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 DESCRIBED 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 SUBJECT TO THIS PERMIT INCLUDES 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 major 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 COLORADO 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 are canceled upon issuance of this permit. 

2. Construction for modification of this facility must commence within 18 months of initial approval permit issuance 

date or within 18 months of date on which such construction or activity was scheduled to commence as stated in the 

application. If commencement does not occur within 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 scrubber 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 permitted 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 commencement of operation, compliance with the conditions 

contained in this permit shall be demonstrated to the Division. 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 certify 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 consecutive 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 requirements 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 dryer, 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 per ton of feed (dry basis) to the kiln. 

Gases discharged into the atmosphere from the 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 Performance for Coal Preparation Plants: These standards apply to thermal 

dryers, pneumatic coal-cleaning equipment, coal processing 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  3o

F. The monitoring device shall be 

recalibrated in accordance with procedures under 40 CFR  60.13. 

Other Operations: Gases discharged into the atmosphere from other 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 operation, bucket elevator, belt conveyor, bagging operation, 

storage bin, enclosed truck or railcar loading station 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 shall 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 utilizing 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 stream for the purpose of drying in the coal mill), and alkali bypass to 

achieve an overall facility sulfur dioxide 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 maintained and operated in a manner consistent 

with good air pollution control practices for minimizing 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 operating 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 shall 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 concentration 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 malfunctions 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 maintained 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 control devices / systems capable of reducing uncontrolled 

emissions of various pollutants as specified in Attachment A. Operating parameters of the control equipment 

shall be identified prior to final approval 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 required 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 Technology (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 kiln / 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 and 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 parameters 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 inspection 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, translime, 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 not exceed 277,614 tons per year and 26,030 tons per 

month. 

Tire derived fuel fired into the cement kiln shall not exceed 55,000 tons per year and 5,156 tons per 

month. 

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

Natural gas fired into the kiln shall not exceed 6,385 x 106

 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, compliance 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) requirements 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 Control 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 Emission 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 base 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 month 

Nitrogen Oxides:............................................................................. 3,203.60 tons per year 

........................................................................................................... 300.34 tons per month 

Carbon Monoxide: .......................................................................... 4,418.20 tons per year 

........................................................................................................... 414.21 tons per month 

Sulfur Dioxide: ............................................................................... 1,073.90 tons per year 

........................................................................................................... 100.68 tons per month 

Volatile Organic Compounds: ........................................................... 196.80 tons per year 

............................................................................................................. 18.45 tons per month 

Lead: .................................................................................................. 148.3 pounds per year 

............................................................................................................. 13.91 pounds per month 

Particulate Matter - Fugitive: ............................................................. 268.70 tons per year 

............................................................................................................. 25.20 tons per month 

Particulate Matter < 10 μm [PM-10]-Fugitive: .................................. 141.28 tons per year 

............................................................................................................. 13.25 tons per month 

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 cement 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 limits 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, the 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 averaging 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 μm [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 shall 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 Oxides 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 tons 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) shall be filed: (Reference: Reg.3, Part A. II. C) 

a. Annually whenever a significant increase 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 reported 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 greater, 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 year, 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 operator of any facility, process, 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 exceedance of any specific emission 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 major 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 Regulation number 3, Part C, Operating Permits (Title V of the 1990 

Federal Clean Air Act Amendments). The application for 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 μm): 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 FOR MINING AND PROCESSING ACTIVITIES

THE FOLLOWING PARTICULATE EMISSIONS CONTROL MEASURES SHALL BE USED FOR COMPLIANCE 

PURPOSES ON THE ACTIVITIES COVERED BY THIS 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 visible 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 visible emissions except that when operating 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 topsoil 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 roads 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 for 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 Particulates, and at least 80 % for Particulate Matter less 

than 10 micrometers aerodynamic diameter [PM-10]. 

6 Any accumulations of debris on haul roads and other areas where they have the potential to get air borne shall be 

cleaned with the least delay, and such delay shall in no case 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 shall 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 particulate emissions. Materials shall be 

sprayed with water during material loading into the storage 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 shall 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 completeness of information supplied by the applicant and is conditioned upon 

conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with 

representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically 

identified on the permit. 

2. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD 

to be necessary to assure compliance 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 challenge to or appeal of, a condition 

hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This 

permit may be revoked at any time prior to final approval by the Air Pollution Control Division (APCD) on grounds set forth in the 

Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any 

express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the 

applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for 

review of the Divisions action. 

4. This permit and any required attachments must be retained and made available for 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 Notice (required by law to be 

submitted to the APCD whenever a portable source is relocated) should be attached to this permit. The permit may be reissued to 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 and 

the submittal of a revised APEN and the required fee. 

5. Issuance (initial approval) of an emission permit does not provide "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. and 

AQCC Regulation No. 3, Part B, Section IV.H. Final approval cannot be granted until the operation or activity commences and has 

been verified by the APCD as conforming in all respects with the conditions of the permit. If the APCD so determines, it will provide 

written documentation of such final approval, which 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 which such construction or activity was scheduled to commence as set forth in 

the permit, whichever is later; (2) discontinue construction for a period of 18 months or more; or (3) do not complete construction 

within a reasonable time of the estimated completion date. Extensions of the expiration date may be granted by the APCD upon a

showing of good cause by the permittee 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 with the permit conditions within 

180 days after commencement of operation as stated in condition 5.

8. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an 

annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the 

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 regulations of 

the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 

(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.