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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 Protectio n • 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 V irginia Air Pollution Control Act (West Virginia Co de §§ 22-5-1 et seq.) and 45CSR30

Requirements for Operating Permits. The permittee identified at the above-referenced facility is aut horized 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, W est Virginia Mailing Address: P.O. Box 885, 1826 South Queen St reet, Martinsburg, WV 25401 Telephone Number: (304) 267-8966 Type of Business Entity: Corporation Facility Description: Capitol Cement Plant is a Po rtland 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, includin g, but not necessarily limited to, the applicant an d any person who participated in the public comment process, by a pe rmit issued, modified or denied by the Secretary ma y 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 perm its governing the facility's operation and complian ce 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 Protectio n • 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 Defe nse ................................................ ................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............................

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

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 

### 5.0. Modern Precalciner Kiln System and related Eq uipment............................................

...... 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 Ceme nt



### .................................... 104Title V Operating Permit R30-00300006-2006 Page 5 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse EP01.01 1943 and 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 Baghouse CD01.01 1972 6,300 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 Non e None

EP01.04 EP01.03 to

EP01.04 and None EP01.03 Discharge to Surge Bin 1943 and 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 Baghouse EP02.01 1966 and 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 NoneTitle V Operating Permit R30-00300006-2006 Page 6 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 ft 2 PE CD03.01

CD03.01 EP03.01 to CD03.01 None

EP03.01 EP03.02 to

EP03.01 PE EP03.02 Material Loading /Unloading (Stone

Bays 1971 805 TPH PE CD03.02
CD03.02 EP03.02 to CD03.02 None

EP03.04 EP03.03 to

EP03.04 None EP03.03 Outside Stone Stockpiles 1971 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 Baghouse EP04.01 Number 1 Tertiary Conveying

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 Stack 4 EP04.02 1965 and 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 Baghouse CD04.02 1981 4,100 cfm Stack 004

Stack 4 CD04.02 to Stack 4 NoneTitle V Operating Permit R30-00300006-2006 Page 7 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse EP05.02 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 Baghouse CD05.02

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 Baghouse CD05.06

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 PE EP05.04 Material Unloading 1965 and 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 Baghouse EP05.05 Conveying Equipment 1965 and 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 NoneTitle V Operating Permit R30-00300006-2006 Page 8 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Settling Chamber CD10.01A Manufacture: Tralyor 1955 Cyclone CD10.01B CD10.01

B CD10.01A to

CD10.01B Cyclone

Number 7 Cyclones (7BC) CD10.01B
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 Baghouse CD10.01C

Manufacture: Western Precipitator 1963 Stack 008

EP13.02 CD10.01C to EP13.02 Baghouse

Number 7 Kiln Torch EP10.03 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 Baghouse EP10.02 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 Baghouse CD10.02

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 DSCSTitle V Operating Permit R30-00300006-2006 Page 9 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Settling Chamber CD11.01A Manufacture: Tralyor 1958 Cyclone CD11.01B and ESP CD11.01C CD11.01B CD11.01A to CD11.01B Cyclone

Number 8 Cyclone CD11.01B
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

Number 8 Kiln Torch EP11.03

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 Baghouse EP11.02 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 Baghouse CD11.02

Manufacture: Mikropul 1975 and 93,000 ACFM at 350 o F (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 ESP EP12.01 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 BaghouseTitle V Operating Permit R30-00300006-2006 Page 10 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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)

Settling Chamber CD12.01A
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 Baghouse CD12.01B Manufacture: Western Precipitator 1965 Stack 008

EP13.02 CD12.01B to EP13.02 Baghouse

Number 9 Kiln Torch EP12.04

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 Baghouse EP12.02 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 PE CD12.02

Manufacture: Micro - Pulse 1975 Temperature (2) Stack 011

Stack 11 CD12.02 to Stack 11 None

CD12.03 EP12.03 to

CD12.03 Baghouse EP12.03 Conveying Equipment 1977 58. 0 Tons of Cement Per Hour Baghouse

CD12.03
EP12.05 EP12.03 to EP12.05 None

Baghouse for Conveying Equipment CD12.03A

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 PE EP12.05 Conveying Equipment #2 and #4

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

Baghouse for Dust Bin Waste CD13.01

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 Baghouse EP13.02 Manufacture: Highland Tank 1991 250 Tons Baghouse CD13.02

ED13.05 EP13.02 to ED13.05 BaghouseTitle V Operating Permit R30-00300006-2006 Page 11 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Dust Bin Waste CD13.02

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 Bagho use CD13.03 CD13.03 EP13.03 to CD13.03 Baghouse

Baghouse for Dust Loadout Customer EP13.03 CD13.03 to EP13.03 Baghouse CD13.03

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 Nodulizer EP13.04 Dust Loadout 1991 50 Tons Nodulizer CD13.04
EP13.05 EP13.04 to EP13.06 None

EP13.04 CD13.04 to

EP13.04 None CD13.04 Nodulizer 1972 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 Ba ghouse 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 None EP13.06 Clinker Kiln Dust Loading and

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

EP11.01 EP13.08 to EP11.01 EP11.01

EP11.01 EP13.09 to

EP11.01 EP11.01 EP13.09 #8 Kiln Dust Scoop 1999 12 TPH 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 NoneTitle V Operating Permit R30-00300006-2006 Page 12 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 DS & PE EP14.01 Clinker Discharge 1955 and 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 PE EP14.02 Conveying Equipment 1955 and 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 PE EP14.04 Stockpile 1955 and 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 None EP14.08 Loading /Unloading (Portable

Crusher) Outside Clinker Stockpile 540 Tons of Cement Produced per Hour None

EP14.04 EP14.08 to EP14.04 PE

Reclaim Screen EP14.05
Manufacture: Reed 1992 100 TPH PE CD14.05 EP14.08 EP14.05 to EP14.08 PE

EP14.07 Outside Clinker Stockpile 1971 None EP14.0 8 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 PETitle V Operating Permit R30-00300006-2006 Page 13 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 FE EP15.06 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 FE EP15.08 Conveying Equipment -Coal/Coke to

#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 Baghouse EP16.01 Conveying Equipment #7 Mill 1955 and 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 NoneTitle V Operating Permit R30-00300006-2006 Page 14 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse CD17.01

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 Baghouse CD18.01

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 BaghouseTitle V Operating Permit R30-00300006-2006 Page 15 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse CD18.02
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 Baghouse CD19.02
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 BaghouseTitle V Operating Permit R30-00300006-2006 Page 16 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse CD20.01

Manufacture: Buell – Norblo 1970 14,000 cfm Stack 024

Stack 24 CD20.01 to Stack 24 None

Silo Loadout 33 EP20.03

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 Baghouse CD20.03
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 Baghouse CD20.02 1971 1,200 cfm Stack 025

Stack 25 CD20.02 to Stack 25 None

Silo Loadout 31 EP20.02

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 Baghouse CD21.01 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 BaghouseTitle V Operating Permit R30-00300006-2006 Page 17 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse CD21.02
Manufacture: Buell – Norblo 15,000 cfm Stack 028

Stack 28 CD21.02 to Stack 28 None

Silo Loadout 51 EP21.03
Manufacture: Martin Marietta 1957 and 1971 100 TPH Baghouse CD21.03 CD21.03 EP21.03 to CD21.03 Baghouse

Baghouse for Silo Loadout 51 CD21.03

Manufacture: Buell – Norblo 1973 1,200 cfm Stack 029 EP21.03 CD21.03 to EP21.03 Baghouse

Silo Loadout 53 EP21.04

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 Baghouse CD21.04
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 Baghouse CD22.01

Manufacture: Buell- Norblo 1973 9,300 cfm Stack 031

Stack 31 CD22.01 to Stack31 None

Silo Loadout 71 EP22.02

Manufacture: Martin Marietta 1964 and 1971 100 TPH Baghouse CD22.03 CD22.03 EP22.03 to CD22.03 Baghouse

Baghouse for Silo Loadout 71 CD22.02
Manufacture: Buell - Norblo 1973 1,200 cfm Stack 032 EP22.03 CD22.03 to EP22.03 BaghouseTitle V Operating Permit R30-00300006-2006 Page 18 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Silo Loadout 73 EP22.03
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 Baghouse CD22.03
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

Baghouse for Northeast Packer CD23.01

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 Baghouse EP23.02 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 Baghouse CD23.02
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 Baghouse EP23.03 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 Baghouse CD23.03 1956 9,680 cfm Stack 038

Stack 38 CD23.03 to Stack 38 None

Packer - Southwest CD23.04 EP23.04 to CD23.04 Baghouse EP23.04 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 Baghouse CD23.04
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 Baghouse CD23.05
Manufacture: Eastern Control 1976 6,000 cfm Stack 039

Stack 39 CD23.05 to Stack 39 NoneTitle V Operating Permit R30-00300006-2006 Page 19 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse CD23.06

Manufacture: Buell – Norblo 1974 5,700 cfm Stack 036

Stack 36 CD23.06 to Stack 36 None

Palletizer and Conveyor EP23.07
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 Baghouse CD24.01

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 Baghouse CD24.02

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 Baghouse CD24.03

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 Baghouse CD24.04

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 NoneTitle V Operating Permit R30-00300006-2006 Page 20 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 0.1 2 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 NoneTitle V Operating Permit R30-00300006-2006 Page 21 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Fuel Dispensing Gas EP29.02 1966 and 1972 0.15/1000

gallons through put None

Boiler Group 030

Boiler EP30.01

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 None From Truck or Other Equipment 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 Baghouse CD31.01
Manufacture: Fuller Pulse Jet 1995 1,865 cfm @ 70 degree F Stack 045

Stack 45 CD31.01 to Stack 45 None

Silo Flyash EP31.02 Manufacture: Highland Tank 1995 300 Tons Baghouse CD31.02 EP31.03 EP31.02 to EP31.03 BaghouseTitle V Operating Permit R30-00300006-2006 Page 22 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Baghouse CD31.02
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 Baghouse CD31.03
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 NoneTitle V Operating Permit R30-00300006-2006 Page 23 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Equipmen t

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
SPT1 to SP 1 EP37.04 Split (SPT1) TBD 3,395,680 TPY None NP105 SPT1 to C4 EP37.05 Surge Pile (SP 1) TBD 3,652,000 TPY None

SPT2 to TC1 EP37.04 Split (SPT2) TBD 3,395,680 TPY CD37.04 NP105 SPT2 to BC1 EP37.04 Conveyor (C4) TBD 3,395,680 TPY CD37.04 NP105 C4 to SPT2Title V Operating Permit R30-00300006-2006 Page 24 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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)

New Crushing System D\C1 CD37.04
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

New Premix Storage Feeding D\C CD37.06
Manufacture: TBD NP107

EP38.01 Swing Conveyor (SW1) TBD 3,395,680 TPY CD38.01 NP107 SW1to SP 2

SP 2 to FD1 EP38.01 Storage Pile (SP 2) TBD 3,395,680 TPY CD38.01 NP107 SP 2 to FD2 EP38.02 Feeder 1 (FD1) TBD 3,395,680 TPY CD38.01 NP107 FD1 to BC1

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

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

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

Secondary Crusher and Screens D/C CD02.01 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 TBDTitle V Operating Permit R30-00300006-2006 Page 25 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

STP3 to C5 EP39.01 Split (SPT3) TBD 3,395,680 TPY CD39.01 NP108 SPT3 to LMB C5 to SB EP39.01 Conveyor (C5) TBD 3,395,680 TPY CD39.01 NP108
C5 to HBTitle V Operating Permit R30-00300006-2006 Page 26 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 NP113Title V Operating Permit R30-00300006-2006 Page 27 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Settling Chamber CD10.01A Manufacture: Traylor TBD 1955 Cyclone CD10.01B CD10.01

B CD10.01A to

CD10.01B Cyclone

Number 7 Cyclones (7BC) CD10.01B
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

Number 7 Kiln Torch EP10.03
Manufacture: Hauck TBD 1971 140

gallons/hr of 1000 Gallons Fuel Oil Burned None EP10.01 EP10.03 to EP10.01 Cyclone

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

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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)

Number 7 Kiln Clinker Cooler EP10.02 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 o F (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

ClS 1 to C S EP43.04 Clinker Silo (ClS 1) TBD CD43.04 NP146 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
C S to U C EP43.06 Conveyor S (C S) TBD 2,212,890 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 FC1Title V Operating Permit R30-00300006-2006 Page 29 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 NoneTitle V Operating Permit R30-00300006-2006 Page 30 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 CFM11Title V Operating Permit R30-00300006-2006 Page 31 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Finish Mill Number 7 Separator EP16.01Pb
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

Baghouse for Finish Mill # 7 CD16.02
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

Baghouse for Finish Mill # 9 CD18.02
Manufacture: Torrit TBD 6,000 cfm Stack 21

Finish Mill Number 10 Separator EP19.01Pb Manufacture: Traylor Manufacturing

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

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Baghouse for Finish Mill # 10 CD19.02
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

Baghouse for Southwest Packer CD23.04
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

Baghouse for Northwest Packer CD23.03 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

Baghouse for Bins – Bulk Loading Plant CD24.01
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

Miscellaneous D\C; Packhouse CD48.01
Manufacture: Fuller Plenum - Pulse TBD CDC60Title V Operating Permit R30-00300006-2006 Page 33 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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

Color Loading D\C CD48.02
Manufacture: Fuller Plenum - Pulse TBD CDC61

EP48.03 Bin Filters (14) TBD CDC62

Bin Filters (14) CD48.03
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 NoneTitle V Operating Permit R30-00300006-2006 Page 34 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 fugi tive dust control system as the associated conveyor s unless otherwise noted. Fugitive Dust Control System / Control Device abbreviations: FE = Full Enclosure, FE/FE = Full En closure 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 De termined, TPH = Tons per hour.

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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006Title V Operating Permit R30-00300006-2006 Page 36 of 106

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West Virginia Department of Environmental Protectio n • 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" mea n those provisions contained in W.Va. Code §§ 22-5-1 to 22- 5-18.

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

2.1.3. "Secretary" means the Secretary of the Department o f Environmental Protection or such other person to whom the Secretary has delegated authority or duties pur suant 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 purp oses 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 NO x Nitrogen Oxides NSPS New Source Performance Standards
PM Particulate Matter
PM 10 Particulate Matter less

than 10 μ m 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 SO 2 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

CompoundsTitle V Operating Permit R30-00300006-2006 Page 37 of 106

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West Virginia Department of Environmental Protectio n • 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 dat e specified on the cover of this permit, except as provided in 45C SR§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 sub mitted 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 applic ation has been submitted consistent with 45CSR§30-6.2. and 45 CSR§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 applicatio n 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 permi t 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, revocat ion and reissuance, or termination, or of a notific ation of planned changes or anticipated noncompliance does n ot 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 permi t term of three (3) or more years. Such a reopenin g shall be completed not later than eighteen (18) mon ths after promulgation of the applicable requiremen t. 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 extend ed 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 De position Control) or other legislative rules of the Secretary. Upon approval by U.S. EPA, excess emiss ions offset plans shall be incorporated into the pe rmit.

c. The Secretary or U.S. EPA determines that the permi t contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permi t.

d. The Secretary or U.S. EPA determines that the permi t 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

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West Virginia Department of Environmental Protectio n • 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 proced ures 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 modificati on as defined in and according to the procedures sp ecified 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 modi fication, in accordance with 45CSR§30-6.5.b., for p ermit 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 app roved economic incentives, marketable permits, emis sions trading, and other similar programs or processes fo r changes that are provided for in the permit and t hat 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 c hange in its operations or emissions that is not ad dressed nor prohibited in its permit and which is not consi dered to be construction nor modification under any rule promulgated by the Secretary without obtaining an a mendment or modification of its permit. Such chang es shall be subject to the following requirements and restrictions:

a. The change must meet all applicable requirements an d 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. Su ch written notice shall describe each such change, including the date, any change in emissions, pollut ants emitted, and any applicable requirement that w ould 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 cha nges made at the source that result in emissions of regulated air pollutants, but not otherwise regulat ed under the permit, and the emissions resulting fr om those changes.Title V Operating Permit R30-00300006-2006 Page 39 of 106

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 e. No permittee may make any change subject to any req uirement under Title IV of the Clean Air Act (Acid Deposition Control) pursuant to the provisions of 4 5CSR§30-5.9.

f. No permittee may make any changes which would requi re 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.

[45CSR  30-5.9.]



### 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 pe rmit in conformance with the permit application and applicable requirements. No such changes shall be a modificat ion under any rule or any provision of Title I of t he 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 allowabl e under the permit. [45CSR§30-5.8]

2.11.2. Before making a change under 45CSR§30-5.8., the per mittee 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 cond itions that are affected. The permittee shall ther eafter 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 prio r to the date that the change is to be made, except that this per iod may be shortened or eliminated as necessary for a change that must be implemented more quickly to address un anticipated conditions posing a significant health, safety, or environmental hazard. If less than seven (7) da ys notice is provided because of a need to respond more quickly to such unanticipated conditions, the permi ttee 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 u nder 45CSR§30-5.8., except those provided for in 45CSR§30-5.8.d. However, the protection of the per mit shield will continue to apply to operations and emissions that are not affected by the change, prov ided that the permittee complies with the terms and conditions of the permit applicable to such operati ons and emissions. The permit shield may be reinst ated for emissions and operations affected by the change:

a. If subsequent changes cause the facility's operatio ns and emissions to revert to those authorized in t he permit and the permittee resumes compliance with th e terms and conditions of the permit, or

b. If the permittee obtains final approval of a signif icant 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 2.11.4. "Section 502(b)(10) changes" are changes that contr avene an express permit term. Such changes do not include changes that would violate applicable requirements or contravene enforceable permit terms and conditio ns that are monitoring (including test methods), recordkeep ing, reporting, or compliance certification require ments. [45CSR§30-2.39]



### 2.12. Reasonably Anticipated Operating Scenarios

2.12.1. The following are terms and conditions for reasonab ly anticipated operating scenarios identified in th is permit.

a. Contemporaneously with making a change from one ope rating 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 ter ms of this permit and 45CSR30.

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

c. The terms and conditions of each such alternative s cenario 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 th is 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 reiss uance, or modification; or for denial of a permit r enewal application. [45CSR§30-5.1.f.1.]



### 2.14. Inspection and Entry

2.14.1. The permittee shall allow any authorized representa tive of the Secretary, upon the presentation of cre dentials and other documents as may be required by law, to p erform the following:

a. At all reasonable times (including all times in whi ch the facility is in operation) enter upon the per mittee's premises where a source is located or emissions rel ated activity is conducted, or where records must b e kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any r ecords that must be kept under the conditions of th is permit;

c. Inspect at reasonable times (including all times in which the facility is in operation) any facilities

, equipment (including monitoring and air pollution C ontrol equipment), practices, or operations regulat ed 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 

### 2.15. Schedule of Compliance

2.15.1. For sources subject to a compliance schedule, certi fied 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 complianc e 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 enf orcement action that it would have been necessary t o halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. How ever, nothing in this paragraph shall be construed as pre cluding consideration of a need to halt or reduce a ctivity as a mitigating factor in determining penalties for nonc ompliance if the health, safety, or environmental i mpacts of halting or reducing operations would be more seriou s 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 sud den 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 exc eed a technology-based emission limitation under th e permit, due to unavoidable increases in emissions attributa ble to the emergency. An emergency shall not inclu de noncompliance to the extent caused by improperly de signed 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 l imitations 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 demon strated through properly signed, contemporaneous operating logs, or other relevant evidence that:

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

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

c. During the period of the emergency the permittee to ok all reasonable steps to minimize levels of emiss ions that exceeded the emission standards, or other requ irements in the permit; andTitle V Operating Permit R30-00300006-2006 Page 42 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 t o the Secretary within one (1) working day of the tim e when emission limitations were exceeded due to th e emergency and made a request for variance, and as a pplicable 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 mi tigate emissions, and corrective actions taken.

[45CSR§30-5.7.c.]

2.17.4. In any enforcement proceeding, the permittee seekin g to establish the occurrence of an emergency has t he burden of proof. [45CSR§30-5.7.d.]

2.17.5. This provision is in addition to any emergency or u pset provision contained in any applicable requirem ent. [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 potenti al to emit and excepting those provisions that are specificall y designated in the permit as "State-enforceable on ly", are enforceable by the Secretary, USEPA, and citizens u nder the Clean Air Act. [45CSR§30-5.2.a.]

2.18.2. Those provisions specifically designated i n the permit as “State-enforceable only” shall beco me “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 ma y request in writing to determine whether cause exists for mo difying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon requ est, the permittee shall also furnish to the Secret ary copies of records required to be kept by the permittee. F or information claimed to be confidential, the perm ittee 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, th e permittee shall directly provide such information to USEPA along with a claim of confidentiality in acco rdance 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 rele vant facts or a submittal of incorrect information in any permit application, the permittee shall promptly su bmit to the Secretary such supplemental facts or co rrected information. [45CSR§30-4.2.]Title V Operating Permit R30-00300006-2006 Page 43 of 106

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West Virginia Department of Environmental Protectio n • 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 requireme nts as of the date of permit issuance provided that such a pplicable requirements are included and are specifi cally identified in this permit or the Secretary has dete rmined that other requirements specifically identif ied are not applicable to the source and this permit includes s uch a determination or a concise summary thereof. [45CSR§30-5.6.a.]

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

a. The liability of an owner or operator of a source f or any violation of applicable requirements prior t o or at the time of permit issuance; or

b. The applicable requirements of the Code of West Vir ginia and Title IV of the Clean Air Act (Acid Deposition Control), consistent with § 408 (a) of t he Clean Air Act.

c. The authority of the Administrator of U.S. EPA to r equire 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 ab ility of any person to establish compliance with, o r a violation of, any applicable requirement through the use of c redible evidence to the extent authorized by law. Nothing in this permit shall be construed to waive any defense s otherwise available to the permittee including bu t not limited to any challenge to the credible evidence r ule 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 an y provision of this permit, or the application of a ny 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]Title V Operating Permit R30-00300006-2006 Page 44 of 106

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West Virginia Department of Environmental Protectio n • 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 A ir 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 acqu ired pursuant to the acid deposition control program, pr ovided that such increases do not require a permit revision under any other applicable requirement.

b. No limit shall be placed on the number of allowance s held by the source. The source may not, however, use allowances as a defense to noncompliance with a ny 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 enforceab le by the Secretary and U. S. EPA. [45CSR§30-5.1.a.2.]Title V Operating Permit R30-00300006-2006 Page 45 of 106

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West Virginia Department of Environmental Protectio n • 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, cor poration, 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 bu rning during existing or predicted periods of atmospheric stagnation. Notification shall be made by such me ans as the Secretary may deem necessary and feasible. [45CSR§6-3.2.]

3.1.3. Asbestos. The permittee is responsible for thoroughly inspect ing the facility, or part of the facility, prior to commencement of demolition or renovation for the pr esence 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 t en (10) working days prior to the commencement of any asbes tos removal on the forms prescribed by the Secretar y if the permittee is subject to the notification requir ements of 40 C.F.R. § 61.145(b)(3)(i). A copy of t his notice is required to be sent to the USEPA, the Division of W aste 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 contribu te to an objectionable odor at any location occupied by t he 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 shal l prepare standby plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tabl es 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 D ivision of Air Quality. This report is to be submi tted no later than July 1 of each year unless directed by D AQ. [W.Va. Code § 22-5-4(a)(14)]

3.1.8. Ozone-depleting substances. For those facilities performing maintenance, servic e, repair or disposal of appliances, the permittee shall comply with the sta ndards for recycling and emissions reduction pursua nt to 40 C.F.R. Part 82, Subpart F, except as provided for M otor Vehicle Air Conditioners (MVACs) in Subpart B:

a. Persons opening appliances for maintenance, service , repair, or disposal must comply with the prohibit ions and required practices pursuant to C.F.R. §§ 40-82. 154 and 82.156.

b. Equipment used during the maintenance, service, rep air, or disposal of appliances must comply with the standards for recycling and recovery equipment purs uant to C.F.R. § 40-82.158.Title V Operating Permit R30-00300006-2006 Page 46 of 106

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 c. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an app roved 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 require ments of Part 68 as part of the annual compliance certification as required by 40 C.F.R. Part 70 or 7 1. [40 C.F.R. 68]

3.1.10. No person shall cause, suffer, allow or permit emis sion of smoke and/or particulate matter into the op en air from any process source operation which is greater than twenty (20) percent opacity, except as noted in sub sections 45CSR

§7- 3.2 (See Section 3.1.11), 3.3, 3.4, 3.5, 3.6, a nd 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.) sha ll not apply to smoke and/or particulate matter emi tted from any process source operation which is less tha n forty (40) percent opacity for any period or peri ods aggregating no more than five (5) minutes in any si xty (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 pe rmit visible emissions from any storage structure(s ) associated with

any manufacturing process(es) that pursuant to Sect ion 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 wit h the storage structures in 40 C.F.R. 63 Subpart LL L, 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 part iculate 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 e xcess of the quantity specified under the appropria te source operation type in 45CSR7, Table 45-7A. Following ta ble list the equipment with their allowable stack e mission
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 EachTitle V Operating Permit R30-00300006-2006 Page 47 of 106

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### 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 a ir pollution control equipment on any process sourc e operation shall contain flow straightening devices or a vertical run of sufficient length to establish flow patterns consistent with acceptable stack sampling procedure s. [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, EP31.0 2, EU7, EU8]

3.1.15. No person shall cause, suffer, allow, or permit any manufacturing process generating fugitive particul ate matter to operate that is not equipped with a system to mi nimize the emissions of fugitive particulate matter . To minimize means that a particulate capture or suppre ssion system shall be installed to ensure the lowes t 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 dus t control of the plant premises, and plant owned, l eased or controlled access roads, by paving, application of asphalt, chemical dust suppressants or other suitab le dust control measures. Good operating practices shall b e implemented and when necessary dust suppressants shall be applied in relation to stockpiling and general m aterial handling to prevent dust generation and atm ospheric entrainment. [45CSR§7-5.2., 45CSR14, R14-026A, B.4.]Title V Operating Permit R30-00300006-2006 Page 48 of 106

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West Virginia Department of Environmental Protectio n • 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. Su ch application shall be made within twenty-four (24) h ours of the malfunction. In cases of major equipme nt 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 45CSR 7) shall be exempt from the provisions of 45CSR§7-4 provided that at all times the owner or operator shall condu ct maintenance operations in a manner consistent wi th good air pollution control practice for minimizing emiss ions. Determination of whether acceptable operatin g and maintenance procedures are being used will be based on information available to the Director, which ma y include, but is not limited to, monitoring results, opacity observations, review of operating and main tenance procedures and inspection of the source. [45CSR§

 7-10.3.]

3.1.19. The owner or operator of each new or existi ng raw mill or finish mill at a facility which is a major source subject to the provisions of 40 C.F.R. Part 63 Subp art LLL shall not cause to be discharged from the m ill sweep or air separator air pollution control device s 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 so urce subject to the provisions of 40 C.F.R. Part 63 Subp art LLL shall not cause to be discharged any gases from these affected sources which exhibit opacity in exc ess 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 operato r of an affected source subject to the provisions o f 40 C.F.R. Part 63 Subpart LLL that commences new construction or r econstruction 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 cemen t plant shall prepare for each affected source subj ect to the provisions of 40 C.F.R. Part 63 Subpart LLL, a writ ten operations and maintenance plan. The affected sources are the Raw Material Preparation (EU2), the Pyropro cessing (EU3), the Clinker Handling and Storage (EU 4), the Cement Production (EU6), the Shipping (EU7), an d the Other Miscellaneous Sources (EU8). The plan shall be submitted to the Administrator for review and ap proval as part of the application for a part 70 per mit and shall include the following information:

(1) Procedures for proper operation and maintenanc e of the affected source and air pollution control devices in order to meet the emission limits and op erating 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 b y 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 kil n and each in line kiln raw mill located at the facil ity at least once per year; andTitle V Operating Permit R30-00300006-2006 Page 49 of 106

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West Virginia Department of Environmental Protectio n • 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 procedu res 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 App endix 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 c onsecutive 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 affec ted 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 tes ting from semi-annually to annually for that affected source. If visible emissions are obse rved during any annual test, the owner or operator must resume testing of that affected sourc e 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 wi th 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 e missions monitoring under this paragraph shall not apply to any totally enclosed conveying s ystem transfer point, regardless of the location of the transfer point. "Totally enclosed c onveying 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 opera ted and maintained as total enclosures on a continuing basis in accordance with the facility op erations and maintenance plan.

(vi) If any partially enclosed or unenclosed conve ying system transfer point is located in a building, the owner or operator of the portland cem ent plant shall have the option to conduct a Method 22 visible emissions monitoring test accor ding 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 mon itored, the requirements of Section 3.2.1 (4) (i) [40 C.F.R. § 63.1350 (a) (4) (i)] apply to the moni toring of the building, and you must also test visible emissions from each side, roof and ven t of the building for at least 1-minute. The test must be conducted under normal operating condi tions.

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

3.2.2. The owner or operator of a kiln shall monit or 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 Protectio n • 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 shal l install, calibrate, maintain, and continuously oper ate 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 appendi x B to part 60 of Chapter I of Title 40.

(2) To remain in compliance, the opacity must be m aintained such that the 6-minute average opacity fo r any 6-minute block period does not exceed 20 percen t. 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), Grou p (006, 007, 012), 45CSR14, R14-026A, B.10., EP42.04]

3.2.3. The owner or operator of a clinker cooler s hall 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) thro ugh (d) (3)].

(1) Except as provided in Section 3.2.3 (2) [40 C. F.R. § 63.1350 (d) (2)], the owner or operator sha ll install, calibrate, maintain, and continuously oper ate a COM located at the outlet of the clinker cool er PM control device to continuously monitor the opaci ty. The COM shall be installed, maintained, calibrated, and operated as required by 40 C.F.R. P art 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 subj ect to the provisions of 40 C.F.R. Part 63 Subpart LLL using a fabric filter with multiple stacks or an el ectrostatic precipitator with multiple stacks may, in lieu of installing the continuous opacity monitorin g system required by Section 3.2.3 (1) [40 C.F.R. § 63.1350 (d) (1)], monitor opacity in accordance wi th 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 o f a COM in accordance with the installation specificati ons 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 e ach 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 repre sentative 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 re cord the average opacity for each six-minute period during the test.

(3) To remain in compliance, the opacity must be m aintained such that the 6-minute average opacity fo r any 6-minute block period does not exceed 10 percen t. 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 finis h mill shall monitor opacity by conducting daily vi sual emissions observations of the mill sweep and air separator PM CD 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 conducte d while the affected source is operating at the representat ive performance conditions. The duration of the Met hod 22 testTitle V Operating Permit R30-00300006-2006 Page 51 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 shall be 6 minutes. If visible emissions are observ ed during any Method 22 visible emissions test, the owner or operator must:

(1) Initiate, within one-hour, the corrective acti ons specified in the site specific operating and ma intenance 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 te st in which visible emissions were observed, conduc t a followup Method 22 test of each stack from which vi sible emissions were observed during the previous Method 22 test. If visible emissions are o bserved during the followup Method 22 test from any stack from which visible emissions were observe d during the previous Method 22 test, conduct a visual opacity test of each stack from which emissi ons were observed during the follow up Method 22 test in accordance with Method 9 of appendix A to p art 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 thr ough #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 mon itor D/F emissions in accordance with Section 3.2.6. (1) thr ough (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 m onitor to record the temperature of the exhaust gases from the kilnin-line kiln/raw mill and alkali bypass, i f applicable, at the inlet to, or upstream of, the ki ln, in-line kiln/raw mill and/or alkali bypass PM c ontrol devices

(i) The recorder response range must include zero and 1.5 times either of the average temperatures established according to the requireme nts in Section 3.3.3 (3) (iv) [40 C.F.R. § 63.1349 (b) (3) (iv)].

(ii) The reference method must be a National Insti tute of Standards and Technology calibrated reference thermocouple-potentiometer system or alte rnate reference, subject to approval by the Administrator.

(2) The owner or operator shall monitor and contin uously record the temperature of the exhaust gases from the kiln, in-line kiln/raw mill and alkali byp ass, if applicable, at the inlet to the kiln, in-li ne kiln/raw mill and/or alkali bypass PMCD.

(3) The three-hour rolling average temperature sha ll be calculated as the average of 180 successive o neminute average temperatures.

(4) Periods of time when one-minute averages are n ot available shall be ignored when calculating thre ehour rolling averages. When one-minute averages bec ome available, the first one-minute average is added to the previous 179 values to calculate the t hree-hour rolling average.

(5) When the operating status of the raw mill of t he 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 othe r temperature sensors shall be verified at least on ce 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 3.2.6. The owner or operator of any kiln or in-lin e kiln/raw mill subject to a D/F emission limit und er 40 C.F.R. Part 63 Subpart LLL shall conduct an inspection of the c omponents 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 t he operation and maintenance plan developed in acco rdance 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 p articulate matter continuous emission monitoring sy stem (PM CEMS) to measure the particulate matter discharged to the atmosphere. All requirements relating to ins tallation, 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 applicat ion to the Administrator for approval of alternate monitoring requirements to demonstrate compliance with the emi ssion standards of 40 C.F.R Part 63 Subpart LLL sub ject 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 p eriods other than those specified in this section, unless the owner or operator documents, using data or info rmation, 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 thr ee runs of the performance test.

(2) If the application to use an alternate monitor ing 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 applica tion for approval of alternate monitoring requireme nts no later than the notification of performance test. The application must contain the information specified in Section 3.2.9. (3) (i) through (3) (ii i) [40 C.F.R. §§ 63.1350 (l) (3) (i) through (l) (3 ) (iii)]:

(i) Data or information justifying the request, su ch as the technical or economic infeasibility, or the impracticality of using the required approach;

(ii) A description of the proposed alternative mon itoring 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; a nd

(iii) Data or information documenting that the alt ernative monitoring requirement would provide equivalent or better assurance of compliance with t he relevant emission standard.

(4) The Administrator will notify the owner or ope rator of the approval or denial of the application within 90 calendar days after receipt of the original requ est, or within 60 calendar days of the receipt of a ny supplementary information, whichever is later. The Administrator will not approve an alternate monitoring application unless it would provide equi valent 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 (i) Notice of the information and findings upon wh ich the intended disapproval is based; and

(ii) Notice of opportunity for the owner or operat or to present additional supporting information before final action is taken on the application. Th is notice will specify how much additional time is allowed for the owner or operator to provid e additional supporting information.

(5) The owner or operator is responsible for submi tting any supporting information in a timely manner to enable the Administrator to consider the applicatio n 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 w ith 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 esta blishing 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 equip ped with a continuous opacity monitor COM or bag le ak 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, maintai ned, 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 th at the 6- minute average opacity for any 6-minute block perio d does not exceed 10 percent. If the average opacit y for any 6-minute block period exceeds 10 percent, this shal l constitute a violation of the standard. If the ow ner or operator chooses to install a BLDS in lieu of condu cting the daily visual emissions testing required u nder 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 manufacture r to be capable of detecting PM emissions at concentrations of 10 milligrams per actual cubic me ter (0.0044 grains per actual cubic foot) or less. “Certify” shall mean that the instrument manufactur er has tested the instrument on gas streams having a range of particle size distributions and confirme d by means of valid filterable PM tests that the minimum detectable concentration limit is at or bel ow 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 increa se in relative PM emissions greater than a preset level.

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

(5) For a positive-pressure fabric filter, each co mpartment or cell must have a bag leak detector. Fo r 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 r equired (for either type of fabric filter), detecto rs may share the system instrumentation and alarm.Title V Operating Permit R30-00300006-2006 Page 54 of 106

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West Virginia Department of Environmental Protectio n • 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 recommend ations. The EPA recommends that where appropriate, the standard operating procedures manu al for each bag leak detection system include concepts from EPA's “Fabric Filter Bag Leak Detecti on Guidance” (EPA–454/R–98–015, September 1997).

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

(i) Adjust the range and the averaging period of t he 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 r esponsible official as defined in §63.2 certifies i n writing to the Administrator that the fabric filter has been inspected and found to be in good operati ng condition.

(9) The owner or operator must maintain and operat e 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 tim e in a 6-month block period. Each time the alarm acti vates, alarm time will be counted as the actual amount of time taken by the owner or operator to in itiate corrective actions. If inspection of the fab ric filter demonstrates that no corrective actions are necessary, no alarm time will be counted. The owner or operator must continuously record the output fro m 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, R14-026 A, B.10., EU2 and EU6]

3.2.11 . Startup, shutdown, and malfunction plan.

(i) The owner or operator of an affected source m ust develop and implement a written startup, shutdo wn, and malfunction plan that describes, in detail, pro cedures for operating and maintaining the source during periods of startup, shutdown, and malfunctio n, and a program of corrective action for malfunctioning process and air pollution control an d monitoring equipment used to comply with the relevant standard. This plan must be developed by t he 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 opera tor operates and maintains each affected source, including associated air pollution control and moni toring equipment, in a manner which satisfies the general duty to minimize emissions es tablished 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 p eriods of startup, shutdown, and malfunction (including corrective action taken to restore malfu nctioning process and air pollution control equipment to its normal or usual manner of operatio n).Title V Operating Permit R30-00300006-2006 Page 55 of 106

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 (ii) During periods of startup, shutdown, and mal function, the owner or operator of an affected sour ce must operate and maintain such source (including as sociated air pollution control and monitoring equipment) in accordance with the procedures specif ied 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 (includ ing actions taken to correct a malfunction) are consist ent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, t he owner or operator must keep records for that event which demonstrate that the procedures specifi ed 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 fo r that event. In addition, the owner or operator must keep records of these events as specified in 4 0 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 equipme nt. Furthermore, the owner or operator shall confirm that actions taken during the relevant repo rting period during periods of startup, shutdown, and malfunction were consistent with the affected s ource'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 (includi ng an action taken to correct a malfunction) is not consi stent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, a nd 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 wi thin 7 working days after the end of the event, in accordance with 40 C.F.R. § 63.10 (d) (5) (unless t he owner or operator makes alternative reporting arrangements, in advance, with the Administrator).

(v) The owner or operator must maintain at the af fected source a current startup, shutdown, and malfunction plan and must make the plan available u pon request for inspection and copying by the Administrator. In addition, if the startup, shutdow n, 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 mainta in at the affected source each previous (i.e., superse ded) 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 rev ision of the plan. If at any time after adoption of a startup, shutdown, and malfunction plan the affecte d source ceases operation or is otherwise no longer subject to the provisions of this part, the owner o r operator must retain a copy of the most recent pl an for 5 years from the date the source ceases operati on or is no longer subject to this part and must ma ke the plan available upon request for inspection and copying by the Administrator. The Administrator may at any time request in writing that the owner o r operator submit a copy of any startup, shutdown, and malfunction plan (or a portion thereof) which i s maintained at the affected source or in the possession of the owner or operator. Upon receipt o f 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 operat or 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 a ny 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 confiden tial business information entitled to protection from disclosure under section 114(c) of the Clean A ir 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 (vi) To satisfy the requirements of this section to develop a startup, shutdown, and malfunction pla n, the owner or operator may use the affected source's sta ndard 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 m ade available for inspection or submitted when requested by the Administrator.

(vii) Based on the results of a determination mad e under 40 C.F.R. § 63.3 6 (e) (1) (i), the Adminis trator may require that an owner or operator of an affecte d source make changes to the startup, shutdown, and malfunction plan for that source. The Administr ator must require appropriate revisions to a startup, shutdown, and malfunction plan, if the Adm inistrator finds that the plan:

(A) Does not address a startup, shutdown, or malf unction event that has occurred;

(B) Fails to provide for the operation of the sou rce (including associated air pollution control and monitoring equipment) during a startup, shutdown, o r malfunction event in a manner consistent with the general duty to minimize emissi ons established by 40 C.F.R. § 63.3 (e) (1) (i);

(C) Does not provide adequate procedures for corr ecting malfunctioning process and/or air pollution control and monitoring equipment as quick ly as practicable; or

(D) Includes an event that does not meet the defi nition of startup, shutdown, or malfunction listed in 40 C.F.R. § 63.2.

(viii) The owner or operator may periodically rev ise the startup, shutdown, and malfunction plan for the affected source as necessary to satisfy the require ments of this part or to reflect changes in equipme nt or procedures at the affected source. Unless the pe rmitting authority provides otherwise, the owner or operator may make such revisions to the startup, sh utdown, and malfunction plan without prior approval by the Administrator or the permitting aut hority. 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 malfu nction plan fails to address or inadequately addres ses an event that meets the characteristics of a malfun ction but was not included in the startup, shutdown

, and malfunction plan at the time the owner or opera tor 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 pr ocess 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 acti vities at the source which are deemed to be a start up, shutdown, or malfunction, or otherwise modifies the applicability of any emission limit, work practice requirement, or other requirement in a standard est ablished under this part, the revised plan shall no t take effect until after the owner or operator has p rovided a written notice describing the revision to the permitting authority.Title V Operating Permit R30-00300006-2006 Page 57 of 106

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 (ix) The title V permit for an affected source mus t require that the owner or operator adopt a startu p, shutdown, and malfunction plan which conforms to th e provisions of this part, and that the owner or operator operate and maintain the source in accorda nce with the procedures specified in the current startup, shutdown, and malfunction plan. However, a ny 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 7 1 of this chapter. Moreover, none of the procedures specified by the startup, shutdown, and malfunction plan for an affected source shall be deemed to fal l 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 Keepi ng/reporting as follows. [Not required for open

stockpiles, Coal and Limestone Feed Stockpile Commo n to Kiln #7, Kiln #8, Kiln #9

, haulroads, haulroads and activities regulated by 40 C.F.R. Part 63 Subpart L LL.]

a. Visible emission observations shall be conducted weekly for fugitive particulate emission activitie s identified in Section 1.0 by a certified Method 9 o bserver during periods of normal operation for a sufficient time interval to determine if any of the emission units listed above or emission points hav e visible emissions and if so, the opacity of the emi ssions. If any of the emission units listed above or emission points have visible emissions exceeding th e regulatory limit of twenty percent (20%) opacity, then a 45CSR7A evaluation shall be conducted immedi ately 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 con dition resulting in the excess visible emissions is corrected within 24 hours and the units are operate d at normal operating conditions.

b. A record of each visible emissions observation s hall be maintained, including any data required by 40 C.F.R. 60 Appendix A, Method 22 or 45CSR7A, whichev er 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 m aintenance 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 th e permitee shall maintain instrumentation on all dust collectors for pressure drop observations. The permittee shall m aintain records of the maintenance performed on each baghou se. These records shall include all maintenance wor k performed on each dust collector including the freq uency of bag/filter change outs. Records shall sta te the date and time of each dust collector inspection, the ins pection results, and corrective action taken, if an y. 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

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West Virginia Department of Environmental Protectio n • 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 per mittee 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 d esigns. The permittee shall maintain records of al l scheduled and non-scheduled maintenance and shall s tate 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 inoperabl e 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 ot herwise required by the Secretary, in accordance with the West Virginia Code, underlying regulations, permits and orders, the permittee shal l conduct test(s) to determine compliance with the emission l imitations set forth in this permit and/or establis hed or set forth in underlying documents. The Secretary or hi s duly authorized representative may at his option witness or conduct such test(s). Should the Secretary exercis e his option to conduct such test(s), the operator shall provide all necessary sampling connections and sampling por ts to be located in such manner as the Secretary ma y require, power for test equipment and the required safety equipment, such as scaffolding, railings and ladders, to comply with generally accepted good safety practice s. 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 approv e or specify additional testing or alternative test ing to the test methods specified in the permit for demons trating compliance with 40 C.F.R. Parts 60, 61, and 63, if applicable, in accordance with the Secretary’s d elegated authority and any established equivalency determination methods which are applicable.

b. The Secretary may on a source-specific basis approv e or specify additional testing or alternative test ing to the test methods specified in the permit for demons trating compliance with applicable requirements whi ch do not involve federal delegation. In specifying o r approving such alternative testing to the test me thods, the Secretary, to the extent possible, shall utiliz e the same equivalency criteria as would be used in approving such changes under Section 3.3.1.a. of th is permit.

c. All periodic tests to determine mass emission limit s from or air pollutant concentrations in discharge stacks and such other tests as specified in this permit sh all be conducted in accordance with an approved tes t protocol. Unless previously approved, such protoco ls shall be submitted to the Secretary in writing a t least thirty (30) days prior to any testing and shall con tain the information set forth by the Secretary. I n addition, the permittee shall notify the Secretary at least f ifteen (15) days prior to any testing so the Secret ary may have the opportunity to observe such tests. This n otification shall include the actual date and time during which the test will be conducted and, if appropriat e, verification that the tests will fully conform t o a referenced protocol previously approved by the Secr etary.

[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 dem onstrate initial

compliance with the emission limits of 40 C.F.R. § 63.1343 and 40 C.F.R. § 63.1345, and Sections 3.1.1 9 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. Perfo rmance test results shall be documented in complete test reports that contain the information required by Se ction 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 through (a) (10)] as well as all other relevant inf ormation. The plan to be followed during testing s hall 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 proce dures and any modifications to standard procedures;

(4) Test results;

(5) Quality assurance procedures and results;

(6) Records of operating conditions during the tes t, preparation of standards, and calibration proced ures;

(7) Raw data sheets for field sampling and field a nd laboratory analyses;

(8) Documentation of calculations;

(9) All data recorded and used to establish parame ters for compliance monitoring; and

(10) Any other information required by the test me thod.

[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 conduct ed 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 lim itations on particulate matter emissions shall demo nstrate compliance by conducting a performance test as spec ified 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 mil l subject to limitations on particulate matter emissi ons 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 nor mal 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 per iod 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 shal l 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 determin e compliance. A determination of the PM collected in the impingers ("back half") of the Met hod 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

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 (ii) Suitable methods shall be used to determine t he 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 e ach run using equation 1:



# E = (C s 

# Q sd 

# ) / P Equation 1

Where:

E = emission rate of particulate matter, kg/Mg of k iln feed.

c s = concentration of PM, kg/dscm.

Q sd = 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 ki ln or in-line kiln/raw mill, the main exhaust and alkali bypass of the kiln or in-line ki ln/raw mill shall be tested simultaneously and the combined emission rate of particulate matte r from the kiln or in-line kiln/raw mill and alkali bypass shall be computed for each run using equation 2, 

# Ec = (C sk 

# Q sdk 

# + C sd 

# Q sdb 

# ) / P Equation 2

Where:

E c = the combined emission rate of particulate matter from the kiln or in-line

kiln/raw mill and bypass stack, kg/Mg of kiln feed.

c sk = concentration of particulate matter in the kiln or in-line kiln/raw mill effluent, kg/dscm.

Q sdk = volumetric flow rate of kiln or in-line kiln/raw mill effluent, dscm/hr.

c sb = concentration of particulate matter in the alkal i bypass gas, kg/dscm.

Q sdb = 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 Secti on 3.3.3 (1) (i) [40 C.F.R. § 63.1349 (b) (1) (i)] shall be determined through the use of a c ontinuous 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 demonstr ate 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 s ubject to limitations on opacity under 40 C.F.R. Pa rt 63 Subpart LLL that is not subject to by Section 3.3.3 (1) [40 C.F.R. § 63.1349 (b) (1)] shall demonstrat e initial compliance with the affected source opacity limit by conducting a test in accordance withTitle V Operating Permit R30-00300006-2006 Page 61 of 106

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 Method 9 of Appendix A to Part 60 of Chapter I of T itle 40. The performance test shall be conducted under the conditions that exist when the affected s ource is operating at the representative performanc e 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 w hether the affected source is in initial compliance with the standard. The duration of the Method 9 per formance 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 p ercent for the first 1-hour period.

(3) The owner or operator of an affected source su bject to limitations on D/F emissions under 40 C.F. R. Part 63 Subpart LLL shall demonstrate initial compl iance with the D/F emission limit by conducting a performance test using Method 23 of appendix A to P art 60 of Chapter I of Title 40. The owner or operator of an in-line kiln/raw mill shall demonstr ate 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 bypas s shall conduct simultaneous performance tests of the kiln or in-line kiln/raw mill exhaust and the a lkali bypass. However, the owner or operator of an in-line kiln/raw mill may conduct a performance tes t of the alkali bypass exhaust when the raw mill of the in-line kiln/raw mill is operating or not opera ting.

(i) Each performance test shall consist of three s eparate 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 fo r each run shall be at least 2.5 dscm (90 dscf). The concentration shall be determined for ea ch 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 i n-line kiln/raw mill PMCD, and where applicable, the temperature at the inlet to the alkali bypass P MCD, must be continuously recorded during the period of the Method 23 test of appendix A to p art 60, and the continuous temperature record(s) must be included in the performance test report.

(iii) One-minute average temperatures must be calcu lated for each minute of each run of the test.

(iv) The run average temperature must be calculate d for each run, and the average of the run average temperatures must be determined and include d 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 unde r 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 ini tial performance test of opacity for the kiln, in-line k iln/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 repea ted every 30Title V Operating Permit R30-00300006-2006 Page 62 of 106

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West Virginia Department of Environmental Protectio n • 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 Sub part LLL, the source must conduct a performance test and establish new temperature limit(s) as spec ified in Section 3.3.3 (3) [40 C.F.R. § 63.1349 (b) (3)].

(2) If a source plans to undertake a change in ope rations that may adversely affect compliance with a n applicable PM standard under 40 C.F.R. § 63.1343, t he 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 perf ormance test required in Section 3.3.6 (1) [40 C.F. R. § 63.1349 (e) (1)], a source may operate under the pl anned operational change conditions for a period not to exceed 360 hours, provided that the conditio ns 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 pretes t operations.

(i) The source must provide the Administrator writ ten notice at least 60 days prior to undertaking an operational change that may adversel y 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 und er 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. § 63.1 349 (e) (1)], including when the planned operational change period would begin.

(ii) The performance test results must be document ed 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 Ad ministrator prior to testing, if requested.

(iv) The performance test must be conducted, and i t 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 info rmation 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; andTitle V Operating Permit R30-00300006-2006 Page 63 of 106

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West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 f. The operating conditions existing at the time of sa mpling 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, r eport, application, or record creation date. Support info rmation includes all calibration and maintenance re cords and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all repor ts required by the permit. Where appropriate, records may be m aintained 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 mai ntain a record of all odor complaints received, any investigation performed in response to such a compl aint, and any responsive action(s) taken. [45CSR§30-5.1.c. State-Enforceable only.]

3.4.4. The owner or operator shall maintain files o f all information (including all reports and notifi cations) required by this section recorded in a form suitable and readil y available for inspection and review as required b y 40 C.F.R. § 63.10(b)(1). The files shall be retained for at l east five years following the date of each occurren ce, measurement, maintenance, corrective action, report , or record. At a minimum, the most recent two year s 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 d isks, on magnetic tape, or on microfiche. [45CSR34, 40 C.F.R. § 63.1355 (a)]

3.4.5. The owner or operator shall maintain record s for each affected source as required by 40 C.F.R. §§ 63.10(b) (2) and (b) (3); and

(1) All documentation supporting initial notificat ions and notifications of compliance status under 4 0 C.F.R. § 63.9;

(2) All records of applicability determination, in cluding supporting analyses; and

(3) If the owner or operator has been granted a wa iver under 40 C.F.R. § 63.8 (f) (6), any informatio n demonstrating whether a source is meeting the requi rements for a waiver of recordkeeping or reporting requirements.

[45CSR34, 40 C.F.R. § 63.1355 (b)]

3.4.6. In addition to the recordkeeping requirement s in Section 3.4.5 [40 C.F.R. § 63.1355 (b)], the o wner or operator of an affected source equipped with a continuous mo nitoring 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 RequirementsTitle V Operating Permit R30-00300006-2006 Page 64 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 3.5.1. Responsible official. Any application form, report, or compliance certifi cation required by this permit to be submitted to the DAQ and/or USEPA shall contain a c ertification by the responsible official that state s that, based on information and belief formed after reason able 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 oth er communications required or permitted to be made to the Secretary of DEP and/or USEPA shall be made in writ ing and shall be deemed to have been duly given whe n delivered by hand, mailed first class or by private carrier with postage prepaid to the address(es) se t 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 57 th 

### 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 st atement and pay fees on an annual basis in accordance with the submittal requi rements of the Division of Air Quality. The certif ied 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 con ditions of this permit on the forms provided by the DAQ. In addition to the annu al compliance certification, the permittee may be r equired to submit certifications more frequently under an a pplicable requirement of this permit. The annual c ertification shall be submitted to the DAQ and USEPA on or befor e March 15 of each year, and shall certify complian ce for the period ending December 31. The permittee shall maintain a copy of the certification on site for f ive (5) years from submittal of the certification. [45CSR§30-5.3.e.]Title V Operating Permit R30-00300006-2006 Page 65 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Sectio n 2.17 of this permit.

3.5.8. Deviations.

a. In addition to monitoring reports required by this permit, the permittee shall promptly submit supplem ental reports and notices in accordance with the followin g:

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) wor king day of the date on which the permittee becomes aware of the deviation, if the permittee de sires to assert the affirmative defense in accordan ce with 45CSR§30-5.7. A written report of such deviat ion, which shall include the probable cause of such deviations, and any corrective actions or prev entative 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 substantia l danger to public health, safety, or the environment shall be reported to the Secretary imme diately by telephone or telefax. A written report of such deviation, which shall include the probable cause of such deviation, and any corrective action s 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 req uired under this permit shall be reported on the more frequent basis.

4. All reports of deviations shall identify the probab le cause of the deviation and any corrective action s 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 attribut able to upset conditions as defined in this permit, report the probable cause of such deviations and any corre ctive 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 b asis, or in accordance with a more detailed schedul e if required by the applicable requirement. [45CSR§30-4.3.h.1.B.]

3.5.10. Each owner or operator subject to the requi rements of 40 C.F.R. Part 63 Subpart LLL shall comp ly with the notification requirements in 40 C.F.R § 63.9 as fol lows:Title V Operating Permit R30-00300006-2006 Page 66 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 pe rmit application may be used in lieu of the initial notification required under 40 C.F.R. § 63.9 (b), p rovided 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 E PA. Permit applications shall be submitted by the same due dates as those specified for the initial n otification.

(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 o bservations 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), notificat ion of the date that the continuous emission monito r 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 speci fied 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 perfo rmance tests as part of the notification of compliance sta tus.

(2) As required by 40 C.F.R. § 63.10 (d) (3), the owner or operator of an affected source shall repo rt 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 requ ired to submit progress reports as a condition of receiv ing an extension of compliance under 40 C.F.R. § 63.6 (i) shall submit such reports by the dates spe cified in the written extension of compliance.

(4) As required by 40 C.F.R § 63.10 (d) (5), if ac tions taken by an owner or operator during a startu p, shutdown, or malfunction of an affected source (inc luding actions taken to correct a malfunction) are consistent with the procedures specified in the sou rce'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 semiannu al report. Reports shall only be required if a startup , shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfun ction report may be submitted simultaneously with the excess emissions and continuous monitoring syst em performance reports; and

(5) Any time an action taken by an owner or operat or during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startu p, shutdown, and malfunction plan, the owner or operat or shall make an immediate report of the actions taken for that event within 2 working days, by tele phone call or facsimile (FAX) transmission. The immediate report shall be followed by a letter, cer tified by the owner or operator or other responsibl e official, explaining the circumstances of the event , the reasons for not following the startup, shutdo wn, and malfunction plan, and whether any excess emissi ons 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 Protectio n • Division of Air Quality Approved: January 4, 2006 (6) As required by 40 C.F.R § 63.10 (e) (2), the o wner or operator shall submit a written report of t he results of the performance evaluation for the conti nuous monitoring system required by 40 C.F.R § 63.8 (e). The owner or operator shall submit the re port simultaneously with the results of the performance test.

(7) As required by 40 C.F.R § 63.10 (e) (2), the o wner or operator of an affected source using a continuous opacity monitoring system to determine o pacity 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 t he continuous opacity monitoring system performance ev aluation conducted under 40 C.F.R § 63.8 (e).

(8) As required by 40 C.F.R § 63.10 (e) (3), the o wner or operator of an affected source equipped wit h a continuous emission monitor shall submit an excess emissions and continuous monitoring system performance report for any event when the continuou s monitoring system data indicate the source is not in compliance with the applicable emission limi tation or operating parameter limit.

(9) The owner or operator shall submit a summary r eport semiannually, which contains the information specified in 40 C.F.R § 63.10 (e) (3) (vi). In addi tion, the summary report shall include:

(i) All exceedences of maximum control device inle t 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 ot her 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 componen t 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 t he 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 down time for any CEM or any continuous monitoring system (CMS) for the reporting period is ten percen t or greater of the total operating time for the reporting period, the owner or operator shall submi t 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 ap plies 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 deter minations 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 Protectio n • 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 Plant s do not apply to Capitol since Capitol began their existing coal handling operatio n 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 propose d coal handling operations will be subject to 40 C.F.R. Part 60 Subpart Y when the mod ifications 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 prio r to August 17, 1971. Capitol is also exempt because it is regulated by 40 C.F.R. Pa rt 63 Subpart LLL.
40 C.F.R. Part 60 Subpart LL (August 24, 1982) Standards of Performance for Metallic Mineral Proce ssing 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 Pr ocessing 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 su bject 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 i n Mineral Industries do not apply because lime or limestone is not listed as a minera l 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 Protectio n • Division of Air Quality Approved: January 4, 2006 

### 4.0. Source-Specific Requirements [Kilns #8 (EP11.01) an d #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 poin t 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 contami nated soils the following provisions shall apply:

(a) The petroleum hydrocarbon contaminated soils shall be introduced to No. 8 and 9 kilns at a maxim um rate of 0.25% by weight of the raw material feed to the kilns. The contaminated soils shall be blende d with the normal stone, shale, clay, and other raw m aterials into a water slurry prior to introduction to the kilns. Certified records of the amounts (tonna ge) 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 eff iciency for the petroleum hydrocarbon constituents.

(c) The kilns shall utilize only petroleum-contam inated soils containing fuel oil, gasoline, kerosen e, motor oil, hydraulic fluid, lubricants, and/or diesel fue l. 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 pri or to utilization in the kilns when the quantity removed at one location is greater than 25 tons. E ach certified test record shall contain, as a minim um, a description of the soil origin at the plant site, soil quantity, date, TPH concentration, and verifi cation of sampling and analytical method. A certified rec ord for each lot of contaminated soil detailing the approximate quantity of soil, in tons, the known co ntaminants present, location from which it was removed, and date processed in the kiln shall be ma intained for each quantity less than 25 tons.

(d) No chlorinated or fluorinated hydrocarbon con taminated 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 soi l in the kilns.

(f) The kilns shall utilize a maximum of 3,825 to ns of petroleum contaminated soil in any calendar y ear.

(g) Only petroleum contaminated soils from the Ca pitol Cement Corporation's Martinsburg plant proper ty 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 follo wing 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 mai ntained on site for a period of 5 years and be readily accessible to the WV Division of Air Qualit y 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 Protectio n • Division of Air Quality Approved: January 4, 2006 (b) A bin vent dust collector, identified in per mit determination form PD98-208 as CD13.08 shall be installed, maintained, and operated so as to achiev e 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 o perated with out control device Cooler Dust Filter CD CD 11.02 also operating.

(b) The Cooler Dust Filter control device for # 8 C linker 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 Poin ts 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 proc ess 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 i n Permit Application R13-1616, R13-1674, R13-1674A, R13-1674 B, and R13-1674C and any amendments thereto. The Secretary may suspend or revoke a permit if the pla ns and specifications upon which the approval was b ased are not adhered to. [45CSR13, R13-1674C, C.3.]

4.1.5. No owner or operator of a new or existing cl inker cooler at a facility which is a major source subject to the provisions of 40 C.F.R. Part 63 Subpart LLL shall c ause to be discharged into the atmosphere from the clinker cooler any gases which:

(1) Contain particulate matter in excess of 0.050 k g per Mg (0.10 LB per ton) of feed (dry basis) to t he kiln.

(2) Exhibit opacity greater than ten percent.

[45CSR34, 40 C.F.R. § 63.1345 (a), 45CSR13, R13-167 4C, B.2. and B.3.]

4.1.6. Existing or reconstructed or new brownfield source s.

No owner or operator of an existing or reconstructe d 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 th ese 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 Protectio n • 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 tem peratures 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 an d 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 l imit specified in Section 4.1.7 [40 C.F.R. § 63.134 4 (b)]. [45CSR34, 40 C.F.R. § 63.1344 (a), B.2., EP11.01 an d EP12.01]

4.1.8. The temperature limit for affected sources m eeting 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 an d 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 shal l be made within twenty-four (24) hours of the equi pment malfunction or fuel shortage. In cases of major eq uipment failure or extended shortages of conforming fuels, additional time periods may be granted by the Direc tor provided a corrective program has been submitte d 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 Por tland 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 M ay 1 to September 30 with low-NO X burners, mid-kiln firing or alternative control te chniques, subject to approval by the Secretary, that achieve at least the same emiss ions decreases as low-NO X burners or mid-kiln firing. [45CSR§1-100.3., Kiln #9 (EP12.01)]

4.1.11. No person shall cause, suffer, allow or per mit emission of particulate matter into the open ai r from any fugitive dust control system which is twenty percent (20%) o pacity or greater. [45CSR§5-3.4., Coal Handling Operations, Group 015]

4.1.12. No person shall cause, suffer, allow or per mit 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 suc h a manner as to minimize the emission of particulate m atter 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 co ntrol of the premises and owned, leased or controlled access roa ds by paving, or other suitable measures. Good ope rating practices shall be observed in relation to stockpil ing, car loading, breaking, screening and general m aintenance to minimize dust generation and atmospheric entrain ment. [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 Protectio n • Division of Air Quality Approved: January 4, 2006 4.1.14. Where more than one source operation or com binations thereof, which are part of a duplicate so urce operation, are vented through separate stacks, the allowable s tack emission rates for the separate stacks shall b e determined by the following formula:



## R s 

## = R t 

## (W s 

## / W t 

## )

Where,

R s is the allowable stack emission rate for the separ ate stack venting the source operation(s) in question;

R t is the total allowable emission rate for the dupli cate source operation;

W s is the operating process weight rate for the sourc e operation(s) vented through the separate stack; and

W t is the total operating process weight rate for the duplicate source operation.

[45CSR§7-4.8., Kilns #8 and #9 (EP11.01 and EP12.0 1)]

4.1.15. Mineral acids shall not be released form an y type source operation or duplicate source operati on or from any air pollution control equipment installed on any type s ource operation or duplicate source operation in ex cess of the quantity given in Table 45-7B of 45CSR7. Following table lists the equipment with their allowable sta ck emission rates for hydrogen chloride (HCl) and Sulf uric Acid (H 2 SO 4 ).



### 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 pe rmit the emission into open air from any source ope ration 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 proce ss source operation(s) which has the potential to e mit 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 dioxid e concentration limitations from manufacturing proc ess 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 Protectio n • 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 g as monitoring devices as the Director deems necessary to determin e compliance with the provisions of 45CSR§10-8.2.a. The data from such devices shall be readily available a t the source location or such other reasonable loca tion that the Director may specify. At the request of the Direct or, or his or her duly authorized representative, s uch data shall be made available for inspection or copying. Failu re 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 so urce(s) shall demonstrate compliance with 45CSR§§10-3, 4 and 5 (S ections 4.1.16 and 4.1.17) by testing and /or monit oring 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 f uel sampling and analysis as set forth in an approv ed 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 45 CSR§1-100 shall complete an initial performance tes t and subsequent annual testing consistent with the requi rements 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 a nnual testing requirements set forth in Section 4.2.3 (a) [45CSR§1-100.6. (a)]. Such equipment shall be ins talled 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 require d by the WV Department of Environmental Protection, Division of Air Quality (DAQ), the permittee shall submit to th e Director of the DAQ a test protocol detailing the proposed test methods, date, and time testing is to take pla ce, testing locations, and any other relevant infor mation. The Director must receive the test protocol no less tha n 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 dur ing 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 stac k gas monitoring devices, sulfur dioxide emission r ates shall be calculated on an equivalent fuel sulfur content bas is. [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 Protectio n • 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 burni ng unit(s), manufacturing process source(s) or combustion sourc e(s) may be required to conduct or have conducted t ests to determine the compliance of such source(s) with the emission limitations of 45CSR§§10-3, 4 or 5 (Secti ons 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 authori zed representative, may at his or her option witnes s or conduct such tests. Should the Director exercise his or he r option to conduct such tests, the operator will p rovide all necessary sampling connections and sampling ports t o be located in such manner as the Director may req uire, power for test equipment, and the required safety e quipment 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 b e readily accessible to WV Division of Air Quality staff to d emonstrate compliance with the conditions of R13-16 74C. 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 maintaine d for a minimum of five (5) years and be made avail able to or submitted to the Director or his/her authorized representative upon request or as required by R13-1 674C. [45CSR13, R13-1674C, B.1.]

4.4.2. The permittee shall maintain accurate record s of daily production and daily average pressure dr op across the baghouse for clinker coolers #7 and #8. These reco rds shall be certified by a responsible official, m aintained on site for a period of five (5) years, and made avail able 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 pro duce and maintain records which shall include, but are not l imited to:

a. The emissions, in pounds of NO X per ton of clinker produced from each affected Por tland cement kiln;

b. The type of control used for each affected Por tland cement kiln;

c. The date, time and duration of any startup, shut down 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 maintaine d shall be retained on site for a minimum of 2 year s and be made available to the Secretary or Administr ator 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 Protectio n • 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 so urce(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 mo nitoring data as established in a monitoring plan pursuant t o 45CSR§10-8.2.c. Such records shall be made avail able to the Director or his duly authorized representative upon request. Such records shall be retained on-si te 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 record s 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-sit e and made available to the Director or his duly au thorized 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 specif ied 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 o wner or operator shall report the results of perfor mance tests as part of the notification of compliance sta tus.

(2) As required by 40 C.F.R. § 63.10 (d) (3), the o wner 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, R13-167 4C, B.2. and B.3.]

4.5.2. The owner or operator shall submit a periodi c exception report to the Director, in a manner spe cified by the Director. Such an exception report shall provide d etails of all excursions outside the range of measu red emissions or monitored parameters established in an approved monitoring plan and shall include, but no t be limited to, the time of the excursion, the magnitud e 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 op erator subject to the requirements of Section 4.1.1 0 (45CSR§1- 100.3.) shall comply by submiting a report documen ting for that kiln the total NO X emissions from May 1 through September 30 of each year to the Secretary and Administrator by October 31 of each year, begin ning in 2004. [45CSR§1-100.5 (b), #9 Kilns (EP12.01)]



### 4.6. Compliance Plan

4.6.1. NoneTitle V Operating Permit R30-00300006-2006 Page 76 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Precal ciner 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 cat egorized 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 n ot exceed 2,300,000 tons per year. Compliance with the annual production limit shall be determined using a 12 mon th rolling total. A 12 month rolling total shall m ean 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), Prehea ter-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 ti me for the previous twelve-(12) consecutive calenda r months.

Pollutant Allowable Emissions (TPY)

PM 10 642.2
TSP 992.1
SO 2 5,702.6
NO x (as NO 2 ) 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 malf unctions, the source shall follow the procedures fo und 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 Protectio n • Division of Air Quality Approved: January 4, 2006 5.1.4. The permittee shall maintain a water truck o n site and in good operating condition, and shall u tilize same to apply water, or a mixture of water and an environme ntally acceptable dust control additive, hereinafte r referred to as solution, as often as is necessary in order to minimize the atmo spheric entrainment of fugitive particulate emissions that may be generated from haulroads and other work areas where mobile equipment is used. T he spraybar shall be equipped with commercially availa ble spray nozzles, of sufficient size and number, s o as to provide adequate coverage to the area being treated

.
The pump delivering the water, or solution, shall b e of sufficient size and capacity so as to be capab le of delivering to the spray nozzle(s) an adequate quant ity of water, or solution, and at a sufficient pres sure, so as to assure that the treatment process will minimize the atmospheric entrainment of fugitive particulate em issions generated from the haulroads and work areas where m obile 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, reconstructe d 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 a tmosphere from these affected sources, any gases wh ich:

(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-li ne 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 oxyg en; or

(ii) 0.40 ng per dscm (1.7×10 −10 gr per dscf) (TEQ) corrected to seven percent oxyg en, when the average of the performance test run average tempera tures 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, R14-026 A, 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 in let to the kiln particulate matter control device ( PMCD) and alkali bypass PMCD, if applicable, does not exceed the applicable temperature limit specified in Secti on 5.1.7. The owner or operator of an in-line kiln/raw mill s ubject 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 Se ction 5.1.20 and established during the performance test when the raw mill was operating is not exceede d.

(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 Se ction 5.1.20 and established during the performance test when the raw mill was not operating, is not ex ceeded.Title V Operating Permit R30-00300006-2006 Page 78 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 estab lished during the performance test, with or without the raw mill operating, is not exceeded.

[45CSR34, 40 C.F.R. § 63.1344 (a), 45CSR14, R14-026 A, 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, R14-026 A, B.10.]

5.1.8. The permitted facility shall be constructed and operated in accordance with information filed i n Permit Application R14-026 and any amendments thereto. Th e Secretary may suspend or revoke a permit if the p lans and specifications upon which the approval was base d are not adhered to. [45CSR14, R14-026A, C.3.]



### Group 1 - Quarry and Crushing Requirements - - - EU 1

5.1.9. Emissions from the Group 1 point sources sha ll 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 Existin g CD01.03 Existing Crusher 40T Bin D\C 0.01 Existing CD01.05 Existing Crushing 1011 to 1007 D\C 0.01 Exi sting CD02.01 Secondary Crusher Dust Collector 0.01 Exist ing CD02.03A Existing Crushing 1000 to 99 D\C 0.01 Exis ting CD02.03B Existing Crushing 999 to 998 D/C 0.01 Exis ting 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 0.0 3 EP01.07 Belt conveyor 1007 to surge pile 0.01 0.00Title V Operating Permit R30-00300006-2006 Page 79 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 100 4 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 0.0 0
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 sou rces (both point and fugitive) shall not exceed 50. 4 tons per year of TSP nor 40.6 tons per year of PM 10 based on a 12 month rolling total. Compliance wit h 45CSR§7- 4.1 will be shown by the more stringent requirement s of Section 5.1.9.

[45CSR14, R14-026A, A.5.]

5.1.10. On and after the date on which the perform ance test required to be conducted by 40 C.F.R. § 6 0.8 is completed, no owner or operator subject to the provisions of 4 0 C.F.R. Part 60 Subpart OOO shall cause to be disc harged 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 provis ions of 40 C.F.R. Part 60 Subpart OOO shall cause t o 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 opa city. [45CSR16, 40 C.F.R. § 60.672 (b), 45CSR14, R14-026A , B.8.]

5.1.12. No owner or operator shall cause to be dis charged into the atmosphere from any crusher, at wh ich a capture system is not used, fugitive emissions which exhibi t 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 Protectio n • 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 n ot exceed the following:

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10

(TPY)

EP04.01.01 Raw bins to feeders East Tunnel 0.03 0.0 1 EP04.01.02 Feeders to belt conveyor East 917 0.03 0 .01
EP05.01.01 Raw bins to feeders West Tunnel 0.01 0.0 0 EP05.01.02 Feeders to belt conveyor West 956 0.01 0 .00 EP26.02.01, EP26.04.01 Truck to stockpile (sand & i ron 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 feede rs 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 0.00Title V Operating Permit R30-00300006-2006 Page 81 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 Emission Point Identification Number Emission Point Description TSP (TPY) PM 10

(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 0.0 6 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 sou rces (both point and fugitive) shall not exceed 32. 6 tons per year of TSP nor 27.6 tons per year of PM 10 based on a 12 month rolling total. Compliance with 45CSR§7- 4.1 will be shown by the more stringent requirement s 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 fine s, 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, aut omobile fluff, carpets, non-hazardous liquids/solids, and r efuse derived fuels the permittee shall notify the Director in writing of the fuel to be used within thirty (30) d ays of the use of the fuel. Use of the alternative fuel shall only commence upon the granting of the written consent o f the Director. [45CSR14, R14-026A, A.9., Preheater-Precalciner Kil n (EP42.04)]

5.1.16. The permittee may combust spent carbon, tir es and/or roofing shingles in the new preheater-pre calciner kiln provided that the permittee shall first conduct or have conducted EPA approved stack tests to determin e compliance with the VOC and PM emission limits as s et forth in Section 5.1.22 while combusting the fuel in question. Until compliance with the VOC and PM emis sion limits are verified and written approval is gr anted by the Director, the permittee may initially only c ombust the amount of fuel needed to perform the sta ck test. A stack test protocol and the anticipated test date s hall be submitted to this office at least 7 days pr ior to the date of the stack test. Results of the stack test shall be reported to this office within 30 days of perfo rmance of stack test. The changes in fuel, however, will not be su bject to NSR/PSD review since the fuel can be accom modated in the new preheater-precalciner kiln and the Permi ttee has accounted for the criteria pollutant emiss ions’ potential changes in this PSD (R14-026 Application)

. [45CSR14, R14-026A, A.10., Preheater-Precalciner Ki ln (EP42.04)]

5.1.17. Both the existing Kiln #7 (EP10.01) and the new preheater-precalciner kiln may combust fuel oi l during startup.Title V Operating Permit R30-00300006-2006 Page 82 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 [45CSR14, R14-026A, A.11., EP10.01 and Preheater-Pr ecalciner Kiln (EP42.04)]

5.1.18. When combusting onsite generated petroleum hydrocarbon contaminated soils the following provis ions shall apply:

(a) The petroleum hydrocarbon contaminated soils sh all be introduced into the kilns at a maximum rate of 0.25% by weight of the raw material feed to the kil ns. 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% destruct ion efficiency for the petroleum hydrocarbon constituents.

(c) The kilns shall combust only onsite generated p etroleum contaminated soils containing fuel oil, gasoline, kerosene, motor oil, hydraulic fluid, lub ricants, and/or diesel fuel. The total petroleum hydrocarbon (TPH) concentration of contaminated soi l shall not exceed 50,000 mg/kg (ppm by weight) as determined by USEPA Methods 8015 (TPH) a nd 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 samp le and analyze the soil prior to utilization in the kilns. Each certified test record shall contain, a s a minimum, a description of the soil origin at th e plant site, soil quantity, date, TPH concentration, and verification of sampling and analytical method

. The aforementioned tests shall be performed at leas t once for each batch of petroleum contaminated soils burned.

(d) No chlorinated or fluorinated hydrocarbon conta minated soils shall be combusted.

(e) No material defined as hazardous wastes under 4 7CSR35 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 o f petroleum contaminated soil per year based on a 12 month rolling total.

(g) Only petroleum contaminated soils from the perm ittee's Martinsburg plant property shall be introdu ced to the kilns.

[45CSR13, R13-1674C, A.1., Kiln #7 (EP10.01), 45CSR 14, R14-026A, A.12.,Preheater-Precalciner Kiln (EP42.04)]

5.1.19. Clinker production from the preheater-preca lciner system shall not exceed 2,200,000 tons per y ear. [45CSR14, R14-026A, A.13., Preheater-Precalciner Ki ln (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 ki ln system first becomes operational whichever comes fi rst. [45CSR14, R14-026A, A.15., Kilns #8 and #9 (EP11.01 and EP12.01)]

5.1.22. Emissions from the preheater-precalciner ki ln 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 Protectio n • Division of Air Quality Approved: January 4, 2006 Source Pollutant Allowable Compliance Method Averag ing Time
Ph/pc Kiln System NOx 3098.0 TPY CEM TPY, rolling m onthly 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 mo nthly

Ph/pc Kiln System VOC 38.7 LB/hr Stack Test 3-hr av erage (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 m onthly 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 PM 10 166.4 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 PM 10 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 mont hly

[45CSR14, R14-026A, A.16., Preheater-Precalciner Ki ln (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 r olling 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 roll ing monthly total VOC 10 LB/hr Stack Test Average (3) 1-hr tests VOC 1.40 TPY Stack Test/production data TPY, 12 rol ling monthly total SO2 900.00 TPY Stack Test/production data TPY, 12 r olling 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 Protectio n • Division of Air Quality Approved: January 4, 2006 Pollutant Allowable Compliance Method Averaging Time
TSP 28.1 TPY Stack Test/production data TPY, 12 rol ling monthly total TSP 0.3 LB/ton dry feed Stack Test/production data Average (3) 1-hr tests
PM 10 23.9 TPY Stack Test/production data TPY, 12 month rolling total

PM 10 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 no t 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 N ew 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 N ew 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 sou rces shall not exceed 241.6 tons per year of TSP no r 205.3 tons per year of PM 10 based on a 12 month rolling total. Compliance wit h 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 equip ped with low-NO x burners. [45CSR14, R14-026A, A.19.]

5.1.26. No person shall cause, suffer, allow or p ermit emission of particulate matter into the open air from any fugitive dust control system which is twenty percen t (20%) opacity or greater. [45CSR§5-3.4., 45CSR14, R14-026A, B.3., Coal Handli ng Operations, EU5]

5.1.27. No person shall cause, suffer, allow or per mit 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 suc h a manner as to minimize the emission of particulate m atter into the open air. [45CSR§5-6.1., 45CSR14, R14-026A, B.3., Coal Handli ng Operations, EU5]

5.1.28. The owner or operator of a coal preparation plant or handling operation shall maintain dust co ntrol of the premises and owned, leased or controlled access roa ds by paving, or other suitable measures. Good ope rating practices shall be observed in relation to stockpil ing, car loading, breaking, screening and general m aintenance to minimize dust generation and atmospheric entrain ment. [45CSR§5-6.2., 45CSR14, R14-026A, B.3., Coal Handli ng Operations, EU5]Title V Operating Permit R30-00300006-2006 Page 85 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 5.1.29. No owner or operator subject to the provisi ons of 45CSR10 shall build, erect, install, modify or use any article, machine, equipment or process, the use of which pur posely conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, t he use of gaseous diluents to achieve compliance with a stand ard which is based on the concentration of a pollut ant 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 c linker cooler at a facility which is a major source subject to the provisions of 40 C.F.R. Part 63 Subpart LLL shall c ause to be discharged into the atmosphere from the clinker coolers any gases which:

(1) Contain particulate matter in excess of 0.050 k g per Mg (0.10 LB per ton) of feed (dry basis) to t he kiln.

(2) Exhibit opacity greater than ten percent.

[45CSR34, 40 C.F.R. § 63.1345 (a), 45CSR14, R14-026 A, 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 shal l be made within twenty-four (24) hours of the equi pment malfunction or fuel shortage. In cases of major eq uipment failure or extended shortages of conforming fuels, additional time periods may be granted by the Direc tor provided a corrective program has been submitte d 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 Por tland 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 M ay 1 to September 30 with low-NO X burners, mid-kiln firing or alternative control te chniques, subject to approval by the Secretary, that achieve at least the same emiss ions decreases as low-NO X 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 s ource operation or duplicate source operation or fr om any air pollution control equipment installed on any type s ource operation or duplicate source operation in ex cess of the quantity given in Table 45-7B of 45CSR7. Following table lists the equipment with their allowable sta ck emission rates for hydrogen chloride (HCl) and Sulf uric Acid (H 2 SO 4 ).

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 (E P10.01) 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 Protectio n • Division of Air Quality Approved: January 4, 2006 5.1.34. No person shall cause, suffer, allow, or pe rmit the emission into open air from any source ope ration 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 proce ss source operation(s) which has the potential to e mit 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 dioxid e concentration limitations from manufacturing proc ess 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 com binations thereof, which are part of a duplicate so urce operation, are vented through separate stacks, the allowable s tack emission rates for the separate stacks shall b e determined by the following formula:



## R s 

## = R t 

## (W s 

## / W t 

## )

Where,

R s is the allowable stack emission rate for the separ ate stack venting the source operation(s) in question;

R t is the total allowable emission rate for the dupli cate source operation;

W s is the operating process weight rate for the sourc e operation(s) vented through the separate stack; and

W t is the total operating process weight rate for the duplicate source operation.

[45CSR§7-4.8., Kilns #7 (EP10.01) and Preheater-Pr ecalciner 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 o perated with out control device Cooler Dust Filter CD 10.02.

(b) The Cooler Dust Filter control device for Clink er 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 Point s ID Stack 009 (EP10.02) for Clinker Cooler #7 shal l not exceed 6.11 pounds per hour and 26.7 tons per y ear.

(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 Protectio n • Division of Air Quality Approved: January 4, 2006 (e) Clinker Cooler # 7 (ID. EP10.02) shall not pro cess more than 35 tons per hour and 306,600 tons pe r 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, R13-1674 B, and R13-1674C and any amendments thereto. The Secretary may suspend or revoke a permit if the pla ns and specifications upon which the approval was b ased 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 sh all 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 Ne w 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 n ot exceed the following:

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10 (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 elev ators 289/83 5.88 2.78 EP14.01 Bucket elevator 289/83 to clinker storage h all 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 sou rces (both point and fugitive) shall not exceed 147 .18 tons per year of TSP nor 77.78 tons per year of PM 10 based on a 12 month rolling total Compliance with 45CSR§7- 4.1 will be shown by more the stringent requirement s 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 Protectio n • 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 sh all 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 n ot exceed the following:

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10 (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 0.0 1 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 0.0 1 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 sou rces (both point and fugitive) shall not exceed 1.3 6 tons per year of TSP nor 1.14 tons per year of PM 10 based on a 12 month rolling total. Compliance wi th 45CSR§7- 4.1 will be shown by more the stringent requirement s 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 sh all, to the extent practicable, maintain and operate, any affected fac ility 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 Protectio n • Division of Air Quality Approved: January 4, 2006 5.1.42. On and after the date on which the performa nce test required to be conducted by 40 C.F.R. § 60 .8 is completed, an owner or operator subject to the provisions of 4 0 C.F.R. Part 60 Subpart Y shall not cause to be di scharged into the atmosphere from any coal processing and co nveying equipment, coal storage system, or coal tra nsfer and loading system processing coal, gases which exh ibit 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 sh all 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 Existi ng CD19.01 No. 10 Finish Mill Norblo D\C 0.01 Existing

Emissions from the Group 6 fugitive sources shall n ot exceed the following:

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10 (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 0.79Title V Operating Permit R30-00300006-2006 Page 90 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 Additionally, emissions from the combined above sou rces (both point and fugitive) shall not exceed 168 .94 tons per year of TSP nor 141.67 tons per year of PM 10 based on a 12 month rolling total. Compliance with 45CSR§7-4.1 will be shown by more the stringent req uirements 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
NO x 20.0 87.6
TSP 3.3 14.4
SO 2 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 h eater shall not exceed the following:

Pollutant LB/hr TPY

CO 2.4 10.7
NO x 4.2 18.6
TSP 0.7 3.1
SO 2 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 shal l only combust fuel oil or natural gas. Additional ly, the Finish Mill 10 air heater shall not exceed 29.7 MMBTU/hr MDHI a nd 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 sh all 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 ExistingTitle V Operating Permit R30-00300006-2006 Page 91 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 n ot exceed the following:

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10 (TPY)

EP23.08 Northwest bulk bins 1.62 0.77

Additionally, emissions from the combined above sou rces (both point and fugitive) shall not exceed 68. 49 tons per year of TSP nor 57.57 tons per year of PM 10 based on a 12 month rolling total. Compliance with 45CSR§7- 4.1 will be shown by more the stringent requirement s 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 Protectio n • 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 n ot exceed the following:

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10

(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 0.51Title V Operating Permit R30-00300006-2006 Page 93 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 EP25.10.01 Waste dust customer trucks (unpaved) 0.8 2 0.24 EP25.08 Misc. plant vehicles (unpaved) 6.90 2.04

Emission Point Identification Number Emission Point Description TSP (TPY) PM 10

(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 sou rces (both point and fugitive) shall not exceed 269 .37 tons per year of TSP nor 80.18 tons per year of PM 10 based on a 12 month rolling total. Compliance with 45CSR§7- 4.1 will be shown by more the stringent requirement s 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 g as monitoring devices as the Director deems necessary to determin e compliance with the provisions of 45CSR§10-8.2.a. The data from such devices shall be readily available a t the source location or such other reasonable loca tion that the Director may specify. At the request of the Direct or, or his or her duly authorized representative, s uch data shall be made available for inspection or copying. Failu re 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 (CEM S) shall be installed, operated, and maintained to measure the emissions of SO 2 , NO x , and CO from the preheater-precalciner kiln system exhaust stack. The CEMS shall be installed within 180 days of startup of the pyropro cessing line, and operated in compliance with the U SEPA PartTitle V Operating Permit R30-00300006-2006 Page 94 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 60, Appendix B, Performance Specification 2 (NO x and SO 2 ) 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 m easure the opacity from the preheater-precalciner kiln system exhaust stack, kiln #7 (EP10.01), and the clinker c oolers. The COMS shall be installed within 180 days of star tup of the pyroprocessing line, and operated as out lined 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 45 CSR§1-100 shall complete an initial performance tes t and subsequent annual testing consistent with the requi rements of 40 CFR Part 60, appendix A, method 7, 7A

, 7C, 7D or 7E;

[45CSR§1-100.6.a., 45CSR14, R14-026A, B.2., Preheat er-Precalciner Kiln, (EP42.04)]

5.2.7. The owner or operator of fuel burning unit(s ), manufacturing process source(s) or combustion so urce(s) shall demonstrate compliance with 45CSR§§10-3, 4 and 5 (S ections 5.1.34 and 5.1.35) by testing and /or monit oring 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 f uel sampling and analysis as set forth in an approv ed 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 determin ed 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 emissi on 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 test ing shall not apply to any specific raw mill or finish mill equip ped with a continuous opacity monitor COM or bag le ak 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 m ill 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 acco rding 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 opacityTitle V Operating Permit R30-00300006-2006 Page 95 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 for any 6-minute block period exceeds 10 percent, t his shall constitute a violation of the standard. I f the owner or operator chooses to install a BLDS in lieu of co nducting the daily visual emissions testing require d under Section 3.2.4 [40 C.F.R. § 63.1350 (e)], the requir ements 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 me ter (0.0044 grains per actual cubic foot) or less. “Certify” shall mean that the instrument manufactur er has tested the instrument on gas streams having a range of particle size distributions and confirme d by means of valid filterable PM tests that the minimum detectable concentration limit is at or bel ow 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 increa se in relative PM emissions greater than a preset lev el.

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

(5) For a positive-pressure fabric filter, each co mpartment or cell must have a bag leak detector. Fo r 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 r equired (for either type of fabric filter), detecto rs 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 recommend ations. The EPA recommends that where appropriate, the standard operating procedures manu al for each bag leak detection system include concepts from EPA's “Fabric Filter Bag Leak Detecti on Guidance” (EPA–454/R–98–015, September 1997).

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

(i) Adjust the range and the averaging period of t he 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 r esponsible 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 operat e 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 tim e in a 6-month block period. Each time the alarm acti vates, alarm time will be counted as the actual amount of time taken by the owner or operator to in itiate corrective actions. If inspection of the fab ric filter demonstrates that no corrective actions are necessary, no alarm time will be counted. The owner or operator must continuously record the output fro m 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, R14-026 A, B.10.]Title V Operating Permit R30-00300006-2006 Page 96 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 Me thod 22 Visible Emissions tests on each emission po int 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 v isible emissions, then the observer shall take the readings semi-annually. If there are no emissions observed in the semi-annual inspection, then the readings sh all be annual. If, at any time a visible emission is obse rved, the inspections shall revert back to monthly, until (6) consecutive monthly readings have no visible emissi ons observed. Records of the Method 22 testing and any necessary Method 9 testing shall be retained on sit e by the permittee for at least five (5) years. Up on request the records shall be certified and made available to th e Director or his/her duly authorized representativ e. [45CSR14, R14-026A, A.6.]

5.3.3. (1) In determining compliance with the parti culate 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 p osition that minimizes interference from other fugitive emission sources (e.g., road dust). The re quired observer position relative to the sun (Method 9, Section 2.1) must be followed.

(iii) For affected facilities using wet dust suppr ession for particulate matter control, a visible mi st is sometimes generated by the spray. The water mist must not be confused with particulate matter emissions and is not to be considered a visi ble 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 e missions standard for any affected facility describ ed 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 followin g conditions apply:

(i) There are no individual readings greater than 10 percent opacity; andTitle V Operating Permit R30-00300006-2006 Page 97 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 (ii) There are no more than 3 readings of 10 perce nt for the 1-hour period.

(4) When determining compliance with the fugitive e missions standard for any crusher at which a captur e system is not used as described under Section 5.1.1 2 [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 a pply:

(i) There are no individual readings greater than 15 percent opacity; and

(ii) There are no more than 3 readings of 15 perce nt 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 compli ance with the particulate matter standards in Secti on 5.1.10 [40 C.F.R. § 60.672 (a)] as follows:

(1) Method 5 or Method 17 shall be used to determi ne the particulate matter concentration. The sample volume shall be at least 1.70 dscm (60 dscf). For M ethod 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 an d filter may be operated at a temperature high enough, but no higher than 121 °C (250 °F), to prev ent 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 stac k gas monitoring devices, sulfur dioxide emission r ates shall be calculated on an equivalent fuel sulfur content bas is. [45CSR§10-8.2.b., Kiln #7 and Preheater-Precalcine r Kiln, (EP42.04)]

5.3.6. At such reasonable times as the Director may designate, the owner or operator of any fuel burni ng unit(s), manufacturing process source(s) or combustion sourc e(s) may be required to conduct or have conducted t ests to determine the compliance of such source(s) with the emission limitations of 45CSR§§10-3, 4 or 5 (Secti ons 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 authori zed representative, may at his or her option witnes s or conduct such tests. Should the Director exercise his or he r option to conduct such tests, the operator will p rovide all necessary sampling connections and sampling ports t o be located in such manner as the Director may req uire, power for test equipment, and the required safety e quipment such as scaffolding, railings, and ladders to comply with generally accepted good safety practices. [45CSR§10-8.1.a., Kiln #7 (EP10.01), 45CSR14, R14-0 26A, 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 (EP10.0 1) and the new precalciner-preheater kiln (EP42.04) . The compliance test on Kiln #7 must be performed in acc ordance with Kiln #7’s existing D/F testing cycle. The compliance test for the new preheater-precalciner k iln 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 Protectio n • Division of Air Quality Approved: January 4, 2006 [45CSR14, R14-026A, B.15., Kiln #7 (EP10.01), Prehe ater-Precalciner Kiln, (EP42.04)]

5.3.8. The permittee shall conduct tests to determi ne compliance with the nitrogen oxides (NO x ), carbon monoxide (CO), sulfur dioxide (SO 2 ), volatile organic compounds (VOC), total suspende d particulate (TSP), particulate matter 10 (PM 10 ), hydrogen chloride (HCl) and sulfuric acid (H 2 SO 4 ) emission limitations in the Kiln #7, Section 5.1.23. The Methods listed below from Appe ndix A of 40 C.F.R. Part 60 shall be utilized for p urposes of conducting performance tests, unless the Directo r approves an alternate or equivalent method. Requ irements shall be met with respect to submission of a test p rotocol and notification of testing. For the equipm ent subject to 40 C.F.R. 63 Subpart LLL, compliance for opacity will be shown by the more stringent rule, 45CSR7 o r 40 C.F.R. 63 Subpart LLL. Kiln #7 testing must be per formed within 120 days of the Title V Permit effect ive date.



### Pollutant Method

Nitrogen Oxides (NO x ) 7 Carbon Monoxide (CO) 10 Sulfur Dioxide (SO 2 ) 6 Volatile Organic Compounds (VOC) 25 or 25A Particulate Matter 10 (PM 10 ) 5 or 5A Total Suspended Particulate (TSP) 5 or 5A Hydrochloric Acid (HCl) 26 Sulfuric Acid (H 2 SO 4 ) 8

The initial testing of the hydrogen chloride (HCl) and sulfuric acid (H 2 SO 4 ) and the subsequent testing to determine compliance with the nitrogen oxides (NO x ), carbon monoxide (CO), sulfur dioxide (SO 2 ), volatile organic compounds (VOC), total suspended particulat e (TSP), and particulate matter 10 (PM 10 ) limitations of Sections 5.1.23 and 5.1.33 shall be conducted in ac cordance with the schedule set forth in the followi ng table:



### Test Test Results Testing Frequency

Initial  50% of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl


### , H 2 SO 4 limits Once/5 years
Initial between 50% and 90 % of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl,

H 2 SO 4 limits Once/3 years

Initial  90% NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl, H 2 SO 4 limits Annual
Annual If annual testing is required, after two successive tests indicate mass

emission rates between 50% and 90 % NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl, H 2 SO 4 limits Once/3 years

Annual If annual testing is required, after three successi ve tests indicate mass

emission rates  50% of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl, H 2 SO 4 limits Once/5 years

Once/3 years If testing is required once/3 years, after two succ essive tests indicate

mass emission rates 50% of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl


### , H 2 SO 4 limits Once/5 years

Once/3 years If testing is required once/3 years and any test in dicates a mass

emission rate 90% of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl, H 2 SO 4 limits Annual

Once/5 years If testing is required once /5 years and any test i ndicates mass

emission rates between 50% and 90 % of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl, H 2 SO 4 limits Once/3 yearsTitle V Operating Permit R30-00300006-2006 Page 99 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 in dicates a mass

emission rate  90% of NO x , CO, SO 2 , PM 10 , TSP, VOC, HCl, H 2 SO 4 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 ho urly VOC, TSP, and PM 10 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 syste m exhaust stack as outlined in the following table. The initial compliance test must be performed within 180 days o f startup of the pyroprocessing system. Said stack tests shall be used to determine a “LB of pollutant per t on of clinker produced” emission factor. This emis sion 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, PM 10 limits Once/5 years Initial Between 50% and 90% of VOC, TSP, PM 10 limits Once/3 years
Initial  90% of VOC, TSP, PM 10 limits Annual
Annual After two successive tests indicate emission rates  50% of VOC, TSP, PM 10 limits Once/5 years
Annual After two successive tests indicate emission rates <90% of VOC, TSP, PM 10 limits Once/3 years
Annual  90% of VOC, TSP, PM 10 limits Annual Once/3 years After two successive tests indicate em ission rates  50% of VOC, TSP, PM 10 limits Once/5 years Once/3 years < 90% of VOC, TSP, PM 10 limits Once/3 years Once/3 years  90% of VOC, TSP, PM 10 limits Annual Once/5 years  50% of VOC, TSP, PM 10 limits Once/5 years Once/5 years < 90% of VOC, TSP, PM 10 limits Once/3 years Once/5 years  90% of VOC, TSP, PM 10 limits Annual

[45CSR14, R14-026A, B.13., Preheater-Precalciner (E P42.04)]

5.3.10. In order to determine compliance with the h ourly emissions limits set forth in Section 5.1.23, and the particulate loading limit set forth in Section 5.1.24, the perm ittee shall perform EPA approved stack tests on Kil n #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 o f pollutant per ton of clinker produced” emission f actor. This emission factor along with clinker production recor ds shall be used to determine compliance with the a nnual emission limits set forth in Section 5.1.23. Said stack tests shall be repeated at least every 5 year s. [45CSR14, R14-026A, B.14., #7 Kiln (EP10.01), Prehe ater-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 2 02 or an

alternative test method approved by the Director to determine the emission rate of Condensable Particu late Matter (CPM) emitted by the new ph-pc kiln and Kiln 7. [45CSR14, R14-026A, B.18., #7 Kiln (EP10.01), Prehe ater-Precalciner Kiln, (EP42.04)]



### Clinker Handling and Storage - - - EU4

5.3.12. The permittee shall perform monthly USEPA M ethod 22 Visible Emissions tests on each emission p oint listedTitle V Operating Permit R30-00300006-2006 Page 100 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 in Section 5.1.35. If a positive emission is obser ved during the monthly USEPA Method 22 inspections, a corrective action as listed in the site-specific St artup, Shutdown, and Malfunction plan must be initi ated within one hour. Additionally, within one hour a certifie d USEPA Method 9 observer must conduct a USEPA Meth od 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 sit e by the permittee for at least five (5) years. Up on request the records shall be certified and made available to th e Director or his/her duly authorized representativ e. [45CSR14, R14-026A, A.21.]



### Fuel Handling - - - EU5

5.3.13. The permittee shall perform monthly USEPA M ethod 22 Visible Emissions tests on each emission p oint listed in Section 5.1.40. If a positive emission is obser ved during the monthly USEPA Method 22 inspections, a corrective action as listed in the site-specific St artup, Shutdown, and Malfunction plan must be initi ated within one hour. Additionally, within one hour a certifie d USEPA Method 9 observer must conduct a USEPA Meth od 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 sit e by the permittee for at least five (5) years. Up on request the records shall be certified and made available to th e Director or his/her duly authorized representativ e. [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 su ch facility, the owner or operator of such facility shall conduct performance test(s) to determine compliance with em ission limitations set forth in §60.252(c) and furn ish a written report of the results of such performance t est(s). [45CSR16, 40 C.F.R. § 60.8 (a), 45CSR14, R14-026A, B.8.]

5.3.15. The owner or operator shall determine compl iance with the particular matter standards in Secti on 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 opa city.

[45CSR16, 40 C.F.R. §§ 60.254 (b) and (b) (2), 45CS R14, R14-026A, B.8.]



### Cement Production - - - EU6

5.3.16. The permittee shall perform monthly USEPA M ethod 22 Visible Emissions tests on each emission p oint listed in Section 5.1.43. If a positive emission is obser ved during the monthly USEPA Method 22 inspections, a corrective action as listed in the site-specific St artup, Shutdown, and Malfunction plan must be initi ated within one hour. Additionally, within one hour a certifie d USEPA Method 9 observer must conduct a USEPA Meth od 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 sit e by the permittee for at least five (5) years. Up on request the records shall be certified and made available to th e Director or his/her duly authorized representativ e. [45CSR14, R14-026A, A.25.]



### Shipping - - - EU7

5.3.17. The permittee shall perform monthly USEPA M ethod 22 Visible Emissions tests on each emission p oint listed in Section 5.1.47. If a positive emission is obser ved during the monthly USEPA Method 22 inspections, a corrective action as listed in the site-specific St artup, Shutdown, and Malfunction plan must be initi ated within one hour. Additionally, within one hour a certifie d USEPA Method 9 observer must conduct a USEPA Meth od 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 sit e by the permittee for at least five (5) years. Up on request the records shall be certified and made available to th e Director or his/her duly authorized representativ e. [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 Protectio n • Division of Air Quality Approved: January 4, 2006 

### Other Miscellaneous Sources - - - EU8

5.3.18. The permittee shall perform monthly USEPA M ethod 22 Visible Emissions tests on each emission p oint listed in Section 5.1.48. If a positive emission is obser ved during the monthly USEPA Method 22 inspections, a corrective action as listed in the site-specific St artup, Shutdown, and Malfunction plan must be initi ated within one hour. Additionally, within one hour a certifie d USEPA Method 9 observer must conduct a USEPA Meth od 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 sit e by the permittee for at least five (5) years. Up on request the records shall be certified and made available to th e Director or his/her duly authorized representativ e. [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 wi th production limits set forth in Sections 5.1.1, 5 .1.19, and 5.1.20, the permittee shall maintain daily and monthly reco rds 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 re presentative upon request. [45CSR14, R14-026A, B.16.]

5.4.3. The permittee shall maintain monthly hours o f operation for the major processing operations at the facility. Such records shall be retained on-site by the perm ittee for at least five (5) years and shall be cert ified and made available to the Director or his duly authorized re presentative 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 provis ions of 40 C.F.R. Part 60 shall furnish the Adminis trator written notification or, if acceptable to both the Administ rator and the owner or operator of a source, electr onic notification, as follows:

(1) A notification of the date construction (or re construction 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 init ial 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 st artup 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 Protectio n • Division of Air Quality Approved: January 4, 2006 [45CSR16, 40 C.F.R. § 60.7 (a) (1), (2), (3), 45CSR 14, 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 pr oduce and maintain records, which shall include, but are not limited to:

a. The emissions, in pounds of NO X per ton of clinker produced from each affected Por tland cement kiln;

b. The type of control used for each affected Portl and cement kiln;

c. The date, time and duration of any startup, shut down 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 maintaine d shall be retained on site for a minimum of 2 year s and be made available to the Secretary or Administr ator 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 so urce(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 mo nitoring data as established in a monitoring plan pursuant t o 45CSR§10-8.2.c. Such records shall be made avail able to the Director or his duly authorized representative upon request. Such records shall be retained on-si te for a minimum of five years. [45CSR§10-8.3.a, Kiln #7 (EP10.01), 45CSR14, R14-02 6A, 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 record s 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-sit e and made available to the Director or his duly au thorized representative upon request. [45CSR§10-8.3.c, Kiln #7 (EP10.01), 45CSR14, R14-02 6A, 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 Protectio n • 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 facili ty shall submit written reports of the results of a ll performance tests conducted to demonstrate compliance with the standa rds 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 oper ator subject to the requirements of Section 5.1.32 (45CSR§1- 100.3.) shall comply with the following requiremen ts:

b. Submit a report documenting for that kiln the total NO X emissions from May 1 through September 30 of each year to the Secretary and Administrator by Oct ober 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 periodi c exception report to the Director, in a manner spe cified by the Director. Such an exception report shall provide d etails of all excursions outside the range of measu red emissions or monitored parameters established in an approved monitoring plan and shall include, but no t be limited to, the time of the excursion, the magnitud e 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 - - - EU5Title V Operating Permit R30-00300006-2006 Page 104 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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. NoneTitle V Operating Permit R30-00300006-2006 Page 105 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • Division of Air Quality Approved: January 4, 2006 

# APPENDIX A

45CSR10 Monitoring Plan for Capitol Cement

 

## No. 7 Kiln

 

## No. 8 Kiln

 

## No. 9 KilnTitle V Operating Permit R30-00300006-2006 Page 106 of 106

ESSROC Cement Corporation  Capitol Cement Corporation

West Virginia Department of Environmental Protectio n • 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 254 02

Phone Number: (304)- 260-1800

Contact Person and Title: Mark A. Andrews, Environ mental 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 coa l and coke, supplemented with scrap tires, as fuel for three rotary cement kilns. The kilns produce ce ment clinker, which is then ground into finished cements and shipped to customers in the mid-Atlanti c 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 applic ation currently on file with the West Virginia Divi sion of Air Quality. The kilns are “ manufacturing proce ss sources “ by definition of 45 CSR 10.2.11. Kilns 7 and 8 vent through a common stack. Number 9 kiln ha s 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 natur al scrubbers for SO2. As part of the clinkering proces s calcium carbonate is converted inside the kiln to lime or CaO. When there is excess oxygen present SO 2 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 bo th 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. De pending 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 s tack testing results verifies the low SO2 emissions from these wet process kilns. The stack test result s 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 Protectio n • 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 28 8

8 March 24, 1994 71.25 47

9 July 13, 1993 91.89 9 7



## Monitoring :

Normal kiln operation requires that excess oxygen b e available for proper combustion and to maintain kiln temperatures. If an oxygen deficiency does occ ur, 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 oxyge n deficiency occurs ( less than 0.25 % ), an alarm sounds and the control room operator makes correcti ons 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 Dire ctor 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 un der 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 o f 2000 ppm and the R13-1674C permit emission rate lim its -- , CCC petitions the Director not to require additional stack testing per 45CSR10A 5.2.c.

(reg10a)