### 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 , 200 3 Robert G. Burnley Signature Date Director, Department of Environmental Quality
Table of Contents, 4 pages Permit, 56 pagesRoanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 2 of 57


### Table of Contents
I. FACILITY INFORMAT ION

................................ ................................ ................................ 6

II. EMISSION UNITS

................................ ................................ ................................ ................. 7

III. FUEL BURNING EQ UIPMENT REQUIREMENTS – NA

................................ ......... 11

IV. PROCESS EQUIPMEN T REQUIREMENTS – RAW MATERIAL PROCESSING 11 A. L IMITATIONS

................................ ................................ ................................ ........................ 11 B. M ONITORING

................................ ................................ ................................ ....................... 12 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 12 D. T ESTING

................................ ................................ ................................ ............................... 12 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 13 V. PROC ESS EQUIPMENT REQUIREMENTS – KILN FEED SYSTEM & RECYCLE DUST

................................ ................................ ................................ ................................ ............ 13 A. L IMITATIONS

................................ ................................ ................................ ........................ 13 B. M ONITORING

................................ ................................ ................................ ....................... 14 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 14 D. T ESTING

................................ ................................ ................................ ............................... 15 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 15 VI. PROCESS EQUIPMEN T REQUIREMENTS – NO. 5 KILN SYSTEM

.................... 15 A. L IMITATIONS

................................ ................................ ................................ ........................ 15 B. M ONITORING

................................ ................................ ................................ ....................... 20 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 23 D. T ESTING

................................ ................................ ................................ ............................... 23 E. R EPORTING (S EE G ENERAL C ONDITIONS )

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

...................... 24 A. L IMITATIONS

................................ ................................ ................................ ........................ 24 B. M ONITORING

................................ ................................ ................................ ....................... 25 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 26 D. T ESTING

................................ ................................ ................................ ............................... 26 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 26 VIII. PROCESS EQUIPM ENT REQUIREMENTS – COAL/COKE GRINDING & HANDLING SYSTEM

................................ ................................ ................................ ............... 26 A. L IMITATIONS

................................ ................................ ................................ ........................ 26 B. M ONITORING

................................ ................................ ................................ ....................... 27 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 28 D. T ESTING

................................ ................................ ................................ ............................... 28 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 28Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 3 of 57 IX. PROCESS EQUIPMENT REQUIREMENTS – CLINKER HANDLING &STORAGE SYSTEM

................................ ................................ ................................ .............. 28 A. L IMITATIONS

................................ ................................ ................................ ........................ 28 B. M ONITORING

................................ ................................ ................................ ....................... 29 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 30 D. T ESTING

................................ ................................ ................................ ............................... 30 E. R EPORTING (S EE G ENERAL C ONDITIONS )

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

.... 30 A. L IMITATIONS

................................ ................................ ................................ ........................ 30 B. M ONITORING

................................ ................................ ................................ ....................... 31 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 32 D. T ESTING

................................ ................................ ................................ ............................... 32 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 32 XI. PROCE SS EQUIPMENT REQUIREMENTS – CEMENT STORAGE SILO SYSTEM

................................ ................................ ................................ ................................ ...... 32 A. L IMITATIONS

................................ ................................ ................................ ........................ 32 B. M ONITORING

................................ ................................ ................................ ....................... 33 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 34 D. T ESTING

................................ ................................ ................................ ............................... 34 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 34 XII. PROCESS EQUIPME NT REQUIREMENTS – CEMENT BULK LOADOUT SYSTEM

................................ ................................ ................................ ................................ ...... 34 A. L IMITATIONS

................................ ................................ ................................ ........................ 34 B. M ONITORING

................................ ................................ ................................ ....................... 35 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 36 D. T ESTING

................................ ................................ ................................ ............................... 36 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 36 XIII. PR OCESS EQUIPMENT REQUIREMENTS – CEMENT BAGGING/PACKING SYSTEM

................................ ................................ ................................ ................................ ...... 36 A. L IMITATIONS

................................ ................................ ................................ ........................ 36 B. M ONITORING

................................ ................................ ................................ ....................... 37 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 38 D. T ESTING

................................ ................................ ................................ ............................... 38 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 38 XIV. PROCESS EQUIPME NT REQUIREMENTS – WASTE DUST STORAGE AND HANDLING SYSTEM

................................ ................................ ................................ ............... 38 A. L IMITATIONS

................................ ................................ ................................ ........................ 38 B. M ONITORING

................................ ................................ ................................ ....................... 39 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 40 D. T ESTING

................................ ................................ ................................ ............................... 40Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 4 of 57 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 40 XV. PROCESS EQUIPMEN T REQUIREMENTS – STORAGE GALLERY

.................. 40 A. L IMITATIONS

................................ ................................ ................................ ........................ 40 B. M ONITORING

................................ ................................ ................................ ....................... 41 C. R ECORDKEEPING (S EE F ACILITY W IDE C ONDITIONS )

................................ ......................... 42 D. T ESTING

................................ ................................ ................................ ............................... 42 E. R EPORTING (S EE G ENERAL C ONDITIONS )

................................ ................................ ........... 42 XVI. FACILITY WIDE C ONDITIONS

................................ ................................ ............... 42 A. L IMITATIONS

................................ ................................ ................................ ........................ 42 B. M ONITORING

................................ ................................ ................................ ....................... 42 C. R ECORDKEEPING

................................ ................................ ................................ .................. 43 D. T ESTING

................................ ................................ ................................ ............................... 44 E. R EPORTING (S EE G ENERAL C ONDITIONS )

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

................................ ................................ ........ 44

XVIII. COMPLIANCE PL AN - NA

................................ ................................ ...................... 45

XIX. PERMIT SHIELD & INAPPLICABLE REQUIREMENTS

................................ .... 45

XX. GENERAL CONDITIO NS

................................ ................................ .............................. 46 A. F EDERAL E NFORCEABILITY

................................ ................................ ................................ . 46 B. P ERMIT E XPIRATION

................................ ................................ ................................ ............ 46 C. R ECORDKEEPING AND R EPORTING

................................ ................................ ....................... 47 D. A NNUAL C OMPLIANCE C ERTIFICATION

................................ ................................ ............... 48 E. P ERMIT D EVIATION R EPORTING

................................ ................................ ........................... 49 F. F AILURE

/M ALFUNCTION R EPORTING

................................ ................................ ................... 49 G. S TARTUP , S HUTDOWN , AND M ALFUNCTION

................................ ................................ ........ 50 H. M ALFUNCTION AS AN A FFIRMATIVE D EFENSE

................................ ................................ ..... 51 I. F UGITIVE D UST E MISSION S TANDARDS

................................ ................................ ............... 52 J. S EVERABILITY

................................ ................................ ................................ ..................... 52 K. D UTY TO C OMPLY

................................ ................................ ................................ ................ 52 L. N EED TO H ALT OR R EDUCE A CTIVITY NOT A D EFENSE

................................ ....................... 53 M. P ERMIT M ODIFICATION

................................ ................................ ................................ .... 53 N. P ROPERTY R IGHTS

................................ ................................ ................................ ............... 53 O. D UTY TO S UBMIT I NFORMATION

................................ ................................ .......................... 53 P. D UTY TO P AY P ERMIT F EES

................................ ................................ ................................ . 53 Q. A LTERNATIVE O PERATING S CENARIOS

................................ ................................ ................ 54 R. I NSPECTION AND E NTRY R EQUIREMENTS

................................ ................................ ............ 54 S. R EOPENING F OR C AUSE

................................ ................................ ................................ ....... 54 T. P ERMIT A VAILABILITY

................................ ................................ ................................ ......... 55 U. T RANSFER OF P ERMITS

................................ ................................ ................................ ........ 55 V. P ERMIT R EVOCATION OR T ERMINATION FOR C AUSE

................................ ........................... 55 W. D UTY TO S UPPLEMENT OR C ORRECT A PPLICATION

................................ .......................... 56Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 5 of 57 X. S TRATOSPHERIC O ZONE P ROTECTION

................................ ................................ .................. 56 Y. A SBESTOS R EQUIREMENTS

................................ ................................ ................................ .. 56 Z. A CCIDENTAL R ELEASE P REVENTION

................................ ................................ ................... 56 AA. C HANGES TO P ERMITS FOR E MISSIONS T RADING

................................ .............................. 56 BB. E MISSIONS T RADING

................................ ................................ ................................ ........ 56 XXI. STATE-ONLY ENFO RCEABLE REQUIREMENTS

................................ .............. 57Roanoke 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/Rated Capacity * Pollution Control Device

(PCD) Description PCD ID Pollutant Controlled 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 & PM 10 6/13/2003

B25-B36 B29,

B30 & B35 Shale crushing plant 500 tph Micropul 78-360 Micropul Micropul 3660, 3543 & 3585 PM & PM 10 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 & PM 1 0 6/13/2003

C21-C37 Limestone & additives

storage/transfer 800 tph PM & PM 10 6/13/2003

C41-C47 C41 &

C45 Raw mix blending, stacker reclaim 900 tph Micropul Micropul 101186 & 102122 PM & PM 10 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 & PM 10 6/13/2003

RS Raw Silos Nos. 1 - 13 165 tph PM & PM 10 6/13/2003Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 8 of 57 Emission Unit ID Stack

ID Emission Unit Description Size/Rated Capacity * Pollution Control Device

(PCD) Description PCD ID Pollutant Controlled 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 & PM 10 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, SO 2 , CO, NO x & VOC 6/13/2003

E2 Main Raw mill No. 2 250 tph Environmental Elements (ESP) E54 PM, SO 2 , CO, NO x & VOC 6/13/2003

K Main No. 5 precalciner Kiln 184 tph Environmental Elements (ESP) K34 PM, SO 2 , CO, NO x & VOC 6/13/2003

Clinker Cooler

C K43 Clinker cooler 184 tph Airpol Inc. IF400/H2P/340- I88130/IT/K/L2D 505300 PM & PM 10 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-8-20Micropul36S504240, 504340, 504265, 504365, 205912 & 504182 PM & PM 10 6/13/2003

Clinker Storage & ConveyingRoanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 9 of 57 Emission Unit ID Stack

ID Emission Unit Description Size/Rated Capacity * Pollution Control Device

(PCD) Description PCD ID Pollutant Controlled 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 & PM 10 6/13/2003

Clinker Grinding
FM5 501 &

502 Finish grinding mill No. 5 20 tph Norfelt HE14-6 Norfelt HE5-6 426111 & 426110 PM & PM 10 6/13/2003

FM6 601 &

602 Finish grinding mill No. 6 20 tph Norfelt HE13-6 Norfelt HE5-6 427111 & 427110 PM & PM 10 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 & PM 10 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 & PM 10 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 & PM 10 6/13/2003

Cement Storage
SG1 159 &

161 Finish silos group No. 1 200 tph Sly SBR-78-10-BV Sly SBR-78-10-BV 634110 & 634120 PM & PM 10 6/13/2003Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 10 of 57 Emission Unit ID Stack

ID Emission Unit Description Size/Rated Capacity * Pollution Control Device

(PCD) Description PCD ID Pollutant Controlled Applicable Permit

Date SG2 164 Finish silos group No. 2 200 tph Sly STJ-1011-10 635050 PM & PM 10 6/13/2003 SG3 168 Finish silos group No. 3 200 tph Sly STJ-1011-10 637030 PM & PM 10 6/13/2003
SG4 172 &

174 Finish silos group No. 4 200 tph Micropul 100S-10-20 Micropul 100S-10 637030 & 637110 PM & PM 10 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 & PM 10 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 & PM 10 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 & PM 10 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 & PM 10 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 shallRoanoke 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 conditioningRoanoke 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. SO 2 , NO x , 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. SO 2 shall also be controlled by the operation of a process lime injection system as needed to help meet the SO 2 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 SO 2 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, SO 2 , 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 Permit Number: VA-20232 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 SO 2 emissions from the main stack verifies that there is "no statistically significant increase" of SO 2 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 SO 2 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 SO 2 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 theyqualify 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 95 0. lbs/hr 3,104.4 tons/yr
Nitrogen Oxides 982. lbs/hr 2,850 tons/yr (as NO 2 )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, CO 2 or O 2 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, CO 2 or O 2 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 inRoanoke 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 CementRoanoke 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 28 of 57 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 itRoanoke 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 30 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)



### 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 Permit Number: VA-20232 December 1 , 2003 Page 31 of 57 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 32 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)



### 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 33 of 57 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 permitteeRoanoke 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 35 of 57 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 Permit Number: VA-20232 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 CementRoanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 37 of 57 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 38 of 57 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 accessRoanoke 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 Permit Number: VA-20232 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 41 of 57 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 42 of 57 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 visibleRoanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 43 of 57 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 44 of 57 6. The annual emissions of SO 2 , 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 NO x , CO 6 mm Btu/hr
G-1 Diesel Emergency generator for

Kiln drive 9 VAC 5-80-720 B PM, NO x , CO, SO 2 300 HP

G-2 Diesel emergency process

water pump 9 VAC 5-80-720 B PM, NO x , CO, SO 2 300 HP
G-3 Portable diesel water pump 9 VAC 5-80-720 B PM, NO x , CO, SO 2 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 total multiple containers T-12 Grinding aid tank 9 VAC 5-80-720 B VOC 10,000 galRoanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 45 of 57 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 46 of 57 

### XX. General Conditions

A. Federal Enforceability
All terms and conditions in this permit are enforceable by the administrator and citizensunder 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 47 of 57 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,Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 48 of 57 (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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 49 of 57 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 50 of 57 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 onRoanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 51 of 57 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 52 of 57 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 53 of 57 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 54 of 57 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.Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 55 of 57 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)Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 56 of 57 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:Roanoke Cement Company Permit Number: VA-20232 December 1 , 2003 Page 57 of 57 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)