STATE OF FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION

NOTICE OF PERMIT



### DEP File No. 1190041-001-AC, PSD-FL-358 Center Hill Plant Sumter County In the Matter of an Application for Permit

by:
Mr. Daniel R. Fritrz, CEO/President Sumter Cement Company,

LLC. P.O. Box 410 Sanford, Florida 32008

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Enclosed is the Final Permit Number 1190041-01-AC (PSD-FL-358) authorizing the construction of a greenfield portland cement plant with a dry process preheater/calciner kiln, in-line raw mill, clinker cooler and associated materials handling, storage, conveyance and shipping facilities. The nominal capacity is 1,715,500 tons per year of clinker. The proj ect will be located in the town of Center Hill, Sumter County. This permit is issued p1;lrsuant to Chapter 403, Florida Statutes. Any party to this order (peimit) has the right to seek judicial review of the permit pursuant to Section 120.68, F.S., by the filing of a Notice of Appeal pursuan~(o Rule 9.110, Florida RuJes of Appellate Procedure, with the Clerk of the Department in the Legal Office; and by filing a copy of the Notice of Appeal accompanied by the applicable filing fees with the appropriate District Court of Appeal. The Notice of Appeal must be filed within 30 (thirty) days from the date this Notice is filed with the Clerk of the Department.
Executed in Tallahassee, Florida. 

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Trina L. Vielhauer, Chief Bureau of Air Regulation



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### CERTIFICATE OF SERVICE

The undersigned duly designated deputy agency clerk hereby certifies that this NOTICE OF FINAL PERMIT (including the FINAL permit) was sent by cert~7~ I}l~i~ (*) and copies were sent by U.S. Mail or electronic mail before the close of business on 6J.; bj (J~ to the person(s) listed:
Dan Fritz, SCC* Joyce Christie Joe Horton, SCC Carol Correa Diana Lamb, Clerk for City of Center Hill City Council Margaret Dwyer Mayor, Center Hill Martin Farber Chair, Sumter County BCC Carol and Rudy Grossouw Gregg Worley, U.S. EPA Region'4, Atlanta GA Everett Hadley
, John Bunyak, National Park Service, Denver CO Lorn and Judy Kerr Mara Nasca, DEP SWD Douglas R. Kinney Porter Rivers III, P .E., B.P. Barber & Associates John and Theresa McCormick Cary Cohrs, NRCF dba ACC Eugenie Mamarchev Marvin A. Beier Ivan Mamarchev Louise Racine '" John Megan Pauline T. Beier :, Sue Michalson Anton and Anke Brok Lfl~ence H. Paser Ruth E. Brown June B. Pager ; H. Callahan Joel Rosenblum Ann Cantlin-Elkins Hans Thiemann



### Clerk Stamp FILING AND ACKNOWLEDGMENT FILED, on this date, pursuant to §120.52, Florida Statutes, with the designated Department Clerk, receipt of which is ( hereby acknowledged.



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+~:Twin Towers Office Building 2600 Blair Stone Road Tallahassee. Florida 32399-2400 Colleen M. Castille Secretary Jeb Bush Governor

DEP File No. 1190041-001-AC Air Permit No. PSD-FL-358 Center Hill Cement Plant Expiration date: June 30, fOIO 

### PERMITTEE:
Sumter Cement Company,

LLC Post Office Box 410 Branford, Florida 32008
Authorized

Representative: Dan Fritz, CEO/President

PROJECT AND LOCATION
This permit authorizes the construction of a greenfield portland cement plant with a dry process preheater/calciner kiln, in-line raw mill, clinker cooler ahd associated materials handling, storage, conveyance and shipping facilities. The nominal capacity is 1,715,500 tons per year of clinker. The project will be located in the town of Center Hill, Sumter County. 1<. ,.'

STATEMENT OF BASIS
The permit is issued under th'e provisions of Chapter 403 of the Florida Statutes (F .S.), and Chapters 62-4,62- 204,62-210,62-212,62-296, and 62-297 of the Florida Administrative Code (F.A.C.). The project was processed in accordance with the requirements of Rule 62~212.400, F.A.C., the preconstruction review program for the Prevention of Significant Deterioration (PSD) of Air Quality. The permittee is authorized to perform the proposed work in accordance with the conditions of this permit and as described in the application, approved drawings, plans, and other documents on file with the Department of Environmental Protection (Department).

The attached Appendices are made a part of this permit: Appendix BD Final BACT Determination and Emissions Standards Appendix C Common State Rules Appendix GC Construction Permit General Conditions Appendix LLL NESHAP Subpart LLL Requirements Appendix 000 NSPS Subpart 000 Requirements Appendix Y NSPS Subpart Y Requirements



### ItA.-l ..<f ~ ~
Michael G. Cooke, Director Division of Air Resources Management



### .J L li' I tJ,;. Effective Date:

"More Protection, Less Process'

Printed on recycled

paper.

### SECTION I. GENERAL INFORMATION

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 2 of 32 FACILITY DESCRIPTION The proposed facility will be a dry process greenfield portla nd cement plant incorporating a dry process kiln with a preheater and calciner (PH/C). The nominal capacity is 1,715,500 tons per year of clinker. Major equipment associated with the main components of the plant will include the following:

• A raw materials storage building (MSB) and a limestone storage building;

• A primary crusher at the quarry and belt conveyors to MSB;

• Raw material piles stored inside of the storage bu ildings. The piles will include limestone, alumina sources (e.g. bauxite and coal ash), iron sources (e.g. mill scal e, slag, and iron ore), silica sources (e.g. sand, and clay), and additives (e.g. feldspar, and gypsum);

• Materials handling equipment including reclaimers, st ackers, belt conveyors, covered conveyors from the MSB and limestone storage building to the raw mill, control system/analyzer, etc.;

• An in-line raw mill that simultaneously dries raw mate rials using the exhaust gas from the kiln, PH/C, and clinker cooler;

• A preheater with staged combustion calciner and selective non-catalytic reduction (SNCR) system;

• An air heater for use when additional drying capacity is required;

• A nominal 12,000 ton per day blending silo;

• An indirect-firing system with a Low NO X main kiln burner capable of burning coal, petroleum coke, fuel oil, and natural gas;

• A whole tire feeder and/or tire gasification system.

• A clinker cooler with cooling air fans, and hot air ducting to the kiln, PH/C, and raw mill;

• Clinker storage and grinding including two finish mills with air separators, clinker silos with metering devices, limestone and gypsum bins and associated conveyors;

• Cement transfer and storage silos, truck loadouts and packhouse; and

• A nominal 28.4 TPH coal and/or petroleum coke grinding system with associated mill, storage facility, associated conveyors, and equipped with a fabric filter baghouse.
REGULATORY CLASSIFICATION
Title III : The cement plant will be a major source of hazardous air pollutants (HAP).
Title V: The cement plant will be a Title V major source in accordance with Chapter 62-213, F.A.C. because the potential emissions of at least one regulated pollutant exceed 100 tons per year. Regulated pollutants include pollutants such as carbon monoxide (CO), nitrogen oxides (NO X ), particulate matter (PM/PM 10 ), sulfur dioxide (SO 2 ), and volatile organic compounds (VOC).
PSD: The facility is located in an area that is designate d as “attainment”, “maintenance”, or “unclassifiable” for each pollutant subject to a National Ambient Air Quality Standard. It is classified as a “portland cement plant”, which is one of the 28 Prevention of Significant Deteri oration (PSD) Major Facility Categories with the lower PSD applicability threshold of 100 tons per year. Potentia l emissions of at least one regulated pollutant exceed 100 tons per year, therefore the facility is classified as a major source of air pollution with respect to Rule 62- 212.400 F.A.C., Prevention of Significant Deterioration of Air Quality.
NSPS: Portions of the cement plant are subject to th e following New Source Performance Standards (NSPS) in 40 CFR 60: Subpart A (General Provisions); Subpart Y (Coal Preparation Plants); and Subpart OOO (Non Metallic Mineral Processing). Any affected source s ubject to the provisions of 40 CFR 63, Subpart LLL

### SECTION I. GENERAL INFORMATION

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 3 of 32 (Portland Cement Manufacturing Industry) is exempt from any otherwise applicable new source performance standard contained in 40CFR 60, S ubpart F (Portland Cement Plants).
NESHAP: Portions of the cement plant are subject to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR 63: Subpart A (Gen eral Provisions); and Subpart LLL (Portland Cement Manufacturing Industry).
State Rules: The cement plant is subject to state Rule 62-296.407, F.A.C. (Portland Cement Plants).
EMISSIONS UNITS This permit authorizes the construction of a new Portla nd cement plant. The project includes the following new emissions units:

EU ID Emissions Unit Description

001 (CH-1) - Primary Crushing, and Associated Conveyors. Includes front end loaders to primary crusher, primary crusher operation, base rock a nd limestone conveyors to base rock storage pile and limestone storage building.
002 (CH-2) - Raw Material Conveying and transfer to and from storage piles.
003 (CH-3) - Raw Material Processing and Storage. Including raw material transport from raw mill to blend silo, blend silo, fly ash silo, and kiln feed and fly ash transport to kiln.
004 (CH-4) - Pyroprocessing System. Includes preh eater/precalciner kiln with in-line raw mill, clinker cooler and air heater.
005 (CH-5) - Clinker Storage and Conveying. In cludes clinker transport from kiln; clinker, limestone, and gypsum silos; and clinker, lim estone and gypsum conveying to finish mills.
006 (CH-6) - Finish Mills Cement Processing. Includes two finish mills, cement silos, packaging plant and truck loadout.
007 (CH-7) - Coal and Petroleum Coke Grinding System. Includes coal mill and ground coal/petroleum bins.
008 (CH-8) – Coal and Petroleum Coke Conveying. Includes coal/petroleum coke handling and conveying from unloading to storage bins.
010 (CH-10, CH-11) – Fugitive Dust From Storag e Piles, Paved Roads, and Unpaved Roads.

RELEVANT DOCUMENTS The documents listed are not a part of this permit; however, this information is specifically related to the permitting action and is on file with the Department.

• Application received on June 16 , updated September 8, 2005

• Department’s Request for Additiona l Information dated October 9, 2005

• Response to Request for Additional Information Received October 21, 2005

• Public Notice of Application published December 1, 2005

• Department’s Technical Evaluation and Preliminary Determination dated December 21, 2005

• Department’s Intent to Issue and Public Notice Package dated December 21, 2005

• Department’s Final Determination and Best Ava ilable Control Technology Determination issued concurrently with this Final Permit

### SECTION II. ADMINISTRATIVE REQUIREMENTS

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 4 of 32 1. Permitting Authority : All documents related to PSD applicati ons for permits to construct or modify emissions units shall be submitted to the Bureau of Air Regulation of the Florida Department of Environmental Protection (DEP) at 2600 Blair Stone Road (MS #5505), Tallahassee, Florida 32399-2400. Copies of all such documents shall also be submitted to the Compliance Authority. All documents related to applications for permits to construct minor sources of air pollution or to operate the facility shall be submitted to the Air Resources Section of the Department’s Southwest District Office at 13051 N. Telecom Parkway, Temple Terrace, FL 33637-0926.
2. Compliance Authority : All documents related to compliance activities such as reports, tests, and notifications shall be submitted to the Air Resources S ection of the Department’s Southwest District Office at 13051 N. Telecom Parkway, Temple Terrace, FL 33637-0926.
3. Applicable Regulations, Forms and Application Procedures : Unless otherwise indicated in this permit, the construction and operation of the subject emissions unit shall be in accordance with the capacities and specifications stated in the application. The facility is subject to all applicable provisions of: Chapter 403 of the Florida Statutes (F.S.); Chapters 62-4, 62- 204, 62-210, 62-212, 62-213, 62-296, and 62-297 of the Florida Administrative Code (F.A.C.); and Title 40, Pa rts 51, 52, 60, 63, 72, 73, and 75 of the Code of Federal Regulations (CFR) adopted by reference in Ru le 62-204.800, F.A.C. The terms used in this permit have specific meanings as defined in the applicable chapters of the Florida Administrative Code. The permittee shall use the applicable forms listed in Rule 62-210.900, F.A.C. and follow the application procedures in Chapter 62-4, F.A.C. Issuance of th is permit does not relieve the permittee from compliance with any applicable federal, state, or local pe rmitting or regulations. [Rules 62-204.800, 62-210.300 and 62- 210.900, F.A.C.]
4. Construction and Expiration : The permit expiration date includes sufficient time to complete construction, perform required testing, submit test reports, and submit an application for a Title V operation permit to the Department. Approval to construct shall become invalid for any of the following reasons: construction is not commenced within 18 months after issuance of this permit; construction is discontinued for a period of 18 months or more; or construction is not completed within a reasonable time. The Department may extend the 18-month period upon a satisfactory showing that an extension is justified. In conjunction with an extension of the 18-month period to commence or con tinue construction (or to construct the project in phases), the Department may require the permittee to demonstrate the adequacy of any previous determination of Best Available Control Technology (B ACT) for emissions units regulated by the project. For good cause, the permittee may request that this PSD ai r construction permit be extended. Such a request shall be submitted to the Department’s Bureau of Ai r Regulation at least sixty (60) days prior to the expiration of this permit. [Rules 62-4.070(4), 62-4.080, 62-210.300(1), and 62-212.400(6)(b), F.A.C.; 40 CFR 52.21(r)(2); 40 CFR 51.166(j)(4)]
5. New or Additional Conditions : For good cause shown and after notice and an administrative hearing, if requested, the Department may require the permittee to conform to new or additional conditions. The Department shall allow the permittee a reasonable time to conform to the new or additional conditions, and on application of the permittee, the Department may grant additional time. [Rule 62-4.080, F.A.C.]

6. Relaxations of Restrictions on Pollutant Emitting Capacity

. If a previously permitted facility or modification becomes a facility or modification whic h would be subject to the preconstruction review requirements of this rule if it were a proposed new facility or modification solely by virtue of a relaxation in any federally enforceable limitation on the capacity of th e facility or modification to emit a pollutant (such as a restriction on hours of operation), which limitation was established after August 7,1980, then at the time of such relaxation the preconstruction review requirements of this rule shall apply to the facility or modification as though construction had not yet commenced on it. [Rule 62-212.400(2)(g), F.A.C.]

### SECTION II. ADMINISTRATIVE REQUIREMENTS

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 5 of 32 7. Modifications : No emissions unit or facility subject to this permit shall be constructed or modified without obtaining an air construction permit from the Department . Such permit shall be obtained prior to beginning construction or modification. [Rule 62- 4.030 and Chapters 62-210 and 62-212, F.A.C.]
8. Title V Permit : This permit authorizes construction of the permitted emissions units and initial operation to determine compliance with Department rules. A T itle V operation permit is re quired for regular operation of the permitted emissions units. The permittee shall apply for a Title V operation permit at least 90 days prior to expiration of this permit, but no later than 180 days after commencing operation. To apply for a Title V operation permit, the applicant shall submit the appropriate application form, compliance test results, and such additional information as the Department may by law require. The application shall be submitted to the Compliance Authority. [Rules 62-4.030, 62-4.050, 62-4.220 and Chapter 62-213, F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS A. Primary Crushing

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 6 of 32 The specific conditions of this subsection apply to the following emissions unit after construction is complete.

EU ID Emission Unit Description

001 (CH-1) - Primary Crushing, and Associated Conveyors. Includes front end loaders to primary crusher, primary crusher operation, base rock a nd limestone conveyors to base rock storage pile and limestone storage building
The primary crushing and conveying system contains the following emission points.

Point ID Emissions Point Description

CH-1-1 Primary Crushing and Conveying – loader to primary crusher, primary crusher, and conveyors

CH-1-2 Base Rock Conveying – belts to radial stacker

CH-1-3 Limestone Conveying - belts

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for, particulate matter (PM/PM 10 ). To satisfy the BACT requirements for this unit the visible emissions limits are surrogate standards for PM.
2. NSPS Requirements : This unit shall comply with all applicable requirements of 40 CFR 60, Subparts A (General Provisions) and OOO (Nonmetallic Mineral Pr ocessing Plants) adopted by reference in Rule 62- 204.800(7)(b), F.A.C. The Department determines th at the BACT emissions performance requirements are as stringent as or more stringent than the limits impo sed by the applicable NSPS provisions. Some separate reporting and monitoring may be requi red by the individual subparts.
E QUIPMENT D ESCRIPTION
3. Equipment Description : The permittee is authorized to construct, operate, and maintain equipment needed for the raw material quarrying, crushing, and storage operati on. Equipment will include a primary crusher at the quarry, and an enclosed limestone storage building ( LSB) which will house the limestone storage piles. Enclosed belt conveyors will be cons tructed between the crusher and the LSB. Open conveyors will transport base rock to the base rock stor age pile. [Applicant Request]
P ERFORMANCE R EQUIREMENTS
4. Hours of Operation : This emissions unit system is allowed to operate 8,760 hours per year. [Applicant Request, Rule62-210.200(PTE), F.A.C.]
5. Process Rate Specification : The crusher may process up to 2,143 tons per hour (TPH) of raw materials. No more than 3,798,428 tons of raw materials sha ll be processed during any consecutive 12 months. {Permitting Note: The process rate includes an estimat ed raw materials moisture content of 17% by weight.} [Rules 62-210.200 (PTE) and 62-4.070(3), F.A.C.]
E MISSIONS A ND T ESTING R EQUIREMENTS
6. Visible Emission Standards : These opacity standards do not apply to truck dumping of nonmetallic minerals into any screening operation, feed hopper, or crusher.

a. Fugitive emissions from the crusher shall not exceed 15% opacity.

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS A. Primary Crushing

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 7 of 32 b. Fugitive emissions from any transfer point on belt c onveyors or from any other affected facility shall not exceed 10% opacity. [Rule 62-212.400(BACT), F.A.C.; and 40 CFR 60, Subpart OOO]
7. Visible Emissions Tests: Compliance with the visible emission limits shall be determined by conducting EPA Method 9 tests. Initial tests shall be conducted 60 days after achieving the maximum production rate at which the unit will be operated, but no later than 180 days af ter initial startup. Thereafter, the permittee shall demonstrate compliance during each federal fiscal year (October 1 st to September 30 th ) for the primary crusher. Tests shall be conducted in accordance with the applicable requirements in Appendix C of this permit as well as the applicable NSPS provisions.
R EPORTING AND R ECORD K EEPING
8. Test Reports: For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the compliance author ity no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C., and 40 CFR 60, Subpart OOO]
9. Process Rate Information: The permittee shall maintain records of the monthly processing rate. Such reports shall be recorded and available for inspection no la ter than 10 days following the end of the month.

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS B. Raw Materials Conveying and Transfer

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 8 of 32 The specific conditions of this subsection apply to the following emissions unit after construction is complete.

EU ID Emissions Unit Description

002 (CH-2) - Raw Material Conveying and transfer to and from storage piles.
The raw materials conveying and transfer systems cont ain all emission points associated with the following

areas:

• Limestone Pile Handling

• Wet Coal Ash Hopper Building

• Wet Coal Ash Pile Handling

• Clay/Sand Hopper Building

• Clay/Sand Pile Handling

• Steel Slag Pile Handling

• Bauxite Pile Handling

• Limestone Conveying • Wet Coal Ash Conveying

• Wet Coal Ash Conveying

• Clay/Sand Conveying

• Bauxite Conveying

• Steel Slag/Iron Ore/Mill Scale Conveying

• Cross belt Analyzer

• Raw Mill Feed Conveying

• Gypsum/Limestone Conveying to Finish Mills
A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for, particulate matter (PM/PM 10 ). To satisfy the BACT requirements for this unit the visible emissions limits are surrogate standards for PM.
2. NESHAP Requirements : This unit is subject to 40 CFR 63, Subpart A (Identification of General Provisions) and 40 CFR 63, Subpart LLL (National Emi ssions Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions performance requirements are as stringent as or more st ringent than the limits imposed by the applicable NESHAP provisions. Some separate reporting and mon itoring may be required by the individual subpart.
E QUIPMENT
3. Equipment Description : The permittee is authorized to construct, operate, and maintain equipment needed for the conveyance and handling of the raw materials. Equipment will include reclaimers, conveyors, belts, loaders, hoppers, and a cross belt analyzer. [Applicant]
P ERFORMANCE R EQUIREMENTS
4. Hours of Operation : This emissions unit system is allowed to operate 8,760 hours per year. [Applicant Request, Rule62-210.200(PTE), F.A.C.]
E MISSIONS AND T ESTING R EQUIREMENTS
5. Visible Emissions Standards : Fugitive emissions from any emissions point shall not exceed 5% opacity. [Rule 62-212.400(BACT)]

6. Compliance Demonstrations: Each emission point shall be tested to demonstrate initial compliance with the emission standards for visible emissions in accordance with EPA Method 9. The tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be operated, but not later than 180 days after the initial startup. Thereafter, compliance with the visible emission limits for each unenclosed transfer point shall be demonstrat ed during each federal fiscal year (October 1 st to September 30 th ). [Rules 62-4.070(3), 62-297.310(7)(a), F.A.C. and 40 CFR 63.1349(b)(2)]
7.

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS B. Raw Materials Conveying and Transfer

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 9 of 32 Periodic Monitoring Requirements : Each affected source subject to an opacity standard shall be periodically monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL]
8. Test Methods : Any required tests shall be performed in acco rdance with the following reference methods and the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions.

Method Description of Method and Comments
9 Visual Determination of the Opacity of Emissions from Stationary Sources

22 Visual Determination of Fugitive Emissions From Material Sources

R EPORTING AND R ECORD K EEPING
9. Test Reports: For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the compliance author ity no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS C. Raw Material Processing and Storage

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 10 of 32 The specific conditions of this subsection apply to the following emissions unit after construction is complete.

ID No. Emissions Unit Description

003 (CH-3) - Raw Material Processing and Storage. Including raw material transport from raw mill to blend silo, blend silo, fly ash silo, and k iln feed and fly ash transport to kiln. The following emissions points in the raw materials processi ng and storage system are controlled by fabric filter baghouses.

Point ID Emissions Point Description

NDC-01 Raw Material Transport From Raw Mill to Homogenizing Silo

NDC-02 Baghouse Dust Bin

NDC-03 Raw Material Transport to Homogenizing Silo

NDC-04 Homogenizing Silo Inlet
NDC-05 Homogenizing Silo

NDC-06 Homogenizing Silo Outlet

NDC-07 Kiln Feed Transport

NDC-08 Fly Ash Silo
NDC-09 Fly Ash Transport to Calciner

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for, particulate matter (PM/PM 10 ). To satisfy the BACT requirements for this unit the visible emissions limits are surrogate standards for PM.
2. NESHAP Requirements : This unit is subject to 40 CFR 63, Subpart A (Identification of General Provisions) and 40 CFR 63, Subpart LLL (National Emi ssions Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions performance requirements are as stringent as or more st ringent than the limits imposed by the applicable NESHAP provisions. Some separate reporting and mon itoring may be required by the individual subpart.
E QUIPMENT A ND C ONTROL T ECHNOLOGY
3. Equipment Description : The permittee is authorized to construct, operate, and maintain equipment needed for the processing and storage of raw materials. Equi pment will include one homogenizing silo (nominal throughput from blend silo of 2,553,018 TPY), one co al ash silo (nominal throughput 278,437 TPY), and associated conveyors, belts, and bucket elevators. [Applicant]
4. Baghouse Controls : Each emissions point identified for raw material processing and storage shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 gr/dscf and a PM 10 design specification of 0.0085 gr/dscf. [Rule 62-212.400(BACT), F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS C. Raw Material Processing and Storage

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 11 of 32 P ERFORMANCE R EQUIREMENTS
5. Hours of Operation : This emissions unit is allowe d to operate 8,760 hours per year. [Applicant Request, Rule62-210.200(PTE), F.A.C
E MISSIONS AND T ESTING R EQUIREMENTS
6. Emissions Limits : Visible emissions are limited to 5% opacity from each of the above listed emissions points controlled by a baghouse. [Rule 62 -212.400(BACT), F.A.C.] {Note: The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) and PM 10 emissions to 0.0085 gr/dscf. The 5% opacity limitation is consistent with this design and provides reasonable assurance that annual emissions of PM/PM 10 from the above emissions points will be less than 12.1/10.28 TPY. Exceedance of the 5% opacity limit shall be deemed an exceedance of this permit condition and not necessarily an exceedance of the opacity limitations given in 40 CFR 63, Subpart LLL.} [Rules 62-4.070(3), 62-212.400, F.A.C. and 40 CFR 63.1348]
7. Compliance Demonstrations: Each emission point shall be tested to demonstrate initial compliance with the emission standards for visible emissions in accordance with EPA Method 9. The tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be operated, but not later than 180 days after the initial startup. Thereafter, compliance with the visible emission limits for each emission point shall be demonstrated during each federal fiscal year (October 1 st to September 30 th ). [Rules 62-4.070(3), 62-297.310(7)(a), F.A.C. and 40 CFR 63.1349(b)(2)]
8. Periodic Monitoring Requirements : Each affected source subject to an opacity standard shall be periodically monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL]
9. Test Methods : Any required tests shall be performed in acco rdance with the following reference methods and the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions.

Method Description of Method and Comments
9 Visual Determination of the Opacity of Emissions from Stationary Sources

22 Visual Determination of Fugitive Emissions From Material Sources

R EPORTING AND R ECORD K EEPING
10. Baghouse O&M Plan : For each baghouse the permittee shall prep are an operation and maintenance (O&M) plan to address proper operation, parametric monitori ng, and a schedule for conducting periodic inspections and preventive maintenance. Baghouse inspections and main tenance activities shall be recorded in a log. The O&M plan shall be submitted to the Compliance Authority prior to the initial compliance tests for this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL]
11. Test Reports: For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the compliance author ity no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C.]SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 12 of 32 The following specific conditions apply to the following emissions unit after construction:

ID No. Emissions Unit Description

004 (CH-4) - Pyroprocessing System. Includes preheater/precalciner kiln with in-line raw mill, clinker cooler and air heater.

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for carbon monoxide (CO), nitrogen oxides (NO X ), sulfur dioxide (SO 2 ), volatile organic compounds (VOC), and particulate matter (PM/PM 10 ).
2. NESHAP Requirements : This unit is subject to 40 CFR 63, Subpart A (Identification of General Provisions) and 40 CFR 63, Subpart LLL (National Emi ssions Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions performance requirements are as stringent as or more st ringent than the limits imposed by the applicable NESHAP provisions for particulate matter. Some sep arate reporting and monitoring may be required by the individual subpart.
E QUIPMENT A ND C ONTROL T ECHNOLOGY
3. Pyroprocessing System : : The permittee is authorized to construct a pyroprocessing system consisting of a dry process pre-heater/calciner rotary kiln with in-lin e raw mill that simultaneously dries raw materials using the exhaust gas from the kiln, PH/C, or cooler. The pr eheater is designed with a staged combustion calciner and a selective non-catalytic reduction (SNCR) system. The kiln will be equipped with a Low NO X main kiln burner capable of burning coal, petroleum coke, natural gas, used oil, and fuel oil. Other equipment includes an air heater for use when additional drying capacity is required, and a clinker cool er with cooling air fans, and hot air ducting to the kiln, PH/C and/or in-line raw m ill. The air heater will be capable of firing fuel oil and natural gas. All emissions from the pyroprocessing system are directed to a single stack. The exhaust stack shall be no more than 16.5 feet in diameter and no less than 427 feet tall. [Applicant Request] 4. Kiln Design : The kiln will be designed to process approximately 353 tons per hour of dry preheater feed material (including baghouse dust recirculation and excluding dry coal ash) with an annual nominal throughput of 2,784,370 tons per year. However, preheater feed rate is ultimately restricted through clinker production limitations. [Applicant Request]
5. NO X Controls a) Low

- NO X Burners and Indirect Firing: The main kiln and calciner will be equipped with Low NO X burners that will create distinct combustion zones within the flame. An indirect firing system will be used to reduce the amount of primary air injected w ith the fuel used in the main kiln burner. b) Staged Combustion in the Calciner (SCC) : Introduction of fuel, air and meal to the calciner will be staged or sequenced for the reduction of NO X emissions. c) SNCR : A selective non-catalytic reduction (SNCR) system shall be designed, cons tructed and operated to achieve the permitted levels for NO X emissions from the pyroprocessing system. The SNCR system will consist of an aqueous ammonia a nd/or urea tank, pumps, piping, compressed air delivery, injectors, control system, and other ancillary equipment. Aqueous ammonia and/or urea solution will be injected at a location(s) in the preheater/calciner with an appropriate temperature profile to support the SNCR process.SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 13 of 32 6. Particulate Matter (PM/PM 10 ) Controls : The permittee shall install a baghouse control system to remove particulate matter emissions from the pyroprocessing exhaust gas stream to achieve the PM/PM 10 emissions standards specified in this permit. 7. Sulfur Dioxide Controls : The use of low-sulfur raw materials will help to keep SO 2 emissions below permitted levels. Additionally, a hydrated lime injection system shall be installed for utilization as needed to reduce SO 2 emissions. P ERFORMANCE R EQUIREMENTS
8. Hours of Operation : The hours of operation for this emissions unit are not limited (8760 hours per year). [Rule62-210.200(PTE), F.A.C.]
9. Process Rate Limitations : Kiln preheater feed rate and dry coal ash shall be monitored and recorded for purposes of determining clinker production. The clinke r production rate of the kiln shall not exceed 208.3 tons per hour (24-hour rolling average) and 1,715,500 tons during any consecutive 12 month period. The clinker production rate shall be determ ined using kiln feed and dry coal ash feed, and kiln and dry coal ash feed loss on ignition (LOI) factors. The feed rates a nd kiln feed LOIs shall be based on a 30 operating-day block average of daily measurements. For purposes of th is requirement, an operating day is any day that the kiln produces clinker or burns fuel. [Rules 62-4.070(3), and 62-212.200(PTE), F.A.C.] 10. Authorized Fuels : Only the following authorized fuels shall be fired in the pyroprocessing system (kiln and calciner): coal, petroleum coke, fly ash, gasified tires, w hole or chipped tires, natural gas, distillate oil, and/or on-specification used oil fuel. The maximum heat input rate to the pyroprocessing system (kiln and calciner) shall not exceed 15,300 MMBtu per day (nominally 638 MMBtu/hr). a) The permittee is authorized to install a tire gasificati on system with an airlock on the feed mechanism. The maximum heat input rate from gasified tires sh all not exceed 40% of the total pyroprocessing heat input rate (kiln and calciner) and shall not exceed 255 MMBtu per hour. The remaining 60% of the total pyroprocessing heat input rate shall come from ot her authorized fuels. The permittee shall provide details of the gasifier system within 30 days of finalizing the design. b) The maximum heat input rate from firing whole or chipped tire derived fuel (TDF) shall not exceed 15% of the total pyroprocessing heat input rate (kiln and calciner) and shall not exceed 96 MMBtu per hour. The remaining 85% of the total pyroprocessing heat input rate shall be from the firing of other authorized fuels. TDF shall be directly fed into the kiln system at the transition section between the base of the calciner and the point where gases exit the kiln. The tire feed mechanism shall be designed with an airlock/gate system. Tires shall be stored, handled and managed in accordance with the provisions of Chapter 62-711, F.A.C. c) Dry coal ash may be injected directly into the calciner. d) The air heater shall fire only natural gas or distillate fuel oil (No. 2 or No. 4) with a design maximum heat input rate of 80 MMBtu per hour. e) The firing of “on-specification” used oil fuel shall not exceed 2000 gallons per hour and 3,000,000 gallons during any consecutive 12 months. On-Speci fication Used Oil Fuel shall meet the following specifications:
1. Arsenic shall not exceed 5.0 ppm; 2. Cadmium shall not exceed 2.0 ppm; 3. Chromium shall not exceed 10.0 ppm; 4. Lead shall not exceed 100.0 ppm; 5. Total halogens shall not exceed 1000 ppm; andSECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 14 of 32 6. Flash point shall not be less than 100° F. Used oil fired as a fuel may be generated from on site sources or purchased from a vendor. Used oil shall not contain any PCB’s. [40 CFR 279.61; 40 CFR 761.20(e); Rule 62-4.070(3), F.A.C.]
11. Prohibited Fuels and Materials : The owner or operator shall not introduce into any part of the process or emission control equipment any of the following fuels and materials: hazardous wastes; petroleum contaminated soil or materials; used oil, oil fuels, or solid fuels other than those allowed by this permit; or solid wastes other than tires as allowed by this permit. [Rule 62-4.070(3), F.A.C.] 12. Cement Kiln Dust : Cement kiln dust shall be re-circulated in the process and shall not be directly discharged from process or emission control equipment. Ceme nt kiln dust removed from process equipment during maintenance and repair shall be confined and controlled at all times and shall be managed in accordance with the applicable provisions of 40 CFR 261. [Rule 62-4.070(3), F.A.C.] E MISSIONS AND T ESTING R EQUIREMENTS
13. Emissions Standards: Emissions from the pyroprocessing system (including the air heater) shall not exceed the following emissions standards.

Pollutant Emission Limit Averaging Time Compliance Method Basis
2.9 lb/ton of clinker CO 604.1 lb/hr 30-day rolling CEMS BACT

1.95 lb/ton of clinker NO X a 406.19 lb/hr 30-day rolling CEMS BACT

0.153 lb/ton of clinker 31.87 lb/hr Three 1-hr runs Annual Test PM/PM 10 b

10 % opacity 6-minute block COMS BACT

0.20 lb/ton of clinker SO 2 41.66 lb/hr 24-hr rolling CEMS BACT

0.115 lb/ton of clinker VOC c 23.95 lb/hr 30-day block CEMS BACT 0.20 ng/dscm (TEQ) @ 7% O 2 Dioxin/Furan d 0.40 ng/dscm (TEQ) @ 7% O 2 Three 3-hr runs Temperature Monitoring NESHAP LLL

THC 50 ppmvd (as propane)@ 7% O 2 30-day block CEMS NESHAP LLL Mercury e 184 lb/12-month period 12-month rolling Fuel/Materials and/or CEMS Avoid PSD

a. For an “initial startup period” NOx emissions shall not exceed 3.0 lb/ton of clinker (624.9 lb/hour) based on a 30-day rolling average. The “initial start up” period shall begin after initial certification of the NOx CEMS and shall end as soon as any of the following conditions are met: 1) The Kiln system produces 121,500 tons of clinker or more in any 30-day rolling period. 2) The Kiln system produces 250,000 tons of clinker. 3) 365 days calendar days elapse after initial certification of the NOx CEMS. After the “initial startup” period ends, NOx emissi ons shall not exceed 1.95 lb/ton of clinker (406.19 lb/hour) based on a 30-day rolling average. These requirements do not waive or vary any applicable NSPS or NESHAP monitoring or record keeping requirements. b. All PM emitted from the baghouse exhaust is assumed to be PM10. The BACT standard for PM is equivalent to approximately 0.09 lb per ton of pr eheater feed material. The emissions limits for particulate matter and visible emissions imposed by Rule 62-212.400(BACT) are as stringent as or moreSECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 15 of 32 stringent than the limits imposed by the applicable NESHAP provisions. The BACT requirements do not waive or vary any applicable NESHAP monitoring or record keeping requirements.

c. Compliance shall be demonstrated by THC CEMS. VOC emissions shall be measured as total hydrocarbons (THC) and expressed as “propane” for the mass emissions rate. d. Dioxin/furans shall not exceed 0.20 ng/dscm (TEQ) @ 7% oxygen when the average of the performance test run temperatures at the inlet to the particulate matter control device is 204° C (400° F) or more and shall not exceed 0.40 ng/dscm (TEQ) @ 7% oxygen when the average of the performance test run average particulate matter control device inlet temperature is 204° C (400° F) or less.

e. Compliance shall be demonstrated using the sampli ng, analysis, and calculation methods specified in permit Condition No. 21. {Note: In combination with the annual clinker pr oduction limitation of 1,715,500 tons per year, the above emissions standards effectively limit annual potential em issions from this unit to: 2,487.5 tons/year of CO; 1,673 tons/year of NOx (after year one); 131 tons /year of PM/PM10; 172 tons/year of SO2; and 99 tons/year of VOC. Note that first year annual NOx emissions could be as high as 2,573 tons/year.} [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
14. Test Methods : Any required stack tests shall be perform ed in accordance with the following methods.
EPA Method Description of Method and Comments

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content. Methods shall be performed as necessary to support other methods.
5 Determination of Particulate Emissions. The minimum sample volume shall be 30 dry standard cubic feet.
6C Determination of SO2 Emissions (Instrumental).
7E Determination of NOx Emissions (Instrumental). NOx emissions testing shall be conducted with the air heater operating at the highest heat input possible during the test.
9 Visual Determination of Opacity
10 Measurement of Carbon Monoxide Emissions (Instrumental). The method shall be based on a continuous sampling train.
23 Measurement of Dioxin/Furan Emissions
25A Measurement of Gaseous Organic Concentr ations (Flame Ionization – Instrumental) The methods are specified in Appendix A of 40 CFR 60, adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written appr oval is received from the Department. Tests shall be conducted in accordance with the appropriate test method and the applicable requirements specified in Appendix C of this permit, NSPS Subpart A in 40 CFR 60, and NESHAP Subparts A and LLL in 40 CFR 63. [Rules 62-204.800, F.A.C.; 40 CFR 60, Appendix A]
15. Testing Requirements : Initial tests shall be conducted betw een 90% and 100% of permitted capacity; otherwise, this permit shall be modified to reflect the true maximum capacity as constructed. Subsequent annual tests shall be conducted be tween 90% and 100% of permitted capacity in accordance with the requirements of Rule 62-297.310(2), F.A.C. Tests sh all be conducted for each required pollutant under the fuel scenario representing the highest potential for genera ting emissions. In general, this fuel scenario is firing coal as the primary fuel and firing TDF, petroleum coke, and coal ash as secondary fuels. If a secondary fuel listed above is not available at the time of testing, tests shall be based on the fuels that areSECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 16 of 32 available. If a secondary fuel is adde d later, additional tests shall be conducted with that fuel scenario within 60 days of first fire of the new secondary fuel. [Rule 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] 16. Initial Compliance Demonstration : Initial compliance stack tests shall be conducted within 60 days after achieving a daily average clinker production rate of 187 tons per hour, but not later than 180 days after the initial startup. In accordance with the test methods specifi ed in this permit, the kiln system exhaust stack shall be tested to demonstrate compliance with the emission standards for particulate matter, CO, SO 2 , NO X , dioxin/furans, and THC. The initial compliance demons tration with the THC, and dioxin/furans emissions standards shall be carried out in accordance with 63.1349(b). The permittee shall provide the Compliance Authority with any other initial emissions perform ance tests conducted to satisfy vendor guarantees. [Rule 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] 17. Subsequent Compliance Testing : Annual compliance stack tests for particulate matter CO, NO X , and SO 2 shall be conducted during each federal fiscal year (October 1 st to September 30 th ). Subsequent dioxins/furans tests shall be conducted in accordance with the provi sions of 40 CFR 63.1349. Data collected from the reference method during the required RATA tests for CO, NO X , and SO 2 may be used to satisfy the annual testing requirement provided the notification requireme nts and emission testing requirements for performance and compliance tests of this permit are satisfied. [Rules 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] 18. Continuous Compliance : Continuous compliance with the permit st andards for opacity and emissions of CO, NOx, SO2, and VOC/THC shall be demonstrated with data collected from the required continuous monitoring systems. [Rules 62-212.400(5)(c) and 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] 19. Supplemental Dioxin/Furan and PM/PM10 Tests : The owner or operator shall notify the Compliance Authority prior to initiating any significant change in th e feed or fuel used in the most recent compliant performance test for dioxin/furan or PM/PM10. For pur poses of this condition, significant means any of the following: a physical or chemical change in the feed or fuel ; the use of a raw material not previously used; a change in the LOI of the coal ash; a change between non-beneficiated coal ash and beneficiated coal ash. Based on the information provided, the Compliance Aut hority will promptly determine if performance testing pursuant to 40 CFR 63.1349 will be required for the new feed or fuel. A significant change shall not include switching to a feed/fuel mix for which the permittee alr eady tested in compliance with the dioxin/furan and PM/PM10 emission limits. [62-4.070(3), F.A.C.] 20. Special Compliance Tests : When the Department, after investig ation, has good reason (such as complaints, increased visible emissions or questionable maintenance of control equipment) to believe that any applicable emission standard contained in a Department rule or in a permit issued pursuant to those rules is being violated, it shall require the owner or operator of the emissions unit to conduct compliance tests which identify the nature and quantity of pollutant emissions from the emissions unit and to provide a report on the results of said tests to the Department. [Rule 62-297.310(7)(b), F.A.C.] 21. Mercury Compliance Demonstration :

a. Material Balance Demonstration: The owner or operator shall demonstrate compliance with the mercury throughput limitation by material balance a nd maintaining records of the monthly and rolling 12-month mercury throughput. Samples of the raw mill feed and all fuels shall be collected each day. A single composite daily sample shall be made from all samples collected during a day. A monthly composite sample shall be made from each of the daily composite samples. Each monthly composite sample shall be analyzed to determine the mercury concentration of the materials representative for the month. The analytical methods used to determ ine mercury concentration shall be EPA or ASTM methods such as EPA Method 7471A (Mercury in Solid or Semisolid Waste). No other methods may be used unless prior written approval is received from the Department. For each raw material and fuel, the monthly mercury throughput rate (pounds per month) shall be the product of the mercury concentration from the monthly composite sample and the mass of raw material or fuel used during the month. If the mercury concentration is below detec tion limit or below the limits of quantification, theSECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 17 of 32 detection limit will be assumed for the concentration of the raw material or fuel. For each month, the mass of mercury introduced into the pyroprocessing system (pounds per month) shall be the sum of the monthly mercury throughput rate for each raw material and fuel. The consecutive 12-month mercury throughput rate shall be the sum of the individual monthly records for the current month and the preceding eleven months (pounds of mercury per consecutive 12-months). Such records, including calculations and data, shall be co mpleted no later than 25 days following the month of the records.
b. Mercury Continuous Emissions Monitoring System (Hg-CEMS) : Within 60 days following the first year of operation, the owner or operator shall install any model of Hg-CEMS that has been demonstrated to meet the requirements in Performance Specification 12A (PS-12A), “Specifications and Test Procedures for Total Vapor phase Mercury Continuous Monitoring Systems in Stationary Sources,” or that has passed verification tests conducted under the auspices of the U.S. Environmental Protection Agency’s (EPA) Environmental Technology Verification (ETV) Program. During the subsequent 90 days, the owner or operator shall certify the Hg-CEMS. If the vendor provides to the Department verification of certification difficulties such that the CEMS cannot be certified by the certification deadline, and every reasonable effort has been made to do so, the Depart ment shall grant a reasonable extension of time to certify the CEMS. After certification the owner or operator will begin reporting Hg mass emissions data. The owner or operator sh all adhere to the calibration drift and quarterly accuracy assessment procedures in 40 CFR Part 60, Appendix F or 40 CFR Part 75, Appendix B. The 12-month rolling mass emissions shall be estimated based on the actual data collected no later than 10 days following the end of the month. The CEMS shall only be used as the method of compliance if the owner or operator notifies the Department of the intent to use the CEMS in lieu of the procedures described in the preceding paragraph. Prior to use of the Hg-C EMS as the method to demonstrate compliance, the owner or operator shall submit written notice to the Department, and receive approval for a missing data substitution plan. For purposes of this requirement, the first year of operation ends 365 calendar days following the first day the kiln produces clinker. If, after 365 days of operation of the Hg-CEMS, the CEMS is not to be used as the method of compliance and the permittee can document that da ta from the CEMS is inaccurate or excessively invalid, and/or that the CEMS has proven to be unreliable and unreasonably bur densome, the owner or operator may request the removal of the Hg CEMS requirements. [Rules 62-4.070(3) and 62-212.400(2)(g), F.A.C.]
E XCESS E MISSIONS {Note: The following conditions apply only to the SIP- based emissions standards specified in Condition No. 13 of this section. Rule 62-210-700, F.A.C. (Excess Emissions) cannot vary or supersede any federal provision of the NSPS or the NESHAP programs.}
22. Operating Procedures: The Best Available Control Technology (BACT) determinations established by this permit rely on “good operating practices” to reduce emissions . Therefore, all operators and supervisors shall be properly trained to operate and maintain the kiln and calciner, and pollution control systems in accordance with the guidelines and procedures established by each manufacturer. The training shall include good operating practices as well as methods for minimizing excess emissions. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 23. Definitions:

a. Startup is defined as the commencement of operation of any emissions unit which has shut down or ceased operation for a period of time sufficient to cause temperature, pressure, chemical or pollution control device imbalances, which result in excess emissions.
b. Shutdown means the cessation of the operation of an emissions unit for any purpose.SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 18 of 32 c. Malfunction means any unavoidable mechanical and/or electrical failure of air pollution control equipment or process equipment or of a process resulting in operation in an abnormal or unusual

manner. [Rule 62-210.200(159,230, and 245), F.A.C.]
24. Excess Emissions Prohibited: Excess emissions caused entirely or in part by poor maintenance, poor operation or any other equipment or process failure that may reasonably be prevented during startup, shutdown or malfunction shall be prohibited. All su ch preventable emissions shall be included in any compliance determinations based on CEMS data. [Rule 62-210.700(4), F.A.C.] 25. Allowable Data Exclusions: Continuous monitoring data collected duri ng periods of startup, shutdown, and malfunction may be excluded from the compliance demonstrations only in accordance with the following requirements, provided that best operational practices to minimize emissions are adhered to and the duration of excess emissions are minimized. As provided by the authority in Rule 62-210.700(5), F.A.C., the following conditions replace the provisions in Rule 62-210.700(1), F.A.C.

a. CO Data : Each 30-day rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited pe riods due to equipment malfunctions. No more than 30 hours in any calendar month shall be excl uded from the compliance determinations due to equipment malfunctions. Malfunctions do not include process upsets that occur as a normal part of cement production.
b. NOx Data : Each 30-day rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited pe riods due to malfunctions of the SNCR system. “Malfunctions of the SNCR system” are defined as any unavoidable mechanical and/or electrical failure that prevents introduction of ammonia-based solutions into the kiln system. No more than 30 hours in any calendar month shall be excluded from the compliance determinations due to malfunctions of the SNCR system.

c. SO 2 Data. Each 24-hr rolling average shall include a ll periods of operation (including startup, shutdown, and malfunction), but may exclude limited pe riods due to malfunctions of the hydrated lime system, which are defined as any unavoidable mechan ical and/or electrical failure that prevents introduction of lime into the kiln system. No more than 30 hours in any calendar month shall be excluded from the compliance determinations due to malfunctions of the hydrated lime system.
d. Other Data : All opacity and VOC data shall be include d in the compliance determination. If the mercury CEMS is used as the method for demonstrati ng compliance, all valid data shall be included in the compliance determination. The permittee shall notify the Compliance Authority w ithin one working day of discovering any emissions in excess of a CEMS standard subject to the specifi ed averaging period. Within one working day of occurrence, the owner or operator shall notify the Co mpliance Authority of any malfunction resulting in the exclusion of CEMS data. All such reasonably preventable emissions shall be included in any CEMS compliance determinations. All valid emissions data (including data collected dur ing startup, shutdown and malfunction) shall be used to report em issions for the Annual Operating Report [Rules 62-210.200, 62-212.400(BACT) and 62-210.700, F.A.C.]SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 19 of 32 C ONTINUOUS M ONITORING R EQUIREMENTS
26. CEM Systems : The permittee shall install, calibrate, operate and maintain continuous emissions monitoring systems (CEMS) to measure and record concentrati ons of CO, Hg, NOx, SO2, and VOC/THC in the kiln system exhaust stack in a manner sufficient to demonstrate continuous compliance with the emissions standards specified in this section. All continuous monitoring systems other than the Hg CEMS shall be installed and functioning within the required performan ce specifications by the time of the initial performance tests. The Hg CEMS shall be installed and func tioning within the required performance specifications following the first year of operation as specified in condition No. 21.

a. CO Monitor. The CO monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance Specification 4 or 4A. Quality assurance procedures shall conform to the requirements of 40 CFR 60, Appendix F. The required RATA tests shall be performed using EPA Method 10 in Appendix A of 40 CFR 60 and shall be based on a continuous sampling tr ain. The CO monitor span values shall be set appropriately, considering the expected range of emissions and corresponding emission standards.
b. NOx Monitor. The NO X monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance Specification 2. Quality assurance procedures shall conform to the requirements of in 40 CFR 60, Appendix F. The required RATA tests shall be pe rformed using EPA Method 7E in Appendix A of 40 CFR 60. The NO X monitor span values shall be set appropria tely, considering the expected range of emissions and corresponding emission standards.

c. SO2 Monitor. The SO 2 monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance Specification 2. Quality assurance procedures shall conform to the requirements of 40 CFR 60, Appendix F. The required RATA tests shall be pe rformed using EPA Method 6C in Appendix A of 40 CFR 60. The SO 2 monitor span values shall be set appropria tely, considering the expected range of emissions and corresponding emission standards.
d. THC Monitor. A monitor shall be installed to determin e THC emissions from the stack and shall meet the requirements of NESHAP Subpart LLL in 40 CFR 63 (40 CFR 63.1349 and 63.1350). The THC monitor shall include provisions to determine the moisture content of the exhaust gas and an algorithm to enable correction of the monitoring results to a dry basis (0% moisture).

e. Diluent Monitor. An oxygen monitor shall be installed at the THC monitor location to correct measured THC emissions to the required oxygen concentration.
f. Mercury Monitor. A mercury monitor (Hg-CEMS) shall be installed and operated as described in Condition 21 above. CEMS, other than the Hg CEMS, are also subject to the General Provisions specified in Subpart A of 40 CFR 60 (CO, NOx, and SO2) and Subpart A of 40 CFR 63 (THC/VOC). [Rules 62-4.070(3), 62-210.800, 62-212.400(BACT) and 62-297.520, F.A.C.]
27. COMS : A continuous opacity monitoring system (COMS) shall be installed, ca librated, operated, and maintained in the kiln system exhaust stack, after the baghouse, in a manner sufficient to demonstrate continuous compliance with the opacity standards specifi ed in this section. Opacity shall be based on a 6- minute block average computed from at least one observation (measurement) every 15 seconds. For the COMS, the 6-minute block averages shall begin at the t op of each hour. The COMS shall meet the applicable requirements of 40 CFR 63.1350. [NESHAP Subpart LLL in 40 CFR 63] 28. CEMS/COMS Certification and Initial Startup : Each CEMS/COMS required by this permit shall be installed prior to startup. Within 60 calendar days of achieving an average daily clinker production rate of 187 tons per hour, but no later than 180 calendar days after initial startup, the owner or operator shall certify each CEMS/COMS. Upon certification of each CEMS/COM S, the owner or operator shall demonstrateSECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 20 of 32 compliance with all applicable standards as specified in this permit. Th e Hg CEMS shall be installed and functioning within the required performance specifications following the first year of operation as specified in condition No. 21. [Rules 62-4.070(3), 62-210.800, 62-212.400(BACT) and 62-297.520, F.A.C.; 40 CFR 60.7(a), 60.13(b) and Appendix B; and 40 CFR 63.7(a)(2)] 29. CEMS Data Requirements : The CEMS shall be installed, calibrate d, maintained, and operated in the in-line kiln/raw mill stack to measure and record the emissions of CO, NO X , SO 2 , and THC/VOC in a manner sufficient to demonstrate compliance with the emission limits of this permit. The CEMS shall express the results in units of pounds per ton of clinker produ ced, and pounds per hour. Emissions of VOC shall be reported in units of the standards (lb/hr, lb/ton of clinker) and ppmvd as propane corrected to 7% oxygen.

a. Valid Hourly Averages: Each CEMS shall be designed and operated to sample, analyze, and record data evenly spaced over the hour at a minimum of one measurement per minute. All valid measurements collected during an hour shall be used to calculate a 1-hour block average that begins at the top of each hour. Each 1-hour block average shall be computed using at least one data point in each fifteen-minute quadrant of an hour, where the unit combusted fuel (or produced clinker) during that quadrant of an hour. Notwithstanding this requirement, a 1-hour aver age shall be computed from at least two data points separated by a minimum of 15 minutes (where the unit operates for more than one quadrant of an hour). If less than two such data points are availabl e, there is insufficient data and the 1-hour block average is not valid.

• Hours during which there is no kiln feed and no fuel fired are not valid hours.

• Hours during which the plant is firing fuel but producing no clinker are valid, but these hours are excluded from the production-normalized emission rate computation (pounds per ton of clinker). These hours are included in any pollutant mass emission rate computation (pounds per hour).
b. 24-hour Rolling Averages : Compliance with the emission limit for SO 2 shall be based on a 24-hour rolling average that shall be recomputed after ever y valid hour as the arithmetic average of that hourly average and the preceding 23 valid hourly averages.

c. 30-day Rolling Averages : Compliance with the emission limits for CO and NO X shall be based on a 30- day rolling average. Each 30-day rolling average sh all be the arithmetic average of all valid hourly averages collected during the last 30 operating days. A new 30-day rolling average shall be recomputed after every day of operation for the new day a nd the preceding 29 operating days. For purposes of computing these emission limits, an operating day is any day that the kiln produces clinker or fires fuel.
d. 30

- day Block Average: Compliance with the emission limit for VOC shall be based on a 30-day block average. Each 30-day block average shall be th e arithmetic average of all valid hourly averages occurring within each 30 operating-day block and sh all be consistent with the averaging period specified in 40 CFR 63.1350(h) for THC emissions.

e. Data Exclusion : Except for monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments, each CEMS shall monitor and record emissions during all operations including episodes of startups, shutdowns, and malfunctions. Limited amounts of CEMS emissions data recorded during some of these episodes may be excluded from the corresponding compliance demonstration subject to the provisions of Condition No. 25 in this section. The permittee shall minimize the duration of data excluded for such epis odes to the extent practicable.
f. Availability . Monitor availability for each CEMS used to demonstrate compliance shall be 95% or greater in any calendar quarter. Monitor availability shall be reported in the quarterly excess emissions report. In the event 95% availability is not achieve d, the permittee shall provide the Department with a report identifying the problems in achieving 95% availa bility and a plan of corrective actions that will be taken to achieve 95% availability. The permitt ee shall implement the reported corrective actionsSECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 21 of 32 within the next calendar quarter. Failure to take corrective actions or continued failure to achieve the minimum monitor availability shall be violations of this permit, except as otherwise authorized by the Compliance Authority.

g. Public Access: Emission data will be available in real time on the company website.
30. Continuous Flow Monitor: A continuous flow monitor shall be inst alled to determine the stack exhaust flow rate to be used in determining mass emission rates. The flow monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance Specification 6. 31. Baghouse Temperature Monitor : A continuous temperature monitor sha ll be installed, calibrated, operated, and maintained at the inlet to the baghouse for the kiln system exhaust in accordance with the requirements of 40 CFR 63.1350(f). [NESHAP Subpart LLL in 40 CFR 63] 32. Ammonia Injection : A monitoring system to continuously monitor and record the ammonia and/or urea injection rate of the SNCR system (1-hour block aver ages) shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] R EPORTING AND R ECORD K EEPING R EQUIREMENTS
33. Operational Records : To demonstrate compliance with the limitati ons specified in this section, the owner or operator shall maintain the following records on site.

a. For each 1-hour block of operation, continuously monito r and record the dry preheater feed rate, clinker production rate, fuel firing rate, heat input rate (t he representative heating value of each fuel and the hourly fuel firing rate), and estimates of NH 3 /NO X molar ratio or ammonia injection rate. Records shall also document the dry preheater feed rate and clinker production rates for each 24-hour rolling period and consecutive12 months. b. For each fuel delivery, maintain records of the quantity of fuel delivered and a representative analysis of the fuel. Records shall include the sulfur content, higher and lower heating value, proximate analysis, and ultimate analyses.

c. Maintain records demonstrating compliance with the mercury throughput limitation as required in Condition No. 21 of this permit. All records shall be made available to the Department and Compliance Authority upon request. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
34. Stack Test Reports : The owner or operator of an emissions unit for which a compliance test is required shall file a report with the Compliance Authority on the results of each such test. The required test report shall be filed with the Compliance Authority as soon as practical but no later than 45 days after the last sampling run of each test is completed. The test report shall provide sufficient detail on the emissions unit tested and the test procedures used to allow the Compliance Authority to determine if the test was properly conducted and the test results properly computed. As a minimum, the test report, other than for an EPA or DEP Method 9 test, shall provide the specified in Rule 62-297.310(8), F.A.C. [Rule 62-297.310(8), F.A.C.] 35. Malfunction Notifications : If temporarily unable to comply with any condition of the permit due to breakdown of equipment (malfunction) or destruction by hazard of fire, wind or by other cause, the permittee shall immediately (within one working day) notify th e Compliance Authority. Notification shall include pertinent information as to the cause of the problem, and what steps are being taken to correct the problem and to prevent its recurrence, and where applicable, th e owner’s intent toward reconstruction of destroyed facilities. Such notification does not release the perm ittee from any liability for failure to comply with Department rules. If requested by the Compliance Au thority, the owner or operator shall submit a quarterly written report describing the malfunction. [Rules 62-210.700(6) and 62-4.130, F.A.C.]SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS D. Pyroprocessing System



### Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 22 of 32 36. SIP Quarterly Report : Within 30 days following the end of each calendar quarter, the permittee shall submit a report to the Compliance Authority summarizing: equipment malfunctions resulting in excluded CEMS data and/or excess emissions; mercury throughput rates; and the monitor availability of each CEMS. The report shall contain the information and follow the general format specified in Appendix F of this permit. [Rules 62-4.070(3), 62-4.130, and 62-212.400(BACT), F.A.C.] 37. Used Oil Records: For each shipment of used oil received, th e owner or operator shall maintain records from the vendor certifying that the used oil meets the above requirements for “on-specification” used oil fuel. Records shall include the following parameters: arsen ic, cadmium, chromium, lead, total halogens, flash point, PCBs, sulfur content, ash, and heating value. Otherwise, the owner or operator shall sample and analyze each shipment of used oil received for the a bove parameters. If vendor cer tifications are relied upon, the owner or operator shall analyze at least one sample obtained each calendar year for the above parameters. If analytical results show that the used oil does not meet the above requirements, the owner or operator shall immediately: cease burning of the used oil, and notify the Compliance Authority of the analytical results. The analysis shall be performed via EPA-approved or A STM methods. The permittee shall obtain, make, and keep the following records: Gallons of on-specifi cation used oil received and burned each month; a) Gallons of on-specification used oil received and burned each month;; b) Name and address of all vendors delivering used oil to the facility c) Copies of the vendor certifications, if obtai ned, and any supporting information; and d) Analytical results.
The records shall be retained in a fo rm suitable for inspection at the facility by the Department, and shall be retained permanently. [40 CFR 279.61; 40 CFR 761.20(e), and Rule 62-4.070(3), F.A.C.]


### 38. O&M Plan for Baghouse : The permittee shall prepare an operation and maintenance (O&M) plan to address the schedule for inspection and preven tive maintenance of the baghouse control system. The O&M plan shall be submitted to the Compliance Authority prior to expi ration of this permit. The permittee shall maintain records of the condition of the control equipmen t for each inspection and any maintenance activities performed. [Rule 62-4.070(3), F.A.C., and 40 CFR 63.1350, Subpart LLL]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS E. Clinker Storage and Conveying

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 23 of 32 The specific conditions of this subsection apply to the following emissions unit after construction is complete.

ID No. Emissions Unit Description

005 (CH-5) - Clinker Storage and Conveying. Includ es clinker transport from kiln; clinker, limestone, and gypsum silos; and clinker, limestone and gypsum conveying to finish mills. Clinker storage and conveying includes the following em ission points controlled by fabric filter baghouses.

Point ID Emissions Point Description

NDC-10 Clinker Transport From Kiln

NDC-11 Clinker Silo #1

NDC-12 Clinker Silo #2

NDC-13 Off-Spec Clinker Silo

NDC-14 Finish Mill #1 Clinker Silo Outlet Conveyor
NDC-15 Finish Mill #2 Clinker Silo Outlet Conveyor

NDC-16 Gypsum and Limestone Silos

NDC-17 Conveying to Finish Mills (2 feed belts)

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for, particulate matter (PM/PM 10 ). To satisfy the BACT requirements for this unit the visible emissions limits act as surrogate standards for PM.
2. NESHAP Requirements : This unit is subject to 40 CFR 63, Subpart A (Identification of General Provisions) and 40 CFR 63, Subpart LLL (National Emi ssions Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions performance requirements are as stringent as or more st ringent than the limits imposed by the applicable NESHAP provisions. Some separate reporting and mon itoring may be required by the individual subpart.
E QUIPMENT A ND C ONTROL T ECHNOLOGY
3. Equipment Description : The permittee is authorized to construct, operate, and maintain equipment needed for the conveying and storage of clinker, and the limestone and gypsum storage and conveying to the two finish mills. Equipment will include two clinker silos, one off-spec clinker silo, gypsum and limestone silos, and associated conveyors, and control equipment.
4. Baghouse Controls : Each emissions point identified for cli nker storage and conveying shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 gr/dscf and a PM 10 design specification of 0.0085 gr/dscf. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
P ERFORMANCE R EQUIREMENTS
5. Hours of Operation : This emissions unit is allowe d to operate 8,760 hours per year. [Applicant Request, Rule 62-210.200(PTE), F.A.C]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS E. Clinker Storage and Conveying

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 24 of 32 E MISSIONS AND T ESTING R EQUIREMENTS
6. Emissions Limits : The following standards apply to each emissions point of this unit including all clinker storage and conveying system transfer points:

a. Emissions are limited to 5% opacity from each of the above listed emissions points controlled by a baghouse.
b. Emissions are limited to 10% opacity from any emissions point not controlled by a baghouse. [Rule 62-212.400(BACT), F.A.C.] {Note: The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) and PM 10 emissions to 0.0085 gr/dscf. The 5% opacity limitation is consistent with this design and provides reasonable assurance that annual emissions of PM/PM 10 from all emission points listed above will be no more than 24.97/21.23 TPY. Exceedance of the 5% opac ity limit shall be deemed an exceedance of this permit condition and not necessarily an exceedance of the opacity limitations given in 40 CFR 63, Subpart LLL.} [Rules 62-4.070(3), 62-212.400, F.A.C. and 40 CFR 63.1348]
7. Compliance Demonstrations: Each emission point shall be tested to demonstrate initial compliance with the emission standards for visible emissions in accordance with EPA Method 9. The tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be operated, but not later than 180 days after the initial startup. Thereafter, compliance with the visible emission limits shall be demonstrated during each federal fiscal year (October 1 st to September 30 th ). [Rules 62-4.070(3), 62-297.310(7)(a), F.A.C. and 40 CFR 63.1349(b)(2)]
8. Periodic Monitoring Requirements : Each affected source subject to an opacity standard shall be periodically monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL]
9. Test Methods : Any required tests shall be performed in acco rdance with the following reference methods and the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions.

Method Description of Method and Comments
9 Visual Determination of the Opacity of Emissions from Stationary Sources

22 Visual Determination of Fugitive Emissions From Material Sources

R EPORTING AND R ECORD K EEPING
10. Baghouse O&M Plan : For each baghouse the permittee shall prep are an operation and maintenance (O&M) plan to address proper operation, parametric monitori ng, and a schedule for conducting periodic inspections and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written log. The O&M plan shall be submitted to the Complia nce Authority prior to the initial compliance tests for this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL]
11. Test Reports: For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the compliance author ity no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS F. Finish Mills Cement Processing

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 25 of 32 The specific conditions of this subsection apply to the following emissions unit after construction is complete.

ID No. Emissions Unit Description

006 (CH-6) - Finish Mills Cement Processing. Includes two finish mills, cement silos, packaging plant and truck loadout. The Finish Mills Cement Processing includes the following emission points controlled by fabric filter baghouses.

Point ID Emissions Point Description

NDC-18 Finish Mill #1 Clinker Conveying

DC-02 Finish Mill #1 Separator Baghouse

DC-03 Finish Mill #1 Sweep Baghouse

NDC-21 Fringe Cement Bin
NDC-19 Finish Mill #1 Baghouse No. 3

DC-04 Finish Mill #2 Separator Baghouse
DC-05 Finish Mill #2 Sweep Baghouse

NDC-20 Finish Mill #2 Baghouse No. 3

NDC-22 Cement Silos

NDC-23 Cement Silos

NDC-24 Cement Silos
NDC-25 Truck Loadout #1

NDC-26 Truck Loadout #2

NDC-27 Truck Loadout #3

NDC-28 Packaging Plant

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for particulate matter (PM/PM 10 ). To satisfy some of the BACT requirements for this unit the visible emissions limits act as surrogate standards for PM.
2. NESHAP Requirements : This unit is subject to 40 CFR 63, Subpart A (Identification of General Provisions) and 40 CFR 63, Subpart LLL (National Emi ssions Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions performance requirements are as stringent as or more st ringent than the limits imposed by the applicable NESHAP provisions. Some separate reporting and mon itoring may be required by the individual subpart.
E QUIPMENT A ND C ONTROL T ECHNOLOGY
3. Equipment Description : The permittee is authorized to construct, operate, and maintain equipment needed for cement finishing, storage, packaging, and loadout. E quipment will include two finish mills, six cement silos

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS F. Finish Mills Cement Processing

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 26 of 32 with two interstices, one fringe cement bin, three tr uck loadouts, one packaging plant, and associated conveyors, bucket elevators, be lts, and control equipment.
4. Baghouse Controls : Each emissions point identified for finish mills cement processing shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 gr/dscf and a PM 10 design specification of 0.0085 gr/dscf. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
P ERFORMANCE R EQUIREMENTS
5. Hours of Operation : This emissions unit is allowe d to operate 8,760 hours per year. [Applicant Request, Rule62-210.200(PTE), F.A.C

6. Process Rate Specification : Each finish mill may process up to 170 tons per hour (TPH) of clinker, gypsum or limestone to produce an equal amount of cement. [Applicant Request] {Note: The finish mills are capable of processing more clinker than can be produced by the on-site pyroprocessing system. Any projects to utilize the additional capacity would constitute a modification per Section 2, Condition 7.}
E MISSIONS AND T ESTING R EQUIREMENTS
7. Particulate Matter Standards: Particulate matter emissions from the finish mill air separators (Points DC-02, and DC-04) shall not exceed 0.0085 grains per dscf of exhaust as determined by EPA method 5. All PM emitted from the baghouse exhaust is assumed to be PM 10 . The BACT requirements do not waive or vary any applicable NESHAP monitoring or record keeping requirements. [Rules 62-212.400 (BACT), F.A.C.]
8. Visible Emissions Standards : Visible emissions shall not exceed the following limits as determined by EPA Method 9:

a. Visible emissions are limited to 5% opacity from each of the above listed emissions points controlled by a baghouse.
b. Visible emissions are limited to 10% opacity from any emissions point not controlled by a baghouse. {Note: The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) and PM 10 emissions to 0.0085 gr/dscf. The 5% opacity limitation is consistent with this design and provides reasonable assurance that annual emissions of PM/PM 10 from the above emissions points (excluding the air separators) will be less than 42.03/35.74 TPY. Exceedan ce of the 5% opacity limit shall be deemed an exceedance of this permit condition and not necessarily an exceedance of the opacity limitations given in 40 CFR 63, Subpart LLL.} [Rules 62-212.400 (BACT), F.A.C.]
9. Testing Requirements : Emission points DC-02 and DC-04 shall be stack tested to demonstrate initial compliance with the applicable emission standards for PM/PM 10 and visible emissions. All other emission points shall be tested for visible emissions only. Th e tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be ope rated, but not later than 180 days after the initial startup. Thereafter, compliance with the particulate limits (PM/PM 10 ) shall be demonstrated within the 12 month period prior to each renewal of the operation pe rmit and compliance with the visible emissions limits for each unenclosed transfer point shall be demons trated during each federal fiscal year (October 1 st to September 30 th ). [Rule 62-297.310(7)(a), F.A.C.]
10. Periodic Monitoring Requirements : Each affected source subject to an opacity standard shall be periodically monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS F. Finish Mills Cement Processing

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 27 of 32 11. Test Methods : Any required tests shall be performed in acco rdance with the following reference methods and the applicable requirements of Appendix C of this permit, and the applicable NSPS provisions.

Method Description of Method and Comments

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content. Methods shall be performed as necessary to support other methods.
5 Determination Particulate Matter from Stationary Sources
9 Visual Determination of the Opacity of Emissions from Stationary Sources

22 Visual Determination of Fugitive Emissions From Material Sources

R EPORTING AND R ECORD K EEPING
12. Baghouse O&M Plan : For each baghouse the permittee shall prep are an operation and maintenance (O&M) plan to address proper operation, parametric monitori ng, and a schedule for conducting periodic inspections and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written log. The O&M plan shall be submitted to the Complia nce Authority prior to the initial compliance tests for this unit. [Rule 62-4.070(3)]
13. Test Reports: For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the compliance author ity no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS G. Coal and Petroleum Coke Grinding System

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 28 of 32 The specific conditions of this subsection apply to the following emissions unit.

ID No. Emissions Unit Description

007 (CH-7) - Coal and Petroleum Coke Grinding System. Includes coal mill and coal bins.
The coal and petroleum coke grinding system includes the following emission points controlled by fabric filter baghouses.

Point ID Emissions Point Description

DC-06 Coal Mill #1 Baghouse

DC-07 Coal Mill #2 Baghouse
NDC-29 Pulverized Coal Bin

NDC-30 Pulverized Coal Bin

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for particulate matter (PM/PM 10 ). To satisfy some of the BACT requirements for this unit the visible emissions limits act as surrogate standards for PM.
2. NSPS Requirements : This unit is subject to 40 CFR 60, Subpa rt A (Identification of General Provisions) and 40 CFR 60, Subpart Y (Standards of Performance for Coal Preparation Plants). The Department determines that the BACT emissions performance requireme nts are as stringent as or more stringent than the limits imposed by the applicable NSPS provisions. Some separate reporting and monitoring may be required by the individual subpart.
E QUIPMENT A ND C ONTROL T ECHNOLOGY
3. Equipment Description : The permittee is authorized to construct, operate, and maintain equipment needed for coal and petroleum coke grinding and storage. Equipm ent will include a coal/petcoke grinding mill (nominal throughput 211,160 TPY and 28.4 TPH), storage bins, and asso ciated conveyor systems. Clinker cooler gas will be used for drying.
4. Baghouse Controls : Each emissions point identified for the coal and petroleum coke grinding system shall be controlled by a baghouse system. Each required baghou se shall be designed, operated, and maintained to achieve a PM design specification of 0.01 gr/dscf and a PM 10 design specification of 0.0085 gr/dscf. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
PERFORMANCE REQUIREMENTS
5. Hours of Operation : The hours of operation for this emissions unit are not limited (8760 hours per year). [Rule62-210.200(PTE), F.A.C.]
E MISSIONS AND T ESTING R EQUIREMENTS
6. Particulate Matter Standards: Particulate matter emissions from the coal mill (Point ID DC-06 and DC-07) shall not exceed 0.0085 grains per dscf of exhaust as determined by EPA method 5. All PM emitted from the baghouse exhaust is assumed to be PM 10 . The BACT requirements do not waive or vary any applicable NESHAP monitoring or record keeping requirements. [Rules 62-212.400 (BACT), F.A.C. and 40 CFR 60.252]
7. Visible Emissions Standards: Visible emissions from each baghouse shall not exceed 5% opacity as

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS G. Coal and Petroleum Coke Grinding System

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 29 of 32 determined by EPA Method 9. [Rules 62-212.400 (BACT), F.A.C. and CFR 60.252]
8. Testing Requirements : Emission points DC-06 and DC-07 shall be stack tested to demonstrate initial compliance with the applicable emission standards for PM/PM 10 and visible emissions. All other emission points shall be tested for visible emissions only. Th e tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be ope rated, but not later than 180 days after the initial startup. Thereafter, compliance with the particulate limits (PM/PM 10 ) shall be demonstrated within the 12 month period prior to each renewal of the operation pe rmit and compliance with the visible emission limits shall be demonstrated during each federal fiscal year (October 1 st to September 30 th ). [Rule 62- 297.310(7)(a), F.A.C.]
9. Test Methods : Any required tests shall be performed in accordance with the following reference methods and the applicable requirements of Appendix C of this permit, and the applicable NSPS provisions.

Method Description of Method and Comments

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content. Methods shall be performed as necessary to support other methods.
5 Determination Particulate Matter from Stationary Sources
9 Visual Determination of the Opacity of Emissions from Stationary Sources

C ONTINUOUS M ONITORING R EQUIREMENTS
10. Thermal Dryer Exit Temperature : A monitoring device for the continuous measurement of the temperature of the gas stream at the exit of the thermal dryer sha ll be installed, calibrated, maintained, and continuously operated to measure the temperature of the gas str eam in accordance with the requirements of 40 CFR, 60.253. [40 CFR 60.253]
R EPORTING AND R ECORD K EEPING
11. Baghouse O&M Plan : For each baghouse the permittee shall prep are an operation and maintenance (O&M) plan to address proper operation, parametric monitori ng, and a schedule for conducting periodic inspections and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written log. The O&M plan shall be submitted to the Complia nce Authority prior to the initial compliance tests for this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL]
12. Test Reports : For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the complia nce authority no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS H. Coal and Petroleum Coke Conveying

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 30 of 32 The specific conditions of this subsection apply to the following emissions unit.

ID No. Emissions Unit Description

008 (CH-8) – Coal and Petroleum Coke Conveying. Includes coal/petroleum coke handling and conveying from unloading to storage bins. The coal and petroleum coke conveying system contains the following emission points.

Point ID Emissions Point Description CH-8-1 Coal/Petroleum Coke Pile Handling – unloading, FEL reclaim, FEL transfer to hopper CH-8-2 Coal/Petroleum Coke Conveying – belt transfer to elevator, transfer to scrap metal box, conveyor transfer to piles, truck dump to hopper, hopper transfer to elevator

A PPLICABLE S TANDARDS AND R EGULATIONS
1. BACT Determinations : A determination of the Best Available Control Technology (BACT) was made for particulate matter (PM/PM 10 ).
2. NSPS Requirements : This unit is subject to 40 CFR 60, Subpa rt A (Identification of General Provisions) and 40 CFR 60, Subpart Y (Standards of Performance for Coal Preparation Plants). The Department determines that the BACT emissions performance requireme nts are as stringent as or more stringent than the limits imposed by the applicable NSPS provisions. Some separate reporting and monitoring may be required by the individual subpart.
E QUIPMENT AND C ONTROL T ECHNOLOGY
3. Equipment Description : The permittee is authorized to construc t, operate, and maintain equipment needed for the conveyance and handling of the coal and petr oleum coke. Equipment w ill include conveyors, belts, loaders, and hoppers. [Applicant Request]
P ERFORMANCE R EQUIREMENTS
4. Hours of Operation : This emissions unit system is allowed to operate 8,760 hours per year. [Applicant Request, Rule62-210.200(PTE), F.A.C.]
E MISSIONS AND T ESTING R EQUIREMENTS
5. Visible Emissions Standards: Visible emissions from all coal/petcoke processing and conveying equipment, coal/petcoke storage system, or coal/petcoke transf er and loading system processing coal/petcoke, and not controlled by a baghouse, shall not exceed 5 % opacity. [Rules 62-212.400 (BACT), F.A.C. and CFR 60.252]

6. Testing Requirements : Each emission point shall be tested to demonstrate initial compliance with the visible emissions standards. The tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be operated, but not later than 180 days after the initial startup. Thereafter, compliance with the visible emission limits shall be demonstrated during each federal fiscal year (October 1 st to September 30 th ). [Rule 62-297.310(7)(a), F.A.C.]
7. Visible Emissions Tests: Compliance with the visible emission limits shall be determined by conducting EPA Method 9 tests. Initial tests shall be conducted 60 days after achieving the maximum production rate at which the unit will be operated, but no later than 180 da ys after initial startup. Thereafter, the permittee shall demonstrate compliance during each federal fiscal year (October 1 st to September 30 th ). Tests shall be conducted in accordance with the applicable require ments in Appendix C of this permit as well as the applicable NSPS provisions.

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS H. Coal and Petroleum Coke Conveying

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 31 of 32 8. Test Reports: For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the complia nce authority no later than 45 days after the last run of each test is completed. [Rules 62-297.310(8), F.A.C.]

### SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS I. Fugitive Dust From Storage Piles, Paved Roads, and Unpaved Roads

Sumter Cement Company Project No. 1190041-001-AC Center Hill Cement Plant Air Permit No. PSD-FL-358 Page 32 of 32 The following specific conditions apply to the following emissions unit after construction.

ID No. Emissions Unit Description

010 (CH-10, CH-11) – Fugitive Dust From Storage Piles, Paved Roads, and Unpaved Roads.

P ERFORMANCE R EQUIREMENTS
1. Unconfined Emissions of Particulate Matter

a. No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from any activity without taking reasonable precautions to prevent such emissions. Such activities include, but are not limited to: vehicular movement; transpor tation of materials; construction, alteration, demolition or wrecking; or industrially related activiti es such as loading, unloading, storing or handling.
b. Reasonable precautions shall include the following: (1) Landscaping and planting of vegetation. (2) Application of water to control fugitive dus t from activities such as demolition of buildings, grading roads, construction, and land clearing. (3) Water supply lines, hoses and sprinklers shall be locat ed near all stockpiles of raw materials, coal, and petroleum coke. (4) All plant operators shall be trained in basic e nvironmental compliance and shall perform visual inspections of raw materials, coal and petroleu m coke periodically and before handling. If the visual inspections indicate a lack of surface moisture, such materials shall be wetted with sprinklers. Wetting shall continue until the poten tial for unconfined particulate matter emissions are minimized. (5) Water spray shall be used to wet the materials a nd fuel if inherent moisture and moisture from wetting the storage piles are not sufficient to prevent unconfined particulate matter emissions. (6) As necessary, applications of asphalt, water, or dust suppressants to unpaved roads, yards, open stockpiles and similar activities. (7) Paving of access roadways, parking areas, manufacture area, and fuel storage yard. (8) Removal of dust from buildings, roads, and othe r paved areas under the control of the owner or operator of the facility to prevent particulate matter from becoming airborne. (9) A vacuum sweeper shall be used to remove dust from paved roads, parking, and other work areas. (10) Enclosure or covering of conveyor systems where practicably feasible. (11) All materials at the plant shall be stored under roof. Materials, other than quarried materials, shall be stored on compacted clay or concrete, or in enclosed vessels. (12) Use of hoods, fans, filters, and similar equipment to contain, capture and/or vent particulate matter. (13) Confining abrasive blasting where possible.

c. In determining what constitutes reasonable precautions for a particular source, the Department shall consider the cost of the control technique or work practice, the environmental impacts of the technique or practice, and the degree of reduction of emissions expected from a particular technique or practice. [Rules 62-212.400(BACT) and 62-296.320(4)(c), F.A.C.]