR 26.11.05.04]

When requested by the Department, the Permittee shall prepare in writing standby 

emissions reduction plans, consistent with good industrial practice and safe 

operating procedures, for reducing emissions creating air pollution during periods 

of Alert, Warning, and Emergency of an air pollution episode. 

4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS 

[COMAR 26.11.01.07] and [COMAR 26.11.03.06C(7)]

The Permittee shall comply with the following conditions for occurrences of 

excess emissions and deviations from requirements of this permit including the 

State-only enforceable section: 

a. Report any deviation from permit requirements that could endanger 

human health or the environment, by orally notifying the Department 

immediately upon discovery of the deviation; 
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b. Promptly report all occurrences of excess emissions that are expected to 

last for one hour or longer by orally notifying the Department of the onset 

and termination of the occurrence; 

c. When requested by the Department the Permittee shall report all 

deviations from permit conditions, including those attributable to 

malfunctions as defined in COMAR 26.11.01.07A, within 5 days of the 

request by submitting a written description of the deviation to the 

Department. The written report must include the cause, dates and times of 

the onset and termination of the deviation, as well as the action planned or 

taken to reduce, eliminate, and prevent the recurrence of the deviation; 

d. The Permittee shall submit to the Department semi-annual monitoring 

reports that confirm that all required monitoring was performed, and that 

provide accounts of all deviations from permit requirements that occurred 

during the reporting periods. Reporting periods shall be January 1 through 

June 30 and July 1 through December 31, and reports shall be submitted 

within 30 days of the end of each reporting period. Each account of 

deviation shall include a description of the deviation, the dates and times 

of onset and termination, identification of the person who observed or 

discovered the deviation, causes and corrective actions taken, and actions 

taken to prevent recurrence. If no deviations from permit conditions 

occurred during a reporting period, the Permittee shall submit a written 

report that so states. 

e. When requested by the Department, the Permittee shall submit a written 

report to the Department within 10 days of receiving the request 

concerning an occurrence of excess emissions. The report shall contain 

the information required in COMAR 26.11.01.07C(2). 

5. ACCIDENTAL RELEASE PROVISIONS 

[COMAR 26.11.03.03B(23)] and [40 CFR Part 68] 

Should the Permittee become subject to 40 CFR Part 68 during the term of this 

permit, the Permittee shall submit risk management plans by the date specified in 

40 CFR Part 68.150 and shall certify compliance with the requirements of 40 CFR 

Part 68 as part of the annual compliance certification as required by 40 CFR Part 

70. 
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The Permittee shall initiate a permit revision or reopening according to the 

procedures of 40 CFR Part 70.7 to incorporate appropriate permit conditions into 

the Permittee's Part 70 Permit. 

6. GENERAL TESTING REQUIREMENTS 

[COMAR 26.11.01.04] 

The Department may require the Permittee to conduct, or have conducted, testing 

to determine compliance with this Part 70 permit. The Department, at its option, 

may witness or conduct these tests. This testing shall be done at a reasonable 

time, and all information gathered during a testing operation will be provided to 

the Department. 

7. EMISSIONS TEST METHODS 

[COMAR 26.11.01.04]

Compliance with the emissions standards and limitations in this Part 70 permit 

shall be determined by the test methods designated and described below or other 

test methods submitted to and approved by the Department. 

Reference documents of the test methods approved by the Department include the 

following: 

a. 40 CFR Part 60, appendix A 

b. 40 CFR Part 51, appendix M 

c. The Department's Technical Memorandum 91-01 "Test Methods 

and Equipment Specifications for Stationary Sources", (January 

1991), as amended through Supplement 2, (July 1, 1992) 

8. EMISSIONS CERTIFICATION REPORT 

[COMAR 26.11.02.19C and D] and 26.11.01.05-1

The Permittee shall certify actual annual emissions of regulated pollutants from 

the facility on a calendar year basis. 
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a. The certification shall be on a form obtained from the Department and 

submitted to the Department not later than April 1 of the year following 

the year for which the certification is required; 

 

b. The individual making the certification shall certify that the information is 

accurate to the individual's best knowledge. The individual shall be: 

(1) Familiar with each source for which the certification form is 

submitted, and 

(2) Responsible for the accuracy of the emission information; 

c. The Permittee shall maintain records necessary to support the emission 

certification including the following information if applicable: 

(1) The total amount of actual emissions of each regulated pollutant 

and the total of all regulated pollutants; 

(2) An explanation of the methods used to quantify the emissions and 

the operating schedules and production data that were used to 

determine emissions, including significant assumptions made; 

(3) Amounts, types, and analyses of all fuels used; 

(4) Emission data from continuous emission monitors that are required 

by this permit, including monitor calibration and malfunction 

information; 

(5) Identification, description, and use records of all air pollution 

control equipment and compliance monitoring equipment 

including: 

(a) Significant maintenance performed, 

(b) Malfunctions and downtime, and 

(c) Episodes of reduced efficiency of all the equipment; 

(6) Limitations on source operation or any work practice standards 

that significantly affect emissions; and 

(7) Other relevant information as required by the Department. 

 
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9. COMPLIANCE CERTIFICATION REPORT 

[COMAR 26.11.03.06C(6) and (7)]

The Permittee shall submit to the Department and EPA Region III a report 

certifying compliance with each term of this Part 70 permit including each 

applicable standard, emission limitation, and work practice for the previous 

calendar year by April 1 of each year. 

a. The compliance certification shall include: 

(1) The identification of each term or condition of this permit which is 

the basis of the certification; 

(2) The compliance status; 

(3) Whether the compliance was continuous or intermittent; 

(4) The methods used for determining the compliance of the source, 

currently and over the reporting period; and 

(5) Any other information required to be reported to the Department 

that is necessary to determine the compliance status of the 

Permittee with this permit. 

b. The Permittee shall submit the compliance certification reports to the 

Department and EPA simultaneously. 

10. CERTIFICATION BY RESPONSIBLE OFFICIAL 

[COMAR 26.11.02.02F]

All application forms, reports, and compliance certifications submitted pursuant 

to this permit shall be certified by a responsible official as to truth, accuracy, and 

completeness. The Permittee shall expeditiously notify the Department of an 

appointment of a new responsible official. 

The certification shall be in the following form: 

 "I certify under penalty of law that this document and all attachments were 

prepared under my direction or supervision in accordance with a system designed 

to assure that qualified personnel properly gather and evaluate the information 

submitted. Based on my inquiry of the person or persons who manage the system, 

or those persons directly responsible for gathering the information, the 
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information submitted is, to the best of my knowledge and belief, true, accurate, 

and complete. I am aware that there are significant penalties for submitting false 

information, including the possibility of fine and imprisonment for knowing 

violations." 

11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING 

[COMAR 26.11.03.06C(5)]

The Permittee shall gather and retain the following information when sampling 

and testing for compliance demonstrations: 

a. The location as specified in this permit, and the date and time that samples 

and measurements are taken; 

b. All pertinent operating conditions existing at the time that samples and 

measurements are taken; 

c. The date that each analysis of a sample or emissions test is performed and 

the name of the person taking the sample or performing the emissions test; 

d. The identity of the Permittee, individual, or other entity that performed the 

analysis; 

e. The analytical techniques and methods used; and 

f. The results of each analysis. 

12. GENERAL RECORDKEEPING 

[COMAR 26.11.03.06(C)(6)]

The Permittee shall retain records of all monitoring data and support information 

that supports the compliance certification for a period of five years from the date 

that the monitoring sample, measurement, application, report or emissions test 

was completed or submitted to the Department. 

These records and support information shall include: 

a. All calibration and maintenance records; 

 

b. All original data collected from continuous monitoring instrumentation; 
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UNION BRIDGE MARYLAND 

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c. Records which support the annual emissions certification; and 

d. Copies of all reports required by this permit. 

13. GENERAL CONFORMITY – Not applicable 

[COMAR 26.11.26.09]

The Permittee shall comply with the general conformity requirements of 40 CFR 

Part 93, Subpart B and COMAR 26.11.26.09. 

14. ASBESTOS PROVISIONS 

[40 CFR Part 61, Subpart M]

The Permittee shall comply with 40 CFR Part 61, Subpart M when conducting 

any renovation or demolition activities at the facility. 

15. OZONE DEPLETING REGULATIONS 

[40 CFR Part 82, Subpart F] 

The Permittee shall comply with the standards for recycling and emissions 

reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for MVACs 

in subpart B: 

a. Persons opening appliances for maintenance, service, repair, or disposal 

must comply with the prohibitions and required practices pursuant to 

§§82.154 and 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, repairs or disposal of appliances 

must be certified by an approved technician certification program pursuant 

to §82.161. 

d. Persons performing maintenance, service, repairs or disposal of appliances 

must certify with the Administrator pursuant to §82.162. 
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e. Persons disposing of small appliances, MVACS, and MVAC-like 

appliances as defined in §82.152, must comply with record keeping 

requirements pursuant to §82.166 . 

f. Persons owning commercial or industrial process refrigeration equipment 

must comply with the leak repair requirements pursuant to §82.156. 

g. 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. 

16. ACID RAIN PERMIT- Not Applicable 
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SECTION IV PLANT SPECIFIC CONDITIONS

This section is comprised of tables containing the emissions standards, emissions 

limitations and work practices applicable to each emissions unit located at this facility. 

The Permittee shall comply with all applicable emissions standards, emissions limitations 

and work practices contained herein. 

These tables also list testing, monitoring, record keeping and reporting requirements 

specific to each emissions unit. In addition to the requirements listed in Section IV, the 

Permittee is subject to the general testing, monitoring, record keeping and reporting 

requirements contained in Section III, Plant Wide Conditions of this permit. 

Quarry- Fugitive Sources

(Not subject to MACT Requirements) 

Note: The quarry is located in Frederick County 

1A Emissions Unit Number(s)

HR1- Quarry Haul Roads 

SP1- Limestone Storage Pile 

TLU1- Limestone truck loading/unloading 

TLU2- Truck loading/unloading 

 Applicable Standards/Limits:

COMAR 26.11.06.03C(1) - Particulate matter Emissions. A person may not cause 

or permit emissions from an unconfined source without taking reasonable precautions 

to prevent particulate matter from becoming airborne.

COMAR 26.11.06.03D- Particulate Matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

 Testing Requirements:

None 

 Monitoring Requirements:

(1) The Permittee shall prepare and update as needed the best management plan 

that describes the procedures and methods that will be used to take reasonable 

precautions. The management plan may be included in the written operation and 

maintenance plan required under the Portland Cement MACT. 

(2) The Permittee shall perform an inspection at a minimum of one minute once a 

month or when weather conditions are favorable to create particulate matter 

becoming airborne to verify that best management practices are being 

implemented. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements:

The Permittee shall maintain the best management plan and records of the dates and 

inspection results for at least five (5) years and make them available to the 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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Department upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off site. The files 

may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[COMAR 26.11.03.06C]

Reporting Requirements:

None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Quarry- Point Sources

(Not subject to MACT Requirements) 

Note: The quarry is located in Frederick County 

1B Emissions Unit Number(s)

Baghouse Emission Unit

A01-012 A01-009- Gyratory Crusher 

A01-018- Belt Conveyor #1 

A01-025 A01-021- Surge Bin 

A02-008 A02-005- Belt Conveyor #2 

A02-006- Secondary Crusher 

A02-010- Belt Conveyor #3 

A02-017-Belt Conveyor #6 

A02-018- Belt Conveyor #5 

A02-019- Tertiary Crusher 

A02-021- Belt Conveyor #4 

A02-012 A02-011- Vibrating Screens and Transfer System 

A02-022- Vibrating Screens and Transfer System 

A02-023- Vibrating Screens and Transfer System 

A02-024- Raw Material Transfer 

A02-015 A02-011- Vibrating Screens and Transfer System 

 A02-022- Vibrating Screens and Transfer System 

A02-023- Vibrating Screens and Transfer System 

A02-025 A02-024- Raw Material Transfer 

B01-017- Raw Material Transfer 

 Applicable Standards/Limits:

A. Visible Emissions 

COMAR 26.11.06.02C(1) - A person may not cause or permit the discharge of 

emissions from any installation or building, other than water in an uncombined 

form, which is greater than 20 percent opacity.” 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(1)(b)(ii) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 
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0.05 gr/SCFD (114.5 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000 - The following equipment shall be equipped with a dust 

collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm): 

(a) A01-021 – Surge Bin; 

(b) A02-024 & B01-017 - Raw Material Transfer; and 

(c) A02-011, A02-023, and A02-022 - Vibrating Screens and 

Transfer System.

(3) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000 - The following equipment shall be equipped with a dust 

collector designed to reduce particulate matter emissions to 0.015 

gr/SCFD (34.3 mg/dscm): 

(a) A01-009- Gyratory Crusher; 

(b) A01-018- Belt Conveyor #1; 

(c) A02-005- Belt Conveyor #2; 

(d) A02-006- Secondary Crusher; 

(e) A02-010- Belt Conveyor #3; 

(f) A02-017- Belt Conveyor #6; 

(g) A02-018- Belt Conveyor #5; 

(h) A02-019- Tertiary Crusher; and 

(i) A02-021- Belt Conveyor #4. 

 Testing Requirements:

None 

 Monitoring Requirements:

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the 

Permittee must resume testing of the exhaust stack of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. If no visible emissions are observed 

during the semi-annual test for the exhaust stack of any emission unit, the 

Permittee may decrease the frequency of testing from semi-annually to annually 

for the exhaust stack of that emission unit. If visible emissions are observed 

during any annual test, the Permittee must resume testing of the exhaust stack of 

that emission unit on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

preventive maintenance plan or the best management plan. Within 24 hours at 

the end of the Method 22 test, the Permittee shall conduct a follow-up Method 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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22 test of each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are still observed, conduct a 

visual opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 

60. The Method 9 test shall be conducted within one-hour of the end of the 

follow-up Method 22 test and the duration of the Method 9 test shall be at least 

six minutes. 

 [COMAR 26.11.03.06C] 

B1. The exhaust gas from each emissions unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging into 

the atmosphere. 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update as needed the preventative 

maintenance plan for each baghouse that describes the maintenance activity and 

time schedule for completing each activity. The preventative maintenance plan 

may be included in a written operation and maintenance plan required under the 

Portland Cement MACT. The Permittee shall perform maintenance activities 

within the timeframes established in the plan and shall maintain a log with 

records of the dates maintenance was performed. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements:

A. The Permittee shall maintain records of the results of the monthly 

inspections for at least five (5) years and make them available to the 

Department upon request. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the 

Department upon request. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C]

 Reporting Requirements:

A and B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Raw Material Handling- Fugitive Sources

(Not subject to MACT Requirements)

2A Emissions Unit Number(s)

B01-011 – Enclosed Limestone Dome 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 42 of 91 

TU1- Iron and silica truck unloading 

SP4- Silica Storage Pile 

SP5- Iron Ore Storage Pile 

 Applicable Standards/Limits:

(1) COMAR 26.11.06.03C(1) - Particulate Matter from Unconfined Sources - A 

person may not cause or permit emissions from an unconfined sources without 

taking reasonable precautions to prevent particulate matter from becoming 

airborne. 

(2) COMAR 26.11.06.03D - Particulate Matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable 

precautions to prevent particulate matter from becoming airborne.

 Testing Requirements

None

 Monitoring Requirements

(1) The Permittee shall comply with and update as needed the best management 

plan that describes the procedures and methods that will be used to take 

reasonable precautions. The management plan may be included in the written 

operation and maintenance plan required under the Portland Cement MACT. 

[COMAR 26.11.03.06C] 

(2) The Permittee shall perform an inspection at a minimum of one minute once a 

month or when weather conditions are favorable to create particulate matter 

becoming airborne to verify that best management practices are being 

implemented. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

The Permittee shall maintain the plan and records of the dates and inspection results 

for at least five (5) years and make them available to the Department upon request. At 

a minimum, the most recent two years of data shall be retained on site. The 

remaining three years of data may be retained off site. The files may be maintained 

on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C]

 Reporting Requirements

None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Raw Material Handling- Fugitive Sources

(Subject to MACT Requirements)

2B Emissions Unit Number(s)

H04-001 – Gypsum Bin 409 

H04-003 – Limestone Tank 416 

H05-001 – Gypsum Bin 509 

H06-001 – Gypsum Bin 609 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 43 of 91 

H07-001 – Gypsum Bin 

H08-001 – Gypsum Bin 

 Applicable Standards/Limits:

(1) COMAR 26.11.06.03C(1) - Particulate Matter from Unconfined Sources - A 

person may not cause or permit emissions from an unconfined sources without 

taking reasonable precautions to prevent particulate matter from becoming 

airborne. 

(2) COMAR 26.11.06.03D - Particulate Matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable 

precautions to prevent particulate matter from becoming airborne. 

(3) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing 

raw material, clinker, or finished product storage bin; conveying system transfer 

point; bagging system; and bulk loading or unloading system. 

 Testing Requirements

None

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test 

must be conducted while the emission unit is in operation. If no visible 

emissions are observed in six consecutive monthly tests for any emission unit, 

the Permittee may decrease the frequency of testing from monthly to semiannually for that emission unit. If visible emissions are observed during any 

semi-annual test, the Permittee must resume testing of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. If no visible emissions are observed during the 

semi-annual test for any emission unit, the Permittee may decrease the 

frequency of testing from semi-annually to annually for that emission unit. If 

visible emissions are observed during any annual test, the Permittee must 

resume testing of that emission unit on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive monthly 

tests. 

If visible emissions are observed during any Method 22 test, the Permittee shall 

initiate the corrective actions specified in the written operations and 

maintenance plan and conduct the follow-up Method 22 test until the problem is 

resolved. 

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations 

and maintenance plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)] 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 44 of 91 

 Record Keeping Requirements

The Permittee shall maintain all records for at least five years following the date of 

each occurrence, measurement, maintenance, corrective action, report, or record. At a 

minimum, the most recent two years of data shall be retained on site. The remaining 

three years of data may be retained off site. The files may be maintained on 

microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[40 CFR §63.1355] 

 Reporting Requirements

The Permittee shall submit a summary report semiannually which contains all failures 

to comply with any provision of the operation and maintenance plan developed in 

accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)]

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Raw Material Handling- Point Sources

(Not subject to MACT requirements)

2C Emissions Unit Number(s)

Baghouse Emission Unit

B02-008 B02-007- Belt Conveyor 

B02-011- Silica Bearing Material Bin 

B02-012- Iron Bearing Material Bin 

B02-017- Reversible Belt Conveyor 

C01-007 C01-002- Limestone Weighfeeder 

C01-004- Iron Weighfeeder 

C01-006- Silica Weighfeeder 

C01-011- Belt Conveyor 

B03-008 B03-004- Fly ash Blending System 

C01-019 C01-015- Fly ash Weigh bin 

C02-011 C02-001- Bucket elevator 

C02-011 C02-002- Belt Conveyor 

 C02-006- 100 T Bin 

 C02-014- 15 T Bin 

B04-016 TT3- Transfer Tower #3 

B04-011 TT3- Transfer Tower #3 

B04-016 B04-019 Limestone bin 

B02-019 TT4- Transfer Tower #4 

B01-018 TT8/9- Transfer Tower #8/9 

G02-041 TT8/9- Transfer Tower #8/9 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 45 of 91 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR Part 60, Subpart F,§60.60(c) - Which limits the opacity of any 

gas from raw material storage to 10 percent. 

B. Particulate Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 

0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000- Each emissions unit shall be equipped with a dust 

collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm). 

 Testing Requirements

A & B. None

 Monitoring Requirements

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the Permittee 

must resume testing of the exhaust stack of that emission unit on a monthly 

basis and maintain that schedule until no visible emissions are observed in six 

consecutive monthly tests. If no visible emissions are observed during the semiannual test for the exhaust stack of any emission unit, the Permittee may 

decrease the frequency of testing from semi-annually to annually for the exhaust 

stack of that emission unit. If visible emissions are observed during any annual 

test, the Permittee must resume testing of the exhaust stack of that emission unit 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

preventive maintenance plan or the best management plan. Within 24 hours at 

the end of the Method 22 test, the Permittee shall conduct a follow-up Method 

22 test of each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are still observed, conduct a visual 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. 

The Method 9 test shall be conducted within one-hour of the end of the followup Method 22 test and the duration of the Method 9 test shall be at least six 

minutes. 

[COMAR 26.11.03.06C] 

B1. The exhaust gas from each emissions unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging into 

the atmosphere. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 46 of 91 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update as needed the preventative 

maintenance plan for each baghouse that describes the maintenance activity and 

time schedule for completing each activity. The Permittee shall perform 

maintenance activities within the timeframes established in the plan and shall 

maintain a log with records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly 

inspections for at least five (5) years and make them available to the 

Department upon request. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A and B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Raw Material Handling - Point Sources

(Subject to MACT requirements)

2D Emissions Unit Number(s)

Baghouse Emission Unit

C01-007 C02-061- Belt Conveyor 

 C02-038- Rejects Belt Conveyor 

C02-011 C02-060- Reversible Belt Conveyor (to Raw Mill) 

C02-021 C02-017- Belt Conveyor (from 15 T Bin) 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than 

water in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or 

existing raw material, clinker, or finished product storage bin; conveying 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 47 of 91 

system transfer point; bagging system; and bulk loading or unloading 

system. 

B. Particulate Emissions

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 

0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000- Each emissions unit shall be equipped with a dust 

collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm). 

 Testing Requirements

A & B. None

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the 

Permittee must resume testing of the exhaust stack of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. If no visible emissions are observed during the 

semi-annual test for the exhaust stack of any emission unit, the Permittee may 

decrease the frequency of testing from semi-annually to annually for the exhaust 

stack of that emission unit. If visible emissions are observed during any annual 

test, the Permittee must resume testing of the exhaust stack of that emission unit 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

written operations and maintenance plan. Within 24 hours at the end of the 

Method 22 test, the Permittee shall conduct a follow-up Method 22 test of each 

stack from which visible emissions were observed during the previous Method 

22 test. If visible emissions are still observed, conduct a visual opacity test in 

accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 

test shall be conducted within one-hour of the end of the follow-up Method 22 

test and the duration of the Method 9 test shall be at least six minutes.

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations 

and maintenance plan which includes the following information: 

(2) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; and 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 48 of 91 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

B. The exhaust gas from each emissions unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging into 

the atmosphere. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date 

of each occurrence, measurement, maintenance, corrective action, report, or 

record. At a minimum, the most recent two years of data shall be retained on 

site. The remaining three years of data may be retained off site. The files may 

be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Coal Feed System - Fugitive Sources

(Not subject to MACT Requirements)

3A Emissions Unit Number(s)

F01-034/F01-037 – Belt Conveyor #11/14 

RU1 – Coal Rail Unloading 

SP2 – Coal Storage Pile 

SP3 – Coal Storage Pile 

TT1 – Transfer Tower #1 

TT2 – Transfer Tower #2 

TU2 – Truck Unloading 

 Applicable Standards/Limits:

(1) COMAR 26.11.06.03C(1) - Particulate Matter from Unconfined Sources - A 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 49 of 91 

person may not cause or permit emissions from an unconfined sources without 

taking reasonable precautions to prevent particulate matter from becoming 

airborne. 

(2) COMAR 26.11.06.03D - Particulate Matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable 

precautions to prevent particulate matter from becoming airborne.

 Testing Requirements

None

 Monitoring Requirements

(1) The Permittee shall comply with and update as needed the best management 

plan that describes the procedures and methods that will be used to take 

reasonable precautions. The management plan may be included in the written 

operation and maintenance plan required under the Portland Cement MACT. 

[COMAR 26.11.03.06C] 

(2) The Permittee shall perform an inspection at a minimum of one minute once a 

month or when weather conditions are favorable to create particulate matter 

becoming airborne to verify that best management practices are being 

implemented. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

The Permittee shall maintain the plan and records of the dates and inspection results 

for at least five (5) years and make them available to the Department upon request. At 

a minimum, the most recent two years of data shall be retained on site. The 

remaining three years of data may be retained off site. The files may be maintained 

on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C]

 Reporting Requirements

None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Coal Feed System - Point Sources

(Not subject to MACT requirements)

3B Emissions Unit Number(s)

Baghouse Emission Unit 

F02-033 F02-018 – Belt Conveyor 

F02-033 F02-019 – Belt Conveyor 

F02-030 F02-019 – Belt Conveyor 

F02-027 TT5- Transfer Tower #5 

 F02-006 – Reclaim Elevator 

F02-010 F02-020 – Belt Conveyor 

F03-058 F03-001- Belt Conveyor 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 50 of 91 

 F03-002- Coal Bin weighfeeder 

 F03-003- Coke Bin Weighfeeder 

G02-025 TT6- Transfer Tower #6 

 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR Part 60, Subpart Y, §60.252(c) - Which limits the opacity of 

any gas from coal processing and conveying equipment, coal storage 

system, or coal transfer and loading to 20 percent. 

B. Particulate Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 

0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000- Each emissions unit shall be equipped with a dust 

collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm). 

 Testing Requirements

A & B. None

 Monitoring Requirements

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee must resume 

testing of the exhaust stack of that emission unit on a monthly basis and 

maintain that schedule until no visible emissions are observed in six consecutive 

monthly tests. If no visible emissions are observed during the semi-annual test 

for the exhaust stack of any emission unit, the Permittee may decrease the 

frequency of testing from semi-annually to annually for the exhaust stack of that 

emission unit. If visible emissions are observed during any annual test, the 

Permittee must resume testing of the exhaust stack of that emission unit on a

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

preventive maintenance plan or the best management plan. Within 24 hours at 

the end of the Method 22 test, the Permittee shall conduct a follow-up Method 

22 test of each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are still observed, conduct a visual 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 51 of 91 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. 

The Method 9 test shall be conducted within one-hour of the end of the followup Method 22 test and the duration of the Method 9 test shall be at least six 

minutes.

[COMAR 26.11.03.06C] 

B1. The exhaust gas from each emissions unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging into 

the atmosphere. 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update as needed the preventative 

maintenance plan for each baghouse that describes the maintenance activity and 

time schedule for completing each activity. The Permittee shall perform 

maintenance activities within the timeframes established in the plan and shall 

maintain a log with records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly 

inspections for at least five (5) years and make them available to the 

Department upon request. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A and B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Raw Meal Feed system

(Subject to MACT requirements) 

4 Emissions Unit Number(s)

Baghouse Emission Unit

C03-001 C03-034, C03-035, C03-040, &C03-042 - Airslide 

C03-047 C03-045- Airslide 

C03-050 C03-008, C03-045, C03-054, & C04-066 - Airslide 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 52 of 91 

C03-030 C03-010 & C03-013 - Airslide and C03-046- Bucket Elevator 

D01-037 C03-046- Bucket Elevator 

 C03-017-Airslide 

 D01-001- Blending Silo 

 D01-003 & D01-002 - Recirculation Airslide 

C03-030 C03-010 & C03-013- Airslide 

D01-034 D01-020- 185 MT Feed Bin 

 D02-004 & D02-017- Airslide 

 D02-006 & D02-019- Flow Meter 

D01-040 D01-023, D01-026, D02-007, &D02-020 - Airslide 

D02-041 D02-010, D02-023, & D02-049 - Airslide 

D02-041 D02-025- Bucket Elevator and D02-026- Bucket Elevator 

D02-027 D02-025- Bucket Elevator and D02-026- Bucket Elevator 

D02-027 D02-033, D02-045, & D02-047- Airslide 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or 

existing raw material, clinker, or finished product storage bin; conveying 

system transfer point; bagging system; and bulk loading or unloading 

system. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) – Particulate Matter - A person may not 

cause or permit particulate matter to be discharged from any installation 

in excess of 0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 

2000 which limits particulate matter emissions from each emissions unit 

to 0.01 gr/scfd (22.9 mg/dscm). 

 Testing Requirements

A & B. None

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the Permittee 

must resume testing of the exhaust stack of that emission unit on a monthly basis 

and maintain that schedule until no visible emissions are observed in six 

consecutive monthly tests. If no visible emissions are observed during the semi-
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 53 of 91 

annual test for the exhaust stack of any emission unit, the Permittee may 

decrease the frequency of testing from semi-annually to annually for the exhaust 

stack of that emission unit. If visible emissions are observed during any annual 

test, the Permittee must resume testing of the exhaust stack of that emission unit 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

written operations and maintenance plan. Within 24 hours at the end of the 

Method 22 test, the Permittee shall conduct a follow-up Method 22 test of each 

stack from which visible emissions were observed during the previous Method 

22 test. If visible emissions are still observed, conduct a visual opacity test in 

accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test 

and the duration of the Method 9 test shall be at least six minutes. 

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations and 

maintenance plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

B. The exhaust gas from each emissions unit shall vent a dust collector designed to 

reduce particulate matter emissions to 0.01 gr/SCFD (22.9 mg/dscm) before 

discharging into the atmosphere. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date 

of each occurrence, measurement, maintenance, corrective action, report or 

record. At a minimum, the most recent two years of data shall be retained on site; 

the remaining three years of data may be retained offsite. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C]

 Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 54 of 91 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Kiln, Raw and Coal Mills

(Subject to MACT requirements)

5 Emissions Unit Number(s)

Baghouse Emission Unit

C04-014 E01-001/E02-001- Preheater-Precalciner/Kiln System 

C02-025- Raw Mill 

F03-028 F03-016- Coal Mill 

F03-032 F03-016- Coal Mill 

F03-036 F03-016- Coal Mill 

F03-040 F03-016- Coal Mill 

F03-044 F03-016- Coal Mill 

F03-048 F03-016- Coal Mill 

Note: These emission units discharge through a common stack. 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1343(b)(2) which limits opacity from the kiln and raw mill 

to 20% or less. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 0.03 

gr/SCFD (68.7 mg/dscm). 

(2) 40 CFR §63.1343(b)(1) which limits particulate matter emissions from 

the kiln and raw mill to 0.15 kg per MG (0.3 lb per ton) of feed (dry 

basis). 

(3) Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 

7, 2000 which limits particulate matter emissions from the main exhaust 

stack to 0.0158 gr/scfd (36.2 mg/dscm).

C. Dioxins/Furans (D/F) 

40 CFR §63.1343(b)(3) which prohibits D/F in excess of 

(1) 0.2 ng per dscm (8.7 X 10 –11 gr per dscf)(TEQ) corrected to seven 
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UNION BRIDGE MARYLAND 

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percent oxygen; or 

(2) 0.4 ng per dscm (1.7 x 10-10 gr dscf)(TEQ) corrected to seven percent 

oxygen, when the temperature at the inlet to the particulate matter air 

pollution control device is 204°C (400°F) or less. 

D. NOx Emissions 

(1) COMAR 26.11.09.08H(2)(b) which limits NOx emissions to 1,800 

pounds per hour on a 30-day rolling average.

(2) Permit to Construct #06-6-0256 issued April 8, 1999 and revised 

June 7, 2000 which states that NOx emissions from the entire premises 

shall not exceed 4,871 tons for any 12-month period, rolling monthly. 

(3) COMAR 26.11.29.15C(1) which requires a person who owns or operates 

a cement manufacturing facility to either meet the applicable emission 

standards in §C(2) of this regulation or implement one of the following 

control measures: 

(a) Install low NOx burners on each kiln; or 

(b) Modify each kiln to implement mid-kiln firing 

Note: The kiln has low NOx burners installed. 

E. SOx Emissions 

(1) Permit to Construct #06-6-0256 issued April 8, 1999 and revised 

June 7, 2000 which states that SO2 emissions from the entire premises 

shall not exceed 1,041 tons for any 12-month period, rolling monthly. 

(2) COMAR 26.11.06.05C(1) which limits the sulfur dioxide concentration 

in the exhaust gases not to exceed 500 parts per million by volume 

corrected to 7 percent oxygen. 

(3) COMAR 26.11.06.05C(2) which limits the content of sulfuric acid, 

sulfur trioxide, or any combination not to exceed 35 milligrams reported 

as sulfuric acid per cubic meter of gas corrected to 7 percent oxygen. 

F. CO Emissions 

Prevention of Significant Deterioration (PSD) Approval #PSD-97-01R dated 

April 8, 1999 and revised on June 7, 2000 which states that the premises-wide 

carbon monoxide (C0) emissions from the Pyroprocessing Portland cement plant 

and the existing Portland cement plant shall not exceed 3,328 tons for any 12-

month period, rolling monthly. 

G. VOC Emissions 

New Source Review Approval #NSR-97-02 issued April 8, 1999 which states 

that premises-wide emissions shall not exceed 165 tons of VOC for any 12-

month period, rolling monthly. In determining compliance with VOC emission 

limits, VOC emissions shall be determined by calculating the numerical 

difference between the measured values of total hydrocarbon (THC) emissions 

and non-VOC emissions (i.e., methane and ethane) measured during the most 

recent test. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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H. Lead Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 

2000 which states that the emissions from the entire premises, including the 

existing Portland cement plant and the Pyroprocessing Portland cement plant, 

shall not exceed 0.6 tons of lead for any 12-month period, rolling monthly. 

I. Fluoride Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 2000 

which states that the emissions from the entire premises, including the existing 

Portland cement plant and the Pyroprocessing Portland cement plant, shall not 

exceed 3.0 tons of fluoride for any 12-month period, rolling monthly. 

 Testing Requirements

A. Visible Emissions 

None 

B. Particulate Matter Emissions 

The Permittee shall conduct a particulate matter emissions test at the interval 

stipulated in Subpart LLL (once every 5 years) using Method 5 of 40 CFR Part 

60, Appendix A. Each performance test shall consist of three separate runs 

under the conditions that exist when the affected source is operating at under 

representative performance conditions in accordance with 40 CFR Part 63, 

Subpart LLL. Each run shall be conducted for at least one hour, and the 

minimum sample volume shall be 0.85 dscm (30 dscf). The average of the three 

runs shall be used to determine compliance. 

[40 CFR §63.1349(b)(1) and (c)] 

C. D/F Emissions 

The Permittee shall conduct a dioxins/furans test at the interval stipulated in 

Subpart LLL (once every 2 1⁄2 years) using Method 23 of 40 CFR Part 60, 

Appendix A. 

(1) Each performance test shall consist of three separate runs; each run shall 

be conducted under the conditions that exist when the affected source is 

operating at under representative performance conditions in accordance 

with 40 CFR Part 63, Subpart LLL. The duration of each run shall be at 

least three hours and the sample volume for each run shall be at least 2.5 

dscm (90 dscf). The concentration shall be determined for each run and 

the arithmetic average of the concentrations measured for the three runs 

shall be calculated and used to determine compliance. 

(2) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD 

must be continuously recorded during the period of the Method 23 test, 

and the continuous temperature record(s) must be included in the 

performance test report. 

(3) One-minute average temperatures must be calculated for each minute of 

each run of the test. 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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(4) The run average temperature must be calculated for each run, and the 

average of the run average temperatures must be determined and included 

in the performance test report and will determine the applicable 

temperature limit in accordance with §63.1344(b). 

[40 CFR §63.1349(b)(3) and (d)] 

D-I. None 

 Monitoring Requirements

A. Visible Emissions 

(1) The Permittee shall install, calibrate, maintain, and continuously operate a 

continuous opacity monitor (COM) located at the outlet of the PM control 

device to continuously monitor the opacity. The COM shall be installed, 

maintained, calibrated, and operated as required by 40 CFR Part 63, Subpart 

A (general provision) and 40 CFR Part 60, Appendix B, Performance 

Specification 1. 

[40 CFR §63.1350(c)(1)] and [COMAR 26.11.01.11B(2)(d)] 

(2) The COM shall automatically reduce all data to 6-minute block average 

calculated from 36 or more equally spaced data points. 

[COMAR 26.11.01.11A(3) and .10G(2)(a)] 

A, B, and C. 

The Permittee shall comply with and update as needed the written operations and 

maintenance plan, which includes the following information:

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §63.1344; 

(2) Corrective actions to be taken when required by §63.1350(e); and 

(3) Procedures to be used to during an inspection of the components of the 

combustion system of each kiln and each in-line kiln located at the facility 

at least once per year. 

[40 CFR §63.1350(a) and (b)]

B. Particulate Matter Emissions 

The exhaust gas from each emission unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging into the 

atmosphere. 

[COMAR 26.11.03.06C]

C1. The Permittee shall conduct an inspection of the components of the combustion

system of each kiln or in-line kiln raw mill at least once a year. 

[40 CFR §63.1350(i)] 

C2. The Permittee shall calibrate, maintain, and continuously operate a continuous 

monitor to record the temperature of the exhaust gases from the kiln and the inline kiln/raw mill, if applicable, at the inlet to or upstream of the PM control 

devices. 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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(1) The recorder response range must include zero and 1.5 times either of the 

average temperature established according to the requirements in 

§63.1349(b)(3)(iv). 

(2) The reference method must be a National Institute of Standards and 

Technology calibrated reference thermocouple-potentiometer system or 

alternate reference, subject to approval by the Administrator. 

(3) The three-hour rolling average temperature shall be calculated as the average 

of 180 successive one-minute average temperatures. 

(4) The period of time when one-minute averages are not available shall be 

ignored when calculating three-hour rolling averages. When one-minute 

averages become available, the first one-minute average is added to the 

previous 179 values to calculate the three-hour rolling average. 

(5) When the operating status of the raw mill of the in-line kiln/raw mill is 

changed from off to on, or from on to off the calculation of the three-hour 

rolling average temperature must begin anew, without considering previous 

recordings. 

(6) The calibration of all thermocouples and other temperature sensors shall be 

verified at least once every three months.

[40 CFR §63.1350(f)] 

D. NOx Emissions 

The Permittee shall use a continuous emissions monitoring system, (CEM) to 

monitor NOx emissions from the main exhaust stack. The Permittee shall install, 

operate, maintain, and calibrate the CEM in accordance with the Performance 

Specifications under 40 CFR Part 60, Appendix B and the Quality Assurance 

Procedures under 40 CFR Part 60, Appendix F. 

[COMAR 26.11.09.08H(1) and Permit to Construct #06-6-0256 issued April 8, 

1999 and revised June 7, 2000] 

E. Sulfur Oxide Emissions 

The Permittee shall use a continuous emissions monitoring system, (CEM) to 

monitor SO2 emissions from the main exhaust stack. The Permittee shall install, 

operate, maintain, and calibrate the CEM in accordance with the Performance 

Specifications under 40 CFR Part 60, Appendix B and the Quality Assurance 

Procedures under 40 CFR Part 60, Appendix F. 

[Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000] 

and [COMAR 26.11.01.11C] 

F. Carbon Monoxide Emissions 

The Permittee shall use a CEM to monitor CO emissions from the main exhaust 

stack. The Permittee shall install, operate, maintain, and calibrate the CEM in 

accordance with the Performance Specifications under 40 CFR Part 60, 

Appendix B and the Quality Assurance Procedures under 40 CFR Part 60, 

Appendix F. 

[Prevention of Significant Deterioration (PSD) Approval #PSD-97-01 issued April 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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8, 1999 and revised June 7, 2000 and COMAR 26.11.01.11C] 

G. VOC Emissions 

The Permittee shall use continuous emission monitoring system (CEM) to 

monitor total hydrocarbon (THC) emissions from the main exhaust stack. The 

Permittee shall install, operate, maintain, and calibrate the CEM in accordance 

with the Performance Specifications 8A of Appendix B to Part 60 and comply 

with all of the requirements from CEM found in the general provisions, subpart 

A of this part. 

[New Source Review Approval #NSR-97-02 issued April 8, 1999 and COMAR 

26.11.01.11C] 

D thru G. 

For each CEM used to monitor a gas concentration, the Permittee shall equip the CEM 

to record not less than four equally spaced data points per hour and to automatically 

reduce data in terms of averaging times consistent with applicable emission standard. 

[COMAR 26.11.01.11D(3)] 

H and I. None 

 Record Keeping Requirements

A-C. 

The Permittee shall maintain all records for at least five years following the date of 

each occurrence, measurement, maintenance, corrective action, report, or record. At a 

minimum, the most recent two years of data shall be retained on site. The remaining 

three years of data may be retained off site. The files may be maintained on 

microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[40 CFR §63.1355] 

D and E. 

The Permittee shall maintain all records for at least five years following the date of 

each occurrence, measurement, maintenance, corrective action, report, or record. At a 

minimum, the most recent two years of data shall be retained on site. The remaining 

three years of data may be retained off site. The files may be maintained on 

microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

F and G. 

The following records with supporting documentation shall be maintained for at least 

5 years and made available to the Department upon request: 

(1) Emissions for each calendar month and each rolling 12-month period; 

(2) Monthly usage of each raw material and each type of fuel used in the 

pyroprocessing plant; 

(3) All required stack emission test reports; 

(4) All processed CEM emission monitoring data; 

(5) All CEM certification and calibration results; and 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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(6) Records of any repairs made to equipment affecting CO or THC emissions and 

to CEM for CO or THC. 

At a minimum, the most recent two years of data shall be retained on site. The 

remaining three years of data may be retained off site. The files may be maintained on 

microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[New Source Review Approval #NSR-97-02 issued April 8, 1999 and Prevention 

of Significant Deterioration (PSD) Approval #PSD-97-01 issued April 8, 1999 and 

revised June 7, 2000 ] 

H and I. None 

 Reporting Requirements

A. If the total continuous monitoring system downtime for any CEM or any 

continuous monitoring system (CMS) for the reporting period is ten percent or 

greater of the total operating time for the reporting period, the Permittee shall 

submit an excess emissions and continuous monitoring system performance 

report along with the summary report. 

[40 CFR §63.1354(b)(10)]

A and C. 

The Company shall submit to the Department semiannually a Summary Report -

Gaseous and Opacity Excess Emissions and Continuous Monitoring System 

(CMS) Performance on January 31st and July 31st of each year. The Summary 

Report shall include the following items: 

(1) Company name and address; 

(2) Identification of the hazardous pollutant; 

(3) A brief description of the process; 

(4) The emissions limit; 

(5) Name, title and signature of responsible party; 

(6) Date of report; 

(7) All exceedances of the three hour average inlet temperature limit to the 

Particulate matter control device; 

(8) All failures to calibrate thermocouples; 

(9) The results of any burner inspections; 

(10) All failures to comply with the operations and maintenance plan; 

(11) The date of the latest CMS certification or audit; 

(12) The total operating time of the affected source during the reporting period; 

and 

(13) A CMS performance summary, including: 

(a) the total CMS downtime during the operating period (in minutes); 

(b) the total CMS downtime expressed as a percent of the total operating 

time; and 

(c) a breakdown of total CMS downtime into periods due to: 

i. Monitoring equipment malfunctions, 

ii. Non monitoring equipment malfunctions, 

iii. Quality assurance/quality control calibrations, 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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iv. Other known causes, and 

v. Other unknown causes. 

[40 CFR §63.1354b(9) and §63.10(e)(3)(vi)] 

 

A, D thru G. 

 The Permittee shall submit a quarterly summary report to the Department not 

later than 30 days following each calendar quarter. The report shall be in a 

format approved by the Department, and shall include the following: 

(1) The cause, time periods, and magnitude of all emissions which exceed the 

applicable emission standards; 

(2) The source downtime including the time and date of the beginning and end 

of each downtime period and whether the source downtime was planned or 

unplanned; 

(3) The time periods and cause of all CEM downtime including records of any 

repairs, adjustments, or maintenance that may affect the validity of emission 

data; 

(4) Quarterly totals of excess emissions, installation downtime, and CEM 

downtime during the calendar quarter; 

(5) Quarterly quality assurance activities; 

(6) Daily calibration activities that include reference values, actual values, 

absolute or percent of span differences, and drift status; and 

(7) Other information required by the Department that is determined to be 

necessary to evaluate the data, to ensure that compliance is achieved, or to 

determine the applicability of this regulation. 

[COMAR 26.11.01.11A(3) and COMAR26.11.01.10G(2)(d)] 

B and C. 

(1) The Permittee shall submit the results of performance tests before the close 

of business on the 60th day following the completion of the performance test. 

[40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] 

(2) At least 30 days prior to each stack emissions testing, the Permittee shall 

submit to the Department a stack test protocol for review and approval. 

[Part D(7) of Permit to Construct #06-6-0256 issued April 8, 1999 and revised 

June 7, 2000]

D. 

 The Permittee shall submit the NOx emissions data to the Department for each 

control period by November 30 beginning with the 2002 control period. 

[COMAR 26.11.29.15B(1)(c)] 

D and E. 

The Permittee shall submit to the Department, a report no later than 30 days after 

the end of each calendar quarter, which shall include a summary of the following 

information: 

(1) Emissions for each calendar month and each rolling 12-month period; 
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(2) All required stack emission test reports; 

(3) All processed CEM emission monitoring data; 

(4) All CEM certification and calibration results; and 

(5) Records of any repairs made to equipment affecting NOx or SO2 emissions 

and to CEM for NOx or SO2. 

[COMAR 26.11.03.06C] 

F and G. 

The Permittee shall submit to the Department, a report no later than 30 days after 

the end of each calendar quarter, which shall include a summary of the following 

information: 

(1) Emissions for each calendar month and each rolling 12-month period; 

(2) All required stack emission test reports; 

(3) All processed CEM emission monitoring data; 

(4) All CEM certification and calibration results; and 

(5) Records of any repairs made to equipment affecting CO or THC emissions 

and to CEM for CO or THC. 

[New Source Review Approval #NSR-97-02 issued April 8, 1999 and Prevention 

of Significant Deterioration (PSD) Approval #PSD-97-01 issued April 8, 1999 and 

revised June 7, 2000 ] 

H and I. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Clinker Cooler and Main Pan Conveyor

(Subject to MACT requirements) 

6 Emissions Unit Number(s) 

E04-016 E03-001 - Clinker Cooler 

E04-016 G01-001 - Main Pan Conveyor 

The clinker cooler is used to cool the kiln product and exhaust from the clinker cooler is 

passed through the clinker cooler baghouse then to the cooler exhaust stack. 

Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1345(a)(2) which limits opacity from the clinker cooler to 

10 percent or less. 

B. Particulate Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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particulate matter to be discharged from any installation in excess of 0.03 

gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000, which limits particulate matter from the clinker cooler 

exhaust stack to 0.0129 gr/scfd (29.5 mg/dscm). 

(3) 40 CFR §63.1345(a)(1) which limits particulate matter emissions from 

clinker coolers to 0.05 kg per Mg (0.10 lb per ton) of feed (dry basis). 

 Testing Requirements

A. None 

B. The Permittee shall conduct a particulate matter emissions test at the interval 

stipulated in Subpart LLL using Method 5 of 40 CFR Part 60, Appendix A. 

Each performance test shall consist of three separate runs under the conditions 

that exist when the affected source is operating under representative performance 

conditions in accordance with 40 CFR Part 63, Subpart LLL. Each run shall be 

conducted for at least one hour, and the minimum sample volume shall be 0.85 

dscm (30 dscf). The average of the three runs shall be used to determine 

compliance. 

[40 CFR §63.1349(b) and (c)]

 Monitoring Requirements

A1. The Permittee shall install, calibrate, maintain, and continuously operate a 

continuous opacity monitor (COM) located at the outlet of the PM control device 

to continuously monitor the opacity. The COM shall be installed, maintained, 

calibrated, and operated as required by 40 CFR Part 63, Subpart A (general 

provision) and 40 CFR Part 60, Appendix B, Performance Specification 1. 

[40 CFR §63.1350(d)(1)] 

A2. The COM shall automatically reduce all data to 6-minute block average calculated 

36 or more equally spaced data points. 

[COMAR 26.11.01.10G(2)(a)] 

B. The exhaust gases from E-03-001-Clinker Cooler and G01-001- Main Pan 

Conveyor shall vent through a dust collector designed to meet the particulate 

matter emissions limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C] 

A and B 

The Permittee shall comply with and update as needed the written operations and 

maintenance plan, which includes the following information:

(1) Procedures for proper operation and maintenance of the affected source and air 

pollution control devices in order to meet the emission limits and operating 

limits of §63.1345; 

(2) Corrective actions to be taken when required by §63.1350(e); and

(3) Procedures to be used to periodically monitor affected sources subject to opacity 

standards under§63.1345. 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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[40 CFR §63.1350(a) and (b)] 

 Record Keeping Requirements

A and B. 

The Permittee shall maintain all records for at least five years following the date of 

each occurrence, measurement, maintenance, corrective action, report or record. At a 

minimum, the most recent two years of data shall be retained on site; the remaining 

three years of data may be retained offsite. The files may be maintained on microfilm, 

on a computer, on floppy disks, on magnetic tape, or no microfiche. 

[40 CFR §63.1355] 

 Reporting Requirements

A1. If the total continuous monitoring system downtime for any CEM or any 

continuous monitoring system (CMS) for the reporting period is ten percent or 

greater of the total operating time for the reporting period, the owner or operator 

shall submit an excess emissions and continuous monitoring system performance 

report along with the summary report. 

[40 CFR §63.1354(b)(10)] 

A2. The Permittee shall submit a quarterly summary report to the Department not 

later than 30 days following each calendar quarter. The report shall be in a 

format approved by the Department, and shall include the following: 

(1) The cause, time periods, and magnitude of all emissions which exceed the 

applicable emission standards; 

(2) The source downtime including the time and date of the beginning and end 

of each downtime period and whether the source downtime was planned or 

unplanned; 

(3) The time periods and cause of all CEM downtime including records of any 

repairs, adjustments, or maintenance that may affect the validity of emission 

data; 

(4) Quarterly totals of excess emissions, installation downtime, and CEM 

downtime during the calendar quarter; 

(5) Quarterly quality assurance activities; 

(6) Daily calibration activities that include reference values, actual values, 

absolute or percent of span differences, and drift status; and 

(7) Other information required by the Department that is determined to be 

necessary to evaluate the data, to ensure that compliance is achieved, or to 

determine the applicability of this regulation. 

[COMAR 26.11.01.11A(3) and COMAR26.11.01.10G(2)(d)] 

B1. The Permittee shall submit the results of performance tests before the close of 

business on the 60th day following the completion of the performance test. 

[40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] 

B2. At least 30 days prior to each stack emissions testing, the Permittee shall submit 

to the Department a stack test protocol for review and approval. 

[Part D(7) of Permit to Construct #06-6-0256 issued April 8, 1999 and 

revised June 7, 2000] 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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A and B 

 The Permittee shall submit a summary report semiannually which contains all 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)]

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Clinker Handling and Craneway - Fugitive Sources

(Subject to MACT Requirements)

7A Emissions Unit Number(s)

CWAY – Craneway 

G04-040 – Drag Conveyor B2 

H04-004 – Clinker Bin 403 

H05-004 – Clinker Bin 503 

H06-004 – Clinker Bin 603 

H07-004 – Clinker Bin 

TU3 – Gypsum Truck Unloading 

TU4 – Truck Unloading 

 Applicable Standards/Limits:

(1) COMAR 26.11.06.03C(1) - Particulate Matter from Unconfined Sources - A 

person may not cause or permit emissions from an unconfined sources without 

taking reasonable precautions to prevent particulate matter from becoming 

airborne. 

(2) COMAR 26.11.06.03D - Particulate Matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable 

precautions to prevent particulate matter from becoming airborne. 

(3) 40 CFR §63.1348 which limits opacity to 10% or less for each new or existing 

raw material, clinker, or finished product storage bin; conveying system transfer 

point; bagging system; and bulk loading or unloading system. 

 Testing Requirements

None

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of each 

emission unit in accordance with Method 22 of Appendix A to part 60. The test 

must be conducted while the emission unit is in operation. If no visible 

emissions are observed in six consecutive monthly tests for any emission unit, 

the Permittee may decrease the frequency of testing from monthly to semiannually for that emission unit. If visible emissions are observed during any 

semi-annual test, the Permittee must resume testing of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. If no visible emissions are observed during the 

semi-annual test for any emission unit, the Permittee may decrease the 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 66 of 91 

frequency of testing from semi-annually to annually for that emission unit. If 

visible emissions are observed during any annual test, the Permittee must 

resume testing of that emission unit on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive monthly 

tests. 

If visible emissions are observed during any Method 22 test, the Permittee shall 

initiate the corrective actions specified in the written operations and 

maintenance plan and conduct the follow-up Method 22 test until the problem is 

resolved.

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations 

and maintenance plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)] 

 Record Keeping Requirements

The Permittee shall maintain all records for at least five years following the date of 

each occurrence, measurement, maintenance, corrective action, report, or record. At a 

minimum, the most recent two years of data shall be retained on site. The remaining 

three years of data may be retained off site. The files may be maintained on 

microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[40 CFR §63.1355] 

 Reporting Requirements

The Permittee shall submit a summary report semiannually which contains all failures 

to comply with any provision of the operation and maintenance plan developed in 

accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)]

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Clinker Handling and Craneway - Point Sources

(Subject to MACT requirements)

7B Emissions Unit Number(s)

Baghouse Emission Unit

G04-011 G04-010- Bucket Elevator 

 G04-014- 750 MT Clinker Bin 

 G04-020- Belt Conveyor 

H09-051 H09-028- Bucket Elevator 

 H09-062- Reversible Belt Conveyor 

H09-059 H09-047- Bucket Elevator 

H09-058- Belt Conveyor 

H09-000- Semifinish Grinding System 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 67 of 91 

H09-031- Belt Conveyor 

G04-034 G04-009 & G04-016 - Belt Conveyor 

 G04-010- Bucket Elevator 

 G04-056- 100 MT Clinker Bin Weighfeeder 

H09-025 H09-019- Weighfeeder 

 H09-023- 100 MT Gypsum Bin Weighfeeder 

H09-024- Belt Conveyor (from Weighfeeder) 

H09-082 H09-021- 100 MT Clinker Bin Weighfeeder 

H09-066- Belt Conveyor 

 H09-020- 100 MT Slag/Clinker Bin Weighfeeder 

G01-009 G01-012- Clinker Storage Silo 

G02-047 G02-002-Transfer Tower #13 

Belt Conveyor 

G02-044 G02-002- Transfer Tower #12 

 Belt Conveyor 

G02-021 G02-002-Transfer Tower #11 

Belt Conveyor 

G02-025 TT6- Transfer Tower #6 

B01-018 TT8/9- Transfer Tower #8/9 

G02-053 TL1- Clinker Truck/Rail Loadout 

H09-033 H09-031 & H09-046 - Belt Conveyor 

H09-036 & H09-041 - Bin & Roll Press 

G03-011 TT9/10- Transfer Tower #9/10 

G03-004 TT7- Transfer Tower #7 

H09-094 H09-091- Metal Reclamation System Belt Conveyor 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than 

water in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or 

existing raw material, clinker, or finished product storage bin; conveying 

system transfer point; bagging system; and bulk loading or unloading 

system. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 

0.03 gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000 – All emission units shall be equipped with a dust 

collector designed to reduce particulate matter emissions to 0.01 

gr/SCFD (22.9 mg/dscm) except TT9/10 - Transfer Tower #9/10 which 

is required to meet 0.0108 gr/SCFD (24.7 mg/dscm). 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 68 of 91 

 Testing Requirements

A & B. None

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for that emission unit. If visible 

emissions are observed during any semi-annual test, the Permittee must resume 

testing of the exhaust stack of that emission unit on a monthly basis and 

maintain that schedule until no visible emissions are observed in six consecutive 

monthly tests. If no visible emissions are observed during the semi-annual test 

for the exhaust stack of any emission unit, the Permittee may decrease the 

frequency of testing from semi-annually to annually for the exhaust stack of that 

emission unit. If visible emissions are observed during any annual test, the 

Permittee must resume testing of the exhaust stack of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

written operations and maintenance plan. Within 24 hours at the end of the 

Method 22 test, the Permittee shall conduct a follow-up Method 22 test of each 

stack from which visible emissions were observed during the previous Method 

22 test. If visible emissions are still observed, conduct a visual opacity test in 

accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test 

and the duration of the Method 9 test shall be at least six minutes. 

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations 

and maintenance plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

B. The exhaust gas from each emissions unit shall vent a dust collector designed to 

reduce particulate matter emissions limits before discharging into the 

atmosphere. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date 

of each occurrence, measurement, maintenance, corrective action, report or 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 69 of 91 

record. At a minimum, the most recent two years of data shall be retained on 

site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

no microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C]

 Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Finish Mill Systems

(Subject to MACT requirements)

8 Emissions Unit Number(s)

H04-044 H04-006- Belt Conveyor 

 H04-014- Finish Mill #4 System 

H06-044 H06-014- Finish Mill #6 System 

 H06-017- Cyclone 642 (FM#6 System) 

 H06-037- Separator 627 (FM#6 System) 

H07-056 H07-014- Finish Mill #7 System and H07-018, H07-069, & H07-070 – 

Finished Cement Transfer System 

H07-057 H07-018, H07-069, & H07-070 – Finished Cement Transfer System 

H05-044 H05-014- Finish Mill #5 System 

H08-056 H08-014- Finish Mill #8 System, H08-017- Separator (FM#8 System), H08-

037- Cyclone (FM#8 System), and H08-067- Cyclone (FM#8 System) 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1347 which limits opacity from the finish mills to 10 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 70 of 91 

percent or less. 

B. Particulate Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 0.03 

gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000, which limits particulate matter from each exhaust stack of 

H04-006 Belt Conveyor, H04-014 Finish Mill #4, H05-014 Finish Mill 

#5, H06-014 Finish Mill #6, H06-017 Cyclone 642, and H06-037 

Separator 627 to 0.0132 gr/scfd (30.2 mg/dscm). 

(3) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000, which limits particulate matter from each exhaust stack of 

H07-014 Finish Mill #7, H08-014 Finish Mill #8, and H07-018, H07-

069, & H07-070 – Finished Cement Transfer System to 0.01 gr/scfd 

(22.9 mg/dscm).

 Testing Requirements

A. None 

B. The Permittee shall conduct a particulate matter emissions test for each mill at 

least once every 5-year period in accordance with AMA Technical Memorandum 

91-01 or using Method 5 of 40 CFR Part 60, Appendix A. Each performance 

test shall consist of three separate runs under the conditions that exist when the 

affected source is operating under representative performance condition s in 

accordance with 40 CFR Part 63, Subpart LLL. Each run shall be conducted for 

at least one hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). 

The average of the three runs shall be used to determine compliance. 

[Part D(6) of Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000] 

 Monitoring Requirements

A1. The Permittee shall conduct daily visual emissions observations of each mill 

sweep and air separator PMCDs of each affected source in accordance with 

Method 22 of Appendix A to part 60. The Method 22 test shall be conducted 

while the affected source is operating under representative performance 

condition s in accordance with 40 CFR 63.7(e). The duration of the Method 22 

test shall be six minutes. If visible emissions are observed during any Method 

22 test, the Permittee shall: 

(1) Initiate, within one-hour, the corrective actions specified in the site 

specific written operations and an maintenance plan required under 40 

CFR §63.1350(a); 

(2) Within 24 hours of the end of the Method 22 test in which visible 

emissions were observed, conduct a follow-up Method 22 test of each 

stack from which visible emissions were observed during the previous 

Method 22 test; and 

(3) If visible emissions are observed during the follow-up Method 22 test, 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 71 of 91 

conduct a visual opacity test of each stack from which visible emissions 

were observed in accordance with Method 9 of appendix A of 40 CFR 

Part 60. The Method 9 test shall be conducted within one-hour of the end 

of the follow-up Method 22 test and the duration of the Method 9 test 

shall be at least thirty minutes. 

[40 CFR §63.1350(e)] 

A2. The Permittee shall comply with and update as needed the written operations and 

maintenance plan. The plan shall include the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §63.1347; and 

(2) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)] 

B. The exhaust gases from each emission unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging to the 

atmosphere. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date 

of each occurrence, measurement, maintenance, corrective action, report or 

record. At a minimum, the most recent two years of data shall be retained on 

site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

no microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain all the records of particulate matter emissions test 

results for at least five years and make them available to the Department upon 

request. At a minimum, the most recent two years of data shall be retained on 

site. The remaining three years of data may be retained off site. The files may 

be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, 

or on microfiche. 

[COMAR 26.11.03.06C]

 Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B1. At least 30 days prior to each stack emissions testing, the Permittee shall submit 

to the Department a stack test protocol for review and approval. 

B2. Within 60 days after each stack emissions testing, the Permittee shall submit to 

the Department the stack emissions test reports and compliance demonstration 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 72 of 91 

with emissions limits. 

[Permit to Construct #06-6-0256N dated April 8, 1999 and revised June 7, 2000]

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Cement Loadout 

(Subject to MACT requirements)

9 Emissions Unit Number(s)

Baghouse Emission Unit

H10-113 H07-040- Cement Cooler 

 H07-071- Airslide 

H08-040-Cement Cooler 

H08-064- Airslide 

H10-001- Airslide 

H10-006- Bucket Elevator 

H10-181 H10-167- Airslide 

H10-176- Bucket Elevator 

H10-179 H10-177- Airslide 

I01-033- Day Tank 

I02-290 I02-289 – Feed Bin 

TL2 – Truck Day Tank Loadout 

H10-221 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

H10-224 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

H10-252 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

H10-254 F1-8, G1-8, H1-8, and J1-8 - Product Silos 

Eastpkhs I03/I04 - Packaging and Palletizing 

H10-119 H10-007, H10-124, and H10-125- Airslide 

H10-010- Bucket Elevator 

I02-204 TL4 - Truck/ Rail and Bulk Loadout System 

I02-208 TL4 - Truck/ Rail and Bulk Loadout System 

I02-224 TL4 - Truck/ Rail and Bulk Loadout System 

I02-228 TL4 - Truck/ Rail and Bulk Loadout System 

I02-244 TL4 - Truck/ Rail and Bulk Loadout System 

I02-248 TL4 - Truck/ Rail and Bulk Loadout System 

I02-264 TL4 - Truck/ Rail and Bulk Loadout System 

I02-268 TL4 - Truck/ Rail and Bulk Loadout System 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or 

existing raw material, clinker, or finished product storage bin; conveying 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 73 of 91 

system transfer point; bagging system; and bulk loading or unloading 

system.

B. Particulate Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 0.03 

gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000, which limits particulate matter from each emissions unit 

to 0.01 gr/scfd (22.9 mg/dscm). 

 Testing Requirements

A & B. None 

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the Permittee 

must resume testing of the exhaust stack of that emission unit on a monthly basis 

and maintain that schedule until no visible emissions are observed in six 

consecutive monthly tests. If no visible emissions are observed during the semiannual test for the exhaust stack of any emission unit, the Permittee may 

decrease the frequency of testing from semi-annually to annually for the exhaust 

stack of that emission unit. If visible emissions are observed during any annual 

test, the Permittee must resume testing of the exhaust stack of that emission unit 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

written operations and maintenance plan. Within 24 hours at the end of the 

Method 22 test, the Permittee shall conduct a follow-up Method 22 test of each 

stack from which visible emissions were observed during the previous Method 

22 test. If visible emissions are still observed, conduct a visual opacity test in 

accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test 

and the duration of the Method 9 test shall be at least six minutes. 

[40 CFR §63.1350(a)(4)(i)-(iii) and (l)] 

A2. The Permittee shall comply with and update as needed the written operations and 

maintenance plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; and 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 74 of 91 

(2) Procedures to be used to periodically monitor affected sources. 

[40 CFR §63.1350(a) and (b)]

B. The exhaust gases from each emissions shall vent through a dust collector to 

meet the particulate matter emissions limit before discharging into the 

atmosphere. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date 

of each occurrence, measurement, maintenance, corrective action, report or 

record. At a minimum, the most recent two years of data shall be retained on 

site; the remaining three years of data may be retained offsite. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

on microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Waste Dust Handling - Point Sources

(Not subject to MACT requirements)

10 Emissions Unit Number(s)

Baghouse Emission Unit

C04-050 C04-037- Bucket Elevator 

C04-075 C04-037- Bucket Elevator 

C04-050 C04-038- 600T Bin and C04-068- Airslide 

C04-075 C04-070, C04-072, and C04-074- Airslide 

 TL3 – Truck Waste Dust Loadout 

 Applicable Standards/Limits:
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 75 of 91 

A. Visible Emissions 

COMAR 26.11.06.02C(2) - A person may not cause or permit the discharge of 

emissions from any installation or building, other than water in an uncombined 

form, which is visible to human observers. 

B. Particulate Matter Emissions 

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 0.03 

gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000- Each emissions unit shall be equipped with a dust collector 

designed to reduce particulate matter emissions to 0.01 gr/SCFD (22.9 

mg/dscm). 

 Testing Requirements

A & B None

 Monitoring Requirements

A. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the 

Permittee must resume testing of the exhaust stack of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. If no visible emissions are observed during the 

semi-annual test for the exhaust stack of any emission unit, the Permittee may 

decrease the frequency of testing from semi-annually to annually for the exhaust 

stack of that emission unit. If visible emissions are observed during any annual 

test, the Permittee must resume testing of the exhaust stack of that emission unit 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

preventive maintenance plan or the best management plan. Within 24 hours at 

the end of the Method 22 test, the Permittee shall conduct a follow-up Method 

22 test of each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are still observed, conduct a visual 

opacity test in accordance with Method 9 of Appendix A of 40 CFR Part 60. 

The Method 9 test shall be conducted within one-hour of the end of the followup Method 22 test and the duration of the Method 9 test shall be at least six 

minutes. 

[COMAR 26.11.03.06C] 

B1. The exhaust gas from each emissions unit shall vent through a dust collector 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 76 of 91 

designed to meet the particulate matter emissions limit before discharging into 

the atmosphere. 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update as needed the preventative 

maintenance plan for each baghouse that describes the maintenance activity and 

time schedule for completing each activity. The Permittee shall perform 

maintenance activities within the timeframes established in the plan and shall 

maintain a log with records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly 

inspections for at least five (5) years and make them available to the 

Department upon request. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be 

retained off site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A and B. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

Miscellaneous Sources Venting Inside Building 

(Subject to MACT requirements)

11 Emissions Unit Number(s)

Baghouse Emission Unit

G04-037 G04-018-Belt Conveyor 

G04-037 G04-019-CE2 Bucket Elevator 

H09-073 G04-031-Drag Conveyor B3 

H09-073 H09-058-Belt Conveyor 

H09-073 H09-075-90T Bin 

 Applicable Standards/Limits:

A. Visible Emissions 

(1) COMAR 26.11.06.02C(2) - A person may not cause or permit the 

discharge of emissions from any installation or building, other than water 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 77 of 91 

in an uncombined form, which is visible to human observers. 

(2) 40 CFR §63.1348 which limits opacity to 10% or less for each new or 

existing raw material, clinker, or finished product storage bin; conveying 

system transfer point; bagging system; and bulk loading or unloading 

system. 

B. Particulate Emissions

(1) COMAR 26.11.06.03B(2) - A person may not cause or permit 

particulate matter to be discharged from any installation in excess of 0.03 

gr/SCFD (68.7 mg/dscm). 

(2) Permit to Construct #06-6-0256N dated April 8, 1999 and revised 

June 7, 2000- Each emissions unit shall be equipped with a dust collector 

designed to reduce particulate matter emissions to 0.01 gr/SCFD (22.9 

mg/dscm). 

 Testing Requirements

A & B. None

 Monitoring Requirements

A1. The Permittee shall conduct a monthly 1-minute visible emissions test of the 

exhaust stack of each emission unit in accordance with Method 22 of Appendix 

A to part 60. The test must be conducted while the emission unit is in operation. 

If no visible emissions are observed in six consecutive monthly tests for the 

exhaust stack of any emission unit, the Permittee may decrease the frequency of 

testing from monthly to semi-annually for the exhaust stack of that emission 

unit. If visible emissions are observed during any semi-annual test, the 

Permittee must resume testing of the exhaust stack of that emission unit on a 

monthly basis and maintain that schedule until no visible emissions are observed 

in six consecutive monthly tests. If no visible emissions are observed during the 

semi-annual test for the exhaust stack of any emission unit, the Permittee may 

decrease the frequency of testing from semi-annually to annually for the exhaust 

stack of that emission unit. If visible emissions are observed during any annual 

test, the Permittee must resume testing of the exhaust stack of that emission unit 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive monthly tests. 

If visible emissions are observed on each stack during any Method 22 test, the 

Permittee shall initiate, within one hour, the corrective actions specified in the 

written operations and maintenance plan. Within 24 hours at the end of the 

Method 22 test, the Permittee shall conduct a follow-up Method 22 test of each 

stack from which visible emissions were observed during the previous Method 

22 test. If visible emissions are still observed, conduct a visual opacity test in 

accordance with Method 9 of Appendix A of 40 CFR Part 60. The Method 9 test 

shall be conducted within one-hour of the end of the follow-up Method 22 test 

and the duration of the Method 9 test shall be at least six minutes. 

[40 CFR §63.1350(a)(4)(i)-(iii)] 

The Permittee have the option to conduct a Method 22 visible emissions test 

according to the requirements of 40 CFR §63.1350(a)(4)(i)-(iii) and (l) for each 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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emissions unit located within the building, or for the building itself. If visible 

emissions from the building are monitored, the requirements of 40 CFR 

§63.1350(a)(4)(i)-(iii) and (l) apply to monitoring the building, and the Permittee 

must also test visible emissions from each side, roof, and vent of the building for 

at least 1 minute. The test must be conducted under normal operating 

conditions.

[40 CFR §63.1350(a)(4)(vi)-(vii)] 

A2. The Permittee shall comply with and update as needed the written operations and 

maintenance plan which includes the following information: 

(1) Procedures for proper operation and maintenance of the affected source 

and air pollution control devices in order to meet the emission limits and 

operating limits of §§63.1348; and 

(2) Procedures to be used to periodically monitor affected sources. 

 [40 CFR §63.1350(a) and (b)] 

B. The exhaust gas from each emissions unit shall vent through a dust collector 

designed to meet the particulate matter emissions limit before discharging into 

the atmosphere. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain all records for at least five years following the date 

of each occurrence, measurement, maintenance, corrective action, report, or 

record. At a minimum, the most recent two years of data shall be retained on site. 

The remaining three years of data may be retained off site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. 

[40 CFR §63.1355] 

B. The Permittee shall maintain the log of inspection and maintenance 

records for at least five (5) years and make it available to the Department 

upon request. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A. The Permittee shall submit a summary report semiannually which contains all 

failures to comply with any provision of the operation and maintenance plan 

developed in accordance with §63.1350(a). 

[40 CFR §63.1354(b)(9)(v)] 

B. None

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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Facility Wide 

12 Emissions Unit Number(s)

Facility Wide 

 Applicable Standards/Limits:

A. NOx Emissions 

Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 

2000 which states that NOx emissions from the entire premises shall not exceed 

4,871 tons for any 12-month period, rolling monthly. 

B. Particulate Matter Emissions 

Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 

2000 which states that emissions from the entire premises shall not exceed the 

following limits for any 12-month period, rolling monthly: 

(1) 925 tons of PM; 

(2) 716 tons of PM10; and 

(3) 586 tons of PM10 stack emissions. 

C. Sulfur Emissions 

Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 

2000 which states that SO2 emissions from the entire premises shall not exceed 

1,041 tons for any 12-month period, rolling monthly. 

D. Carbon Monoxide Emissions 

Prevention of Significant Deterioration (PSD) Approval #PSD-97-01R dated 

April 8, 1999 which states that the premises-wide carbon monoxide (C0) 

emissions from the Pyroprocessing Portland cement plant and the existing 

Portland cement plant shall not exceed 3,328 tons for any 12-month period, 

rolling monthly. 

E. VOC Emissions 

New Source Review Approval #NSR-97-02 issued April 8, 1999 which states 

that premises-wide emissions shall not exceed 165 tons of VOC for any 12-

month period, rolling monthly. In determining compliance with VOC emission 

limits, VOC emissions shall be determined by calculating the numerical 

difference between the measured values of total hydrocarbon (THC) emissions 

and non-VOC emissions. 

F. Lead Emissions 

Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 7, 

2000 which states that the emissions from the entire premises, including the 

existing Portland cement plant and the Pyroprocessing Portland cement plant, 

shall not exceed 0.6 tons of lead for any 12-month period, rolling monthly. 

G. Fluoride Emissions 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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(1) Permit to Construct #06-6-0256 dated April 8, 1999 and revised June 

7, 2000 which states that the emissions from the entire premises, including 

the existing Portland cement plant and the Pyroprocessing Portland cement 

plant, shall not exceed 3.0 tons of fluoride for any 12-month period, rolling 

monthly. 

(2) COMAR 26.11.03.06C which prevents the discharge of fluorides into the 

atmosphere that causes a violation of any applicable ambient air quality 

standards for fluorides set forth in COMAR 26.11.04. 

 Testing Requirements

A thru G 

None 

 Monitoring Requirements

A thru G 

 The Permittee shall calculate premises-wide emissions for each month and each 

12-month period, rolling monthly, to demonstrate compliance with the emissions 

limits. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A thru G 

The Permittee shall maintain the following records with supporting 

documentation for at least five years and make these records available to the 

Department upon request: 

(1) Premises-wide emissions for each month and each 12-month period, rolling 

monthly; and 

(2) Any violation of any emission limit required for each rolling 12-month 

period. 

At a minimum, the most recent two years of data shall be retained on site. The 

remaining three years of data may be retained off site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

on microfiche. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A through G 

(1) The Permittee shall include the emissions of NOx, Particulate matter, SO2 ,

CO, VOC, Lead, and Fluoride for each month and each 12-month period, 

rolling monthly, in the required quarterly report, the semiannual summary 

report, and the annual emission certification. 

(2) The Permittee shall submit to the Department a written report, no later than 30 

days after a detection of any violation of any emission limit required for each 

rolling 12-month period. 

[COMAR 26.11.03.06C] 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 

MACT Requirements
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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(Applies to MACT Sources Only)

Applicable Standards and Regulations

The Permittee shall comply with the following sections of the General Provisions. The 

provisions, which do not apply, have been deleted. 

Table 1 to Subpart LLL of Part 63—Applicability of General Provisions 

General Provisions 

40 CFR Citation 

Requirement Comment 

63.1(a)(1) through (4) Applicability 

63.1(a)(6) through (a)(8) Applicability 

63.1(a)(10) through (14) Applicability 

63.1(b)(2) and (3) Initial Applicability Determination

63.1(c)(1) Applicability after Standard 

 Established 

63.1(c)(2) Permit Requirements Area Sources Must Obtain 

Title V 

Permits 

63.1(c)(4) and (5) Extensions, Notifications 

63.1(e) Applicability of Permit Program 

63.2 Definitions Additional Definitions in 

§63.1341 

63.3(a) through (c) Units and Abbreviations 

63.4(a)(1) through (a)(3) Prohibited Activities 

63.4(a)(5) Compliance Date 

63.4(b)and (c) Circumvention, Severability 

63.5(a)(1) and (2) Construction/Reconstruction 

63.5(b)(1) Compliance Dates 

63.5(b)(3) through (6) Construction Approval. 

Applicability 

63.5(d)(1) through (4) Approval of Construction/ 

Reconstruction 

63.5(e) Approval of Construction/ 

Reconstruction 

63.5(f)(1) and (2) Approval of Construction/ 

Reconstruction 

63.6(a) Compliance for Standards and 

Maintenance 

63.6(b)(1) through (5) Compliance Dates 

63.6(b)(7) Compliance Dates 

63.6(c)(1) and (2) Compliance Dates 

63.6(c)(5) Compliance Dates 

63.6(e)(1) and (e)(2) Operation & Maintenance 
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PART 70 OPERATING PERMIT NO. 24-013-00012 

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63.6(e)(3) Startup, Shutdown and 

 Malfunction 

63.6(f)(1) through (3) Compliance with Emission 

Standards 

63.6(g)(1) through (g)(3) Alternative Standard 

63.6(h)(1) and (2) Opacity/VE Standards 

63.6(h)(4) and (h)(5)(i) Opacity/VE Standards 

63.6(h)(6) Opacity/VE Standards 

63.6(h)(7) Opacity/VE Standards 

63.6(i)(1) through (i)(14) Extension of Compliance 

63.6(i)(16) Extension of Compliance 

63.6(j) Exemption from Compliance 

63.7(a)(1) through (a)(3) Performance Testing 

Requirements 

§63.1349 has specific 

requirements 

63.7(b) Notification 

63.7(c) Quality Assurance/Test Plan 

63.7(d) Testing Facilities 

63.7(e)(1) through (4) Conduct of Tests 

63.7(f) Alternative Test Method 

63.7(g) Data Analysis 

63.7(h) Waiver of Tests 

63.8(a)(1) Monitoring Requirements 

63.8(b)(1) through (3) Conduct of Monitoring 

63.8(c)(1) through (8) CMS Operation/Maintenance Performance specification 

supersedes requirements 

for THC CEM. Temperature 

and activated carbon 

injection monitoring data 

reduction requirements 

given in subpart LLL. 

63.8(d) Quality Control 

63.8(e) Performance Evaluation for CMS Performance Specification 

supersedes requirements 

for THC 

63.8(f)(1) through (f)(5) Alternative Monitoring Method Additional requirements in 

§1350(l) 

63.8(f)(6) Alternative to RATA Test 

63.8(g) Data Reduction 

63.9(a) Notification Requirements 

63.9(b)(1) through (5) Initial Notifications 

63.9(c) Request for Compliance Extension 

63.9(d) New Source Notification for 

Special Compliance Requirements

63.9(e) Notification of Performance Test 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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63.9(f) Notification of VE/Opacity Test Notification not required for 

VE/opacity test under 

§63.1350(e) and (j) 

63.9(g) Additional CMS Notifications 

63.9(h)(1) through (h)(3) Notification of Compliance Status 

63.9(h)(5) and (h)(6) Notification of Compliance Status 

63.9(i) Adjustment of Deadlines 

63.9(j) Change in Previous Information 

63.10(a) Record keeping/Reporting 

63.10(b) General Requirements 

63.10(c)(1) Additional CMS Record Keeping PS-8A applies instead of 

requirements for THC CEM 

63.10(c)(5) through (c)(8) Additional CMS Record Keeping PS-8A applies instead of 

requirements for THC CEM 

63.10(c)(10) through (15) Additional CMS Record Keeping 

63.10(d)(1) General Reporting Requirements 

63.10(d)(2) Performance Test Results 

63.10(d)(3) Opacity or VE Observations 

63.10(d)(4) Progress Reports 

63.10(d)(5) Startup, Shutdown, Malfunction 

Reports 

63.10(e)(1) and (e)(2) Additional CMS Reports 

63.10(e)(3) Excess Emissions and CMS 

Performance Reports 

Exceedances are defined in 

subpart LLL 

63.10(f) Waiver for Record Keeping/ 

Reporting 

63.12(a)-(c) State Authority and Delegations 

63.13(a)-(c) State/Regional Addresses 

63.14(a) and (b) Incorporation by Reference 

63.15(a) and (b) Availability of Information 

13 Emissions Unit Number(s)

Facility Wide- MACT Sources Only 

Applicable Standards/Limits:

40 CFR §63.6(e)(3)(i) which requires that the Permittee comply with the written startup, 

shutdown, and malfunction plan that describes, in detail, procedures for operating and 

maintaining the source during periods of startup, shutdown, and malfunction; a program 

of corrective action for malfunctioning process; and air pollution control and monitoring 

equipment used to comply with the relevant standard. 

40 CFR §63.6(e)(3)(viii) which states that the Permittee may periodically revise the 

startup, shutdown, and malfunction plan for the affected source as necessary to satisfy 

the requirements of this part or to reflect changes in equipment or procedures at the 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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affected source. Unless the permitting authority provides otherwise, the Permittee may 

make such revisions to the startup, shutdown, and malfunction plan without prior 

approval by the Administrator or the permitting authority. However, each revision to a 

startup, shutdown, and malfunction plan must be reported in the semiannual report 

required by §63.10(d)(5). If the start-up, shutdown, and malfunction plan fails to 

address or inadequately addresses an event that meets the characteristics of a 

malfunction but was not included in the start-up, shutdown, and malfunction plan at the 

time the Permittee developed the plan, the Permittee must revise the startup, shutdown, 

and malfunction plan within 45 days after the event to include detailed procedures for 

operating and maintaining the source during similar malfunction events and a program 

of corrective action for similar malfunctions of process or air pollution control and 

monitoring equipment. In the event that the Permittee makes any revision to the 

startup, shutdown, and malfunction plan which alters the scope of the activities at the 

source which are deemed to be a startup, shutdown, and malfunction, or otherwise 

modifies the applicability of any emission limit, work practice requirement, or other 

requirement in a standard established under this part, the revised plan shall not take 

effect until after the Permittee has provided a written notice describing the revision to 

the permitting authority. 

Testing Requirements

40 CFR 63.1349(c) requires the Permittee to repeat performance test for particulate 

matter emissions required under 40 CFR 63.1349(b)(1) and (b)(2) at least once every five 

years. 40 CFR 63.1349(d) requires the Permittee to repeat performance test for 

dioxin/furan emissions required under 40 CFR 63.1349(b)(3) at least once every 30 

months. 40 CFR 63.1349(e)(1) requires that if a source plans to undertake a change in 

operations that may adversely affect compliance with an applicable D/F standard under 

this subpart, the source must conduct a performance test and establish new temperature 

limit(s) as specified in paragraph (b)(3) of this section. 40 CFR 63.1349(e)(2) requires 

that If a source plans to undertake a change in operations that may adversely affect 

compliance with an applicable PM standard under § 63.1343, the source must conduct a 

performance test as specified in paragraph (b)(1) of this section. 

[40 CFR 63.1349(c), (d), and (e)]

Monitoring Requirements

At all times, including periods of startup, shutdown, and malfunction, the Permittee 

shall operate and maintain any affected source, including associated air pollution 

control equipment and monitoring equipment, in a manner consistent with safety and 

good air pollution control practices for minimizing emissions to the levels required by 

the relevant standards, i.e., meet the emission standard or comply with the start-up, 

shutdown, and malfunction plan. Malfunctions shall be corrected as soon as 

practicable after their occurrence in accordance with the startup, shutdown, and 

malfunction plan. To the extent that an unexpected event arises during a start-up, 

shutdown, and malfunction, the Permittee shall comply by minimizing emissions 

during such a startup, shutdown, or malfunction event consistent with safety and good 

air pollution control practices. 

[40 CFR §63.6(e)(1)(i -ii)] 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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For any affected source located inside a building, the Permittee has the option to monitor 

visible emissions for each conveying system transfer point or the building in accordance 

with 40 CFR §63.1350(a)(4)(i – iii) and (l). If visible emissions from a building are 

monitored, the Permittee must also test visible emissions from each side, roof, and vent 

of the building for at least 1 minute. The test must be conducted under normal operating 

condition. 

[40 CFR §63.1350(a)(4)(vi – vii)]

Record Keeping Requirements

When actions taken by the Permittee during a startup, shutdown, or malfunction 

(including actions taken to correct a malfunction) are consistent with the procedures 

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

Permittee shall keep records for that event which demonstrate the procedures specified 

in the plan were followed. These records may take the form of a “checklist”, or other 

effective form of record keeping that confirms conformance with the startup, 

shutdown, and malfunction plan for that event. In addition, the Permittee shall keep 

records of these events as specified in §63.10(b), including records of the occurrence 

and duration of each startup, shutdown, or malfunction of operation and each 

malfunction of the air pollution control and monitoring equipment. Furthermore, the 

Permittee shall confirm that action taken during the relevant reporting period during 

periods of start-up, shutdown, or malfunction were consistent with the affected 

source’s startup, shutdown, and malfunction plan in the semiannual (or more frequent) 

startup, shutdown, and malfunction report required in §63.10(d)(5). 

If an action taken by the Permittee during a startup, shutdown, or malfunction (including 

an action taken to correct a malfunction) is not consistent with the procedures specified 

in the affected source’s startup, shutdown, and malfunction plan, and the source exceeds 

the relevant emission standard, then the Permittee shall record the actions taken for that 

event and shall report such actions within 2 working days after commencing actions 

inconsistent with the plan, followed by a letter within 7 working days after the end of 

the event, in accordance with §63.10(d)(5) (unless the Permittee makes alternative 

reporting arrangements , in advance, with the Administrator). 

The Permittee shall maintain at the affected source a current startup, shutdown, and 

malfunction plan and shall make the plan available upon request for inspection and 

copying by the Administrator. In addition, if the startup, shutdown, and malfunction 

plan is subsequently revised, the Permittee shall maintain at the affected source each 

previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, and 

must make each such previous version available for inspection and copying by the 

Administrator for a period of 5 years after revision of the plan. If at any time after 

adoption of a startup, shutdown, and malfunction plan the affected source ceases 

operation or is otherwise no longer subject to the provisions of this part, the Permittee 

shall retain a copy of the most recent plan for 5 years from the date the source ceases 

operation or is no longer subject to this part and shall make the plan available upon 

request for inspection and copying by the Administrator. 

[40 CFR §63.6(e)(3)(iii – v)] 
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UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

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Reporting Requirements

The Permittee shall, if actions taken are consistent with the procedures specified in the 

startup, shutdown, or malfunction plan, during a startup, shutdown, or malfunction of 

an affected source (including actions taken to correct a malfunction), state such 

information in a semiannual report. Reports shall only be required if a startup, 

shutdown, or malfunction occurred during the reporting period. The startup, shutdown, 

and malfunction report may be submitted simultaneously with the excess emissions and 

continuous monitoring system performance reports. 

Any time an action taken by the Permittee during a startup, shutdown, or malfunction 

(including actions taken to correct a malfunction) is not consistent with the procedures 

in the startup, shutdown, or malfunction plan, the Permittee shall make an immediate 

report of the actions taken for that event within 2 working days, by telephone call or 

fax transmission. The immediate report shall be followed by a letter, certified by the 

Permittee explaining the circumstances of the event, the reasons for not following the 

startup, shutdown, or malfunction plan, and whether any excess emissions and/or 

parameter monitoring exceedances are believed to have occurred. 

[40 CFR §63.1354(b)(4 – 5)]

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed 

in the table above. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 87 of 91 

SECTION V INSIGNIFICANT ACTIVITIES

This section contains a list of the insignificant emissions units that were reported in the 

Title V permit application. The applicable Clean Air Act requirements, if any, are listed 

below the insignificant activity. 

(1) No.__3__ Stationary internal combustion engines with less than 1,000 brake 

horsepower (746 kilowatt) operating less than 2000 hours and all 

stationary internal combustion engines with less than 500 brake 

horsepower (373 kilowatt); 

(a) Emissions During Idle Mode (COMAR 26.11.09.05B(2)). The 

Permittee may not cause or permit the discharge of emissions 

from any engine, operating at other than idle conditions, greater 

than 10 percent opacity. 

(b) Emissions During operating Mode (COMAR 26.11.0905b(3)). 

The Permittee may not cause or permit the discharge of 

emissions from any engine, operating at other than idle 

conditions greater than 40 percent opacity. 

(c) Exceptions: 

(i) COMAR 26.11.09.5B(2) does not apply for a period of 2 

consecutive minutes after a period of idling of 15 

consecutive minutes for the purpose of clearing exhaust 

system. 

(ii) COMAR 26.11.09.5B(3) does not apply to emissions 

resulting directly from cold engine start-up and warm-up for 

the following maximum periods: 

(1) Engines that are idled continuously when not in service: 

30 minutes; and 

(2) All other engines: 15 minutes. 

(iii) COMAR 26.11.09.05B(2) & (3) does not apply while 

maintenance, repair or testing is being performed by 

qualified mechanics. 

(2) ___X___ Water cooling towers and water cooling ponds unless used for 

evaporative cooling of water from barometric jets or barometric 

condensers, or used in conjunction with an installation requiring a 

permit to operate; 
LEHIGH CEMENT COMPANY 

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PART 70 OPERATING PERMIT NO. 24-013-00012 

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(3) No.__4__ Unheated VOC dispensing containers or unheated VOC rinsing 

containers of 60 gallons (227 liters) capacity or less; 

(a) The Permittee shall not use any VOC degreasing material that 

exceeds a vapor pressure of 1mmHg at 20° Celsius (COMAR 

26.11.19.09D(2)(b)). 

(b) The Permittee shall implement good operating practices to 

minimize spills and evaporation of VOC degreasing material. 

These practices shall include covers (including water covers), 

lids, or other methods of minimizing evaporative losses, and 

reducing the time and frequency during which parts are 

cleaned (COMAR 26311.19.09D(3)(a-d)). 

(c) The Permittee shall not use a halogenated substance that is a 

VOC in any cold degreasing operations (COMAR 

263.11.19.09D(3)(a-d)). 

The Permittee shall maintain the following records of operating data 

at the sire for at least five (5) years and shall make available to the 

Department upon request: 

(a) Monthly records of the total VOC degreasing material used 

(COMAR 26.11.19.09F); and 

(b) The good operating practices established by COMAR 

26.11.19.09D established in Writing and displayed so they are 

clearly visible to the operator at the facility (COMAR 

26.11.19.09D(3)(a-d)). 

(4) ___X___ Equipment for drilling, carving, cutting, routing, turning, sawing, 

planing, spindle sanding, or disc sanding of wood or wood products; 

Containers, reservoirs, or tanks used exclusively for: 

(5) ___X___ Storage of butane, propane, or liquefied petroleum, or natural gas; 

 

(19) ___X___ Storage of lubricating oils: 

(a) constructed before July 23, 1984, or 

(b) constructed after July 23, 1984 and are less than 10,000 gals.; 
LEHIGH CEMENT COMPANY 

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PART 70 OPERATING PERMIT NO. 24-013-00012 

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(20) ___X___ Storage of lubricating oils greater than 10,000 gals. and constructed 

after July 23, 1984; (NOTE: tanks may have applicable 

requirements in 40CFR60) 

(23) No.__2__ Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation jet engine 

fuel; 

(a) constructed before July 23, 1984, or 

(a) constructed after July 23, 1984 and are less than 10,000 gals.; 

(24) No.__1__ Storage of Numbers 1,2,4,5, and 6 fuel oil and aviation jet engine 

fuel greater than 10,000 gals. and constructed after July 23, 1984; 

(NOTE: this condition has applicable requirements in 40CFR60) 

(25) No.__X_ Storage of motor vehicle gasoline, having an individual tank 

capacity of 2,000 gallons or less; 

(36) ___X___ First aid and emergency medical care provided at the facility, 

including related activities such as sterilization and medicine 

preparation used in support of a manufacturing or production 

process: 

(38) ___X___ Potable water treatment equipment, not including air-stripping 

 equipment; 

(39) ___X___ Noncontact water (i.e, water that has not been in direct contact with 

process fluids) cooling towers except as regulated under Section 112 

of the Clean Air Act; 

(41) ___X___ Emissions resulting from the use of explosives for blasting at 

quarrying operations and from the required disposal of boxes used to 

ship the explosive; 

(42) ___X___ Comfort air conditioning subject to requirements of title VI the 

Clean Air Act; and 

(46) ___X___ Laboratory fume hoods and vents. 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 90 of 91 

SECTION VI STATE ONLY ENFORCEABLE CONDITIONS

The Permittee is subject to the following state-only enforceable requirements: 

A. Applicable Regulations 

(1) COMAR 26.11.01.11B(7), which requires installation of a data telemetry 

system for all required CEMs. This system shall be designed and installed in 

accordance with specifications approved by the Department and shall be 

operational by the date specified in Regulation .10D(1) of this chapter. 

(2) COMAR 26.11.06.08 and 26.11.06.09, which generally prohibit the 

discharge of emissions beyond the property line in such a manner that a 

nuisance or air pollution is created. 

(3) COMAR 26.11.15.05, which requires that the Permittee implement 

“Best Available Control Technology for Toxics” (T – BACT) to 

control emissions of toxic air pollutants. 

(4) COMAR 26.11.15.06, which prohibits the discharge of toxic air 

pollutants to the extent that such emissions will unreasonably 

endanger human health 

B. Compliance Demonstration 

(1) The Permittee shall submit to the Department, by April 1 of each year during 

the term of this permit, a written certification of the results of an analysis of 

emissions of toxic air pollutants from the Permittee’s facility during the 

previous calendar year. The analysis shall include either: 

(a) a statement that previously submitted compliance demonstrations 

for emissions of toxic air pollutants remain valid, or 

(b) a revised compliance demonstration, developed in accordance with 

requirements included under COMAR 26.11.15 & 16, that accounts for 

changes in operations, analytical methods, emissions determinations, or 

other circumstances that have invalidated previous demonstrations. 

(2) The Permittee shall not use any alternative kiln raw material, fuel, or additive 

except the following: 

(a) Quarried stone, sand and shale; 

(b) Iron-bearing materials, such as pyrites and millscale; 

(c) Cat fines; 

(d) Bottom ash and fly ash from coal-fired fuel burning equipment; 

(e) Coal; 

(f) Scrap tires; 
LEHIGH CEMENT COMPANY 

UNION BRIDGE MARYLAND 

PART 70 OPERATING PERMIT NO. 24-013-00012 

Page 91 of 91 

(g) Petroleum coke; 

(h) Used oil generated on site; and 

(i) Other materials which are included in the Permittee’s current 

operating permit or may have been approved by the Department in 

the past under separate action. 

Any alternative kiln raw material, fuel, or additive not approved under authority of 

this permit or under any previous action may not be used unless it is demonstrated 

to the Department's satisfaction that the use of any substitute raw material, fuel or 

additive does not violate the Department’s air toxics screening levels and does not 

increase air emissions beyond the allowable limits stated in the permit to construct, 

the PSD approval, or the NSR approval. 

[Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7, 2000]