Federal Operating Permit

Article 1

This permit is based upon the requirements of Title V of the Federal Clean Air Act and Chapter

80, Article 1 of the Commonwealth of Virginia Regulations for the Control and Abatement of

Air Pollution. Until such time as this permit is reopened and revised, modified, revoked,

terminated or expires, the permittee is authorized to operate in accordance with the terms and

conditions contained herein. This permit is issued under the authority of Title 10.1, Chapter 13,

§10.1-1322 of the Air Pollution Control Law of Virginia. This permit is issued consistent with

the Administrative Process Act, and 9 VAC 5-80-50 through 9 VAC 5-80-300 of the State Air

Pollution Control Board Regulations for the Control and Abatement of Air Pollution of the

Commonwealth of Virginia.

Authorization to operate a Stationary Source of Air Pollution as described in this permit is

hereby granted to:

Permittee Name: Roanoke Cement Company Registration Number: 20232

Facility Name: Roanoke Cement Company AFS ID Number: 51-023-0003

Facility Location: 555 Catawba Road

Botetourt County, Virginia

Permit Number: VA-20232

January 1, 2004

Effective Date

December 31, 2008

Expiration Date

December 1, 2003

Robert G. Burnley Signature Date

Director, Department of Environmental Quality

Table of Contents, 4 pages

Permit, 56 pages
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 2 of 57

Table of Contents

I. FACILITY INFORMATION................................................................................................ 6

II. EMISSION UNITS................................................................................................................. 7

III. FUEL BURNING EQUIPMENT REQUIREMENTS – NA......................................... 11

IV. PROCESS EQUIPMENT REQUIREMENTS – RAW MATERIAL PROCESSING11

A. LIMITATIONS........................................................................................................................ 11

B. MONITORING ....................................................................................................................... 12

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 12

D. TESTING............................................................................................................................... 12

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 13

V. PROCESS EQUIPMENT REQUIREMENTS – KILN FEED SYSTEM & RECYCLE

DUST............................................................................................................................................ 13

A. LIMITATIONS........................................................................................................................ 13

B. MONITORING ....................................................................................................................... 14

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 14

D. TESTING............................................................................................................................... 15

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 15

VI. PROCESS EQUIPMENT REQUIREMENTS – NO. 5 KILN SYSTEM.................... 15

A. LIMITATIONS........................................................................................................................ 15

B. MONITORING ....................................................................................................................... 20

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 23

D. TESTING............................................................................................................................... 23

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 24

VII. PROCESS EQUIPMENT REQUIREMENTS – CLINKER COOLER...................... 24

A. LIMITATIONS........................................................................................................................ 24

B. MONITORING ....................................................................................................................... 25

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 26

D. TESTING............................................................................................................................... 26

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 26

VIII. PROCESS EQUIPMENT REQUIREMENTS – COAL/COKE GRINDING &

HANDLING SYSTEM............................................................................................................... 26

A. LIMITATIONS........................................................................................................................ 26

B. MONITORING ....................................................................................................................... 27

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 28

D. TESTING............................................................................................................................... 28

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 28
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 3 of 57

IX. PROCESS EQUIPMENT REQUIREMENTS – CLINKER HANDLING

&STORAGE SYSTEM.............................................................................................................. 28

A. LIMITATIONS........................................................................................................................ 28

B. MONITORING ....................................................................................................................... 29

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 30

D. TESTING............................................................................................................................... 30

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 30

X. PROCESS EQUIPMENT REQUIREMENTS – CLINKER GRINDING SYSTEM.... 30

A. LIMITATIONS........................................................................................................................ 30

B. MONITORING ....................................................................................................................... 31

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 32

D. TESTING............................................................................................................................... 32

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 32

XI. PROCESS EQUIPMENT REQUIREMENTS – CEMENT STORAGE SILO

SYSTEM...................................................................................................................................... 32

A. LIMITATIONS........................................................................................................................ 32

B. MONITORING ....................................................................................................................... 33

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 34

D. TESTING............................................................................................................................... 34

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 34

XII. PROCESS EQUIPMENT REQUIREMENTS – CEMENT BULK LOADOUT

SYSTEM...................................................................................................................................... 34

A. LIMITATIONS........................................................................................................................ 34

B. MONITORING ....................................................................................................................... 35

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 36

D. TESTING............................................................................................................................... 36

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 36

XIII. PROCESS EQUIPMENT REQUIREMENTS – CEMENT BAGGING/PACKING

SYSTEM...................................................................................................................................... 36

A. LIMITATIONS........................................................................................................................ 36

B. MONITORING ....................................................................................................................... 37

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 38

D. TESTING............................................................................................................................... 38

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 38

XIV. PROCESS EQUIPMENT REQUIREMENTS – WASTE DUST STORAGE AND

HANDLING SYSTEM............................................................................................................... 38

A. LIMITATIONS........................................................................................................................ 38

B. MONITORING ....................................................................................................................... 39

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 40

D. TESTING............................................................................................................................... 40
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 4 of 57

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 40

XV. PROCESS EQUIPMENT REQUIREMENTS – STORAGE GALLERY .................. 40

A. LIMITATIONS........................................................................................................................ 40

B. MONITORING ....................................................................................................................... 41

C. RECORDKEEPING (SEE FACILITY WIDE CONDITIONS)......................................................... 42

D. TESTING............................................................................................................................... 42

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 42

XVI. FACILITY WIDE CONDITIONS............................................................................... 42

A. LIMITATIONS........................................................................................................................ 42

B. MONITORING ....................................................................................................................... 42

C. RECORDKEEPING.................................................................................................................. 43

D. TESTING............................................................................................................................... 44

E. REPORTING (SEE GENERAL CONDITIONS)........................................................................... 44

XVII. INSIGNIFICANT EMISSION UNITS........................................................................ 44

XVIII. COMPLIANCE PLAN - NA ...................................................................................... 45

XIX. PERMIT SHIELD & INAPPLICABLE REQUIREMENTS.................................... 45

XX. GENERAL CONDITIONS.............................................................................................. 46

A. FEDERAL ENFORCEABILITY ................................................................................................. 46

B. PERMIT EXPIRATION ............................................................................................................ 46

C. RECORDKEEPING AND REPORTING....................................................................................... 47

D. ANNUAL COMPLIANCE CERTIFICATION ............................................................................... 48

E. PERMIT DEVIATION REPORTING........................................................................................... 49

F. FAILURE/MALFUNCTION REPORTING................................................................................... 49

G. STARTUP, SHUTDOWN, AND MALFUNCTION ........................................................................ 50

H. MALFUNCTION AS AN AFFIRMATIVE DEFENSE..................................................................... 51

I. FUGITIVE DUST EMISSION STANDARDS ............................................................................... 52

J. SEVERABILITY ..................................................................................................................... 52

K. DUTY TO COMPLY................................................................................................................ 52

L. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE ....................................................... 53

M. PERMIT MODIFICATION .................................................................................................... 53

N. PROPERTY RIGHTS ............................................................................................................... 53

O. DUTY TO SUBMIT INFORMATION.......................................................................................... 53

P. DUTY TO PAY PERMIT FEES ................................................................................................. 53

Q. ALTERNATIVE OPERATING SCENARIOS................................................................................ 54

R. INSPECTION AND ENTRY REQUIREMENTS ............................................................................ 54

S. REOPENING FOR CAUSE....................................................................................................... 54

T. PERMIT AVAILABILITY......................................................................................................... 55

U. TRANSFER OF PERMITS ........................................................................................................ 55

V. PERMIT REVOCATION OR TERMINATION FOR CAUSE ........................................................... 55

W. DUTY TO SUPPLEMENT OR CORRECT APPLICATION.......................................................... 56
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 5 of 57

X. STRATOSPHERIC OZONE PROTECTION.................................................................................. 56

Y. ASBESTOS REQUIREMENTS .................................................................................................. 56

Z. ACCIDENTAL RELEASE PREVENTION ................................................................................... 56

AA. CHANGES TO PERMITS FOR EMISSIONS TRADING.............................................................. 56

BB. EMISSIONS TRADING ........................................................................................................ 56

XXI. STATE-ONLY ENFORCEABLE REQUIREMENTS.............................................. 57
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 6 of 57

I. Facility Information

Permittee Responsible Official

Roanoke Cement John Summerbell

P.O. Box 27 President

Cloverdale, Virginia 24077

Facility Contact Person

Roanoke Cement Robert Omer

555 Catawba Road Environmental Coordinator

Botetourt County, Virginia (540) 966-1509

Registration Number: 20232

AFS Identification Number: 51-023-0003

Facility Description: SIC Code 3241 – Establishments primarily engaged in manufacturing

hydraulic cement, including portland, natural, masonry, and pozzolana cements

The facility quarries raw material, high grade limestone, low grade limestone (referred to as

shale) and clay onsite. The rock is crushed at the crushing plants and then layered in the

stacker reclaim building where a small amount of screened clay is added. The stacking

produces a homogeneous blend when it is reclaimed and sent to the raw mills. Only small

adjustments to the mix are required to produce quality cement. The raw mills then pulverize

the stone. The pulverized stone is sintered in a 6 stage preheater/precalciner dry process kiln

which is direct fired primarily with pulverized coal. The clinker from the kiln is then cooled

in the clinker cooler for handling. The clinker is ground in the finish mills and mixed with

other additives, such as gypsum. Most of the finished product is shipped by rail car. The

remainder is either bulk loaded onto trucks or bagged at the packing plant and shipped out.
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 7 of 57

II. Emission Units

Equipment to be operated consists of:

Emission

Unit ID

Stack

ID Emission Unit Description Size/RatedCapacity*

Pollution Control Device

(PCD) Description PCD ID PollutantControlled

Applicable Permit

Date

Fuel Burning Equipment - NA.

Raw Material Processing

B01-B17

B04,

B-5,

B12,

B13 &

B16

Limestone crushing &

screening 900 tph

Sly 141 type 360

Micropul

Sly 158 type 360

Micropul 1215-10-20

Micropul

2220,

2025,

2240,

2250 &

101155

PM & PM10 6/13/2003

B25-B36

B29,

B30 &

B35

Shale crushing plant 500 tph

Micropul 78-360

Micropul

Micropul

3660,

3543 &

3585

PM & PM10 6/13/2003

Kiln Feed System & Recycle Dust

C01-C16

C09,

C11,

C15,

30,

32,

31A

& 36

Rock Sampling 60 tph

Micropul 100S-8-20

Micropul 25S-8-30

Micropul 100S-8-30

Micropul 55S-8-55

Micropul 23S-8-105

Micropul 55-8-55

Micropul 25S-6-30

101956,

101960,

101979,

101980,

101287 &

101995

PM & PM10 6/13/2003

C21-C37 Limestone & additives

storage/transfer 800 tph PM & PM10 6/13/2003

C41-C47 C41 &

C45

Raw mix blending, stacker

reclaim 900 tph MicropulMicropul

101186 &

102122 PM & PM10 6/13/2003

D01-D48

D03,

D42,

D47

&

D48

Raw meal feed/proportioning 400 tph

Micropul 80-F-2

Micropul 80-F-3

Micropul 80-F-3

Micropul 100S-8-20

102944,

104908,

103908 &

102926

PM & PM10 6/13/2003

RS Raw Silos Nos. 1 - 13 165 tph PM & PM10 6/13/2003
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 8 of 57

Emission

Unit ID

Stack

ID Emission Unit Description Size/RatedCapacity*

Pollution Control Device

(PCD) Description PCD ID PollutantControlled

Applicable Permit

Date

F04-H12

G10,

G11,

73,

75,

G12B,

H02

&

63A

Homogenizing & kiln feed 320 tph

Micropul 64S-8-20

Micropul

Micropul 144S-6-20

Micropul 100S-6-20

BHA ROABAB002

Micropul

DCE DLM-V10/10F1

104968,

104967,

110002,

110990,

503205

&

63A

PM & PM10 6/13/2003

No. 5 Kiln System (alkyli bypass & inline raw mills)

E1 Main Raw mill No. 1 250 tph Environmental Elements

(ESP) E04

PM, SO2,

CO, NOx &

VOC

6/13/2003

E2 Main Raw mill No. 2 250 tph Environmental Elements

(ESP) E54

PM, SO2,

CO, NOx &

VOC

6/13/2003

K Main No. 5 precalciner Kiln 184 tph Environmental Elements

(ESP) K34

PM, SO2,

CO, NOx &

VOC

6/13/2003

Clinker Cooler

C K43 Clinker cooler 184 tph

Airpol Inc.

IF400/H2P/340-

I88130/IT/K/L2D

505300 PM & PM10 6/13/2003

Coal/Coke Grinding & Handling

S01-S86

S23,

S63,

S27,

S67,

110 &

113

Coal/Coke grinding &

handling (including coal mill

air heater)

30 tph

Micropul

Micropul

Micropul

Micropul

Micropul 100S-8-20

Micropul36S504240,

504340,

504265,

504365,

205912 &

504182

PM & PM10 6/13/2003

Clinker Storage & Conveying
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 9 of 57

Emission

Unit ID

Stack

ID Emission Unit Description Size/RatedCapacity*

Pollution Control Device

(PCD) Description PCD ID PollutantControlled

Applicable Permit

Date

L01-M52

L02,

L27,

L31,

M55

&

M57

Clinker Storage & conveying 184 tph

Micropul

Micropul 80S-12-20A

Micropul

Dalimatic V45/15M

Micropul 64S-6-20

506107,

520196,

506112,

506125

&

506165

PM & PM10 6/13/2003

Clinker Grinding

FM5 501 &

502 Finish grinding mill No. 5 20 tph Norfelt HE14-6

Norfelt HE5-6

426111 &

426110 PM & PM10 6/13/2003

FM6 601 &

602 Finish grinding mill No. 6 20 tph Norfelt HE13-6

Norfelt HE5-6

427111 &

427110 PM & PM10 6/13/2003

FM9

150A,

154 &

156

Finish grinding mill No. 9 20 tph

Griffen JV-36-9X

Envirotech HE-5-6

Envirotech HE-18-6

507160,

507963 &

507965

PM & PM10 6/13/2003

FM10

136,

138,

140,

142A,

143,

145,

147,

147A,

148A

&

148B

Finish grinding mill No. 10 182 tph

Fuller 640S8

DCE DLM V45/15F10

DCE DLM V45/15F10

ZZ Conv. 13008-20-TA

Fuller 224C10

Fuller 6Z128

Fuller 18Z128

ZZ C.CF42-39(37)-20

Donaldson/Day232RF12

3606-20TRD BV

520144,

520150,

520157,

506195,

520182,

520257,

520270,

520301,

304700

&

1488

PM & PM10 6/13/2003

FM11

1101,

1102,

1103,

104,

FAS,

LS &

PS

Finish grinding mill No. 11 100 tph

Fuller 390512

Fuller 2M690512

Fuller 100C10

Fuller 100C10

Sly SBR-45-8

Sly SBR-45-8

Sly SBR 48

1101,

1102,

1103,

104,

FAS,

LS &

PS

PM & PM10 6/13/2003

Cement Storage

SG1 159 &

161 Finish silos group No. 1 200 tph Sly SBR-78-10-BVSly SBR-78-10-BV

634110 &

634120 PM & PM10 6/13/2003
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 10 of 57

Emission

Unit ID

Stack

ID Emission Unit Description Size/RatedCapacity*

Pollution Control Device

(PCD) Description PCD ID PollutantControlled

Applicable Permit

Date

SG2 164 Finish silos group No. 2 200 tph Sly STJ-1011-10 635050 PM & PM10 6/13/2003

SG3 168 Finish silos group No. 3 200 tph Sly STJ-1011-10 637030 PM & PM10 6/13/2003

SG4 172 &

174 Finish silos group No. 4 200 tph Micropul 100S-10-20

Micropul 100S-10

637030 &

637110 PM & PM10 6/13/2003

SG5

179,

181,

183 &

186

Finish silos group No. 5 600 tph

Micropul 100S-8-20

Micropul 100S-8-20

Micropul 100S-8-20

(See CBL)

709114,

709115,

709116 PM & PM10 6/13/2003

Cement Bulk Load Out

CBL

186,

188,

190 &

191B

Rail/ truck loading (Group 5

silos & dribble bin) 640 tph

Midwest MCP8-2.0

Midwest MCP8-2.0

Midwest MCP8-2.0

Fuller 87-20080-336

751002,

751003,

751004 &

750020

PM & PM10 6/13/2003

Cement Bagging/Packing

PH

PH1,

PH2

&

PH3

Cement Packing 113 tph

Sly STJ-1311-10

Sly STJ-1311-10

Sly STJ-1311-10

BPH1,

BPH2

&

BPH3

PM & PM10 6/13/2003

Waste Dust Storage & Handling

K26-K72

K61,

70A,

K66

&

K73

150 tph

Micropul 48S-8-20

Micropul 80S-8-20

Micropul 48S-8-20

Micropul 81S-8

505087,

506106,

503777

&

121280

PM & PM10 6/13/2003

*The Size/Rated capacity and PCD efficiency is provided for informational purposes only, and is not an applicable requirement.
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 11 of 57

III. Fuel Burning Equipment Requirements – NA

IV. Process Equipment Requirements – Raw Material processing

A. Limitations

1. Particulate emissions from the Raw Material Processing System shall be controlled

by fabric filters. The fabric filters shall be provided with adequate access for

inspection. Each fabric filter shall be equipped with a device to continuously measure

the differential pressure drop across the fabric filter. The device shall be installed in

an accessible location and shall be maintained by the permittee such that it is in

proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

2. Unless otherwise specified, dust emission controls shall include the following or

equivalent as a minimum:

a. Dust from drills, shot piles, material handling, screens, crushers, load-outs and

traffic areas shall be controlled by wet suppression or equivalent (as approved by

the DEQ). There shall be no exemption from this requirement due to cold

weather. The wet suppression spray systems shall be operated at optimum design,

and pressure gauges or flow meters shall be installed (with adequate access for

inspection of the measuring device) to indicate system operating pressures or flow

rates.

b. All material being stockpiled outside shall be kept moist to control dust during

storage and handling or covered at all times to minimize emissions.

c. Haul roads shall be controlled by wet suppression.

(9 VAC 5-80-10 H, 9 VAC 5-50-260 9 VAC 5-80-110 & Condition 16 of 6/13/2003

PSD permit)

3. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-80-

110, 9 VAC 5-170-160 & Condition 61 of 6/13/2003 PSD permit)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 12 of 57

4. Emissions from the operation of the Raw Material Processing System from primary

crushing through feed to the raw mills, shall not exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 5.85 lbs/hr 25.01 tons/yr

PM-10 0.005 gr/acf 5.56 lbs/hr 23.75 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 49 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following measures

in order to minimize the duration and frequency of excess emissions, with respect to air

pollution control equipment and process equipment which affect such emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a period

of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E & Conditions 73 & 74 of

6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 13 of 57

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

V. Process Equipment Requirements – Kiln Feed System & Recycle Dust

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the No. 5 Kiln Feed and Storage System shall be

controlled by fabric filters. The fabric filters shall be provided with adequate access

for inspection. Each fabric filter shall be equipped with a device to continuously

measure the differential pressure drop across the fabric filter. The device shall be

installed in an accessible location and shall be maintained by the permittee such that it

is in proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. The annual throughput of the Kiln Feed System from the raw mills to the No. 5 kiln,

including recycle dust, shall not exceed 2,258,932 tons, calculated monthly as the

sum of each consecutive 12 month period.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 22 of 6/13/2003 PSD permit

4. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 14 of 57

5. Emissions from the operation of the Kiln Feed System, including reactivation of

thirteen old silos refr. RS, shall not exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 1.44 lbs/hr 6.3 tons/yr

PM-10 0.005 gr/acf 1.37 lbs/hr 5.98 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 50 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following measures

in order to minimize the duration and frequency of excess emissions, with respect to air

pollution control equipment and process equipment which affect such emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a period

of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 15 of 57

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

VI. Process Equipment Requirements – No. 5 Kiln System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants and 40 CFR Part 63 Subpart LLL –

National Emission Standards for Hazardous Air Pollutants From the Portland Cement

Manufacturing Industry. Current copies of 40 CFR Part 60 Subpart F and 40 CFR Part 63

Subpart LLL have been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61, or 40 CFR 63.2 and 40 CFR 63.1341, as

applicable.

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

National Emissions Standards for Hazardous Air Pollutants for Source Categories;

Portland Cement Manufacturing Industry (40 CFR Part 63 Subpart LLL), in

accordance with the compliance schedule set forth under these standards. The facility

has determined that it is considered an area source and the facility is required to

obtain a Title V permit. Under this determination, only the No. 5 Kiln is considered

an affected facility per 40 CFR Part 63 Subpart LLL. Should the facility’s area

source status change, then the facility will need to comply with the major source

requirements and submit an application to amend this permit.

(9 VAC 5-50-260, 9 VAC 5-60-70, 9 VAC 5-80-110 & Condition 67 of 6/13/2003

PSD permit)

2. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

3. Particulate emissions from the No. 5 Kiln System, raw mills, and alkali bypass (main

stack) shall be controlled by electrostatic precipitators. The electrostatic precipitators

shall be provided with adequate access for inspection. Water spray gas conditioning
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 16 of 57

systems shall be operated as needed by the ESPs to meet the opacity and particulate

emission limits, especially when one or both raw mills are off-line, by ensuring

optimum gas conditions for the ESPs such as approximately equivalent gas

conditioning as normally achieved when both raw mills are on-line. Each

electrostatic precipitator shall be equipped with devices to continuously measure the

temperature, voltage and current to the electrostatic precipitators. The measuring

device shall be installed in an accessible location and shall be maintained by the

permittee such that it is in proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 4 of 6/13/2003

PSD permit)

4. SO2, NOx, VOC, CO emissions from the No. 5 Kiln System shall be controlled by

process control, to include proper operation and maintenance of the Kiln and

pollution control devices controlling Kiln emissions.

(9 VAC 5-80-10 H and 9 VAC 5-50-260, 9 VAC 5-80-110 & Conditions 5, 6, 7 & 8

of 6/13/2003 PSD permit)

5. SO2 shall also be controlled by the operation of a process lime injection system as

needed to help meet the SO2 emission limits. This is mainly to be used when one or

both raw mills are off-line, and should be operated to provide approximately

equivalent SO2 control as normally achieved when both raw mills are on-line.

(9 VAC 5-80-10 H and 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 5 of

6/13/2003 PSD permit)

6. Particulate/opacity, SO2, NOx, and VOC emissions from the No. 5 Kiln System shall

be controlled, when normal controls are not adequate, by reducing production as

much as needed to achieve compliance with the emission limits for the No. 5 kiln

system (main stack).

(9 VAC 5-80-10 H, 9 VAC 5-170-160, 9 VAC 5-20-30, 9 VAC 5-80-110 &

Condition 9 of 6/13/2003 PSD permit)

7. The approved fuels for the No. 5 kiln are: (a) coal, (b) petroleum coke substituting for

up to 50% of the coal Btu (typically 0.9107 tons of petroleum coke per ton of coal, at

typical 12,750 Btu/lb for coal and typical 14,000 Btu/lb for petroleum coke), (c)

synthetic fuel (Synfuel) substituting for up to 25% of the coal, (d) No. 2 fuel oil

primarily for heat-up and flame stabilization and (e) natural gas primarily for heat-up,

flame stabilization, and as an alternate fuel. The petroleum coke fuel approval is

subject to additional restrictions in this permit: see conditions VI.A.8, 9, 12 & 13

below. A change in the fuels may require a permit to modify and operate.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 17 of 6/13/2003 PSD permit)

8. Petroleum coke fuel in the No. 5 kiln shall be fired in the hot end of the kiln; no

petroleum coke shall be fired in the precalciner portion of the kiln.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 18 of 6/13/2003 PSD permit)
Roanoke Cement Company

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December 1, 2003

Page 17 of 57

9. The No. 5 kiln shall consume no more than 162,500 tons of coal per year, 73,996 tons

of petroleum coke per year, and no more than 162,500 tons per year of coal plus

petroleum coke combined per year and no more than 40,625 tons of synthetic coal

(Synfuel) per year, calculated monthly as the sum of each consecutive 12 month

period.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 20 of 6/13/2003 PSD permit)

10. The sulfur content of the coal to be burned in the No. 5 kiln shall not exceed 1.5

percent by weight per shipment and 1.0 percent by weight annual average (except as

provided below), calculated monthly as the average of each consecutive 12 month

period. The permittee shall maintain records (supplier fuel analysis) of all coal

shipments purchased. These records shall be available for inspection by the DEQ.

Such records shall be current for the most recent five years.

If justified, coal containing increased sulfur but not to exceed 1.5 percent sulfur as an

annual average (and per shipment) may be used temporarily during unusual

conditions upon written agreement from the Director, West Central Regional Office.

The sulfur dioxide emissions limits in this permit shall continue to be met. The

owner shall provide justification for needing higher sulfur coal, shall minimize the

amount of excess sulfur, provide an estimate of the percent sulfur, the amount of coal,

and the duration of its use. The length of time for a temporary agreement shall be

minimized and shall not exceed 12 months per agreement.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 30 of 6/13/2003 PSD permit

11. As an option to Roanoke Cement Co., coal with a higher sulfur content than the

typical 1.0% sulfur content coal for the No. 5 kiln is permit approved, subject to DEQ

agreement, if a representative comparison demonstration of SO2 emissions from the

main stack verifies that there is "no statistically significant increase" of SO2 emissions

to the atmosphere when burning the higher sulfur coal. The comparison

demonstration shall use this plant's modified No. 5 kiln system, typical raw

material/additives, standard formulations, and each fuel. The details of the

comparison demonstration shall be arranged with the Director, West Central Regional

Office. Limited trial burns with the higher sulfur coal to establish the process before

a comparison demonstration may be arranged with the Director, West Central

Regional Office.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 31 of 6/13/2003 PSD permit)

12. The sulfur content of the petroleum coke to be burned in the No. 5 kiln shall not

exceed 4.0 percent by weight per shipment and 3.5 percent by weight annual average,

calculated monthly as the average of each consecutive 12 month period. The

permittee shall maintain records (supplier fuel analysis) of all coke shipments

purchased. These records shall be available for inspection by the DEQ. Such records

shall be current for the most recent five years.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 32 of 6/13/2003 PSD permit)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 18 of 57

13. Before petroleum coke with a higher sulfur content than permitted for coal may be

used as fuel for the No. 5 kiln system, a representative comparison demonstration of

SO2 emissions from the main stack shall be measured, using this plant's modified

kiln, typical raw material/additives, standard formulations and each fuel, to verify that

there is "no statistically significant increase" of SO2 emissions to the atmosphere

when burning petroleum coke. The details of the comparison demonstration shall be

arranged with the Director, West Central Regional Office. Limited trial burns with

petroleum coke to establish the process before a comparison demonstration may be

arranged with the Director, West Central Regional Office.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 33 of 6/13/2003 PSD permit)

14. The approved fuel for the raw mills is No. 2 fuel oil and natural gas. A change in the

fuels may require a permit to modify and operate. (The raw mills will normally be

heated by the No. 5 kiln exhaust.)

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 19 of 6/13/2003 PSD permit)

15. The annual throughput of the No. 5 Kiln System shall not exceed 1,300,000 tons of

clinker produced, calculated monthly as the sum of each consecutive 12 month

period.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 23 of 6/13/2003 PSD permit)

16. No hazardous, solid or regulated medical (infectious) waste may be processed

through the No. 5 Kiln System without being approved through the DEQ permitting

process including a public comment period/public hearing. This permit does not

allow for the processing/use of these materials.

The permittee shall notify the Director, West Central Regional Office of any

proposed change in materials to be processed through the No. 5 Kiln System prior to

the change to determine if a permit may be required. Notification shall include

identification of the material and the constituents of the material, identification as to

its classification as a waste by VDEQ-Waste Division or Federal EPA, the proposed

first day of use, the anticipated maximum hourly and yearly throughput, calculations

of the predicted maximum hourly and yearly emissions of the constituents and their

derivatives, MSDS data and ACGIH Handbook references. Also describe the

unloading, storage, handling, any processing, emission controls, and the maximum

hourly and yearly throughputs and emissions from these operations. Additional

information may be required.

For the purpose of this condition, use of the following substances are acceptable

without further review provided they have not been contaminated to the extent they

qualify as a hazardous waste, solid waste or regulated medical waste by VDEQWaste Division or Federal EPA regulations:

a. Naturally occurring: limestone, shale, cement rock and equivalent raw materials,

b. Naturally occurring: sand and equivalent high silica substances,
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 19 of 57

c. Gypsum, and naturally occurring: high calcium limestone and equivalent high

calcium substances,

d. Steel mill scale (iron oxide) from carbon steel mill facilities and equivalent

naturally occurring high iron/iron oxide ores,

e. Naturally occurring: bauxite and equivalent high alumina substances,

f. Bottom ash and fly ash,

g. Other raw materials/additives that DEQ determines are exempt from review,

including toxic emissions evaluation,

h. Specific fuels as listed elsewhere in this permit.

i. Granulated iron/pig iron blast furnace slag glass.

j. Spent foundry sand, containing no greater toxic concentrations than represented

by the November 1997 permit application for spent foundry sand from the

Graham-White foundry in Salem.

(9 VAC 5-170-160 and 9 VAC 5-50-200, 9 VAC 5-80-110 & Condition 3 of

6/13/2003 PSD permit)

17. Visible emissions from the No. 5 kiln system/raw mills/alkali bypass (main stack)

shall not exceed twenty percent (20%) opacity as determined by the required

continuous opacity monitor. This condition applies at all times except during startup,

shutdown and malfunction.

(9 VAC 5-170-160, 9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-

290, 9 VAC 5-50-400, 40 CFR 60.62(a)(2), 9 VAC 5-80-110 & Condition 62 of

6/13/2003 PSD permit)

18. Emissions from the operation of the No. 5 Kiln System including the kiln hot

end/preheater/precalciner, raw mill pulverizers and alkali bypass (main stack) shall

not exceed the limits specified below:

Total Suspended 0.30 lbs/ton 83.9 lbs/hr 297.5 tons/yr

Particulate kiln feed

PM-10 0.255 lbs/ton 71.31 lbs/hr 252.8 tons/yr

kiln feed

Sulfur Dioxide 950. lbs/hr 3,104.4 tons/yr

Nitrogen Oxides 982. lbs/hr 2,850 tons/yr

 (as NO2)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 20 of 57

Carbon Monoxide 600. lbs/hr 1,950 tons/yr

Volatile Organic

 Compounds 126.35 lbs/hr 493. tons/yr

Lead 0.13 lbs/hr 0.46 tons/yr

Fluorides 0.17 lbs/hr 0.6 tons/yr

Sulfuric Acid Mist 10.0 lbs/hr 35.5 tons/yr

Hydrogen Chloride 4.89 lbs/hr N.A. tons/yr

The sulfur dioxide pound per hour emission limit is averaged over 3 hours and the

nitrogen oxide pound per hour emission limit is averaged over 24 hours. Annual

emission limits are based on 1,300,000 tons per year clinker produced. The

corresponding kiln feed is based on a combined total of 2,258,932 tons per year raw

materials plus recycle dust.

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-1700, 9 VAC 5-50-400, 9 VAC 5-

80-110 & Condition 51 of 6/13/2003 PSD permit)

19. Dioxin/Furan emissions from the No. 5 kiln system/raw mills/alkali bypass (main

stack) shall not exceed:

a. 8.7x10-11 grains per dscf (TEQ) corrected to seven percent oxygen; or

b. 1.7x10-10 grains per dscf (TEQ) corrected to seven percent oxygen, when the

average of the performance test run average temperatures at the inlet to the

particulate matter control device (PMCD) is 400 degrees Fahrenheit or less.

(40 CFR 63.1343(d))

B. Monitoring

1. A continuous emission monitor shall be installed to measure and record opacity from

the No. 5 kiln system/raw mills/alkali bypass system (main stack). The monitor shall

be located on the main stack. This opacity monitor shall be a "compliance" monitor.

The monitor shall be maintained, located, and calibrated in accordance with approved

procedures (ref. 40 CFR 60.13). A thirty (30) day notification, prior to the

demonstration of continuous monitoring system's performance, and subsequent

notifications shall be submitted to the Director, West Central Regional Office.

(Completed in 1997.)

(9 VAC 5-50-40 F, 9 VAC 5-80-110, 40 CFR 60.63 & Condition 42 of 6/13/2003

PSD permit)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 21 of 57

2. A continuous emission monitor shall be installed to measure and record the emission

of sulfur dioxide from the No. 5 kiln system/raw mills/alkali bypass system (main

stack). The monitor shall be located on the main stack. This sulfur dioxide monitor

shall be a "compliance" monitor. The monitor shall be co-located with a cfm, CO2 or

O2 monitor. The monitor shall be maintained, located, and calibrated in accordance

with approved procedures (ref. 40 CFR 60.13). A thirty (30) day notification, prior to

the demonstration of continuous monitoring system's performance, and subsequent

notifications shall be submitted to the Director, West Central Regional Office.

(Completed in 1997.)

(9 VAC 5-50-40 F, 9 VAC 5-80-110, 9 VAC 5-170-160 & Condition 43 of 6/13/2003

PSD permit)

3. Continuous emission monitors shall be installed to measure and record the emissions

of carbon monoxide, nitrogen oxides and volatile organic compounds or total

hydrocarbons from the No. 5 kiln system/raw mills/alkali bypass system (main stack).

(The CO CEM is a 2003 new requirement). The type of monitor proposed for

measurement of volatile organic compounds shall be approved by the Director, West

Central Regional Office. The monitors shall be located on the main stack.

Exceedance of the emission limits stated in this permit may subject Roanoke Cement

Company to a request from DEQ to re-test these stack emissions. Each monitor shall

be co-located with a flow, cfm, CO2 or O2 monitor. The monitors shall be maintained,

located, and calibrated in accordance with approved procedures (ref. 40 CFR 60.13).

A thirty (30) day notification, prior to the demonstration of continuous monitoring

system's performance, and subsequent notifications shall be submitted to the Director,

West Central Regional Office. [Already operational in 1997.]In accordance with 40

CFR 60.13, a Relative Accuracy Test Audit (RATA) shall be performed, and

demonstrate compliance, on the CO Continuous Emission Monitoring System

(CEMS) on the No. 5 kiln system within 60 days after achieving the maximum

production rate at which the No. 5 kiln system will be operated, but not later than 180

days after issuance of the 2003 CO PSD permit. The details of the tests are to be

arranged with the Director, West Central Regional Office. The permittee shall submit

a test protocol at least thirty (30) days prior to testing. Three (3) copies of the test

results shall be submitted to the Director, West Central Regional Office within 45

days after test completion and shall conform to the test report format enclosed with

this permit. One copy of the test results shall be submitted to EPA within 45 days of

test completion.

(9 VAC 5-50-40 F, 9 VAC 5-80-110, 9 VAC 5-170-160 & Condition 44 of 6/13/2003

PSD permit)

4. Process instruments to continuously measure and record oxygen and temperature

shall be installed near the outlet of the kiln's precalciner. Although not required to

meet any specific air pollution control regulatory requirements, these are considered

to be normal plant process instruments which assist the plant in determining the

preferred operating parameters for process control of NOx and VOC. Stack

continuous emission monitors are already required for NOx and VOC, as stated in
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 22 of 57

Condition 3.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 48 of 6/13/2003 PSD permit)

5. Prepare a written operations and maintenance plan. The plan shall be submitted to

DEQ and EPA for approval. The plan shall include the procedures for the proper

operation and maintenance of the affected source and control devices in order to meet

the emission limits and operating limits of A.19 and 40 CFR 63.1343(d). The

maintenance plan shall include an annual inspection of the combustion system

components of each in-line kiln/raw mill and establish the procedures to be used

during the inspection. Failure to comply with any provision of the operations and

maintenance plan developed in accordance with this condition and 40 CFR

63.1350(a) shall be a violation of the standard.

(40 CFR 63.1350(a), 40 CFR 63.1350(a)(1) & (a)(3) & 40 CFR 63.1350(b))

6. Install, calibrate, maintain and continuously operate a continuos monitor to record the

temperature at the inlet to, or upstream of, the in-line kiln/raw mill and the alkali

bypass particulate matter control devices in accordance with 40 CFR 63.1350 (f).

a. The recorder response range must include zero and 1.5 times either of the

average temperatures established according to the requirements of 40 CFR

63.1344 and 40 CFR 63.1349(b)(3)(iv).

b. The reference method must be a National Institute of Standards and Technology

calibrated reference thermocouple-potentiometer system or approved alternate.

Calibration shall be verified quarterly.

c. The owner or operator shall monitor and continuously record the temperature of

the exhaust gases from the in-line kiln/raw mill and/or alkali bypass particulate

matter control device. The three hour rolling average temperature shall be

calculated in accordance with 40 CFR 63.1350(f)(3), (4) & (5)

(40 CFR 63.1350(f)(1) through (6))

7. Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 23 of 57

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. Periodic performance tests shall be conducted for particulate emissions from the No.

5 kiln system/raw mills/alkali bypass (main stack) to determine compliance with the

particulate emission limits contained in Condition A.18 The tests shall be performed,

and demonstrate compliance, once every other calendar year. Tests shall be

conducted and reported and data reduced as set forth in 9 VAC 5-50-30 of State

Regulations, and the test methods and procedures contained in each applicable section

or subpart listed in 9 VAC 5-50-410. The details of the tests are to be arranged with

the Director, West Central Regional Office. The permittee shall submit a test

protocol at least thirty (30) days prior to testing. Three (3) copies of the test results

shall be submitted to the Director, West Central Regional Office within 45 days after

test completion and shall conform to the test report format enclosed with this permit.

(9 VAC 5-50-30, 9 VAC 5-80-10 J, 9 VAC 5-80-110, 9 VAC 5-170-160 & Condition

36 of 6/13/2003 PSD permit)

2. Initial performance tests for D/F specified in 40 CFR 63.1349(b)(3) shall be repeated

every 30 months or within 90 days of initiating any significant change in the feed or

fuel from that used in the previous performance test.

(40 CFR 63.1349(d) & (e)

3. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 24 of 57

4. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

VII. Process Equipment Requirements – Clinker Cooler

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the Clinker Cooler shall be controlled by an electrostatic

precipitator. The electrostatic precipitator shall be provided with adequate access for

inspection. The electrostatic precipitator shall be equipped with devices to

continuously measure the temperature and the voltages and currents to the

electrostatic precipitator. The device shall be installed in an accessible location and

shall be maintained by the permittee such that it is in proper working order at all

times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 10 of 6/13/2003

PSD permit)

3. The annual throughput of the Clinker Cooler shall not exceed 1,300,000 tons of

clinker produced, calculated monthly as the sum of each consecutive twelve (12)

month period.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 23 of 6/13/2003 PSD permit)

4. Visible emissions from the Clinker Cooler stack shall not exceed ten percent (10%)

opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A). This

condition applies at all times except during startup, shutdown and malfunction.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-50-

400, 9 VAC 5-170-160, 40 CFR 60.62(b)(2), 9 VAC 5-80-110 & Condition 63 of

6/13/2003 PSD permit)
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 25 of 57

5. Emissions from the operation of the Clinker Cooler shall not exceed the limits

specified below:

Total Suspended 0.0473 lbs/ton 13.23 lbs/hr 46.9 tons/yr

 Particulate kiln feed annual avg.

PM-10 0.0402 lbs/ton 11.24 lbs/hr 39.9 tons/yr

kiln feed annual avg.

Annual emission limits are based on 1,300,000 tons per year of clinker produced.

The corresponding kiln feed is based on a combined total of 2,258,932 tons per year

raw materials plus recycle dust.

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-1700, 9 VAC 5-50-400, 9 VAC 5-

80-110 & Condition 52 of 6/13/2003 PSD permit)

B. Monitoring

1. The electrostatic precipitator shall be equipped with devices to continuously measure

the temperature, and the voltage and current to the electrostatic precipitator. The

device shall be installed in an accessible location and shall be maintained by the

permittee such that it is in proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260 and Condition 10 of 6/13/2003 PSD permit)

2. A continuous emission monitor shall be installed to measure and record opacity of the

clinker cooler. The opacity monitor shall be located on the clinker cooler stack. The

monitor shall be an "compliance" monitor. The monitor shall be maintained, located,

and calibrated in accordance with approved procedures (ref. 40 CFR 60.13). A thirty

(30) day notification, prior to the demonstration of continuous monitoring system's

performance, and subsequent notifications shall be submitted to the Director, West

Central Regional Office. (Completed In 1997.)

(9 VAC 5-50-40 F, 9 VAC 5-80-110, 40 CFR 60.63 & Condition 45 of 6/13/2003

PSD permit)

3. Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 26 of 57

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

VIII. Process Equipment Requirements – Coal/Coke Grinding & Handling

System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart Y –

Standards of Performance for Coal Preparation Plants. A current copy of 40 CFR Part 60

Subpart Y has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.251

A. Limitations

1. The permittee shall operate all affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 27 of 57

Plants (40 CFR Part 60 Subpart Y). (Finish Mill 9 is not subject to this requirement.)

(9 VAC 5-50-410, 40 CFR 60 Subpart Y)

2. Particulate emissions from the Coal/Coke Grinding System shall be controlled by

fabric filters. The fabric filters shall be provided with adequate access for inspection.

Each fabric filter shall be equipped with a device to continuously measure the

differential pressure drop across the fabric filter. The device shall be installed in an

accessible location and shall be maintained by the permittee such that it is in proper

working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.252(c) & Condition 61 of 6/13/2003 PSD permit)

4. Emissions from the operation of the Coal/Coke Grinding and Handling System shall

not exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 1.80 lbs/hr 7.9 tons/yr

PM-10 0.005 gr/acf 1.71 lbs/hr 7.5 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 53 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following measures

in order to minimize the duration and frequency of excess emissions, with respect to air

pollution control equipment and process equipment which affect such emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.
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December 1, 2003

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d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a period

of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

IX. Process Equipment Requirements – Clinker Handling &Storage System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the Clinker Handling and Storage System shall be

controlled by fabric filters. The fabric filters shall be provided with adequate access

for inspection. Each fabric filter shall be equipped with a device to continuously

measure the differential pressure drop across the fabric filter. The device shall be

installed in an accessible location and shall be maintained by the permittee such that it
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 29 of 57

is in proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

4. Emissions from the operation of the Clinker Storage and Handling System, including

adding a third 25,000 ton silo controlled by the existing fabric filter with no emissions

increase, shall not exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 1.36 lbs/hr 6.0 tons/yr

PM-10 0.005 gr/acf 1.29 lbs/hr 5.7 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 55 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following measures

in order to minimize the duration and frequency of excess emissions, with respect to air

pollution control equipment and process equipment which affect such emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.
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December 1, 2003

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e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a period

of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

X. Process Equipment Requirements – Clinker Grinding System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the Clinker Grinding System shall be controlled by fabric

filters. The fabric filters shall be provided with adequate access for inspection. Each

fabric filter shall be equipped with a device to continuously measure the differential

pressure drop across the fabric filter. The device shall be installed in an accessible

location and shall be maintained by the permittee such that it is in proper working

order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)
Roanoke Cement Company

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December 1, 2003

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3. Particulate emissions from the storage and handling of fly ash shall be controlled by

enclosing all storage of fly ash and by fabric filtration (or DEQ approved equivalent)

of all emissions from storing and handling fly ash. No outside stockpiles shall be

used for storage of fly ash. The fabric filters shall be provided with adequate access

for inspection. The fabric filter shall be equipped with a device to continuously

measure the differential pressure drop across the fabric filter. The device shall be

installed in an accessible location and shall be maintained by the permittee such that it

is in proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 12 of 6/13/2003

PSD permit)

4. Operations at the Gypsum Unloading Bin and the Gypsum Storage Bin shall not

exceed 16 hours per day and 5839 hours per year, calculated monthly as the sum of

each consecutive 12 month period.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 28 of 6/13/2003 PSD permit)

5. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

6. Emissions from the operation of the Clinker Grinding Systems, including addition of

large finish mill 11 (refr. FM11) and reactivation of small finish mills 5 and 6 (refr.

FM5 and FM6), shall not exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 17.83 lbs/hr 76.3 tons/yr

PM-10 0.005 gr/acf 16.94 lbs/hr 72.5 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-1700, 9 VAC 5-50-400, 9 VAC 5-

80-110 & Condition 56 of 6/13/2003 PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following measures

in order to minimize the duration and frequency of excess emissions, with respect to air

pollution control equipment and process equipment which affect such emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.
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December 1, 2003

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c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a period

of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XI. Process Equipment Requirements – Cement Storage Silo System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)
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December 1, 2003

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2. Particulate emissions from the Cement Silos shall be controlled by fabric filters. The

fabric filters shall be provided with adequate access for inspection. Each fabric filter

shall be equipped with a device to continuously measure the differential pressure drop

across the fabric filter. The device shall be installed in an accessible location and

shall be maintained by the permittee such that it is in proper working order at all

times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

4. Emissions from the operation of the Cement Silos shall not exceed the limits

specified below:

Total Suspended

 Particulate 0.005 gr/acf 1.76 lbs/hr 7.7 tons/yr

PM-10 0.005 gr/acf 1.67 lbs/hr 7.3 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 57 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 34 of 57

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XII. Process Equipment Requirements – Cement Bulk Loadout System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)
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December 1, 2003

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2. Particulate emissions from Cement Bulk Loadout shall be controlled by fabric filters.

The fabric filters shall be provided with adequate access for inspection. Each fabric

filter shall be equipped with a device to continuously measure the differential

pressure drop across the fabric filter. The device shall be installed in an accessible

location and shall be maintained by the permittee such that it is in proper working

order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. Particulate emissions from the Cement Bulk Loadout to rail and trucks shall be

controlled by loadout through the No. 5 cement silo group loadout station with

retractable chute which shall be controlled by a fabric filter collector or through the

Dribble Bin loadout station with retractable chute which shall be controlled by a

fabric filter collector.

(9 VAC 5-80-10 H and 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 13 of

6/13/2003 PSD permit)

4. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

5. Emissions from the operation of the Cement Bulk Loadout System (rail and truck),

including the Dribble Bin, shall not exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 0.36 lbs/hr 1.44 tons/yr

PM-10 0.005 gr/acf 0.35 lbs/h 1.37 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 58 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.
Roanoke Cement Company

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December 1, 2003

Page 36 of 57

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XIII. Process Equipment Requirements – Cement Bagging/Packing System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement
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Permit Number: VA-20232

December 1, 2003

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Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the Cement Bagging/Packing Systems shall be controlled

by fabric filters. The fabric filters shall be provided with adequate access for

inspection. Each fabric filter shall be equipped with a device to continuously measure

the differential pressure drop across the fabric filter. The device shall be installed in

an accessible location and shall be maintained by the permittee such that it is in

proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

4. Emissions from the operation of the Cement Bagging/Packing System shall not

exceed the limits specified below:

Total Suspended

 Particulate 0.005 gr/acf 2.29 lbs/hr 6.69 tons/yr

PM-10 0.005 gr/acf 2.18 lbs/hr 6.35 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 59 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.
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December 1, 2003

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d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XIV. Process Equipment Requirements – Waste Dust Storage and Handling

System

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the Waste Dust Storage and Handling System shall be

controlled by fabric filters. The fabric filters shall be provided with adequate access
Roanoke Cement Company

Permit Number: VA-20232

December 1, 2003

Page 39 of 57

for inspection. Each fabric filter shall be equipped with a device to continuously

measure the differential pressure drop across the fabric filter. The device shall be

installed in an accessible location and shall be maintained by the permittee such that it

is in proper working order at all times.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 11 of 6/13/2003

PSD permit)

3. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

4. Emissions from the operation of the Waste Dust Storage and Handling System shall

not exceed the limits specified below:

Total Suspended

Particulate 0.005 gr/acf 0.34 lbs/hr 1.5 tons/yr

PM-10 0.005 gr/acf 0.33 lbs/hr 1.4 tons/yr

(9 VAC 5-50-260, 9 VAC 5-50-180, 9 VAC 5-80-110 & Condition 54 of 6/13/2003

PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.
Roanoke Cement Company

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December 1, 2003

Page 40 of 57

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.

Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XV. Process Equipment Requirements – Storage Gallery

This section of the permit contains terms and conditions from 40 CFR Part 60 Subpart F –

Standards of Performance for Portland Cement Plants. A current copy of 40 CFR Part 60

Subpart F has been attached. As used in this section, all terms shall have the meaning as

defined in 40 CFR 60.2 and 40 CFR 60.61

A. Limitations

1. The permittee shall operate the affected facilities in compliance with all applicable

New Source Performance Standards; Standards of Performance for Portland Cement

Plants (40 CFR Part 60 Subpart F)

(9 VAC 5-50-410, 40 CFR 60 Subpart F)

2. Particulate emissions from the clinker stored in the Storage Gallery shall be

controlled by use of the existing gallery for storage of cement clinker only during

malfunctions involving the Clinker Handling and Storage System. Enclosed bin

systems in the Storage Gallery with all emissions controlled by fabric filters are

exempt from this condition.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 15 of 6/13/2003

PSD permit)
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3. The annual throughput of clinker through the Storage Gallery, as storage during

malfunctions involving the Clinker Handling and Storage System, shall not exceed

20,000 tons of clinker per year, calculated monthly as the sum of each consecutive 12

month period. Enclosed bin systems in the Storage Gallery with all emissions

controlled by fabric filters are exempt from this condition and do not contribute to

20,000 ton per year limit on storage.

(9 VAC 5-170-160, 9 VAC 5-80-110 & Condition 25 of 6/13/2003 PSD permit)

4. Visible emissions from the Storage Gallery shall not exceed ten percent (10%)

opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A).

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 64 of 6/13/2003 PSD permit)

5. Visible emissions from the fabric filter exhaust stacks shall not exceed 3% opacity

except during one six-minute period in any one hour in which visible emissions shall

not exceed 10% opacity.

(9 VAC 5-50-20, 9 VAC 5-50-80, 9 VAC 5-50-260, 9 VAC 5-50-290, 9 VAC 5-170-

160, 9 VAC 5-80-110, 40 CFR 60.62(c) & Condition 61 of 6/13/2003 PSD permit)

B. Monitoring

Operation & Maintenance Procedures – The permittee shall take the following

measures in order to minimize the duration and frequency of excess emissions, with

respect to air pollution control equipment and process equipment which affect such

emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance.

b. Develop an inspection schedule, monthly at a minimum, to insure the operational

integrity of the air pollution control equipment and maintain records of inspection

results.

c. Have available written operating procedures for the air pollution control

equipment. These procedures shall be based on the manufacturer’s

recommendations, at a minimum.

d. Train operators in the proper operation of all air pollution control equipment and

familiarize the operators with the written operating procedures. The permittee

shall maintain records of the training provided including the names of trainees,

the date of training and the nature of the training.

e. Maintain an inventory of spare parts that are needed to maintain the air pollution

control equipment in proper working order.
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Records of maintenance, inspections and training shall be maintained on site for a

period of five (5) years and shall be made available to DEQ personnel upon request.

(9 VAC 5-80-110, 9 VAC 5-80-110 F & K, 9 VAC 5-40-20E, 9 VAC 5-50-20E &

Conditions 73 & 74 of 6/13/2003 PSD permit)

C. Recordkeeping (See Facility Wide Conditions)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XVI. Facility Wide Conditions

A. Limitations

1. Any dusty material being transported in bulk form shall be transported into or out of

the plant only in enclosed tanker trucks or rail cars, or equivalent totally enclosed

trucks, rail cars or containers, or DEQ-Air Division approved equivalent. Dusty

materials include cement product, waste dust and fly ash.

(9 VAC 5-80-10 H, 9 VAC 5-50-260, 9 VAC 5-80-110 & Condition 14 of 6/13/2003

PSD permit)

2. Visible emissions from other process fugitive emission points shall not exceed ten

percent (10%) opacity.

(9 VAC 5-20-110, 9 VAC 5-50-20, 9 VAC 5-50-400, 9 VAC 5-80-110 & Condition

65 of 6/13/2003 PSD permit)

B. Monitoring

Visible Emissions: - Each emissions unit with a visible emissions requirement in this

permit that does not have a continuous opacity monitor meeting the requirements of 40

CFR 60 Appendix A, shall be observed visually at least once each calendar month in

which the emissions unit operates. Observations shall be performed more frequently if

requested by the DEQ or EPA. The visual observations shall be conducted using 40 CFR

60 Appendix A Method 22 techniques (condensed water vapor/steam is not a visible
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emission) for at least one minute to only identify the presence of visible emissions. Each

emissions unit in the Method 22 technique observation having visible emissions shall be

evaluated by conducting a 40 CFR 60 Appendix A Method 9 visible emissions evaluation

(VEE) for at least six (6) minutes; the VEE must begin within one hour of the Method 22

test. 40 CFR 60 Appendix A Method 9 requires the observer to have a Method 9

certification that is current at the time of the VEE. If any of these six (6) minute VEE

averages exceed the unit’s opacity limitation, a VEE shall be conducted on these

emissions for at least 3 six minute periods (at least 18 minutes). All visible emission

observations, VEE results, and corrective actions taken shall be recorded.

(9 VAC 5-80-110E & 40 CFR 63.1350)

C. Recordkeeping

The permittee shall maintain records of all emission data and operating parameters

necessary to demonstrate compliance with this permit. The content and format of such

records shall be arranged with the Director, West Central Regional Office. These records

shall include, but are not limited to:

1. Annual throughput of the following, calculated monthly as the sum of each

consecutive twelve (12) month period.

a. Primary/secondary crushing overall process throughput,

b. No. 5 Kiln feed material throughput, including recycle dust,

c. No. 5 Kiln/Clinker Cooler clinker produced,

d. Clinker Grinding System cement produced,

e. Storage Gallery clinker throughput,

f. Waste Dust Storage and Handling System throughput,

2. The annual consumption of coal, and petroleum coke by the No. 5 kiln system,

calculated monthly as the sum of each consecutive twelve (12) month period.

3. The annual overall consumption of No. 2 fuel oil and natural gas by the plant,

calculated monthly as the sum of each consecutive twelve (12) month period.

4. Coal and petroleum coke shipments purchased, indicating sulfur content per

shipment.

5. Continuous emissions monitors and process monitor data/records.
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6. The annual emissions of SO2, NOx and VOC for the No. 5 kiln system (main stack),

calculated monthly as the sum of each consecutive twelve (12) month period.

These records shall be available on site for inspection by the DEQ and shall be current for

the most recent five (5) years.

(9 VAC 5-50-50, 9 VAC 5-80-110 & Condition 69 of 6/13/2003 PSD permit)

D. Testing

1. The permitted facility shall be constructed so as to allow for emissions testing at any

time using appropriate methods. Upon request from the Department, test ports shall

be provided at the appropriate locations.

(9 VAC 5-50-30 F, 9 VAC 5-80-110 & Condition 34 of 6/13/2003 PSD permit)

2. If testing is conducted for compliance purposes, in addition to the monitoring

specified in this permit, the permittee shall use test methods in accordance with

procedures approved by the DEQ.

(9 VAC 5-80-110)

E. Reporting (See General Conditions)

XVII.Insignificant Emission Units

The following emission units at the facility are identified in the application as

insignificant emission units under 9 VAC 5-80-720:

Emission

Unit No. Emission Unit Description Citation 1 Pollutant(s)

Emitted Rated Capacity

001-001 Cleaver Brooks ng fired boiler 9 VAC 5-80-720 C NOx, CO 6 mm Btu/hr

G-1 Diesel Emergency generator for

Kiln drive 9 VAC 5-80-720 B PM, NOx, CO, SO2 300 HP

G-2 Diesel emergency process

water pump 9 VAC 5-80-720 B PM, NOx, CO, SO2 300 HP

G-3 Portable diesel water pump 9 VAC 5-80-720 B PM, NOx, CO, SO2 60 HP

G-4 Steam jenny propane engine 9 VAC 5-80-720 B NOx, CO 6 HP

SK Safety-Kleen cold solvent

cleaning units (7) 9 VAC 5-80-720 B VOC 30 gal each

T-1 Raw Mill, No. 2 fuel oil tank 9 VAC 5-80-720 B VOC 20,000 gal

T-2 Em gen. diesel fuel tank 9 VAC 5-80-720 B VOC 275 gal

T-4A Gasoline tank & dispensing 9 VAC 5-80-720 B VOC 2,000 gal

T-4B Diesel fuel tank & dispensing 9 VAC 5-80-720 B VOC 2,000 gal

T-5 Oil house lubricant storage 9 VAC 5-80-720 B VOC 4,000 gal total

multiple containers

T-6 Diesel fuel tank & dispensing 9 VAC 5-80-720 B VOC 20,000 gal

T-9 Diesel fuel tank, emergency

water pump 9 VAC 5-80-720 B VOC 275 gal

T-11 Lubricant Storage, Mill

building 9 VAC 5-80-720 B VOC 2,000 gal totalmultiple containers

T-12 Grinding aid tank 9 VAC 5-80-720 B VOC 10,000 gal
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Emission

Unit No. Emission Unit Description Citation 1 Pollutant(s)Emitted Rated Capacity

T-13 Grinding aid-blend tank 9 VAC 5-80-720 B VOC 5,000 gal

T-14 Lubricant storage, quarry shop 9 VAC 5-80-720 B VOC 2,500 gal total

multiple containers

1

The citation criteria for insignificant activities are as follows:

9 VAC 5-80-720 A - Listed Insignificant Activity, Not Included in Permit Application

9 VAC 5-80-720 B - Insignificant due to emission levels

9 VAC 5-80-720 C - Insignificant due to size or production rate

These insignificant emission units are presumed to be in compliance with all

requirements of the federal Clean Air Act as may apply. Based on this presumption, no

monitoring, recordkeeping, or reporting shall be required for these emission units in

accordance with 9 VAC 5-80-110.

XVIII. Compliance Plan - NA

XIX. Permit Shield & Inapplicable Requirements

Compliance with the provisions of this permit shall be deemed compliance with all

applicable requirements in effect as of the permit issuance date as identified in this

permit. This permit shield covers only those applicable requirements covered by terms

and conditions in this permit and the following requirements which have been

specifically identified as being not applicable to this permitted facility:

Citation Title of Citation Description of Applicability

-None IdentifiedNothing in this permit shield shall alter the provisions of §303 of the federal Clean Air

Act, including the authority of the administrator under that section, the liability of the

owner for any violation of applicable requirements prior to or at the time of permit

issuance, or the ability to obtain information by the administrator pursuant to §114 of the

federal Clean Air Act, (ii) the Board pursuant to §10.1-1314 or §10.1-1315 of the

Virginia Air Pollution Control Law or (iii) the Department pursuant to §10.1-1307.3 of

the Virginia Air Pollution Control Law.

(9 VAC 5-80-140)
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XX. General Conditions

A. Federal Enforceability

All terms and conditions in this permit are enforceable by the administrator and citizens

under the federal Clean Air Act, except those that have been designated as only stateenforceable.

(9 VAC 5-80-110 N)

B. Permit Expiration

This permit has a fixed term of five years. The expiration date shall be the date five years

from the effective date of this permit. Unless the owner submits a timely and complete

application for renewal to the Department consistent with the requirements of 9 VAC 5-

80-80, has been submitted, to the West Central Regional Office of the DEQ, by the

owner, the right of the facility to operate shall be terminated upon permit expiration.

1. The owner shall submit an application for renewal at least six months but no earlier than

eighteen months prior to the date of permit expiration.

2. If an applicant submits a timely and complete application for an initial permit or renewal

under this section, the failure of the source to have a permit or the operation of the

source without a permit shall not be a violation of Article 1, Part II of 9 VAC 5 Chapter

80, until the Board takes final action on the application under 9 VAC 5-80-150.

3. No source shall operate after the time that it is required to submit a timely and complete

application under subsections C and D of 9 VAC 5-80-80 for a renewal permit, except in

compliance with a permit issued under Article 1, Part II of 9 VAC 5 Chapter 80.

4. If an applicant submits a timely and complete application under section 9 VAC 5-80-80

for a permit renewal but the Board fails to issue or deny the renewal permit before the

end of the term of the previous permit, (i) the previous permit shall not expire until the

renewal permit has been issued or denied and (ii) all the terms and conditions of the

previous permit, including any permit shield granted pursuant to 9 VAC 5-80-140, shall

remain in effect from the date the application is determined to be complete until the

renewal permit is issued or denied.

5. The protection under subsections F 1 and F 5 (ii) of section 9 VAC 5-80-80 F shall

cease to apply if, subsequent to the completeness determination made pursuant

section 9 VAC 5-80-80 D, the applicant fails to submit by the deadline specified in

writing by the Board any additional information identified as being needed to process

the application.

(9 VAC 5-80-80 B, C & F, 9 VAC 5-80-110 D & 9 VAC 5-80-170 B)
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C. Recordkeeping and Reporting

1. All records of monitoring information maintained to demonstrate compliance with the

terms and conditions of this permit shall contain, where applicable, the following:

a. The date, place as defined in the permit, and time of sampling or measurements.

b. The date(s) analyses were performed.

c. The company or entity that performed the analyses.

d. The analytical techniques or methods used.

e. The results of such analyses.

f. The operating conditions existing at the time of sampling or measurement.

(9 VAC 5-80-110 F)

2. Records of all monitoring data and support information shall be retained for at least

five years from the date of the monitoring sample, measurement, report, or

application. Support information includes all calibration and maintenance records

and all original strip-chart recordings for continuous monitoring instrumentation, and

copies of all reports required by the permit.

(9 VAC 5-80-110 F)

3. The permittee shall submit the results of monitoring contained in any applicable

requirement to DEQ no later than March 1 and September 1 of each calendar year.

This report must be signed by a responsible official, consistent with 9 VAC 5-80-80

G. (Note that much of the recordkeeping required by this permit also serves as

required periodic monitoring to determine emissions compliance and therefore needs

to be addressed in the periodic reports.) The details of the reports are to be arranged

with the Director, West Central Regional Office. The reports shall include:

a. The time period included in the report. The time periods to be addressed are

January 1 to June 30 and July 1 to December 31.

b. All deviations from permit requirements. For purposes of this permit, deviations

include, but are not limited to:

(1) Exceedance of emissions limitations or operational restrictions;

(2) Excursions from control device operating parameter requirements, as

documented by continuous emission monitoring, periodic monitoring, or

compliance assurance monitoring which indicates an exceedance of emission

limitations or operational restrictions; or,
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(3) Failure to meet monitoring, recordkeeping, or reporting requirements

contained in this permit.

c. If there were no deviations from permit conditions during the time period, the

permittee shall include a statement in the report that “no deviations from permit

requirements occurred during this semi-annual reporting period.”

d. The report shall be sent to the following address:

Director, West Central Regional Office

Attn: Air Compliance Manager

Virginia DEQ

3019 Peters Creek Road

Roanoke, VA 24019

(9 VAC 5-80-110 F)

D. Annual Compliance Certification

Exclusive of any reporting required to assure compliance with the terms and conditions

of this permit or as part of a schedule of compliance contained in this permit, the

permittee shall submit to EPA and to DEQ no later than March 1 each calendar year a

certification of compliance with all terms and conditions of this permit including

emission limitation standards or work practices. The compliance certification shall

comply with such additional requirements that may be specified pursuant to §114(a)(3)

and §504(b) of the federal Clean Air Act. This certification shall be signed by a

responsible official, consistent with 9 VAC 5-80-80 G, and shall include:

1. The time period included in the certification. The time period to be addressed is

January 1 to December 31.

2. The identification of each term or condition of the permit that is the basis of the

certification.

3. The compliance status.

4. Whether compliance was continuous or intermittent, and if not continuous,

documentation of each incident of non-compliance.

5. Consistent with subsection 9 VAC 5-80-110 E, the method or methods used for

determining the compliance status of the source at the time of certification and over

the reporting period.

6. Such other facts as the permit may require to determine the compliance status of the

source.
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This annual compliance certification shall be sent to the following addresses:

Director, West Central Regional Office

ATTN: Air Compliance Manager

Virginia DEQ

3019 Peters Creek Road

Roanoke, VA 24019

Clean Air Act Title V Compliance Certification (3AP00)

U. S. Environmental Protection Agency, Region III

1650 Arch Street

Philadelphia, PA 19103-2029.

(9 VAC 5-80-110 K.5)

E. Permit Deviation Reporting

The permittee shall notify the Director, West Central Regional Office, within four (4)

daytime business hours after discovery of any deviations from permit requirements which

may cause excess emissions for more than one hour, including those attributable to upset

conditions as may be defined in this permit. In addition, within 14 days of the discovery,

the permittee shall provide a written statement explaining the problem, any corrective

actions or preventative measures taken, and the estimated duration of the permit

deviation. Owners subject to the requirements of 9 VAC 5-40-50 C and 9 VAC 5-50-50

C are not required to provide the written statement prescribed in this paragraph for

facilities subject to the monitoring requirements of 9 VAC 5-40-40 and 9 VAC 5-50-40.

The occurrence should also be reported in the next semi-annual compliance monitoring

report pursuant to General Condition XX.C.3 of this permit.

(9 VAC 5-80-110 F.2 & 9 VAC 5-80-250)

F. Failure/Malfunction Reporting

In the event that any affected facility or related air pollution control equipment fails or

malfunctions in such a manner that may cause excess emissions for more than one hour,

the owner shall, as soon as practicable but no later than four daytime business hours after

the malfunction is discovered, notify the Director, West Central Regional Office, by

facsimile transmission, telephone or telegraph of such failure or malfunction and shall

within 14 days of discovery provide a written statement giving all pertinent facts,

including the estimated duration of the breakdown. Owners subject to the requirements of

9 VAC 5-40-50 C and 9 VAC 5-50-50 C are not required to provide the written statement

prescribed in this paragraph for facilities subject to the monitoring requirements of 9

VAC 5-40-40 and 9 VAC 5-50-40. When the condition causing the failure or

malfunction has been corrected and the equipment is again in operation, the owner shall

notify the Director, West Central Region.

1. The emission units that have continuous monitors subject to 9 VAC 5-40-50 C and 9

VAC 5-50-50 C are not subject to the 14 day written notification.
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2. The emission units subject to the reporting and the procedure requirements of 9 VAC

5-40-50 C and the procedures of 9 VAC 5-50-50 C are listed below:

a. Inline Kiln/ Raw Mill System (Main Stack)

b. Klinker Cooler (Main Stack)

3. Each owner required to install a continuous monitoring system subject to 9 VAC 5-40-

41 or 9 VAC 5-50-410 shall submit a written report of excess emissions (as defined in

the applicable emission standard) to the board for every calendar quarter. All

quarterly reports shall be postmarked by the 30th day following the end of each

calendar quarter and shall include the following information:

a. The magnitude of excess emissions computed in accordance with 40 CFR

60.13(h) or 9 VAC 5-40-41 B 6, any conversion factors used, and the date and

time of commencement and completion of each period of excess emissions;

b. Specific identification of each period of excess emissions that occurs during

startups, shutdowns, and malfunctions of the source. The nature and cause of any

malfunction (if known), the corrective action taken or preventative measures

adopted;

c. The date and time identifying each period during which the continuous

monitoring system was inoperative except for zero and span checks and the nature

of the system repairs or adjustments; and

d. When no excess emissions have occurred or the continuous monitoring systems

have not been inoperative, repaired or adjusted, such information shall be stated in

the report.

4. All malfunctions of emission units not subject to 9 VAC 5-40-50 C and 9 VAC 5-50-

50 C require written reports within 14 days of the discovery of the malfunction.

(9 VAC 5-20-180 C, 9 VAC 5-40-50, 9 VAC 5-50-50 & 9 VAC 5-80-250)

G. Startup, Shutdown, and Malfunction

At all times, including periods of startup, shutdown, soot blowing, and malfunction,

owners shall, to the extent practicable, maintain and operate any affected facility

including associated air pollution control equipment in a manner consistent with air

pollution control practices for minimizing emissions. Determination of whether

acceptable operating and maintenance procedures are being used will be based on
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information available to the Board, which may include, but is not limited to, monitoring

results, opacity observations, review of operating and maintenance procedures, and

inspection of the source.

(9 VAC 5-50-20 E, 9 VAC 5-40-20 E)

H. Malfunction as an Affirmative Defense

1. A malfunction constitutes an affirmative defense to an action brought for

noncompliance with technology-based emission limitations if the requirements of

paragraph 2 of this condition are met.

2. The affirmative defense of malfunction shall be demonstrated by the permittee

through properly signed, contemporaneous operating logs, or other relevant evidence

that show the following:

a. A malfunction occurred and the permittee can identify the cause or causes of the

malfunction.

b. The permitted facility was at the time being properly operated.

c. During the period of malfunction, the permittee took all reasonable steps to

minimize levels of emissions that exceeded the emissions standards or other

requirements in the permit.

d. The permittee notified the board of the malfunction within two working days

following the time when the emissions limitations were exceeded due to the

malfunction. This notification shall include a description of the malfunction, any

steps taken to mitigate emissions, and corrective actions taken. The notification

may be delivered either orally or in writing. The notification may be delivered by

electronic mail, facsimile transmission, telephone, or any other method that

allows the permittee to comply with the deadline. The notice fulfills the

requirement of 9 VAC 5-80-110 F.2. b to report promptly deviations from permit

requirements. This notification does not release the permittee from the

malfunction reporting requirements under 9 VAC 5-20-180 C.

3. In any enforcement proceeding, the permittee seeking to establish the occurrence of a

malfunction shall have the burden of proof.

4. The provisions of this section are in addition to any malfunction, emergency or upset

provision contained in any applicable requirement.

(9 VAC 5-80-250)
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I. Fugitive Dust Emission Standards

During the operation of a stationary source or any other building, structure, facility, or

installation, no owner or other person shall cause or permit any materials or property to

be handled, transported, stored, used, constructed, altered, repaired, or demolished

without taking reasonable precautions to prevent particulate matter from becoming

airborne. Such reasonable precautions may include, but are not limited to, the following:

1. Use, where possible, of water or chemicals for control of dust in the demolition of

existing buildings or structures, construction operations, the grading of roads, or the

clearing of land;

2. Application of asphalt, water, or suitable chemicals on dirt roads, materials

stockpiles, and other surfaces which may create airborne dust; the paving of roadways

and the maintaining of them in a clean condition;

3. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling

of dusty material. Adequate containment methods shall be employed during

sandblasting or other similar operations;

4. Open equipment for conveying or transporting material likely to create objectionable

air pollution when airborne shall be covered or treated in an equally effective manner

at all times when in motion; and,

5. The prompt removal of spilled or tracked dirt or other materials from paved streets

and of dried sediments resulting from soil erosion.

(9 VAC 5-40-90 & 9 VAC 5-50-90)

J. Severability

The terms of this permit are severable. If any condition, requirement or portion of the

permit is held invalid or inapplicable under any circumstance, such invalidity or

inapplicability shall not affect or impair the remaining conditions, requirements, or

portions of the permit.

(9 VAC 5-80-110 G.1)

K. Duty to Comply

The permittee shall comply with all terms and conditions of this permit. Any permit

noncompliance constitutes a violation of the federal Clean Air Act or the Virginia Air

Pollution Control Law or both and is grounds for enforcement action; for permit

termination, revocation and reissuance, or modification; or, for denial of a permit renewal

application.

(9 VAC 5-80-110 G.2)
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L. Need to Halt or Reduce Activity not a Defense

It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of this permit.

(9 VAC 5-80-110 G.3)

M. Permit Modification

A physical change in, or change in the method of operation of, this stationary source may

be subject to permitting under State Regulations 9 VAC 5-80-50, 9 VAC 5-80-1100, 9

VAC 5-80-1790, or 9 VAC 5-80-2000 and may require a permit modification and/or

revisions except as may be authorized in any approved alternative operating scenarios.

(9 VAC 5-80-190 and 9 VAC 5-80-260)

N. Property Rights

The permit does not convey any property rights of any sort, or any exclusive privilege.

(9 VAC 5-80-110 G.5)

O. Duty to Submit Information

1. The permittee shall furnish to the Board, within a reasonable time, any information

that the Board may request in writing to determine whether cause exists for

modifying, revoking and reissuing, or terminating the permit or to determine

compliance with the permit. Upon request, the permittee shall also furnish to the

Board copies of records required to be kept by the permit and, for information

claimed to be confidential, the permittee shall furnish such records to the Board along

with a claim of confidentiality.

(9 VAC 5-80-110 G.6)

2. Any document (including reports) required in a permit condition to be submitted to

the Board shall contain a certification by a responsible official that meets the

requirements of 9 VAC 5-80-80 G.

(9 VAC 5-80-110 K.1)

P. Duty to Pay Permit Fees

The owner of any source for which a permit under 9 VAC 5-80-50 through 9 VAC 5-80-

300 was issued shall pay permit fees consistent with the requirements of 9 VAC 5-80-310

through 9 VAC 5-80-350. The actual emissions covered by the permit program fees for

the preceding year shall be calculated by the owner and submitted to the Department by

April 15 of each year. The calculations and final amount of emissions are subject to

verification and final determination by the Department.

(9 VAC 5-80-110 H & 9 VAC 5-80-340 C)
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Q. Alternative Operating Scenarios

Contemporaneously with making a change between reasonably anticipated operating

scenarios identified in this permit, the permittee shall record in a log at the permitted

facility a record of the scenario under which it is operating. The permit shield described

in 9 VAC 5-80-140 shall extend to all terms and conditions under each such operating

scenario. The terms and conditions of each such alternative scenario shall meet all

applicable requirements including the requirements of 9 VAC 5 Chapter 80, Article 1.

(9 VAC 5-80-110 J)

R. Inspection and Entry Requirements

The permittee shall allow DEQ, upon presentation of credentials and other documents as

may be required by law, to perform the following:

1. Enter upon the premises where the source is located or emissions-related activity is

conducted, or where records must be kept under the terms and conditions of the

permit.

2. Have access to and copy, at reasonable times, any records that must be kept under the

terms and conditions of the permit.

3. Inspect at reasonable times any facilities, equipment (including monitoring and air

pollution control equipment), practices, or operations regulated or required under the

permit.

4. Sample or monitor at reasonable times substances or parameters for the purpose of

assuring compliance with the permit or applicable requirements.

(9 VAC 5-80-110 K.2)

S. Reopening For Cause

The permit shall be reopened by the Board if additional federal requirements become

applicable to a major source with a remaining permit term of three years or more. Such

reopening shall be completed no later than 18 months after promulgation of the

applicable requirement. No such reopening is required if the effective date of the

requirement is later than the date on which the permit is due to expire, unless the original

permit or any of its terms and conditions has been extended pursuant to 9 VAC 5-80-80

F.

1. The permit shall be reopened if the Board or the administrator determines that the

permit contains a material mistake or that inaccurate statements were made in

establishing the emissions standards or other terms or conditions of the permit.
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December 1, 2003

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2. The permit shall be reopened if the administrator or the Board determines that the

permit must be revised or revoked to assure compliance with the applicable

requirements.

3. The permit shall not be reopened by the Board if additional applicable state

requirements become applicable to a major source prior to the expiration date

established under 9 VAC 5-80-110 D.

(9 VAC 5-80-110 L)

T. Permit Availability

Within five days after receipt of the issued permit, the permittee shall maintain the permit

on the premises for which the permit has been issued and shall make the permit

immediately available to DEQ upon request.

(9 VAC 5-80-150 E)

U. Transfer of Permits

1. No person shall transfer a permit from one location to another, unless authorized

under 9 VAC 5-80-130, or from one piece of equipment to another.

(9 VAC 5-80-160)

2. In the case of a transfer of ownership of a stationary source, the new owner shall

comply with any current permit issued to the previous owner. The new owner shall

notify the Board of the change in ownership within 30 days of the transfer and shall

comply with the requirements of 9 VAC 5-80-200.

(9 VAC 5-80-160)

3. In the case of a name change of a stationary source, the owner shall comply with any

current permit issued under the previous source name. The owner shall notify the

Board of the change in source name within 30 days of the name change and shall

comply with the requirements of 9 VAC 5-80-200.

(9 VAC 5-80-160)

V. Permit Revocation or Termination for Cause

A permit may be revoked or terminated prior to its expiration date if the owner

knowingly makes material misstatements in the permit application or any amendments

thereto or if the permittee violates, fails, neglects or refuses to comply with the terms or

conditions of the permit, any applicable requirements, or the applicable provisions of 9

VAC 5 Chapter 80 Article 1. The Board may suspend, under such conditions and for

such period of time as the Board may prescribe, any permit for any of the grounds for

revocation or termination or for any other violations of these regulations.

(9 VAC 5-80-190 C & 9 VAC 5-80-260)
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December 1, 2003

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W. Duty to Supplement or Correct Application

Any applicant who fails to submit any relevant facts or who has submitted incorrect

information in a permit application shall, upon becoming aware of such failure or

incorrect submittal, promptly submit such supplementary facts or corrections. An

applicant shall also provide additional information as necessary to address any

requirements that become applicable to the source after the date a complete application

was filed but prior to release of a draft permit.

(9 VAC 5-80-80 E)

X. Stratospheric Ozone Protection

If the permittee handles or emits one or more Class I or II substances subject to a

standard promulgated under or established by Title VI (Stratospheric Ozone Protection)

of the federal Clean Air Act, the permittee shall comply with all applicable sections of 40

CFR Part 82, Subparts A to F.

(40 CFR Part 82, Subparts A-F)

Y. Asbestos Requirements

The permittee shall comply with the requirements of National Emissions Standards for

Hazardous Air Pollutants (40 CFR 61) Subpart M, National Emission Standards for

Asbestos as it applies to the following: Standards for Demolition and Renovation (40

CFR 61.145), Standards for Insulating Materials (40 CFR 61.148), and Standards for

Waste Disposal (40 CFR 61.150).

(9 VAC 5-60-70 and 9 VAC 5-80-110 A.1)

Z. Accidental Release Prevention

If the permittee has more, or will have more than a threshold quantity of a regulated

substance in a process, as determined by 40 CFR 68.115, the permittee shall comply with

the requirements of 40 CFR Part 68.

(40 CFR Part 68)

AA. Changes to Permits for Emissions Trading

No permit revision shall be required under any federally approved economic incentives,

marketable permits, emissions trading and other similar programs or processes for

changes that are provided for in this permit.

(9 VAC 5-80-110 I)

BB. Emissions Trading

Where the trading of emissions increases and decreases within the permitted facility

is to occur within the context of this permit and to the extent that the regulations

provide for trading such increases and decreases without a case-by-case approval of

each emissions trade:
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December 1, 2003

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1. All terms and conditions required under 9 VAC 5-80-110, except subsection N,

shall be included to determine compliance.

2. The permit shield described in 9 VAC 5-80-140 shall extend to all terms and

conditions that allow such increases and decreases in emissions.

3. The owner shall meet all applicable requirements including the requirements of 9

VAC 5-80-50 through 9 VAC 5-80-300.

(9 VAC 5-80-110 I)

XXI. State-Only Enforceable Requirements

The following terms and conditions are not required under the federal Clean Air Act or under

any of its applicable federal requirements, and are not subject to the requirements of 9 VAC

5-80-290 concerning review of proposed permits by EPA and draft permits by affected states.

None Identified

(9 VAC 5-80-110 N and 9 VAC 5-80-300)