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 Supervisor
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 2 

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-NOx .....................................................................................................................................................77

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

Appendix 1: Abbreviations & Acronyms...................................................................................................80

Appendix 2. Schedule of Compliance ......................................................................................................81

Appendix 3. Monitoring Requirements.....................................................................................................81

Appendix 4. Recordkeeping.....................................................................................................................81
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 3 

Appendix 5. Testing Procedures..............................................................................................................81

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

Appendix 7. Emission Calculations..........................................................................................................84

Appendix 8. Reporting .............................................................................................................................85
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 4 

AUTHORITY AND ENFORCEABILITY 

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 conditions 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 requirements 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 

Page 5 

A. GENERAL CONDITIONS 

Permit Enforceability 

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. 

(R 336.1213(5))

• Those conditions that are hereby incorporated in a state-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 federal 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 relieve the permittee from any responsibilities or obligations 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 Environmental 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 conditions 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 provisions of the federal Clean Air Act (CAA). Any terms and conditions 

based on applicable requirements which are designated as “state only” are not enforceable 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 enforcement action that it would have been necessary to halt or 

reduce the permitted activity in order to maintain compliance with the conditions of this 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 notification of planned changes or anticipated noncompliance does 

not stay any ROP term or condition. This does not supersede 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 authorized representative of the 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 emissions-related activity is 

conducted or where records must be kept 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 compliance with the ROP or applicable requirements. 
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 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 Administrator of the USEPA, or the department 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 fee schedule and requirements pursuant to Section 5522 of 

Act 451. (R 336.1213(1)(g))

8. This ROP does not convey any property 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 shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air 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 density greater than the most 

stringent of Rule 301(1)(a) or (b) unless otherwise specified 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 one 6-minute average per hour of not more than 27% 

opacity.

b. A limit specified by an applicable federal new source performance standard. 

12. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, 

alone or in reaction with other air contaminants, 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 comfortable 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 expense, 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 

Page 7 

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the 

applicable reference test method within 60 days 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 method 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 parameters 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, measurement, 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 certification 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 shall certify to the appropriate District Office of the 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 appropriate District Office of the AQD pursuant to 

Rule 213(3)(c). This certification shall include all the information specified in Rule 213(4)(c)(i) through (v) and 

shall state that, based on information and belief formed 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 Division, 77 West Jackson Boulevard, Chicago, IL, 60604. 

(R 336.1213(4)(c))

20. The certification of compliance shall be submitted annually 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 defined in Rule 213(3)(c)(ii) as follows, unless otherwise 

described in this ROP (R 336.1213(3)(c)): 

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting 

consistent with the requirements of Rule 912 as detailed in Condition 25. All reports submitted pursuant to 

this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii). 

b. For deviations which exceed the emissions allowed 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 exceed the emissions allowed under the ROP, prompt reporting means the 

reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe 

the reasons for each deviation and the actions taken to minimize or correct each deviation. 
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 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 either of the following (R 336.1213(3)(c)): 

a. Submitting a certification by a responsible 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 calendar 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 certification 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 complete. The certification shall include a listing of the 

reports that are being certified. 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 certification 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 frequently if specified, the 

permittee shall submit certified reports of any required monitoring to the appropriate 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 regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing 

the emissions inventory forms provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable 

standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an 

applicable standard or limitation, as required 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 shall be by any reasonable means, including 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 discovery of the abnormal conditions 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 summary 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 have been identified as non-applicable to this ROP and are 

included in the permit shield. 

27. Nothing in this ROP shall alter or affect any of the following: 

a. The provisions of Section 303 of the CAA, emergency orders, including 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 for 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 program, consistent with Section 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 

Page 9 

d. The ability of the USEPA to obtain information from a source pursuant to Section 114 of the CAA. 

(R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incorporated 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 Rule 216(1)(a)(v) until the amendment 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 application 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 the 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 comply 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 stationary 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 

Page 10 

1.10 Renewals 

35. For renewal of this ROP, an administratively complete application 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 services, maintains, or repairs appliances except for motor 

vehicle air conditioners (MVAC), or disposes of appliances containing refrigerant, including MVAC and small 

appliances, or if the permittee is a refrigerant reclaimer, appliance owner or a manufacturer of appliances or 

recycling and recovery equipment, the permittee shall comply with all applicable standards 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 performs 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. The term “motor vehicle” as used in 

Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used 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 Part 68, the permittee shall register and submit to the 

USEPA the required data related to the risk management plan for reducing 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 accident 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 present 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 regulatory agency necessary to ensure compliance 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 reduction credit trading are allowed pursuant to any applicable interstate or 

regional emission trading program that has been approved by the Administrator of the USEPA as a part of 

Michigan’s State Implementation Plan. Such activities 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 

Page 11 

Permit To Install (PTI) 

43. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified 

unless a PTI authorizing such action is issued by the department, except to the extent 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 performing 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. The request must include all 

of the information required by Subrules (1)(a), (b) and (c) of Rule 219. The 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 shall become void unless otherwise authorized by the 

department. Furthermore, the person to whom that PTI 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 

Page 12 

B. SOURCE-WIDE CONDITIONS 

Part B outlines the source-wide terms and conditions that apply 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 apply to this source, NA (not applicable) has been used in 

the table. If there are no source-wide conditions, 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/OPERATIONAL RESTRICTION(S) 

1. The Permittee shall implement and maintain the AQD approved fugitive dust control program. Should the AQD 

determine the fugitive dust control program 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 

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)

NA 
 ROP 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 pursuant to General Condition 23 of Part A. Report shall be 

received by the appropriate AQD District Office by March 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 General 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 Special 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 apply, NA (not applicable) has been used in the table. If 

there are no conditions specific to individual emission 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 Filter (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-NOx 

EU-Kiln 23 Kiln 23, Baghouses (26-255), (26-256) 01/01/75 FG-PCMACT 

FG-NOx

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-PCMACT 
 ROP 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-PCMACT 
 ROP 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 maintain an operations and maintenance plan for EU-Quarry1 

(except the rock drill). Should the AQD determine the 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 District Supervisor. Upon written approval of a modified 

operation and maintenance plan by the District Supervisor, 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 

operating2

. (R 336.1910) 

3. The permittee shall apply dust suppressant system to the road system at a frequency sufficient to prevent 

fugitive dust.2

 (R 336.1371) 

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

XII. TESTING/SAMPLING
 ROP 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 preventative 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 March 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 General 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/dscf2 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/OPERATIONAL 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 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 District Supervisor. Upon written approval of a modified operation and maintenance plan by the 
 ROP 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 differential 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 dust suppression system, foaming 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 preventative 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 baghouse of the secondary crusher shall be read and recorded daily. 

(R 336.1213(3))

4. Monthly usage rates of the dust suppressant for the primary 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 the 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 March 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 General 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 
 ROP 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 Mill 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 

gases2

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 pounds2 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 tons2 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 

processed2

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 pounds2 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 tons2 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.6
 ROP 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 tons2 Per hour, 

based on a 

24 hour 

average 

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

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. The Permittee shall not use Paxton quarry shale as a raw 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 advance by the AQD. Approval of such 

stack testing by the AQD may require submittal of an application for a permit to install2

. (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 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 District Supervisor. Upon written approval 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 without 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, SO2, CO, NOx, and VOC emission rates from the 

EU-Raw Mill System, by testing, at the owner’s expense in accordance with Department 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 per hour based on a 24-hour average, shall be kept on file. 

(R 336.1213(3)) 

2. The Permittee shall record and maintain all preventative maintenance records associated with EU-Raw 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))
 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 March 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 General 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 

gas2

 

 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 pounds2 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 ton2 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 

gas2

 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 pounds2 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 ton2 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)
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Expiration Date: December 2, 2008 

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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 

gas2

 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 pounds2 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 tons2 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 

gas2

 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 pounds2 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 tons2 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 

gas2

 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 pounds2 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 tons2 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)
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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 

gas2

 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 pound2 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 ton2 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 

gas2

 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 pounds2 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 tons2 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 

gas2

 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 pounds2 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 tons2 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) 
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Expiration Date: December 2, 2008 

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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 ammonia-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/OPERATIONAL RESTRICTION(S) 

1. The Permittee shall not operate the Iron Ore Tailings Conveyor (18-205) and Flyash Dome (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 Conveyors (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 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 District Supervisor. Upon written approval 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 PM-10 emission rates from EU-ARM by testing, at the owner’s expense, 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 

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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 operation of the file Iron Ore Tailings Conveyor (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 from 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 preventative maintenance records associated with EU-ARM 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 March 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 General 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 submittal of a complete report of the test results. If a stack 

test is required, 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))

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 8 
 ROP 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 8.52

 302 R 336.1225, R 336.1901, 

40 CFR 52.21

2. SV17-045 312

 1252 R 336.1225, R 336.1901, 

40 CFR 52.21

3. SV17-105 312

 1252 R 336.1225, R 336.1901, 

40 CFR 52.21

4. SV17-205 312

 134.52 R 336.1225, R 336.1901, 

40 CFR 52.21

5. SV17-325 

8.52

 652 

not vertically 

oriented 

R 336.1225, R 336.1901, 

40 CFR 52.21

6. SV17-425 

8.52

 652 

not vertically 

oriented 

R 336.1225, R 336.1901, 

40 CFR 52.21

7. SV18-205 152

 452 R 336.1225, R 336.1901, 

40 CFR 52.21

8. SV31-188 22.22

 1202 R 336.1225, R 336.1901, 

40 CFR 52.21

9. SV32-171 33.72

 1102 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 

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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/OPERATIONAL RESTRICTION(S) 

1. The permittee shall not operate EU-Coal Handling System 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 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 District Supervisor. Upon written approval 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))

NA 
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Expiration Date: December 2, 2008 

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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 encrusting 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 suppressant 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 March 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 General 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 

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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 (SO2) 2,088 tons2 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 (NOx) 1,530 tons2 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 tons2 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 (SO2) 548 ppmv 

corrected to 7% 

oxygen on a dry 

basis2 

 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
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

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Page 35 

Pollutant Limit Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method 

Underlying 

Applicable 

Requirements

5. Nitrogen Oxides (NOx) 584 ppmv 

corrected to 7% 

oxygen on a dry 

basis2 

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 

basis2

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 basis2

 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% 

oxygen1 

 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 pounds1 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.7
 ROP 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 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 District Supervisor. Upon written approval 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 SO2, NOx, 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 SO2 and NOx 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

 (40 CFR 60.13, R 336.2150, 

R 336.1213(3))

2. For EU-Kiln 19, the Permittee shall keep records of the SO2, NOx, 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 each 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 SO2, NOx 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 concentrations, as one-minute averages 
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 37 

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

c. Estimated CKD wasted, in tons 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 Permittee 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-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 pursuant to General Condition 23 of Part A. Report shall be 

received by the appropriate AQD District Office by March 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 General 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 (SO2) above 548 

parts per million by volume (ppmv); of nitrogen oxides (NOx) 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 taken, and a total operating time of the source. If no 

exceedances or CEMS downtime occurred during the time period, the permittee shall report that fact.2 

(R 336.2170, 40 CFR 60.7(c)&(d)) 

5. The permittee shall perform the Quality Assurance Procedures of the CEMS for SO2., NOx, and CO, as set forth 

in Appendix F of 40 CFR Part 60. Each quarter the results shall be presented and submitted in the format of 

the data assessment report (DAR) 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 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))

7. A complete test plan for particulate 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)

See Appendix 8 
 ROP 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 1562 2202 R 336.1225, R 336.1901, 

40 CFR 52.21 

2. SV25-672, SV25-673 1452 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 (SO2) 2,065 tons2 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 (NOx) 1,513 tons2 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 tons2 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 (SO2) 542 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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.6
 ROP 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 (NOx) 578 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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 

basis2

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 basis2 

 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 basis2

 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% 

oxygen2 

 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 pounds2 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.7 
 ROP 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 SO2, NOx, 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 (PS) 2 of Appendix B, 40 CFR Part 60 for SO2 and NOx 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

 (40 CFR 60.13, R 336.2150, 

R 336.1213(3))

2. For EU-Kiln 20, the Permittee shall keep records of the SO2, NOx, 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 each 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 SO2, NOx 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 concentrations, as one-minute averages 

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

c. Estimated CKD wasted, in tons 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 Permittee 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-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 March 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 General 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 (SO2) above 542 

parts per million by volume (ppmv); of the excess emissions of nitrogen oxides (NOx) 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 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 taken, and a total operating time of the source. 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 SO2, NOx and CO as set forth 

in Appendix F of 40 CFR Part 60. Each quarter the results shall be presented and submitted in the format of 

the data assessment report (DAR) 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 submitted 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 1562 2202 R 336.1225, R 336.1901, 40 CFR 

52.21 

2. SV25-672, SV25-673 1452 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 (SO2) 2,056 tons2 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 (NOx) 1,506 tons2 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 tons2 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 (SO2) 539 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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
 ROP 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 (NOx) 575 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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 

basis2

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 basis2 

 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 basis2

 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% 

oxygen1 

 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 pounds1 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.7 
 ROP 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 SO2, NOx, 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 (PS) 2 of Appendix B, 40 CFR Part 60 for SO2 and NOx 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

 (40 CFR 60.13, R 336.2150, 

R 336.1213(3))

2. For EU-Kiln 21, the Permittee shall keep records of the SO2, NOx, 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 each 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 SO2, NOx, and CO in tons per calendar month and tons 

per year on a twelve month rolling average using 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 concentrations, as one-minute averages 

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

c. Estimated CKD wasted, in tons 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 Permittee 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-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 March 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 General 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 (SO2) above 539 

parts per million by volume (ppmv); of the excess emissions of nitrogen oxides (NOx) 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 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 taken, and a total operating time of the source. 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 SO2, NOx and CO as set forth 

in Appendix F of 40 CFR Part 60. Each quarter the results shall be presented and submitted in the format of 

the data assessment report (DAR) 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 submitted 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 1562 2202 R 336.1225, R 336.1901, 

40 CFR 52.21 

2. SV25-672, SV25-673 1452 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 (SO2) 9,685 tons2 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 (NOx) 3,930 tons2 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 tons2 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 (SO2) 1,611 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

 

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
 ROP 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 (NOx) 952 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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 

basis2 

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 basis2

 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 

basis1 

 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 pounds1 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/m3 

corrected to 

70oF and 29.92 

inches Hg1 

 EU-Kiln 22 Condition V.4 R 336.1901, C.J. 

No. 93-000651-

CE Paragraph 

IV.6

11. Chromium 0.0058 pound1 Per hour EU-Kiln 22 Condition V.4 R 336.1901, C.J. 

No. 93-000651-

CE Paragraph 

IV.6

12. Cadmium 112 ug\m3

corrected to 

70oF and 29.92 

inches Hg1 

 EU-Kiln 22 Condition V.4 R 336.1901, C.J. 

No. 93-000651-

CE Paragraph 

IV.6
 ROP 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 pound1 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 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 SO2, NOx, and CO emissions from each kiln 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 (PS) 2 of Appendix B, 40 CFR Part 60 for SO2 and NOx 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, 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 SO2, NOx, 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 each 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 SO2, NOx, 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) recycled, 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 Permittee 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 March 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 Special 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 (SO2) above 1,611 

parts per million by volume (ppmv); of nitrogen oxides (NOx) above 952 parts per million by volume (ppmv); and 

of the excess emissions of carbon monoxide (CO) above 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 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 53 

5. The permittee shall perform the Quality Assurance Procedures of the CEMS for SO2, NOx, and CO as set forth 

in Appendix F of 40 CFR Part 60. Each quarter the results shall be presented and submitted in the format of 

the data assessment report (DAR) 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 chromium 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 2882 2922 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 (SO2) 9,728 tons2 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 (NOx) 3,947 tons2 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 tons2 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 (SO2) 1,813 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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
 ROP 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 (NOx) 1,071 ppmv 

corrected to 7% 

oxygen on a dry 

basis2

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 

basis2 

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% 

oxygen1 

 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 pounds1 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/m3 

corrected to 

70oF and 29.92 

inches Hg1 

 EU-Kiln 23 Condition V.4 R 336.1901, C.J. 

No. 93-000651-

CE Paragraph 

IV.6

11. Chromium 0.0058 pound1 Per hour EU-Kiln 23 Condition V.4 R 336.1901, C.J. 

No. 93-000651-

CE Paragraph 

IV.6

12. Cadmium 112 ug\m3

corrected to 

70oF and 29.92 

inches Hg1 

 EU-Kiln 23 Condition V.4 R 336.1901, C.J. 

No. 93-000651-

CE Paragraph 

IV.6
 ROP 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 pound1 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 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 SO2, NOx, 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, 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 SO2 and NOx

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 SO2, NOx, 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 each 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 SO2, NOx, 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) recycled, 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 Permittee 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 March 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 General 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 (SO2) above 1,813 

parts per million by volume (ppmv); of nitrogen oxides (NOx) 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 month. The EER shall include the cause of the excess 

emissions, if known; periods of monitor downtime; any corrective action taken; and the total operating time of 

the sources. If no exceedances or CEMS downtime occurred 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 SO2, NOx, and CO as set forth 

in Appendix F of 40 CFR Part 60. Each quarter the results 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 chromium 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 2882 2922 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 basis2

 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 
 ROP 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 preventative 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 March 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 General 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 

foot2

 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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. NA 
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

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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 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 preventative maintenance records associated with EU-Clinker 

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 March 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 General 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 2152 27.52 R 336.1201(3)

2. SV25-825 4372 21.32 (not 

vertically 

discharged) 

R 336.1201(3) 

3. SV26-825 4372 55.32 (not 

vertically 

discharged) 

R 336.1201(3) 

4. SV40-100 5592 54.02 (not 

vertically 

discharged) 

R 336.1201(3) 

5. SV40-110 3462 121.02 (not 

vertically 

discharged) 

R 336.1201(3) 

6. SV40-120 2,5002 63.02 (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 District 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; anticipated duration of the outside storage; 

and other relevant information as required by the District Supervisor. The plan shall be submitted to the District 

Supervisor, for approval, at least 30 days prior to storing clinker outside2

. (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 basis2

 EU-Finish Mill 

System 

Condition V.1 

Condition V.2 

R 336.1201(3) 

2. Particulate 62.6 pounds2 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 basis2

 Finish Mill 20 

Finish Mill 21 

Condition V.1 

Condition V.2 

R 336.1331 

4. Particulate 0.07 pounds2 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

NA 
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

 PTI No.: MI-PTI-B1477-2003b 

Page 65 

III. PROCESS/OPERATIONAL 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 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 District Supervisor. Upon written approval 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-Finish Mill System by testing, at the owner’s expense, in 

accordance with Department requirements, 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 preventative 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 March 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 General 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 
 ROP 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 Pounds2 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 

basis2

 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 1
 ROP 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 preventative 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 emission rates from EU-Cement Bulk Loading by testing, at the owner’s expense, in 

accordance with Department requirements, 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 required 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 March 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 General 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 apply, 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-NOx Kilns subject to Part 8 Rules. EU-Kiln 22, EU-Kiln 23 
 ROP 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 

Requirements

1. Polychlorinated dibenzop-dioxins and 

dibenzofurans 

0.20 ng 

TEQ/dscm@

 EU-Kiln19, EU-Kiln 

20, 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-Kiln 

20, 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-Kiln 

20, 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 kilns2

 EU-Kiln19, EU-Kiln 

20, 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 kilns2

 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% O2. This 

limit is applicable when the exhaust gas temperature to the fabric filter collector 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% O2. 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/OPERATIONAL 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 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 District Supervisor. Upon written approval 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 preventative maintenance records associated with; EU-Kiln19, 

EU-Kiln 20, EU-Kiln21, EU-Kiln22, EU-Kiln 23 EU-CC19, EU-CC20, EU-CC21, EU-CC22, EU-CC23; EU-Raw 

Mill System; EU-Clinker Handling System; EU-Finish Mill System; 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 initial 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 emission 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 63.1350(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, implement 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 emissions from Eu-Kiln 19, EU Kiln 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 continuous opacity monitoring system (COMS) shall be 

installed, calibrated, maintained, and operated in accordance 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 specified 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). The reference method must be a National Institiute of 

Standards and Technology calibrated reference thermocouple-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 available shall be ignored when calculating three-hour 

rolling averages for Eu-Kiln 19, EU Kiln 20, EU-Kiln 21, EU-Kiln 22, or EU-Kiln 23. When one-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 temperature sensors shall be verified at least once every three 

months. (40 CFR 63.1350(f)(6)

7. The permittee shall monitor emissions and operating and maintenance information for FG-PCMACT in 

accordance with the National Emission Standards for Hazardous 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 pursuant to General Condition 23 of Part A. Report shall be 

received by the appropriate AQD District Office by March 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 General 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 shall submit a written excess emission report (EER) in 

an acceptable format to the District 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, periods of COMS downtime, any corrective action taken, and a total operating 

time of the sources. If no exceedances or COMS downtime 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 submit 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))
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Expiration Date: December 2, 2008 

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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/furans 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. (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-Kiln19, EU-Kiln20, EU-Kiln21, EU-kiln23, EU-CC19, 

EU-CC20, EU-CC21, EU-CC22, 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 

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FG-KG5CC 

FLEXIBLE GROUP CONDITIONS

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

Emission Unit: EU-CC19, EU-CC20, EU-CC21, (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 pounds2 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 pounds2 Per hour EU-CC19, EU-CC20, 

EU-CC21 

Condition V.1 R 336.1201(3)

3. Particulate 109.0 tons2 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/OPERATIONAL 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 owner’s expense, in accordance 

with Department requirements, shall be required within 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)) 
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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 March 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 General 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 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, 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. SV25-507 841 501 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 841 501 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 

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FG-NOx 

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 

produced1

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/OPERATIONAL 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 NOx 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)) 
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2. 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 (PS) 2 of Appendix 

B, 40 CFR Part 60 for NOx. The span value shall be 2.0 times the lowest 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 NOx 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 NOx 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 March 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 General 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-NOx. 

b. If emissions or emission rates exceed the emissions or rates allow for in the ozone control period. 

c. The total operating time of FG-NOx during the ozone control period. 

d. Continuous emission monitoring (CEM) system performance information shall include the date and time of 

each period during which the CEM was inoperative, except for zero and span checks, and the nature of the 

system repairs or adjustments. When the CEM has not been inoperative, 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 

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Page 79 

E. NON-APPLICABLE REQUIREMENTS 

At the time of ROP issuance, the AQD has determined that no non-applicable requirements have been identified for 

incorporation into the permit shield provision set forth 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 

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Page 80 

APPENDICES

Appendix 1: Abbreviations & Acronyms 

The following is an alphabetical listing of abbreviations/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 NSPS New Source Performance Standards 

CO Carbon Monoxide NSR New Source Review 

COM Continuous Opacity Monitoring PM Particulate Matter 

Department Michigan Department of Environmental Quality 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 Prevention 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 

H2S 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 SO2 Sulfur Dioxide 

LAER Lowest Achievable Emission Rate 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 measured at the gun air cap shall not exceed ten (10) pounds per square inch gauge (psig).
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Expiration Date: December 2, 2008 

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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 with 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 specifications 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 conditions. 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 independent of testing for the other kilns. 

4. Upon written notification from the District Supervisor, AQD, testing for a kiln shall return to testing under the 

immediately lower tier (for example, from Tier Three 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 right 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% during any two consecutive calendar quarters 

5. The Permittee shall submit a testing report demonstrating 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-approved 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 performing the required HCl testing. 

Tier One:

1. The kiln shall be tested monthly while in this tier. 
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Expiration Date: December 2, 2008 

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Page 82 

2. Monthly testing shall continue until six consecutive successful 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 AQD 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 that 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, the AQD will provide written notification specifying whether 

the AQD has determined that the test results met the requirements of item 2 above within 14 calendar days of 

receiving a complete test report. 

Tier Two:

1. The kiln shall be tested once each calendar 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 AQD 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 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, the AQD will provide written notification specifying 

whether the AQD has determined that the test results meet 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, the AQD will provide written notification specifying whether 

the AQD has determined that the test results met the requirements 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 

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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 conveyors EU-Finish Mill System; 

PC MACT 

443-75 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 

System 
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Expiration Date: December 2, 2008 

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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-ARM 

786-89A 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 23 

837-90 Secondary crusher EU-Quarry Operations2 

152-92 Foam dust suppressant for secondary crusher EU-Quarry Operations2 

152-92 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 MACT 

380-94 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, emission unit and/or flexible group Special Conditions. Therefore, this appendix is not 

applicable. 
 ROP No.: MI-ROP-B1477-2003b 

Expiration Date: December 2, 2008 

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Page 85 

Appendix 8. Reporting 

A. Annual, Semiannual, and Deviation Certification Reporting 

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form 

(EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting section of 

the source-wide, emission unit and/or flexible group Special Conditions. Alternative formats must meet the 

provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor. 

B. Other Reporting 

Specific reporting requirement formats 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.