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Title V Operating Permit R30-00300006-2006 Page 2 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Permit Number: R30-00300006-2006

Permittee: ESSROC Cement Corporation

Facility Name: Capitol Cement Corporation 

Mailing Address: 3251 Bath Pike, Nazareth, PA 18064

This permit is issued in accordance with the West Virginia Air Pollution Control Act (West Virginia Code §§ 22-5-1 et seq.) 

and 45CSR30 Requirements for Operating Permits. The permittee identified at the above-referenced facility is authorized 

to operate the stationary sources of air pollutants identified herein in accordance with all terms and conditions of this 

permit. 

Facility Location: Martinsburg, Berkeley County, West Virginia 

Mailing Address: P.O. Box 885, 1826 South Queen Street, Martinsburg, WV 25401 

Telephone Number: (304) 267-8966 

Type of Business Entity: Corporation 

Facility Description: Capitol Cement Plant is a Portland cement manufacturing facility. Their 

cement is used to make concrete, concrete products and masonry cement. 

SIC Codes: Primary 3241; Secondary 1422; Tertiary NA 

UTM Coordinates: 243.50 km Easting  4369.00 km Northing  Zone 18

Any person whose interest may be affected, including, but not necessarily limited to, the applicant and any person who 

participated in the public comment process, by a permit issued, modified or denied by the Secretary may appeal such action 

of the Secretary to the Air Quality Board pursuant to article one [§§ 22B-1-1 et seq.], Chapter 22B of the Code of West 

Virginia. West Virginia Code §22-5-14.

Issuance of this Title V Operating Permit does not supersede or invalidate any existing permits under 45CSR13, 14 or 19, 

although all applicable requirements from such permits governing the facility's operation and compliance have been 

incorporated into the Title V Operating Permit.
Title V Operating Permit R30-00300006-2006 Page 3 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Table of Contents 

 1.0. Emission Units..........................................................................................................................5

 2.0. General Conditions ................................................................................................................ 35 

 2.1. Definitions ........................................................................................................................35 

 2.2. Acronyms..........................................................................................................................35 

 2.3. Permit Expiration and Renewal ........................................................................................36 

 2.4. Permit Actions ..................................................................................................................36 

 2.5. Reopening for Cause.........................................................................................................36 

 2.6. Administrative Permit Amendments .................................................................................37 

 2.7. Minor Permit Modifications .............................................................................................37 

 2.8. Significant Permit Modification........................................................................................37 

 2.9. Emissions Trading ............................................................................................................37 

 2.10. Off-Permit Changes ..........................................................................................................37 

 2.11. Operational Flexibility......................................................................................................38 

 2.12. Reasonably Anticipated Operating Scenarios...................................................................39 

 2.13. Duty to Comply.................................................................................................................39 

 2.14. Inspection and Entry .........................................................................................................39 

 2.15. Schedule of Compliance ...................................................................................................40 

 2.16. Need to Halt or Reduce Activity not a Defense ................................................................40 

 2.17. Emergency ........................................................................................................................40 

 2.18. Federally-Enforceable Requirements................................................................................41 

 2.19. Duty to Provide Information.............................................................................................41 

 2.20. Duty to Supplement and Correct Information...................................................................41 

 2.21. Permit Shield ....................................................................................................................42 

 2.22. Credible Evidence.............................................................................................................42 

 2.23. Severability.......................................................................................................................42 

 2.24. Property Rights .................................................................................................................42 

 2.25. Acid Deposition Control...................................................................................................43 

 3.0. Facility-Wide Requirements.................................................................................................. 44 

 3.1. Limitations and Standards.................................................................................................44 

 3.2. Monitoring Requirements .................................................................................................47 

 3.3. Testing Requirements .......................................................................................................57 

 3.4. Recordkeeping Requirements ...........................................................................................61 

 3.5. Reporting Requirements ...................................................................................................63 

 3.6. Compliance Plan...............................................................................................................66 

 3.7. Permit Shield ....................................................................................................................66 

 4.0. Kilns Requirements................................................................................................................ 68 

 4.1. Limitations and Standards.................................................................................................68 

 4.2. Monitoring Requirements .................................................................................................72 

 4.3. Testing Requirements .......................................................................................................72 

 4.4. Recordkeeping Requirements ...........................................................................................73 

 4.5. Reporting Requirements ...................................................................................................74 

 4.6. Compliance Plan...............................................................................................................74 
Title V Operating Permit R30-00300006-2006 Page 4 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 5.0. Modern Precalciner Kiln System and related Equipment.................................................. 75 

 5.1. Limitations and Standards.................................................................................................75 

 5.2. Monitoring Requirements .................................................................................................92 

 5.3. Testing Requirements .......................................................................................................95 

 5.4. Recordkeeping Requirements .........................................................................................100 

 5.5. Reporting Requirements .................................................................................................102 

 5.6. Compliance Plan.............................................................................................................103 

 

APPENDIX A 45CSR10 Monitoring Plan for Capitol Cement.................................... 104
Title V Operating Permit R30-00300006-2006 Page 5 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

1.0. Emission Units 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Crushing Group 001 

42 Inch Primary Crusher CD01.01 EP01.01 to 

CD01.01 

EP01.01 1943 and Baghouse 

1982 

805 TPH Baghouse 

CD01.01 

EP01.03 CD01.01 to 

EP01.03 

PE 

Dust Filter for Transfer Point 

between 42” Crusher and 42” Belt 

EP01.01 CD01.01 to 

EP01.01 

CD01.01 1972 6,300 Baghouse 

CF/min 

Stack 001 

Stack 1 CD01.01 to 

Stack 1 

None 

EP01.02 Crusher Feeder 1982 805 TPH None EP01.01 EP01.02 to 

EP01.01 

None 

EP0X.04 Crusher Feeder Stockpiles 1972 None EP01.02 EP0X.04 to 

EP01.02 

None 

EP0X.05 Quarry Waste Stockpiles 1972 None None None None 

EP01.04 EP01.03 to 

EP01.04 and 

EP01.03 Discharge to Surge Bin 1943 and None 

1982 

805 TPH PE 

CD01.03 

EP01.07 EP01.07 None 

EP01.04 Conveying Equipment 1943 and 

1982 

805 TPH FE 

CD01.04 

EP01.05 EP01.04 to 

EP01.05 

FE 

EP01.05 Conveying Equipment 1943 and 

1982 

805 TPH FE 

CD01.05 

EP02.01 EP01.05 to 

EP02.01 

FE 

EP01.06 Reclaim Scalper 1955 and 

1971 

750 TPH None EP01.03 EP01.06 to 

EP01.03 

None 

EP01.07 Discharge to Surge Pile 805 TPH None EP01.08 EP01.07 to 

EP01.08 

None 

EP01.08 Load/Unload Surge Stone 805 TPH None None None None 

Secondary Crushing Group 002 

Secondary Crusher and Screens 

8’ X 16’ Screen 

CD02.01 EP02.01 to 

CD02.01 

EP02.01 1966 and Baghouse 

1982 

805 TPH Baghouse 

CD02.01 

EP02.02 EP02.01 to 

EP02.02 

Baghouse 

CD02.01 Baghouse for Secondary Crusher and 

Screens 

1990 46,000 cfm at 

70 degrees F 

Stack 002 Stack 2 CD02.01 to 

Stack 2 

None 

EP02.03 EP02.02 to 

EP02.03 

DS and 

PE 

EP02.02 Conveying Equipment 1965 and 

1982 

805 TPH DSWs 

CD02.02A 

and FE 

CD02.02B EP02.04 EP02.02 to 

EP02.04 

DS 

EP02.03 Conveying Equipment - Belt 

Discharge to Material Storage 

1965 and 

1982 

805 TPH DSWS 

and PE 

EP03.01 EP02.03 to 

EP03.01 

PE 

EP02.04 999 Belt Discharge to Stone 

Stockpile 

1965 and 

1982 

805 TPH DSWS EP03.03 EP02.04 to 

EP03.03 

None 

 
Title V Operating Permit R30-00300006-2006 Page 6 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Tertiary Crushing Group 003 

Raw Material Storage EP03.02 EP03.01 to 

EP03.02 

PE 

Bay 1 for Cement Rock EP03.04 EP03.01 to 

EP03.04 

PE 

Bay 2 for Cement Rock EP04.01 EP03.01 to 

EP04.01 

None 

Bay 3 for Cement Rock EP05.01 EP03.01 to 

EP05.01 

FE 

Bay 4 for Shale EP05.03 EP03.01 to 

EP05.03 

FE 

EP03.01 

Bay 5 for Limestone 

1966 and 

1971 

0.860 ft2 PE 

CD03.01 

CD03.01 EP03.01 to 

CD03.01 

None 

EP03.01 EP03.02 to 

EP03.01 

EP03.02 Material Loading /Unloading (Stone PE 

Bays 

1971 805 TPH PE 

CD03.02 

CD03.02 EP03.02 to 

CD03.02 

None 

EP03.04 EP03.03 to 

EP03.04 

EP03.03 Outside Stone Stockpiles 1971 None None 

EP03.02 EP03.03 to 

EP03.02 

PE 

EP03.04 Loading/Unloading 1971 805 TPH None EP03.03 EP03.04 to 

EP03.03 

None 

EP04.03 EP04.01 to 

EP04.03 

EP04.01 Number 1 Tertiary Conveying Baghouse 

Equipment to #5 Raw STG Bins 

1965 and 

1971 

240 TPH FE 

CD06.01 

EP05.01 EP04.01 to 

EP05.06 

CD05.01 

Number 1 Tertiary Screens and 

Elevator 

EP04.02 EP04.03 to 

EP04.02 

Baghouse 

EP06.01 EP04.03 to 

EP06.01 

FE 

EP07.01 EP04.03 to 

EP07.01 

CD07.01 

EP04.03 1965 and 

1971 

240 TPH Baghouse 

CD04.03 

CD04.03 EP04.03 to 

CD04.03 

Stack 3 

Tertiary Crusher Number 1 CD04.02 EP04.02 to 

CD04.02 

EP04.02 1965 and Stack 4 

1971 

240 TPH Baghouse 

CD04.02 

EP04.03 EP04.02 to 

EP04.03 

Baghouse 

CD04.03 Baghouse for Number 1 Tertiary 

Screens and Elevator 

1966 10,800 cfm Stack 003 EP04.03 CD04.03 to 

EP04.03 

Stack 3 

Baghouse for Tertiary Crusher 

Number 1 

EP04.03 CD04.02 to 

EP04.03 

CD04.02 1981 4,100 cfm Stack 004 Baghouse 

Stack 4 CD04.02 to 

Stack 4 

None 

 
Title V Operating Permit R30-00300006-2006 Page 7 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

CD05.01 EP05.01 to 

CD05.01 

FE 

EP04.03 EP05.01 to 

EP04.03 

Baghouse 

EP05.01 Number 2 Tertiary Conveying 

Equipment to #2 Tertiary Crusher 

1965 and 

1971 

240 TPH FE 

CD05.01 

EP05.06 EP05.01 to 

EP05.06 

Baghouse 

Number 2 Tertiary Screens and 

Elevator 

EP05.02 EP05.06 to 

EP05.02 

Baghouse 

EP08.01 EP05.06 to 

EP08.01 

FE 

EP05.06 

Manufacture: Tyer, Rexord

1965 and 

1971 

240 TPH Baghouse 

CD05.06 

CD05.06 EP05.06 to 

CD05.06 

Baghouse 

Tertiary Crusher Number 2 EP05.06 EP05.02 to 

EP05.06 

EP05.02 Baghouse 

Manufacture: Pennsylvania Crusher

1965 and 

1971 

240 TPH Baghouse 

CD05.02 

CD05.02 EP05.02 to 

CD05.02 

Baghouse 

Baghouse for Tertiary Crusher 

Number 2 

EP05.02 CD05.02 to 

EP05.02 

CD05.02 Baghouse 

Manufacture: Torrit

1981 4,100 cfm Stack 006 

Stack 6 CD05.02 to 

Stack 6 

None 

Baghouse for Number 2 Tertiary 

Screens and Elevator 

EP05.06 CD05.06 to 

EP05.06 

CD05.06 Baghouse 

Manufacture: Buell - Norblo

1966 10,800 cfm Stack 005 

Stack 5 CD05.06 to 

Stack 5 

None 

CD05.04

A 

EP05.04 to 

CD05.04A 

EP05.04 Material Unloading 1965 and PE 

1971 

200 TPH DSWs 

CD05.04A 

PE EP05.05 EP05.04 to 

EP05.05 

FE 

CD05.04A Wet Material PE 

CD05.04B 

CD05.04

B 

CD05.04A to 

CD05.04B 

None 

EP04.03 EP05.05 to 

EP04.03 

EP05.05 Conveying Equipment 1965 and Baghouse 

1971 

200 TPH FE 

CD05.05 

EP05.06 EP05.05 to 

EP05.06 

Baghouse 

EP05.03 Conveying Equipment 1965 and 

1971 

50 TPH FE 

CD05.03 

EP17.01 EP05.04 to 

EP17.01 

Baghouse 

EP06.01 Conveying Equipment 1965 and 

1971 

120 TPH FE 

CD06.01 

EP09.01 EP06.01 to 

EP09.01 

None 

EP07.01 Conveying Equipment in a Building 1965 and

1971 

120 TPH FE 

CD07.01 

EP09.01 EP07.01 to 

EP09.01 

None 

Conveyor Equipment is Enclosed 

within Tertiary Grinding Building 

CD07.01 

Control Efficiency: 80.0 % 

1965 and 

1971 

120 TPH PE 

CD07.01 

ATM CD07.01 to 

Atmosphere 

(ATM) 

None 

EP08.01 Conveying Equipment 1965 and 

1971 

120 TPH FE 

CD08.01 

EP09.01 EP08.01 to 

EP09.01 

None 

 
Title V Operating Permit R30-00300006-2006 Page 8 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP10.01 EP09.01 to 

EP10.01 

Cyclone 

ESP 

EP11.01 EP09.01 to 

EP11.01 

Cyclone 

ESP 

EP09.01 Slurry Storage, Handling, and Raw 

Mills 

1965 and 

1971 

360 TPH None 

EP12.01 EP09.01 to 

EP12.01 

Cyclone 

ESP 

Kiln Number 7 Group 006 

Number 7 Kiln CD10.01

A 

EP10.01 to 

CD.10.01A 

Cyclone 

and ESP 

EP10.01 

Manufacture: Tralyor

1955 and 

1971 

35 TPH 

33.0 Short 

Tons/hr or 

31.7 Metric 

Tons/hr 

Cyclone 

CD10.01B 

and ESP 

CD10.01C 

EP10.02 EP10.01 to 

EP10.02 

Baghouse 

CD10.01A Settling Chamber 

Manufacture: Tralyor

1955 Cyclone 

CD10.01B 

CD10.01

B 

CD10.01A to 

CD10.01B 

Cyclone 

CD10.01B Number 7 Cyclones (7BC) 

Manufacture: Buell

1955 ESP 

CD10.01C

CD10.01

C 

CD10.01B to 

CD10.01C 

ESP 

Number 7 Electro Static Precipitator 

(ESP)

EP13.01 CD10.01C to 

EP13.01 

CD10.01C Baghouse 

Manufacture: Western Precipitator

1963 Stack 008 

EP13.02 CD10.01C to 

EP13.02 

Baghouse 

EP10.03 Number 7 Kiln Torch 

Manufacture: Fuller Company

1971 140 

gallons/hr of 

1000 

Gallons Fuel 

Oil Burned 

None EP10.01 EP10.03 to 

EP10.01 

Cyclone 

and ESP 

Number 7 Kiln Clinker Cooler CD10.02 EP10.02 to 

CD.10.02 

EP10.02 Baghouse 

Manufacture: Fuller Company

1955, 

1971, 

06/04/00 

35.0 short 

tons/hr or 

31.7 metric 

tons/hr; 35 

LB / ton 

Clinker 

Baghouse 

CD.10.02 

EP10.04 EP10.02 to 

EP10.04 

PE 

Number 7 Kiln Clinker Cooler Dust 

Filter (Baghouse) 

EP10.04 CD.10.02 to 

EP10.04 

CD10.02 Baghouse 

Manufacture: Micro-Pulse

1975 and 

2000 

93,000 

ACFM at 

350 o

F (2) 

Emission 

Limits are: 

6.11 LB/hr 

and 

26.7 TPY of 

PM 

Stack 009 

Stack 9 CD.10.02 to 

Stack 9 

None 

EP10.04 Conveying Equipment for #3 and #5 

Drags Plus Elevator 

1955 & 

1971 

128 Tons 

Cement 

Produced 

CD10.04 

PE 

EP14.01 EP10.04 to 

EP14.01 

DSCS 

Conveying Equipment for #7 Drags 

Plus Elevator 

EP10.05 

Manufacture: Aumund Louise

06/04/00 35 Tons 

Cement 

Produced 

CD10.05 

PE 

EP14.01 EP10.05 to 

EP14.01 

DSCS 
Title V Operating Permit R30-00300006-2006 Page 9 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Kiln Number 8 Group 007 

Number 8 Kiln 

Manufacture: Tralyor

EP11.02 EP11.01 to 

EP11.02 

Cyclone 

and ESP 

EP11.01 1958 and 

1971 

35.0 Tons of 

Clinker / 

hour 33.0 

Short 

Tons/hr or 

31.7 Metric 

Tons/hr; 

Cyclone 

CD11.01B 

and ESP 

CD11.01C 

CD11.01A EP11.01 to 

CD11.01A 

Baghouse 

CD11.01A Settling Chamber 

Manufacture: Tralyor

1958 Cyclone 

CD11.01B 

and ESP 

CD11.01C 

CD11.01B CD11.01A to 

CD11.01B 

Cyclone 

CD11.01B Number 8 Cyclone 

Manufacture: Buell

1958 ESP 

CD11.01C 

CD11.01C CD11.01B to 

CD11.01C 

ESP 

Number 8 Electro Static Precipitator 

(ESP)

Stack 007 CD11.01C to 

Stack 007 

None 

Manufacture: Western Precipitator EP13.01 CD11.01C to 

EP13.01 

Baghouse 

CD11.01C 1963 Stack 007 

EP13.02 CD11.01C to 

EP13.02 

Baghouse 

EP11.03 Number 8 Kiln Torch 

Manufacture: Hauck

1971 140 

gallons/hr of 

1000 

Gallons Fuel 

Oil Burned 

None EP11.01 EP11.03 to 

EP11.01 

Cyclone 

and ESP 

Conveying Equipment for #8 Drags 

Plus Elevator 

EP11.04 

Manufacture: Aumund Louise

07/23/03 35 Tons 

Cement 

Produced 

CD11.04 

PE 

EP10.04 EP11.04 to 

EP10.04 

DSCS 

Number 8 Kiln Clinker Cooler CD11.02 EP11.02 to 

CD11.02 

EP11.02 Baghouse 

Manufacture: Fuller Company

1958, 

1971, 

07/23/00 

35.0 short 

tons/hr or 

31.7 metric 

tons/hr 

Baghouse 

CD11.02 

EP10.04 EP11.02 to 

EP10.04 

PE 

Number 8 Kiln Clinker Cooler Dust 

Filter 

EP10.04 CD11.02 to 

EP10.04 

CD11.02 Baghouse 

Manufacture: Mikropul

1975 and 93,000 

ACFM at 

350 oF (2) 

Emission 

Limits are: 

6.11 LB/hr 

and 

26.7 TPY of 

PM 

Stack 010 

Stack 10 CD11.02 to 

Stack 10 

None 

Kiln Number 9 Group 012 

Number 9 Kiln CD12.01

A 

EP12.01 to 

CD.12.01A 

EP12.01 ESP 

Manufacture: Tralyor

1966 and 

1971 

58.0 TPH 

53.0 short 

tons/hr or 

52.6 metric 

tons/hr 

ESP 

CD12.01B 

EP12.02 EP12.01 to 

EP12.02 

Baghouse 

 
Title V Operating Permit R30-00300006-2006 Page 10 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

CD12.01A Settling Chamber 

Manufacture: Fuller 

1966 ESP 

CD12.01B 

CD12.01

B 

CD12.01A to 

CD12.01B 

ESP 

Number 9 Electro Static Precipitator EP13.01 CD12.01B to 

EP13.01 

CD12.01B Baghouse 

Manufacture: Western Precipitator

1965 Stack 008 

EP13.02 CD12.01B to 

EP13.02 

Baghouse 

EP12.04 Number 9 Kiln Torch 

Manufacture: Hauck

1966 and 

1971 

140 

gallons/hr of 

1000 

Gallons Fuel 

Oil Burned 

None EP12.01 EP12.04 to 

EP12.01 

None 

Number 9 Kiln Clinker Cooler CD12.02 EP12.02 to 

CD12.02 

EP12.02 Baghouse 

Manufacture: Fuller Company

1966 and 

1971 

58.0 Tons of 

Cement Per 

Hour 

Baghouse 

CD10.02 

EP12.03 EP12.02 to 

EP12.03 

PE 

Number 9 Kiln Clinker Cooler Dust 

Filter (Baghouse) 

EP10.04 CD12.02 to 

EP10.04 

CD12.02 PE 

Manufacture: Micro - Pulse

1975 Temperature 

(2)

 

Stack 011 

Stack 11 CD12.02 to 

Stack 11 

None 

CD12.03 EP12.03 to 

CD12.03 

EP12.03 Conveying Equipment 1977 58.0 Tons of Baghouse 

Cement Per 

Hour 

Baghouse 

CD12.03 

EP12.05 EP12.03 to 

EP12.05 

None 

CD12.03A Baghouse for Conveying Equipment 

Manufacture: DCE Vokes

1985 1,700 cfm 

@ 200 

degree. F @ 

9” SP 

Stack 012 Stack 12 CD12.03 

Stack 12 

None 

EP10.04 EP12.05 to 

EP10.04 

EP12.05 Conveying Equipment #2 and #4 PE 

Drags Plus Elevator 

 58.0 TPH PE 

CD12.05 

EP14.05 EP12.05 to 

EP14.05 

PE 

Dust Bin Waste Group 013 

Dust Bin Waste CD13.01 EP13.01 to 

CD13.01 

Baghouse 

ED13.03 EP13.01 to 

ED13.03 

Baghouse 

EP13.01 

Manufacture: Highland Tank

1991 200 Tons Baghouse 

CD13.01 

ED13.04 EP13.01 to 

ED13.04 

Baghouse 

CD13.01 Baghouse for Dust Bin Waste 

Manufacture: Micro - Pulse

1991 1,700 cfm 

@ 70 

degree. F. @ 

8” SP 

Stack 013 Stack 13 CD13.01 to 

Stack 13 

None 

Dust Bin Waste - Return CD13.02 EP13.02 to 

CD13.02 

EP13.02 Baghouse 

Manufacture: Highland Tank

1991 250 Tons Baghouse 

CD13.02 

ED13.05 EP13.02 to 

ED13.05 

Baghouse 
Title V Operating Permit R30-00300006-2006 Page 11 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

 

CD13.02 Baghouse for Dust Bin Waste 

Manufacture: Micro - Pulse

1991 1,700 cfm 

@ 70 

degree. F. @ 

8” SP 

Stack 014 Stack 14 CD13.02 to 

Stack 14 

None 

EP13.03 Dust Loadout to Customer 1991 50 Tons Baghouse 

CD13.03 

CD13.03 EP13.03 to 

CD13.03 

Baghouse 

Baghouse for Dust Loadout 

Customer 

EP13.03 CD13.03 to 

EP13.03 

CD13.03 Baghouse 

Manufacture: Micro - Pulse

1991 1,700 cfm 

@ 70 

degree. F. @ 

8” SP 

Stack 015 

Stack 15 CD13.03 to 

Stack 15 

None 

CD13.04 EP13.04 to 

CD13.04 

EP13.04 Dust Loadout 1991 50 Tons Nodulizer Nodulizer 

CD13.04 

EP13.05 EP13.04 to 

EP13.06 

None 

EP13.04 CD13.04 to 

EP13.04 

CD13.04 Nodulizer 1972 None None 

CD13.04 EP13.04 to 

CD13.04 

Nodulizer 

CD13.05 EP13.05 to 

CD13.05 

Baghouse 

EP10.01 EP13.05 to 

EP10.01 

CD10.01C 

EP11.01 EP13.05 to 

EP11.01 

CD11.01C 

EP13.05 Dust Return Pump Feed Screw 1991 25 Tons Baghouse 

Baghouse 

CD13.05 

EP12.01 EP13.05 to 

EP12.01 

CD12.01B 

Baghouse for Dust Return Pump 

Feed Screw 

CD13.05 

Manufacture: Micro - Pulse

1991 1,700 cfm 

@ 70 

degree. F. @ 

8” SP 

Stack 016 Stack 16 CD13.05 to 

Stack 16 

Stack 16 

EP13.07 EP13.06 to 

EP13.07 

EP13.06 Clinker Kiln Dust Loading and None 

Unloading by Truck 

 50 Tons None 

Customer EP13.06 to 

Customer 

None 

EP13.07 Clinker Kiln Dust Stockpile None EP13.06 EP13.07 to 

EP13.06 

None 

CD13.08 EP13.08 to 

CD13.08 

EP13.08 Dust Scoop Storage Bin for #8 Kiln 01/27/1999 12 TPH CD13.08 Baghouse 

EP11.01 EP13.08 to 

EP11.01 

EP11.01 

EP11.01 EP13.09 to 

EP11.01 

EP13.09 #8 Kiln Dust Scoop 1999 12 TPH EP11.01 EP11.01 

CD13.09 EP13.09 to 

CD13.09 

Baghouse 

CD13.08 Dust Filter for #8 Kiln Dust Scoop 

Storage Bin 

1999 2,100 

SCFM 

Stack Fan CD13.08 to 

Fan to 

None 
Title V Operating Permit R30-00300006-2006 Page 12 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Manufacture: Industrial Accessories 

Company

Atmosphere 

The Handling of Clinker Group 014 

EP14.02 EP14.01 to 

EP14.02 

EP14.01 Clinker Discharge 1955 and DS & PE 

1971 

128 TPH DSCS 

CD14.01A

CD14.01A EP14.01 to 

CD14.01A 

DS 

CD14.01A Dust Suppressant by Chemical 

Stabilization / Wetting a (DSCS) 

1992 PE 

CD14.01B

CD14.01B CD14.01A to 

CD14.01B

FE 

CD14.01B Stacker 1981 FE None None None 

CD14.02A EP14.02 to 

CD14.02A 

EP14.02 Conveying Equipment 1955 and PE 

1971 

128 TPH PE 

CD14.02A 

EP14.04 EP14.02 to 

EP14.04 

PE 

CD14.02A Dust Suppressant by Chemical 

Stabilization / Wetting a (DSCS) 

1992 PE 

CD14.04B

None None None 

EP14.03 EP14.04 to 

EP14.03 

EP14.04 Stockpile 1955 and PE 

1971 

1.16 Acres PE 

CD14.04 

EP14.05 EP14.04 to 

EP14.05 

PE 

EP16.01 EP14.03 to 

EP16.01 

Baghouse 

EP17.01 EP14.03 to 

EP17.01 

Baghouse 

EP19.01 EP14.03 to 

EP18.01 

Baghouse 

EP14.03 Conveying Equipment 1955 and 

1971 

177 TPH PE 

CD14.03 

EP19.01 EP14.03 to 

EP19.01 

Baghouse 

EP14.06 Loading and Unloading Clinker 1971 150 TPH PE 

CD14.06 

EP14.04 EP14.06 to 

EP14.04 

PE 

EP14.08 EP14.07 to 

EP14.08 

EP14.08 Loading /Unloading (Portable None 

Crusher) Outside Clinker Stockpile 

 540 Tons of 

Cement 

Produced 

per Hour 

None 

EP14.04 EP14.08 to 

EP14.04 

PE 

EP14.05 Reclaim Screen 

Manufacture: Reed

1992 100 TPH PE 

CD14.05 

EP14.08 EP14.05 to 

EP14.08 

PE 

EP14.07 Outside Clinker Stockpile 1971 None EP14.08 EP14.07 to 

EP14.08 

PE 

 Truck Loading/Unloading Clinker2or 

Other Equipment to Reclaim Screen 

 None EP14.05 Truck to 

EP14.05 

PE 

 

Coal Handling Group 015 

EP15.01 Unloading Rail Road Hopper -

Coal/Coke 

1966 and 

1972 

300 TPH PE 

CD15.01 

EP15.02 EP15.01 to 

EP15.02 

PE 
Title V Operating Permit R30-00300006-2006 Page 13 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP15.02 Conveying Equipment -Coal/Coke: 1966 and 

1972 

300 TPH PE 

CD15.02 

EP15.03 EP15.02 to 

EP15.03 

PE 

EP15.03 Conveying Equipment - Coal/Coke: 1966 and 

1972 

300 TPH None EP15.04 EP15.03 to 

EP15.04 

None 

 

EP15.04 Stockpile-Coal/Coke 1965 and 

1972 

12,000 Tons 

 3.9 Acres 

None EP15.05 EP15.03 to 

EP15.05 

None 

EP15.11 Loading / Unloading of Coal / Coke 1972 200 TPH None EP15.04 EP15.11 to 

EP15.04 

None 

EP15.05 Conveying Equipment -Coal/Coke: 1965 and 

1972 

50 TPH FE 

CD15.05 

EP15.06 EP15.05 to 

EP15.06 

FE 

Crusher -Coal/Coke EP15.07 EP15.06 to 

EP15.07 

EP15.06 FE 

Manufacture: Jeffrey Manufacturing 

Company

1965 and 

1971 

50 TPH FE 

CD15.06 

EP15.08 EP15.06 to 

EP15.08 

FE 

EP10.01 EP15.07 to 

EP10.01 

Cyclone 

and ESP 

EP10.01 EP15.07 to 

EP11.01 

Cyclone 

and ESP 

EP15.07 Conveying Equipment -Coal/Coke to 

#9 Kiln 

1965 and 

1972 

16 TPH FE 

CD15.07 

EP10.01 EP15.07 to 

EP12.01 

ESP 

EP15.09 EP15.08 to 

EP15.09 

EP15.08 Conveying Equipment -Coal/Coke to FE 

#7 and #8 Kilns 

1965 and 

1972 

50 TPH FE 

CD15.08 

EP15.10 EP15.08 to 

EP15.10 

FE 

EP10.01 EP15.09 to 

EP10.01 

Cyclone 

and ESP 

EP10.01 EP15.09 to 

EP11.01 

Cyclone 

and ESP 

EP15.09 Conveying Equipment -Coal/Coke to 

#8 Kiln 

1965 and 

1972 

10 TPH FE 

CD15.09 

EP10.01 EP15.09 to 

EP12.01 

ESP 

EP10.01 EP15.10 to 

EP10.01 

Cyclone 

and ESP 

EP10.01 EP15.10 to 

EP11.01 

Cyclone 

and ESP 

EP15.10 Conveying Equipment -Coal/Coke to 

#7 Kiln 

1965 and 

1972 

10 TPH FE 

CD15.10 

EP10.01 EP15.10 to 

EP12.01 

ESP 

Finish Mill Number 7 Group 016 

EP16.02 EP16.01 to 

EP16.02 

EP16.01 Conveying Equipment #7 Mill 1955 and Baghouse 

1971 

30 TPH Baghouse 

CD16.01 

CD16.01 EP16.01 to 

CD16.01 

Baghouse 

Baghouse for Conveying Equipment 

–Number 7 Finish Mill 

CD16.01 

Manufacture: Envirotech

1975 24,000 cfm Stack 017 Stack 17 CD16.01 to 

Stack 17 

None 
Title V Operating Permit R30-00300006-2006 Page 14 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

 

Finish Mill Number 7 CD16.02 EP16.02 to 

CD16.02 

Baghouse 

EP20.01 EP16.02 to 

EP20.01 

Baghouse 

EP21.01 EP16.02 to 

EP21.01 

Baghouse 

EP21.02 EP16.02 to 

EP21.02 

Baghouse 

EP16.02 

Manufacture: Tralyor Manufacturing 

Company 

1955 and 

1971 

30 TPH Baghouse 

CD16.02 

EP22.01 EP16.02 to 

EP22.01 

Baghouse 

CD16.02 Baghouse for Finish Mill # 7 1982 6,000 cfm Stack 018 Stack 18 CD16.02 to 

Stack 18 

None 

Finish Mill Number 8 Group 017 

Conveying Equipment CD17.01 EP17.01 to 

CD17.01 

Baghouse 

EP20.01 EP17.01 to 

EP20.01 

Baghouse 

EP21.01 EP17.01 to 

EP21.01 

Baghouse 

EP21.02 EP17.01 to 

EP21.02 

Baghouse 

EP17.01 

Manufacture: Tralyor Manufacturing 

Company 

1958 and 

1971 

32 TPH Baghouse 

CD17.01 

EP22.01 EP17.01 to 

EP22.01 

Baghouse 

Baghouse for Conveying Equipment 

–Number 8 Finish Mill 

EP17.01 CD17.01 to 

EP17.01 

CD17.01 Baghouse 

Manufacture: Envirotech

1975 32,000 cfm Stack 019 

Stack 19 CD17.01 to 

Stack 19 

None 

Finish Mill Number 9 Group 018 

EP18.01 Conveying Equipment: 1959 and 

1971 

30 TPH Baghouse 

CD18.01 

CD18.01 EP18.01 to 

CD18.01 

Baghouse 

Baghouse for Conveying Equipment 

–Number 9 Finish Mill 

EP18.01 CD18.01 to 

EP18.01 

CD18.01 Baghouse 

Manufacture: Envirotech

1975 24,000 cfm Stack 020 

Stack 20 CD18.01 to 

Stack 20 

None 

Finish Mill Number 9 CD18.02 EP18.02 to 

CD18.02 

Baghouse 

EP20.01 EP18.02 to 

EP20.01 

Baghouse 

EP18.02 

Manufacture: Tralyor Manufacturing 

Company 

1959 and 

1971 

30 TPH Baghouse 

CD18.02 

EP21.01 EP18.02 to 

EP21.01 

Baghouse 
Title V Operating Permit R30-00300006-2006 Page 15 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP21.02 EP18.02 to 

EP21.02 

Baghouse 

EP22.01 EP18.02 to 

EP22.01 

Baghouse 

Baghouse for Finish Mill # 9 EP18.02 CD18.02 to 

EP18.02 

CD18.02 Baghouse 

Manufacture: Torrit

1982 6,000 cfm Stack 021 

Stack 21 CD18.02 to 

Stack 21 

None 

Finish Mill Number 10 Group 019 

EP19.01 Conveying Equipment: 1965 and 

1986 

85 TPH Baghouse 

CD19.01 

CD19.01 EP19.01 to 

CD19.01 

Baghouse 

Baghouse for Conveying Equipment–

Number 10 Finish Mill 

EP19.01 CD19.01 to 

EP19.01 

Baghouse 

Manufacture: Envirotech

Type of Filter: Fabric 

CD19.01 

Control Efficiency: 99.8 % 

1986 20,000 cfm Stack 023 

Stack 23 CD19.01 to 

Stack 23 

None 

Finish Mill Number 10 CD19.02 EP19.02 to 

CD19.02 

Baghouse 

EP20.01 EP19.02 to 

EP20.01 

Baghouse 

EP21.01 EP19.02 to 

EP21.01 

Baghouse 

EP21.02 EP19.02 to 

EP21.02 

Baghouse 

EP19.02Pb 

Manufacture: Traylor Manufacturing 

Company

1965 and 

1986 

85 TPH Baghouse 

CD19.02 

EP22.01 EP19.02 to 

EP22.01 

Baghouse 

Baghouse for Finish Mill # 10 EP19.02 CD19.02 to 

EP19.02 

CD19.02 Baghouse 

Manufacture: Fuller Plenum-Pulse

1986 58,500 cfm 

@ 176 

degree F @ 

27” SP 

Stack 022 

Stack 22 CD19.02 to 

Stack 22 

None 

East Bank Silos Group 020 

East Bank Silos [30 through 45] 

(16 Silos) 

CD20.01 EP20.01 to 

CD20.01 

Baghouse 

EP20.02 EP20.01 to 

EP20.02 

Baghouse 

EP20.03 EP20.01 to 

EP20.03 

Baghouse 

EP23.06 EP20.01 to 

EP23.06 

Baghouse 

EP23.01 EP20.01 to 

EP23.01 

Baghouse 

EP23.02 EP20.01 to 

EP23.02 

Baghouse 

EP24.01 EP20.01 to 

EP24.01 

Baghouse 

EP20.01 

Manufacture: Martin Marietta

1955 and 

1971 

21,848 Tons 

145 TPH 

Baghouse 

CD20.01 

EP24.04 EP20.01 to 

EP24.04 

Baghouse 
Title V Operating Permit R30-00300006-2006 Page 16 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Baghouse for East Bank Silos [30 

through 45] 

EP20.01 CD20.01 to 

EP20.01 

CD20.01 Baghouse 

Manufacture: Buell – Norblo

1970 14,000 cfm Stack 024 

Stack 24 CD20.01 to 

Stack 24 

None 

EP20.03 Silo Loadout 33 

Manufacture: Martin Marietta

1955 and 

1971 

100 TPH Baghouse 

CD20.03 

CD20.03 EP20.03 to 

CD20.03 

Baghouse 

 

Baghouse for Silo Loadout 33 EP20.03 CD20.03 to 

EP20.03 

CD20.03 Baghouse 

Manufacture: Buell – Norblo

1971 1,200 cfm Stack 026 

Stack 26 CD20.03 to 

Stack 26 

None 

Baghouse 

Manufacture: Buell – Norblo

EP20.02 CD20.02 to 

EP20.02 

CD20.02 1971 1,200 cfm Stack 025 Baghouse 

Stack 25 CD20.02 to 

Stack 25 

None 

EP20.02 Silo Loadout 31 

Manufacture: Martin Marietta

1955 and 

1971 

100 TPH Baghouse 

CD20.02 

CD20.02 EP20.02 to 

CD20.02 

Baghouse 

Middle Bank Silos Group 021 

Middle Bank Silos [50 through 65] CD21.01 EP21.01 to 

CD21.01 

Baghouse 

EP21.03 EP21.01 to 

EP21.03 

Baghouse 

EP21.04 EP21.01 to 

EP21.04 

Baghouse 

EP23.03 EP21.01 to 

EP23.03 

Baghouse 

EP23.04 EP21.01 to 

EP23.04 

Baghouse 

EP23.05 EP21.01 to 

EP23.05 

Baghouse 

EP21.01 

Manufacture: Martin Marietta

1957 and 

1971 

20,833 Tons 

177 TPH 

Baghouse 

CD21.01 

EP23.06 EP21.01 to 

EP23.06 

Baghouse 

Baghouse for Middle Bank Silos EP21.01 CD21.01 to 

EP21.01 

CD21.01 Baghouse 

Manufacture: W. W. Sly

1966 4,000 cfm Stack 027 

Stack 27 CD21.01 to 

Stack 27 

None 

Silos - Masonry CD21.02 EP21.02 to 

CD21.02 

Baghouse 

EP21.03 EP21.02 to 

EP21.03 

Baghouse 

EP21.04 EP21.02 to 

EP21.04 

Baghouse 

EP23.03 EP21.02 to 

EP23.03 

Baghouse 

EP21.02 

Manufacture: Martin Marietta

1957 and 

1971 

5,117 Tons 

32.0 TPH 

Baghouse 

CD21.02 

EP23.04 EP21.02 to 

EP23.04 

Baghouse 
Title V Operating Permit R30-00300006-2006 Page 17 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP23.05 EP21.02 to 

EP23.05 

Baghouse 

EP23.06 EP21.02 to 

EP23.08 

Baghouse 

Baghouse for Masonry Silos EP21.02 CD21.02 to 

EP21.02 

CD21.02 Baghouse 

Manufacture: Buell – Norblo

 15,000 cfm Stack 028 

Stack 28 CD21.02 to 

Stack 28 

None 

 

EP21.03 Silo Loadout 51 

Manufacture: Martin Marietta

1957 and 

1971 

100 TPH Baghouse 

CD21.03 

CD21.03 EP21.03 to 

CD21.03 

Baghouse 

CD21.03 Baghouse for Silo Loadout 51 

Manufacture: Buell – Norblo

1973 1,200 cfm Stack 029 EP21.03 CD21.03 to 

EP21.03 

Baghouse 

EP21.04 Silo Loadout 53 

Manufacture: Martin Marietta

1957 and 

1971 

100 TPH Baghouse 

CD21.04 

CD21.04 EP21.04 to 

CD21.04 

Baghouse 

Baghouse for Silo Loadout 53 EP21.04 CD21.04 to 

EP21.04 

CD21.04 Baghouse 

Manufacture: Buell – Norblo

1973 1,200 cfm Stack 030 

Stack 30 CD21.04 to 

Stack 30 

None 

West Bank Silos Group 022 

West Bank Silos [70 to 85] CD22.01 EP22.01 to 

CD22.01 

Baghouse 

EP21.03 EP22.01 to 

EP22.02 

Baghouse 

EP21.04 EP22.01 to 

EP22.03 

Baghouse 

EP23.03 EP22.01 to 

EP23.03 

Baghouse 

EP23.04 EP22.01 to 

EP23.04 

Baghouse 

EP23.05 EP22.01 to 

EP23.05 

Baghouse 

EP23.06 EP22.01 to 

EP23.08 

Baghouse 

EP24.01 EP22.01 to 

EP24.01 

Baghouse 

EP22.01 

Manufacture: Martin Marietta

1964 and 

1971 

21,484 Tons 

145 TPH 

Baghouse 

CD22.01 

EP24.02 EP22.01 to 

EP24.02 

Baghouse 

Baghouse for West Bank Silos [70 to 85] EP22.01 CD22.01 to 

EP22.01 

CD22.01 Baghouse 

Manufacture: Buell- Norblo 

1973 9,300 cfm Stack 031 

Stack 31 CD22.01 to 

Stack31 

None 

EP22.02 Silo Loadout 71 

Manufacture: Martin Marietta

1964 and 

1971 

100 TPH Baghouse 

CD22.03 

CD22.03 EP22.03 to 

CD22.03 

Baghouse 

CD22.02 Baghouse for Silo Loadout 71 

Manufacture: Buell - Norblo

1973 1,200 cfm Stack 032 EP22.03 CD22.03 to 

EP22.03 

Baghouse 
Title V Operating Permit R30-00300006-2006 Page 18 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Stack 32 CD22.03 to 

Stack 32 

None 

EP22.03 Silo Loadout 73 

Manufacture: Martin Marietta

1964 and 

1971 

100 TPH Baghouse 

CD22.03 

CD22.04 EP22.04 to 

CD22.04 

Baghouse 

Baghouse for Silo Loadout 73 EP22.04 CD22.04 to 

EP22.04 

CD22.03 Baghouse 

Manufacture: Buell - Norblo 

1973 1,200 cfm Stack 033 

Stack 33 CD22.04 to 

Stack 33 

None 

Loadout and Packaging Group 023 

Packer - Northeast 

Manufacture: St. Regis Corp.

EP23.01 1956 and 

1971 

62 TPH Baghouse 

CD23.01 

CD23.01 EP23.01 to 

CD23.01 

Baghouse 

CD23.01 Baghouse for Northeast Packer 

Manufacture: Industrial Accessories 

Company

1997 9,680 

ACFM at 

100 o

F 

Stack 034 EP23.01 CD23.01 to 

EP23.01 

None 

Packer - Southeast CD23.02 EP23.02 to 

CD23.02 

EP23.02 Baghouse 

Manufacture: St. Regis Corp.

1956 and 

1971 

62 TPH Baghouse 

CD23.02 

EP23.07 EP23.02 to 

EP23.07 

FE 

Baghouse for Southeast Packer EP23.02 CD23.02 to 

EP23.02 

CD23.02 Baghouse 

Manufacture: Industrial Accessories 

Company

1997 9,680 

ACFM at 

100 o

F 

Stack 035 

Stack 35 CD23.02 to 

Stack 35 

None 

Packer – Northwest CD23.02 EP23.03 to 

CD23.03 

EP23.03 Baghouse 

Manufacture: St. Regis Corp.

1958 and 

1971 

62 TPH Baghouse 

CD23.03 

EP23.07 EP23.03 to 

EP23.07 

FE 

Baghouse for Northwest Packer 

Manufacture: W. W. Sly

EP23.03 CD23.03 to 

EP23.03 

CD23.03 1956 9,680 cfm Stack 038 Baghouse 

Stack 38 CD23.03 to 

Stack 38 

None 

Packer - Southwest CD23.04 EP23.04 to 

CD23.04 

EP23.04 Baghouse 

Manufacture: St. Regis Corp.

1978 62 TPH Baghouse 

CD23.04 

EP23.07 EP23.04 to 

EP23.07 

FE 

Baghouse for Southwest Packer EP24.04 CD23.04 to 

EP23.04 

CD23.04 Baghouse 

Manufacture: Eastern Control

1958 11,627 cfm Stack 037 

Stack 37 CD23.04 to 

Stack 37 

None 

EP23.05 Loadout - Southwest 1957 and 

1971 

100 TPH Baghouse 

CD23.05 

CD23.05 EP23.05 to 

CD23.05 

Baghouse 

Baghouse for Southwest Loadout EP24.05 CD23.05 to 

EP23.05 

CD23.05 Baghouse 

Manufacture: Eastern Control

1976 6,000 cfm Stack 039 

Stack 39 CD23.05 to 

Stack 39 

None 
Title V Operating Permit R30-00300006-2006 Page 19 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP23.06 Loadout - Southeast 1955 and 

1971 

100 TPH Baghouse 

CD23.06 

CD23.06 EP23.06 to 

CD23.06 

Baghouse 

Baghouse for Southeast Loadout EP24.06 CD23.06 to 

EP23.06 

CD23.06 Baghouse 

Manufacture: Buell – Norblo

1974 5,700 cfm Stack 036 

Stack 36 CD23.06 to 

Stack 36 

None 

EP23.07 Palletizer and Conveyor 

Manufacture: Lawson Division

1972 56 TPH FE 

CD23.07 

CD23.07 EP23.07 to 

CD23.07 

FE 

 

EP23.08 Loadout - Northwest 1957 and 

1971 

50 TPH Baghouse 

CD23.04 

CD23.04 EP23.08 to 

CD23.04 

Baghouse 

Bulk Loadout Group 024 

EP24.01 Bins – Bulk Loading Plant 1962 an 

1971 

5,736 Tons 

 320 TPH 

Baghouse 

CD24.01 

CD24.01 EP24.01 to 

CD24.01 

Baghouse 

Baghouse for Bins – Bulk Loading 

Plant 

EP24.01 CD24.01 to 

EP24.01 

CD24.01 Baghouse 

Manufacture: Fuller Plenum - Pulse

1959 8,000 cfm 

@ 12” SP 

@ 70 degree 

F 

Stack 040 

Stack 40 CD24.01 to 

Stack 40 

None 

EP24.02 Loading – North Bulk Loading Plant 1962 and

1971 

125 TPH Baghouse 

CD24.02 

CD24.02 EP24.02 to 

CD24.02 

Baghouse 

Baghouse for Loading – North Bulk 

Loading Plant 

EP24.02 CD24.02 to 

EP24.02 

CD24.02 Baghouse 

Manufacture: W.W. Sly

1959 1,900 cfm Stack 042 

Stack 42 CD24.02 to 

Stack 42 

None 

EP24.03 Loading – South Bulk Loading Plant 1962 and

1971 

125 TPH Baghouse 

CD24.03 

CD24.03 EP24.03 to 

CD24.03 

Baghouse 

Baghouse for Loading – South Bulk 

Loading Plant 

EP24.03 CD24.03 to 

EP24.03 

CD24.03 Baghouse 

Manufacture: W. W. Sly

1959 1,900 cfm Stack 041 

Stack 41 CD24.03 to 

Stack 41 

None 

EP24.04 Bins – Masonry Bulk Loading Plant 1962 and 

1971 

391 Tons 

 125 TPH 

Baghouse 

CD24.04 

CD24.04 EP24.04 to 

CD24.04 

Baghouse 

Baghouse for Bins – Masonry Bulk 

Loading Plant 

EP24.04 CD24.04 to 

EP24.04 

CD24.04 Baghouse 

Manufacture: Torrit

1989 4,100 cfm 

@ 9” SP @ 

70 degree F 

Stack 044 

Stack 44 CD24.04 to 

Stack 44 

None 

Haul Roads Group 025 

EP25.01 Quarry Haul Roads 1972 6.79 

miles/hr 

DSWS None None None 

EP25.02 Quarry Shale Haul Roads 1972 10.14 

miles/hr 

DSWS None None None 

EP25.03 Quarry Haul Roads 1972 18.55 

miles/hr 

DSWS None None None 

EP25.04 Cement Shipment Haul Roads 1972 16.88 

miles/hr 

DSWS None None None 

EP25.05 Sand AL, Etc. Haul Roads 1972 10.00 

miles/hr 

DSWS None None None 
Title V Operating Permit R30-00300006-2006 Page 20 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP25.06 Coal/Coke Haul Roads 1972 10.00 

miles/hr 

DSWS None None None 

EP25.08 Miscellaneous Haul Roads 1972 1.04 

miles/hr 

DSWS None None None 

EP25.09 Fly Ash Haul Roads 1972 4.40 

miles/hr 

DSWS None None None 

EP25.10 Customer Dust Haul Roads 1972 4.00 

miles/hr 

DSWS None None None 

 

EP25.11 Stone Bought/Sold Haul Roads 1972 20.00 

miles/hr 

DSWS None None None 

EP25.12 Gypsum Haul Roads Highway 1972 8.00 

miles/hr 

DSWS None None None 

EP25.13 Clinker Haul Roads Highway 1972 1.20 

miles/hr 

DSWS None None None 

EP25.14 Gypsum Haul Roads Plant Trucks 1972 6.00 

miles/hr 

DSWS None None None 

EP25.15 Clinker Haul Roads Plant 1972 11.20 

miles/hr 

DSWS None None None 

EP01.02 EP0X.03 to 

EP01.02 

None 

EP0X.04 EP0X.03 to 

EP0X.04 

None 

EP0X.03 Quarry Truck Loading and 

Unloading 

1972 805.0 TPH None 

EP0X.05 EP0X.03 to 

EP0X.05 

None 

Material Group 026 

EP26.01 Stockpile – Silica Bearing Material 1972 0.29 ft 2 None None None None 

EP26.02 Material Unloading – Silica Bearing 

Material 

1971 100 TPH None None None None 

CD26.02 Wet Material None None None None 

EP26.04 Material Unloading – Iron Bearing 

Material 

1971 100 TPH None EP26.03 EP26.04 to 

EP26.03 

None 

EP26.03 Stockpile – Iron Bearing Material 1971 0.12 ft 2 None None None None 

EP26.05 Stockpile – Gypsum Type Material 1971 0.46 ft 2 None EP26.06 EP26.05 to 

EP26.06 

None 

EP26.06 Material Load/Unload Gypsum Type 

Material 

1971 100 TPH None EP26.05 EP26.06 to 

EP26.05 

None 

EP26.07 Stockpile – Aluminum Bearing 

Material 

1971 0.06 ft 2 None None None None 

EP26.08 Material Load/Unload Aluminum 

Bearing Material 

1971 100 TPH None EP26.08 EP26.07 to 

EP26.08 

None 

 
Title V Operating Permit R30-00300006-2006 Page 21 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Parts Cleaner Group 027 

EP27.01 Parts Cleaner 1987 6.0 LB of 

Cold 

Cleaner in 

Operation 

Closed 

Lid 

CD27.01 

None None None 

CD27.01 Closed Lid 1987 None None None None 

 

Group 028 

EP28.01 Refrigerant Usage 1972 6.0 LB/hr None None None None 

 

 

Group 029 

EP29.01 Fuel Storage Gas 1972 2.0/1000 

gallons 

storage 

capacity 

None EP29.02 EP29.01 to 

EP29.02 

None 

EP29.02 Fuel Dispensing Gas 1966 and 

1972 

0.15/1000 

gallons 

through put 

None 

 

Boiler Group 030 

EP30.01 Boiler 

Manufacture: Clever Brookes

1966 and 

1972 

0.347 

MMBtu/hr 

at 22.5 per 

gallons of 

oil 

None None None None 

Silo Flyash Group 031 (see Finish Mill – Flow Sheet CC-F-925) 

EP31.01 Truck to 

EP31.01 

 From Truck or Other Equipment None None 

EP31.02 Truck to 

EP31.02 

None 

Silo Flyash CD31.01 EP31.01 to 

CD31.01 

Baghouse 

EP17.01 EP31.01 to 

EP17.01 

Baghouse 

EP31.01 

Manufacture: Highland Tank

1995 300 Tons Baghouse 

CD31.01 

EP19.01 EP31.01 to 

EP19.01 

Baghouse 

Baghouse for Silo Flyash EP31.01 CD31.01 to 

EP31.01 

CD31.01 Baghouse 

Manufacture: Fuller Pulse Jet

1995 1,865 cfm 

@ 70 degree 

F 

Stack 045 

Stack 45 CD31.01 to 

Stack 45 

None 

EP31.02 Silo Flyash 

Manufacture: Highland Tank

1995 300 Tons Baghouse 

CD31.02 

EP31.03 EP31.02 to 

EP31.03 

Baghouse 
Title V Operating Permit R30-00300006-2006 Page 22 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP17.01 EP31.01 to 

EP17.01 

Baghouse 

EP19.01 EP31.01 to 

EP19.01 

Baghouse 

Baghouse for Silo Flyash EP31.02 CD31.02 to 

EP31.02 

CD31.02 Baghouse 

Manufacture: Fuller Pulse Jet

1995 20,000 cfm Stack 046 

Stack 46 CD31.02 to 

Stack 46 

None 

EP31.03 Loadout Flyash 1995 50.0 TPH Baghouse 

CD31.03 

CD31.03 EP31.03 to 

CD31.03 

Baghouse 

 

Baghouse for Loadout Flyash EP31.03 CD31.03 to 

EP31.03 

CD31.03 Baghouse 

Manufacture: Mid – West Interm.

1995 500 cfm @ 

5” SP 

Stack 047 

Stack 47 CD31.03 to 

Stack 47 

None 

Storage Tanks Group 032 

Oil Storage Tanks Underground 

Tanks in Emission Unit ID: 

1946 

through 

1974 

69,000 

Gallons 

Total 

1 1966 10,000 

Gallons 

2 1966 10,000 

Gallons 

3 1966 10,000 

Gallons 

4 1972 20,000 

Gallons 

5 1974 4,000 

Gallons 

EP32.01 

6 1946 15,000 

Gallons 

None None None None 

Oil Storage Tanks Aboveground 

Tanks in Emission Unit ID: 

1992 22,000 

Gallons 

Total 

34 1992 2,000 

35 1992 2,000 

36 1992 2,000 

46 1999 2,000 

55 1999 2,000 

56 1999 15,000 

EP32.02 

6 Tanks 1999 550 

None None None None 
Title V Operating Permit R30-00300006-2006 Page 23 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Tanks Group 033 

EP33.01 Additive (Totes) Tanks 

Exempt from emission levels 

 1, 000 

Gallons 

Each 

Throughput 

None None None None 

 

Group 034 

EP34.01 Spill Cleanup Activities 1955 2.083 TPH 

100.0 Tons 

of Cement 

Handled/hr 

CD34.01 None None None 

CD34.01 Vac Truck and Other Controls -

Miscellaneous 

1955 None None None None 

 

Modern Precalciner Kiln System and Related Equipment 

Quarry and Crushing EU1 

EP37.01 Truck (T1) TBD 3,652,000 

TPY 

None T1 to SB 

EP37.01 Small Bin (SB) TBD 3,652,000 

TPY 

None SB to C1 

EP37.01 Conveyor (C1) TBD 3,652,000 

TPY 

None C1 to C2 

EP37.01 Conveyor (C2) TBD 3,652,000 

TPY 

None NP104 C2 to F1 

EP37.02 Truck (T2) TBD None T2 to LB 

EP37.02 Large Bin (LB) TBD 3,652,000 

TPY 

None LB to C2 

EP37.03 Feeder (F1) TBD 3,395,680 

TPY 

CD37.03 NP104 F1 to C3 

EP37.03 Conveyor (C3) TBD 3,395,680 

TPY 

CD37.03 NP104 C3 to SPT1 

EP37.03 Hammermill (H1) TBD 3,395,680 

TPY 

CD37.03 NP104 H1 to F1 

CD37.03 New Primary Crusher D\C TBD NP104 

EP37.04 Split (SPT1) TBD 3,395,680 SPT1 to SP 1 

TPY 

None NP105 

SPT1 to C4 

EP37.05 Surge Pile (SP 1) TBD 3,652,000 

TPY 

None 

EP37.04 Split (SPT2) TBD 3,395,680 SPT2 to TC1 

TPY 

CD37.04 NP105 

SPT2 to BC1 

EP37.04 Conveyor (C4) TBD 3,395,680 

TPY 

CD37.04 NP105 C4 to SPT2 
Title V Operating Permit R30-00300006-2006 Page 24 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

CD37.04 New Crushing System D\C1 

Manufacture: 

TBD NP105 

EP37.06 Top Conveyor (TC 1) TBD 3,395,680 

TPY 

CD37.06 NP107 TC1 to SW1 

EP37.06 Bottom Conveyor (BC 1) TBD 3,395,680 

TPY 

CD37.06 NP107 BC1 to SPT3 

CD37.06 New Premix Storage Feeding D\C 

Manufacture: 

TBD NP107 

EP38.01 Swing Conveyor (SW1) TBD 3,395,680 

TPY 

CD38.01 NP107 SW1to SP 2 

EP38.01 Storage Pile (SP 2) TBD 3,395,680 SP 2 to FD1 

TPY 

CD38.01 NP107 

SP 2 to FD2 

EP38.02 Feeder 1 (FD1) TBD 3,395,680 

TPY 

CD38.01 NP107 FD1 to BC1 

EP38.02 Feeder 2 (FD2) TBD 3,395,680 STP1 to FD2 

TPY 

CD38.01 NP107 

FD2 to BC1 

CD38.01 New Premix Storage Discharge D\C TBD NP107 

 

 End Loader (EL 1) TBD 3,395,680 

TPY 

 None EL 1 to 1013 

EP01.03 Belt Conveyor 1013 TBD 3,395,680 

TPY 

 NP100 1013 to 40TB 

EP01.04 40 Ton Bin (40TB) TBD 3,395,680 

TPY 

CD01.03 

PE 

NP100 40TB to 

F40TB 

EP01.05 Feeder from 40 Ton Bin (F40TB) TBD 3,395,680 

TPY 

CD01.03 

PE 

NP100 F40TB to 

1011 

EP01.05 Belt Conveyor 1011 TBD 3,395,680 

TPY 

CD01.03 

PE 

NP100 1011 to 1007 

CD01.03BH 40 Ton Bin & Belt Conveyor 1013 D/C TBD 

CD01.05BH Belt Conveyors 1013 & 1011 D/C TBD 

EP01.05 Belt Conveyor 1007 TBD 3,395,680 

TPY 

CD01.05 

PE 

NP101 1007 to SEC 

Secondary Crusher (SEC) and 

8’ X 16’ Screen 

EP02.01 

Manufacture: Simplicity, Tyler & 

Penn Crusher 

TBD 805 TPH CD02.01 SEC to 1000 

CD02.01 Secondary Crusher and Screens D/C TBD 46,000 cfm 

at 

70 degree F 

Stack 2 Stack 2 CD02.01 to 

Stack 2 

None 

EP02.03 Belt Conveyor 1000 TBD 3,395,680 

TPY 

CD02.03A 

DSWS 

NP102 1000 to 999 

EP02.03 Belt Conveyor 999 TBD 3,395,680 

TPY 

CD02.03A 

DSWS 

NP102 999 to 998 

EP02.03 Shuttle Conveyor 998 TBD 3,395,680 

TPY 

CD02.03B 

PE 

NP103 998 to CSSH 

 Raw Storage Hill CRSH TBD 
Title V Operating Permit R30-00300006-2006 Page 25 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Cement Receiving DC1 of Additive 

Cement Consist of:

Truck Dumping of Additive Cement

Truck Dumping to Conveyor (CDC1) 

Conveyor (CDC1) 

Conveyor (CDC1) to Conveyor (CDC2) 

EP46.01 

Conveyor (CDC2) 

TBD CD46.01 NP141 

CD46.01 Cement Receiving DC1 TBD NP141 

Cement Receiving DC2 of Additive 

Cement Consist of:

Conveyor (CDC2) to Conveyor (CDC3) 

EP46.02 

Conveyor (CDC3) 

TBD CD46.02 NP142 

CD46.02 Cement Receiving DC2 TBD NP142 

Cement Receiving DC3 of Additive 

Cement Consist of:

Conveyor (CDC4)

EP46.03 

Conveyor (CDC3) to Conveyor (CDC4) 

TBD CD46.03 NP143 

 

CD46.03 Cement Receiving DC3 TBD NP143 

Cement Receiving DC4 of Additive 

Cement Consist of:

Conveyor (CDC5)

Conveyor (CDC4) to Conveyor (CDC5) 

Stock Pile 

Conveyor (CDC5) to Stock Pile (DC4A) 

End Loader 

Stock Pile (DC4A) to End Loader 

End Loader to Conveyor (CDC6) 

EP46.04 

Conveyor (CDC6)

TBD CD46.04 NP144 

CD46.04 Cement Receiving DC4 TBD NP144 

Cement Receiving DC5 of Additive 

Cement Consist of:

Conveyor (CDC6) to Split (SPT DC5) 

Split (SPT DC5) 

Split (SPT DC5) to Stock Pile (SPDC5) 

Stock Pile (SPDC5) 

Split (SPT DC5) to Conveyor CDC7 

Conveyor CDC7 

EP46.05 

Conveyor CDC7 to Raw Material (EU2) 

Conveyor (C7) by Truck 

TBD CD46.05 NP145 CDC5 to 

CD46.05 Cement Receiving DC5 TBD NP145 

Raw Material Preparation EU2 

EP39.01 Split (SPT3) TBD 3,395,680 STP3 to C5 

TPY 

CD39.01 NP108 

SPT3 to 

LMB 

EP39.01 Conveyor (C5) TBD 3,395,680 C5 to SB 

TPY 

CD39.01 NP108 

C5 to HB 
Title V Operating Permit R30-00300006-2006 Page 26 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP39.03 Limestone Mix Bin (LMB) TBD 3,395,680 

TPY 

CD39.01 NP108 LMB to 

LBMF 

EP39.03 Shale Bin (SB) TBD 339,568 TPY CD39.01 NP108 SB to SBF 

EP39.04 High Bin (HB) 

TBD 

3,395,680 

TPY 

CD39.01 NP108 HB to 

EP39.03 Feeder (F3) TBD 3,395,680 

TPY 

CD39.01 NP108 SB to F3 

EP39.03 Shale Bin Feeder (SBF) TBD 3,395,680 

TPY 

CD39.01 NP108 SBF to C6 

EP39.03 Conveyor (C6) TBD 3,395,680 

TPY 

CD39.01 NP108 

EP39.02 Limestone Mix Bin Feeder (LMBF) TBD 3,395,680 

TPY 

CD39.01 NP108 LMBF to C6 

EP39.04 High Silo (HS) TBD 3,395,680 

TPY 

CD39.01 NP108 HS to HSF 

EP39.04 High Silo Feeder (HSF) TBD 3,395,680 

TPY 

CD39.01 NP108 HSF to C6 

CD39.01 New Limestone Silos Feeding D\C TBD NP108 

 

EP39.05 Additive Truck (T3) TBD 248,286 TPY CD39.05 NP109 T3 to C7 

EP39.05 Additive Conveyor (C7) TBD 248,286 TPY CD39.05 NP109 C7 to C8 

EP39.05 Additive Conveyor (C8) TBD 248,286 TPY CD39.05 NP109 C8 to BE1 

CD39.05 New Additive Discharge System D\C TBD NP109 

EP39.06 Bucket Elevator (BE1) TBD 248,286 TPY CD39.06 NP110 BE1 to C9 

EP39.06 Conveyor (C9) TBD 248,286 TPY CD39.06 NP110 C9 to P S 

EP39.07 Pyrite Silo (P S) TBD 248,286 TPY CD39.06 NP110 P S to PSF 

EP39.07 Pyrite Silo Feeder (PSF) TBD 248,286 TPY CD39.06 NP110 PSF to C6 

EP39.07 Conveyor (C6) TBD 248,286 TPY CD39.06 NP110 C14 to SPT 4 

EP39.08 Sand Silo (S S) TBD 248,286 TPY CD39.06 NP110 S S to SSF 

EP39.08 Sand Silo Feeder (SSF) TBD 248,286 TPY CD39.06 NP110 SSF to C6 

CD40.01 New Raw Mill High Zone D\C TBD NP111 

EP40.01 Split (SPT4) TBD CD40.01 NP111 SPT4 to HP1 

EP40.01 Hopper (HP1) TBD CD40.01 NP111 HP1 to C7 

EP40.02 Conveyor (C7) TBD CD40.02 NP112 C7 to 

SPT5 to BE2 

STP5 to SP 3 

EP40.02 Split (SPT5) TBD CD40.02 NP112 

STP5 to RM1 

EP40.03 Surge Pile (SP3) TBD 3,652,000 

TPY 

None 

EP40.02 Bucket Elevator (BE2) TBD CD40.01 NP112 BE2 to C8 

EP40.02 Conveyor (C8) TBD CD40.01 NP111 C8 to BE2 

EP40.04 Raw Mill (RM1) TBD CD40.02 NP111 RM1 to C8 

EP40.01 Coal Feeders (CF) TBD None CF to CFC 

CD40.02 New Raw Mill Low Zone D\C TBD NP111 

CD40.05 New Raw Meal Air Slide D\C TBD NP113 
Title V Operating Permit R30-00300006-2006 Page 27 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP40.05 Raw Meal Conveying Equipment TBD CD40.05 NP113 EP40.05 to 

EP40.06 

EP40.06 Homo Silo Feeding Equipment TBD CD40.06 NP114 EP40.06 to 

EP40.07 

CD40.06 New Homo Silo Feeding D\C TBD NP114 

EP40.07 Homo Silo Discharge Equipment TBD NP115 EP40.07 to 

EP42.02 

CD40.07 New Homo Silo Discharge D/C TBD NP115 

Pyroprocessing EU3 

EP42.04 New Raw Mill Kiln TBD In = 

3,652,000 

TPY 

Out = 

2,212,890 

TPY of 

Clinker 

 NP118 EP42.04 to 

EP43.01 

 

CD42.04 New Raw Mill Kiln/Clinker Cooler 

D\C 

TBD NP118 

EP42.02 New Kiln Feeding Bucket Elevator 

DC 

TBD 3,652,000 

TPY 

 NP116 EP42.02 to 

EP42.03 

CD42.02 New Kiln Feeding Bucket Elevator 

D\C 

TBD NP116 

CD42.03 New Kiln Feeding with Pump D\C TBD NP117 

EP42.03 New Kiln Feeding with Pump DC TBD 3,652,000 

TPY 

 NP117 EP42.03 to 

EP42.04 

Kiln #7 EP10.01 to 

CD.10.01A 

EP10.01 

Manufacture: Traylor

TBD 

19 

Output: 

100,000 

TPY White 

Cement 

Cyclone 

CD10.01B 

and ESP 

CD10.01C 

CD10.01

A 

EP10.02 EP10.01 to 

EP10.02 

Cyclone 

and ESP 

Baghouse 

CD10.01A Settling Chamber 

Manufacture: Traylor

TBD 

1955 

Cyclone 

CD10.01B 

CD10.01

B 

CD10.01A to 

CD10.01B 

Cyclone 

CD10.01B Number 7 Cyclones (7BC) 

Manufacture: Buell

TBD 

1955 

 ESP 

CD10.01C

CD10.01

C 

CD10.01B to 

CD10.01C 

ESP 

Number 7 Electro Static Precipitator 

(ESP)

CD10.01C 

Manufacture: Western Precipitator

TBD 

1963 

 Stack 008 EP13.01 

EP13.02 

Stack 

008 

CD10.01C to 

EP13.01 

CD10.01C to 

EP13.02 

CD10.01C to 

Stack 008 

Baghouse 

Baghouse 

None 

EP10.03 Number 7 Kiln Torch 

Manufacture: Hauck

TBD 

1971 

140 

gallons/hr of 

1000 

Gallons Fuel 

Oil Burned 

None EP10.01 EP10.03 to 

EP10.01 

Cyclone 

and ESP 
Title V Operating Permit R30-00300006-2006 Page 28 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP10.02 Number 7 Kiln Clinker Cooler 

Manufacture: Fuller Company

TBD 

1955, 

1971, 

06/04/00 

35.0 short 

TPH or 

31.7 metric 

TPH; 35 LB 

/ ton Clinker 

Baghouse 

CD.10.02 

CD10.02 

EP10.04 

EP10.02 to 

CD.10.02 

EP10.02 to 

EP10.04 

Baghouse 

PE 

Number 7 Kiln Clinker Cooler Dust 

Filter (Baghouse) 

CD10.02 

Manufacture: Micro-Pulse

TBD 

1975 and 

2000 

93,000 

ACFM at 

350 oF (2) 

Emission 

Limits are: 

6.11 LB/hr 

and 

26.7 TPY of 

PM 

Stack 9 EP10.04 

Stack 009 

CD.10.02 to 

EP10.04 

CD.10.02 to 

Stack 009 

Baghouse 

None 

EP10.04 Conveying Equipment for #3 and #5 

Drags Plus Elevator 

TBD 128 Tons 

Cement 

Produced 

CD10.04 

PE 

EP14.01 EP10.04 to 

EP14.01 

DSCS 

 

Conveying Equipment for #7 Drags 

Plus Elevator 

EP10.05 

Manufacture: Aumund Louise 

TBD 

06/04/00 

35 Tons 

Cement 

Produced 

CD10.05 

PE 

EP14.01 EP10.05 to 

EP14.01 

DSCS 

Clinker Handling and Storage EU4 

EP43.01 New Clinker Cooler TBD 2,212,890 

TPY 

CD42.02 NP118 

EP43.02 New Clinker Cooler Discharge DC TBD 2,212,890 

TPY 

CD43.02 NP119 

EP43.03 Cooler Conveyor (CoC1) TBD 2,212,890 

TPY 

CD43.03 NP120 CoC1 to ClC1 

EP43.03 Clinker Conveyor (ClC1) TBD 2,212,890 

TPY 

CD43.03 NP120 ClC1 to ClS 1 

EP43.04 Clinker Silo (ClS 1) TBD CD43.04 NP146 ClS 1 to C S

ClS 1 to C N 

BClS to L C 

BClS to M C 

EP43.05 Big Clinker Silo (BClS) TBD CD43.03 NP120 

BClS to U C 

EP43.06 Conveyor S (C S) TBD 2,212,890 C S to U C 

TPY 

CD43.06 NP147 

C S to L C 

EP43.06 Upper Conveyor (U C) TBD 2,212,890 

TPY 

CD43.06 NP147 U C to U C 2 

EP43.06 Lower Conveyor (L C) TBD 2,212,890 

TPY 

CD43.06 NP147 L C to Ci DP 

EP43.06 Conveyor N (C N) 

TBD 

2,212,890 

TPY 

CD43.06 NP147 C N to U C 

EP43.07 Middle Conveyor (M C) 

TBD 

2,212,890 

TPY 

CD43.07 NP121 M C to U C 2 

EP43.07 Upper Conveyor 2 (U C 2) TBD 2,212,890 

TPY 

CD43.07 NP121 U C 2 to FM 

FC1 
Title V Operating Permit R30-00300006-2006 Page 29 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP43.07 Big Clinker Silo TBD CD43.07 NP121 BCS to S C 

EP43.07 Short Conveyor (S C) TBD 2,212,890 

TPY 

CD43.07 NP121 S C to U C 2 

FM FC1 to 

FM FC2 

EP43.08 Existing FM Feed Conveyor1 (FM 

FC1) 

TBD 2,212,890 

TPY 

CD43.08 NP124 

FM FC1 to 

FM10 

EP43.09 Clinker Dispatching (Ci DP) TBD CD43.09 NP122 Ci DP to TL 

EP43.10 Truck Loadout (TL) TBD CD43.10 NP123 TL to Trucks 

EP43.11 Railroad Loadout (RL) TBD CD43.10 NP123 RL to 

Railcars 

EP43.12 Clinker Bin (Ci B) TBD CD43.08 NP124 Ci B to 

 

FM FC2 to 

FM8 

FM FC2 to 

FM7 

EP43.13 Existing FM Feed Conveyor2 (FM 

FC2) 

TBD CD43.13 

FM FC2 to 

FM9 

EP43.14 Clinker Hopper (Finish Mill 8) TBD CD43.13 NP125 FM8 to 

EP43.15 Clinker Hopper (Finish Mill 7) TBD CD43.13 NP125 FM7 to 

EP43.16 Clinker Hopper (Finish Mill 9) TBD CD43.13 NP125 CH9 to 

EP43.17 Clinker Hopper (Finish Mill 10) TBD CD43.13 NP125 CH10 to 

CD43.02 New Cooler Discharge D\C TBD NP112 

CD43.03 New Clinker Storage Feeding D\C TBD NP120 

CD43.04 Small Clinker Storage Discharge D\C TBD NP146 

CD43.06 Small Clinker Storage Feeding D\C TBD NP147 

CD43.07 New Clinker Storage Discharge D\C TBD NP121 

CD43.08 New Steel Conveyor Discharge D\C TBD NP124 

CD43.09 New Shipping Plant Feeding D\C TBD NP124 

CD43.10 New Shipping System D\C TBD NP123 

CD43.13 New Chain Conveyor D\C TBD NP125 

EP43.18 Emergency Outside Clinker Pile TBD None 

EP43.19 Transfer to Emergency Outside 

Clinker Pile 

TBD 3,652,000 

TPY 

None 

EP43.20 Emergency Outside Clinker Pile to 

Underground Conveyor 

TBD 3,652,000 

TPY 

None 

 
Title V Operating Permit R30-00300006-2006 Page 30 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Fuel Handling EU5 

EP41.01 Coal Feeders Conveyor (CFC1) TBD 3,652,000 

TPY 

None CFC1 to CSH 

EP41.02 CSH Fuel Bins TBD 3,652,000 

TPY 

None CSH to CSHF 

EP41.01 CSH Fuel Bins Feeders (CSHF) TBD None CSHF to CF2 

EP41.02 Coal Feeder Conveyor (CF2) TBD None 

EP41.03 Coal Mill (CM) TBD 3,652,000 

TPY 

CD42.04 NP118 

EP41.03 New Coal Dust Silo for Kiln DC TBD 3,652,000 

TPY 

 NP139 

CD41.03 New Coal Dust Silo for Kiln D\C TBD NP139 

EP41.04 New Coal Dust Silo for PRS DC TBD NP140 

CD41.04 New Coal Dust Silo for PRS D\C TBD NP140 

Cement Production EU6 

EP44.01 Gypsum Bin to Finish Mill 12 

(G B 12) 

TBD CD44.01 NP128 G B 12 to 

CFM12 

EP44.01 Gypsum Bin to Finish Mill 11 

(G B 11) 

TBD CD44.02 NP126 G B 11 to 

CFM11 

 

EP44.01 Conveyor for Finish Mill 12 

(CFM12) 

TBD CD44.01 NP128 CFM12 to 

BEFM12 

EP44.02 Conveyor for Finish Mill 11 

(CFM11) 

TBD CD44.02 NP126 CFM11 to 

BEFM11 

EP44.03 Clinker Bin to Finish Mill 12 (CB12) TBD CD44.01 NP128 CB12 to 

CFM12 

EP44.04 Clinker Bin to Finish Mill 11 (CB11) TBD CD44.02 NP126 CB11 to 

FM11 

EP44.05 Additive Bin to Finish Mill 12 

(AB12) 

TBD CD44.02 NP128 AB12 to 

CFM12 

EP44.06 Additive Bin to Finish Mill 11 

(AB11) 

TBD CD44.01 NP126 AB11 to 

FM11 

EP44.07 Bucket Elevator to Finish Mill 11 

(BEFM11) 

TBD CD44.07 NP148 BEFM11 to 

C10 

EP44.07 Conveyor in Finish Mill 11 (C10) TBD CD44.07 NP148 C10 to 

BFM11 

EP44.07 Bin for Finish Mill 11 (BFM11) TBD CD44.07 NP148 BFM11 to 

C11 

EP44.08 Conveyor in Finish Mill 11 (C11) TBD CD44.07 NP148 C11 to FM11 

EP44.09 Finish Mill 11 (FM11) TBD 180 

tons/hour 

CD44.09 NP127 FM11 to C12 

EP44.15 Conveyor from Finish Mill 11 (C12) TBD CD44.07 NP148 C12 to 

CFM11 

EP44.16 Conveyor from Finish Mill 11 (C13) TBD CD44.02 NP126 C13 to 

CFM11 
Title V Operating Permit R30-00300006-2006 Page 31 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP44.08 Bin in Finish Mill 11 (B2FM11) TBD CD44.07 NP148 B2FM11 to 

CFM11 

EP44.08 Conveyor in Finish Mill 11 (C14) TBD CD44.07 NP148 C14 to 

CFM11 

EP44.10 Conveyor in Finish Mill 12 (C15) TBD CD44.10 NP149 C15 to 

EP44.10 Bucket Elevator for Finish Mill 12 

(BEFM12) 

TBD CD44.10 NP149 BEFM12 to 

C15 

EP44.11 Bin for Finish Mill 12 (BFM12) TBD CD44.07 NP149 BFM12 to 

C16 

EP44.12 Conveyor in Finish Mill 12 (C16) TBD 180 

tons/hour 

CD44.10 NP149 C16 to FM12 

EP44.13 Finish Mill 12 (FM12) TBD 180 

tons/hour 

CD44.12 NP129 FM12 to C17 

EP44.14 Conveyor in Finish Mill 12 (C17) TBD CD44.01 NP149 C17 to 

CFM12 

EP44.11 Bin in Finish Mill 12 (B2FM12) TBD CD44.01 NP149 B2FM12 to 

CFM12 

EP44.11 Conveyor in Finish Mill 12 (C18) TBD CD44.10 NP149 C18 to 

CFM12 

CD44.01 New Mill 12 Feeding System D\C TBD NP128 

CD44.02 New Mill 11 Feeding System D\C TBD NP126 

CD44.07 No. 11 Cement Mill D\C TBD NP148 

 

CD44.09 New Cement Mill 11 D\C TBD NP127 

CD44.10 No. 12 Cement Mill D\C TBD NP149 

CD44.12 New Cement Mill 12 D\C TBD NP129 

EP16.01Pb Finish Mill Number 7 Separator 

Manufacture: 

TBD CD16.01 SRCID17 

Baghouse for Conveying Equipment 

–Number 7 Finish Mill 

CD16.01 

Manufacture: Envirotech

TBD 24,000 cfm Stack 17 SRCID17 None 

CD16.02 Baghouse for Finish Mill # 7 

Manufacture: Torrit

TBD 6,000 cfm Stack 18 

EP17.02 Finish Mill Number 8 TBD CD17.01 SRCID19 

EP17.01Pb Finish Mill Number 8 Separator TBD SRCID19 

Baghouse for Conveying Equipment 

–Number 8 Finish Mill 

CD17.01 

Manufacture: Envirotech

TBD 32,000 cfm Stack 19 SRCID19 

EP18.01Pb Finish Mill Number 9 Separator TBD CD18.01 SRCID20 

Baghouse for Conveying Equipment 

–Number 9 Finish Mill 

CD18.01 

Manufacture: Envirotech

TBD 24,000 cfm Stack 20 

CD18.02 Baghouse for Finish Mill # 9 

Manufacture: Torrit

TBD 6,000 cfm Stack 21 

EP19.01Pb Finish Mill Number 10 Separator 

Manufacture: Traylor Manufacturing 

Company

TBD 180 TPH CD19.02 
Title V Operating Permit R30-00300006-2006 Page 32 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

Baghouse for Conveying Equipment–

Number 10 Finish Mill 

CD19.01 

Manufacture: Envirotech

TBD 20,000 cfm Stack 23 

CD19.02 Baghouse for Finish Mill # 10 

Manufacture: Fuller Plenum-Pulse

TBD 58,500 cfm 

@ 176 

degree F @ 

27” SP 

Stack 22 

Shipping EU7 

EP45.01 Bulk Lane Loadout 1 (BLL1) TBD CD45.01 NP135 BLL1 to 

Trucks 

EP45.02 Bulk Lane Loadout 2 (BLL2) TBD CD45.02 NP136 BLL2 to 

Trucks 

EP45.03 Bulk Rail Loadout (BRL) TBD CD45.03 NP137 BRL to Rail 

Cars 

CD45.01 New Bulk Lane 1 D\C TBD NP135 

CD45.02 New Bulk Lane 2 D\C TBD NP136 

CD45.03 New Bulk Rail Lane D\C TBD NP137 

EP45.04 New Ext.1 Cement Silo Feeding DC TBD CD45.04 NP130 

CD45.04 New Ext.1 Cement Silo Feeding D\C TBD NP130 

EP45.05 New Ext.2 Cement Silo Feeding DC TBD CD45.05 NP131 

CD45.05 New Ext. 2 Cement Silo Feeding D\C TBD 

EP45.04 New Ext.3 Cement Silo Feeding DC TBD CD45.06 NP132 

 

CD45.06 New Ext.3 Cement Silo Feeding D\C TBD 

EP45.07 New Int. Cement Silo Feeding DC TBD CD45.07 NP133 

CD45.07 New Int. Cement Silo Feeding D\C TBD NP133 

EP45.08 New Int. Cement Silo Discharge DC TBD CD45.08 NP134 

CD45.08 New Int. Cement Silo Discharge D\C TBD NP134 

Packer #3 

Packer - Southwest 

EP23.04 

Manufacture: St. Regis Corp.

TBD 62 TPH CD23.04 SRCID3

7 

 

CD23.04 Baghouse for Southwest Packer 

Manufacture: Eastern Control

TBD 11,627 cfm Stack 37 SRCID37 

Packer #4 

Packer – Northwest 

EP23.03 

Manufacture: St. Regis Corp.

TBD 62 TPH CD23.03 SRCID38 

CD23.03 Baghouse for Northwest Packer 

Manufacture: W. W. Sly

TBD 9,680 cfm Stack 38 SRCID38 

EP24.01 Bins – Bulk Loading Plant TBD 5,736 Tons 

 320 TPH 

CD24.01 SRCID40 

CD24.01 Baghouse for Bins – Bulk Loading Plant 

Manufacture: Fuller Plenum - Pulse

TBD 8,000 cfm 

@ 12” SP 

@ 70 degree 

F 

Stack 40 SRCID40 

EP48.01 Miscellaneous Packhouse in Color Plant TBD CD48.01 CDC60 

CD48.01 Miscellaneous D\C; Packhouse 

Manufacture: Fuller Plenum - Pulse

TBD CDC60 
Title V Operating Permit R30-00300006-2006 Page 33 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP48.02 Color Loading TBD CD48.02 CDC61 

CD48.02 Color Loading D\C 

Manufacture: Fuller Plenum - Pulse

TBD CDC61 

EP48.03 Bin Filters (14) TBD CDC62 

CD48.03 Bin Filters (14) 

Manufacture: Fuller Plenum - Pulse

TBD CDC62 

EP47.01 East Bank Silos 1 DC TBD CD47.01 NP150 

CD47.01 East Bank Silos 1 DC TBD NP150 

EP20.04 East Bank Silos 2 DC TBD CD20.04 NP151 

CD20.04 East Bank Silos 2 DC TBD NP151 

ED20.05 East Bank Silos 3DC TBD CD20.05 NP152 

CD20.05 East Bank Silos 3DC TBD NP152 

EP20.06 East Bank Silos 4 DC TBD CD20.06 NP153 

CD20.06 East Bank Silos 4DC TBD NP153 

EP20.07 East Bank Silos 5 DC TBD CD20.07 NP154 

CD20.07 East Bank Silos 5 DC TBD NP154 

EP21.05 Middle Bank Silos 1 DC TBD CD21.05 NP155 

CD21.05 Middle Bank Silos 1DC TBD NP155 

EP21.06 Middle Bank Silos 2 DC TBD CD21.06 NP156 

CD21.06 Middle Bank Silos 2DC TBD NP156 

 

EP21.07 Middle Bank Silos 3 DC TBD CD21.07 NP157 

CD21.07 Middle Bank Silos 3DC TBD NP157 

EP21.08 Middle Bank Silos 4 DC TBD CD21.08 NP158 

CD21.08 Middle Bank Silos 4DC TBD NP158 

CD22.04 West Bank Silos 1DC TBD CD22.04 NP159 

CD22.04 West Bank Silos 1 DC TBD NP159 

CD22.05 West Bank Silos 2 DC TBD CD22.05 NP160 

CD22.05 West Bank Silos 2DC TBD NP160 

EP22.06 West Bank Silos 3 DC TBD CD22.06 NP161 

CD22.06 West Bank Silos 3DC TBD NP161 

EP22.07 West Bank Silos 4 DC TBD CD22.07 NP162 

CD22.07 West Bank Silos 4DC TBD NP162 

 

Other Miscellaneous Sources EU8 

EP42.01 Bypass Dust Loadout (BDL) TBD CD42.01 NP163 BDL to 

Railcar 

CD42.01 Kiln Bypass DC TBD NP163 

EP47.02 Slag Storage Pile TBD 180 

tons/hour 

None 

EP50.01 Slag Shipment TBD None 

EP50.02 Slag Shipment TBD None 

EP50.03 Slag Receipts TBD None 
Title V Operating Permit R30-00300006-2006 Page 34 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Associated Emissions Points 

Emission 

Unit ID Emission Unit Description 

Year 

Installed 

or 

Modified 

Design or 

Nominal 

Capacity 

Control 

Device 

ID No Transfer 

Description 

Fugitive 

Dust 

Control 

System/

Control 

Device(1)

EP50.04 Slag Receipts TBD None 

 Slag Handling TBD 

EP25.01 Quarry Haul Roads TBD 6.79 

miles/hr 

DSWS None None None 

EP25.02 Quarry Shale Haul Roads TBD 10.14 

miles/hr 

DSWS None None None 

EP25.03 Quarry Haul Roads TBD 18.55 

miles/hr 

DSWS None None None 

EP25.04 Cement Shipment Haul Roads TBD 16.88 

miles/hr 

DSWS None None None 

EP25.05 Sand AL, Etc. Haul Roads TBD 10.00 

miles/hr 

DSWS None None None 

EP25.05 Additive Trucks TBD DSWS None None None 

EP25.06 Coal/Coke Haul Roads TBD 10.00 

miles/hr 

DSWS None None None 

EP25.06 Fuel Deliveries TBD DSWS None None None 

EP25.07 Waste Dust Trucks TBD DSWS None None None 

EP25.08 Miscellaneous Haul Roads TBD 1.04 

miles/hr 

DSWS None None None 

EP25.09 Fly Ash Haul Roads TBD 4.40 

miles/hr 

DSWS None None None 

 

EP25.10 Waste Dust Customer Haul Roads TBD 4.00 

miles/hr 

DSWS None None None 

EP25.11 Stone Bought/Sold Haul Roads TBD 20.00 

miles/hr 

DSWS None None None 

EP25.12 Gypsum Haul Roads Highway TBD 8.00 

miles/hr 

DSWS None None None 

EP25.13 Clinker Bought/Sold Haul Roads TBD 1.20 

miles/hr 

DSWS None None None 

EP25.15 Clinker Haul Roads Plant TBD 11.20 

miles/hr 

DSWS None None None 

 

(1) Transfer points (TP) have the same type of fugitive dust control system as the associated conveyors unless otherwise noted. Fugitive 

Dust Control System / Control Device abbreviations: FE = Full Enclosure, FE/FE = Full Enclosure in Building, PE = Partial 

Enclosure, NE = No Enclosure, WT = Water Truck, WS = Water Spray, MD = Minimization of Material Drop, DSWS = Dust 

Suppressant by Water Spray, DSCS = Dust Suppression by Chemical Stabilization/ Wetting, TBD = To Be Determined, TPH = Tons 

per hour.

(2) Temperature value limits established by stack testing. 
Title V Operating Permit R30-00300006-2006 Page 35 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 
Title V Operating Permit R30-00300006-2006 Page 36 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.0. General Conditions 

2.1. Definitions 

2.1.1. All references to the "West Virginia Air Pollution Control Act" or the "Air Pollution Control Act" mean those 

provisions contained in W.Va. Code §§ 22-5-1 to 22-5-18. 

2.1.2. The "Clean Air Act" means those provisions contained in 42 U.S.C. §§ 7401 to 7671q, and regulations 

promulgated thereunder. 

2.1.3. "Secretary" means the Secretary of the Department of Environmental Protection or such other person to whom 

the Secretary has delegated authority or duties pursuant to W.Va. Code §§ 22-1-6 or 22-1-8 (45CSR§30-2.12.). 

 The Director of the Division of Air Quality is the Secretary's designated representative for the purposes of this 

permit. 

2.2. Acronyms 

CAAA Clean Air Act Amendments

CBI Confidential Business Information

CEM Continuous Emission Monitor 

CES Certified Emission Statement

C.F.R. or CFR Code of Federal Regulations 

CO Carbon Monoxide 

C.S.R. or CSR Codes of State Rules

DAQ Division of Air Quality

DEP Department of Environmental 

Protection 

FOIA Freedom of Information Act 

HAP Hazardous Air Pollutant 

HON Hazardous Organic NESHAP 

HP Horsepower 

lbs/hr or lb/hr Pounds per Hour 

LDAR Leak Detection and Repair 

M Thousand 

MACT Maximum Achievable Control 

Technology 

MM Million 

MMBtu/hr or Million British Thermal Units per 

 mmbtu/hr Hour 

MMCF/hr or Million Cubic Feet Burned per 

 mmcf/hr Hour

NA Not Applicable 

NAAQS National Ambient Air Quality 

Standards 

NESHAPS National Emissions Standards for 

Hazardous Air Pollutants 

NOx Nitrogen Oxides 

NSPS New Source 

Performance Standards 

PM Particulate Matter 

PM10 Particulate Matter less 

than 10μm in diameter 

pph Pounds per Hour 

ppm Parts per Million 

PSD Prevention of Significant 

Deterioration 

psi Pounds per Square Inch 

SIC Standard Industrial 

Classification 

SIP State Implementation 

Plan 

SO2 Sulfur Dioxide 

TAP Toxic Air Pollutant 

TPY Tons per Year 

TRS Total Reduced Sulfur 

TSP Total Suspended 

Particulate 

USEPA United States 

Environmental 

Protection Agency 

UTM Universal Transverse 

Mercator 

VEE Visual Emissions 

Evaluation 

VOC Volatile Organic 

Compounds 
Title V Operating Permit R30-00300006-2006 Page 37 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.3. Permit Expiration and Renewal 

2.3.1. Permit duration. This permit is issued for a fixed term of five (5) years and shall expire on the date specified on 

the cover of this permit, except as provided in 45CSR§30-6.3.b. and 45CSR§30-6.3.c. 

[45CSR§30-5.1.b.]

2.3.2. A permit renewal application is timely if it is submitted at least six (6) months prior to the date of permit 

expiration. 

[45CSR§30-4.1.a.3.] 

2.3.3. Permit expiration terminates the source's right to operate unless a timely and complete renewal application has 

been submitted consistent with 45CSR§30-6.2. and 45CSR§30-4.1.a.3. 

[45CSR§30-6.3.b.]

2.3.4. If the Secretary fails to take final action to deny or approve a timely and complete permit application before the 

end of the term of the previous permit, the permit shall not expire until the renewal permit has been issued or 

denied, and any permit shield granted for the permit shall continue in effect during that time. 

[45CSR§30-6.3.c.]

2.4. Permit Actions 

2.4.1. This permit 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.

[45CSR§30-5.1.f.3.] 

2.5. Reopening for Cause 

2.5.1. This permit shall be reopened and revised under any of the following circumstances: 

a. Additional applicable requirements under the Clean Air Act or the Secretary's legislative rules become

applicable to a major source with a remaining permit term of three (3) or more years. Such a reopening 

shall be completed not later than eighteen (18) months after promulgation of the applicable requirement. 

No such reopening is required if the effective date of the requirement is later than the date on which the 

permit is due to expire, unless the original permit or any of its terms and conditions has been extended 

pursuant to 45CSR§§30-6.6.a.1.A. or B.

b. Additional requirements (including excess emissions requirements) become applicable to an affected 

source under Title IV of the Clean Air Act (Acid Deposition Control) or other legislative rules of the

Secretary. Upon approval by U.S. EPA, excess emissions offset plans shall be incorporated into the permit. 

c. The Secretary or U.S. EPA determines that the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or conditions of the permit. 

d. The Secretary or U.S. EPA determines that the permit must be revised or revoked and reissued to assure

compliance with the applicable requirements.

[45CSR§30-6.6.a.] 
Title V Operating Permit R30-00300006-2006 Page 38 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.6. Administrative Permit Amendments 

2.6.1. The permittee may request an administrative permit amendment as defined in and according to the procedures 

specified in 45CSR§30-6.4. 

[45CSR§30-6.4.]

2.7. Minor Permit Modifications 

2.7.1. The permittee may request a minor permit modification as defined in and according to the procedures specified 

in 45CSR§30-6.5.a. 

[45CSR§30-6.5.a.]

2.8. Significant Permit Modification 

2.8.1. The permittee may request a significant permit modification, in accordance with 45CSR§30-6.5.b., for permit 

modifications that do not qualify for minor permit modifications or as administrative amendments. 

[45CSR§30-6.5.b.]

2.9. Emissions Trading 

2.9.1. 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 the permit and that are in 

accordance with all applicable requirements. 

[45CSR§30-5.1.h.]

2.10. Off-Permit Changes 

2.10.1. Except as provided below, a facility may make any change in its operations or emissions that is not addressed 

nor prohibited in its permit and which is not considered to be construction nor modification under any rule 

promulgated by the Secretary without obtaining an amendment or modification of its permit. Such changes 

shall be subject to the following requirements and restrictions: 

a. The change must meet all applicable requirements and may not violate any existing permit term or 

condition. 

b. The permittee must provide a written notice of the change to the Secretary and to U.S. EPA within two (2) 

business days following the date of the change. Such written notice shall describe each such change, 

including the date, any change in emissions, pollutants emitted, and any applicable requirement that would 

apply as a result of the change. 

c. The change shall not qualify for the permit shield.

d. The permittee shall keep records describing all changes made at the source that result in emissions of

regulated air pollutants, but not otherwise regulated under the permit, and the emissions resulting from 

those changes. 
Title V Operating Permit R30-00300006-2006 Page 39 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

e. No permittee may make any change subject to any requirement under Title IV of the Clean Air Act (Acid 

Deposition Control) pursuant to the provisions of 45CSR§30-5.9. 

f. No permittee may make any changes which would require preconstruction review under any provision of 

Title I of the Clean Air Act (including 45CSR14 and 45CSR19) pursuant to the provisions of 45CSR§30-

5.9. 

[45CSR30-5.9.]

2.11. Operational Flexibility 

2.11.1. The permittee may make changes within the facility as provided by § 502(b)(10) of the Clean Air Act. Such 

operational flexibility shall be provided in the permit in conformance with the permit application and applicable 

requirements. No such changes shall be a modification under any rule or any provision of Title I of the Clean 

Air Act (including 45CSR14 and 45CSR19) promulgated by the Secretary in accordance with Title I of the

Clean Air Act and the change shall not result in a level of emissions exceeding the emissions allowable under 

the permit. 

[45CSR§30-5.8]

2.11.2. Before making a change under 45CSR§30-5.8., the permittee shall provide advance written notice to the 

Secretary and to U.S. EPA, describing the change to be made, the date on which the change will occur, any 

changes in emissions, and any permit terms and conditions that are affected. The permittee shall thereafter 

maintain a copy of the notice with the permit, and the Secretary shall place a copy with the permit in the public 

file. The written notice shall be provided to the Secretary and U.S. EPA at least seven (7) days prior to the date 

that the change is to be made, except that this period may be shortened or eliminated as necessary for a change 

that must be implemented more quickly to address unanticipated conditions posing a significant health, safety, 

or environmental hazard. If less than seven (7) days notice is provided because of a need to respond more 

quickly to such unanticipated conditions, the permittee shall provide notice to the Secretary and U.S. EPA as 

soon as possible after learning of the need to make the change. 

[45CSR§30-5.8.a.]

2.11.3. The permit shield shall not apply to changes made under 45CSR§30-5.8., except those provided for in 

45CSR§30-5.8.d. However, the protection of the permit shield will continue to apply to operations and

emissions that are not affected by the change, provided that the permittee complies with the terms and

conditions of the permit applicable to such operations and emissions. The permit shield may be reinstated for 

emissions and operations affected by the change: 

a. If subsequent changes cause the facility's operations and emissions to revert to those authorized in the 

permit and the permittee resumes compliance with the terms and conditions of the permit, or 

b. If the permittee obtains final approval of a significant modification to the permit to incorporate the change 

in the permit. 

[45CSR§30-5.8.c.]
Title V Operating Permit R30-00300006-2006 Page 40 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.11.4. "Section 502(b)(10) changes" are changes that contravene an express permit term. Such changes do not include 

changes that would violate applicable requirements or contravene enforceable permit terms and conditions that 

are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements. 

[45CSR§30-2.39] 

2.12. Reasonably Anticipated Operating Scenarios 

2.12.1. The following are terms and conditions for reasonably anticipated operating scenarios identified in this permit. 

a. Contemporaneously with making a change from one operating scenario to another, the permittee shall 

record in a log at the permitted facility a record of the scenario under which it is operating and to document 

the change in reports submitted pursuant to the terms of this permit and 45CSR30. 

b. The permit shield shall extend to all terms and conditions under each such operating scenario; and 

c. The terms and conditions of each such alternative scenario shall meet all applicable requirements and the 

requirements of 45CSR30. 

[45CSR§30-5.1.i.]

2.13. Duty to Comply 

2.13.1. The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation 

of the West Virginia Code and the Clean Air Act and is grounds for enforcement action by the Secretary or 

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

application. 

[45CSR§30-5.1.f.1.]

2.14. Inspection and Entry 

2.14.1. The permittee shall allow any authorized representative of the Secretary, upon the presentation of credentials 

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

a. At all reasonable times (including all times in which the facility is in operation) enter upon the permittee's 

premises where a source is located or emissions related 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 (including all times in which the facility is in operation) any facilities, 

equipment (including monitoring and air pollution Control equipment), practices, or operations regulated or 

required under the permit; 

d. Sample or monitor at reasonable times substances or parameters to determine compliance with the permit

or applicable requirements or ascertain the amounts and types of air pollutants discharged. 

[45CSR§30-5.3.b.] 
Title V Operating Permit R30-00300006-2006 Page 41 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.15. Schedule of Compliance 

2.15.1. For sources subject to a compliance schedule, certified progress reports shall be submitted consistent with the 

applicable schedule of compliance set forth in this permit and 45CSR§30-4.3.h., but at least every six (6) 

months, and no greater than once a month, and shall include the following: 

a. Dates for achieving the activities, milestones, or compliance required in the schedule of compliance, and 

dates when such activities, milestones or compliance were achieved; and 

b. An explanation of why any dates in the schedule of compliance were not or will not be met, and any 

preventative or corrective measure adopted.

[45CSR§30-5.3.d.] 

2.16. Need to Halt or Reduce Activity not a Defense 

2.16.1. 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. However, 

nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a 

mitigating factor in determining penalties for noncompliance if the health, safety, or environmental impacts of 

halting or reducing operations would be more serious than the impacts of continued operations. 

[45CSR§30-5.1.f.2.]

2.17. Emergency 

2.17.1. 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. 

[45CSR§30-5.7.a.]

2.17.2. Effect of any emergency. An emergency constitutes an affirmative defense to an action brought for 

noncompliance with such technology-based emission limitations if the conditions of 45CSR§30-5.7.c. are met. 

[45CSR§30-5.7.b.]

2.17.3. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous 

operating logs, or other relevant evidence that: 

a. An emergency occurred and that the permittee can identify the cause(s) of the emergency; 

b. The permitted facility was at the time being properly operated; 

c. 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 
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West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

d. Subject to the requirements of 45CSR§30-5.1.c.3.C.1, the permittee submitted notice of the emergency to 

the Secretary within one (1) working day of the time when emission limitations were exceeded due to the 

emergency and made a request for variance, and as applicable rules provide. This notice, report, and 

variance request fulfills the requirement of 45CSR§30-5.1.c.3.B. This notice must contain a detailed 

description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. 

[45CSR§30-5.7.c.]

2.17.4. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the 

burden of proof. 

[45CSR§30-5.7.d.]

2.17.5. This provision is in addition to any emergency or upset provision contained in any applicable requirement. 

[45CSR§30-5.7.e.] 

2.18. Federally-Enforceable Requirements 

2.18.1. All terms and conditions in this permit, including any provisions designed to limit a source's potential to emit 

and excepting those provisions that are specifically designated in the permit as "State-enforceable only", are 

enforceable by the Secretary, USEPA, and citizens under the Clean Air Act. 

[45CSR§30-5.2.a.] 

 2.18.2. Those provisions specifically designated in the permit as “State-enforceable only” shall become “Federallyenforceable” requirements upon SIP approval by the USEPA. 

2.19. Duty to Provide Information 

2.19.1. The permittee shall furnish to the Secretary within a reasonable time any information the Secretary 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 Secretary copies 

of records required to be kept by the permittee. For information claimed to be confidential, the permittee shall 

furnish such records to the Secretary along with a claim of confidentiality in accordance with 45CSR31. If 

confidential information is to be sent to USEPA, the permittee shall directly provide such information to 

USEPA along with a claim of confidentiality in accordance with 40 C.F.R. Part 2. 

[45CSR§30-5.1.f.5.] 

2.20. Duty to Supplement and Correct Information 

2.20.1. Upon becoming aware of a failure to submit any relevant facts or a submittal of incorrect information in any 

permit application, the permittee shall promptly submit to the Secretary such supplemental facts or corrected 

information.

[45CSR§30-4.2.] 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.21. Permit Shield 

2.21.1. Compliance with the conditions of this permit shall be deemed compliance with any applicable requirements as 

of the date of permit issuance provided that such applicable requirements are included and are specifically 

identified in this permit or the Secretary has determined that other requirements specifically identified are not 

applicable to the source and this permit includes such a determination or a concise summary thereof. 

[45CSR§30-5.6.a.]

2.21.2. Nothing in this permit shall alter or affect the following: 

a. 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; or 

b. The applicable requirements of the Code of West Virginia and Title IV of the Clean Air Act (Acid 

Deposition Control), consistent with § 408 (a) of the Clean Air Act. 

c. The authority of the Administrator of U.S. EPA to require information under § 114 of the Clean Air Act or 

to issue emergency orders under § 303 of the Clean Air Act. 

[45CSR§30-5.6.c.] 

2.22. Credible Evidence 

2.22.1. Nothing in this permit shall alter or affect the ability of any person to establish compliance with, or a violation 

of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in 

this permit shall be construed to waive any defenses otherwise available to the permittee including but not 

limited to any challenge to the credible evidence rule in the context of any future proceeding. 

[45CSR§30-5.3.e.3.B. and 45CSR38] 

2.23. Severability 

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

of this permit to any circumstance is held invalid by a court of competent jurisdiction, the remaining permit 

terms and conditions or their application to other circumstances shall remain in full force and effect. 

[45CSR§30-5.1.e.] 

2.24. Property Rights 

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

[45CSR§30-5.1.f.4] 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

2.25. Acid Deposition Control 

2.25.1. Emissions shall not exceed any allowances that the source lawfully holds under Title IV of the Clean Air Act 

(Acid Deposition Control) or rules of the Secretary promulgated thereunder. 

a. No permit revision shall be required for increases in emissions that are authorized by allowances acquired 

pursuant to the acid deposition control program, provided that such increases do not require a permit 

revision under any other applicable requirement. 

b. No limit shall be placed on the number of allowances held by the source. The source may not, however,

use allowances as a defense to noncompliance with any other applicable requirement. 

c. Any such allowance shall be accounted for according to the procedures established in rules promulgated

under Title IV of the Clean Air Act. 

[45CSR§30-5.1.d.] 

2.25.2. Where applicable requirements of the Clean Air Act are more stringent than any applicable requirement of 

regulations promulgated under Title IV of the Clean Air Act (Acid Deposition Control), both provisions shall be 

incorporated into the permit and shall be enforceable by the Secretary and U. S. EPA.

[45CSR§30-5.1.a.2.] 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

3.0. Facility-Wide Requirements 

3.1. Limitations and Standards

3.1.1. Open burning. The open burning of refuse by any person, firm, corporation, association or public agency is 

prohibited except as noted in 45CSR§6-3.1. 

[45CSR§6-3.1.]

3.1.2. Open burning exemptions. The exemptions listed in 45CSR§6-3.1 are subject to the following stipulation: 

Upon notification by the Secretary, no person shall cause, suffer, allow or permit any form of open burning 

during existing or predicted periods of atmospheric stagnation. Notification shall be made by such means as the 

Secretary may deem necessary and feasible. 

[45CSR§6-3.2.]

3.1.3. Asbestos. The permittee is responsible for thoroughly inspecting the facility, or part of the facility, prior to

commencement of demolition or renovation for the presence of asbestos and complying with 40 C.F.R. § 

61.145, 40 C.F.R. § 61.148, and 40 C.F.R. § 61.150. The permittee must notify the Secretary at least ten (10) 

working days prior to the commencement of any asbestos removal on the forms prescribed by the Secretary if 

the permittee is subject to the notification requirements of 40 C.F.R. § 61.145(b)(3)(i). A copy of this notice is 

required to be sent to the USEPA, the Division of Waste Management and the Bureau for Public Health - 

Environmental Health. 

[40 C.F.R. 61] 

3.1.4. Odor. No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute to 

an objectionable odor at any location occupied by the public. 

[45CSR§4-3.1 State-Enforceable only.]

3.1.5. [Reserved] 

3.1.6. Standby plan for reducing emissions. When requested by the Secretary, the permittee shall prepare standby 

plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tables I, II, and 

III of 45CSR11. 

[45CSR§11-5.2]

3.1.7. Emission inventory. The permittee is responsible for submitting, on an annual basis, an emission inventory in 

accordance with the submittal requirements of the Division of Air Quality. This report is to be submitted no 

later than July 1 of each year unless directed by DAQ. 

[W.Va. Code § 22-5-4(a)(14)] 

3.1.8. Ozone-depleting substances. For those facilities performing maintenance, service, repair or disposal of 

appliances, the permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 

C.F.R. Part 82, Subpart F, except as provided for Motor Vehicle Air Conditioners (MVACs) in Subpart B:

a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the prohibitions 

and required practices pursuant to C.F.R. §§ 40-82.154 and 82.156. 

b. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the

standards for recycling and recovery equipment pursuant to C.F.R. § 40-82.158. 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

c. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved 

technician certification program pursuant to C.F.R. § 40-82.161.

[40 C.F.R. 82, Subpart F]

3.1.9. Risk Management Plan. Should this stationary source, as defined in 40 C.F.R. § 68.3, become subject to Part 

68, then the owner or operator shall submit a risk management plan (RMP) by the date specified in 40 C.F.R. § 

68.10 and shall certify compliance with the requirements of Part 68 as part of the annual compliance 

certification as required by 40 C.F.R. Part 70 or 71. 

[40 C.F.R. 68] 

3.1.10. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from 

any process source operation which is greater than twenty (20) percent opacity, except as noted in subsections 

45CSR§7- 3.2 (See Section 3.1.11), 3.3, 3.4, 3.5, 3.6, and 3.7. (See Section 3.1.12). 

[45CSR§7-3.1., Groups 001, 002, 025, 026, 029, 030, 032, 033, 034, 45CSR14, R14-026A, B.4., EU1, 

EP39.01, EU8] 

3.1.11. The provisions of Section 3.1.10 (45CSR§7-3.1.) shall not apply to smoke and/or particulate matter emitted 

from any process source operation which is less than forty (40) percent opacity for any period or periods 

aggregating no more than five (5) minutes in any sixty (60) minute period. 

[45CSR§7-3.2., Groups 001, 002, 025, 026, 029, 030, 032, 033, 034, EU1, EP39.01, EU8] 

 3.1.12. No person shall cause, suffer, allow or permit visible emissions from any storage structure(s) associated with 

any manufacturing process(es) that pursuant to Section 3.1.15 [45CSR§7-5.1] is required to have a full

enclosure and be equipped with a particulate matter control device. Compliance with this streamlined opacity 

limit for storage structures assures compliance with the storage structures in 40 C.F.R. 63 Subpart LLL, Section 

3.1.20(40 C.F.R. § 63.1348). 

[45CSR§7-3.7., Groups 020, 021, 022, 031, EP20.01, EP21.01, EP21.02, EP22.01, EP31.01, EP31.02, EU7, 

EU8 ] 

3.1.13. No person shall cause, suffer, allow or permit particulate matter to be vented into the open air from any type 

source operation or duplicate source operation, or from all air pollution control equipment installed on any type 

source operation or duplicate source operation in excess of the quantity specified under the appropriate source 

operation type in 45CSR7, Table 45-7A. Following table list the equipment with their allowable stack emission 

rates. 

Old Sources Allowable Stack Emission Rate 

Description LB PM/hr 

Crushing Facility Equipment Group 001 50 Each 

Secondary Crushing Facility Equipment 

Group 002 

50 Each 

Tertiary Crushing Facility Equipment 

Group 003 

50 Each 

Kiln Number 7 and Associated Equipment 

Group 006 

45.6 Each 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Old Sources Allowable Stack Emission Rate 

Description LB PM/hr 

Kiln Number 8 and Associated Equipment 

Group 007 

45.6 Each 

Kiln Number 9 and Associated Equipment 

Group 012 

56.6 Each 

Dust Bin Waste and Associated Equipment 

Group 013 

43 Each 

The Handling Equipment of Clinker 

Group 014 

50 Each 

Finish Mill Number 7 and Associated 

Equipment Group 016 

31.4 Each 

Finish Mill Number 8 and Associated 

Equipment Group 017 

31.4 Each 

Finish Mill Number 9 and Associated 

Equipment Group 018 

31.4 Each 

Finish Mill Number 10 and Associated 

Equipment Group 019 

43.6 Each 

East Bank Silos and Associated Equipment 

Group 020 

39.7 Each 

Middle Bank Silos, Masonry Silo and 

Associated Equipment Group 021 

41.6 Each 

West Bank Silos and Associated 

Equipment Group 022 

39.7 Each 

Loadout and Packaging Equipment 

Group 023 

37 Each 

Bulk Loadout Equipment Group 024 50 Each 

Silo Flyash Equipment Group 031 33 Each 

 [45CSR§7-4.1., Groups 001, 002, 020, 021, 022, 025, 026, 029, 030, 031, 032, 033, 034] 

3.1.14. Any stack serving any process source operation or air pollution control equipment on any process source 

operation shall contain flow straightening devices or a vertical run of sufficient length to establish flow patterns 

consistent with acceptable stack sampling procedures. 

[45CSR§7-4.12., Groups 001, 002, 020, 021, 022, 025, 026, 029, 030, 031, 032, 033, 034, EU1, EP39.01, 

EP20.01, EP21.01, EP21.02, EP22.01, EP31.01, EP31.02, EU7, EU8] 

 

3.1.15. No person shall cause, suffer, allow, or permit any manufacturing process generating fugitive particulate matter 

to operate that is not equipped with a system to minimize the emissions of fugitive particulate matter. To 

minimize means that a particulate capture or suppression system shall be installed to ensure the lowest fugitive 

particulate emissions reasonably achievable. 

[45CSR§7-5.1., 45CSR14, R14-026A, B.4.] 

 

3.1.16. The owner or operator of a plant shall maintain dust control of the plant premises, and plant owned, leased or 

controlled access roads, by paving, application of asphalt, chemical dust suppressants or other suitable dust 

control measures. Good operating practices shall be implemented and when necessary dust suppressants shall 

be applied in relation to stockpiling and general material handling to prevent dust generation and atmospheric 

entrainment. 

[45CSR§7-5.2., 45CSR14, R14-026A, B.4.] 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

3.1.17. Due to unavoidable malfunction of equipment, emissions exceeding those set forth in 45CSR7 may be permitted 

by the Director for periods not to exceed ten (10) days upon specific application to the Director. Such 

application shall be made within twenty-four (24) hours of the malfunction. In cases of major equipment 

failure, additional time periods may be granted by the Director provided a corrective program has been

submitted by the owner or operator and approved by the Director. 

 [45CSR§7-9.1.]

3.1.18. Maintenance operations (as defined in 45CSR7) shall be exempt from the provisions of 45CSR§7-4 provided 

that at all times the owner or operator shall conduct maintenance operations in a manner consistent with good 

air pollution control practice for minimizing emissions. Determination of whether acceptable operating and 

maintenance procedures are being used will be based on information available to the Director, which may 

include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance 

procedures and inspection of the source. 

 [45CSR§7-10.3.]

3.1.19. The owner or operator of each new or existing raw mill or finish mill at a facility which is a major source 

subject to the provisions of 40 C.F.R. Part 63 Subpart LLL shall not cause to be discharged from the mill 

sweep or air separator air pollution control devices of these affected sources any gases which exhibit

opacity in excess of ten percent (10%). 

[45CSR34, 40 C.F.R. § 63.1347, Raw Mills #5 through #10, Finish Mills #7 through #10, 45CSR14, 

R14-026A, B.10., EU2 and EU6]

3.1.20. The owner or operator of each existing raw material, clinker, or finished product storage bin; conveying system 

transfer point; bagging system; and bulk loading or unloading system at a facility which is a major source 

subject to the provisions of 40 C.F.R. Part 63 Subpart LLL shall not cause to be discharged any gases from 

these affected sources which exhibit opacity in excess of ten percent. 

[45CSR34, 40 C.F.R. § 63.1348, Group (003, 006, 012, 013, 014, 019, 021, 022, 023, and 024), 45CSR14, 

R14-026A, B.10., EU2, EU4, EU6, EU7]

3.1.21. The compliance date for an owner or operator of an affected source subject to the provisions of 40 C.F.R. Part 

63 Subpart LLL that commences new construction or reconstruction after March 24, 1998 is June 14, 1999 or 

upon startup of operations, whichever is later. 

[45CSR34, 40 C.F.R. § 63.1351]

3.2. Monitoring Requirements

3.2.1. The owner or operator of each portland cement plant shall prepare for each affected source subject to the 

provisions of 40 C.F.R. Part 63 Subpart LLL, a written operations and maintenance plan. The affected sources 

are the Raw Material Preparation (EU2), the Pyroprocessing (EU3), the Clinker Handling and Storage (EU4), 

the Cement Production (EU6), the Shipping (EU7), and the Other Miscellaneous Sources (EU8). The plan shall 

be submitted to the Administrator for review and approval as part of the application for a part 70 permit and 

shall include the following information: 

(1) Procedures for proper operation and maintenance of the affected source and air pollution control 

devices in order to meet the emission limits and operating limits of 40 C.F.R. §§ 63.1343 through 

63.1348, except 40 C.F.R. § 63.1346; 

(2) Corrective actions to be taken when required by Section 3.2.5 [40 C.F.R. 63.1350 (e)]; 

(3) Procedures to be used during an inspection of the components of the combustion system of each kiln 

and each in line kiln raw mill located at the facility at least once per year; and 
Title V Operating Permit R30-00300006-2006 Page 49 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(4) Procedures to be used to periodically monitor affected sources subject to opacity standards under

Section 3.1.20 [40 C.F.R. § 63.1348]. Such procedures must include the provisions of Section 3.2.1 

(4) (i) through (iv) [40 C.F.R. §§ 63.1350 (a) (4) (i) through (a) (4) (iv)]. 

(i) The owner or operator must conduct a monthly 1-minute visible emissions test of each 

affected source in accordance with Method 22 of Appendix A to 40 C.F.R part 60 of Chapter 

I of Title 40. The test must be conducted while the affected source is in operation. 

(ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, 

the owner or operator may decrease the frequency of testing from monthly to semi-annually 

for that affected source. If visible emissions are observed during any semi-annual test, the 

owner or operator must resume testing of that affected source on a monthly basis and 

maintains that schedule until no visible emissions are observed in six consecutive monthly 

tests. 

(iii) If no visible emissions are observed during the semi-annual test for any affected source, the 

owner or operator may decrease the frequency of testing from semi-annually to annually for 

that affected source. If visible emissions are observed during any annual test, the owner or 

operator must resume testing of that affected source on a monthly basis and maintains that 

schedule until no visible emissions are observed in six consecutive monthly tests. 

(iv) If visible emissions are observed during any Method 22 test, the owner or operator must 

conduct a 6-minute test of opacity in accordance with Method 9 of appendix A to part 60 of 

Chapter I of Title 40. The Method 9 test must begin within one hour of any observation of 

visible emissions. 

(v) The requirement to conduct Method 22 visible emissions monitoring under this paragraph 

shall not apply to any totally enclosed conveying system transfer point, regardless of the 

location of the transfer point. "Totally enclosed conveying system transfer point" shall mean 

a conveying system transfer point that is enclosed on all sides, top, and bottom. The 

enclosures for these transfer points shall be operated and maintained as total enclosures on a 

continuing basis in accordance with the facility operations and maintenance plan. 

(vi) If any partially enclosed or unenclosed conveying system transfer point is located in a 

building, the owner or operator of the portland cement plant shall have the option to conduct 

a Method 22 visible emissions monitoring test according to the requirements of Section 3.2.1 

(4) (i) through (4) (iv) [40 C.F.R. §§ 63.1350 (a) (4) (i) through (iv)] for each such conveying 

system transfer point located within the building, or for the building itself, according to 

Section 3.2.1 (4) (vii) [40 C.F.R. § 63.1350 (a) (4) (vii)]. 

(vii) If visible emissions from a building are monitored, the requirements of Section 3.2.1 (4) (i) 

[40 C.F.R. § 63.1350 (a) (4) (i)] apply to the monitoring of the building, and you must also 

test visible emissions from each side, roof and vent of the building for at least 1-minute. The 

test must be conducted under normal operating conditions. 

[45CSR34, 40 C.F.R. § 63.1350 (a), 45CSR14, R14-026A, B.10., EU2, EU3, EU4, EU5,EU6, EU7, EU8]

3.2.2. The owner or operator of a kiln shall monitor opacity at each point where emissions are vented from these 

affected sources in accordance with 40 C.F.R. §§ 63.1350 (c) (1) through (c) (3). 
Title V Operating Permit R30-00300006-2006 Page 50 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(1) Except as provided in Section 3.2.2 (2) [40 C.F.R. § 63.1350 (c) (3)], the owner or operator shall 

install, calibrate, maintain, and continuously operate a continuous opacity monitor (COM) located at 

the outlet of the PM control device to continuously monitor the opacity. The COM shall be installed, 

maintained, calibrated, and operated as required by 40 C.F.R. Part 63 Subpart A, general provisions of

40 C.F.R. Part 63, and according to PS-1 of appendix B to part 60 of Chapter I of Title 40. 

(2) To remain in compliance, the opacity must be maintained such that the 6-minute average opacity for 

any 6-minute block period does not exceed 20 percent. If the average opacity for any 6-minute block 

period exceeds 20 percent, this shall constitute a violation of the standard. Startup, Shutdown or 

Malfunction events are not included. 

[45CSR34, 40 C.F.R. § 63.1350 (c) (1) and (3), Group (006, 007, 012), 45CSR14, R14-026A, B.10., 

EP42.04] 

3.2.3. The owner or operator of a clinker cooler shall monitor opacity at each point where emissions are vented from 

the clinker cooler in accordance with Section 3.2.3 (1) through (3) [40 C.F.R. §§ 63.1350 (d) (1) through (d) 

(3)]. 

(1) Except as provided in Section 3.2.3 (2) [40 C.F.R. § 63.1350 (d) (2)], the owner or operator shall 

install, calibrate, maintain, and continuously operate a COM located at the outlet of the clinker cooler 

PM control device to continuously monitor the opacity. The COM shall be installed, maintained, 

calibrated, and operated as required by 40 C.F.R. Part 63 Subpart A, general provisions of 40 C.F.R. 

63, and according to PS-1 of appendix B to part 60 of Chapter I of Title 40. 

(2) The owner or operator of a clinker cooler subject to the provisions of 40 C.F.R. Part 63 Subpart LLL 

using a fabric filter with multiple stacks or an electrostatic precipitator with multiple stacks may, in 

lieu of installing the continuous opacity monitoring system required by Section 3.2.3 (1) [40 C.F.R. §

63.1350 (d) (1)], monitor opacity in accordance with Section 3.2.3 (2) (i) through (ii) [40 C.F.R. § 

63.1350 (d) (2) (i) through (ii)]. If the control device exhausts through a monovent, or if the use of a 

COM in accordance with the installation specifications of PS–1 of appendix B to part 60 of this 

chapter is not feasible, the owner or operator must monitor opacity in accordance with Section 3.2.3 

(2) (i) through (ii) [40 C.F.R. § 63.1350 (d) (2) (i) through (ii)]. 

(i) Perform daily visual opacity observations of each stack in accordance with the procedures of 

Method 9 of appendix A to part 60 of this chapter. The Method 9 test shall be conducted 

while the affected source is operating at the representative performance conditions. The 

duration of the Method 9 test shall be at least 30 minutes each day. 

(ii) Use the Method 9 procedures to monitor and record the average opacity for each six-minute 

period during the test. 

(3) To remain in compliance, the opacity must be maintained such that the 6-minute average opacity for 

any 6-minute block period does not exceed 10 percent. If the average opacity for any 6-minute block 

period exceeds 10 percent, this shall constitute a violation of the standard. Startup, Shutdown or 

Malfunction events are not included. 

[45CSR34, 40 C.F.R. § 63.1350 (d), EP10.02, EP11.02, and EP12.02, 45CSR14, R14-026A, B.10., 

EP43.01] 

3.2.4. The owner or operator of a raw mill or finish mill shall monitor opacity by conducting daily visual emissions 

observations of the mill sweep and air separator PMCD of these affected sources in accordance with the

procedures of Method 22 of appendix A to part 60 of this chapter. The Method 22 test shall be conducted while 

the affected source is operating at the representative performance conditions. The duration of the Method 22 test 
Title V Operating Permit R30-00300006-2006 Page 51 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

shall be 6 minutes. If visible emissions are observed during any Method 22 visible emissions test, the owner or 

operator must: 

(1) Initiate, within one-hour, the corrective actions specified in the site specific operating and maintenance 

plan developed in accordance with Section 3.2.1 (1) and (2) [40 C.F.R. §§ 63.1350 (a) (1) and (a) (2)]; 

and 

(2) Within 24 hours of the end of the Method 22 test in which visible emissions were observed, conduct a 

followup Method 22 test of each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are observed during the followup Method 22 test from 

any stack from which visible emissions were observed during the previous Method 22 test, conduct a 

visual opacity test of each stack from which emissions were observed during the follow up Method 22 

test in accordance with Method 9 of appendix A to part 60 of this chapter. The duration of the Method 

9 test shall be 30 minutes. 

[45CSR34, 40 C.F.R. § 63.1350 (e), Raw Mills #5 through #10, Finish Mills #7 through #10, 45CSR14, 

R14-026A, B.10., EU2 and EU6]

3.2.5. The owner or operator of an affected source subject to a limitation on D/F emissions shall monitor D/F 

emissions in accordance with Section 3.2.6. (1) through (6) [40 C.F.R. §§ 63.1350 (f) (1) through (f) (6)]. 

(1) The owner or operator shall install, calibrate, maintain, and continuously operate a continuous monitor 

to record the temperature of the exhaust gases from the kilnin-line kiln/raw mill and alkali bypass, if 

applicable, at the inlet to, or upstream of, the kiln, in-line kiln/raw mill and/or alkali bypass PM control 

devices 

(i) The recorder response range must include zero and 1.5 times either of the average 

temperatures established according to the requirements in Section 3.3.3 (3) (iv) [40 C.F.R. § 

63.1349 (b) (3) (iv)]. 

(ii) The reference method must be a National Institute of Standards and Technology calibrated 

reference thermocouple-potentiometer system or alternate reference, subject to approval by 

the Administrator. 

(2) The owner or operator shall monitor and continuously record the temperature of the exhaust gases 

from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to the kiln, in-line 

kiln/raw mill and/or alkali bypass PMCD. 

(3) The three-hour rolling average temperature shall be calculated as the average of 180 successive oneminute average temperatures. 

(4) Periods of time when one-minute averages are not available shall be ignored when calculating threehour rolling averages. When one-minute averages become available, the first one-minute average is 

added to the previous 179 values to calculate the three-hour rolling average. 

(5) When the operating status of the raw mill of the in-line kiln/raw mill is changed from off to on, or from 

on to off the calculation of the three-hour rolling average temperature must begin anew, without 

considering previous recordings. 

 (6) The calibration of all thermocouples and other temperature sensors shall be verified at least once every 

three months. 

[45CSR34, 40 C.F.R. § 63.1350 (f), Group (006, 007, 012), 45CSR14, R14-026A, B.10., EP42.04] 
Title V Operating Permit R30-00300006-2006 Page 52 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

3.2.6. The owner or operator of any kiln or in-line kiln/raw mill subject to a D/F emission limit under 40 C.F.R. Part 

63 Subpart LLL shall conduct an inspection of the components of the combustion system of each kiln or in-line 

kiln/raw mill at least once per year. 

[45CSR34, 40 C.F.R. § 63.1350 (i), Groups (006, 007, 012), EP42.04]

3.2.7. The owner or operator of an affected source subject to a limitation on opacity under Section 3.1.20 [40 C.F.R § 

63.1348] shall monitor opacity in accordance with the operation and maintenance plan developed in accordance 

with Section 3.2.1 [40 C.F.R. § 63.1350 (a)]. 

[45CSR34, 40 C.F.R. § 63.1350 (j), Group (003, 006, 012, 013, 014, 019, 021, 022, 023, and 024), 

45CSR14, R14-026A, B.10., EU2, EU4, EU6, EU7]

3.2.8. The owner or operator of an affected source subject to a particulate matter standard under 40 C.F.R. § 63.1343 

shall install, calibrate, maintain, and operate a particulate matter continuous emission monitoring system (PM 

CEMS) to measure the particulate matter discharged to the atmosphere. All requirements relating to installation, 

calibration, maintenance, operation or performance of the PM CEMS and implementation of the PM CEMS 

requirement are deferred pending further rulemaking. 

[45CSR34, 40 C.F.R. § 63.1350 (k), Group (006, 007, and 012), 45CSR14, R14-026A, B.10., EP42.04]

3.2.9. An owner or operator may submit an application to the Administrator for approval of alternate monitoring 

requirements to demonstrate compliance with the emission standards of 40 C.F.R Part 63 Subpart LLL subject 

to the provisions of Section 3.2.9. (1) through (6) [40 C.F.R. §§ 63.1350 (l) (1) through (l) (6)]. 

(1) The Administrator will not approve averaging periods other than those specified in this section, unless 

the owner or operator documents, using data or information, that the longer averaging period will 

ensure that emissions do not exceed levels achieved during the performance test over any increment of 

time equivalent to the time required to conduct three runs of the performance test. 

(2) If the application to use an alternate monitoring requirement is approved, the owner or operator must 

continue to use the original monitoring requirement until approval is received to use another 

monitoring requirement. 

(3) The owner or operator shall submit the application for approval of alternate monitoring requirements 

no later than the notification of performance test. The application must contain the information 

specified in Section 3.2.9. (3) (i) through (3) (iii) [40 C.F.R. §§ 63.1350 (l) (3) (i) through (l) (3) (iii)]: 

(i) Data or information justifying the request, such as the technical or economic infeasibility, or 

the impracticality of using the required approach; 

(ii) A description of the proposed alternative monitoring requirement, including the operating 

parameter to be monitored, the monitoring approach and technique, the averaging period for 

the limit, and how the limit is to be calculated; and 

(iii) Data or information documenting that the alternative monitoring requirement would provide 

equivalent or better assurance of compliance with the relevant emission standard. 

(4) The Administrator will notify the owner or operator of the approval or denial of the application within 

90 calendar days after receipt of the original request, or within 60 calendar days of the receipt of any 

supplementary information, whichever is later. The Administrator will not approve an alternate 

monitoring application unless it would provide equivalent or better assurance of compliance with the 

relevant emission standard. Before disapproving any alternate monitoring application, the 

Administrator will provide: 
Title V Operating Permit R30-00300006-2006 Page 53 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(i) Notice of the information and findings upon which the intended disapproval is based; and 

(ii) Notice of opportunity for the owner or operator to present additional supporting information 

before final action is taken on the application. This notice will specify how much additional 

time is allowed for the owner or operator to provide additional supporting information. 

(5) The owner or operator is responsible for submitting any supporting information in a timely manner to 

enable the Administrator to consider the application prior to the performance test. Neither submittal of 

an application, nor the Administrator's failure to approve or disapprove the application relieves the 

owner or operator of the responsibility to comply with any provision of 40 C.F.R. Part 63 Subpart 

LLL. 

(6) The Administrator may decide at any time, on a case-by-case basis that additional or alternative 

operating limits, or alternative approaches to establishing operating limits, are necessary to 

demonstrate compliance with the emission standards of 40 C.F.R. Part 63 Subpart LLL. 

[45CSR34, 40 C.F.R. § 63.1350 (l), Group 006, 007, 012, 013, 014, 019, 021, 022, 023, 024, EU3, EU4, 

EU6, EU7]

3.2.10. The requirements under Section 3.2.4 [40 C.F.R. § 63.1350 (e)] to conduct daily Method 22 testing shall not 

apply to any specific raw mill or finish mill equipped with a continuous opacity monitor COM or bag leak 

detection system (BLDS). If the owner or operator chooses to install a COM in lieu of conducting the daily 

visual emissions testing required under 3.2.4 [40 C.F.R. § 63.1350 (e)], then the COM must be installed at the 

outlet of the PM control device of the raw mill or finish mill, and the COM must be installed, maintained, 

calibrated, and operated as required by the general provisions in subpart A of this part and according to PS–1 of 

appendix B to part 60 of this chapter. To remain in compliance, the opacity must be maintained such that the 6-

minute average opacity for any 6-minute block period does not exceed 10 percent. If the average opacity for any 

6-minute block period exceeds 10 percent, this shall constitute a violation of the standard. If the owner or 

operator chooses to install a BLDS in lieu of conducting the daily visual emissions testing required under 

paragraph (e) of this section, the requirements in 3.2.10 (1) through (9) [40 C.F.R. § 63.1350 (m)(1) through 

(9)] apply to each BLDS: 

 (1) The BLDS must be certified by the manufacturer to be capable of detecting PM emissions at 

concentrations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. 

“Certify” shall mean that the instrument manufacturer has tested the instrument on gas streams having 

a range of particle size distributions and confirmed by means of valid filterable PM tests that the 

minimum detectable concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 

grains per actual cubic foot) or less. 

(2) The sensor on the BLDS must provide output of relative PM emissions. 

(3) The BLDS must have an alarm that will activate automatically when it detects a significant increase in 

relative PM emissions greater than a preset level. 

(4) The presence of an alarm condition should be clearly apparent to facility operating personnel. 

(5) For a positive-pressure fabric filter, each compartment or cell must have a bag leak detector. For a 

negative-pressure or induced-air fabric filter, the bag leak detector must be installed downstream of the 

fabric filter. If multiple bag leak detectors are required (for either type of fabric filter), detectors may 

share the system instrumentation and alarm. 
Title V Operating Permit R30-00300006-2006 Page 54 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(6) All BLDS must be installed, operated, adjusted, and maintained so that they are based on the 

manufacturer's written specifications and recommendations. The EPA recommends that where 

appropriate, the standard operating procedures manual for each bag leak detection system include 

concepts from EPA's “Fabric Filter Bag Leak Detection Guidance” (EPA–454/R–98–015, September 

1997). 

(7) The baseline output of the system must be established as follows: 

(i) Adjust the range and the averaging period of the device; and 

(ii) Establish the alarm set points and the alarm delay time. 

(8) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be 

adjusted except as specified in the operations and maintenance plan required by paragraph (a) of this 

section. In no event may the range be increased by more than 100 percent or decreased by more than 

50 percent over a 1 calendar year period unless a responsible official as defined in §63.2 certifies in 

writing to the Administrator that the fabric filter has been inspected and found to be in good operating 

condition. 

(9) The owner or operator must maintain and operate the fabric filter such that the bag leak detector alarm 

is not activated and alarm condition does not exist for more than 5 percent of the total operating time 

in a 6-month block period. Each time the alarm activates, alarm time will be counted as the actual 

amount of time taken by the owner or operator to initiate corrective actions. If inspection of the fabric 

filter demonstrates that no corrective actions are necessary, no alarm time will be counted. The owner

or operator must continuously record the output from the BLDS during periods of normal operation. 

Normal operation does not include periods when the BLDS is being maintained or during startup, 

shutdown or malfunction. 

[45CSR34, 40 C.F.R. § 63.1350 (m), 45CSR14, R14-026A, B.10., EU2 and EU6]

3.2.11. Startup, shutdown, and malfunction plan.

 (i) The owner or operator of an affected source must develop and implement a written startup, shutdown, 

and malfunction plan that describes, in detail, procedures for operating and maintaining the source 

during periods of startup, shutdown, and malfunction, and a program of corrective action for 

malfunctioning process and air pollution control and monitoring equipment used to comply with the 

relevant standard. This plan must be developed by the owner or operator by the source's compliance 

date for that relevant standard. The purpose of the startup, shutdown, and malfunction plan is to -- 

 (A) Ensure that, at all times, the owner or operator operates and maintains each affected source, 

including associated air pollution control and monitoring equipment, in a manner which 

satisfies the general duty to minimize emissions established by 40 C.F.R. § 63.3 (e) (1) (i); 

 (B) Ensure that owners or operators are prepared to correct malfunctions as soon as practicable 

after their occurrence in order to minimize excess emissions of hazardous air pollutants; and 

 (C) Reduce the reporting burden associated with periods of startup, shutdown, and malfunction 

(including corrective action taken to restore malfunctioning process and air pollution control 

equipment to its normal or usual manner of operation). 
Title V Operating Permit R30-00300006-2006 Page 55 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 (ii) During periods of startup, shutdown, and malfunction, the owner or operator of an affected source 

must operate and maintain such source (including associated air pollution control and monitoring 

equipment) in accordance with the procedures specified in the startup, shutdown, and malfunction plan 

developed under Section 3.2.11 (i) [40 C.F.R. § 63.3 (e) (3) (i)]. 

 (iii) When actions taken by the owner or operator during a startup, shutdown, or malfunction (including 

actions taken to correct a malfunction) are consistent with the procedures specified in the affected 

source's startup, shutdown, and malfunction plan, the owner or operator must keep records for that 

event which demonstrate that the procedures specified in the plan were followed. These records may 

take the form of a "checklist," or other effective form of recordkeeping that confirms conformance 

with the startup, shutdown, and malfunction plan for that event. In addition, the owner or operator 

must keep records of these events as specified in 40 C.F.R. § 63.10 (b), including records of the 

occurrence and duration of each startup, shutdown, or malfunction of operation and each malfunction 

of the air pollution control and monitoring equipment. Furthermore, the owner or operator shall 

confirm that actions taken during the relevant reporting period during periods of startup, shutdown, 

and malfunction were consistent with the affected source's startup, shutdown and malfunction plan in 

the semiannual (or more frequent) startup, shutdown, and malfunction report required in 40 C.F.R. § 

63.10 (d) (5). 

 (iv) If an action taken by the owner or operator during a startup, shutdown, or malfunction (including an 

action taken to correct a malfunction) is not consistent with the procedures specified in the affected

source's startup, shutdown, and malfunction plan, and the source exceeds any applicable emission 

limitation in the relevant emission standard, then the owner or operator must record the actions taken

for that event and must report such actions within 2 working days after commencing actions 

inconsistent with the plan, followed by a letter within 7 working days after the end of the event, in 

accordance with 40 C.F.R. § 63.10 (d) (5) (unless the owner or operator makes alternative reporting 

arrangements, in advance, with the Administrator). 

 (v) The owner or operator must maintain at the affected source a current startup, shutdown, and 

malfunction plan and must make the plan available upon request for inspection and copying by the 

Administrator. In addition, if the startup, shutdown, and malfunction plan is subsequently revised as 

provided in Section 3.2.11 (viii) [40 C.F.R. § 63.3 (e) (3) (viii)], the owner or operator must maintain 

at the affected source each previous (i.e., superseded) version of the startup, shutdown, and 

malfunction plan, and must make each such previous version available for inspection and copying by 

the Administrator for a period of 5 years after revision of the plan. If at any time after adoption of a 

startup, shutdown, and malfunction plan the affected source ceases operation or is otherwise no longer

subject to the provisions of this part, the owner or operator must retain a copy of the most recent plan 

for 5 years from the date the source ceases operation or is no longer subject to this part and must make 

the plan available upon request for inspection and copying by the Administrator. The Administrator 

may at any time request in writing that the owner or operator submit a copy of any startup, shutdown, 

and malfunction plan (or a portion thereof) which is maintained at the affected source or in the 

possession of the owner or operator. Upon receipt of such a request, the owner or operator must 

promptly submit a copy of the requested plan (or a portion thereof) to the Administrator. The 

Administrator must request that the owner or operator submit a particular startup, shutdown, or 

malfunction plan (or a portion thereof) whenever a member of the public submits a specific and 

reasonable request to examine or to receive a copy of that plan or portion of a plan. The owner or 

operator may elect to submit the required copy of any startup, shutdown, and malfunction plan to the 

Administrator in an electronic format. If the owner or operator claims that any portion of such a 

startup, shutdown, and malfunction plan is confidential business information entitled to protection 

from disclosure under section 114(c) of the Clean Air Act or 40 CFR 2.301, the material which is 

claimed as confidential must be clearly designated in the submission. 
Title V Operating Permit R30-00300006-2006 Page 56 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 (vi) To satisfy the requirements of this section to develop a startup, shutdown, and malfunction plan, the 

owner or operator may use the affected source's standard operating procedures (SOP) manual, or an 

Occupational Safety and Health Administration (OSHA) or other plan, provided the alternative plans 

meet all the requirements of this section and are made available for inspection or submitted when 

requested by the Administrator. 

 (vii) Based on the results of a determination made under 40 C.F.R. § 63.3 6 (e) (1) (i), the Administrator 

may require that an owner or operator of an affected source make changes to the startup, shutdown, 

and malfunction plan for that source. The Administrator must require appropriate revisions to a 

startup, shutdown, and malfunction plan, if the Administrator finds that the plan: 

 (A) Does not address a startup, shutdown, or malfunction event that has occurred; 

 (B) Fails to provide for the operation of the source (including associated air pollution control and

monitoring equipment) during a startup, shutdown, or malfunction event in a manner 

consistent with the general duty to minimize emissions established by 40 C.F.R. § 63.3 (e) (1) 

(i); 

 (C) Does not provide adequate procedures for correcting malfunctioning process and/or air 

pollution control and monitoring equipment as quickly as practicable; or 

 (D) Includes an event that does not meet the definition of startup, shutdown, or malfunction listed 

in 40 C.F.R. § 63.2. 

 (viii) The owner or operator may periodically revise the startup, shutdown, and malfunction plan for the 

affected source as necessary to satisfy the requirements of this part or to reflect changes in equipment 

or procedures at the affected source. Unless the permitting authority provides otherwise, the owner or

operator may make such revisions to the startup, shutdown, and malfunction plan without prior 

approval by the Administrator or the permitting authority. However, each such revision to a startup, 

shutdown, and malfunction plan must be reported in the semiannual report required by 40 C.F.R. § 

63.10 (d) (5). If the startup, shutdown, and malfunction plan fails to address or inadequately addresses 

an event that meets the characteristics of a malfunction but was not included in the startup, shutdown, 

and malfunction plan at the time the owner or operator developed the plan, the owner or operator must 

revise the startup, shutdown, and malfunction plan within 45 days after the event to include detailed 

procedures for operating and maintaining the source during similar malfunction events and a program 

of corrective action for similar malfunctions of process or air pollution control and monitoring 

equipment. In the event that the owner or operator makes any revision to the startup, shutdown, and 

malfunction plan which alters the scope of the activities at the source which are deemed to be a startup, 

shutdown, or malfunction, or otherwise modifies the applicability of any emission limit, work practice

requirement, or other requirement in a standard established under this part, the revised plan shall not 

take effect until after the owner or operator has provided a written notice describing the revision to the 

permitting authority. 
Title V Operating Permit R30-00300006-2006 Page 57 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(ix) The title V permit for an affected source must require that the owner or operator adopt a startup, 

shutdown, and malfunction plan which conforms to the provisions of this part, and that the owner or 

operator operate and maintain the source in accordance with the procedures specified in the current 

startup, shutdown, and malfunction plan. However, any revisions made to the startup, shutdown, and 

malfunction plan in accordance with the procedures established by this part shall not be deemed to 

constitute permit revisions under part 70 or part 71 of this chapter. Moreover, none of the procedures

specified by the startup, shutdown, and malfunction plan for an affected source shall be deemed to fall 

within the permit shield provision in section 504 (f) of the Clean Air Act.

[45CSR34, 40 C.F.R. § 63.6 (e) (3), Group (006, 007, 012, 013, 014, 019, 021, 022, 023, and 024), EU2 

through EU7]

 3.2.12. The permittee shall conduct monitoring/Record Keeping/reporting as follows. [Not required for open 

stockpiles, Coal and Limestone Feed Stockpile Common to Kiln #7, Kiln #8, Kiln #9, haulroads, haulroads and 

activities regulated by 40 C.F.R. Part 63 Subpart LLL.] 

a. Visible emission observations shall be conducted weekly for fugitive particulate emission activities 

identified in Section 1.0 by a certified Method 9 observer during periods of normal operation for a 

sufficient time interval to determine if any of the emission units listed above or emission points have 

visible emissions and if so, the opacity of the emissions. If any of the emission units listed above or 

emission points have visible emissions exceeding the regulatory limit of twenty percent (20%) opacity,

then a 45CSR7A evaluation shall be conducted immediately after the violation of the regulatory limit 

unless the permittee can demonstrate a valid reason that the time frame should be extended. A 

45CSR7A evaluation shall not be required if the condition resulting in the excess visible emissions is

corrected within 24 hours and the units are operated at normal operating conditions.

 

b. A record of each visible emissions observation shall be maintained, including any data required by 40 

C.F.R. 60 Appendix A, Method 22 or 45CSR7A, whichever is appropriate. The record shall include, 

at a minimum, the date, time, name of the emission unit, the applicable visible emissions requirement,

the results of the observation, and the name of the observer. Records shall be maintained on site for a 

period of no less than five (5) years stating any maintenance or corrective actions taken as a result of 

the weekly inspections, and the times the fugitive dust control system(s) are inoperable and any 

corrective actions taken. 

 

 [45CSR§30-5.1.c.]

3.2.13. The permittee shall conduct weekly visible emission observations on all dust collectors and the permitee shall 

maintain instrumentation on all dust collectors for pressure drop observations. The permittee shall maintain 

records of the maintenance performed on each baghouse. These records shall include all maintenance work 

performed on each dust collector including the frequency of bag/filter change outs. Records shall state the date 

and time of each dust collector inspection, the inspection results, and corrective action taken, if any. Records 

shall be maintained on site for five (5) years from the record creation date. 

 [45CSR§30-5.1.c.] 
Title V Operating Permit R30-00300006-2006 Page 58 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

3.2.14. The permittee shall maintain daily records indicating the use of any dust suppressants or any other suitable dust 

controls measures applied at the facility. The permittee shall also inspect all fugitive dust control systems 

weekly from May 1 through September 30 and monthly from October 1 through April 30 to ensure that they are 

operated and maintained in conformance with their designs. The permittee shall maintain records of all 

scheduled and non-scheduled maintenance and shall state any maintenance or corrective actions taken as a result 

of the weekly and/or monthly inspections, the times the fugitive dust control system(s) were inoperable and any 

corrective actions taken. 

[45CSR§30-5.1.c.]

3.3. Testing Requirements

3.3.1. Stack testing. As per provisions set forth in this permit or as otherwise required by the Secretary, in 

accordance with the West Virginia Code, underlying regulations, permits and orders, the permittee shall conduct 

test(s) to determine compliance with the emission limitations set forth in this permit and/or established or set 

forth in underlying documents. The Secretary or his duly authorized representative may at his option witness or 

conduct such test(s). Should the Secretary exercise his option to conduct such test(s), the operator shall provide 

all necessary sampling connections and sampling ports to be located in such manner as the Secretary may 

require, power for test equipment and the required safety equipment, such as scaffolding, railings and ladders, to 

comply with generally accepted good safety practices. Such tests shall be conducted in accordance with the 

methods and procedures set forth in this permit or as otherwise approved or specified by the Secretary in 

accordance with the following: 

a. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing to 

the test methods specified in the permit for demonstrating compliance with 40 C.F.R. Parts 60, 61, and 63, 

if applicable, in accordance with the Secretary’s delegated authority and any established equivalency 

determination methods which are applicable. 

b. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing to 

the test methods specified in the permit for demonstrating compliance with applicable requirements which 

do not involve federal delegation. In specifying or approving such alternative testing to the test methods, 

the Secretary, to the extent possible, shall utilize the same equivalency criteria as would be used in

approving such changes under Section 3.3.1.a. of this permit. 

c. All periodic tests to determine mass emission limits from or air pollutant concentrations in discharge stacks 

and such other tests as specified in this permit shall be conducted in accordance with an approved test 

protocol. Unless previously approved, such protocols shall be submitted to the Secretary in writing at least 

thirty (30) days prior to any testing and shall contain the information set forth by the Secretary. In addition, 

the permittee shall notify the Secretary at least fifteen (15) days prior to any testing so the Secretary may 

have the opportunity to observe such tests. This notification shall include the actual date and time during 

which the test will be conducted and, if appropriate, verification that the tests will fully conform to a 

referenced protocol previously approved by the Secretary. 

[WV Code § 22-5-4(a)(15) and 45CSR13]

 3.3.2. The owner or operator of an affected source subject to 40 C.F.R. Part 63 Subpart LLL shall demonstrate initial 

compliance with the emission limits of 40 C.F.R. § 63.1343 and 40 C.F.R. § 63.1345, and Sections 3.1.19 and 

3.1.20 [40 C.F.R. §§ 63.1347 through 63.1348] using the test methods and procedures in Section 3.3.3 [40 

C.F.R. § 63.1349 (b)] and 40 C.F.R. § 63.7. Performance test results shall be documented in complete test 

reports that contain the information required by Section 3.3.2 (1) through (10) [40 C.F.R. §§ 63.1349 (a) (1) 
Title V Operating Permit R30-00300006-2006 Page 59 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

through (a) (10)] as well as all other relevant information. The plan to be followed during testing shall be made 

available to the Administrator prior to testing, if requested. 

(1) A brief description of the process and the air pollution control system; 

(2) Sampling location description(s); 

(3) A description of sampling and analytical procedures and any modifications to standard procedures; 

(4) Test results; 

(5) Quality assurance procedures and results; 

(6) Records of operating conditions during the test, preparation of standards, and calibration procedures; 

(7) Raw data sheets for field sampling and field and laboratory analyses; 

(8) Documentation of calculations; 

(9) All data recorded and used to establish parameters for compliance monitoring; and 

(10) Any other information required by the test method. 

[45CSR34, 40 C.F.R. § 63.1349 (a), Groups (006, 007, 012, 013, 014, 019, 021, 022, 023, and 024), 

45CSR14, R14-026A, B.10., EU3, EU4, EU6, EU7]

3.3.3. Performance tests to demonstrate compliance with 40 C.F.R. Part 63 Subpart LLL shall be conducted as 

specified in Section 3.3.3 [40 C.F.R. §§ 63.1349 (b)(1) through (b)(3)]. 

(1) The owner or operator of a kiln subject to limitations on particulate matter emissions shall demonstrate 

compliance by conducting a performance test as specified in Section 3.3.3 (1) (i) through (1) (iv) [40

C.F.R. §§ 63.1349 (b) (1) (i) through (b) (1) (iv)]. The owner or operator of an in-line kiln/raw mill 

subject to limitations on particulate matter emissions shall demonstrate initial compliance by 

conducting separate performance tests as specified in Section 3.3.3 (1)(i) through (1)(iv) [40 C.F.R. §§ 

63.1349 (b) (1) (i) through (b) (1) (iv)] while the raw mill of the in-line kiln/raw mill is under normal 

operating conditions and while the raw mill of the in-line kiln/raw mill is not operating. The owner or 

operator of a clinker cooler subject to limitations on particulate matter emissions shall demonstrate 

initial compliance by conducting a performance test as specified in Section 3.3.3 (1) (i) through (1) 

(iii) [40 C.F.R. §§ 63.1349 (b) (1) (i) through (b) (1) (iii)]. The opacity exhibited during the period of 

the Method 5 of Appendix A to 40 C.F.R. part 60 of Chapter I of Title 40 performance tests required 

by Section 3.3.3 (1) (i) [40 C.F.R. § 63.1349 (b) (1) (i)] shall be determined as required in 40 C.F.R. § 

63.1349 (b) (1) (v) and (b) (vi). 

(i) Method 5 of appendix A to 40 C.F.R. part 60 of Chapter I of Title 40 shall be used to 

determine PM emissions. Each performance test shall consist of three separate runs under 

the conditions that exist when the affected source is operating at the representative 

performance conditions in accordance with 40 C.F.R. § 63.7 (e). Each run shall be conducted 

for at least 1 hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). The 

average of the three runs shall be used to determine compliance. A determination of the PM 

collected in the impingers ("back half") of the Method 5 particulate sampling train is not 

required to demonstrate initial compliance with the PM standards of 40 C.F.R. Part 63, 

Subpart LLL. However, this shall not preclude the permitting authority from requiring a 

determination of the "back half" for other purposes. 
Title V Operating Permit R30-00300006-2006 Page 60 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(ii) Suitable methods shall be used to determine the kiln or in-line kiln/raw mill feed rate, except 

for fuels, for each run. 

(iii) The emission rate, E, of PM shall be computed for each run using equation 1: 

E = (Cs Qsd) / P Equation 1 

Where: 

E = emission rate of particulate matter, kg/Mg of kiln feed. 

cs = concentration of PM, kg/dscm. 

Qsd = volumetric flow rate of effluent gas, dscm/hr. 

P = total kiln feed (dry basis), Mg/hr. 

(iv) When there is an alkali bypass associated with a kiln or in-line kiln/raw mill, the main 

exhaust and alkali bypass of the kiln or in-line kiln/raw mill shall be tested simultaneously 

and the combined emission rate of particulate matter from the kiln or in-line kiln/raw mill and 

alkali bypass shall be computed for each run using equation 2, 

Ec = (Csk Qsdk + Csd Qsdb) / P Equation 2

Where: 

Ec = the combined emission rate of particulate matter from the kiln or in-line 

kiln/raw mill and bypass stack, kg/Mg of kiln feed. 

csk = concentration of particulate matter in the kiln or in-line kiln/raw mill effluent, 

kg/dscm. 

Qsdk = volumetric flow rate of kiln or in-line kiln/raw mill effluent, dscm/hr. 

csb = concentration of particulate matter in the alkali bypass gas, kg/dscm. 

Qsdb = volumetric flow rate of alkali bypass gas, dscm/hr. 

P = total kiln feed (dry basis), Mg/hr. 

(v) Except as provided in 40 C.F.R. § 63.1349 (b) (1) (vi) the opacity exhibited during the period 

of the Method 5 performance tests required by Section 3.3.3 (1) (i) [40 C.F.R. § 63.1349 (b) 

(1) (i)] shall be determined through the use of a continuous opacity monitor (COM). The 

maximum six-minute average opacity during the three Method 5 test runs shall be determined 

during each Method 5 test run, and used to demonstrate initial compliance with the applicable 

opacity limits of Sections 4.1.6 (2) and 5.1.5 (2) [40 C.F.R. § 63.1343 (b) (2)], 40 C.F.R. § 

63.1343 (c) (2), or Sections 4.1.5 (2) and 5.1.30 [40 C.F.R. § 63.1345 (a) (2)]. 

(2) The owner or operator of any affected source subject to limitations on opacity under 40 C.F.R. Part 63 

Subpart LLL that is not subject to by Section 3.3.3 (1) [40 C.F.R. § 63.1349 (b) (1)] shall demonstrate 

initial compliance with the affected source opacity limit by conducting a test in accordance with 
Title V Operating Permit R30-00300006-2006 Page 61 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Method 9 of Appendix A to Part 60 of Chapter I of Title 40. The performance test shall be conducted 

under the conditions that exist when the affected source is operating at the representative performance 

conditions in accordance with 40 C.F.R. § 63.7 (e). The maximum 6-minute average opacity exhibited 

during the test period shall be used to determine whether the affected source is in initial compliance

with the standard. The duration of the Method 9 performance test shall be 3 hours (30 6-minute 

averages), except that the duration of the Method 9 performance test may be reduced to 1 hour if the 

conditions of Section 3.3.3 (2) (i) through (2) (ii) [40 C.F.R. §§ 63.1349 (b) (2) (i) through (ii)] apply: 

(i) There are no individual readings greater than 10 percent opacity; 

(ii) There are no more than three readings of 10 percent for the first 1-hour period. 

(3) The owner or operator of an affected source subject to limitations on D/F emissions under 40 C.F.R. 

Part 63 Subpart LLL shall demonstrate initial compliance with the D/F emission limit by conducting a 

performance test using Method 23 of appendix A to Part 60 of Chapter I of Title 40. The owner or 

operator of an in-line kiln/raw mill shall demonstrate initial compliance by conducting separate 

performance tests while the raw mill of the in-line kiln/raw mill is under normal operating conditions

and while the raw mill of the in-line kiln/raw mill is not operating. The owner or operator of a kiln or 

in-line kiln/raw mill equipped with an alkali bypass shall conduct simultaneous performance tests of 

the kiln or in-line kiln/raw mill exhaust and the alkali bypass. However, the owner or operator of an

in-line kiln/raw mill may conduct a performance test of the alkali bypass exhaust when the raw mill of

the in-line kiln/raw mill is operating or not operating. 

(i) Each performance test shall consist of three separate runs; each run shall be conducted under 

the conditions that exist when the affected source is operating at the representative 

performance conditions in accordance with 40 C.F.R. § 63.7 (e). The duration of each run 

shall be at least 3 hours, and the sample volume for each run shall be at least 2.5 dscm (90 

dscf). The concentration shall be determined for each run, and the arithmetic average of the 

concentrations measured for the three runs shall be calculated and used to determine 

compliance. 

(ii) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD, and where applicable, 

the temperature at the inlet to the alkali bypass PMCD, must be continuously recorded during 

the period of the Method 23 test of appendix A to part 60, and the continuous temperature 

record(s) must be included in the performance test report. 

(iii) One-minute average temperatures must be calculated for each minute of each run of the test. 

(iv) The run average temperature must be calculated for each run, and the average of the run 

average temperatures must be determined and included in the performance test report and 

will determine the applicable temperature limit in accordance with 40 C.F.R. § 63.1344 (b). 

[45CSR34, 40 C.F.R. §§ 63.1349 (b) (1) (i) – (v), (2), and (3) (i) – (iv), Group (006, 007, 012, 013, 014, 020, 

021, 022, 023, and 024), 45CSR14, R14-026A, B.10., EU3, EU4, EU6, EU7]

3.3.4. Except as provided in Section 3.3.6 [40 C.F.R. § 63.1349 (e)], performance tests required under Section 3.3.3 

(1) through (2) [40 C.F.R. §§ 63.1349 (b) (1) and (b) (2)] shall be repeated every five years, except that the 

owner or operator of a kiln, in-line kiln/raw mill or clinker cooler is not required to repeat the initial 

performance test of opacity for the kiln, in-line kiln/raw mill or clinker cooler. 

[45CSR34, 40 C.F.R. § 63.1349 (c), Group (006, 007, 012, 013, 014, 019, 021, 022, 023, and 024), EU3, 

EU4, EU6, EU7]

3.3.5. Performance tests required under Section 3.3.3 (3) [40 C.F.R. § 63.1349 (b) (3)] shall be repeated every 30 
Title V Operating Permit R30-00300006-2006 Page 62 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

months. 

[45CSR34, 40 C.F.R. § 63.1349 (d), Group (006, 007, 012, 013, 014, 019, 021, 022, 023, and 024), EU3, 

EU4, EU6, EU7]

3.3.6. (1) If a source plans to undertake a change in operations that may adversely affect compliance with an 

applicable D/F standard under 40 C.F.R. Part 63 Subpart LLL, the source must conduct a performance 

test and establish new temperature limit(s) as specified in Section 3.3.3 (3) [40 C.F.R. § 63.1349 (b)

(3)]. 

(2) If a source plans to undertake a change in operations that may adversely affect compliance with an 

applicable PM standard under 40 C.F.R. § 63.1343, the source must conduct a performance test as 

specified in Section 3.3.3 (1) [40 C.F.R. § 63.1349 (b) (1)]. 

(3) In preparation for and while conducting a performance test required in Section 3.3.6 (1) [40 C.F.R. § 

63.1349 (e) (1)], a source may operate under the planned operational change conditions for a period 

not to exceed 360 hours, provided that the conditions in Sections 3.3.6 (3) (i) through (3) (iv) [40 

C.F.R. §§ 63.1349 (e) (3) (i) through (iv)] are met. The source shall submit temperature and other 

monitoring data that are recorded during the pretest operations. 

(i) The source must provide the Administrator written notice at least 60 days prior to 

undertaking an operational change that may adversely affect compliance with an applicable 

standard under 40 C.F.R. Part 63 Subpart LLL, or as soon as practicable where 60 days 

advance notice is not feasible. Notice provided under Section 3.3.6. (3) (i) [40 C.F.R. § 

63.1349 (e) (3) (i)] shall include a description of the planned change, the emissions standards 

that may be affected by the change, and a schedule for completion of the performance test 

required under Section 3.3.6. (1) [40 C.F.R. § 63.1349 (e) (1)], including when the planned 

operational change period would begin. 

(ii) The performance test results must be documented in a test report according to Section 3.3.2 

[40 C.F.R. § 63.1349 (a)]. 

(iii) A test plan must be made available to the Administrator prior to testing, if requested. 

(iv) The performance test must be conducted, and it must be completed within 360 hours after the 

planned operational change period begins. 

[45CSR34, 40 C.F.R. § 63.1349 (e)]

3.4. Recordkeeping Requirements

3.4.1. Monitoring information. The permittee shall keep records of monitoring information that include the 

following: 

a. The date, place as defined in this 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 the analyses; and 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

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

[45CSR§30-5.1.c.2.A.]

3.4.2. Retention of records. 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 monitoring sample, measurement, report, 

application, or record creation date. Support information includes all calibration and maintenance records and 

all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required 

by the permit. Where appropriate, records may be maintained in computerized form in lieu of the above

records.

[45CSR§30-5.1.c.2.B.]

3.4.3. Odors. For the purposes of 45CSR4, the permittee shall maintain a record of all odor complaints received, any

investigation performed in response to such a complaint, and any responsive action(s) taken. 

[45CSR§30-5.1.c. State-Enforceable only.]

3.4.4. The owner or operator shall maintain files of all information (including all reports and notifications) required by 

this section recorded in a form suitable and readily available for inspection and review as required by 40 C.F.R. 

§ 63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence, 

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be retained off site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. 

[45CSR34, 40 C.F.R. § 63.1355 (a)]

3.4.5. The owner or operator shall maintain records for each affected source as required by 40 C.F.R. §§ 63.10(b) (2) 

and (b) (3); and 

(1) All documentation supporting initial notifications and notifications of compliance status under 40 

C.F.R. § 63.9; 

(2) All records of applicability determination, including supporting analyses; and 

(3) If the owner or operator has been granted a waiver under 40 C.F.R. § 63.8 (f) (6), any information 

demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or reporting 

requirements. 

[45CSR34, 40 C.F.R. § 63.1355 (b)]

3.4.6. In addition to the recordkeeping requirements in Section 3.4.5 [40 C.F.R. § 63.1355 (b)], the owner or operator 

of an affected source equipped with a continuous monitoring system shall maintain all records required by 40 

C.F.R. § 63.10 (c). 

[45CSR34, 40 C.F.R. § 63.1355 (c)]

3.5. Reporting Requirements
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

3.5.1. Responsible official. Any application form, report, or compliance certification required by this permit to be 

submitted to the DAQ and/or USEPA shall contain a certification by the 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. 

[45CSR§§30-4.4. and 5.1.c.3.D.]

3.5.2. A permittee may request confidential treatment for the submission of reporting required under 45CSR§30-

5.1.c.3 pursuant to the limitations and procedures of West Virginia Code § 22-5-10 and 45CSR31. 

[45CSR§30-5.1.c.3.E.]

3.5.3. All notices, requests, demands, submissions and other communications required or permitted to be made to the 

Secretary of DEP and/or USEPA shall be made in writing and shall be deemed to have been duly given when 

delivered by hand, mailed first class or by private carrier with postage prepaid to the address(es) set forth below 

or to such other person or address as the Secretary of the Department of Environmental Protection may 

designate: 

If to the DAQ: If to the US EPA: 

Director 

WVDEP 

Division of Air Quality 

601 57th Street SE 

Charleston, WV 25304 

Phone: 304/926-0475 

FAX: 304/926-0478

Associate Director 

Office of Enforcement and Permits Review 

(3AP12) 

U. S. Environmental Protection Agency 

Region III 

1650 Arch Street 

Philadelphia, PA 19103-2029

3.5.4. Certified emissions statement. The permittee shall submit a certified emissions statement and pay fees on an 

annual basis in accordance with the submittal requirements of the Division of Air Quality. The certified 

emissions statement and pay fees to be submitted on July 31 of each year unless directed by DAQ. 

[45CSR§30-8.]

3.5.5. Compliance certification. The permittee shall certify compliance with the conditions of this permit on the 

forms provided by the DAQ. In addition to the annual compliance certification, the permittee may be required 

to submit certifications more frequently under an applicable requirement of this permit. The annual certification 

shall be submitted to the DAQ and USEPA on or before March 15 of each year, and shall certify compliance for 

the period ending December 31. The permittee shall maintain a copy of the certification on site for five (5) 

years from submittal of the certification.

[45CSR§30-5.3.e.] 
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ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

3.5.6. Semi-annual monitoring reports. The permittee shall submit reports of any required monitoring on or before 

September 15 for the reporting period January 1 to June 30 and on or before March 15 for the reporting period 

July 1 to December 31. All instances of deviation from permit requirements must be clearly identified in such 

reports. All required reports must be certified by a responsible official consistent with 45CSR§30-4.4. 

[45CSR§30-5.1.c.3.A.]

3.5.7. Emergencies. For reporting emergency situations, refer to Section 2.17 of this permit. 

3.5.8. Deviations. 

a. In addition to monitoring reports required by this permit, the permittee shall promptly submit supplemental 

reports and notices in accordance with the following: 

1. Any deviation resulting from an emergency or upset condition, as defined in 45CSR§30-5.7., shall be 

reported by telephone or telefax within one (1) working day of the date on which the permittee 

becomes aware of the deviation, if the permittee desires to assert the affirmative defense in accordance 

with 45CSR§30-5.7. A written report of such deviation, which shall include the probable cause of 

such deviations, and any corrective actions or preventative measures taken, shall be submitted and 

certified by a responsible official within ten (10) days of the deviation. 

2. Any deviation that poses an imminent and substantial danger to public health, safety, or the 

environment shall be reported to the Secretary immediately by telephone or telefax. A written report 

of such deviation, which shall include the probable cause of such deviation, and any corrective actions 

or preventative measures taken, shall be submitted by the responsible official within ten (10) days of

the deviation. 

3. Deviations for which more frequent reporting is required under this permit shall be reported on the 

more frequent basis. 

4. All reports of deviations shall identify the probable cause of the deviation and any corrective actions or 

preventative measures taken.

[45CSR§30-5.1.c.3.C.] 

b. The permittee shall, in the reporting of deviations from permit requirements, including those attributable to 

upset conditions as defined in this permit, report the probable cause of such deviations and any corrective 

actions or preventive measures taken in accordance with any rules of the Secretary.

[45CSR§30-5.1.c.3.B.]

3.5.9. New applicable requirements. If any applicable requirement is promulgated during the term of this permit, the 

permittee will meet such requirements on a timely basis, or in accordance with a more detailed schedule if 

required by the applicable requirement. 

[45CSR§30-4.3.h.1.B.]

3.5.10. Each owner or operator subject to the requirements of 40 C.F.R. Part 63 Subpart LLL shall comply with the 

notification requirements in 40 C.F.R § 63.9 as follows: 
Title V Operating Permit R30-00300006-2006 Page 66 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(1) Initial notifications as required by 40 C.F.R. §§ 63.9 (b) through (d). For the purposes of 40 C.F.R. 

Part 63 Subpart LLL, a Title V or 40 CFR part 70 permit application may be used in lieu of the initial

notification required under 40 C.F.R. § 63.9 (b), provided the same information is contained in the 

permit application as required by 40 C.F.R. § 63.9 (b), and the State to which the permit application 

has been submitted has an approved operating permit program under part 70 of Chapter I of Title 40 

and has received delegation of authority from the EPA. Permit applications shall be submitted by the 

same due dates as those specified for the initial notification. 

(2) Notification of performance tests, as required by 40 C.F.R. §§ 63.7 and 63.9 (e). 

(3) Notification of opacity and visible emission observations required by 40 C.F.R. § 63.1349 in 

accordance with 40 C.F.R. §§ 63.6 (h) (5) and 63.9 (f). 

(4) As required by 40 C.F.R. § 63.9 (g), notification of the date that the continuous emission monitor 

performance evaluation required by 40 C.F.R.§ 63.8 (e) is scheduled to begin. 

(5) Notification of compliance status, as required by 40 C.F.R. § 63.9(h). 

[45CSR34, 40 C.F.R. § 63.1353 (b)]

3.5.11. The owner or operator of an affected source shall comply with the reporting requirements specified in 40 C.F.R. 

§ 63.10 of the general provisions of 40 C.F.R. Part 63 Subpart A as follows: 

(1) As required by 40 C.F.R. § 63.10 (d) (2), the owner or operator shall report the results of performance 

tests as part of the notification of compliance status. 

(2) As required by 40 C.F.R. § 63.10 (d) (3), the owner or operator of an affected source shall report the 

opacity results from tests required by 40 C.F.R. § 63.1349. 

(3) As required by 40 C.F.R. § 63.10 (d) (4), the owner or operator of an affected source who is required 

to submit progress reports as a condition of receiving an extension of compliance under 40 C.F.R. § 

63.6 (i) shall submit such reports by the dates specified in the written extension of compliance. 

(4) As required by 40 C.F.R § 63.10 (d) (5), if actions taken by an owner or operator during a startup, 

shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are 

consistent with the procedures specified in the source's startup, shutdown, and malfunction plan 

specified in 40 C.F.R § 63.6 (e) (3), the owner or operator shall state such information in a semiannual 

report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the 

reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with 

the excess emissions and continuous monitoring system performance reports; and 

(5) Any time an action taken by an owner or operator during a startup, shutdown, or malfunction 

(including actions taken to correct a malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the owner or operator shall make an immediate report of the actions 

taken for that event within 2 working days, by telephone call or facsimile (FAX) transmission. The 

immediate report shall be followed by a letter, certified by the owner or operator or other responsible 

official, explaining the circumstances of the event, the reasons for not following the startup, shutdown, 

and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are 

believed to have occurred. 
Title V Operating Permit R30-00300006-2006 Page 67 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(6) As required by 40 C.F.R § 63.10 (e) (2), the owner or operator shall submit a written report of the 

results of the performance evaluation for the continuous monitoring system required by 40 C.F.R § 

63.8 (e). The owner or operator shall submit the report simultaneously with the results of the 

performance test. 

(7) As required by 40 C.F.R § 63.10 (e) (2), the owner or operator of an affected source using a 

continuous opacity monitoring system to determine opacity compliance during any performance test 

required under 40 C.F.R § 63.7 and described in 40 C.F.R § 63.6 (d) (6) shall report the results of the 

continuous opacity monitoring system performance evaluation conducted under 40 C.F.R § 63.8 (e). 

(8) As required by 40 C.F.R § 63.10 (e) (3), the owner or operator of an affected source equipped with a 

continuous emission monitor shall submit an excess emissions and continuous monitoring system 

performance report for any event when the continuous monitoring system data indicate the source is 

not in compliance with the applicable emission limitation or operating parameter limit. 

(9) The owner or operator shall submit a summary report semiannually, which contains the information 

specified in 40 C.F.R § 63.10 (e) (3) (vi). In addition, the summary report shall include: 

(i) All exceedences of maximum control device inlet gas temperature limits specified in Sections 

4.1.7, 5.1.6, 4.1.8 and 5.1.7 [40 C.F.R §§ 63.1344(a) and (b)]; 

(ii) All failures to calibrate thermocouples and other temperature sensors as required under 

Section 3.2.5 (6) [40 C.F.R § 63.1350 (f) (6)]; and 

(iv) The results of any combustion system component inspections conducted within the reporting 

period as required under Section 3.2.6 [40 C.F.R § 63.1350 (i)]. 

(v) All failures to comply with any provision of the operation and maintenance plan developed in 

accordance with Section 3.2.1 [40 C.F.R § 63.1350 (a)]. 

(10) If the total continuous monitoring system downtime for any CEM or any continuous monitoring 

system (CMS) for the reporting period is ten percent or greater of the total operating time for the 

reporting period, the owner or operator shall submit an excess emissions and continuous 

monitoring system performance report along with the summary report. 

[45CSR34, 40 C.F.R. § 63.1354 (b)]

3.6. Compliance Plan

3.6.1. None 

3.7. Permit Shield

3.7.1. The permittee is hereby granted a permit shield in accordance with 45CSR§30-5.6. The permit shield applies 

provided the permittee operates in accordance with the information contained within this permit. 

3.7.2. The following requirements specifically identified are not applicable to the source based on the determinations 

set forth below. The permit shield shall apply to the following requirements provided the conditions of the 

determinations are met. 
Title V Operating Permit R30-00300006-2006 Page 68 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

40 C.F.R. Part 60 

Subpart Y

(October 24, 1974)

Standards of Performance for Coal Preparation Plants do not apply to Capitol since 

Capitol began their existing coal handling operation prior to October 24, 1974, and 40 

C.F.R. § 63.1356 (b) says that the conveying system transfer points used to convey coal 

from the mill to the kiln that are associated with coal preparation at a portland cement 

plant are not subject to Subpart Y. Capitol proposed coal handling operations will be 

subject to 40 C.F.R. Part 60 Subpart Y when the modifications are completed. 

40 C.F.R. Part 60 

Subpart F

(August 31, 1971)

Standards of Performance for Portland Cement Plants do not apply to Capitol since 

Capitol commenced construction or modification prior to August 17, 1971. Capitol is 

also exempt because it is regulated by 40 C.F.R. Part 63 Subpart LLL. 

40 C.F.R. Part 60

Subpart LL

(August 24, 1982)

Standards of Performance for Metallic Mineral Processing do not apply because lime or 

limestone is not metallic mineral. 

40C.F.R. Part 60 

Subpart OOO 

(August 1, 1985)

Standards of Performance for Nonmetallic Mineral Processing Plants do not apply to 

Capitol Cement since Capitol commenced construction or modification prior to August 

31, 1983. The existing affected sources regulated by 40 C.F.R. Part 63 Subpart LLL are 

not subject to this NSPS. Capitol new and modified non-mineral facilities that are not 

subject to 40 C.F.R. Part 63 Subpart LLL will be subject to 40 C.F.R. Part 60 Subpart 

OOO when the modifications are completed. 

60 C.F.R. Part 60 

Subpart UUU

(April 23, 1986)

Standards of Performance for Calciners and Dryers in Mineral Industries do not apply 

because lime or limestone is not listed as a mineral processed or produced in a mineral 

processing plant. 

40 C.F.R. Part 72 

(01/11/93)

Acid Rain Program General Provisions does not apply to Capitol Cement Corporation 

because it is not considered a Title IV (Acid Rain) Source. 
Title V Operating Permit R30-00300006-2006 Page 69 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

4.0. Source-Specific Requirements [Kilns #8 (EP11.01) and #9 (EP12.01), Clinker Cooler #8 (EP11.02) and 

#9 (EP12.02), Dust Scoop (EP13.08), and #5, #6, #7, #8, #9, and #10 Raw Mills (EP09.01) of source 

group 009, 010, 011, 012, and 013 and emission point ID(s) CD11.02, CD13.08, Stack 007, Stack 008, 

Stack 010, and Stack 011] 

4.1. Limitations and Standards

4.1.1. When utilizing petroleum hydrocarbon contaminated soils the following provisions shall apply: 

 (a) The petroleum hydrocarbon contaminated soils shall be introduced to No. 8 and 9 kilns at a maximum 

rate of 0.25% by weight of the raw material feed to the kilns. The contaminated soils shall be blended 

with the normal stone, shale, clay, and other raw materials into a water slurry prior to introduction to 

the kilns. Certified records of the amounts (tonnage) of contaminated soil and raw materials utilized

shall be maintained in accordance with Section 4.1.1 (c). 

 (b) The kilns shall provide 99.0% destruction efficiency for the petroleum hydrocarbon constituents.

 (c) The kilns shall utilize only petroleum-contaminated soils containing fuel oil, gasoline, kerosene, motor 

oil, hydraulic fluid, lubricants, and/or diesel fuel. The total petroleum hydrocarbon (TPH) 

concentration of contaminated soil shall not exceed 50,000 mg/kg (ppm by weight) as determined by 

USEPA Methods 8015 (TPH) and 8020 (BTEX) tests set forth in Third Edition of "Test Methods for 

Evaluating Solid Waste, Physical/Chemical Methods", Office of Solid Waste Publication SW-846. 

The permittee shall sample and analyze the soil prior to utilization in the kilns when the quantity 

removed at one location is greater than 25 tons. Each certified test record shall contain, as a minimum, 

a description of the soil origin at the plant site, soil quantity, date, TPH concentration, and verification 

of sampling and analytical method. A certified record for each lot of contaminated soil detailing the

approximate quantity of soil, in tons, the known contaminants present, location from which it was 

removed, and date processed in the kiln shall be maintained for each quantity less than 25 tons. 

 (d) No chlorinated or fluorinated hydrocarbon contaminated soils shall be utilized. 

 (e) No material defined as hazardous wastes under 47CSR35 and 45CSR25 shall be utilized. Results of 

TCLP tests and analyses required in Section 4.1.1 (c) for each soil quantity greater than 25 tons 

removed from one location shall be submitted to the Director of Air Quality prior to utilizing the soil 

in the kilns. 

 (f) The kilns shall utilize a maximum of 3,825 tons of petroleum contaminated soil in any calendar year. 

 

 (g) Only petroleum contaminated soils from the Capitol Cement Corporation's Martinsburg plant property 

shall be introduced to the kilns. 

 [45CSR13, R13-1674C, A.1., Kilns #8 (EP11.01) and #9 (EP12.01)] 

 4.1.2. When returning cement kiln dust (CKD) into kiln Number 8 utilizing the "dust scoops" the following shall 

apply: 

 

 (a) The rate of CKD returned shall not exceed 12 tons per hour or a total of 90,960 tons per year. Daily 

and annual records of the CKD returned shall be maintained on site for a period of 5 years and be 

readily accessible to the WV Division of Air Quality staff upon request. Records shall at a minimum 

be certified once per month. 

 
Title V Operating Permit R30-00300006-2006 Page 70 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 (b) A bin vent dust collector, identified in permit determination form PD98-208 as CD13.08 shall be

installed, maintained, and operated so as to achieve a 99.5% control efficiency of particulate matter 

emissions from the pneumatic transfer of CKD to the scoop storage bin (EP13.08). 

[45CSR13, R13-1674C, A.2.] 

 4.1.3. When utilizing the replacement cooler for # 8 kilns the following apply: 

(a) Clinker Cooler # 8 (ID. EP11.02) shall not be operated with out control device Cooler Dust Filter CD 

CD 11.02 also operating. 

(b) The Cooler Dust Filter control device for # 8 Clinker Cooler (CD 11.02) shall be operated and 

maintain with a minimum collection efficiency of 99.96% for particulate matter. 

(c) Particulate Matter Emissions from Emission Points ID Stack 010 (EP11.02) for #8 Clinker Cooler 

shall each not exceed 6.11 pounds per hour and 26.7 tons per year. 

(d) A continuous opacity monitor shall be installed, operated, and maintained in accordance with 40 

C.F.R. 60 for Emission Points Stack 010 (EP11.02). 

(e) Clinker Cooler # 8 (ID. EP11.02) shall not process more than 35 tons per hour and 306,600 tons per

year of clinker. 

[45CSR13, R13-1674C, A.3.] 

4.1.4. The permitted facility shall be constructed and operated in accordance with information filed in Permit 

Application R13-1616, R13-1674, R13-1674A, R13-1674B, and R13-1674C and any amendments thereto. The 

Secretary may suspend or revoke a permit if the plans and specifications upon which the approval was based are 

not adhered to. 

[45CSR13, R13-1674C, C.3.] 

4.1.5. No owner or operator of a new or existing clinker cooler at a facility which is a major source subject to the 

provisions of 40 C.F.R. Part 63 Subpart LLL shall cause to be discharged into the atmosphere from the clinker 

cooler any gases which: 

(1) Contain particulate matter in excess of 0.050 kg per Mg (0.10 LB per ton) of feed (dry basis) to the 

kiln. 

 (2) Exhibit opacity greater than ten percent. 

[45CSR34, 40 C.F.R. § 63.1345 (a), 45CSR13, R13-1674C, B.2. and B.3.] 

4.1.6. Existing or reconstructed or new brownfield sources. 

No owner or operator of an existing or reconstructed kiln at a facility that is a major source subject to the 

provisions of 40 C.F.R. Part 63, Subpart LLL, shall cause to be discharged into the atmosphere from these 

affected sources, any gases which: 

(1) Contain particulate matter (PM) in excess of 0.15 kg per Mg (0.30 LB per ton) of feed (dry basis) to 

the kiln. 
Title V Operating Permit R30-00300006-2006 Page 71 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(2) Exhibit opacity greater than 20 percent. 

(3) Contain D/F in excess of: 

(i) 0.20 ng per dscm (8.7×10−11 gr per dscf) (TEQ) corrected to seven percent oxygen; or 

(ii) 0.40 ng per dscm (1.7×10−10 gr per dscf) (TEQ) corrected to seven percent oxygen, when 

the average of the performance test run average temperatures at the inlet to the particulate 

matter control device is 204 °C (400 °F) or less. 

[45CSR34, 40 C.F.R. § 63.1343 (b), B.2., EP11.02 and EP12.01]

4.1.7. The owner or operator of a kiln subject to a D/F emission limitation under Section 4.1.6 [40 C.F.R. § 63.1343] 

must operate the kiln such that the temperature of the gas at the inlet to the kiln particulate matter control device 

(PMCD) does not exceed the applicable temperature limit specified in Section 4.1.7 [40 C.F.R. § 63.1344 (b)]. 

[45CSR34, 40 C.F.R. § 63.1344 (a), B.2., EP11.01 and EP12.01]

4.1.8. The temperature limit for affected sources meeting the limits of Section 4.1.7 [40 C.F.R. § 63.1344 (a)] is 

determined in accordance with Section 3.3.3 (3) (vi) [40 C.F.R. § 63.1349 (b) (3) (iv)]. 

[45CSR34, 40 C.F.R. § 63.1344 (b), B.2., EP11.01 and EP12.01]

4.1.9. Due to unavoidable malfunction of equipment or inadvertent fuel shortages, emissions exceeding those provided 

for in 45CSR10 may be permitted by the Director for periods not to exceed ten (10) days upon specific 

application to the Director. Such application shall be made within twenty-four (24) hours of the equipment 

malfunction or fuel shortage. In cases of major equipment failure or extended shortages of conforming fuels, 

additional time periods may be granted by the Director provided a corrective program has been submitted by the 

owner or operator and approved by the Director. 

[45CSR§10-9.1, Kilns #8 and #9 EP11.01 and EP12.01)]

4.1.10. Standard requirements. 

After May 31, 2004, an owner or operator of any Portland cement kiln subject to 45CSR§1-100 shall not 

operate the kiln during May 1 through September 30 unless the kiln has installed and operates during May 1 to 

September 30 with low-NOX burners, mid-kiln firing or alternative control techniques, subject to approval by 

the Secretary, that achieve at least the same emissions decreases as low-NOX burners or mid-kiln firing. 

[45CSR§1-100.3., Kiln #9 (EP12.01)] 

4.1.11. No person shall cause, suffer, allow or permit emission of particulate matter into the open air from any fugitive 

dust control system which is twenty percent (20%) opacity or greater. 

[45CSR§5-3.4., Coal Handling Operations, Group 015]

4.1.12. No person shall cause, suffer, allow or permit a coal preparation plant or handling operation to operate that is 

not equipped with a fugitive dust control system. This system shall be operated and maintained in such a 

manner as to minimize the emission of particulate matter into the open air. 

[45CSR§5-6.1., Coal Handling Operations, Group 015]

4.1.13. The owner or operator of a coal preparation plant or handling operation shall maintain dust control of the 

premises and owned, leased or controlled access roads by paving, or other suitable measures. Good operating 

practices shall be observed in relation to stockpiling, car loading, breaking, screening and general maintenance 

to minimize dust generation and atmospheric entrainment. 

[45CSR§5-6.2., Coal Handling Operations, Group 015]
Title V Operating Permit R30-00300006-2006 Page 72 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

4.1.14. Where more than one source operation or combinations thereof, which are part of a duplicate source operation, 

are vented through separate stacks, the allowable stack emission rates for the separate stacks shall be determined 

by the following formula: 

Rs = Rt (Ws / Wt) 

Where, 

Rs

 is the allowable stack emission rate for the separate stack venting the source operation(s) in 

question; 

Rt is the total allowable emission rate for the duplicate source operation; 

Ws

 is the operating process weight rate for the source operation(s) vented through the separate stack; 

and 

Wt

 is the total operating process weight rate for the duplicate source operation. 

[45CSR§7-4.8., Kilns #8 and #9 (EP11.01 and EP12.01)] 

4.1.15. Mineral acids shall not be released form any type source operation or duplicate source operation or from any air 

pollution control equipment installed on any type source operation or duplicate source operation in excess of the 

quantity given in Table 45-7B of 45CSR7. Following table lists the equipment with their allowable stack 

emission rates for hydrogen chloride (HCl) and Sulfuric Acid (H2SO4). 

Allowable Stack Emission Rate Kiln Pollutant 

Milligrams Per Dry Cubic Meter 

HCl Mist and/or Vapor 420 Number 8 

Sulfuric Acid Mist 70 

HCl Mist and/or Vapor 420 Number 9 

Sulfuric Acid Mist 70 

[45CSR§7-4.2., Kilns #8 and #9 (EP11.01 and EP12.01)] 

4.1.16. No person shall cause, suffer, allow, or permit the emission into open air from any source operation an in-stack 

sulfur dioxide concentration exceeding 2000 ppmv by volume from existing source operations, except as 

provided in 45CSR§10-4.1. 

 

e. Any owner or operator of a manufacturing process source operation(s) which has the potential to emit 

less than 500 pounds per year of sulfur oxides. 

[45CSR§§10-4.1. and 4.1.e., EP11.01 and EP12.01] 

4.1.17. Compliance with the allowable sulfur dioxide concentration limitations from manufacturing process source 

operation(s) set forth in 45CSR10 shall be based on a block three-(3) hour averaging time. 

[45CSR§10-4.2., EP11.01 and EP12.01] 
Title V Operating Permit R30-00300006-2006 Page 73 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

4.2. Monitoring Requirements

4.2.1. At the request of the Director the owner and/or operator of a source shall install such stack gas monitoring 

devices as the Director deems necessary to determine compliance with the provisions of 45CSR§10-8.2.a. The 

data from such devices shall be readily available at the source location or such other reasonable location that the 

Director may specify. At the request of the Director, or his or her duly authorized representative, such data shall 

be made available for inspection or copying. Failure to promptly provide such data shall constitute a violation 

of 45CSR10. 

[45CSR§10-8.2.a., Kilns #8 and #9 (EP11.01 and EP12.01)]

4.2.2. The owner or operator of fuel burning unit(s), manufacturing process source(s) or combustion source(s) shall 

demonstrate compliance with 45CSR§§10-3, 4 and 5 (Sections 4.1.16 and 4.1.17) by testing and /or monitoring 

in accordance with one or more of the following: 40 C.F.R. Part 60, Appendix A, Method 6, Method 15, 

continuous emissions monitoring systems (CEMS) or fuel sampling and analysis as set forth in an approved 

monitoring plan for each emission unit. 

[45CSR§10-8.2.c, Kilns #8 and #9 (EP11.01 and EP12.01)]

4.2.3. Monitoring requirements. 

a. Any owner or operator of an kiln subject to 45CSR§1-100 shall complete an initial performance test and 

subsequent annual testing consistent with the requirements of 40 CFR Part 60, appendix A, method 7, 7A, 

7C, 7D or 7E; and 

b. The operator may use the results of continuous emission monitoring system (CEMS) to replace the annual 

testing requirements set forth in Section 4.2.3 (a) [45CSR§1-100.6. (a)]. Such equipment shall be installed 

and operated consistent with 45CSR§1-70 through 76 and 40 C.F.R. Part 75. 

[45CSR§1-100.6, #9 Kilns (EP12.01)] 

4.3. Testing Requirements

4.3.1. With regard to the emissions testing required by the WV Department of Environmental Protection, Division of 

Air Quality (DAQ), the permittee shall submit to the Director of the DAQ a test protocol detailing the proposed 

test methods, date, and time testing is to take place, testing locations, and any other relevant information. The 

Director must receive the test protocol no less than thirty (30) days prior to the date the testing is to take place. 

The Director shall be notified at least fifteen (15) days in advance of the actual dates and times during which the 

tests will be conducted. The results of emissions testing shall be submitted to the DAQ within thirty (30) days 

of completion of testing. 

[45CSR13, R13-1674C, B.5.] 

 

4.3.2. Prior to the installation of calibrated stack gas monitoring devices, sulfur dioxide emission rates shall be 

calculated on an equivalent fuel sulfur content basis. 

[45CSR§10-8.2.b., Kilns #8 and #9 (EP11.01 and EP12.01)] 
Title V Operating Permit R30-00300006-2006 Page 74 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

4.3.3. At such reasonable times as the Director may designate, the owner or operator of any fuel burning unit(s), 

manufacturing process source(s) or combustion source(s) may be required to conduct or have conducted tests to 

determine the compliance of such source(s) with the emission limitations of 45CSR§§10-3, 4 or 5 (Sections 

4.1.16 and 4.1.17). Such tests shall be conducted in accordance with the appropriate test method set forth in 40 

C.F.R. Part 60, Appendix A, Method 6, Method 15 or other equivalent EPA testing method approved by the

Director. The Director, or his or her duly authorized representative, may at his or her option witness or conduct 

such tests. Should the Director exercise his or her option to conduct such tests, the operator will provide all 

necessary sampling connections and sampling ports to be located in such manner as the Director may require, 

power for test equipment, and the required safety equipment such as scaffolding, railings, and ladders to comply 

with generally accepted good safety practices. 

[45CSR§10-8.1.a., Kilns #8 and #9 (EP11.01 and EP12.01)] 

4.3.4. See Section 3.3. 

4.3.5. See Section 5.3.8 for Kilns #8 and #9 (EP11.01 and EP12.01) for stack testing. 

4.4. Recordkeeping Requirements

4.4.1. Records required under Section 4.1.1 (a), (c), and Section 4.1.2 shall be maintained on-site and be readily 

accessible to WV Division of Air Quality staff to demonstrate compliance with the conditions of R13-1674C. 

Each record shall be certified by the plant manager to be true and accurate, based on information and belief after 

reasonable inquiry. The records shall be maintained for a minimum of five (5) years and be made available to 

or submitted to the Director or his/her authorized representative upon request or as required by R13-1674C. 

[45CSR13, R13-1674C, B.1.] 

4.4.2. The permittee shall maintain accurate records of daily production and daily average pressure drop across the 

baghouse for clinker coolers #7 and #8. These records shall be certified by a responsible official, maintained on 

site for a period of five (5) years, and made available to the Director of the Division of Air Quality or his/her 

duly authorized representative upon request. 

[45CSR13, R13-1674C, B.6.] 

 

4.4.3. Recordkeeping requirements. -- Any owner or operator of a kiln subject to 45CSR§1-100 shall produce and 

maintain records which shall include, but are not limited to: 

a. The emissions, in pounds of NOX per ton of clinker produced from each affected Portland cement kiln; 

 b. The type of control used for each affected Portland cement kiln; 

c. The date, time and duration of any startup, shutdown or malfunction in the operation of any of the 

cement kilns or the emissions monitoring equipment;

 d. The results of any performance testing; 

 e. Daily cement kiln production records; and 

f. All records required to be produced or maintained shall be retained on site for a minimum of 2 years 

and be made available to the Secretary or Administrator upon request. 

[45CSR§1-100.7., Kilns #9 (EP12.01)]
Title V Operating Permit R30-00300006-2006 Page 75 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

4.4.4. The owner or operator of fuel burning unit(s), manufacturing process source(s) or combustion source(s) subject 

to 45CSR§§10-3, 4 or 5 (Sections 4.1.16 and 4.1.17) shall maintain on-site a record of all required monitoring 

data as established in a monitoring plan pursuant to 45CSR§10-8.2.c. Such records shall be made available to 

the Director or his duly authorized representative upon request. Such records shall be retained on-site for a 

minimum of five years. 

[45CSR§10-8.3.a., Kilns #8 and #9 (EP11.01 and EP12.01)] 

4.4.5. The owner or operator of a fuel burning unit(s) or a combustion source(s) shall maintain records of the 

operating schedule and the quantity and quality of fuel consumed in each unit in a manner specified by the 

Director. Such records are to be maintained on-site and made available to the Director or his duly authorized 

representative upon request. 

[45CSR§10-8.3.c, Kilns #8 and #9 (EP11.01 and EP12.01)] 

4.5. Reporting Requirements

4.5.1. The owner or operator of an affected source shall comply with the reporting requirements specified in 40 C.F.R. 

§ 63.10 of the general provisions of 40 C.F.R. Part 63 Subpart A as follows: 

(1) As required by 40 C.F.R. § 63.10 (d) (2), the owner or operator shall report the results of performance 

tests as part of the notification of compliance status. 

(2) As required by 40 C.F.R. § 63.10 (d) (3), the owner or operator of an affected source shall report the 

opacity results from tests required by Sections 3.3.2 through 3.3.7 [40 C.F.R. § 63.1349]. 

[45CSR34, 40 C.F.R. § 63.1354 (b), 45CSR13, R13-1674C, B.2. and B.3.]

4.5.2. The owner or operator shall submit a periodic exception report to the Director, in a manner specified by the 

Director. Such an exception report shall provide details of all excursions outside the range of measured 

emissions or monitored parameters established in an approved monitoring plan and shall include, but not be 

limited to, the time of the excursion, the magnitude of the excursion, the duration of the excursion, the cause of 

the excursion and the corrective action taken. 

[45CSR§10-8.3.b., Kilns #8 and #9 (EP11.01 and EP12.01)] 

4.5.3. Reporting requirements. -- Any owner or operator subject to the requirements of Section 4.1.10 (45CSR§1-

100.3.) shall comply by submiting a report documenting for that kiln the total NOX emissions from May 1 

through September 30 of each year to the Secretary and Administrator by October 31 of each year, beginning in 

2004. 

[45CSR§1-100.5 (b), #9 Kilns (EP12.01)] 

4.6. Compliance Plan

4.6.1. None 
Title V Operating Permit R30-00300006-2006 Page 76 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

5.0. Source-Specific Requirements [Kiln #7 (EP10.01), Clinker Cooler #7 (EP10.02), and emission point 

ID(s) CD10.02 and Stack 009, plus the Modern Precalciner Kiln System and related Equipment and 

emission point ID(s) New Points] 

5.1. Limitations and Standards

PLANT AREAS

The existing and modified parts of the plant is categorized into the following groups: 

Group 1: Quarry and Crushing --- EU1 

Group 2: Raw Material Preparation --- EU2 

Group 3: Pyroprocessing --- EU3 

Group 4: Clinker Handling and Storage --- EU4 

Group 5: Fuel Handling --- EU5 

Group 6: Cement Production --- EU6 

Group 7: Shipping --- EU7 

Group 8: Other Miscellaneous Sources --- EU8 

Facility Wide Requirements

5.1.1. Clinker production from the facility shall not exceed 2,300,000 tons per year. Compliance with the annual 

production limit shall be determined using a 12 month rolling total. A 12 month rolling total shall mean the sum 

of the clinker production at any given time for the previous twelve (12) consecutive calendar months. 

[45CSR14, R14-026A, A.1., #7 Kiln (EP10.01), Preheater-Precalciner Kiln (EP42.04)] 

5.1.2. Emissions from the facility shall not exceed the following based on a rolling yearly total. A rolling yearly total 

shall mean the sum of the emissions at any given time for the previous twelve-(12) consecutive calendar months. 

Pollutant Allowable Emissions (TPY)

PM10 642.2 

TSP 992.1 

SO2 5,702.6 

NOx (as NO2) 3,704.2 

CO 4,493.0 

VOC 159.4 

Fluorides 1.2 

Lead 2.7 

[45CSR14, R14-026A, A.2.] 

5.1.3. During periods of startup, shutdown and malfunctions, the source shall follow the procedures found in the site 

specific Startup, Shutdown, and Malfunction plan as required by 40 C.F.R. Part 63 Subpart LLL. 

[45CSR34, 40 C.F.R. 63.6 (e), 45CSR14, R14-026A, A.3., See Section 3.2.12.] 
Title V Operating Permit R30-00300006-2006 Page 77 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

5.1.4. The permittee shall maintain a water truck on site and in good operating condition, and shall utilize same to 

apply water, or a mixture of water and an environmentally acceptable dust control additive, hereinafter referred 

to as solution, as often as is necessary in order to minimize the atmospheric entrainment of fugitive particulate 

emissions that may be generated from haulroads and other work areas where mobile equipment is used. The 

spraybar shall be equipped with commercially available spray nozzles, of sufficient size and number, so as to 

provide adequate coverage to the area being treated. 

The pump delivering the water, or solution, shall be of sufficient size and capacity so as to be capable of 

delivering to the spray nozzle(s) an adequate quantity of water, or solution, and at a sufficient pressure, so as to 

assure that the treatment process will minimize the atmospheric entrainment of fugitive particulate emissions 

generated from the haulroads and work areas where mobile equipment is used. 

[45CSR14, R14-026A, A.4.] 

 

5.1.5. Existing, reconstructed, or new brownfield sources. 

No owner or operator of an existing, reconstructed or new brownfield kiln or an existing, reconstructed or new 

brownfield in-line kiln/raw mill at a facility that is a major source subject to the provisions of 40 C.F.R. Part 63 

Subpart LLL shall cause to be discharged into the atmosphere from these affected sources, any gases which: 

(1) Contain particulate matter (PM) in excess of 0.15 kg per Mg (0.30 LB per ton) of feed (dry basis) to 

the kiln. When there is an alkali bypass associated with a kiln or in-line kiln/raw mill, the combined

particulate matter emissions from the kiln or in-line kiln/raw mill and the alkali bypass are subject to 

this emission limit. 

(2) Exhibit opacity greater than 20 percent. 

(3) Contain D/F in excess of: 

(i) 0.20 ng per dscm (8.7×10−11 gr per dscf) (TEQ) corrected to seven percent oxygen; or 

(ii) 0.40 ng per dscm (1.7×10−10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the 

average of the performance test run average temperatures at the inlet to the particulate matter 

control device is 204 °C (400 °F) or less. 

[45CSR34, 40 C.F.R. § 63.1343 (b), 45CSR14, R14-026A, B.10.] 

5.1.6. The owner or operator of a kiln subject to a D/F emission limitation under 40 C.F.R. § 63.1343 must operate the 

kiln such that the temperature of the gas at the inlet to the kiln particulate matter control device (PMCD) and 

alkali bypass PMCD, if applicable, does not exceed the applicable temperature limit specified in Section 5.1.7. 

The owner or operator of an in-line kiln/raw mill subject to a D/F emission limitation under Sections 5.1.5 [40 

C.F.R. § 63.1343 (b)] must operate the in-line kiln/raw mill, such that: 

(1) When the raw mill of the in-line kiln/raw mill is operating, the applicable temperature limit for the 

main in-line kiln/raw mill exhaust, specified in Section 5.1.20 and established during the performance

test when the raw mill was operating is not exceeded. 

(2) When the raw mill of the in-line kiln/raw mill is not operating, the applicable temperature limit for the 

main in-line kiln/raw mill exhaust, specified in Section 5.1.20 and established during the performance

test when the raw mill was not operating, is not exceeded. 
Title V Operating Permit R30-00300006-2006 Page 78 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(3) If the in-line kiln/raw mill is equipped with an alkali bypass, the applicable temperature limit for the 

alkali bypass specified in Section 5.1.20 and established during the performance test, with or without

the raw mill operating, is not exceeded. 

[45CSR34, 40 C.F.R. § 63.1344 (a), 45CSR14, R14-026A, B.10.] 

5.1.7. The temperature limit for affected sources meeting the limits of Section 5.1.19 or Section 5.1.19 (a) (1) through 

(a) (3) is determined in accordance with Section 3.3.3 (3) (iv) [40 C.F.R. § 63.1349 (b) (3) (iv)]. 

[45CSR34, 40 C.F.R. § 63.1344 (b), 45CSR14, R14-026A, B.10.] 

5.1.8. The permitted facility shall be constructed and operated in accordance with information filed in Permit 

Application R14-026 and any amendments thereto. The Secretary may suspend or revoke a permit if the plans 

and specifications upon which the approval was based are not adhered to. 

[45CSR14, R14-026A, C.3.] 

Group 1 - Quarry and Crushing Requirements - - - EU1

5.1.9. Emissions from the Group 1 point sources shall not exceed the following: 

Emission Point 

Identification 

Number 

Emission Point Description 

Outlet 

Loading 

(gr/dscf) 

Existing 

Or 

New 

CD01.01 Primary Crusher Dust Collector 0.02 Existing 

CD01.03 Existing Crusher 40T Bin D\C 0.01 Existing 

CD01.05 Existing Crushing 1011 to 1007 D\C 0.01 Existing 

CD02.01 Secondary Crusher Dust Collector 0.01 Existing 

CD02.03A Existing Crushing 1000 to 99 D\C 0.01 Existing 

CD02.03B Existing Crushing 999 to 998 D/C 0.01 Existing 

CD37.03 New Primary Crusher D\C 0.01 New 

CD37.04 New Crushing System D\C1 0.01 New 

CD37.06 New Premix Storage Feeding D\C 0.01 New 

CD38.01 New Premix Storage Discharge D\C 0.01 New 

 Emissions from the Group 1 fugitive sources shall not exceed the following: 

Emission Point 

Identification Number Emission Point Description TSP (TPY) PM10 (TPY)

EP0X.01 Quarry Drilling 0.01 0.01 

EP0X.02 Quarry Blasting 0.01 0.01 

EP0X.03.01 Loader to truck (good rock) 0.07 0.03 

EP0X.03.02 Loader to truck (waste rock) 0.01 0.00 

EP0X.03.03 Truck to waste pile 0.01 0.00 

EP0X.03.04 Truck to crusher pile 0.07 0.03 

EP0X.03.05 Truck or loader to crusher dump 0.07 0.03 

EP01.07 Belt conveyor 1007 to surge pile 0.01 0.00 

 
Title V Operating Permit R30-00300006-2006 Page 79 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Emission Point 

Identification Number Emission Point Description TSP (TPY) PM10 (TPY)

EP.01.08 Loader transfer 0.01 0.00 

EP.02.01.04 Belt conveyor 1005 to belt conveyor 1004 0.02 0.01 

EP.02.01.07 Screen 1003 to conveyor 1002 0.01 0.00 

EP02.02 Belt conveyor 1001 to belt conveyor 1000 0.02 0.01 

EP02.04 Belt conveyor 999 to stone pile 0.01 0.00 

EP03.04.01 Stone pile to loader 0.01 0.00 

EP03.04.02 Loader to truck 0.01 0.00 

EP03.02 Shuttle conveyor 998 to raw bins 0.04 0.02 

EP35.01 Belt conveyor 989 to limestone bin 0.01 0.00 

EP37.01.01 Truck to small bin 1.58 0.75 

EP37.01.02 Small bin to conveyor 0.40 0.19 

EP37.01.03 Conveyor to conveyor 0.40 0.19 

EP37.02.01 Truck to large bin 1.58 0.75 

EP37.02.02 Large bin to conveyor 0.40 0.19 

EP37.04.01 Conveyor to split 0.79 0.37 

EP37.05 Split to surge pile 0.12 0.06 

EP03.01 5 stone storage piles 0.15 0.07 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 50.4 tons 

per year of TSP nor 40.6 tons per year of PM10 based on a 12 month rolling total. Compliance with 45CSR§7-

4.1 will be shown by the more stringent requirements of Section 5.1.9. 

[45CSR14, R14-026A, A.5.] 

5.1.10. On and after the date on which the performance test required to be conducted by 40 C.F.R. § 60.8 is completed, 

no owner or operator subject to the provisions of 40 C.F.R. Part 60 Subpart OOO shall cause to be discharged 

into the atmosphere from any transfer point on belt conveyors or from any other affected facility any stack 

emissions which: 

(1) Contain particulate matter in excess of 0.05 g/dscm (0.022 gr/dscf); and 

(2) Exhibit greater than 7 percent opacity. 

 

[45CSR16, 40 C.F.R. § 60.672 (a)] 

5.1.11. No owner or operator subject to the provisions of 40 C.F.R. Part 60 Subpart OOO shall cause to be discharged 

into the atmosphere from any transfer point on belt conveyors or from any other affected facility any fugitive 

emissions which exhibit greater than 10 percent opacity. 

[45CSR16, 40 C.F.R. § 60.672 (b), 45CSR14, R14-026A, B.8.] 

5.1.12. No owner or operator shall cause to be discharged into the atmosphere from any crusher, at which a capture 

system is not used, fugitive emissions which exhibit greater than 15 percent opacity. 

[45CSR16, 40 C.F.R. § 60.672 (c), 45CSR14, R14-026A, B.8.] 
Title V Operating Permit R30-00300006-2006 Page 80 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Group 2 - Raw Material Preparation Requirements - - - EU2

5.1.13. Emissions from the following sources shall not exceed the following: 

CD 

Identification 

Number 

CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing 

Or 

New 

CD04.03 No.1 Tertiary Norblo 0.01 Existing 

CD04.02 No. 1 Tertiary Torit 0.01 Existing 

CD05.06 No. 2 Tertiary Norblo 0.02 Existing 

CD05.02 No. 2 Tertiary Torit 0.01 Existing 

CD38.01 New Premix Storage Discharge D\C 0.01 New 

CD39.01 New Limestone Silos Feeding D\C 0.01 New 

CD39.05 New Additive Discharge System D\C 0.01 New 

CD39.06 New Additive Discharge System D\C 0.01 New 

CD40.01 New Raw Mill High Zone D\C 0.01 New 

CD40.06 New Homo Silo Feeding D\C 0.01 New 

CD40.07 New Homo Silo Discharge D/C 0.01 New 

CD40.02 New Raw Mill Low Zone D\C 0.01 New 

CD40.05 New Raw Meal Air Slide D\C 0.01 New 

Emissions from the Group 2 fugitive sources shall not exceed the following: 

Emission Point Identification Number Emission Point Description TSP 

(TPY) 

PM10 

(TPY) 

EP04.01.01 Raw bins to feeders East Tunnel 0.03 0.01 

EP04.01.02 Feeders to belt conveyor East 917 0.03 0.01 

EP05.01.01 Raw bins to feeders West Tunnel 0.01 0.00 

EP05.01.02 Feeders to belt conveyor West 956 0.01 0.00 

EP26.02.01, EP26.04.01 Truck to stockpile (sand & iron ore) 0.01 0.00 

EP26.02.02, EP26.04.02 Pile to loader 0.01 0.00 

EP26.02.03, EP26.04.03 Loader to hopper 0.01 0.00 

EP26.02.04, EP26.04.04 Hopper to feeder 985 0.01 0.00 

EP26.02.05, EP26.04.05 Feeder 985 to elevator 984 0.01 0.00 

EP26.02.06, EP26.04.06 Elevator 984 to storage bins 922/924 0.01 0.00 

EP26.02.07, EP26.04.07 Storage bins 922/924to feeders 921/923 0.01 0.00 

EP26.02.08, EP26.04.08 Feeders to belt conveyor 917 0.01 0.00 

EP04.01.03 Hammermill 916 to return belt east 917 0.01 0.00 

EP04.03.04 Screens 914/913 to roof belt east 912 0.01 0.00 

EP05.01.03 Hammermill 955 to return belt west 956 0.01 0.00 

EP05.06.04 Screen 952 to roof belt west 951 0.01 0.00 

EP05.05 Raw bin to feeder 993 0.01 0.00 

EP05.03 Feeder 993 to belt conveyor 992 0.01 0.00 

EP06.01.01 Belt conveyor 992 to hammermill 991 0.01 0.00 
Title V Operating Permit R30-00300006-2006 Page 81 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 

Emission Point Identification Number Emission Point Description TSP 

(TPY) 

PM10 

(TPY) 

EP06.01.02 Hammermill 991 0.01 0.00 

EP06.01.03 Hammermill 991 to elevator 990 0.01 0.00

EP07.01 Elevator 990 to roof belt 989 0.01 0.00 

EP08.01A.01 Roof belt 912 to #5 & 7 RM feed bin 0.06 0.03 

EP08.01A.02 #5 & 7 RM feed bin to feeders 128/277 0.01 0.00 

EP09.01A Feeder 128 to #5 RM 126.5 0.01 0.00 

EP09.01B.01 Feeder 277 to #7 RM 275.7 0.01 0.00 

EP08.01B.01 Roof belt 951 to #9 RM feed bin 0.01 0.00 

EP08.01B.02 #9 RM feed bin to feeder 884 0.01 0.00 

EP09.01B.02 Feeder 884 to #9 RM 881.9 0.01 0.00 

EP26.02.09, EP26.04.09 Feeder 985 to belt conveyor 917/956 0.01 0.00 

EP40.03 Split to surge pile 0.01 0.00 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 32.6 tons 

per year of TSP nor 27.6 tons per year of PM10 based on a 12 month rolling total. Compliance with 45CSR§7-

4.1 will be shown by the more stringent requirements of Section 5.1.13. 

 

[45CSR14, R14-026A, A.7.] 

Group 3 - Pyroprocessing Requirements - - - EU3

5.1.14. The existing long wet kiln (#7 Kiln) (EP10.01) shall only combust coal, coal fines, coke or on site generated 

petroleum contaminated soils as outlined in Section 5.1.18. 

[45CSR14, R14-026A, A.8., #7 Kiln (EP10.01)] 

5.1.15. The new preheater-precalciner kiln may combust any combination of the following fuels: coal, coal fines, coke, 

and on site generated petroleum contaminated soils (as outlined in Section 5.1.18). If the permittee wishes to 

use alternative fuels including but not limited to tires, wood, paper cardboard, non-PVC plastics, automobile 

fluff, carpets, non-hazardous liquids/solids, and refuse derived fuels the permittee shall notify the Director in 

writing of the fuel to be used within thirty (30) days of the use of the fuel. Use of the alternative fuel shall only 

commence upon the granting of the written consent of the Director. 

[45CSR14, R14-026A, A.9., Preheater-Precalciner Kiln (EP42.04)] 

5.1.16. The permittee may combust spent carbon, tires and/or roofing shingles in the new preheater-precalciner kiln 

provided that the permittee shall first conduct or have conducted EPA approved stack tests to determine 

compliance with the VOC and PM emission limits as set forth in Section 5.1.22 while combusting the fuel in 

question. Until compliance with the VOC and PM emission limits are verified and written approval is granted 

by the Director, the permittee may initially only combust the amount of fuel needed to perform the stack test. A 

stack test protocol and the anticipated test date shall be submitted to this office at least 7 days prior to the date 

of the stack test. Results of the stack test shall be reported to this office within 30 days of performance of stack 

test. The changes in fuel, however, will not be subject to NSR/PSD review since the fuel can be accommodated 

in the new preheater-precalciner kiln and the Permittee has accounted for the criteria pollutant emissions’ 

potential changes in this PSD (R14-026 Application). 

[45CSR14, R14-026A, A.10., Preheater-Precalciner Kiln (EP42.04)] 

5.1.17. Both the existing Kiln #7 (EP10.01) and the new preheater-precalciner kiln may combust fuel oil during startup. 
Title V Operating Permit R30-00300006-2006 Page 82 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

[45CSR14, R14-026A, A.11., EP10.01 and Preheater-Precalciner Kiln (EP42.04)] 

5.1.18. When combusting onsite generated petroleum hydrocarbon contaminated soils the following provisions shall 

apply: 

(a) The petroleum hydrocarbon contaminated soils shall be introduced into the kilns at a maximum rate of 

0.25% by weight of the raw material feed to the kilns. Certified records of the amounts (tonnage) of 

contaminated soil and raw materials utilized per month shall be maintained in accordance with Section 

5.1.18 (c). 

(b) The kilns shall provide at least 99.0% destruction efficiency for the petroleum hydrocarbon 

constituents. 

(c) The kilns shall combust only onsite generated petroleum contaminated soils containing fuel oil, 

gasoline, kerosene, motor oil, hydraulic fluid, lubricants, and/or diesel fuel. The total petroleum 

hydrocarbon (TPH) concentration of contaminated soil shall not exceed 50,000 mg/kg (ppm by 

weight) as determined by USEPA Methods 8015 (TPH) and 8020 (BTEX) tests set forth in Third 

Edition of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods", Office of Solid 

Waste Publication SW-846. The permittee shall sample and analyze the soil prior to utilization in the

kilns. Each certified test record shall contain, as a minimum, a description of the soil origin at the 

plant site, soil quantity, date, TPH concentration, and verification of sampling and analytical method. 

The aforementioned tests shall be performed at least once for each batch of petroleum contaminated 

soils burned. 

(d) No chlorinated or fluorinated hydrocarbon contaminated soils shall be combusted. 

(e) No material defined as hazardous wastes under 47CSR35 or 45CSR25 shall be combusted. Results of 

TCLP tests and analyses required in Section 5.1.18 (c) shall be submitted to the Director of the 

Division of Air Quality prior to utilizing the soil in the kilns. 

(f) The kilns may combust a maximum of 3,825 tons of petroleum contaminated soil per year based 

on a 12 month rolling total. 

 

(g) Only petroleum contaminated soils from the permittee's Martinsburg plant property shall be introduced 

to the kilns. 

[45CSR13, R13-1674C, A.1., Kiln #7 (EP10.01), 45CSR14, R14-026A, A.12.,Preheater-Precalciner Kiln 

(EP42.04)] 

5.1.19. Clinker production from the preheater-precalciner system shall not exceed 2,200,000 tons per year. 

[45CSR14, R14-026A, A.13., Preheater-Precalciner Kiln (EP42.04)] 

5.1.20. Beginning no later than 180 days following startup of the preheater-precalciner kiln system, clinker production 

from Kiln 7 shall not exceed 100,000 tons per year based on a rolling 12 month total. 

[45CSR14, R14-026A, A.14., Kiln #7 (EP10.01)] 

5.1.21. Operation of the existing kiln systems (#8 Kiln and #9 Kiln) shall permanently cease after the preheaterprecalciner kiln system achieves full production or within 180 days after the preheater-precalciner kiln 

system first becomes operational whichever comes first. 

[45CSR14, R14-026A, A.15., Kilns #8 and #9 (EP11.01 and EP12.01)] 

5.1.22. Emissions from the preheater-precalciner kiln shall not exceed the following: 
Title V Operating Permit R30-00300006-2006 Page 83 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Source Pollutant Allowable Compliance Method Averaging Time 

Ph/pc Kiln System NOx 3098.0 TPY CEM TPY, rolling monthly

Ph/pc Kiln System NOx 1745.0 LB/hr CEM 8-hr average (LB/hr) 

Ph/pc Kiln System CO 3960.0 LB/hr CEM 1-hr average (LB/hr) 

Ph/pc Kiln System CO 4425.8 TPY CEM TPY, rolling monthly

Ph/pc Kiln System VOC 38.7 LB/hr Stack Test 3-hr average (LB/hr) 

Ph/pc Kiln System VOC 154.0 TPY Stack Test/production 

data TPY, rolling monthly

Ph/pc Kiln System VOC 0.14 LB/ton 

clinker CEM/production data 12 month rolling 

average 

Ph/pc Kiln System SO2 4425.8 TPY CEM TPY, rolling monthly

Ph/pc Kiln System SO2 2111.3 LB/hr CEM 3-hr average (LB/hr) 

Ph/pc Kiln System, 

with Clinker Cooler 

& Coal Mill 

TSP 195.8 TPY Stack Test / 

production data TPY, rolling monthly

Ph/pc Kiln System, 

with Clinker Cooler 

& Coal Mill 

PM10 166.4 TPY Stack Test / 

production data TPY, rolling monthly

Ph/pc Kiln System, 

with Clinker Cooler 

& Coal Mill 

TSP 60.1 LB/hr Stack Test Average (3) 1-hr tests

Ph/pc Kiln System, 

with Clinker Cooler 

& Coal Mill 

PM10 51.1 LB/hr Stack Test Average (3) 1-hr tests

Ph/pc Kiln System 

with Clinker Cooler Opacity 20 % COM 6-minute block 

average 

Ph/pc Kiln System 

with Clinker Cooler Pb 2.37 TPY Production data TPY, rolling monthly

Ph/pc Kiln System 

with Clinker Cooler Fluorides 1.0 TPY Production data TPY, rolling monthly

[45CSR14, R14-026A, A.16., Preheater-Precalciner Kiln (EP42.04)] 

5.1.23. Emissions from Kiln #7 (EP10.01) shall not exceed the following: 

Pollutant Allowable Compliance Method Averaging Time 

NOx 500.00 TPY Stack Test/production data TPY, 12 rolling monthly total 

NOx 807LB/hr Stack Test Average (3) 1-hr tests 

CO 60 LB/hr Stack Test Average (3) 1-hr tests 

CO 6.00 TPY Stack Test/production data TPY, 12 rolling monthly total 

VOC 10 LB/hr Stack Test Average (3) 1-hr tests 

VOC 1.40 TPY Stack Test/production data TPY, 12 rolling monthly total 

SO2 900.00 TPY Stack Test/production data TPY, 12 rolling monthly total 

SO2 2000 ppm Stack Test 3-hr average (ppmdv) 
Title V Operating Permit R30-00300006-2006 Page 84 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 

Pollutant Allowable Compliance Method Averaging Time 

TSP 28.1 TPY Stack Test/production data TPY, 12 rolling monthly total 

TSP 0.3 LB/ton dry feed Stack Test/production data Average (3) 1-hr tests 

PM10 23.9 TPY Stack Test/production data TPY, 12 month rolling total 

PM10 0.26 LB/ton dry feed Stack Test/production data Average (3) 1-hr tests 

Opacity 20 % COM 6-minute block average 

Pb 0.36 TPY Production data TPY, 12 rolling monthly total 

Fluorides 0.05 TPY Production data TPY, 12 rolling monthly total 

[45CSR14, R14-026A, A.17., Kiln #7 (EP10.01)] 

5.1.24. Emissions from the Group 3 sources shall not exceed the following: 

CD 

Identification 

Number 

CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing

Or 

New 

CD42.04 New Raw Mill Kiln/Clinker Cooler D\C 0.01 New 

CD10.01 No. 7/8 Kiln and Torch 0.03 Existing 

CD10.02 No. 7 Kiln Clinker Cooler 0.02 Existing 

CD42.02 New Kiln Feeding Bucket Elevator D\C 0.01 New 

CD42.03 New Kiln Feeding with pump D\C 0.01 New 

CD43.02 New Cooler Discharge D\C 0.01 New 

Additionally, emissions from the combined above sources shall not exceed 241.6 tons per year of TSP nor 205.3 

tons per year of PM10 based on a 12 month rolling total. Compliance with 45CSR§7-4.1 will be shown by the 

more stringent requirements of Section 5.1.24. 

[45CSR14, R14-026A, A.18.] 

5.1.25. The new in-line raw mill kiln will be equipped with low-NOx burners. 

[45CSR14, R14-026A, A.19.] 

5.1.26. No person shall cause, suffer, allow or permit emission of particulate matter into the open air from any 

fugitive dust control system which is twenty percent (20%) opacity or greater. 

[45CSR§5-3.4., 45CSR14, R14-026A, B.3., Coal Handling Operations, EU5] 

5.1.27. No person shall cause, suffer, allow or permit a coal preparation plant or handling operation to operate that is 

not equipped with a fugitive dust control system. This system shall be operated and maintained in such a 

manner as to minimize the emission of particulate matter into the open air. 

[45CSR§5-6.1., 45CSR14, R14-026A, B.3., Coal Handling Operations, EU5] 

5.1.28. The owner or operator of a coal preparation plant or handling operation shall maintain dust control of the 

premises and owned, leased or controlled access roads by paving, or other suitable measures. Good operating 

practices shall be observed in relation to stockpiling, car loading, breaking, screening and general maintenance 

to minimize dust generation and atmospheric entrainment. 

[45CSR§5-6.2., 45CSR14, R14-026A, B.3., Coal Handling Operations, EU5] 
Title V Operating Permit R30-00300006-2006 Page 85 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

5.1.29. No owner or operator subject to the provisions of 45CSR10 shall build, erect, install, modify or use any article, 

machine, equipment or process, the use of which purposely conceals an emission which would otherwise 

constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of 

gaseous diluents to achieve compliance with a standard which is based on the concentration of a pollutant in the 

gases discharged to the atmosphere. 

[45CSR§10-11.1., 45CSR14, R14-026A, B.5.] 

5.1.30. No owner or operator of a new or existing clinker cooler at a facility which is a major source subject to the 

provisions of 40 C.F.R. Part 63 Subpart LLL shall cause to be discharged into the atmosphere from the clinker 

coolers any gases which: 

(1) Contain particulate matter in excess of 0.050 kg per Mg (0.10 LB per ton) of feed (dry basis) to the 

kiln. 

(2) Exhibit opacity greater than ten percent. 

[45CSR34, 40 C.F.R. § 63.1345 (a), 45CSR14, R14-026A, B.10., EP10.02 and EP43.01] 

5.1.31. Due to unavoidable malfunction of equipment or inadvertent fuel shortages, emissions exceeding those provided 

for in 45CSR10 may be permitted by the Director for periods not to exceed ten (10) days upon specific 

application to the Director. Such application shall be made within twenty-four (24) hours of the equipment 

malfunction or fuel shortage. In cases of major equipment failure or extended shortages of conforming fuels, 

additional time periods may be granted by the Director provided a corrective program has been submitted by the 

owner or operator and approved by the Director. 

[45CSR§10-9.1, 45CSR13, R13-1674C, Kiln #7 (EP10.01), 45CSR14, R14-026A, B.5., and PreheaterPrecalciner Kiln (EP42.04)] 

5.1.32. Standard requirements. 

After May 31, 2004, an owner or operator of any Portland cement kiln subject to 45CSR§1-100 shall not 

operate the kiln during May 1 through September 30 unless the kiln has installed and operates during May 1 to 

September 30 with low-NOX burners, mid-kiln firing or alternative control techniques, subject to approval by 

the Secretary, that achieve at least the same emissions decreases as low-NOX burners or mid-kiln firing. 

[45CSR§1-100.3., 45CSR14, R14-026A, B.2., Preheater-Precalciner Kiln (EP42.04)] 

5.1.33. Mineral acids shall not be released form any type source operation or duplicate source operation or from any air 

pollution control equipment installed on any type source operation or duplicate source operation in excess of the 

quantity given in Table 45-7B of 45CSR7. Following table lists the equipment with their allowable stack 

emission rates for hydrogen chloride (HCl) and Sulfuric Acid (H2SO4). 

Allowable Stack Emission Rate Kiln Pollutant 

Milligrams Per Dry Cubic Meter 

HCl Mist and/or Vapor 210 Precalciner Kiln 

Sulfuric Acid Mist 35 

HCl Mist and/or Vapor 210 Number 7 

Sulfuric Acid Mist 35 

[45CSR§7-4.2., 45CSR14, R14-026A, B.2., Kilns #7 (EP10.01) and Preheater-Precalciner Kiln (EP42.04)] 
Title V Operating Permit R30-00300006-2006 Page 86 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

5.1.34. No person shall cause, suffer, allow, or permit the emission into open air from any source operation an in-stack 

sulfur dioxide concentration exceeding 2000 ppmv by volume from existing source operations, except as 

provided in 45CSR§10-4.1. 

 

e. Any owner or operator of a manufacturing process source operation(s) which has the potential to emit 

less than 500 pounds per year of sulfur oxides. 

[45CSR§§10-4.1. and 4.1.e., EP10.01 and EP42.04] 

5.1.35. Compliance with the allowable sulfur dioxide concentration limitations from manufacturing process source 

operation(s) set forth in 45CSR10 shall be based on a block three-(3) hour averaging time. 

[45CSR§10-4.2., EP10.01 and EP42.04] 

5.1.36. Where more than one source operation or combinations thereof, which are part of a duplicate source operation, 

are vented through separate stacks, the allowable stack emission rates for the separate stacks shall be determined 

by the following formula: 

Rs = Rt (Ws / Wt) 

Where, 

Rs is the allowable stack emission rate for the separate stack venting the source operation(s) in 

question; 

Rt is the total allowable emission rate for the duplicate source operation; 

Ws

 is the operating process weight rate for the source operation(s) vented through the separate stack; 

and 

Wt is the total operating process weight rate for the duplicate source operation. 

[45CSR§7-4.8., Kilns #7 (EP10.01) and Preheater-Precalciner Kiln (EP42.04)] 

Kiln #7 

5.1.37. When utilizing the replacement coolers for Kiln # 7 the following apply: 

(a) Clinker Cooler # 7 (ID. EP10.02) shall not be operated with out control device Cooler Dust Filter CD 

10.02. 

(b) The Cooler Dust Filter control device for Clinker Cooler (CD 10.02) # 7 shall be operated and 

maintain with a minimum collection efficiency of 99.96% for particulate matter. 

(c) Particulate Matter Emission from Emission Points ID Stack 009 (EP10.02) for Clinker Cooler #7 shall 

not exceed 6.11 pounds per hour and 26.7 tons per year. 

(d) A continuous opacity monitor shall be installed, operated, and maintained in accordance with 40 

C.F.R. 60 for Emission Points Stack 009 (EP10.02). 
Title V Operating Permit R30-00300006-2006 Page 87 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(e) Clinker Cooler # 7 (ID. EP10.02) shall not process more than 35 tons per hour and 306,600 tons per 

year. 

[45CSR13, R13-1674C, A.3., EP10.02] 

5.1.38. The permitted facility shall be constructed and operated in accordance with information filed in Permit 

Application R13-1616, R13-1674, R13-1674A, R13-1674B, and R13-1674C and any amendments thereto. The 

Secretary may suspend or revoke a permit if the plans and specifications upon which the approval was based are 

not adhered to. 

[45CSR13, R13-1674C, C.3., EP10.01.] 

Group 4 - Clinker Handling and Storage Requirements --- EU4

5.1.39. Emissions from the Group 4 point sources shall not exceed the following: 

CD 

Identification 

Number 

CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing

Or 

New 

CD43.03 New Clinker Storage Feeding D\C 0.01 New 

CD43.04 Small Clinker Storage Discharge D\C 0.01 New 

CD43.06 Small Clinker Storage Feeding D\C 0.01 New 

CD43.07 New Clinker Storage Discharge D\C 0.01 New 

CD43.08 New Steel Conveyor Discharge D\C 0.01 New 

CD43.09 New Shipping Plant Feeding D\C 0.01 New 

CD43.10 New Shipping System D\C 0.01 New 

Emissions from the Group 4 fugitive sources shall not exceed the following: 

Emission Point 

Identification Number Emission Point Description TSP (TPY) PM10 

(TPY) 

EP10.04A.01 Cooler #7 to cooler drag conveyor 7CPC1 5.88 2.78 

EP10.04A.02 Cooler drag 7CPC1 to drag conveyors 692/209/85 5.88 2.78 

EP10.04A.03 Drag conveyor 692/209/85 to bucket elevators 289/83 5.88 2.78 

EP14.01 Bucket elevator 289/83 to clinker storage hall 5.88 2.78 

EP14.02.01 Clam bucket pickup 5.88 2.78 

EP14.02.02 Clam bucket to clinker pile 5.88 2.78 

EP14.03.01 Clam bucket pickup 45.0 21.28 

EP14.03.02 Clam bucket to clinker bins 45.0 21.28 

EP14.05 Clinker reclaim screen 0.07 0.03 

EP14.07 Clinker received to pile 0.07 0.03 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 147.18 tons 

per year of TSP nor 77.78 tons per year of PM10 based on a 12 month rolling total Compliance with 45CSR§7-

4.1 will be shown by more the stringent requirements of Section 5.1.39. 
Title V Operating Permit R30-00300006-2006 Page 88 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

[45CSR14, R14-026A, A.20.] 

Group 5 - Fuel Handling Requirements - - - EU5

5.1.40. Emissions from the Group 5 point sources shall not exceed the following: 

CD Identification Number

CD Description 

Outlet Loading

(gr/dscf) 

Existing Or 

New 

CD41.03 New Coal Dust Silo for Kiln D\C 0.01 New 

CD41.04 New Coal Dust Silo for PRS D\C 0.01 New 

Emissions from the Group 5 fugitive sources shall not exceed the following: 

Emission Point 

Identification Number Emission Point Description TSP (TPY) PM10 

(TPY) 

EP15.01.01 Rail unloading to hopper 0.08 0.04 

EP15.01.02 Hopper to feeders 585/586 0.03 0.01 

EP15.02 Feeders 585/586 to conveyor 584 0.01 0.00 

EP15.03 Conveyor 584 to coal tower 0.01 0.00 

EP15.04.01 Coal tower to stockpile 0.01 0.00 

EP15.11 Truck unloading to stockpile 0.01 0.00 

EP15.04.02 Stockpile to feeders 569/570 0.01 0.00 

EP15.05.01 Feeders 569/570 to belt conveyor 567 0.01 0.00 

EP15.05.02 Belt conveyor 567 to hammermill 566 0.01 0.00 

EP15.06 Hammermill 566 0.01 0.00 

EP15.07.01 Hammermill 566 to belt conveyor 564 0.01 0.00 

EP15.07.02 Belt conveyor 564 to belt conveyor 562 0.01 0.00 

EP15.09A Belt conveyor 562 to belt conveyor 557 0.01 0.00 

EP15.10.01 Belt conveyor 557 to #7 coal tank 0.01 0.00 

EP15.10.02 #7 coal tank to weigh belt 81 0.01 0.00 

EP15.10.03 Weigh belt 81 to #7 coal mill feeder 80 0.01 0.00 

EP41.01.01 Coal feeder to conveyor 0.02 0.01 

EP41.01.02 Conveyor to CSH fuel bins 0.01 0.00 

EP41.02.01 CSH fuel bins to feeders 0.01 0.00 

EP41.03.02 Feeders to conveyor 0.02 0.01 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 1.36 tons 

per year of TSP nor 1.14 tons per year of PM10 based on a 12 month rolling total. Compliance with 45CSR§7-

4.1 will be shown by more the stringent requirements of Section 5.1.40. 

[45CSR14, R14-026A, A.22.] 

5.1.41. At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent 

practicable, maintain and operate, any affected facility including associated air pollution equipment in a manner 

consistent with good air pollution control practice for minimizing emissions. 

[45CSR16, 40 C.F.R. § 60.11 (d), 45CSR14, R14-026A, B.8.] 
Title V Operating Permit R30-00300006-2006 Page 89 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 

5.1.42. On and after the date on which the performance test required to be conducted by 40 C.F.R. § 60.8 is completed, 

an owner or operator subject to the provisions of 40 C.F.R. Part 60 Subpart Y shall not cause to be discharged 

into the atmosphere from any coal processing and conveying equipment, coal storage system, or coal transfer 

and loading system processing coal, gases which exhibit 20 percent opacity or greater. 

[45CSR16, 40 C.F.R. § 60.252 (c), 45CSR14, R14-026A, B.8., Fuel Handling System] 

 

Group 6 - Cement Production Requirements - - - EU6

5.1.43. Emissions from the Group 6 point sources shall not exceed the following: 

CD 

Identification

Number 

CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing 

Or 

New 

CD49.01 Finish Mill Transfer D\C 0.02 Existing 

CD43.13 New Chain Conveyor D\C 0.01 New 

CD44.01 New Mill 12 Feeding System D\C 0.01 New 

CD44.02 New Mill 11 Feeding System D\C 0.01 New 

CD44.07 No. 11 Cement Mill D\C 0.01 New 

CD44.09 New Cement Mill 11 D\C 0.01 New 

CD44.10 No. 12 Cement Mill D\C 0.01 New 

CD44.12 New Cement Mill 12 D\C 0.01 New 

CD16.01 No. 7 Finish Mill Norblo D\C 0.01 Existing 

CD16.02 No. 7 Finish Mill Torit D\C 0.01 Existing 

CD17.01 No. 8 Finish Mill Norblo D\C 0.01 Existing 

CD18.01 No. 9 Finish Mill Norblo D\C 0.01 Existing 

CD18.02 No. 9 Finish Mill Torit D\C 0.01 Existing 

CD19.02 No. 10 Finish Mill Baghouse D\C 0.01 Existing 

CD19.01 No. 10 Finish Mill Norblo D\C 0.01 Existing

Emissions from the Group 6 fugitive sources shall not exceed the following: 

Emission Point 

Identification Number Emission Point Description TSP (TPY) PM10 

(TPY) 

EP26.06.03 Truck unloading to stockpile 0.01 0.00 

EP26.06.04 Stockpile to truck 0.01 0.00 

EP26.06.05 Truck to storage hall 0.01 0.00 

EP26.06.06 Clam bucket to gypsum bin 0.01 0.00 

EP16.01U Feed bins to feeders 43 and 44 0.64 0.30 

EP17.01U Feed bins to feeders 246/245/244 0.64 0.30

EP18.01U Feed bins to feeders 361/362 1.29 0.61 

EP19.01U Feed bins to feeders 652/651 1.68 0.79 
Title V Operating Permit R30-00300006-2006 Page 90 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 168.94 tons 

per year of TSP nor 141.67 tons per year of PM10 based on a 12 month rolling total. Compliance with

45CSR§7-4.1 will be shown by more the stringent requirements of Section 5.1.43. 

[45CSR14, R14-026A, A.24.] 

5.1.44. Emissions from the new Finish Mills 11 & 12 air heater shall not exceed the following: 

Pollutant LB/hr TPY 

CO 11.5 50.5 

NOx 20.0 87.6 

TSP 3.3 14.4 

SO2 71.0 310.8 

VOC 0.8 3.3 

Fluorides 0.04 0.16 

[45CSR14, R14-026A, A.26.] 

5.1.45. Emissions from the new Finish Mill 10 air heater shall not exceed the following: 

Pollutant LB/hr TPY 

CO 2.4 10.7 

NOx 4.2 18.6 

TSP 0.7 3.1 

SO2 15.1 66.0 

VOC 0.2 0.7 

[45CSR14, R14-026A, A.27.] 

5.1.46. Finish Mills 10 and 11 &12 air heaters shall only combust fuel oil or natural gas. Additionally, the Finish Mill 

10 air heater shall not exceed 29.7 MMBTU/hr MDHI and the Finish Mills 11 and 12 air heater shall not exceed 

139.9 MMBTU/hr MDHI. 

[45CSR14, R14-026A, A.28.] 

Group - 7 Shipping Requirements - - - EU7

5.1.47. Emissions from the Group 7 point sources shall not exceed the following: 

 

CD 

Identification 

Number 

CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing

Or 

New 

CD24.03 S. Truck Plant D\C 0.02 Existing 

CD23.01 N.E. Packer D\C 0.01 Existing 

CD45.01 New Bulk Lane 1 D\C 0.01 New 

CD45.02 New Bulk Lane 2 D\C 0.01 New 

CD45.03 New Bulk Rail Lane D\C 0.01 New 

CD23.02 S.E. Packer D\C 0.01 Existing 
Title V Operating Permit R30-00300006-2006 Page 91 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

CD23.04 S.W. Packer D\C 0.01 Existing 

 

CD 

Identification 

Number 

CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing

Or 

New 

CD23.03 N.W. Packer D\C 0.01 Existing 

CD24.01 Truck Plant Bins D\C 0.01 Existing 

CD24.02 N. Truck Plant D\C 0.02 Existing 

CD24.04 Truck Plant B-Lock D\C 0.01 Existing 

CD45.04 New Ext.1 Cement Silo Feeding D\C 0.01 New 

CD45.05 New Ext. 2 Cement Silo Feeding D\C 0.01 New

CD45.06 New Ext.3 Cement Silo Feeding D\C 0.01 New 

CD45.07 New Int. Cement Silo Feeding D\C 0.01 New 

CD45.08 New Int. Cement Silo Discharge D\C 0.01 New

CD46.01 Cement Receiving DC1 0.01 New 

CD46.02 Cement Receiving DC2 0.01 New 

CD46.03 Cement Receiving DC3 0.01 New 

CD46.04 Cement Receiving DC4 0.01 New 

CD46.05 Cement Receiving DC5 0.01 New 

CD47.01 East Bank Silos 1DC 0.01 New 

CD20.04 East Bank Silos 2DC 0.01 New 

CD20.05 East Bank Silos 3DC 0.01 New 

CD20.06 East Bank Silos 4DC 0.01 New 

CD20.07 East Bank Silos 5DC 0.01 New 

CD21.06 Middle Bank Silos 2DC 0.01 New 

CD21.07 Middle Bank Silos 3DC 0.01 New 

CD21.08 Middle Bank Silos 4DC 0.01 New 

CD22.04 West Bank Silos 1DC 0.01 New 

CD22.05 West Bank Silos 2DC 0.01 New 

CD22.06 West Bank Silos 3DC 0.01 New 

CD22.07 West Bank Silos 4DC 0.01 New 

CD48.01 Miscellaneous D\C; Packhouse 0.01 New 

CD48.02 Color Loading D\C 0.01 New 

CD48.03 Bin Filters (14) 0.01 New 

Emissions from the Group 7 fugitive sources shall not exceed the following: 

Emission Point 

Identification Number Emission Point Description TSP (TPY) PM10 

(TPY) 

EP23.08 Northwest bulk bins 1.62 0.77 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 68.49 tons 

per year of TSP nor 57.57 tons per year of PM10 based on a 12 month rolling total. Compliance with 45CSR§7-

4.1 will be shown by more the stringent requirements of Section 5.1.47. 
Title V Operating Permit R30-00300006-2006 Page 92 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

[45CSR14, R14-026A, A.29.] 

Group - 8 Miscellaneous Sources Requirements - - - EU8

5.1.48. Emissions from the Group 8 point sources shall not exceed the following: 

CD 

Identification 

Number CD Description 

Outlet 

Loading 

(gr/dscf) 

Existing 

Or 

New 

CD13.01 Waste Dust Tank D\C 0.01 Existing 

CD31.03 Flyash Loadout D\C 0.01 Existing 

CD42.01 Kiln Bypass D\C 0.01 Existing 

CD13.03 Dry Dust Loading D\C 0.01 Existing 

EP30.01 Maint. Bldg. Boiler 0.02 Existing 

CD31.01 Flyash Tank No. 1 D\C 0.01 Existing 

CD31.02 Flyash Tank No. 2 D\C 0.01 Existing 

CD13.08 7&8 Kiln Dust Scoop Bin 0.01 Existing 

Emissions from the Group 8 fugitive sources shall not exceed the following: 

Emission Point Identification Number Emission Point Description TSP 

(TPY) 

PM10 

(TPY) 

EP13.04 Waste dust bin/wet drum to dump truck 0.69 0.33 

EP13.06 Dump truck to CKD pile 2.06 0.98 

EP34.01 Vacuum truck and sweeper 5.15 2.44 

EP0X.04 Crusher feed pile 0.14 0.07 

EP0X.05 Quarry waste pile 0.14 0.07 

EP26.01 Sand storage pile 0.04 0.02 

EP26.03 Iron storage pile 0.16 0.08 

EP47.02 Slag storage pile 0.08 0.04 

EP03.03 Calcium rock storage pile 0.03 0.01 

EP26.05 Gypsum storage pile 0.15 0.08 

EP15.04.03 Coal storage 0.52 0.26 

EP13.07 CKD stockpile 4.70 2.35 

EP25.01 Quarry haul roads 176.64 52.14 

EP25.02 Quarry haul roads (shale) 3.63 1.07 

EP25.03 Quarry haul roads (waste) 15.02 4.43 

EP25.05.01 Additive trucks (unpaved) 6.23 1.84 

EP50.03 Slag receipts (unpaved) 2.84 0.84 

EP25.07 Waste dust trucks (unpaved) 4.45 1.31 

EP25.06.01 Fuel deliveries (unpaved) 1.49 0.44 

EP25.09.01 Flyash trucks (unpaved) 10.94 3.23 

EP25.11.01 Stone bought/sold (unpaved) 1.71 0.51 
Title V Operating Permit R30-00300006-2006 Page 93 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

EP25.10.01 Waste dust customer trucks (unpaved) 0.82 0.24 

EP25.08 Misc. plant vehicles (unpaved) 6.90 2.04 

 

Emission Point Identification Number Emission Point Description TSP 

(TPY) 

PM10 

(TPY) 

EP25.04.02 Cement shipments (paved) 11.22 2.19 

EP50.02 Slag shipments (paved) 1.22 0.24 

EP25.05.02 Slag receipts (paved) 2.09 0.41 

EP50.04 Waste dust trucks (paved) 0.95 0.19 

EP25.06.02 Fuel deliveries (paved) 0.57 0.11 

EP25.09.02 Flyash trucks (paved) 1.88 0.37 

EP25.11.02 Stone bought/sold (paved) 0.82 0.16 

EP25.10.02 Waste dust trucks (paved) 0.44 0.09 

EP43.18 Emergency outside clinker pile 0.07 0.03 

EP43.19 Transfer to emergency outside clinker pile 5.88 2.78 

EP43.20 Emergency outside clinker pile to 

underground conveyor 

3.68 1.74 

Additionally, emissions from the combined above sources (both point and fugitive) shall not exceed 269.37 tons 

per year of TSP nor 80.18 tons per year of PM10 based on a 12 month rolling total. Compliance with 45CSR§7-

4.1 will be shown by more the stringent requirements of Section 5.1.48. 

[45CSR14, R14-026A, A.31.] 

5.2. Monitoring Requirements

Facility Wide Requirements

5.2.1. See Section 3.2. 

5.2.2. At the request of the Director the owner and/or operator of a source shall install such stack gas monitoring 

devices as the Director deems necessary to determine compliance with the provisions of 45CSR§10-8.2.a. The 

data from such devices shall be readily available at the source location or such other reasonable location that the 

Director may specify. At the request of the Director, or his or her duly authorized representative, such data shall 

be made available for inspection or copying. Failure to promptly provide such data shall constitute a violation 

of 45CSR10. 

[45CSR§10-8.2.a., EP10.01 and EP42.04] 

Quarry and Crushing and Raw Material Preparation - - - EU1 and EU2

5.2.3. No additional requirements. 

Pyroprocessing - - - EU3 

5.2.4. A continuous emission monitoring system (CEMS) shall be installed, operated, and maintained to measure the 

emissions of SO2, NOx, and CO from the preheater-precalciner kiln system exhaust stack. The CEMS shall be 

installed within 180 days of startup of the pyroprocessing line, and operated in compliance with the USEPA Part 
Title V Operating Permit R30-00300006-2006 Page 94 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

60, Appendix B, Performance Specification 2 (NOx and SO2) and Performance Specification 4, 4a or 4b (CO) 

as appropriate. 

[45CSR14, R14-026A, B.11.] 

5.2.5. A continuous opacity monitoring system (COMS) shall be installed, operated, and maintained to measure the 

opacity from the preheater-precalciner kiln system exhaust stack, kiln #7 (EP10.01), and the clinker coolers. 

The COMS shall be installed within 180 days of startup of the pyroprocessing line, and operated as outlined in 

Section 5.2.12 [40 C.F.R. § 63.1350 (m)]. 

[45CSR14, R14-026A, B.12.] 

 

5.2.6. Monitoring requirements. 

a. Any owner or operator of an kiln subject to 45CSR§1-100 shall complete an initial performance test and 

subsequent annual testing consistent with the requirements of 40 CFR Part 60, appendix A, method 7, 7A, 

7C, 7D or 7E; 

[45CSR§1-100.6.a., 45CSR14, R14-026A, B.2., Preheater-Precalciner Kiln, (EP42.04)] 

5.2.7. The owner or operator of fuel burning unit(s), manufacturing process source(s) or combustion source(s) shall 

demonstrate compliance with 45CSR§§10-3, 4 and 5 (Sections 5.1.34 and 5.1.35) by testing and /or monitoring 

in accordance with one or more of the following: 40 C.F.R. Part 60, Appendix A, Method 6, Method 15, 

continuous emissions monitoring systems (CEMS) or fuel sampling and analysis as set forth in an approved 

monitoring plan for each emission unit. 

[45CSR§10-8.2.c, B.5., Kiln #7 (EP10.01), Preheater-Precalciner Kiln, (EP42.04)] 

Clinker Handling and Storage - - - EU4

5.2.8. No additional requirements. 

Fuel Handling - - - EU5

5.2.9. See Section 3.2. 

5.2.10. Compliance with opacity standards shall be determined by conducting observations in accordance with 

Reference Method 9 in appendix A of 40 C.F.R. 60. For purposes of determining initial compliance, the

minimum total time of observations shall be 3 hours (30 6-minute averages) for the performance test or other set 

of observations (meaning those fugitive-type emission sources subject only to an opacity standard). 

[45CSR16, 40 C.F.R. § 60.11 (b), B.8., 45CSR14, R14-026A] 

Cement Production - - - EU6

5.2.11. See Section 3.2. 

5.2.12. The requirements under Section 3.2.4 [40 C.F.R. § 63.1350 (e)] to conduct daily Method 22 testing shall not 

apply to any specific raw mill or finish mill equipped with a continuous opacity monitor COM or bag leak 

detection system (BLDS). If the owner or operator chooses to install a COM in lieu of conducting the daily 

visual emissions testing required under Section 3.2.4 [40 C.F.R. § 63.1350 (e)], then the COM must be installed 

at the outlet of the PM control device of the raw mill or finish mill, and the COM must be installed, maintained, 

calibrated, and operated as required by the general provisions in 40 C.F.R. Part 63 Subpart A and according to 

PS–1 of appendix B to 40 C.F.R. Part 60. To remain in compliance, the opacity must be maintained such that 

the 6-minute average opacity for any 6-minute block period does not exceed 10 percent. If the average opacity 
Title V Operating Permit R30-00300006-2006 Page 95 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

for any 6-minute block period exceeds 10 percent, this shall constitute a violation of the standard. If the owner 

or operator chooses to install a BLDS in lieu of conducting the daily visual emissions testing required under 

Section 3.2.4 [40 C.F.R. § 63.1350 (e)], the requirements in Section 5.2.12 (1) through (9) [40 C.F.R. § 63.1350 

(m) (1) through (9)] apply to each BLDS: 

(1) The BLDS must be certified by the manufacturer to be capable of detecting PM emissions at 

concentrations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. 

“Certify” shall mean that the instrument manufacturer has tested the instrument on gas streams having 

a range of particle size distributions and confirmed by means of valid filterable PM tests that the 

minimum detectable concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 

grains per actual cubic foot) or less. 

(2) The sensor on the BLDS must provide output of relative PM emissions. 

(3) The BLDS must have an alarm that will activate automatically when it detects a significant increase 

 in relative PM emissions greater than a preset level. 

(4) The presence of an alarm condition should be clearly apparent to facility operating personnel. 

(5) For a positive-pressure fabric filter, each compartment or cell must have a bag leak detector. For a 

negative-pressure or induced-air fabric filter, the bag leak detector must be installed downstream of the 

fabric filter. If multiple bag leak detectors are required (for either type of fabric filter), detectors may 

share the system instrumentation and alarm. 

(6) All BLDS must be installed, operated, adjusted, and maintained so that they are based on the 

manufacturer's written specifications and recommendations. The EPA recommends that where 

appropriate, the standard operating procedures manual for each bag leak detection system include 

concepts from EPA's “Fabric Filter Bag Leak Detection Guidance” (EPA–454/R–98–015, September 

1997). 

(7) The baseline output of the system must be established as follows: 

(i) Adjust the range and the averaging period of the device; and 

(ii) Establish the alarm set points and the alarm delay time. 

(8) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be 

adjusted except as specified in the operations and maintenance plan required by paragraph (a) of this 

section. In no event may the range be increased by more than 100 percent or decreased by more than 

50 percent over a 1 calendar year period unless a responsible official as defined in 40 C.F.R. § 63.2 

certifies in writing to the Administrator that the fabric filter has been inspected and found to be in good 

operating condition. 

(9) The owner or operator must maintain and operate the fabric filter such that the bag leak detector alarm 

is not activated and alarm condition does not exist for more than 5 percent of the total operating time 

in a 6-month block period. Each time the alarm activates, alarm time will be counted as the actual 

amount of time taken by the owner or operator to initiate corrective actions. If inspection of the fabric 

filter demonstrates that no corrective actions are necessary, no alarm time will be counted. The owner

or operator must continuously record the output from the BLDS during periods of normal operation. 

Normal operation does not include periods when the BLDS is being maintained or during startup, 

shutdown or malfunction. 

[45CSR34, 40 C.F.R. § 63.1350 (m), 45CSR14, R14-026A, B.10.] 
Title V Operating Permit R30-00300006-2006 Page 96 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Shipping - - - EU7

5.2.13. See Section 3.2. 

Other Miscellaneous Sources - - - EU8

5.2.14. See Section 3.2. 

 

5.3. Testing Requirements

 

Facility Wide Requirements

5.3.1. See Section 3.3. 

Quarry and Crushing and Raw Material Preparation - - - EU1 and EU2

5.3.2. The permittee shall perform monthly USEPA Method 22 Visible Emissions tests on each emission point listed 

in Sections 5.1.9 and 5.1.13. If any emissions are observed in accordance with the Method 22 testing the 

permittee shall, within 24 hours, perform a Method 9 test in accordance with 40 CFR Part 60, Appendix A. If 

six (6) consecutive monthly inspections reveal no visible emissions, then the observer shall take the readings 

semi-annually. If there are no emissions observed in the semi-annual inspection, then the readings shall be 

annual. If, at any time a visible emission is observed, the inspections shall revert back to monthly, until (6) 

consecutive monthly readings have no visible emissions observed. Records of the Method 22 testing and any 

necessary Method 9 testing shall be retained on site by the permittee for at least five (5) years. Upon request the 

records shall be certified and made available to the Director or his/her duly authorized representative. 

[45CSR14, R14-026A, A.6.] 

5.3.3. (1) In determining compliance with the particulate matter standards in Sections 5.1.11 and 5.1.12 [40 

C.F.R. § 60.672 (b) and (c)], the owner or operator shall use Method 9 and the procedures in 40 C.F.R.

§ 60.11, with the following additions: 

(i) The minimum distance between the observer and the emission source shall be 4.57 meters 

(15 feet). 

(ii) The observer shall, when possible, select a position that minimizes interference from other 

fugitive emission sources (e.g., road dust). The required observer position relative to the sun 

(Method 9, Section 2.1) must be followed. 

(iii) For affected facilities using wet dust suppression for particulate matter control, a visible mist 

is sometimes generated by the spray. The water mist must not be confused with particulate 

matter emissions and is not to be considered a visible emission. When a water mist of this 

nature is present, the observation of emissions is to be made at a point in the plume where the 

mist is no longer visible. 

(2) When determining compliance with the fugitive emissions standard for any affected facility described 

under Sections 5.1.11 [40 C.F.R. § 60.672 (b)], the duration of the Method 9 observations may be 

reduced from 3 hours (thirty 6-minute averages) to 1 hour (ten 6-minute averages) only if the following 

conditions apply: 

(i) There are no individual readings greater than 10 percent opacity; and 
Title V Operating Permit R30-00300006-2006 Page 97 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

(ii) There are no more than 3 readings of 10 percent for the 1-hour period. 

(4) When determining compliance with the fugitive emissions standard for any crusher at which a capture 

system is not used as described under Section 5.1.12 [40 C.F.R. § 60.672 (c)], the duration of the 

Method 9 observations may be reduced from 3 hours (thirty 6-minute averages) to 1 hour (ten 6-

minute averages) only if the following conditions apply: 

(i) There are no individual readings greater than 15 percent opacity; and 

(ii) There are no more than 3 readings of 15 percent for the 1-hour period. 

[45CSR16, 40 C.F.R. § 60.675 (c) (1), (3), and (4), 45CSR14, R14-026A, B.8.]

 

5.3.4. The owner or operator shall determine compliance with the particulate matter standards in Section 5.1.10 [40 

C.F.R. § 60.672 (a)] as follows: 

(1) Method 5 or Method 17 shall be used to determine the particulate matter concentration. The sample

volume shall be at least 1.70 dscm (60 dscf). For Method 5, if the gas stream being sampled is at 

ambient temperature, the sampling probe and filter may be operated without heaters. If the gas stream 

is above ambient temperature, the sampling probe and filter may be operated at a temperature high 

enough, but no higher than 121 °C (250 °F), to prevent water condensation on the filter. 

(2) Method 9 and the procedures in 40 C.F.R. § 60.11 shall be used to determine opacity. 

 

[45CSR16, 40 C.F.R. § 60.675 (b)]

Pyroprocessing - - - EU3

5.3.5. Prior to the installation of calibrated stack gas monitoring devices, sulfur dioxide emission rates shall be 

calculated on an equivalent fuel sulfur content basis. 

[45CSR§10-8.2.b., Kiln #7 and Preheater-Precalciner Kiln, (EP42.04)] 

5.3.6. At such reasonable times as the Director may designate, the owner or operator of any fuel burning unit(s), 

manufacturing process source(s) or combustion source(s) may be required to conduct or have conducted tests to 

determine the compliance of such source(s) with the emission limitations of 45CSR§§10-3, 4 or 5 (Sections 

5.1.34 and 5.1.35). Such tests shall be conducted in accordance with the appropriate test method set forth in 40 

C.F.R. Part 60, Appendix A, Method 6, Method 15 or other equivalent EPA testing method approved by the

Director. The Director, or his or her duly authorized representative, may at his or her option witness or conduct 

such tests. Should the Director exercise his or her option to conduct such tests, the operator will provide all 

necessary sampling connections and sampling ports to be located in such manner as the Director may require, 

power for test equipment, and the required safety equipment such as scaffolding, railings, and ladders to comply 

with generally accepted good safety practices. 

[45CSR§10-8.1.a., Kiln #7 (EP10.01), 45CSR14, R14-026A, B.5., Preheater-Precalciner Kiln (EP42.04), 

Finish Mills (EP44.09, EP44.13 and EP19.02Pb] 

5.3.7. In order to determine compliance with the D/F limits set forth in 40 C.F.R. 63 Subpart LLL, the permittee shall 

perform EPA approved stack tests on Kiln #7 (EP10.01) and the new precalciner-preheater kiln (EP42.04). The 

compliance test on Kiln #7 must be performed in accordance with Kiln #7’s existing D/F testing cycle. The 

compliance test for the new preheater-precalciner kiln must be performed within 180 days of startup of the said 

kilns pyroprocessing system. 
Title V Operating Permit R30-00300006-2006 Page 98 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

[45CSR14, R14-026A, B.15., Kiln #7 (EP10.01), Preheater-Precalciner Kiln, (EP42.04)] 

5.3.8. The permittee shall conduct tests to determine compliance with the nitrogen oxides (NOx), carbon monoxide 

(CO), sulfur dioxide (SO2), volatile organic compounds (VOC), total suspended particulate (TSP), particulate 

matter 10 (PM10), hydrogen chloride (HCl) and sulfuric acid (H2SO4) emission limitations in the Kiln #7, 

Section 5.1.23. The Methods listed below from Appendix A of 40 C.F.R. Part 60 shall be utilized for purposes 

of conducting performance tests, unless the Director approves an alternate or equivalent method. Requirements 

shall be met with respect to submission of a test protocol and notification of testing. For the equipment subject 

to 40 C.F.R. 63 Subpart LLL, compliance for opacity will be shown by the more stringent rule, 45CSR7 or 40 

C.F.R. 63 Subpart LLL. Kiln #7 testing must be performed within 120 days of the Title V Permit effective date. 

 

Pollutant Method

Nitrogen Oxides (NOx) 7 

Carbon Monoxide (CO) 10 

Sulfur Dioxide (SO2) 6 

Volatile Organic Compounds (VOC) 25 or 25A 

Particulate Matter 10 (PM10) 5 or 5A 

Total Suspended Particulate (TSP) 5 or 5A 

Hydrochloric Acid (HCl) 26 

Sulfuric Acid (H2SO4) 8 

The initial testing of the hydrogen chloride (HCl) and sulfuric acid (H2SO4) and the subsequent testing to 

determine compliance with the nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (SO2), volatile 

organic compounds (VOC), total suspended particulate (TSP), and particulate matter 10 (PM10) limitations of 

Sections 5.1.23 and 5.1.33 shall be conducted in accordance with the schedule set forth in the following table: 

Test Test Results Testing Frequency

Initial 50% of NOx, CO, SO2, PM10, TSP, VOC, HCl, H2SO4 limits Once/5 years 

Initial between 50% and 90 % of NOx, CO, SO2, PM10, TSP, VOC, HCl, 

H2SO4 limits 

Once/3 years 

Initial 90% NOx, CO, SO2, PM10, TSP, VOC, HCl, H2SO4 limits Annual 

Annual If annual testing is required, after two successive tests indicate mass 

emission rates between 50% and 90 % NOx, CO, SO2, PM10, TSP, 

VOC, HCl, H2SO4 limits 

Once/3 years 

Annual If annual testing is required, after three successive tests indicate mass 

emission rates 50% of NOx, CO, SO2, PM10, TSP, VOC, HCl, 

H2SO4 limits 

Once/5 years 

Once/3 years If testing is required once/3 years, after two successive tests indicate 

mass emission rates 50% of NOx, CO, SO2, PM10, TSP, VOC, HCl, 

H2SO4 limits 

Once/5 years 

Once/3 years If testing is required once/3 years and any test indicates a mass 

emission rate 90% of NOx, CO, SO2, PM10, TSP, VOC, HCl, 

H2SO4 limits 

Annual 

Once/5 years If testing is required once /5 years and any test indicates mass 

emission rates between 50% and 90 % of NOx, CO, SO2, PM10, TSP, 

VOC, HCl, H2SO4 limits 

Once/3 years 
Title V Operating Permit R30-00300006-2006 Page 99 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Test Test Results Testing Frequency

Once/5 years If testing is required once/5 years and any test indicates a mass 

emission rate 90% of NOx, CO, SO2, PM10, TSP, VOC, HCl, 

H2SO4 limits 

Annual 

 

[45CSR§30-5.1.c., 45CSR§7-8.1., #7 Kiln (EP10.01),]

5.3.9. In order to determine compliance with the hourly VOC, TSP, and PM10 emissions limits set forth in Section 

5.1.22 and the particulate loading limit set forth in Section 5.1.24, the permittee shall perform EPA approved 

stack tests on the preheater-precalciner kiln system exhaust stack as outlined in the following table. The initial 

compliance test must be performed within 180 days of startup of the pyroprocessing system. Said stack tests 

shall be used to determine a “LB of pollutant per ton of clinker produced” emission factor. This emission factor 

along with clinker production records shall be used to determine compliance with the annual VOC and PM

emission limits set forth in Section 5.1.22. 

Test Test Results Testing Frequency 

Initial 50% of VOC, TSP, PM10 limits Once/5 years 

Initial Between 50% and 90% of VOC, TSP, PM10 limits Once/3 years 

Initial 90% of VOC, TSP, PM10 limits Annual 

Annual After two successive tests indicate emission rates 50% of VOC, TSP, PM10 limits Once/5 years 

Annual After two successive tests indicate emission rates <90% of VOC, TSP, PM10 limits Once/3 years 

Annual 90% of VOC, TSP, PM10 limits Annual 

Once/3 years After two successive tests indicate emission rates 50% of VOC, TSP, PM10 limits Once/5 years 

Once/3 years < 90% of VOC, TSP, PM10 limits Once/3 years 

Once/3 years 90% of VOC, TSP, PM10 limits Annual 

Once/5 years 50% of VOC, TSP, PM10 limits Once/5 years 

Once/5 years < 90% of VOC, TSP, PM10 limits Once/3 years 

Once/5 years 90% of VOC, TSP, PM10 limits Annual 

[45CSR14, R14-026A, B.13., Preheater-Precalciner (EP42.04)] 

5.3.10. In order to determine compliance with the hourly emissions limits set forth in Section 5.1.23, and the particulate 

loading limit set forth in Section 5.1.24, the permittee shall perform EPA approved stack tests on Kiln #7. The 

compliance tests must be performed within 180 days following startup of the preheater-precalciner kiln system. 

Said stack tests shall be used to determine a “LB of pollutant per ton of clinker produced” emission factor. This 

emission factor along with clinker production records shall be used to determine compliance with the annual 

emission limits set forth in Section 5.1.23. Said stack tests shall be repeated at least every 5 years. 

[45CSR14, R14-026A, B.14., #7 Kiln (EP10.01), Preheater-Precalciner Kiln, (EP42.04)] 

5.3.11. Within 180 days of startup of the new ph-pc kiln Capitol will perform tests using EPA Method 202 or an 

alternative test method approved by the Director to determine the emission rate of Condensable Particulate 

Matter (CPM) emitted by the new ph-pc kiln and Kiln 7. 

[45CSR14, R14-026A, B.18., #7 Kiln (EP10.01), Preheater-Precalciner Kiln, (EP42.04)] 

Clinker Handling and Storage - - - EU4

5.3.12. The permittee shall perform monthly USEPA Method 22 Visible Emissions tests on each emission point listed 
Title V Operating Permit R30-00300006-2006 Page 100 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

in Section 5.1.35. If a positive emission is observed during the monthly USEPA Method 22 inspections, a 

corrective action as listed in the site-specific Startup, Shutdown, and Malfunction plan must be initiated within 

one hour. Additionally, within one hour a certified USEPA Method 9 observer must conduct a USEPA Method 

9 “Opacity Measurement” (6-minutes) on the affected source. Records of the Method 22 testing and any 

necessary Method 9 testing shall be retained on site by the permittee for at least five (5) years. Upon request the 

records shall be certified and made available to the Director or his/her duly authorized representative. 

[45CSR14, R14-026A, A.21.] 

Fuel Handling - - - EU5

 

5.3.13. The permittee shall perform monthly USEPA Method 22 Visible Emissions tests on each emission point listed 

in Section 5.1.40. If a positive emission is observed during the monthly USEPA Method 22 inspections, a 

corrective action as listed in the site-specific Startup, Shutdown, and Malfunction plan must be initiated within 

one hour. Additionally, within one hour a certified USEPA Method 9 observer must conduct a USEPA Method 

9 “Opacity Measurement” (6-minutes) on the affected source. Records of the Method 22 testing and any 

necessary Method 9 testing shall be retained on site by the permittee for at least five (5) years. Upon request the 

records shall be certified and made available to the Director or his/her duly authorized representative. 

[45CSR14, R14-026A, A.23.] 

5.3.14. Within 60 days after achieving the maximum production rate at which the affected facility will be operated, but 

not later than 180 days after initial startup of such facility, the owner or operator of such facility shall conduct 

performance test(s) to determine compliance with emission limitations set forth in §60.252(c) and furnish a 

written report of the results of such performance test(s). 

[45CSR16, 40 C.F.R. § 60.8 (a), 45CSR14, R14-026A, B.8.]

5.3.15. The owner or operator shall determine compliance with the particular matter standards in Section 5.1.42 [40 

C.F.R. § 60.252] as follows: 

 (2) Method 9 and the procedures in Section 5.2.12 [40 C.F.R. § 60.11] shall be used to determine opacity. 

[45CSR16, 40 C.F.R. §§ 60.254 (b) and (b) (2), 45CSR14, R14-026A, B.8.]

Cement Production - - - EU6

5.3.16. The permittee shall perform monthly USEPA Method 22 Visible Emissions tests on each emission point listed 

in Section 5.1.43. If a positive emission is observed during the monthly USEPA Method 22 inspections, a 

corrective action as listed in the site-specific Startup, Shutdown, and Malfunction plan must be initiated within 

one hour. Additionally, within one hour a certified USEPA Method 9 observer must conduct a USEPA Method 

9 “Opacity Measurement” (6-minutes) on the affected source. Records of the Method 22 testing and any 

necessary Method 9 testing shall be retained on site by the permittee for at least five (5) years. Upon request the 

records shall be certified and made available to the Director or his/her duly authorized representative. 

[45CSR14, R14-026A, A.25.]

Shipping - - - EU7

5.3.17. The permittee shall perform monthly USEPA Method 22 Visible Emissions tests on each emission point listed 

in Section 5.1.47. If a positive emission is observed during the monthly USEPA Method 22 inspections, a 

corrective action as listed in the site-specific Startup, Shutdown, and Malfunction plan must be initiated within 

one hour. Additionally, within one hour a certified USEPA Method 9 observer must conduct a USEPA Method 

9 “Opacity Measurement” (6-minutes) on the affected source. Records of the Method 22 testing and any 

necessary Method 9 testing shall be retained on site by the permittee for at least five (5) years. Upon request the 

records shall be certified and made available to the Director or his/her duly authorized representative. 

[45CSR14, R14-026A, A.30.] 
Title V Operating Permit R30-00300006-2006 Page 101 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Other Miscellaneous Sources - - - EU8

5.3.18. The permittee shall perform monthly USEPA Method 22 Visible Emissions tests on each emission point listed 

in Section 5.1.48. If a positive emission is observed during the monthly USEPA Method 22 inspections, a 

corrective action as listed in the site-specific Startup, Shutdown, and Malfunction plan must be initiated within 

one hour. Additionally, within one hour a certified USEPA Method 9 observer must conduct a USEPA Method 

9 “Opacity Measurement” (6-minutes) on the affected source. Records of the Method 22 testing and any 

necessary Method 9 testing shall be retained on site by the permittee for at least five (5) years. Upon request the 

records shall be certified and made available to the Director or his/her duly authorized representative. 

[45CSR14, R14-026A, A.32.] 

5.4. Recordkeeping Requirements

 

Facility Wide Requirements

5.4.1. See Section 3.4. 

5.4.2. For the purpose of determining compliance with production limits set forth in Sections 5.1.1, 5.1.19, and 5.1.20, 

the permittee shall maintain daily and monthly records of the amount of clinker produced in each kiln. Such 

records shall be retained on-site by the permittee for at least five (5) years and shall be certified and made 

available to the Director or his duly authorized representative upon request. 

[45CSR14, R14-026A, B.16.] 

5.4.3. The permittee shall maintain monthly hours of operation for the major processing operations at the facility. 

Such records shall be retained on-site by the permittee for at least five (5) years and shall be certified and made 

available to the Director or his duly authorized representative upon request. 

[45CSR14, R14-026A, B.17.] 

Quarry and Crushing and Raw Material Preparation - - - EU1 and EU2

5.4.4. See Section 3.4. 

5.4.5. Any owner or operator subject to the provisions of 40 C.F.R. Part 60 shall furnish the Administrator written 

notification or, if acceptable to both the Administrator and the owner or operator of a source, electronic 

notification, as follows: 

(1) A notification of the date construction (or reconstruction as defined under 40 C.F.R. § 60.15) of an 

affected facility is commenced postmarked no later than 30 days after such date. 

(2) A notification of the anticipated date of initial startup of an affected facility postmarked not more than 

60 days not less than 30 days prior to such date. 

(3) A notification of the actual date of initial startup of an affected facility postmarked within 15 days after 

such date. 
Title V Operating Permit R30-00300006-2006 Page 102 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

[45CSR16, 40 C.F.R. § 60.7 (a) (1), (2), (3), 45CSR14, R14-026A, B.8.]

 

Pyroprocessing - - - EU3

5.4.6. See Section 3.4. 

5.4.7. Recordkeeping requirements. -- Any owner or operator of an kiln subject to 45CSR§1-100 shall produce and 

maintain records, which shall include, but are not limited to: 

a. The emissions, in pounds of NOX per ton of clinker produced from each affected Portland cement kiln; 

b. The type of control used for each affected Portland cement kiln; 

c. The date, time and duration of any startup, shutdown or malfunction in the operation of any of the 

cement kilns or the emissions monitoring equipment;

d. The results of any performance testing; 

e. Daily cement kiln production records; and 

f. All records required to be produced or maintained shall be retained on site for a minimum of 2 years 

and be made available to the Secretary or Administrator upon request. 

[45CSR§1-100.7., 45CSR14, R14-026A, B.2., Preheater-Precalciner Kiln, (EP42.04)]

5.4.8. The owner or operator of fuel burning unit(s), manufacturing process source(s) or combustion source(s) subject 

to 45CSR§§10-3, 4 or 5 (Sections 5.1.34 and 5.1.35) shall maintain on-site a record of all required monitoring 

data as established in a monitoring plan pursuant to 45CSR§10-8.2.c. Such records shall be made available to 

the Director or his duly authorized representative upon request. Such records shall be retained on-site for a 

minimum of five years. 

[45CSR§10-8.3.a, Kiln #7 (EP10.01), 45CSR14, R14-026A, B.5., Preheater-Precalciner Kiln, (EP42.04)]

5.4.9. The owner or operator of a fuel burning unit(s) or a combustion source(s) shall maintain records of the 

operating schedule and the quantity and quality of fuel consumed in each unit in a manner specified by the 

Director. Such records are to be maintained on-site and made available to the Director or his duly authorized 

representative upon request. 

[45CSR§10-8.3.c, Kiln #7 (EP10.01), 45CSR14, R14-026A, B.5., Preheater-Precalciner Kiln, (EP42.04)] 

Clinker Handling and Storage - - - EU4

5.4.10. See Section 3.4. 

Fuel Handling - - - EU5

 

5.4.11. See Section 3.4. 

Cement Production - - - EU6

5.4.12. See Section 3.4. 
Title V Operating Permit R30-00300006-2006 Page 103 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Shipping - - - EU7

5.4.13. See Section 3.4. 

Other Miscellaneous Sources - - - EU8

 

5.4.14. See Section 3.4. 

5.5. Reporting Requirements 

 

Facility Wide Requirements

5.5.1. See Section 3.5. 

Quarry and Crushing and Raw Material Preparation - - - EU1 and EU2

5.5.2. See Section 3.5. 

5.5.3. The owner or operator of any affected facility shall submit written reports of the results of all performance tests 

conducted to demonstrate compliance with the standards set forth in Sections 5.1.10 and 5.1.12 [40 C.F.R. § 

60.672], including reports of opacity observations made using Method 9 to demonstrate compliance with 

Sections 5.1.11 and 5.1.12 [40 C.F.R. § 60.672 (b) and (c)], and 40 C.F.R. § 60.672 (f). 

[45CSR16, 40 C.F.R. § 60.676 (f), 45CSR14, R14-026A, B.8.] 

Pyroprocessing - - - EU3

5.5.4. See Section 3.5. 

5.5.5. Reporting requirements. -- Any owner or operator subject to the requirements of Section 5.1.32 (45CSR§1-

100.3.) shall comply with the following requirements: 

b. Submit a report documenting for that kiln the total NOX emissions from May 1 through September 30 of 

each year to the Secretary and Administrator by October 31 of each year, beginning in 2004. 

[45CSR§1-100.5 (b), 45CSR14, R14-026A, B.2., Kiln #7 (EP10.01), Preheater-Precalciner Kiln, 

(EP42.04)] 

5.5.6. The owner or operator shall submit a periodic exception report to the Director, in a manner specified by the 

Director. Such an exception report shall provide details of all excursions outside the range of measured 

emissions or monitored parameters established in an approved monitoring plan and shall include, but not be 

limited to, the time of the excursion, the magnitude of the excursion, the duration of the excursion, the cause of 

the excursion and the corrective action taken. 

[45CSR§10-8.3.b, Preheater-Precalciner Kiln, (EP42.04) and Kiln #7 (EP10.01)] 

Clinker Handling and Storage - - - EU4

5.5.7. See Section 3.5. 

Fuel Handling - - - EU5
Title V Operating Permit R30-00300006-2006 Page 104 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 

5.5.8. See Section 3.5. 

Cement Production - - - EU6

5.5.9. See Section 3.5. 

Shipping - - - EU7

5.5.10. See Section 3.5. 

Other Miscellaneous Sources - - - EU8

 

5.5.11. See Section 3.4. 

5.6. Compliance Plan 

5.6.1. None 
Title V Operating Permit R30-00300006-2006 Page 105 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

APPENDIX A 

45CSR10 Monitoring Plan for Capitol Cement 

 No. 7 Kiln 

 No. 8 Kiln 

 No. 9 Kiln 
Title V Operating Permit R30-00300006-2006 Page 106 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

Facility Information:

Name: Capitol Cement Corporation

Location: 18264 South Queen Street, Martinsburg WV 25401 

Mailing Address: P O Box 885, Martinsburg, WV 25402 

Phone Number: (304)- 260-1800 

Contact Person and Title: Mark A. Andrews, Environmental Engineer 

Facility Description:

Capitol Cement Corporation (CCC) owns and operates a cement manufacturing plant near Martinsburg 

WV. The plant is a wet process type, which uses coal and coke, supplemented with scrap tires, as fuel 

for three rotary cement kilns. The kilns produce cement clinker, which is then ground into finished 

cements and shipped to customers in the mid-Atlantic region. 

The three kilns are identified locally as numbers 7, 8 and 9. They are identified as emission units 10.01, 

11.01, and 12.01 respectively in the Title V application currently on file with the West Virginia Division 

of Air Quality. The kilns are “ manufacturing process sources “ by definition of 45 CSR 10.2.11. Kilns 7 

and 8 vent through a common stack. Number 9 kiln has a separate stack. The only current applicable air

permit pertaining to the three kilns is R13-1674C. 

Cement Kiln Process Description:

The only sulfur in cement kilns comes from the fuel and raw material. Cement kilns by nature are natural 

scrubbers for SO2. As part of the clinkering process calcium carbonate is converted inside the kiln to

lime or CaO. When there is excess oxygen present SO2 converts to calcium and aluminum sulfates. As a 

result, SO2 emissions are far below the 45 CSR 10.4.1 limit of 2000 ppm and the R13-1674C permit 

limits of 924 lb./ hr. for # 7 or # 8 kiln and 1531 lb./ hr. for # 9 kiln. In the discussion of cement

manufacturing in AP-42, Section 11.6.1 of 1/ 95 it is stated that “ Sulfur Dioxide may be generated both 

from the sulfur compounds in the raw materials and from sulfur in the fuel. The sulfur content of both

raw materials and fuels varies from plant to plant and with geographic location. However, the alkaline

nature of the cement provides for direct absorption of SO2 into the product, thereby mitigating the 

quantity of SO2 emissions in the exhaust stream. Depending on the process and the source of sulfur , 

SO2 absorption ranges from about 70 percent to more than 95 percent. “ No continuous emission 

monitors for SO2 are installed on the kilns. Past stack testing results verifies the low SO2 emissions

from these wet process kilns. The stack test results are summarized below: 
Title V Operating Permit R30-00300006-2006 Page 107 of 106 

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protection • Division of Air Quality 

Approved: January 4, 2006 

 Kiln Number Test Date SO2 Concentration (ppm) SO2 Emission Rate ( lb./ hr.)

 7 June 23, 1999 273.29 418

 July 15, 1993 18.80 21 

 June 22, 2001 330.31 288 

 

 8 March 24, 1994 71.25 47 

 9 July 13, 1993 91.89 97 

Monitoring :

Normal kiln operation requires that excess oxygen be available for proper combustion and to maintain 

kiln temperatures. If an oxygen deficiency does occur, the kiln will cool down and not produce an 

acceptable product. When excess oxygen is present, the kiln is a natural scrubber for SO2 as described

above. CCC therefore petitions the Director approve the continued monitoring of the kiln oxygen level 

as an alternate to installing CEMs per 45 CSR 10A6.2.b.1. The oxygen level is measured continuously 

and recorded on a strip chart recorder. If an oxygen deficiency occurs ( less than 0.25 % ), an alarm 

sounds and the control room operator makes corrections by adjusting the kiln induced draft and/or fuel. 

Recordkeeping and Reporting:

CCC proposes that the kiln oxygen level be recorded hourly by the control room operator and that this 

record be maintained on site for review by the Director or his / her representative for five years per 45 

CSR 10A7.1.d.

Because of the low level of SO2 emissions from CCC’s cement kilns relative to 45 CSR 10 and permit 

R13-1674C limits and the inherent natural scrubbing action of the cement kiln process, CCC petitions 

the Director to waive any requirement for exception reporting under 45 CSR 10A7.2.b. 

Compliance Testing:

Because of the natural scrubbing action of the wet cement kiln process and the results of past stack 

testing -- which showed the SO2 concentration to be far below fifty percent of the 45CSR10 4.1 limit of 

2000 ppm and the R13-1674C permit emission rate limits -- , CCC petitions the Director not to require 

additional stack testing per 45CSR10A 5.2.c. 

(reg10a)