### 043/0001/999 ver 11/99 PERMIT NO: 

# 98FR0895

INITIAL APPROVAL

DATE ISSUED: 

# MODIFICATION - 2

ISSUED TO: 

# HOLNAM, INC. - PORTLAND PLANT

THE SOURCE TO WHICH THIS PERMIT APPLIES IS DES CRIBED AND LOCATED AS FOLLOWS:

Portland cement manufacturing facility, including raw materials quarries, known as Holnam Portland

Plant , located at 3500 State Highway 120, near Florence, Fremont County, Colorado.

THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJEC T TO THIS PERMIT I NCLUDES THE FOLLOWING:

This is a facility-wide permit covering all equipment / activities at this facility. Details of equipment / activities are given in Attachment A.

This facility is a major stationary source located in an area designated as attainment / unclassifiable for all criteria pollutants.

Issuance of this permit was for a ma jor modification of a major stationary source. This Modification-1 is a minor
modification.

THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLO RADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq ), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN
THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:

1. All previous versions of this permit ar e canceled upon issuance of this permit.

2. Construction for modification of this facility must co mmence within 18 months of initial approval permit issuance
date or within 18 months of date on which such construc tion or activity was scheduled to commence as stated in the application. If commencement does not occur wi thin the stated time the permit will expire on January 29, 2001. (See General Condition No. 6., Item 1 on the reverse side of the first page of this permit.) (Reference: Regulation No. 3, Part B, IV. G. 4.) Comment [COMMENT1]: ALT-F5, G, E expands permit for final printout

Comment [COMMENT2]: NOTE: ALT-C Adds conditions, (Standard condition 0 allows you to create a non-standard condition). Before you finish you MUST use the 'Regenerate' option of ALT-C at least once (Even with canned permits). Use Shift-F7 to print draft permit, and PRINTPMT to print final copy.

### Page 2 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 3. Operation of the wet scrubb er by-pass (AIRS ID: 111) shall be restricted to periods of unforeseen (breakdown) of the scrubber, and shall be reported under upset provisions. 4. Prior to the start up of the equipment / activities permitt ed under this permit, all existing activities / operations not covered by this permit shall be terminated. The permittee shall send a notification to the Division of the termination of the activities. Upon starting of operations under this permit, all previous permits / exemptions for individual equipment / activities, or group of equipment / activities, stand canceled . These include, but not limited to Permits/Exemptions No.: 10FR107-1, 10FR107-2, 10FR484, 93FR1062, and 95FR399.

5. Within one hundred and eighty days (180) after co mmencement of operation, compliance with the conditions contained in this permit shall be demonstrated to the Divisi on. It is the permittee's responsibility to self certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Information on how to cert ify compliance was mailed with the permit or can be obtained from the Division at 303-692-3209.)

6. If more than one provision applies, the most stringent provision shall be applicable.

7. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty c onsecutive minutes. Opacity shall be measured by EPA Method 9. (Reference: Regulation 1, Section II. A. 1. & 4.)

8. This source is subject to the odor requireme nts of Regulation No. 2. (State only enforceable)

9. The manufacturer, model number and serial number of the subject equipment shall be provided to the Division prior to Final Approval. (Reference: Reg. 3, Part B. IV. E.)

10. AIRS ID numbers (for example, AIRS ID: 006") shall be marked on the subject equipment for ease of identification. (Reference: Reg. 3, Part B, IV. E.) (State only enforceable)

11. The following operations at this facility are subject to the requirements of Regulation No. 6 - Standards of Performance for New Stationary Sources including, but not limited to, the following:

Part A - Federal Register Regulations Adopted By Reference:

Subpart F - Standards of Performance for Portland Cement Plants : These standards apply to kiln, clinker cooler, raw mill system, finish mill system, raw mill drye r, raw material storage, clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems.

Kiln : Gases discharged into the atmosphere from the kiln shall not contain particulate matter in excess of 0.30 pound ton of feed (dry basis) to the kiln. Emissions through all bypasses must be included while determining compliance with this standard.

Gases discharged into the atmosphere from the kiln shall not exhibit greater than 20 percent opacity.

A continuous opacity monitoring system shall be installed, calibrated, maintained, and operated to measure the opacity of emissions discharged into the atmosphere from the kiln. The monitoring system shall be recalibrated in accordance with procedures under 40 CFR

 60.13.

### Page 3 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 Clinker Cooler : Gases discharged into the atmosphere from any clinker cooler shall not contain particulate matter in excess of 0.10 pound pe r ton of feed (dry basis) to the kiln.

Gases discharged into the atmosphere from th e clinker cooler shall not exhibit greater than 10 percent opacity.

A continuous opacity monitoring system shall be installed, calibrated, maintained, and operated to measure the opacity of emissions discharged into the atmosphere from the clinker cooler. The monitoring system shall be recalibrated in accordance with procedures under 40 CFR

 60.13.

Other Operations: Gases discharged into the atmosphere from all other operations shall not exhibit greater than 10 percent opacity.

Subpart Y - Standards of Performanc e for Coal Preparation Plants: These standards apply to thermal dryers, pneumatic coal-cleaning equipment, coal proces sing and conveying equipment (including breakers and crushers), coal storage systems, and coal transfer and loading systems.

Thermal Dryer: Gases discharged into the atmosphere from the thermal dryer shall not contain particulate matter in excess of 0.031 grain per dry standard cubic foot. The permittee has proposed to limit the emissions to 0.01 grain per dry standard cubic foot.

Gases discharged into the atmosphere from the thermal dryer shall not exhibit 20 percent opacity or greater.

A temperature measurement and monitoring device shall be installed, calibrated, maintained, and continuously operated for measurement of temperature of the gas stream at the exit of the thermal dryer. The monitoring device is to be certified by

the manufacturer to be accurate within



##  3 o 

### F. The monitoring device shall be recalibrated in accordance with procedures under 40 CFR

 60.13.

Other Operations : Gases discharged into the atmosphere from ot her operations shall not exhibit 20 percent opacity or greater.

Subpart OOO - Standards of Performance for Non-Metallic Mineral Processing Plants : These standards apply to each crusher, grinding mill, screening operat ion, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading stat ion that commences construction, reconstruction, or modification after August 31, 1983. Emission sources to which Subpart F is applicable, are not subject to Subpart OOO.

### Page 4 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 All Emission Sources : Stack emissions shall not contain particulate matter in excess of 0.05 gram per dry standard cubic meter, and sha ll not exhibit opacity greater than 7
percent.

Fugitive emissions shall not exhibit greater than 10 percent opacity.

There shall be no visible fugitive emissions from any building enclosing any
of the emission sources.

Stack emissions through vents on buildings enclosing emission sources shall not contain particulate matter in excess of 0.05 gram per dry standard cubic meter, and shall not exhibit opacity greater than 7 percent.

Part B - Specific Facilities and Sources, Non-Federal NSPS:

Subpart III - Standards of Performance for New Manufacturing Processes:

Standard for Particulate Matter:

Emissions of particulate matter shall not exceed the emission rate determined by use of the equation:



## E = 17.31 (P) 0.16



### Where:

E is the Allowable Particulate Matter Emissions in pounds per hour. P is the Process Weight rate in tons of kiln feed per hour.

Discharge into the atmosphere shall not exhibit opacity greater than 20 percent.

Standard for Sulfur Dioxide:

Emissions of sulfur dioxide shall be controlled by utilizin g best practical control technology. Lime scrubber is used for control of sulfur dioxide from gases exiting the 5-stage preheater / precalciner (excluding that portion of the gases redirected from the gas st ream for the purpose of drying in the coal mill), and alkali bypass to achieve an overall facility sulfur diox ide control efficiency of 80 %.

12. The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply to all emission sources subject to Regulation No. 6.

a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be ma intained and operated in a manner consistent with good air pollution control practices for mi nimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operat ing and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11)

### Page 5 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 b. No article, machine, equipment or process sha ll be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or
with a standard which is based on the concentra tion of a pollutant in the gases discharged to the atmosphere. (

 § 60.12)

c. Written notification of construction and initial startup dates shall be submitted to the Division as required under

 § 60.7.

d. Records of startups, shutdowns, and malfunc tions shall be maintained, as required under § 60.7.

e. Written notification of continuous monitoring system demonstrations shall be submitted to the Division as required under

 § 60.7.

f. Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under

 § 60.7.

g. Excess Emission and Monitoring System Performance Reports shall be submitted as required
under

 60.7.

h. Performance tests shall be conducted as required under

 § 60.8.

j. Compliance with opacity standards shall be demonstrated according to

 § 60.11.

k. Continuous monitoring systems shall be ma intained and operated as required under

 § 60.13.

A copy of the complete applicable subpart(s) is attached.

13. The emission sources shall be equipped with contro l devices / systems capable of reducing uncontrolled emissions of various pollutants as speci fied in Attachment A. Operating parameters of the control equipment shall be identified prior to final appr oval of this permit. The identified operating parameters will replace the control efficiency requirement on the final permit. (Reference: Reg.3, Part B, IV. E.)

14. The particulate emission control measures listed on Attachment B (as approved by the Division) shall be applied to the particulate emission producing sources as requ ired by Regulation No. 1, Section III. D. 1. b.

### Page 6 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 15. The equipment / activities at this facility are subject to the provisions of Prevention of Significant Deterioration (PSD). Application of Best Available Control Tech nology (BACT) is required. Emissions from various equipment / activities shall be controlled, and the permittee shall comply with the following BACT
determinations:

Preheater / Precalciner and Kiln System referenced under AIRS ID: 111

Carbon Monoxide:

Controls: Good Combustion Practices for minimizing emissions of Carbon Monoxide. Emissions not to exceed 4.64 pounds per ton of clinker produced.

Volatile Organic Compounds:

Controls: Good Combustion Practices for minimizing emissions of volatile organic compounds. Emissions not to exceed 0.21 pound per ton of clinker produced.

Coal Mill Vent referenced under AIRS ID: 107

Carbon Monoxide: A bypass stream of hot gases from the ki ln / precalciner is sent through the coal mill for drying of coal. Good Combustion Practices are used in the kiln and precalciner.

Volatile Organic Compounds: Good Combustion Practices are used in the kiln and precalciner.

16. Good Combustion Practices constitute monitoring an d control of several operating parameters. These parameters include, but not limited to, fuel flow rate, primary and secondary air flows, carbon monoxide concentration in the flue gas, level of excess air, and recirculating air flow . All relevant parameters and their optimal operating ranges for various combustion devices shall be identified, and included in the required operation and maintenance plan. Continuous emission monitoring systems shall be programmed to send out warnings if the operating parameters are on the verge of going out of the established operating ranges, and alarms shall be sounded if the operating parame ters go out of established operating range.

### Page 7 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 17. This facility shall be limited to throughput as listed below and all other activities, operational rates and numbers of equipment as stated in the application. Throughput of individual equipment / activities shall be limited to the process rate limits specified in Attachment A. Monthly records of the actual throughput shall be maintained by the applicant and made available to the Division for in spection upon request. (Reference: Regulation 3, Part B,III.A.4)

Cement clinker produced at this facility shall not exceed 1,873,898 tons per year and 178,127 tons per month.

Overburden / waste rock disposed at the quarries shall not exceed 4,895,749 tons per year, and 458,980 tons per month.

Total raw materials (including limestone, translim e, and sand/sandstone) extracted from the quarries shall not exceed 3,086,264 tons per year and 289,340 tons per month.

Total quantity of coal processed and fired shall no t exceed 277,614 tons per year and 26,030 tons per
month.

Tire derived fuel fired into the cement kiln shal l not exceed 55,000 tons per year and 5,156 tons per
month.

Spent lubricant (non-hazardous) fired into the ce ment kiln shall not exceed 100 tons per year.

Natural gas fired into the kiln shall not exceed 6,385 x 10 6 

### SCF per year and 532,083,334 SCF per
month.

Total feed into the cement kiln (dry basis) shall not exceed 3,021,478 tons per year and 283,264 tons per month.

During the first twelve (12) months of operation, co mpliance with both the monthly and yearly production limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the yearly production limits shall be determined on a rolling twelve (12) month total.

18. Prevention of Significant Deterioration (PSD) requirement s shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Reference: Reg.3, Part B, IV. D. 3. b.(iv)). This condition applies to all pollutants for which major modification and application of Best Available Co ntrol Technology (BACT) have not been addressed in this permit. They include, but not limited to, Particulate Matter, Particulate Matter less than 10 micrometers in diameter [PM-10], Sulfur Dioxide, and Oxides of Nitrogen.

19. This facility is subject to Title 40 CFR Part 63 - National Emission Standards for Hazardous Air Pollutants for Source Categories, Subpart LLL - National Emissi on Standards for the Portland Cement Manufacturing Industry. Compliance with these standards shall be achieved immediately upon startup of operation.

### Page 8 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 20. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis): Compliance with the annual limits shall be determined on a rolling (12) month total. By the end of
each month a new twelve month total is calculated ba se on the previous twelve months data. The permit holder shall calculate monthly emissions and keep a compliance record on site for Division review. (Reference: Regulation 3, Part B, III.A.4)

Particulate Matter:.............................................................................. 299.14 tons per year Particulate Matter < 10 μm [PM-10]:................................................. 298.80 tons per year (includes condensables) ............................................................................................................. 28.02 tons per mon th Nitrogen Oxides:............................................................................. 3,203.60 tons per year ........................................................................................................... 300.34 tons per mont h Carbon Monoxide: .......................................................................... 4,418.20 tons per year ........................................................................................................... 414.21 tons per mont h Sulfur Dioxide: ............................................................................... 1,073.90 tons per year ........................................................................................................... 100.68 tons per mont h Volatile Organic Compounds: ........................................................... 196.80 tons per year ............................................................................................................. 18.45 tons per mon th Lead: .................................................................................................. 148.3 pounds per year ............................................................................................................. 13.91 pounds per m onth Particulate Matter - Fugitive: ............................................................. 268.70 tons per year ............................................................................................................. 25.20 tons per mon th Particulate Matter < 10 μm [PM-10]-Fugitive: .................................. 141.28 tons per year ............................................................................................................. 13.25 tons per mon th

Note : These limits include emissions of combustion gases from explosives used in blasting, but do not include emissions of combustion gases from internal combustion engines mounted on mining related equipment and trucks hauling out the ceme nt product from the facility. However, all these emissions have been considered in modeling for the purpose of demonstrating compliance with various ambient quality standards and allowable increments.

During the first twelve (12) months of operation, compliance with both the monthly and yearly emission limitations is required. After the first twelve (12) months of operation, compliance with only the yearly limitation is required. Compliance with the yearly limi ts shall be determined on a rolling twelve (12) month
total.

Compliance with the fugitive particulate matter emission limits shall be demonstrated by not exceeding the process rate limits, and by applying, at a minimum, th e emission control measures specified in Attachment

B.

### Page 9 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 21. Source compliance tests shall be conducted to measure the emission rate(s) for the pollutants listed below in order to show compliance with emission limits and to demonstrate the performance of the emission control devices. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any stack test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averag ing time (Reference: Regulation 3, Part B.IV.H.3) Volatile Organic Compounds using EPA approved methods. Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Sulfur Dioxide using EPA approved methods. Particulate Matter using EPA approved methods.

Particulate Matter < 10 μ m [PM-10] using EPA approved methods.

All emission sources subject to specific emission standards, and those with actual uncontrolled emissions of 10 tons per year or greater, shall be tested. These are listed on Attachment C. However, the Division reserves the right to require testing of any other emission source.

22. Prior to scheduling of the stack tests, the applicant sha ll submit to the Division for approval an operating and maintenance plan for all control equipment and control practices, and a proposed record keeping format that will outline how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. (Reference: Reg. 3, Part B,IV.B.2).

23. Continuous emission monitoring systems shall be installed, calibrated, maintained, and operated on the common stack (common to kiln, cooler, alkali bypass, and raw mill ) and on the coal mill vent stack, for measurement and recording of concentrations and emission rates of Oxid es of Nitrogen, Carbon Monoxide, Oxygen, and Sulfur Dioxide. These systems shall conform to 40 CFR

 60.13. Quarterly reports of the emission rates shall be submitted to the Division within ten (10) days of the ending of the quarter.

24. Haul trucks with payload capacity of at least 150 to ns each shall be used, for haulage of raw materials and overburden / waste rock, to minimize the vehicle-miles-traveled.

25. A revised Air Pollutant Emission Notice (APEN) sh all be filed: (Reference: Reg.3, Part A. II. C)

a. Annually whenever a significant incr ease in emissions occurs as follows:

For any criteria pollutant :

For sources emitting less than 100 tons per year , a change in actual emissions of five tons per year or more, above the level report ed on the last APEN; or

For VOC sources in ozone non-attainment areas emitting less than 100 tons of VOC per year, a change in actual emissions of one ton per year or more or five percent, whichever is greate r, above the level reported on the last APEN submitted; or

For sources emitting 100 tons per year or more , a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or

### Page 10 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 A change in actual emissions, above the level reported on the last APEN submitted, of 50 pounds of lead.

For any non-criteria reportable pollutant:

If the emissions increase by 50% or five (5) tons per ye ar, whichever is less, above the level reported on the
last APEN submitted to the Division.

b. Whenever there is a change in the owner or ope rator of any facility, pr ocess, or activity; or

c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or

d. Whenever a permit limitation must be modified; or

e. No later than 30 days before the existing APEN expires.

By:_______________________________ By:________________________________ Cathy Rhodes
Permit Reviewer James S. Geier P.E.
Unit Leader
Construction Permits Unit Stationary Sources Program
Air Pollution Control Division

INITIAL APPROVAL: JULY 29, 1999

MODIFICATION-1: PERTAINED TO ADDITION OF A BY-PASS FOR WET LIME SCRUBBER (AIRS ID: 111)

THIS MODIFICATION-2: PERTAINS TO INCREASE IN NATURAL GAS FUEL USE LIMIT. (NO CHANGE IN EMISSIONS LIMITS) (AIRS ID: 111)

### Page 11 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 Notes to Permit Holder:

1) The production / throughput or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedan ce of any specific emissi on control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision.

2) The emission levels contained in this permit are based on the emission factors used in the Divisions preliminary analysis.

3) This facility is classified as a:

Major Stationary Source

Modification/s addressed in this permit is a majo r modification of a major stationary source.

4) This source is subject to the Common Provisions Regulation Part II, Subpart E, Upset Conditions and Breakdowns. The permittee shall notify the Division of any upset condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than two (2) hours after the start of the next working day, followed by written notice to the Division explaining the cause of the occurrence and that proper action has been or is being taken to correct the conditions causing said violation and to prevent such
excess emission in the future.

5) The following emissions of non-criteria reportable air pollutants are estimated based upon the material consumption / throughput limits. This information is listed to inform the operator of the Division's analysis of the specific compounds. This information is listed on the Division's emission inventory system.

C.A.S. # POLLUTANT EMISSIONS [LB/YR]

71-43-2 Benzene ...................................................................................................29,982.0 7440-47-3 Chromium Compounds.................................................................................262.0 7647-01-0 Hydrogen Chloride ..................................................................................32,793.0 7664-41-7 Ammonia .................................................................................................18,739.0 7782-49-2 Selenium Compounds ...................................................................................375.0 50-00-0 Formaldehyde ...............................................................................................862.0 91-20-3 Naphthalene ...............................................................................................3,186.0

6) This source is subject to the provisions of Regulati on number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application fo r the Operating Permit is due within one year of commencing operation.

### Page 12 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 ATTACHMENT A

EQUIPMENT / ACTIVITIES COVERED UNDER THIS FACILITY-WIDE PERMIT

AIRS

ID DESCRIPTION MAKE, MODEL, SERIAL NUMBER, DESIGN RATE, CAPACITY, DIMENSIONS,

CONSTRUCTION DETAILS, CONSUMPTION, PRODUCTION, EMISSION CONTROLS, EMISSIONS REMARKS /

SPECIFIC PROVISIONS

101 

### RAW MATERIALS EXTRACTION - QUARRY OPERATIONS

TOP SOIL REMOVAL AND STOCKPILING FOR FUTURE USE DURING

RECLAMATION OF MINED LAND. AIRS ID: 101A.

PROCESS RATE:

TOP SOIL REMOVED / STOCKPILED: 41,000 TONS/YEAR

HAUL TRUCKS: 965 VEHICLE-MILES-TRAVELED (VMT) PER YEAR

MAXIMUM AREA SUBJECT TO WIND EROSION (AREAS ACTIVELY USED): ONE (1) ACRE.

EMISSIONS:

PARTICULATE MATTER - FUGITIVE: 2.63 TONS PER YEAR

PM-10: 1.32 TONS PER YEAR EMISSION CONTROL MEASURES.

MINIMIZATION OF DISTURBED AREAS

AND AREAS SUBJECT TO WIND

EROSION.

REVEGETATION OF DISTURBED

SURFACES.

COARSE LAYER ON SURFACE.

APPLICATION OF CHEMICAL

STABILIZERS.

WATERING AND MAINTAINING
SURFACE MOISTURE TO ADEQUATELY

CONTROL EMISSIONS.

WINDBREAKS / BARRIERS.

DRILLING AND BLASTING. THESE OPERATIONS FRAGMENT THE ROCKS, WHICH INCLUDE OVERBURDEN, WASTE ROCK, TRANSLIME (LOW GRADE BLENDABLE LIMESTONE), SILICEOUS ROCK (USED AS A SOURCE OF SILICA), AND LIMESTONE. AIRS ID: 101B.

PROCESS RATE:

TOTAL NUMBER OF HOLES DRILLED: _____ /YEAR.

AVERAGE DEPTH OF THE HOLES: _____ FEET.

TOTAL QUANTITY OF EXPLOSIVES USED: 2,107 TONS/YEAR

EMISSIONS:

PARTICULATE MATTER - FUGITIVE: 1.35 TONS PER YEAR

PM-10 - FUGITIVE: 0.70 TONS PER YEAR

OXIDES OF NITROGEN: 17.90 TONS PER YEAR

CARBON MONOXIDE: 70.60 TONS PER YEAR EMISSION CONTROL MEASURES:

WET DRILLING.

DELAY ACTION DETONATION AND SEQUENTIAL BLASTING TO MINIMIZE

FORMATION OF FINE PARTICULATE

MATTER.

COMBUSTION GAS EMISSIONS FROM

COMBUSTION OF DIESEL FUEL IN

INTERNAL COMBUSTION ENGINES ON

THE DRILLS ARE NOT INCLUDED IN THE

EMISSIONS.



### ATTACHMENT A CONTINUED...

### Page 13 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 ATTACHMENT A

EQUIPMENT / ACTIVITIES COVERED UNDER THIS FACILITY-WIDE PERMIT

AIRS

ID DESCRIPTION MAKE, MODEL, SERIAL NUMBER, DESIGN RATE, CAPACITY, DIMENSIONS,

CONSTRUCTION DETAILS, CONSUMPTION, PRODUCTION, EMISSION CONTROLS, EMISSIONS REMARKS /

SPECIFIC PROVISIONS

101

CONTD OVERBURDEN AND WASTE ROCK REMOVAL, HAULAGE, AND DISPOSAL:

AIRS ID: 101C.

PROCESS RATE:

OVERBURDEN AND WASTEROCK DISPOSAL: 4,895,749 TONS PER YEAR
HAUL TRUCKS: 22,253 VMT PER YEAR

EMISSIONS:

PARTICULATE MATTER (PM): 32.37 TONS PER YEAR PM-10 (PM < 10 μm): 16.73 TONS PER YEAR CONTROL PLAN

RAW MATERIALS REMOVAL AND HAULAGE TO PRIMARY CRUSHERS:

AIRS ID: 101D.

PROCESS RATE:

RAW MATERIALS QUARRIED AND HAULED: 3,086,264 TONS PER YEAR
HAUL TRUCKS: 38,189 VMT PER YEAR

EMISSIONS:

PARTICULATE MATTER (PM): 62.47 TONS PER YEAR PM-10 (PM < 10 μm): 37.27 TONS PER YEAR CONTROL PLAN

CEMENT KILN DUST HAULAGE AND DISPOSAL:

AIRS ID: 101E.

PROCESS RATE:

CEMENT KILN DUST DISPOSED: 74,956 TONS PER YEAR
HAUL TRUCKS: 3,514 VMT PER YEAR

EMISSIONS:

PARTICULATE MATTER (PM): 2.23 TONS PER YEAR
PM-10 (PM < 10 μ m): 1.34 TONS PER YEAR WETTING OF THE MATERIAL PRIOR TO

PLACEMENT. THIS HARDENS THE
MATERIALS, AND THERE WILL BE NO

EMISSIONS.



### ATTACHMENT A CONTINUED...

### Page 14 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 101

CONTD DISTURBED AREAS IN QUARRY AND PLANT. AIRS ID: 101F

PROCESS RATE:

TOTAL MAXIMUM SUBJECT TO WIND EROSION: 440 ACRES

EMISSIONS:

PARTICULATE MATTER: 167.21 TONS PER YEAR

PM-10: 83.61 TONS PER YEAR MINIMIZATION OF AREAS EXPOSED TO

WIND EROSION.

MINED LAND RECLAMATION ACTIVITIES. please give details . AIRS ID: 101G .



### RAW MATERIALS CRUSHING AND PRE-BLENDING:

102 TRANSFER FROM HAUL TRUCKS TO FEED HOPPER OF PRIMARY CRUSHER

No. 1: AIRS ID: 102A.

PROCESS RATE:

TOTAL RAW MATERIALS TRANSFERRED: 95,000 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.01 TON PER YEAR

PM-10: 0.01 TON PER YEAR EXISTING. TO BE PROVIDED WITH

CONTROL DEVICES.

SUBJECT TO NSPS, OOO, unless constructed prior to August 31, 1983 and not subsequently

modified. Proof of date of construction shall be provided to the Division prior to final approval.

TRANSFER FROM HAUL TRUCKS TO FEED HOPPER OF PRIMARY CRUSHER

No. 2: AIRS ID: 102B.

PROCESS RATE:

TOTAL RAW MATERIALS TRANSFERRED: 2,991,264 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.02 TON PER YEAR

PM-10: 0.02 TON PER YEAR TO BE CONSTRUCTED.

SUBJECT TO NSPS, OOO



### ATTACHMENT A CONTINUED...

### Page 15 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 102

CONTD ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, ______ TYPE ROCK CRUSHER, DESIGN RATED AT ____ TPH, FOR PRIMARY CRUSHING OF RAW

MATERIALS. THIS CRUSHER IS IDENTIFIED AS 

### PRIMARY CRUSHER

NO. 1 . EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE IDENTIFIED AS _______.

PROCESS RATE:

RAW MATERIALS PROCESSED: 95,000 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.05 TON PER YEAR

PM-10: 0.05 TON PER YEAR EXISTING CRUSHER

SUBJECT TO NSPS, OOO unless constructed prior to August 31, 1983 and not subsequently

modified. Proof of date of construction shall be provided to the Division prior to final approval.

TRANSFER AND CONVEYING OF PRODUCT FROM PRIMARY CRUSHER NO. 1

TO SECONDARY CRUSHER NO. 1. EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE IDENTIFIED AS ______. AIRS ID: 102D.

PROCESS RATE:

RAW MATERIALS CONVEYED/TRANSFERRED: 95,000 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.01 TON PER YEAR

PM-10: 0.01 TON PER YEAR EXISTING TRANSFER POINTS AND

CONVEYOR SYSTEM.

SUBJECT TO NSPS, OOO unless constructed prior to August 31, 1983 and not subsequently

modified. Proof of date of construction shall be provided to the Division prior to final approval.

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, _______ TYPE ROCK CRUSHER, DESIGN RATED AT ______ TPH, FOR SECONDARY CRUSHING OF

RAW MATERIALS. THIS IS IDENTIFIED A 

### SECONDARY CRUSHER NO. 1.

EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE IDENTIFIED AS _________. AIRS ID: 102E.

PROCESS RATE:

TOTAL RAW MATERIALS CRUSHED: 95,000 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.03 TON PER YEAR

PM-10: 0.03 TON PER YEAR EXISTING CRUSHER

SUBJECT TO NSPS, OOO unless constructed prior to August 31, 1983 and not subsequently

modified. Proof of date of construction shall be provided to the Division prior to final approval.



### ATTACHMENT A CONTINUED...

### Page 16 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 102

CONTD ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, _______ TYPE ROCK CRUSHER, DESIGN RATED AT ______ TPH, FOR PRIMARY CRUSHING OF

RAW MATERIALS. THIS IS IDENTIFIED AS 

### PRIMARY CRUSHER NO. 2.

EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE IDENTIFIED AS ________. AIRS ID: 102F

PROCESS RATE:

TOTAL RAW MATERIALS CRUSHED: 2,991,264 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.91 TON PER YEAR

PM-10: 0.91 TON PER YEAR TO BE CONSTRUCTED.

SUBJECT TO NSPS, OOO.

TRANSFER AND CONVEYING OF PRODUCT FROM SECONDARY CRUSHER

NO. 1 TO EXISTING STORAGE SILO. EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE IDENTIFIED AS ________. AIRS ID: 102G .

PROCESS RATE:

TOTAL RAW MATERIALS TRANSFERRED: 95,000 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.10 TON PER YEAR

PM-10: 0.10 TON PER YEAR EXISTING, AND TO BE MODIFIED.

SUBJECT TO NSPS, F.

TRANSFER AND CONVEYING OF PRODUCT FROM PRIMARY CRUSHER NO. 2

TO PRE-BLENDING HALL. EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE IDENTIFIED AS ________. AIRS ID: 102H.

PROCESS RATE:

TOTAL RAW MATERIALS TRANSFERRED: 2,991,264 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.28 TON PER YEAR

PM-10: 0.27 TON PER YEAR TO BE CONSTRUCTED.

SUBJECT TO NSPS, F.



### ATTACHMENT A CONTINUED...

### Page 17 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 102

CONTD TRANSFER AND CONVEYING OF RAW MATERIALS (RECEIVED FROM OUTSIDE SOURCES) TO PRE-BLENDING HALL. EMISSIONS CONTROLLED BY

A FABRIC FILTER BAGHOUSE IDENTIFIED AS ________. AIRS ID: 102J.

PROCESS RATE:

TOTAL RAW MATERIALS TRANSFERRED: 30,215 TONS PER YEAR TO BE CONSTRUCTED.

SUBJECT TO NSPS, F.

PRE-BLENDING ACTIVITIES: ALL EQUIPMENT / ACTIVITIES ARE ENCLOSED

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, STACKER BELT, FOR

LAYERED STACKING OF RAW MATERIALS. THIS IS IDENTIFIED AS


### STACKER BELT

. HEIGHT OF FALL OF MATERIALS FROM THE STACKER

BELT ONTO THE MATERIAL PILE IS AUTOMATICALLY REDUCED (MAXIMUM HEIGHT OF FALL ___ FEET) TO MINIMIZE FORMATION AND

EMISSIONS OF FINE PARTICULATE MATTER USING AUTOMATIC

DISCHARGE HEIGHT CONTROLS.

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, RECLAIMER, DESIGN RATED AT _______ TPH, FOR RECLAMATION OF PRE-BLENDED RAW

MATERIALS. THIS IS IDENTIFIED AS 

### RECLAIMER

.

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, CONVEYOR BELT FOR

CONVEYING OF PRE-BLENDED RAW MATERIALS TO MILL FEED BINS. THIS

IS IDENTIFIED AS 

### PRE-BLENDED RAW MATERIALS CONVEYOR

.

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, CONVEYOR BELT FOR

CONVEYING OF INDIVIDUAL RAW MATERIALS TO CORRECTION BINS.

THIS IS IDENTIFIED AS 

### CORRECTION RAW MATERIALS
CONVEYOR

.

TRANSFER POINTS ASSOCIATED WITH THESE ACTIVITIES.

EMISSIONS FROM THESE ACTIVITIES ARE CONTROLLED BY EXHAUST AIR

VENTED THROUGH A FABRIC FILTER BAGHOUSE IDENTIFIED AS

__________.

AIRS ID: 102K.

PROCESS RATE:

TOTAL RAW MATERIALS BLENDED: 3,021,478 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.25 TON PER YEAR

PM-10: 0.25 TON PER YEAR TO BE CONSTRUCTED.

SUBJECT TO NSPS, F.



### ATTACHMENT A CONTINUED...

### Page 18 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 102

CONTD TRANSFERRING AND CONVEYING OF RAW MATERIALS BLEND FROM RAW
MILL FEED BINS / CORRECTION BINS AND THEN TO TRANSFER TOWER (ACROSS THE RIVER).

EMISSIONS ARE CONTROLLED BY A FABRIC FILTER BAGHOUSE. AIRS ID:

102L.

PROCESS RATE:

RAW MATERIALS BLEND TRANSFERRED/CONVEYED: 3,021,478 TONS / YEAR

EMISSIONS:

PARTICULATE MATTER: 0.22 TON PER YEAR

PM-10: 0.21 TON PER YEAR SUBJECT TO NSPS, F.

103 UNLOADING, TRANSFERRING (FROM UNLOAD HOPPER TO CONVEYOR, AND FROM CONVEYOR ONTO STOCKPILE) AND CONVEYING OF COAL (RECEIVED FROM OUTSIDE SOURCES BY RAILCARS OR TRUCKS)TO COAL

STOCKPILE. HEIGHT OF FALL REDUCED TO MINIMIZE FORMATION OF

FINE PARTICULATE MATTER. EMISSIONS CONTROLLED BY MAINTAINING

NEGATIVE PRESSURE IN THE UNLOADING ENCLOSURES AND
EXHAUSTING THROUGH FABRIC FILTER BAGHOUSE/S. AIRS ID: 103A.

PROCESS RATES:

COAL UNLOADED/TRANSFERRED/CONVEYED: 277,614 TONS / YEAR

EMISSIONS:

PARTICULATE MATTER: 1.94 TONS PER YEAR

PM-10: 1.85 TONS PER YEAR SUBJECT TO NSPS, Y.

COAL STOCKPILE:

PROCESS RATE:

MAXIMUM AREA OF COAL STOCKPILE AT ANY TIME: 0.138 ACRE

COAL STORED / HANDLED: 277,614 TONS PER YEAR.

EMISSIONS:

PARTICULATE MATTER-FUG: 0.45 TON PER YEAR

PM-10-FUG: 0.33 TON PER YEAR SURFACE MOISTURE



### ATTACHMENT A CONTINUED...

### Page 19 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 103

CONTD RECLAIMING, CONVEYING, AND TRANSFERRING OF COAL TO COAL

SCREEN. EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE. AIRS

ID:103C.

PROCESS RATE:

COAL HANDLED: 277,614 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.19 TON PER YEAR

PM-10: 0.19 TON PER YEAR SUBJECT TO NSPS, Y.

SCREENING, AND CRUSHING OF OVERSIZE COAL

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, VIBRATING SCREEN DESIGNED RATED AT ______ TPH, FOR SCREENING OF COAL.

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, ______ TYPE COAL CRUSHER, DESIGN RATED AT _____ TPH.

AIRS ID: 103D.

EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE.

PROCESS RATE:

COAL SCREENED / CRUSHED: 277,614 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.19 TON PER YEAR

PM-10: 0.17 TON PER YEAR SUBJECT TO NSPS, Y.

TRANSFERRING AND CONVEYING OF CRUSHED COAL TO TRANSFER
TOWER. EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE/S. AIRS

ID: 103E.

PROCESS RATE:

COAL TRANSFERRED / CONVEYED: 277,614 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.02 TON PER YEAR

PM-10: 0.02 TON PER YEAR SUBJECT TO NSPS, Y.



### ATTACHMENT A CONTINUED...

### Page 20 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 104 UNLOADING, TRANSFERRING AND CONVEYING OF RAW MATERIALS AND ADDITIVES (RECEIVED FROM OUTSIDE SOURCES BY RAILCARS OR TRUCKS) TO TRANSFER TOWER. EMISSIONS CONTROLLED BY

MAINTAINING NEGATIVE PRESSURE IN THE UNLOADING ENCLOSURES
AND EXHAUSTING THROUGH FABRIC FILTER BAGHOUSE/S.

PROCESS RATES:

OTHER RAW MATERIALS / ADDITIVES: 228,000 TONS / YEAR

EMISSIONS:

PARTICULATE MATTER: 0.17 TON PER YEAR

PM-10: 0.16 TON PER YEAR SUBJECT TO NSPS, F.

105 TRANSFERRING AND CONVEYING OF COAL FROM TRANSFER TOWER TO

COAL SILO. EMISSIONS CONTROLLED BY ENCLOSURES AND FABRIC

FILTER BAGHOUSE.

PROCESS RATE:

COAL TRANSFERRED/CONVEYED: 277,614 TONS / YEAR

EMISSIONS:

PARTICULATE MATTER: 0.02 TON PER YEAR

PM-10: 0.02 TON PER YEAR SUBJECT TO NSPS, Y.

106 TRANSFERRING AND CONVEYING OF RAW MATERIAL BLEND FROM

TRANSFER TOWER TO RAW MILL. EMISSIONS CONTROLLED BY

ENCLOSURES AND FABRIC FILTER BAGHOUSE.

PROCESS RATE:

RAW MATERIAL BLEND HANDLED: 3,086,264 TONS / YEAR

EMISSIONS:

PARTICULATE MATTER: 0.23 TON PER YEAR

PM-10: 0.22 TON PER YEAR SUBJECT TO NSPS, F.

107 TRANSFERRING (FROM COAL SILO), CONVEYING (AND ELEVATING), AND

GRINDING OF COAL.

ONE (1) MAKE, MODEL AND S/N: NOT AVAILABLE, ______ (TYPE) GRINDING MILL, DESIGN RATED AT ______ TPH, FOR GRINDING OF COAL. HOT GASES
THROUGH A BYPASS FROM PREHEATER / PRECALCINER IS DRAWN AND

PASSED THROUGH THE GRINDING MILL FOR THERMAL DRYING OF THE

COAL. PARTICULATE EMISSIONS IS CONTROLLED BY A FABRIC FILTER BAGHOUSE WITH AN AIR FLOW RATE OF _________ ACFM.

PROCESS RATE:

COAL HANDLED AND MILLED: 277,614 TONS PER YEAR.

EMISSIONS:

PARTICULATE MATTER: 14.44 TONS PER YEAR

PM-10: 14.44 TONS PER YEAR

OXIDES OF NITROGEN: 263.00 TONS PER YEAR

SULFUR DIOXIDE: 448.60 TONS PER YEAR

CARBON MONOXIDE: 358.90 TONS PER YEAR

VOLATILE ORGANIC COMPOUNDS: 16.20 TONS PER YEAR SUBJECT TO NSPS, Y.

THE GASES EXITING THE BAGHOUSE

CONTAINS SULFUR DIOXIDE. REGULATION NO. 6 REQUIRES THAT

BEST PRACTICAL CONTROL

TECHNOLOGY BE USED TO CONTROL

EMISSIONS OF SULFUR DIOXIDE.

THE OVERALL FACILITY CONTROL

EFFICIENCY OF ABOVE 80 % IS BEING

DETERMINED AS SATISFYING THIS REQUIREMENT.

BAGHOUSE OUTLET GRAIN LOADING:

0.011 GRAIN PER DSCF.

### Page 21 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 RAW MATERIAL BLEND MILLING

108 ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, VERTICAL ROLLER MILL, DESIGN RATED AT _____ TPH, FOR MILLING OF RAW MATERIAL

BLEND TO PRODUCE RAW MEAL. THIS WORKS IN CLOSED-CIRCUIT WITH

CLASSIFYING DRY CYCLONES. GASES EXITING THE PREHEATER ARE

ROUTED THROUGH THIS RAW MILL FOR FURTHER HEAT RECOVERY. THIS

ALSO RESULTS IN FURTHER ABSORPTION OF SULFUR DIOXIDE. EMISSIONS CONTROLLED BY MAINTAINING NEGATIVE PRESSURE, AND BY

EXHAUSTING THROUGH FABRIC FILTER BAGHOUSE. BAGHOUSE OUTLET ROUTED TO THE WET SCRUBBER, AND THEN TO THE COMMON STACK (OF ALKALI BYPASS, CLINKER COOLER, AND RAW MILL).

THE SYSTEM IS IDENTIFIED AS 

### RAW MILL SYSTEM

.

PROCESS RATE:

RAW MATERIAL BLEND MILLED: 3,857,830 TONS PER YEAR (RECIRCULATION INCLUDED)

EMISSIONS:

PARTICULATE MATTER: 6.17 TONS PER YEAR

PM-10: 6.17 TONS PER YEAR SUBJECT TO NSPS, F.

109 TRANSFERRING AND ELEVATING OF MILLED RAW MEAL TO BLENDING

SILO. BUCKET ELEVATOR IS USED WITH TRANSFERS INTO BOTTOM BOOT AND OUT OF THE TOP DISCHARGE INTO THE BLENDING (HOMOGENIZING)

SILO. EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE.

PROCESS RATE:

RAW MEAL TRANSFERRED/ELEVATED: 3,086,264 TONS PER YEAR.

EMISSIONS:

PARTICULATE MATTER: 3.86 TONS PER YEAR

PM-10: 3.86 TONS PER YEAR SUBJECT TO NSPS, F.

110 TRANSFERRING FROM BLENDING SILO, ELEVATING, AND TRANSFERRING

INTO KILN FEED BIN. BUCKET ELEVATOR IS USED WITH TRANSFERS INTO

THE BOTTOM BOOT AND OUT OF THE TOP DISCHARGE INTO THE KILN

FEED BIN. EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE.

PROCESS RATE:

RAW MEAL HANDLED: 3,086,264 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 1.54 TONS PER YEAR

PM-10: 1.54 TONS PER YEAR SUBJECT TO NSPS, F.

### Page 22 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 CEMENT CLINKERING

111 TRANSFERRING / PREHEATING / PRECALCINING / CLINKERING:

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, 5-STAGE, COUNTERCURRENT, CYCLONIC, PREHEATER/PRECALCINER, DESIGN RATED AT 385 TPH FEED (DRY BASIS). DRYING AND PARTIAL

CALCINATION TAKES PLACE IN THIS OPERATION. HOT GASES EXITING

THE CEMENT KILN IS USED IN THIS PYROPROCESSING STEP.

SUPPLEMENTAL HEAT IS PROVIDED WITH COMBUSTION OF COAL IN THE

PRECALCINER STAGE. PART OF THE HOT GASES EXITING THE ROTARY

KILN IS TAKEN OUT THROUGH A BYPASS AND ROUTED TO THE COAL

MILL.

ROTARY KILN:

ONE (1) MAKE, MODEL, AND A/N: NOT AVAILABLE, HIGH TEMPERATURE, CLINKERING ROTARY KILN, MEASURING ____ FEET DIAMETER, ____ FEED LONG, DESIGN RATED AT A KILN FEED (TO PREHEATER) OF ______ TPH.

EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE WITH AN AIR FLOW RATE OF ________ ACFM.

ALKALI BYPASS:

ALKALI LADEN DUST IS REMOVED FROM THE KILN SYSTEM THROUGH A

BYPASS. THE GAS EXITING THE BAGHOUSE IS ROUTED TO THE SULFUR

DIOXIDE SCRUBBER AND THEN TO THE COMMON STACK. THE DUST IS

COLLECTED IN A FABRIC FILTER BAGHOUSE. THIS HIGH ALKALI DUST IS

DISCARDED AS CEMENT KILN DUST. GAS FLOW RATE THROUGH THIS BYPASS IS _______ ACFM.

PROCESS RATE:

TOTAL FEED TO THE KILN: 3,086,264 TONS PER YEAR. (TO PREHEATER) COAL FIRED: ______ TONS PER YEAR. (MAIN FIRING) COAL FIRED INTO THE PRECALCINER: ____ TONS PER YEAR (SUPPLEMENTAL FIRING) TIRE DERIVED FUEL FIRED: 55,000 TONS PER YEAR. NATURAL GAS: 700,000,000 SCF PER YEAR. HIGH ALKALI CEMENT KILN DUST COLLECTED: 74,956 TONS PER YEAR.

EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE WITH AN AIR FLOW RATE OF _______ ACFM.

GASES EXITING THE BAGHOUSE IS ROUTED TO THE COMMON STACK (OF CEMENT KILN, CEMENT CLINKER COOLER, ALKALI BYPASS, AND RAW MILL SYSTEM). A LIME SCRUBBER CONTROLS THE EMISSIONS OF SULFUR

DIOXIDE PRIOR TO THE RELEASE INTO THE ATMOSPHERE THROUGH THE COMMON STACK. THE SCRUBBER IS EQUIPPED WITH A BY-PASS FOR OPERATION DURING UNFORESEEN (BREAKDOWN) STOPPAGE OF THE

SCRUBBER. SUBJECT TO NSPS, F

BAGHOUSE OUTLET GRAIN LOADING:

0.011 GRAIN PER DSCF.

CONTROL EFFICIENCY FOR SULFUR

DIOXIDE: 87.5 PER CENT.

LOW NOx COMBUSTION SYSTEM

GOOD COMBUSTION CONTROL

PRACTICES.

WET LIME SCRUBBER FOR CONTROL OF

SULFUR DIOXIDE.

111

CONTD EMISSIONS FROM TRANSFERRING/PREHEATER/PRECALCINER/CLINKERING

PARTICULATE MATTER: 132.10 TONS PER YEAR

PM-10: 132.10 TONS PER YEAR OXIDES OF NITROGEN: 2,922.71 TONS PER YEAR CARBON MONOXIDE: 3,988.70 TONS PER YEAR

SULFUR DIOXIDE: 623.23 TONS PER YEAR

VOLATILE ORGANIC COMPOUNDS: 180.50 TONS PER YEAR

PROCESS RATE: SUBJECT TO NSPS, F.

BAGHOUSE OUTLET GRAIN LOADING:

0.011 GRAIN PER DSCF.

### Page 23 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 112 CEMENT CLINKER COOLER:

ONE (1) MAKE, MODEL, AND S/N: NOT AVAILABLE, AIR-SWEPT GRATE TYPE CLINKER COOLER, DESIGN RATED AT _____ TPH. COOLED CLINKER

IS CONVEYED TO CLINKER DOME. EMISSIONS CONTROLLED BY A FABRIC FILTER BAGHOUSE WITH AN AIR FLOW OF _______ ACFM. THE GAS EXITING THE BAGHOUSE IS ROUTED TO THE COMMON STACK (OF CEMENT KILN, ALKALI BYPASS, CLINKER COOLER AND RAW MILL).

PROCESS RATE:

CEMENT CLINKER COOLED: 1,873,898 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 60.20 TONS PER YEAR

PM-10: 60.20 TONS PER YEAR SUBJECT TO NSPS, F.

BAGHOUSE OUTLET GRAIN LOADING:

0.011 GRAIN PER DSCF.

113 CEMENT CLINKER STORAGE AND HANDLING:

CEMENT CLINKER DOME. STORAGE CAPACITY: TONS THE DOME IS MAINTAINED UNDER A NEGATIVE PRESSURE, AND THE AIR

IS EXHAUSTED THROUGH FABRIC FILTER BAGHOUSE.

PROCESS RATE:

CEMENT CLINKER STORED / HANDLED: 1,873,898 TONS PER YEAR.

EMISSIONS:

PARTICULATE MATTER: 0.07 TON PER YEAR

PM-10: 0.07 TON PER YEAR SUBJECT TO NSPS, F.

114 TRANSFERRING AND CONVEYING OF CEMENT CLINKER (INCLUDE CLINKER RECEIVED FROM OUTSIDE SOURCES) AND CEMENT ADDITIVES (GYPSUM AND LIMESTONE FOR MORTAR CEMENT) TO CEMENT FINISH

MILL BINS:

DETAILS OF BINS AND IDENTIFICATION:

EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE.

PROCESS RATE:

CEMENT CLINKER HANDLED: 2,022,193 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 0.09 TON PER YEAR

PM-10: 0.08 TON PER YEAR SUBJECT TO NSPS, F.

### Page 24 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 FINISH MILL SYSTEM:

MILL #1 (AIRS ID: 115A) (PLEASE GIVE DETAILS)

MILL #2 (AIRS ID: 115B) (PLEASE GIVE DETAILS)

MILL #3 (AIRS ID: 115C) THIS IS TO BE CONSTRUCTED 115

EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE COLLECTORS, WITH AIR FLOW RATE/S _________ ACFM.

TOTAL PROCESS RATE:

TOTAL CEMENT PRODUCED: 2,022,193 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 70.78 TONS PER YEAR

PM-10: 70.78 TONS PER YEAR SUBJECT TO NSPS, F.

MILL #3 BAGHOUSE OUTLET GRAIN

LOADING: 0.011 GRAIN PER DSCF.

116 TRANSFERRING AND CONVEYING OF CEMENT TO CEMENT SILOS ( BULK LOADOUTS AND PACKHOUSE):

DETAILS OF HANDLING EQUIPMENT (PLEASE GIVE THESE DETAILS)

EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE.

PROCESS RATE:

TOTAL CEMENT HANDLED: 2,022,193 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 2.55 TONS PER YEAR
PM-10: 2.43 TONS PER YEAR SUBJECT TO NSPS, F.

117 CEMENT PACKHOUSE FOR PACKING OF CEMENT IN BAGS OR OTHER
CONTAINERS.

EQUIPMENT DETAILS (PLEASE GIVE THE DETAILS).

EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE.

PROCESS RATE:

CEMENT PACKED IN BAGS/CONTAINERS: 99,999 TONS PER YEAR.

EMISSIONS:

PARTICULATE MATTER: 0.13 TON PER YEAR
PM-10: 0.13 TON PER YEAR SUBJECT TO NSPS, F.

### Page 25 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 118 CEMENT BULK LOADOUTS (RAIL CARS AND TANKER TRUCKS)

EQUIPMENT DETAILS (PLEASE GIVE DETAILS)

11 EXISTING BULK LOADOUTS

2 LOADOUTS TO BE CONSTRUCTED

EMISSIONS CONTROLLED BY FABRIC FILTER BAGHOUSE/S.

PROCESS RATE:

BULK CEMENT LOADED: 2,022,193 TONS PER YEAR

EMISSIONS:

PARTICULATE MATTER: 2.58 TONS PER YEAR
PM-10: 2.46 TONS PER YEAR SUBJECT TO NSPS, F.



### ATTACHMENT A CONTINUED...

119 CEMENT PRODUCT HAULOUT: PAVED HAULROADS.

TOTAL VEHICLE-MILES TRAVELED: 8,000 PER YEAR

EMISSIONS:

PARTICULATE MATTER: 1.60 TONS PER YEAR
PM-10: 1.20 TONS PER YEAR CONTROL PLAN



### END OF ATTACHMENT A.

### Page 26 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 ATTACHMENT B

PARTICULATE EMISSIONS CONTROL PLAN FO R MINING AND PROCESSING ACTIVITIES

THE FOLLOWING PARTICULATE EMISSIONS CONTRO L MEASURES SHALL BE USED FOR COMPLIANCE
PURPOSES ON THE ACTIVITIES COVERED BY TH IS PERMIT, AS REQUIRED BY THE AIR QUALITY CONTROL COMMISSION REGULATION NO.1, SECTION III. D. 1. b. THIS SOURCE IS SUBJECT TO THE
FOLLOWING EMISSION GUIDELINES:

a. Mining and Processing Activities - Visible emissions not to exceed 20%, no off-property transport of visible emissions.

b. Haul Roads - No off-property transport of vi sible emissions shall apply to on -site haul roads, the nuisance guidelines shall apply to off-site haul roads.

c. Haul Trucks - No off-property transport of visibl e emissions except that when op erating off the property of the owner or operator, the applicable guidelines shall be no off-vehicle transport of visible emissions.

Control Measures

1 Adequate soil moisture must be maintained in tops oil and overburden to control emissions during removal. Watering shall be implemented if necessary.

2 Topsoil and overburden stockpiles shall be compacted and revegetated within one year.

3 Emissions from material handling (i.e. removal, loading, and hauling) shall be controlled by watering at all times unless natural moisture is sufficient to control emissions.

4 Vehicle speed on haul roads, service roads, unpaved ro ads and disturbed areas shall not exceed maxima specified below:

Empty haul trucks: 35 m.p.h. (mean speed 25 m.p.h.) Loaded haul trucks: 25 m.p.h. (mean speed 15 m.p.h.)

Speed limit signs shall be posted.

5 Unpaved haul roads shall be treated with chemicals fo r crusting and dust suppression, and watered as often as needed to effectively control fugitive particulate emissions such that the above guidelines are met, and to achieve control efficiencies of, at least 85 % for Total Suspended Pa rticulates, and at least 80 % for Particulate Matter less than 10 micrometers aer odynamic diameter [PM-10].

6 Any accumulations of debris on haul roads and other areas where they have th e potential to get air borne shall be cleaned with the least delay, and such delay shall in no ca se exceed four (4) hours. The haul roads and other areas shall be inspected at least twice in a work shift. Time interval between the first and last inspection within a work shift shall be at least three (3) hours.

7 Reclamation works and sequential extraction of material sh all be initiated to keep the total disturbed areas at any one time to a minimum. Comment [COMMENT3]: Use SHIFT-F5, 5, 3 to number a condition

### Page 27 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 8 Material stockpiles shall be watered as necessary to control fugitive part iculate emissions. Materials shall be sprayed with water during material loading into the stor age bins or stockpiles, if emissions are not otherwise controlled.

9 Plant entryway, truck service roads, and other traffic areas shall be concreted or graveled. Watering shall be implemented if emission guidelines above are not met.

10 Sequential blasting using delay action detonators shal l be implemented to minimize formation of airborne particulate matter.

11 Rock drills used for blast hole drilling shall be equipped with wet drilling system to effectively suppress the emissions of particulate matter.

12 Activities causing fugitive dust emissions shall be suspended when wind speeds reach or exceed 30 miles per hour.

END OF ATTACHMENT B.

### Page 28 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 ATTACHMENT C

EMISSION SOURCES REQUIRED TO BE STACK TESTED

1. Raw materials crushers.

2. Preheater / precalciner / kiln / raw mill.

3. Clinker cooler.

4. Alkali bypass.

5. Coal mill.

6. Cement finish mills.

7. Representative baghouses (at least one in five) identified in the protocol and approved by the Division.

### Page 29 Colorado Department of Public Health and Environment
Construction Permit Air Pollution Control Division HOLNAM, INC. - PORTLAND PLANT
Permit No. 98FR0895 Initial Approval - Modification-2

043/0001/999 ver 11/99 GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8 )

1. This permit is issued in reliance upon the accuracy and co mpleteness of information supplie d by the applicant and is conditi oned upon conduct of the activity, or constr uction, installation and operation of the source, in accordance with this information and wit h representations made by the applicant or a pplicant's agents. It is valid only for th e equipment and operations or activity spe cifically identified on the permit.

2. Unless specifically stated otherwise, th e general and specific conditions contained in this pe rmit have been determined by t he APCD to be necessary to assure co mpliance with the provisions of Section 25-7-114.5(7)(a), C.R.S.

3. Each and every condition of this permit is a material part hereof and is not severable. Any cha llenge to or appeal of, a co ndition hereof shall constitute a rejection of the entire permit and upon such occurrence, this pe rmit shall be deemed denied ab initio . This permit may be revoked at any time prior to final approval by the Air Pollution Contro l Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Qu ality Control Commission (AQCC), including failure to meet any express term or condition of th e permit. If the Division denies a permit, c onditions imposed upon a permit are contested by th e applicant, or the Division revokes a permit, the applicant or owner or operator of a s ource may request a he aring before the AQ CC for review of the Divisions action.

4. This permit and any required attachments must be retained and made available fo r inspection upon request at the location set forth herein. With respect to a portable source which is moved to a new location, a copy of the Relocation Notic e (required by law t o be submitted to the APCD whenever a portable s ource is relocated) should be attached to this permit. The permit may be reissued t o a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section III.B. upon a request for transfer of ownership an d the submittal of a revised APEN and the required fee.

5. Issuance (initial approval) of an emission permit does not pr ovide "final" authority for this activity or operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. a nd AQCC Regulation No. 3, Part B, Section IV .H. Final approval cannot be granted until the operation or activity commences and ha s been verified by the APCD as conforming in all respects with th e conditions of the permit. If the APCD so determines, it will provide written documentation of such final approval, wh ich does constitute "final" authority to operate. Compliance with the permit conditions must be demonstrated within 180 days after commencement of operation.

6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within 18 months after either the date of issuance of this permit or the date on whic h such construction or activity wa s scheduled to commence as set forth in the permit, whichever is later; (2) discon tinue construction for a period of 18 months or more; or (3) do not complete construc tion within a reasonable time of the estimated co mpletion date. Extensions of the expirati on date may be granted by the APCD upon a showing of good cause by the permitte e prior to the expiration date.

7. YOU MUST notify the APCD at least thirty days (fifteen days for portable sources) prior to commencement of the permitted operation or activity . Failure to do so is a violation of Section 25-7-114.5(12)(a), C.R.S. and AQCC Regulation No. 3, Part B, Section IV.H.1., and can result in the revocation of the permit. You must demonstrate compliance w ith the permit conditions within 180 days after commenceme nt of operation as stated in condition 5.

8. Section 25-7-114.7(2)(a), C.R.S. require s that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and admi nistration. If a source or activity is to be discontinued, the owner must notify th e Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate.

9. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regu lations of the AQCC may result in administrative, civil or criminal enforcement actions under Secti ons 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.