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 (C OMAR) 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 heari ng be held regarding the pe rmit. This request shall be made to the Department in writing not later than 15 days after the applicant receives notice that the pe rmit has been denied or of the objectionable terms and conditions. The request shall include the basis for the request and refer to any object ionable terms and conditions.

If you have any questions, please feel fr ee 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 IIIBcc: Shannon, George B, DaveLEHIGH 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 Fred erick 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 kiln s were replaced with one pre-heater/k iln 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 Br idge 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 sa nd, mill scale and fly ash/bottom ash are purchased.

Rock Crushing

Trucks dump the rock into the hopper of an ap ron feeder, which feeds a gyratory crusher where it is broken down into fragments less than six inches in si ze. 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 diam eter and 126 feet high an d 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 st orage piles. Alumina-bear ing 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 sepa rate 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 throug h a dust collector to the main kiln stack. The raw mill runs most, but not all, of the time the kiln operates.

Blending SiloLEHIGH 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. Pa rticulate 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 th e 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 vent ed through a dust collector to the main kiln stack.

Kiln , Raw Meal Feed, and Coal Mill Feed Systems

The preheater/precalciner kiln system allows hi gher production with a smaller kiln and more efficient fuel use. The pr ocess 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 ve nt 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 evaporat e 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 be fore 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 st ack. 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 th e 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 th e 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 mi ll 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 NO X (TPY) SO X (TPY) PM 10 (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 NO X , 25 tons per year for VOCs, 100 tons per year for any other criteria pollutants, 10 tons per year for any single hazardou s air pollutant (HAP) and 25 tons pe r year for combined HAPs. Since the actual emissions of NOx, SOx, PM 10, 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 r eceived 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 Pa rt 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 Emission s 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 Emission s 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 1970LEHIGH 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 Emission s 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 Emission s 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 2002LEHIGH 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 Emission s 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 (subj ect to MACT requirements)
Emissions Unit
Number Emissions Unit Name Emission s 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- 2002LEHIGH 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 Emission s 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 Emission s 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 Emission s 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 Emission s 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 2002LEHIGH 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 Emission s 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 Emission s 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 1970LEHIGH 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 Emission s 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 Emission s 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 Emission s 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 Emission s Unit Description Date of
Installation G04-018 Belt conveyor Venting through Dust Collector G04-037
located inside – NP1 NewLEHIGH 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 Emission s 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 2000LEHIGH 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 de scription of the facility and an inventory list of the emissions units for which applicable requiremen ts are identified in Section IV of the permit.

Section II of the Part 70 Permit contains the ge neral 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 certifica tion 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 wo rk 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 tes ting, 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-on ly enforceable requiremen ts. 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 th at 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 ai r pollutant (HAP) emission source. The Lehigh Union Bridge Plant is subject to the Portland Cement MACT st andards 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 determina tion (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 requ irements 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, th e new kiln is considered a New Brownfield Site, not a Greenfield site. The following sources at a Portland cement plant are su bject 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 asso ciated 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 transferri ng material from the raw mate rial 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 asso ciated with the conv eyor transferring material from the raw material storage to the raw mill. Conveyor system transf er 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 mi ll. 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 Ju ly 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 change s to the rule. 67 Fed. Reg. 72580 (D ec. 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 opera tions 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 reconstructe d 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 Perform ance for Nonmetallic Mineral Processing Plant. The raw material storage equipment cons tructed 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 Subpa rt Y of Part 60 - Standards of Performance for Coal Preparation Plants.

Operations at the quarry are not subject to NSPS requ irements 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 provisio ns 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 Pr eparation Plants”, do not apply to conveying system transfer points used to convey coal from the mill to the kiln that are associated with coal prep aration. (See § 63.1356)

Prevention of Significant Deterior ation(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, PM 10 , SO 2 , 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 CountyLEHIGH 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 hand led, transported, or st ored, or a building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent par ticulate 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 th at will be used to take reasonable precautions. Th e 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 b ecoming 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 requiremen t 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 requirem ents for the Portland Cement MACT. Although these emissions source s 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 reason able precautions are being implemen ted, 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 updatedLEHIGH 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 pr ocedures are needed to pr event 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; andLEHIGH 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 mo nthly 1-minute visible emissions te st 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 emissi on unit, the Permittee ma y 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, th e 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 speci fied 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 ti me schedule for comple ting 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 maintena nce 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 dataLEHIGH 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 year s 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 : T he 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 be gins 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 ty pe 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 subjec t to the general emission standard of COMAR 26.11.06.03B(1)(b)(ii). In addition, the emission un its 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 baghou ses 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 hand led, transported, or st ored, or a building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent par ticulate 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 precau tions. The best management plan may be included in the written operation and mainte nance plan required under the Portland Cement
MACT.

The Permittee shall perform an inspection at a mini mum of one minute once a month or when weather conditions are favorable to create particulate matter b ecoming 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 reason able precautions are being implemen ted, 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 pr ocedures are needed to pr event particulate matter from becoming airborne.

2B. Raw Material Handling- Fugitive Sour ces (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 pre cautions 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 emi ssions are observed in si x consecutive monthly tests for any emission unit, the Permit tee 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 Pe rmittee 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 maintena nce 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 pe riodically 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, correctiv e action, report, or record. At a minimum, the most recent two years of data shall be retained on site. The remaini ng 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 im plemented, 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 ai rborne. 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 RequirementsLEHIGH 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 mo nthly 1-minute visible emissions te st 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 emissi on unit, the Permittee ma y 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, th e 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions speci fied 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 ti me schedule for comple ting 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 ke pt 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 year s 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 be gins 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 ty pe 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 subjec t to the general emission standard of COMAR 26.11.06.03B(1)(b)(ii). In addition, the emission un its 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 baghou ses designed to meet a specified emission rate.

The Permittee provided information with the PSD appli cation 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 Sour ces (Subject to MACT Requirements) Baghouse Emission Unit C01-007 C02-061- Belt Conveyor C02-038- Reject s 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 co llector designed to reduce partic ulate matter emissions to 0.01 gr/SCFD (22.9 mg/dscm).

Compliance Demonstration Testing requirements
NoneLEHIGH 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 visi ble emissions test of the exhaust stack of each
affected source in accordance w ith Method 22 of Appendix A to part 60. The test must be
conducted while the a ffected 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 sour ce 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 ex haust 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 observ ed during any annual te st, 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions sp ecified 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 emi ssions 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 maintena nce 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 pe riodically 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 leas t 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 y ears 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 controllin g emissions of particulate matter from the emission units. The Portland Cement MACT limits opacity to 10 percent. The MACT re quires 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 requirem ents therefore there is no periodic monitoring proposed for the
emissions units.

For particulate matter, the Permittee is subjec t 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 li mit facility-wide increase of PM-10 emissions from the modernization/expansion project, to below the PSD si gnificance 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 hand led, transported, or st ored, or a building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent par ticulate matter from becoming airborne.

Compliance Demonstration Testing Requirements
NoneLEHIGH 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 precau tions. The best management plan may be included in the written operation and mainte nance 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 b ecoming 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 reason able precautions are being implemen ted, 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 pr ocedures are needed to pr event 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 storag e system, or coal transf er 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 visibl e 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 emissi on unit, the Permittee ma y 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, th e 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions speci fied 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 accordan ce 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 ti me schedule for comple ting 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 offLEHIGH 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 ke pt 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 year s 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 be gins 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 ty pe 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 subjec t to the general emission standard of COMAR 26.11.06.03B(1)(b)(ii). In addition, the emission un its 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 baghou ses designed to meet a specified emission rate.

The Permittee provided information with the PSD appli cation 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 (Sub ject 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 BinLEHIGH 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 Meth od 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 vi sible 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 decr ease 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 observ ed on each stack during any Method 22 test, the Permittee shall initiate, within one hour, the corrective ac tions 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 ma intenance 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 pe riodically monitor affected sources. [40 CFR §63.1350(a) and (b)]

B. Particulate matter Emissions The exhaust gas from each equipment shall vent a du st 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 l east 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 y ears 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 upo n request. At a minimum, the most recent two years of data shall be retained on site. The remain ing 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 re quires 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 requirem ents 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 subjec t 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-1 0. 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-Precal ciner/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, pr eheater-precalciner, kiln, clinker cool er, baghouse, stack and associated
duct work. Gases from the Preheat er-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 mi ll feed system, including th e coal mill, is not subject to MACT requirements, the coal mi lls are addressed here with Preheat er-Precalciner/Kiln system because they utilize the exhaust gases fr om the Preheater-Precalciner/K iln 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 rev ised June 7, 2000 which states that NOx emissions from the entire prem ises 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 Ap ril 8, 1999 and revis ed June 7, 2000 which
states that SO 2 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 fr om 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-wid e 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 differenc e 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 pr emises, including the existing Portland cement plant and theLEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 32 of 64 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 ar e 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 pr emises, 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 emissi ons 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 ex ist 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 emi ssion 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 sa mple volume for each run shall be at least 2.5 dscm (90 dscf). The concentration shall be dete rmined for each run an d the arithmetic average
of the concentrations measured for the three ru ns 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 calc ulated for each minute of each run of the test. (4) The run average temperature must be calcula ted 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 Pa rt 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)]LEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 33 of 64 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 oper ation and maintenance of the a ffected 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 contin uously 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 Ins titute 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 sh all be calculated as the average of 180 successive one-minute average temperatures. (4) The period of time when one-minute aver ages 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 th ree-hour rolling average temperature must begin anew, without co nsidering 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 th e Performance Specifications under 40 CFR Part 60, Ap pendix B and the Quality
Assurance Procedures under 40 CFR Part 60, Appendix F. [COMAR 26.11.09.08H(1) and Permit to Construc t #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 SO 2 emissions from the main exhaust stack. The Permittee shall install, operate, maintain, and calibrate the CEM in
accordance with th e Performance Specifications under 40 CFR Part 60, Ap pendix 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]LEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 34 of 64 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. Th e 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 occurr ence, 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 an d 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.LEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 35 of 64 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 Sy stem (CMS) Performance on January
31 st and July 31 st 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 summ ary, 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 sha ll 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;LEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 36 of 64 (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 va lues, 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 60 th 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 emissi ons 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 an d each rolling 12-m onth 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 SO 2 emissions and to CEM for
NOx or SO 2
. [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 an d 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 matterLEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 37 of 64 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 60 th 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 (3 65° F). The testing with the Raw Mill off indicated a dioxin/furan concentration of 0.0169 ng per dscm corrected to se ven percent oxygen at an average temperature of 124.4°C (224° F).

Lehigh also conducted the tests for Lead emissions from th e 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 De partment has decide d 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 Ap ril 8, 1999 and revised June 7, 2 000, 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.LEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 38 of 64 Compliance Demonstration Testing Requirements
A. None

B. The Permittee shall conduct a particulate matter emi ssions 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, co rrective action, report or record. At a minimum, the most recent two years of data shall be retained on site; the remaining three y ears 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:LEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 39 of 64 (1) The cause, time periods, and magnitude of a ll emissions which exceed the applicable emission standards; (2) The source downtime includin g 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 performa nce tests before the close of business on the 60 th 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 te sting, 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 an d 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 associ ated 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 testin g 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 re quires the Permittee to install, operate, and maintain a continuous opacity mon itor. The Permittee is required to submit a quarterly summary report that includes the cause, time period s, and magnitude of all emissions which exceed the standards of 10 percent opacity. The report also includes the time peri ods 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 subjec t 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 increaseLEHIGH CEMENT COMPANY
UNION BRIDGE PLANT
PART 70 OPERATING PERMIT FACT SHEET
OPERATING PERMIT NO. 24-013-00012

Page 40 of 64 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 te st 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 hand led, transported, or st ored, or a building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent par ticulate 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 emi ssions are observed in si x consecutive monthly tests for any emission unit, the Permit tee 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 Pe rmittee 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 maintena nce 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 pe riodically 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, correctiv e action, report, or record. At a minimum, the most recent two years of data shall be retained on site. The remainin g 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 reason able precautions are being implemen ted, 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 pr ocedures are needed to pr event particulate matter from becoming airborne.

7B. Clinker Handling and Craneway- Point So urces (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 visi ble emissions test of the exhaust stack of each
affected source in accordance w ith Method 22 of Appendix A to part 60. The test must be
conducted while the a ffected 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 sour ce 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 ex haust 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 observ ed during any annual te st, the Permittee shallLEHIGH 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions sp ecified 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 emi ssions 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 oper ation and maintenance of the a ffected 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 pe riodically monitor affected sources. [40 CFR §63.1350(a) and (b)]

B. The exhaust gas from each emission unit shall vent th rough 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 leas t 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 y ears 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 upo n request. At a minimum, the most recent two years of data shall be retained on site. The remain ing 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. Lehi gh 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 collect ors demonstrated that the du st 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 controllin g emissions of particulate matter from the emission units. The Portland Cement MACT limits opacity to 10 percent. The MACT re quires 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 requiremen ts therefore there is no periodic monitoring proposed for the
emissions units.

For particulate matter, the Permittee is subjec t 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-1 0. 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 M ill #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 emissi ons 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 represen tative performance conditions in accordance with 40 CFR Part 63, Subpart LLL. Each run shall be conduc ted 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 proced ures 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 cond itions in accordance w ith 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 speci fied 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 emissi ons were observed during the previous Method 22 test; and (3) If visible emissions are obse rved during the follow-up Method 22 test, conduct a visual opacity test of
each stack from which visible emissi ons 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 maintena nce 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 peri odically 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 leas t five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. At a minimum, the most recent two yearsLEHIGH 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 remaini ng 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 Depart ment upon request. At a minimum, the most recent two years of data shall be re tained on site; the remaining thr ee 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 testi ng, 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 wa s 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 te sting 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 testi ng 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 re quires the Permittee to perform daily visible emissions observations of the ex haust 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 requ irements 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 subjec t 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-1 0. 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 pr ocedures 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 em issions 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 visi ble emissions test of the exhaust stack of each
affected source in accordance w ith Method 22 of Appendix A to part 60. The test must be
conducted while the a ffected 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 sour ce 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 ex haust 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 observ ed during any annual te st, 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions sp ecified 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 emi ssions 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 maintena nce 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 pe riodically 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 RequirementsLEHIGH 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, maintena nce, 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 upo n request. At a minimum, the most recent two years of data shall be retained on site. The remain ing 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 controllin g emissions of particulate matter from the emission units. The Portland Cement MACT limits opacity to 10 percent. The MACT re quires 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 requirem ents therefore there is no periodic monitoring proposed for the
emissions units.

For particulate matter, the Permittee is subjec t 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-1 0. 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 UnitLEHIGH 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 inst allation 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 visibl e 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 emissi on unit, the Permittee ma y 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, th e 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions speci fied 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 ti me schedule for comple ting 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 ke pt 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 year s 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 be gins 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 ty pe 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 subjec t to the general emission standard of COMAR 26.11.06.03B(1)(b)(ii). In addition, the emission un its 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 baghou ses designed to meet a specified emission rate.

The Permittee provided information with the PSD appli cation 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 UnitLEHIGH 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 visi ble 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 emissi on unit, the Permittee ma y 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, th e 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 Meth od 22 test, the Permittee shall initiate, within one hour, the corrective actions sp ecified 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 emi ssions 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 em issions unit located within the building, or for the building itself. If visible emissions from the building are monitored, theLEHIGH 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) an d (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 maintena nce 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 pe riodically 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, maintena nce, 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 upo n request. At a minimum, the most recent two years of data shall be retained on site. The remain ing 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 th e 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 subjec t to the general emission standard of COMAR 26.11.06.03B(1)(b)(ii). In addition, the emission un its are subject to a more restrictive limit based onLEHIGH 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 baghou ses designed to meet a specified emission rate.

The Permittee provided information with the PSD applica tion that the baghouses were designed to satisfy the emissions limitation. No stack testing was required. If pr operly 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 ef ficiency. The Permittee is also required to maintain inspection and maintenance records for the baghouses to dem onstrate that a preventative pl an is being implemented.

Since all emissions units are located inside the building, the Permittee could only monitor the visible emissions from the building in acco rdance 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 PM 10 ; and (3) 586 tons of PM 10 stack emissions.
Note: The PM and PM 10 limitations are based on the emissions number in the PSD application for the total new potential emissions of PM and PM 10 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
PM 10
.

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 PyroprocessingPortland cement plant, shall not exceed the following limits for any 12-month period, rolling monthly1,041 tons of SO 2
. Note: The SO 2 limitation is based on the emissions number in the PSD application for the total new potential emissions of SO 2 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 SO 2
.

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 pl ant 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 es tablished 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 determ ined by calculating the nu merical 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 le vel for lead. The projected potential increase in emissions of lead submitted in the PSD applicati on 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 prem ises-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, SO 2 , 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 availabl e to the Department upon request: (1) Premises-wide emissions for e ach month and each 12-month pe riod, rolling monthly; and (2) Any violation of any emission limit re quired 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 file s may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. [COMAR 26.11.03.06C]

Reporting RequirementsLEHIGH 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 emissi ons of NOx, Particulate matter, SO 2 , CO, VOC, Lead,
and Fluoride for each month and each 12-month period, rolling monthl y, in the required quarterly report, the semiannual summary repo rt, 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 resu lts of compliance stack tests. The emissions of NOx,
SO 2, 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 SO 2 CEM was certified on August 14, 2002. Based on the CEM collected data for SO 2 during the 12 month period, September 2002 to August 2003, the total emissions were 9 tons per year. The SO 2 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 DeterminationLEHIGH 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) Circumve ntion, 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 RequirementsLEHIGH CEMENT COMPANY
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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 k eeping/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 Author ity and Delegations 63.13(a)-(c) State/Re gional 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, procedur es for operating and maintaining the source duringLEHIGH 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 sour ce 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 Administrato r or the permitting authority. Howe ver, 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 addres s or inadequately addresse s 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 deta iled 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 pl an 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 performa nce 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 plan s 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 speci fied 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 acc ordance with the startup, shutdown, and malfunction plan. To the extent that an un expected 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 po int 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 th e 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 RequirementsLEHIGH CEMENT COMPANY
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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 specifi ed in the affected source’s start-up, shutdown, and malfunction plan, the Permittee shall keep records for that event which demonstr ate the procedures specified in the plan were followed. These records may ta ke the form of a “checklist”, or other effective form of re cord 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 r ecords 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 speci fied in the affected source ’s startup, shutdown, and malfunction plan, and the source exceeds the relevant emissi on 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 ac cordance with §63.10(d)(5) (unless the Permittee makes alternative reporting arra ngements , in advance, with the Administrator).

The Permittee shall maintain at the aff ected 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 adop tion of a startup, shutdown, and malfun ction 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 operati on 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 informa tion in a semiannual report. Reports sh all 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 procedur es 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 follo wed by a letter, certified by the Permittee explaining the circumstances of the event, the reason s 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 SCHEDULELEHIGH 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 recy cling and emission reductions pursuant to 40 CFR Part 82, Subpart F.

SECTION 112(r) – AC CIDENTAL 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 emission s 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 consecutiv e 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 cont ainers or unheated VOC rinsing containers of 60 gallons (227 liters) capacity or less;

(a) The Permittee shall not use any VOC de greasing material that exceeds a vapor pressure of 1mmHg at 20° Cels ius (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 du ring 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 medici ne 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 un der Section 112 of the Clean Air Act;

(41) _X

_ Emissions resulting from the use of explosiv es 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; andLEHIGH 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 su ch a manner that a nuisance or air pollution is created.

(3) COMAR 26.11.15.05
, which requires the installation and operatio n of T-BACT for new installations or sources discharging a toxic ai r 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 approv al, 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 ............................................................ 32LEHIGH 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 SPEC IFIC CONDITIONS.................................................... 38

SECTION V INSIGNIFICANT ACTIVITIES........................................................ 87

SECTION VI STATE ONLY EN FORCEABLE CONDITIONS............................ 90LEHIGH 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 Por tland cement manufacturing plant in Union Bridge, Maryland. The plant is located in both Ca rroll and Frederick Counties. The quarry is located in Fred erick County while the main part of the plant is located in Carroll County. The or iginal 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 Emission s 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 withLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 5 of 91 Emissions Unit
Number Emissions Unit Name Emission s Unit Description Date of
Installation
025 – EP6 New DC

2. Raw Material Handling

Emissions Unit
Number Emissions Unit Name Emission s 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 2002LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 6 of 91 Emissions Unit
Number Emissions Unit Name Emission s 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 Emission s 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 Di scharging 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 2002LEHIGH 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 Emission s 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 Emission s Unit Description Date of
Installation

C02-025
E02-001
E01-001 Raw Mill
Kiln Precalciner/preheater Discharging to dust collector C04-
014 – EP13 2001LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 8 of 91 Emissions Unit
Number Emissions Unit Name Emission s 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 – Po int Sources (subject to MACT requirements)
Emissions Unit
Number Emissions Unit Name Emission s 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 Emission s 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 Di scharging 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- 2001LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 9 of 91 Emissions Unit
Number Emissions Unit Name Emission s 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 (sub ject to MACT requirements)
Emissions Unit
Number Emissions Unit Name Emission s 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 1970LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 10 of 91 Emissions Unit
Number Emissions Unit Name Emission s 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 Disc harging 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 Emission s 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 Di scharges 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, 1970LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 11 of 91 Emissions Unit
Number Emissions Unit Name Emission s Unit Description Date of
Installation 68, 69, 70, & 71

10. Waste Dust Handling – ( not subject to MACT requirements)
Emissions Unit
Number Emissions Unit Name Emission s 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 Emission s 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 2000LEHIGH 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 otherw ise 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 CompoundsLEHIGH 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 c onditions 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 w ill automatica lly 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 corre cted 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 in formation 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 confid entiality 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 s upporting the claim of confidentiality. Information submitted to the Department w ithout a request that the information be deemed confidential may be made availabl e to the public. Subject to approval of the Department, the Permittee may provide a summary of confidential information that is suitable for public revi ew. 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 re opened and revised for cause. The filing of an application by the Permittee for a permit revision or renewal; or a notification of termination, planned cha nges 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 fals e 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 complian ce with applicable requirements of the Clean Air Act; or

d. Additional requirements become app licable 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 pe rmit 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 official s 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 re voke 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 PE RMITS—GENERAL CONDITIONS

[COMAR 26.11.03.14] and[COMAR 26.11.03.06A(8)]

a. The Permittee shall submit an applicati on 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 th e source and revision to the permit.
This information shall be sufficient to evaluate the propos ed change and to determine whether it will comply with all applicable requirements of the
Clean Air Act.

c. The Permittee may not change any pr ovision of a compliance plan or schedule in a Part 70 permit as an administrative permit amendment or as a minor permit modification unless th e 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 ch ange 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 CO MAR 26.11.03.17 and in accordance with the following conditions:

a. A significant modification is a revi sion 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 leve l 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 operati on 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 pe rmit issuance and renewal, including the requirements for applications, publ ic participation, and review by affected states and EPA, except:

(1) An application needs only to incl ude 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 ch ange that would otherwise require aLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 17 of 91 significant permit modification if proce dures for enhanced preconstruction review of the change are followed th at 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 significan t permit modification that results in a violation of any applicable re quirement 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 issu ed 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, orLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 18 of 91 (c) Changing from one approved te st 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 standa rd 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 th e 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 th e 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 perm its, 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 na me, 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 owne rship 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 Pa rt 70 permit, are governed by regulations promulgated under Titl e 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 approva ls 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 constr uct or approvals otherwise required by COMAR 26.11.02 prior to making the change have firs t 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 CHANG ES 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 pe rmits and approvals required by COMAR 26.11.02 and .03;

(2) The change is not subject to a ny 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 Ai r 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 federa lly 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 pe rmits 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 fe derally enforceable permit term or condition related to monitoring, including test methods, record keeping, reporting, or complia nce certificati on requirements;

(6) The change does not violate a fe derally 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 expressl y prohibit the change under COMAR
26.11.03.18.

b. The Permittee shall notify the Departme nt and the EPA in writing of a proposed on-permit change under CO MAR 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; andLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 24 of 91 (5) Any permit term or condition that would no longer apply.

c. The responsible official of this faci lity 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 requirem ent 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 PERMIT S TO CONSTRUC T 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:LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 25 of 91 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 di scharges one ton per year or more of lead or lead compounds measured as elemental lead, permit to construct;

f. All stationary sources of air pollu tion, 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 conf lict between the a pplicability of (a -e) above and an exemption listed in COMAR 26.11.02.10 , the provision th at 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 ex tent 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 pe rmits but may not adversely affect the rights of a person, including EPA and aff ected 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.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 26 of 91 20. PROPERTY RIGHTS

[COMAR 26.11.03.06E(4)]

This Part 70 permit does not convey a ny 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 th e 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 de lay and without prio r notification the Permittee's property where a Part 70 source is located, emissions-related activity is conducted, or records required by th is permit are kept;

b. Have access to and make copies of records required by the permit;

c. Inspect all emissions units within th e facility subject to the permit and all related monitoring systems, air polluti on 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)]LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 27 of 91 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 theDepartment 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 c onditions 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.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 28 of 91 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 em ission which would otherwise constitute a violation of any applicable ai r pollution control regulation.

28. PERMIT SHIELD

[COMAR 26.11.03.23]

A permit shield as described in COMA R 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 vi olation 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;LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 29 of 91 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 appr oved 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.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 30 of 91 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, repair ed, 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 re quest and receive approval from the Department.

3. AIR POLLUTION EPISODE

[COMAR 26.11.05.04]

When requested by the Department, the Pe rmittee shall prepare in writing standby emissions reduction plans, consistent with good industrial practice and safe operating procedures, for reducing emissi ons creating air pollu tion during periods of Alert, Warning, and Emergenc y 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 fo llowing conditions for occurrences of
excess emissions and deviations from re quirements 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;LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 31 of 91 b. Promptly report all occurrences of excess emissions that are expected to last for one hour or longer by orally notif ying 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 desc ription of the deviation to the Department. The written report must include the cause, dates and times of
the onset and termination of the deviati on, as well as the action planned or taken to reduce, eliminate, and prev ent 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 fro m 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, identifi cation 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.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 32 of 91 The Permittee shall initiate a permit revision or reopening according to the procedures of 40 CFR Part 70.7 to incor porate 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.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 33 of 91 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 followi ng information if applicable:

(1) The total amount of actual em issions 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 produc tion 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 em ission monitors that are required by this permit, including monito r calibration and malfunction information;

(5) Identification, description, a nd 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 informati on as required by the Department.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 34 of 91 9. COMPLIANCE CERTIFICATION REPORT

[COMAR 26.11.03.06C(6) and (7)]

The Permittee shall submit to the Depa rtment and EPA Region III a report certifying compliance with each term of this Part 70 permit including each applicable standard, emission limitati on, 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 determin e 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 comp liance certifications submitted pursuant to this permit shall be certified by a respons ible official as to truth, accuracy, and completeness. The Permittee shall expedi tiously notify the De partment 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 supervisi on in accordance with a system designed to assure that qua lified 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, theLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 35 of 91 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 th e 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 sa mple or emissions test is performed and the name of the person taking the samp le or performing th e emissions test;

d. The identity of the Permittee, individu al, 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 re cords of all monitoring data and support information that supports the compliance ce rtification 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;LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 36 of 91 c. Records which support the annua l 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 ac tivities at the facility.

15. OZONE DEPLETING REGULATIONS

[40 CFR Part 82, Subpart F]

The Permittee shall comply with the st andards for recycling and emissions reduction pursuant to 40 CFR Part 82, S ubpart F, except as provided for MVACs in subpart B:

a. Persons opening appliances for mainte nance, 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 st andards for recycling and recovery equipment pursuant to §82.158.

c. Persons performing maintenance, servi ce, repairs or dispos al of appliances must be certified by an approved tec hnician certification program pursuant to §82.161.

d. Persons performing maintenance, servi ce, repairs or dispos al of appliances must certify with the Administrator pursuant to §82.162.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 37 of 91 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 indust rial 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 ApplicableLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 38 of 91 SECTION IV PLANT SPECIFIC CONDITIONS

This section is comprised of tables cont aining the emissions standards, emissions limitations and work practices a pplicable 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 s ource 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, it s appurtenances, or a road to be used, constructed, altered, repaired, or demolis hed 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 fa vorable to create particulate matter becoming airborne to verify that be st management practices are being implemented. [COMAR 26.11.03.06C] Record Keeping Requirements: The Permittee shall maintain the best manage ment plan and records of the dates and inspection results for at least five (5) years and make them available to theLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 39 of 91 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 requi rements 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 buildi ng, 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 ofLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 40 of 91 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 par ticulate 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 par ticulate 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 fo r the exhaust stack of that emission
unit. If visible emissions are obser ved during any semi-annual test, the Permittee must resume testing of the e xhaust stack of that emission unit on a monthly basis and maintain that sc hedule until no visible emissions are observed in six consecutive monthly tests. If no visible emi ssions are observed during the semi-annual test for the exha ust 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 re sume 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 e ach 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 MethodLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 41 of 91 22 test of each stack from which visi ble 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 conduc ted 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 an d maintenance plan required under the
Portland Cement MACT. The Permittee shall perform maintenance activities
within the timeframes established in th e 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) ye ars and make them available to the Department upon request. At a minimu m, 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 magn etic 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 minimu m, 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 magn etic tape, or on microfiche. [COMAR 26.11.03.06C] Reporting Requirements:
A and B. None A permit shield shall cover the applicable requi rements 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 DomeLEHIGH 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 Un confined 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, it s 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 pl an 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 fa vorable to create particulate matter becoming airborne to verify that be st 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 disk s, on magnetic tape, or on microfiche. [COMAR 26.11.03.06C ] Reporting Requirements
None A permit shield shall cover the applicable requi rements 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 609LEHIGH 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 Un confined 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, it s 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 produc t 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 consecutiv e 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 resu me testing of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions 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 duri ng any Method 22 test, the Permittee shall initiate the corrective actions spec ified 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 or der to meet the emission limits and operating limits of §§63.1348; and (2) Procedures to be used to peri odically 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, co rrective 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 disk s, 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 oper ation and maintenance plan developed in accordance with §63.1350(a). [40 CFR §63.1354(b)(9)(v)] A permit shield shall cover the applicable requi rements 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 Bear ing 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 insta llation or building, other than waterLEHIGH 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 par ticulate 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 fo r 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 st ack 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 visibl e 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 visibl e 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 e ach 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 visi ble emissions were observed during the previous Method 22 test. If visible emi ssions 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 thr ough 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 an d update as needed the preventative maintenance plan for each baghouse that describes the maintenance activity and time schedule for completing each act ivity. The Permittee shall perform
maintenance activities within the timeframes establishe d in the plan and shall maintain a log with records of th e 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) ye ars and make them available to the Department upon request. At a minimu m, 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 magne tic 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 maintain ed 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 requi rements 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 in stallation or building, other than water in an uncombined form, whic h 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 fi nished product storage bin; conveyingLEHIGH 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 par ticulate 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 fo r the exhaust stack of that emission
unit. If visible emissions are obs erved during any semi-annual test, the Permittee must resume testing of the e xhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions 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 visibl e 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 e ach 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 conduc t a follow-up Method 22 test of each
stack from which visible emissions we re 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 with in 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 or der to meet the emission limits and operating limits of §§63.1348; andLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 48 of 91 (2) Procedures to be used to peri odically monitor affected sources. [40 CFR §63.1350(a) and (b)]

B. The exhaust gas from each emissions unit shall vent thr ough 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, mainte nance, 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 re cent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintain ed 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 requi rements 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 Un confined Sources - ALEHIGH 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, it s 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 pl an 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 fa vorable to create particulate matter becoming airborne to verify that be st 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 disk s, on magnetic tape, or on microfiche. [COMAR 26.11.03.06C ] Reporting Requirements
None A permit shield shall cover the applicable requi rements 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 ConveyorLEHIGH 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 insta llation 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 par ticulate 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 emission s 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 exha ust stack of that
emission unit. If visible emissions ar e observed during any annual test, the Permittee must resume testing of the e xhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions are observed in six consecutive monthly tests.
If visible emissions are observed on e ach 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 visi ble emissions were observed during the previous Method 22 test. If visible emi ssions are still observed, conduct a visualLEHIGH 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 a nd update as needed the preventative maintenance plan for each baghouse that describes the maintenance activity and time schedule for completing each ac tivity. The Permittee shall perform
maintenance activities within the timeframe s established in the plan and shall maintain a log with records of th e 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) ye ars and make them available to the Department upon request. At a minimu m, 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 magne tic 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 maintain ed 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 requi rements 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 - AirslideLEHIGH 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 insta llation 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 fi nished 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 em issions 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 fo r 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 stac k of that emission unit on a monthly basis
and maintain that schedule until no vi sible emissions are observed in six consecutive monthly tests. If no visibl e 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 se mi-annually to annually for the exhaust
stack of that emission unit. If visibl e 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 e ach 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 conduc t a follow-up Method 22 test of each
stack from which visible emissions we re 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 upda te as needed the written operations and maintenance plan which includes the following information: (1) Procedures for proper operation a nd maintenance of the affected source and air pollution control devices in or der to meet the emission limits and operating limits of §§63.1348; (2) Procedures to be used to peri odically 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, main tenance, 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 re cent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintain ed 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 allLEHIGH CEMENT COMPANY
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 requi rements 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- Preheate r-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 insta llation 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 fr om 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) co rrected to sevenLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 55 of 91 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 ei ther meet the applicable emission standards in §C(2) of this regulati on 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 SO 2 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 Deteriorat ion (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 de termining 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 a nd ethane) measured during the most

recent test.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 56 of 91 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 fo r 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 Pyropro cessing 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 r uns; each run shall
be conducted under the conditions that exist when the affected source is operating at under representative perf ormance 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 concentr ations measured for the three runs shall be calculated and used to determine compliance. (2) The temperature at the inlet to th e kiln or in-line kiln/raw mill PMCD must be continuously recorded durin g 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 mu st be calculated for each minute of
each run of the test.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 57 of 91 (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 opac ity. 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 or der to meet the emission limits and operating limits of §63.1344; (2) Corrective actions to be take n 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 con duct an inspection of the components of the combustio n 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.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 58 of 91 (1) The recorder response range must in clude 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 thermo couple-potentiometer system or alternate reference, subject to approval by the Administrator. (3) The three-hour rolling average temper ature 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 firs t 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 begi n 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 CE M in accordance with the Performance Specifications under 40 CFR Part 60, A ppendix 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 em issions monitoring system, (CEM) to
monitor SO 2 emissions from the main exhaust stack. The Permittee shall install, operate, maintain, and calibrate the CE M in accordance with the Performance Specifications under 40 CFR Part 60, A ppendix 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, operat e, maintain, and calibrate the CEM in accordance with the Performance Speci fications under 40 CFR Part 60, Appendix B and the Quality Assurance Procedures under 40 CFR Part 60, Appendix F. [Prevention of Significant Deterioratio n (PSD) Approval #PSD-97-01 issued AprilLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 59 of 91 8, 1999 and revised June 7, 2000 and COMAR 26.11.01.11C]

G. VOC Emissions
The Permittee shall use continuous em ission monitoring system (CEM) to monitor total hydrocarbon (THC) emissions from the main exhaust stack. The Permittee shall install, operate, mainta in, 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 concen tration, 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, co rrective 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 disk s, 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, co rrective 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 disk s, on magnetic tape, or on microfiche. [COMAR 26.11.03.06C]

F and G. The following records with supporting documenta tion 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; andLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 60 of 91 (6) Records of any repairs made to equi pment 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 disk s, on magnetic tape, or on microfiche. [New Source Review Approval #NSR-97-02 issued April 8, 1999 and Prevention of Significant Deterioration (PSD) Appr oval #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 th e 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 31 st and July 31 st 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 av erage 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 affect ed source during the reporting period;
and (13) A CMS performance summary, including: (a) the total CMS downtime during th e 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,LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 61 of 91 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 CE M downtime includi ng records of any repairs, adjustments, or maintenance th at 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 di fferences, 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 60 th 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;LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 62 of 91 (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 SO 2 emissions
and to CEM for NOx or SO 2

. [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) Appr oval #PSD-97-01 issued April 8, 1999 and revised June 7, 2000 ]

H and I. None A permit shield shall cover the applicable requi rements 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 pr oduct 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 insta llation 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 permitLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 63 of 91 particulate matter to be discharged fr om 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 particulat e matter emissions test at the interval stipulated in Subpart LLL using Met hod 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. Th e COM shall be installed, maintained, calibrated, and operated as required by 40 CFR Part 63, Subpart A (general provision) and 40 CFR Part 60, Appendi x 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-Cli nker Cooler and G01-001- Main Pan Conveyor shall vent through a dust collect or 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 ma intenance 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 ta ken when required by §63.1350(e); and (3) Procedures to be used to periodically monitor affected sources subject to opacity standards under§63.1345.LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 64 of 91 [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, co rrective 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 th e 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 includi ng records of any repairs, adjustments, or maintenance th at 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 di fferences, 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 60 th 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]LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 65 of 91 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 requi rements 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 Un confined 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, it s 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 produc t 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 consecutiv e 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 resu me testing of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions 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 theLEHIGH 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 duri ng any Method 22 test, the Permittee shall initiate the corrective actions spec ified 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 a nd maintenance of the affected source and air pollution control devices in or der to meet the emission limits and operating limits of §§63.1348; and (2) Procedures to be used to peri odically 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, co rrective 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 disk s, 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 oper ation and maintenance plan developed in accordance with §63.1350(a). [40 CFR §63.1354(b)(9)(v)] A permit shield shall cover the applicable requi rements 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 SystemLEHIGH 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 in stallation or building, other than water in an uncombined form, whic h 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 fi nished 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 par ticulate 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 emission s 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 exha ust stack of that
emission unit. If visible emissions ar e observed during any annual test, the Permittee must resume testing of the e xhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions are observed in six consecutive monthly tests.
If visible emissions are observed on e ach 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 conduc t a follow-up Method 22 test of each
stack from which visible emissions we re 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 a nd maintenance of the affected source and air pollution control devices in or der to meet the emission limits and operating limits of §§63.1348; and (2) Procedures to be used to peri odically monitor affected sources. [40 CFR §63.1350(a) and (b)]

B. The exhaust gas from each emissions un it shall vent a dust collector designed to reduce particulate matter emissions li mits 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, main tenance, corrective action, report orLEHIGH 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 ma y 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 re cent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintain ed 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 requi rements 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 Syst em and H07-018, H07-069, & H07-070 – Finished Cement Transfer System H07-057 H07-018, H07-069, & H07-070 – Fi nished 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 insta llation 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 10LEHIGH 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 fr om 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 matte r 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 matte r from each exhaust stack of H07-014 Finish Mill #7, H08-014 Finish Mill #8, and H07-018, H07- 069, & H07-070 – Finished Cement Tr ansfer 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 pe riod 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 repr esentative 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 ope rating 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 correcti ve 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 upda te 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 or der to meet the emission limits and operating limits of §63.1347; and (2) Procedures to be used to period ically monitor affected sources. [40 CFR §63.1350(a) and (b)]

B. The exhaust gases from each emission unit sh all 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, main tenance, 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 ma y 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 reco rds 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 tw o 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 demonstrationLEHIGH 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 requi rements 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 insta llation 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 fi nished product storage bin; conveyingLEHIGH 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 fr om 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 fo r 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 stac k of that emission unit on a monthly basis
and maintain that schedule until no vi sible emissions are observed in six consecutive monthly tests. If no visibl e 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 visibl e 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 e ach 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 conduc t a follow-up Method 22 test of each
stack from which visible emissions we re 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 upda te 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 or der to meet the emission limits and operating limits of §§63.1348; andLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 74 of 91 (2) Procedures to be used to peri odically 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, main tenance, 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 re cent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintain ed 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 requi rements 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 buildi ng, 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 fr om 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 matte r 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 obs erved during any semi-annual test, the Permittee must resume testing of the e xhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions 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 visibl e 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 e ach 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 visi ble emissions were observed during the previous Method 22 test. If visible emi ssions 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 thro ugh a dust collectorLEHIGH 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 comp leting each activity. Th e Permittee shall perform
maintenance activities within the timeframe s established in the plan and shall maintain a log with records of th e 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) ye ars and make them available to the Department upon request. At a minimu m, 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 magne tic 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 maintain ed 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 requi rements 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 insta llation or building, other than waterLEHIGH 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 fi nished 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 fr om 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 matte r 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 fo r the exhaust stack of that emission
unit. If visible emissions are obs erved during any semi-annual test, the Permittee must resume testing of the e xhaust stack of that emission unit on a monthly basis and maintain that schedule until no visible emi ssions 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 visibl e 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 e ach 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 conduc t a follow-up Method 22 test of each
stack from which visible emissions we re observed during the previous Method
22 test. If visible emissions are still observed, conduct a visual opacity test in
accordance with Method 9 of A ppendix 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 te st 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 CF R §63.1350(a)(4)(i)-(iii) and (l) for eachLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 78 of 91 emissions unit located within the building, or for the building itself. If visible emissions from the building are mon itored, the requirements of 40 CFR §63.1350(a)(4)(i)-(iii) and (l) apply to m onitoring 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 upda te 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 or der to meet the emission limits and operating limits of §§63.1348; and (2) Procedures to be used to peri odically monitor affected sources. [40 CFR §63.1350(a) and (b)]

B. The exhaust gas from each emissions unit shall vent thr ough 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, mainte nance, 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 re cent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintain ed 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 requi rements 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 79 of 91 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 th e entire premises shall not exceed the following limits for any 12-month period, rolling monthly: (1) 925 tons of PM; (2) 716 tons of PM 10 ; and (3) 586 tons of PM 10 stack emissions.

C. Sulfur Emissions Permit to Construct #06-6-0256 issued April 8, 1999 and revised June 7,
2000 which states that SO 2 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 Deteriorat ion (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 exce ed 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 de termining 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 fo r any 12-month period, rolling monthly.

G. Fluoride EmissionsLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 80 of 91 (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 discharg e 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-w ide emissions for each month and each 12-month period, rolling monthly, to de monstrate compliance with the emissions
limits. [COMAR 26.11.03.06C] Record Keeping Requirements
A thru G
The Permittee shall maintain the fo llowing records with supporting documentation for at least five years a nd 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, SO 2 , CO, VOC, Lead, and Fluoride for each month and each 12-month period, rolling monthly, in the required quart erly 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 requi rements of the Clean Air Act that are listed
in the table above.

MACT RequirementsLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 81 of 91 (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 appl y, 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) Extens ions, 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) Oper ation & MaintenanceLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 82 of 91 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 fo r CMS Performance Specification supersedes requirements
for THC 63.8(f)(1) through (f)(5) Alternative Monito ring 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 TestLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 83 of 91 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) Notifi cation of Compliance Status 63.9(h)(5) and (h)(6) Notificat ion 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 K eeping PS-8A applies instead of requirements for THC CEM 63.10(c)(5) through (c)(8) Additional CMS Reco rd 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 co mply with the written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining the source during periods of st artup, shutdown, and malfunction; a program of corrective action for malfunctioning proces s; 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 th e affected source as necessary to satisfy the requirements of this part or to reflect changes in equipment or procedures at theLEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 84 of 91 affected source. Unless the permitting authority provides otherwise, the Permittee may make such revisions to the startup, s hutdown, and malfunction plan without prior approval by the Administrator or the permitting authority. However, each revision to a startup, shutdown, and malfunction plan mu st 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 ev ent that meets the characteristics of a
malfunction but was not included in the start- up, shutdown, and malf unction plan at the time the Permittee developed the plan, the Perm ittee 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 th is 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 pl ans to undertake a change in operations that may adversely affect complia nce with an applicable D/F standard under this subpart, the source must conduct a perf ormance 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 undertak e a change in operations that may adversely affect compliance with an applicable PM standa rd under § 63.1343, the source must conduct a performance test as specified in pa ragraph (b)(1) of this section. [40 CFR 63.1349(c), (d), and (e)] Monitoring Requirements At all times, including periods of start up, shutdown, and malfunction, the Permittee shall operate and maintain any affected source, including asso ciated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practic es 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. Malfuncti ons shall be corrected as soon as practicable after their occurrence in acco rdance 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 malfunc tion event consistent with safety and good air pollution control practices. [40 CFR §63.6(e)(1)(i -ii)]LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 85 of 91 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 visi ble 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 duri ng a startup, shutdown, or malfunction (including actions taken to correct a malfunc tion) are consistent with the procedures specified in the affected source’s star tup, shutdown, and malfunction plan, the Permittee shall keep records for that event which demonstrate the procedures specified in the plan were followed. These records ma y 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 reco rds 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 malfunc tion were consistent with the affected source’s startup, shutdown, and malfunction pl an 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 st artup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified
in the affected source’s st artup, shutdown, and malfuncti on plan, and the source exceeds the relevant emission standard, then the Perm ittee 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 advan ce, 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 re vision of the plan. If at any time after adoption of a startup, shutdown, and malf unction 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 subjec t 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)]LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 86 of 91 Reporting Requirements The Permittee shall, if actions taken are consis tent with the procedures specified in the startup, shutdown, or malfunction plan, duri ng a startup, shutdown, or malfunction of an affected source (includi ng 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 dur ing a startup, shutdown, or malfunction (including actions taken to correct a malfuncti on) is not consistent with the procedures in the startup, shutdown, or malfunction pl an, 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 sha ll 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 requi rements 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 uni ts 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 e ngines 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 Mo de (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 no t 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 contin uously 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 conjunctio n with an installation requiring a permit to operate;LEHIGH CEMENT COMPANY
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 88 of 91 (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 1m mHg at 20° Celsius (COMAR 26.11.19.09D(2)(b)).

(b) The Permittee shall implemen t 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 mini mizing 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 fo llowing records of operating data at the sire for at least five (5) y ears 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 Writin g 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, cu tting, 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 li quefied 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
UNION BRIDGE MARYLAND
PART 70 OPERATING PERMIT NO. 24-013-00012

Page 89 of 91 (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. an d constructed after July 23, 1984; (NOTE: this condition has applic able requirements in 40CFR60)

(25) No.__ X _ Storage of motor vehicle gaso line, having an individual tank capacity of 2,000 gallons or less;

(36) ___X ___ First aid and emergency me dical 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 us e of explosives for blasting at quarrying operations and from the requ ired 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 require s installation of a data telemetry system for all required CEMs. This syst em shall be designed and installed in accordance with specifications approve d by the Department and shall be operational by the date specified in Re gulation .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 prope rty line in such a manner that a nuisance or air pollution is created.

(3) COMAR 26.11.15.05, which requir es that the Permittee implement “Best Available Control Technology for Toxics” (T – BACT) to
control emissions of t oxic air pollutants.

(4) COMAR 26.11.15.06, which prohib its the discharge of toxic air pollutants to the extent that su ch 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 inva lidated previous demonstrations.

(2) The Permittee shall not use any alterna tive 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 ma y 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 li mits 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]