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 conditio ns described on the attached pages.

Page 1 of 73

Program Manager Director, Air and Radiation Management AdministrationPART 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 manuf acturing 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. Th e cement production at this location dates back to 1903 and the current long dry kiln has been in op eration 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 (a lumina), 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 be lt conveyor to the screening system (Q7) for sizing. Oversized material discarded by the scr eening 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 ar e 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 syst em (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 transporte d to the fuel mill (C8) where it is pulverized. Particulate matter emissions are controlled by a cy clone 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 (R 37) is transported to the raw mill separator (R43) by a bucket elevator (R41). Acceptable materi al is pneumatically conveyed to three (3) raw material bl ending silos (R60)
where it is blended as kiln feed. Particulate matter emissi ons 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 captu res any dust generated at the feed end. As the raw material traverses the length of the kiln (KB13) toward the lower (hotte r) end, chemical reactions take place to produce clinker. As
the raw material is heated to about 1800 ° F, the carbonaceous materi als are oxidized, the alka line 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. WastePART 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 us e 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 pulver izing mill. The Raymond coal pulverizing

mill vents to a cyclone and a baghouse for pa rticulate matter emissions control. Th e 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 build ing (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 homogene ous, finely ground product, Portland cement. The product from the finished mill is transpor ted to a separator. Material, which is too larg e, is recycled to the finish mill. Acceptabl e 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 re turned to the process.

Final Product Packaging and Loadout The final product is transferred from the pack house silo s 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. Mo st 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
, NO

x , and SO 2 emissions based on actual emissions. As a major source of nitrogen oxide (NO

x ) emissions, the facility is subject to NO

x RACT.

The following table summarizes the annual emissions of criteria pollutants from St. Lawrence Cement, Inc. based on its 2000, 2001 and 2002 Emissions Certif ication Report and the annual emi ssions 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 NO X (TPY) SO X (TPY) PM 10 (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 C ounty is 50 tons per year for VOCs, 100 tons per year for NO X 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 PM 10 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 recei ve a Part 70 permit for the Hagersto wn plant as of December 1,2001, the date Maryland’s interim approval of its Part 70 program expi red. As a consequence, St. Lawrence Cement, Inc. was required to submit a Part 71 permit app lication by May 31,2002. The Departme nt received St. Lawrence’s Part 71 application on June 6
, 2002. An administrative completeness revi ew was conducted and the application was deemed to be administratively complete. A letter was sent to St. Lawrence Cement, In c. granting an application shield. The Part 71 application serves as a revi sed 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 Emission s 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 Em issions – Inside Building 1970PART 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 Emission s 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 1970PART 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 Cont rolled 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 Emission s 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 - R egistration #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 KC 1 Discharging through Multicyclone KC2 and

ESP KC3 - EKC4 1970

6. Cement Kiln System ( Not Include Kiln and C linker 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 1970PART 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 work ing loss Fugitive Emissions 1970 ETNK2 Liquid Fuel Tanks breat hing 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 - Registra tion #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) 1976PART 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 Disc harges 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 1970PART 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 contai ns the general requirements for testi ng, 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 identif ies the basis upon which the Permittee will demonstrate compliance. The basis will include testing, monitoring, record keeping, and reporti ng 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 Ai r Act, the requirement is listed under the activity.

Section VI of the Part 70 Permit contai ns State-only enforceable requirements. Upon issuance of the Part 70 Permit, it will supersede the facility's current State Permit to Operat e. 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 RE VIEW/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 constructe d or modified after August 17, 1971 ); 40 CFR 60, Subpart Y ( Coal Preparation Plant s constructed or modified October 24, 1974 ); 40 CFR 60, Subpart OOO ( Nonmetallic Mineral Processi ng Plants constructed or m odifies 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 ai r 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 un der the Portland cement manufacturing pl ant MACT (maximum achievable control technology) outlined in 40 CFR Part 63, Subpart LLL. Th e only affected facility s ubject to the Portland cement manufacturing plant MACT for an area so urce is each kiln and each in-line kiln/raw mill for dioxin/furan emissions control. Emissions units which are affected sources subj ect to the provisions Subpart LLL are, according to 40 CFR § 63.1356, exempt from otherwise applicable new source pe rformance standard contained in 40 CFR 60, Subpart F or in Subpart OOO.

On April 5, 2002, EPA issued a direct final rule amendi ng the Portland Cement MACT w ith 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 advers e comments in July 2002. 67 Fed. Reg. 44371 (July 2, 2002). After following formal rulemaking procedures, EPA ultimat ely 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 prepar e 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 1 976, 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 inst alled 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 c onveyors 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 constructe d 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, th e 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 crushe r, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truc k or railcar loading station constructed or modified after August 31, 1983 is subject to 40 CFR 60, S ubpart OOO - Standards of Performance for Nonmetallic Mineral processing Plants. An aff ected facility subject to 40 CFR 60, Subpart F is exempt from 40 CFR 60, Subpart OOO.

EAQ21, EAQ23, EAQ25, EAQ27, and EAQ28 were inst alled in 1999 and were subject to Subpart OOO. The rest of the quarry operations date back to the 1950’s a nd was not subject to Subpart OOO. The emissions units under the Portland cement operation are either subject to Subpart F, Subpa rt LLL (Portland Cement MACT), or installed before August 31, 1983.

NSR and PSD

St. Lawrence Hagerstown plant has not applied for any a pprovals 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 precau tions 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, altere d, repaired, or demolished without taking reasonable precautions to prev ent 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 whethe r the reasonable precautions need to be revised. The inspection shall be conducted at a mini mum 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 demonstrationPART 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 impl ementation 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 Perm ittee is required to perform a monthly inspection and maintain records of the results. Inspections are requi red at times when weather conditions are favorable for particulate matter to become airborne. The best manageme nt 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 we re 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 an y fugitive emissions which exhibit greater than 10 percent opacity except, as pr ovided 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 ot her 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 reasonabl e 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 taki ng 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 w ill be evaluated at the door(s) of the building. A visible emission evaluation will be performed on the exhaust of each ope rating source, using EPA Reference Method 22 forPART 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 sh all immediately inspect and/ or repair the emissions unit and related equipment until no vi sible emissions are observed base d 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 measuremen t shows opacity less than 10 percent, the opacity shall be
recorded and no further action will be n ecessary 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 re place 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 fo r 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 Perm ittee 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 n eeded 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 impl ementation 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 mont hly observation and inspection to prev ent any violations of NSPS visible emissions requirements and maintain records of the resu lts. 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 add itional or different procedures are need ed to prevent particulate matter from becoming airborne.

1C. Quarry - Registration # 7-0108 - Point Sources (Not Subject to NSPS Subpart OOO): The following equipment we re 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 proce ss 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 par ticulate 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 calen dar month. A visible emission evaluation will be performed on the exha ust 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 emi ssions are still observed, the Permittee will immediately undertak e the following: (1) The Permittee shall perform a Reference EPA Method 9 observation for 6-minute period. If the 6- minute average opacity measuremen t shows opacity less than 20 percent, the opacity shall be
recorded and no further action will be n ecessary 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 re place 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 fo r 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 ac tion will be necessary for this monthly inspection. (3) If correction maintenance cannot be completed within 48 hours, the Perm ittee shall report to the Department excess emissions in acco rdance 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 equipmen t shall vent through a dust collector designed to meet the particulate matter emissions limit before discharging into the atmosphere. [COMAR 26.11.03.06C] B2. The Permittee shall comply with a nd update the preventative maintenan ce 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 c opy 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 preven tative maintenance plan for
each dust collector that describes th e maintenance activity and time sche dule 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 R 14; 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 prev ent 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, altere d, repaired, or demolished without taking reasonable precautions to prev ent particulate matter from becoming airborne.

Compliance Demonstration Testing Requirements

NonePART 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 mini mum of one minute once a month or when weather conditions are favorable to cause partic ulate 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 impl ementation 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 Perm ittee is required to perform a monthly inspection and maintain records of the results. Inspections are requi red at times when weather conditions are favorable for particulate matter to become airborne. The best manageme nt 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 we re 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 Crushe r 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 th ru -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 EmissionsPART 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 ra te 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 par ticulate 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 calen dar month. A visible emission evaluation will be performed on the exha ust of each operating source, using EPA Reference Method 22 for one-minute peri od. If no visible emissions are observed, such cond itions will be noted in the inspection log. If visible emissi ons 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 em issions are still observed, the Perm ittee 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 measuremen t shows opacity less than 20 percent, the opacity shall be
recorded and no further action will be n ecessary 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 re place 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 fo r 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 Perm ittee shall report to the Department excess emissions in acco rdance with COMAR 26.11.01.07C.

[COMAR 26.11.03.06C]

B. The Permittee shall comply with and update the preventative maintenan ce plan for each dust collector that describes the maintenance activity and time schedul e 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 c opy 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 thePART 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 ta ken 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 preven tative maintenance plan for
each dust collector that describes th e maintenance activity and time sche dule 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 in stalled 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 cleani ng up of control equipment, if: (a) The visible emissions are not gr eater 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 ra te 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 disc harged 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 RequirementsPART 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 w eek. A visible emission evaluation will be performed on the exhaust of each ope rating 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 sh all immediately inspect and/ or repair the emissions unit and related equipment until no vi sible emissions are observed base d on EPA Reference Method 22. If visible emissions are still observed, the Permitt ee 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 measuremen t shows opacity less than 20 percent, the opacity shall be
recorded and no further action will be n ecessary for this w eekly inspection. (2) If the 6-minute average opacity measurement exceeds 20 percent, the Permittee shall initiate corrective maintenance immediately and repeatedly to repair or re place 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 fo r 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 ac tion will be necessary for this weekly inspection. (3) If correction maintenance cannot be completed within 48 hours, the Perm ittee 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 equipmen t 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 prev entative maintenance plan fo r the dust collector that describes the maintenance activity and time schedul e 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 c opy 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 ta ken 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 opac ity. 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 emissi ons observations at least once a week. For particulate matter emissions, the Permittee is required to prepare a preventative main tenance plan for each dust collector th at 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 Ha ndling - Registration # 7-0108- Fugiti ve 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 Feed ers 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 prev ent 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, altere d, repaired, or demolished without taking reasonable precautions to prev ent 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 whethe r the reasonable precautions need to be revised. The inspection shall be conducted at a mini mum 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 impl ementation 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 Perm ittee is required to perform a monthly inspection and maintain records of the results. Inspections are requi red at times when weather conditions are favorable forPART 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 preven t 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 Point s 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 clean ing up of control equipment, if: (a) The visible emissions are not gr eater 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 proce ss 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 par ticulate 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 cal endar month. A visible emission evaluation will be performed on the exha ust 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 emi ssions are still observed, the Permittee w ill 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 measuremen t shows opacity less than 20 percent, the opacity shall be
recorded and no further action will be n ecessary 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 re place 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 fo r 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 ac tion will be necessary for this monthly inspection. (3) If correction maintenance cannot be completed within 48 hours, the Perm ittee 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 a nd update the preventative maintenan ce plan for each dust collector that describes the maintenance activity and time schedul e 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 c opy 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 ta ken 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 preven tative maintenance plan for
each dust collector that describes th e maintenance activity and time sche dule for completing each activity.

4. Kiln System - R egistration #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 clean ing up of control equipment, if: (a) The visible emissions are not gr eater 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 proce ss 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 par ticulate 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 per cent 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 impl ement 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 NO

x control. Compliance with the facility’s NOx emissions limit will be determined according to the NOx emissions co llected 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 su lfuric 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 1,400 o 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 year s 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 volum e 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 sti pulated 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 a nd used to determine compliance. ( 2) The temperature at the inlet to the kiln or in-lin e 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 cal culated for each minute of each run of the test. (4) The run average temperature must be calculated for each run, and the aver age 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 w ith COMAR 26.11.01.10B, shall continuous ly monitor opacity of the stack gases using a continuous opacity monitor that is cer tified 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 thePART 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 insp ection 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 conti nuously 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 re quirements in §63.1349(b)(3)(iv). (2) The reference method must be a National Institute of Standards and Technol ogy 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 ar e not available shall be ignored when calculating three-hour rolling averages. When one-minute aver ages become available, the first one-minute average is added to the previous 179 values to calculate the thr ee-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 th e three-hour rolling average temper ature must begin anew, without considering previous recordings. (6) The calibration of all thermocouples and other temper ature 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 SO 2 , emissions from the main exhaust stack. The Permittee shall install, operate, maintain, and calibrate the
CEM in accordance with the Perfo rmance Specifications under 40 CF R 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 CE M to record not less than four e qually 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. NonePART 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 occurren ce, measurement, maintenance, correctiv e action, report or record. At a minimum, the most recent two years of data shall be retained on site; the remaini ng three years of data may be retained
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 occurren ce, measurement, maintenance, correctiv e action, report or record. At a minimum, the most recent two years of data shall be reta ined on site; the remaining th ree 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 Departme nt, and shall include the following: (1) The cause, time periods, and magnitude of all em issions 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 60 th day following the completion of the performance test. (2) At least 30 days prior to each stack emissions te sting, the Permittee shall submit to the Department a stack test protocol for review and approval. [COMAR 26.11.03.06C]

C

. (1) The Permittee shall submit the results of performance tests before the close of business on the 60 th day following the completion of the performance test. [40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] (2) At least 30 days prior to each stack emissions te sting, the Permittee shall submit to the Department a stack test protocol for review and approval. [COMAR 26.11.03.06C]

D. NOx EmissionsPART 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 contro l 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 Ap ril 15, 2004 for the required certification of its NOx
and SO 2 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 cleani ng up of control equipment, if: (a) The visible emissions are not gr eater 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 ra te 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 disc harged 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. NonePART 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 emissi ons test at once every 5 y ears 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 operate s at least 90% of maximum allowable process rate. Each run shall be conducted for at least one hour, a nd 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 ope rating 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 sh all immediately inspect and/ or repair the emissions unit and related equipment until no vi sible emissions are observed base d on EPA Reference Method 22. If visible emissions are still observed, the Perm ittee 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 measuremen t shows opacity less than 20 percent, the opacity shall be
recorded and no further action will be n ecessary 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 re place 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 fo r 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 ac tion will be necessary for this weekly inspection. (3) If correction maintenance cannot be completed within 48 hours, the Perm ittee 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 equipmen t 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 prev entative maintenance plan fo r the dust collector that describes the maintenance activity and time schedul e 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 c opy 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 ta ken to bring back into proper operation. [COMAR 26.11.03.06C]

Reporting Requirement

A. NonePART 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 60 th day following the completion of the performance test. (2) At least 30 days prior to each stack emissions te sting, the Permittee shall submit to the Department a stack test protocol for review and approval. [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 potentia l emissions from the raw mill and raw m ill 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 pr eventative maintenance plan for each dust collector that describes the maintenance activity and time schedule for co mpleting 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 Clin ker Cooler) - Registration #7-0109 – Fugitive Emissions The following equipment we re 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 Cool er KC1 to Drag Conveyor KCB EAKC9 Transfer from Drag Belt KC9 to Kick out Be lt 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 reasonabl e 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 taki ng 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 im plemented and to determine whether the reasonable pr ecautions need toPART 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 mini mum 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 impl ementation 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 Perm ittee is required to perform a monthly inspection and maintain records of the results. Inspections are requi red 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 preven t particulate matter from becoming airborne.

6B. Cement Kiln System (Not Including Kiln an d 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 C KD Bucket Elevators KB35 & KB36 Waste Dust Bin KB40A and Recovery Waste Dust Bin KB40B
EAKC9-S EAKC9 -Transfer from Dr ag Belt KC8 to Drag Belt KC 9 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 clean ing up of control equipment, if: (a) The visible emissions are not gr eater 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: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 32 of 47 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 ra te 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 disc harged 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 m onth. A visible emission evaluation will be performed on the exhaust of each ope rating 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 sh all immediately inspect and/ or repair the emissions unit and related equipment until no vi sible emissions are observed base d 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 measuremen t shows opacity less than 20 percent, the opacity shall be
recorded and no further action will be n ecessary 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 fo r 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 ac tion will be necessary for this monthly inspection. (3) If correction maintenance cannot be completed w ithin 48 hours, the Permitt ee shall report to the Department excess emissions in acco rdance with COMAR 26.11.01.07C.
[COMAR 26.11.03.06C]

B. The Permittee shall comply with a nd update the preventative maintenan ce plan for each dust collector that describes the maintenance activity and time schedul e 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 c opy 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 ta ken 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 preven tative maintenance plan for
each dust collector that describes the maintenance activity and time sc hedule for completing each activity.

7A. Finish Mill System - Registration #7-0111– Fugitive Emissions (Subject to 40 CFR Part 60, Subpart F) The following equipment we re 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 Be lt 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 taki ng 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 particulat e 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 whethe r the reasonable precautions need toPART 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 mi nimum 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 impl ementation 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 Perm ittee is required to perform a monthly observation and inspection to prevent any violations of NSPS visible emissions re quirements and maintain records of the results. Inspections are required at times when weather conditions are favorable for par ticulate 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 we re 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; Tr ansfer 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 M ill 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 Silo s, Loadout to Truck and Rail
EBS814 EBS814 -Bulk Cement Silo s, 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 clean ing up of control equipment, if: (a) The visible emissions are not gr eater 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 w ill be evaluated at the door(s) of the building. A visible emission evaluation will be performed on each operating source, using EPA Re ference 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 emissi ons are observed based on EPA Re ference 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 measuremen t shows opacity less than 10 percent, the opacity shall be
recorded and no further action will be n ecessary 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 re place 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 fo r 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 ac tion will be necessary for this monthly inspection. (3) If correction maintenance cannot be completed within 48 hours, the Perm ittee shall report to the Department excess emissions in acco rdance with COMAR 26.11.01.07C. [COMAR 26.11.03.06C]

B1. The exhaust gas from each equipmen t 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 maintenan ce plan for each dust collector that describes the maintenance activity and time schedul e for completing each activ ity. 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 c opy 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 preven tative maintenance plan for
each dust collector that describes the maintenance activity and time sc hedule 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 ow ner 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 l eak tight and automatically close upon disconnection. [COMAR 26.11.03.06C]

Record Keeping Requirements The Permittee shall maintain records of the inspection resu lts, 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

NonePART 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 degreasi ng material that exceeds the following vapor pressure of 1 mm Hg (0.019 psia) at 20 o 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, a nd 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 writi ng, 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—A pplicability 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 DeterminationPART 70 OPERATING PERMIT FACT SHEET ST. LAWRENCE CEMENT, INC.
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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) Constr uction/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) Approva l 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 AnalysisPART 70 OPERATING PERMIT FACT SHEET ST. LAWRENCE CEMENT, INC.
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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 requi rements 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 Notif ication not required fo r 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 Keep ing PS-8A applies instead of requirements for

THC CEM 63.10(c)(10) through (15) Additional CMS Record Keeping 63.10(d)(1) General Reporting Requirements 63.10(d)(2) Performance Test Results 63.10(d)(3) Opacity or VE Observations 63.10(d)(4) Progress Reports 63.10(d)(5) Startup, Shutdown, Malfunction Reports 63.10(e)(1) and (e)(2) Additional CMS Reports 63.10(e)(3) Excess Emissions and CMS Performance Reports Exceedances are defined in subpart LLL

63.10(f) Waiver for Record Keeping/ Reporting 63.12(a)-(c) State Author ity and Delegations 63.13(a)-(c) State/Re gional Addresses 63.14(a) and (b) Incorporation by Reference 63.15(a) and (b) Availability of InformationPART 70 OPERATING PERMIT FACT SHEET ST. LAWRENCE CEMENT, INC.
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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 star tup, shutdown, a nd 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 th at 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 re quirement 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 consis t of three separate runs; each run sh all be conducted under the conditions
that exist when the aff ected source is operating under representa tive performance cond itions 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 ds cf). The concentration sha ll be determined for each run and the arithmetic average of th e 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-lin e 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 cal culated for each minute of each run of the test. (4) The run average temperature must be calculated for each run, and the aver age 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 malf unction, 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 occu rrence in accordance with the startup, shutdown, and malfuncti on plan. To the extent that anPART 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 consis tent 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, shut down, 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 fo r 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 keep ing 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 dura tion of each startup, shutdown, or malfunction of operation and each malfunction of the air pollution control and monitoring equipmen t. Furthermore, the Permittee shall confirm that action taken during the relevant reporting peri od 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 repor t 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 w ith §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 st artup, shutdown, and malfunction plan and shall make the plan available upon request for inspec tion and copying by the Admini strator. 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, shutdow n, and malfunction plan, and must make each su ch 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 startu p, shutdown, and malfunction plan th e affected source ceases operation or is otherw ise 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 i s no longer subject to this part and shall make the plan availa ble 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 sha ll 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 star tup, 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 circ umstances of the event, the reasons for not following the startup, shutdown, or malfunc tion plan, and whether any excess emissions and/or parameter monitoring exceedances are be lieved 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 47PART 70 OPERATING PERMIT FACT SHEET ST. LAWRENCE CEMENT, INC.
1260 SECURITY ROAD
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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 o ccasional cleaning of control equipment if:

(a) The visible emissions are not great er 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.
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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 (incl uding 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 SECTIO N -ONLY ENFORCEABLE SECTIONSt. Lawrence Cement, Inc.’s Portland cement plant in Hagerstown, Maryland is subject to the following S tate-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 us e 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 S tate-only regulations as long as the Permittee complies with the applicable federally enforceable requ irements. There is no n eed to require additional co mpliance 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 (C OMAR) 26.11.03.11 states the following:

If the Department denies a Part 70 permit or issues it with terms and conditions that are objectionable to the app licant, 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 enclosuresKathleen Anderson, EPA Region IIIBcc: Shannon, George B , DaveST. 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............................. 31ST. 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 ............................................. 73ST. 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 Coun ty, Maryland plant. The Wash ington County site quarries limestone, operates a limestone crushing plant, a raw mill system, a ceme nt 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 Emission s 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 Fug itive 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 1970ST. 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 Emission s 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 Emi ssions Unit Description Date of
Installation Fugitive Emissions
EAR8 Transfer from Raw Material Bins to Belt Feeders, then to (Shown in Figure 1) 1970ST. 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 Emi ssions 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 1970ST. 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 Emi ssions 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 Emission s 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 - R egistration #7-0109 0108 ( Subject to MACT for D/F )
Emissions Unit
Number Emissions Unit Name Emi ssions Unit Description Date of
Installation KB13 Kiln Discharging through Multicyclone
KB19 and ESP KB21 – EKB22 1970

5. Clinker Cooler - R egistration #7-0109 ( Not Subject to MACT and NSPS requirements)
Emissions Unit
Number Emissions Unit Name Emi ssions 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) - R egistration #7-0109 ( Not Subject to MACT and NSPS)
Emissions Unit
Number Emissions Unit Name Emi ssions Unit Description Date of
Installation Fugitive Emissions
EKB37-F Transfer from
ESP/Multiclone to Bucket Fugitive Emissions 1970ST. 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 Emi ssions 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 - Registra tion #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 Emi ssions 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 1976ST. 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 Emi ssions 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 Emi ssions 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 sh all have the meanings established under COMAR
26.11.01 and .02 unless otherwis e stated in this permit.

2. ACRONYMSST. 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 Availabl e 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
NO
x Nitrogen Oxides
NSPS New Source Performance Standards
NSR New Source Review OTR Ozone Transport Region
PM Particulate Matter
PM10 Particulate Matter with Nominal Ae rodynamic 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
SO 2 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 auto matically 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 righ t 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 Perm ittee 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 late r 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 afte r 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 s ubmitted in an application shall be considered part of the public record and available fo r 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, th e 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 pr ovide 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 reope ned and revised for cause. The filing of an application by the Permittee for a permit revision or renewal; or a notificat ion 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 so urce 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, a nd 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 PERMITST. 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 Pa rt 70 permit except as provided in COMAR
26.11.03.15.

11. REVISION OF PART 70 PE RMITS – GENERAL CONDITIONS

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

a. The Permittee shall submit an 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 ex cept that the application for a revision need include only information listed that is re lated to the proposed change to the source and revision to the permit. This informati on 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 approve d 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 modi fication 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 th e federally enforceable provisions in the permit that does not qualify as an ad ministrative permit amendment under COMAR 26.11.03.15 or a minor permit modificati on as defined under COMAR 26.11.03.16.

b. This permit does not preclude the Permittee fr om 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 un it within the source. Air pollution controlST. 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 leve l 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, in cluding the requirements for applications, public participation, a nd review by affected states and EPA, except:

(1) An application need include only inform ation pertaining to the proposed change
to the source and modification of this permit, including a description of the change and modification, and any new a pplicable requirements of the Clean Air Act that will apply if the change occurs;

(2) Public participation, and re view by affected states and EPA, is limited to only the application and those federally enforceab le 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 otherwis e 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-c onstruct and approvals required by COMAR
26.11.02.

f. The Permittee shall not make a significant perm it modification that results in a violation of any applicable requireme nt 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 De partment, 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 pe rmit 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 app licable 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 fe derally 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 fede rally enforceable emissions standard,

(b) Source specific determination for tempor ary 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 corresp onding underlying applicable requirement of the Clean Air Act, but that the Perm ittee has assumed to avoid an applicable requirement to which the source woul d otherwise be subject, including:

(a) A federally enforceable emissions standa rd applied to the source pursuant to
COMAR 26.11.02.03 to avoid classificati on as a Title I modification; and

(b) An alternative emissions standard app lied to an emissions unit pursuant to regulations promulgated under Secti on 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 requiremen ts 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, th e 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 pe rmits-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 pe rmit 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 duri ng this time, the terms and conditions of both this permit and the applicati on 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 re gulations 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 resp onsible 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, addre ss, 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 ope rational control of a source for which the Department determines that no other revi sion to the permit is necessary and is documented as per COMAR 26.11.03.15B(4);

(5) Incorporates into this permit the re quirements from preconstruction review permits or approvals issued by the De partment 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; orST. 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 ofthe application, if all permits-toconstruct or approvals otherwise requir ed 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 applie s 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 CHANG ES TO THIS SOURCE

[COMAR 26.11.03.19]

The Permittee may make off-permit changes to this facility as provided in COMAR 26.11.03.19 and in accordance with the following conditions:

a. The Permittee may make a change to this permitted facility that is not addressed or prohibited by the federally enforceable c onditions 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 requiremen ts 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 Depart ment 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 wr itten notice shall describe the change, including the date it was made, any cha nge in emissions, including the pollutantsST. 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 ar e 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 acti on 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 faci lity 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 th e 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 applicab le requirement of the Clean Air Act;

(5) The change does not violate a federally enforceable permit term or condition related to monitoring, including test me thods, 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 Pa rt 70 permit unless the Department has approved the change in writing; and

(8) This permit does not expressly prohib it 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 fro m 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 facili ty shall certify in accordance with COMAR 26.11.02.02F that the proposed change meet s the criteria for the use of on-permit changes under COMAR 26.11.03.18.

d. The Permittee shall attach a copy of each not ice 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 COMA R 26.11.03.18 are not subject to the requirements for part 70 permit revisions.

f. Upon satisfying the requirements under CO MAR 26.11.03.18, the Permittee may make the proposed change.

g. The permit shield in COMAR 26.11.03.23 doe s not apply to on-permit changes under
COMAR 26.11.03.18.

h. The Permittee is subject to enforcement acti on 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 pres cribed in Regulation .19 of COMAR 26.11.02.

b. The fee is due on and shall be paid on or be fore each 12-month anniversary date of the permit.

c. Failure to pay the annual permit fee constitu tes cause for revocation of the permit by the Department.

18. REQUIREMENTS FOR PERMIT S TO CONSTRUC T AND APPROVALS

[COMAR 26.11.02.09]

The Permittee may not construct or modify or cause to be constructed or modified any of the following sources without first obtaining, and ha ving 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 s ource, 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 Ai r 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 elementa l lead, permit to construct;

f. All stationary sources of ai r pollution, including installa tions and air pollution control equipment, except as listed in COMAR 26.11.02.10, permit to construct;

g. In the event of a conf lict between the applicab ility of (a.— e.) above and an exemption listed in COMAR 26.11.02.10, the provisi on that requires a permit applies.

h. Approval of a PSD or NSR source by the De partment 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 no t 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 ex isting permit procedures or time frames.

20. PROPERTY RIGHTS

[COMAR 26.11.03.06E(4)]

This Part 70 permit does not convey any pr operty rights of any so rt, 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 ch allenged, or any term or condition deemed unenforceable, the remainder of the requirement s 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 agenci es, upon presentation of credentials or other documents as may be required by law, to:

a. Enter at a reasonable time without delay a nd without prior notification the Permittee’s property where a Part 70 source is located, emissions-related activ ity 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 fac ility subject to the permit and all related monitoring systems, air pollution control eq uipment, and practices or operations regulated or required by the permit; and

d. Sample or monitor any substances or paramete rs 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 revi sing 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 Ai r Act, and/or the Environmental Article Title 2 of the Annotated Code of Maryla nd 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, A nnotated 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 RED UCE ACTIVITY NOT A DEFENSE

[COMAR 26.11.03.06E(2)]

The need to halt or reduce activ ity in order to comply with th e 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 articl e, machine, equipment or other contrivance, the use of which, without resulting in a reducti on in the total weight of emissions, conceals or
dilutes emissions which would otherwise constitu te 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 Secti on 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 requi rement 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 buildi ng, its appurtenances, or a road to be used, constructed, altered, repaired, or demolis hed 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, th e Permittee shall not cause or permit an open fire from June 1 through August 31 of any cal endar year. Prior to any open burning, the Permittee shall request and receiv e approval from the Department.

3. AIR POLLUTION EPISODE

[COMAR 26.11.05.04]

When requested by the Department, the Permitte e shall prepare in writing standby emissions reduction plans, consistent w ith good industrial practice and safe operating procedures, for reducing emissions creating air pollution during periods of Aler t, 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 follo wing 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 requirement s that could endanger human health or the environment, by orally notifying the De partment 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 emi ssions that are expected to last for one hour or longer by orally notif ying the Department of the onset and termination of the

occurrence;

c. When requested by the Department the Permittee shall report all deviations from permit conditions, including those 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 re port 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 pr event recurrence of the deviation;

d. The Permittee shall submit to the Departme nt semi-annual monitoring reports that confirm that all required monitoring was perf ormed, 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 descripti on of the deviation, the dates and times of onset and termination, identification of th e 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 Perm ittee 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 Pa rt 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 requirement s 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 REQUIREMENTSST. 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 a nd described below or other test methods submitted to and approved by the Department.

Reference documents of the test methods appr oved 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 Source s”, (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 emission s 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 th e year following the year for which the certification is required;

b. The individual making the certification shall cer tify that the information is accurate to
the individual’s best knowle dge. 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 necessa ry 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 calibra tion 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 wo rk 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 conditi on 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 reporte d to the Department that is necessary to determine the compliance status of the Permittee with this permit.

b. The Permittee shall submit the compliance certi fication reports to the Department and EPA simultaneously.

10. CERTIFICATION BY RESPONSIBLE OFFICIAL

[COMAR 26.11.02.02F]

All application forms, reports, and complian ce 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 al l attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the info rmation 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 aw are that there are significant penalties for submitting false information, including the possib ility 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 conditi ons existing at the time thatsamples 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 mon itoring 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 c ontinuous 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 conform ity 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 sta ndards 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, se rvice, repair, or disposal shall comply with the prohibitions and require d 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, repa irs or disposal of appliances shall be certified by an approved technician ce rtification program pursuant to 40 CFR § 82.161.

d. Persons performing maintenance, service, repair s or disposal of app liances shall certify with the Administrator pursuant to 40 CFR § 82.162.

e. Persons disposing of small ap pliances, MVACS, and MVAC- like appliances as defined in 40 CFR 82.152, shall comply with reco rd keeping requirements pursuant to 40 CFR § 82.166.

f. Persons owning commercial or industrial pro cess refrigeration equipment shall comply with the leak repair requirements pursuant to 40 CFR § 82.156.

g. Owners/operators of appliances normally co ntaining 50 or more pounds of refrigerant shall keep records of refrigerant purchased and added to such app liances pursuant to 40
CFR § 82.166.

16. ACID RAIN PERMIT

Not applicableST. 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 th e 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, reco rd 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, mon itoring, 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 F eeder Q28.1; from Feeder Q28.1 to Belt Q27 EARMH3 Raw Material Stockpile Truck Unlo ading 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 sour ce without taking reasonable precautions to prevent particulate matter from becoming airborne. (2) COMAR 26.11.06.03D - Particulate matter from Materi als 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, construc ted, altered, repaired, or demolished without taking reasonable precautio ns 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 insp ection of the facility to observe each emissions unit to verify that reasonable precau tions are being implemented and to determine whether the reasonable precautions need to be re vised. The inspection shall be conducted at a minimum of once per month at times when th e effectiveness of the reasonable precautions
can be assessed. [COMAR 26.11.03.06C] Record Keeping Requirements : The Permittee shall maintain the best manage ment plan and records of the dates and inspection results for at least five (5) years and make them available to the Department upon
request. [COMAR 26.11.03.06C] Reporting Requirements : None A permit shield shall cover the applicable require ments 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 di scharged into the atmosphere from any transfer point on belt conveyors or from other affected facility any fugitive emissions which exhibit great er 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 unconfin ed 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, it s appurtenances, or a road to be used, constructed, altered, repaired, or demo lished without taking reasonable precautions to prevent particulate matter from becoming airborne. Testing Requirements : None Monitoring Requirements: A. The Permittee will conduct a walk-through in spection of the facility once per calendar month. Fugitive emission sources inside build ings will be evaluated at the door(s) of the building. A visible emission evaluation w ill 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 inspecti on 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 emi ssions 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 insp ection of the facility to observe each emissions unit to verify that reasonable precautions are being implemented and to determine whether the reasonable precautions ne ed 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 mana gement 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 require ments 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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 discha rge of particulate matter emissions from confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the follo wing 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 proce ss 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 in spection 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 inspecti on 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 emi ssions 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 shal l 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 requestST. 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack into proper operation. [COMAR 26.11.03.06C] Reporting Requirements
None A permit shield shall cover the applicable requireme nts 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 sour ce without taking reasonable precautions to prevent particulate matter from becoming airborne. (2) COMAR 26.11.06.03D - Particulate matter fr om 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, construc ted, altered, repaired, or demolished without taking reasonable precautio ns 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 insp ection of the facility to observe each emissions unit to verify that reasonable precau tions are being implemented and to determine whether the reasonable precautions need to be re vised. The inspection shall be conducted at a minimum of once per month at times when th e 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 manage ment 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 requirem ents 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 Tr ansfer 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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 discha rge 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 proce ss weight per hour exceeds 60,000 pounds, theST. 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 th at 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 in spection 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 inspecti on 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 emi ssions 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 imme diately 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 observat ions 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 inspec tion log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 maintenan ce 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack into proper operation. [COMAR 26.11.03.06C] Reporting Requirements
None A permit shield shall cover the applicable requireme nts 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 Discha rge 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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 discha rge of particulate matter emissions from confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the follo wing 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 proce ss 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 in spection of the facility once per week. A visible emission evaluation will be performe d on the exhaust of each operating source, using EPA Reference Method 22 for one-minut e period. If no visible emissions are observed, such conditions will be noted in th e 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 st ill 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this weekly inspection. (3) If correction maintenance cannot be comp leted 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 sha ll 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 main tenance plan for the
dust collector that describes the maintenan ce 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack into proper operation. [COMAR 26.11.03.06C] Reporting Requirements
None A permit shield shall cover the applicable requireme nts 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 sour ce without taking reasonable precautions to prevent particulate matter from becoming airborne. (2) COMAR 26.11.06.03D - Particulate matter from Materi als 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, construc ted, altered, repaired, or demolished without taking reasonable precautio ns 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 insp ection of the facility to observe each emissions unit to verify that reasonable precau tions are being implemented and to determine whether the reasonable precautions need to be re vised. The inspection shall be conducted at a minimum of once per month at times when th e 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 requireme nts 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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 discha rge of particulate matter emissions from confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the follo wing 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 proce ss 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 RequirementsST. 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 in spection 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 st ill 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 upda te the preventative maintenance plan for each
dust collector that describes the maintenan ce 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack into proper operation. [COMAR 26.11.03.06C] Reporting RequirementsST. 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 requireme nts of the Clean Air Act that are listed in the
table above.

4. Kiln System - R egistration #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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 discha rge of particulate matter emissions from confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the follo wing 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 proce ss 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 th e particulate matter air pollution control device is 204°C (400° (F) or less.

D. NOx EmissionsST. 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 m eet 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 th e sulfur dioxide co ncentration 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 c ontent of sulfuric aci d, sulfur trioxide, or any combination not to exceed 70 milligra ms reported as sulfuric acid per cubic meter of gas corrected to 7 percent oxygen.

F. When burning scrap tires as an alternate fu el in the kiln, the Permittee shall not allow: (1) the feed rate of sc rap tires to exceed 3.8 tons per hour; and (2) the temperature between the preheating a nd calcining zones of the kiln to fall below 1,400 o F. [Permit to Construct 043-7-0 109M issued on November 21, 2002] Testing Requirements A, D, E, and F None

B. The Permittee shall conduct a particulate ma tter 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 pr ocess 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 cal culated 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 applicab le 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 Ad ministration Technical Memorandum 90-01 “Continuous Emission Monitoring (CEM) Po licies 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 sha ll 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 ope ration 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 sha ll 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 upda te the written operations and maintenance plan, which includes the following information: (1) Procedures for proper operation and ma intenance of the affected source and air pollution control devices in order to meet the emissions limits and operating limits of §63.1344; (2) Corrective actions to be take n when required by §63.1350(e); and (3) Procedures to be used to during an in spection 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 operat e 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 Nati onal Institute of Standards and Technology calibrated reference thermocouple-potentio meter system or alternate reference, subject to approval by the Administrator. (3) The three-hour rolling average temperat ure shall be calculated as the average of 180 successive one-minute average temperatures. (4) The period of time when one-minute aver ages are not available shall be ignored when calculating three-hour rolling averages. When one-minute averages become available, the first one-mi nute average is added to th e 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 cal culation 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 SO 2 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 reco rd not less than four equally spaced data points per hour and to automatically re duce 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 coll ected from both testing and/or monitoring requirements for at least five years followi ng the date of each occu rrence, measurement, maintenance, corrective action, report or re cord. At a minimum, the most recent two years of data shall be retained on site; the remaining three years of data may be retainedST. 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 microfil m, 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 followi ng the date of each occu rrence, measurement, maintenance, corrective action, report or re cord. 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 microfil m, 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 a nd 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 dow ntime including record s 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 60 th 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 prot ocol 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 60 th day following the completion of the performance test. [40 CFR §63.1354(b)(1)] & [40 CFR §63.10(d)(2)] (2) At least 30 days prior to each stack emissions testing, the Permittee shall submit to the Department a stack test prot ocol 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 da ta 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 requireme nts 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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 discha rge of particulate matter emissions from confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the follo wing 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 proce ss 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 ma tter emissions test at once every 5 years inST. 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 pr ocess 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 in spection of the facility once per week. A visible emission evaluation will be performe d on the exhaust of each operating source, using EPA Reference Method 22 for one-minut e period. If no visible emissions are observed, such conditions will be noted in th e 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 st ill 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this weekly inspection. (3) If correction maintenance cannot be comp leted 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 sha ll 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 main tenance plan for the
dust collector that describes the maintenan ce 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 RequirementsST. 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack 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 60 th 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 prot ocol for review and approval. [COMAR 26.11.03.06C] A permit shield shall cover the applicable requireme nts of the Clean Air Act that are listed in the
table above.

6A. Cement Kiln System ( Not Including K iln 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 Ki ck 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 sour ce without taking reasonable precautions to prevent particulate matter from becoming airborne. (2) COMAR 26.11.06.03D - Particulate matter from Materi als 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, construc ted, altered, repaired, or demolished without taking reasonable precautio ns 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 insp ection of the facility to observe each emissions unit to verify that reasonable precau tions are being implemented and to determine whether the reasonable precautions need to be re vised. The inspection shall be conducted at a minimum of once per month at times when th e 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 requireme nts 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 Rec overy to Bucket Elevator KB44
EKB37-S EKB37 -Transfer from CKD Buck et 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 occasi onal cleaning up of control equipment, if: (1) The visible emissions are not grea ter 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 discha rge of particulate matter emissions from confined sources into the atmosphere in excess of the limit determined from the Table 1 or determined by the follo wing 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 pro cess weight per hour exceeds 60,000 pounds (27,200 kilograms), the maximum allowable wei ght of particulate ma tter discharged per hour may exceed that calculated by the e quation shown in (1) provided that the concentration of particulate matter in the gase s 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 insp ection of the facility once per month. A visible emission evaluation will be performe d on the exhaust of each operating source, using EPA Reference Method 22 for one-minut e period. If no visible emissions are observed, such conditions will be noted in th e 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 st ill 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 mainte nance plan for each
dust collector that describes the maintenan ce 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack into proper operation. [COMAR 26.11.03.06C] Reporting Requirements
None A permit shield shall cover the applicable requireme nts 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 Conve yor 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 Be lt Conveyor F54 and then to Finish Mill
EF60 Transfer from Air Slide F 61-11 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 discha rged into the atmosphere from any affected facility other than kiln a nd 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 reasonableST. 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, it s appurtenances, or a road to be used, constructed, altered, repaired, or demo lished without taking reasonable precautions to prevent particulate matter from becoming airborne. Testing Requirements
None Monitoring Requirements A. The Permittee will conduct a walk-through in spection of the facility once per calendar month. Fugitive emission sources inside build ings will be evaluated at the door(s) of the building. A visible emission evaluation w ill be performed on each operating source, using EPA Reference Method 22 for one-minut e period. If no visible emissions are observed, such conditions will be noted in th e 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 st ill 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 insp ection of the facility to observe each emissions unit to verify that reasonable precautions are being implemented and to determine whether the reasonable precautions ne ed to be revised. The inspection shall be conducted at a minimum of once per month at times when the effectiveness of theST. 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 mana gement 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 requireme nts of the Clean Air Act that are listed in the
table above.

7B. Finish Mill System - Re gistration #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 Silo s, Loadout to Truck and Rail
EBS814 EBS814 -Bulk Cement Silo s, 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 occasi onal cleaning up of control equipment, if: (a) The visible emissions are not gr eater 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 construc ted 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 in spection of the facility once per calendar month. Fugitive emission sources inside build ings will be evaluated at the door(s) of the building. A visible emission evaluation w ill be performed on each operating source, using EPA Reference Method 22 for one-minut e period. If no visible emissions are observed, such conditions will be noted in th e 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 st ill 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 imme diately 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 observat ions 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 insp ection log and no further action will be necessary for this monthly inspection. (3) If correction maintenance cannot be comp leted 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 sha ll 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 mainte nance plan for each
dust collector that describes the maintenan ce 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 descri ption of maintenance activity performed.
The Permittee shall maintain records of the baghouse malfun ctions and the corrective actions taken to bring it b ack into proper operation. [COMAR 26.11.03.06C] Reporting Requirements
None A permit shield shall cover the applicable requireme nts 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 Recove ry. An owner or operator of a gasoline
tank truck or an owner of a stati onary storage tank subj ect to this regulation may not cause or permit gasoline to be loaded into a stationa ry tank unless the loading system is equipped with a vapor balance line that is proper ly 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 r ecords of the inspec tion 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 requireme nts 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 20 o C; and (2) COMAR 26.11.19.09D(4) - A person may not use a haloge nated substance that is a VOC in any cold degreasing. Testing Requirements
None Monitoring Requirements (1) The Permittee shall implement good operati ng practices including covers (including water covers), lids, or othe r 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 establis hed 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 mainta ined at the facility and made available fo r review by the Department upon request. [COMAR 26.11.19.09D(3)(d)] Reporting Requirements
None A permit shield shall cover the applicable requireme nts 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 CommentST. 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) Extens ions, Notifications 63.1(e) Applicability of Permit Program 63.2 Definitions Additional Definitions in §63.1341 63.3(a) through (c) Units and Abbreviations 63.4(a)(1) through (a)(3) Prohibited Activities

63.4(a)(5) Compliance Date 63.4(b)and (c) Circumvention, Severability 63.5(a)(1) and (2) Construction/Reconstruction 63.5(b)(1) Compliance Dates 63.5(b)(3) through (6) Construction Approval Applicability 63.5(d)(1) through (4) Approval of Construction/
Reconstruction 63.5(e) Approval of Construction/
Reconstruction 63.5(f)(1) and (2) Approval of Construction/
Reconstruction 63.6(a) Compliance for Standards and
Maintenance 63.6(b)(1) through (5) Compliance Dates 63.6(b)(7) Compliance Dates 63.6(c)(1) and (2) Compliance Dates 63.6(c)(5) Compliance Dates 63.6(e)(1) and (e)(2) Oper ation & 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 StandardsST. 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/Ma intenance 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 Add itional 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 NotificationsST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 65 of 73 63.9(h)(1) through (h)(3) Notification of Compliance
Status 63.9(h)(5) and (h)(6) Notif ication 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 star tup, shutdown, and malf unction; a program of corrective action for malfunctioning process; and air pollution c ontrol and monitoring equipment used to comply with the relevant standard.

40 CFR §63.6(e)(3)(viii) which states that the Pe rmittee may periodically revise the startup, shutdown, and malfunction plan for the aff ected source as necessary to satisfy the requirements of this part or to reflect change s in equipment or procedures at the affectedST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 66 of 73 source. Unless the permitting authority provid es otherwise, the Permittee may make such revisions to the startup, shutdown, and ma lfunction plan without prior approval by the Administrator or the permitting authority. Howe ver, each revision to a startup, shutdown, and malfunction plan must be reported in the se miannual report required by §63.10(d)(5). If the startup, shutdown, and malf unction plan fails to address or inadequately addresses an
event that meets the characteristics of a malf unction 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 malfunc tion 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 simila r malfunctions of process or air pollution control a nd monitoring equipment. In the event that the Permittee makes any revision to the startup, shutdown, and malf unction plan which alte rs the scope of the
activities at the source which are deemed to be a startup, shutdown, and malfunction, or otherwise modifies the appli cability of any emission limit, work practice requirement, or other requirement in a standard established under this part, th e 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 pl ans to undertake a change in operations that may adversely affect compliance with an applicab le D/F standard under th is 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 emissi ons to the levels required by the relevant standards, i.e., meet the emission standard or comply with the st art-up, shutdown, and malfunction plan. Malfunctions shall be corr ected as soon as practicable after their occurrence in accordance with the startup, sh utdown, and malfunction plan. To the extent that an unexpected event arises during a st art-up, shutdown, and ma lfunction, the Permittee shall comply by minimizing emissions during such a startup, shutdown, or malfunction event consistent with safety and good air pollution c ontrol 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 malfunc tion) 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 demons trate the procedures specified in the plan were followed. These records may take the fo rm 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 Perm ittee shall keep records of these events asST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 67 of 73 specified in § 63.10(b), including records of the occu rrence and duration of each startup, shutdown, or malfunction of operation and each malfunction of the air pollution control and monitoring equipment. Furthermore, th e Permittee shall confirm that action taken during the relevant reporting period during pe riods of start-up, shutdown, or malfunction
were consistent with the affected source’s st artup, shutdown, and malfunction plan in the semiannual (or more frequent) startup, s hutdown, and malfuncti on report required in §63.10(d)(5).

If an action taken by the Permittee during a star tup, shutdown, or malfunction (including an action taken to correct a malfunction) is not cons istent 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 sh all record the actions taken for that event and shall report such actions within 2 worki ng 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 th e startup, shutdown, and malfunction plan is subsequently revised, the Permittee shall mainta in at the affected source each previous (i.e., superseded) version of the startup, shutdow n, and malfunction plan, and must make each such previous version available for inspect ion and copying by the Administrator for a period of 5 years after revision of the plan. If at any time after a doption 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 availa ble 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 consis tent 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 re quired if a startup, shutdown, or malfunction occurred during the reporting pe riod. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports.

Any time an action taken by the Permittee dur ing a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, or malfunction plan, th e 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 PermitteeST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 68 of 73 explaining the circumstances of the event, the reasons for not following the startup, shutdown, or malfunction plan, and whethe r 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 requireme nts 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

Page 69 of 73 SECTION V INSIGNIFICANT ACTIVITIES

This section provides a list of insignificant emissi ons units that were reported in the Title V permit application. The applicable Clean Air Act requir ements, if any, are list ed 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 establ ishes that the Permittee may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an un combined form, which is greater than 20 percent opacity.

Exceptions: COMAR 26.11.09.05A(2) doe s 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 esta blishes that the Permittee may not burn, sell, or make available for sale a ny 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 engi nes with an output less than 500 brake horsepower (373 kilowatts) and which ar e 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, great er 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.ST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 70 of 73 (C) Exceptions:

(i) COMAR 26.11.09.05B(2) does not apply for a period of 2 consecutive minutes after a peri od 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 star t-up and warm-up for the following maximum periods:

(a) Engines that are idled continuous ly 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 pe rformed by qualified mechanics.

(4) X Space heaters utilizing dir ect 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), whic h requires that the Permittee implement good operating practices designed to minimize spills and evaporation of VOC degreasing materi al. These practices, which shall be established in writing and displayed such that they are clearly visible to operators, shall include co vers (including water covers), lids, or other methods of minimizing ev aporative losses, and reducing the time and frequency during which parts are cleaned;

(c) COMAR 26.11.19.09D(4), which prohib its 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; andST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 71 of 73 (b) Written descriptions of good operating practices designed to minimize spills and evaporation of VOC degreasing materials.

(6) X Equipment for drilling, carving, cutti ng, routing, turning, sawing, planing, spindle sanding, or disc sanding of wood or wood products;

(7) X Brazing, soldering, or welding equi pment, and cutting torches related to manufacturing and construction activiti es 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 car e provided at the facility, including
related activities such as sterilizati on and medicine preparation used in support of a manufacturi ng 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 re quirements of Title VI of the Clean Air Act;

(13) X Natural draft hoods or natural draft ve ntilators 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 add itional pages as necessary:ST. LAWRENCE CEMENT COMPANY
1260 SECURITY ROAD HAGERSTOWN, MARYLAND 21742
PART 70 OPERATING PERMIT NO. 24-043-00008

Page 72 of 73 (15) any other emissions unit, not listed in this section, with a potential to emit less than
the “de minimus” levels listed in COMA R 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

Page 73 of 73 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, wh ich 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 th e discharge of toxi c 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 inva lidated 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 Re gulation .10D(1) of this chapter.”