Michigan Department of Environmental Quality Air Quality Division



### EFFECTIVE DATE: December 2, 2003

REVISION DATE(S): April 15, 2005, June 15, 2006

ISSUED TO

Lafarge Midwest, Inc., Alpena Plant

State Registration Number (SRN): B1477

LOCATED AT

Alpena, Alpena County, Michigan 49707



## RENEWABLE OPERATING PERMIT

Permit Number: MI-ROP-B1477-2003b

Expiration Date: December 2, 2008

Administratively Complete ROP Renewal Application Due Between June 2, 2007 and June 2, 2008

This Renewable Operating Permit (ROP) is issued in accordance with and subject to Section 5506(3) of Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Pursuant to Michigan Air Pollution Control Rule 210(1), this ROP constitutes the permittee’s authority to operate the stationary source identified above in accordance with the general conditions, special conditions and attachments contained herein. Operation of the stationary source and all emission units listed in the permit are subject to all applicable future or amended rules and regulations pursuant to PA 451 and the federal Clean Air Act.



## SOURCE-WIDE PERMIT TO INSTALL

Permit Number: MI-PTI-B1477-2003b

This Permit to Install (PTI) is issued in accordance with and subject to Section 5505(5) of Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. Pursuant to Michigan Air Pollution Control Rule 214a, the terms and conditions herein, identified by the underlying applicable requirement citation of Rule 201(1)(a), constitute a federally enforceable PTI. The PTl terms and conditions do not expire and remain in effect unless the criteria of Rule 201(6) are met. Operation of all emission units identified in the PTI is subject to all applicable future or amended rules and regulations pursuant to PA 451 and the federal Clean Air Act. Michigan Department of Environmental Quality

______________________________________ Lynn Fiedler, Permit Section SupervisorROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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## TABLE OF CONTENTS

AUTHORITY AND ENFORCEABILITY................................................................................................... ...4

A. GENERAL CONDITIONS ......................................................................................................... ............5

Permit Enforceability .......................................................................................................... .........................5 1.1 General Provisions............................................................................................................. ..............5 1.2 Equipment and Design........................................................................................................... ..........6 1.3 Emission Limits ................................................................................................................ ................6 1.4 Testing/Sampling ............................................................................................................... ..............6 1.5 Monitoring/Recordkeeping ....................................................................................................... ........7 1.6 Certification & Reporting ...................................................................................................... ............7 1.7 Permit Shield.................................................................................................................. ..................8 1.8 Revisions...................................................................................................................... ....................9 1.9 Re-openings.................................................................................................................... .................9 1.10 Renewals....................................................................................................................... .............10 Stratospheric Ozone Protection ................................................................................................. ...............10 Risk Management Plan........................................................................................................... ..................10 Emission Trading ............................................................................................................... .......................10 Permit To Install (PTI) ........................................................................................................ .......................11

B. SOURCE-WIDE CONDITIONS..................................................................................................... ......12

C. EMISSION UNIT CONDITIONS................................................................................................... .......14

EMISSION UNIT SUMMARY TABLE .................................................................................................... ...14 EU-Quarry Operations-1 ......................................................................................................... ..................17 EU-Quarry Operations-2 ......................................................................................................... ..................20 EU-RAW MILL SYSTEM............................................................................................................. ..............23 EU-ARM......................................................................................................................... ...........................26 EU-Coal Handling System ........................................................................................................ ................32 EU-Kiln19...................................................................................................................... ............................34 EU-Kiln20...................................................................................................................... ............................39 EU-Kiln21...................................................................................................................... ............................44 EU-Kiln22...................................................................................................................... ............................49 EU-Kiln23...................................................................................................................... ............................54 EU-CKD System .................................................................................................................. .....................59 EU-Clinker System.............................................................................................................. ......................61 EU-Finish Mill System.......................................................................................................... .....................64 EU-Cement Storage and Bulk Loading............................................................................................. ........67

D. FLEXIBLE GROUP CONDITIONS .................................................................................................. ...70

FLEXIBLE GROUP SUMMARY TABLE ................................................................................................... 70 FG-PCMACT...................................................................................................................... .......................71 FG-KG5CC ....................................................................................................................... ........................75 FG-NO x 

### ............................................................................................................................... ......................77

APPENDICES..................................................................................................................... ......................80

Appendix 1: Abbreviations & Acronyms.......................................................................................... .........80 Appendix 2. Schedule of Compliance ............................................................................................ ..........81 Appendix 3. Monitoring Requirements........................................................................................... ..........81 Appendix 4. Recordkeeping..................................................................................................... ................81ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 3 Appendix 5. Testing Procedures................................................................................................ ..............81 Appendix 6. Permits to Install (PTI).......................................................................................... ................83 Appendix 7. Emission Calculations............................................................................................. .............84 Appendix 8. Reporting ......................................................................................................... ....................85ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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## AUTHORITY AND EN FORCEABILITY

For the purpose of this permit, the permittee is defined as any person who owns or operates an emission unit at a stationary source for which this permit has been issued. The department is defined in Rule 104(d) as the Director of the Michigan Department of Environmental Quality (MDEQ) or his or her designee.

The permittee shall comply with all specific details in the permit terms and conditions and the cited underlying applicable requirements. All terms and condi tions in this ROP are both federally enforceable and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most stationary sources for which an ROP has been issued. These general conditions are included in Part A of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units which are represented as a flexible group, or the entire stationary source which is represented as a source-wide group. Special conditions are identified in Parts B, C, D and/or the appendices.

In accordance with Rule 213(2)(a), all underlying applicable requirements will be identified for each ROP term or condition. All terms and conditions that are included in a Permit to Install (PTI), are streamlined or subsumed, or is state-only enforceable will be noted as such.

In accordance with Section 5507 of Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, the permittee has included in the ROP application a compliance certification, a schedule of compliance, and a compliance plan. For applicable requirements with which the source is in compliance, the source will continue to comply with these requirements. For applicable requirements with which the source is not in compliance, the source will comply with the detailed schedule of compliance requirements that are incorporated as an appendix in this ROP. Furthermore, for any applicable requirements effective after the date of issuance of this ROP, the stationary source will meet the requirem ents on a timely basis, unless the underlying applicable requirement requires a more detailed schedule of compliance.

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other units of government as required by law.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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## A. GENERAL CONDITIONS

Permit Enforceability

• All conditions in this permit are both federally en forceable and state enforceab le unless otherwise noted. (R 336.1213(5))

• Those conditions that are hereby incorporated in a stat e-only enforceable Source-wide Permit to Install (PTI) pursuant to Rule 201(2)(d)are designated by Footnote 1. (R 336.1213(5)(a), R 336.1214a(5))

• Those conditions that are hereby incorporation in f ederal enforceable Source-wide PTI No. MI-PTI-B1477-2003 pursuant to Rule 201(2)(c)(c) is designated by Footnote 2. (R 336.1213(5)(b), R 336.1214a(3))

• This permit does not reliev e the permittee from any resp onsibilities or oblig ations imposed on the permittee, at this source, under Consent Judgment Number 93- 000651, entered on September 28, 2000, between the MDEQ and the permittee.



### 1.1 General Provisions

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of Article II, Chapter 1, Part 55, Air Pollution Control, of the Natural Resources and Envi ronmental Protection Act, 1994 PA 451, as amended (Act 451), and is grounds for enforcement action, for ROP revocation or revision, or for denial of the renewal of the ROP. All terms and co nditions of this ROP that are designated as federally enforceable are enforceable by the Administrator of the United States Environmental Protection Agency (USEPA) and by citizens under the prov isions of the federal Clean Air Ac t (CAA). Any terms and conditions based on applicable requirements which are designated as “state only” are not enf orceable by the USEPA or citizens pursuant to the CAA. (R 336.1213(1)(a))

2. It shall not be a defense for the permittee in an enforc ement action that it would hav e been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this ROP. (R 336.1213(1)(b))

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit modification, revision, or termination, or a notificat ion of planned changes or anticipated noncompliance does not stay any ROP term or condition. This does not su persede or affect the ability of the permittee to make changes, at the permittee’s own risk , pursuant to Rules 215 and 216. (R 336.1213(1)(c))

4. The permittee shall allow the department, or an aut horized representative of th e department, upon presentation of credentials and other documents as may be required by law and upon stating the authority for and purpose of the investigation, to perform any of the following activities (R 336.1213(1)(d)) : a. Enter, at reasonable times, a stationary source or other premises where emi ssions-related activity is conducted or where records must be ke pt under the conditions of the ROP. b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the ROP. c. Inspect, at reasonable times, any of the following: i. Any stationary source. ii. Any emission unit. iii. Any equipment, including monitoring and air pollution control equipment. iv. Any work practices or operations regulated or required under the ROP. d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or parameters for the purpose of assuring compli ance with the ROP or applicable requirements.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 6 5. The permittee shall furnish to the department, within a reasonable time, any information the department may request, in writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies of any records that are required to be kept as a term or condition of this ROP. For information which is claimed by the permittee to be confidential, consistent with the requirements of 1976 PA 442, MCL §15.231 et seq., and known as the Freedom of Information Act, the person may also be required to furnish the records directly to the USEPA together with a claim of confidentiality. (R 336.1213(1)(e))

6. A challenge by any person, the Admi nistrator of the USEPA, or the departm ent to a particular condition or a part of this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any other condition or part of this ROP. (R 336.1213(1)(f))

7. The permittee shall pay fees consistent with the f ee schedule and requirements pursuant to Section 5522 of Act 451. (R 336.1213(1)(g))

8. This ROP does not convey any prope rty rights or any exclusive privilege. (R 336.1213(1)(h))



### 1.2 Equipment and Design

9. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required operating efficiency. The collection and disposal of air contaminants sha ll be performed in a manner so as to minimize the introduction of contaminants to the outer ai r. Transport of collected ai r contaminants in Priority I and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370)

10. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance with the Michigan Air Pollution Control rules and existing law. (R 336.1910)



### 1.3 Emission Limits

11. Except as provided in Subrules 2, 3, and 4 of Rule 301, a person shall not cause or permit to be discharged into the outer air from a process or process equipment a visible emission of a densi ty greater than the most stringent of Rule 301(1)(a) or (b) unless otherwise specif ied in this ROP. The grading of visible emissions shall be determined in accordance with Rule 303. (R 336.1301(1) in pertinent part) : a. A 6-minute average of 20% opacity, except for on e 6-minute average per hour of not more than 27% opacity. b. A limit specified by an applicable feder al new source performance standard.

12. The permittee shall not cause or permi t the emission of an air contaminant or water vapor in quantities that cause, alone or in reaction with other air co ntaminants, either of the following: a. Injurious effects to human health or safety, animal life , plant life of significant economic value, or property. 1 (R 336.1901(a)) b. Unreasonable interference with the comf ortable enjoyment of life and property. 1 (R 336.1901(b))



### 1.4 Testing/Sampling

13. The department may require the owner or operator of any source of an air contaminant to conduct acceptable performance tests, at the owner’s or operator’s expens e, in accordance with Rule 1001 and Rule 1003, under any of the conditions listed in Rule 1001(1). (R 336.2001)

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and Rule 1003. (R 336.2001(2), R 336.2001(3), R 336.2003(1))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 7 15. Any required test results shall be submitted to the Ai r Quality Division (AQD) in the format prescribed by the applicable reference test method within 60 day s following the last date of the test. (R 336.2001(4))



### 1.5 Monitoring/Recordkeeping

16. Records of any periodic emission or parametric monitoring required in this ROP shall include the following information specified in Rule 213(3)(b)(i), where appropriate (R 336.1213(3)(b)) : a. The date, location, time, and me thod of sampling or measurements. b. The dates the analyses of the samples were performed. c. The company or entity that performed the analyses of the samples. d. The analytical techniques or methods used. e. The results of the analyses. f. The related process operating conditions or para meters that existed at the time of sampling or measurement.

17. All required monitoring data, support information and all reports, including reports of all instances of deviation from permit requirements, shall be kept and furnished to the department upon request for a period of not less than 5 years from the date of the monitoring sample, me asurement, report or application. Support information includes all calibration and maintenance records and all original strip-chart recordings, or other original data records, for continuous monitoring instrumentation and copies of all reports required by the ROP. (R 336.1213(1)(e), R 336.1213(3)(b)(ii))



### 1.6 Certification & Reporting

18. Except for the alternate certific ation schedule provided in Rule 213(3)(c) (iii)(B), any document required to be submitted to the department as a term or condition of this ROP shall contain an original certification by a responsible official which states that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

19. A responsible official sh all certify to the appropri ate District Office of t he AQD and the USEPA that the stationary source is and has been in compliance with all terms and conditions contained in the ROP except for deviations that have been or are being reported to the app ropriate District Office of the AQD pursuant to Rule 213(3)(c). This certification s hall include all the information specifi ed in Rule 213(4)(c)(i) through (v) and shall state that, based on information and belief fo rmed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. The USEPA address is: USEPA, Air Compliance Data - Michigan, Air and Radiation Divisi on, 77 West Jackson Boulevard, Chicago, IL, 60604. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annua lly for the term of this ROP as detailed in the special conditions, or more frequently if specified in an applicable requirement or in this ROP. (R 336.1213(4)(c))

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt reporting of deviations from ROP requirements is defi ned in Rule 213(3)(c)(ii) as follows, unless otherwise described in this ROP (R 336.1213(3)(c)) : a. For deviations that exceed t he emissions allowed under the ROP, prompt reporting means reporting consistent with the requirements of Rule 912 as detail ed in Condition 25. All reports submitted pursuant to this paragraph shall be promptly certif ied as specified in Rule 213(3)(c)(iii). b. For deviations which exceed the emissions allow ed under the ROP and which are not reported pursuant to Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe reasons for each deviation and the actions taken to minimize or correct each deviation. c. For deviations that do not exc eed the emissions allowed under the RO P, prompt reporting means the reporting of all deviations in the semiannual reports requi red by Rule 213(3)(c)(i). The report shall describe the reasons for each deviation and the actions ta ken to minimize or correct each deviation.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 8 22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in Rule 213(3)(c)(iii) as ei ther of the following (R 336.1213(3)(c)) : a. Submitting a certification by a resp onsible official with each report which states that, based on information and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, and complete. b. Submitting, within 30 days following the end of a cale ndar month during which one or more prompt reports of deviations from the emissions allowed under the ROP were submitted to the department pursuant to Rule 213(3)(c)(ii), a certif ication by a responsible official which states that, based on information and belief formed after reasonable inquiry, the statements and information contained in each of the reports submitted during the previous month were true, accurate, and comple te. The certification sha ll include a listing of the reports that are being certif ied. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a monthly basis pursuant to this paragraph shall include a statement that certificati on of the report will be provided within 30 days following the end of the calendar month.

23. Semiannually for the term of the ROP as detailed in the special conditions, or more fr equently if specified, the permittee shall submit certified reports of any required monitoring to the approp riate District Office of the AQD. All instances of deviations from ROP requirements during the reporting period shall be clearly identified in the reports. (R 336.1213(3)(c)(i))

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine the actual emissions, of each regulat ed air pollutant as defined in Rule 212(6) for each emi ssion unit utilizing the emissions inventory form s provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdo wn, or malfunction that results in emissions of a hazardous or toxic air pollutant which cont inue for more than one hour in excess of any applicable standard or limitation, or emissions of any air contami nant continuing for more than two hours in excess of an applicable standard or limitation, as requir ed in Rule 912, to the appropriate District Office of the AQD. The notice shall be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal conditions or malfunction. Notice s hall be by any reasonable means, includ ing electronic, telephonic, or oral communication. Written reports, if required under Rule 912, must be submitted to the appropriate District Supervisor within 10 days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been corrected, or within 30 days of di scovery of the abnormal c onditions or malfunction, whichever is first. The written reports shall include all of the information required in Rule 912(5) and shall be certified by a responsible official in a manner consistent with the CAA. (R 336.1912)



### 1.7 Permit Shield

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements as of the date of ROP issuance, if either of the following provisions is satisfied (R 336.1213(6)(a)(i), R 336.1213(6)(a)(ii)) : a. The applicable requirements are included and are specifically identified in the ROP. b. The permit includes a determination or concise su mmary of the determination by the department that other specifically identified requirements are not applicable to the stationary source.

Any requirements identified in Part E of this ROP ha ve been identified as non-applicable to this ROP and are included in the permit shield.

27. Nothing in this ROP shall alte r or affect any of the following: a. The provisions of Section 303 of the CAA, emergency orders, incl uding the authority of the USEPA under Section 303 of the CAA. (R 336.1213(6)(b)(i)) b. The liability of the owner or operator of this source fo r any violation of applicable requirements prior to or at the time of this ROP issuance. (R 336.1213(6)(b)(ii)) c. The applicable requirements of the acid rain prog ram, consistent with Sect ion 408(a) of the CAA. (R 336.1213(6)(b)(iii))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 9 d. The ability of the USEPA to obtain information from a source pursuant to Se ction 114 of the CAA. (R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incor porated into this ROP through procedures for any of the following: a. Operational flexibility changes made pursuant to Rule 215. (R 336.1215(5)) b. Administrative amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.1216(1)(b)(iii)) c. Administrative amendments made pursuant to Ru le 216(1)(a)(v) until the am endment has been approved by the department. (R 336.1216(1)(c)(iii)) d. Minor permit modifications made pursuant to Rule 216(2). (R 336.1216(2)(f)) e. State-only modifications made pursuant to Rule 216(4) until the changes have been approved by the department. (R 336.1216(4)(e))

29. Expiration of this ROP results in the loss of the permit shield. If a timely and administratively complete application for renewal is submitted not more than 18 months, but not less than 6 months, before the expiration date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a))



### 1.8 Revisions

30. For changes to any process or process equipment covered by this ROP that does not require a revision of the ROP pursuant to Rule 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216)

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to Rule 216(1). (R 336.1219(3))

32. For revisions to this ROP, an administratively complete ap plication shall be considered timely if it is received by the department in accordance with the time frames specified in Rule 216. (R 336.1210(9))

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the department takes final action, the permittee shall comply with both the applicable requirements governing the change and the ROP terms and conditions proposed in t he application for the modification. During this time period, the permittee may choose to not comply with the existing ROP terms and conditions that the application seeks to change. However, if the permittee fails to co mply with the ROP terms and conditions proposed in the application during this time period, the terms and conditions in the ROP are enforceable. (R 336.1216(1)(c)(3), R 336.1216(2)(d), R 336.1216(4)(d))



### 1.9 Re-openings

34. A ROP shall be reopened by the department prior to the expiration date and revised by the department under any of the following circumstances: a. If additional requirements become applicable to this stati onary source with three or more years remaining in the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP expiration date. (R 336.1217(2)(a)(i)) b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. (R 336.1217(2)(a)(ii)) c. If the department determines that the ROP contains a material mistake, information required by any applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or the terms or conditions of the ROP. (R 336.1217(2)(a)(iii)) d. If the department determines that the ROP must be revised to ensure compliance with the applicable requirements. (R 336.1217(2)(a)(iv))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 10 1.10 Renewals

35. For renewal of this ROP, an administratively complete appl ication shall be considered timely if it is received by the department not more than 18 months, but not less than 6 months, before the expiration date of the ROP. (R 336.1210(7))



### Stratospheric Ozone Protection

36. If the permittee is subject to 40 CFR Part 82 and servic es, maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of app liances containing refrigerant, including MVAC and small appliances, or if the permittee is a refrigerant reclaime r, appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall comp ly with all applicable st andards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F.

37. If the permittee is subject to 40 CFR Part 82 and perfor ms a service on motor (fleet) vehicles when this service involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. T he term “motor vehicle” as used in Subpart B does not include a vehicle in which final as sembly of the vehicle has not been completed by the original equipment manufacturer. The term MVAC as us ed in Subpart B does not include the air-tight sealed refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using Hydrochlorofluorocarbon-22 refrigerant.



### Risk Management Plan

38. If subject to Section 112(r) of the CAA and 40 CFR Pa rt 68, the permittee shall register and submit to the USEPA the required data related to t he risk management plan for reduci ng the probability of accidental releases of any regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in 68.130. The list of substances, threshold quantities, and acci dent prevention regulations promulgated under Part 68 do not limit in any way the general duty provisions under Section 112(r)(1).

39. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall comply with the requirements of Part 68 no later than the latest of the following dates as provided in 68.10(a): a. June 21, 1999, b. Three years after the date on which a regulated substance is first listed under 68.130, or c. The date on which a regulated substance is first pr esent above a threshold quantity in a process.

40. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall submit any additional relevant information requested by any regulato ry agency necessary to ensure comp liance with the requirements of 40 CFR Part 68.

41. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance with all applicable requirements of Section 112( r) as detailed in Rule 213(4)(c)). (40 CFR Part 68)



### Emission Trading

42. Emission averaging and emission redu ction credit trading are allowed pursua nt to any applicable interstate or regional emission trading program th at has been approved by the Admini strator of the USEPA as a part of Michigan’s State Implementation Plan. Such activi ties must comply with Rule 215 and Rule 216. (R 336.1213(12))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 11 Permit To Install (PTI)

43. The process or proc ess equipment included in this permit shall not be reconstructed, relocated, or modified unless a PTI authorizing such action is issued by the depa rtment, except to the ext ent such action is exempt from the PTI requirements by any applicable rule. 2 (R 336.1201(1))

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence indicates the process or process equipment is not perfor ming in accordance with the terms and conditions of the PTI or is violating the department’s rules or the CAA. 2 (R 336.1201(8), Section 5510 of Act 451, PA 1994)

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or operates the process or process equipment at the location authorized by the PTI. If a new owner or operator submits a written request to the department pursuant to Rule 219 and the department approves the request, this PTI will be amended to reflect the change of ownership or operational control. T he request must include all of the information required by Subrules (1)(a), (b) and (c) of Rule 219. T he written request shall be sent to the appropriate AQD District Supervisor, MDEQ. 2 (R 336.1219)

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and conditions have been approved has not commenced within 18 months, or has been interrupted for 18 months, the applicable terms and conditions from that PTI sh all become void unless otherwise authorized by the department. Furthermore, the person to whom that PT I was issued, or the designated authorized agent, shall notify the department via the Supervisor, Permit Section, MDEQ, AQD, PO Box 30260, Lansing, MI 48909, if it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment allowed by the terms and conditions from that PTI. 2 (R 336.1201(4))

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 12 

## B. SOURCE-WIDE CONDITIONS

Part B outlines the source-wide terms and conditions that appl y to this stationary source. The permittee is subject to these Special Conditions for the stationary source in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the Special Conditions and the underlying applicable requirements cited. If a specific condition type does not appl y to this source, NA (not applicable) has been used in the table. If there are no source-wide condition s, this portion of the permit will be left blank.



## SOURCE-WIDE CONDITIONS

POLLUTION CONTROL EQUIPMENT

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The Permittee shall implement and maintain the AQD app roved fugitive dust control program. Should the AQD determine the fugitive dust control program to be inadequat e, the District Supervisor may request modification of the program to address those inadequacies. The Perm ittee may also propose changes to the program to the District Supervisor. Upon written approval of a modified fugitive dust control program by the District Supervisor, the Permittee shall implement and maintain the modified fugitive dust control program. 2 (R 336.1371, R 336.1901)



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NAROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 13 V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years (R 336.1213(3)(b)(ii))

NA



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years (R 336.1213(3)(b)(ii))

NA



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursu ant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to G eneral Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 14 

## C. EMISSION UNIT CONDITIONS

Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit Summary Table. The permittee is subject to the Spec ial Conditions for each emission unit in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a Specific Condition type does not appl y, NA (not applicable) has been used in the table. If there are no conditions specific to individual em ission units, this section will be left blank.



### EMISSION UNIT SUMMARY TABLE The descriptions provided below are for informational purposes and do not constitute Enforceable Conditions

Emission Unit ID Emission Unit Description (Including Process Equipment & Control Device(s)) Installation Date/ Modification Date Flexible Group ID

EU-QUARRY OPERATIONS-1 Rock Drill and Fabric Fi lter (08-040), Truck Loading, Haul Roads, Primary Crusher Stockpile, 01/01/57-1/01/83 01/01/88 NA

EU-QUARRY OPERATIONS-2 Primary Crusher (10-001 ), Primary Crusher Conveyor (10-032), Dust Suppression System (10-049) Secondary Crusher System: Secondary Crusher (11-002), Secondary Crusher Conveyor (11-063), Foaming System (11-047), Belt Conveyor (11-064), Stone Tower (upper bench, ALPCU-0005), Belt Conveyors (11-065) (11-069), (11-072), (11-067), Stone Tower (lower bench, ALPCU-0006) 11/30/90 – 05/01/02 NA

EU-RAW MILL SYSTEM Raw Mill System: Bin Fill System; (20-008), (21-008), (20-009), (21-009), (20-010), (21-010), (20-011), Fabric Filter (20-273); Raw Mill 14 System, (20-020), (20-021), (20-022), (20-023), (20-031), (20-032), (20- 033), (20-039), (20-040), (20-050), (20-060), (20-255), (20-256), (20-257), (20-267), (20-100), (20-258), (20-259 (crossover to Mill 15)), (20-260), (20-271), (20-273), (20-275), (20-090), (20-050), (20-460), (20-461) (20-080), (20-462), (20-463), Fabric Filters (20-268), (20-269), (20-270), (20-275); Raw Mill 15 System, (21-020), (21-021), (21-022), (21-023), 21-031), (21-032), (21-039), (21-040), (21-255), (21-256), (21-100), (21-060), (21-462), (21-463), (21-258), (20- 259 (crossover to Mill 14)),(21-260), (21-050), (21-080), (21-460), (21-461), (21-275), (21-464), Fabric Filters, (21-268), (21-269), (21-270). 01/01/65 09/01/90 FG-PCMACT (excludes Bin Fill System)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 15 Emission Unit ID Emission Unit Description (Including Process Equipment & Control Device(s)) Installation Date/ Modification Date Flexible Group ID

EU-ARM Alternate Raw Materials System: Flyash Receiving (17-018, 17-020—17-032, 17-040, 17-100, 17-200); Fabric Filters (17-005, 17-045,17-105, 17-205, 17-325, 17-425, 18-205) 10/01/94 17-325 and 17-425 only, included in

FG-PCMACT

EU-Coal Handling System EU-Coal pile, EU-Coke Pile 01/01/84

EU-Kiln 19 Kiln 19 (25-119), Baghouses (25-252), (25-253) 01/01/65 – 06/19/90 FG-PCMACT

EU-Kiln 20 Kiln 20 (25-120), Baghouses (25-263, 25-265) 01/01/65 – 6/19/90 FG-PCMACT

EU-Kiln 21 Kiln 21 (25-121), Baghouses (25-264, 25-266) 01/01/65 – 6/19/90 FG-PCMACT

EU-Kiln 22 Kiln 22, Baghouses (26-261), (26-262) 01/01/75 FG-PCMACT FG-NO x EU-Kiln 23 Kiln 23, Baghouses (26-255), (26-256) 01/01/75 FG-PCMACT FG-NO x EU-CC19, Clinker Cooler 19 (25-159), Baghouse (25-507) 12/02/94 FG-KG5-CC FG-PCMACT EU-CC20 Clinker Cooler 20 (25-160), Baghouse (25-507) 10/01/65 FG-KG5-CC FG-PCMACT EU-CC21 Clinker Cooler 21 (25-161), Baghouse (25-507) 05/01/95 FG-KG5-CC FG-PCMACT EU-CC22 Clinker Cooler 22 (26-162), Fabric Filter (26-252) 02/15/95 FG-PCMACT

EU-CC23 Clinker Cooler 23 (26-163), Fabric Filter (26-258) 01/01/75 FG-PCMACT

EU-CKD SYSTEM Cement Kiln Dust Handling System, Dust Conditioning Storage Bin (32-200), Pugmill (33-310), Fabric Filter (33-250) 06/01/98 NA

EU-CLINKER SYSTEM Clinker Handling System, Crusher (41-437), Fabric Filters (25-825, 26-251, 26-257, 26-825, 25-506, 25-267, 25-268, DC-07, DC-08, DC-09, DC-10, 40-100, 40-110, 40-120, 41-439, 41-352, 41-356, 41-427, 41-447, 41-450), Clinker Storage Building (ALP309BI02) 01/01/90 FG-PCMACT

EU-FINISH MILLS Finish Grind Mill Feed Tank Fill (44-010, 43-010, 40-009 49-609, 45-001, 45-003) (Finish Mills 13-16, 19 -21 (45-043, 45-044, 45-045, 45-046, 49-049), Fabric Filters (41-485, 43-290, 45-261, 45-262, 45-264, 49-269, 49-270, 43-271, 43-272, 43-265, 43-269, 43-270, 44-269, 44-270, 44-271, 44-272) 01/01/90 FG-PCMACTROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 16 Emission Unit ID Emission Unit Description (Including Process Equipment & Control Device(s)) Installation Date/ Modification Date Flexible Group ID

EU-CEMENT STORAGE AND BULK LOADING Storage No. 2 (Bin Nos 24,25,26,27, 28, 29, 30, 31, 32, 33), Fabric Filters (46-411, 50-705, 50-706, 50-707); Storage No. 3 (Bin Nos 16n, 16s, 17n, 17s, 18n, 18s, 19n, 19s, 20n, 20s, 21n, 21s, 22n, 22s, 23n, 23s), Fabric Filters (46-412, 50-721, 50-722); Storage No. 4 (Bin Nos 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47), Fabric Filters (50-416, 50-417, 50-418, 50-419, 50-420, 50-422, 50-423, 50-424, 50-425, 50-426, 50- 427, 50-428, DC09, DC10, DC11, DC12, DC13, DC14, DC15, DC16, DC17, DC18, DC19, DC20, DC21, DC22, DC23, DC24, DC25, DC26, DC27, DC28, DC29, DC30, DC31, DC32, DC33, DC34, DC35, DC36); Tanks 1-4 (46-731, 46-732, 46-733, 46-734), Fabric Filters (46-710, 46-762) 01/01/56 1961-1968 01/01/81 01/01/88 FG-PCMACTROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 17 

## EU-Quarry Operations-1 EMISSION UNIT CONDITIONS

DESCRIPTION: Rock Drill and Fabric Filter (08-040), Truck Loading, Haul Roads, Primary Crusher Stockpile

Flexible Group ID: NA



### POLLUTION CONTROL EQUIPMENT Dust Suppressant, Fabric Filter

IX. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Opacity 15% 2 At point of highest opacity at footprint of the stockpile 6-minute average EU-Quarry Operations-1 Condition V Condition VI.1 R 336.1301, C.J. No. 93-000651- CE, Paragraph IV(6)



### X. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### XI. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall develop, implement and mainta in an operations and maintenance plan for EU-Quarry1 (except the rock drill). Should the AQD determine t he operation and maintenance plan to be inadequate, the District Supervisor may request modification of the program to address those inadequacies. The Permittee may also propose changes to the program to the Distri ct Supervisor. Upon written approval of a modified operation and maintenance plan by the District Supervi sor, the Permittee shall implement and maintain the modified operation and maintenance plan. 2 (R 336.1213(3))

2. The Permittee shall not operate the rock drill without the fabric filter 08-040 being installed and properly operating 2

. (R 336.1910)

3. The permittee shall apply dust suppressant system to the road system at a freque ncy sufficient to prevent fugitive dust. 2 (R 336.1371)



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA

XII. 

### TESTING/SAMPLINGROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 18 Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 19 XIII. MONITORING /RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))



### 1. The Permittee shall record and maintain all preventati ve maintenance records associated with EU-Quarry Operations-1 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)©(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)©(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)©)

See Appendix 8



### XIV. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. NA



### XV. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 20 

## EU-Quarry Operations-2 EMISSION UNIT CONDITIONS

DESCRIPTION: Primary Crusher (10-001), Primary Crusher Conveyor (10-032), Secondary Crusher System: Secondary Crusher (11-002), Secondary Crusher Conveyor (11-063), Belt Conveyor (11-064), Belt Conveyors (11-065) (11-069) (11-072) (11-067).

Flexible Group ID: NA



### POLLUTION CONTROL EQUIPMENT: Dust Suppression System (10-049); Stone Towers (ALPCU-0005), (ALPCU-0006); Foaming System (11-047)

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Opacity 5%* 2 Secondary crusher

conveyors, secondary stone stockpiles Condition V.1 Condition VI.1 Condition VI.3 R 336.1201(3)

2. Opacity 0%* 2 Secondary crusher and building fugitive emissions Condition VI.3 R 336.1201(3)

3. Opacity <7% Secondary crusher Condition VI.7 40 CFR 60.672 C.J. No. 93- 000651-CE, Paragraph IV(6) 4. Particulate 0.022 g/dscf 2 Secondary crusher Condition V.1 40 CFR 60.672(a)(1) 336.1201(3)

* Compliance with this limit shall be considered compliance with the following applicable requirements which have

been subsumed under this streamlined requirement: 40 CFR Part 60, Subparts A and OOO.



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not process more than 4,000,000 tons of material through the secondary crusher per year. 2 (40 CFR 52.21)

2. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by theROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 21 District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))

3. The compliant differential pressure range across the baghouse shall be included in the AQD approved Malfunction Abatement Plan. This compliant differentia l pressure range shall be determined by stack test or other methods, as approved by the District Supervisor. (R 336.1910, R 336.1911(2)(b))

4. The Permittee shall not operate the primary crusher , primary crusher conveyor, secondary crusher, and secondary crusher conveyor without the appropriate dus t suppression system, foam ing system or stone tower towers being installed and properly operating. (R 336.1910)



### IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The Permittee shall equip and maintain the secondary crusher baghouse with a gauge which measures the pressure drop across the baghouse. 2 (R 336.1201(3))



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

NA



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall record and maintain all preventa tive maintenance records associated with EU-Quarry Operations-2 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))

2. A written record of the amount of material processed by the secondary crusher shall be kept on file and made available to the AQD upon request. 2 (R 336.1213(3))

3. Pressure drop across the baghou se of the secondary crusher s hall be read and recorded daily. (R 336.1213(3))

4. Monthly usage rates of the dust suppressant for the pr imary crusher conveyor shall be kept and made available to the AQD upon request. 2 (R 336.1213(3))

5. Monthly usage rates of the foaming system for t he secondary crusher conveyor shall be kept and made available to the AQD upon request. 2 (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 22 VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 23 

## EU-RAW MILL SYSTEM EMISSION UNIT CONDITIONS

DESCRIPTION: Raw Mill System, Bin Fill System, Raw M ill 14, Raw Mill 15, associated conveyors.

Flexible Group ID: PCMACT



### POLLUTION CONTROL EQUIPMENT: Dust Collectors

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Particulate 0.03 pound Per 1,000 Pounds

of exhaust

gases 2 3 hour average EU-Raw Mill System Condition V.1 40 CFR 52.21; C.J. No. 93- 000651-CE, Paragraph IV.6 2. Particulate 27.51 pounds 2 per hour based on a

3 hour average EU-Raw Mill System Condition V.1 40 CFR 52.21; C.J. No. 93- 000651-CE, Paragraph IV.6 3. Particulate 120.2 tons 2 12 month rolling time period as determined at the end of each calendar

month EU-Raw Mill System Condition V.1 40 CFR 52.21; C.J. No. 93- 000651-CE, Paragraph IV.6

4. Sulfur Dioxide 0.0147 pounds per ton of raw material processed 2 3 hour average EU-Raw Mill System Condition VI.4 40 CFR 52.21; R 336.1402; C.J. No. 93- 000651-CE, Paragraph IV.6 5. Sulfur Dioxide 9.4 pounds 2 Per hour based on a 3 hour average EU-Raw Mill System Condition VI.4 40 CFR 52.21; R 336.1402; C.J. No. 93- 000651-CE, Paragraph IV.6 6. Sulfur Dioxide 29.4 tons 2 12 month rolling time period as determined at the end of each calendar

month EU-Raw Mill System Condition VI.4 40 CFR 52.21; R 336.1402; C.J. No. 93-000651- CE, Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 24 II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Raw materials 640 tons 2 Per hour, based on a

24 hour average EU-Raw Mill System Condition VI.1 40 CFR 52.21



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The Permittee shall not use Paxton quarry shale as a ra w material in the system. Further, the Permittee shall not make any other change in the quality and nature or any meaningful increase in the quantity of the emission of an air contaminant from the system without stack testing approved in advanc e by the AQD. Approval of such stack testing by the AQD may require submitta l of an application for a permit to install 2

. (40 CFR 52.21)

2. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))

3. The Permittee shall not operate EU-Raw Mill System wi thout the appropriate fabric filters and dust collectors being installed and properly operating. (R 336.1910) 2

4. The Permittee shall not use any fuel in the system except natural gas. 2 (40 CFR 52.21)



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. On or before May 31, 2006, verification of particulate matter, SO 2, CO, NO x, and VOC emission rates from the EU-Raw Mill System, by testing, at the owner’s exp ense in accordance with D epartment requirements will be required. 2 (R 336.1213(3))



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. A record of the amount of raw material processed pe r hour based on a 24-hour average, shall be kept on file. (R 336.1213(3))

2. The Permittee shall record and maintain all preventat ive maintenance records asso ciated with EU-Raw Mill System for a period of not less than five years a nd shall be made available to the AQD upon request. (R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 25 VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 26



## EU-ARM EMISSION UNIT CONDITIONS

DESCRIPTION: Alternate Raw Materials Storage and Handling; Associated Conveyors, Rail Car Unloading and Storage Buildings, Kiln Group 5 and 6 Kiln Dust Return.

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. PM-10 0.02 grains per actual cubic foot of exhaust gas 2 Iron Ore Tailings Conveyor (18-205) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 2. PM-10 0.43 pounds 2 Per hour Iron Ore Tailings Conveyor (18-205) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 3. PM-10 0.4 ton 2 Per Year Iron Ore Tailings Conveyor(18-205) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 4. PM-10 0.02 grains per actual cubic foot of exhaust gas 2 Each Flyash Gravity Conveyor (17-325 and 17-425) Condition V.2 Condition V.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 5. PM-10 0.17 pounds 2 Per hour Each Flyash Gravity Conveyor (17-325 and 17-425) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 6. PM-10 0.7 ton 2 Per year Each Flyash Gravity Conveyor (17-325 and 17-425) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 27 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

7. PM-10 0.02 grain per actual cubic foot of exhaust gas 2 Flyash Unload Hopper (17-045) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 8. PM-10 2.31 pounds 2 Per hour Flyash Unload Hopper (17-045) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 9. PM-10 2.4 tons 2 Per year Flyash Unload Hopper (17-045) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 10. PM-10 0.02 grain per actual cubic foot of exhaust gas 2 Flyash Dome (17-105) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 11. PM-10 2.57 pounds 2 Per hour Flyash Dome (17-105) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 12. PM-10 2.7 tons 2 Per year Flyash Dome (17-105) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 13. PM-10 0.02 grain per actual cubic foot of exhaust gas 2 Flyash Bin (17-205) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 14. PM-10 2.23 pounds 2 Per hour Flyash Bin (17-205) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 15. PM-10 3.5 tons 2 Per year Flyash Bin (17-205) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 28 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

16. PM-10 0.02 grain per actual cubic foot of exhaust gas 2 Flyash Railcar Unloading (17-005) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 17. PM-10 0.17 pound 2 Per hour Flyash Railcar Unloading (17-005) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 18. PM-10 0.2 ton 2 Per year Flyash Railcar Unloading (17-005) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d)) 19. PM-10 0.02 grain per actual cubic foot of exhaust gas 2 KG5 Kiln Dust Return (31-171) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 20. PM-10 1.24 pounds 2 Per hour KG5 Kiln Dust Return (31-171) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 21. PM-10 5.4 tons 2 Per year KG5 Kiln Dust Return (31-171) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 22. PM-10 0.02 grain per actual cubic foot of exhaust gas 2 KG6 Kiln Dust Return (32-171) (32-173) Condition V.1 Condition V.2 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 23. PM-10 2.87 pounds 2 Per hour KG6 Kiln Dust Return (32-171) (32-173) Condition V.1 Condition V.2 Condition VI.1 R 336.1331, R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d) 24. PM-10 12.6 tons 2 Per year KG6 Kiln Dust Return (32-171) (32-173) Condition V.2 Condition VI.2 R 336.1205, R 336.1224, R 336.1225, 40 CFR 52.21

(c) and (d)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 29 II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA

1. The permittee shall not use in EU-ARM any ammoni a-treated fly ash that has been conditioned with water. 1 (R 336.1901)

2. If the permittee uses any ammonia-treated fly ash in EU-ARM, the permittee shall not condition the ammoniatreated fly ash with water. 1 (R 336.1901)



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The Permittee shall not operate t he Iron Ore Tailings Conveyor (18-205) and Flyash Do me (17-105), for more than 2080 hours per year, each. 2 (R 336.1224, R 336.1225, R 336.1331)

2. The Permittee shall not operate the Flyash Gravity C onveyors (17-325, (17-425), for more than 7884 hours per year, each. 2 (R 336.1224, R 336.1225, R 336.1331)

3. The Permittee shall not operate the Flyash Bin (17-205), for more than 3120 hours per year. 2 (R 336.1224, R 336.1225, R 336.1331)

4. The Permitee shall not operate the Flyash Rail Car (17-005) for more than 2300 hours per year. 2 (R 336.1224, R 336.1225, R 336.1331)

5. The Permittee shall not operate the Flyash Unload Hopper (17-045) for more than 3500 hours per year. 2 (R 336.1205, R 336.1224, R 336.1225)

6. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and ma intain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of PM-10 emission rates from EU-ARM by testing, at the owner’s expe nse, in accordance with Department requirements, may be required. 2 (R 336.2001, R 336.2002, R 336.2004 R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 30 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years (R 336.1213(3)(b)(ii))

1. A written log of the hours of operatio n of the file Iron Ore Tailings Convey or (18-205), Flyash Dome (17-105), Flyash Gravity Conveyors (17-325, and 17-425), Flyash Bin (17-205), Flyash Rail Car (17-005), Flyash Unload Hopper (17-045) shall be kept on file. 2 (R 336.1213(3))

2. The Permittee shall calculate annual emission rates fr om EU-ARM using the most recent stack test data to establish emission factors. (R 336.1213(3))

3. The Permittee shall record and maintain all preventat ive maintenance records associated with EU-ARM for a period of not less than five years and sha ll be made available to the AQD upon request (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. Verification of PM-10 emission rates includes the submitta l of a complete report of the test results. If a stack test is required, the results shall be submitted to the Di strict Supervisor, AQD within 60 days of the completion of the stack test. 2 (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))

5. The annual emissions FROM EU-ARM shall be reported to the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(3))

6. Within 14 days after a change in the supplier of fly ash or iron ore tailings for EU-ARM , the permittee shall notify the AQD District Supervisor, in writing, of the change. 1 (R 336.1225, R 336.1901)

See Appendix 8ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 31 VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV17-005 8.5 2 30 2 R 336.1225, R 336.1901, 40 CFR 52.21

2. SV17-045 31 2 125 2 R 336.1225, R 336.1901, 40 CFR 52.21

3. SV17-105 31 2 125 2 R 336.1225, R 336.1901, 40 CFR 52.21

4. SV17-205 31 2 134.5 2 R 336.1225, R 336.1901, 40 CFR 52.21

5. SV17-325 8.5 2 65 2 not vertically

oriented R 336.1225, R 336.1901, 40 CFR 52.21

6. SV17-425 8.5 2 65 2 not vertically

oriented R 336.1225, R 336.1901, 40 CFR 52.21

7. SV18-205 15 2 45 2 R 336.1225, R 336.1901, 40 CFR 52.21

8. SV31-188 22.2 2 120 2 R 336.1225, R 336.1901, 40 CFR 52.21

9. SV32-171 33.7 2 110 2 R 336.1225, R 336.1901, 40 CFR 52.21



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 32 

## EU-Coal Handling System EMISSION UNIT CONDITIONS

DESCRIPTION: Coal Handling

Flexible Group ID: 

### FG-PCMACT

POLLUTION CONTROL EQUIPMENT: Dust Suppression System and Encrusting Agents

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Opacity 10% 2 EU-Coal Handling System Condition V.1 R 336.1331



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall not operate EU-Coal Handling Syst em without application of coal encrusting agent and dust suppression systems. 2 (R 336.1301(1)(c), R 336.1910)

2. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be in adequate, the District Supervisor may request modification of the program to address those inadequac ies. The Permittee may also propose changes to the program to the District Supervisor. Upon written approval of a modified operation and maintenance plan by the District Supervisor, the Permi ttee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

NAROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 33 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall record the amount of encrusti ng agent applied for each month and shall be made available to the AQD, upon request. 2 (R 336.1213(3))

2. The Permittee shall record the amount of dust suppre ssant applied for each month and shall be made available to the AQD, upon request. 2 (R 336.1213(3))

3. The Permittee shall record and maintain all preventative maintenance records associated with EU-Coal Handling System for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 34 

## EU-Kiln19 EMISSION UNIT CONDITIONS

DESCRIPTION: EU-Kiln 19, Kiln Dust Return System, (31-220), (31-291), (31-003), 31-006), (31-109), (31-110), (31-111), (31-007)

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouse

I. EMISSION LIMITS

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Sulfur Dioxide (SO 2 ) 2,088 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 19 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

2. Nitrogen Oxides (NO x ) 1,530 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 19 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE, Paragraph IV.6

3. Carbon Monoxide (CO) 284 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 19 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE, Paragraph IV.6

4. Sulfur Dioxide (SO 2 ) 548 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 19 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE, Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 35 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

5. Nitrogen Oxides (NO x ) 584 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 19 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE, Paragraph IV.6

6. Carbon Monoxide (CO) 170 ppmv corrected to 7% oxygen on a dry basis 2 Per 12 - month rolling time period values, as determined at the end of each calendar

month EU-Kiln 19 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE, Paragraph IV.6

7. Particulate 0.25 pound per 1,000 pounds

of exhaust

gases, calculated on a dry basis 2 Kiln 19 Condition V.1 R 336.1331, C.J. No. 93- 000651-CE, Paragraph IV.6

8. Particulate 0.10 pound per 1,000 pounds

of exhaust

gases, calculated on a dry basis 2 Kiln Dust Return System, (31-220), (31-291), (31-003), 31-006), (31-109), (31-110), (31-111), (31-007) Condition V.1 R 336.1331, C.J. No. 93- 000651-CE, Paragraph IV.6

9. Hydrogen chloride (HCl) 65 parts per million by volume, combined emissions, as HCl equivalents, corrected to 7% oxygen 1 EU-Kiln 19 Condition V.3 Condition VI.4 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93- 000651-CE, Paragraph IV.7

10. Hydrogen chloride (HCl) 36 pounds 1 Per hour EU-Kiln 19 Condition V.3 Condition VI.4 R 336.1224, R 336.1225, R336.1901, C.J. No. 93- 000651-CE, Paragraph IV.7ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 36 II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years (R 336.1213(3)(b)(ii))

1. On or before May 31, 2007 verification of particulate emission rates from EU-Kiln 19 by testing at the owner’s expense, shall be required. (R 336.1213(3), R 336.2001, R 336.2003, R 336.2004)

2. The permittee shall perform periodic verification of HCl and chlorine gas emissions from EU-Kiln 19 at the owner’s expense, in accordance with the AQD’s requirements and in accordance with the minimum requirements specified in Appendix 5. 1 (R 336.1213(3))

See Appendix 5



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years (R 336.1213(3)(b)(ii))

1. The permittee shall monitor and record the SO 2 , NO x , and CO from EU-Kiln 19 on a continuous basis in a manner and with instrumentation acceptable to the AQD. The continuous emission monitoring system (CEMS) shall be installed, calibrated, maintained, and operated in accordance with the procedures set forth in 40 CFR 60.13 and and Performance Specification (PS) 2 of Appendix B, 40 CFR Part 60 for SO 2 and NO x and Performance Specification (PS) 4, 4A or 4B , of A ppendix B, 40 CFR Part 60 for CO. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 2 (40 CFR 60.13, R 336.2150, R 336.1213(3))

2. For EU-Kiln 19, the Permitt ee shall keep records of the SO 2 , NO x , and CO exhaust concentrations in parts per million by volume, corrected to 7% oxygen on a dry gas basis, both as one-minute averages and as 12 month rolling time period values as determined at the end of eac h calendar month. Concentrations shall be recorded consistent with the approved monitoring plan. 2 (40 CFR 52.21, R 336.1213(3))

3. The Permittee shall calculate and record the tons per calendar month and tons per year on a twelve month rolling average of SO 2 , NO x and CO using CEMS data. (R 336.1213(3))

4. The Permittee shall keep records of the information listed below for EU-Kiln 19. 1 (R 336.1901, R 336.1224, R 336.1225, R 336.1213(3))

a. Oxygen exhaust concentrati ons, as one-minute averagesROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 37 b. Estimated cement kiln dust (CKD) rec ycled, in tons, for each hour of operation

c. Estimated CKD wasted, in t ons for each hour of operation

d. Burn zone temperature, as one-minute averages

e. Kiln feed, in tons, for each hour of operation

f. The Permittee shall monitor and record the baghous e pressure drop as described in the preventative maintenance program for the baghouse.

5. Should the AQD determine the records to be inadequate, the District Supervisor may request modifications of the records to address those inadequacies. The Permitt ee may also propose changes to the records to the District Supervisor. Upon written approval of modified records by the District Supervisor, the Permittee shall implement and maintain the modified records. 2 (40 CFR 52.21, R 336.1213(3))

6. The Permittee shall record and maintain all preventat ive maintenance records associated with EU-Kiln 19 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursu ant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to G eneral Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. An excess emissions report (EER) and summary repor t shall be submitted in an acceptable format to the District Supervisor within 30 days following the end of each calendar quarter. The EER shall include each occurrence of all excursions and the magnitudes of the excess emissions of sulfur dioxide (SO 2 ) above 548 parts per million by volume (ppmv); of nitrogen oxides (NO x ) above 584 parts per million by volume (ppmv); of carbon monoxide (CO) above 170 parts per million by volume (ppmv). All concentrations shall be corrected to 7% oxygen on a dry gas basis and based on a 12 month rolling time period, as determined at the end of each calendar month. The EER shall include the magnitude, of each excursion greater than the permit limit and the time period represented by such averages. It shall also include the cause of the excess emission, if known, periods of CEMS downtime, any corrective action ta ken, and a total operating time of the source. If no exceedances or CEMS downtime occurred during the ti me period, the permittee shall report that fact. 2 (R 336.2170, 40 CFR 60.7(c)&(d))

5. The permittee shall perform the Qualit y Assurance Procedures of the CEMS for SO 2., NO x , and CO, as set forth in Appendix F of 40 CFR Part 60. Each quarter the result s shall be presented and submitted in the format of the data assessment report (D AR) along with the quarterly EER and summary reports. 2 (40 CFR, Part 60 Appendix F, R 336.1213(3))

6. Verification of emission rates of particulate, includes t he submittal of a complete report of the test results. The results shall be submitted to the District Supervisor, AQD within 60 days of the completion of the stack test. 2 (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))

7. A complete test plan for particulate shall be submitt ed to the AQD at least 30 days prior to testing and must receive approval from the AQD. (R 336.2003, R 336.2004)

See Appendix 8ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 38 VIII. STACK RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV25-289 156 2 220 2 R 336.1225, R 336.1901, 40 CFR 52.21

2. 

### SV25-672, SV25-673 145 2 R 336.1201(3)



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 39 

## EU-Kiln20 EMISSION UNIT CONDITIONS

DESCRIPTION: EU-Kiln 20, Kiln Dust Return System, (31-220), (31-291), (31-003), 31-006), (31-109), (31-110), (31-111), (31-007);)

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouse

I. EMISSION LIMITS

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Sulfur Dioxide (SO 2 ) 2,065 tons 2 Per 12- month rolling time period,

as determined at the end of each calendar

month EU-Kiln 20 Condition V.2 Condition VI.1 Condition VI.4 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

2. Nitrogen Oxides (NO x ) 1,513 tons 2 Per rolling 12-month time period,

as determined at the end of each calendar

month EU-Kiln 20 Condition V.2 Condition VI.1 Condition VI.4 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

3. Carbon Monoxide (CO) 280 tons 2 Per rolling 12-month time period,

as determined at the end of each calendar

month EU-Kiln 20 Condition V.2 Condition VI.1 Condition VI.4 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

4. Sulfur Dioxide (SO 2 ) 542 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 20 Condition V.2 Condition VI.3 Condition VI.5 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 40 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

5. Nitrogen Oxides (NO x ) 578 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 20 Condition V.2 Condition VI.2 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

6. Carbon Monoxide (CO) 168 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 20 Condition V.2 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

7. Particulate 0.25 pound per 1000 pounds of exhaust gases, calculated on a dry basis 2 Kiln 20 Condition V.1 R 336.1331, C.J. No. 93- 000651-CE, Paragraph IV.6

8. Particulate 0.10 pound per 1,000 pounds

of exhaust

gases, calculated on a dry basis 2 Kiln Dust Return System, (31-220), (31-291), (31-003), 31-006), (31-109), (31-110), (31-111), (31-007) Condition V.1 R 336.1331, C.J. No. 93- 000651-CE Paragraph IV.6

9. Hydrogen chloride (HCl) 65 parts per million by volume, combined emissions, as HCl equivalents, corrected to 7% oxygen 2 EU-Kiln 20 Condition V.3 Condition VI.4 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.7

10. Hydrogen chloride (HCl) 36 pounds 2 Per hour EU-Kiln 20 Condition V.3 Condition VI.4 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.7ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 41 II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. On or before May 31, 2007 verification of particulate emission rates from EU-Kiln 20 by testing at the owner’s expense shall be required. (R 336.1213(3), R 336.2001, R 336.2003, R 336.2004)

2. The permittee shall perform periodic verification of HCl and chlorine gas emissions from EU-Kiln 20 at the owner’s expense, in accordance with the AQD’s requirements and in accordance with the minimum requirements specified in Appendix 5. 1 (R 336.1213(3))

See Appendix 5



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall monitor and record the SO 2 , NO x , and CO from EU-Kiln 20 on a continuous basis in a manner and with instrumentation acceptable to the AQD. The continuous emission monitoring system (CEMS) shall be installed, calibrated, maintained, and operated in accordance with the procedures set forth in 40 CFR 60.13 and Performance Specification (P S) 2 of Appendix B, 40 CFR Part 60 for SO 2 and NO x and Performance Specification (PS) 4, 4A or 4B , of A ppendix B, 40 CFR Part 60 for CO. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 2 (40 CFR 60.13, R 336.2150, R 336.1213(3))

2. For EU-Kiln 20, the Permitt ee shall keep records of the SO 2 , NO x , and CO exhaust concentrations in parts per million by volume, corrected to 7% oxygen on a dry gas basis, both as one-minute averages and as 12 month rolling time period values as determined at the end of eac h calendar month. Concentrations shall be recorded consistent with the approved monitoring plan. 2 (40 CFR 52.21, R 336.1213(3))

3. The Permittee shall calculate and record the tons per calendar month and tons per year on a twelve month rolling average of SO 2 , NO x and CO using emission factors established by CEMS data. (R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 42 4. The Permittee shall keep records of the information listed below for EU-Kiln 20. 1 (R 336.1901, R 336.1224, R 336.1225, R 336.1213(3))

a. Oxygen exhaust concentrati ons, as one-minute averages

b. Estimated cement kiln dust (CKD) rec ycled, in tons, for each hour of operation

c. Estimated CKD wasted, in t ons for each hour of operation

d. Burn zone temperature, as one-minute averages

e. Kiln feed, in tons, for each hour of operation

f. The Permittee shall monitor and record the baghous e pressure drop as described in the preventative maintenance program for the baghouse.

5. Should the AQD determine the records to be inadequate, the District Supervisor may request modifications of the records to address those inadequacies. The Permitt ee may also propose changes to the records to the District Supervisor. Upon written approval of modified records by the District Supervisor, the Permittee shall implement and maintain the modified records. 2 (40 CFR 52.21, R 336.1213(3))

6. The Permittee shall record and maintain all preventat ive maintenance records associated with EU-Kiln 20 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1 Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2 Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3 Annual certification of compliance pursuant to Gene ral Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4 An excess emissions report (EER) and summary report shall be submitted in an acceptable format to the District Supervisor within 30 days following the end of each calendar quarter. The EER shall include each occurrence of all excursions and the magnitudes of the excess emissions of sulfur dioxide (SO 2 ) above 542 parts per million by volume (ppmv); of t he excess emissions of nitrogen oxides (NO x ) above 578 parts per million by volume (ppmv); of the excess emissions of carbon monoxide (CO) above 168 parts per million by volume (ppmv). All concentrations shall be corrected to 7% oxygen on a dry gas basis and based on a 12-month rolling time period, as determined at the end of each calendar month. The EER shall include the magnitude, of each excursion greater than the permit lim it and the time period represented by such averages. It shall also include the cause of the excess emission, if known, periods of CE MS downtime, any corrective action taken, and a total operating time of the sour ce. If no exceedances or CEMS downtime occurred during the time period, the permittee shall report that fact. 2 (40 CFR 60.7(c)&(d), R 336.2170)

5 The permittee shall perform the Quality Assurance Procedures of the CEMS for SO 2 , NO x and CO as set forth in Appendix F of 40 CFR Part 60. Each quarter the result s shall be presented and submitted in the format of the data assessment report (D AR) along with the quarterly EER and summary reports. 2 (40 CFR Part 60 Appendix F, R 336.1213(3))

6 A complete test plan for particulate, shall be submitt ed to the AQD at least 30 days prior to testing and must receive approval from the AQD. 2 (R 336.2003, R 336.2004)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 43 7 Verification of emission rates of particulate, includes the submittal of a complete report of the test results. The results shall be submitted to the District Supervisor, AQD within 60 days of the completion of the stack test. 2 (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))

See Appendix 8



### VIII. STACK RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV25-290 156 2 220 2 R 336.1225, R 336.1901, 40 CFR 52.21 2. SV25-672, SV25-673 145 2 R 336.1201(3)



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b)

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 44 

## EU-Kiln21 EMISSION UNIT CONDITIONS

DESCRIPTION: EU-Kiln21, Kiln Dust Return System, (31-220), (31-291), (31-003), 31-006), (31-109), (31-110), (31-111), (31-007)

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMITS

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Sulfur Dioxide (SO 2 ) 2,056 tons 2 Per 12- month rolling time period,

as determined at the end of each calendar

month EU-Kiln 21 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

2. Nitrogen Oxides (NO x ) 1,506 tons 2 Per 12- month rolling time period,

as determined at the end of each calendar

month EU-Kiln 21 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

3. Carbon Monoxide (CO) 279 tons 2 Per 12- month rolling time period,

as determined at the end of each calendar

month EU-Kiln 21 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21. C.J. No. 93- 000651-CE Paragraph IV.6

4. Sulfur Dioxide (SO 2 ) 539 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 21 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 45 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

5. Nitrogen Oxides (NO x ) 575 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 21 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

6. Carbon Monoxide (CO) 167 ppmv corrected to 7% oxygen on a dry basis 2 Per 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 21 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

7. Particulate 0.25 pound per 1000 pounds of exhaust gases, calculated on a dry basis 2 Kiln 21 Condition V.1 R 336.1331, C.J. No. 93-000651- CE Paragraph IV.6

8. Particulate 0.10 pound per 1,000 pounds

of exhaust

gases, calculated on a dry basis 2 Kiln Dust Return System, (31-220), (31-291), (31-003), 31-006), (31-109), (31-110), (31-111), (31-007) Condition V.1 R 336.1331, C.J. No. 93-000651- CE Paragraph IV.6

9. Hydrogen chloride (HCl) 65 parts per million by volume, combined emissions, as HCl equivalents, corrected to 7% oxygen 1 EU-Kiln 21 Condition V.3 ConditionVI.4 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.7

10. Hydrogen chloride (HCl) 36 pounds 1 Per hour EU-Kiln 21 Condition V.3 ConditionVI.4 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.7ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 46 II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. On or before May 31, 2007 verification of particulate emission rates from EU-Kiln 21 by testing at the owner’s expense, shall be required. (R 336.1213(3), R 336.2001, R 336.2003, R 336.2004)

2. The permittee shall perform periodic verification of HCl and chlorine gas emissions from EU-Kiln 21 at the owner’s expense, in accordance with the AQD’s requirements and in accordance with the minimum requirements specified in Appendix 5. 1 (R 336.1213(3)

See Appendix 5



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall monitor and record the SO 2 , NO x , and CO from EU-Kiln 21 on a continuous basis in a manner and with instrumentation acceptable to the AQD. The continuous emission monitoring system (CEMS) shall be installed, calibrated, maintained, and operated in accordance with the procedures set forth in 40 CFR 60.13 and Performance Specification (P S) 2 of Appendix B, 40 CFR Part 60 for SO 2 and NO x and Performance Specification (PS) 4, 4A or 4B , of A ppendix B, 40 CFR Part 60 for CO. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 2 (40 CFR 60.13, R 336.2150, R 336.1213(3))

2. For EU-Kiln 21, the Permitt ee shall keep records of the SO 2 , NO x , and CO exhaust concentrations in parts per million by volume, corrected to 7% oxygen on a dry gas basis, both as one-minute averages and as 12 month rolling time period values as determined at the end of eac h calendar month. Concentrations shall be recorded consistent with the approved monitoring plan. 2 (40 CFR 52.21, R 336.1213(3))

3. The Permittee shall calculate and record emissions of SO 2 , NO x , and CO in tons per calendar month and tons per year on a twelve month rolling average usi ng emission factors established CEMS data. (R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 47 4. The Permittee shall keep records of the information listed below for EU-Kiln 21. 1 (R 336.1901, R 336.1224, R 336.1225, R 336.1213(3))

a. Oxygen exhaust concentrati ons, as one-minute averages

b. Estimated cement kiln dust (CKD) rec ycled, in tons, for each hour of operation

c. Estimated CKD wasted, in t ons for each hour of operation

d. Burn zone temperature, as one-minute averages

e. Kiln feed, in tons, for each hour of operation

f. The Permittee shall monitor and record the baghouse pressure drop as described in the preventative maintenance program for the baghouse.

5. Should the AQD determine the records to be inadequate, the District Supervisor may request modifications of the records to address those inadequacies. The Permitt ee may also propose changes to the records to the District Supervisor. Upon written approval of modified records by the District Supervisor, the Permittee shall implement and maintain the modified records. 2 (40 CFR 52.21, R 336.1213(3))

6. The Permittee shall record and maintain all preventat ive maintenance records associated with EU-Kiln 21 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1 Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2 Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3 Annual certification of compliance pursuant to Gene ral Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4 An excess emissions report (EER) and summary report shall be submitted in an acceptable format to the District Supervisor within 30 days following the end of each calendar quarter. The EER shall include each occurrence of all excursions and the magnitudes of the excess emissions of sulfur dioxide (SO 2 ) above 539 parts per million by volume (ppmv); of t he excess emissions of nitrogen oxides (NO x ) above 575 parts per million by volume (ppmv); of the excess emissions of carbon monoxide (CO) above 167 parts per million by volume (ppmv). All concentrations shall be corrected to 7% oxygen on a dry gas basis and based on a 12-month rolling time period, as determined at the end of each calendar month. The EER shall include the magnitude, of each excursion greater than the permit lim it and the time period represented by such averages. It shall also include the cause of the excess emission, if known, periods of CE MS downtime, any corrective action taken, and a total operating time of the sour ce. If no exceedances or CEMS downtime occurred during the time period, the permittee shall report that fact. 2 (40 CFR 60.7(c)&(d), R 336.2170)

5 The permittee shall perform the Quality Assurance Procedures of the CEMS for SO 2 , NO x and CO as set forth in Appendix F of 40 CFR Part 60. Each quarter the result s shall be presented and submitted in the format of the data assessment report (D AR) along with the quarterly EER and summary reports. 2 (40 CFR Part 60 Appendix F, R 336.1213(3))

6 A complete test plan for particulate shall be submitt ed to the AQD at least 30 days prior to testing and must receive approval from the AQD. (R 336.2003, R 336.2004)

7 Verification of emission rates of particulate includes the submittal of a complete report of the test results. The results shall be submitted to the District Supervisor, AQD within 60 days of the completion of the stack test. 2 (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 48 See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV25-291 156 2 220 2 R 336.1225, R 336.1901, 40 CFR 52.21 2. SV25-672, SV25-673 145 2 R 336.1201(3)



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 49 

## EU-Kiln22 EMISSION UNIT CONDITIONS

DESCRIPTION: EU-Kiln 22, Kiln 22 Dust Return System (32-173)

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMITS

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Sulfur Dioxide (SO 2 ) 9,685 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 22 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

2. Nitrogen Oxides (NO x ) 3,930 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 22 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

3. Carbon Monoxide (CO) 537 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 22 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

4. Sulfur Dioxide (SO 2 ) 1,611 ppmv corrected to 7% oxygen on a dry basis 2 12- month rolling time period values, as determined at the end of each calendar

month EU-Kiln 22 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 50 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

5. Nitrogen Oxides (NO x ) 952 ppmv corrected to 7% oxygen on a dry basis 2 12-month rolling time period values, as determined at the end of each calendar

month EU-Kiln 22 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

6. Carbon Monoxide (CO) 204 ppmv corrected to 7% oxygen on a dry basis 2 12-month rolling time period values, as determined at the end of each calendar

month EU-Kiln 22 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

7. Particulate 0.10 pound per 1,000 pounds

of exhaust

gases, calculated on a dry basis 2 EU-Kiln 22, Kiln Feed Reclaim System (32-115), (32-116), (32-117), (32-171), (32-172), (32-173), Condition V.1 R 336.1331, C.J. No. 93-000651- CE Paragraph IV.6

8. Hydrogen chloride 170 parts per million by volume, combined emissions, as HCl equivalents, corrected to 7% oxygen on a dry basis 1 EU-Kiln 22 Condition V.3 Condition VI.5 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.7

9. Hydrogen chloride 162 pounds 1 Per hour EU-Kiln 22 Condition V.3 Condition VI.5 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.7 10. Chromium 8.6 ug/m 3

corrected to 70oF and 29.92 inches Hg 1 EU-Kiln 22 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6 11. Chromium 0.0058 pound 1 Per hour EU-Kiln 22 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6 12. Cadmium 112 ug\m 3

corrected to 70oF and 29.92 inches Hg 1 EU-Kiln 22 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 51 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

13. Cadmium 0.0758 pound 1 Per hour EU-Kiln 22 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. On or before May 31, 2007, verification of particulate em ission rates from EU-Kiln 22, by testing, at the owner’s expense shall be required. (R 336.1213(3), R 336.2001, R 336.2003)

2. The permittee shall perform periodic verification of HCl and chlorine gas emissions from EU-Kiln 22, at the owner’s expense, in accordance with the AQD’s requirements and in accordance with the minimum requirements specified in Appendix 5. 1 (R 336.1213(3), R 336.2001, R 336.2003)

3. Verification of chromium and cadmium emission rates from EU-Kiln 22 by testing at the owner’s expense, may be required. (R 336.1224, R 336.1225, R 336.1901, R 336.1213(3))

See Appendix 5



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1 The Permittee shall monitor and record the SO 2 , NO x , and CO emissions from each kiln on a continuous basis in a manner and with instrumentation acceptable to t he AQD. The continuous emission monitoring system (CEMS) shall be installed, calibrated, maintained, and op erated in accordance with the procedures set forth in 40 CFR 60.13 and Performance Specification (PS) 2 of Appendix B, 40 CFR Part 60 for SO 2 and NO x and Performance Specification (PS) 4, 4A or 4B , of Appendix B, 40 CFR Part 60 for CO. The span value shall be 2.0 times the lowest emissi on standard or as specified in the federal regulations. 2 (R 336.2150, 40 CFR 60.13, R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 52 2 For EU-Kiln 22, the Permittee shall keep records of the SO 2 , NO x , and CO exhaust concentrations in parts per million by volume, corrected to 7% oxygen on a dry gas basis, both as one-minute averages and as 12 month rolling time period values as determined at the end of eac h calendar month. Concentrations shall be recorded consistent with the approved monitoring plan. 2 (40 CFR 52.21, R 336.1213(3))

3 The Permittee shall calculate and record emissions of SO 2 , NO x , and CO in tons per calendar month and tons per year on a twelve month rolling average using emission factors established by CEMS data. (R 336.1213(3))

4 The Permittee shall keep records of the information listed below for EU-Kiln 22. 1 (R 336.1901, R 336.1224, R 336.1225, R 336.1213(3))

a Oxygen exhaust concentrations , as one-minute averages.

b Opacity in the stack consistent with the approved monitoring plan

c Estimated cement kiln dust (CKD) recycl ed, in tons, for each hour of operation.

d Estimated CKD wasted, in tons for each hour of operation.

e Burning zone temperature, as one-minute averages.

f Baghouse inlet temperature, as one-minute averages.

g Baghouse pressure drop.

h Kiln feed, in tons, for each hour of operation.

5 Should the AQD determine the records to be inadequate, the District Supervisor may request modifications of the records to address those inadequacies. The Permitt ee may also propose changes to the records to the District Supervisor. Upon written approval of modified records by the District Supervisor, the Permittee shall implement and maintain the modified records. 2 (40 CFR 52.21, R 336.1213(3))

6 The Permittee shall record and maintain all preventative maintenance records associated with EU-Kiln22 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to Special Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to Special Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Specia l Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. An excess emissions report (EER) and summary report shall be submitted in an acceptable format to the District Supervisor within 30 days following the end of each calendar quarter. The EER shall include each occurrence of all excursions and the magnitudes of the excess emissions of sulfur dioxide (SO 2 ) above 1,611 parts per million by volume ( ppmv); of nitrogen oxides (NO x ) above 952 parts per million by volume (ppmv); and of the excess emissions of carbon monoxide (CO) ab ove 204 parts per million by volume (ppmv). All concentrations shall be corrected to 7% oxygen on a dry gas basis and based on a 12-month rolling time period, as determined at the end of each calendar month. The EER shall also include the cause of the excess emissions, if known; periods of CEMS downtime; any corrective action taken; and the total operating time of the source. If no exceedances or CEMS downtime occurred du ring the reporting period, the permittee shall report that fact. 2 (40 CFR 60.7(c)&(d), R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 53 5. The permittee shall perform the Qualit y Assurance Procedures of the CEMS for SO 2 , NO x , and CO as set forth in Appendix F of 40 CFR Part 60. Each quarter the result s shall be presented and submitted in the format of the data assessment report (D AR) along with the quarterly EER and summary reports. 2 (40 CFR Part 60 Appendix F, R 336.1213(3))

6. A complete test plan for particulate, cadmium and ch romium shall be submitted to the AQD at least 30 days prior to testing and must receive approval from the AQD. (R 336.2003, R 336.2004, R 336.1213(3))

7. Verification of emission rates of particulate, cadmiu m and chromium includes the submittal of a complete report of the test results. The results shall be submitted to the District Supervisor, AQD within 60 days of the completion of the stack test. 2 (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV26-292 288 2 292 2 R 336.1225, 40 CFR 52.21, R 336.1901



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1))a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 54 

## EU-Kiln23 EMISSION UNIT CONDITIONS

DESCRIPTION: EU-Kiln23, Kiln 23 Dust Return System (32-173)

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMITS

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Sulfur Dioxide (SO 2 ) 9,728 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 23 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE, Paragraph IV.6

2. Nitrogen Oxides (NO x ) 3,947 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 23 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

3. Carbon Monoxide (CO) 539 tons 2 12-month rolling time period, as determined at the end of each calendar

month EU-Kiln 23 Condition V.2 Condition VI.1 Condition VI.3 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

4. Sulfur Dioxide (SO 2 ) 1,813 ppmv corrected to 7% oxygen on a dry basis 2 12-month rolling time period values, as determined at the end of each calendar

month EU-Kiln 23 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 55 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

5. Nitrogen Oxides (NO x ) 1,071 ppmv corrected to 7% oxygen on a dry basis 2 12-month rolling time period values, as determined at the end of each calendar

month EU-Kiln 23 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

6. Carbon Monoxide (CO) 230 ppmv corrected to 7% oxygen on a dry basis 2 12-month rolling time period values, as determined at the end of each calendar

month EU-Kiln 23 Condition V.2 Condition VI.1 Condition VI.2 40 CFR 52.21, C.J. No. 93- 000651-CE Paragraph IV.6

7. Particulate 0.10 pound per 1,000 pounds

of exhaust

gases, calculated on a dry basis 2 EU-Kiln 23 Kiln Feed Reclaim System (32-115), (32-116), (32-117), (32-171), (32-172), (32-173) Condition V.1 R 336.1331, C.J. No. 93-000651- CE Paragraph IV.6

8. Hydrogen chloride 170 parts per million by volume, combined emissions, as HCl equivalents, corrected to 7% oxygen 1 EU-Kiln 23 Condition V.3 Condition VI.5 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6

9. Hydrogen chloride 162 pounds 1 Per hour EU-Kiln 23 Condition V.3 Condition VI.5 R 336.1224, R 336.1225, R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6 10. Chromium 8.6 ug/m 3

corrected to 70oF and 29.92 inches Hg 1 EU-Kiln 23 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6 11. Chromium 0.0058 pound 1 Per hour EU-Kiln 23 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6 12. Cadmium 112 ug\m 3

corrected to 70oF and 29.92 inches Hg 1 EU-Kiln 23 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 56 Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

13. Cadmium 0.0758 pound 1 Per hour EU-Kiln 23 Condition V.4 R 336.1901, C.J. No. 93-000651- CE Paragraph IV.6



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1 The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement an d maintain the modified operation and maintenance plan



### . (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. On or before May 31, 2007, verification of particulate emission rates from EU-Kiln 23 by testing at the owner’s expense shall be required. (R 336.1313(3), R 336.2001, R 336.2003, R 336.2004)

2. The permittee shall perform periodic verification of HCl and chlorine gas emissions from EU-Kiln 23, at the owner’s expense, in accordance with the AQD’s requirements and in accordance with the minimum requirements specified in Appendix 5. 1 (R 336.1313(3), R 336.2001, R 336.2003)

3. Verification of chromium and cadmium emission rates from each kiln by testing at the owner’s expense may be required. (R 336.1313(3), R 336.2001, R 336.2003)

See Appendix 5



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1 The Permittee shall monitor and record the SO 2 , NO x , and CO emissions from EU-Kiln 23 on a continuous basis in a manner and with instrumentation acceptable to the AQD. The continuous emission monitoring system (CEMS) shall be installed, calibrated, maintai ned, and operated in accordance with the procedures set forth in 40 CFR 60.13 and Performance Specification (PS) 2 of Appendix B, 40 CFR Part 60 for SO 2 and NO x and Performance Specification (PS) 4, 4A or 4B , of Appendix B, 40 CFR Part 60 for CO. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 2 (R 336.2150, R 336.1213(3), 40 CFR 60.13)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 57 2 For EU-Kiln 23, the Permittee shall keep records of the SO 2 , NO x , and CO exhaust concentrations in parts per million by volume, corrected to 7% oxygen on a dry gas basis, both as one-minute averages and as 12 month rolling time period values as determined at the end of eac h calendar month. Concentrations shall be recorded consistent with the approved monitoring plan. 2 (40 CFR 52.21, R 336.1213(3))

3 The Permittee shall calculate and record emissions of SO 2 , NO x , and CO in tons per calendar month and tons per year on a twelve month rolling average using emission factors established by CEMS data. (R 336.1213(3))

4 The Permittee shall keep records of the information listed below for EU-Kiln 23. 1 (R 336.1901, R 336.1224, R 336.1225, R 336.1213(3))

a Oxygen exhaust concentrations , as one-minute averages.

b Opacity in the stack consistent with the approved monitoring plan

c Estimated cement kiln dust (CKD) recycl ed, in tons, for each hour of operation.

d Estimated CKD wasted, in tons for each hour of operation.

e Burning zone temperature, as one-minute averages.

f Baghouse inlet temperature, as one-minute averages.

g Baghouse pressure drop.

h Kiln feed, in tons, for each hour of operation.

5 Should the AQD determine the records to be inadequate, the District Supervisor may request modifications of the records to address those inadequacies. The Permitt ee may also propose changes to the records to the District Supervisor. Upon written approval of modified records by the District Supervisor, the Permittee shall implement and maintain the modified records. (40 CFR 52.21, R 336.1213(3))

6 The Permittee shall record and maintain all preventative maintenance records associated with EU-Kiln 23 for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1 Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2 Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3 Annual certification of compliance pursuant to Gene ral Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4 An excess emissions report (EER) and summary report shall be submitted in an acceptable format to the District Supervisor within 30 days following the end of each calendar quarter. The EER shall include each occurrence of all excursions and the magnitudes of the excess emissions of sulfur dioxide (SO 2 ) above 1,813 parts per million by volume ( ppmv); of nitrogen oxides (NO x ) above 1,071 parts per million by volume (ppmv); and of the excess emissions of carbon monoxide (CO) above 230 parts per million by volume (ppmv). All concentrations shall be corrected to 7% oxygen on a dry gas basis and based on a 12-month rolling time period, as determined at the end of each calendar mont h. The EER shall include the cause of the excess emissions, if known; periods of moni tor downtime; any corrective action ta ken; and the total operating time of the sources. If no exceedances or CEMS downtime occu rred during the reporting period, the permittee shall report that fact. 2 (40 CFR 60.7(c)&(d), R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 58 5 The permittee shall perform the Quality Assurance Procedures of the CEMS for SO 2 , NO x , and CO as set forth in Appendix F of 40 CFR Part 60. Each quarter the result s shall be presented and submitted in the format of the data assessment report (DAR ) along with the quarterly EER and summary reports. (40 CFR Part 60 Appendix F, R 336.1213(3))

6 A complete test plan for particulate, cadmium and ch romium shall be submitted to the AQD at least 30 days prior to testing and must receive approval from the AQD. (R 336.2003, R 336.2004, R 336.1213(3))

7 Verification of emission rates of particulate, cadmium and chromium includes the submittal of a complete report of the test results. The results shall be submitted to the District Supervisor, AQD within 60 days of the completion of the stack test. 2 (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV26-292 288 2 292 2 R 336.1225, 40 CFR 52.21, R 336.1901



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 59 

## EU-CKD System EMISSION UNIT CONDITIONS

DESCRIPTION: Cement Kiln Dust System, (33-116), (33-200), (33-230), (33-250), (33-250), (33-251), (33-252), (33-208), (33-212), (33-305), (33-339), (33-340), (33-310)

Flexible Group ID: NA



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Particulate 0.10 pound per 1,000 pounds exhaust, on a

dry basis 2 EU-CKD System Condition V.1 Condition V.2 R 336.1331, R 336.1901, C.J. No. 93-000651- CE, Paragraph IV.6 2. Opacity 20% 6-minute average EU-CKD System Condition V.2 R 336.1901, R 336.1301(1) (c), C.J. No. 93- 000651-CE Paragraph IV.6



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NAROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 60 V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of particulate matter emissions from EU -CKD System by testing, at the owner’s expense, in accordance with Department requirements, may be required. (R 336.2001, R 336.2004, R 336.1213(3))



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall record and maintain all preventati ve maintenance records associated with EU-CKD System for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b)

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 61 

## EU-Clinker System EMISSION UNIT CONDITIONS

DESCRIPTION: Clinker Handling and Storage System

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1 Particulate 0.02 Grains, per dry standard cubic foot 2 Conveyors (25-211), (25-212), (26-213), (26-215),(40-020), (41-175), (41-176), (41-421) (41-423) and Clinker Storage Silos (ST-1), (St-2) and Clinker Storage Building (ALP309B102) Condition V.1 Condition V1.1 R 336.1331, C.J. No. 93-000651- CE Paragraph IV.6

2 Particulate 0.10 pound, per 1,000 pounds

of exhaust gases, on a dry basis EU- Clinker System Condition V.1 Condition V1.1 R 336.1331, C.J. No. 93-000651- CE Paragraph IV.6



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

1. NAROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 62 V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of particulate matter emissions from EU-Clinker System by te sting, at the owner’s expense, in accordance with Department requirements, may be required. (R 336.2001, R 336.2004, R 336.1213(3))



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall record and maintain all preventa tive maintenance records associated with EU-Clinker System for a period of not less than five years a nd shall be made available to the AQD upon request. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust cross

section area (square inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV25-506 215 2 27.5 2 R 336.1201(3)

2. SV25-825 437 2 21.3 2 (not vertically discharged) R 336.1201(3)

3. SV26-825 437 2 55.3 2 (not vertically discharged) R 336.1201(3)

4. SV40-100 559 2 54.0 2 (not vertically discharged) R 336.1201(3)

5. SV40-110 346 2 121.0 2 (not vertically discharged) R 336.1201(3)

6. SV40-120 2,500 2 63.0 2 (not vertically discharged) R 336.1201(3)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 63 IX. OTHER REQUIREMENT(S)

1. Clinker may be stored outside with approval of the Di strict Supervisor. The permittee shall submit a plan detailing the following: where the clinker will be stored; how it will be loaded, transported and unloaded; the amount of clinker to be stored outside; dust suppression measures; anticipat ed duration of the outside storage; and other relevant information as requir ed by the District Supervisor. The pl an shall be submitted to the District Supervisor, for approval, at least 30 days prior to storing clinker outside 2

. (R 336.1301, R 336.1901, R 336.1910)

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 64 

## EU-Finish Mill System EMISSION UNIT CONDITIONS

DESCRIPTION: EU-Finish Mills 13-16, 19, 20, and 21, Roller Press Feed Bins, Bucket Elevators and Roller Presses

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Particulate 0.03 pound, per 1,000 pounds

of exhaust gases, on a dry gas basis 2 EU-Finish Mill System Condition V.1 Condition V.2 R 336.1201(3)

2. Particulate 62.6 pounds 2 Per hour EU-Finish Mill System Condition V.1 Condition V.2 R 336.1201(3)

3. Particulate 0.15 pound per 1,000 pounds

of exhaust gases, on a dry gas basis 2 Finish Mill 20 Finish Mill 21 Condition V.1 Condition V.2 R 336.1331

4. Particulate 0.07 pounds 2 Per hour Finish Mill 20 Finish Mill 21 Condition V.1 Condition V.2 R 336.1201(3)

5. Opacity 5% 2 * 6-minute averages EU-Finish Mill System Condition V.2 Condition VI.1 R 336.1201(3)

* Compliance with this limit shall be considered compliance with the following applicable requirement which have been subsumed under this streamlined requirement: 40 CFR Part 60 Subpart F, 40 CFR 63.1342 Table 1



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NAROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 65 III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of particulate emissions from EU-Finis h Mill System by testing, at the owner’s expense, in accordance with Department r equirements, may be required. (R 336.2001, R 336.2002, R 336.2004, R 336.1213(3))



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall record and maintain all preventat ive maintenance records associated with EU-Finishing Mill System for a period of not less than five years and shall be made available to the AQD upon request (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NAROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 66 IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b)

2 This condition is federally established and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 67 

## EU-Cement Storage and Bulk Loading EMISSION UNIT CONDITIONS

DESCRIPTION: Bulk Cement Loading; Truck, Rail Car and Ship Loading

Flexible Group ID: FG-PCMACT



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Particulate 0.03 pound per 1,000 pounds

of exhaust gases, on a dry basis 2 Cement Bulk Loading, Storage #4 Condition V.1 R 336.1201(3)

2. Particulate 0.65 Pounds 2 Per hour Cement Bulk Loading, Storage #4 Condition V.1 R 336.1201(3)

3. Particulate 0.10 pound per 1,000 pounds

of exhaust gases, on a dry basis 2 Truck and Rail Car Loading (46-673) Condition V.1 R 336.1201(3)

4. Particulate 2.33 pounds Per hour Truck and Rail Car Loading (46-673) Condition V.1 R 336.1201(3)

5. Particulate 2.4 tons Per year Truck and Rail Car Loading (46-673) Condition V.1 R 336.1201(3)

6. Opacity 0% 2 * Truck and Rail Car Loading (46-673) Condition V.2 R 336.1301(1)(c)

7. Particulate 0.05 pounds per 1,000 pounds of exhaust gases, on a dry basis Old Boat End Silos and Transfer

Equipment Condition V.1 R 336.1201(3)

8. Particulate 0.15 pounds per 1,000 pounds of exhaust gases, on a dry basis Cement Boat Loading Condition V.1 R 336.1331

*Compliance with this limit shall be considered compliance with the following applicable requirement which have been subsumed under this streamlined requirement: 40 CFR Part 60 Subpart F, 40 CFR 63.1342 Table 1ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 68 II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. The Permittee shall record and maintain all preventati ve maintenance records associated with EU-Cement Storage and Bulk Loading for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The Permittee shall equip and maintain the fabric filter dust collector for storage #4 with continuous differential pressure measurement device. 2 (R 336.1910)



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of particulate emissi on rates from EU-Cement Bulk Loading by testing, at the owner’s expense, in accordance with Department r equirements, may be required. (R 336.2001, R 336.2002, R 336.2004, R 336.1213(3))

2. The Permittee shall conduct monthly Method 22 visible emission readings for 6 minutes. If visible emissions are observed, method 9 visible emission readings shall be conducted. (R 336.1213(3))

3. If after six months of monthly Method 22 visible emission readings, no visible emissions have been observed, the Method 22 readings shall decrease to semi-annually. (R 336.1213(3))

4. If after two semi-annual Method 22 visible emission readings, no visible emissions have been observed, the Method 22 readings shall decrease to annually. (R 336.1213(3))

5. If any Method 9 visible emission reading exceeds 20%, the permittee shall, within one hour, implement the malfunction abatement plan requi red in Condition III.1, above. (R 336.1213(3))



### VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Records of all Method 9 visible emission readings shall be kept on file and made available to the AQD upon request. (R 336.1213(3))

2. The Permittee shall monitor and record the differential pressure on storage #4 daily. (R 336.213(3)ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 69 VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 70 

## D. FLEXIBLE GROUP CONDITIONS

Part D outlines terms and conditions that apply to more than one emission unit. The permittee is subject to the Special Conditions for each flexible group in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the Special Conditions and the underlying applicable requirements cited. If a specific condition type does not appl y, NA (not applicable) has been used in the table. If there are no Special Conditions that apply to more than one emission unit, this section will be left blank.



### FLEXIBLE GROUP SUMMARY TABLE The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Flexible Group ID Flexible Group Description Associated Emission Unit IDs FG-PC-MACT Equipment subject to Portland Cement MACT EU-Kilns 19, 20, 21, 22, 23 and EU-CC19, EU-CC20, EU-CC21, EU-CC22, EU-CC23 (clinker coolers); EU-Raw Mills (14 and 15); raw mills #14 and #15; Kilns 19,20,21,22,23 and associated clinker coolers; finish mill system; finished product storage; conveyor transfer points, bagging and bulk loading and unloading systems EU-Finish Mill System. FG-KG5CC Clinker coolers number 19, 20 and 21 subject to particulate limits. EU-CC19, EU-CC20, EU-CC21 FG-NO x Kilns subject to Part 8 Rules. EU-Kiln 22, EU-Kiln 23ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 71 

## FG-PCMACT FLEXIBLE GROUP CONDITIONS

DESCRIPTION: Equipment subject to the Portland Cement MACT, 40 CFR Part 63 Subparts A & LLL

Emission Units: Secondary Crusher Stone Piles; EU-Raw Mill System; EU-ARM (part); EU

- Kiln 19, EU

- Kiln 20, EU

- Kiln 21, EU

- Kiln 22, EU

- Kiln 23; EU-CC19, EU-CC20, EU-CC21, EU -CC22, EU-CC23; EU-Finish Mill System; EU-Clinker System; EU-Bulk Cement Storage and Loading



### .

POLLUTION CONTROL EQUIPMENT: Baghouses – 20-268, 20-269, 20-270, 20-271, 21-268, 21-269, 21-270, 21-271, 43-269, 43-270, 43-271, 43-272, 44-269, 44-270, 44-271, 44-272, 45-261, 45-262, 45-264, 49-269, 49-270.

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements1. Polychlorinated dibenzop-dioxins and dibenzofurans 0.20 ng TEQ/dscm @ EU-Kiln19, EU-Kiln20, EU-Kiln21, EUKiln22, EU-Kiln 23 Condition V.1 Condition VI.3 Condition VI.4 Condition VI.5 Condition VI.6 Condition VI.7 40 CFR 63.1343(3)

2. Polychlorinated dibenzop-dioxins and dibenzofurans 0.40 ng TEQ/dscm # EU-Kiln19, EU-Kiln20, EU-Kiln21, EUKiln22, EU-Kiln 23 Condition V.1 Condition VI.3 Condition VI.4 Condition VI.5 Condition VI.6 Condition VI.7 40 CFR 63.1343(3)

3. Opacity 20% 2 EU-Kiln19, EU-Kiln20, EU-Kiln21, EUKiln22, EU-Kiln23 Condition VI.2 40 CFR 63.1343(b)(2),

R 336.1301 4. Opacity 10% 2 * EU-CC19, EU-CC20, EU-CC21, EU-CC22, EU-CC23 Condition VI.2 40 CFR 63.1345(a)(2),

R 336.1301 5. Opacity 10% 2 * EU-Raw Mill System; EU-Clinker Handling System; EU-Finish

Mill System; EUBulk Loading System Condition VI.2 40 CFR 63.1350(e), R 335.1301

6. Particulate 0.30 lb. per ton of feed (dry basis) to kilns 2 EU-Kiln19, EU-Kiln20, EU-Kiln21, EUKiln 22, EU-Kiln 23, Condition V.2 40 CFR 63.1343(b)(1)

7. Particulate 0.10 lb. per ton of feed (dry basis) to kilns 2 EU-CC19, EU-CC20, EU-CC21, EU-CC22, EU-CC23 Condition V.2 40 CFR 63.1345(a)(1)

@ Units are nanograms Toxic Equivalent (TEQ) per dry standard cubic meter (dsm) of exhaust gas at 7% O 2 . This limit is applicable when the exhaust gas temperature to the fabric filter co llector is greater than 400o Fahrenheit.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 72 # Units are nanograms Toxic Equivalent (TEQ) per dry standard cubic meter (dsm) of exhaust gas at 7% O 2 . This limit is applicable when the exhaust gas temperature to the fabric filter collector is less than or equal to 400o Fahrenheit.

* Compliance with this limit shall be considered compliance with the following applicable requirements which have been subsumed under this streamlined requirement: 40 CFR Part 60, Subpart F



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

1. The permittee shall develop, implement and maintain an operations and maintenance plan. Should the AQD determine the operation and maintenance plan to be i nadequate, the District Supervisor may request modification of the program to address those inadequaci es. The Permittee may also propose changes to the program to the District Supervisor. Upon written appr oval of a modified operation and maintenance plan by the District Supervisor, the Permittee shall implement and maintain the modified operation and maintenance plan. The Permittee shall record and maintain all preventati ve maintenance records associated with; EU-Kiln19, EU-Kiln 20, EU-Kiln21, EU-Kiln22, EU -Kiln 23 EU-CC19, EU-CC20, EU-CC 21, EU-CC22, EU-CC23; EU-Raw Mill System; EU-Clinker Handling System; EU-Finish Mill Sy stem; EU- Bulk Loading System for a period of not less than five years and shall be made available to the AQD upon request. (R 336.1213(3))



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of dioxin and furan emission rates from EU -Kiln 19, EU-Kiln 20, EU-Kiln 21, EU-Kiln 22, EU-Kiln 23, by testing at the owner’s expense, shall be required within 30 months of the initia l testing required under 40 CFR 63.1349 and every 30 months thereafter. (40 CFR 63.1349(d))

2. On or before May 31, 2007, verification of particulate emission rates from EU-Kiln 19, EU-Kiln 20, EU-Kiln 21, EU-Kiln 22, EU-Kiln 23, and EU-CC19, EU-CC20, EU-CC21, EU-CC22, and EU -CC23 by testing at the owner’s expense, shall be required. (R 336.1313(3), R 336.2001, R 336.2003, 40 CFR 63.1349(b)(1))

3. The Permittee shall conduct monthly Method 22 visible em ission readings for 1 minute. If visible emissions are observed, method 9 visible emission readings shall be conducted. (R 336.1213(3))

4. If after six months of monthly Method 22 visible emission readings, no visible emissions have been observed, the Method 22 readings shall decrease to semi-annually. (R 336.1213(3) 40 CFR 63.1351(a)(4)(ii))

5. If after two semi-annual Method 22 visible emission readings, no visible emissions have been observed, the Method 22 readings shall decrease to annually. (R 336.1213(3) 40CFR 63.135 0(a)(4)(iii))

6. If any Method 9 visible emission reading exceeds the opacity limits specified in Conditions I.3, I.4, and I.5 above, the permittee shall, within one hour, impl ement the operation and maintenance plan required in Condition III.1, above. (R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 73 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall monitor and record the visible emi ssions from Eu-Kiln 19, EU K iln 20, EU-Kiln 21, EU-Kiln 22, EU-Kiln 23, EU-CC19, EU-CC20, EU-CC21, EU-CC22, and EU-CC23 on a continuous basis in a manner and with instrumentation acceptable to the AQD. The c ontinuous opacity monitoring system (COMS) shall be installed, calibrated, maintained, and operated in acco rdance with the procedures set forth in 40 CFR 60.13 and Performance Specification 1 (PS 1) of Appendix B, 40 CFR Part 60. The span value shall be 2.0 times the lowest emission standard or as spec ified in the federal regulations. (R 336.2150, R 336.1213(3), 40 CFR Part 63 Subparts A & LLL)

2. Records of all Method 9 visible emission readings shall be kept on file and made available to the AQD upon request. (R 336.1213(3))

3. The Permittee shall install, calibrate, maintain and continuously operate a continuous monitor to record the temperature of the exhaust gases from Eu-Kiln 19, EU Kiln 20, EU-Kiln 21 , EU-Kiln 22, and EU-Kiln 23 . The recorder response range must include zero and 1.5 times either of the average temperatures established according to the requirements in § 63.1349(b)(3)(iv). T he reference method must be a National Institiute of Standards and Technology calibrated reference thermocoupl e-potentiometer or alternate reference, subject to approval by the epartment. (40 CFR 63.1350(f)(1))

4. The three-hour rolling average shall be calculated as the average of 180 successive one-minute average temperatures. (40 CFR 63.1350(f)(3))

5. Periods of time when one-minute averages are not av ailable shall be ignored when calculating three-hour rolling averages for Eu-Kiln 19, EU K iln 20, EU-Kiln 21, EU-Kiln 22, or EU -Kiln 23. When on e-minute averages become available, the first one-minute average is added to the previous 179 values to calculate the three-hour rolling average. (40 CFR 63.1350(f)(4))

6. The calibration of all thermocouples and other temperat ure sensors shall be verified at least once every three months. (40 CFR 63.1350(f)(6)

7. The permittee shall monitor emissions and operat ing and maintenance information for FG-PCMACT in accordance with the National Emission Standards for Ha zardous Air Pollutants as specified in 40 CFR Part 63 Subparts A and LLL. (R 336.1224, R 336.1225, 40 CFR Part 63 Subparts A & LLL)



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursu ant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to G eneral Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. In accordance with 40 CFR 63.10(e)(2), the permittee sha ll submit a written excess emission report (EER) in an acceptable format to the Di strict Supervisor within 30 days of the end reporting period as specified in VII.2 above. The EER shall include the magnitude, in actual percent opacity, of each six minute average of opacity greater than the permit limit and the time period represented by such averages. It shall also include the cause of the excess emission, if known, per iods of COMS downtime, any corrective action taken, and a total operating time of the sources. If no exceedances or COMS downti me occurred during the time period, the permittee shall report that fact.* (40 CFR 63.10(e)(2))

5. In accordance with 40 CFR 63.10, the permittee shall s ubmit a written summary report in an acceptable format to the District Supervisor within 30 days of the end reporting period. (40 CFR 63.10(b) (c) and (d))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 74 6. A complete test plan for particulate and dioxin/furans must be approved by the AQD prior to testing. (R 336.2001, R 336.2003 

### , R 336.2004, R 336.1213(3))

7. Verification of emission rates of particulate and dioxin/fu rans includes the submittal of a complete report of the test results. The results shall be s ubmitted to the District Supervisor, AQ D within 60 days of the completion of the stack test. (R 336.2001(4), R 336.2003, R 336.2004, R 336.1213(3))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV26-252 66 48.5 R 336.1224, R 336.1225, R 336.1201(3), R 336.1901, R 336.1313, 40 CFR Part 63 Subpart LLL 2. SV26-258 66 48.5 R 336.1224, R 336.1225, 336.1201(3), R 336.1901, R 336.1313, 40 CFR Part 63 Subpart LLL



### IX. OTHER REQUIREMENT(S)

1. The Permittee shall submit to the District Supervisor for approval, site specific operating, maintenance and corrective action plan for EU-Raw Mill System, EU-K iln19, EU-Kiln20, EU-Kiln21, EU-kiln23, EU-CC19, EU-CC20, EU-CC21, EU-CC 22, EU-CC23, EU-Finish Mill System, EU-Cement Bulk Loading System within 180 days of the issuance of this permit. (40 CFR 63.1350(a))

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 75 

## FG-KG5CC FLEXIBLE GROUP CONDITIONS

DESCRIPTION: Clinker coolers number 19, 20 and 21 subject to particulate limits

Emission Unit: EU-CC19, EU-CC20, EU-CC 21, (25-159), (25-160), (25-161)



### POLLUTION CONTROL EQUIPMENT : Baghouse (25-507)



### I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Particulate 0.04 pounds 2 Per 1,000 pounds of

exhaust gases, on a

dry gas

basis EU-CC19, EU-CC20, EU-CC21 Condition V.1 R 336.1201(3)

2. Particulate 24.8 pounds 2 Per hour EU-CC19, EU-CC20, EU-CC21 Condition V.1 R 336.1201(3)

3. Particulate 109.0 tons 2 Per year EU-CC19, EU-CC20, EU-CC21 Condition V.1 Condition VI.1 R 336.1201(3)



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

NA



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. Verification of particulate matter emission rates from EU-CC by testing, at the ow ner’s expense, in accordance with Department requirements, shall be required with in 5 years of the initial testing required under 40 CFR 1349(b)(1). (R 336.2001, R 336.2002, R 336.2004, R 336.1213(3), 40 CFR 1349(b)(1))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 76 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall calculate annual emission rates from KG5-CC using the most recent stack test data to establish emission factors. (R 336.1213(3))



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. A complete test plan for particulate must be submitted to and approved by the AQD prior to testing. 2 (R 336.2001, R 336.2003, R 336.2004, R 336.1213(3))



### 5. Verification of emission rates of particulate includes the s ubmittal of a complete report of the test results. The results shall be submitted to the District Supervisor, AQ D within 60 days of the completion of the stack test. 2 (R 336.2001, R 336.2003, R 336.2004, R 336.1213(3))

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

1. SV25-507 84 1 50 1 R 336.1224, R 336.1225, R 336.1901, R 336.1201(3), R 336.1313, 40 CFR Part 63 Subpart LLL 2. SV25-507a 84 1 50 1 R 336.1224, R 336.1225, R 336.1901, R 336.1201(3), R 336.1313, 40 CFR Part 63 Subpart LLL



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 77 

## FG-NO x 

## FLEXIBLE GROUP CONDITIONS

DESCRIPTION: Part 55, Air Pollution Control of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended; Part 8, Rule 801 as amended December 4, 2002

Emission Unit: EU-Kiln 22, EU-Kiln 23



### POLLUTION CONTROL EQUIPMENT: Baghouses

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

1. Nitrogen Oxides 12.7 pounds per ton of

clinker produced 1 May 1, through September 30, of each year Kilns 22 and 23 combined Condition VI.4 R 336.1801(4)(h)



### II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Scenario Equipment Monitoring/ Testing Method Underlying Applicable Requirements

NA



### III. PROCESS/OPERATIO NAL RESTRICTION(S)

NA



### IV. DESIGN/EQUIPMENT PARAMETER(S)

NA



### V. TESTING/SAMPLING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

NA



### VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The Permittee shall monitor and record the NO x emissions from each kiln on a continuous basis in a manner and with instrumentation acceptable to the AQD. (R 336.1801(8)(b), 40 CFR Part 60.13, R 336.1213(3))ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 78 2. The continuous emission monitoring system (CEMS) s hall be installed, calibrated, maintained, and operated in accordance with the procedures set forth in 40 CFR 60. 13 and Performance Specification (PS) 2 of Appendix B, 40 CFR Part 60 for NO x . The span value shall be 2.0 times the lowe st emission standard or as specified in the federal regulations. (R 336.1801(11)(a) and (b), 40 CFR Part 60.13, R 336.1213(3))

3. The Permittee shall calculate the NO x emissions in tons per annual ozone period using emission factors established by CEMS data. (R 336.1213(3))

4. The Permittee shall calculate the pounds per ton of clinker produced using the following formula: (R 336.1213(3))

tons of NO x emission during the ozone period x 2000 lbs/ ton tons of clinker produced during the ozone period.



### VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be received by the appropriate AQD District Office by Ma rch 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Gener al Conditions 19 and 20 of Part A. Report shall be received by the appropriate AQD district office by March 15 for the previous calendar year. (R 336.1213(4)(c))

4. The Permittee shall submit a summary report, in an acceptable format, to the department within 60 days after the end of each ozone period. 1 (R 336.1801(12)) The report shall include the following information:

a. The date, time magnitude of emissions, and emission rates of FG-NO x . b. If emissions or emission rates exceed the emission s or rates allow for in the ozone control period.

c. The total operating time of FG-NO x during the ozone control period.

d. Continuous emission monitoring (CEM) system perform ance information shall include the date and time of each period during which the CEM was inoperative, ex cept for zero and span chec ks, and the nature of the system repairs or adjustments. When the CEM has not been inoperat ive, repaired, or adjusted, the information shall be stated in the report.

See Appendix 8



### VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Dimensions

(inches) Minimum Height Above Ground (feet) Underlying Applicable Requirements

NA



### IX. OTHER REQUIREMENT(S)

NA

Footnotes : 1 This condition is state-only enforceable and was established pursuant to Rule 201(1)(b).

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 79 E. NON-APPLICABLE REQUIREMENTS

At the time of ROP issuance, the AQD has determined t hat no non-applicable requirements have been identified for incorporation into the permit shield provision set fort h in the General Conditions in Part A pursuant to Rule 213(6)(a)(ii).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 80 

## APPENDICES

Appendix 1: Abbreviations & Acronyms The following is an alphabetical listing of abbrevia tions/acronyms that may be used in this permit. AQD Air Quality Division MM Million acfm Actual cubic feet per minute MSDS Material Safety Data Sheet BACT Best Available Control Technology MW Megawatts BTU British Thermal Unit NA Not Applicable °C Degrees Celsius NAAQS National Ambient Air Quality Standards

CAA Federal Clean Air Act NESHAP National Emission Standard for Hazardous Air Pollutants CAM Compliance Assurance Monitoring NMOC Non-methane Organic Compounds CEM Continuous Emission Monitoring NOx Oxides of Nitrogen CFR Code of Federal Regulations N SPS New Source Performance Standards

CO Carbon Monoxide NSR New Source Review COM Continuous Opacity Monitoring PM Particulate Matter Department Michigan Department of Environmental Qual ity PM-10 Particulate Matter less than 10 microns in diameter Dscf Dry standard cubic foot pph Pound per hour Dscm Dry standard cubic meter ppm Parts per million

USEPA United States Environmental Protection Agency ppmv Parts per million by volume EU Emission Unit ppmw Parts per million by weight °F Degrees Fahrenheit PS Performance Specification FG Flexible Group PSD Preventi on of Significant Deterioration GACS Gallon of Applied Coating Solids psia Pounds per square inch absolute gr Grains psig Pounds per square inch gauge

HAP Hazardous Air Pollutant PeTE Permanent Total Enclosure Hg Mercury PTI Permit to Install Hr Hour RACT Reasonable Available Control Technology HP Horsepower ROP Renewable Operating Permit

H 2 S Hydrogen Sulfide SC Special Condition HVLP High Volume Low Pressure * scf Standard cubic feet ID Identification (Number) sec Seconds IRSL Initial Risk Screening Level SCR Selective Catalytic Reduction ITSL Initial Threshold Screening Level SO 2 Sulfur Dioxide

LAER Lowest Achievable Emission Ra te SRN State Registration Number

Lb Pound TAC Toxic Air Contaminant M Meter Temp Temperature MACT Maximum Achievable Control Technology THC Total Hydrocarbons MAERS Michigan Air Emissions Reporting System tpy Tons per year MAP Malfunction Abatement Plan μg Microgram MDEQ Michigan Department of Environmental Quality VE Visible Emissions Mg Milligram VOC Volatile Organic Compounds mm Millimeter yr Year

* For HVLP applicators, the pressure meas ured at the gun air cap shall not exceed t en (10) pounds per square inch gauge (psig).ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 81 Appendix 2. Schedule of Compliance

The permittee certified in the ROP application that this stationary source is in compliance with all applicable requirements and the permittee shall continue to comply wi th all terms and conditions of this ROP. A Schedule of Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii))



### Appendix 3. Monitoring Requirements

Specific monitoring requirement procedures, methods or sp ecifications are detailed in Part A or the appropriate source-wide, emission unit and/or flexible group Special Conditions. Therefore, this appendix is not applicable.



### Appendix 4. Recordkeeping

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate source-wide, emission unit and/or flexible group special condit ions. Therefore, this appendix is not applicable.



### Appendix 5. Testing Procedures

The permittee shall use the following approved test plans , procedures, and averaging to measure the pollutant emissions for the applicable requirements referenced in EU-Kiln 19, EU-Kiln 20, EU-Kiln 21, EU-Kiln 22 and EU-Kiln 23.



## Requirements for HCl Testing

General requirements: 1. The testing plan shall meet all of the requirements of this appendix.

2. The testing plan shall include three tiers: Tier One, Tier Two, and Tier Three.

3. Testing in any kiln shall progress from one tier to the next based on test results in that kiln only. Testing for each kiln shall progress through the tiers i ndependent of testing for the other kilns.

4. Upon written notification from the Di strict Supervisor, AQD, testing for a k iln shall return to testing under the immediately lower tier (for example, from Tier Thr ee to Tier Two) under any of the circumstances below. Testing for the kiln shall then remain in this lower tier until the test results again satisfy the consecutive test requirement for this lower tier. The AQD reserves the ri ght to exercise discretion in applying this provision, based on its review of the details of any such circumstance.

• The results of any test fail to meet the HCl limits for FG-KG5 or FG-KG6.

• HCl monitor downtime exceeds 5% during any calendar quarter

• HCl monitor downtime exceeds 3% duri ng any two consecutive calendar quarters

5. The Permittee shall submit a testing report demonst rating that the HCl process monitors comply with the requirements of the AQD-approved validation procedure. Until the AQD has approved this testing report and begun to direct operating conditions for tests based on data from the process monitors, tests shall be conducted with the kilns operating as described in the AQD-a pproved testing plan. The AQD will use data from the HCl process monitors required by FG-KG5(VI)(1) and FG-KG6(VI)(7) to determine the operating conditions Lafarge shall use when perform ing the required HCl testing.

Tier One: 1. The kiln shall be tested monthly while in this tier.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

Page 

### 82 2. Monthly testing shall continue unt il six consecutive succes sful tests have been completed for the kiln. A successful test meets the following criteria.

• Test results met the limits of FG-KG5 or FG-KG6.

• Operating conditions during the test met the AQD-approved objectives for the test.

3. After written notification from the AQ D that the kiln has met the requirements of item 2 above, testing for the kiln shall move to Tier Two. For each complete test report t hat will not complete all of the testing required under this tier, the AQD will provide written notification specifying whether the test results met the requirements of item 2 above within 30 calendar days of receipt of a complete test report. For each complete test report that may complete all of the testing required under this tier, th e AQD will provide written not ification specifying whether the AQD has determined that the test results met the r equirements of item 2 above within 14 calendar days of receiving a complete test report.

Tier Two: 1. The kiln shall be tested once each ca lendar quarter while in this tier.

2. Quarterly testing shall continue until four consecutive tests have been successfully completed for the kiln. A successful test meets the following criteria.

• Test results met the limits of FG-KG5 or FG-KG6.

• Operating conditions during the test met the AQD-approved objectives for the test.

3. After written notification from the AQ D that the kiln has met the requirements of item 2 above, testing for the kiln shall move to Tier Three. For each complete test report that will not complete all of the testing required under this tier, the AQD will provide writt en notification specifying whether the test results met the requirements of item 2 above within 30 calendar days of receipt of a comp lete test report. For each complete test report that may complete all of the testing required under this ti er, the AQD will provide written notification specifying whether the AQD has determined that the test results m eet the requirements of item 2 above within 14 calendar days of receiving a complete test report.

Tier Three: 1. The kiln shall be tested once each calendar year while in this tier.

2. A successful test meets the following criteria.

• Test results met the limits of FG-KG5 or FG-KG6.

• Operating conditions during the test met the AQD-approved objectives for the test.

For each complete test report required under this tier, t he AQD will provide written not ification specifying whether the AQD has determined that the test results met the r equirements of item 2 above within 14 calendar days of receiving a complete test report.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 83 Appendix 6. Permits to Install (PTI)

The following table lists any PTI and/or Operate that relate to the identified Emission Units or Flexible groups in this ROP. This includes all PTI and/or Operate that are hereby incorporated into Source-wide PTI No. MI-PTI-B1477-2003

Permit to Install Number Description of Equipment Corresponding Emission Unit(s) or

Flexible Group(s) 

### 1-68 7 Baghouses on storage silos FG-PC MACT 8-72 1 Baghouse on clinker belt transfer EU-Clinker Handling System 118-74 Finish Mills FG-PC MACT 426-74 1 Baghouse for clinker proportioning EU-Clinker Handling System 353-75 1 Baghouse on ship loading equipment EU-Cement Storage and Bulk Loading: FG-PC MACT 442-75 Baghouses on crusher and conv eyors EU-Finish Mill System; PC MACT443-75 Baghouse for dry stone conveyor EU-Quarry Operations2 221-76 Baghouses on conveyors EU-Finish Mill System; PC MACT 131-76 2 Baghouses on transfer pipes and #3silo storage bins EU-Finish Mill System 624-77 2 Baghouses for clinker transfer EU-Clinker Handling System 376-78 Baghouses for rail car and tuck loading EU-Cement Storage and Bulk Loading; FG-PC MACT 960-78 Baghouse on clinker conveyors EU-Clinker Handling System 796-79 Rail car storage and handling system and finish grind EU-Finish Mill System; EU Cement Storage and Bulk Loading; FG-PC MACT 797-79 Baghouses for old boat end silos EU-Finish Mill System; EU Cement Storage and Bulk Loading; FG-PC MACT 798-79 Baghouses for No. 2 cement storage bins EU- Cement Storage and Bulk Loading; FG-PC MACT 857-79 Baghouses for clinker transfer points EU-Clinker Handling System 956-79 Baghouses for kiln dust handling EU-CKD System 42-83 Coal handling equipment EU- Coal Handling SystemROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 84 Permit to Install Number Description of Equipment Corresponding Emission Unit(s) or

Flexible Group(s) 

### 126-86D Kiln Group 6; Kilns 22 and 23 EU-Kiln 22; EU-Kiln 23; FG-PC MACT; FG-NOx 163-88 Bulk cement truck and railcar loading station EU-Cement Storage and Bulk Loading; FG-PC MACT 356-88C Finish grind dust collectors EU-Finish Mill System; FG-PC MACT 356-88E Conveyor covers, baghouses and clinker conveyors and storage building. EU- Clinker Handling System; FG-PC MACT 83-98 CKD return system EU-CKD System 622-89C Removal of continuous emission monitors EU Raw Mill System; FG-PC MACT 166-93 Alternate raw materials storage and transfer EU-ARM786-89A Raw material handling EU-Quarry Operations2 158-90 Cement kiln dust return system EU-Kiln 19; EU-Kiln 20; EU-Kiln 21; EU-Kiln 22; EU-Kiln 23837-90 Secondary crusher EU-Quarry Operations2152-92 Foam dust suppressant for secondary crusher EU-Quarry Operations2152-92 Foam dust suppressant for secondary crusher EU-Quarry Operations2 936-92 Encrusting agent for coal pile EU-Coal Handling System 886-93 Foam dust suppressant for coal handling EU-Coal Handling System 203-94 Truck loading and cement storage silos EU-Cement Storage and Bulk Loading; FG-PC MACT380-94 New clinker cooler for Kiln 19 EU-Kiln 19; FGKG5CC 268-97 Increase HCl limit on Kilns 19, 20, 21 EU-Kiln 19; EU-Kiln 20 EU-Kiln 21

Appendix 7. Emission Calculations

Specific emission calculations to be used with monitoring, testing or recordkeeping data are detailed in the appropriate source-wide, emissi on unit and/or flexible group Special Condit ions. Therefore, this appendix is not applicable.ROP No.: MI-ROP-B1477-2003b Expiration Date: December 2, 2008 PTI No.: MI-PTI-B1477-2003b

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### 85 Appendix 8. Reporting

A. Annual, Semiannual, and Deviation Certification Reporting

The permittee shall use the MDEQ Report Certificat ion form (EQP 5736) and MDEQ Deviation Report form (EQP 5737) for the annual, semiannual and deviation certificat ion reporting referenced in the Reporting section of the source-wide, emission uni t and/or flexible group Special Condition s. Alternative formats must meet the provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), res pectively, and be approved by t he AQD District Supervisor.

B. Other Reporting

Specific reporting requirement format s and procedures are detailed in Part A or the appropriate source-wide, emission unit and/or flexible group Special Conditions. Therefore, Part B of this appendix is not applicable.