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 Permit No. 1680-00025 

973 PER20050003 

TABLE OF CONTENTS

SECTION 1. GENERAL CONDITIONS ................................................................................ 3 

SECTION 2. EMISSION POINTS & POLLUTION CONTROL DEVICES ....................... 13 

SECTION 3. EMISSION LIMITATIONS & STANDARDS................................................ 15 

SECTION 4. COMPLIANCE SCHEDULE........................................................................... 30 

SECTION 5. MONITORING, RECORDKEEPING & REPORTING REQUIREMENTS .. 31 

SECTION 6. ALTERNATIVE OPERATING SCENARIOS................................................ 47 

SECTION 7. TITLE VI REQUIREMENTS .......................................................................... 48 

APPENDIX A LIST OF ABBREVIATIONS USED IN THIS PERMIT 

APPENDIX B 40 CFR 82 - PROTECTION OF STRATOSPHERIC OZONE 

APPENDIX C 40 CFR, PART 63, SUBPART LLL, NATIONAL EMISSION 

STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR 

CATEGORIES; PORTLAND CEMENT MANUFACTURING 

INDUSTRY 

APPENDIX D 40 CFR, PART 63, SUBPART EEE, NATIONAL EMISSION 

STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM 

HAZARDOUS WASTE COMBUSTORS 

APPENDIX E 40 CFR, PART 61, SUBPART V, NATIONAL EMISSION 

STANDARD FOR EQUIPMENT LEAKS (FUGITIVE EMISSION 

SOURCES) 

APPENDIX F OPERATION AND MAINTENANCE PLAN 

APPENDIX G 40 CFR, PART 63, SUBPART PP, NATIONAL EMISSION 

STANDARDS FOR CONTAINERS 
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 Permit No. 1680-00025 

973 PER20050003 

SECTION 1. GENERAL CONDITIONS

1.1 The permittee must comply with all conditions of this permit. Any permit noncompliance 

constitutes a violation of the Federal Act and is grounds for enforcement action; for permit 

termination, revocation and reissuance, or modification; or for denial of a permit renewal 

application. (Ref.: APC-S-6, Section III.A.6.a.) 

1.2 It shall not be a defense for a 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 permit. (Ref.: APC-S-6, Section III.A.6.b.) 

1.3 This permit and/or any part thereof may be modified, revoked, reopened, and reissued, or 

terminated for cause. The filing of a request by the permittee for a permit modification, 

revocation and reissuance, or termination, or of a notification of planned changes or 

anticipated noncompliance does not stay any permit condition. (Ref.: APC-S-6, Section 

III.A.6.c.) 

1.4 This permit does not convey any property rights of any sort, or any exclusive privilege. 

(Ref.: APC-S-6, Section III.A.6.d.) 

1.5 The permittee shall furnish to the DEQ within a reasonable time any information the DEQ 

may request in writing to determine whether cause exists for modifying, revoking and 

reissuing, or terminating the permit or to determine compliance with the permit. Upon 

request, the permittee shall also furnish to the DEQ copies of records required to be kept by 

the permittee or, for information to be confidential, the permittee shall furnish such records 

to DEQ along with a claim of confidentiality. The permittee may furnish such records 

directly to the Administrator along with a claim of confidentiality. (Ref.: APC-S-6, Section 

III.A.6.e.) 

1.6 The provisions of this permit are severable. If any provision of this permit, or the 

application of any provision of this permit to any circumstances, is challenged or held 

invalid, the validity of the remaining permit provisions and/or portions thereof or their 

application to other persons or sets of circumstances, shall not be affected thereby. (Ref.: 

APC-S-6, Section III.A.5.) 

1.7 The permittee shall pay to the DEQ an annual permit fee. The amount of fee shall be 

determined each year based on the provisions of regulated pollutants for fee purposes and the 

fee schedule specified in the Commission on Environmental Quality's order which shall be 

issued in accordance with the procedure outlined in Regulation APC-S-6. 

(a) For purposes of fee assessment and collection, the permittee shall elect for actual or 
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allowable emissions to be used in determining the annual quantity of emissions 

unless the Commission determines by order that the method chosen by the applicant 

for calculating actual emissions fails to reasonably represent actual emissions. 

Actual emissions shall be calculated using emission monitoring data or direct 

emissions measurements for the pollutant(s); mass balance calculations such as the 

amounts of the pollutant(s) entering and leaving process equipment and where mass 

balance calculations can be supported by direct measurement of process parameters, 

such direct measurement data shall be supplied; published emission factors such as 

those relating release quantities to throughput or equipment type (e.g., air emission 

factors); or other approaches such as engineering calculations (e.g., estimating 

volatilization using published mathematical formulas) or best engineering 

judgements where such judgements are derived from process and/or emission data 

which supports the estimates of maximum actual emission. (Ref.: APC-S-6, Section 

VI.A.2.) 

(b) If the Commission determines that there is not sufficient information available on a 

facility's emissions, the determination of the fee shall be based upon the permitted 

allowable emissions until such time as an adequate determination of actual emissions 

is made. Such determination may be made anytime within one year of the submittal 

of actual emissions data by the permittee. (Ref.: APC-S-6, Section VI.A.2.) If at any 

time within the year the Commission determines that the information submitted by 

the permittee on actual emissions is insufficient or incorrect, the permittee will be 

notified of the deficiencies and the adjusted fee schedule. Past due fees from the 

adjusted fee schedule will be paid on the next scheduled quarterly payment time. 

(Ref.: APC-S-6, Section VI.D.2.) 

(c) The fee shall be due September 1 of each year. By July 1 of each year the permittee 

shall submit an inventory of emissions for the previous year on which the fee is to be 

assessed. The permittee may elect a quarterly payment method of four (4) equal 

payments; notification of the election of quarterly payments must be made to the 

DEQ by the first payment date of September 1. The permittee shall be liable for 

penalty as prescribed by State Law for failure to pay the fee or quarterly portion 

thereof by the date due. (Ref.: APC-S-6, Section VI.D.) 

(d) If in disagreement with the calculation or applicability of the Title V permit fee, the 

permittee may petition the Commission in writing for a hearing in accordance with 

State Law. Any disputed portion of the fee for which a hearing has been requested 

will not incur any penalty or interest from and after the receipt by the Commission of 

the hearing petition. (Ref.: APC-S-6, Section VI.C.) 
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1.8 No permit revision shall be required under any approved economic incentives, marketable 

permits, emissions trading and other similar programs or processes for changes that are 

provided for in this permit. (Ref.: APC-S-6, Section III.A.8.) 

1.9 Any document required by this permit to be submitted to the DEQ shall contain a 

certification by a responsible official that states that, based on information and belief formed 

after reasonable inquiry, the statements and information in the document are true, accurate, 

and complete. (Ref.: APC-S-6, Section II.E.) 

1.10 The permittee shall allow the DEQ, or an authorized representative, upon the presentation of 

credentials and other documents as may be required by law, to perform the following: 

(a) enter upon the permittee's premises where a Title V source is located or emissionsrelated activity is conducted, or where records must be kept under the conditions of 

this permit; 

(b) have access to and copy, at reasonable times, any records that must be kept under the 

conditions of this permit; 

(c) inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under the 

permit; and 

(d) as authorized by the Federal Act, sample or monitor, at reasonable times, substances 

or parameters for the purpose of assuring compliance with the permit or applicable 

requirements. (Ref.: APC-S-6, Section III.C.2.) 

1.11 Except as otherwise specified or limited herein, the permittee shall have necessary sampling 

ports and ease of accessibility for any new air pollution control equipment, obtained after 

May 8, 1970, and vented to the atmosphere. (Ref.: APC-S-1, Section 3.9(a)) 

1.12. Except as otherwise specified or limited herein, the permittee shall provide the necessary 

sampling ports and ease of accessibility when deemed necessary by the Permit Board for air 

pollution control equipment that was in existence prior to May 8, 1970. (Ref.: APC-S-1, 

Section 3.9(b)) 

1.13 Compliance with the conditions of this permit shall be deemed compliance with any 

applicable requirements as of the date of permit issuance where such applicable requirements 

are included and are specifically identified in the permit or where the permit contains a 

determination, or summary thereof, by the Permit Board that requirements specifically 

identified previously are not applicable to the source. (Ref.: APC-S-6, Section III.F.1.) 
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1.14 Nothing in this permit shall alter or affect the following: 

(a) the provisions of Section 303 of the Federal Act (emergency orders), including the 

authority of the Administrator under that section; 

(b) the liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

(c) the applicable requirements of the acid rain program, consistent with Section 408(a) 

of the Federal Act. 

(d) the ability of EPA to obtain information from a source pursuant to Section 114 of the 

Federal Act. (Ref.: APC-S-6, Section III.F.2.) 

1.15 The permittee shall comply with the requirement to register a Risk Management Plan if 

permittee's facility is required pursuant to Section 112(r) of the Act to register such a plan. 

(Ref.: APC-S-6, Section III.H.) 

1.16 Expiration of this permit terminates the permittee's right to operate unless a timely and 

complete renewal application has been submitted. A timely application is one which is 

submitted at least six (6) months prior to expiration of the Title V permit. If the permittee 

submits a timely and complete application, the failure to have a Title V permit is not a 

violation of regulations until the Permit Board takes final action on the permit application. 

This protection shall cease to apply if, subsequent to the completeness determination, the 

permittee fails to submit by the deadline specified in writing by the DEQ any additional 

information identified as being needed to process the application. (Ref.: APC-S-6, Section 

IV.C.2., Section IV.B., and Section II.A.1.c.) 

1.17 The permittee is authorized to make changes within their facility without requiring a permit 

revision (ref: Section 502(b)(10) of the Act) if: 

(a) the changes are not modifications under any provision of Title I of the Act; 

(b) the changes do not exceed the emissions allowable under this permit; 

(c) the permittee provides the Administrator and the Department with written 

notification in advance of the proposed changes (at least seven (7) days, or such 

other time frame as provided in other regulations for emergencies) and the 

notification includes: 

(1) a brief description of the change(s), 

(2) the date on which the change will occur, 
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973 PER20050003 

(3) any change in emissions, and 

(4) any permit term or condition that is no longer applicable as a result of the 

change; 

(d) the permit shield shall not apply to any Section 502(b)(10) change. (Ref.: APCS-6, Section IV.F.) 

1.18 Should the Executive Director of the Mississippi Department of Environmental Quality 

declare an Air Pollution Emergency Episode, the permittee will be required to operate in 

accordance with the permittee's previously approved Emissions Reduction Schedule or, in 

the absence of an approved schedule, with the appropriate requirements specified in 

Regulation APC-S-3, "Regulations for the Prevention of Air Pollution Emergency Episodes" 

for the level of emergency declared. (Ref.: APC-S-3) 

1.19 Except as otherwise provided herein, a modification of the facility may require a Permit to 

Construct in accordance with the provisions of Regulations APC-S-2, "Permit Regulations 

for the Construction and/or Operation of Air Emissions Equipment", and may require 

modification of this permit in accordance with Regulations APC-S-6, AAir Emissions 

Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act@. 

Modification is defined as "[a]ny physical change in or change in the method of operation of 

a facility which increases the actual emissions or the potential uncontrolled emissions of any 

air pollutant subject to regulation under the Federal Act emitted into the atmosphere by that 

facility or which results in the emission of any air pollutant subject to regulation under the 

Federal Act into the atmosphere not previously emitted. A physical change or change in the 

method of operation shall not include: 

(a) routine maintenance, repair, and replacement; 

(b) use of an alternative fuel or raw material by reason of an order under Sections 2 (a) 

and (b) of the Federal Energy Supply and Environmental Coordination Act of 1974 

(or any superseding legislation) or by reason of a natural gas curtailment plan 

pursuant to the Federal Power Act; 

(c) use of an alternative fuel by reason of an order or rule under Section 125 of the 

Federal Act; 
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 Permit No. 1680-00025 

973 PER20050003 

(d) use of an alternative fuel or raw material by a stationary source which: 

(1) the source was capable of accommodating before January 6, 1975, unless 

such change would be prohibited under any federally enforceable permit 

condition which was established after January 6, 1975, pursuant to 40 CFR 

52.21 or under regulations approved pursuant to 40 CFR 51.166; or 

(2) the source is approved to use under any permit issued under 40 CFR 52.21 or 

under regulations approved pursuant to 40 CFR 51.166; 

(e) an increase in the hours of operation or in the production rate unless such change 

would be prohibited under any federally enforceable permit condition which was 

established after January 6, 1975, pursuant to 40 CFR 52.21 or under regulations 

approved pursuant to 40 CFR Subpart I or 40 CFR 51.166; or 

(f) any change in ownership of the stationary source." 

1.20 Any change in ownership or operational control must be approved by the Permit Board. 

(Ref.: APC-S-6, Section IV.D.4.) 

1.21 This permit is a Federally approved operating permit under Title V of the Federal Clean Air 

Act as amended in 1990. All terms and conditions, including any designed to limit the 

source's potential to emit, are enforceable by the Administrator and citizens under the 

Federal Act as well as the Commission. (Ref.: APC-S-6, Section III.B.1) 

1.22 Except as otherwise specified or limited herein, the open burning of residential, commercial, 

institutional, or industrial solid waste, is prohibited. This prohibition does not apply to 

infrequent burning of agricultural wastes in the field, silvicultural wastes for forest 

management purposes, land-clearing debris, debris from emergency clean-up operations, and 

ordnance. Open burning of land-clearing debris must not use starter or auxiliary fuels which 

cause excessive smoke (rubber tires, plastics, etc.); must not be performed if prohibited by 

local ordinances; must not cause a traffic hazard; must not take place where there is a High 

Fire Danger Alert declared by the Mississippi Forestry Commission or Emergency Air 

Pollution Episode Alert imposed by the Executive Director and must meet the following 

buffer zones. 

(a) Open burning without a forced-draft air system must not occur within 500 yards of 

an occupied dwelling. 

(b) Open burning utilizing a forced-draft air system on all fires to improve the 

combustion rate and reduce smoke may be done within 500 yards of but not within 

50 yards of an occupied dwelling. 
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(c) Burning must not occur within 500 yards of commercial airport property, private air 

fields, or marked off-runway aircraft approach corridors unless written approval to 

conduct burning is secured from the proper airport authority, owner or operator. 

(Ref.: APC-S-1, Section 3.7) 

1.23 Except as otherwise specified herein, the permittee shall be subject to the following 

provision with respect to emergencies. 

(a) Except as otherwise specified herein, an "emergency" means any situation arising 

from sudden and reasonably unforeseeable events beyond the control of the source, 

including acts of God, which situation requires immediate corrective action to restore 

normal operation, and that causes the source to exceed a technology-based emission 

limitation under the permit, due to unavoidable increases in emissions attributable to 

the emergency. An emergency shall not include noncompliance to the extent caused 

by improperly designed equipment, lack of preventative maintenance, careless or 

improper operation, or operator error. 

(b) An emergency constitutes an affirmative defense to an action brought for 

noncompliance with such technology-based emission limitations if the conditions 

specified in (c) following are met. 

(c) The affirmative defense of emergency shall be demonstrated through properly signed 

contemporaneous operating logs, or other relevant evidence that include information 

as follows: 

(1) an emergency occurred and that the permittee can identify the cause(s) of the 

emergency; 

(2) the permitted facility was at the time being properly operated; 

(3) during the period of the emergency the permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emission standards, or other 

requirements in the permit; and 

(4) the permittee submitted notice of the emergency to the DEQ within 2 

working days of the time when emission limitations were exceeded due to the 

emergency. This notice must contain a description of the emergency, any 

steps taken to mitigate emissions, and corrective actions taken. 

(d) In any enforcement proceeding, the permittee seeking to establish the occurrence 

of an emergency has the burden of proof. 

(e) This provision is in addition to any emergency or upset provision contained in any 

applicable requirement specified elsewhere herein. (Ref.: APC-S-6, Section III.G.) 

1.24 Except as otherwise specified herein, the permittee shall be subject to the following 

provisions with respect to upsets, startups, shutdowns and maintenance. 
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(a) Upsets (as defined by APC-S-1, Section 2.34) 

(1) The occurrence of an upset constitutes an affirmative defense to an 

enforcement action brought for noncompliance with emission standards or 

other requirements of Applicable Rules and Regulations or any applicable 

permit if the permittee demonstrates through properly signed 

contemporaneous operating logs, or other relevant evidence that include 

information as follows: 

(i) an upset occurred and that the permittee can identify the cause(s) of 

the upset; 

(ii) the source was at the time being properly operated; 

(iii) during the upset the permittee took all reasonable steps to minimize 

levels of emissions that exceeded the emission standards, or other 

requirements of Applicable Rules and Regulations or any applicable 

permit; 

(iv) the permittee submitted notice of the upset to the DEQ within 5 

working days of the time the upset began; and 

(v) the notice of the upset shall contain a description of the upset, any 

steps taken to mitigate emissions, and corrective actions taken. 

(2) In any enforcement proceeding, the permittee seeking to establish the 

occurrence of an upset has the burden of proof. 

(3) This provision is in addition to any upset provision contained in any 

applicable requirement. 

(b) Startups and Shutdowns (as defined by APC-S-1, Sections 2.31 & 2.26) 

(1) Startups and shutdowns are part of normal source operation. Emissions 

limitations applicable to normal operation apply during startups and 

shutdowns except as follows: 

(i) when sudden, unavoidable breakdowns occur during a startup or 

shutdown, the event may be classified as an upset subject to the 

requirements above; 

(ii) when a startup or shutdown is infrequent, the duration of excess 

emissions is brief in each event, and the design of the source is such 
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973 PER20050003 

that the period of excess emissions cannot be avoided without 

causing damage to equipment or persons; or 

(iii) when the emissions standards applicable during a startup or shutdown 

are defined by other requirements of Applicable Rules and 

Regulations or any applicable permit. 

(2) In any enforcement proceeding, the permittee seeking to establish the 

applicability of any exception during a startup or shutdown has the burden of 

proof. 

(3) In the event this startup and shutdown provision conflicts with another 

applicable requirement, the more stringent requirement shall apply. 

(c) Maintenance 

(1) Maintenance should be performed during planned shutdown or repair of 

process equipment such that excess emissions are avoided. Unavoidable 

maintenance that results in brief periods of excess emissions and that is 

necessary to prevent or minimize emergency conditions or equipment 

malfunctions constitutes an affirmative defense to an enforcement action 

brought for noncompliance with emission standards, or other regulatory 

requirements if the permittee can demonstrate the following: 

(i) the permittee can identify the need for the maintenance; 

(ii) the source was at the time being properly operated; 

(iii) during the maintenance the permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emission standards, or 

other requirements of Applicable Rules and Regulations or any 

applicable permit; 

(iv) the permittee submitted notice of the maintenance to the DEQ within 

5 working days of the time the maintenance began or such other 

times as allowed by DEQ; and 

(v) the notice shall contain a description of the maintenance, any steps 

taken to mitigate emissions, and corrective actions taken. 

(2) In any enforcement proceeding, the permittee seeking to establish the 

applicability of this section has the burden of proof. 
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(3) In the event this maintenance provision conflicts with another applicable 

requirement, the more stringent requirement shall apply. 

(Ref.: APC-S-1, Section 10) 

1.25 The permittee shall comply with all applicable standards for demolition and renovation 

activities pursuant to the requirements of 40 CFR Part 61, Subpart M, as adopted by 

reference in Regulation APC-S-1, Section 8. The permittee shall not be required to obtain a 

modification of this permit in order to perform the referenced activities. 
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SECTION 2. EMISSION POINTS & POLLUTION CONTROL DEVICES 

Emission Point Description 

AA-000 Portland Cement plant 

AA-001 Wet process cement kiln with electrostatic precipitator (Facility Reference No. s-26) 

AA-002 Clinker Cooler with baghouse (Facility Reference No. s-30) 

AA-003 Primary Crushing and handling with baghouse (Facility Reference Nos. s-5 & s-6), 

quarry drilling (Facility Reference No. s-2),quarry truck loading (Facility Reference 

No. s-3), truck unloading into primary crusher hopper (Facility Reference No. s-4), 

tunnel belt to the high rock belt transfer (Facility No. s-7) 

AA-004 Raw materials grinding and storage which includes: storage and handling of raw 

materials in the Raw Materials and the Mill building (Facility Reference Nos. s-8, s-9, 

 s-12, s-14, s-16 thru s-25), raw materials storage piles outside the raw materials 

building (Facility Reference Nos. s-10, s-11, s-13, s-15), gypsum, anhydrite, and 

clinker reclaim piles and reclaim, reclaim clinker transfer (Facility Reference Nos. s77 & s-78), sand transfer, sweet limestone, iron ore, bag shipping, bulk shipping, 

slurry thinner, grinding aid, gypsum molds, and dust emissions generated by on site 

truck traffic. 

AA-005 Coal handling and storage system (Facility Reference Nos. S-33, 34, 35 & 36) 

AA-006 Clinker Storage and handling which includes: clinker transfer system with baghouse 

(Facility Reference No. s-31), the clinker belt to east & west bucket elevators (Facility 

Reference No. s-47) and to clinker silo drag chain baghouse (Facility Reference No. 

s-49), the material (gypsum, reclaim clinker anhydrite, clinker) handling system on 

top of the clinker silos A-H with baghouse (Facility Reference Nos. s-44, s-45, s-48, 

s-50), clinker transfer system with baghouse (Facility Reference No. s-32), transfer 

from silos E,F,G, and H to weigh feeders to finish mills with baghouse (Facility 

Reference No.s-52), transfer from clinker silos A,B,C & D to the finish mill feed belt 

with baghouse (Facility Reference No. s-51) 

AA-008 Finish milling, storage, and bagging which includes: finish mill system with baghouse 

(Facility Reference No. s-53), #1 transfer from pneumatic system to cement silos with 

baghouse (Facility Reference No. s-54), #2 transfer from pneumatic system to cement 

silos with baghouse (Facility Reference No. s-55), #3 transfer from pneumatic system 

to cement silos with baghouse (Facility Reference No. s-56) 

AA-009 Shipping which includes: cement load-out to cement bin with baghouse (Facility 

Reference No. s-57), cement load-out to trucks with baghouse (Facility Reference No. 

s-58), cement load-out to trains with baghouse (Facility Reference No. s-59) 

AA-010 (IA)* Laboratory activities baghouse ( * Reclassified as Insignificant Activity in 2003) 

AA-011 Cement kiln dust handling and transfer with baghouse (Ref. Nos. s-27 & s-28) 

AA-012 Note: Formally a 7500 gallon waste fuel trailer, no longer a permitted source 
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Emission Point Description 

AA-013 Decommissioned air compressor (S-64) 

AA-014 Decommissioned air compressor (S-65) 

AA-015 0.471 MMBTUH (200 hp) auxiliary kiln drive (Facility Reference No. s-66) 

AA-016 Decommissioned water blaster (S-67) 

AA-017 Power washer (Facility Reference No. s-68) 

AA-018 #1 welder (Facility Reference No. s-69) 

AA-019 #2 welder (Facility Reference No. s-70) 

AA-020 Decommissioned welder (S-71) 

AA-021 Decommissioned concrete mixer (S-72) 

AA-022 Decommissioned castable mixer (S-73) 

AA-023 Waste fuel delivery system to kiln (Facility Reference Nos. s-76 & v-3) 

AA-024 1000 gallon gasoline storage tank (S-74) 

AA-025 The carbon canister system which controls emissions from the following storage, 

blending and burn tanks: four 39,000 gallon waste fuel tanks and two 97,000 gallon 

waste fuel tanks (Facility Reference No. s-75) 

AA-026 10 MMBTUH Vaporizer (Facility Reference No. S-79) 

AA-027 Air Compressor with a 115 Hp (0.293 MMBTUH/hr) diesel engine (Facility 

Reference No. S-84) 

AA-028 Fire Control system with a 265 Hp (0.675 MMBTUH/hr) diesel engine (Facility 

Reference No. S-85) 

AA-029 19.5 MMBTUH/hr Auxiliary generator, diesel-fired (Facility Reference No. S-86) 

AA-030 Gypsum, anhydrite and clinker reclaim system and reclaim piles (Facility Reference 

Nos. S-37 thru S-43) 

AA-031 Portable clinker loading unit (Facility Reference No. S-88) 

AA-032 Synthetic gypsum transport unit (Facility Reference No. S-89) 
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SECTION 3. EMISSION LIMITATIONS & STANDARDS 

(A) Facility-Wide Emission Limitations & Standards

3.A.1 Except as otherwise specified or limited herein, the permittee shall not cause, permit, or 

allow the emission of smoke from a point source into the open air from any manufacturing, 

industrial, commercial or waste disposal process which exceeds forty (40) percent opacity 

subject to the exceptions provided in (a) & (b). 

(a) Startup operations may produce emissions which exceed 40% opacity for up to 

fifteen (15) minutes per startup in any one-hour and not to exceed three (3) startups 

per stack in any twenty-four (24) hour period. 

(b) Emissions resulting from soot blowing operations shall be permitted provided such 

emissions do not exceed 60 percent opacity, and provided further that the aggregate 

duration of such emissions during any twenty-four (24) hour period does not exceed 

ten (10) minutes per billion BTU gross heating value of fuel in any one hour. 

(Ref.: APC-S-1, Section 3.1) 

3.A.2 Except as otherwise specified or limited herein, the permittee shall not cause, allow, or 

permit the discharge into the ambient air from any point source or emissions, any air 

contaminant of such opacity as to obscure an observer's view to a degree in excess of 40% 

opacity, equivalent to that provided in Paragraph 3.A.1. This shall not apply to vision 

obscuration caused by uncombined water droplets. (Ref.: APC-S-1, Section 3.2) 
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B. Emission Point Specific Emission Limitations & Standards

Emission 

Point(s) 

Applicable Requirement Condition 

Number(s) 

Pollutant/ 

Parameter 

Limit/Standard 

40 CFR 60, Subparts A & F 3.B.1 PM N/A 

40 CFR 61.340, Subpart FF 3.B.2 Benzene Waste 

Operations 

N/A 

40 CFR 61, Subpart V 3.B.35 VHAP N/A 

Construction Permit issued 

April 27, 1993 

3.B.3 thru 

3.B.6 

N/A N/A 

40 CFR 63, Subpart EEE 3.B.24 Hazardous 

Waste 

HAP’s 

N/A 

40 CFR 63, Subpart LLL 3.B.24 HAP’s N/A 

AA-000 

40 CFR 63, Subpart PP 3.B.36 VHAP N/A 

40 CFR 63.1204(a)(6)-(7) 

40 CFR 63.143(b)(1)-(3) 

3.B.30 PM 0.30 lb/ton of feed (dry basis) 

APC-S-1 Section 4.2(a) 3.B.21 SO2 2000 ppm 

Construction Permit 10 lbs/ton of clinker produced 

modified on August 20, 

2004. 

3.B.37 NOx 

2,625 tons/year 

Construction Permit 

modified on August 20, 

2004. 

3.B.38 Clinker 

Production 

525,000 tons of clinker per any 

consecutive 12-month period 

Construction Permit issued 

April 27, 1993 

(Changed metals to match 

HWC MACT) 

3.B.7, 

3.B.8, 

3.B.11 

thru 

3.B.13, 

3.B.22, 

and 

3.B.23 

LVM, SVM, 

Mercury, HCL, 

ash content, 

PCBs, organic 

compounds, 

heat content, Cl 

Feedrate, 

MTEC, wastederived fuel 

feed rate 

See tables below. 

AA-001 

40 CFR Part 63, Subpart 

EEE (upon notification of 

compliance and when 

hazardous waste as defined 

in §261.3 is in the 

combustion chamber (cement 

kiln). 

3.B.25 Hg 

Dioxins/Furans 

120 micrograms/dscm corrected to 7% 

O2

0.20 nanograms TEQ/dscm corrected 

to 7% O2

or 

0.40 nanograms TEQ/dscm corrected 

to 7% O2 provided combustion 

temperature is 400 °F or lower 

based on the average of the test run’s 

average temperature at inlet to the dry 

PM control device 
Page 17 of 48

 Permit No. 1680-00025 

973 PER20050003 

Emission 

Point(s) 

Applicable Requirement Condition 

Number(s) 

Pollutant/ 

Parameter 

Limit/Standard 

3.B.25 

(Continued) 

Lead/Cadmium 

(Semivolatile 

Metals) 

Arsenic, 

beryllium, and 

chromium 

(Low Volatile 

Metals) 

330 micrograms/dscm combined 

emissions corrected to 7% O2

56 micrograms/dscm corrected to 7% 

O2 

3.B.26 CO 

or 

THC 

100 ppm by volume over an hourly 

average on dry basis corrected to 7% 

O2

20 ppm by volume over an hourly 

average on a dry basis corrected to 7% 

O2

3.B.27 HCl and Cl2 130 ppm by volume combined 

emissions expressed as HCl 

equivalents on a dry basis, corrected 

to 7% O2

3.B.27 and 

3.B.29 

Opacity 20% 

3.B.28 DRE 99.99% for each POHC designated 

40 CFR Part 63, Subpart 

EEE (upon notification of 

compliance and when 

hazardous waste as defined 

in §261.3 is in the 

combustion chamber (cement 

kiln). 

3.B.33 Combustion 

System Leaks 

Control combustion system leaks of 

HAP 

3.B.29 Dioxins/Furans 0.20 nanograms/dscm (8.7x10-11 

gr/dscf) TEQ corrected to 7% O2

or 

0.40 nanograms TEQ/dscm corrected 

to 7 % O2 provided combustion 

temperature is 400F or lower based 

on the average of the test run’s 

average temperature at the inlet to the 

dry PM control device 

AA-001 

(Continued) 

40 CFR Part 63, Subpart 

LLL (upon notification of 

compliance and during 

periods that non-hazardous is 

being feed to the cement 

kiln) 

3.B.32 Waste Derived 

Fuel 

Automatic cutoff mechanism so that 

the waste derived fuel is automatically 

shut off when certain conditions occur 

AA-002 40 CFR 63, Subpart LLL 3.B.30 PM 0.050 kg/Mg (0.10 lb/ ton) of feed on 

dry basis to kiln 

AA-002 

AA-006, 

AA-008, 

AA-009, 

AA-011, 

AA-030, 

AA-031, 

AA-032 

APC-S-1, Section 3.6(a) 3.B.15 

& 

1.19 

PM E = 4.1p.0.67

or 

as otherwise limited by facility 

modification restrictions 
Page 18 of 48

 Permit No. 1680-00025 

973 PER20050003 

Emission 

Point(s) 

Applicable Requirement Condition 

Number(s) 

Pollutant/ 

Parameter 

Limit/Standard 

AA-002, 

AA-004, 

AA-006, 

AA-008, 

AA-009, 

AA-011, 

AA-030, 

AA-031, 

AA-032 

40 CFR 63, Subpart LLL 

(Emission point AA-010 is 

excluded from 40 CFR 63, 

Subpart LLL) 

3.B.31 Opacity < 10% 

APC-S-1, Section 3.4.A.1 3.B.16 

& 

1.19 

PM 0.6 lbs/MMBTUH 

or 

as otherwise limited by facility 

modification restrictions 

AA-015, 

AA-017, 

AA-018, 

AA-019, 

AA-027, 

AA-028 

APC-S-1, Section 4.1(a) 3.B.17 

& 

1.19 

SO2 4.8 lbs/MMBTUH 

or 

as otherwise limited by facility 

modification restrictions 

Construction Permit issued 

April 27, 1993 

3.B.9, 

3.B.10, 

3.B.14 

AA-025 Fuel See conditions for fuel restrictions 

40 CFR 61.240 (40 CFR 63, 

Subpart V) 

3.B.35 VHAP Equipment Leak Standards 

AA-026 APC-S-1, Section 4.1(a) 3.B.17 SO2 4.8 lbs/MMBTU 

and 

AA-029 APC-S-1, Section 3.4(a)2 3.B.34 PM E = 0.8808 * I-0.1667

3.B.1 The permittee is subject to and shall comply with the New Source Performance Standards for 

Portland Cement Plants as defined in 40 CFR 60, Subpart A – General Provisions and 40 

CFR 60, Subpart F, including the continuous opacity monitoring as defined in 40 CFR 60.63. 

 (Ref.: 40 CFR 60.63. 40 CFR 63, Subpart LLL subsumes 40 CFR 60, Subpart F) 

3.B.2 The permittee is subject to and shall comply with the National Emission Standard for 

Benzene Waste Operations as defined in 40 CFR 61.340, Subpart FF. (Appendix C) 

 (Ref.: 40 CFR 61.340. FF exempts 40 CFR 63, Part DD) 

3.B.3 Condition moved to 5.B.41. 

3.B.4 Condition moved to 5.B.42. 

3.B.5 Condition moved to 5.B.43. 
Page 19 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.6 The permittee shall minimize dust from truck traffic on unpaved access and in-plant roads by 

water sprinkling or equivalent when conditions warrant. 

 (Ref.: Construction Permit issued on April 27, 1993) 

3.B.7 For Emission Point AA-001, while hazardous waste-derived fuel is being fired, the permittee 

shall not discharge or cause combustion gases to be emitted into the atmosphere pollutants 

per the following table: 

POLLUTANT MAXIMUM EMISSIONS REGULATION 

CITATION(S)

Low-Volatile Metals, including 

Arsenic, Beryllium, and 

Chromium 

56 μg/dscm, combined emissions, corrected 

to 7% oxygen 

40 CFR 63.1204(a)(4) 

Semi-Volatile Metals, including 

Lead and Cadmium 

330 μg/dscm, combined emissions, corrected 

to 7% oxygen 

40 CFR 63.1204(a)(3) 

Mercury 120 μg/dscm, corrected to 7% oxygen 40 CFR 63.1204(a)(2) 

Hydrogen Chloride, 

Hydrochloric Acid and Chlorine 

Gas (expressed as Hydrochloric 

Acid Equivalents) 

130 ppm by volume, dry basis, combined 

emissions, corrected to 7% oxygen 

40 CFR 63.1204(a)(6) 

Organic Compounds 0.01% of the quantities in the waste derived 

fuel 

Construction Permit issued on 

April 27, 1993 

Particulate Matter 0.15 kg per MG of feed, dry basis 40 CFR 63.1204(a)(7) 

Opacity 20% 40 CFR 63.1204(a)(7) 

Dioxins and Furans 0.20 nanograms TEQ/dscm, corrected to 7% 

oxygen, or 

0.40 nanograms TEQ/dscm corrected to 7 

percent oxygen provided that the combustion 

gas temperature at the inlet to the initial dry 

particulate matter control device is 400 

degrees Fahrenheit or lower based on the 

average test run average temperatures 

40 CFR 63.1204(a)(1) 

(Ref: 40 CFR 63.1204(a)(1-7), Subpart EEE. Part EEE subsumes 40 CFR 63. 1343, Part LLL) 
Page 20 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.8 For Emission Point AA-001, the permittee is allowed to burn hazardous waste derived 

fuel, tire derived fuel, petroleum coke, hazardous and/or non-hazardous (supplemental 

fuel), that meets the following specifications for each type of fuel in the rotary kiln 

(Emission Point 001). 

Hazardous Waste Fuel Specifications 

Constituent As-Burned Specification 

Heat Content, Btu/lb > 8000 

Ash, % < 20.0 

PCB's, ppm <50 

Non-hazardous Waste Fuel Specifications 

(e.g. tire-derived fuel, used oil, and other solid & liquid fuels 

Constituent As-Burned Specification 

Heat Content, Btu/lb > 5000 

Ash, % < 40.0 

In addition, the feed rates of the following constituents shall be limited on a 12-hour 

rolling average basis as indicated below: 

Operating Parameter Units HWC MACT 

Limit Basis 

Maximum Chlorine Feed Rate 12-HRA g/hr < 222,962 2001 CP Test 

12-HRA lb/hr < 491.6 2001 CP Test 

Maximum Low-volatility metals (LVM) from 12-HRA g/hr <16,356 2001 CP Test 

all feed streams 

12-HRA lb/hr < 36.1 2001 CP Test 

Maximum Low-volatility metals (LVM) from 12-HRA g/hr < 14,110 2001 CP Test 

pumpable feed streams 

12-HRA lb/hr < 31.1 2001 CP Test 

Maximum Semi-volatile metals (SVM) from 12-HRA g/hr < 23,587 2001 CP Test 

all feed streams 

12-HRA lb/hr < 52.0 2001 CP Test 

Maximum mercury (MTEC) emission limit 

from HWDF only based on current stack 

flow and Hg mass feed rate 

12-HRA μg/dscm < 120 HWM MACT Rule

(Ref.: 40 CFR 63.1204) (Note: Feed rates match those in Subpart EEE, HWC MACT) 
Page 21 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.9 For Emission Point AA-025, hazardous waste derived fuel must be obtained in bulk 

quantities (tank truck or railcar) from distributors, marketers, and/or generators subject to 

and in compliance with all requirements of Mississippi and USEPA regulations and 

standards promulgated for marketers and/or generators of hazardous waste derived fuel. 

Hazardous waste fuel may only be accepted directly from generators with a current Waste 

Pre-Qual Form on file at the facility. 

 (Ref.: Construction Permit issued on April 27, 1993) 

3.B.10 Prohibition on burning dioxin-listed wastes. The permittee shall accept only those Hazardous 

Wastes permitted by RCRA Permit No. MSD077655876. 

(Ref.: Construction Permit issued on April 27, 1993 and Miss. Hazardous Waste 

Management Regulation (MHWMR) Part 261) 

3.B.11 For Emission Point AA-001, the permittee shall not fire waste derived fuel at a rate to 

exceed 57 gal/min on an hourly rolling average or a volume to exceed 28,770,000 gal/yr. 

Records shall be maintained to document the waste derived fuel rate and cumulative volume 

consumed for each calendar year. The permittee shall submit a semi-annual report stating 

the maximum fuel rate in gallons/hour for each period and the total quantity of waste 

derived fuel burned during that period. 

 (Ref.: Construction Permit issued on April 27, 1993) 

3.B.12 For Emission Point AA-001, an automatic shutoff shall be installed such that waste derived 

fuel is automatically shut off when any of the following conditions occur: 

(a) The kiln's ID fan stops. 

(b) The carbon monoxide concentration at the kiln feed end is greater than 1% for more 

than 60 seconds. 

(c) [THIS CONDITION INTENTIONALLY LEFT BLANK.] 

(d) The kiln's rotation stops for more than 60 seconds. 

(e) The oxygen concentration at the kiln’s stack is less than 0.5% for more than 60 

seconds. 

(f) The electrostatic precipitator malfunctions or is de-energized for more than 60 

seconds. 

(g) The raw material feed to the kiln is less 78 TPH on an hourly rolling average. 

 (Ref.: Construction Permit issued on April 27, 1993) 

3.B.13 During startup, shutdown, or unstable kiln conditions, hazardous waste derived fuel shall not 

be fired until the kiln reaches normal operating temperatures. 

 (Ref.: Construction Permit issued on April 27, 1993) 
Page 22 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.14 Any spillage from the unloading of waste derived fuel at the receiving area shall be promptly 

managed in accordance with the requirements of the Resource Conservation and Recovery 

Act. 

 (Ref.: Construction Permit issued on April 27, 1993) 

3.B.15 Except as otherwise specified, Emission Points AA-002 thru AA-006, AA-008, AA-009, 

AA-011, AA-030, AA-031 and AA-032 shall not cause, permit, or allow the emission from 

any manufacturing process, in any one hour from any point source, particulate matter in total 

quantities in excess of the amount determined by the relationship: 

E = 4.1 p 0.67

where E is the emission rate in pounds per hour and p is the process weight input rate in 

tons per hour. 

Conveyor discharge of coarse solid matter may be allowed if no nuisance is created beyond 

the property boundary where the discharge occurs. 

 (Ref.: APC-S-1. Section 3.6(a)) 

3.B.16 For Emission Points AA-015, AA-017, AA-018, AA-019, AA-027, and AA-028, the 

permittee shall not allow particulate emissions from installations of less than 10 million 

BTU per hour heat input to exceed 0.6 pounds per million BTU per hour heat input. 

 (Ref.: APC-S-1, Section 3.4,A.1) 

3.B.17 For Emission Points AA-015, AA-017, AA-018, AA-019, AA-026, AA-027, AA-028, and 

AA-029, the permittee shall not allow the maximum discharge of sulfur oxides from any 

fuel burning installation in which the fuel is burned primarily to produce heat or power by 

indirect heat transfer to exceed 4.8 pounds (measured as sulfur dioxide) per million BTU 

heat input. 

 (Ref.: APC-S-1, Section 4.1(a)) 

3.B.18, 3.B.19, and 3.B.20 Removed in modification on December 29, 2004. 

3.B.21 Emission Point AA-001 shall not cause or permit the emission of gas containing sulfur 

oxides (measured as sulfur dioxide) in excess of 2,000 ppm (volume). 

 (Ref.: APC-S-1, Section 4.2(a)) 

3.B.22 The permittee shall not burn any radioactive waste. 

 (Ref.: Construction Permit issued on April 27, 1993) 
Page 23 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.23 For Emission Point AA-001, the rotary kiln, the permittee can substitute alternative raw 

materials or fuel provided it meets the definition of non-hazardous material. However, 

written notification must be provided to the DEQ prior to using the alternative raw material 

or fuel. If the use of the raw material or fuel will result in a significant emissions increase 

(as defined in APC-S-5 or more specifically defined in 40 CFR 52.21(b)(23)) of any 

pollutant regulated under the Clean Air Act, or a physical modification is required, then a 

construction permit must be obtained and the Title V Operating permit must be modified 

prior to using the alternative raw material or fuel. 

 (Ref.: Construction Permit issued on April 27, 1993) 

3.B.24 The permittee is subject to and shall comply with the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, 40 

CFR Part 63, Subpart LLL and the General Provisions, 40 CFR Part 63, Subpart A. When 

hazardous waste, as defined by 40 CFR §261.3 is introduced into the combustion chamber of 

the cement kiln, the permittee shall comply with the NESHAP for Hazardous Waste 

Combustors, 40 CFR Part 63, Subpart EEE. 

3.B.25 This condition is intentionally left blank. 

3.B.26 For Emission Point AA-001, while hazardous waste-derived fuel is being fired, the permittee 

shall limit: 

(a) Hydrocarbons in the main stack in excess of 20 parts per million by volume, over an 

hourly rolling average (monitored continuously with a continuous emissions 

monitoring system), dry basis, corrected to 7 percent oxygen, and reported as 

propane; or 

(b) Carbon monoxide in the main stack in excess of 100 parts per million by volume, 

over an hourly rolling average (monitored continuously with a continuous emissions 

monitoring system), dry basis and corrected to 7 percent oxygen. 

 (Ref.: 40 CFR § 63.1204(a)(5)(ii)(A)-(B), Subpart EEE) 

3.B.27 This condition is intentionally left blank. 

3.B.28 For Emission Point AA-001, the permittee shall achieve a destruction and removal efficiency 

(DRE) of 99.99 percent for each principle organic hazardous constituent (POHC). 

 (Ref.: 40 CFR §63.1204(c), Subpart EEE) 

3.B.29 This condition is intentionally left blank. 
Page 24 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.30 For Emission Point AA-002, the permittee shall not discharge to the atmosphere any gases 

which contain particulate matter (PM) in excess of 0.050 kg per MG of feed, dry basis. 

(Ref.: 40 CFR §63.1345, Subpart LLL. LLL subsumes 40 CFR 60, Part F. LLL subsumes 

40 CFR §63.1204(a)(1-7), Subpart EEE.) 

3.B.31 For Emission Points AA-002, AA-004, AA-006, AA-008, AA-009, AA-011, AA-030, AA031, and AA-032 the permittee shall not cause to be discharged any gases which exhibit 

opacity greater than 10 percent. 

 (Ref.: 40 CFR §63.1348, Subpart LLL. LLL subsumes 40 CFR 60, Part F) 

3.B.32 For Emission Point AA-001, the permittee shall install an automatic cutoff mechanism so 

that the hazardous waste-derived fuel is automatically shut off when any of the following 

conditions occur: 

(a) When any operating parameter limit specified under 40 CFR §63.1209 is exceeded; 

(b) When any emissions standard monitored by a CEMS is exceeded; 

(c) When the allowable combustion chamber pressure is exceeded; 

(d) When the span value of any CMS detector, except a CEMS, is met or exceeded; 

(e) Upon malfunction of a CMS monitoring an operating parameter limit or an emissions 

level; 

(f) When any component of the automatic waste feed cut-off system (AWFCO) system 

fails. 

 (Ref.: 40 CFR §63.1206(c)(3), Subpart EEE) 

3.B.33 For Emission Point AA-001, the permittee shall control combustion system leaks of HAP in 

accordance with the requirements of 40 CFR 63.1206(c)(5). 

 (Ref.: 40 CFR §63.1206(c)(5), Subpart EEE, as seen in Appendix D) 

3.B.34 Emission Points AA-026 and AA-029 shall not exceed a particulate matter emission rate as 

determined by the relationship 

E = 0.8808 * I -0.1667 

where E is the emission rate in pounds per million BTU per hour heat input and I is the heat 

input in millions of BTU per hour. 

 (Ref.: APC-S-1, Section 3.4(a)2) 
Page 25 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.35 The permittee shall comply with all applicable standards for equipment leaks pursuant to the 

requirements of National Emission Standard for Equipment leaks (Fugitive Emission 

Sources) 40 CFR Part 61, Subpart V, as seen in Appendix E. 

(a) Each piece of equipment to which 40 CFR 61, Subpart V applies shall be marked in 

such manner that it can be distinguished readily from other pieces of equipment. 

(Ref.: 40 CFR 61.242-1(d)) 

(b) Each pump to which 40 CFR 61, Subpart V applies shall be checked by visual 

inspection each calendar week for indications of liquids dripping from the pump seal. 

(Ref.: 40 CFR 61.242-2(a)(2)) 

(c) For each pump to which 40 CFR 61, Subpart V applies and when a pump leak is 

detected, it shall be repaired as soon as practicable, but not later than 15 calendar 

days after it is detected, except as provided in Sec. 61.242-10. 

(Ref.: 40 CFR 61.242-2(c)(1)) 

(d) For each pump to which 40 CFR 61, Subpart V applies, a first attempt at a pump leak 

repair shall be made no later than 5 calendar days after each leak is detected. 

(Ref.: 40 CFR 61.242-2(c)(2)) 

(e) Each sampling connection system shall be equipped with a closed-purge, closedloop, or closed-vent system, except as provided in Sec. 61.242-1(c). Gases displaced 

during filling of the sample container are not required to be collected or captured. 

(Ref.: 40 CFR 61.242-5(a)) 

(f) Each closed-purge, closed-loop, or closed-vent system as required in E of this section 

shall collect and recycle the purged process fluid. 

(Ref.: 40 CFR 61.242-5(b)(2)) 

(g) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a 

second valve. The cap, blind flange, plug, or second valve shall seal the open end at 

all times except during operations requiring process fluid flow through the openended valve or line. Each open-ended valve or line equipped with a second valve 

shall be operated in a manner such that the valve on the process fluid end is closed 

before the second valve is closed. When a double block and bleed system is being 

used, the bleed valve or line may remain open during operations that require venting 

the line between the block valves but shall comply with paragraph 40 CFR 61.242-

6(a) at all other times. 

(Ref.: 40 CFR 61.242-6(a)(1) and (2)) 
Page 26 of 48

 Permit No. 1680-00025 

973 PER20050003 

(h) Each valve shall be monitored monthly to detect leaks by the method specified in 

Sec. 61.245(b). When a leak is detected, it shall be repaired as soon as practicable, 

but no later than 15 calendar days after the leak is detected, except as provided in 

§61.242-10. The first attempt at repair shall be made no later than 5 calendar days 

after each leak is detected. 

(Ref.: 40 CFR 61.242-7) 

(i) If evidence of a potential leak is found by visual, audible, olfactory, or any other 

detection method at pressure relief devices in liquid service and connectors, the 

owner or operator shall monitor the equipment within 5 days by the method specified 

in Sec. 61.245(b). If an instrument reading of 10,000 ppm or greater is measured, a 

leak is detected. When a leak is detected, it shall be repaired as soon as practicable, 

but not later than 15 calendar days after it is detected, except as provided in Sec. 

61.242-10. The first attempt at repair shall be made no later than 5 calendar days 

after each leak is detected. First attempts at repair include, but are not limited to, the 

best practices described under Sec. 61.242-7(e). 

(Ref.: 40 CFR 61.242-8) 

(j) Vapor recovery systems shall be designed and operated to recover the organic vapors 

vented to them with an efficiency of 95 percent or greater, or to an exit concentration 

of 20 parts per million by volume, whichever is less stringent. 

(Ref.: 40 CFR 61.242-11(b)) 

(k) Leaks, as indicated by an instrument reading greater than 500 parts per million by 

volume above background or by visual inspections, shall be repaired as soon as 

practicable. A first attempt at repair shall be made no later than 5 calendar days after 

the leak is detected. Repair shall be completed no later than 15 calendar days after 

the leak is detected. 

(Ref.: 40 CFR 61.242-11(g)) 

(l) Closed vent systems and control devices used to comply with provisions of 40 CFR 

61, Subpart V shall be operated at all times when emissions may be vented to them. 

(Ref.: 40 CFR 61.242-11(m)) 

3.B.36 The permittee shall comply with all applicable standards pursuant to the requirements of 

National Emission Standards for Containers, 40 CFR 63, Subpart PP, as seen in Appendix G. 

 (Ref.: 40 CFR 63.920) 
Page 27 of 48

 Permit No. 1680-00025 

973 PER20050003 

3.B.37 The permittee is authorized to operate Emission Point AA-001 in accordance with the 

following emission limitation: 

Nitrogen Oxides 10 lbs/ton of clinker produced, not to exceed 2,625 tons/year, 

as determined by EPA Reference Method 20, 40 CFR 60, 

Appendix A, based on a 12-month rolling average. 

 (Ref.: Construction Permit issued on April 27, 1993, and modified August 20, 2004) 

3.B.38 For Emission Point AA-001, the permittee shall limit clinker production to no more than 

525,000 tons of clinker per any consecutive 12-month period. 

 (Ref.: Construction Permit modified August 20, 2004) 

3.B.39 For Emission Point AA-001, the AWFCO system required in 3.B.32 and associated alarms 

must be tested at least weekly to verify operability. 

 (Ref.: 40 CFR § 63.1206(c)(3)(vii)) 

3.B.40 If it is determined that an emission standard has been exceeded during a comprehensive 

performance test or a confirmatory performance test required in Condition 5.B.2, the 

permittee shall immediately cease any burning of hazardous waste. Refer to 40 CFR 

63.1207(l) for conditions and steps necessary to resume burning of hazardous waste. 

 (Ref.: 40 CFR 63.1207(l)) 
Page 28 of 48

 Permit No. 1680-00025 

973 PER20050003 

C. Insignificant and Trivial Activity Emission Limitations & Standards

Applicable Requirement Condition 

Number(s) 

Pollutant/ 

Parameter 

Limit/Standard 

APC-S-1, Section 3.6(a) 3.C.1 

& 

1.19 

PM E = 4.1 p 0.67

or as otherwise limited by facility 

modification restrictions 

APC-S-1, Section 3.4(a)(1) 3.C.2 

& 

1.19 

PM 0.6 lbs/MMBTU, or 

as otherwise limited by facility 

modification restrictions 

APC-S-1, Section 4.1(a) 3.C.3 

& 

1.19 

SO2 4.8 lbs/MMBTU, or 

as otherwise limited by facility 

modification restrictions 

3.C.1 The maximum permissible emission of particulate matter shall not exceed in one hour the 

total quantities determined by the relationship: 

E = 4.1 p0.67 

Where E is the emission rate in lbs/hr and p is the process weight input rate in tons/hr. 

3.C.2 The maximum permissible emission of ash and/or particulate matter from fossil fuel burning 

installations of less than 10 million BTU per hour heat input shall not exceed 0.6 pounds per 

million BTU per hour heat input. 

3.C.3 The maximum discharge of sulfur oxides from any fuel burning installation in which the fuel 

is burned primarily to produce heat or power by indirect heat transfer shall not exceed 4.8 

pounds (measured as sulfur dioxide) per million BTU heat input. 
Page 29 of 48

 Permit No. 1680-00025 

973 PER20050003 

D. Work Practice Standards

Emission 

Point(s) 

Applicable Requirement Condition 

Number(s) 

Pollutant/ 

Parameter

Limit/Standard 

AA-000 Construction Permit issued 

on April 27, 1993 

3.D.1 Hazardous 

Waste 

N/A 

3.D.1 All plant personnel responsible for handling hazardous waste shall have training in 

hazardous waste spill control and containment to provide rapid response and cleanup of 

hazardous waste spills occurring within the plant site. 

 (Ref.: Construction Permit issued on April 27, 1993) 
Page 30 of 48

 Permit No. 1680-00025 

973 PER20050003 

SECTION 4. COMPLIANCE SCHEDULE 

4.1 Unless otherwise specified herein, the permittee shall be in compliance with all 

requirements contained herein upon issuance of this permit. 

4.2 Except as otherwise specified herein, the permittee shall submit to the Permit Board and 

to the Administrator of EPA Region IV a certification of compliance with permit terms 

and conditions, including emission limitations, standards, or work practices, by January 

31 for the preceding calendar year. Each compliance certification shall include the 

following: 

(a) the identification of each term or condition of the permit that is the basis of the 

certification; 

(b) the compliance status; 

(c) whether compliance was continuous or intermittent; 

(d) the method(s) used for determining the compliance status of the source, currently 

and over the applicable reporting period; 

(e) such other facts as may be specified as pertinent in specific conditions elsewhere 

in this permit. (Ref.: APC-S-6, Section III.C.5.a.,c.,&d.) 
Page 31 of 48

 Permit No. 1680-00025 

973 PER20050003 

SECTION 5. MONITORING, RECORDKEEPING & REPORTING 

REQUIREMENTS 

A. General Monitoring, Recordkeeping and Reporting Requirements

5.A.1 The permittee shall install, maintain, and operate equipment and/or institute procedures as 

necessary to perform the monitoring and recordkeeping specified below. 

5.A.2 In addition to the recordkeeping specified below, the permittee shall include with all records 

of required monitoring information the following: 

(a) the date, place as defined in the permit, and time of sampling or measurements; 

(b) the date(s) analyses were performed; 

(c) the company or entity that performed the analyses; 

(d) the analytical techniques or methods used; 

(e) the results of such analyses; and 

(f) the operating conditions existing at the time of sampling or measurement. 

(Ref.: APC-S-6, Section III.A.3.b.(1)(a)-(f)) 

5.A.3 Except as otherwise specified herein, the permittee shall retain records of all required 

monitoring data and support information for a period of at least five (5) years from the date 

of the monitoring sample, measurement, report, or application. Support information includes 

all calibration and maintenance records, all original strip-chart recordings for continuous 

monitoring instrumentation, and copies of all reports required by the permit. (Ref.: APC-S6, Section III.A.3.b.(2)) 

5.A.4 Except as otherwise specified herein, the permittee shall submit reports of any required 

monitoring by July 31 and January 31 for the preceding six-month period. All instances of 

deviations from permit requirements must be clearly identified in such reports and all 

required reports must be certified by a responsible official consistent with APC-S-6, Section 

II.E. (Ref.: APC-S-6, Section III.A.3.c.(1)) 

5.A.5 Except as otherwise specified herein, the permittee shall report all deviations from permit 

requirements, including those attributable to upsets, the probable cause of such deviations, 

and any corrective actions or preventive measures taken. Said report shall be made within 

five (5) days of the time the deviation began. (Ref.: APC-S-6, Section III.A.3.c.(2)) 

5.A.6 Except as otherwise specified herein, the permittee shall perform emissions sampling and 

analysis in accordance with EPA Test Methods and with any continuous emission 

monitoring requirements, if applicable. All test methods shall be those versions or their 

equivalents approved by the DEQ and the EPA. 

5.A.7 The permittee shall maintain records of any alterations, additions, or changes in equipment 

or operation. 
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 Permit No. 1680-00025 

973 PER20050003 

B. Specific Monitoring and Recordkeeping Requirements

5.B.1 Detailed records shall be maintained at the plant site for the purposes of accomplishing the 

items listed below: 

(a) Every burn tank containing waste-derived fuel shall be analyzed for the items in 

Paragraph 3.B.8, including aroclor 1242, 1248, 1254, and 1260 (PCB's). 

(b) Additionally, once per quarter a sample shall be taken from a randomly selected 

truck load or railcar of hazardous waste derived fuel and analyzed for each 

constituent listed in Paragraph 3.B.8, as well as the solvent screen analysis in 

accordance with EPA Method 8000 and 8015, or their equivalent and for dioxins and 

furans. 

(c) The permittee shall submit a semi-annual report consisting of a summary of all 

analyses performed during the period. The report shall be submitted no later than 30 

days after the end of the reporting period. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.2 The following conditions apply with regard to demonstration of compliance: 

(a) The permittee must conduct comprehensive performance tests to demonstrate 

compliance with the emission standards provided by §63.1204 and establish limits 

for the operating parameters provided by §63.1209, and demonstrate compliance 

with the performance specifications for continuous monitoring systems. 40 CFR 

63.1207(b)(1) The emission standards provided by §63.1204 are outlined in the table 

below and compliance must be demonstrated during the comprehensive performance 

test: 

Standard HWC MACT Standard Regulatory Citation

Destruction and Removal Efficiency (DRE) > 99.99% 40 CFR 63.1204(c) 

Hydrocarbons (at 7% oxygen) < 20 ppm 40 CFR 63.1204(a)(5)(ii)(A) 

Dioxin / Furans 0.2 μg/dscm, 

or 

< 0.4 μg/dscm at < 400 °F APCD inlet 

temp. 

40 CFR 63.1204(a)(1)(ii) 

Particulate matter < 0.15 kg/Mg dry feed 40 CFR 63.1204(a)(7) 

Opacity (as monitor of PM and ESP 

performance) 

< 20% 40 CFR 63.1204(a)(7) 

SVMs – (Lead & Cadmium) < 330 μg/dscm 40 CFR 63.1204(a)(3) 

LVMs – (Arsenic, Beryllium, & Chromium) < 56 μg/dscm 40 CFR 63.1204(a)(4) 

Mercury < 120 μg/dscm MTEC 

from HWDF only 

40 CFR 63.1204(a)(2) 

Hydrochloric acid and chlorine gas (as HCL) < 130 ppmv 40 CFR 63.1204(a)(6) 
Page 33 of 48

 Permit No. 1680-00025 

973 PER20050003 

Minimum kiln pressure drop < 0 inches water column 40 CFR 63.1206(c)(5)(i) 
Page 34 of 48

 Permit No. 1680-00025 

973 PER20050003 

(b) The permittee must conduct confirmatory performance tests to demonstrate 

compliance with the dioxin/furan emission standard when the source operates under 

normal operating conditions; and conduct a performance evaluation of continuous 

monitoring systems required for compliance assurance with the dioxin/furan 

emission standard under §63.1209(k). The emission standards provided by §63.1204 

and §63.1209 are outlined in the table below: 

Pollutant Emission Limit / Requirement Regulation Citation 

Dioxins and 

Furans 

< 0.2 μg/dscm, or

< 0.4 μg/dscm at < 400 °F APCD inlet temp. 

40 CFR 63.1204(a)(1)(ii) 

Minimum 

combustion 

chamber 

temperature 

1. Measure the temperature of each combustion chamber at a location 

that best represents, as practicable, the bulk gas temperature in the 

combustion zone. 

2. Document the temperature measurement location in the test plan you 

submit under §63.1207(e) and (f). 

3. Establish a minimum hourly rolling average limit as the average of 

the test run averages. 

40 CFR 63.1209(k)(2)(i) 

40 CFR 63.1209(k)(2)(ii) 

Maximum flue gas 

flow rate or 

production rate 

1. As an indicator of gas residence time in the control device, establish 

and comply with a limit on the maximum flue gas flow rate, the 

maximum production rate, or another parameter that is documented in 

the site-specific test plan as an appropriate surrogate for gas residence 

time, as the average of the maximum hourly rolling averages for each 

run. 

2. Comply with this limit on a hourly rolling average basis. 

40 CFR 63.1209(k)(3)(i) 

40 CFR 63.1209(k)(3)(ii) 

Maximum 

hazardous 

waste feed rate 

1. Establish limits on the maximum pumpable and total (pumpable and 

non-pumpable) hazardous waste feed rate for each location where waste 

is fed. 

2. Establish the limits as the average of the maximum hourly rolling 

averages for each run. 

3. Comply with the feed rate limit(s) on a hourly rolling average basis. 

40 CFR 63.1209(k)(4)(i) 

40 CFR 63.1209(k)(4)(ii) 

40 CFR 63.1209(k)(4)(iii) 

(c) The permittee shall comply with the testing schedule as outlined in the table 

below: 

Date Type of Performance Test 

September 1, 2000 Trial Burn, in Lieu of Initial Comprehensive Performance Test 

October 15, 2006 Initial Confirmatory Performance Test (37 months after compliance date, 

September 15, 2003) 

September 1, 2006 Subsequent Comprehensive Performance Test (61 months after initial 

comprehensive test) 

April 1, 2009 Confirmatory Performance Test (31 months after previous comprehensive 

performance test) 

(Ref.: 40 CFR 63.1207) 
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 Permit No. 1680-00025 

973 PER20050003 

(d) In the event the permittee is unable to perform the test required herein within the 

time periods stated because of conditions beyond the control of the permittee, the 

Mississippi Department of Environmental Quality shall be authorized to extend the 

time periods for conducting the test for a period of up to 90 days. 

5.B.3 When burning waste derived fuel, the permittee shall continuously monitor and record the 

following: 

(a) coal feed rate and petroleum coke feed rate 

(b) supplemental fuel feed rate 

(c) kiln burn zone temperature 

(d) oxygen content in the exhaust at the kiln stack 

(e) carbon monoxide content downstream of the electrostatic precipitator by a 

continuous monitor meeting EPA Performance Specification 4 

(f) kiln discharge end draft (pressure) 

(g) inlet feed rate of each constituent for which there is a feed rate limit identified in 

3.B.8 

(h) total hydrocarbons 

The permittee shall maintain calibration and audit procedures and schedules for all 

instrumentation required for continuously monitoring items 5.B.3(a) through 5.B.3(h) at the 

site. 

The permittee shall submit a semi-annual report which identifies the date, time and 

magnitude of the maximum one-minute average CO concentration during the month and the 

date, time, and magnitude of the maximum hourly average CO concentration during the 

month. 

 (Ref.: Construction Permit issued on April 27, 1993 and 40 CFR § 63.1209(a)(1)(i)) 

5.B.4 Each shipment of hazardous waste derived fuel shall be manifested as to its composition and 

said manifest shall be kept on site for at least three years from the date of delivery. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.5 A downtime record for the electrostatic precipitator shall be kept in a log suitable for 

inspection by the Department of Environmental Quality personnel for a period of not less 

than three years after any given downtime. Additionally, the permittee shall submit a 

monthly report stating the date, time, duration, and cause of electrostatic precipitator 

malfunctions that exceed six (6) minutes. The report shall be due within fifteen (15) days of 

the end of the reporting period. 

 (Ref.: Construction Permit issued on April 27, 1993) 
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 Permit No. 1680-00025 

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5.B.6 All lines and equipment while in contact with the waste derived fuel containing hazardous 

waste shall be visually inspected at least once per day for leaks. All leaks in the burn area 

shall be controlled promptly and shall be repaired within 24 hours of detection and all spills 

exceeding 10 gallons or the EPA reportable quantity specified under 40 CFR Parts 117 & 

302 shall be reported to the Department of Environmental Quality within 24 hours of 

occurrence. Any leaks detected outside the burn area shall be documented and within five 

(5) days of detection attempts will be made to repair the defect(s). All repairs must be 

completed within 15 days of initial detection. A leak inspection and spill log shall be 

maintained to permanently record the aforementioned requirements and be made available 

for inspection for at least five years. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.7 The permittee shall retain all records, data, and analysis for the Department of 

Environmental Quality review for a period of at least five years. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.8 Condition removed on December 29, 2004. 

5.B.9 The permittee shall conduct soils testing annually to determine the soil concentration of 

arsenic, beryllium, cadmium, hexavalent chromium, lead, and mercury at locations 

designated by the Department of Environmental Quality. Soil testing will consist of four 

(4) four-foot deep sample cores. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.10 The permittee shall provide a sampling plan prior to the acceptance of any waste derived 

fuel that assures representative sampling of the waste derived fuel. Additionally, the 

sampling of the waste derived fuel shall be done by using a "modified" composite liquid 

waste sampler (COLIWASA) or other approved device to assure representative sampling of 

the tanker truck or railcar bottom sludges as well as the liquid waste derived fuel. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.11 The cement kiln dust shall be sampled and analyzed on a periodic basis to ensure it 

continues to meet the Bevil exemption as defined by 40 CFR 266.112. The sampling and 

analytical frequencies may be reviewed and modified by the DEQ staff. Periodic means 

weekly for metals and quarterly for organics. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.12 The cement kiln dust shall be sampled and analyzed for TCDD equivalents once per month. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.13 The hazardous waste fuel shall be screened according to Method #9916 for radioactivity, 

Standard Operating Procedure For the Determination of Radioactivity in Waste Materials 

Using Ludlum Model 19 Micro R Meter, or equivalent method to be approved by the 
Page 37 of 48

 Permit No. 1680-00025 

973 PER20050003 

Administrator. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.14 For Emission Point AA-001, records shall be maintained to document the hazardous waste 

derived fuel rate and cumulative volume consumed for each calendar year. The permittee 

shall submit a semi-annual report stating the maximum fuel rate in gallons/hour for each 

period and the total quantity of hazardous waste derived fuel burned during that period. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.15 (a) The permittee shall provide on-site office space for use by a DEQ staff person and 

provide that person with immediate access to the facility. 

(b) The permittee shall provide a computer link-up from its Artesia facility to the 

Jackson office to monitor continuously the operating conditions relative to the 

burning of hazardous waste and operation of air pollution control equipment. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.16 The facility is subject to and shall comply with the New Source Performance Standards 

(NSPS) 40 CFR 60, Subpart A – General Provisions and 40 CFR 60, Subpart Kb - Standards 

of Performance for Volatile Organic Liquid Storage Vessels for the tanks described in 

Emission Point AA-025. The applicable requirements of Subpart Kb are as follows: 

a) Storage vessels equipped with the closed vent system and control device shall meet 

the standards for volatile organic compounds (VOCs) as given in 60.112b(a)(3). 

b) Testing requirements and procedures shall be as specified in 60.113b(c) 

c) Reporting and recordkeeping requirements as specified in 60.115b. 

d) Monitoring of operations as specified in 60.116b. 

e) For the two 97,000 gallon tanks, the permittee is also subject to and shall comply 

with the notification and recordkeeping requirement as given in 40 CFR 60, Subpart 

A - General Provisions. 

 (Ref.: Construction Permit issued on April 27, 1993) 

5.B.17 The permittee shall comply with Monitoring, Testing, and Recordkeeping requirements in 

the National Emission Standard for Benzene Waste Operations, Subpart FF, more 

specifically defined in 40 CFR 61.354, 61.355, and 61.356. 

(Ref.: Construction Permit issued on April 27, 1993. FF subsumes 40 CFR 63, Part DD)) 
Page 38 of 48

 Permit No. 1680-00025 

973 PER20050003 

5.B.18 For Emission Points AA-002, AA-004, AA-006, AA-008, and AA-009, the permittee shall 

comply with all the provisions detailed in the approved Operation and Maintenance Plan as 

required by 40 CFR §63.1350(a). The Operation and Maintenance Plan is contained in 

Appendix F of the permit. 

 (Ref.: 40 CFR 63.1350. LLL subsumes 40 CFR 60, Part F) 

5.B.19 For Emission Points AA-001 and AA-002, the permittee shall maintain and continuously 

operate a Continuous Emissions Monitor (CEM) and a Continuous Opacity Monitor (COM) 

in accordance with 40 CFR Part 60, Appendix B, Performance Specification 1 (opacity), 4B 

(CO and O2), and 8A (hydrocarbons), and in compliance with the quality assurance 

procedures provided in the appendix to 40 CFR 63, Subpart EEE. Monitoring requirements 

and procedures for alternative monitoring as detailed in the approved Operation and 

Maintenance Plan shall be followed. 

(Ref.: 40 CFR 63.1350(a) and 40 CFR 63.1209(a)(2). LLL subsumes 40 CFR 60, Part F) 

5.B.20 For Emission Point AA-008, the permittee shall conduct daily visual emissions observations 

in accordance with the procedures of Method 22 of 40 CFR Part 60, Appendix A. All 

monitoring requirements and corrective action as detailed in the approved Operation and 

Maintenance Plan shall be followed. 

(Ref.: 40 CFR 63.1350(e). LLL subsumes 40 CFR 60, Part F) 

5.B.21 For Emission Point AA-001, the permittee shall prepare and at all time operate in accordance 

to an operation and maintenance plan that describes procedures for operation, inspection, 

maintenance, and corrective measures for all components of the combustor, including 

associated pollution control equipment, that could affect emissions of HAP. 

(Ref.: 40 CFR §63.1206(c)(7)) 

5.B.22 For Emission Point AA-001, the permittee shall develop a written startup, shutdown, 

malfunction plan describing in detail the procedures for operating and maintaining the 

facility during periods of startup, shutdown, and malfunction. 

(Ref.: 40 CFR §63.1206(c)(7)) 

5.B.23 For Emission Point AA-001, the permittee shall establish a training and certification program 

for each person who has responsibilities affecting operations that may affect emissions of 

HAP. Such persons include, but are not limited to, chief facility operators, control room 

operators, continuous monitoring system operators, persons that sample and analyze feed 

streams, persons that manage and charge feed streams to the combustor, persons that operate 

emission control devices, ash and waste handlers, and maintenance personnel. Site-specific, 

source developed implemented training programs for control room operators must include 

the following elements: 

(a) Training on the following subjects: 

(1) Environmental concerns, including types of emissions; 
Page 39 of 48

 Permit No. 1680-00025 

973 PER20050003 

(2) Basic combustion principles, including products of combustion; 

(3) Operation of the specific type of combustor used by the operator, including 

proper startup, waste firing, and shutdown procedures; 

(4) Combustion controls and continuous monitoring systems; 

(5) Operation of air pollution control equipment and factors affecting 

performance; 

(6) Inspection and maintenance of the combustor, continuous monitoring 

systems, and air pollution control devices; 

(7) Actions to correct malfunctions or conditions that may lead to malfunction; 

(8) Residue characteristics and handling procedures; and 

(9) Applicable Federal, state, and local regulations, including Occupational 

Safety and Health Administration workplace standards; and 

(b) An examination designed and administered by the instructor; and 

(c) Written material covering the training course topics that may serve as reference 

material following completion of the course. 

(Ref.: 40 CFR §63.1206(c)(6)(i) and 40 CFR §63.1206(c)(6)(v)) 

5.B.24 For Emission Point AA-001, the permittee shall develop and implement a feedstream 

analysis plan and record it in the operating record. The plan must be developed in 

accordance with the requirements of 40 CFR §63.1209(c)(2)(i-vi). 

5.B.25 For Emission Point AA-001, the permittee shall calculate the hazardous waste residence time 

and include the calculation in the performance test plan and the operating record. 

Ref.: 40 CFR §63.1206(b)(11)) 

5.B.26 [Intentionally left blank.] 

5.B.27 Condition removed on December 29, 2004. 

5.B.28 The permittee shall commence comprehensive performance testing no later than 61 months 

after the date of commencing the previous comprehensive performance test. A minimum of 

three runs of a performance test must be conducted to document compliance with the 

emission standards. 

(Ref.: 40 CFR §63.1207(d)(1) and 40 CFR §63.1206(b)(12)) 
Page 40 of 48

 Permit No. 1680-00025 

973 PER20050003 

5.B.29 The permittee shall conduct confirmatory performance tests to demonstrate compliance with 

the dioxin/furan when operating under normal conditions and conduct a performance 

evaluation of continuous monitoring systems required for compliance assurance with the 

dioxin/furan emission standard under 40 CFR §63.1209(k). Confirmatory performance 

testing must commence no later than 31 months after the date of commencing the previous 

comprehensive performance test. 

(Ref.: 40 CFR §63.1207(b)(2) and 40 CFR §63.1207(d)(2)) 

5.B.30 Condition removed on December 29, 2004. 

5.B.31 The permittee shall submit a notification of intention to conduct a confirmatory performance 

test and CMS performance evaluation and a test plan and CMS performance evaluation plan 

at least 60 calendar days before the performance test is scheduled to begin. The permittee 

will be notified within 30 calendar days of the approval or intent to deny approval of the 

plans. 

(Ref.: 40 CFR §63.1207(e)(1)(ii)) 

5.B.32 For Emission Point AA-001, the permittee shall operate the kiln such that the following 

parameters do not exceed the average determined for each parameter as determined in the 

most recent performance test submitted to the Administrator. In addition, the permittee shall 

continuously monitor the following parameters when burning hazardous waste derived fuel 

(HWDF) to ensure the limits as established in the most recent performance test are not 

exceeded. 

 (a) The feedrate of each feedstream; 

 (b) Oxygen content to correct CEMS; 

 (c) HC content downstream of ESP; 

 (d) APCD inlet temperature; 

 (e) Maximum combustion chamber pressure; 

 (f) Minimum combustion chamber temperature; 

 (g) Feed rate of each feedstream for regulated constituents. 

Within 180 days after the Initial Confirmatory Performance Test scheduled on or before 

October 15, 2006 set in Condition 5.B.2, the permittee shall submit a plan to the 

Administrator to incorporate parametric ranges for the following: 

 (1) minimum combustion chamber temperature; 

 (2) maximum flue gas flow rate or production rate; 

 (3) maximum hazardous waste feed rate; 

 (4) gas temperature at the inlet to the ESP; 

 (5) ESP operating parameters. 

(Ref.: 40 CFR 63.1209(j)-(p)) 
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 Permit No. 1680-00025 

973 PER20050003 

5.B.33 For all sources that are intended to operate in volatile hazardous air pollutant (VHAP) 

service: pumps, compressors, pressure relief devices, sampling connection systems, openended valves or lines, valves, flanges and other connectors, product accumulator vessels, and 

control devices or systems required by the 40 CFR Part 61, Subpart V, the permittee shall 

comply with the compliance demonstration and monitoring, performance testing, 

recordkeeping, and reporting in accordance with §61.245, §61.246, and §61.247. 

(Ref.: 40 CFR 61.240) 

5.B.34 To comply with conditions in 3.B.11, records shall be maintained to document the waste 

derived fuel rate and cumulative volume consumed for each calendar year. The permittee 

shall submit a semi-annual report stating the maximum fuel rate in gallons/hour for each 

period and the total quantity of waste derived fuel burned during that period. This condition 

is not federally enforceable under the Federal Clean Air Act. 

(Ref.: Construction Permit issued on April 27, 1993) 

5.B.35 For any area of the facility that is subject to 40 CFR Parts 60, 61, and/or 63 for the control of 

air emissions for containers as described in 40 CFR Part 63 Subpart PP, the permittee shall 

comply with the compliance demonstration and monitoring, performance testing, 

recordkeeping, and reporting in accordance with §63.925, §63.926, §63.927, §63.928. 

5.B.36 For Emission Points AA-002, AA-003, AA-006, AA-008, AA-009, AA-010, and AA-011, 

the permittee shall perform periodic (once per month) inspections to assure that each 

baghouse is operating efficiently. The permittee shall keep records of each inspection. For 

each baghouse these records should include the condition of the bags, the pressure drop, the 

number of replacement bags that are readily available, and documentation of any 

maintenance that has been performed. The permittee shall follow the O&M plan for all 

equipment and control equipment associated with these Emission Points (see Appendix). 

(Ref.: APC-S-6, Section III.A.3.a(2)) 

5.B.37 For Emission Point AA-001, to demonstrate compliance with the annual NOx limitation in 

3.B.38, a continuous emission monitoring system (CEMS) to monitor the average hourly 

NOx emission rate from the kiln shall be installed and operated. The CEMS shall meet the 

specifications and procedures of Appendix B of 40 CFR 60 and will be certified and 

maintained in accordance with these procedures. 

(Ref.: APC-S-6, Section III.A.3.a(2)) 

5.B.38 For Emission Point AA-001, the permittee shall monitor total clinker production on a daily 

basis. 

(Ref: Construction Permit modified August 20, 2004) 
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 Permit No. 1680-00025 

973 PER20050003 

5.B.39 For Emission Point AA-001, the permittee must install and operate continuous monitoring 

systems other than CEMS in conformance with Sec. 63.8(c)(3) that requires compliance with 

the manufacturer's written specifications or recommendations for installation, operation, and 

calibration of the system. 

(Ref.: 40 CFR 63.1209(b) and 40 CFR 63.8(c)(3)) 

5.B.40 For Emission Point AA-001, the results of AWFCO system tests required in 3.B.39 shall be 

documented in the operating record of the AWFCO operability test procedures and results. 

(Ref.: 40 CFR § 63.1206(c)(3)(vii)) 

5.B.41 Regular monthly inspections of the pollution control equipment shall be performed and 

regular maintenance on such equipment shall be performed as necessary to maintain proper 

operation. Records of these inspections and maintenance shall be kept in log form and must 

be made available for review upon request during any inspection visit by Department of 

Environmental Quality personnel. 

(Ref.: Construction Permit issued on April 27, 1993) 

5.B.42 The permittee shall maintain on hand at all times sufficient equipment as is necessary to 

conduct routine maintenance and repair of the pollution control equipment to insure 

compliance with the emission limits set in this permit. 

(Ref.: Construction Permit issued on April 27, 1993) 

5.B.43 For Emission Points AA-002, AA-003, AA-006, AA-008, AA-009, AA-010, and AA-011, 

the permittee shall maintain in working order measuring devices as are necessary for regular 

monitoring and/or measurement of pressure drop across the baghouse emission control 

systems. 

(Ref.: Construction Permit issued on April 27, 1993) 
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 Permit No. 1680-00025 

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5.B.44 For Emission Point AA-001, the permittee shall monitor emissions of each regulated NSR 

pollutant (as indicated in the following table) at the end of each calendar year. 

NSR 

Pollutant 

Baseline 

Emissions 

(tons/year) 

Projected 

Actual 

Emissions 

(tons/year) 

PSD 

Significance 

Level 

(tons/year) 

Baseline + 

Significance 

Level 

(tons/year) 

NOx 1,534 1,534 40 1,574 

CO 332 332 100 432 

Pb 0.11 0.11 0.6 0.71 

PM total 155 167 25 180 

PM10 132 142 15 147 

SO2 3,091 3,091 40 3,131 

VOC 7.19 7.19 40 47.2 

The values listed in the table above are not emission limits but are only for 

purposes of evaluating when the reporting requirements of condition 5.C.12 

is applicable.

The permittee shall monitor and/or calculate, and record the annual emissions (tons/year) of 

each regulated New Source Review (NSR) pollutant that could increase as a result of this 

project. Annual emissions, as used in this condition means 12 consecutive calendar months 

beginning with initial firing of PET coke in the kiln or upon modification to the kiln ID fan. 

Annual emissions of all NSR pollutants, listed above, shall be maintained for a period of at 

least 10 years after notification to the MDEQ that PET coke has been used as a fuel or that 

the kiln ID fan modification has been completed. 

(Ref.: 40 CFR 52.21(r)(6)(iii) 
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 Permit No. 1680-00025 

973 PER20050003 

C. Specific Reporting Requirements 

Emission 

Point(s) 

Pollutant/Parameter 

Monitored 

Reporting Requirement Condition 

Number 

Applicable 

Requirement 

AA-025 Waste Fuel Reporting 5.C.1 Construction 

Permit Issued 

April 27, 1993 

AA-002, 

AA-003, 

AA-006, 

AA-008, 

AA-009, 

AA-010, 

AA-011 

Baghouse 

operations 

Report baghouse data collected 5.C.7 APC-S-6, 

Section III.A.3.a(2) 

AA-001 NOx CEMS for NOx limit 

(2,625 tpy) in 3.B.38. 

5.C.8 APC-S-6, 

Section III.A.3.a(2) 

5.C.1 The permittee shall comply with the Reporting requirements in the National Emission 

Standard for Benzene Waste Operations, Subpart FF, more specifically defined in 40 CFR 

61.357. 

(Ref.: 40 CFR 61.357. FF subsumes 40 CFR 63, Part DD) 

5.C.2 The permittee shall submit an excess emissions and continuous monitoring system 

performance report for any event when the continuous monitoring system data indicate noncompliance with the applicable emission limitation or operating parameter limit. 

(Ref.: 40 CFR 63.10(e)(3)) 

5.C.3 The permittee shall submit a summary report semiannually containing the information 

specified in 40 CFR §63.10(e)(3)(vi) and also the following information: 

(1) All exceedences of maximum control device inlet gas temperature sensors (if 

applicable); 

(2) All failures to calibrate thermocouples and other temperature sensors (if applicable); 

(3) All failures to maintain the activated carbon injection rate, and the activated carbon 

injection carrier gas flow rate (if applicable); 

(4) The results of any combustion system component inspections conducted within the 

reporting period; 

(5) All failures to comply with any provision of the operation and maintenance plan; 

(6) Periodic startup, shutdown, and malfunction reports (Ref.: 40 CFR § 63.10(d)(5)(i)); 
Page 45 of 48

 Permit No. 1680-00025 

973 PER20050003 

(7) Immediate startup, shutdown, and malfunction reports 

(Ref.: 40 CFR § 63.10(d)(5)(ii)). 

5.C.4 The permittee shall submit a Notification of Compliance (NOC) within 90 days of 

completion of a comprehensive performance test. The NOC shall document compliance or 

noncompliance with the emission standards and continuous monitoring system requirements 

and identify operating parameter limits under 40 CFR §63.1209. 

(Ref.: 40 CFR §63.1207(j)) 

5.C.5 The permittee shall submit a semiannual report in accordance with 40 CFR §63.1354(b)(9). 

(Ref: 40 CFR 60.1354(b)(9). LLL subsumes 40 CFR 60, Part F) 

5.C.6 For each set of 10 exceedences of an emission standard or operating requirement while 

hazardous waste remains in the combustion chamber during a 60-day block period, the 

permittee shall submit a written report within 5 calendar days of the 10th exceedence 

documenting the exceedences and results of the investigation and corrective measures taken. 

(Ref.: 40 CFR §63.1206(c)(3)(vi)) 

5.C.7. For Emission Points AA-002, AA-003, AA-006, AA-008, AA-009, AA-010, and AA-011, 

the permittee shall submit a report in accordance with Paragraph 5.A.4 summarizing the data 

collected from the visual observations and/or periodic inspections performed on each 

baghouse during the previous six-month period. 

(Ref.: APC-S-6, Section III.A.3.a(2)) 

5.C.8. For the monitoring and recordkeeping requirements in 5.B.37 regarding Emission Point AA001, the permittee shall submit a report in accordance with Paragraph 5.A.4 summarizing the 

total annual NOx emission rate in tons/year for each consecutive 12-month period based on 

certified NOx CEMS hourly averages. 

5.C.9 For Emission Point AA 001, the permittee shall submit semiannual reports by July 31 and 

January 31 for the preceding six month period summarizing the following: 

(A) The total annual NOx emission rate in tons/year for each consecutive 12-month 

period based on certified NOx CEMS hourly averages. 

(B) The total annual clinker production rate in tons/year for each consecutive 12 month 

period. 

(C) A demonstration that on a 30 day rolling averaging basis the permittee did not allow 

NOx emissions to exceed 10 lbs/ton of clinker produced. 

 (Ref: Construction Permit modified August 20, 2004) 
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 Permit No. 1680-00025 

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5.C.10 The permittee shall submit a notification of intention to conduct a comprehensive 

performance test and CMS performance evaluation and a site-specific test plan and CMS 

performance evaluation test plan at least one (1) year before the performance test and 

performance evaluation are scheduled to begin. The permittee will be notified within nine 

(9) months of the approval or intent to deny approval of the site-specific test plan and CMS 

performance evaluation test plan. 

(Ref.: 40 CFR § 63.1207(e)(1)(i)) 

5.C.11 The permittee shall submit a Notification of Compliance (NOC) within 90 days of 

completion of a confirmatory performance test. The NOC shall document compliance or 

noncompliance with the applicable dioxin/furan emission standard. 

(Ref.: 40 CFR § 63.1207(j)(2))

5.C.12 For Emission Point AA-001, if annual emissions (tons/year) exceed baseline actual 

emissions, as required in the monitoring condition 5.B.44 above, by a significant amount, the 

permittee shall submit a report to the Mississippi Environmental Quality Board within 60 

days after the end of such calendar year. The report shall contain the following information: 

(A) The name, address, and telephone number of the stationary source 

(B) The annual emissions calculated pursuant to condition 5.B.44 above 

(C) An explanation as to why annual emissions differ from the pre-construction 

projected actual emissions 

 (Ref.: 40 CFR 52.21(r)(6)(v)) 
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SECTION 6. ALTERNATIVE OPERATING SCENARIOS

None permitted. 
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973 PER20050003 

SECTION 7. TITLE VI REQUIREMENTS 

The following are applicable or potentially applicable requirements originating from Title VI of the 

Clean Air Act. The full text of the referenced regulations is contained in Appendix B to this permit. 

7.1 If the permittee stores or transports class I or class II substances, the permittee shall comply 

with the standards for labeling of products using ozone-depleting substances pursuant to 40 

CFR Part 82, Subpart E: 

(a) All containers in which a class I or class II substance is stored or transported, all 

products containing a class I substance, and all products directly manufactured with a 

class I substance must bear the required warning statement if being introduced into 

interstate commerce pursuant to ' 82.106. 

(b) The placement of the required warning statement must comply with the requirements 

pursuant to ' 82.108. 

(c) The form of the label bearing the required warning statement must comply with the 

requirements pursuant to ' 82.110. 

(d) No person may modify, remove, or interfere with the required warning statement 

except as described in ' 82.112. 

7.2 If the permittee performs any of the activities described below, the permittee shall comply 

with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, 

Subpart F, except as provided for MVACs in Subpart B: 

(a) Persons opening appliances for maintenance, service, repair, or disposal must comply 

with the required practices pursuant to ' 82.156. 

(b) Equipment used during the maintenance, service, repair, or disposal of appliance 

must comply with the standards for recycling and recovery equipment pursuant to '

82.158. 

(c) Persons performing maintenance, service, repair, or disposal of appliances must be 

certified by an approved technician certification program pursuant to ' 82.161. 

(d) Persons disposing of small appliances, MVACs, and MVAC-like appliances must 

comply with the recordkeeping requirements pursuant to ' 82.166. (AMVAC - like 

appliance@ is defined at ' 82.152.) 

(e) Persons owning commercial or industrial process refrigeration equipment must 

comply with the leak repair requirements pursuant to ' 82.156. 
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(f) Owners/operators of appliances normally containing 50 or more pounds of 

refrigerant must keep records of refrigerant purchased and added to such appliances 

pursuant to ' 82.166. 

7.3 If the permittee manufactures, transforms, imports, or exports a class I or class II substance, 

the permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A, 

Production and Consumption Controls. 

7.4 If the permittee performs a service on motor (fleet) vehicles and if this service involves an 

ozone-depleting substance (refrigerant) in the motor vehicle air conditioner (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 Amotor vehicle@ as used in Subpart B does not include a vehicle in which final 

assembly of the vehicle has not been completed. The term AMVAC@ as used in Subpart B 

does not include air-tight sealed refrigeration systems used for refrigerated cargo, or air 

conditioning systems on passenger buses using HCFC-22 refrigerant. 

7.5 The permittee shall be allowed to switch from any ozone-depleting substance to any 

alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated 

pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program. 

973 PER20050003 

APPENDIX A 

List of Abbreviations Used In this Permit

APC-S-1 Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants 

APC-S-2 Permit Regulations for the Construction and/or Operation of Air Emissions Equipment 

APC-S-3 Regulations for the Prevention of Air Pollution Emergency Episodes 

APC-S-4 Ambient Air Quality Standards 

APC-S-5 Regulations for the Prevention of Significant Deterioration of Air Quality 

APC-S-6 Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean 

Air Act 

APC-S-7 Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act 

BACT Best Available Control Technology 

CEM Continuous Emission Monitor 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

CO Carbon Monoxide 

COM Continuous Opacity Monitor 

COMS Continuous Opacity Monitoring System 

DEQ Mississippi Department of Environmental Quality 

EPA United States Environmental Protection Agency 

gr/dscf Grains Per Dry Standard Cubic Foot 

HP Horsepower 

HAP Hazardous Air Pollutant 

lbs/hr Pounds per Hour 

M or K Thousand 

MACT Maximum Achievable Control Technology 

MM Million 

MMBTUH Million British Thermal Units per Hour 

NA Not Applicable 

NAAQS National Ambient Air Quality Standards 

NESHAP National Emissions Standards For Hazardous Air Pollutants, 40 CFR 61 

or 

National Emission Standards For Hazardous Air Pollutants for Source Categories, 40 CFR 63 

NMVOC Non-Methane Volatile Organic Compounds 

NOx Nitrogen Oxides 

NSPS New Source Performance Standards, 40 CFR 60 

O&M Operation and Maintenance 

PM Particulate Matter 

PM10 Particulate Matter less than 10 Φm in diameter 

ppm Parts per Million 

PSD Prevention of Significant Deterioration, 40 CFR 52 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

TPY Tons per Year 

TRS Total Reduced Sulfur 

VEE Visible Emissions Evaluation 

VHAP Volatile Hazardous Air Pollutant 

VOC Volatile Organic Compound
973 PER20050003 

APPENDIX B 

40 CFR 82

PROTECTION OF STRATOSPHERIC OZONE
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APPENDIX C

40 CFR, PART 63, SUBPART LLL, 

NATIONAL EMISSION STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FOR CATEGORIES;

PORTLAND CEMENT MANUFACTURING INDUSTRY
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APPENDIX D 

40 CFR PART 63, SUBPART EEE, 

NATIONAL EMISSION STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS FROM 

HAZARDOUS WASTE COMBUSTORS
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APPENDIX E 

40 CFR PART 61, SUBPART V, 

NATIONAL EMISSION STANDARD FOR 

EQUIPMENT LEAKS (FUGITIVE EMISSION SOURCES)
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APPENDIX F

Operation and Maintenance Plan
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APPENDIX G 

40 CFR PART 63, SUBPART PP,

NATIONAL EMISSION STANDARDS FOR

CONTAINERS