Robert L. Ehrlich, Jr. Kendl P. Philbrick 

 Governor Secretary 

Air and Radiation Management Administration 

1800 Washington Boulevard, Suite 720 

Baltimore, MD 21230 

 Part 70 

 Construction Permit X Operating Permit 

PERMIT NO. 24-043-00008 DATE ISSUED February 1, 2005 

 

PERMIT FEE 

To be paid in accordance with 

COMAR 26.11.02.19B(b) EXPIRATION DATE April 30, 2009 

 LEGAL OWNER & ADDRESS SITE 

St. Lawrence Cement Company 

1260 Security Road 

Hagerstown, MD 21742 

Same 

Washington County 

 

 SOURCE DESCRIPTION 

Portland Cement Manufacturing Plant. 

 

This source is subject to the conditions described on the attached pages. 

Page 1 of 73 

Program Manager Director, Air and Radiation Management Administration 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 1 of 47 

BACKGROUND

St. Lawrence Cement, Inc., a subsidiary of Holcim, Ltd., operates a Portland cement manufacturing plant in Hagerstown, 

Washington County, Maryland. It quarries limestone, operates a limestone crushing plant, a raw mill system, a cement 

kiln/clinker cooler system, a finish mill system, and a shipping operation. The cement production at this location dates 

back to 1903 and the current long dry kiln has been in operation since 1971. The maximum annual clinker production 

from the kiln is 693,500 tons.

The following is a description of the process steps at the Hagerstown facility. 

Quarry (EQ108) 

The principal raw materials used for the Hagerstown plant are limestone shale (alumina), sand (silica), and iron ore or 

mill scale. Limestone is removed from the quarry by blasting operations, hauled by truck to a pan feeder (Q1), and 

crushed in the primary crusher (Q2) at the quarry site. 

Rock Crushing and Storage

Crushed rock from the primary crusher is transported by belt conveyor to the screening system (Q7) for sizing. 

Oversized material discarded by the screening operation is further crushed in a secondary crusher (Q9). Emissions from 

the crushing system are controlled by the use of water sprays on the primary crusher and by a baghouse (Q11) on the 

screening plant and the secondary crusher. The crushed rock fragments, less than six inches in size, are conveyed either to 

a covered stockpile (Q24) in the storage dome or in outside stone storage pile (EASTP1) before being fed to the raw mill. 

Raw Mill System (ER110) 

Limestone from the storage piles is conveyed via belts (Q27, R14 and R16) to a hopper bin for the raw mill feed bins. 

Purchased sand, alumina, and iron ore are stored in outside stockpiles (EASTP2). Limestone from the feed bins, shale, 

silica (sand), and mill scale (iron) are fed by inside feeders into the heated raw mill (R37) in which the raw feed is dried 

and milled to a powder. The dust, generated as the raw materials being transported to the raw mill, is controlled by a 

baghouse. Primary heat for the raw mill is supplied by the raw mill hot air generation system (R39) - a No. 2 fuel oilfired burner. The hot exhaust gas from the clinker cooler supplies additional heat. Particulate matter emissions from the 

raw mill and blending system are controlled by seven (7) baghouses. 

Coal System (EK109) 

Coal, stored in an outside stockpile (EASTP2), is fed into solid fuel bins, crushed (in crusher C3) and transported by 

conveyor (conveyor C3) to the coal wet tank (C10) from which it is transported to the fuel mill (C8) where it is 

pulverized. Particulate matter emissions are controlled by a cyclone and a baghouse (C15). The normal fuel for the kiln, 

coal, is supplemented by fuel oil or tire-derived fuel (TDF). 

Pyroprocessing System (EK109) 

The ground raw material mixture from the rotary raw mill (R37) is transported to the raw mill separator (R43) by a 

bucket elevator (R41). Acceptable material is pneumatically conveyed to three (3) raw material blending silos (R60) 

where it is blended as kiln feed. Particulate matter emissions in the raw mill/kiln feed blending area are controlled by 

three baghouses (R50, R62, and KB3). The kiln feed is introduced into the upper (cooler) end of the coal-fired 520-foot 

long dry rotary kiln for calcination. Dust collector KB11 captures any dust generated at the feed end. As the raw material 

traverses the length of the kiln (KB13) toward the lower (hotter) end, chemical reactions take place to produce clinker. As 

the raw material is heated to about 1800°F, the carbonaceous materials are oxidized, the alkaline components vaporized, 

and the calcium carbonate converted to calcium silicate. At a temperature of 2700°F to 3000°F the material fuses to form 

cement clinker. Dust generated during the calcination process in the kiln is captured by a multiclone (KB19) and sent to 

a recovery dust bin (KB40B) or waste dust bin (KB40A). The exhaust gas from the multiclone is vented through an 

electrostatic precipitator (ESP) to the stack. Dust captured by the ESP (KB21) is either reintroduced to the kiln process or 

transported to waste-dust bin. Any dust generated during the wasting process is captured by dust collector KB54. Waste 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 2 of 47 

dust is loaded onto trucks at the unloader (KB53) and transferred to a stockpile (EASTP3) from which it is sent to the 

agricultural industry for use as a lime substitute. 

Clinker cooler (EK109)/ Clinker Storage

The clinker is discharged from the lower end of the kiln to the clinker cooler (KC1) where fans are used to cool the 

clinker. The heated exhaust air from the clinker cooler is split into three streams. One stream is controlled by a 

multiclone (KC2) and an electrostatic precipitator (KC3); a second stream provides heat to the raw mill; and the third 

stream is routed through a cyclone to the 15-ton per hour Raymond coal pulverizing mill. The Raymond coal pulverizing 

mill vents to a cyclone and a baghouse for particulate matter emissions control. The cooled clinker is transported by 

conveyor (conveyor F37) either to a 30,000-ton storage silo (F105) equipped with dust collector (F92-2) or a clinker 

storage building (F83) equipped with two (2) dust collectors (F81-3 and F81-4) as well as heavy curtains over the access 

doorways. Dust generated in the transfer process to clinker storage is captured and controlled by dust collector KC9. 

Finish Mill (EF111) 

Clinker is stored in the 30,000-ton storage silo (F105) equipped with dust collector (F92-2) from which it is conveyed to 

the finish mill system as required. Each of the four belt transfer points of the clinker storage-to-finish mill conveyor 

system is controlled by a dust collector (F96-2, F86, F42, or F39). The clinker storage building (F83), an alternate clinker 

storage area, is equipped with two (2) dust collectors (F81-3 and F81-4) as well as heavy curtains over the access 

doorways. 

Finish Mill (F55)/Final Product Storage (EF111) 

Clinker is conveyed from clinker storage to the finish mill feed bins. Each of the four belt transfer points of the clinker 

storage-to-finish mill conveyor system is controlled by a dust collector (F96-2, F86, F42, or F39). Gypsum and slag are 

stored in covered sheds. Clinker, along with small amounts of gypsum and limestone, are crushed in the 90-ton per hour 

finish mill (F55), a rotary ball mill, to produce a homogeneous, finely ground product, Portland cement. The product 

from the finished mill is transported to a separator. Material, which is too large, is recycled to the finish mill. Acceptable 

product is pneumatically transported to seven pack house silos equipped with four dust collectors (EF76-1, EF76-2, 

EF76-5 and EF76-6) or two bulk cement silos equipped with baghouses (EF67 and EF75) for final product storage. Any 

dust generated during transport is collected by dust collectors F68 and F69 and returned to the process. 

Final Product Packaging and Loadout

The final product is transferred from the pack house silos through Bucket Elevators PH32 and PH12 to Packing 

Machines PH20-1 and PH21-1. The emissions generated from transport is controlled by Baghouse PH8 and the emission 

from packaging operation is controlled by Baghouse EPH22. Most of the product is bulk loaded and shipped by truck or 

rail from either the pack house silos or bulk cement silos. 

Haul Roads

Road dust on the plant property is controlled with water sprayed from a water truck. An asphalt emulsifier has been 

applied to the roads around the raw material storage area to reduce fugitive dust emissions. 

The SIC code for this facility is 3241. The facility is a major source of particulate matter, VOC, NOx, and SO2 emissions 

based on actual emissions. As a major source of nitrogen oxide (NOx) emissions, the facility is subject to NOx RACT. 

The following table summarizes the annual emissions of criteria pollutants from St. Lawrence Cement, Inc. based 

on its 2000, 2001 and 2002 Emissions Certification Report and the annual emissions of hazardous air pollutants 

(HAPS) based on the results of a stack test conducted in August, 2000. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 3 of 47 

Table 1: Actual Emissions 

Year NOX

(TPY) 

SOX

(TPY) 

PM10

(TPY) 

CO 

(TPY) 

VOC 

(TPY) 

HAP 

(TPY) 

2000 2618 249 210 46 15 4.5 

2001 2041 72 204 41 22 3.8 

2002 1974 301 154 43 22 8.5 

The major source threshold for triggering Title V permitting requirements in Washington County is 50 tons per year 

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

single hazardous air pollutant (HAP) and 25 tons per year for combined HAPs. Since the actual emissions of NOx, 

SOx, and PM10 from the facility are greater than the major source threshold, St. Lawrence Cement, Inc. is required 

to obtain a Title V-Part 70 Operating Permit under COMAR 26.11.03.01. 

St. Lawrence Cement, Inc. did not receive a Part 70 permit for the Hagerstown plant as of December 1,2001, the 

date Maryland’s interim approval of its Part 70 program expired. As a consequence, St. Lawrence Cement, Inc. was 

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

application on June 6, 2002. An administrative completeness review was conducted and the application was 

deemed to be administratively complete. A letter was sent to St. Lawrence Cement, Inc. granting an application 

shield. The Part 71 application serves as a revised Part 70 application for this Part 70 permit. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 4 of 47 

II. EMISSIONS UNIT IDENTIFICATION 

St. Lawrence Cement, Inc.’s Hagerstown plant has identified the following emissions units at the facility as being 

subject to the Title V permitting requirements and having applicable requirements. 

Table 2: Emission Unit Identification 

1. Quarry - Registration # 7-0108 (Not subject to MACT) 

Emissions 

Point Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources - not subject to NSPS 

EADRL1 Quarry drilling Fugitive emissions 1970 

EARMH1 Quarry raw material handling Fugitive emissions 1970 

EARMH2 Transfer from Outside Surge Stone 

Pile and Front End Loader to 

Stone Hopper Q28; from Stone 

Hopper Q28 to Feeder Q28.1; 

from Feeder Q28.1 to Belt Q27 

Fugitive Emissions 1970 

EARMH3 Raw Material Stockpile Truck 

Unloading onto Piles; to Raw 

Material Bins and Solid Fuel Bins 

Fugitive – Partial Enclosure 1970 

EAROAD1 Quarry haul roads Fugitive emissions - Controlled by water 

spray 

1970 

EAROAD2 Raw Material (Coal, Slag, GAF, 

Sand, Iron) Haul Road; CKD Haul 

Trucks to CKD Pile; Truck Traffic 

from Bulk Silos and Pack house 

Fugitive Emissions – Water Spray 1970 

EASTP1 Outside Surge Stone Pile Wind 

Erosion 

Fugitive Emissions 1970 

EASTP2 Raw Material (Coal, Slag, GAF, 

Sand, Iron) Stone Pile Wind 

Erosion 

Fugitive Emissions 1970 

EAQ1 Pan Feeder Q1 (Shown in Figure 1) 1970

EAQ2 Primary Crusher Q2 Fugitive emissions - Controlled by water 

spray 

1970 

EAQ3 Transfer from Belt Q3 to Belt Q4 Fugitive emissions - Controlled by water 

spray 

1970 

Fugitive Sources - Subject to CFR 40 Part 60 Subpart OOO 

EAQ21 Transfer from Stack Conveyor 

Q21 to Outside Surge Stone Pile 

EASTP1 

Fugitive Emissions 1999 

EAQ23 Transfer from Belt Q23 to 

Stacker/Conveyor Q25 

Inside Dome Q24 - Fugitive Emissions 1999 

EAQ25 Transfer from Stack/Conveyor 

Q25 to Indoor Pile 

Inside Dome Q24 - Fugitive Emissions 1999 

EAQ27 Conveyor Q27 Transfer Points Fugitive Emissions 1999 

EAQ28 Stone Hopper Q28 and Feeder 

Q28.1 

Fugitive Emissions 1999 

EARMH4 EARMH4-Dome Fugitive Emissions – Inside Building 1970 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 5 of 47 

Emissions 

Point Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources - not subject to NSPS 

Point Sources - not subject to NSPS 

EAQ4 Transfer from Belt Q4 to Pan 

Feeder Q6-1 and Belt 5 

Controlled by Baghouse Q11 – EAQ11 1970 

EAQ7 Transfer from Belt Q5 to Screen 

Q7 

Controlled by Baghouse Q11 installed in 

1999 – EAQ11 

1970 

EAQ7-A Transfer from Screen Q7 to Belt 

10 

Controlled by Baghouse Q11 installed in 

1999 – EAQ11 

1970 

EAQ9 Transfer from Screen Q7 to 

Secondary Crusher Q9 

Controlled by Baghouse Q11 installed and 

the same capacity crusher replacement in 

1999 – EAQ11 

1970 

EAQ10 Transfer from Belt Q10 to Flop 

Gate Q19 

Controlled by Baghouse Q11 installed in 

1999 – EAQ11 

1970 

2. Raw Mill System - Registration # 7-0110 (Not subject to MACT and NSPS) 

Emissions 

Point Number Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Emissions 

EAR8 Transfer from Raw Material Bins 

to Belt Feeders, then to Belt 

Conveyor R8, then to Belt 

conveyor R11-1 

(Shown in Figure 1) 1970

EAR11 Conveyor R11-1 Fugitive Emissions 1970 

EAR14 Transfer from Belt Q27 to Belt 

conveyor R14; from Belt conveyor 

R14 to Belt conveyor R16 

Fugitive Emissions 1970 

ER32 Transfer from Raw Mill Bins to 

Feeders; Transfer from Feeders to 

Belt conveyor R32 

(Shown in Figure 2) 1970 

EF36 Transfer from Crossover Stone 

Belt to Masonry/Slag Tank 

(Shown in Figure 2) 1970 

Point Sources 

ER13 Transfer from Belt R11-1 to Flop 

Gate R11-3; from Flop Gate R11-3 

to Crusher R12-1 and Belt R14; 

and Transfer from Crusher R12-1 

to Belt R12-4 and then R14 

(Shown in Figure 1) Controlled by Dust 

Collector R13 – EAR13 

1970 

ER17 Transfer from Raw Mill Tripper 

R16 to Raw Mill Feed Bins R20-1 

thru -5 

Controlled by Duct Collector R17 – ER17 1970 

ER38 Raw Mill R37 and Discharge from 

Raw Mill R37 to Bucket Elevator 

R41 

Controlled by Duct Collector R38B – ER38 1970 

ER39 Raw Mill heater R39 Controlled by Duct Collector R38B – ER38 1970 

ER45 Transfer from Belt conveyor R32 

to Raw Mill R37 and Raw Miller 

Air Separator R43 

Controlled by Duct Collector R45 – ER45 1970 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 6 of 47 

Emissions 

Point Number Emissions Unit Name Emissions Unit Description Date of 

Installation 

ER50 Transfer from Air Slides to 

Blending Silos R60-1 thru -3 

Controlled by Duct Collector R50 – ER50 1970 

ER62 Raw Material Blending operation Controlled by Duct Collector R62 – ER62 1970 

EKB3 Transfer from Blending Silos R60-

1 thru -3 to Air Slides (EKB1A, 

EKB1B, EKB1C, EKB1D, 

EKB1E, and EKB1F) 

Controlled by Duct Collector KB3 – EKB3 1970 

3. Coal and Alternative Fuel Handling - Registration # 7-0108 ( Not subject to MACT and NSPS) 

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources 

EROAD2 Haul truck s on plant roads (See Quarry Section) 1970

EASTP2 Coal storage pile (See Quarry Section) 1970

EAC1 Solid fuel bins C1-1 & C1-2 (Shown in Figure 1) 1970

EAC2 Vibratory Feeders C2-1 & C2-2 (Shown in Figure 1) 1970

EAC3 Coal Crusher Inside Building 1970 

EAC4 Belt Conveyor C4 (Shown in Figure 1) 1970 

EAC7 Weigh Feeder C7-1 (Shown in Figure 8) 1970 

EAC10 Coal Silo C10 (Shown in Figure 8) 1970 

EAC19 I-Bin C19 (Shown in Figure 8) 1970 

Point Sources 

EC15 Coal Mill C8-1 and Cyclone C14 Controlled by Baghouse C15 – EAC8 

(Shown in Figure 8) 

1970 

4. Kiln System - Registration #7-0109 (Subject to MACT for D/F) 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

KB13 Kiln Discharging through Multicyclone KB19 

and ESP KB21 – EKB22 

1970 

5. Clinker Cooler - Registration #7-0109 (Not subject to MACT and NSPS) 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

KC4 Clinker Cooler KC1 Discharging through Multicyclone KC2 and 

ESP KC3 - EKC4 

1970 

6. Cement Kiln System ( Not Include Kiln and Clinker Cooler) - Registration #7-0109 (Not subject to 

MACT and NSPS) 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Fugitive Emissions 

EKB37-F Transfer from ESP/Multiclone to 

Bucket Elevators KB35 & KB36 

Fugitive Emissions 1970 

EKB53 Transfer from CKD Unloader to 

Haul Trucks 

Fugitive Emissions – Water Spray 1970 

EASTP3 CKD Pile Wind Erosion Fugitive Emissions 1970 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 7 of 47 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

EACKDH CKD Pile Activity Fugitive Emissions 1970 

EAKC8 Transfer from Clinker Cooler KC1 

to Drag Conveyor KCB 

(Shown in Figure 5) 1970

EAKC9 Transfer from Drag Belt KC9 to 

Kick out Belt KC9-2 and Transfer 

from Belt Conveyor KC9-3 to Belt 

Conveyor 37 

Part of EAKC9 (Shown in Figure 5 and 

Emission Certifications) - Fugitive 

Emission 

1970 

EAROAD2 CKD Haul Trucks to CKD Pile Fugitive Emissions 1970 

ETNK1 Liquid Fuel Tanks working loss Fugitive Emissions 1970 

ETNK2 Liquid Fuel Tanks breathing loss Fugitive Emissions 1970 

Point Sources 

EKB11 Transfer from Kiln Feed Pumps 

(EKB4 and EKB5) to Kiln Feed 

Hopper; Transfer from CKD 

Recovery to Bucket Elevator 

KB44 

Controlled by Duct Collector KB11-3 – 

EKB11 

1970 

EKB37-S Transfer from CKD Bucket 

Elevators KB35 & KB36 Waste 

Dust Bin KB40A and Recovery 

Waste Dust Bin KB40B 

Controlled by Duct Collector KB37A and 

KB37B – EKB37 

1970 

EKC9 Transfer from Drag Belt KC8 to 

Drag Belt KC9 and Belt Conveyor 

KC9-3 and Transfer from Belt 

Conveyor KC9-3 to Belt Conveyor 

37 and Kick out Belt KC9-2 to 

Belt Conveyor 37 

Controlled by Duct Collector KC9-5 

(Shown in Figure 5) 

1970 

EAKB54 Transfer from Waste Dust Bin to 

Customer Trucks

Controlled by Duct Collector KB54 – 

EAKB54 

1970 

7. Finish Mill System - Registration #7-0111 (Not subject to MACT)

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Fugitive Emissions (Subject to 40 CFR Part 60 Subpart F) 

EAF83 Discharge point from Conveyor 

F81 and storage of clinker 

Fugitive Emissions 1976 

EAROAD2 Traffic from Bulk Silos and Pack 

house 

( See Quarry Section) 1970 (1976) 

EASTP3 Gypsum and Slag Storage Pile 

Unloading and Wind Erosion 

Fugitive Emission Source – Partial 

Enclosure 

1970 (1976) 

EARMH3 Raw Material Stockpile Truck 

Unloading onto Piles; to Raw 

Material Bins 

Fugitive – Partial Enclosure 1970 (1976) 

EF54 Transfer from Air Slide F61-31 to 

Belt Conveyor F54 and then to 

Finish Mill 

(Shown in Figure 7) 1976 

EF60 Transfer from Air Slide F61-11 to (Shown in Figure 7) 1976
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 8 of 47 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Bucket Elevator F60 

EF61 Transfer from Air Slides F68-1 

and F68-2 to Air Slide F61-32 and 

Cement Coolers F63A and 63B 

and then to F-K pump F65 

(Shown in Figure 7) 1976

Point Sources (Subject to 40 CFR Part 60 Subpart F) 

EF39 Transfer from Belt F40 to Belt 

F43-1 in S. Transfer Tower 

Discharges to Baghouse F39 1976 

EF42 Transfer from Belt F80 to Belt 

F40; Transfer from Conveyor F37 

to Conveyors F81and F40 in N. 

Transfer Tower 

Discharges to Baghouse F42 – EP42 1976 

EF67 Bulk Cement Silos, Filling Discharges to Baghouse F67-4 1976 

EF68 Finish Mill F55 Finish Mill controlled by cyclone and 

Baghouse F68 

1976 

EF69 Mill Separator F62 Discharges to Baghouse FF69 1976 

EF71 Finish Mill Weigh Feeders; Finish 

Mill Feed Belt; 

Transfer from Belt F43 Tripper to 

F45- Series Clinker Bins 

Controlled by Baghouse F71 1976 

EF75 Bulk Cement Silos, Filling Discharges to Baghouse F75 1976 

EF81-3 Tripper F81-2 and Transfer from 

Belt F81 to Bucket Elevator F97 

Discharges to Baghouse F81-7 and 

Baghouse F81-8 

1976 

EF86 Transfer from Belt F98 and F83 

Silos to Belt F80 

Discharges to Baghouse F86 1976 

EF92 Transfer from Bucket Elevator F97 

to Conveyor 91, then to Clinker 

Silo F105 

Discharges to Baghouse F92-2 - EF92 1976 

EF96 Transfer from Clinker Silo F105 to 

Feeders; Transfer from 

Gypsum/Clinker Feeders to Belt 

F98; then Belt F80 

Discharges to Baghouse F96-2 - EF96 1976 

EBS802 Bulk Cement Silos, Loadout to 

Truck and Rail 

Discharges to Baghouse BS802 1976 

EBS814 Bulk Cement Silos, Loadout to 

Truck and Rail 

Discharges to Baghouse BS814 1976 

8. Gasoline Tank 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

EKNK3 One 3,000 gallon Gasoline Tank VOC Emissions Source 1992 

9. Cold Degreaser 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

ECD1 Cold Degreaser VOC Emissions Sources 1970 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 9 of 47 

III. OVERVIEW OF THE PART 70 PERMIT

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

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

Section II of the Part 70 Permit contains the general requirements that relate to administrative permit actions. This 

section includes the procedures for renewing, amending, reopening, and transferring permits, the relationship to 

permits to construct and approvals, and the general duty to provide information and to comply with all applicable 

requirements. 

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

requirements that affect the facility as a whole, such as open burning, air pollution episodes, particulate matter from 

construction and demolition activities, asbestos provisions, ozone depleting substance provisions, general 

conformity, and acid rain permit. This section includes the requirement to report excess emissions and deviations, 

to submit an annual emissions certification report and an annual compliance certification report, and results of 

sampling and testing. 

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

and work practices applicable to each emissions unit located at the facility. For each standard, limitation, and work 

practice, the permit identifies the basis upon which the Permittee will demonstrate compliance. The basis will 

include testing, monitoring, record keeping, and reporting requirements. The demonstration may include one or 

more of these methods. 

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

of regulated air pollutants and do not require a permit to construct or registration with the Department. For 

insignificant activities that are subject to a requirement under the Clean Air Act, the requirement is listed under the 

activity. 

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

it will supersede the facility's current State Permit to Operate. Section VI identifies requirements that are not based 

on the Clean Air Act, but solely on Maryland air pollution regulations. These requirements generally relate to the 

prevention of nuisances and implementation of Maryland's Air Toxics Program. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 10 of 47 

REGULATORY REVIEW/TECHNICAL REVIEW/COMPLIANCE METHODOLGY 

Overview

The Federal regulations which could come into play at a cement manufacturing facility with an on-site quarry 

operation are: 40 CFR 60, Subpart F (Portland Cement Plants constructed or modified after August 17, 1971); 40 

CFR 60, Subpart Y (Coal Preparation Plants constructed or modified October 24, 1974); 40 CFR 60, Subpart OOO 

(Nonmetallic Mineral Processing Plants constructed or modifies after October 24, 1974); and 40 CFR 63, Subpart 

LLL (MACT for Portland Cement Manufacturing Plants). 

Portland Cement MACT- 40 CFR Part 63 Subpart LLL

Since the potential emissions, based on its rated capacity, of a single hazardous air pollutant (HAP) is less than 10 tons 

per year and the aggregate emissions of all HAPs is less than 25 tons per year, the facility is subject to the requirements 

for an area, but not a major, source under the Portland cement manufacturing plant MACT (maximum achievable control 

technology) outlined in 40 CFR Part 63, Subpart LLL. The only affected facility subject to the Portland cement 

manufacturing plant MACT for an area source is each kiln and each in-line kiln/raw mill for dioxin/furan emissions 

control. Emissions units which are affected sources subject to the provisions Subpart LLL are, according to 40 CFR 

§ 63.1356, exempt from otherwise applicable new source performance standard contained in 40 CFR 60, Subpart F 

or in Subpart OOO. 

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

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

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

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

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

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

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

would not affect the MACT requirements on St. Lawrence’s Hagerstown plant 

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). 

Under the MACT, St. Lawrence was required to prepare for each affected source, a written operations and 

maintenance plan and include it in the Title V permit application. St. Lawrence’s Part 71 application includes an 

Operation and Maintenance Plan. 

New Source Performance Standards (NSPS)

The finish mills were modified in 1976, the kiln was modified in 1979, Belt conveyors Q4, Q10, Q21, Q23, Q25, 

Q27, and Q28 were installed or modified in 1999. The remaining emission units were installed in 1970. 

1. 40 CFR 60, Subpart F 

The raw mill system and the cement kiln system except the kiln were installed or modified prior to 1971 and 

were not subject to 40 CFR 60, Subpart F. The finish mill system was constructed or modified after August 

17, 1971 and was subject to 40 CFR 60, Subpart F. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 11 of 47 

Although St. Lawrence’s Kiln was modified in 1979, it is not subject to Subpart F because it is a MACT 

source. Therefore, only the finish mills and Belt conveyors Q4, Q10, and Q27 are subject to 40 CFR 60, 

Subpart F. 

2. 40 CFR 60, Subpart Y 

Any 200 ton/day or more coal preparation plant constructed or modified after October 24, 1974 is subjected to 

40 CFR 60, Subpart Y – Standards of Performance for Coal Preparation Plant. 

Although St. Lawrence Cement’s Hagerstown plant crushes over 500 tons of coal per operating day and grinds 

and transports over 280 tons of coal per operating day, the coal plant was constructed or modified in 1970. 

Therefore, it is not subject to the provisions of 40 CFR Part 60, Subpart Y. 

3. 40 CFR 60, Subpart OOO 

For a nonmetallic mineral processing plant, any crusher, grinding mill, screening operation, bucket elevator, 

belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading station constructed or modified 

after August 31, 1983 is subject to 40 CFR 60, Subpart OOO - Standards of Performance for Nonmetallic 

Mineral processing Plants. An affected facility subject to 40 CFR 60, Subpart F is exempt from 40 CFR 60, 

Subpart OOO. 

EAQ21, EAQ23, EAQ25, EAQ27, and EAQ28 were installed in 1999 and were subject to Subpart OOO. The 

rest of the quarry operations date back to the 1950’s and was not subject to Subpart OOO. The emissions units 

under the Portland cement operation are either subject to Subpart F, Subpart LLL (Portland Cement MACT), or 

installed before August 31, 1983. 

NSR and PSD

St. Lawrence Hagerstown plant has not applied for any approvals for new source review (NSR) or prevention of 

significant deterioration (PSD). 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 12 of 47 

Compliance Tables of Section IV of the Part 70 Permit

1A. Quarry - Registration # 7-0108 - Fugitive Emissions Sources):

 The following equipment were installed or modified Prior to August 31, 1983 

Emission Units

EADRL1 Quarry drilling 

EARMH1 Quarry raw material handling 

EARMH2 Transfer from Outside Surge Stone Pile and Front End Loader to Stone Hopper Q28; from Stone 

Hopper Q28 to Feeder Q28.1; from Feeder Q28.1 to Belt Q27 

EARMH3 Raw Material Stockpile Truck Unloading onto Piles; to Raw Material Bins and Solid Fuel Bins 

EAROAD1 Quarry haul roads 

EAROAD2 Raw Material (Coal, Slag, GAF, Sand, Iron) Haul Road; CKD Haul Trucks to CKD Pile; Truck 

Traffic from Bulk Silos and Pack house 

EASTP1 Outside Surge Stone Pile Wind Erosion 

EASTP2 Raw Material (Coal, Slag, GAF, Sand, Iron) Stone Pile Wind Erosion 

EAQ1 Pan Feeder Q1 

EAQ2 Primary Crusher Q2 

EAQ3 Transfer from Belt Q3 to Belt Q4 

Applicable Standards and Limitations

(1) COMAR 26.11.06.03C(1) - 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 - A person may not cause or permit any material to be handled, transported, or 

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

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

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

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

and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each emissions unit to verify 

that reasonable precautions are being implemented and to determine whether the reasonable precautions need to 

be revised. The inspection shall be conducted at a minimum of once per month at times when the effectiveness 

of the reasonable precautions can be assessed. 

[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. 

[COMAR 26.11.03.06C] 

Reporting Requirements- None 

Discussion of compliance demonstration
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 13 of 47 

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

prevent particulate matter from becoming airborne. The Permittee is required to prepare a best management plan in 

which the reasonable precautions that the Permittee will implement are listed and described. To document that 

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

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

particulate matter to become airborne. The best management plan is required to be updated when it is determined 

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

1B. Quarry - Registration # 7-0108 - Fugitive Emissions Sources (Subject to 40 CFR Part 60 Subpart OOO):

The following equipment were installed or modified after August 31, 1983 

Emission Units

EAQ21 Transfer from Stack Conveyor Q21 to Outside Surge Stone Pile EASTP1 

EAQ23 Transfer from Belt Q23 to Stacker/Conveyor Q25 

EAQ25 Transfer from Stack/Conveyor Q25 to Indoor Pile 

EAQ27 Conveyor Q27 Transfer Points 

EAQ28 Stone Hopper Q28 and Feeder Q28.1 

EARMH4 EARMH4-Dome 

Applicable Standards and Limitations

A. Visible Emissions 

(1) 40 CFR §60.672(b) - A person may not cause to be discharged into the atmosphere from any transfer point 

on belt conveyors or from other affected facility any fugitive emissions which exhibit greater than 10 

percent opacity except, as provided in paragraphs (c), (d) and (e) of this section. 

(2) 40 CFR §60.672(e)(1) - A person may not cause to be discharged into the atmosphere from any building 

enclosing transfer point on a conveyor belt or any other affected facility any visible fugitive emissions 

except emissions from a vent as defined in 40 CFR §60.671. 

B. Particulate Matter 

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

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

becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and Construction. A person may not 

cause or permit any material to be handled, transported, or stored, or a building, its appurtenances, or a 

road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

Compliance Demonstration

Testing Requirements

A. None

B. None 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar month. Fugitive 

emission sources inside buildings will be evaluated at the door(s) of the building. A visible emission 

evaluation will be performed on the exhaust of each operating source, using EPA Reference Method 22 for 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 14 of 47 

one-minute period. If no visible emissions are observed, such conditions will be noted in the inspection 

log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair the emissions 

unit and related equipment until no visible emissions are observed based on EPA Reference Method 22. If 

visible emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 10 percent, the opacity shall be 

recorded and no further action will be necessary for this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 10 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 10 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C.

 [COMAR 26.11.03.06C] 

B. 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 Permittee shall perform a 

walk through inspection of the facility to observe each emissions unit to verify that reasonable precautions 

are being implemented and to determine whether the reasonable precautions need to be revised. The 

inspection shall be conducted at a minimum of once per month at times when the effectiveness of the 

reasonable precautions can be assessed. 

[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. 

[COMAR 26.11.03.06C]

Reporting Requirements

A. None

B. None 

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. In addition, the 

Permittee is required to perform a monthly observation and inspection to prevent any violations of NSPS visible 

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

conditions are favorable for particulate matter to become airborne. The best management plan is required to be 

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

becoming airborne. 

1C. Quarry - Registration # 7-0108 - Point Sources (Not Subject to NSPS Subpart OOO):

The following equipment were installed or modified prior to August 31, 1983.
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 15 of 47 

Emissions Points Emissions Units

EAQ11 EAQ4 -Transfer from Belt Q4 to Pan Feeder Q6-1 and Belt 5 

EAQ11 EAQ7 -Transfer from Belt Q5 to Screen Q7 

EAQ11 EAQ7 -A -Transfer from Screen Q7 to Belt 10 

EAQ11 EAQ9 -Transfer from Screen Q7 to Secondary Crusher Q9 

EAQ11 EAQ10 -Transfer from Belt Q10 to Flop Gate Q19 

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 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter emissions from 

confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by 

the following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds (27,200 kilograms), the 

maximum allowable weight of particulate matter discharged per hour may exceed that calculated by the 

equation shown in (1) provided that the concentration of particulate matter in the gases discharged to the 

atmosphere is less than 0.05 gr/scfd (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar month. A visible 

emission evaluation will be performed on the exhaust of each operating source, using EPA Reference 

Method 22 for one-minute period. If no visible emissions are observed, such conditions will be noted in 

the inspection log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair 

the emissions unit and related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 20 percent, the opacity shall be 

recorded and no further action will be necessary for this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 20 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

[COMAR 26.11.03.06C]
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 16 of 47 

B1. The exhaust gas from each equipment 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 dust collector that 

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

perform maintenance activities within the timeframes established in the plan and shall maintain a log with 

records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

maintenance for at least five (5) years and make them available to the Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 

[COMAR 26.11.03.06C] 

Reporting Requirement

None 

Discussion of compliance demonstration:

The Permittee shall monitor monthly to ensure visible emissions from each dust collector not exceeding 20 percent 

opacity. For particulate matter emissions, the Permittee is required to prepare a preventative maintenance plan for 

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

2A. Raw Mill System - Registration # 7-0110- Fugitive Emissions (Not Subject to NSPS OOO) 

The following equipment were installed or modified prior to August 17, 1971. 

Emissions Units

EAR8 Transfer from Belt Conveyor R8 to Belt conveyor R11-1 

EAR11 Conveyor R11-1 

EAR14 Transfer from Belt Q27 to Belt conveyor R14; from Belt conveyor R14 to Belt conveyor R16 

ER32 Transfer from Raw Mill Bins to Feeders; Transfer from Feeders to Belt conveyor R32 

ER36 Transfer from Crossover Stone Belt to Mansory/Slag Tank 

Applicable Standards and Limitations

(1) COMAR 26.11.06.03C(1) - 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 - A person may not cause or permit any material to be handled, transported, or 

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

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

Compliance Demonstration

Testing Requirements

None 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 17 of 47 

Monitoring Requirements

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

and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C] 

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

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

are being implemented. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

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

least five (5) years and make them available to the Department upon request. 

[COMAR 26.11.03.06C]

Reporting Requirements

None 

Discussion of compliance demonstration

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

prevent particulate matter from becoming airborne. The Permittee is required to prepare a best management plan in 

which the reasonable precautions that the Permittee will implement are listed and described. To document that 

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

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

particulate matter to become airborne. The best management plan is required to be updated when it is determined 

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

2B. Raw Mill System - Registration # 7-0110- Point Sources (Not Subject to NSPS):

The following equipment were installed or modified prior to August 17, 1971.

Emissions Points Emissions Units

EAR13 ER13 -Transfer from Belt R11-1 to Flop Gate R11-3; from Flop Gate R11-3 to Crusher R12-1 

and Belt R14; and Transfer from Crusher R12-1 to Belt R12-4 and then R14 

ER17 ER17 -Transfer from Raw Mill Tripper R16 to Raw Mill Feed Bins R20-1 thru –5 

ER38 ER38 -Raw Mill R37 and Discharge from Raw Mill R37 to Bucket Elevator R41 

ER38 ER39 -Raw Mill heater R39

ER45 ER45 -Transfer from Belt conveyor R32 to Raw Mill R37 and Raw Miller Air Separator R43 

ER50 ER50 -Transfer from Air Slides to Blending Silos R60-1 thru -3 

EKB3 EKB3 -Transfer from Blending Silos R60-1 thru -3 to Air Slides (EKB1A, EKB1B, EKB1C, 

EKB1D, EKB1E, and EKB1F) 

Applicable Standards and Limitations

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 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 18 of 47 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b) which prohibits the discharge of particulate matter emissions from confined 

sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the 

following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

 

For those processes in which the process weight per hour exceeds 60,000 pounds (27,200 kilograms), the 

maximum allowable weight of particulate matter discharged per hour may exceed that calculated by the 

equation shown in (1) provided that the concentration of particulate matter in the gases discharged to the 

atmosphere is less than 0.05 gr/scfd (115 mg/dscm). 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar month. A visible 

emission evaluation will be performed on the exhaust of each operating source, using EPA Reference 

Method 22 for one-minute period. If no visible emissions are observed, such conditions will be noted in 

the inspection log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair 

the emissions unit and related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately undertake the 

following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 20 percent, the opacity shall be 

recorded and no further action will be necessary for this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 20 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective measures shall be noted in the 

inspection log and no further action will be necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

[COMAR 26.11.03.06C] 

B. The Permittee shall comply with and update the preventative maintenance plan for each dust collector that 

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

perform maintenance activities within the timeframes established in the plan and shall maintain a log with 

records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

maintenance for at least five (5) years and make them available to the Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 19 of 47 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 

[COMAR 26.11.03.06C] 

Reporting Requirement

None 

Discussion of compliance demonstration

The Permittee shall monitor monthly to ensure visible emissions from each dust collector not exceeding 20 percent 

opacity. For particulate matter emissions, the Permittee is required to prepare a preventative maintenance plan for 

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

2C. Raw Mill and Raw Mill Heater - Registration #7-0110 (Not subject to NSPS) 

The Raw Mill and the Raw Mill Heater were installed or modified prior to August 17, 1971.

Emissions Points Emissions Units

ER38 ER38 -Raw Mill R37 and Discharge from Raw Mill R37 to Bucket Elevator R41 

ER38 ER39 -Raw Mill heater R39 

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. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process modification or 

justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b) which prohibits the discharge of particulate matter emissions from confined 

sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the 

following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the maximum allowable 

weight of particulate matter discharged per hour may exceed that calculated by the above equation 

provided that the concentration of particulate matter in the gases discharged to the atmosphere is less than 

0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 20 of 47 

A. The Permittee will conduct a walk-through inspection of the facility once per week. A visible emission 

evaluation will be performed on the exhaust of each operating source, using EPA Reference Method 22 for 

one-minute period. If no visible emissions are observed, such conditions will be noted in the inspection 

log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair the emissions 

unit and related equipment until no visible emissions are observed based on EPA Reference Method 22. If 

visible emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 20 percent, the opacity shall be 

recorded and no further action will be necessary for this weekly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 20 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this weekly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

[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 limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update the preventative maintenance plan for the dust collector that 

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

perform maintenance activities within the timeframes established in the plan and shall maintain a log with 

records of the date maintenance was performed. 

[COMAR 26.11.03.06C] 

Record keeping Requirement

A. The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

maintenance for at least five (5) years and make them available to the Department upon request. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 

[COMAR 26.11.03.06C] 

Reporting Requirement

None 

Discussion of compliance demonstration

The Permittee shall monitor to ensure visible emissions not exceeding 20 percent opacity. Since the potential 

emissions from the raw mill and raw mill heater could be significant, the Permittee is required to perform 1-minute 

Method 22 visible emissions observations at least once a week. For particulate matter emissions, the Permittee is 

required to prepare a preventative maintenance plan for each dust collector that describes the maintenance activity 

and time schedule for completing each activity. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 21 of 47 

3A. Coal and Alternative Fuel Handling - Registration # 7-0108- Fugitive Emissions (Not Subject to NSPS) 

The following equipment were installed or modified prior to October 24, 1974. 

Emissions Units

EASTP2 Coal storage pile (See Quarry Section) 

EAC1 Solid fuel bins C1-1 & C1-2 

EAC2 Vibratory Feeders C2-1 & C2-2 

EAC3 Coal Crusher 

EAC4 Belt Conveyor C4 

EAC7 Weigh Feeder C7-1 

EAC10 Coal Silo C10 

EAC19 I-Bin C19 

Applicable Standards and Limitations

(1) COMAR 26.11.06.03C(1) - 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 - A person may not cause or permit any material to be handled, transported, or 

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

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

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

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

and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each emissions unit to verify 

that reasonable precautions are being implemented and to determine whether the reasonable precautions need to 

be revised. The inspection shall be conducted at a minimum of once per month at times when the effectiveness 

of the reasonable precautions can be assessed. 

 [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. 

[COMAR 26.11.03.06C]

Reporting Requirements

None 

Discussion of compliance demonstration

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

prevent particulate matter from becoming airborne. The Permittee is required to prepare a best management plan in 

which the reasonable precautions that the Permittee will implement are listed and described. To document that 

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

maintain records of the results. Inspections are required at times when weather conditions are favorable for 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 22 of 47 

particulate matter to become airborne. The plan is required to be updated when it is determined that additional or 

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

3B. Coal and Alternative Fuel Handling - Registration # 7-0108- Point Sources (Not Subject to NSPS) 

The coal mill was installed in1970.

Emissions Points Emissions Units

EC15 EC15 -Coal Mill C8-1 and Cyclone C14 controlled by dust collector C15

Applicable Standards and Limitations

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. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process modification or 

justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter emissions from 

confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by 

the following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

 

For those processes in which the process weight per hour exceeds 60,000 pounds (27,200 kilograms), the 

maximum allowable weight of particulate matter discharged per hour may exceed that calculated by the 

equation shown in (1) provided that the concentration of particulate matter in the gases discharged to the 

atmosphere is less than 0.05 gr/scfd (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar month. A visible 

emission evaluation will be performed on the exhaust of each operating source, using EPA Reference 

Method 22 for one-minute period. If no visible emissions are observed, such conditions will be noted in 

the inspection log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair 

the emissions unit and related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 20 percent, the opacity shall be 

recorded and no further action will be necessary for this monthly inspection. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 23 of 47 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 20 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

[COMAR 26.11.03.06C] 

B. The Permittee shall comply with and update the preventative maintenance plan for each dust collector that 

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

perform maintenance activities within the timeframes established in the plan and shall maintain a log with 

records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

maintenance for at least five (5) years and make them available to the Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 

[COMAR 26.11.03.06C] 

Reporting Requirement

None 

Discussion of compliance demonstration

The Permittee shall monitor monthly to ensure visible emissions from each dust collector not exceeding 20 percent 

opacity. For particulate matter emissions, the Permittee is required to prepare a preventative maintenance plan for 

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

4. Kiln System - Registration #7-0109 (Subject to MACT Requirements)

Emissions Points Emissions Units

KB13 Kiln 

The kiln is subject to the requirements under the MACT area source. Since the kiln was installed prior to August 

17, 1971, it is not subject to 40 CFR, Subpart F. 

Applicable Standards/Limits

A. Visible Emissions 

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

installation or building, other than water in an uncombined form, which is greater than 20 percent opacity. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 24 of 47 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process modification or 

justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter emissions from 

confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by 

the following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

 

For those processes in which the process weight per hour exceeds 60,000 pounds (27,200 kilograms), the 

maximum allowable weight of particulate matter discharged per hour may exceed that calculated by the 

equation shown in (1) provided that the concentration of particulate matter in the gases discharged to the 

atmosphere is less than 0.05 gr/scfd (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)]

C. Dioxins/Furans (D/F) 

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

(1) 0.2 ng per dscm (8.7 X 10 –11 gr per dscf)(TEQ) corrected to seven 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)(a) which limits NOx emissions to 1,000 pounds per hour on a 30-day 

rolling average.

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

facility to either meet the applicable emissions 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. 

(3) COMAR 26.11.29.15C(4) - The owner/operator of a cement manufacturing facility subject to this 

regulation may submit an alternative control proposal for approval by the Department. 

Note: St. Lawrence Cement received approval from MDE for its Linkman control system as an 

alternative NOx control. 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) COMAR 26.11.06.05B(1) which limits the sulfur dioxide concentration in the exhaust gases not to 

exceed 2000 parts per million by volume corrected to 7 percent oxygen. 

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

combination not to exceed 70 milligrams reported as sulfuric acid per cubic meter of gas corrected to 7 

percent oxygen. 

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

emissions collected from the main kiln stack. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 25 of 47 

F. When burning scrap tires as an alternate fuel in the kiln, the Permittee shall not allow: 

(1) the feed rate of scrap tires to exceed 3.8 tons per hour; and 

(2) the temperature between the preheating and calcining zones of the kiln to fall below 1,400o

F. 

[Permit to Construct 043-7-0109M issued on November 21, 2002]

Compliance Demonstration

Testing Requirements

A, D, E, and F None 

B. The Permittee shall conduct a particulate matter emissions test at once every 5 years in accordance with 40 CFR 

60.64 and Method 5 of 40 CFR Part 60, Appendix A. Each performance test shall consist of three separate runs 

under the conditions that the kiln operates at least 90% of maximum allowable process rate. 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. 

[COMAR 26.11.03.06C] 

C. The Permittee shall conduct a dioxins/furans emissions test at the interval stipulated in Subpart LLL(once 

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

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

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

conditions in accordance with 40 CFR Part 63, Subpart LLL. The duration of each run shall be at least 

three hours and the sample volume for each run shall be at least 2.5 dscm (90 dscf). The concentration 

shall be determined for each run and the arithmetic average of the concentrations measured for the 

three runs shall be calculated and used to determine compliance. 

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

during the period of the Method 23 test, and the continuous temperature record(s) must be included in 

the performance test report. 

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

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

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

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

[40 CFR §63.1349(b)(3) and (d)] 

Monitoring Requirements

A. The Permittee, in accordance with COMAR 26.11.01.10B, shall continuously monitor opacity of the stack 

gases using a continuous opacity monitor that is certified in accordance with 40 CFR Part 60, Appendix B 

and meets the quality assurance criteria of the Department’s air Management Administration Technical 

Memorandum 90-01 “Continuous Emission Monitoring (CEM) Policies and Procedures” (October 1990) 

which is incorporated by reference. 

[COMAR 26.11.01.11A] 

A and B. 

(1) The Permittee shall record the daily production rates and kiln feed rates. 

(2) 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] 

A, B, and C. 

(1) The Permittee shall inspect daily the operation of the Linkman process control and the kiln air 

pollution control equipment, including the electrostatic precipitator (ESP), and shall keep the 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 26 of 47 

equipment properly maintained and in good working order so as to ensure full and continuous 

compliance with all applicable regulations. The daily inspection shall include an examination of the 

ESP operational data. 

[Permit to Construct 043-7-0109M issued on November 21, 2002] 

(2) The Permittee shall not feed tires to the kiln during periods of start-up, shut-down, or when the ESP is 

not functioning properly. 

[Permit to Construct 043-7-0109M issued on November 21, 2002] 

C1. The Permittee shall comply with and update the written operations and maintenance plan, which includes 

the following information: 

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

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

(2) Corrective actions to be taken when required by §63.1350(e); and 

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

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

[40 CFR §63.1350(a) and (b)] 

C2. The Permittee shall conduct an inspection of the components of the combustion system of each kiln or inline kiln raw mill at least once a year. 

[40 CFR §63.1350(i)] 

C3. The Permittee shall calibrate, maintain, and continuously operate a continuous monitor to record the 

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

upstream of the PM control devices. 

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

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

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

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

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

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

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

average is added to the previous 179 values to calculate the three-hour rolling average. 

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

from on to off the calculation of the three-hour rolling average temperature must begin anew, without 

considering previous recordings. 

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

three months. 

[40 CFR §63.1350(f)] 

D and E. 

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

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

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

Quality Assurance Procedures under 40 CFR Part 60, Appendix F, and MDE’s Technical 

Memorandum TM-90-01. 

[COMAR 26.11.09.08H(1)] 

(2). 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 emissions standard. 

[COMAR 26.11.01.11D(3)] 

F. None 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 27 of 47 

Record keeping Requirements

A, B, D, E, and F 

The Permittee shall maintain all records collected from both testing and/or 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. 

[COMAR 26.11.03.06C] 

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] 

Reporting Requirements

A, D, and E 

 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 emissions 

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 emissions 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 COMAR 26.11.01.10G(2)(d)] 

B. (1) The Permittee shall submit the results of performance tests before the close of business on the 60th day 

following the completion of the performance test. 

 (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. 

[COMAR 26.11.03.06C] 

C. (1) The Permittee shall submit the results of performance tests before the close of business on the 60th day 

following the completion of the performance test. 

[40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] 

(2) At least 30 days prior to each stack emissions testing, the Permittee shall submit to the Department a 

stack test protocol for review and approval. 

[COMAR 26.11.03.06C] 

D. NOx Emissions 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 28 of 47 

The Permittee shall submit 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)] 

F. None 

Notes: St. Lawrence submitted its RATA reports on April 15, 2004 for the required certification of its NOx 

and SO2 CEMs. 

Background information:

St. Lawrence conducted compliance testing on April 23 and 24, 2002 for dioxin/furan emissions from the Kiln 

exhaust stack. The testing indicated that a dioxin/furan concentration of 0.016 ng /dscm corrected to seven percent 

oxygen when the APCD inlet temperature from the Kiln was 578 degree F. 

5. Clinker Cooler - Registration #7-0109 (Not Subject to MACT and NSPS Subpart F Requirements) 

The clinker cooler was installed or modified prior to August 17, 1971.

Emissions Points Emissions Units

KC1 Clinker Cooler 

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. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process modification or 

justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b) which prohibits the discharge of particulate matter emissions from confined 

sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the 

following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the maximum allowable 

weight of particulate matter discharged per hour may exceed that calculated by the above equation 

provided that the concentration of particulate matter in the gases discharged to the atmosphere is less than 

0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

Compliance Demonstration

Testing Requirements

A. None 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 29 of 47 

B. The Permittee shall conduct a particulate matter emissions test at once every 5 years in accordance with 40 

CFR 60.64 and Method 5 of 40 CFR Part 60, Appendix A. Each performance test shall consist of three 

separate runs under the conditions that the kiln operates at least 90% of maximum allowable process rate. 

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. 

[COMAR 26.11.03.06C]. 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per week. A visible emission 

evaluation will be performed on the exhaust of each operating source, using EPA Reference Method 22 for 

one-minute period. If no visible emissions are observed, such conditions will be noted in the inspection 

log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair the emissions 

unit and related equipment until no visible emissions are observed based on EPA Reference Method 22. If 

visible emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 20 percent, the opacity shall be 

recorded and no further action will be necessary for this weekly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 20 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this weekly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

[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 limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C]

B2. The Permittee shall comply with and update the preventative maintenance plan for the dust collector that 

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

perform maintenance activities within the timeframes established in the plan and shall maintain a log with 

records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record keeping Requirement

A. The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

maintenance for at least five (5) years and make them available to the Department upon request. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 

[COMAR 26.11.03.06C] 

Reporting Requirement

A. None 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 30 of 47 

B. (1) The Permittee shall submit the results of performance tests before the close of business on the 60th day 

following the completion of the performance test. 

(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. 

[COMAR 26.11.03.06C] 

Discussion of compliance demonstration

The Permittee shall monitor visible emissions to ensure that the opacity from the exhaust of the clinker cooler does 

not exceed 20 percent. Since the potential emissions from the raw mill and raw mill heater could be significant, the 

Permittee is required to perform 1-minute visible emissions observations at least once a week. For particulate 

matter emissions, the Permittee is required to prepare a preventative maintenance plan for each dust collector that 

describes the maintenance activity and time schedule for completing each activity. In addition, the Permittee shall 

conduct particulate matter emissions testing at least once every 5-year period. 

6A. Cement Kiln System ( Not Including Kiln and Clinker Cooler) - Registration #7-0109 – Fugitive Emissions 

The following equipment were installed or modified prior to August 17, 1971.

Emissions Units

EKB37-F Transfer from ESP/Multiclone to Bucket Elevators KB35 & KB36 

EAKB53 Transfer from CKD Unloader to Haul Trucks 

EASTP3 CKD Pile Wind Erosion 

EACKDH CKD Pile Activity 

EAKC8 Transfer from Clinker Cooler KC1 to Drag Conveyor KCB 

EAKC9 Transfer from Drag Belt KC9 to Kick out Belt KC9-2 and Transfer from Belt Conveyor KC9-3 to 

Belt Conveyor 37 

EAROD2 CKD Haul Truck to CKD Pile 

ETNK1 Liquid Fuel Tanks working loss 

ETNK2 Liquid Fuel Tanks breathing loss 

 

Applicable Standards and Limitations

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

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

becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and Construction. A person may not 

cause or permit any material to be handled, transported, or stored, or a building, its appurtenances, or a 

road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

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

and methods that will be used to take reasonable precautions. [COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each emissions unit to verify 

that reasonable precautions are being implemented and to determine whether the reasonable precautions need to 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 31 of 47 

be revised. The inspection shall be conducted at a minimum of once per month at times when the effectiveness 

of the reasonable precautions can be assessed. 

 [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. 

[COMAR 26.11.03.06C]

Reporting Requirements

None 

Discussion of compliance demonstration

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

prevent particulate matter from becoming airborne. The Permittee is required to prepare a best management plan in 

which the reasonable precautions that the Permittee will implement are listed and described. To document that 

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

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

particulate matter to become airborne. The plan is required to be updated when it is determined that additional or 

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

6B. Cement Kiln System (Not Including Kiln and Clinker Cooler) - Registration #7-0109 – Point Sources

The following equipment were installed or modified prior to August 17, 1971. 

Emissions Points Emissions Units

EKB11 EKB11 -Transfer from Kiln Feed Pumps (EKB4 and EKB5) to Kiln Feed Hopper; Transfer 

from CKD Recovery to Bucket Elevator KB44 

EKB37-S EKB37 -Transfer from CKD Bucket Elevators KB35 & KB36 Waste Dust Bin KB40A and 

Recovery Waste Dust Bin KB40B 

EAKC9-S EAKC9 -Transfer from Drag Belt KC8 to Drag Belt KC9 and Belt Conveyor KC9-3 and 

Transfer from Belt Conveyor KC9-3 to Belt Conveyor 37 and Kick out Belt KC9-2 to Belt 

Conveyor 37 

EAKB54 EAKB53 -Transfer from Waste Dust Bin to Customer Trucks 

Applicable Standards and Limitations

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. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process modification or 

justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- minute period. 

[COMAR 26.11.06.02A(2)] 

A. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 
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1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

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COMAR 26.11.06.03B(1)(b) which prohibits the discharge of particulate matter emissions from confined 

sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the 

following equation when the process rate exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

 

For those processes in which the process weight per hour exceeds 60,000 pounds, the maximum allowable 

weight of particulate matter discharged per hour may exceed that calculated by the above equation 

provided that the concentration of particulate matter in the gases discharged to the atmosphere is less than 

0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per month. A visible emission 

evaluation will be performed on the exhaust of each operating source, using EPA Reference Method 22 for 

one-minute period. If no visible emissions are observed, such conditions will be noted in the inspection 

log. If visible emissions are observed, the Permittee shall immediately inspect and/or repair the emissions 

unit and related equipment until no visible emissions are observed based on EPA Reference Method 22. If 

visible emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 20 percent, the opacity shall be 

recorded and no further action will be necessary for this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 20 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

 [COMAR 26.11.03.06C] 

B. The Permittee shall comply with and update the preventative maintenance plan for each dust collector that 

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

perform maintenance activities within the timeframes established in the plan and shall maintain a log with 

records of the dates maintenance was performed. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

maintenance for at least five (5) years and make them available to the Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 33 of 47 

[COMAR 26.11.03.06C] 

Reporting Requirement

None 

Discussion of compliance demonstration

The Permittee shall monitor monthly to ensure visible emissions from each dust collector not exceeding 20 percent 

opacity. For particulate matter emissions, the Permittee is required to prepare a preventative maintenance plan for 

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

7A. Finish Mill System - Registration #7-0111– Fugitive Emissions (Subject to 40 CFR Part 60, Subpart F) 

The following equipment were installed or modified after August 17, 1971. 

Emissions Points

EAF83 Discharge point from Conveyor F81 and storage of clinker 

EAROAD2 Traffic from Bulk Silos (See Quarry Section) 

EASTP3 Gypsum and Slag Storage Pile Unloading and Wind Erosion 

EF54 Transfer from Air Slide F61-31 to Belt Conveyor F54 and then to Finish Mill 

EF60 Transfer from Air Slide F61-11 to Bucket Elevator F60 

EF61 Transfer from Air Slides F68-1 and F68-2 to Air Slide F61-32 and Cement Coolers F63A and 

63B and then to F-K pump F65 

Applicable Standards and Limitations

A. Visible Emissions 

40 CFR §60.62(c) - A person may not cause to be discharged into the atmosphere from any affected 

facility other than kiln and clinker cooler any gases which exhibit 10 percent opacity, or greater. 

B. Particulate Matter Emissions 

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

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

matter from becoming airborne. 

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

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

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

precautions to prevent particulate matter from becoming airborne. 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

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

and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C] 

The Permittee shall perform a walk through inspection of the facility to observe each emissions unit to verify 

that reasonable precautions are being implemented and to determine whether the reasonable precautions need to 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 34 of 47 

be revised. The inspection shall be conducted at a minimum of once per month at times when the effectiveness 

of the reasonable precautions can be assessed. 

[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. 

[COMAR 26.11.03.06C] 

Reporting Requirements

None 

Discussion of compliance demonstration

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

prevent particulate matter from becoming airborne. The Permittee is required to prepare a best management plan in 

which the reasonable precautions that the Permittee will implement are listed and described. To document that 

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

inspection to prevent any violations of NSPS visible emissions requirements and maintain records of the results. 

Inspections are required at times when weather conditions are favorable for particulate matter to become airborne. 

The plan is required to be updated when it is determined that additional or different procedures are needed to 

prevent particulate matter from becoming airborne. 

7B. Finish Mill System - Registration #7-0111– Point Sources (Subject to 40 CFR Part 60, Subpart F) 

The following equipment were installed or modified after August 17, 1971. 

Emissions Points Emissions Units

EF39 EF39 -Transfer from Belt F40 to Belt F43-1 in S. Transfer Tower 

EF42 EF42 -Transfer from Belt F80 to Belt F40; Transfer from Conveyor F37 to Conveyors F81and 

F40 in N. Transfer Tower 

EF67 EF67 -Bulk Cement Silos, Filling 

EF68 EF68 -Finish Mill F55 

EF69 EF69 - Mill Separator F62 

EF71 EF71 -Finish Mill Weigh Feeders; Finish Mill Feed Belt; Transfer from Belt F43 Tripper to 

F45- Series Clinker Bins 

EF75 EF75 -Bulk Cement Silos, Filling 

EF81 EF81 -Transfer from Conveyor F81 to F83 Silos or Bucket Elevator F97 

EF86 EF86 -Transfer from Belt F98 and F83 Silos to Belt F80 

EF92 EF92 -Transfer from Bucket Elevator F97 to Conveyor 91, then to Clinker Silo F105 

EF96 EF96 -Transfer from Clinker Silo F105 to Feeders; Transfer from Gypsum/Clinker Feeders to 

Belt F98 

EBS802 EBS802 -Bulk Cement Silos, Loadout to Truck and Rail 

EBS814 EBS814 -Bulk Cement Silos, Loadout to Truck and Rail 

Applicable Standards and Limitations

A. Visible Emissions 

(1) 40 CFR §60.62(c) - A person may not cause to be discharged into the atmosphere from any affected 

facility other than kiln and clinker cooler any gases which exhibit 10 percent opacity, or greater. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 35 of 47 

(2) 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. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process modification or 

justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed on or after January 17, 1972: 

COMAR 26.11.06.03B(1)(a) - A person may not cause or permit particulate matter to be discharged from 

any installation in excess of 0.05 gr/SCFD (115 mg/dscm).

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar month. Fugitive 

emission sources inside buildings will be evaluated at the door(s) of the building. A visible emission 

evaluation will be performed on each operating source, using EPA Reference Method 22 for one-minute 

period. If no visible emissions are observed, such conditions will be noted in the inspection log. If visible 

emissions are observed, the Permittee shall immediately inspect and/or repair the emissions unit and related 

equipment until no visible emissions are observed based on EPA Reference Method 22. If visible 

emissions are still observed, the Permittee will immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6-

minute average opacity measurement shows opacity less than 10 percent, the opacity shall be 

recorded and no further action will be necessary for this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 10 percent, the Permittee shall initiate 

corrective maintenance immediately and repeatedly to repair or replace equipment that is causing 

excess emissions until corrective maintenance has been completed. The “completeness of corrective 

maintenance” means that at least two 6-minute EPA Method 9 observations are taken within 60 

minutes and shows opacity less than 10 percent for each observation. If the corrective maintenance 

has been completed, the visible observations with the corrective maintenance shall be noted in the 

inspection log and no further action will be necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall report to the 

Department excess emissions in accordance with COMAR 26.11.01.07C. 

[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 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 dust collector that 

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

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

Cement MACT. The Permittee shall perform maintenance activities within the timeframes established in 

the plan and shall maintain a log with records of the dates maintenance was performed. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 36 of 47 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log of inspection and 

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

minimum, the most recent two years of data shall be retained on site. The remaining three years of data 

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

magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each baghouse and a record 

of the date and description of maintenance activity performed. The Permittee shall maintain records of the 

baghouse malfunctions and the corrective actions taken to bring back into proper operation. 

[COMAR 26.11.03.06C]

Reporting Requirement

None 

Discussion of compliance demonstration

The Permittee shall monitor monthly to ensure visible emissions from each dust collector not exceeding 10 percent 

opacity. For particulate matter emissions, the Permittee is required to prepare a preventative maintenance plan for 

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

8. One 3,000 gallon Gasoline Tank – Installed in 1992 

Emissions Points Emissions Units 

ETNK3 3,000 Gallon Gasoline Storage Tank 

Applicable Standards and Limitations 

COMAR 26.11.13.04C(2) – “Stage 1 Vapor Recovery. An owner or operator of a gasoline tank truck or an owner 

of a stationary storage tank subject to this regulation may not cause or permit gasoline to be loaded into a stationary 

tank unless the loading system is equipped with a vapor balance line that is properly installed, maintained, and 

used.”

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

Once a month the Permittee shall visually inspect the gasoline loading and unloading operations for liquid leaks 

and spills, and verify that the loading connections are leak tight and automatically close upon disconnection. 

[COMAR 26.11.03.06C] 

Record Keeping Requirements

The Permittee shall maintain records of the inspection results, gasoline throughput, and tank size for at least five 

years and shall make such records available to the Department upon request. 

[COMAR 26.11.03.06C] 

Reporting Requirements

None
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 37 of 47 

9. One Cold Degreaser – Installed in 1970 

Emissions Points Emissions Units 

ECD1 One Cold Degreaser 

Applicable Standards and Limitations 

(1) COMAR 26.11.19.09D(2) - A person may not use any VOC degreasing material that exceeds the following 

vapor pressure of 1 mm Hg (0.019 psia) at 20o

C; and 

(2) COMAR 26.11.19.09D(4) - A person may not use a halogenated substance that is a VOC in any cold 

degreasing. 

Compliance Demonstration

Testing Requirements

None 

Monitoring Requirements

(1) The Permittee shall implement good operating practices including covers (including water covers), lids, or 

other methods of minimizing evaporative losses, and reducing the time and frequency during which parts 

are cleaned. 

[COMAR 26.11.19.09D(3)(b)] 

(2) Good operating practices shall be established in writing, and displayed so they are clearly visible to the 

operator. 

[COMAR 26.11.19.09D(3)(c)] 

Record Keeping Requirements

The written good operating practices shall be maintained at the facility and made available for review by the 

Department upon request. 

[COMAR 26.11.19.09D(3)(d)] 

Reporting Requirements

None

MACT Requirements

(Applies to MACT Sources Only)

Applicable Standards and Regulations

The Permittee shall comply with the following sections of the General Provisions. The provisions, which do not apply, have 

been deleted. 

Table 1 to Subpart LLL of Part 63—Applicability of General Provisions 

General Provisions 

40 CFR Citation 

Requirement Comment 

63.1(a)(1) through (4) Applicability 

63.1(a)(6) through (a)(8) Applicability 

63.1(a)(10) through (14) Applicability 

63.1(b)(2) and (3) Initial Applicability Determination 
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ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 38 of 47 

63.1(c)(1) Applicability after Standard 

 Established 

63.1(c)(2) Permit Requirements Area Sources Must Obtain Title V 

Permits 

63.1(c)(4) and (5) Extensions, Notifications 

63.1(e) Applicability of Permit Program 

63.2 Definitions Additional Definitions in §63.1341 

63.3(a) through (c) Units and Abbreviations 

63.4(a)(1) through (a)(3) Prohibited Activities 

63.4(a)(5) Compliance Date 

63.4(b)and (c) Circumvention, Severability 

63.5(a)(1) and (2) Construction/Reconstruction 

63.5(b)(1) Compliance Dates 

63.5(b)(3) through (6) Construction Approval. 

Applicability 

63.5(d)(1) through (4) Approval of Construction/ 

Reconstruction 

63.5(e) Approval of Construction/ 

Reconstruction 

63.5(f)(1) and (2) Approval of Construction/ 

Reconstruction 

63.6(a) Compliance for Standards and 

Maintenance 

63.6(b)(1) through (5) Compliance Dates 

63.6(b)(7) Compliance Dates 

63.6(c)(1) and (2) Compliance Dates 

63.6(c)(5) Compliance Dates 

63.6(e)(1) and (e)(2) Operation & Maintenance 

63.6(e)(3) Start-up, Shut-Down and 

 Malfunction 

63.6(f)(1) through (3) Compliance with Emission 

Standards 

63.6(g)(1) through (g)(3) Alternative Standard 

63.6(h)(1) and (2) Opacity/VE Standards 

63.6(h)(4) and (h)(5)(i) Opacity/VE Standards 

63.6(h)(6) Opacity/VE Standards 

63.6(h)(7) Opacity/VE Standards 

63.6(i)(1) through (i)(14) Extension of Compliance 

63.6(i)(16) Extension of Compliance 

63.6(j) Exemption from Compliance 

63.7(a)(1) through (a)(3) Performance Testing 

Requirements 

§63.1349 has specific requirements 

63.7(b) Notification 

63.7(c) Quality Assurance/Test Plan 

63.7(d) Testing Facilities 

63.7(e)(1) through (4) Conduct of Tests 

63.7(f) Alternative Test Method 

63.7(g) Data Analysis 
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ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 39 of 47 

63.7(h) Waiver of Tests 

63.8(a)(1) Monitoring Requirements 

63.8(b)(1) through (3) Conduct of Monitoring 

63.8(c)(1) through (8) CMS Operation/Maintenance Performance specification supersedes 

requirements for THC CEM. Temperature 

and activated carbon injection monitoring 

data reduction requirements given in subpart 

LLL. 

63.8(d) Quality Control 

63.8(e) Performance Evaluation for CMS Performance Specification supersedes 

requirements for THC 

63.8(f)(1) through (f)(5) Alternative Monitoring Method Additional requirements in §1350(l) 

63.8(f)(6) Alternative to RATA Test 

63.8(g) Data Reduction 

63.9(a) Notification Requirements 

63.9(b)(1) through (5) Initial Notifications 

63.9(c) Request for Compliance Extension 

63.9(d) New Source Notification for 

Special Compliance Requirements 

63.9(e) Notification of Performance Test 

63.9(f) Notification of VE/Opacity Test Notification not required for VE/opacity test 

under §63.1350(e) and (j) 

63.9(g) Additional CMS Notifications 

63.9(h)(1) through (h)(3) Notification of Compliance Status 

63.9(h)(5) and (h)(6) Notification of Compliance Status 

63.9(i) Adjustment of Deadlines 

63.9(j) Change in Previous Information 

63.10(a) Record keeping/Reporting 

63.10(b) General Requirements 

63.10(c)(1) Additional CMS Record Keeping PS-8A applies instead of requirements for 

THC CEM 

63.10(c)(5) through (c)(8) Additional CMS Record Keeping PS-8A applies instead of requirements for 

THC CEM 

63.10(c)(10) through (15) Additional CMS Record Keeping 

63.10(d)(1) General Reporting Requirements 

63.10(d)(2) Performance Test Results 

63.10(d)(3) Opacity or VE Observations 

63.10(d)(4) Progress Reports 

63.10(d)(5) Startup, Shutdown, Malfunction 

Reports 

63.10(e)(1) and (e)(2) Additional CMS Reports 

63.10(e)(3) Excess Emissions and CMS 

Performance Reports 

Exceedances are defined in subpart LLL 

63.10(f) Waiver for Record Keeping/ 

Reporting 

63.12(a)-(c) State Authority and Delegations 

63.13(a)-(c) State/Regional Addresses 

63.14(a) and (b) Incorporation by Reference 

63.15(a) and (b) Availability of Information 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 40 of 47 

Applicable Standards and Regulations

40 CFR §63.6(e)(3)(i) which requires that the Permittee comply with the written startup, shutdown, and 

malfunction plan that describes, in detail, procedures for operating and maintaining the source during periods of 

startup, shutdown, and malfunction; a program of corrective action for malfunctioning process; and air pollution 

control and monitoring equipment used to comply with the relevant standard. 

40 CFR §63.6(e)(3)(viii) which states that the Permittee may periodically revise the startup, shutdown, and 

malfunction plan for the affected source as necessary to satisfy the requirements of this part or to reflect changes in 

equipment or procedures at the affected source. Unless the permitting authority provides otherwise, the Permittee 

may make such revisions to the startup, shutdown, and malfunction plan without prior approval by the 

Administrator or the permitting authority. However, each revision to a startup, shutdown, and malfunction plan 

must be reported in the semiannual report required by §63.10(d)(5). If the startup, shutdown, and malfunction plan 

fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not 

included in the startup, shutdown, and malfunction plan at the time the Permittee developed the plan, the Permittee 

must revise the startup, shutdown, and malfunction plan within 45 days after the event to include detailed 

procedures for operating and maintaining the source during similar malfunction events and a program of corrective 

action for similar malfunctions of process or air pollution control and monitoring equipment. In the event that the 

Permittee makes any revision to the startup, shutdown, and malfunction plan which alters the scope of the activities 

at the source which are deemed to be a startup, shutdown, and malfunction, or otherwise modifies the applicability 

of any emission limit, work practice requirement, or other requirement in a standard established under this part, the 

revised plan shall not take effect until after the Permittee has provided a written notice describing the revision to the 

permitting authority. 

Compliance Demonstration

Testing Requirements

The Permittee shall conduct a dioxins/furans emissions test for the cement kiln at the interval stipulated in Subpart 

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

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

that exist when the affected source is operating under representative performance conditions in accordance 

with 40 CFR Part 63, Subpart LLL. The duration of each run shall be at least three hours and the sample 

volume for each run shall be at least 2.5 dscm (90 dscf). The concentration shall be determined for each 

run and the arithmetic average of the concentrations measured for the three runs shall be calculated and 

used to determine compliance. 

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

during the period of the Method 23 test, and the continuous temperature record(s) must be included in the 

performance test report. 

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

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

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

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

[40 CFR §63.1349(b)(3) and (d)] 

Monitoring Requirements

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain any affected 

source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety 

and good air pollution control practices for minimizing emissions to the levels required by the relevant standards, i.e., meet 

the emission standard or comply with the startup, shutdown, and malfunction plan. Malfunctions shall be corrected as soon 

as practicable after their occurrence in accordance with the startup, shutdown, and malfunction plan. To the extent that an 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 41 of 47 

unexpected event arises during a start-up, shutdown, and malfunction, the Permittee shall comply by minimizing emissions 

during such a startup, shutdown, or malfunction event consistent with safety and good air pollution control practices. 

[40 CFR §63.6(e)(1)(i -ii)] 

Record Keeping Requirements

When actions taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) are consistent with the procedures specified in the affected source’s start-up, shutdown, and malfunction plan, 

the Permittee shall keep records for that event which demonstrate the procedures specified in the plan were followed. These 

records may take the form of a “checklist”, or other effective form of record keeping that confirms conformance with the 

startup, shutdown, and malfunction plan for that event. In addition, the Permittee shall keep records of these events as 

specified in §63.10(b), including records of the occurrence and duration of each startup, shutdown, or malfunction of 

operation and each malfunction of the air pollution control and monitoring equipment. Furthermore, the Permittee shall 

confirm that action taken during the relevant reporting period during periods of startup, shutdown, or malfunction were 

consistent with the affected source’s startup, shutdown, and malfunction plan in the semiannual (or more frequent) start-up, 

shutdown, and malfunction report required in §63.10(d)(5). 

If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a 

malfunction) is not consistent with the procedures specified in the affected source’s startup, shutdown, and malfunction plan, 

and the source exceeds the relevant emission standard, then the Permittee shall record the actions taken for that event and 

shall report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter 

within 7 working days after the end of the event, in accordance with §63.10(d)(5) (unless the Permittee makes alternative 

reporting arrangements , in advance, with the Administrator). 

The Permittee shall maintain at the affected source a current startup, shutdown, and malfunction plan and shall make the plan 

available upon request for inspection and copying by the Administrator. In addition, if the startup, shutdown, and 

malfunction plan is subsequently revised, the Permittee shall maintain at the affected source each previous (i.e., superseded) 

version of the startup, shutdown, and malfunction plan, and must make each such previous version available for inspection 

and copying by the Administrator for a period of 5 years after revision of the plan. If at any time after adoption of a startup, 

shutdown, and malfunction plan the affected source ceases operation or is otherwise no longer subject to the provisions of 

this part, the Permittee shall retain a copy of the most recent plan for 5 years from the date the source ceases operation or is 

no longer subject to this part and shall make the plan available upon request for inspection and copying by the Administrator. 

[40 CFR §63.6(e)(3)(iii – v)] 

 

Reporting Requirements

The Permittee shall, if actions taken are consistent with the procedures specified in the start-up, shutdown, or malfunction 

plan, during a start-up, shut down, or malfunction of an affected source (including actions taken to correct a malfunction), 

state such information in a semiannual report. Reports shall only be required if a start-up, shutdown, or malfunction 

occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with 

the excess emissions and continuous monitoring system performance reports. 

Any time an action taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, shutdown, or malfunction plan, the Permittee shall make an 

immediate report of the actions taken for that event within 2 working days, by telephone call or fax transmission. The 

immediate report shall be followed by a letter, certified by the Permittee explaining the circumstances of the event, the 

reasons for not following the startup, shutdown, or malfunction plan, and whether any excess emissions and/or parameter 

monitoring exceedances are believed to have occurred. 

[40 CFR §63.1354(b)(4 – 5)] 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 42 of 47 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 43 of 47 

COMPLIANCE SCHEDULE

St. Lawrence Cement, Inc.’s plant in Hagerstown, Maryland is in compliance with air quality requirements.

TITLE IV - ACID RAIN

St. Lawrence Cement, Inc.’s plant in Hagerstown is not subject to the Acid Rain Program. 

TITLE VI - OZONE DEPLETING SUBSTANCES

The Permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, 

Subpart F. 

SECTION 112(r) -ACCIDENTAL RELEASE

St. Lawrence Cement, Inc.’s plant in Hagerstown is not subject to the requirements of Section 112 (r).

PERMIT - SHIELD

St. Lawrence Cement, Inc.’s Hagerstown, Maryland facility requested a permit shield in July 1997.
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 44 of 47 

INSIGNIFICANT ACTIVITIES 

The following emissions units and activities are exempt from Part 70 permit requirements: 

(1) No. 1 Fuel burning equipment using gaseous fuels or no. 1 or no. 2 fuel oil, and having a heat input less 

than 1,000,000 Btu (1.06 gigajoules) per hour; 

 

COMAR 26.11.09.05A(1), which establishes that the Permittee may not cause or permit the 

discharge of emissions from any fuel burning equipment, other than water in an uncombined form, 

which is greater than 20 percent opacity. 

Exceptions: COMAR 26.11.09.05A(2) does not apply to emissions during load changing, soot 

blowing, start-up, or adjustments or occasional cleaning of control equipment if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in 

any sixty minute period. 

COMAR 26.11.09.07A(1)(c), which establishes that the Permittee may not burn, sell, or make 

available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent. 

(2) No. 2 Fuel-burning equipment using solid fuel and having a heat input of less than 350,000 Btu (0.37 

gigajoule) per hour; 

(3) No. 1 Stationary internal combustion engines with an output less than 500 brake horsepower (373 

kilowatts) and which are not used to generate electricity for sale or for peak or load shaving; 

(A) COMAR 26.11.09.05B(2), Emissions During Idle Mode: The Permittee may not cause or 

permit the discharge of emissions from any engine, operating at idle, greater than 10 percent 

opacity. 

(B) COMAR 26.11.09.05B(3), Emissions During Operating Mode: 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 26.11.09.05B(2) does not apply for a period of 2 consecutive minutes after a 

period of idling of 15 consecutive minutes for the purpose of clearing the exhaust 

system. 

(ii) COMAR 26.11.09.05B(2) does not apply to emissions resulting directly from cold 

engine start-up and warm-up for the following maximum periods: 

(a) Engines that are idled continuously when not in service: 30 minutes; 

(b) All other engines: 15 minutes. 

(iii) COMAR 26.11.09.05B(2) & (3) do not apply while maintenance, repair or testing is 

being performed by qualified mechanics. 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 45 of 47 

(4) X Space heaters utilizing direct heat transfer and used solely for comfort heat; 

(5) No. 2 Unheated VOC dispensing containers or unheated VOC rinsing containers of 60 gallons (227 liters) 

capacity or less; 

(a) COMAR 26.11.19.09D(2)(b), which establishes that the Permittee shall not use any VOC 

degreasing material that exceeds a vapor pressure of 1 mm Hg at 20 ° C; 

(b) COMAR 26.11.19.09D(3)(a—d), which requires that the Permittee implement good 

operating practices designed to minimize spills and evaporation of VOC degreasing material. 

 These practices, which shall be established in writing and displayed such that they are clearly 

visible to operators, shall include covers (including water covers), lids, or other methods of 

minimizing evaporative losses, and reducing the time and frequency during which parts are 

cleaned; 

(c) COMAR 26.11.19.09D(4), which prohibits the use of any halogenated VOC for cold 

degreasing. 

The Permittee shall maintain on site for at least five (5) years, and shall make available to the 

Department upon request, the following records of operating data: 

(a) Monthly records of the total VOC degreasing materials used; and 

(b) Written descriptions of good operating practices designed to minimize spills and evaporation 

of VOC degreasing materials. 

(6) X Equipment for drilling, carving, cutting, routing, turning, sawing, planing, spindle sanding, or disc 

sanding of wood or wood products; 

(7) X Brazing, soldering, or welding equipment, and cutting torches related to manufacturing and 

construction activities that emit HAP metals and not directly related to plant maintenance, upkeep 

and repair or maintenance shop activities; 

(8) Containers, reservoirs, or tanks used exclusively for: 

(a) X Storage of butane, propane, or liquefied petroleum, or natural gas; 

(b) No. 81 Storage of lubricating oils 

(c) No. 9 Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation jet engine fuel; 

(9) X First aid and emergency medical care provided at the facility, including related activities such as 

sterilization and medicine preparation used in support of a manufacturing or production process; 

(10) X Potable water treatment equipment, not including air stripping equipment; 

(11) X Emissions resulting from the use of explosives for blasting at quarrying operations and from the 

required disposal of boxes used to ship the explosive; 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 46 of 47 

(12) X Comfort air conditioning subject to requirements of Title VI of the Clean Air Act; 

 

(13) X Natural draft hoods or natural draft ventilators that exhaust air pollutants into the ambient air from 

manufacturing/industrial or commercial processes; 

(14) X Laboratory fume hoods and vents; 

For the following, attach additional pages as necessary: 

(15) any other emissions unit, not listed in this section, with a potential to emit less than the “de minimus” levels 

listed in COMAR 26.11.02.10X (list and describe units): 

 No. 1 Halon Fire Suppression System (Control Room) 

 No. 2 Laboratory Exhaust Vents 

 No. 8 Welding Machines (Maintenance) 
PART 70 OPERATING PERMIT FACT SHEET 

ST. LAWRENCE CEMENT, INC. 

1260 SECURITY ROAD 

HAGERSTOWN MD 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 47 of 47 

STATE-ONLY ENFORCEABLE SECTION -ONLY ENFORCEABLE SECTIONSt. Lawrence Cement, Inc.’s Portland cement plant in Hagerstown, Maryland is subject to the following State-only 

requirements: 

Emissions Unit No: Facility-Wide

Applicable Limits/Standards 

(1) COMAR 26.11.06.08, which prohibits the operation or maintenance of an installation or premises in such a 

manner that a nuisance or air pollution is created. 

(2) COMAR 26.11.06.09, which prohibits the discharge into the atmosphere of gases, vapors, or odors beyond 

the property line in such a manner that a nuisance or air pollution is created. 

(3) COMAR 26.11.15.05, which requires the Permittee to use the Best Available Control Technology for Toxics 

(T-BACT) to minimize toxic air pollutants. 

(4) COMAR 26.11.15.06, which prohibits the discharge of toxic air pollutants to the extent that the emissions 

will unreasonably endanger human health. 

Compliance Demonstration 

The Permittee has demonstrated compliance with the above State-only regulations as long as the Permittee complies with 

the applicable federally enforceable requirements. There is no need to require additional compliance demonstration to 

meet the State-only requirements. 
 24-043-00008 

 

Ms. Victoria Mock, Manager 

Environmental-Hagerstown Plant 

St. Lawrence Cement 

1260 Security Road 

Hagerstown, MD 21742 

Re: Part 70 Operating Permit Renewal 

Dear Ms. Mock: 

 Enclosed please find the Title V Operating Permit and Fact Sheet for the St. Lawrence 

Cement Hagerstown facility. The permit will expire on April 30, 2009. 

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

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

are objectionable to the applicant, the applicant may request that a contested case 

hearing be held regarding the permit. This request shall be made to the Department 

in writing not later than 15 days after the applicant receives notice that the permit has 

been denied or of the objectionable terms and conditions. The request shall include 

the basis for the request and refer to any objectionable terms and conditions. 

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

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

 Sincerely, 

 Karen G. Irons, P.E., Administrator 

 Air Quality Permits Program 

 Air & Radiation Management Administration 

KGI/jm 

Enclosures 

cc: Dave Campbell, EPA Region III, with enclosures 
 Kathleen Anderson, EPA Region III 
Bcc: Shannon, George B , Dave
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 2 of 73 

SECTION I SOURCE IDENTIFICATION .............................................................................. 4

1. DESCRIPTION OF FACILITY......................................................................................... 4

2. FACILITY INVENTORY LIST ........................................................................................ 4

SECTION II GENERAL CONDITIONS................................................................................. 10

1. DEFINITIONS ................................................................................................................. 10

2. ACRONYMS ................................................................................................................... 10

3. EFFECTIVE DATE ......................................................................................................... 11

4. PERMIT EXPIRATION .................................................................................................. 11

5. PERMIT RENEWAL....................................................................................................... 12

6. CONFIDENTIAL INFORMATION................................................................................ 12

7. PERMIT ACTIONS......................................................................................................... 13

8. PERMIT AVAILABILITY.............................................................................................. 13

9. REOPENING THE PART 70 PERMIT FOR CAUSE BY THE EPA ............................ 13

10. TRANSFER OF PERMIT ........................................................................................... 13

11. REVISION OF PART 70 PERMITS – GENERAL CONDITIONS........................... 14

12. SIGNIFICANT PART 70 OPERATING PERMIT MODIFICATIONS..................... 14

13. MINOR PERMIT MODIFICATIONS ........................................................................ 15

14. ADMINISTRATIVE PART 70 OPERATING PERMIT AMENDMENTS............... 18

15. OFF-PERMIT CHANGES TO THIS SOURCE.......................................................... 19

16. ON-PERMIT CHANGES TO SOURCES................................................................... 20

17. FEE PAYMENT .......................................................................................................... 22

18. REQUIREMENTS FOR PERMITS-TO-CONSTRUCT AND APPROVALS........... 22

19. CONSOLIDATION OF PROCEDURES FOR PUBLIC PARTICIPATION............. 23

20. PROPERTY RIGHTS.................................................................................................. 23

21. SEVERABILITY......................................................................................................... 23

22. INSPECTION AND ENTRY ...................................................................................... 24

23. DUTY TO PROVIDE INFORMATION..................................................................... 24

24. COMPLIANCE REQUIREMENTS............................................................................ 25

25. CREDIBLE EVIDENCE ............................................................................................. 25

26. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE .............................. 25

27. CIRCUMVENTION .................................................................................................... 25

28. PERMIT SHIELD........................................................................................................ 26

29. ALTERNATE OPERATING SCENARIOS ............................................................... 26

SECTION III PLANT WIDE CONDITIONS ........................................................................... 27

1. PARTICULATE MATTER FROM CONSTRUCTION AND DEMOLITION.............. 27

2. OPEN BURNING ............................................................................................................ 27

3. AIR POLLUTION EPISODE .......................................................................................... 27

4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS............................................ 27

5. ACCIDENTAL RELEASE PROVISIONS ..................................................................... 28

6. GENERAL TESTING REQUIREMENTS...................................................................... 28

7. EMISSIONS TEST METHODS ...................................................................................... 29

8. EMISSIONS CERTIFICATION REPORT ..................................................................... 29

9. COMPLIANCE CERTIFICATION REPORT................................................................. 30

10. CERTIFICATION BY RESPONSIBLE OFFICIAL................................................... 31

11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING............................. 31
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 3 of 73 

12. GENERAL RECORDKEEPING................................................................................. 32

13. GENERAL CONFORMITY........................................................................................ 32

14. ASBESTOS PROVISIONS ......................................................................................... 32

15. OZONE DEPLETING REGULATIONS .................................................................... 33

16. ACID RAIN PERMIT ................................................................................................. 33

SECTION IV PLANT SPECIFIC CONDITIONS..................................................................... 34

SECTION V INSIGNIFICANT ACTIVITIES......................................................................... 69

SECTION VI STATE-ONLY ENFORCEABLE CONDITIONS ............................................. 73
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 4 of 73 

SECTION I SOURCE IDENTIFICATION

DESCRIPTION OF FACILITY 

St. Lawrence Cement, Inc., manufactures Portland cement, masonry cement, and blended cement at 

its Hagerstown, Washington County, Maryland plant. The Washington County site quarries 

limestone, operates a limestone crushing plant, a raw mill system, a cement kiln/clinker cooler 

system, a finish mill system, and a packaging and shipping operation. Although cement production 

at this location dates back to 1903, the current long dry kiln has been in operation since 1971. The 

maximum annual clinker production from the kiln is 693,500 tons. 

2. FACILITY INVENTORY LIST 

1. Quarry - Registration # 7-0108 (Not subject to MACT) 

Emissions Point 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources - Not subject to NSPS requirements 

EADRL1 Quarry drilling Fugitive emissions 1970 

EARMH1 Quarry raw material 

handling 

Fugitive emissions 1970 

EARMH2 Transfer from Outside Surge 

Stone Pile and Front End 

Loader to Stone Hopper 

Q28; from Stone Hopper 

Q28 to Feeder Q28.1; from 

Feeder Q28.1 to Belt Q27 

Fugitive Emissions 1970 

EARMH3 Raw Material Stockpile 

Truck Unloading onto Piles; 

to Raw Material Bins and 

Solid Fuel Bins 

Fugitive – Partial Enclosure 1970 

EAROAD1 Quarry haul roads Fugitive emissions - Controlled 

by water spray 

1970 

EAROAD2 Raw Material (Coal, Slag, 

GAF, Sand, Iron) Haul Road; 

CKD Haul Trucks to CKD 

Pile; Truck Traffic from 

Bulk Silos and Pack house 

Fugitive Emissions – Water Spray 1970 

EASTP1 Outside Surge Stone Pile 

Wind Erosion 

Fugitive Emissions 1970 

EASTP2 Raw Material (Coal, Slag, 

GAF, Sand, Iron) Stone Pile 

Wind Erosion 

Fugitive Emissions 1970 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 5 of 73 

Emissions Point 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources - Not subject to NSPS requirements 

EAQ1 Pan Feeder Q1 (Shown in Figure 1) 1970

EAQ2 Primary Crusher Q2 Fugitive emissions - Controlled 

by water spray 

1970 

EAQ3 Transfer from Belt Q3 to 

Belt Q4 

Fugitive emissions - Controlled 

by water spray 

1970 

Fugitive Sources - Subject to CFR 40 Part 60 Subpart OOO requirements 

EAQ21 Transfer from Stack 

Conveyor Q21 to Outside 

Surge Stone Pile EASTP1 

Fugitive Emissions 1999 

EAQ23 Transfer from Belt Q23 to 

Stacker/Conveyor Q25 

Inside Dome Q24 - Fugitive 

Emissions 

1999 

EAQ25 Transfer from 

Stack/Conveyor Q25 to 

Indoor Pile 

Inside Dome Q24 - Fugitive 

Emissions 

1999 

EAQ27 Conveyor Q27 Transfer 

Points 

Fugitive Emissions 1999 

EAQ28 Stone Hopper Q28 and 

Feeder Q28.1 

Fugitive Emissions 1999 

EARMH4 EARMH4-Dome Fugitive Emissions – Inside 

Building 

1999 

Point Sources - Not subject to NSPS requirements 

EAQ4 Transfer from Belt Q4 to Pan 

Feeder Q6-1 and Belt 5 

Controlled by Baghouse Q11 – 

EAQ11 

1970 

EAQ7 Transfer from Belt Q5 to 

Screen Q7 

Controlled by Baghouse Q11 

installed in 1999 – EAQ11 

1970 

EAQ7-A Transfer from Screen Q7 to 

Belt 10 

Controlled by Baghouse Q11 

installed in 1999 – EAQ11 

1970 

EAQ9 Transfer from Screen Q7 to 

Secondary Crusher Q9 

Controlled by Baghouse Q11 

installed and the same capacity 

crusher replacement in 1999 – 

EAQ11 

1970 

EAQ10 Transfer from Belt Q10 to 

Flop Gate Q19 

Controlled by Baghouse Q11 

installed in 1999 – EAQ11 

1970 

2. Raw Mill System - Registration # 7-0110 (Not subject to MACT and NSPS)

Emissions Point 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Fugitive Emissions 

EAR8 Transfer from Raw Material 

Bins to Belt Feeders, then to 

(Shown in Figure 1) 1970
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 6 of 73 

Emissions Point 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Belt Conveyor R8, then to 

Belt conveyor R11-1 

EAR11 Conveyor R11-1 Fugitive Emissions 1970 

EAR14 Transfer from Belt Q27 to 

Belt conveyor R14; from 

Belt conveyor R14 to Belt 

conveyor R16 

Fugitive Emissions 1970 

ER32 Transfer from Raw Mill Bins 

to Feeders; Transfer from 

Feeders to Belt conveyor 

R32 

(Shown in Figure 2) 1970 

EF36 Transfer from Crossover 

Stone Belt to Mansory/Slag 

Tank 

(Shown in Figure 2) 1970 

Point Sources 

ER13 Transfer from Belt R11-1 to 

Flop Gate R11-3; from Flop 

Gate R11-3 to Crusher R12-1 

and Belt R14; and Transfer 

from Crusher R12-1 to Belt 

R12-4 and then R14 

(Shown in Figure 1) Controlled by 

Dust Collector R13 – EAR13 

1970 

ER17 Transfer from Raw Mill 

Tripper R16 to Raw Mill 

Feed Bins R20-1 thru -5 

Controlled by Duct Collector R17 

– ER17 

1970 

ER38 Raw Mill R37 and Discharge 

from Raw Mill R37 to 

Bucket Elevator R41 

Controlled by Duct Collector 

R38B – ER38 

1970 

ER39 Raw Mill heater R39 Controlled by Duct Collector 

R38B – ER38 

1970 

ER45 Transfer from Belt conveyor 

R32 to Raw Mill R37 and 

Raw Miller Air Separator 

R43 

Controlled by Duct Collector R45 

– ER45 

1970 

ER50 Transfer from Air Slides to 

Blending Silos R60-1 thru -3 

Controlled by Duct Collector R50 

– ER50 

1970 

ER62 Raw Material Blending 

operation 

Controlled by Duct Collector R62 

– ER62 

1970 

EKB3 Transfer from Blending Silos 

R60-1 thru -3 to Air Slides 

(EKB1A, EKB1B, EKB1C, 

EKB1D, EKB1E, and 

Controlled by Duct Collector KB3 

– EKB3 

1970 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 7 of 73 

Emissions Point 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

EKB1F) 

3. Coal and Alternative Fuel Handling - Registration # 7-0108 ( Not subject to 

MACT and NSPS)

Emissions Unit 

Number 

Emissions Unit Name Emissions Unit Description Date of 

Installation 

Fugitive Sources 

EROAD2 Haul truck s on plant roads (See Quarry Section) 1970

EASTP2 Coal storage pile (See Quarry Section) 1970

EAC1 Solid fuel bins C1-1 & C1-2 (Shown in Figure 1) 1970

EAC2 Vibratory Feeders C2-1 & 

C2-2 

(Shown in Figure 1) 1970

EAC3 Coal Crusher Inside Building 1970 

EAC4 Belt Conveyor C4 (Shown in Figure 1) 1970 

EAC7 Weigh Feeder C7-1 (Shown in Figure 8) 1970 

EAC10 Coal Silo C10 (Shown in Figure 8) 1970 

EAC19 I-Bin C19 (Shown in Figure 8) 1970 

Point Sources 

EC15 Coal Mill C8-1 and Cyclone 

C14 

Controlled by Baghouse C15 – 

EAC8 (Shown in Figure 8) 

1970 

4. Kiln System - Registration #7-01090108 ( Subject to MACT for D/F )

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

KB13 Kiln Discharging through Multicyclone 

KB19 and ESP KB21 – EKB22 

1970 

5. Clinker Cooler - Registration #7-0109( Not Subject to MACT and NSPS 

requirements) 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

KC4 Clinker Cooler KC1 Discharging through Multicyclone 

KC2 and ESP KC3 - EKC4 

1970 

6. Cement Kiln System ( Not Include Kiln and Clinker Cooler) - Registration #7-0109 

( Not Subject to MACT and NSPS)

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Fugitive Emissions 

EKB37-F Transfer from 

ESP/Multiclone to Bucket 

Fugitive Emissions 1970 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 8 of 73 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Elevators KB35 & KB36 

EKB53 Transfer from CKD 

Unloader to Haul Trucks 

Fugitive Emissions – Water Spray 1970 

EASTP3 CKD Pile Wind Erosion Fugitive Emissions 1970 

EACKDH CKD Pile Activity Fugitive Emissions 1970 

EAKC8 Transfer from Clinker Cooler 

KC1 to Drag Conveyor KCB 

(Shown in Figure 5) 1970

EAKC9 Transfer from Drag Belt 

KC9 to Kick out Belt KC9-2 

and Transfer from Belt 

Conveyor KC9-3 to Belt 

Conveyor 37 

Part of EAKC9 (Shown in Figure 

5 and Emission Certifications) - 

Fugitive Emission 

1970 

EAROAD2 CKD Haul Trucks to CKD 

Pile 

Fugitive Emissions 1970 

ETNK1 Liquid Fuel Tanks working 

loss 

Fugitive Emissions 1970 

ETNK2 Liquid Fuel Tanks breathing 

loss 

Fugitive Emissions 1970 

Point Sources 

EKB11 Transfer from Kiln Feed 

Pumps (EKB4 and EKB5) to 

Kiln Feed Hopper; Transfer 

from CKD Recovery to 

Bucket Elevator KB44 

Controlled by Duct Collector 

KB11-3 – EKB11 

1970 

EKB37-S Transfer from CKD Bucket 

Elevators KB35 & KB36 

Waste Dust Bin KB40A and 

Recovery Waste Dust Bin 

KB40B 

Controlled by Duct Collector 

KB37A and KB37B – EKB37 

1970 

EKC9 Transfer from Drag Belt 

KC8 to Drag Belt KC9 and 

Belt Conveyor KC9-3 and 

Transfer from Belt Conveyor 

KC9-3 to Belt Conveyor 37 

and Kick out Belt KC9-2 to 

Belt Conveyor 37 

Controlled by Duct Collector 

KC9-5 (Shown in Figure 5) 

1970 

EAKB54 Transfer from Waste Dust 

Bin to Customer Trucks

Controlled by Duct Collector 

KB54 – EAKB54 

1970 

7. Finish Mill System - Registration #7-0111 (Not Subject to MACT)
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 9 of 73 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

Fugitive Emissions (Subject to 40 CFR Part 60 Subpart F) 

EAF83 Discharge point from 

Conveyor F81 and storage of 

clinker 

Fugitive Emissions 1976 

EAROAD2 Traffic from Bulk Silos and 

Pack house 

( See Quarry Section) 1970 (1976) 

EASTP3 Gypsum and Slag Storage 

Pile Unloading and Wind 

Erosion 

Fugitive Emission Source – Partial 

Enclosure 

1970 (1976) 

EARMH3 Raw Material Stockpile 

Truck Unloading onto Piles; 

to Raw Material Bins 

Fugitive – Partial Enclosure 1970 (1976) 

EF54 Transfer from Air Slide F61-

31 to Belt Conveyor F54 and 

then to Finish Mill 

(Shown in Figure 7) 1976

EF60 Transfer from Air Slide F61-

11 to Bucket Elevator F60 

(Shown in Figure 7) 1976

EF61 Transfer from Air Slides 

F68-1 and F68-2 to Air Slide 

F61-32 and Cement Coolers 

F63A and 63B and then to FK pump F65 

(Shown in Figure 7) 1976

Point Sources (Subject to 40 CFR Part 60 Subpart F) 

EF39 Transfer from Belt F40 to 

Belt F43-1 in S. Transfer 

Tower 

Discharges to Baghouse F39 1976 

EF42 Transfer from Belt F80 to 

Belt F40; Transfer from 

Conveyor F37 to Conveyors 

F81and F40 in N. Transfer 

Tower 

Discharges to Baghouse F42 – 

EP42 

1976 

EF67 Bulk Cement Silos, Filling Discharges to Baghouse F67-4 1976 

EF68 Finish Mill F55 Finish Mill controlled by cyclone 

and Baghouse F68 

1976 

EF69 Mill Separator F62 Discharges to Baghouse FF69 1976 

EF71 Finish Mill Weigh Feeders; 

Finish Mill Feed Belt; 

Transfer from Belt F43 

Tripper to F45- Series 

Clinker Bins 

Controlled by Baghouse F71 1976 

EF75 Bulk Cement Silos, Filling Discharges to Baghouse F75 1976 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 10 of 73 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

EF81 Tripper F81-2 and Transfer 

from Belt F81 to Bucket 

Elevator F97 

Discharges to Baghouse F81-7 and 

Baghouse F81-8 

1976 

EF86 Transfer from Belt F98 and 

F83 Silos to Belt F80 

Discharges to Baghouse F86 1976 

EF92 Transfer from Bucket 

Elevator F97 to Conveyor 

91, then to Clinker Silo F105 

Discharges to Baghouse F92-2 - 

EF92 

1976 

EF96 Transfer from Clinker Silo 

F105 to Feeders; Transfer 

from Gypsum/Clinker 

Feeders to Belt F98; then 

Belt F80 

Discharges to Baghouse F96-2 - 

EF96 

1976 

EBS802 Bulk Cement Silos, Loadout 

to Truck and Rail 

Discharges to Baghouse BS802 1976 

EBS814 Bulk Cement Silos, Loadout 

to Truck and Rail 

Discharges to Baghouse BS814 1976 

8. Gasoline Tank 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

EKNK3 One 3,000 gallon Gasoline 

Tank 

VOC Emissions Source 1992 

9. Cold Degreaser 

Emissions Unit 

Number Emissions Unit Name Emissions Unit Description Date of Installation 

ECD1 Cold Degreaser VOC Emissions Sources 1970 

SECTION II GENERAL CONDITIONS

1. DEFINITIONS 

[COMAR 26.11.01.01] and [COMAR 26.11.02.01]

 The words or terms in this Part 70 permit shall have the meanings established under COMAR 

26.11.01 and .02 unless otherwise stated in this permit. 

2. ACRONYMS 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 11 of 73 

 ARMA Air and Radiation Management Administration 

 BACT Best Available Control Technology 

 Btu British thermal unit 

 CAA Clean Air Act 

 CAM Compliance Assurance Monitoring 

 CEM Continuous Emissions Monitor 

 CFR Code of Federal Regulations 

 CO Carbon Monoxide 

 COMAR Code of Maryland Regulations 

 EPA United States Environmental Protection Agency 

 FR Federal Register 

 gr grains 

 HAP Hazardous Air Pollutant 

 MACT Maximum Achievable Control Technology 

 MDE Maryland Department of the Environment 

 MVAC Motor Vehicle Air Conditioner 

 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 

 SO2 Sulfur Dioxide 

 TAP Toxic Air Pollutant 

 tpy tons per year 

 VE Visible Emissions 

 VOC Volatile Organic Compounds 

3. EFFECTIVE DATE 

 The effective date of the conditions in this Part 70 permit is the date of permit issuance, 

unless otherwise stated in the permit. 

4. PERMIT EXPIRATION 

[COMAR 26.11.03.13B(2)]
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 12 of 73 

 Upon expiration of this permit, the terms of the permit will automatically continue to remain 

in effect until a new Part 70 permit is issued for this facility provided that the Permittee has 

submitted a timely and complete application and has paid applicable fees under COMAR 

26.11.02.16. 

 Otherwise, upon expiration of this permit the right of the Permittee to operate this facility is 

terminated. 

5. PERMIT RENEWAL 

[COMAR 26.11.03.02B(3)] and [COMAR 26.11.03.02E]

 The Permittee shall submit to the Department a completed 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 submit such supplementary facts 

or corrected information no later than 10 days after becoming aware that this occurred. The 

Permittee shall also provide additional information as necessary to address any requirements 

that become applicable to the facility after the date a completed 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. 

6. CONFIDENTIAL INFORMATION 

[COMAR 26.11.02.02G]

 In accordance with the provisions of the State Government Article, Sec. 10-611 et seq., 

Annotated Code of Maryland, all information submitted in an application shall be considered 

part of the public record and available for inspection and copying, unless the Permittee 

claims that the information is confidential when it is submitted to the Department. At the 

time of the request for inspection or copying, the Department will make a determination with 

regard to the confidentiality of the information. The Permittee, when requesting 

confidentiality, shall identify the information in a manner specified by the Department and, 

when requested by the Department, promptly provide specific reasons supporting the claim 

of confidentiality. Information submitted to the Department without a request that the 

information be deemed confidential may be made available to the public. Subject to 

approval of the Department, the Permittee may provide a summary of confidential 

information that is suitable for public review. The content of this Part 70 permit is not 

subject to confidential treatment. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 13 of 73 

7. PERMIT ACTIONS 

[COMAR 26.11.03.06E(3)] and [COMAR 26.11.03.20(A)]

 This Part 70 permit may be revoked or reopened and revised for cause. The filing of an 

application by the Permittee for a permit revision or renewal; or a notification of termination, 

planned changes or anticipated noncompliance by the facility, does not stay a term or 

condition of this permit. 

 The Department shall reopen and revise, or revoke the Permittee’s Part 70 permit under the 

following circumstances: 

a. Additional requirements of the Clean Air Act become applicable to this facility and the 

remaining permit term is 3 years or more; 

b. The Department or the EPA determines that this Part 70 permit contains a material 

mistake, or is based on false or inaccurate information supplied by or on behalf of the 

Permittee; 

c. The Department or the EPA determines that this Part 70 permit must be revised or 

revoked to assure compliance with applicable requirements of the Clean Air Act; or 

d. Additional requirements become applicable to an affected source under the Federal 

Acid Rain Program. 

8. PERMIT AVAILABILITY 

[COMAR 26.11.02.13G]

 The Permittee shall maintain this Part 70 permit in the vicinity of the facility for which it was 

issued, unless it is not practical to do so, and make this permit immediately available to 

officials of the Department upon request. 

9. REOPENING THE PART 70 PERMIT FOR CAUSE BY THE EPA 

[COMAR 26.11.03.20B]

 The EPA may terminate, modify, or revoke and reissue a permit for cause as prescribed in 40 

CFR §70.7(g) 

10. TRANSFER OF PERMIT 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 14 of 73 

[COMAR 26.11.02.02E]

 The Permittee shall not transfer this Part 70 permit except as provided in COMAR 

26.11.03.15. 

11. REVISION OF PART 70 PERMITS – GENERAL CONDITIONS 

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

a. The Permittee shall submit an application to the Department to revise this 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 include only information listed that is related to the proposed change to the source 

and revision to the permit. This information shall be sufficient to evaluate the proposed 

change and to determine whether it will comply with all applicable requirements of the 

Clean Air Act. 

c. The Permittee may not change any provision of a compliance plan or schedule in a Part 

70 permit as an administrative permit amendment or as a minor permit modification 

unless the change has been approved by the Department in writing. 

d. A permit revision is not required for a change that is provided for in this permit relating 

to approved economic incentives, marketable permits, emissions trading, and other 

similar programs. 

12. SIGNIFICANT PART 70 OPERATING PERMIT MODIFICATIONS 

[COMAR 26.11.03.17]

 The Permittee may apply to the Department to make a significant modification to its Part 70 

Permit as provided in COMAR 26.11.03.17 and in accordance with the following conditions: 

a. A significant modification is a revision to the federally enforceable provisions in the 

permit that does not qualify as an administrative permit amendment under COMAR 

26.11.03.15 or a minor permit modification as defined under COMAR 26.11.03.16. 

b. This permit does not preclude the Permittee from making changes, consistent with the 

provisions of COMAR 26.11.03, that would make the permit or particular terms and 

conditions of the permit irrelevant, such as by shutting down or reducing the level of 

operation of a source or of an emissions unit within the source. Air pollution control 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 15 of 73 

equipment shall not be shut down or its level of operation reduced if doing so would 

violate any term of this permit. 

c. Significant permit modifications are subject to all requirements of COMAR 26.11.03 as 

they apply to permit issuance and renewal, including the requirements for applications, 

public participation, and review by affected states and EPA, except: 

(1) An application need include only information pertaining to the proposed change 

to the source and modification of this permit, including a description of the 

change and modification, and any new applicable requirements of the Clean Air 

Act that will apply if the change occurs; 

(2) Public participation, and review by affected states and EPA, is limited to only the 

application and those federally enforceable terms and conditions of the Part 70 

permit that are affected by the significant permit modification. 

d. As provided in COMAR 26.11.03.15B(5), an administrative permit amendment may be 

used to make a change that would otherwise require a significant permit modification if 

procedures for enhanced preconstruction review of the change are followed that satisfy 

the requirements of 40 CFR 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 shall not make a significant permit modification that results in a violation 

of any applicable requirement of the Clean Air Act. 

g. The permit shield in COMAR 26.11.03.23 applies to a final significant permit 

modification that has been issued by the Department, to the extent applicable under 

COMAR 26.11.03.23. 

13. MINOR PERMIT MODIFICATIONS 

[COMAR 26.11.03.16]

 The Permittee may apply to the Department to make a minor modification to the federally 

enforceable provisions of this Part 70 permit as provided in COMAR 26.11.03.16 and in 

accordance with the following conditions: 

a. A minor permit modification is a Part 70 permit revision that: 

(1) Does not result in a violation of any applicable requirement of the Clean Air Act; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 16 of 73 

(2) Does not significantly revise existing federally enforceable monitoring, including 

test methods, reporting, record keeping, or compliance certification requirements 

except by: 

(a) Adding new requirements, 

(b) Eliminating the requirements if they are rendered meaningless because the 

emissions to which the requirements apply will no longer occur, or 

(c) Changing from one approved test method for a pollutant and source 

category to another; 

(3) Does not require or modify a: 

(a) Case-by-case determination of a federally enforceable emissions 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 emissions standard applied to the source pursuant to 

COMAR 26.11.02.03 to avoid classification as a Title I modification; and 

(b) An alternative emissions standard applied to an emissions unit pursuant to 

regulations promulgated under Section 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 shall submit to the Department an application for a minor permit 

modification that satisfies the requirements of COMAR 26.11.03.03 which includes the 

following: 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 17 of 73 

(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; 

(3) Certification by a responsible official, in accordance with COMAR 26.11.02.02F, 

that: 

(a) The proposed change meets the criteria for a minor permit modification, and 

(b) The Permittee has obtained or applied for all required permits-to-construct 

required by COMAR 26.11.03.16 with respect to the proposed change; 

(4) Completed forms for the Department to use to notify the EPA and affected states, 

as required by COMAR 26.11.03.07-.12. 

c. Permittee’s Ability to Make Change 

(1) For changes proposed as minor permit modifications to this permit that will 

require the applicant to obtain a permit to construct, the permit to construct must 

be issued prior to the new change. 

(2) During the period of time after the Permittee applies for a minor modification but 

before the Department acts in accordance with COMAR 26.11.03.16F(2): 

(a) The Permittee shall comply with applicable requirements of the Clean Air 

Act related to the change and the permit terms and conditions described in 

the application for the minor modification. 

(b) The Permittee is not required to comply with the terms and conditions in the 

permit it seeks to modify. If the Permittee fails to comply with the terms 

and conditions in the application during this time, the terms and conditions 

of both this permit and the application for modification may be enforced 

against it. 

d. The Permittee is subject to enforcement action if it is determined at any time that a 

change made under COMAR 26.11.03.16 is not within the scope of this regulation. 

e. Minor permit modification procedures may be used for Part 70 permit modifications 

involving the use of economic incentives, marketable permits, emissions trading, and 

other similar approaches, but only to the extent that the minor permit modification 

procedures are explicitly provided for in regulations approved by the EPA as part of the 

Maryland SIP or in other applicable requirements of the Clean Air Act. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 18 of 73 

14. ADMINISTRATIVE PART 70 OPERATING PERMIT AMENDMENTS 

[COMAR 26.11.02.15] 

 The Permittee may apply to the department to make an administrative permit amendment as 

provided in COMAR 26.11.03.15 and in accordance with the following conditions: 

a. An application for an administrative permit amendment shall: 

(1) Be in writing; 

(2) Include a statement certified by a responsible official that the proposed 

amendment meets the criteria in COMAR 26.11.03.15 for an administrative 

permit amendment, and 

(3) Identify those provisions of this part 70 permit for which the amendment is 

requested, including the basis for the request. 

b. An administrative permit amendment: 

(1) Is a correction of a typographical error; 

(2) Identifies a change in the name, address, or phone number of a person identified 

in this permit, or a similar administrative change involving the Permittee or other 

matters which are not directly related to the control of air pollution; 

(3) requires more frequent monitoring or reporting by the Permittee; 

(4) Allows for a change in ownership or operational control of a source for which the 

Department determines that no other revision to the permit is necessary and is 

documented as per COMAR 26.11.03.15B(4); 

(5) Incorporates into this permit the requirements from preconstruction review 

permits or approvals issued by the Department in accordance with COMAR 

26.11.03.15B(5), but only if it satisfies 40 CFR 70.7(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); 

(7) Notwithstanding COMAR 26.11.03.15B(1)—(6), all modifications to acid rain 

control provisions included in this Part 70 permit are governed by applicable 

requirements promulgated under Title IV of the Clean Air Act; or 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 19 of 73 

(8) Incorporates any change to a term or condition specified as State-only 

enforceable, if the Permittee has obtained all necessary permits-to-construct and 

approvals that apply to the change. 

c. The Permittee may make the change addressed in the application for an administrative 

amendment upon receipt by the Department of the application, if all permits-toconstruct or approvals otherwise required by COMAR 26.11.02 prior to making the 

change have first been obtained from the Department. 

d. The permit shield in COMAR 26.11.03.23 applies to administrative permit amendments 

made under Section B(5) of COMAR 26.11.03.15 , but only after the Department takes 

final action to revise the permit. 

e. The Permittee is subject to enforcement action if it is determined at any time that a 

change made under COMAR 26.11.03.15 is not within the scope of this regulation. 

15. OFF-PERMIT CHANGES TO THIS SOURCE 

 [COMAR 26.11.03.19]

 The Permittee may make off-permit changes to this facility as provided in COMAR 

26.11.03.19 and in accordance with the following conditions: 

a. The Permittee may make a change to this permitted facility that is not addressed or 

prohibited by the federally enforceable conditions of this Part 70 permit without 

obtaining a Part 70 permit revision if: 

(1) The Permittee has obtained all permits and approvals required by COMAR 

26.11.02 and .03; 

(2) The change is not subject any requirements under Title IV of the Clean Air Act; 

(3) The change is not a Title I modification; and 

(4) The change does not violate an applicable requirement of the Clean Air Act or a 

federally enforceable term or condition of the permit. 

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 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 20 of 73 

emitted, and any new applicable requirements of the Clean Air Act that apply as a 

result of the change. 

c. Upon satisfying the requirements of COMAR 26.11.03.19, the Permittee may make the 

proposed change. 

d. The Permittee shall keep a record describing: 

(1) Changes made at the facility that result in emissions of a regulated air pollutant 

subject to an applicable requirement of the Clean Air Act , but not otherwise 

regulated under this permit; and 

(2) The emissions resulting from those changes. 

e. Changes that qualify under COMAR 26.11.03.19 are not subject to the requirements for 

Part 70 revisions. 

f. The Permittee shall include each off-permit change under COMAR 26.11.03.19 in the 

application for renewal of the part 70 permit. 

g. The permit shield in COMAR 26.11.03.23 does not apply to off-permit changes made 

under COMAR 26.11.03.19. 

h. The Permittee is subject to enforcement action if it is determined that an off-permit 

change made under COMAR 26.11.03.19 is not within the scope of this regulation. 

16. ON-PERMIT CHANGES TO SOURCES 

[COMAR 26.11.03.18]

 The Permittee may make on-permit changes that are allowed under Section 502(b)(10) of the 

Clean Air Act as provided in COMAR 26.11.03.18 and in accordance with the following 

conditions: 

a. The Permittee may make a change to this facility without obtaining a revision to this 

Part 70 permit if: 

(1) The change is not a Title I modification; 

(2) The change does not result in emissions in excess of those expressly allowed 

under the federally enforceable provisions of the 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; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 21 of 73 

(3) The Permittee has obtained all permits and approvals required by COMAR 

26.11.02 and .03; 

(4) The change does not violate an applicable requirement of the Clean Air Act; 

(5) The change does not violate a federally enforceable permit term or condition 

related to monitoring, including test methods, record keeping, reporting, or 

compliance certification requirements; 

(6) The change does not violate a federally enforceable permit term or condition 

limiting hours of operation, work practices, fuel usage, raw material usage, or 

production levels if the term or condition has been established to limit emissions 

allowable under this permit; 

(7) If applicable, the change does not modify a federally enforceable provision of a 

compliance plan or schedule in this Part 70 permit unless the Department has 

approved the change in writing; and 

(8) This permit does not expressly prohibit the change under COMAR 26.11.03.18. 

b. The Permittee shall notify the Department and the EPA in writing of a proposed onpermit change under COMAR 26.11.03.18 not later than 7 days before the change is 

made. The written information shall include the following information: 

(1) A description of the proposed change; 

(2) The date on which the change is proposed to be made; 

(3) Any change in emissions resulting from the change, including the pollutants 

emitted; 

(4) Any new applicable requirement of the Clean Air Act; and 

(5) Any permit term or condition that would no longer apply. 

c. The responsible official of this facility shall certify in accordance with COMAR 

26.11.02.02F that the proposed change meets the criteria for the use of on-permit 

changes under COMAR 26.11.03.18. 

d. The Permittee shall attach a copy of each notice required by condition b. above to this 

Part 70 permit. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 22 of 73 

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 an on-permit 

change made under COMAR 26.11.03.18 is not within the scope of the regulation or 

violates any requirement of the State air pollution control law. 

17. FEE PAYMENT 

[COMAR 26.11.02.16A(2) & (5)(b)]

a. The fee for this Part 70 permit is as prescribed in Regulation .19 of COMAR 26.11.02. 

b. The fee is due on and shall be paid on or before each 12-month anniversary date of the 

permit. 

c. Failure to pay the annual permit fee constitutes cause for revocation of the permit by 

the Department. 

18. REQUIREMENTS FOR PERMITS TO CONSTRUCT AND APPROVALS 

[COMAR 26.11.02.09]

The Permittee may not construct or modify or cause to be constructed or modified any of the 

following sources without first obtaining, and having in current effect, the specified permitsto-construct and approvals: 

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; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 23 of 73 

d. National Emission Standards for Hazardous Air Pollutants source, as defined in COMAR 

26.11.01.01, permit to construct; 

e. A stationary source of lead that discharges one ton per year or more of lead or lead 

compounds measured as elemental lead, permit to construct; 

f. All stationary sources of air pollution, including installations and air pollution control 

equipment, except as listed in COMAR 26.11.02.10, permit to construct; 

g. In the event of a conflict between the applicability of (a.— e.) above and an exemption 

listed in COMAR 26.11.02.10, the provision that requires a permit applies. 

h. Approval of a PSD or NSR source by the Department does not relieve the Permittee 

obtaining an approval from also obtaining all permits-to-construct required b y (c.— g.) 

above. 

19. CONSOLIDATION OF PROCEDURES FOR PUBLIC PARTICIPATION 

[COMAR 26.11.02.11C] and [COMAR 26.11.03.01K]

 The Permittee may request the Department to authorize special procedures for the Permittee 

to apply simultaneously, to the extent possible, for a permit to construct and a revision to this 

permit. 

 These procedures may provide for combined public notices, informational meetings, and 

public hearings for both permits but shall not adversely affect the rights of a person, 

including EPA and affected states, to obtain information about the application for a permit, to 

comment on an application, or to challenge a permit that is issued. 

 These procedures shall not alter any existing permit procedures or time frames. 

20. PROPERTY RIGHTS 

[COMAR 26.11.03.06E(4)]

 This Part 70 permit does not convey any property rights of any sort, or any exclusive 

privileges. 

21. SEVERABILITY 

[COMAR 26.11.03.06A(5)]
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 24 of 73 

 If any portion of this Part 70 permit is challenged, or any term or condition deemed 

unenforceable, the remainder of the requirements of the permit continues to be valid. 

22. INSPECTION AND ENTRY 

[COMAR 26.11.03.06G(3)]

 The Permittee shall allow employees and authorized representatives of the Department, the 

EPA, and local environmental health agencies, upon presentation of credentials or other 

documents as may be required by law, to: 

a. Enter at a reasonable time without delay and without prior notification the Permittee’s 

property where a Part 70 source is located, emissions-related activity is conducted, or 

records required by this permit are kept; 

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

c. Inspect all emissions units within the facility subject to the permit and all related 

monitoring systems, air pollution control equipment, and practices or operations 

regulated or required by the permit; and 

d. Sample or monitor any substances or parameters at or related to the emissions units at 

the facility for the purpose of determining compliance with the permit. 

23. DUTY TO PROVIDE INFORMATION 

[COMAR 26.11.03.06E(5)]

 The Permittee shall furnish to the Department, within a reasonable time specified by the 

Department, information requested in writing by the Department in order to determine 

whether the Permittee is in compliance with the federally enforceable conditions of this Part 

70 permit, or whether cause exists for revising or revoking the permit. Upon request, the 

Permittee shall also furnish to the Department records required to be kept under the permit. 

 For information claimed by the Permittee to be confidential and therefore potentially not 

discloseable to the public, the Department may require the Permittee to provide a copy of the 

records directly to the EPA along with a claim of confidentiality. 

 The Permittee shall also furnish to the Department, within a reasonable time specified by the 

Department, information or records requested in writing by the Department in order to 

determine if the Permittee is in compliance with the State-only enforceable conditions of this 

permit. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 25 of 73 

24. COMPLIANCE REQUIREMENTS 

[COMAR 26.11.03.06E(1)], [COMAR 26.11.03.06A(11)] and [COMAR 26.11.02.05]

 The Permittee shall comply with the conditions of this Part 70 permit. Noncompliance with 

the permit constitutes a violation of the Clean Air Act, and/or the Environmental Article Title 

2 of the Annotated Code of Maryland and may subject the Permittee to: 

a. Enforcement action, 

b. Permit revocation or revision, 

c. Denial of the renewal of a Part 70 permit, or 

d. Any combination of these actions. 

 The conditions in this Part 70 permit are enforceable by EPA and citizens under the Clean 

Air Act except for the State-only enforceable conditions. 

 Under Environmental Article Section 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. 

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]
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 26 of 73 

 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 emissions which would otherwise constitute a violation of any applicable air pollution 

control regulation. 

28. PERMIT SHIELD 

[COMAR 26.11.03.23]

 A permit shield as described in COMAR 26.11.03.23 shall apply only 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 Section 303 of the Clean Air Act, including the 

authority of EPA under that section; 

b. The liability of the Permittee for a violation of an applicable requirement of the Clean 

Air Act before or when this permit is issued or for a violation that continues after 

issuance; 

c. The requirements of the Acid Rain Program, consistent with Section 408(a) of the 

Clean Air Act; 

d. The ability of the Department or EPA to obtain information from a source pursuant to 

Maryland law and Section 114 of the Clean Air Act; or 

e. The authority of the Department to enforce an applicable requirement of the State air 

pollution control law that is not an applicable requirement of the Clean Air Act. 

29. ALTERNATE OPERATING SCENARIOS 

[COMAR 26.11.03.06A(9)]

 For all alternate operating scenarios approved by the Department and contained within this 

permit, the Permittee, while changing from one approved scenario to another, shall 

contemporaneously record in a log maintained at the facility each scenario under which the 

emissions unit is operating and the date and time the scenario started and ended. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 27 of 73 

SECTION III PLANT WIDE CONDITIONS

1. PARTICULATE MATTER FROM CONSTRUCTION AND DEMOLITION 

[COMAR 26.11.06.03D]

 The Permittee shall not cause or permit any building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

2. OPEN BURNING 

[COMAR 26.11.07]

 Except as provided in COMAR 26.11.07.04, the Permittee shall not cause or permit an open 

fire from June 1 through August 31 of any calendar year. Prior to any open burning, the 

Permittee shall request and receive approval from the Department. 

3. AIR POLLUTION EPISODE 

[COMAR 26.11.05.04]

 When requested by the Department, the Permittee shall prepare in writing standby emissions 

reduction plans, consistent with good industrial practice and safe operating procedures, for 

reducing emissions creating air pollution during periods of Alert, Warning, and Emergency 

of an air pollution episode. 

4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS 

[COMAR 26.11.01.07] and [COMAR 26.11.03.06C(7)]

 The Permittee shall comply with the following conditions for occurrences of excess 

emissions and deviations from requirements of this permit, including those in Section VI – 

State-only Enforceable Conditions: 

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; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 28 of 73 

b. Promptly report all occurrences of excess emissions that are expected to last for one 

hour or longer by orally notifying the Department of the onset and termination of the 

occurrence; 

c. When requested by the Department the Permittee shall report all deviations from permit 

conditions, including those attributed to malfunctions as defined in COMAR 

26.11.01.07A, within 5 days of the request by submitting a written description of the 

deviation to the Department. The written report shall include the cause, dates and times 

of the onset and termination of the deviation, and an account of all actions planned or 

taken to reduce, eliminate, and prevent recurrence of the deviation; 

d. The Permittee shall submit to the Department semi-annual monitoring reports that 

confirm that all required monitoring was performed, and that provide accounts of all 

deviations from permit requirements that occurred during the reporting periods. 

Reporting periods shall be January 1 through June 30 and July 1 through December 31, 

and reports shall be submitted within 30 days of the end of each reporting period. Each 

account of deviation shall include a description of the deviation, the dates and times of 

onset and termination, identification of the person who observed or discovered the 

deviation, causes and corrective actions taken, and actions taken to prevent recurrence. 

If no deviations from permit conditions occurred during a reporting period, the 

Permittee shall submit a written report that so states; and 

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. 

 The Permittee shall initiate a permit revision or reopening according to the procedures of 40 

CFR Part 70.7 to incorporate appropriate permit conditions into the Permittee’s Part 70 

permit. 

6. GENERAL TESTING REQUIREMENTS 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 29 of 73 

[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 shall be provided to the Department. 

7. EMISSIONS TEST METHODS 

[COMAR 26.11.01.05]

 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 60, appendix A 

b. 40 CFR 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 [COMAR 26.11.01.05-1]

 The Permittee shall certify actual annual emissions of regulated pollutants from the facility 

on a calendar year basis. 

a. The certification shall be on forms 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 certifications forms are submitted, and 

(2) Responsible for the accuracy of the emissions information; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 30 of 73 

c. The Permittee shall maintain records necessary to support the emissions certification 

including the following information if applicable: 

(1) The total amount of actual emissions of each regulated pollutant and the total of 

all regulated pollutants; 

(2) An explanation of the methods used to quantify the emissions and the operating 

schedules and production data that were used to determine emissions, including 

significant assumptions made; 

(3) Amounts, types and analyses of all fuels used; 

(4) Emissions data from continuous emissions monitors that are required by this 

permit, including monitor calibration and malfunction information; 

(5) Identification, description, and use records of all air pollution control equipment 

and compliance monitoring equipment including: 

(a) Significant maintenance performed, 

(b) Malfunctions and downtime, and 

(c) Episodes of reduced efficiency of all equipment; 

(6) Limitations on source operation or any work practice standards that significantly 

affect emissions; and 

(7) Other relevant information as required by the Department. 

9. COMPLIANCE CERTIFICATION REPORT 

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

The Permittee shall submit to the Department and EPA Region III a report certifying 

compliance with each term of this Part 70 permit including each applicable standard, 

emissions limitation, and work practice for the previous calendar year by April 1 of each 

year. 

a. The compliance certification shall include: 

(1) The identification of each term or condition of this permit which is the basis of 

the certification; 

(2) The compliance status; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 31 of 73 

(3) Whether the compliance was continuous or intermittent; 

(4) The methods used for determining the compliance status of each source, currently 

and over the reporting period; and 

(5) Any other information required to be reported to the Department that is necessary 

to determine the compliance status of the Permittee with this permit. 

b. The Permittee shall submit the compliance certification reports to the Department and 

EPA simultaneously. 

10. CERTIFICATION BY RESPONSIBLE OFFICIAL 

[COMAR 26.11.02.02F]

 All application forms, reports, and compliance certifications submitted pursuant to this 

permit shall be certified by a responsible official as to truth, accuracy, and completeness. 

The Permittee shall expeditiously notify the Department of an appointment of a new 

responsible official. 

 The certification shall be in the following form: 

 “I certify under penalty of law that this document and all attachments were prepared under 

my direction or supervision in accordance with a system designed to assure that qualified 

personnel properly gather and evaluate the information submitted. Based on my inquiry of 

the person or persons who manage the system, or those persons directly responsible for 

gathering the information, the information submitted is, to the best of my knowledge and 

belief, true, accurate, and complete. I am aware that there are significant penalties for 

submitting false information, including the possibility of fine and imprisonment for knowing 

violations.” 

11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING 

[COMAR 26.11.03.06C(5)]

 The Permittee shall gather and retain the following information when sampling and testing 

for compliance demonstrations: 

a. The location as specified in this permit, and the date and time that samples and 

measurements are taken; 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 32 of 73 

b. All pertinent operating conditions existing at the time that samples and measurements 

are taken; 

c. The date that each analysis of a sample or emissions test is performed and the name of 

he person taking the sample or performing the emissions test; 

d. The identity of the Permittee, individual, or other entity that performed the analysis; 

e. The analytical techniques and methods used; and 

f. The results of each analysis. 

12. GENERAL RECORDKEEPING 

[COMAR 26.11.03.06C(5) and (6)]

 The Permittee shall retain records of all monitoring data and information that support the 

compliance certification for a period of five (5) 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; 

c. Records which support the annual emissions certification; and 

d. Copies of all reports required by this permit. 

13. GENERAL CONFORMITY 

[COMAR 26.11.26.09]

 The Permittee shall comply with the general conformity requirements of 40 CFR 93, Subpart 

B and COMAR 26.11.26.09. 

14. ASBESTOS PROVISIONS 

[40 CFR Part 61, Subpart M]
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 33 of 73 

 The Permittee shall comply with 40 CFR Part 61, Subpart M when conducting any 

renovation or demolition activities at the facility. 

15. OZONE DEPLETING REGULATIONS 

[40 CFR 82, Subpart F]

 The Permittee shall comply with the standards for recycling and emissions reduction 

pursuant to 40 CFR 82, Subpart F, except as provided for MVACs in subpart B: 

a. Persons opening appliances for maintenance, service, repair, or disposal shall comply 

with the prohibitions and required practices pursuant to 40 CFR §82.154 and §82.156. 

b. Equipment used during the maintenance, service, repair or disposal of appliances shall 

comply with the standards for recycling and recovery equipment pursuant to 40 CFR 

§82.158. 

c. Persons performing maintenance, service, repairs or disposal of appliances shall be 

certified by an approved technician certification program pursuant to 40 CFR §82.161. 

d. Persons performing maintenance, service, repairs or disposal of appliances shall certify 

with the Administrator pursuant to 40 CFR §82.162. 

e. Persons disposing of small appliances, MVACS, and MVAC-like appliances as defined 

in 40 CFR 82.152, shall comply with record keeping requirements pursuant to 40 CFR 

§82.166. 

f. Persons owning commercial or industrial process refrigeration equipment shall comply 

with the leak repair requirements pursuant to 40 CFR §82.156. 

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

shall keep records of refrigerant purchased and added to such appliances pursuant to 40 

CFR §82.166. 

16. ACID RAIN PERMIT 

 Not applicable 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 34 of 73 

SECTION IV PLANT SPECIFIC CONDITIONS

This section is comprises of tables containing the emissions standards, emissions limitations, and 

work practices applicable to each emissions unit located at this facility. The Permittee shall 

comply with all applicable emissions standards, emissions limitations and work practices 

included herein. 

These tables also list testing, monitoring, record keeping and reporting requirements specific to 

each emissions unit. In addition to the requirements included here in Section IV, the Permittee 

is also subject to the general testing, monitoring, record keeping and reporting requirements 

included in Section III–Plant-Wide Conditions of this permit. 

1A. Quarry- Fugitive Sources - Registration # 7-0108 

The following equipment were installed or modified prior to August 31, 1983.

1A Emissions Unit Number(s)

EADRL1 Quarry drilling 

EARMH1 Quarry raw material handling 

EARMH2 Transfer from Outside Surge Stone Pile and Front End Loader to Stone 

Hopper Q28; from Stone Hopper Q28 to Feeder Q28.1; from Feeder Q28.1 to 

Belt Q27 

EARMH3 Raw Material Stockpile Truck Unloading onto Piles; to Raw Material Bins 

and Solid Fuel Bins 

EAROAD1 Quarry haul roads 

EAROAD2 Raw Material (Coal, Slag, GAF, Sand, Iron) Haul Road; CKD Haul Trucks to 

CKD Pile; Truck Traffic from Bulk Silos and Pack house 

EASTP1 Outside Surge Stone Pile Wind Erosion 

EASTP2 Raw Material (Coal, Slag, GAF, Sand, Iron) Stone Pile Wind Erosion 

EAQ1 Pan Feeder Q1 

EAQ2 Primary Crusher Q2 

EAQ3 Transfer from Belt Q3 to Belt Q4 

1 Applicable Standards/Limits:

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

permit emissions from an unconfined source without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

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

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

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

demolished without taking reasonable precautions to prevent particulate matter from 

becoming airborne. 

 Testing Requirements:

 None 

 Monitoring Requirements:
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 35 of 73 

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. 

[COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each 

emissions unit to verify that reasonable precautions are being implemented and to determine 

whether the reasonable precautions need to be revised. The inspection shall be conducted at 

a minimum of once per month at times when the effectiveness of the reasonable precautions 

can be assessed. 

[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. 

[COMAR 26.11.03.06C] 

 Reporting Requirements:

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in 

the table above. 

1B. Quarry - Registration # 7-0108 - Fugitive Emissions Sources (Subject to 40 CFR 

Part 60 Subpart OOO): 

The following equipment were installed or modified after August 31, 1983. 

1B Emissions Unit Number(s)

EAQ21 Transfer from Stack Conveyor Q21 to Outside Surge Stone Pile EASTP1 

EAQ23 Transfer from Belt Q23 to Stacker/Conveyor Q25 

EAQ25 Transfer from Stack/Conveyor Q25 to Indoor Pile 

EAQ27 Conveyor Q27 Transfer Points 

EAQ28 Stone Hopper Q28 and Feeder Q28.1 

EARMH4 EARMH4-Dome 

1 Applicable Standards/Limits: 

A. Visible Emissions 

(1) 40 CFR §60.672(b) - A person may not cause to be discharged into the atmosphere 

from any transfer point on belt conveyors or from other affected facility any fugitive 

emissions which exhibit greater than 10 percent opacity except, as provided in 

paragraphs (c), (d) and (e) of this section. 

(2) 40 CFR §60.672(e)(1) - A person may not cause to be discharged into the 

atmosphere from any building enclosing transfer point on a conveyor belt or any 

other affected facility any visible fugitive emissions except emissions from a vent as 

defined in 40 CFR §60.671.

B. Particulate Matter 

(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. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 36 of 73 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable precautions 

to prevent particulate matter from becoming airborne. 

 Testing Requirements:

 None 

 Monitoring Requirements:

A. The Permittee will conduct a walk-through inspection of the facility once per calendar 

month. Fugitive emission sources inside buildings will be evaluated at the door(s) of the 

building. A visible emission evaluation will be performed on the exhaust of each 

operating source, using EPA Reference Method 22 for one-minute period. If no visible 

emissions are observed, such conditions will be noted in the inspection log. If visible 

emissions are observed, the Permittee shall immediately inspect and/or repair the 

emissions unit and related equipment until no visible emissions are observed based on 

EPA Reference Method 22. If visible emissions are still observed, the Permittee will 

immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 10 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 10 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 10 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[COMAR 26.11.03.06C] 

B. 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 Permittee shall perform a walk through inspection of the facility to observe each 

emissions unit to verify that reasonable precautions are being implemented and to 

determine whether the reasonable precautions need to be revised. The inspection shall 

be conducted at a minimum of once per month at times when the effectiveness of the 

reasonable precautions can be assessed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements: 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 37 of 73 

A. The Permittee shall maintain records of the results of the monthly inspections and the 

log of inspection and maintenance for at least five (5) years and make them available to 

the Department upon request 

[COMAR 26.11.03.06C] 

B. 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. 

[COMAR 26.11.03.06C] 

 Reporting Requirements: 

None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in 

the table above. 

1C. Quarry - Registration # 7-0108 - Point Sources (Not Subject to NSPS Subpart 

OOO): 

The following equipment were installed or modified prior to August 31, 1983.

1C Emission Unit Number(s)

EAQ11 EAQ4 -Transfer from Belt Q4 to Pan Feeder Q6-1 and Belt 5 

EAQ11 EAQ7 -Transfer from Belt Q5 to Screen Q7 

EAQ11 EAQ7 -A -Transfer from Screen Q7 to Belt 10 

EAQ11 EAQ9 -Transfer from Screen Q7 to Secondary Crusher Q9 

EAQ11 EAQ10 -Transfer from Belt Q10 to Flop Gate Q19 

1 Applicable Standards/Limits

A. Visible Emissions 

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- 

minute period. 

[COMAR 26.11.06.02A(2)]

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

 COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate exceeds 

60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 38 of 73 

For those processes in which the process weight per hour exceeds 60,000 pounds, the 

maximum allowable weight of particulate matter discharged per hour may exceed that 

calculated by the above equation provided that the concentration of particulate matter in 

the gases discharged to the atmosphere is less than 0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)]

 Testing Requirements

 None 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar 

month. A visible emission evaluation will be performed on the exhaust of each 

operating source, using EPA Reference Method 22 for one-minute period. If no visible 

emissions are observed, such conditions will be noted in the inspection log. If visible 

emissions are observed, the Permittee shall immediately inspect and/or repair the 

emissions unit and related equipment until no visible emissions are observed based on 

EPA Reference Method 22. If visible emissions are still observed, the Permittee will 

immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[COMAR 26.11.03.06C] 

B. The Permittee shall develop and update as needed a preventative maintenance plan for 

each dust collector that describes the maintenance activity and time schedule for 

completing each activity. The Permittee shall perform maintenance activities within the 

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

maintenance was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log 

of inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 39 of 73 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the dates and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C]

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

2A. Raw Mill System - Registration # 7-0110- Fugitive Emissions (Not Subject to NSPS 

OOO) 

The following equipment were installed or modified prior to August 17, 1971.

2A Emission Unit Number(s)

EAR8 Transfer from Belt Conveyor R8 to Belt conveyor R11-1 

EAR11 Conveyor R11-1 

EAR14 Transfer from Belt Q27 to Belt conveyor R14; from Belt conveyor R14 to 

Belt conveyor R16 

ER32 Transfer from Raw Mill Bins to Feeders; Transfer from Feeders to Belt 

conveyor R32 

ER36 Transfer from Crossover Stone Belt to Masonry/Slag Tank 

 Applicable Standards/Limits

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

permit emissions from an unconfined source without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

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

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

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

demolished without taking reasonable precautions to prevent particulate matter from 

becoming airborne.

 Testing Requirements

 None 

 Monitoring Requirements

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

describes the procedures and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each 

emissions unit to verify that reasonable precautions are being implemented and to determine 

whether the reasonable precautions need to be revised. The inspection shall be conducted at 

a minimum of once per month at times when the effectiveness of the reasonable precautions 

can be assessed. 

[COMAR 26.11.03.06C] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 40 of 73 

 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. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

2B. Raw Mill System - Registration # 7-0110- Point Sources (Not Subject to NSPS): 

The following equipment were installed or modified prior to August 17, 1971.

2B Emission Unit Number(s)

EAR13 ER13 -Transfer from Belt R11-1 to Flop Gate R11-3; from Flop Gate R11-3 

to Crusher R12-1 and Belt R14; and Transfer from Crusher R12-1 to Belt 

R12-4 and then R14 

ER17 ER17 -Transfer from Raw Mill Tripper R16 to Raw Mill Feed Bins R20-1

thru –5 

ER45 ER45 -Transfer from Belt conveyor R32 to Raw Mill R37 and Raw Miller 

Air Separator R43 

ER50 ER50 -Transfer from Air Slides to Blending Silos R60-1 thru -3 

EKB3 EKB3 -Transfer from Blending Silos R60-1 thru -3 to Air Slides (EKB1A, 

EKB1B, EKB1C, EKB1D, EKB1E, and EKB1F) 

 Applicable Standards/Limits

A. Visible Emissions 

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 

60- minute period. 

[COMAR 26.11.06.02A(2)]

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate 

exceeds 60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 41 of 73 

maximum allowable weight of particulate matter discharged per hour may exceed that 

calculated by the above equation provided that the concentration of particulate matter 

in the gases discharged to the atmosphere is less than 0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)]

 Testing Requirements

 None 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar 

month. A visible emission evaluation will be performed on the exhaust of each 

operating source, using EPA Reference Method 22 for one-minute period. If no visible 

emissions are observed, such conditions will be noted in the inspection log. If visible 

emissions are observed, the Permittee shall immediately inspect and/or repair the 

emissions unit and related equipment until no visible emissions are observed based on 

EPA Reference Method 22. If visible emissions are still observed, the Permittee will 

immediately undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

measures shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[COMAR 26.11.03.06C] 

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

dust collector that describes the maintenance activity and time schedule for completing 

each activity. The Permittee shall perform maintenance activities within the timeframes 

established in the plan and shall maintain a log with records of the date maintenance was 

performed. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log 

of inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 

[COMAR 26.11.03.06C] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 42 of 73 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the date and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

2C. Raw Mill and Raw Mill Heater - Registration # 7-0110- Point Sources (Not Subject 

to NSPS): 

The following equipment were installed or modified prior to August 17, 1971.

2C Emission Unit Number(s)

ER38 ER38 -Raw Mill R37 and Discharge from Raw Mill R37 to Bucket 

Elevator R41 

ER38 ER39 -Raw Mill heater R39 

 Applicable Standards/Limits

A. Visible Emissions 

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- 

minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate exceeds 

60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the 

maximum allowable weight of particulate matter discharged per hour may exceed that 

calculated by the above equation provided that the concentration of particulate matter in 

the gases discharged to the atmosphere is less than 0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 43 of 73 

 Testing Requirements

 None 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per week. A 

visible emission evaluation will be performed on the exhaust of each operating source, 

using EPA Reference Method 22 for one-minute period. If no visible emissions are 

observed, such conditions will be noted in the inspection log. If visible emissions are 

observed, the Permittee shall immediately inspect and/or repair the emissions unit and 

related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately 

undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this weekly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this weekly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[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 limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C]

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

dust collector that describes the maintenance activity and time schedule for completing 

each activity. The Permittee shall perform maintenance activities within the timeframes 

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

was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the weekly observations and the log 

of inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 

[COMAR 26.11.03.06C] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 44 of 73 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the dates and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

3A. Coal and Alternative Fuel Handling - Registration # 7-0108- Fugitive Emissions 

(Not Subject to NSPS) 

The following equipment were installed or modified prior to October 24, 1974. 

3A Emission Unit Number(s)

EASTP2 Coal storage pile (See Quarry Section) 

EAC1 Solid fuel bins C1-1 & C1-2 

EAC2 Vibratory Feeders C2-1 & C2-2 

EAC3 Coal Crusher 

EAC4 Belt Conveyor C4 

EAC7 Weigh Feeder C7-1 

EAC10 Coal Silo C10 

EAC19 I-Bin C19 

 Applicable Standards/Limits

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

permit emissions from an unconfined source without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

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

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

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

demolished without taking reasonable precautions to prevent particulate matter from 

becoming airborne. 

 Testing Requirements

 None 

 Monitoring Requirements

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

describes the procedures and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each 

emissions unit to verify that reasonable precautions are being implemented and to determine 

whether the reasonable precautions need to be revised. The inspection shall be conducted at 

a minimum of once per month at times when the effectiveness of the reasonable precautions 

can be assessed. 

[COMAR 26.11.03.06C] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 45 of 73 

 Record Keeping Requirements

The Permittee shall maintain records of the results of the monthly inspections and the log of 

inspection and maintenance for at least five (5) years and make them available to the 

Department upon request. 

[COMAR 26.11.03.06C]

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

3B. Coal and Alternative Fuel Handling - Registration # 7-0108- Point Sources (Not 

Subject to NSPS) 

The coal mill was installed in 1970.

3B Emission Unit Number(s)

EC15 EC15 -Coal Mill C8-1 and Cyclone C14 controlled by dust collector C15 

 Applicable Standards/Limits

A. Visible Emissions 

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 

60- minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate exceeds 

60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the 

maximum allowable weight of particulate matter discharged per hour may exceed that 

calculated by the above equation provided that the concentration of particulate matter in 

the gases discharged to the atmosphere is less than 0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)]

 Testing Requirements

 None 

 Monitoring Requirements
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 46 of 73 

A. The Permittee will conduct a walk-through inspection of the facility once per calendar 

month. A visible emission evaluation will be performed on the exhaust of each operating 

source, using EPA Reference Method 22 for one-minute period. If no visible emissions 

are observed, such conditions will be noted in the inspection log. If visible emissions are 

observed, the Permittee shall immediately inspect and/or repair the emissions unit and 

related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately 

undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[COMAR 26.11.03.06C] 

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

dust collector that describes the maintenance activity and time schedule for completing 

each activity. The Permittee shall perform maintenance activities within the timeframes 

established in the plan and shall maintain a log with records of the date maintenance was 

performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log 

of inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the dates and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C]

 Reporting Requirements
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 47 of 73 

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

4. Kiln System - Registration #7-0109 (Subject to MACT Requirements) 

The kiln was installed in 1970. 

4 Emission Unit Number(s)

KB13 Kiln 

 Applicable Standards/Limits

A. Visible Emissions 

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- 

minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate exceeds 

60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the 

maximum allowable weight of particulate matter discharged per hour may exceed that 

calculated by the above equation provided that the concentration of particulate matter in 

the gases discharged to the atmosphere is less than 0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

C. Dioxins/Furans (D/F) 

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

(1) 0.2 ng per dscm (8.7 X 10 –11 gr per dscf)(TEQ) corrected to seven 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 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 48 of 73 

(1) COMAR 26.11.09.08H(2)(a) which limits NOx emissions to 1,000 pounds per 

hour on a 30-day rolling average. 

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

cement manufacturing facility to either meet the applicable emissions 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. 

E. SOx Emissions 

(1) COMAR 26.11.06.05B(1) which limits the sulfur dioxide concentration in the 

exhaust gases not to exceed 2000 parts per million by volume corrected to 7 

percent oxygen. 

(2) COMAR 26.11.06.05B(2) which limits the content of sulfuric acid, sulfur trioxide, 

or any combination not to exceed 70 milligrams reported as sulfuric acid per cubic 

meter of gas corrected to 7 percent oxygen. 

F. When burning scrap tires as an alternate fuel in the kiln, the Permittee shall not allow: 

(1) the feed rate of scrap tires to exceed 3.8 tons per hour; and 

(2) the temperature between the preheating and calcining zones of the kiln to fall 

below 1,400o

F. 

[Permit to Construct 043-7-0109M issued on November 21, 2002]

 Testing Requirements

A, D, E, and F None 

B. The Permittee shall conduct a particulate matter emissions test at once every 5 years in 

accordance with 40 CFR 60.64 and Method 5 of 40 CFR Part 60, Appendix A. Each 

performance test shall consist of three separate runs under the conditions that the kiln 

operates at least 90% of maximum allowable process rate. 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. 

[COMAR 26.11.03.06C] 

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

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

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

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

under representative performance conditions in accordance with 40 CFR Part 63, 

Subpart LLL. The duration of each run shall be at least three hours and the sample 

volume for each run shall be at least 2.5 dscm (90 dscf). The concentration shall be 

determined for each run and the arithmetic average of the concentrations measured 

for the three runs shall be calculated and used to determine compliance. 

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

continuously recorded during the period of the Method 23 test, and the continuous 

temperature record(s) must be included in the performance test report. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 49 of 73 

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

of the test. 

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

the run average temperatures must be determined and included in the performance 

test report and will determine the applicable temperature limit in accordance with 

§63.1344(b). 

[40 CFR §63.1349(b)(3) and (d)] 

 Monitoring Requirements

A. The Permittee, in accordance with COMAR 26.11.01.10B, shall continuously monitor 

opacity of the stack gases using a continuous opacity monitor that is certified in 

accordance with 40 CFR Part 60, Appendix B and meets the quality assurance criteria of 

the Department’s air Management Administration Technical Memorandum 90-01 

“Continuous Emission Monitoring (CEM) Policies and Procedures” (October 1990) 

which is incorporated by reference. 

[COMAR 26.11.01.11A]

A and B. 

(1) The Permittee shall record the daily production rates and kiln feed rates. 

(2) 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] 

A, B, and C. 

(1) The Permittee shall inspect daily the operation of the Linkman process control and 

the kiln air pollution control equipment, including the electrostatic precipitator 

(ESP), and shall keep the equipment properly maintained and in good working 

order so as to ensure full and continuous compliance with all applicable 

regulations. The daily inspection shall include an examination of the ESP 

operational data. 

[Permit to Construct 043-7-0109M issued on November 21, 2002] 

(2) The Permittee shall not feed tires to the kiln during periods of start-up, shut-down, 

or when the ESP is not functioning properly. 

[Permit to Construct 043-7-0109M issued on November 21, 2002] 

C1. The Permittee shall comply with and update the written operations and maintenance 

plan, which includes the following information: 

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

pollution control devices in order to meet the emissions limits and operating limits 

of §63.1344; 

(2) Corrective actions to be taken when required by §63.1350(e); and 

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

system of each kiln and each in-line kiln located at the facility at least once per 

year. 

[40 CFR §63.1350(a) and (b)] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 50 of 73 

C2. 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)] 

C3. The Permittee shall calibrate, maintain, and continuously operate a continuous monitor 

to record the temperature of the exhaust gases from the kiln and the in-line kiln/raw mill, 

if applicable, at the inlet to or upstream of the PM control devices. 

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

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

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

calibrated reference thermocouple-potentiometer system or alternate reference, 

subject to approval by the Administrator. 

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

180 successive one-minute average temperatures. 

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

when calculating three-hour rolling averages. When one-minute averages become 

available, the first one-minute average is added to the previous 179 values to 

calculate the three-hour rolling average. 

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

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

temperature must begin anew, without considering previous recordings. 

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

verified at least once every three months. 

[40 CFR §63.1350(f)] 

D and E. 

(1) The Permittee shall use a continuous emissions monitoring system (CEM) to 

monitor NOx and SO2 emissions from the main exhaust stack. The Permittee shall 

install, operate, maintain, and calibrate the CEM in accordance with the 

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

Assurance Procedures under 40 CFR Part 60, Appendix F, and MDE’s Technical 

Memorandum TM-90-01. 

[COMAR 26.11.09.08H(1)] 

(2). 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 emissions standard. 

[COMAR 26.11.01.11D(3)] 

F. None 

 Record Keeping Requirements

A, B, D, E, and F 

The Permittee shall maintain all records collected from both testing and/or 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 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 51 of 73 

offsite. The files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche. 

[COMAR 26.11.03.06C] 

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] 

 Reporting Requirements

A, D, and E 

 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 emissions 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 emissions 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 COMAR 26.11.01.10G(2)(d)] 

B. (1) The Permittee shall submit the results of performance tests before the close of 

business on the 60th day following the completion of the performance test. 

(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. 

[COMAR 26.11.03.06C] 

C. (1) The Permittee shall submit the results of performance tests before the close of 

business on the 60th day following the completion of the performance test. 

[40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] 

(2) At least 30 days prior to each stack emissions testing, the Permittee shall submit to 

the Department a stack test protocol for review and approval. 

[COMAR 26.11.03.06C]
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 52 of 73 

D. NOx Emissions 

The Permittee shall submit 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)] 

F. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

5. Clinker Cooler - Registration #7-0109 (Not Subject to MACT and NSPS) 

The clinker cooler was installed or modified prior to August 17, 1971.

5 Emission Unit Number(s)

KC1 Clinker Cooler 

 Applicable Standards/Limits

A. Visible Emissions 

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in any 60- 

minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate exceeds 

60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

For those processes in which the process weight per hour exceeds 60,000 pounds, the 

maximum allowable weight of particulate matter discharged per hour may exceed that 

calculated by the above equation provided that the concentration of particulate matter in 

the gases discharged to the atmosphere is less than 0.05 gr.SCFD (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)] 

 Testing Requirements

A. None 

B. The Permittee shall conduct a particulate matter emissions test at once every 5 years in 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 53 of 73 

accordance with 40 CFR 60.64 and Method 5 of 40 CFR Part 60, Appendix A. Each 

performance test shall consist of three separate runs under the conditions that the kiln 

operates at least 90% of maximum allowable process rate. 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. 

[COMAR 26.11.03.06C]. 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per week. A 

visible emission evaluation will be performed on the exhaust of each operating source, 

using EPA Reference Method 22 for one-minute period. If no visible emissions are 

observed, such conditions will be noted in the inspection log. If visible emissions are 

observed, the Permittee shall immediately inspect and/or repair the emission unit and 

related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately 

undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this weekly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this weekly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[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 limit before discharging into the atmosphere. 

[COMAR 26.11.03.06C]

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

dust collector that describes the maintenance activity and time schedule for completing 

each activity. The Permittee shall perform maintenance activities within the timeframes 

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

was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 54 of 73 

A. The Permittee shall maintain records of the results of the weekly observations and the 

log of inspection and maintenance for at least five (5) years and make them available to 

the Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the dates and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

A. None 

B. (1) The Permittee shall submit the results of performance tests before the close of 

business on the 60th day following the completion of the performance test. 

(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. 

[COMAR 26.11.03.06C] 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

6A. Cement Kiln System ( Not Including Kiln and Clinker Cooler) - Registration #7-

0109 – Fugitive Emissions 

The following equipment were installed or modified prior to August 17, 1971.

6A Emission Unit Number(s)

EKB37-F Transfer from ESP/Multiclone to Bucket Elevators KB35 & KB36 

EAKB53 Transfer from CKD Unloader to Haul Trucks 

EASTP3 CKD Pile Wind Erosion 

EACKDH CKD Pile Activity 

EAKC8 Transfer from Clinker Cooler KC1 to Drag Conveyor KCB 

EAKC9 Transfer from Drag Belt KC9 to Kick out Belt KC9-2 and Transfer from Belt 

Conveyor KC9-3 to Belt Conveyor 37 

EAROD2 CKD Haul Truck to CKD Pile 

ETNK1 Liquid Fuel Tanks working loss 

ETNK2 Liquid Fuel Tanks breathing loss 

 Applicable Standards/Limits

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

permit emissions from an unconfined source without taking reasonable precautions to 

prevent particulate matter from becoming airborne. 

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

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

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

demolished without taking reasonable precautions to prevent particulate matter from 

becoming airborne. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 55 of 73 

 Testing Requirements

None 

 Monitoring Requirements

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

describes the procedures and methods that will be used to take reasonable precautions. 

[COMAR 26.11.03.06C]

The Permittee shall perform a walk through inspection of the facility to observe each 

emissions unit to verify that reasonable precautions are being implemented and to determine 

whether the reasonable precautions need to be revised. The inspection shall be conducted at 

a minimum of once per month at times when the effectiveness of the reasonable precautions 

can be assessed. 

 [COMAR 26.11.03.06C] 

 Record Keeping Requirements

The Permittee shall maintain records of the results of the monthly inspections and the log of 

inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 

[COMAR 26.11.03.06C]

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

6B. Cement Kiln System (Not Including Kiln and Clinker Cooler) - Registration #7-

0109 – Point Sources

The following equipment were installed or modified prior to August 17, 1971. 

6B Emission Unit Number(s)

EKB11 EKB11 -Transfer from Kiln Feed Pumps (EKB4 and EKB5) to Kiln Feed 

Hopper; Transfer from CKD Recovery to Bucket Elevator KB44 

EKB37-S EKB37 -Transfer from CKD Bucket Elevators KB35 & KB36 Waste Dust 

Bin KB40A and Recovery Waste Dust Bin KB40B 

EAKC9-S EAKC9 -Transfer from Drag Belt KC8 to Drag Belt KC9 and Belt Conveyor 

KC9-3 and Transfer from Belt Conveyor KC9-3 to Belt Conveyor 37 and 

Kick out Belt KC9-2 to Belt Conveyor 37 

EAKB54 EAKB53 -Transfer from Waste Dust Bin to Customer Trucks 

 Applicable Standards/Limits

A. Visible Emissions

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

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

which is greater than 20 percent opacity. 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(1) The visible emissions are not greater than 40 percent opacity; and 

(2) The visible emissions do not occur for more than 6 consecutive minutes in any 60- 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 56 of 73 

minute period. 

[COMAR 26.11.06.02A(2)] 

B. Particulate Matter Emissions 

For the installations constructed before January 17, 1972: 

COMAR 26.11.06.03B(1)(b)(i) which prohibits the discharge of particulate matter 

emissions from confined sources into the atmosphere in excess of the limit determined 

from the Table 1 or determined by the following equation when the process rate exceeds 

60,000 pounds per hour: 

E (lb/hr) = 55.0 x P(0.11 power) – 40, where P is the process weight in tons per hour. 

 

For those processes in which the process weight per hour exceeds 60,000 pounds 

(27,200 kilograms), the maximum allowable weight of particulate matter discharged per 

hour may exceed that calculated by the equation shown in (1) provided that the 

concentration of particulate matter in the gases discharged to the atmosphere is less than 

0.05 gr/scfd (115 mg/dscm). 

[COMAR 26.11.06.03B(1)(b)(ii)]

 Testing Requirements

 None 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per month. A 

visible emission evaluation will be performed on the exhaust of each operating source, 

using EPA Reference Method 22 for one-minute period. If no visible emissions are 

observed, such conditions will be noted in the inspection log. If visible emissions are 

observed, the Permittee shall immediately inspect and/or repair the emissions unit and 

related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately 

undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 57 of 73 

 [COMAR 26.11.03.06C] 

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

dust collector that describes the maintenance activity and time schedule for completing 

each activity. The Permittee shall perform maintenance activities within the timeframes 

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

was performed. 

[COMAR 26.11.03.06C] 

 Record Keeping Requirements

B. The Permittee shall maintain records of the results of the monthly inspections and the log 

of inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 

[COMAR 26.11.03.06C] 

C. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the dates and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C]

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

7A. Finish Mill System - Registration #7-0111– Fugitive Emissions (Subject to 40 CFR 

Part 60, Subpart F) 

The following equipment were installed or modified after August 17, 1971. 

7a Emission Unit Number(s)

EAF83 Discharge point from Conveyor F81 and storage of clinker 

EAROAD2 Traffic from Bulk Silos (See Quarry Section) 

EASTP3 Gypsum and Slag Storage Pile Unloading and Wind Erosion 

EF54 Transfer from Air Slide F61-31 to Belt Conveyor F54 and then to Finish Mill 

EF60 Transfer from Air Slide F61-11 to Bucket Elevator F60 

EF61 Transfer from Air Slides F68-1 and F68-2 to Air Slide F61-32 and Cement 

Coolers F63A and 63B and then to F-K pump F65 

 Applicable Standards/Limits

A. Visible Emissions 

40 CFR §60.62(c) - A person may not cause to be discharged into the atmosphere from 

any affected facility other than kiln and clinker cooler any gases which exhibit 10 

percent opacity, or greater. 

B. Particulate Matter Emissions 

(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 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 58 of 73 

precautions to prevent particulate matter from becoming airborne. 

(2) COMAR 26.11.06.03D - Particulate matter from Materials Handling and 

Construction. A person may not cause or permit any material to be handled, 

transported, or stored, or a building, its appurtenances, or a road to be used, 

constructed, altered, repaired, or demolished without taking reasonable precautions 

to prevent particulate matter from becoming airborne. 

 Testing Requirements

 None 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar 

month. Fugitive emission sources inside buildings will be evaluated at the door(s) of the 

building. A visible emission evaluation will be performed on each operating source, 

using EPA Reference Method 22 for one-minute period. If no visible emissions are 

observed, such conditions will be noted in the inspection log. If visible emissions are 

observed, the Permittee shall immediately inspect and/or repair the emission unit and 

related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately 

undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 10 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 10 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 10 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[COMAR 26.11.03.06C] 

B. 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. 

[COMAR 26.11.03.06C] 

The Permittee shall perform a walk through inspection of the facility to observe each 

emissions unit to verify that reasonable precautions are being implemented and to 

determine whether the reasonable precautions need to be revised. The inspection shall 

be conducted at a minimum of once per month at times when the effectiveness of the 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 59 of 73 

reasonable precautions can be assessed. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the 

log of inspection and maintenance for at least five (5) years and make them available to 

the Department upon request 

[COMAR 26.11.03.06C] 

B. 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. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

. None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

7B. Finish Mill System - Registration #7-0111– Point Sources (Subject to 40 CFR Part 

60, Subpart F) 

The following equipment were installed or modified after August 17, 1971.

7B Emission Unit Number(s)

EF39 EF39 -Transfer from Belt F40 to Belt F43-1 in S. Transfer Tower 

EF42 EF42 -Transfer from Belt F80 to Belt F40; Transfer from Conveyor F37 to 

Conveyors F81and F40 in N. Transfer Tower 

EF67 EF67 -Bulk Cement Silos, Filling 

EF68 EF68 -Finish Mill F55 

EF69 EF69 - Mill Separator F62 

EF71 EF71 -Finish Mill Weigh Feeders; Finish Mill Feed Belt; Transfer from Belt 

F43 Tripper to F45- Series Clinker Bins 

EF75 EF75 -Bulk Cement Silos, Filling 

EF81 EF81 -Transfer from Conveyor F81 to F83 Silos or Bucket Elevator F97 

EF86 EF86 -Transfer from Belt F98 and F83 Silos to Belt F80 

EF92 EF92 -Transfer from Bucket Elevator F97 to Conveyor 91, then to Clinker 

Silo F105 

EF96 EF96 -Transfer from Clinker Silo F105 to Feeders; Transfer from 

Gypsum/Clinker Feeders to Belt F98 

EBS802 EBS802 -Bulk Cement Silos, Loadout to Truck and Rail 

EBS814 EBS814 -Bulk Cement Silos, Loadout to Truck and Rail

 Applicable Standards/Limits

A. Visible Emissions 

(1) 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. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 60 of 73 

COMAR 26.11.06.02C(1) does not apply to emissions during start-up and process 

modification or justification, or occasional cleaning up of control equipment, if: 

(a) The visible emissions are not greater than 40 percent opacity; and 

(b) The visible emissions do not occur for more than 6 consecutive minutes in 

any 60- minute period. 

[COMAR 26.11.06.02A(2)]

(2) 40 CFR §60.62(c) - A person may not cause to be discharged into the atmosphere 

from any affected facility other than kiln and clinker cooler any gases which 

exhibit 10 percent opacity, or greater.

B. Particulate Matter Emissions 

For the installations constructed after January 17, 1972: 

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

be discharged from any installation in excess of 0.05 gr/SCFD (115 mg/dscm). 

 Testing Requirements

 None 

 Monitoring Requirements

A. The Permittee will conduct a walk-through inspection of the facility once per calendar 

month. Fugitive emission sources inside buildings will be evaluated at the door(s) of the 

building. A visible emission evaluation will be performed on each operating source, 

using EPA Reference Method 22 for one-minute period. If no visible emissions are 

observed, such conditions will be noted in the inspection log. If visible emissions are 

observed, the Permittee shall immediately inspect and/or repair the emission unit and 

related equipment until no visible emissions are observed based on EPA Reference 

Method 22. If visible emissions are still observed, the Permittee will immediately 

undertake the following: 

(1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute 

period. If the 6-minute average opacity measurement shows opacity less than 20 

percent, the opacity shall be recorded and no further action will be necessary for 

this monthly inspection. 

(2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee 

shall initiate corrective maintenance immediately and repeatedly to repair or 

replace equipment that is causing excess emissions until corrective maintenance 

has been completed. The “completeness of corrective maintenance” means that at 

least two 6-minute EPA Method 9 observations are taken within 60 minutes and 

shows opacity less than 20 percent for each observation. If the corrective 

maintenance has been completed, the visible observations with the corrective 

maintenance shall be noted in the inspection log and no further action will be 

necessary for this monthly inspection. 

(3) If correction maintenance cannot be completed within 48 hours, the Permittee shall 

report to the Department excess emissions in accordance with COMAR 

26.11.01.07C. 

[COMAR 26.11.03.06C] 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 61 of 73 

B1. The exhaust gas from each equipment 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 

dust collector that describes the maintenance activity and time schedule for completing 

each activity. The Permittee shall perform maintenance activities within the timeframes 

established in the plan and shall maintain a log with records of the date maintenance was 

performed. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements

A. The Permittee shall maintain records of the results of the monthly inspections and the log 

of inspection and maintenance for at least five (5) years and make them available to the 

Department upon request 

[COMAR 26.11.03.06C] 

B. The Permittee shall maintain a copy of the preventative maintenance plan for each 

baghouse and a record of the dates and description of maintenance activity performed. 

The Permittee shall maintain records of the baghouse malfunctions and the corrective 

actions taken to bring it back into proper operation. 

[COMAR 26.11.03.06C] 

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

8. One 3,000 gallon Gasoline Tank – Installed in 1992 

8 

Emission Unit Number(s)

ETNK3 3,000 Gallon Gasoline Storage Tank 

 Applicable Standards/Limits

COMAR 26.11.13.04C(2) – “Stage 1 Vapor Recovery. An owner or operator of a gasoline 

tank truck or an owner of a stationary storage tank subject to this regulation may not cause or 

permit gasoline to be loaded into a stationary tank unless the loading system is equipped 

with a vapor balance line that is properly installed, maintained, and used.” 

 Testing Requirements

 None 

 Monitoring Requirements

Once a month the Permittee shall visually inspect the gasoline loading and unloading 

operations for liquid leaks and spills, and verify that the loading connections are leak tight 

and automatically close upon disconnection. 

[COMAR 26.11.03.06C]

 Record Keeping Requirements

The Permittee shall maintain records of the inspection results, gasoline throughput, and tank 

size for at least five years and shall make such records available to the Department upon 

request. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 62 of 73 

[COMAR 26.11.03.06C]

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

9. One Cold Degreaser – Installed in 1970 

9 Emission Unit Number(s)

ECD1 One Cold Degreaser 

 Applicable Standards/Limits

(1) COMAR 26.11.19.09D(2) - A person may not use any VOC degreasing material that 

exceeds the following vapor pressure of 1 mm Hg (0.019 psia) at 20o

C; and 

(2) COMAR 26.11.19.09D(4) - A person may not use a halogenated substance that is a 

VOC in any cold degreasing. 

 Testing Requirements

 None 

 Monitoring Requirements

(1) The Permittee shall implement good operating practices including covers (including 

water covers), lids, or other methods of minimizing evaporative losses, and reducing the 

time and frequency during which parts are cleaned. 

[COMAR 26.11.19.09D(3)(b)] 

(2) Good operating practices shall be established in writing, and displayed so they are 

clearly visible to the operator. 

[COMAR 26.11.19.09D(3)(c)]

 Record Keeping Requirements

The written good operating practices shall be maintained at the facility and made available for

review by the Department upon request. 

[COMAR 26.11.19.09D(3)(d)]

 Reporting Requirements

 None 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 

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 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 63 of 73 

63.1(a)(1) through (4) Applicability 

63.1(a)(6) through 

(a)(8) 

Applicability 

63.1(a)(10) through 

(14) 

Applicability 

63.1(b)(2) and (3) Initial Applicability 

Determination 

63.1(c)(1) Applicability after Standard 

 Established 

63.1(c)(2) Permit Requirements Area Sources Must Obtain Title V 

Permits 

63.1(c)(4) and (5) Extensions, Notifications 

63.1(e) Applicability of Permit Program 

63.2 Definitions Additional Definitions in §63.1341 

63.3(a) through (c) Units and Abbreviations 

63.4(a)(1) through 

(a)(3) 

Prohibited Activities 

63.4(a)(5) Compliance Date 

63.4(b)and (c) Circumvention, Severability 

63.5(a)(1) and (2) Construction/Reconstruction 

63.5(b)(1) Compliance Dates 

63.5(b)(3) through (6) Construction Approval 

Applicability 

63.5(d)(1) through (4) Approval of Construction/ 

Reconstruction 

63.5(e) Approval of Construction/ 

Reconstruction 

63.5(f)(1) and (2) Approval of Construction/ 

Reconstruction 

63.6(a) Compliance for Standards and 

Maintenance 

63.6(b)(1) through (5) Compliance Dates 

63.6(b)(7) Compliance Dates 

63.6(c)(1) and (2) Compliance Dates 

63.6(c)(5) Compliance Dates 

63.6(e)(1) and (e)(2) Operation & Maintenance 

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 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

Page 64 of 73 

63.6(h)(4) and (h)(5)(i) Opacity/VE Standards 

63.6(h)(6) Opacity/VE Standards 

63.6(h)(7) Opacity/VE Standards 

63.6(i)(1) through 

(i)(14) 

Extension of Compliance 

63.6(i)(16) Extension of Compliance 

63.6(j) Exemption from Compliance 

63.7(a)(1) through 

(a)(3) 

Performance Testing 

Requirements 

§63.1349 has specific requirements 

63.7(b) Notification 

63.7(c) Quality Assurance/Test Plan 

63.7(d) Testing Facilities 

63.7(e)(1) through (4) Conduct of Tests 

63.7(f) Alternative Test Method 

63.7(g) Data Analysis 

63.7(h) Waiver of Tests 

63.8(a)(1) Monitoring Requirements 

63.8(b)(1) through (3) Conduct of Monitoring 

63.8(c)(1) through (8) CMS Operation/Maintenance Performance specification 

supersedes requirements for THC 

CEM. Temperature and activated 

carbon injection monitoring data 

reduction requirements given in 

subpart LLL. 

63.8(d) Quality Control 

63.8(e) Performance Evaluation for 

CMS 

Performance Specification 

supersedes requirements for THC 

63.8(f)(1) through 

(f)(5) 

Alternative Monitoring Method Additional requirements in §1350(l) 

63.8(f)(6) Alternative to RATA Test 

63.8(g) Data Reduction 

63.9(a) Notification Requirements 

63.9(b)(1) through (5) Initial Notifications 

63.9(c) Request for Compliance 

Extension 

63.9(d) New Source Notification for 

Special Compliance 

Requirements 

63.9(e) Notification of Performance Test 

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 
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HAGERSTOWN, MARYLAND 21742 

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63.9(h)(1) through 

(h)(3) 

Notification of Compliance 

Status 

63.9(h)(5) and (h)(6) Notification of Compliance 

Status 

63.9(i) Adjustment of Deadlines 

63.9(j) Change in Previous Information 

63.10(a) Record keeping/Reporting 

63.10(b) General Requirements 

63.10(c)(1) Additional CMS Record 

Keeping 

PS-8A applies instead of 

requirements for THC CEM 

63.10(c)(5) through 

(c)(8) 

Additional CMS Record 

Keeping 

PS-8A applies instead of 

requirements for THC CEM 

63.10(c)(10) through 

(15) 

Additional CMS Record 

Keeping 

63.10(d)(1) General Reporting Requirements 

63.10(d)(2) Performance Test Results 

63.10(d)(3) Opacity or VE Observations 

63.10(d)(4) Progress Reports 

63.10(d)(5) Startup, Shutdown, Malfunction 

Reports 

63.10(e)(1) and (e)(2) Additional CMS Reports 

63.10(e)(3) Excess Emissions and CMS 

Performance Reports 

Exceedances are defined in subpart 

LLL 

63.10(f) Waiver for Record Keeping/ 

Reporting 

63.12(a)-(c) State Authority and Delegations 

63.13(a)-(c) State/Regional Addresses 

63.14(a) and (b) Incorporation by Reference 

63.15(a) and (b) Availability of Information 

10 Emission Unit Number(s)

Facility Wide – MACT Sources Only 

 Applicable Standards/Limits

40 CFR §63.6(e)(3)(i) which requires that the Permittee comply with the written startup, 

shutdown, and malfunction plan that describes, in detail, procedures for operating and 

maintaining the source during periods of startup, shutdown, and malfunction; a program of 

corrective action for malfunctioning process; and air pollution control and monitoring 

equipment used to comply with the relevant standard. 

40 CFR §63.6(e)(3)(viii) which states that the Permittee may periodically revise the startup, 

shutdown, and malfunction plan for the affected source as necessary to satisfy the 

requirements of this part or to reflect changes in equipment or procedures at the affected 
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HAGERSTOWN, MARYLAND 21742 

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source. Unless the permitting authority provides otherwise, the Permittee may make such 

revisions to the startup, shutdown, and malfunction plan without prior approval by the 

Administrator or the permitting authority. However, each revision to a startup, shutdown, 

and malfunction plan must be reported in the semiannual report required by §63.10(d)(5). If 

the startup, shutdown, and malfunction plan fails to address or inadequately addresses an 

event that meets the characteristics of a malfunction but was not included in the startup, 

shutdown, and malfunction plan at the time the Permittee developed the plan, the Permittee 

must revise the startup, shutdown, and malfunction plan within 45 days after the event to 

include detailed procedures for operating and maintaining the source during similar 

malfunction events and a program of corrective action for similar malfunctions of process or 

air pollution control and monitoring equipment. In the event that the Permittee makes any 

revision to the startup, shutdown, and malfunction plan which alters the scope of the 

activities at the source which are deemed to be a startup, shutdown, and malfunction, or 

otherwise modifies the applicability of any emission limit, work practice requirement, or 

other requirement in a standard established under this part, the revised plan shall not take 

effect until after the Permittee has provided a written notice describing the revision to the 

permitting authority. 

 Testing Requirements

40 CFR 63.1349(d) requires the Permittee to repeat performance test for dioxin/furan 

emissions required under 40 CFR 63.1349(b)(3) at least once every 30 months. 40 CFR 

63.1349(e)(1) requires that if a source plans to undertake a change in operations that may 

adversely affect compliance with an applicable D/F standard under this subpart, the source 

must conduct a performance test and establish new temperature limit(s) as specified in 

paragraph (b)(3) of this section. 

 Monitoring Requirements

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall 

operate and maintain any affected source, including associated air pollution control 

equipment and monitoring equipment, in a manner consistent with safety and good air 

pollution control practices for minimizing emissions to the levels required by the relevant 

standards, i.e., meet the emission standard or comply with the start-up, shutdown, and 

malfunction plan. Malfunctions shall be corrected as soon as practicable after their 

occurrence in accordance with the startup, shutdown, and malfunction plan. To the extent 

that an unexpected event arises during a start-up, shutdown, and malfunction, the Permittee 

shall comply by minimizing emissions during such a startup, shutdown, or malfunction 

event consistent with safety and good air pollution control practices. 

[40 CFR §63.6(e)(1)(i -ii)] 

 Record Keeping Requirements

When actions taken by the Permittee during a startup, shutdown, or malfunction 

(including actions taken to correct a malfunction) are consistent with the procedures 

specified in the affected source’s startup, shutdown, and malfunction plan, the Permittee 

shall keep records for that event which demonstrate the procedures specified in the plan 

were followed. These records may take the form of a “checklist”, or other effective form 

of record keeping that confirms conformance with the startup, shutdown, and malfunction 

plan for that event. In addition, the Permittee shall keep records of these events as 
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HAGERSTOWN, MARYLAND 21742 

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specified in §63.10(b), including records of the occurrence and duration of each startup, 

shutdown, or malfunction of operation and each malfunction of the air pollution control 

and monitoring equipment. Furthermore, the Permittee shall confirm that action taken 

during the relevant reporting period during periods of start-up, shutdown, or malfunction 

were consistent with the affected source’s startup, shutdown, and malfunction plan in the 

semiannual (or more frequent) startup, shutdown, and malfunction report required in 

§63.10(d)(5). 

If an action taken by the Permittee during a startup, shutdown, or malfunction (including an 

action taken to correct a malfunction) is not consistent with the procedures specified in the 

affected source’s startup, shutdown, and malfunction plan, and the source exceeds the 

relevant emission standard, then the Permittee shall record the actions taken for that event 

and shall report such actions within 2 working days after commencing actions inconsistent 

with the plan, followed by a letter within 7 working days after the end of the event, in 

accordance with §63.10(d)(5) (unless the Permittee makes alternative reporting 

arrangements , in advance, with the Administrator). 

The Permittee shall maintain at the affected source a current startup, shutdown, and 

malfunction plan and shall make the plan available upon request for inspection and 

copying by the Administrator. In addition, if the startup, shutdown, and malfunction plan is 

subsequently revised, the Permittee shall maintain at the affected source each previous (i.e., 

superseded) version of the startup, shutdown, and malfunction plan, and must make each 

such previous version available for inspection and copying by the Administrator for a 

period of 5 years after revision of the plan. If at any time after adoption of a startup, 

shutdown, and malfunction plan the affected source ceases operation or is otherwise no 

longer subject to the provisions of this part, the Permittee shall retain a copy of the most 

recent plan for 5 years from the date the source ceases operation or is no longer subject to 

this part and shall make the plan available upon request for inspection and copying by the 

Administrator. 

[40 CFR §63.6(e)(3)(iii – v)] 

 Reporting Requirements

The Permittee shall, if actions taken are consistent with the procedures specified in the 

startup, shutdown, or malfunction plan, during a startup, shutdown, or malfunction of an 

affected source (including actions taken to correct a malfunction), state such information in 

a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction 

occurred during the reporting period. The startup, shutdown, and malfunction report may 

be submitted simultaneously with the excess emissions and continuous monitoring system 

performance reports. 

Any time an action taken by the Permittee during a startup, shutdown, or malfunction 

(including actions taken to correct a malfunction) is not consistent with the procedures in 

the startup, shutdown, or malfunction plan, the Permittee shall make an immediate report 

of the actions taken for that event within 2 working days, by telephone call or fax 

transmission. The immediate report shall be followed by a letter, certified by the Permittee 
ST. LAWRENCE CEMENT COMPANY 

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HAGERSTOWN, MARYLAND 21742 

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explaining the circumstances of the event, the reasons for not following the startup, 

shutdown, or malfunction plan, and whether any excess emissions and/or parameter 

monitoring exceedances are believed to have occurred. 

[40 CFR §63.1354(b)(4 – 5)] 

A permit shield shall cover the applicable requirements of the Clean Air Act that are listed in the 

table above. 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

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SECTION V INSIGNIFICANT ACTIVITIES

This section provides a list of insignificant emissions units that were reported in the Title V permit 

application. The applicable Clean Air Act requirements, if any, are listed below the insignificant 

activity. 

(1) No. 1 Fuel burning equipment using gaseous fuels or no. 1 or no. 2 fuel oil, and 

having a heat input less than 1,000,000 Btu (1.06 gigajoules) per hour; 

COMAR 26.11.09.05A(1), which establishes that the Permittee may not 

cause or permit the discharge of emissions from any fuel burning 

equipment, other than water in an uncombined form, which is greater than 

20 percent opacity. 

Exceptions: COMAR 26.11.09.05A(2) does not apply to emissions during 

load changing, soot blowing, start-up, or adjustments or occasional cleaning 

of control equipment if: 

(a) The visible emissions are not greater than 40 percent 

opacity; and 

(b) The visible emissions do not occur for more than 6 

consecutive minutes in any sixty-minute period. 

COMAR 26.11.09.07A(1)(c), which establishes that the Permittee may not 

burn, sell, or make available for sale any distillate fuel with a sulfur content 

by weight in excess of 0.3 percent. 

(2) No. 2 Fuel-burning equipment using solid fuel and having a heat input of less than 

350,000 Btu (0.37 gigajoule) per hour; 

(3) No. 1 Stationary internal combustion engines with an output less than 500 brake 

horsepower (373 kilowatts) and which are not used to generate electricity 

for sale or for peak or load shaving; 

(A) COMAR 26.11.09.05B(2), Emissions During Idle Mode: The 

Permittee may not cause or permit the discharge of emissions from any 

engine, operating at idle, greater than 10 percent opacity. 

(B) COMAR 26.11.09.05B(3), Emissions During Operating Mode: 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. 
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1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

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(C) Exceptions: 

(i) COMAR 26.11.09.05B(2) does not apply for a period of 2 

consecutive minutes after a period of idling of 15 consecutive 

minutes for the purpose of clearing the exhaust system. 

(ii) COMAR 26.11.09.05B(2) does not apply to emissions resulting 

directly from cold engine start-up and warm-up for the following 

maximum periods: 

(a) Engines that are idled continuously when not in service: 30 

minutes; 

(b) All other engines: 15 minutes. 

(iii) COMAR 26.11.09.05B(2) & (3) do not apply while maintenance, 

repair or testing is being performed by qualified mechanics. 

(4) X Space heaters utilizing direct heat transfer and used solely for comfort heat; 

(5) No. 2 Unheated VOC dispensing containers or unheated VOC rinsing containers 

of 60 gallons (227 liters) capacity or less; 

(a) COMAR 26.11.19.09D(2)(b), which establishes that the Permittee 

shall not use any VOC degreasing material that exceeds a vapor 

pressure of 1 mm Hg at 20°C; 

(b) COMAR 26.11.19.09D(3)(a—d), which requires that the Permittee 

implement good operating practices designed to minimize spills and 

evaporation of VOC degreasing material. These practices, which shall 

be established in writing and displayed such that they are clearly 

visible to operators, shall include covers (including water covers), lids, 

or other methods of minimizing evaporative losses, and reducing the 

time and frequency during which parts are cleaned; 

(c) COMAR 26.11.19.09D(4), which prohibits the use of any halogenated 

VOC for cold degreasing. 

The Permittee shall maintain on site for at least five (5) years, and shall 

make available to the Department upon request, the following records of 

operating data: 

(a) Monthly records of the total VOC degreasing materials used; and 
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HAGERSTOWN, MARYLAND 21742 

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(b) Written descriptions of good operating practices designed to minimize 

spills and evaporation of VOC degreasing materials. 

(6) X Equipment for drilling, carving, cutting, routing, turning, sawing, planing, 

spindle sanding, or disc sanding of wood or wood products; 

(7) X Brazing, soldering, or welding equipment, and cutting torches related to 

manufacturing and construction activities that emit HAP metals and not 

directly related to plant maintenance, upkeep and repair or maintenance 

shop activities; 

(8) Containers, reservoirs, or tanks used exclusively for: 

(a) X Storage of butane, propane, or liquefied petroleum, or 

natural gas; 

(b) No. 81 Storage of lubricating oils 

(c) No. 9 Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation 

jet engine fuel; 

(9) X First aid and emergency medical care provided at the facility, including 

related activities such as sterilization and medicine preparation used in 

support of a manufacturing or production process; 

(10) X Potable water treatment equipment, not including air stripping equipment; 

(11) X Emissions resulting from the use of explosives for blasting at quarrying 

operations and from the required disposal of boxes used to ship the 

explosive; 

(12) X Comfort air conditioning subject to requirements of Title VI of the Clean 

Air Act; 

(13) X Natural draft hoods or natural draft ventilators that exhaust air pollutants 

into the ambient air from manufacturing/industrial or commercial processes; 

(14) X Laboratory fume hoods and vents; 

For the following, attach additional pages as necessary: 
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1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

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(15) any other emissions unit, not listed in this section, with a potential to emit less than 

the “de minimus” levels listed in COMAR 26.11.02.10X (list and describe units): 

No. 1 Halon Fire Suppression System (Control Room) 

No. 2 Laboratory Exhaust Vents 

No. 8 Welding Machines (Maintenance) 

 
ST. LAWRENCE CEMENT COMPANY 

1260 SECURITY ROAD 

HAGERSTOWN, MARYLAND 21742 

PART 70 OPERATING PERMIT NO. 24-043-00008 

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SECTION VI STATE-ONLY ENFORCEABLE CONDITIONS

The Permittee is subject to the following state-only enforceable requirements: 

A. Applicable Regulations 

(1) COMAR 26.11.06.08 and 26.11.06.09, which generally prohibit the discharge 

of emissions beyond the property line in such a manner that a nuisance or air 

pollution is created. 

(2) COMAR 26.11.15.05, which requires that the Permittee implement “Best 

Available Control Technology for Toxics” (T – BACT) to control emissions of 

toxic air pollutants. 

(3) COMAR 26.11.15.06, which prohibits the discharge of toxic air pollutants to 

the extent that such emissions will unreasonably endanger human health. 

B. Compliance Demonstration 

(1) The Permittee shall submit to the Department, by April 1 of each year during 

the term of this permit, a written certification of the results of an analysis of 

emissions of toxic air pollutants from the Permittee’s facility during the 

previous calendar year. The analysis shall include either: 

(a) a statement that previously submitted compliance demonstrations for 

emissions of toxic air pollutants remain valid, or 

(b) a revised compliance demonstration, developed in accordance with 

requirements included under COMAR 26.11.15 & 16, that accounts for 

changes in operations, analytical methods, emissions determinations, or 

other circumstances that have invalidated previous demonstrations. 

(2) The Permittee shall install data telemetry for all required CEMs (COMAR 

26.11.01.11B(7)). This system shall be designed and installed in accordance 

with specifications approved by the Department. The system shall be 

operational by the date specified in Regulation .10D(1) of this chapter.”