AIR POLLUTION CONTROL DISTRICT OF JEFFERSON COUNTY, KENTUCKY

TITLE V OPERATING PERMIT

Permit No.: 156-97-TV Plant ID: 0060

Effective Date: April 18, 2001 Expiration Date: April 18, 2006

UTM Northing: 4210.10 UTM Easting: 595.80

SIC: 3241 NAICS: 32731 AFS: 00060

Permission is hereby given by the Air Pollution Control District of Jefferson County to operate

equipment located at:

Kosmos Cement Company - Louisville Plant

15301 Dixie Highway

Louisville, Kentucky 40272

in accordance with the permit application on file with the District and under the conditions in the

permit. This permit and the authorization to operate the emission units listed shall expire on midnight

on the expiration date shown above. If a renewal permit is not issued prior to the expiration date,

the owner or operator may continue to operate in accordance with the terms and conditions of this

permit beyond the expiration date, provided that a complete renewal application is submitted to the

District no earlier than eighteen (18) months and no later than one-hundred eighty (180) days prior

to the expiration date.

Applicant for Permit: Kosmos Cement Company

Responsible Official: Stuart Tomlinson

Title of Responsible Official: Plant Manager

Date Application Received: 21 April 1997

Date Application Administratively Complete: 11 June 1997

Date Public Notice Given: 22 October 2000

________________________________ _________________________________

Reviewing Engineer (89) Air Pollution Control Officer
Permit No. 156-97-TV Plant ID 0060

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Table of Contents

Abbreviations and Acronyms ..................................................... 7

Preamble .................................................................... 8

General Conditions ............................................................ 9

Emission Unit U-1 Description: Barge Unloading & Transfer .......................... 16

Applicable Regulations .................................................. 16

Allowable Emissions .................................................... 16

Components ........................................................... 17

Additional Conditions ................................................... 18

Comment ............................................................. 19

Emission Unit U-2 Description: Limestone Handling ................................. 20

Applicable Regulations .................................................. 20

Allowable Emissions .................................................... 20

Components ........................................................... 20

Additional Conditions ................................................... 21

Comment ............................................................. 23

Emission Unit U-3 Description: Raw Material Crushing .............................. 24

Applicable Regulations .................................................. 24

Allowable Emissions .................................................... 24

Components ........................................................... 24

Control Devices .................................................. 24

Additional Conditions ................................................... 25

Comment ............................................................. 27

Emission Unit U-4 Description: Limestone Storage/ Reclaim .......................... 28

Applicable Regulations .................................................. 28

Allowable Emissions .................................................... 28

Components ........................................................... 29

Control Devices .................................................. 29

Additional Conditions ................................................... 30

Comment ............................................................. 32

Emission Unit U-5 Description: Raw material crushing and drying (Clay) ................ 33

Applicable Regulations .................................................. 33

Allowable Emissions .................................................... 33

Components ........................................................... 34

Control Devices .................................................. 35

Additional Conditions ................................................... 36

Comment ............................................................. 38
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-6 Description: Proportioning Silos ................................. 39

Applicable Regulations .................................................. 39

Allowable Emissions .................................................... 39

Components ........................................................... 40

Control Devices .................................................. 40

Additional Conditions ................................................... 41

Comment ............................................................. 42

Emission Unit U-7 Description: Raw Mill "D" ..................................... 43

Applicable Regulations .................................................. 43

Allowable Emissions .................................................... 43

Components ........................................................... 44

Control Devices .................................................. 44

Additional Conditions ................................................... 45

Comment ............................................................. 48

Emission Unit U-8 Description: Raw Mill "A" ...................................... 49

Applicable Regulations .................................................. 49

Allowable Emissions .................................................... 49

Components ........................................................... 50

Control Devices .................................................. 50

Additional Conditions ................................................... 51

Comment ............................................................. 54

Emission Unit U-9 Description: Raw Mill "B" ...................................... 55

Applicable Regulations .................................................. 55

Allowable Emissions .................................................... 55

Components ........................................................... 56

Control Devices .................................................. 56

Additional Conditions ................................................... 57

Comment ............................................................. 60

Emission Unit U-10 Description: Raw Mill "C" ..................................... 61

Applicable Regulations .................................................. 61

Allowable Emissions .................................................... 61

Components ........................................................... 62

Control Devices .................................................. 62

Additional Conditions ................................................... 63

Comment ............................................................. 66

Emission Unit U-11 Description: Blending Silos .................................... 67

Applicable Regulations .................................................. 67

Allowable Emissions .................................................... 67

Components ........................................................... 67

Control Devices .................................................. 68

Additional Conditions ................................................... 69
Permit No. 156-97-TV Plant ID 0060

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Comment ............................................................. 71

Emission Unit U-12 Description: Kiln Feed System .................................. 72

Applicable Regulations .................................................. 72

Allowable Emissions .................................................... 72

Components ........................................................... 73

Control Devices .................................................. 73

Additional Conditions ................................................... 74

Comment ............................................................. 76

Emission Unit U-13 Description: Preheater and Kiln ................................. 77

Applicable Regulations .................................................. 77

Allowable Emissions .................................................... 78

Components ........................................................... 78

Control Devices .................................................. 78

Additional Conditions ................................................... 79

Comment ............................................................. 93

Emission Unit U-14 Description: Bypass System ................................... 94

Applicable Regulations .................................................. 94

Allowable Emissions .................................................... 94

Components ........................................................... 95

Control Devices .................................................. 95

Additional Conditions ................................................... 96

Comment ............................................................. 98

Emission Unit U-15 Description: Insufflation System ................................ 99

Applicable Regulations .................................................. 99

Allowable Emissions .................................................... 99

Components ........................................................... 99

Control Devices ................................................. 100

Additional Conditions .................................................. 101

Comment ............................................................ 103

Emission Unit U-16 Description: Coal Handling System ............................. 104

Applicable Regulations ................................................. 104

Allowable Emissions ................................................... 104

Components .......................................................... 105

Additional Conditions .................................................. 106

Emission Unit U-17 Description: Coal Mill System ................................. 109

Applicable Regulations ................................................. 109

Allowable Emissions ................................................... 109

Components .......................................................... 109

Additional Conditions .................................................. 110
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-18 Description: Clinker Cooler ................................... 112

Applicable Regulations ................................................. 112

Allowable Emissions ................................................... 112

Components .......................................................... 113

Control Devices ................................................. 113

Additional Conditions .................................................. 114

Comment ............................................................ 117

Emission Unit U-19 Description: Clinker Handling / Storage / Reclaim ................. 118

Applicable Regulations ................................................. 118

Allowable Emissions ................................................... 118

Components .......................................................... 119

Control Devices ................................................. 120

Additional Conditions .................................................. 121

Comment ............................................................ 123

Emission Unit U-20 Description: Finish Mill No. 1 ................................. 124

Applicable Regulations ................................................. 124

Allowable Emissions ................................................... 124

Components .......................................................... 125

Control Devices ................................................. 125

Additional Conditions .................................................. 126

Comment ............................................................ 129

Emission Unit U-21 Description: Finish Mill No. 2 ................................. 130

Applicable Regulations ................................................. 130

Allowable Emissions ................................................... 130

Components .......................................................... 131

Control Devices ................................................. 131

Additional Conditions .................................................. 132

Comment ............................................................ 134

Emission Unit U-22 Description: Finish Mill No. 3 for Kosmortar Mixing ............... 135

Applicable Regulations ................................................. 135

Allowable Emissions ................................................... 135

Components .......................................................... 136

Control Devices ................................................. 136

Additional Conditions .................................................. 137

Comment ............................................................ 139

Emission Unit U-23 Description: Lime Slurry System ............................... 140

Applicable Regulations ................................................. 140

Allowable Emissions ................................................... 140

Components .......................................................... 140

Control Devices ................................................. 141

Additional Conditions .................................................. 142

Comment ............................................................ 144
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-24 Description: Rail / Barge Loading .............................. 145

Applicable Regulations ................................................. 145

Allowable Emissions ................................................... 145

Components .......................................................... 146

Control Devices ................................................. 146

Additional Conditions .................................................. 148

Comment ............................................................ 150

Emission Unit U-25 Description: Truck Loading ................................... 151

Applicable Regulations ................................................. 151

Allowable Emissions ................................................... 151

Components .......................................................... 152

Control Devices ................................................. 152

Additional Conditions .................................................. 155

Comment ............................................................ 155

Emission Unit U-26 Description: Storage Silos (13 - 17) & Packaging .................. 156

Applicable Regulations ................................................. 156

Allowable Emissions ................................................... 156

Components .......................................................... 157

Control Devices ................................................. 158

Additional Conditions .................................................. 159

Comment ............................................................ 161

Emission Unit U-29 Description: Gasoline Dispensing Facility ........................ 162

Applicable Regulations ................................................. 162

Allowable Emissions ................................................... 162

Components .......................................................... 162

Additional Conditions .................................................. 163

Emission Unit U-30 Description: Non-halogenated Cold Solvent Metal Cleaners .......... 164

Applicable Regulations ................................................. 164

Allowable Emissions ................................................... 164

Components .......................................................... 164

Additional Conditions .................................................. 165

NOx RACT Plan ............................................................. 168

Appendix A to NOx RACT Plan .......................................... 170

NOx RACT Plan Appendix B ............................................ 174

PERMIT SHIELD ........................................................... 187

OFF-PERMIT DOCUMENTS ................................................. 187

ALTERNATIVE OPERATING SCENARIO .................................... .187

INSIGNIFICANT ACTIVITIES ................................................ 187
Permit No. 156-97-TV Plant ID 0060

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Abbreviations and Acronyms

AC - Additional Condition

AFS - AIRS Facility Subsystem

AIRS - Aerometric Information Retrieval System

APCD - Air Pollution Control District

ASL - Adjusted Significant Level

atm - Atmosphere

BACT - Best Available Control Technology

Btu - British Thermal Unit

EC - Degrees Centigrade

CEMS - Continuous Emission Monitoring System

CAAA - Clean Air Act Amendments (15 November 1990)

cf - Cubic foot

DOE - District Only Enforceable

EF - Degrees Fahrenheit

gal - Gallon

HAP - Hazardous Air Pollutant

Hg - Mercury

hr - hour

lbs - Pounds 

l - Liter

MACT - Maximum Achievable Control Technology

m - Meter

mg - Milligram

mm - Millimeter

MM - Million

MOCS - Management of Change System

NAICS - North American Industry Classification System

NSR - New Source Review

NO - Nitrogen oxides x

NSPS - New Source Performance Standards

PM - Particulate Matter

PM - Particulate matter less than 10 microns 10

ppm - Parts per million

PSD - Prevention of Significant Deterioration

PMP - Preventive Maintenance Plan

psia - Pounds per square inch absolute

RACT - Reasonably Available Control Technology

SIC - Standard Industrial Classification

SIP - State Implementation Plan

SO2- Sulfur dioxide

TAL - Threshold Ambient Limit

TAP - Toxic Air Pollutant

tpy - Tons per year

VOC - Volatile Organic Compound

UTM - Universal Transverse Mercator
Permit No. 156-97-TV Plant ID 0060

10 August 2000 8

Preamble

Title V of the Clean Air Act Amendments of 1990 required EPA to create an operating permit

program for implementation by state or local air permitting authorities. The purposes of this program

are (1) to require an affected company to assume full responsibility for demonstrating compliance

with applicable regulations; (2) to capture all of the regulatory information pertaining to an affected

company in a single document; and (3) to make permits more consistent with each other.

A company is subject to the Title V program if it meets any of several criteria related to the nature

or amount of its emissions. The Title V operating permit specifies what the affected company is, how

it may operate, what its applicable regulations are, how it will demonstrate compliance, and what is

required if compliance is not achieved. In Jefferson County, Kentucky, the Air Pollution Control

District (APCDJC) is responsible for issuing Title V permits to affected companies and enforcing

local regulations and delegated federal and state regulations. EPA may enforce federal regulations

but not "District Only Enforceable Regulations".

Title V offers the public an opportunity to review and comment on a company's draft permit. It is

intended to help the public understand the company's compliance responsibility under the Clean Air

Act. Additionally, the Title V process provides a mechanism to incorporate new applicable

requirements. Such requirements are available to the public for review and comment before they are

adopted.

Title V Permit general conditions define requirements which are generally applicable to all Title V

companies under the jurisdiction of APCDJC. This avoids repeating these requirements in every

section of the company's Title V permit. Company-specific conditions augment the general

conditions as necessary; these appear in the sections of the permit addressing individual emission units

or emission points.

The general conditions include references to regulatory requirements that may not currently apply to

the company, but which provide guidance for potential changes at the company or in the regulations

during the life of the permit. Such requirements may become applicable if the company makes certain

modifications or a new applicable requirement is adopted.

When the applicability of a section or subpart of a regulation is unclear, a clarifying citation will be

made in the company's Title V permit at the emission unit/point level. Comments may also be added

at the emission unit/point level to give further clarification or explanation.

The source's Title V permit may include a list of "insignificant activities," which are activities or

processes falling into the general categories defined in Regulation 2.02, Section 2, and not associated

with a specific operation or process for which there is a specific regulation. Activities so identified

may be insignificant with regard to application disclosure requirements but may still have generally

applicable requirements that continue to apply and must be included in the Title V operating permit.

No periodic monitoring shall be required for facilities designated as insignificant activities.
Permit No. 156-97-TV Plant ID 0060

10 August 2000 9

General Conditions

1. Compliance - The owner or operator shall comply with all applicable requirements and with

all terms and conditions of this permit. Any noncompliance shall constitute a violation of the

Act, State and District regulations and shall cause the source to be subject to enforcement

actions including, but not limited to, the termination, revocation and reissuance, or revision

of this permit, or denial of a permit application to renew this permit. Notwithstanding any

other provision in the Jefferson County portion of the Kentucky SIP approved by EPA, any

credible evidence may be used for the purpose of establishing whether the owner or operator

is in compliance with, has violated, or is in violation of any such plan. (Regulation 2.16,

sections 4.1.3, 4.1.13.1 and 4.1.13.7)

2. Compliance Certification - The owner or operator shall certify, annually or more frequently

if required in applicable regulations, compliance with the terms and conditions contained in

this permit, including emission limitations, standards, or work practices. This certification

shall meet the requirements of Regulation 2.16, sections 3.5.11 and 4.3.5. The owner or

operator shall submit the annual compliance certification directly to the following address as

well as to the District, as set forth in Regulation 2.16, section 4.3.5.4: 

US EPA - Region IV

Air Enforcement Branch

Atlanta Federal Center

61 Forsyth Street

Atlanta, GA 30303-8960

3. Compliance Schedule - A compliance schedule must meet the requirements of Regulation

2.16, section 3.5.9.5. The owner or operator shall submit a schedule of compliance for each

emission unit that is not in compliance with all applicable requirements. A schedule of

compliance shall be supplemental to, and shall not condone noncompliance with, the

applicable requirements on which it is based. For each schedule of compliance, the owner or

operator shall submit certified progress reports at least semi-annually, or at a more frequent

period if specified in an applicable requirement or by the District in accordance with

Regulation 2.16 section 4.3.4. The progress reports shall contain: 

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

of compliance, and dates when activities, milestones, or compliance were achieved.

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

met, and preventive or corrective measures adopted.

4. Duty to Supplement or Correct Application - If the owner or operator fails to submit

relevant facts or has submitted incorrect information in the permit application, it shall, upon

discovery of the occurrence, promptly submit the supplementary facts or corrected

information in accordance with Regulation 2.16, section 3.4.
Permit No. 156-97-TV Plant ID 0060

10 August 2000 10

5. Emergency Provision

a. An emergency shall constitute an affirmative defense to an enforcement action

brought for noncompliance with technology-based emission limitations. The

affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs, or other relevant evidence that: 

i. An emergency occurred and that the owner or operator can identify the cause

of the emergency.

ii. The permitted facility was at the time being properly operated.

iii. During the period of the emergency the owner or operator expeditiously took

all reasonable steps, consistent with safe operating practices, to minimize

levels of emissions that exceeded the emission standards or other requirements

in this permit.

iv. The owner or operator submitted notice meeting the requirements of

Regulation 1.07 of the time when emissions limitations were exceeded

because of the emergency. This notice must fulfill the requirement of this

condition, and must contain a description of the emergency, any steps taken

to mitigate emissions, and any corrective actions taken.

b. In an enforcement proceeding, the owner or operator seeking to establish the

occurrence of an emergency has the burden of proof.

c. This condition is in addition to any emergency or upset provision contained in an

applicable requirement.

(Regulation 2.16, sections 4.7.1 through 4.7.4)

6. Emission Fees Payment Requirements - The owner or operator shall pay annual emission

fees in accordance with Regulation 2.08. Failure to pay the emissions fees when due shall

constitute a violation of District Regulations. Such failure is subject to penalties and an

increase in the fee of an additional 5% per month up to a maximum of 25% of the original

amount due. In addition, failure to pay emissions fees within 60 days of the due date shall

automatically suspend this permit to operate until the fee is paid or a schedule for payment

acceptable to the District has been established. (Regulation 2.08, section 1.3)

7. Emission Offset Requirements - The owner or operator shall comply with the requirements

of Regulation 2.04.

8. Enforceability Requirements - Except for the conditions that are specifically designated as

“District Only Enforceable Conditions”, all terms and conditions of this permit, including any

provisions designed to limit a source's potential to emit, are enforceable by EPA and citizens

as specified under the Act. (Regulation 2.16, sections 4.2.1 and 4.2.2)
Permit No. 156-97-TV Plant ID 0060

10 August 2000 11

9. Enforcement Action Defense

a. It shall not be a defense for the owner or operator in an enforcement action that it

would have been necessary for the owner or operator to halt or reduce the permitted

activity in order to maintain compliance with the conditions of this permit.

b. The owner or operator's failure to halt or reduce activity may be a mitigating factor

in assessing penalties for noncompliance if the health, safety or environmental impacts

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

operation.

(Regulation 2.16, sections 4.1.13.2 and 4.1.13.3)

10. Hazardous Air Pollutants and Sources Categories - The owner or operator shall comply

with the applicable requirements of Regulations 5.02 and 5.14.

11. Information Requests - The owner or operator shall furnish to the District, within a

reasonable time, information requested in writing by the District, to determine whether cause

exists for revising, revoking and reissuing, or terminating this permit, or to determine

compliance with this permit. The owner or operator shall also furnish, upon request, copies

of records required to be kept by this permit. (Regulation 2.16, section 4.1.13.6) If

information is submitted to the District under a claim of confidentiality, the source shall

submit a copy ofthe confidential information directly to EPA. (Regulation 2.07, section 10.2)

12. Insignificant Activities - The owner or operator shall notify the District in a timely manner

of any proposed change to an insignificant activity that would require a permit revision.

(Regulation 2.16, section 5)

13. Inspection and Entry - Upon presentation of credentials and other documents as required

by law, the owner or operator shall allow the District or an authorized representative to

perform the following during reasonable hours: 

a. Enter the premises to inspect any emissions-related activity or records required in this

permit.

b. Have access to and copy records required by this permit.

c. Inspect facilities, equipment (including monitoring and air pollution control

equipment), practices, or operations regulated or required by this permit.

d. Sample or monitor substances or parameters to assure compliance with this permit or

any applicable requirements.

(Regulation 2.16, section 4.3.2)

14. Monitoring and Related Record keeping and Reporting Requirements - The owner or

operator shall comply with the requirements of Regulation 2.16, section 4.1.9. The owner

or operator shall submit all required monitoring reports at least once every six months, unless
Permit No. 156-97-TV Plant ID 0060

10 August 2000 12

more frequent reporting is required by an applicable requirement. The reporting period shall

be January 1st through June 30th and July 1st through December 31st of each calendar year.

All reports shall be postmarked by the 60th day following the end of each reporting period.

If surrogate operating parameters are monitored and recorded in lieu of emission monitoring,

then an exceedance of multiple parameters may be deemed a single violation by the District

for enforcement purposes.

15. Off-permit Documents - Any applicable requirements, including emission limitations, control

technology requirements, or work practice standards, contained in an off-permit document

cannot be changed without undergoing the permit revision procedures in Regulation 2.16,

Section 5. (Regulation 2.16, section 4.1.5)

16. Operational Flexibility - The owner or operator may make changes without permit revision

in accordance with Regulation 2.16, section 5.8.

17. Permit Amendments (Administrative) - This permit can be administratively amended by

the District in accordance with Regulation 2.16, sections 2.3 and 5.4.

18. Permit Application Submittal - The owner or operator shall submit a timely and complete

application for permit renewal or significant revision. If the owner or operator submits a

timely and complete application then the owner or operator's failure to have a permit is not

a violation until the District takes formal action on this permit application. This protection

shall cease to apply if, subsequent to completeness determination, the owner or operator fails

to submit, by the deadline specified in writing by the District, additional information required

to process the application as required by Regulation 2.16, sections 3 and 5.2.

19. Permit Duration - This permit is issued for a fixed term of 5 years, in accordance with

Regulation 2.16, section 4.1.8.3.

20. Permit Renewal, Expiration and Application - Permit renewal, expiration and application

procedural requirements shall be in accordance with Regulation 2.16,sections 4.1.8.2 and 5.3.

This permit may only be renewed in accordance with section 5.3.

21. Permit Revisions - No permit revision shall be required under any approved economic

incentives, marketable permits, emissions trading and other similar programs or processes for

changes that are provided for in the permit. (Regulation 2.16, section 4.1.16)

22. Permit Revision Procedures (Minor) - Except as provided in 40 CFR Part 72, the Acid

Rain Program, this permit may be revised in accordance with Regulation 2.16, section 5.5.

23. Permit Revision Procedures (Significant) - A source seeking to make a significant permit

revision shall meet all the Title V requirements for permit applications, issuance and renewal,

in accordance with Regulation 2.16, section 5.7, and all other applicable District Regulations.

24. Permit Revocation and Termination by the District - The District may terminate this

permit only upon written request of the owner or operator. The District may revoke a permit
Permit No. 156-97-TV Plant ID 0060

10 August 2000 13

for cause, in accordance with Regulation 2.16, section 5.11.1.1 through 5.11.1.5. For

purposes of Section 5, substantial or unresolved noncompliance includes, but is not limited

to: 

a. Knowingly operating process or air pollution control equipment in a manner not

allowed by an applicable requirement or that results in excess emissions of a regulated

air pollutant that would endanger the public or the environment.

b. Failure or neglect to furnish information, analyses, plans, or specifications required

by the District.

c. Knowingly making any false statement in any permit application.

d. Noncompliance with Regulation 1.07, section 4.2; or

e. Noncompliance with KRS Chapter 77.

25. Permit Shield - The permit shield shall apply in accordance with Regulation 2.16, section

4.6.1.

26. Prevention of Significant Deterioration of Air Quality - The owner or operator shall

comply with the requirements of Regulation 2.05.

27. Property Rights - This permit shall not convey property rights of any sort or grant exclusive

privileges in accordance with Regulation 2.16, section 4.1.13.5.

28. Public Participation - Except for modifications qualifying for administrative permit

amendments or minor permit revision procedures, all permit proceedings shall meet the

requirements of Regulations 2.07, Section 1; and 2.16, sections 5.1.1.2 and 5.5.4.

29. Reopening For Cause - This permit shall be reopened and revised by the District in

accordance with Regulation 2.16 section 5.9.

30. Reopening for Cause by EPA - This permit may be revised, revoked and reissued or

terminated for cause by EPA in accordance with Regulation 2.16 section 5.10.

31. Risk Management Plan (112(r)) - For each process subject to Section 112(r) of the Act,

the owner or operator shall comply with 40 CFR Part 68 and Regulation 5.15.

32. Severability Clause - The conditions of this permit are severable. Therefore, if any condition

of this permit, or the application of any condition of this permit to any specific circumstance,

is determined to be invalid, the application of the condition in question to other

circumstances, as well as the remainder of this permit's conditions, shall not be affected.

(Regulation 2.16, section 4.1.12)

33. Stack Height Considerations - The owner or operator shall comply with the requirements

of Regulation 2.10.
Permit No. 156-97-TV Plant ID 0060

10 August 2000 14

34. Startups, Shutdowns, and Malfunctions Requirements - The owner or operator shall

comply with the requirements of Regulation 1.07.

35. Submittal of Reports, Data, Notifications, and Applications

a. Applications, reports, test data, monitoring data, compliance certifications, and any

other document required by this permit as set forth in Regulation 2.16 sections 3.1,

3.4, 3.5, 4.1.13.6, 5.8.5 and 5.11.7 shall be submitted to: 

Air Pollution Control District of Jefferson County

850 Barret Ave

Louisville, KY 40204-1745

b. Documents which are specifically required to be submitted to EPA as set forth in

Regulation 2.16 sections 3.3, and 5.8.5 shall be mailed to EPA at the following

address: 

US EPA - Region IV

APTMD - 12th floor

Atlanta Federal Center

61 Forsyth Street

Atlanta, GA 30303-3104

36. Other Applicable Regulations - The owner or operator shall comply with all applicable

requirements of the following regulations: 

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title

1.01 General Application of Regulations and Standards

1.02 Definitions

1.03 Abbreviations and Acronyms

1.04 Performance Tests

1.05 Compliance with Emission Standards and Maintenance Requirements

1.06 Source Self-Monitoring and Reporting

1.07 Emissions During Startups, Shutdowns, Malfunctions, and Emergencies

1.08 Administrative Procedures

1.09 Prohibition of Air Pollution

1.10 Circumvention

1.11 Control of Open Burning

1.14 Control of Fugitive Particulate Emissions

2.01 General Application
Permit No. 156-97-TV Plant ID 0060

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title

10 August 2000 15

2.02 Air Pollution Regulation Requirements and Exemptions

2.03 Permit Requirements - Non-Title V Construction and Operating Permits and

Demolition/Renovation Permits

2.07 Public Notification for Title V, PSD, and Offset Permits; SIP Revisions; and Use of Emission

Reduction Credits

2.09 Causes for Permit Suspension

2.10 Stack Height Considerations

2.11 Air Quality Model Usage

2.16 Title V Operating Permits

4.01 General Provisions for Emergency Episodes

4.02 Episode Criteria

4.03 General Abatement Requirements

4.07 Episode Reporting Requirements

5.01 General Provisions (for Hazardous Air Pollutants)

5.03 Potential Hazardous Emissions

6.01 General Provisions (for Existing Affected Facilities)

6.02 Emission Monitoring for Existing Sources

7.01 General Provisions (for New Affected Facilities)

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title

1.12 Control of Nuisances

1.13 Control of Objectionable Odors in the Ambient Air

2.08 Emissions Fees, Permit Fees, Permit Renewal Procedures, and Additional Program Fees

8.03 Commuter Vehicle Testing Requirements

Emission Unit U-1 Description: Barge Unloading & Transfer (limestone transfer from barge to

conveying systems)

Applicable Regulations:
Permit No. 156-97-TV Plant ID 0060

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FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

6.09 Standards of Performance for Existing 1.2

Process Operations

40 CFR 60 Standards of Performance for Nonmetallic Sections: 60.670, 60.671,

Subpart mineral Processing Plants 60.672, 60.675

OOO

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

7.02 Federal New Source Performance Sections: 1.72, 2, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity 10% (40 CFR 60.672(b))

Components:
Permit No. 156-97-TV Plant ID 0060

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Emission Point Description Control ID

E-1 Unloading hopper (K-100) fugitive emissions, no control

E-2 Conveyor Belt (K-101) fugitive emissions, no control

E-3 Conveyor Belt (K-102) fugitive emissions, no control

E-4 Conveyor Belt (K-103) fugitive emissions, no control

E-5 Conveyor Belt (K-104) fugitive emissions, no control

E-6 Conveyor Belt (K-137) fugitive emissions, no control

E-8 Conveyor Belt (K-140) fugitive emissions, no control

E-9 Conveyor Belt (K-148) fugitive emissions, no control

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (40 CFR 60, Subpart OOO)

Opacity

The owner or operator shall not allow or cause the opacity from this emission unit to exceed

10%; (40 CFR 60.672 (b)) 

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. To demonstrate compliance with the opacity standard, the owner or operator shall

conduct a daily one-minute visible emissions survey, during normal operation and

daylight hours, of the PM emission points identified as E-2 through E-6, E-8 and E-9.

No more than four Emission Points shall be observed simultaneously.

b. For Emission Points without observed visible emissions during twelve consecutive

operating weeks, the owner or operator may elect to conduct a weekly one-minute

visible emission survey, during normal operation and daylight hours. No more than

four Emission Points shall be observed simultaneously.

c. For Emission Points without observed visible emissions during twelve consecutive

operating weeks as per 2.b, the owner or operator may elect to conduct a monthly

one-minute visible emission survey, during normal operation and daylight hours. No

more than four Emission Points shall be observed simultaneously.

d. At Emission Points where visible emissions are observed, the owner or operator shall

initiate corrective action within eight hours of the initial observation. If the visible

emissions persist, the owner or operator shall perform or cause to be performed a

Method 9 for stack emissions or Method 22 for fugitive emissions within 24 hours of

the initial observation. If the opacity standard is exceeded, the owner or operator

shall report the exceedance to the District, pursuant to Regulation 1.07, and take all

practicable steps to eliminate the exceedance. Subsequent visible emission surveys

shall be conducted as indicated in 2.a.

d. No visible emission survey needs to be performed if an Emission Point is not being

operated during a given day, week or month (as appropriate).

3. Record Keeping (Regulation 2.16, section 4.1.9.2)
Permit No. 156-97-TV Plant ID 0060

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Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3)

Opacity

The owner or operator shall include, at a minimum, the following information in the semiannual compliance monitoring reports for opacity:

a. Emission Unit ID number and Emission Point ID number or Stack ID number

b. The beginning and ending date of the reporting period

c. The date, time, and result of each Method 22 conducted (or a negative declaration if

none)

d. Description of any corrective action taken pursuant to Additional Condition 2.c.

Comment

Emission Point E-1, does not qualify as a regulated facility under 40 CFR 60, Subpart OOO. It is not

a storage bin. Because of the date of installation, it would be regulated by 6.09, however, there is

no control device or stack associated with this emission point, therefore it is exempt from all

emissions standards. Emission Point E-1 is not subject to monitoring, recordkeeping or reporting

requirements. However, it is incumbent upon the owner or operator to assure compliance of this

emission point with nuisance regulation 1.14 as stated in Regulation 6.09, section 1.2.

Emission Unit U-2 Description: Limestone Handling (screening and transfer) 

 
Permit No. 156-97-TV Plant ID 0060

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Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Nonmetallic Sections: 60.670, 60.671,

Subpart Mineral Processing Plants 60.672, 60.675

OOO

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

7.02 Federal New Source Performance Sections: 1.72, 2, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity 10% (40 CFR 60.672(b))

Opacity 7% (40 CFR 60.672(a)(2))

PM 0.05 g/dscm (40 CFR 60.672(a)(1))

Components:

Emission Point Description Control ID

E-11 Feeder fugitive emissions, no control

E-12 Conveyor Belt (K-149) baghouse C-1 (K-162)

E-13 screens (K-151 & K-152) baghouse C-1 (K-162)

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (40 CFR 60, Subpart OOO)

a. Opacity

i. The owner or operator shall not allow or cause the opacity from this emission

unit to exceed 10%; ( 40 CFR 60.672 (b) for E-11) 

ii. The owner or operator shall not allow the discharge of visible emissions to

exceed 7%; ( 40 CFR 60.672 (a)(2) for E-12 and E-13 at the C-1 baghouse

stack S-1)

b. PM

The owner or operator shall not cause to be discharged into the atmosphere, any stack

emissions which contain particulate matter in excess of 0.05 g/dscm. (40 CFR

60.672(a)(1))

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. To demonstrate compliance with the opacity standard, the owner or operator

shall conduct a daily one-minute visible emissions survey, during normal

operation and daylight hours, of the PM emission points identified as E-12 and

E-13. No more than four Emission Points shall be observed simultaneously.

ii. For Emission Points without observed visible emissions during twelve

consecutive operating weeks, the owner or operator may elect to conduct a

weekly one-minute visible emission survey, during normal operation and

daylight hours. No more than four Emission Points shall be observed

simultaneously.

iii.. For Emission Points without observed visible emissions during twelve

consecutive operating weeks as per 2.a.ii, the owner or operator may elect to

conduct a monthly one-minute visible emission survey, during normal

operation and daylight hours. No more than four Emission Points shall be

observed simultaneously.

iv. At Emission Points where visible emissions are observed, the owner or

operator shall initiate corrective action within eight hours of the initial

observation. If the visible emissions persist, the owner or operator shall

perform or cause to be performed a Method 9 for stack emissions or Method

22 for fugitive emissions within 24 hours of the initial observation. If the

opacity standard is exceeded, the owner or operator shall report the

exceedance to the District, pursuant to Regulation 1.07, and take all
Permit No. 156-97-TV Plant ID 0060

22

practicable steps to eliminate the exceedance. Subsequent visible emission

surveys shall be conducted as indicated in 2.a.i.

iv. No visible emission survey needs to be performed if an Emission Point is not

being operated during a given day, week or month (as appropriate).

b. PM

Monitoring requirements for Control Device C-1 are specified in Emission Unit U-3,

additional condition 2.b.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. PM

Recordkeeping requirements, see Emission Unit U-3, additional condition 3.b.

4. Reporting (Regulation 2.16, section. 4.1.9.3)

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)
Permit No. 156-97-TV Plant ID 0060

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iv. Description of any corrective action taken pursuant to Additional Condition

2.a.iii.

b. PM

Compliance reporting requirements, see Emission Unit U-3, additional condition 4.b

Comment

Applicability of 40 CFR 60, Subpart F and 40 CFR 60, Subpart OOO is based on the EPA guidance

memo dated 12 June 1995.

Emission Unit U-3 Description: Raw Material Crushing
Permit No. 156-97-TV Plant ID 0060

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Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Sections: 60.670, 60.671,

Subpart OOO Nonmetallic Mineral Processing Plants 60.672, 60.675

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

7.02 Federal New Source Performance Sections: 1.72, 2, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity 7% (40 CFR 60.672(a)(2))

PM 0.05 g/dscm (40 CFR 60.672(a)(1))

Components:

Emission Point Description Control ID

E-14 Secondary Crusher (K-156) baghouse C-1 (K-162)

E-15 Belt Conveyor (K-157) baghouse C-1 (K-162)

E-16 Belt Conveyor (K-159) baghouse C-1 (K-162)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-1 S-1 Bag House See AC 2.a & N/A See AC 2.a & semi-

(K-162) 2.b 2.b annual

Additional Conditions

1. Standards (Regulation 2.16, section 4.1.1)
Permit No. 156-97-TV Plant ID 0060

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a. Opacity

The owner or operator shall not allow the discharge of visible emissions to exceed

7%; (40 CFR 60.672 (a)(2) for E-14, E-15 and E-16 at the C-1 baghouse stack S-1)

b. PM

The owner or operator shall not cause to be discharged into the atmosphere, any stack

emissions which contain particulate matter in excess of 0.05 g/dscm. (40 CFR 60.672

(a)(1)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. To demonstrate compliance with the opacity standard, the owner or operator

shall conduct a daily one-minute visible emissions survey, during normal

operation and daylight hours, of the PM emission points E-14, E-15 and E-16

and stack S-1. No more than four Emission Points shall be observed

simultaneously.

ii. For Emission Points without observed visible emissions during twelve

consecutive operating weeks, the owner or operator may elect to conduct a

weekly one-minute visible emission survey, during normal operation and

daylight hours. No more than four Emission Points shall be observed

simultaneously.

iii. For Emission Points without observed visible emissions during twelve

consecutive operating weeks as per 2.a.ii, the owner or operator may elect to

conduct a monthly one-minute visible emission survey, during normal

operation and daylight hours. No more than four Emission Points shall be

observed simultaneously.

iv. At Emission Points where visible emissions are observed, the owner or

operator shall initiate corrective action within eight hours of the initial

observation. If the visible emissions persist, the owner or operator shall

perform or cause to be performed a Method 9 for stack emissions or Method

22 for fugitive emissions within 24 hours of the initial observation. If the

opacity standard is exceeded, the owner or operator shall report the

exceedance to the District, pursuant to Regulation 1.07, and take all

practicable steps to eliminate the exceedance. Subsequent visible emission

surveys shall be conducted as indicated in 2.a.i.

iv. No visible emission survey needs to be performed if an Emission Point is not

being operated during a given day, week or month (as appropriate).
Permit No. 156-97-TV Plant ID 0060

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b. PM

The owner or operator shall inspect C-1 baghouse for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collector for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. PM

The owner or operator shall maintain records of all inspections and maintenance

performed for C-1 baghouse. These records shall include:

i. results of all inspections

ii. the date and time of each inspection

iii. the name of the person conducting the inspection
Permit No. 156-97-TV Plant ID 0060

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iv. any repairs or maintenance performed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.iii.

b. PM

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for PM:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. Description of any corrective action taken pursuant to Additional Condition

3.b.iv.

Comment

Applicability of 40 CFR 60, Subpart F and 40 CFR 60, Subpart OOO is based on the EPA guidance

memo dated 12 June 1995.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-4 Description: Limestone Storage/ Reclaim

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c))

Components:
Permit No. 156-97-TV Plant ID 0060

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Emission Point Description Control ID

E-17 Six Weigh Feeders (K-307 fugitive emissions, no control

thru K-312)

E-18 Belt Conveyor (K-313) fugitive emissions, no control

E-19 Bin (K-314) baghouse C-2 (K-332)

E-20 Feeder (K-320) baghouse C-2 (K-332)

E-21 3 Existing Raw Feed baghouse C-3 (K-401-2)

Weigh Feeders

E-22 3 Existing Raw Feed baghouse C-4 (K-401-4)

Weigh Feeders

E-23 Belt Conveyor (K-401) baghouse C-5 (K-402)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-2 S-2 Baghouse See AC 2 N/A See AC 2 semiannual

C-3 S-3 Baghouse See AC 2 N/A See AC 2 semiannual

C-4 S-4 Baghouse See AC 2 N/A See AC 2 semiannual

C-5 S-5 Baghouse See AC 2 N/A See AC 2 semiannual

 

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-2,

C-3, C-4 and C-5 to equal or exceed 10%. The owner or operator shall not allow

or cause the fugitive emissions from Emission Points E-17 and E-18 to equal or

exceed 10% opacity. (40 CFR 60.62 (c))

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-17 through E-23 in accordance with 40 CFR 60,

Appendix A, Method 22. The test must be conducted while the emission unit

is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-2 , C-3, C-4 and C-5 baghouses for the

following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks
Permit No. 156-97-TV Plant ID 0060

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iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.d.

Comment
Permit No. 156-97-TV Plant ID 0060

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With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-5 Description: Raw material crushing and drying (Clay)

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 60 Standards of Performance for Sections: 60.670, 60.671,

Subpart OOO Nonmetallic Mineral Processing Plants 60.672, 60.675

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.09 Standards of Performance for Existing 1.2

Process Operations

6.10 Standard of Performance for Existing Sections: 1, 2, 4, 6.2

Process Gas Streams

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c))

SO 2000 ppm by volume at 0% oxygen (Regulation 6.10, Section 4) 2

Components:
Permit No. 156-97-TV Plant ID 0060

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Emission Point Description Control ID

E-24 Hopper (K-201) fugitive emissions, no control

E-25 Feeder (K-202) fugitive emissions, no control

E-26 Belt conveyor (K-209) baghouse C-6 (K-239)

E-27 Crusher (K-203) baghouse C-6 (K-239)

E-28 Belt Conveyor (K-204) baghouse C-6 (K-239)

E-29 Belt Conveyor (K-205) baghouse C-6 (K-239)

E-30 Dryer (K-206) 65 MM Btu Baghouses C-7 & C-8 (K-216

direct fired furnace and K-231)

E-31 Elevator (K-207) fugitive emissions, no control

E-32 Screen (K-210) Baghouse C-6 (K-239)

E-33 Elevator (K-213) fugitive emissions, no control

E-34 Clay Silo (K-317) Baghouse C-9 (K-334)

E-35 Clay Silo (K-315) Baghouse C-9 (K-334)

E-36 Clay Silo (K-316) Baghouse C-9 (K-334)

E-37 Raw Material Silo (K-318) Baghouse C-9 (K-334)

E-38 Dust Silo (K-319) baghouse C-10 (K-335)

Control Devices:
Permit No. 156-97-TV Plant ID 0060

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ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-6 S-6 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-7 S-7 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-8 S-7 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-9 S-8 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-10 S-9 Baghouse See AC 2.a N/A See AC 2.a semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-2,

C-6, C-7, C-8, C-9 and C-10 to equal or exceed 10%. The owner or operator shall

not allow or cause the fugitive emissions from Emission Points E-25, E-31 and E-33

to equal or exceed 10% opacity. (40 CFR 60.62 (c))

b. SO2

The owner or operator shall not allow or cause the emissions of SO2 from Emission

Point E-30 to exceed 2000 ppm by volume at O% oxygen. (Regulation 6.10, Section

4)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-25 through E-38 in accordance with 40 CFR 60,

Appendix A, Method 22. The test must be conducted while the emission unit

is in operation.

ii. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

iii. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain 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 shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

v. The owner or operator shall inspect C-6 , C-7, C-8, C-9 and C-10 baghouses

for the following items:

A) Verify fan is running and belts are on, daily.
Permit No. 156-97-TV Plant ID 0060

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B) Verify dampers are working properly daily.

C) Verify cleaning mechanism is working properly every two weeks

D) Replace all worn bags as needed.

E) Verify bags are clean and not filled with dust every two weeks

F) Verify dust removal system is working properly every two weeks, and

G) Inspect area around collectors for signs of dust every two weeks.

b. SO2

i. The owner or operator shall combust fuel oil with a sulfur content no more

than 0.5% by weight.

ii. The owner or operator shall comply with Additional Condition 2.f) for

Emission Unit U-13, when combusting “On-Spec”, “Off-Spec” and waste oils.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. SO2

The owner or operator shall maintain records of:

i. When and for what duration were fuels other than natural gas combusted in

the unit.

ii. Fuel oil vendor certification that the fuel oil meets the 0.5% by weight sulfur

content.
Permit No. 156-97-TV Plant ID 0060

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iii. Comply with Additional Condition 3.e.i for Emission Unit U-13.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.iv.

b. SO2

i. No compliance reporting is required when the unit combusts natural gas.

ii. No compliance reporting is required when the unit combusts No. 2 fuel

oil.

iii. The owner or operator shall report semi-annually, by exception, when

Additional Condition 2.b was not complied with. If no exceptions, then a

negative declaration shall be supplied in the report.

Comment

1. Emission Point E-24, does not qualify as a regulated facility under 40 CFR 60, Subpart OOO.

It is not a storage bin. Because of the date of installation, it would be regulated by 6.09,

however, there is no control device or stack associated with this emission point, therefore it

is exempt from all emissions standards. Emission Point E-24 is not subject to monitoring,

recordkeeping or reporting requirements. However, it is incumbent upon the owner or

operator to assure compliance of this emission point with nuisance regulation 1.14 as stated

in Regulation 6.09, section 1.2.

2. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-6 Description: Proportioning Silos

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c))
Permit No. 156-97-TV Plant ID 0060

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Components:

Emission Point Description Control ID

E-39 Feeder (K-500) Baghouse C-2 (K-332)

E-40 Feeder (K-329) Baghouse C-2 (K-332)

E-41 Feeder (K-327) Baghouse C-2 (K-332)

E-42 Feeder (K-323) Baghouse C-2 (K-332)

E-43 Feeder (K-325) Baghouse C-2 (K-332)

E-44 Belt Conveyor (K-401) Baghouse C-2 (K-332)

E-45 Belt Conveyor (K-520) Baghouses C-11 (K-522)

E-46 Belt Conveyor (K-521) Baghouses C-11 (K-522)

E-47 Belt Conveyor (K-519) Baghouses C-11 (K-522)

E-48 Hopper Baghouses C-11 (K-522)

E-49 Feeder (K-517) Baghouses C-11 (K-522)

E-50 Elevator (K-518) Baghouses C-11 (K-522)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-2 S-2 Baghouse See AC 2 N/A See AC 2 semiannual

C-11 S-10 Baghouse See AC 2 N/A See AC 2 semiannual
Permit No. 156-97-TV Plant ID 0060

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Additional Conditions

1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-2

 and C-11 to equal or exceed 10%. (40 CFR 60.62 (c))

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-39 through E-50 in accordance with 40 CFR 60,

Appendix A, Method 22. The test must be conducted while the emission unit

is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-2 and C-11 baghouses for the following

items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks
Permit No. 156-97-TV Plant ID 0060

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iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.d.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-7 Description: Raw Mill "D"

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.10 Standard of Performance for Existing Sections: 1, 2, 4, 6.2

Process Gas Streams

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1347)

SO 2000 ppm by volume at 0% oxygen (Regulation 6.10, Section 4) 2
Permit No. 156-97-TV Plant ID 0060

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Components:

Emission Point Description Control ID

E-51 Feeder (K-524) fugitive emissions, no control

E-81 Mill “D” (K-526) Baghouse C-12 and C-13 (K541 and K-545)

E-53 Elevator (K-536) fugitive emissions, no control

E-81 Separator (K-538) Baghouse C-13 (K-545)

E-81 Furnace, 150 MMBtu Baghouse C-13 (K-545)

direct fired furnace (is used

only when kiln is down)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-12 S-11 Cyclone See AC 2.a N/A See AC 2.a semiannual

C-13 S-11 Baghouse See AC 2.a N/A See AC 2.a semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

i. The owner or operator shall not allow or cause the opacity from baghouse C13 to equal or exceed 10%. The owner or operator shall not allow or cause

the fugitive emissions from Emission Points E-51 and E-53 to equal or exceed

10%. (40 CFR 60.62 (c))

ii. The owner or operator shall not allow or cause the opacity from the raw mill

and its baghouse C-13 to equal or exceed 10%. This is applicable only when

the kiln is down and the furnace is used. 

Normal operation of this Emission Unit is that all emissions go through the

kiln and receives heated air from the kiln. (40 CFR 63.1347)

b. SO2

The owner or operator shall not allow or cause the emissions of SO2 from Emission

Point E-30 at stack S-11 to exceed 2000 ppm by volume at 0% oxygen. (Regulation

6.10, Section 4)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. Stack S-11, for Emission point E-81, is subject to the COM requirements in

Emission Unit U-13, additional condition 2.a.v. 

ii. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-51 and E-53 in accordance with 40 CFR 60, Appendix

A, Method 22. The test must be conducted while the emission unit is in

operation.

iii. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

iv. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.
Permit No. 156-97-TV Plant ID 0060

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and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

v. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

vi. The owner or operator shall inspect C-12 and C-13 baghouses for the

following items:

A). Verify fan is running and belts are on, daily.

B) Verify dampers are working properly daily.

C) Verify cleaning mechanism is working properly every two weeks

D) Replace all worn bags as needed.

E) Verify bags are clean and not filled with dust every two weeks

F) Verify dust removal system is working properly every two weeks, and

G). Inspect area around collector for signs of dust every two weeks.

b. SO2

i. The owner or operator shall combust fuel oil with a sulfur content no more

than 0.5% by weight.

ii. The owner or operator shall comply with Additional Condition 2.f) for

Emission Unit U-13, when combusting “On-Spec”, “Off-Spec” and waste oils.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

i. The owner or operator shall, for Stack S-11, maintain records as per

additional condition 3.a.ii for Emission Unit U-13.

ii. The owner or operator shall, for Emission Points E-51 and E-53 maintain

records of:

A. results of all Method 22 and Method 9 tests performed

B. the date and time of the survey
Permit No. 156-97-TV Plant ID 0060

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C. the name of the person conducting the survey or test

D. whether visible emissions were observed

E. a negative declaration may be entered in the record if an Emission

Point is not being operated during a given day, week or month (as

appropriate)

b. SO2

The owner or operator shall maintain records of:

i. Fuel oil vendor certification that the fuel oil meets the 0.5% by weight sulfur

content.

ii. Comply with Additional Condition 3.e.i for Emission Unit U-13.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

i. The owner or operator shall, for Stack S-11, report as per additional

condition 4.ii for Emission Unit U-13.

ii. The owner or operator shall include, at a minimum, the following information

in the semi-annual compliance monitoring reports for opacity:

A. Emission Unit ID number and Emission Point ID number or Stack ID

number

B. The beginning and ending date of the reporting period

C. The date, time, and result of each Method 9 or Method 22 conducted

that exceeded the standard (or a negative declaration if none were

performed)

D. Description of any corrective action taken pursuant to Additional

Condition 2.a.

b. SO2

i. No compliance reporting is required when the unit combusts natural gas.

ii. No compliance reporting is required when the unit combusts No. 2 fuel oil.
Permit No. 156-97-TV Plant ID 0060

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iii. The owner or operator shall report semi-annually, by exception, when

Additional Condition 2.b was not complied with. If no exceptions, then a

negative declaration shall be supplied in the report.

Comment

1. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.

2. Control device C-12 is a set of cyclones that are vented to Baghouse C-13, thus monitoring

is relegated to the vent stack S-11, there is no point of emissions for C-12.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-8 Description: Raw Mill "A"

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.10 Standard of Performance for Existing Sections: 1, 2, 4, 6.2

Process Gas Streams

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c), 40 CFR 63.1347 and 40 CFR 63.1348)

SO 2000 ppm by volume at O% oxygen (Regulation 6.10, Section 4) 2
Permit No. 156-97-TV Plant ID 0060

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Components:

Emission Point Description Control ID

E-56 Feeder (K-407) fugitive emissions, no control

E-57 Elevator (K-408) Baghouse C-14 (K-421)

E-58 Belt Conveyor (K-409) Baghouse C-15 (K-418)

E-59 Separator (K-411) Baghouse C-16 (K-424)

E-60 Mill “A” (K-413) Baghouse C-17 (K-415)

E-59 Furnace, 20 MMBtu direct Baghouse C-16 (K-424)

fired furnace

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-14 S-12 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-15 S-13 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-16 S-14 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-17 S-15 Baghouse See AC 2.a N/A See AC 2.a semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-14,

C-15, C-16 and C-17 to equal or exceed 10%. The owner or operator shall not allow

or cause the fugitive emissions from Emission Point E-56 to equal or exceed 10%.(40

CFR 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348)

b. SO2

The owner or operator shall not allow or cause the emissions of SO2 from Emission

Point E-59 to exceed 2000 ppm by volume at 0% oxygen. (Regulation 6.10, Section

4)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-56 through E-58 in accordance with 40 CFR 60,

Appendix A, Method 22. The test must be conducted while the emission unit

is in operation.

A. If no visible emissions are observed in six consecutive monthly tests,

the owner or operator may decrease the frequency of testing from

monthly to semi-annually for this emission unit. If visible emissions

are observed during any semi-annual test, the owner or operator shall

resume testing on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests.

B. If no visible emissions are observed during two consecutive tests from

this emission unit, the owner or operator may decrease the frequency

of testing from semi-annually to annually. If visible emissions are

observed during any annual test, the owner or operator shall resume

testing on a monthly basis. and maintain that schedule until no visible

emissions are observed in six consecutive monthly tests.

C. If visible emissions are observed during any Method 22 test, the

owner or operator shall conduct a 6-minute test of opacity in

accordance with 40 CFR 60, Appendix A, Method 9. The Method 9

Test must begin within one hour of any observation of visible

emissions.

ii. The owner or operator shall, for Emission Points E-59 and E-60, monitor

opacity by conducting daily visible emissions observations of the mill sweep
Permit No. 156-97-TV Plant ID 0060

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and air separator particulate matter control devices, in accordance with

procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall

be conducted while the emission unit is operating at the highest load or

capacity level reasonably expected to occur within the day. The duration of

the Method 22 test shall be six minutes. If visible emissions are observed

during any Method 22 visible emissions test, the owner or operator shall:

A. Initiate, within one-hour, the corrective actions specified in the site

specific operating and maintenance plan;

B. Conduct a Method 22 or Method 9 test after the corrective action is

completed. 

1) If no visible emissions are observed, return to monitoring

described above. 

2) If visible emissions are still observed, the owner or operator

shall, within 24 hours of the end of the Method 22 test in

which visible emissions were first observed, conduct a visible

emissions test of each stack from which visible emissions were

observed in accordance with procedures of 40 CFR 60,

Appendix A, Method 9. The duration of the Method 9 shall

be 30 minutes. 

iii. The owner or operator shall test Stack S-15 once every five years using

Method 9. The test shall occur by no later than the end of the first quarter of

the fourth year of the permit. 

iv. The owner or operator shall inspect C-14, C-15, C-16 and C-17 baghouses

for the following items:

A) Verify fan is running and belts are on, daily.

B) Verify dampers are working properly daily.

C) Verify cleaning mechanism is working properly every two weeks

D) Replace all worn bags as needed.

E) Verify bags are clean and not filled with dust every two weeks

F) Verify dust removal system is working properly every two weeks, and

G) Inspect area around collectors for signs of dust every two weeks.

b. SO2
Permit No. 156-97-TV Plant ID 0060

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i. The owner or operator shall combust fuel oil with a sulfur content no more

than 0.5% by weight.

ii. The owner or operator shall comply with Additional Condition 2.f) for

Emission Unit U-13, when combusting “On-Spec”, “Off-Spec” and waste oils.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. SO2

The owner or operator shall maintain records of:

i. Fuel oil vendor certification that the fuel oil meets the 0.5% by weight sulfur

content.

ii. Comply with Additional Condition 3.e.i for Emission Unit U-13.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period
Permit No. 156-97-TV Plant ID 0060

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iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.

b. SO2

i. No compliance reporting is required when the unit combusts natural gas.

ii. No compliance reporting is required when the unit combusts No. 2 fuel oil.

iii. The owner or operator shall report semi-annually, by exception, when

Additional Condition 2.b was not complied with. If no exceptions, then a

negative declaration shall be supplied in the report.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.

Emission Unit U-9 Description: Raw Mill "B"
Permit No. 156-97-TV Plant ID 0060

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Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.10 Standard of Performance for Existing Sections: 1, 2, 4, 6.2

Process Gas Streams

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c), 40 CFR 63.1347 and 40 CFR 63.1348)

SO 2000 ppm by volume at 0% oxygen (Regulation 6.10, Section 4) 2
Permit No. 156-97-TV Plant ID 0060

56

Components:

Emission Point Description Control ID

E-61 Feeder (K-435) fugitive emissions, no control

E-62 Elevator (K-436) Baghouse C-18 (K-454)

E-63 Belt Conveyor (K-427) Baghouse C-19 (K-448)

E-64 Separator (K-429) Baghouse C-20 (K-451)

E-65 Mill “B” (K-441) Baghouse C-21 (K-445)

E-64 Furnace, 20 MMBtu direct Baghouse C-20 (K-451)

fired furnace

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-18 S-16 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-19 S-17 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-20 S-18 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-21 S-19 Baghouse See AC 2.a N/A See AC 2.a semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-14,

C-15, C-16 and C-17 to equal or exceed 10%. The owner or operator shall not allow

or cause the fugitive emissions from Emission Point E-56 to equal or exceed 10%.(40

CFR 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348)

b. SO2

The owner or operator shall not allow or cause the emissions of SO2 from Emission

Point E-64 to exceed 2000 ppm by volume at 0% oxygen. (Regulation 6.10, Section

4)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-61 through E-63 in accordance with 40 CFR 60,

Appendix A, Method 22. The test must be conducted while the emission unit

is in operation.

A. If no visible emissions are observed in six consecutive monthly tests,

the owner or operator may decrease the frequency of testing from

monthly to semi-annually for this emission unit. If visible emissions

are observed during any semi-annual test, the owner or operator shall

resume testing on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests.

B. If no visible emissions are observed during two consecutive tests from

this emission unit, the owner or operator may decrease the frequency

of testing from semi-annually to annually. If visible emissions are

observed during any annual test, the owner or operator shall resume

testing on a monthly basis. and maintain that schedule until no visible

emissions are observed in six consecutive monthly tests.

C. If visible emissions are observed during any Method 22 test, the

owner or operator shall conduct a 6-minute test of opacity in

accordance with 40 CFR 60, Appendix A, Method 9. The Method 9

Test must begin within one hour of any observation of visible

emissions.

ii. The owner or operator shall, for Emission Points E-64 and E-65, monitor

opacity by conducting daily visible emissions observations of the mill sweep
Permit No. 156-97-TV Plant ID 0060

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and air separator particulate matter control devices, in accordance with

procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall

be conducted while the emission unit is operating at the highest load or

capacity level reasonably expected to occur within the day. The duration of

the Method 22 test shall be six minutes. If visible emissions are observed

during any Method 22 visible emissions test, the owner or operator shall:

A. Initiate, within one-hour, the corrective actions specified in the site

specific operating and maintenance plan;

B. Conduct a Method 22 or Method 9 test after the corrective action is

completed. 

1) If no visible emissions are observed, return to monitoring

described above. 

2) If visible emissions are still observed, the owner or operator

shall, within 24 hours of the end of the Method 22 test in

which visible emissions were first observed, conduct a visible

emissions test of each stack from which visible emissions were

observed in accordance with procedures of 40 CFR 60,

Appendix A, Method 9. The duration of the Method 9 shall

be 30 minutes. 

iii. The owner or operator shall test Stack S-19 once every five years using

Method 9. The test shall occur by no later than the end of the first quarter of

the fourth year of the permit. 

iv. The owner or operator shall inspect C-18, C-19, C-20 and C-21 baghouses

for the following items:

A) Verify fan is running and belts are on, daily.

B) Verify dampers are working properly daily.

C) Verify cleaning mechanism is working properly every two weeks

D) Replace all worn bags as needed.

F) Verify bags are clean and not filled with dust every two weeks

G) Verify dust removal system is working properly every two weeks, and

H) Inspect area around collectors for signs of dust every two weeks.

b. SO2
Permit No. 156-97-TV Plant ID 0060

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i. The owner or operator shall combust fuel oil with a sulfur content no more

than 0.5% by weight.

ii. The owner or operator shall comply with Additional Condition 2.f) for

Emission Unit U-13, when combusting “On-Spec”, “Off-Spec” and waste oils.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. SO2

The owner or operator shall maintain records of:

i. Fuel oil vendor certification that the fuel oil meets the 0.5% by weight sulfur

content.

ii. Comply with Additional Condition 3.e.i for Emission Unit U-13.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period
Permit No. 156-97-TV Plant ID 0060

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iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.

b. SO2

i. No compliance reporting is required when the unit combusts natural gas.

ii. No compliance reporting is required when the unit combusts No. 2 fuel oil.

iii. The owner or operator shall report semi-annually, by exception, when

Additional Condition 2.b was not complied with. If no exceptions, then a

negative declaration shall be supplied in the report.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-10 Description: Raw Mill "C"

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.10 Standard of Performance for Existing Sections: 1, 2, 4, 6.2

Process Gas Streams

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c), 40 CFR 63.1347 and 40 CFR 63.1348)

SO 2000 ppm by volume at 0% oxygen (Regulation 6.10, Section 4) 2
Permit No. 156-97-TV Plant ID 0060

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Components:

Emission Point Description Control ID

E-67 Belt Conveyor (K-501) fugitive emissions, no control

E-68 Belt Conveyor (K-513) Baghouse C-22 (K-516)

E-69 Crusher (K-512) Baghouse C-22 (K-516)

E-70 Elevator (K-502) Baghouse C-22 (K-516)

E-71 Separator (K-503) Baghouse C-23 (K-505)

E-72 Mill “C” (K-504) Baghouse C-22 (K-516)

E-73 Pump (K-509) Baghouse C-22 (K-516)

E-71 Furnace (K-464), 6 Baghouse C-23 (K-505)

MMBtu direct fired

furnace

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-22 S-20 Baghouse See AC 2.a N/A See AC 2.a semiannual

C-23 S-21 Baghouse See AC 2.a N/A See AC 2.a semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-22

and C-23 to equal or exceed 10%. The owner or operator shall not allow or cause

the fugitive emissions from Emission Point E-67 to equal or exceed 10%.(40 CFR

60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348)

b. SO2

The owner or operator shall not allow or cause the emissions of SO2 from Emission

Point E-71 to exceed 2000 ppm by volume at 0% oxygen. (Regulation 6.10, Section

4)

2. Monitoring Requirements (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Points E-67 through E-70 and E-73 in accordance with 40 CFR

60, Appendix A, Method 22. The test must be conducted while the emission

unit is in operation.

A. If no visible emissions are observed in six consecutive monthly tests,

the owner or operator may decrease the frequency of testing from

monthly to semi-annually for this emission unit. If visible emissions

are observed during any semi-annual test, the owner or operator shall

resume testing on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests.

B. If no visible emissions are observed during two consecutive tests from

this emission unit, the owner or operator may decrease the frequency

of testing from semi-annually to annually. If visible emissions are

observed during any annual test, the owner or operator shall resume

testing on a monthly basis. and maintain that schedule until no visible

emissions are observed in six consecutive monthly tests.

C. If visible emissions are observed during any Method 22 test, the

owner or operator shall conduct a 6-minute test of opacity in

accordance with 40 CFR 60, Appendix A, Method 9. The Method 9

Test must begin within one hour of any observation of visible

emissions.

ii. The owner or operator shall, for Emission Points E-71 and E-72, monitor

opacity by conducting daily visible emissions observations of the mill sweep
Permit No. 156-97-TV Plant ID 0060

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and air separator particulate matter control devices, in accordance with

procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall

be conducted while the emission unit is operating at the highest load or

capacity level reasonably expected to occur within the day. The duration of

the Method 22 test shall be six minutes. If visible emissions are observed

during any Method 22 visible emissions test, the owner or operator shall:

A. Initiate, within one-hour, the corrective actions specified in the site

specific operating and maintenance plan;

B. Conduct a Method 22 or Method 9 test after the corrective action is

completed. 

1) If no visible emissions are observed, return to monitoring

described above. 

2) If visible emissions are still observed, the owner or operator

shall, within 24 hours of the end of the Method 22 test in

which visible emissions were first observed, conduct a visible

emissions test of each stack from which visible emissions were

observed in accordance with procedures of 40 CFR 60,

Appendix A, Method 9. The duration of the Method 9 shall

be 30 minutes. 

iii. The owner or operator shall test Stack S-20 once every five years using

Method 9. The test shall occur by no later than the end of the first quarter of

the fourth year of the permit. 

iv. The owner or operator shall inspect C-22 and C-23 baghouses for the

following items:

A) Verify fan is running and belts are on, daily.

B) Verify dampers are working properly daily.

C) Verify cleaning mechanism is working properly every two weeks

D) Replace all worn bags as needed.

E) Verify bags are clean and not filled with dust every two weeks

F) Verify dust removal system is working properly every two weeks, and

G) Inspect area around collectors for signs of dust every two weeks.

b. SO2
Permit No. 156-97-TV Plant ID 0060

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i. The owner or operator shall combust fuel oil with a sulfur content no more

than 0.5% by weight.

ii. The owner or operator shall comply with Additional Condition 2.f) for

Emission Unit U-13, when combusting “On-Spec”, “Off-Spec” and waste oils.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. SO2

The owner or operator shall maintain records of:

i. Fuel oil vendor certification that the fuel oil meets the 0.5% by weight sulfur

content.

ii. Comply with Additional Condition 3.e.i for Emission Unit U-13.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period
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iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.

b. SO2

i. No compliance reporting is required when the unit combusts natural gas.

ii. No compliance reporting is required when the unit combusts No. 2 fuel oil.

iii. The owner or operator shall report semi-annually, by exception, when

Additional Condition 2.b was not complied with. If no exceptions, then a

negative declaration shall be supplied in the report.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.

Emission Unit U-11 Description: Blending Silos
Permit No. 156-97-TV Plant ID 0060

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Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:

Emission Point Description Control ID

E-75 Blending Silos (K-602E Baghouse C-24 (K-600)

and K-601W)

Control Devices:
Permit No. 156-97-TV Plant ID 0060

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ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-24 S-22 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from baghouse C-24

 to equal or exceed 10%. (40 CFR 60.62 (c) and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Point E-75 in accordance with 40 CFR 60, Appendix A, Method

22. The test must be conducted while the emission unit is in operation.

i. If no visible emissions are observed in six consecutive monthly tests,

the owner or operator may decrease the frequency of testing from

monthly to semi-annually for this emission unit. If visible emissions

are observed during any semi-annual test, the owner or operator shall

resume testing on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests.

ii. If no visible emissions are observed during two consecutive tests from

this emission unit, the owner or operator may decrease the frequency

of testing from semi-annually to annually. If visible emissions are

observed during any annual test, the owner or operator shall resume

testing on a monthly basis. and maintain that schedule until no visible

emissions are observed in six consecutive monthly tests.

iii. If visible emissions are observed during any Method 22 test, the

owner or operator shall conduct a 6-minute test of opacity in

accordance with 40 CFR 60, Appendix A, Method 9. The Method 9

Test must begin within one hour of any observation of visible

emissions.

b. The owner or operator shall inspect C-24 baghouse for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks
Permit No. 156-97-TV Plant ID 0060

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vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collector for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
Permit No. 156-97-TV Plant ID 0060

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Emission Unit U-12 Description: Kiln Feed System

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:
Permit No. 156-97-TV Plant ID 0060

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Emission Point Description Control ID

E-76 Silo (South) (K-616) Baghouse C-25 (K-618-3)

E-77 Silo (North (K-617) Baghouse C-26 (K-618)

E-78 Belt Weight Feeder (K- Baghouse C-27 (K-627)

624)

E-79 Pump (K-625) Baghouse C-27 (K-627)

E-80 Pump (K-626) Baghouse C-27 (K-627)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-25 S-23 Baghouse See AC 2 N/A See AC 2 semiannual

C-26 S-24 Baghouse See AC 2 N/A See AC 2 semiannual

C-27 S-25 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-25,

C-26 and C-27 to equal or exceed 10%.(40 CFR 60.62 (c) and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Emission Point E- 76 through E - 80 in accordance with 40 CFR 60,

Appendix A, Method 22. The test must be conducted while the emission unit

is in operation.

i. If no visible emissions are observed in six consecutive monthly tests,

the owner or operator may decrease the frequency of testing from

monthly to semi-annually for this emission unit. If visible emissions

are observed during any semi-annual test, the owner or operator shall

resume testing on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests.

ii. If no visible emissions are observed during two consecutive tests from

this emission unit, the owner or operator may decrease the frequency

of testing from semi-annually to annually. If visible emissions are

observed during any annual test, the owner or operator shall resume

testing on a monthly basis. and maintain that schedule until no visible

emissions are observed in six consecutive monthly tests.

iii. If visible emissions are observed during any Method 22 test, the

owner or operator shall conduct a 6-minute test of opacity in

accordance with 40 CFR 60, Appendix A, Method 9. The Method 9

Test must begin within one hour of any observation of visible

emissions.

b. The owner or operator shall inspect C-25, C-26 and C-27 baghouses for the

following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.
Permit No. 156-97-TV Plant ID 0060

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v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all Method 22 and Method 9 tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted that

exceeded the standard (or a negative declaration if none were performed)

iv. Description of any corrective action taken pursuant to Additional Condition

2.

Comment
Permit No. 156-97-TV Plant ID 0060

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With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.

Emission Unit U-13 Description: Preheater and Kiln
Permit No. 156-97-TV Plant ID 0060

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Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1343, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.42 Reasonably Available Control Sections 1.2, 2, 3, 4.3, 5

Technology Requirements for Major

Volatile Organic Compounds and

Nitrogen Oxides emitting facilities

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.12 Standards of Performance for New or Sections: 1 through 5

Modified Sources Emitting Toxic Air

Pollutants

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:
Permit No. 156-97-TV Plant ID 0060

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Pollutant Limit/Standard

Opacity 20% (40 CFR 60.62(a)(2) and 40 CFR 63.1343(b)(2))

Opacity 10% (40 CFR 60.62(c) 40 CFR 63.1347 and 40 CFR

63.1348)

PM 0.30 lb per ton, feed to the kiln (dry basis) (40 CFR

60.62(a)(1) and 40 CFR 63.1343(b)(1))

PM 162.9 tons per year, (Regulation 2.05)

SO 165 lb/hr, 665 tons per year (Regulation 2.05) 2

CO 450 lb/hr, 1690 tons per year (Regulation 2.05)

NO 6.6 lb per ton of clinker produced (Regulation 6.42) X

Dioxin & Furan 0.4 ng/dscm, TEQ corrected to 7% O and , the inlet 2

temperature @ control device of 400 F or less; or 0.20 o

ng per dscm (8.7 x 10 gr per dscf) (TEQ) corrected to -11

seven percent oxygen (see additional condition 1.f) 

TAPs < ASL (Regulation 5.12)

Components:

Emission Point Description Control ID

E-81 Preheater (K-900) Baghouse C-28 (K-945)

E-82 Dust Tank (K-945-27) Baghouse C-29 (K-945-32)

Kiln (K-901)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-28 S-11 Baghouse See AC 2.a & N/A See AC 2.a & semi2.b 2.b annual

C-29 S-26 Baghouse See AC 2.a & N/A See AC 2.a & semi2.b 2.b annual

Additional Conditions
Permit No. 156-97-TV Plant ID 0060

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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

i. The owner or operator shall not allow or cause the opacity from baghouse C28 to exceed 20%. (40 CFR 60.62 (a)(2))

ii. The owner or operator shall not allow or cause the opacity from baghouse C29 to equal or exceed 10%.(40 CFR 60.62 (c))

b. PM

i. The owner or operator not cause to be discharged into the atmosphere from

Stack S-11, any gases which contain particulate matter in excess of 0.15 kg

per metric ton of feed (dry basis) to the kiln (0.30 lb. per ton). (40 CFR

60.62(a)(1))

ii. The owner or operator shall not exceed 162.9 tons per year of emissions to

the atmosphere. (Regulation 2.05) 

c. SO2

The owner or operator shall not exceed 165 pound per hour and 665 tons per year of

emissions to the atmosphere. (Regulation 2.05) 

d. CO

The owner or operator shall not exceed 450 pound per hour and 1690 tons per year

of emissions to the atmosphere. (Regulation 2.05) 

e. NOX

i. The owner or operator shall not exceed 6.6 pounds of emissions to the

atmosphere per ton of clinker produced or 825 pounds per hour. (Regulation

6.42) 

ii. See attached NO RACT Plan (Regulation 6.42) X

f. Dioxin/Furan
Permit No. 156-97-TV Plant ID 0060

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The owner or operator shall no discharge into the atmosphere, any gases which

contain Dioxin/Furan in excess of:

i. 0.20 ng per dscm (8.7 x 10 gr per dscf) (TEQ) corrected to seven percent

-11

oxygen; or

ii. 0.40 ng per dscm (1.7 x 10 gr per dscf) (TEQ) corrected to seven percent

-10

oxygen, when the average of the performance test run average temperatures

at the inlet of the particulate matter control device is 204 C (400 F) or less. o o

g. TAPs

i. The owner or operator shall limit Toxic Air Pollutant (TAP) emissions from

Emission Point E-90 to no more than the Adjusted Significance Level (ASL)

based on a stack height of 98 feet and 168 hours of operation per week,

unless modeling or a BACT/RACT analysis has been performed and submitted

to the District, to demonstrate compliance. (Regulation 5.12)

ii. The owner or operator may combust 1.1 tons per hour of Tire Derived Fuel.

(Regulation 5.12)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Stack S-26 in accordance with 40 CFR 60, Appendix A, Method 22. The

test must be conducted while the emission unit is in operation.

ii. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

iii. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain 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 shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.
Permit No. 156-97-TV Plant ID 0060

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v. The owner or operator shall install, calibrate, maintain and operate in

accordance with 40 CFR 60.13 and 40 CFR 60, Appendix B PS-1, a

continuous opacity monitoring system (COM) to measure the opacity of

emissions discharged into the atmosphere from stack S-11.

vi. Should the COM fail for any reason for more than 24 hours, the owner or

operator, shall, to remain in compliance, perform a Method 9 test (40 CFR 60

Appendix A) for at least 30 minutes, during each day, under normal operating

conditions, on stack S-11. The COM failure shall be reported to the District

as per Regulation 1.07.

b. PM

i. The owner or operator shall inspect C-28 and C-29 baghouses for the

following items:

1) Verify fan is running and belts are on, daily.

2) Verify dampers are working properly daily.

3) Verify cleaning mechanism is working properly every two weeks

4) Replace all worn bags as needed.

5) Verify bags are clean and not filled with dust every two weeks

6) Verify dust removal system is working properly every two weeks, and

7) Inspect area around collector for signs of dust every two weeks.

ii. The owner or operator shall test Stack S-11 once every five years using

Methods 1 through 5. The test shall occur by no later than the end of the first

quarter of the fourth year of the permit. 

c. SO2

i. The owner or operator shall install, calibrate, maintain and operate in

accordance with 40 CFR 60.13 and 40 CFR 60, Appendix B PS-2, a

continuous emissions monitoring system (CEMS to measure the SO2

emissions discharged into the atmosphere from stack S-11.

A) The SO CEMS shall be operated and data recorded during all periods 2

of operation of the cement kiln except for CEMS breakdowns and

repairs. Data shall be recorded during calibration checks and zero and

span adjustments.
Permit No. 156-97-TV Plant ID 0060

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B) The 1-hour average SO emission rates measured by the CEMS shall 2

be expressed in pounds per hour and shall be used to calculate the

average emission rates. At least 2 data points shall be used to

calculate each 1-hour average. 

C) The span value for the SO CEMS shall be determined so that all 2

expected concentrations can be accurately measured and

D) The Quality Assurance Procedures in 40 CFR Part 60 Appendix F

shall be followed.

E) When SO emission data or flow monitor data (if a flow monitor is 2

used) are not obtained because of CEMS breakdowns, repairs,

calibration checks, or zero and span adjustments, emission data shall

be obtained by using one of the following options to provide emission

data for a minimum of 75% of the operating hours in each kiln

operating day, in at least 22 out of 30 successive cement kiln

operating days:

F) Standby monitoring systems, 40 CFR Part 60 Appendix A Method 6,

Method 6A or Method 6C, or other approved reference methods, or

data substitution as follows:

(1) If the missing data period is 6 hours or less, then substitute an

average of the quality-assured data from the hour immediately

before and the hour immediately after the missing data period

for each hour of missing data, and

(2) If the missing data period is greater than 6 hours, then

substitute the greatest emission rate or flow (if a flow monitor

is used) recorded during the previous 2160 quality-assured

monitor operating hours at a clinker production rate that is

within 10% of the current operating rate. If there are not

enough data to satisfy this requirement, then substitute data

from a higher clinker production rate or the maximum design

flow or emission rate.

(3) The clinker production rate shall be determined and recorded

during all periods of operation of the cement kiln except for

breakdowns and repairs of the system used to determine the

clinker production rate (raw materials weigh feeder and

associated data acquisition system). Data shall be recorded

during periods of calibration for the weigh feeder, which at a

minimum shall be performed annually.

(4) The clinker production rate determined from monitoring the

rate of raw materials input to the cement kiln shall be

calculated by dividing the rate of raw materials input to the

cement kiln by the current raw materials conversion factor.

The raw materials conversion factor shall be determined on a
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quarterly basis and this conversion factor shall be used in the

calculation of the clinker production rate until the next

quarterly raw materials conversion rate test is performed. The

raw materials conversion rate factor shall be determined by

weighing and recording the raw materials input to the cement

kiln with the weigh feeder and weighing and recording the

clinker output from the cement kiln with the use of a certified

scale over a four- to twelve-hour period and an average

calculated from those data. The current raw materials

conversion factor shall be included with the quarterly

emissions report.

ii. A monitoring plan shall be created and kept current for the system used to

determine compliance with the pounds of SO kiln limit. The most current 2

version of the monitoring plan shall be submitted to the District and also be

easily accessed by the monitoring system operation personnel.

iii Flow monitor requirements shall be pursuant Appendix B of the NOX RACT

Plan.

d. CO

i. The owner or operator shall install, calibrate, maintain and operate in

accordance with 40 CFR 60.13 and 40 CFR 60, Appendix B PS-4 or 4A, a

continuous emissions monitoring system (CEM) to measure the CO emissions

discharged into the atmosphere from stack S-11.

A) The CO CEMS shall be operated and data recorded during all periods

of operation of the cement kiln except for CEMS breakdowns and

repairs. Data shall be recorded during calibration checks and zero and

span adjustments.

B) The 1-hour average CO emission rates measured by the CEMS shall

be expressed in pounds per hour and shall be used to calculate the

average emission rates. At least 2 data points shall be used to

calculate each 1-hour average. 

C) The span value for the CO CEMS shall be determined so that all

expected concentrations can be accurately measured and

D) The Quality Assurance Procedures in 40 CFR Part 60 Appendix F

shall be followed.

E) When CO emission data or flow monitor data (if a flow monitor is

used) are not obtained because of CEMS breakdowns, repairs,

calibration checks, or zero and span adjustments, emission data shall

be obtained by using one of the following options to provide emission
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data for a minimum of 75% of the operating hours in each kiln

operating day, in at least 22 out of 30 successive cement kiln

operating days:

F) Standby monitoring systems, 40 CFR Part 60 Appendix A Method 10

or Method 10B, or other approved reference methods, or Data

substitution as follows:

(1) If the missing data period is 6 hours or less, then substitute an

average of the quality-assured data from the hour immediately

before and the hour immediately after the missing data period

for each hour of missing data, and

(2) If the missing data period is greater than 6 hours, then

substitute the greatest emission rate or flow (if a flow monitor

is used) recorded during the previous 2160 quality-assured

monitor operating hours at a clinker production rate that is

within 10% of the current operating rate. If there are not

enough data to satisfy this requirement, then substitute data

from a higher clinker production rate or the maximum design

flow or emission rate.

(3) The clinker production rate shall be determined and recorded

during all periods of operation of the cement kiln except for

breakdowns and repairs of the system used to determine the

clinker production rate (raw materials weigh feeder and

associated data acquisition system). Data shall be recorded

during periods of calibration for the weigh feeder, which at a

minimum shall be performed annually.

(4) The clinker production rate determined from monitoring the

rate of raw materials input to the cement kiln shall be

calculated by dividing the rate of raw materials input to the

cement kiln by the current raw materials conversion factor.

The raw materials conversion factor shall be determined on a

quarterly basis and this conversion factor shall be used in the

calculation of the clinker production rate until the next

quarterly raw materials conversion rate test is performed. The

raw materials conversion rate factor shall be determined by

weighing and recording the raw materials input to the cement

kiln with the weigh feeder and weighing and recording the

clinker output from the cement kiln with the use of a certified

scale over a four- to twelve-hour period and an average

calculated from those data. The current raw materials

conversion factor shall be included with the quarterly

emissions report.

ii. A monitoring plan shall be created and kept current for the system used to

determine compliance with the pounds of SO kiln limit. The most current 2
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version of the monitoring plan shall be submitted to the District and also be

easily accessed by the monitoring system operation personnel.

iii Flow monitor requirements shall be pursuant Appendix B of the NOX RACT

Plan.

e. NOX

i. See attached NO RACT Plan for compliance record keeping requirements. X

ii. During RATA for the flow monitors, the audit shall be performed at the one

typical high velocity.

f. Dioxin/Furan

The owner or operator shall test stack S-11, utilizing Method 23 of appendix A, 40

CFR part 60, twice during the duration of the permit. Testing shall be performed at

the timeframes specified in 40 CFR 63.1349

g. TAPs

i. Source generated Waste Oil, having the characteristics specified in 2.e.ii, may

be combusted as a secondary fuel in the kiln.

ii. The source may combust “On-Spec” and “Off-Spec” oils, having the

following characteristics, as a secondary fuel in the kiln.

A) Heat content of 10,000 Btu or more per pound

B) Suspended solids, 15% or less by weight

C) pH of aqueous extraction between 5 and 10

D) Chlorinated solids less than 0.1% by weight

E) Ash less than 5%

F) sulfur less than 3%

G) viscosity - pumpable

H) water emulsions - no layering (emulsifiable content OK)

I) Minimum flash point - 100 Fo

J) Maximum allowed constituents:

Constituent Max Allowed Max Allowed

 “On-Spec” “Off -Spec”

Arsenic 5 ppm 5 ppm

Cadmium 2 ppm 2 ppm
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Chromium 10 ppm 10 ppm

Lead 100 ppm 100 ppm

Total halogens 1000 ppm 4000 ppm

PCB’s 2 ppm 2 ppm

iii. If waste oil, other than what was specified in 2.e.i and ii are to be used as a

secondary fuel, it will be necessary that the owner or operator submit an

analysis to the District for prior approval.

iv. The owner or operator shall incorporate spent coal ash as a partial clay

substitute, as it deems necessary.

v. The owner or operator shall, during the combustion of TDF:

A. For products of incomplete combustion, not allow the oxygen

concentration at the kiln inlet to drop below 0.5%.

B. install, maintain and properly operate an automatic TDF shutdown

for:

(I) Coal mill outage and belt malfunction, with an alarm to sound

at +5% coal flow rate

(II) Primary ID fan outage

(III) Baghouse ID fan outage

(IV) High baghouse temperature of 500 F

o

(V) Oxygen levels below 5000 ppm for a period of 5 minutes, with

an alarm to sound for oxygen levels below 10,000 ppm for a

period of 15 minutes

(VI) TDF shall not be introduced to the kiln until steady state

conditions, as characterized by a CO reading of 100 ppm, an

O reading of 0.5%, a minimum raw feed rate of 110 tons per 2

hour are reached and maintained for five consecutive minutes.

(VII) Continuous emissions monitors, strip chart or data recorders

shall be installed, calibrated, tested and operated with required

reporting and recordkeeping in accordance with Regulation

7.01 and 40 CFR 60, Appendix B for the following

parameters:

(1) The temperature at the second stage pre-heater

(2) The oxygen concentration in the kiln

(3) The TDF feed rate

(4) The power draw of the kiln-induced draft fan

converted electronically to represent gas flow through

the kiln

(5) Opacity

(6) Carbon monoxide in the kiln exhaust
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(VIII) The owner or operator shall install, maintain, operate,

calibrate and audit a CEM data logging system, as follows:

(1) Polling shall be at least every 5 seconds

(2) Instantaneous values can be obtained

(3) Averages shall be over the last 15 minute period

(4) 15-minute averages for the last 96 hours

(IX) The owner or operator shall develop an Operations and

Maintenance Manual which details the proper O&M

procedures for its personnel. A current copy of the manual

shall be kept on hand at the plant at all times for review by the

District. The manual shall, at a minimum, have a description

of the proper procedures for operation and maintenance of:

(1) The receipt of TDF into the plant

(2) The handling of TDF prior to combustion

(3) shutdown

(4) emergency shutdown

(5) safety

(6) spill prevention and clean up

(7) recordkeeping

(8) preventative maintenance

(9) company’s response to malfunction of the TFD

process

C. After any disruption in the utilization of TDF, lasting more than 180

days, the owner or operator shall conduct performance tests, as

specified in 40 CFR 60 Appendix A, for particulate matter (PM) and

sulfur dioxide (SO2). The requirements of Regulation 1.04 shall be

followed during performance testing. These performance tests shall

be conducted within 90 days after the resumption of combusting TDF.

The owner or operator shall conduct any additional performance tests

specified by the District. The owner or operator shall make available

to the District such records as may be necessary to determine

conditions during such performance tests. A written report of the

results of the performance tests shall be submitted to the District

within 90 days of the completion of the tests. The District shall be

notified at least 45 days in advance of the starting date of these

performance tests. As pre-test conference shall be held with the

District, and at the District’s discretion, at least 30 days before the

start of the tests. The TDF feed rate shall not exceed the feed rate

established during such trail burns, unless a retest is run at a higher

feed rate. The District shall require a minimum of 2 performance tests

for PM and SO2. One test will establish the baseline conditions (no

TDF being combusted) and the other for TDF combustion at no less

than 90% of the maximum TDF combustion rate.

D. The owner or operator shall maintain all records, receipts, manifests,

test results, burn rates, combustion parameters, and all other records

or data required by this process for a period of five years from the
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date that such records are generated. Such records or data shall be

made available to the District within 3 days, upon request. 

E. The owner or operator agrees to cease the combustion of TDF for

non-compliance, if the District so orders.

 3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

i. For Stack S-26, the owner or operator shall maintain records of:

A. results of all visible emission surveys and tests performed

B. the date and time of the survey

C. the name of the person conducting the survey or test

D. whether visible emissions were observed

E. a negative declaration may be entered in the record if an Emission

Point is not being operated during a given day, week or month (as

appropriate)

ii. For Stack S-11 (COM)

A. The owner or operator shall record the daily production rates and kiln

feed rates.

B. The data acquisition and handling system used in recording and

reporting the necessary information required for the determination of

compliance with the opacity limit shall also meet all of the

requirements specified in NO RACT Plan Appendix B. x

b. PM

The owner or operator shall maintain records of:

i. results of all inspections and tests performed

ii. the date and time of the inspection or test

iii. the name of the person conducting the inspection or test

iv. any remedial action that occurred, as a result of inspection or test.

c. SO2

The owner or operator shall keep records for each operating day including the

following information:

i Calendar date,
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ii The average hourly SO emission rates measured, expressed as pounds per 2

hour and tons per consecutive 12 month period.

iii The 30-day average SO emission rates calculated at the end of each cement 2

kiln operating day from the measured hourly sulfur dioxide emission rates for

the preceding 30 cement kiln operating days. The average shall not include

data recorded during periods of CEMS breakdowns, repairs, calibration

checks, and zero and span adjustments,

iv Identification of the cement kiln operating days when the calculated rolling

30-day average SO emission rates are in excess of the SO emissions 2 2

standard. 

v. Identification of the cement kiln operating days for which pollutant data have

not been obtained, including reasons for not obtaining sufficient data and a

description of corrective actions taken,

vi Identification of the times when emission data have been excluded from the

calculation of average emission rates, the reasons for excluding data, and

description of corrective action taken,

vii Identification of times when hourly averages have been obtained based on

40 CFR Part 60 Appendix A Method 6 or Method 6A,

viii Identification of times which the CEMS (including all monitors) was

inoperative, including the date and time and the nature of the system repairs

or adjustments except for zero and span checks,

ix Identification of the times when the pollutant concentration exceeded full span

of the CEMS,

x . Description of any modifications to the CEMS that could affect the ability of

the CEMS to comply with 40 CFR Part 60 Appendix B Performance

Specification 2,

xi Results of daily CEMS drift tests and quarterly accuracy assessments as

required under 40 CFR Part 60 Appendix F Procedure 1.

d. CO

The owner or operator shall keep records for each operating day including the

following information:

i Calendar date,

ii The average hourly CO emission rates measured, expressed as pounds per

hour and tons per consecutive 12 month period.
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iii The 30-day average CO emission rates calculated at the end of each cement

kiln operating day from the measured hourly carbon monoxide emission rates

for the preceding 30 cement kiln operating days. The average shall not

include data recorded during periods of CEMS breakdowns, repairs,

calibration checks, and zero and span adjustments,

iv Identification of the cement kiln operating days when the calculated rolling

30-day average CO emission rates are in excess of the CO emissions standard.

v. Identification of the cement kiln operating days for which pollutant data have

not been obtained, including reasons for not obtaining sufficient data and a

description of corrective actions taken,

vi Identification of the times when emission data have been excluded from the

calculation of average emission rates, the reasons for excluding data, and

description of corrective action taken,

vii Identification of times when hourly averages have been obtained based on

40 CFR Part 60 Appendix A Method 10 or Method 10B,

viii Identification of times which the CEMS (including all monitors) was

inoperative, including the date and time and the nature of the system repairs

or adjustments except for zero and span checks,

ix Identification of the times when the pollutant concentration exceeded full span

of the CEMS,

x . Description of any modifications to the CEMS that could affect the ability of

the CEMS to comply with 40 CFR Part 60 Appendix B Performance

Specification 4,

xi Results of daily CEMS drift tests and quarterly accuracy assessments as

required under 40 CFR Part 60 Appendix F Procedure 1,

e. NOX

See attached NO RACT Plan for compliance reporting requirements. X

f. Dioxin/Furan

The owner or operator shall maintain records per 40 CFR 63.1355.

g. TAPs
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i. The owner or operator shall maintain, on site, all analytical test results

of waste oil, “Off-Spec” oils and “On-Spec” oils.

ii. The owner or operator shall obtain and retain an elemental and TCLP

for each initial shipment of spent coal ash from all suppliers.

iii. The owner or operator shall obtain and retain certification from any

and all coal ash suppliers. The certificate shall contain the following:

A. Name, address and telephone number of the supplier

B. A statement form the supplier that the spent coal ash was

generated from the combustion of coal, only.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

i. The owner or operator shall include, at a minimum, the following information

in the semi-annual compliance monitoring report for opacity for stack S-26:

A. Emission Unit ID number and Emission Point ID number or Stack ID

number

B. The beginning and ending date of the reporting period

C. The date, time, and result of each Method 9 or Method 22 conducted

(or a negative declaration if none)

D. Description of any corrective action taken pursuant to Additional

Condition 2.a.iii.

ii. The owner or operator shall, for Stack S-11, report

A. per 40 CFR 60.65, report excess emissions as defined as all six-minute

periods during which the average opacity exceeds 20%.

B. the content of this report shall comply with the requirements of 40

CFR 60.7(c).

C. not withstanding 40 CFR 60.7(c), such report shall be semi-annual.

c. SO2

i. All SO2 CEMS reporting required by 40 CFR Part 60 Appendix F is to be

submitted to the District.
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ii. All “estimated” data shall be reported with a clear notation that they are

estimated and not obtained from a certified monitor or EPA-approved test

method.

iii. The owner or operator shall submit excess emission reports for any excess

emissions that occurred during the reporting period. This report shall include

the magnitude of the excess emissions and the date and time of the

commencement and completion of each period of excess emissions as well as

the nature and cause of each period of excess emissions and any corrective

actions taken or preventive measures adopted,

iv. The owner or operator shall submit a Summary Report with every quarterly

report. The Summary Report shall be in the format given in 40 CFR §60.7

Figure 1.

d. CO

i. All CO CEMS reporting required by 40 CFR Part 60 Appendix F is to be

submitted to the District.

ii. All “estimated” data shall be reported with a clear notation that they are

estimated and not obtained from a certified monitor or EPA-approved test

method.

iii. The owner or operator shall submit excess emission reports for any excess

emissions that occurred during the reporting period. This report shall include

the magnitude of the excess emissions and the date and time of the

commencement and completion of each period of excess emissions as well as

the nature and cause of each period of excess emissions and any corrective

actions taken or preventive measures adopted,

iv. The owner or operator shall submit a Summary Report with every quarterly

report. The Summary Report shall be in the format given in 40 CFR §60.7

Figure 1.

e. NOX

See attached NOX RACT Plan

f. Dioxin/Furan

The owner or operator shall report per 40 CFR 63.1354

g. TAPs
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The owner or operator shall submit semi-annually reports to the District, certifying

that the spent coal ash supplied to the company was generated from the combustion

of coal only and is not contaminated with any other material.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.

Emission Unit U-14 Description: Bypass System 

Applicable Regulations:
Permit No. 156-97-TV Plant ID 0060

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FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart Hazardous Air Pollutants From Portland 63.1342, 63.1343, 63.1348,

LLL Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

7.02 Federal New Source Performance 1.16, 2, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c))

Opacity 20% (40 CFR 60.62(a)(2) and 40 CFR 63.1343(b)(2))

PM 0.3 lb./ton of feed, dry basis 40 CFR 60.62(a)(1) and 40 CFR

63.1343(b)(1)

Components:
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Emission Point Description Control ID

E-83 Spray Tower (K-937) Cyclone C-30 and ESP C-31

(K-934 and K-938)

E-84 Elevator (K-940) Baghouse C-32 (K-948)

E-84 Dust Bin (K-941) Baghouse C-32 (K-948)

E-86 Truck Loadout (K-934-2) fugitive emissions, no control

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-30 S-27 Cyclone and See AC 2 N/A See AC 2 semiC-31 ESP annual

C-32 S-28 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

a. The owner or operator shall not allow or cause the opacity from baghouse C-32 to

equal or exceed 10%. The owner or operator shall not allow or cause the fugitive

emissions from Emission Point E-86 to equal or exceed 10%. (40 CFR 60.62 (c))

b. The owner or operator shall not allow or cause the opacity from Stack S-27 to exceed

20%. This is the kiln by-pass. (40 CFR 60.62 (a)(2) and 40 CFR 63.1343(b)(2))

PM

See comment

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity (see comment)

i. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Stack S-28 and E-86 in accordance with 40 CFR 60, Appendix A, Method

22. The test must be conducted while the emission unit is in operation.

ii. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

iii. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain 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 shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-30, C-31 and C-32 baghouses for the

following items:

i. Verify fan is running and belts are on, daily.
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ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity (see comment)

i. The owner or operator shall maintain records of:

A) results of all visible emission surveys and tests performed

B) the date and time of the survey

C) the name of the person conducting the survey or test

D) whether visible emissions were observed

E) a negative declaration may be entered in the record if an Emission

Point is not being operated during a given day, week or month (as

appropriate)

ii. For Stack S-27 see comment

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity (see comment)
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i. The owner or operator shall include, at a minimum, the following information

in the semi-annual compliance monitoring reports for opacity:

A) Emission Unit ID number and Emission Point ID number or Stack ID

number

B) The beginning and ending date of the reporting period

C) The date, time, and result of each Method 9 or Method 22 conducted

(or a negative declaration if none)

D) Description of any corrective action taken pursuant to Additional

Condition 2.a.iii.

ii. For Stack S-27 see comment

Comment

1. The source has undergone significant modifications, the by-pass stack no longer exists.

Therefore, it is felt that it serves no useful purpose, to spell out PM compliance requirements

or COM requirements for a unit that is no longer in operation.

2. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.
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Emission Unit U-15 Description: Insufflation System 

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:

Emission Point Description Control ID

E-87 Bin (K-907) Baghouse C-33 (K-908)

Control Devices:
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ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-33 S-29 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouse C-33

to equal or exceed 10%. (40 CFR 60.62 (c) and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity (see comment)

a. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Stack S-29 in accordance with 40 CFR 60, Appendix A, Method 22. The

test must be conducted while the emission unit is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-33 baghouse for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks
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vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collector for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity (see comment)

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity (see comment)

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.iii.

Comment
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1. The source has undergone significant modifications, the Insufflation System no longer exists.

Therefore, it is felt that it serves no useful purpose, to spell out PM compliance requirements

requirements for a unit that is no longer in operation.

2. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.
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Emission Unit U-16 Description: Coal Handling System

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

1.14 Control of Fugitive Emissions Sections 1, 2, 2.3 and 2.4

6.09 Standards of Performance for Existing Sections 1, 2, 3.1, 3.2, 3.3,

Process Operations 3.4, 3.6, 4, 5

40 CFR 60 Standards of Performance for Portland Sections 60.60, 60.61, 60.62,

Subpart F Cement Plans 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.12 Standards of Performance for New or Sections: 1 through 5

Modified Sources Emitting Toxic Air

Pollutants

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance 1.16, 2, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c))
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Components:

Emission Point Description Control ID

E-88 Hopper fugitive emissions, no control

E-89 Belt Conveyor (K-1304-1) fugitive emissions, no control

.
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Additional Conditions

1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

i. The owner or operator shall not allow or cause the opacity from the fugitive

Emission Points E-88 and E-89 to equal or exceed 10%. (40 CFR 60.62 (c))

ii. The owner or operator shall not cause or permit the discharge of fugitive

emissions in excess of 20% opacity from Emission Point E-92. (Regulation

1.14, sec 2.2)

iii. The owner or operator shall not cause or permit the discharge, from Emission

Point E-92, of visible fugitive emissions beyond the lot line of the property on

which the emissions originate. (Regulation 1.14, sec 2.3)

b. TAPs (Regulation 5.11 & 5.12)

The owner or operator shall limit Toxic Air Pollutant (TAP) emissions from Emission

Point E-90 to no more than the Adjusted Significance Level (ASL) specified in

Regulation 5.12 unless modeling or a BACT/RACT analysis has been performed and

submitted to the District, to demonstrate compliance. 

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. To demonstrate compliance with the opacity standard, the owner or operator

shall conduct a daily one-minute visible emissions survey, during normal

operation and daylight hours, of the PM emission points identified as E-88, E89, E-90, E-91 and E-92. No more than four Emission Points shall be

observed simultaneously.

ii. For Emission Points without observed visible emissions during twelve

consecutive operating weeks, the owner or operator may elect to conduct a

weekly one-minute visible emission survey, during normal operation and

daylight hours. No more than four Emission Points shall be observed

simultaneously.

iii. At Emission Points where visible emissions are observed, the owner or

operator shall initiate corrective action within eight hours of the initial

observation. If the visible emissions persist, the owner or operator shall

perform or cause to be performed a Method 9 for stack emissions or Method

22 for fugitive emissions within 24 hours of the initial observation. If the

opacity standard is exceeded, the owner or operator shall report the
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exceedance to the District, pursuant to Regulation 1.07, and take all

practicable steps to eliminate the exceedance. Subsequent visible emission

surveys shall be conducted as indicated in 2.a.

iv. No visible emission survey needs to be performed if an Emission Point is not

being operated during a given day, week or month (as appropriate).

b. TAPs (Regulation 5.11 & 5.12)

The owner or operator shall perform an analysis of the constituents in ash from any

new source of this material and demonstrate that the emissions of these constituents

do not exceed the ASL.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

a. results of all visible emission surveys and tests performed

b. the date and time of the survey

c. the name of the person conducting the survey or test

d. whether visible emissions were observed

e. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. TAPs (Regulation 5.11 & 5.12)

The owner or operator shall maintain, on site, all material analyses, of all current and

past ash suppliers.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

a. Emission Unit ID number and Emission Point ID number or Stack ID number

b. The beginning and ending date of the reporting period
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c. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

d. Description of any corrective action taken pursuant to Additional Condition

2.a.iii.

b. TAPs (Regulation 5.11 & 5.12)

The owner or operator shall submit to the District for approval:

i. A request to utilize a new source or supply of ash.

ii. The laboratory analysis of the proposed ash

iii. Emissions evaluations for TAP compliance

Comment

Emission points E-90 and E-91 are storage piles and have been determined to be insignificant

activities. See Insignificant activities listing.
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Emission Unit U-17 Description: Coal Mill System

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

6.09 Standards of Performance for Existing Sections 1, 2, 3.1, 3.2, 3.3,

Process Operations 3.4, 3.6, 4, 5

Allowable Emissions:

Pollutant Limit/Standard

Opacity < 20% , Regulation 6.09, section 3.1

Components:

Emission Point Description Control ID

E-93 Coal Bin (K-902) fugitive emissions, no control

E-94 Weigh Feeder ((K-930) fugitive emissions, no control

E-95 Coal Mill (K-904) installed fugitive emissions, no control

1974

.
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Additional Conditions

1. Standards (Regulation 6.09, section 3.1)

Opacity

The owner or operator shall, for each particulate matter (PM) Emission Point

subject to Regulation 6.09, not cause or permit the discharge of emissions equal to

or in excess of 20% opacity.

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. To demonstrate compliance with the opacity standard, the owner or operator

shall conduct a weekly one-minute visible emissions survey, during normal

operation and daylight hours, of the PM emission points identified as E-93,

E-94 and E-95 No more than four Emission Points shall be observed

simultaneously.

b. For Emission Points without observed visible emissions during twelve

consecutive operating weeks, the owner or operator may elect to conduct a

monthly one-minute visible emission survey, during normal operation and

daylight hours. No more than four Emission Points shall be observed

simultaneously.

c. For Emission Points without observed visible emissions during twelve

consecutive operating weeks as per 2.b, the owner or operator may elect to

conduct a monthly one-minute visible emission survey, during normal

operation and daylight hours. No more than four Emission Points shall be

observed simultaneously.

d. At Emission Points where visible emissions are observed, the owner or

operator shall initiate corrective action within eight hours of the initial

observation. If the visible emissions persist, the owner or operator shall

perform or cause to be performed a Method 9 for stack emissions or Method

22 for fugitive emissions within 24 hours of the initial observation. If the

opacity standard is exceeded, the owner or operator shall report the

exceedance to the District, pursuant to Regulation 1.07, and take all

practicable steps to eliminate the exceedance. Subsequent visible emission

surveys shall be conducted as indicated in item 2.a.

d. No visible emission survey needs to be performed if an Emission Point is not

being operated during a given day, week or month (as appropriate).
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3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

a. results of all visible emission surveys and tests performed

b. the date and time of the survey

c. the name of the person conducting the survey or test

d. whether visible emissions were observed

e. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

a. Emission Unit ID number and Emission Point ID number or Stack ID number

b. The beginning and ending date of the reporting period

c. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

d. Description of any corrective action taken pursuant to Additional Condition

2.a.iii.
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Emission Unit U-18 Description: Clinker Cooler

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1345, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

PM 0.1 lb PM per ton of feed to the kiln (dry Basis) (40 CFR

60.62(b)(1) and 40 CFR 63.1345)

Opacity <10% (40 CFR 60.62(c), 40 CFR 63.1345 and 40 CFR 63.1348)

Components:
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Emission Point Description Control ID

E-97 Cooler (rear) (K-909) Baghouse C-35 (K-924)

E-98 Drag (K-909-4) Baghouse C-36 (K-917)

E-99 Elevator (west) (K-912) fugitive emissions, no control

E-100 Elevator (K-913) fugitive emissions, no control

E-101 Hot Tank (K-915) Baghouse C-37 (K-915-4)

E-102 Belt Conveyor (K-949) fugitive emissions, no control

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-35 S-30 Baghouse See AC 2.b N/A See AC 2.a & semi2.b annual

C-36 S-31 Baghouse See AC 2.b N/A See AC 2.a & semi2.b annual

C-37 S-32 Baghouse See AC 2.b N/A See AC 2.a & semi2.b annual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

The owner or operator shall not allow or cause the opacity from the

baghouses C-35, C-36 and C-37 to equal or exceed 10%. The owner or

operator shall not allow or cause the opacity from the fugitive Emission Points

E-99, E-100, E-101, and E-102 to equal or exceed 10%. (40 CFR 60.62 (c)

40 CFR 63.1345 and 40 CFR 63.1348)

b. PM

The owner or operator shall not cause to be discharged into the atmosphere,

from Stack S-30, any gases which contain particulate matter in excess of 0.50

kg per metric ton of feed (dry basis) to the kiln (0.10 lb per ton).

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall conduct a monthly 1-minute visible

emissions test on Stacks S-31 and S-32 in accordance with 40 CFR

60, Appendix A, Method 22. The test must be conducted while the

emission unit is in operation.

ii. If no visible emissions are observed in six consecutive monthly tests,

the owner or operator may decrease the frequency of testing from

monthly to semi-annually for this emission unit. If visible emissions

are observed during any semi-annual test, the owner or operator shall

resume testing on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests.

iii. If no visible emissions are observed during two consecutive tests from

this emission unit, the owner or operator may decrease the frequency

of testing from semi-annually to annually. If visible emissions are

observed during any annual test, the owner or operator shall resume

testing on a monthly basis. and maintain 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 shall conduct a 6-minute test of opacity in

accordance with 40 CFR 60, Appendix A, Method 9. The Method 9

Test must begin within one hour of any observation of visible

emissions.

v. The owner or operator shall install, calibrate, maintain and operate in

accordance with 40 CFR 60.13, a continuous opacity monitoring
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system to measure the opacity emissions discharged into the

atmosphere from S-30.

vi. The owner or operator shall, during any period that the continuous

opacity monitor (COM) is down for more than a twenty-four hour

period, perform a Method 9 test on Stack S-30 once per day until the

COM is back in operation. The results of such test(s) shall be

supplied to the District in the source’s semi-annual report.

b. PM

i. The owner or operator shall inspect C-35, C-36 and C-37 baghouses

for the following items:

1) Verify fan is running and belts are on, daily.

2) Verify dampers are working properly daily.

3) Verify cleaning mechanism is working properly every two

weeks

4) Replace all worn bags as needed.

5) Verify bags are clean and not filled with dust every two weeks

6) Verify dust removal system is working properly every two

weeks, and

7) Inspect area around collectors for signs of dust every two

weeks.

ii. The owner or operator shall test Stack S-30 once every five years

using Methods 1 through 5. The test shall occur by no later than the

end of the first quarter of the fourth year of the permit. 

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test
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iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. PM

The owner or operator shall maintain records of:

i. results of all inspections performed

ii. the date and time of the inspection

iii. the name of the person conducting the inspection

iv. results of observed findings and any corrective actions taken

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.a.iii.

v. The owner or operator shall submit reports of excess emissions as defined in

40 CFR 60.63(d). The content of these reports must comply with the

requirements of 40 CFR 60.7(c). Not withstanding the provisions of 40 CFR

60.7(c), such reports shall be submitted semi-annually. (Regulation 40 CFR

60.65)

vi. For purposes of reports under 40 CFR 60.65, periods of excess emissions

shall be reported are defined as all 6-minute periods during which the average

opacity exceeds that allowed by 40 CFR 60.62(a)(2) or 40 CFR 60(b)(2) for

Stack S-30. (Regulation 40 CFR 60.63)
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b. PM

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for PM:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, results of inspections that had negative consequences to PM

compliance, and corrective action taken to remedy the discovered problem.

Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
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Emission Unit U-19 Description: Clinker Handling / Storage / Reclaim

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:
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Emission Point Description Control ID

E-103 Belt Conveyor (K-949) Baghouse C-38 (K-949-5)

E-104 Belt Conveyor (K-949-3) Baghouse C-39 (K-958)

E-105 Tripper Belt Conveyor (K- Baghouse C-40 (K-954)

950)

E-107 Drag (K-957) Baghouse C-39 (K-958)

E-108 Clinker Bins (K-1000, K- Baghouse C-39 (K-958)

1001, K-1015 & K-1016)

E-109 Hopper (K-1308-1) fugitive emissions, no control

E-110 Belt Conveyor (K-1308) fugitive emissions, no control

E-111 Elevator (K-955) Baghouse C-40 (K-954)

E-112 6 Feeders (K-951-1 thru Baghouses C-41 thru C-46

K-951-6) (K-953 thru K-953-5)

E-113 Belt Conveyor (K-952) Baghouses C-41 thru C-46

(K-953 thru K-953-5)

E-114 Belt Conveyor (K-956) Baghouse C-40 (K-954)

Control Devices:
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ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-38 S-33 Baghouse See AC 2 N/A See AC 2 semiannual

C-39 S-34 Baghouse See AC 2 N/A See AC 2 semiannual

C-40 S-35 Baghouse See AC 2 N/A See AC 2 semiannual

C-41 S-36 Baghouse See AC 2 N/A See AC 2 semiannual

C-42 S-37 Baghouse See AC 2 N/A See AC 2 semiannual

C-43 S-38 Baghouse See AC 2 N/A See AC 2 semiannual

C-44 S-39 Baghouse See AC 2 N/A See AC 2 semiannual

C-45 S-40 Baghouse See AC 2 N/A See AC 2 semiannual

C-46 S-41 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-38,

C-39, C-40, C-41, C-42, C-43, C-44, C-45 and C-46 to equal or exceed 10%. The

owner or operator shall not allow or cause the opacity from the fugitive Emission

Points E-109 and E-110 to equal or exceed 10%. (40 CFR 60.62 (c) and 40 CFR

63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall conduct a monthly 1-minute visible emissions test

on Stacks S-33 through S-41 in accordance with 40 CFR 60, Appendix A,

Method 22. The test must be conducted while the emission unit is in

operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-38, C-39, C-40, C-41, C-42, C-43, C44, C-45 and C-46 baghouses for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks
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iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.
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Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
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Emission Unit U-20 Description: Finish Mill No. 1

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

6.13 Standard of Performance for New 1, 2, 3.3, 4, 5, 6

Storage Vessels for Volitile Organic

Compounds

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1347 and 40 CFR 63.1348)
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Components:

Emission Point Description Control ID

E-115 Weigh Feeder (K-1001-1) fugitive emissions, no control

E-116 Weigh Feeder (K-1001-2) fugitive emissions, no control

E-117 Mill (K-1003) Baghouse C-47 (K-1012)

E-118 Elevator (K-1006) Baghouse C-47 (K-1012)

E-119 Separator (K-1008) Baghouse C-48 (K-1014)

E-120 Pump (K-1011) Baghouse C-48 (K-1014)

none Storage Tank - 2,000 gal N/A

(grinding aid) installed

1974

none Storage Tank - 12,000 gal N/A

(grinding aid) installed

1974

none Storage Tank - 12,000 gal N/A

(air entraining agent)

installed 1974

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-47 S-42 Baghouse See AC 2 N/A See AC 2 semiannual

C-48 S-43 Baghouse See AC 2 N/A See AC 2 semiannual
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Additional Conditions

1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-47

and C-48 to equal or exceed 10%. The owner or operator shall not allow or cause

the opacity from the fugitive Emission Points E-115 and E-116 to equal or exceed

10%. (40 CFR 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348)

b. VOC

The owner or operator of a VOC storage vessel with a capacity of 250 gallons or

more, and the material to be stored has a vapor pressure equal to or greater than 1.5

psia, shall equip the storage vessel with permanent submerged fill pipe. (Regulation

6.13, section 3.3)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. The owner or operator shall, for Emission points E-115 and E-116 conduct

a monthly 1-minute visible emissions test of this emission unit in accordance

with 40 CFR 60, Appendix A, Method 22. The test must be conducted while

the emission unit is in operation.

ii. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

iii. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain 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 shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.
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v. The owner or operator shall, for control device C-47 and C-48, monitor

opacity at stacks S-42 and S-43 by conducting daily visible emissions

observations of the mill sweep and air separator particulate matter control

devices, in accordance with procedures of 40 CFR 60, Appendix A, Method

22. The Method 22 test shall be conducted while the emission unit is

operating at the highest load or capacity level reasonably expected to occur

within the day. The duration of the Method 22 test shall be six minutes. If

visible emissions are observed during any Method 22 visible emissions test,

the owner or operator shall:

1) Initiate, within one-hour, the corrective actions specified in the site

specific operating and maintenance plan;

2) Conduct a Method 22 or Method 9 test after the corrective action is

completed. 

A) If no visible emissions are observed, return to monitoring

described above. 

B) If visible emissions are still observed, the owner or operator

shall, within 24 hours of the end of the Method 22 test in

which visible emissions were first observed, conduct a visible

emissions test of each stack from which visible emissions were

observed in accordance with procedures of 40 CFR 60,

Appendix A, Method 9. The duration of the Method 9 shall

be 30 minutes. 

g. The owner or operator shall test Stack S-42 once every five years using

Method 9. The test shall occur by no later than the end of the first quarter of

the fourth year of the permit. 

h. The owner or operator shall inspect C-47 and C-48 baghouses for the

following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.
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b. VOC

No compliance monitoring required, see comment 2.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. VOC

No compliance record keeping required, see comment 2.

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.

b. VOC
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No compliance reporting required, see comment 2.

Comment

1. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.

2. The VOC materials stored in the two grinding agent tanks and the one air entrainment agent

tank have vapor pressures much less than 1.5 psia. Therefore, even though the regulation

applies, there are no standards to meet. The air entrainment agent is a HAP, however there

are no standards or MACT for this emission point.

3. All three finish mills, emission units E-20 through E-22 draw from these three tanks.
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Emission Unit U-21 Description: Finish Mill No. 2

Applicable Regulations: 

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c), 40 CFR 63.1347 and 40 CFR 63.1348)
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Components:

Emission Point Description Control ID

E-121 Weigh Feeder (K-1016-1) fugitive emissions, no control

E-122 Weigh Feeder (K-1015-2) fugitive emissions, no control

E-123 Mill (K-1018) Baghouse C-49 (K-1012)

E-124 Elevator (K-1021) Baghouse C-49 (K-1012)

E-125 Separator (K-1023) Baghouse C-50 (K-1014)

E-126 Pump (K-1026-2) Baghouse C-50 (K-1014)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-49 S-44 Baghouse See AC 2 N/A See AC 2 semiannual

C-50 S-45 Baghouse See AC 2 N/A See AC 2 semiannual
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Additional Conditions

1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-49

and C-50 to equal or exceed 10%. The owner or operator shall not allow or cause

the opacity from the fugitive Emission Points E-121 and E-122 to equal or exceed

10%. (40 CFR 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall, for Emission points E-121 and E-122 conduct

a monthly 1-minute visible emissions test of this emission unit in accordance

with 40 CFR 60, Appendix A, Method 22. The test must be conducted while

the emission unit is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall, for control device C-49 and C-50, monitor

opacity at stacks S-44 and S-45 by conducting daily visible emissions

observations of the mill sweep and air separator particulate matter control

devices, in accordance with procedures of 40 CFR 60, Appendix A, Method

22. The Method 22 test shall be conducted while the emission unit is

operating at the highest load or capacity level reasonably expected to occur

within the day. The duration of the Method 22 test shall be six minutes. If
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visible emissions are observed during any Method 22 visible emissions test,

the owner or operator shall:

i. Initiate, within one-hour, the corrective actions specified in the site

specific operating and maintenance plan;

ii. Conduct a Method 22 or Method 9 test after the corrective action is

completed. 

1. If no visible emissions are observed, return to monitoring

described above. 

2. If visible emissions are still observed, the owner or operator

shall, within 24 hours of the end of the Method 22 test in

which visible emissions were first observed, conduct a visible

emissions test of each stack from which visible emissions were

observed in accordance with procedures of 40 CFR 60,

Appendix A, Method 9. The duration of the Method 9 shall

be 30 minutes. 

g. The owner or operator shall test Stack S-44 once every five years using

Method 9. The test shall occur by no later than the end of the first quarter of

the fourth year of the permit. 

f. The owner or operator shall inspect C-49 and C-50 baghouses for the

following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.
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3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.

Comment

1. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.

2. All three finish mills, emission units E-20 through E-22 draw from the three tanks in Emission

Unit E-20.
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Emission Unit U-22 Description: Finish Mill No. 3 for Kosmortar Mixing

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1347, 63.1348,

Cement Manufacturing Industry 63.1349, 63.1350, 63.1351,

63.1353, 63.1354, and

63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:
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Emission Point Description Control ID

E-127 Hopper (K-1100) Baghouse C-51 (K-1102)

E-128 Pump (K-1011) Baghouse C-51 (K-1102)

E-129 Lime Bin (K-1105) Baghouse C-52 (K-1103)

E-130 Mortar Silo (K-1106) Baghouse C-53 (K-1104)

E-131 Pump (K-1112) fugitive emissions, no control

E-132 Mortar Bin (K-1114) Baghouse C-54 (K-1113)

E-133 Ground Limestone Bin (K- Baghouse C-55 (K-1115)

1116)

E-134 Feed Screw (K-1127) Baghouse C-56 (K-1128)

E-135 Kosmos Mortar Mixing Baghouse C-56 (K-1128)

Mill (K-1129)

E-136 Pump (K-1130) Baghouse C-56 (K-1128)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-51 S-46 Baghouse See AC 2 N/A See AC 2 semiannual

C-52 S-47 Baghouse See AC 2 N/A See AC 2 semiannual

C-53 S-48 Baghouse See AC 2 N/A See AC 2 semiannual

C-54 S-49 Baghouse See AC 2 N/A See AC 2 semiannual

C-55 S-50 Baghouse See AC 2 N/A See AC 2 semiannual

C-56 S-51 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-51,

C-52, C-53, C-54, C-55 and C-56 to equal or exceed 10%. The owner or operator

shall not allow or cause the opacity from the fugitive Emission Point E-131 to equal

or exceed 10%. (40 CFR 60.62 (c) and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall, for Emission Point E-131 and stacks S-46, S47, S-48, S-49, S-50 and S-51 conduct a monthly 1-minute visible emissions

test of this emission unit in accordance with 40 CFR 60, Appendix A, Method

22. The test must be conducted while the emission unit is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall test Stack S-51 once every five years using

Method 9. The test shall occur by no later than the end of the first quarter of

the fourth year of the permit. 

f. The owner or operator shall inspect C-51, C-52, C-53, C-54, C-55 and C-56

baghouses for the following items:

i. Verify fan is running and belts are on, daily.
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ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)
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iv. Description of any corrective action taken pursuant to Additional Condition

2.

Comment

1. With the owner or operator agreement, it was decided to implement the Cement MACT

opacity monitoring procedures before the required compliance date.

2. All three finish mills, emission units E-20 through E-22 draw from the three tanks in Emission

Unit E-20.
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Emission Unit U-23 Description: Lime Slurry System

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Nonmetallic Sections 60.670, 60.671,

Subpart mineral Processing Plants 60.672, 60.675

OOO

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

7.02 Federal New Source Performance 1.72, 2, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity 10% (40 CFR 60.672(b))

Opacity 7% (40 CFR 60.672(a)(2))

PM 0.05 g/dscm (40 CFR 60.672(a)(1))

Components:

Emission Point Description Control ID

E-137 Tank (K-554) Baghouse C-57 (K-557)

E-138 Tank (K-555) Baghouse C-57 (K-557)

E-139 Tank (K-556) Baghouse C-57 (K-557)

E-140 Level Box (K-1540) fugitive emissions, no control

E-141 Truck Load Out (K-104) fugitive emissions, no control
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Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-57 S-52 Baghouse See AC 2 N/A See AC 2 semiannual
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Additional Conditions

1. Standards (40 CFR 60, Subpart OOO)

a. Opacity

i. The owner or operator shall not allow or cause the opacity from Emission

Points E-140 and E-141 to exceed 10%; (40 CFR 60.672 (b)) 

ii. The owner or operator shall not allow or cause the opacity from S-52 to

exceed 7%; (40 CFR 60.672 (a)(2)) 

b. PM

The owner or operator shall not allow PM emissions to exceed 0.05 g/dscm from S52.

2. Monitoring Requirements (Regulation 2.16, sections 4.1.9.1.2.)

a. Opacity

i. To demonstrate compliance with the opacity standard, the owner or operator

shall conduct a daily one-minute visible emissions survey, during normal

operation and daylight hours, of the fugitive PM Emission Points identified as

E-140 and E-141 and Stack S-52. No more than four Emission Points shall

be observed simultaneously.

ii. For Emission Points without observed visible emissions during twelve

consecutive operating weeks, the owner or operator may elect to conduct a

weekly one-minute visible emission survey, during normal operation and

daylight hours. No more than four Emission Points shall be observed

simultaneously.

iii. For Emission Points without observed visible emissions during twelve

consecutive operating weeks as per 2.a.ii, the owner or operator may elect to

conduct a monthly one-minute visible emission survey, during normal

operation and daylight hours. No more than four Emission Points shall be

observed simultaneously.

iv. At Emission Points where visible emissions are observed, the owner or

operator shall initiate corrective action within eight hours of the initial

observation. If the visible emissions persist, the owner or operator shall

perform or cause to be performed a Method 9 for stack emissions or Method

22 for fugitive emissions within 24 hours of the initial observation. If the

opacity standard is exceeded, the owner or operator shall report the

exceedance to the District, pursuant to Regulation 1.07, and take all
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practicable steps to eliminate the exceedance. Subsequent visible emission

surveys shall be conducted as indicated in 2.a.

iv. No visible emission survey needs to be performed if an Emission Point is not

being operated during a given day, week or month (as appropriate).

b. PM

The owner or operator shall inspect the C-57 baghouse for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collector for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

b. PM
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The owner or operator shall maintain records of:

i. the date and time of the inspection

ii. the name of the person conducting the inspection

iii. inspection findings

iv. any maintenance, bag replacement or repairs instituted

4. Reporting (Regulation 2.16, section. 4.1.9.3)

a. Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 22 conducted (or a negative

declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.

b. PM

No compliance reporting required

Comment

This facility is subject to subpart OOO because the product is not for cement production, it is sent

to clients off site. Because the source owns the limestone quarry, it follows that this facility is an

extension of the non-metallic mineral production. This is a continuation of the Emission Units 1 &

2 processes.
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Emission Unit U-24 Description: Rail / Barge Loading 

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)
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Components:

Emission Point Description Control ID

E-143 Silo 12 Baghouse C-58 (K-1420)

E-144 Pump (K-1424) Baghouse C-59 (K-1425)

E-145 Silos 4 thru 11 Baghouses C-60 thru C-62

(K-1450, K-1452 & K-1454)

E-146 Rail Car Load Spout (K- Baghouse C-63 (K-1487)

1485)

E-147 Diversion Bin (K-1490) Baghouse C-64 (K-1491)

E-148 Pump (K-1443) Baghouse C-59 (K-1425)

E-149 Surge Bin (K-1433) Baghouse C-65 (K-1431)

E-150 Pump (K-1438) Baghouse C-65 (K-1431)

E-151 Barge Baghouse C-66 (K-1430)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-58 S-53 Baghouse See AC 2 N/A See AC 2 semiannual

C-59 S-54 Baghouse See AC 2 N/A See AC 2 semiannual

C-60 S-55 Baghouse See AC 2 N/A See AC 2 semiannual

C-61 S-56 Baghouse See AC 2 N/A See AC 2 semiannual

C-62 S-57 Baghouse See AC 2 N/A See AC 2 semiannual

C-63 S-58 Baghouse See AC 2 N/A See AC 2 semiannual
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C-64 S-59 Baghouse See AC 2 N/A See AC 2 semiannual

C-65 S-61 Baghouse See AC 2 N/A See AC 2 semiannual

C-66 S-62 Baghouse See AC 2 N/A See AC 2 semiannual
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Additional Conditions

1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-58,

C-59, C-60, C-61, C-62, C-63, C-64, C-65 and C-66 to equal or exceed 10%. (40

CFR 60.62 (c) and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall, for stacks S-53, S-54, S-55, S-56, S-57, S-58,

S-59, S-61 and S-62 conduct a monthly 1-minute visible emissions test of this

emission unit in accordance with 40 CFR 60, Appendix A, Method 22. The

test must be conducted while the emission unit is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-58, C-59, C-60, C-61, C-62, C-63, C64, C-65 and C-66 baghouses for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.
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iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.
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Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.

 
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Emission Unit U-25 Description: Truck Loading

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:
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Emission Point Description Control ID

E-152 Silos 1 thru 3 Baghouse C-67 (K-1400)

E-153 Load Spout East (K-1410) Baghouse C-69 (K-1412)

E-154 Load Spout West (K-1406) Baghouse C-68 (K-1408)

Control Devices:

ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-67 S-63 Baghouse See AC 2 N/A See AC 2 semiannual

C-68 S-64 Baghouse See AC 2 N/A See AC 2 semiannual

C-69 S-65 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-67,

C-68 and C-69 to equal or exceed 10%. (40 CFR 60.62 (c) and 40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall, for stacks S-63, S-64 and S-65 conduct a

monthly 1-minute visible emissions test of this emission unit in accordance

with 40 CFR 60, Appendix A, Method 22. The test must be conducted while

the emission unit is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall inspect C-67, C-68, and C-69 baghouses for the

following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.

iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.
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v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.

Comment
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With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.

Emission Unit U-26 Description: Storage Silos (13 - 17) & Packaging

Applicable Regulations:
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FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

40 CFR 60 Standards of Performance for Portland Sections: 60.60, 60.61, 60.62,

Subpart F Cement Plants 60.63, 60.64, 60.65 & 60.66

40 CFR 63 General Provisions Sections: 63.1 thru 63.15,

Subpart A excluding 63.11

40 CFR 63 National Emission Standards For Sections: 63.1340, 63.1341,

Subpart LLL Hazardous Air Pollutants From Portland 63.1342, 63.1348, 63.1349,

Cement Manufacturing Industry 63.1350, 63.1351, 63.1353,

63.1354, and 63.1355 

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.02 Federal Emission Standards for Hazardous Sections: 2, 3, 4, and 5

Air Pollutants Incorporated by Reference

5.14 Hazardous Air Pollutants and Source Sections: 1, 2 and 3

Categories

7.02 Federal New Source Performance Sections: 1.162, 3, 4, 5

Standards Incorporated by Reference

Allowable Emissions:

Pollutant Limit/Standard

Opacity <10% (40 CFR 60.62(c) and 40 CFR 63.1348)

Components:
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Emission Point Description Control ID

E-155 Silos 13-17 Baghouse C-70 (K-1243)

E-156 Silos 13-17 Baghouse C-71 (K-1244)

E-157 Elevator (K-1206) Baghouse C-72 (K-1246)

E-158 Elevator (K-1229) Baghouse C-73 (K-1245)

E-159 Holding Bin (A) Baghouse C-73 (K-1245)

E-160 Surge Bin (A) Baghouse C-73 (K-1245)

E-161 Pack (K-1235) Baghouse C-73 (K-1245)

E-162 Holding Bin (B) Baghouse C-72 (K-1246)

E-163 Surge Bin (B) Baghouse C-72 (K-1246)

E-164 Packer (K-1217) Baghouse C-72 (K-1246)

E-165 Holding Bin (C) Baghouse C-74 (K-1247)

E-166 Surge Bin (C) Baghouse C-74 (K-1247)

E-167 Packer (K-1218) Baghouse C-74 (K-1247)

E-168 Truck Load Out Baghouse C-75 (K-1281)

Control Devices:
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ID Stack Description Performance Range Monitoring & Reporting

 ID Indicator Frequency Frequency

C-70 S-66 Baghouse See AC 2 N/A See AC 2 semiannual

C-71 S-67 Baghouse See AC 2 N/A See AC 2 semiannual

C-72 S-68 Baghouse See AC 2 N/A See AC 2 semiannual

C-73 S-69 Baghouse See AC 2 N/A See AC 2 semiannual

C-74 S-70 Baghouse See AC 2 N/A See AC 2 semiannual

C-75 S-71 Baghouse See AC 2 N/A See AC 2 semiannual

Additional Conditions
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1. Standards (Regulation 2.16, section 4.1.1)

Opacity

The owner or operator shall not allow or cause the opacity from the baghouses C-70,

C-71, C-72, C-73 C-74, and C-75 to equal or exceed 10%. (40 CFR 60.62 (c) and

40 CFR 63.1348)

2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity

a. The owner or operator shall, for stacks S-66 through S-71 conduct a monthly

1-minute visible emissions test of this emission unit in accordance with 40

CFR 60, Appendix A, Method 22. The test must be conducted while the

emission unit is in operation.

b. If no visible emissions are observed in six consecutive monthly tests, the

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

semi-annually for this emission unit. If visible emissions are observed during

any semi-annual test, the owner or operator shall resume testing on a monthly

basis and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during two consecutive tests from this

emission unit, the owner or operator may decrease the frequency of testing

from semi-annually to annually. If visible emissions are observed during any

annual test, the owner or operator shall resume testing on a monthly basis.

and maintain that schedule until no visible emissions are observed in six

consecutive monthly tests.

d. If visible emissions are observed during any Method 22 test, the owner or

operator shall conduct a 6-minute test of opacity in accordance with 40 CFR

60, Appendix A, Method 9. The Method 9 Test must begin within one hour

of any observation of visible emissions.

e. The owner or operator shall test Stacks S-66 and S-67 once every five years

using Method 9. The test shall occur by no later than the end of the first

quarter of the fourth year of the permit. 

f. The owner or operator shall inspect C-70, C-71, C-72, C-73, C-74, and C-75

baghouses for the following items:

i. Verify fan is running and belts are on, daily.

ii. Verify dampers are working properly daily.
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iii. Verify cleaning mechanism is working properly every two weeks

iv. Replace all worn bags as needed.

v. Verify bags are clean and not filled with dust every two weeks

vi. Verify dust removal system is working properly every two weeks, and

vii. Inspect area around collectors for signs of dust every two weeks.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

Opacity

The owner or operator shall maintain records of:

i. results of all visible emission surveys and tests performed

ii. the date and time of the survey

iii. the name of the person conducting the survey or test

iv. whether visible emissions were observed

v. a negative declaration may be entered in the record if an Emission Point is not

being operated during a given day, week or month (as appropriate)

4. Reporting (Regulation 2.16, section. 4.1.9.3) 

Opacity

The owner or operator shall include, at a minimum, the following information in the

semi-annual compliance monitoring reports for opacity:

i. Emission Unit ID number and Emission Point ID number or Stack ID number

ii. The beginning and ending date of the reporting period

iii. The date, time, and result of each Method 9 or Method 22 conducted (or a

negative declaration if none)

iv. Description of any corrective action taken pursuant to Additional Condition

2.
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Comment

With the owner or operator agreement, it was decided to implement the Cement MACT opacity

monitoring procedures before the required compliance date.
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Emission Unit U-29 Description: Gasoline Dispensing Facility

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

7.15 Standards of Performance for Gasoline Transfer 1,2, 3.1, 3.3, 3.8, 4, 5, 6

To New Service Station Storage Tanks (Stage 1

Vapor Recovery)

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.14 Hazardous Air Pollutants and Source Categories 1 and 2

Allowable Emissions:

Pollutant Limit/Standard

VOC See Additional Conditions 1, 2, and 3

Components:

Emission Point Description Control ID

E-171 4000 gallon Gasoline Stage I

Storage Tank &

Dispensing Facility
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Additional Conditions

1. Standards (Regulation 7.15)

a. The owner or operator shall install, maintain and operate the storage tank with a

submerged fill pipe, a vapor balance system and vapor tight connections on the liquid

fill and vapor return hoses. ( Regulation 7.15, sec. 3.1.1 and 3.14)

b. The owner or operator shall equip all fill tubes with vapor-tight covers including

gaskets. ( Regulation 7.15, sec. 3.8.1)

c. The owner or operator shall maintain all hoses, fittings, and couplings in a vapor-tight

condition. (Regulation 7.15, sec. 3.8.5)

2. Monitoring (Regulation 2.16, section 4.1.9.1.2)

The owner or operator shall perform a monthly visual inspection of this facility to assure that

gaskets, hoses and couplings are maintaining their vapor tight characteristics.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

The owner or operator shall maintain records of the monthly inspections performed. These

records shall include:

a. Date of inspection

b. Name of who performed the inspection

c. Findings of the inspection

d. Date of any remedial action

e. Description of the remedial action taken

4. Reporting (Regulation 2.16, section 4.1.9.3)

The owner or operator shall report, semi-annually, at a minimum, the following 

information:

a. Emission Unit ID number and Emission Point ID number or Stack ID number

b. The beginning and ending date of the reporting period

c. Remedial measures taken, should 3.e have an entry during the reporting

period.
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Emission Unit U-30 Description: Non-halogenated Cold Solvent Metal Cleaners

Applicable Regulations:

FEDERALLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

1.05 Compliance with Emission Standards and 1, 3, 4, 5

Maintenance Requirements

6.18 Standards of Performance for Existing 1, 2, 3, 4.1, 4.2

Solvent Metal Cleaning Equipment

DISTRICT ONLY ENFORCEABLE REGULATIONS

Regulation Title Applicable Sections

5.14 Hazardous Air Pollutants and Source 1, 2, 3, 4

Categories

5.11 Standards of Performance for Existing 1, 2, 3, 4, 5, 6

Sources Emitting Toxic Air Pollutants

Allowable Emissions:

Pollutant Limit/Standard

TAPs See Additional Condition # 3

VOC See Additional Condition #1 

Components:

Non-halogenated cold solvent metal cleaning tank, rated capacity of 30 gal, installed in 1994.

Fugitive emission point.
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Additional Conditions

1. Standards Regulation 2.16, section 4.1.1)

a. VOC

i. The cleaner shall be equipped with a cover. If the VOC volatility is greater

than 15 mm Hg measured at 100EF or if the VOC is agitated or heated, then

the cover shall be designed so that it can be easily operated with one hand.

ii. The cleaner shall be equipped with a drainage facility such that VOC that

drains off parts removed from the cleaner will return to the cleaner. If the

VOC volatility is greater than 32 mm Hg measured at 100EF, then the

drainage facility shall be internal so that parts are enclosed under the cover

while draining. The drainage facility may be external if the District determines

that an internal type cannot fit into the cleaning system.

iii. A permanent, conspicuous label summarizing the operating requirements

specified in 1.a.vi, vii, and viii shall be installed on or near the cleaner.

iv. If used, the VOC spray shall be a fluid stream (not a fine, atomized, or shower

type spray) at a pressure that does not cause excessive splashing.

v. If the VOC volatility is greater than 32 mm Hg measured at 100EF or if the

VOC is heated above 120EF, then one of the following control devices shall

be used:

1) Freeboard that gives a freeboard ratio equal to or greater than 0.7,

2) Water cover (VOC must be insoluble in and heavier than water), or

3) Other systems of equivalent control, such as a refrigerated chiller or

carbon absorption.

vi. Do not dispose of waste VOC or transfer it to another party in a manner that

more than 20% by weight of the waste VOC can evaporate into the

atmosphere. Store waste VOC only in covered containers,

vii. Close degreaser cover whenever not handling a part in the cleaner, and

viii. Drain cleaned parts until dripping ceases (15 seconds is usually necessary).

ix Operate a cold cleaning degreaser with a solvent vapor pressure that exceeds

1.0 mm Hg (0.019 psi) measured at 20EC (68EF).
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b. TAPs

Limit Toxic Air Pollutant (TAP) emissions from this source to no more than the

Adjusted Significance Level (ASL) specified in Regulations 5.11 and 5.12 for this

emission unit, unless modeling or a BACT/RACT analysis has been performed to

demonstrate compliance. 

2. Monitoring , Regulation 2.16, section 4.1.9.1.2)

a. VOC

See additional condition 3.a

b. TAPs

i. The owner or operator shall calculate average hourly TAP emissions, based

on records maintained for additional condition 3.a, to assure that the ASL has

not been exceeded.

ii. The owner or operator may submit a one time demonstration that the PTE for

TAP emissions from this facility can not exceed the calculated ASL. Such

submittal will negate additional conditions 3.b and 4.b.

3. Record Keeping (Regulation 2.16, section 4.1.9.2)

a. VOC

i. The owner or operator shall keep monthly records of VOC usage for each

emission point.

ii. The owner or operator shall:

1) The name and address of the solvent supplier,

2) The date of the purchase,

3) The type of the solvent, and

4) The vapor pressure of the solvent measured in mm Hg at 20EC

(68EF).

iii. The owner or operator shall maintain records of employee training for the

proper operation of this emission unit. These records shall contain:

1) The date of the training

2) The name of the person trained

3) Who performed the training

b. TAPs
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Based on 3.a, the owner or operator shall, on a monthly basis, calculate hourly TAP

emissions to demonstrate compliance with additional condition 1.b.

4. Reporting (Regulation 2.16, section 4.1.9.3)

The owner or operator shall clearly identify all deviations from permit requirements in the

semi-annual reports. All reports shall be certified by a responsible official as defined in

Regulation 2.16, section 2.36. If no deviations occur in that reporting period then the owner

or operator shall report a negative declaration for each of the following categories.

a. VOC

The owner or operator shall report semi-annually the following for each emission

point:

i. Emission Unit ID number and Emission point ID number

ii. The beginning and ending date of the reporting period

iv. Identification of applicable equipment standard or record

v. A declaration that the equipment standard or record is being maintained

b. TAPs

The owner or operator shall report any occurrence where the calculated ASL was

exceeded. 
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Nox RACT Plan

Amendment 1

1. The oxides of nitrogen (NO , expressed as NO ) emission from the cement kiln shall not x 2

exceed 6.6 pounds per ton of clinker produced by the kiln, based upon a rolling 30-day

average.

2. The NOx emission rate for the cement kiln shall be determined using the methods and

procedures specified in NO RACT Plan Appendix A - Amendment 1 and Appendix B - x

Amendment 1.

3. The Kosmos Cement Company (Kosmos) shall install, calibrate, maintain, and operate a NOx

continuous emissions monitoring system (CEMS) for the cement kiln and shall keep records

and submit reports and other notifications as specified in NO RACT Plan Appendix A - x

Amendment 1 and Appendix B - Amendment 1 .

4. Kosmos shall keep a record identifying all deviations from the requirements of this NOx

RACT Plan and shall submit to the District a written report of all deviations that occurred

during the preceding semi-annual period. Semi-annual periods shall run from January 1 to

June 30 and July 1 to December 31. The semi-annual report shall contain the information

specified in NOx RACT Plan Appendix A - Amendment 1 Section II. A. and B. If no

deviation occurred during the semi-annual period, the report shall contain a negative

declaration. Each report shall be submitted within 60 days following the end of the semiannual period.

5. In lieu of the requirements in this NOx RACT Plan, Kosmos may comply with alternative

requirements regarding emission limitations, equipment operation, test methods, monitoring,

record keeping, or reporting, provided the following conditions are met:

a. The alternative requirements are established and incorporated into an operating permit

pursuant to a Title V Operating Permit issuance, renewal, or significant permit

revision process as established in Regulation 2.16,

b. The alternative requirements are consistent with the streamlining procedures and

guidelines set forth in section II.A. of White Paper Number 2 for Improved

Implementation of the Part 70 Operating Permits Program, March 5, 1996, U.S.

Environmental Protection Agency, Office of Air Quality Planning and Standards. The

overall effect of compliance with alternative requirements shall consider the effect on

an intrinsic basis, such as pounds per ton of clinker produced by the kiln,

c. The U.S. Environmental Protection Agency (EPA) has not objected to the issuance,

renewal, or revision of the Title V Operating Permit, and either

d. If the public comment period preceded the EPA review period, then the District had

transmitted any public comments concerning the alternative requirements to EPA with

the proposed permit, or

e. If the EPA and public comment periods ran concurrently, then the District had

transmitted any public comments concerning the alternative requirements to EPA no

later than 5 working days after the end of the public comment period.
Permit No. 156-97-TV Plant ID 0060

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The District's determination of approval of any alternative requirements is not binding on

EPA. Noncompliance with any alternative requirement established pursuant to the Title V

Operating Permit process constitutes a violation of this NO RACT Plan. x
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Appendix A to NOx RACT Plan

 Amendment 1

Requirements for NOx CEMS

1. General Operating Requirements

a. Kosmos shall install, calibrate, maintain, and operate a continuous emissions

monitoring system (CEMS) for measuring oxides of nitrogen (NO ) emissions x

discharged to the atmosphere from the cement kiln and record the output of the

system.

b. The NO CEMS shall be operated and data recorded during all periods of x

operation of the cement kiln except for CEMS breakdowns and repairs. Data shall

be recorded during calibration checks and zero and span adjustments.

c. The 1-hour average NOx emission rates measured by the CEMS shall be expressed

in pounds per ton of clinker produced by the cement kiln and shall be used to

calculate the average emission rates. At least 2 data points shall be used to

calculate each 1-hour average. 

d. The NOx rates expressed in pounds per ton of clinker produced shall be calculated

using the exhaust flow rate of 233,500 dry standard cubic feet per minute. As an

alternative, the NO emission rates may be calculated using exhaust flow rates x

obtained by a flow measuring monitor as approved by the District. A flow

measuring monitor shall meet the requirements in NO RACT Plan Appendix B - x

Amendment 1.

e. The procedures under 40 CFR §60.13 (d), (e), (f), and (h) shall be followed for

installation, evaluation, and operation of the CEMS.

f. The NOx CEMS shall be installed and operated in compliance with the

requirements of 40 CFR Part 60 Appendix B Performance Specification 2 and the

quality assurance and certification requirements of Performance Specification 2

shall be met as well as the requirements in this Appendix.

g. The span value for the NOx CEMS shall be determined so that all expected

concentrations can be accurately measured and recorded as indicated in NOx

RACT Plan Appendix B - Amendment 1.

h. The Quality Assurance Procedures in 40 CFR Part 60 Appendix F shall be

followed. All reporting required by 40 CFR Part 60 Appendix F to be submitted to

the Agency shall instead be submitted to the District.

i. When NO emission data or flow monitor data (if a flow monitor is used) are not x

obtained because of CEMS breakdowns, repairs, calibration checks, or zero and

span adjustments, emission data shall be obtained by using one of the following

options to provide emission data for a minimum of 75% of the operating hours in
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each kiln operating day, in at least 22 out of 30 successive cement kiln operating

days:

i. Standby monitoring systems, 40 CFR Part 60 Appendix A Method 7 or

Method 7a, or other approved reference methods, or

ii. Data substitution as follows:

A) If the missing data period is 6 hours or less, then substitute an

average of the quality-assured data from the hour immediately

before and the hour immediately after the missing data period for

each hour of missing data, and

B) If the missing data period is greater than 6 hours, then substitute the

greatest emission rate or flow (if a flow monitor is used) recorded

during the previous 168 quality-assured monitor operating hours at

a clinker production rate that is within 10% of the current operating

rate. If there are not enough data to satisfy this requirement, then

substitute data from a higher clinker production rate or the

maximum design flow or emission rate.

All “estimated” data shall be reported with a clear notation that they are

estimated and not obtained from a certified monitor or EPA-approved test

method.

j. The clinker production rate shall be determined and recorded during all periods of

operation of the cement kiln except for breakdowns and repairs of the system used

to determine the clinker production rate (raw materials weigh feeder and

associated data acquisition system). Data shall be recorded during periods of

calibration for the weigh feeder, which at a minimum shall be performed annually.

k. The clinker production rate determined from monitoring the rate of raw materials

input to the cement kiln shall be calculated by dividing the rate of raw materials

input to the cement kiln by the current raw materials conversion factor. The raw

materials conversion factor shall be determined on a quarterly basis and this

conversion factor shall be used in the calculation of the clinker production rate

until the next quarterly raw materials conversion rate test is performed. The raw

materials conversion rate factor shall be determined by weighing and recording the

raw materials input to the cement kiln with the weigh feeder and weighing and

recording the clinker output from the cement kiln with the use of a certified scale

over a four- to twelve-hour period and an average calculated from those data. The

current raw materials conversion factor shall be included with the semi-annual

emissions report.

l. If a flow monitor is used in the determination of the pounds NO per ton of clinker x

produced by the cement kiln, then the flow monitoring system shall meet all the

requirements specified in NO RACT Plan Appendix B - Amendment 1. x

m. The data acquisition and handling system used in recording and reporting the

necessary information required for the determination of compliance with the limit

set for the pounds of NO per ton of clinker produced by the cement kiln shall x
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meet all of the requirements specified in NO RACT Plan Appendix B - x

Amendment 1.

n. A monitoring plan shall be created and kept current for the system used to

determine compliance with the pounds of NOx per ton of clinker produced by the

cement kiln limit. The most current version of the monitoring plan shall be

submitted to the District and also be easily accessed by the monitoring system

operation personnel.

2. Reporting and record keeping requirements

a. Kosmos shall keep records and submit semi-annual reports for each operating day

including the following information:

i. Calendar date,

ii. The average hourly NO emission rates measured, expressed as pounds per x

ton of clinker produced by the cement kiln,

iii. The 30-day average NOx emission rates, expressed as pounds per ton

clinker produced by the cement kiln, calculated at the end of each cement

kiln operating day from the measured hourly nitrogen oxide emission rates

for the preceding 30 cement kiln operating days. The average shall not

include data recorded during periods of CEMS breakdowns, repairs,

calibration checks, and zero and span adjustments,

iv. Identification of the cement kiln operating days when the calculated rolling

30-day average NO emission rates are in excess of the NO emissions x x

standard of the NO RACT Plan - Amendment 1. Kosmos shall submit x

excess emission reports for any excess emissions that occurred during the

reporting period. This report shall include the magnitude of the excess

emissions in pounds per ton of clinker produced and the date and time of

the commencement and completion of each period of excess emissions as

well as the nature and cause of each period of excess emissions and any

corrective actions taken or preventive measures adopted,

v. Identification of the cement kiln operating days for which pollutant data

have not been obtained, including reasons for not obtaining sufficient data

and a description of corrective actions taken,

vi. Identification of the times when emission data have been excluded from the

calculation of average emission rates, the reasons for excluding data, and

description of corrective action taken,

vii. Identification of times when hourly averages have been obtained based on

40 CFR Part 60 Appendix A Method 7 or Method 7a,

viii. Identification of times which the CEMS (including all monitors) was

inoperative, including the date and time and the nature of the system

repairs or adjustments except for zero and span checks,

ix. Identification of the times when the pollutant concentration exceeded full

span of the CEMS,

x. Description of any modifications to the CEMS that could affect the ability

of the CEMS to comply with 40 CFR Part 60 Appendix B Performance

Specification 2,
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xi. Results of daily CEMS drift tests and quarterly accuracy assessments as

required under 40 CFR Part 60 Appendix F Procedure 1,

xii. Results of the quarterly raw materials conversion factor testing, and

xiii. Clinker production rates used to determine the pounds of NO per ton of x

clinker produced by the cement kiln.

All semi-annual reports and Summary Reports shall be postmarked by the 60th day

following the end of each semi-annual period.

b. Kosmos shall submit a Summary Report with every semi-annual report. The

Summary Report shall be in the format given in 40 CFR §60.7 Figure 1.

c. All records required by this NOx RACT Plan - Amendment 1 shall be maintained

by Kosmos for a period of 5 years following the date of such record. 
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NOx RACT Plan Appendix B

Amendment 1

Requirements for Flow Monitors

and Additional Requirements for NOx CEMS

1. Installation of the Flow Monitor

Install the flow monitor in a location that provides representative volumetric flow over all

operating conditions. Such a location is one that provides an average velocity of the flue gas

flow over the stack or duct cross section, provides a representative NOx emission rate (in

lb/ton of clinker produced by the cement kiln), and is representative of the pollutant

concentration monitor location. Where the moisture content of the flue gas affects volumetric

flow measurements, use the procedures in both Reference Methods 1 and 4 of 40 CFR Part

60 Appendix A to establish a proper location for the flow monitor. The District recommends

(but does not require) performing a flow profile study following the procedures in 40 CFR

Part 60 Appendix A Method 1 section 2.5 or 2.4 for each of the three operating or load levels

indicated in section 5.b. to determine the acceptability of the potential flow monitor location

and to determine the number and location of flow sampling points required to obtain a

representative flow value. The procedure in 40 CFR Part 60 Appendix A Test Method 1

section 2.5 may be used even if the flow measurement location is greater than or equal to 2

equivalent stack or duct diameters downstream or greater than or equal to 1⁄2 duct diameter

upstream from a flow disturbance. If a flow profile study shows that cyclonic (or swirling)

or stratified flow conditions exist at the potential flow monitor location that are likely to

prevent the monitor from meeting the performance specifications of this Appendix, then the

District recommends either (1) selecting another location where there is no cyclonic (or

swirling) or stratified flow condition or (2) eliminating the cyclonic (or swirling) or stratified

flow condition by straightening the flow, e.g., by installing straightening vanes. The District

also recommends selecting flow monitor locations to minimize the effects of condensation,

coating, erosion, or other conditions that could adversely affect flow monitor performance.

2. Acceptability of Monitor Location 

If the flow monitor is installed in a location that does not satisfy these physical criteria, but

nevertheless the monitor achieves the performance specifications of this Appendix, then the

location is acceptable, notwithstanding the requirements of this Appendix.

Whenever Kosmos successfully demonstrates that modifications to the exhaust duct or stack

(such as installation of straightening vanes, modifications of ductwork, and the like) are

necessary for the flow monitor to meet the performance specifications, the District may

approve an interim alternative flow monitoring methodology and an extension to the required

certification date for the flow monitor.

Where no location exists that satisfies the physical siting criteria in the previous two

paragraphs, where the results of flow profile studies performed at two or more alternative

flow monitor locations are unacceptable, or where installation of a flow monitor in either the

stack or the ducts is demonstrated to be technically infeasible, Kosmos may petition the

District for an alternative method for monitoring flow.
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3. Equipment Specifications

a. Instrument Span

To the extent practicable, measure at a range such that the majority of readings

obtained during normal operation are between 25 and 75 percent of full-scale range

of the instrument. Select the full-scale range of the flow monitor so that it can

accurately measure all potential volumetric flow rates at the flow monitor installation

site. For this purpose, determine the span value of the flow monitor using the

following procedure:

i. Determine the MPV or maximum potential flow rate (MPF) in scfh (wet

basis) from velocity traverse testing.

ii. Use the highest velocity measured at or near the maximum unit operating

load.

iii. Calculate the MPV in units of wet standard fpm.

iv. Then, if necessary, convert the MPV to equivalent units of flow rate (e.g.,

scfh or kscfh) or differential pressure (inches of water), consistent with the

measurement units used for the daily calibration error test to calculate the

span value.

v. Multiply the MPV (in equivalent units) by 125 percent, and round up the

result to no less than 2 significant figures.

vi. Report the full-scale range setting, and calculations of the span value, MPV,

and MPF to the District and include this information in the monitoring plan.

If conditions change such that the maximum potential velocity may change

significantly, adjust the range to assure the continued accuracy of the flow monitor.

Calculate an adjusted span using the procedures in this section. Select the full-scale

range of the instrument to be greater than or equal to the adjusted span value. Record

and report the new full-scale range setting, calculations of the span value, MPV, and

MPF, and the adjusted span value to the District and include this information in the

monitoring plan. Record and report the adjusted span and reference values as parts

of the records for the calibration error test. Whenever the span value is adjusted, use

reference values for the calibration error test based on the most recent adjusted span

value. 

Perform a calibration error test according to section 3.ii. whenever making a change

to the flow monitor span or range. Recertification is required whenever making a

significant change in the flow monitor's range that requires an internal modification

to the monitor.

b. Design for Quality Control Testing

i. Design of the Flow Monitor

Design all the flow monitors to meet the applicable performance

specifications.

ii. Calibration Error Test
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Design and equip each flow monitor to allow for a daily calibration error test

consisting of at least two reference values:

A) Zero to 20 % of span or an equivalent reference value (e.g., pressure

pulse or electronic signal) and

B) 50 to 70 % of span. Flow monitor response, both before and after any

adjustment, must be recorded.

 Design each flow monitor to allow a daily calibration error test of

A) the entire flow monitoring system, from and including the probe tip

(or equivalent) through and including the data acquisition and

handling system, or

B) the flow monitoring system from and including the transducer through

and including the data acquisition and handling system.

iii. Interference Check

A) Design and equip each flow monitor with a means to ensure that the

moisture expected to occur at the monitoring location does not

interfere with the proper functioning of the flow monitoring system.

Design and equip each flow monitor with a means to detect, on at

least a daily basis, pluggage of each sample line and sensing port, and

malfunction of each resistance temperature detector (RTD),

transceiver, or equivalent. 

B) Design and equip each differential pressure flow monitor to provide

(1) an automatic, periodic back purging (simultaneously on both

sides of the probe) or equivalent method of sufficient force

and frequency to keep the probe and lines sufficiently free of

obstructions on at least a daily basis to prevent velocity

sensing interference, and

 (2) a means for detecting leaks in the system on at least a

quarterly basis (manual check is acceptable). 

C) Design and equip each thermal flow monitor with a means to ensure

on at least a daily basis that the probe remains sufficiently clean to

prevent velocity sensing interference. 

D) Design and equip each ultrasonic flow monitor with a means to ensure

on at least a daily basis that the transceivers remain sufficiently clean

(e.g., backpurging system) to prevent velocity sensing interference. 

4. Performance Specifications

a. Calibration Error

The calibration error of flow monitors shall not exceed 3.0 % based upon the span of

the instrument as calculated using Equation A-6 of 40 CFR Part 75 Appendix A.

b. Relative Accuracy for Flow

The relative accuracy of flow monitors shall not exceed 10.0 %. Where the average

of the flow monitor measurements of gas velocity during one or more operating levels

of the relative accuracy test audit is less than or equal to 10.0 fps, the mean value of

the flow monitor velocity measurements shall not exceed ±2.0 fps of the reference
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method mean value in fps wherever the relative accuracy specification above is not

achieved.

5. Certification Testing

a. Flow Monitor 7-day Calibration Error Test

Measure the calibration error of each flow monitor according to the following

procedures:

i. Introduce the reference signal corresponding to the values specified in

section 3.ii.B) to the probe tip (or equivalent) or to the transducer.

ii. During the 7-day certification test period, conduct the calibration error test

while the cement kiln is operating once each operating day (as close to

24-hour intervals as practicable). In the event that extended cement kiln

outages occur after the commencement of the test, the 7 consecutive

operating days need not be 7 consecutive calendar days.

iii. Record the flow monitor responses by means of the data acquisition and

handling system.

iv. Calculate the calibration error using Equation A-6 of 40 CFR Part 75

Appendix A.

v. Do not perform any corrective maintenance, repair, or replacement upon the

flow monitor during the 7-day certification test period other than that required

for normal daily operation as specified by the monitor manufacturer or by the

NO RACT Plan - Amendment 1. x

vi. Do not make adjustments between the zero and high reference level

measurements on any day during the 7-day test.

vii. If the flow monitor operates within the calibration error performance

specification (i.e., less than or equal to 3 % error each day and requiring no

corrective maintenance, repair, or replacement during the 7-day test period)

the flow monitor passes the calibration error test portion of the certification

test.

viii. Record all maintenance activities and the magnitude of any adjustments.

ix. Record output readings from the data acquisition and handling system before

and after all adjustments.

x. Record and report all calibration error test results using the unadjusted flow

rate measured in the calibration error test prior to resetting the calibration.

xi. Record all adjustments made during the 7-day period at the time the

adjustment is made and report them in the certification application.

b. Relative Accuracy 

i. Perform relative accuracy test audits for the flow monitor at three different

exhaust gas velocities, expressed in terms of percent of flow monitor span, or

different operating levels. Select the operating levels as follows:

A) A frequently used low operating level selected within the range

between the minimum safe and stable operating level and 50 % load,
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B) A frequently used high operating level selected within the range

between 80 % of the maximum operating level and the maximum

operating level, and 

C) The normal operating level.

ii. If the normal operating level is within 10.0 % of the maximum operating level

of either A) or B) above, use a level that is evenly spaced between the low and

high operating levels used. The maximum operating level shall be equal to the

design capacity less any physical or regulatory limitations or other deratings.

Calculate flow monitor relative accuracy at each of the three operating levels.

If a flow monitor fails the relative accuracy test on any of the three levels of

a three-level relative accuracy test audit, the three-level relative accuracy test

audit shall be repeated.

iii. If the kiln is normally operated at only one level, then it is acceptable to

perform relative accuracy test audits at the normal operating level only. 

c. Calculations

Using the data from the relative accuracy test audits, calculate relative accuracy in

accordance with the procedures and equations specified in section VI.

d. Reference Method Measurement Location

Select a location for reference method measurements that is 

i. accessible,

ii. in the same proximity as the monitor or monitoring system location, and

iii. meets the requirements of Method 1 (or 1A) in 40 CFR Part 60 Appendix A

for volumetric flow, except as otherwise indicated in this section or as

approved by the District.

e. Reference Method Traverse Point Selection

Select traverse points that:

i. Ensure acquisition of representative samples of flue gas flow rate over the

flue cross section, and

ii. Meet the requirements of 40 CFR Part 60 Appendix A Method 1 (or 1A)(for

volumetric flow).

f. Sampling Strategy

Conduct the reference method tests so they will yield results representative of the flue

gas flow rate from the cement kiln and can be correlated with the flow monitor CEMS

measurements. To properly correlate the volumetric flow rate data with the reference

method data, mark the beginning and end of each reference method test run (including

the exact time of day) on the individual chart recorder or other permanent recording

device. 
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g. Correlation of Reference Method and Continuous Emission Monitoring System

i. Confirm that the monitor or monitoring system and reference method test

results are on consistent moisture basis (e.g., since the flow monitor measures

flow rate on a wet basis, Method 2 test results shall also be on a wet basis).

ii. Compare flow-monitor and reference method results on an scfh basis. Also,

consider the response times of the flow monitoring system to ensure

comparison of simultaneous measurements. 

iii. For each relative accuracy test audit run, compare the measurements obtained

from the monitor or continuous emission monitoring system against the

corresponding reference method values. Tabulate the paired data in a table

such as the one shown in Figure 2 of 40 CFR Part 75 Appendix A.

h. Number of Reference Method Tests

Perform a minimum of 9 sets of paired monitor (or monitoring system) and reference

method test data for every required relative accuracy test. For the certification and

annual quality assurance relative accuracy test audits for flow monitors, perform a

minimum of 9 sets at each operating level as specified in section e.ii. Conduct each

set within a period of 30 to 60 minutes. 

Note: The tester may choose to perform more than 9 sets of reference method tests.

If this option is chosen, the tester may reject a maximum of 3 sets of the test

results as long as the total number of test results used to determine the relative

accuracy or bias is greater than or equal to 9. Report all data, including the

rejected data, and reference method test results.

i. Reference Methods

The following methods from 40 CFR Part 60 Appendix or their approved alternatives

are the reference methods for performing relative accuracy test audits: Method 1 or

1A for siting; Method 2 (or 2A, 2C, or 2D) for velocity , and Method 4 for moisture.

6. Calculations

a. Flow Monitor Calibration Error

For each reference value, calculate the percentage calibration error based upon span

using the equation A-6 as given in 40 CFR Part 75 Appendix A.

b. Relative Accuracy for Flow Monitors

Analyze the relative accuracy test audit data from the reference method test for flow

monitors using the following procedures:

i. Summarize the results on a data sheet. An example is shown in Figure 3 of

40 CFR Part 75 Appendix A. 

ii. Calculate the mean of the monitor or monitoring system measurement values.

iii. Calculate the mean of the reference method values.

iv. Using data from the source CEMS, calculate the arithmetic differences

between the reference method and monitor measurement data sets.

v. Calculate the arithmetic mean of the difference, the standard deviation, the

confidence coefficient, and the monitor or monitoring system relative accuracy
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using the procedures and equations found in 40 CFR Part 75 Appendix A as

is specified in the following sections.

c. Arithmetic Mean

Calculate the arithmetic mean of the differences using equation A-7 as given in 40

CFR Part 75 Appendix A.

d. Standard Deviation

Calculate the standard deviation of a data set using equation A-8 as given in 40 CFR

Part 75 Appendix A.

e. Confidence Coefficient

Calculate the confidence coefficient using equation A-9 as given in 40 CFR Part 75

Appendix A.

f. Relative Accuracy

Calculate the relative accuracy of a data set using equation A-10 as given in 40 CFR

Part 75 Appendix A.

7. Quality Assurance and Quality Control

a. Calibration Error Test

Perform the daily calibration error test of each flow monitoring system according to

the procedure in this section.

i. Perform the daily calibration error tests on each scale that has been used since

the previous calibration error test. For example, if the flow has not exceeded

the low scale value (based on the maximum expected concentration) since the

previous calibration error test, the calibration error test may be performed on

the low scale only. If, however, the flow has exceeded the low scale span

value for one hour or longer since the previous calibration error test, perform

the calibration error test on both the low and high scales.

ii. All daily calibration error tests shall be performed while the unit is in

operation at normal, stable conditions (i.e. "on-line").

b. Daily Flow Interference Check

Perform the daily flow monitor interference checks specified in section 3.b.iii. while

the unit is in operation at normal, stable conditions. 

c. Recalibration

The District recommends adjusting the calibration, at a minimum, whenever the daily

calibration error exceeds the limits of the applicable performance specification for the

flow monitor in section IV.

d. Out-of-Control Period

i. An out-of-control period occurs when the calibration error of a flow monitor

exceeds 6.0 % based upon the span value, which is twice the applicable

specification of this section. The out-of-control period begins with the hour
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of completion of the failed calibration error test and ends with the hour of

completion following an effective recalibration. Whenever the failed

calibration, corrective action, and effective recalibration occur within the same

hour, the hour is not out of control if 2 or more valid readings are obtained

during that hour.

ii. An out-of-control period also occurs whenever interference of a flow monitor

is identified. The out-of-control period begins with the hour of completion of

the failed interference check and ends with the hour of completion of an

interference check that is passed. 

e. Quality Assurance of Data With Respect to Daily Assessments

When a monitoring system passes a daily assessment (i.e., daily calibration error test

or daily flow interference check), data from that monitoring system are prospectively

validated for 26 clock hours (i.e., 24 hours plus a 2-hour grace period) beginning with

the hour in which the test is passed, unless another assessment (i.e. a daily calibration

error test, an interference check of a flow monitor, or a relative accuracy test audit)

is failed within the 26-hour period.

f. Data Invalidation with Respect to Daily Assessments

Data from a monitoring system are invalid beginning with the first hour following the

expiration of a 26-hour data validation period.

g. Daily Assessment Start-Up Grace Period

For the purpose of quality assuring data with respect to a daily assessment (i.e. a daily

flow interference check), a start-up grace period may apply when a unit begins to

operate after a period of non-operation. The start-up grace period for a daily

calibration error test is independent of the start-up grace period for a daily flow

interference check. To qualify for a start-up grace period for a daily assessment, there

are two requirements:

i. The unit must have resumed operation after being in outage for 1 or more

hours (i.e., the unit must be in a start-up condition) as evidenced by a change

in unit operating time from zero in one clock hour to an operating time greater

than zero in the next clock hour, and

ii. For the monitoring system to be used to validate data during the grace period,

the previous daily assessment of the same kind must have been passed on-line

within 26 clock hours prior to the last hour in which the unit operated before

the outage. In addition, the monitoring system must be in-control with

respect to quarterly and semi-annual or annual assessments.

If both of the above conditions are met, then a start-up grace period of up to 8 clock

hours applies, beginning with the first hour of unit operation following the outage.

During the start-up grace period, data generated by the monitoring system are

considered quality-assured. For each monitoring system, a start-up grace period for

a calibration error test or flow interference check ends when either:

i. A daily assessment of the same kind (i.e., calibration error test or flow

interference check) is performed, or 

ii. 8 clock hours have elapsed (starting with the first hour of unit operation

following the outage), whichever occurs first.
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h. Data Recording

Record and tabulate all calibration error test data according to month, day,

clock-hour, and magnitude in scfh. Program monitors that automatically adjust data

to the corrected calibration values (e.g., microprocessor control) to record either:

i. The unadjusted flow rate measured in the calibration error test prior to

resetting the calibration, or

ii. The magnitude of any adjustment.

Record the following applicable flow monitor interference check data:

i. Sample line/sensing port pluggage, and

ii. Malfunction of each RTD, transceiver, or equivalent.

8. Quarterly Assessments

For a differential pressure flow monitor or flow monitoring system, perform a leak check of

all sample lines (a manual check is acceptable) during each unit operating quarter. This

requirement is effective as of the calendar quarter following the calendar quarter in which the

flow monitor or flow emission monitoring system is provisionally certified.

9. Annual Assessments

For the flow monitor, perform the relative accuracy test audit (RATA) assessment once

annually (within four calendar quarters) after the calendar quarter in which the monitor or

monitoring system was last tested, as specified below for the type of test and the performance

achieved. This requirement is effective as of the calendar quarter following the calendar

quarter in which the monitor or continuous monitoring system is provisionally certified.

a. Relative Accuracy Test Audit (RATA)

Perform relative accuracy test audits annually and, to the extent practicable, no less

than 4 months apart for the flow monitor. The three-level audit shall be performed

at the three different operating or load levels specified in V.B. 

b. Out-of-Control Period

An out-of-control period occurs under any of the following condition : the relative

accuracy of a flow monitor exceeds 10.0 %, for low flow situations (£10.0 fps) or the

flow monitor mean value (if applicable) exceeds ±2.0 fps of the reference method

mean whenever the relative accuracy is greater than 15.0 %. For a flow relative

accuracy test audit at 3 operating levels, the out-of-control period begins with the

hour of completion of the first failed relative accuracy test audit at any of the three

operating levels, and ends with the hour of completion of a satisfactory three-level

relative accuracy test audit. 

10. Other Audits

Affected units may be subject to relative accuracy test audits at any time. If a monitor or

continuous emission monitoring system fails the relative accuracy test during the audit, the

monitor or continuous emission monitoring system shall be considered to be out-of-control
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beginning with the date and time of completion of the audit, and continuing until a successful

audit test is completed following corrective action.

11. Span Determination for the NOx Monitor

a. To the extent practicable, measure the NOx emissions at a range such that the majority

of readings obtained during normal operation are between 25 and 75 % of full-scale

range of the instrument. 

b. Maximum Potential Concentration

i. The monitor must be capable of accurately measuring up to 125 % of the

maximum potential concentration (MPC) as determined below in this section.

To determine the maximum potential concentration, Kosmos may use NOx

emission test results or historical fully quality assured CEMS data over the

previous 30 unit operating days. Multiply the MPC by 125 % and round up

to the nearest multiple of 100 ppm to determine the span value. The span

value shall be used to determine the concentrations of the calibration gases.

ii. Report the full-scale range setting and calculations of the MPC, maximum

potential NOx emission rate, and span to the District and record them in the

monitoring plan. Select the full-scale range of the instrument to be consistent

with section 11.a, and to be greater than or equal to the span value. This

selected monitor range with a span rounded up from 125 % of the maximum

potential concentration shall be the "high scale" of the NO pollutant x

concentration monitor.

iii. If NOx emission testing is used to determine the maximum potential NOx

concentration, use the following guidelines:

A) Use Method 7E from 40 CFR Part 60 Appendix A to measure total

NO concentration. x

B) Operate the unit at the minimum safe and stable production level, the

normal production level, and the maximum production level. If the

normal load and maximum load are identical, an intermediate level

need not be tested.

C) Operate at the highest excess O level expected under normal 2

operating conditions.

D) Make at least 3 runs with 3 traverse points of at least 20 minutes

duration at each operating condition.

E) Select the highest NOx concentration from all measured values as the

maximum potential concentration for NOx. If historical CEM data are

used to determine the MPC, the data must represent various operating

conditions, including the minimum safe and stable production level,

normal production level, and production level load.

F) Calculate the MPC and span using the highest hourly NOx

concentration in ppm. 

c. Maximum Expected Concentration
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i. If the majority of NOx concentrations are expected to be less than 25 % of the

full-scale range of the instrument selected under section 11.b, use a "low

scale" measurement range.

ii. Calculate the span for the additional (lower) range by multiplying the

maximum expected concentration by 125 % and by rounding up the resultant

concentration to the nearest multiple of 10 ppm. The span value of this

additional (lower) range shall also be used to determine the concentrations of

the calibration gases.

iii. Include the full-scale range setting and calculations of the MEC and span and

report these to the District and record them in the monitoring plan.

iv. Select the full scale range of the instrument to be consistent with section

XI.A., and to be greater or equal to the lower range span value. This selected

monitor range with a span rounded up from 125 % of the maximum expected

concentration is the "low scale" of NO pollutant concentration monitors. x

d. Auto-ranging monitors 

For monitors that can continuously and automatically adjust their range of

measurement, the monitor shall be capable at any time of accurately measuring up to

125 % of the maximum potential concentration as defined in section 11.ii. Define the

span value for an auto-ranging monitor as 125 % of the maximum potential

concentration and 125 % of the maximum expected concentration if a second span is

determined to be necessary under section 11.iii. Determine concentrations of the

calibration gases based upon the span value.

e. Adjustment of Span

i. Whenever the fuel supply, emission controls, or other process parameters

change such that the maximum expected concentration or the maximum

potential concentration may change significantly, adjust the NO pollutant x

concentration span and monitor range to assure the continued accuracy of the

monitoring system. Determine the adjusted span value using the procedures

in sections 11.ii. or 11.iii. Select the new full scale range of the instrument to

be greater than or equal to the adjusted span value and to be consistent with

the guidelines of section 11.i.

ii. Record and report the new full-scale range setting, calculations of the span

value, MPC, and MEC (if appropriate), maximum potential NOx emission rate

and the adjusted span value to the District and record them in the monitoring

plan. In addition, record and report the adjusted span as part of the records

for the daily calibration error test and linearity check.

iii. Whenever the span value is adjusted, use calibration gas concentrations based

on the most recent adjusted span value. Perform a cylinder gas audit (CGA)

according to 40 CFR Part 60 Appendix F whenever making a change to the

monitor span or range. Recertification is required whenever a significant

change is made in the monitor's range that requires an internal modification to

the monitor (e.g., a change of measurement cell length).
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12. Data Acquisition and Handling Systems

Automated data acquisition and handling systems shall meet the following requirements:

a. Read and record the full range of potential NOx emission concentrations and

volumetric flow from zero through span, raw materials input rates to the cement kiln,

and flow (if used),

b. Provide a continuous, permanentrecord of all measurements and required information

as an ASCII flat file capable of transmission via an IBM-compatible personal

computer diskette or other electronic media,

c. Interpret and convert the individual output signals from a flow monitor (if used) and

a NOx CEMS to produce a continuous readout of pollutant mass emission rates in the

units of pounds NO per ton of clinker produced by the cement kiln, x

d. Calculate and record intermediate values necessary to obtain emissions rates such as

NOx concentration, raw materials input to the cement kiln, and flow (if used), and

e. Calculate and record emissions in units of the standard (pounds NO per ton of clinker x

produced by the cement kiln).

13. Data Preparation

If the NOx concentration is in ppm, multiply it by 1.194 × 10 (lb/dscf)/ppm to convert it to -7

units of lb/dscf. If the NOx concentration is in mg/dscm, multiply it by 6.24 x 10-8

(lb/dscf)/(mg/dscm) to convert it to lb/dscf. Then, use the appropriate gas flow rate and

clinker production rate to calculate the emissions in terms of pounds NO per ton of clinker x

produced by multiplying lb/dscf by the appropriate dscf and dividing by the appropriate tons

of clinker production rate from the cement kiln.

14. NO Emission Rate (Monitoring System) x

For each test run in a data set, calculate the average NO emission rate (in lb per ton of clinker x

produced), by means of the data acquisition and handling system, during the time period of

the test run. Tabulate the results as shown in 40 CFR Part 75 Appendix A Figure 4 (replace

lb/mmBtu with lb/tons of clinker produced by the cement kiln).

15. Relative Accuracy

Use the equations and procedures in 40 CFR Part 60 Appendix B Specification 2 to calculate

the relative accuracy for the NOx CEMS. In using Equation 2-1, "d" is, for each run, the

difference between the NOx emission rate values (in lb per ton of clinker produced by the

cement kiln) obtained from the reference method data and the NO CEMS. x

16. Quality Assurance and Quality Control Procedures

Quality Control Program

Develop and implement a quality control program for the continuous emission monitoring

systems and their components. As a minimum, include in each quality control program a

written plan that describes in detail complete, step-by-step procedures and operations for each

of the following activities:
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a. Calibration Error Test and Linearity Check Procedures. Identify calibration

error test and linearity check procedures specific to the CEMS that may

require variance from the procedures in this NO RACT Plan - Amendment x

1.

b. Calibration and Linearity Adjustments. Explain how each component of the

CEMS will be adjusted to provide correct responses to calibration gases,

reference values, and/or indications of interference both initially and after

repairs or corrective action. Identify equations, conversion factors, assumed

moisture content, and other factors affecting calibration of each CEMS.

c. Preventive Maintenance. Keep a written record of procedures, including

those specified by the manufacturers, needed to maintain the CEMS in proper

operating condition and a schedule for those procedures. Include provisions

for maintaining an inventory of spare parts.

d. Audit Procedures. Keep a written record of procedures and details peculiar

to the installed CEMS that are to be used for relative accuracy test audits,

such as sampling and analysis methods.

e. Record keeping and Reporting. Keep a written record describing procedures

that will be used to implement the record keeping and reporting requirements.
Permit No. 156-97-TV Plant ID 0060

186

PERMIT SHIELD

The owner or operator is hereby granted a permit shield that shall apply as long as the owner or

operator demonstrates ongoing compliance with all the conditions of this permit. Compliance with

the conditions of this permit shall be deemed compliance with all applicable requirements of the

regulations cited in this permit as of the date of issuance per Regulation 2.16, section 4.6.1.1.

OFF-PERMIT DOCUMENTS

There are no Off-Permit Documents associated with the issuance of this permit.

ALTERNATIVE OPERATING SCENARIO

The company requested no alternative operating scenario in its Title V application.

Insignificant Activities

Description Quantity Basis

Internal combustion engines fixed or mobile 1 Reg 2.02, sec 2.2

Brazing, soldering or welding operation 1 Reg 2.02, sec 2.3.4

500 Kw Emergency Generator 1 < 100 hr annual

operation

Unpaved Haul Roads various No regulatory authority

Outdoor Storage Piles, coal, gypsum, ash, etc. various No regulatory authority

Combustion Source <10 MMBtu, #2 fuel oil 1 Reg 2.02, sec 2.1.1

Diesel/fuel oil storage tanks, 3-10,000 gallon, 1- 1 Reg 2.02, sec 2.3.23

500 gallon capacity

Used (waste) oil storage tank - 500 gallon 1 Reg 2.02, sec 2.3.23

capacity

A. Insignificant Activities are only those activities or processes falling into the general

categories defined in Regulation 2.02, Section 2, and not associated with a specific

operation or process for which there is a specific regulation. Equipment associated

with a specific operation or process (Emission Unit) shall be listed with the specific
Permit No. 156-97-TV Plant ID 0060

187

process even though there may be no applicable requirements. Information contained

in the permit and permit summary shall clearly indicate that those items identified with

negligible emissions have no applicable requirements.

B. Activities identified In Regulation 2.02, Section 2, may not require a permit and may

be insignificant with regard to application disclosure requirements but may still have

generally applicable requirements that continue to apply to the source and must be

included in the Title V permit.

i. No facility, having been designated as an insignificant activity, shall be exempt

from any generally applicable requirements which shall include a 20% opacity

limit for facilities not otherwise regulated.

ii. No periodic monitoring shall be required for facilities designated as

insignificant activities.