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 operat e equipment located at: Kosmos Cement Company - Louisville Plant 15301 Dixie Highway Louisville, Kentucky 40272 in accordan ce with the permit application on file with the District and under the conditions in th e permit. This permit and the authorization to operate the emission units listed shall expire on midnigh t on the expiration date shown above. If a renewal permit is not issued prior to the expiration date, the ow ner 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 eightee n (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 OfficerPermit No. 156-97-TV Plant ID 0060

2 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
............................................................. 38Permit No. 156-97-TV Plant ID 0060

3 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
................................................... 69Permit No. 156-97-TV Plant ID 0060

4 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
.................................................. 110Permit No. 156-97-TV Plant ID 0060

5 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
............................................................ 144Permit No. 156-97-TV Plant ID 0060

6 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 NO RACT Plan
............................................................. 168 x Appendix A to NO RACT Plan
.......................................... 170 x NO RACT Plan Appendix B
............................................ 174 x PERMIT SHIELD
........................................................... 187 OFF-PERMIT DOCUMENTS
................................................. 187 ALTERNATIVE OPERATING SCENARIO
.................................... .187 INSIGNIFICANT ACTIVITIES
................................................ 187Permit No. 156-97-TV Plant ID 0060

7 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 E C - 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 SO - Sulfur dioxide 2 TAL - Threshold Ambient Limit TAP - Toxic Air Pollutant tpy - Tons per year VOC - Volatile Organic Compound UTM - Universal Transverse MercatorPermit No. 156-97-TV Plant ID 0060

8 10 August 2000 Preamble Title V of th e Clean Air Act Amendments of 1990 required EPA to create an operating permi t 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 informati on pertaining to an affected company in a single document; and (3) to make permits more consistent with each other. A company is sub

ject 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, ho w it may operate, what its applicable regulations are, how it will dem onstrate compliance, and what is requir edif compliance is not achieved. In Jefferson County, Kentucky, the Air Pollution Contro l District(APCDJC) is responsible for issuing Title V permits to affected companies and enforcing local regulations and delegated f ederal and state regulations. EPA may enforce federal regulations but not "District Only Enforceable Regulations". T i tle 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 th e Clean Air Act. Addit ionally, the Title V process provides a mechanism to incorporate new applicabl e requirements. Such requirements are available to the public for review and comment before they are adopted. Title V Permit general conditions defi ne requirements which are generally applicable to all Title V comp anies under the jurisdiction of APCDJC. This avoids repeating these requirements in every sec tion of the company's Title V permit. Company-specific conditions augment the genera l conditions as necessary; these appear in the sections of the permit addressing individual emission unit s 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 reg ulations duringthe life of the permit. Such requirements may become applicable if the company makes certai n modifications or a new applicable requirement is adopted. When the applicability of a section or subpart of a regulation i s unclear, a clarifying citation will be madein the company's Title V permit at the emission unit/point level. Comments may also be adde d 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 associate d with a specific operation or process for which there is a spe cific regulation. Activities so identified may be insignificant with regard to application disclosure requiremen ts 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

9 10 August 2000 General Conditions 1. Compliance- The owner or operator shall comply with all applicable requirements and wit h allterms and conditions of this permit. Any noncompliance shall constitute a violation of th e Act, State an d District regulations and shall cause the source to be subject to enforcemen t 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 Cou nty portion of the Kentucky SIP approved by EPA, any credible evidence may be used for the purpose of establishing whether the owner or operato r 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. ComplianceCertification- The owner or operator shall certify, annually or more frequentl y if required in applicable regulations, compliance with theterms and conditions contained in this permit, includingemission 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 o r operator shall submit the annual compliance certification directly to the following address a s 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 s chedule 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 uni t that is not in compliance with all applicable requirements. A schedule o f com pliance shall be supplemental to, and shall not condone noncompliance with, th e applicablerequirements on which it is based. For each schedule of compliance, the owner o r operator shall submit certified progress rep orts 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 schedul e 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 submi t relevant facts or has submitted incorrect information in the permit app lication, it shall, upon disc overy of the occurrence, promptly submit the supplementary facts or correcte d information in accordance with Regulation 2.16, section 3.4.Permit No. 156-97-TV Plant ID 0060

10 10 August 2000 5. Emergency Provision
a. An emergency shall constitute an affirmative defense to an enforcement actio n broug htfor noncompliance with technology-based emission limitations. Th e affirma tive 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 ca use 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 to ok al l reasonable steps, consistent with safe operating practices, to minimiz e levels of emissions that exceeded the emission standards or other requirement s in this permit. iv. The owner or operator submitted notice meeting the requirements o f Regu lation 1.07 of the time when emissions limitations were exceede d because o f the emergency. This notice must fulfill the requirement of thi s 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 th e occurrence of an emergency has the burden of proof.
c. This condi tion is in addition to any emergency or upset provision contained in a n 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 fee s 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 a n increase in the fee of an additional 5% per month up to a maximum of 25% of the original am ount 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. EmissionOffset Requirements - The owner or operator shall comply with the requirement s 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 an y provisions designed to limit a source's potential to emit, are enforceable by EPA and citizen s as specified under the Act. (Regulation 2.16, sections 4.2.1 and 4.2.2)Permit No. 156-97-TV Plant ID 0060

11 10 August 2000 9. Enforcement Action Defense
a. Itshall notbe 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 own er or operator's failure to halt or reduce activity may be a mitigating factor inassessing penalties for noncompliance if the health, safety or environmental impact s of halting or reducing operations would be more serious than the impacts of continue d operation. (Regulation 2.16, sections 4.1.13.2 and 4.1.13.3) 10. Hazardous Air Pollutants and So urces 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 caus e exists for revising, revoking and reissuing, or terminating this permit, or to determin e compliance with this permit. The owner or operator shall also f urnish, upon request, copies of records req uired to be kept by this permit. (Regulation 2.16, section 4.1.13.6) I f information is submitted to the District under a claim of confidentiality, the source shal l submit a copy of the confidential information directly to EPA. (Regulation 2.07, section 10.2 ) 12. Insignificant Activities - The owner or operator shall notify t he District in a timely manner of any prop osed change to an insignificant activity that would require a permit revision
. (Regulation 2.16, section 5) 13. Inspection a nd Entry - Upon presentation of credentials and other documents as required by law, the owner or operator shall allow the District or an authorized representative t o perform the following during reasonable hours:
a. Enter

the premises to inspect any emissions-related activity or records required in thi s permit. b. Have access to and copy records required by this permit.
c. Ins pectfacilities, equipment (including monitoring and air pollution contro l equipment), practices, or operations regulated or required by this permit. d. Sampleor monitor substances or parameters to assure compliance with this permit o r 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, unles sPermit No. 156-97-TV Plant ID 0060

12 10 August 2000 morefrequent reporting is required by an applicable requirement. The reporting period shal l be January 1st through June 30th and July 1st through December 31st of ea ch 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 s ingle violation by the District for enforcement purposes. 15. Off-permit

Documents- Any applicable requirements, including emission limitations, contro l techn ology requirements, or work practice standards, contained in an off-permit document cannotbe changed without undergoing the permit revision procedures in Regulation 2.16 , Section 5. (Regulation 2.16, section 4.1.5) 16. OperationalFlexibility- The owner or operator may make changes without permit revisio n 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 s ubmit a timely and complete application for permit renewal or significant revision. If the owner or operator submits a timely and complete ap plication then the owner or operator's failure to have a permit is not a violation until the Distric t takes formal action on this permit application. This protection shallcease to apply if, subsequent to completeness determination, the owner or operator fail s to submit, by the deadline specified in writing by the District, additional information require d to process the application as required by Regulation 2.16, sections 3 and 5.2. 19. Pe rmit

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 applicatio n 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. Per mit

Revisions - No permit revision shall be required under any approved economi c incentives, marketable permits, emissions trading and other similar programs or processes fo r changes that are provided for in the permit. (Regulation 2.16, section 4.1.16) 22. Permit

Revisi on Procedures (Minor) - Except as provided in 40 CFR Part 72, the Aci d Rain Program, this permit may be revised in accordance with Regulation 2.16, section 5.5. 23. Permit Revision Procedures (Significant) - A source seeki ng to make a significant permit revisionshall meet all the Title V requirements for permit applications, issuance and renewal , inaccordance with Regulation 2.16, section 5.7, and all other applicable District Regulations
. 24. Permit

Re vocation and Termination by the District- The District may terminate thi s permit only upon written request of the owner or operator. The District may revoke a permi tPermit No. 156-97-TV Plant ID 0060

13 10 August 2000 forcause, in accordance with Regulation 2.16, section 5.11.1.1 through 5.11.1.5. Fo r 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 no t allowed by an applicable requirement or that results in excess emissions of a regulate d air pollutant that would endanger the public or the environment. b. Failure or neglect t o 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 shal l comply with the requirements of Regulation 2.05. 27. PropertyRights - This permit shall not convey property rights of any sort or grant exclusiv e privileges in accordance with Regulation 2.16, section 4.1.13.5. 28. Pub licParticipation - Except for modifications qualifying for administrative permi t amendme nts or minor permit revision procedures, all permit proceedings shall meet th e requirements of Regulations 2.07, Section 1; and 2.16, sections 5.1.1.2 and 5.5.4. 29. Reopen ing For Cause- This permit shall be reopened and revised by the District i n accordance with Regulation 2.16 section 5.9. 30. Reopening for Cause by EPA - This permit may be revised, revoked and reissued o r terminated for cause by EPA in accordance with Regulation 2.16 section 5.10. 31. Risk Managem ent 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. SeverabilityClause - The conditions of this permit are severable. Therefore, if any conditio n of this permit, or the application of any condition of this permit to any specific circumstance , is det ermined to be invalid, the application of the condition in question to othe r 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 - Th e owner or operator shall comply with the requirements of Regulation 2.10.Permit No. 156-97-TV Plant ID 0060

14 10 August 2000 34. Startups, Shutdowns, and Malfunctions Requirements - The owner or operator shal l 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 docu ment 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 i n Regulation 2 .16 sections 3.3, and 5.8.5 shall be mailed to EPA at the followin g address: US EPA - Region IV APTMD - 12th floor Atlanta Federal Center 61 Forsyth Street Atlanta, GA 30303-3104 36. Oth erApplicable Regulations - The owner or operator shall comply with all applicabl e 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 ApplicationPermit No. 156-97-TV Plant ID 0060
FEDERALLY ENFORCEABLE REGULATIONS Regulation Title

15 10 August 2000 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

Emi ssion Unit U-1 Description: Barge Unloading & Transfer (limestone transfer from barge t o conveying systems) Applicable Regulations:Permit No. 156-97-TV Plant ID 0060

16 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

17 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 ConditionsPermit No. 156-97-TV Plant ID 0060

18 1
. Standards (40 CFR 60, Subpart OOO) Opacity Theowner or operator shall not allow or cause the opacity from this emission unit to excee d 10%; (40 CFR 60.672 (b))
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.) Opacity
a. To d emonstrate compliance with the opacity standard, the owner or operator shal l cond ucta daily one-minute visible emissions survey, during normal operation an d 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 EmissionPoints without observed visible emissions during twelve consecutive opera ting weeks, the owner or operator may elect to conduct a weekly one-minut e visible emission survey, during normal operation and daylight hours. No more than four Emission Points shall be observed simultaneously.
c. For EmissionPoints without observed visible emissions during twelve consecutive operating w eeks as per 2.b, the owner or operator may elect to conduct a monthl y one-minutevisible emission survey, during normal operation and daylight hours. N o more than four Emission Points shall be observed simultaneously. d. At Emission Points where visible emissions are observed, the owner or operator shal l initi ate corrective action within eight hours of the initial observation. If the visible emissions p ersist, 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 o f the initial observation. If the opacity standard is exceeded, the owner or operato r shall report the exceedance to the District, pursuant to Regulation 1.07, and take all practicable steps to eliminat e 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

19 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 no t 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 conduct ed (or a negative declaration if none) d. Description of any corrective action taken pursuant to Additional Condition 2.c.
Comment EmissionPoint E-1, does not qualify as a regulated facility under 40 CFR 60, Subpart OOO. It is no t a storage bin. Because of the date of installation, it would be regulated by 6.09, however, there is no contr ol device or stack associated with this emission point, therefore it is exempt from al l 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 thi s 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

20 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 ConditionsPermit No. 156-97-TV Plant ID 0060

21 1. Standards (40 CFR 60, Subpart OOO)
a. Opacity i. Theowner or operator shall not allow or cause the opacity from this emissio n 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 t o exceed 7%; ( 40 CFR 60.672 (a)(2) for E-12 and E-13 at the C-1 baghous e stack S-1) b. PM Theowner or operator shall not cause to be discharged into the atmosphere, any stac k emission s which contain particulate matter in excess of 0.05 g/dscm. (40 CF R 60.672(a)(1))
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)
a. Opacity i. To demonstrate compliance with the opacity standa rd, the owner or operator shall conduct a daily one-minute visible emissions survey, during normal operationand daylight hours, of the PM emission points identified as E-12 an d E-13. No more than four Emission Points shall be observed simultaneously. ii. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks, the owner or operator may elect to conduct a weekl y one-minute visible emission survey, during normal operation an d da ylight hours. No more than four Emission Points shall be observe d simultaneously. iii.. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks as per 2.a.ii, the owner or operator may elect to conducta monthly one-minute visible emission survey, during normal operation and daylight hours. No more than four Emission Points shall b e observed simultaneously. iv. At Emission Points where visible emissions are observed, the owner o r ope rator shall initiate corrective action within eight hours of the initial obse rvation. If the visible emissions persist, the owner or operator shal l perform or cause to be performed a Method 9 for stac k emissions or Method 22 for f ugitive emissions within 24 hours of the initial observation. If th e opa city standard is exceeded, the owner or operator shall report th e exceed ance to the District, pursuant to Regulation 1.07, and take al lPermit No. 156-97-TV Plant ID 0060

22 pr acticable 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 no t being operated during a given day, week or month (as appropriate). b. PM Monitoringrequirements 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 no t 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. EmissionUnit 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

23 iv. Description of any corre ctive action taken pursuant to Additional Condition 2.a.iii. b. PM Compliancereporting 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 guidanc e memo dated 12 June 1995.

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

24 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

25 a. Opacity The owner or operator shall not allow the discharge of visible emissions to excee d 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 Theowner or operator shall not cause to be discharged into the atmosphere, any stac k emissions which contain particulate matter in excess of 0.05 g/dscm. (40 CFR 60.67 2 (a)(1)
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)
a. Opacity i. To demonstrate compliance with the opacity standa rd, the owner or operator shall conduct a daily one-minute visible emissions survey, during normal operationand daylight hours, of the PM emission points E-14, E-15 and E-1 6 and stack S-1. No more than four Emission Points shall be observe d simultaneously. ii. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks, the owner or operator may elect to conduct a weekl y one-minute visible emission survey, during normal operation an d da ylight hours. No more than four Emission Points shall be observe d simultaneously. iii. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks as per 2.a.ii, the owner or operator may elect to conducta monthly one-minute visible emission survey, during normal operation and daylight hours. No more than four Emission Points shall b e observed simultaneously. iv. At Emission Points where visible emissions are observed, the owner o r ope rator shall initiate corrective action within eight hours of the initial obse rvation. If the visible emissions persist, the owner or operator shal l perform or cause to be performed a Method 9 for stac k emissions or Method 22 for f ugitive emissions within 24 hours of the initial observation. If th e opa city standard is exceeded, the owner or operator shall report th e exceed ance to the District, pursuant to Regulation 1.07, and take al l pr acticable 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 no t being operated during a given day, week or month (as appropriate).Permit No. 156-97-TV Plant ID 0060

26 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, an d 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 no t being operated during a given day, week or month (as appropriate) b. PM The o wner or operator shall maintain records of all inspections and maintenanc e 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 inspectionPermit No. 156-97-TV Plant ID 0060

27 iv. any repairs or maintenance performed
v. a negative declaration may be entered in the record if an Emission Point is no t 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. EmissionUnit 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 corre ctive 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. EmissionUnit 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 corre ctive 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 guidanc e memo dated 12 June 1995.Permit No. 156-97-TV Plant ID 0060

28 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

29 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 ConditionsPermit No. 156-97-TV Plant ID 0060

30 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 allo w or cause the fugitive emissions from Emission Points E-17 and E-18 to equal o r exceed 10% opacity. (40 CFR 60.62 (c))
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity
a. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emissio n Points E-17 through E-23 in accordance with 40 CFR 60 , Appendix A, Method 22. The test must be conducted while the emission uni t is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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. Theowner or operator shall inspect C-2 , C-3, C-4 and C-5 baghouses for th e 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 weeksPermit No. 156-97-TV Plant ID 0060

31 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, an d 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 no t 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting period iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive action taken pursuant to Additional Condition 2.d.
CommentPermit No. 156-97-TV Plant ID 0060

32 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

33 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

34 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

35 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 ConditionsPermit No. 156-97-TV Plant ID 0060

36 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. SO 2 The owner or operator shall not allow or cause the emissions of SO from Emission 2 Point E-30 to exceed 2000 ppm by volume at O% oxygen. (Regulation 6.10, Sectio n 4) 2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)
a. Opacity i. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emissio n Points E-25 through E-38 in accordance with 40 CFR 60 , Appendix A, Method 22. The test must be conducted while the emission uni t is in operation. ii. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests. iii. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. iv. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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

37 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, an d G) Inspect area around collectors for signs of dust every two weeks. b. SO 2 i. The owner or operator shall combust fuel oil with a sulfur content no mor e than 0.5% by weight. ii. The owner or operator shall comply with Additional Condition 2.f) fo r 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 no t being operated during a given day, week or month (as appropriate) b. SO 2 The owner or operator shall maintain records of: i. When and f

or 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% b y weight sulfur content.Permit No. 156-97-TV Plant ID 0060

38 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting period iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive action taken pursuant to Additional Condition 2.a.iv. b. SO 2 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. EmissionPoint 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 assoc iated with this emission point, therefore it is exempt from all emissions standards. Emission Point E-24 is not subject to monitoring, reco rdkeeping or reporting requirements. However, it is incumbent upon the owner o r operator to assure compliance of this emission point wit h 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 MAC T opacity monitoring procedures before the required compliance date.Permit No. 156-97-TV Plant ID 0060

39 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

40 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 semiannualPermit No. 156-97-TV Plant ID 0060

41 Additional Conditions 1. Standards (Regulation 2.16, section 4.1.1)

Opacity The ow ner 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. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emissio n Points E-39 through E-50 in accordance with 40 CFR 60 , Appendix A, Method 22. The test must be conducted while the emission uni t is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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. Theowner or operator shall inspect C-2 and C-11 baghouses for the followin g 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 weeksPermit No. 156-97-TV Plant ID 0060

42 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, an d 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 no t 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting period iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive 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

43 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) 2Permit No. 156-97-TV Plant ID 0060

44 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 ConditionsPermit No. 156-97-TV Plant ID 0060

45 1. Standards (Regulation 2.16, section 4.1.1)
a. Opacity i. The owner or operator shall not allow or cause the opacity from baghou se C13 to equal or exceed 10%. The owner or operator shall not allow or cause thefugitive emissions from Emission Points E-51 and E-53 to equal or excee d 10%. (40 CFR 60.62 (c)) ii. The owner or operator shall not allow or cause the o pacity from the raw mill and its baghouse C-13 to equal or exceed 10%. This is applicable only wh en the kiln is down and the furnace is used. Norm al 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. SO 2 The owner or operator shall not allow or cause the emissions of SO from Emission 2 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 po int E-81, is subject to the COM requirements in Emission Unit U-13, additional condition 2.a.v. ii. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emission Points E-51 and E-53 in accordance with 40 CFR 60, Appen dix A, Method 2 2. The test must be conducted while the emission unit is i n operation. iii. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests. iv. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
.Permit No. 156-97-TV Plant ID 0060

46 and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests.
v. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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 ow ner or operator shall inspect C-12 and C-13 baghouses for th e 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, an d G). Inspect area around collector for signs of dust every two weeks. b. SO 2 i. The owner or operator shall combust fuel oil with a sulfur content no mor e than 0.5% by weight. ii. The owner or operator shall comply with Additional Condition 2.f) fo r 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 pe r additional condition 3.a.ii for Emission Unit U-13. ii. The owner or operator shall, for Emission Points E-51 and E-53 maintai n records of: A. results of all Method 22 and Method 9 tests performed B. the date and time of the surveyPermit No. 156-97-TV Plant ID 0060

47 C. the name of the person conducting the survey or test D. whether visible emissions were observed E. anegati ve declaration may be entered in the record if an Emissio n Point is not being operated during a given day, week or month (a s appropriate) b. SO 2 The owner or operator shall maintain records of: i. Fuel oil vendor certification that the fuel oil meets the 0.5% b y 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 additiona l condition 4.ii for Emission Unit U-13. ii. Theowner or operator shall include, at a minimum, the following informatio n in the semi-annual compliance monitoring reports for opacity: A. EmissionUnit 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 o r Method 22 conducted that exceeded the standard (or a negative declaration if none wer e performed) D. Descri ption of any corrective action taken pursuant to Additiona l Condition 2.a. b. SO 2 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

48 iii. The own er or operator shall report semi-annually, by exception, whe n Additio nal 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 MAC T opacity monitoring procedures before the required compliance date. 2. Control device C-12 is a set of cyc lones 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

49 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) 2Permit No. 156-97-TV Plant ID 0060

50 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 ConditionsPermit No. 156-97-TV Plant ID 0060

51 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-1 4, C-15, C-16 and C-17 to equal or exceed 10%. The owner or operator shall not allo w or cause the fugitive emissions from Emission Point E-56 to equal or exceed 10%.(4 0 CFR 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348) b. SO 2 The owner or operator shall not allow or cause the emissions of SO from Emission 2 Point E-59 to exceed 2000 ppm by volume at 0% oxygen. (Regulation 6.10, Secti on 4)
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)
a. Opacity i. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emissio n Points E-56 through E-58 in accordance with 40 CFR 60 , Appendix A, Method 22. The test must be conducted while the emission uni t is in operation. A. If no visible emissions are observed in six consecutive mo nthly tests, the owner or operator may decrease the frequency of testing fro m monthly to semi-annually for this emission uni t. If visible emissions are observed during any semi-annual test, the owner or oper ator shall resume testing on a monthly basis and maintain that schedule until n o visible emissions are observed in six consecutive monthly tests. B. If no visible emissions are observed during two consecutive tests fro m this emission unit, the owner or operator may decrease the frequency of tes ting from semi-annually to annually. If visible emissions ar e observed during any annual test, the owner or operator shall resume testingon a monthly basis. and maintain that schedule until no visibl e emissions are observed in six consecutive monthly tests. C. If vi sible emissions are observed during any Method 22 test, th e owneror operator shall conduct a 6-minute test of opacity i n accordance with 40 CFR 60, Append ix A, Method 9. The Method 9 Testmustbegin within one hour of any observation of visibl e emissions. ii. The owner or operator shall, for Emission Points E-59 and E-60, monito r opacity by conducting daily visible emissions observations of the mill sweepPermit No. 156-97-TV Plant ID 0060

52 and air separator particulate matter control devices, in accordance with procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shal l be c onducted while the emission unit is operating at the highest load o r capacity level reason ably expected to occur within the day. The duration of the Method 22 test shall be six minutes. If visible emissions are observe d during any Method 22 visible emissions test, the owner or operator shall: A. Initiate , within one-hour, the corrective actions specified in the sit e specific operating and maintenance plan; B. Conducta Method 22 or Method 9 test after the corrective action is completed. 1) If n o visible emissions are observed, return to monitorin g 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 i n whichvisible emissions were first observed, conduct a visibl e emissions test of each stack from which visible emissions were obs ervedin accordance with procedures of 40 CFR 60 , Appendix A, Method 9. The duration of the Method 9 shall be 30 minutes. iii. Th e owner or operator shall test Stack S-15 once every five years usin g Method 9. The test shall occur by no later than the end o f 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 baghouse s 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, an d G) Inspect area around collectors for signs of dust every two weeks.

b. SO 2Permit No. 156-97-TV Plant ID 0060

53 i. The owner or operator shall combust fuel oil with a sulfur content no mor e than 0.5% by weight. ii. The owner or operator shall comply with Additional Condition 2.f) fo r 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 no t being operated during a given day, week or month (as appropriate)
b. SO 2 The owner or operator shall maintain records of: i. Fuel oil vendor certification that the fuel oil meets the 0.5% b y 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting periodPermit No. 156-97-TV Plant ID 0060

54 iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive action taken pursuant to Additional Condition 2.a. b. SO 2 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 own er or operator shall report semi-annually, by exception, whe n Additio nal 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

55 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) 2Permit 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 ConditionsPermit No. 156-97-TV Plant ID 0060

57 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-1 4, C-15, C-16 and C-17 to equal or exceed 10%. The owner or operator shall not allo w or cause the fugitive emissions from Emission Point E-56 to equal or exceed 10%.(4 0 CFR 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348) b. SO 2 The owner or operator shall not allow or cause the emissions of SO from Emission 2 Point E-64 to exceed 2000 ppm by volume at 0% oxygen. (Regulation 6.10, Secti on 4)
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)
a. Opacity i. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emissio n Points E-61 through E-63 in accordance with 40 CFR 60 , Appendix A, Method 22. The test must be conducted while the emission uni t is in operation. A. If no visible emissions are observed in six consecutive mo nthly tests, the owner or operator may decrease the frequency of testing fro m monthly to semi-annually for this emission uni t. If visible emissions are observed during any semi-annual test, the owner or oper ator shall resume testing on a monthly basis and maintain that schedule until n o visible emissions are observed in six consecutive monthly tests. B. If no visible emissions are observed during two consecutive tests fro m this emission unit, the owner or operator may decrease the frequency of tes ting from semi-annually to annually. If visible emissions ar e observed during any annual test, the owner or operator shall resume testingon a monthly basis. and maintain that schedule until no visibl e emissions are observed in six consecutive monthly tests. C. If vi sible emissions are observed during any Method 22 test, th e owneror operator shall conduct a 6-minute test of opacity i n accordance with 40 CFR 60, Append ix A, Method 9. The Method 9 Testmustbegin within one hour of any observation of visibl e emissions. ii. The owner or operator shall, for Emission Points E-64 and E-65, monito r opacity by conducting daily visible emissions observations of the mill sweepPermit No. 156-97-TV Plant ID 0060

58 and air separator particulate matter control devices, in accordance with procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shal l be c onducted while the emission unit is operating at the highest load o r capacity level reason ably expected to occur within the day. The duration of the Method 22 test shall be six minutes. If visible emissions are observe d during any Method 22 visible emissions test, the owner or operator shall: A. Initiate , within one-hour, the corrective actions specified in the sit e specific operating and maintenance plan; B. Conducta Method 22 or Method 9 test after the corrective action is completed. 1) If n o visible emissions are observed, return to monitorin g 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 i n whichvisible emissions were first observed, conduct a visibl e emissions test of each stack from which visible emissions were obs ervedin accordance with procedures of 40 CFR 60 , Appendix A, Method 9. The duration of the Method 9 shall be 30 minutes. iii. Th e owner or operator shall test Stack S-19 once every five years usin g Method 9. The test shall occur by no later than the end o f 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 baghouse s 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, an d H) Inspect area around collectors for signs of dust every two weeks.
b. SO 2Permit No. 156-97-TV Plant ID 0060

59 i. The owner or operator shall combust fuel oil with a sulfur content no mor e than 0.5% by weight. ii. The owner or operator shall comply with Additional Condition 2.f) fo r 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 no t being operated during a given day, week or month (as appropriate)
b. SO 2 The owner or operator shall maintain records of: i. Fuel oil vendor certification that the fuel oil meets the 0.5% b y 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting periodPermit No. 156-97-TV Plant ID 0060

60 iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive action taken pursuant to Additional Condition 2.a. b. SO 2 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 own er or operator shall report semi-annually, by exception, whe n Additio nal 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

61 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) 2Permit No. 156-97-TV Plant ID 0060

62 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 ConditionsPermit No. 156-97-TV Plant ID 0060

63 1. Standards (Regulation 2.16, section 4.1.1)
a. Opacity The owner or operator shall not allow or cause the opaci ty from the baghouses C-22 andC-23 to equal or exceed 10%. The owner or operator shall not allow or caus e the fugitive emissions from Emission Point E-67 to equal or exceed 10%.(40 CF R 60.62 (c), 40 CFR 63.1347 and 40 CFR 63.1348) b. SO 2 The owner or operator shall not allow or cause the emissions of SO from Emission 2 Point E-71 to exceed 2000 ppm by volume at 0% oxygen. (Regulation 6.10, Secti on 4)
2. Monitoring Requirements (Regulation 2.16, sections 4.1.9.1.2.)
a. Opacity i. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emission Points E-67 through E-70 and E-73 in acc ordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the emissi on unit is in operation. A. If no visible emissions are observed in six consecutive mo nthly tests, the owner or operator may decrease the frequency of testing fro m monthly to semi-annually for this emission uni t. If visible emissions are observed during any semi-annual test, the owner or oper ator shall resume testing on a monthly basis and maintain that schedule until n o visible emissions are observed in six consecutive monthly tests. B. If no visible emissions are observed during two consecutive tests fro m this emission unit, the owner or operator may decrease the frequency of tes ting from semi-annually to annually. If visible emissions ar e observed during any annual test, the owner or operator shall resume testingon a monthly basis. and maintain that schedule until no visibl e emissions are observed in six consecutive monthly tests. C. If vi sible emissions are observed during any Method 22 test, th e owneror operator shall conduct a 6-minute test of opacity i n accordance with 40 CFR 60, Append ix A, Method 9. The Method 9 Testmustbegin within one hour of any observation of visibl e emissions. ii. The owner or operator shall, for Emission Points E-71 and E-72, monito r opacity by conducting daily visible emissions observations of the mill sweepPermit No. 156-97-TV Plant ID 0060

64 and air separator particulate matter control devices, in accordance with procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shal l be c onducted while the emission unit is operating at the highest load o r capacity level reason ably expected to occur within the day. The duration of the Method 22 test shall be six minutes. If visible emissions are observe d during any Method 22 visible emissions test, the owner or operator shall: A. Initiate , within one-hour, the corrective actions specified in the sit e specific operating and maintenance plan; B. Conducta Method 22 or Method 9 test after the corrective action is completed. 1) If n o visible emissions are observed, return to monitorin g 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 i n whichvisible emissions were first observed, conduct a visibl e emissions test of each stack from which visible emissions were obs ervedin accordance with procedures of 40 CFR 60 , Appendix A, Method 9. The duration of the Method 9 shall be 30 minutes. iii. Th e owner or operator shall test Stack S-20 once every five years usin g Method 9. The test shall occur by no later than the end o f the first quarter of the fourth year of the permit. iv. The ow ner or operator shall inspect C-22 and C-23 baghouses for th e 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, an d G) Inspect area around collectors for signs of dust every two weeks.

b. SO 2Permit No. 156-97-TV Plant ID 0060

65 i. The owner or operator shall combust fuel oil with a sulfur content no mor e than 0.5% by weight. ii. The owner or operator shall comply with Additional Condition 2.f) fo r 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 no t being operated during a given day, week or month (as appropriate)
b. SO 2 The owner or operator shall maintain records of: i. Fuel oil vendor certification that the fuel oil meets the 0.5% b y 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting periodPermit No. 156-97-TV Plant ID 0060

66 iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive action taken pursuant to Additional Condition 2.a. b. SO 2 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 own er or operator shall report semi-annually, by exception, whe n Additio nal 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 SilosPermit No. 156-97-TV Plant ID 0060

67 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

68 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 ConditionsPermit No. 156-97-TV Plant ID 0060

69 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. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t onEmission Point E-75 in accordance with 40 CFR 60, Appendix A, Metho d 22. The test must be conducted while the emission unit is in operation. i. If no visible emissions are observed in six consecutive mo nthly tests, the owner or operator may decrease the frequency of testing fro m monthly to semi-annually for this emission uni t. If visible emissions are observed during any semi-annual test, the owner or oper ator shall resume testing on a monthly basis and maintain that schedule until n o visible emissions are observed in six consecutive monthly tests. ii. If no visible emissions are observed during two consecutive tests fro m this emission unit, the owner or operator may decrease the frequency of tes ting from semi-annually to annually. If visible emissions ar e observed during any annual test, the owner or operator shall resume testingon a monthly basis. and maintain that schedule until no visibl e emissions are observed in six consecutive monthly tests. iii. If vi sible emissions are observed during any Method 22 test, th e owneror operator shall conduct a 6-minute test of opacity i n accordance with 40 CFR 60, Append ix A, Method 9. The Method 9 Testmustbegin within one hour of any observation of visibl e 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 weeksPermit No. 156-97-TV Plant ID 0060

70 vi. Verify

dust removal system is working properly every two weeks, an d 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 no t 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting period iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive 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

71 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

72 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 ConditionsPermit No. 156-97-TV Plant ID 0060

73 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 5, 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. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Emissio n Point E- 76 through E - 80 in accordance with 40 CFR 60 , Appendix A, Method 22. The test must be conducted while the emission uni t is in operation. i. If no visible emissions are observed in six consecutive mo nthly tests, the owner or operator may decrease the frequency of testing fro m monthly to semi-annually for this emission uni t. If visible emissions are observed during any semi-annual test, the owner or oper ator shall resume testing on a monthly basis and maintain that schedule until n o visible emissions are observed in six consecutive monthly tests. ii. If no visible emissions are observed during two consecutive tests fro m this emission unit, the owner or operator may decrease the frequency of tes ting from semi-annually to annually. If visible emissions ar e observed during any annual test, the owner or operator shall resume testingon a monthly basis. and maintain that schedule until no visibl e emissions are observed in six consecutive monthly tests. iii. If vi sible emissions are observed during any Method 22 test, th e owneror operator shall conduct a 6-minute test of opacity i n accordance with 40 CFR 60, Append ix A, Method 9. The Method 9 Testmustbegin within one hour of any observation of visibl e 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

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

dust removal system is working properly every two weeks, an d 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 no t 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. EmissionUnit ID number and Emission Point ID number or Stack ID number ii. The beginning and ending date of the reporting period iii. Th e date, time, and result of each Method 9 or Method 22 conducted tha t exceeded the standard (or a negative declaration if none were performed) iv. Description of any corre ctive action taken pursuant to Additional Condition 2.
CommentPermit No. 156-97-TV Plant ID 0060

75 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 KilnPermit No. 156-97-TV Plant ID 0060

76 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

77 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 ConditionsPermit No. 156-97-TV Plant ID 0060

78 1. Standards (Regulation 2.16, section 4.1.1)
a. Opacity i. Theowner or operator shall not allow or cause the opacity from baghouse C

28 to exceed 20%. (40 CFR 60.62 (a)(2)) ii. Theowner or operator shall not allow or cause the opacity from baghouse C

29 to equal or exceed 10%.(40 CFR 60.62 (c)) b. PM i. Theowner or operator not cause to be discharged into the atmosphere from St ack S-11, any gases which contain particulate matter in excess of 0.15 kg permetric ton of feed (dry basis) to the kiln (0.30 lb. per ton). (40 CF R 60.62(a)(1)) ii. The ow ner or operator shall not exceed 162.9 tons per year of emissions t o the atmosphere. (Regulation 2.05)
c. SO 2 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. NO X i. The owner or operator shall not exceed 6.6 pounds of emissions to th e atmosphere per ton of clinker produced or 825 pounds per hour. (Regulatio n 6.42) ii. See attached NO RACT Plan (Regulation 6.42) X

f. Dioxin/FuranPermit No. 156-97-TV Plant ID 0060

79 The owner or operator shall no discharge into the atmosphere, any gases whic h contain Dioxin/Furan in excess of: i. 0.20 ng per dscm (8.7 x 10 gr per dscf) (TEQ) corrected to seven percen t -11 oxygen; or ii. 0.40 ng per dscm (1.7 x 10 gr per dscf) (TEQ) corrected to seven percen t -10 oxygen, when th e average of the performance test run average temperatures at the inlet of the particulate ma tter control device is 204 C (400 F) or less. o o g. TAPs i. The owner or operator shall limit Toxic Air Po llutant (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 submitte d 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. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Stack S-26 in accordance with 40 CFR 60, Appendix A, Metho d 22. The test must be conducted while the emission unit is in operation. ii. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests. iii. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. iv. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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

80 v. The owneror operator shall install, calibrate, maintain and operate i n ac cordance with 40 CFR 60.13 and 40 CFR 60, Appendix B PS-1, a continuous opacity monitoring system (COM) to measure the opacity o f emissions discharged into the atmosphere from stack S-11. vi. Sh ouldthe COM fail for any reason for more than 24 hours, the owner o r operator, shall, to remain in compliance, perform a Method 9 test (40 CFR 6 0 Appendix A) for at least 30 minutes, during each day, under normal operatin g conditions, on stack S-11. The COM failure shall be reported to the District as per Regulation 1.07. b. PM i. The ow ner or operator shall inspect C-28 and C-29 baghouses for th e 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, an d 7) Inspect area around collector for signs of dust every two weeks. ii. Th e owner or operator shall test Stack S-11 once every five years usin g Methods 1 through 5. The test shall occur by no later than the end of the firs t quarter of the fourth year of the permit.
c. SO 2 i. The owneror operator shall install, calibrate, maintain and operate i n ac cordance with 40 CFR 60.13 and 40 CFR 60, Appendix B PS-2, a con tinuous emissions monitoring system (CEMS to measure the SO 2 emissions discharged into the atmosphere from stack S-11. A) TheSO CEMS shall be operated and data recorded during all period s

2 of op eration of the cement kiln except for CEMS breakdowns an d repairs. Data shall be recorded during calibration checks and zero an d span adjustments.Permit No. 156-97-TV Plant ID 0060

81 B) The1-hour average SO emission rates measured by the CEMS shal l 2 be expresse d in pounds per hour and shall be used to calculate th e average emission rates. At least 2 data points shall be used t o calculate each 1-hour average. C) The span v alue for the SO CEMS shall be determined so that al l 2 expected concentrations can be accurately measured and D) Th e Quality Assurance Procedures in 40 CFR Part 60 Appendix F shall be followed. E) Whe n SO emission data or flow monitor data (if a flow monitor i s 2 used) are not obtained because of CEMS breakdowns, repairs , calibration checks, or zero and span adjustm ents, emission data shall beobtained by using one of the following options to provide emissio n datafo r a minimum of 75% of the operating hours in each kil n operating day, in at least 22 out of 30 successive cement kil n operating days: F) Standby monitoring systems, 40 CFR Part 60 Appendix A Method 6, Method6A 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 immediatel y before and the hour immediately after the missing data perio d for each hour of missing data, and (2) If the mi ssing data period is greater than 6 hours, the n substitute the greatest emission rate or flow (if a flow monito r is us ed) recorded during the previous 2160 quality-assure d monit or operating hours at a clinker production rate that i s withi n 10% of the current operating rate. If there are no t enough data to satisfy this requirement, then substitute dat a from a higher clinker production rate or the max imum design flow or emission rate. (3) The clinker production rate shall be d etermined and recorded during all periods of operation of the cement kiln except fo r breakdo wns and repairs of the system used to determine th e clinker production rate (raw materials weigh feeder an d associated data acquisition system). Data shall be recorde d during periods of calibratio n for the weigh feeder, which at a minimum shall be performed annually. (4) The clinker production rate determined from monitoring the rateof raw materials input to the cement kiln shall b e calculated by dividing the rate of raw materials input to th e cemen tkiln by the current raw materials conversion factor
. The raw materials conversion factor shallbe determined on aPermit No. 156-97-TV Plant ID 0060

82 quarterly basis and this convers ion factor shall be used in the cal culation of the clinker production rate until the nex t quarterly raw materials conversion rate test is performed. Th e raw m aterials conversion rate factor shall be determined b y weighing and recording the raw materials input to t he cement kiln with the weigh feeder and weighing and recording th e clinker output from the cement kiln with the use of a certif ied scale over a four- to twelve-hour period and an averag e calculatedfrom those data. The current raw material s conve rsion factor shall be included with the quarterl y emissions report. ii. A moni toring plan shall be created and kept current for the system used t o determine compliance with the pounds of SO kiln limit. The most current 2 version of the mo nitoring 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 NO RACT X Plan. d. CO i. The owneror operator shall install, calibrate, maintain and operate i n accordanc e 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 emission s discharged into the atmosphere from stack S-11. A) TheCO CEMS shall be operated and data recorded during all period s of op eration of the cement kiln except for CEMS breakdowns an d repairs. Data shall be recorded during calibration checks and zero an d span adjustments. B) The 1-hour average CO emission rates measured by the CEMS shall be expresse d in pounds per hour and shall be used to calculate th e average emission rates. At least 2 data points shall be used t o calculate each 1-hour average. C) The s pan value for the CO CEMS shall be determined so that al l expected concentrations can be accurately measured and D) Th e Quality Assurance Procedures in 40 CFR Part 60 Appendix F shall be followed. E) When CO em ission data or flow monitor data (if a flow monitor i s used) are not obtained because of CEMS breakdowns, repairs , calibration checks, or zero and span adjustm ents, emission data shall beobtained by using one of the following options to provide emissio nPermit No. 156-97-TV Plant ID 0060

83 datafo r a minimum of 75% of the operating hours in each kil n operating day, in at least 22 out of 30 successive cement kil n operating days: F) Standby

monitoring systems, 40 CFR Part 60 Appendix A Method 1 0 orMethod 10B, or other approved reference methods, or Dat a 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 immediatel y before and the hour immediately after the missing data perio d for each hour of missing data, and (2) If the mi ssing data period is greater than 6 hours, the n substitute the greatest emission rate or flow (if a flow monito r is us ed) recorded during the previous 2160 quality-assure d monit or operating hours at a clinker production rate that i s withi n 10% of the current operating rate. If there are no t enough data to satisfy this requirement, then substitute dat a from a higher clinker production rate or the max imum design flow or emission rate. (3) The clinker production rate shall be d etermined and recorded during all periods of operation of the cement kiln except fo r breakdo wns and repairs of the system used to determine th e clinker production rate (raw materials weigh feeder an d associated data acquisition system). Data shall be recorde d during periods of calibratio n for the weigh feeder, which at a minimum shall be performed annually. (4) The clinker production rate determined from monitoring the rateof raw materials input to the cement kiln shall b e calculated by dividing the rate of raw materials input to th e cemen tkiln by the current raw materials conversion factor
. The raw materials conversion factor shallbe determined on a quarterly basis and this convers ion factor shall be used in the cal culation of the clinker production rate until the nex t quarterly raw materials conversion rate test is performed. Th e raw m aterials conversion rate factor shall be determined b y weighing and recording the raw materials input to t he cement kiln with the weigh feeder and weighing and recording th e clinker output from the cement kiln with the use of a certif ied scale over a four- to twelve-hour period and an averag e calculatedfrom those data. The current raw material s conve rsion factor shall be included with the quarterl y emissions report. ii. A moni toring plan shall be created and kept current for the system used t o determine compliance with the pounds of SO kiln limit. The most current 2Permit No. 156-97-TV Plant ID 0060

84 version of the mo nitoring 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 NO RACT X Plan.
e. NO X i. See attached NO RACT P lan 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. Sourcegenerated Waste Oil, having the characteristics specified in 2.e.ii, ma y be combusted as a secondary fuel in the kiln. ii. The source may combust “On-Spec” and “Off-Spec” oils, having th e 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 F o J) Maximum allowed constituents:

Constituent Max Allowed Max Allowed

“On-Spec” “Off -Spec” Arsenic 5 ppm 5 ppm Cadmium 2 ppm 2 ppmPermit No. 156-97-TV Plant ID 0060

85 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 second ary

fuel, it will be necessary that the owner or operator submit a n 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 oxyge n concentration at the kiln inlet to drop below 0.5%. B. ins tall, maintain and properly operate an automatic TDF shutdow n for: (I) Coal mill outage and belt malfunction, with an alarm to soun d 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, wit h an alarm t o 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 stat e conditions, as characterized by a CO reading of 100 ppm, an O reading of 0.5%, a minimum raw feed rate o f 110 tons per 2 hour are reached and maintained for five consecutive minutes
. (VII) Continuou s emissions monitors, strip chart or data recorders shallbe installed, calibrated, tested and operated with require d reporting and recordkeeping in accordance with Regulatio n 7.01 and 40 CFR 60, Appendix B for the followin g 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 fa n converted electronically to represent gas flow thro ugh the kiln (5) Opacity (6) Carbon monoxide in the kiln exhaustPermit No. 156-97-TV Plant ID 0060

86 (VIII) Th e 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 an d Maint enance Manual which details the proper O& M proce dures for its personnel. A current copy of the manua l shallbe kept on hand at the plant at all times for review by th e 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) co mpany’s response to malfunction of the TF D process C. After any disruption in the utilization of TDF, lasting more than 180 days, the owner or operator shall conduct performance tests, a s specified in 40 CFR 60 Appendix A, for pa rticulate matter (PM) and su lfur dioxide (SO ). The requirements of Regulation 1.04 shall b e

2 followed during p erformance testing. These performance tests shall beconducted within 90 days after the resumption of combusting TDF
. Theowner or operator shall conduct any additional performance test s specified by the District. The owner or operator shall make av ailable to the District such records as may be necessary to determin e condit ions during such performance tests. A written report of th e resul ts of the performance tests shall be submitted to the Distric t within 90 da ys of the completion of the tests. The District shall b e notifiedat least 45 days in advance of the starting date of thes e performa nce tests. As pre-test conference shall be held with th e Distr ict, and at the District’s discretion, at least 30 days before th e start of the tests. The TDF feed rate shall not exceed the feed rat e established during such trail burns, unless a retest is run at a highe r feed rate. The District shall require a minimum of 2 performance test s for PM and SO . One test will establish the baseline conditions (no

2 TDF being comb usted) 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 rec ords, receipts, manifests, test results, burn rates, combustion parameters, and all other records ordata requ ired by this process for a period of five years from th ePermit No. 156-97-TV Plant ID 0060

87 dat e that such records are generated. Such records or data shall b e made available to the District within 3 days, upon request. E. The own er or operator agrees to cease the combustion of TDF fo r 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. anegati ve declaration may be entered in the record if an Emissio n Point is not being operated during a given day, week or month (a s appropriate) ii. For Stack S-11 (COM) A. Theowner or operator shall record the daily production rates and kil n feed rates. B. The dataacquisition and handling system used in recording an d reporting the necessary information required for th e determination of compl iance with the opacity limit shall also meet all of th e 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. SO 2 The o wner or operator shall keep records for each operating day including th e following information: i Calendar date,Permit No. 156-97-TV Plant ID 0060

88 ii The ave rage hourly SO emission rates measured, expressed as pounds pe r 2 hour and tons per consecutive 12 month period. iii The 30-day average SO emission r ates calculated at the end of each cement 2 kilnoperating day from the measured hourly sulfur dioxide emission rates fo r the preceding30 cement kiln operating days. The average shall not include da ta recorded during periods of CEMS breakdowns, repairs, calibratio n 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 emission s

2 2 standard.
v. Identificationof the cement kiln operating days for which pollutant data hav e not been obtained, including reasons for not obtaining sufficient data and a description of corrective actions taken, vi Identification of the ti mes when emission data have been excluded from the calcul ation of average emission rates, the reasons for excluding data, an d description of corrective action taken, vii Identi fication of times when hourly averages have been obtained based o n 40 CFR Part 60 Appendix A Method 6 or Method 6A, viii Ide ntification of times which the CEMS (including all monitors) wa s inoperative, including the date and time and the nature of the system repairs or adjustments except for zero and span checks, ix Identificationof the times when the pollutant concentration exceeded full span of the CEMS,
x . Description of any modifications to the CEMS that could affect the ab ility of the CEMS to comply with 40 CFR Part 60 Appendix B Performanc e Specification 2, xi Resul ts of daily CEMS drift tests and quarterly accuracy assessments a s required under 40 CFR Part 60 Appendix F Procedure 1. d. CO The o wner or operator shall keep records for each operating day including th e following information: i Calendar date, ii The av erage hourly CO emission rates measured, expressed as pounds pe r hour and tons per consecutive 12 month period.Permit No. 156-97-TV Plant ID 0060

89 iii The 30-day aver age CO emission rates calculated at the end of each cement kilnoperating day from the measured hourly carbon monoxide emission rate s forthe p receding 30 cement kiln operating days. The average shall no t 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. Identificationof the cement kiln operating days for which pollutant data hav e not been obtained, including reasons for not obtaining sufficient data and a description of corrective actions taken, vi Identification of the ti mes when emission data have been excluded from the calcul ation of average emission rates, the reasons for excluding data, an d description of corrective action taken, vii Identi fication of times when hourly averages have been obtained based o n 40 CFR Part 60 Appendix A Method 10 or Method 10B, viii Ide ntification of times which the CEMS (including all monitors) wa s inoperative, including the date and time and the nature of the system repairs or adjustments except for zero and span checks, ix Identificationof the times when the pollutant concentration exceeded full span of the CEMS,
x . Description of any modifications to the CEMS that could affect the ab ility of the CEMS to comply with 40 CFR Part 60 Appendix B Performanc e Specification 4, xi Resul ts of daily CEMS drift tests and quarterly accuracy assessments a s required under 40 CFR Part 60 Appendix F Procedure 1,
e. NO X 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. TAPsPermit No. 156-97-TV Plant ID 0060

90 i. The owner or operator shall maintain, on site, all analytical test result s of waste oil, “Off-Spec” oils and “On-Spec” oils. ii. Theowner or operator shall obtain and retain an elemental and TCL P 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 wa s generated from the combustion of coal, only.
4. Reporting (Regulation 2.16, section. 4.1.9.3)

Opacity i. Theowner or operator shall include, at a minimum, the following informatio n in the semi-annual compliance monitoring report for opacity for stack S-26: A. EmissionUnit 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 o r Method 22 conducted (or a negative declaration if none) D. Descri ption of any corrective action taken pursuant to Additiona l 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-minut e periods during which the average opacity exceeds 20%. B. the conte nt of this report shall comply with the requirements of 4 0 CFR 60.7(c). C. not withstanding 40 CFR 60.7(c), such report shall be semi-annual.
c. SO 2 i. Al l SO CEMS reporting required by 40 CFR Part 60 Appendix F is to b e

2 submitted to the District.Permit No. 156-97-TV Plant ID 0060

91 ii. All “ estimated” data shall be reported with a clear notation that they ar e estimated and not obtained from a certified monitor or EPA-approved tes t method. iii. The owner or operator shall submit excess emission reports for any exces s emissions that occurred during the reporting period. This report shall includ e the magnitude of the excess emissions and the date and time of th e commencement

and completion of each period of excess emissions as well a s the nature and cause of each period of excess emissions and any correctiv e actions taken or preventive measures adopted, iv. The owner o r 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 b e submitted to the District. ii. All “ estimated” data shall be reported with a clear notation that they ar e estimated and not obtained from a certified monitor or EPA-approved tes t method. iii. The owner or operator shall submit excess emission reports for any exces s emissions that occurred during the reporting period. This report shall includ e the magnitude of the excess emissions and the date and time of th e commencement

and completion of each period of excess emissions as well a s the nature and cause of each period of excess emissions and any correctiv e actions taken or preventive measures adopted, iv. The owner o r 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. NO X See attached NO RACT Plan X f. Dioxin/Furan The owner or operator shall report per 40 CFR 63.1354 g. TAPsPermit No. 156-97-TV Plant ID 0060

92 The o wner 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

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

94 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 ConditionsPermit No. 156-97-TV Plant ID 0060

95 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 t o eq ual or exceed 10%. The owner or operator shall not allow or cause the fugitiv e emissions from Emission Point E-86 to equal or exceed 10%. (40 CFR 60.62 (c)) b. Theowner or operator shall not allow or cause the opacity from Stack S-27 to excee d 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. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t onStack S-28 and E-86 in accordance with 40 CFR 60, Appendix A, Metho d 22. The test must be conducted while the emission unit is in operation. ii. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests. iii. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. iv. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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.Permit No. 156-97-TV Plant ID 0060

96 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, an d 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) anegati ve declaration may be entered in the record if an Emissio n Point is not being operated during a given day, week or month (a s appropriate) ii. For Stack S-27 see comment

4. Reporting (Regulation 2.16, section. 4.1.9.3)

Opacity (see comment)Permit No. 156-97-TV Plant ID 0060

97 i. Theowner or operator shall include, at a minimum, the following informatio n in the semi-annual compliance monitoring reports for opacity: A) EmissionUnit 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 o r Method 22 conducted (or a negative declaration if none) D) Descri ption of any corrective action taken pursuant to Additiona l 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 requirement s 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 MAC T opacity monitoring procedures before the required compliance date.Permit No. 156-97-TV Plant ID 0060

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

99 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 ConditionsPermit No. 156-97-TV Plant ID 0060

100 1. Standards (Regulation 2.16, section 4.1.1)

Opacity The owner or oper ator 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. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Stack S-29 in accordance with 40 CFR 60, Appendix A, Metho d 22. The test must be conducted while the emission unit is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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 weeksPermit No. 156-97-TV Plant ID 0060

101 vi. Verify

dust removal system is working properly every two weeks, an d 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.a.iii.

CommentPermit No. 156-97-TV Plant ID 0060

102 1. Thesource 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 requirement s requirements for a unit that is no longer in operation.
2. With the owner or operator agreement, it was decided to implement the Cement MAC T opacity monitoring procedures before the required compliance date.Permit No. 156-97-TV Plant ID 0060

103 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))Permit No. 156-97-TV Plant ID 0060

104 Components: Emission Point Description Control ID E-88 Hopper fugitive emissions, no control E-89 Belt Conveyor (K-1304-1) fugitive emissions, no control

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

105 Additional Conditions 1. Standards (Regulation 2.16, section 4.1.1)
a. Opacity i. The owner or operator shal l 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 own er or operator shall not cause or permit the discharge of fugitiv e emissions in excess of 20% opacity from Emission Point E-92. (Regulation 1.14, sec 2.2) iii. Theowner or operator shall not cause or permit the discharge, from Emissio n Point E-92, of visible fugitive emissions beyond the lot line of the property o n which the emissions originate. (Regulation 1.14, sec 2.3) b. TAPs (Regulation 5.11 & 5.12) Theowner or operator shall limit Toxic Air Pollutant (TAP) emissions from Emissio n PointE-90 to no more than the Adjusted Significance Level (ASL) specified i n Regulation5.12 unless modeling or a BACT/RACT analysis has been performed an d 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 standa rd, the owner or operator shall conduct a daily one-minute visible emissions survey, during normal operationand daylight hours, of the PM emission points identified as E-88, E

89, E-9 0, E-91 and E-92. No more than four Emission Points shall b e observed simultaneously. ii. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks, the owner or operator may elect to conduct a weekl y one-minute visible emission survey, during normal operation an d da ylight hours. No more than four Emission Points shall be observe d simultaneously. iii. At Emission Points where visible emissions are observed, the owner o r ope rator shall initiate corrective action within eight hours of the initial obse rvation. If the visible emissions persist, the owner or operator shal l perform or cause to be performed a Method 9 for stac k emissions or Method 22 for f ugitive emissions within 24 hours of the initial observation. If th e opa city standard is exceeded, the owner or operator shall report th ePermit No. 156-97-TV Plant ID 0060

106 exceed ance to the District, pursuant to Regulation 1.07, and take al l pr acticable 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 no t 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 th at 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 no t being operated during a given day, week or month (as appropriate) b. TAPs (Regulation 5.11 & 5.12) Theowner or operator shall maintain, on site, all material analyses, of all current an d 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. EmissionUnit ID number and Emission Point ID number or Stack ID number b. The beginning and ending date of the reporting periodPermit No. 156-97-TV Plant ID 0060

107 c. The date, time, and result of each Method 9 or Method 22 conducted (or a negative declaration if none) d. Description of any corre ctive 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 insignifican t activities. See Insignificant activities listing.Permit No. 156-97-TV Plant ID 0060

108 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

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

109 

### Additional Conditions 1. Standards (Regulation 6.09, section 3.1)

Opacity Th e owner or operator shall, for each particulate matter (PM) Emission Poin t subjectto 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 standa rd, the owner or operator shall c onduct 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 observe d simultaneously. b. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks, the owner or operator may elect to conduct a monthlyone-minute visible emission survey, during normal operation an d da ylight hours. No more than four Emission Points shall be observe d simultaneously.
c. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks as per 2.b, the owner or operator may elect t o conducta monthly one-minute visible emission survey, during normal operation and daylight hours. No more than four Emission Points shall b e observed simultaneously. d. At Emission Points where visible emissions are observed, the owner o r ope rator shall initiate corrective action within eight hours of the initial obse rvation. If the visible emissions persist, the owner or operator shal l perform or cause to be performed a Method 9 for stac k emissions or Method 22 for f ugitive emissions within 24 hours of the initial observation. If th e opa city standard is exceeded, the owner or operator shall report th e exceed ance to the District, pursuant to Regulation 1.07, and take al l pr acticable 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 no t being operated during a given day, week or month (as appropriate).Permit No. 156-97-TV Plant ID 0060

110 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.a.iii.Permit No. 156-97-TV Plant ID 0060

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

112 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 ConditionsPermit No. 156-97-TV Plant ID 0060

113 1. Standards (Regulation 2.16, section 4.1.1)

a. Opacity The owneror operator shall not allow or cause the opacity from th e baghouses C- 35, C-36 and C-37 to equal or exceed 10%. The owner o r operator shall not allow or cause the opacity from the fugitive Emission Point s 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 s hall not cause to be discharged into the atmosphere, from Stack S-30, any gases which contain particulate matter in excess of 0.5 0 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 visibl e emiss ions test on Stacks S-31 and S-32 in accordance with 40 CF R 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 mo nthly tests, the owner or operator may decrease the frequency of testing fro m monthly to semi-annually for this emission uni t. If visible emissions are observed during any semi-annual test, the owner or oper ator shall resume testing on a monthly basis and maintain that schedule until n o visible emissions are observed in six consecutive monthly tests. iii. If no visible emissions are observed during two consecutive tests fro m this emission unit, the owner or operator may decrease the frequency of tes ting from semi-annually to annually. If visible emissions ar e observed during any annual test, the owner or operator shall resume testingon a monthly basis. and maintain that schedule until no visibl e emissions are observed in six consecutive monthly tests. iv. If vi sible emissions are observed during any Method 22 test, th e owneror operator shall conduct a 6-minute test of opacity i n accordance with 40 CFR 60, Append ix A, Method 9. The Method 9 Testmustbegin within one hour of any observation of visibl e emissions.
v. The owner or operator shall install, calibrate, maintain and operate in accord ance with 40 CFR 60.13, a continuous opacity monitorin gPermit No. 156-97-TV Plant ID 0060

114 sy stemto measure the opacity emissions discharged into th e atmosphere from S-30. vi. The owner or operator shall, during any period that the continuou s opacity monitor (COM) is down for more than a twenty-four hou r 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 b e 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) Veri fy

cleaning mechanism is working properly every tw o weeks 4) Replace all worn bags as needed. 5) Verify

bags are clean and not filled with dust every two week s 6) Verify

dust removal system is working properly every tw o weeks, and 7) Inspe ctarea around collectors for signs of dust every tw o weeks. ii. The owner or operator shall test Stack S-30 once every five year s using Methods 1 through5. 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 testPermit No. 156-97-TV Plant ID 0060

115 iv. whether visible emissions were observed
v. a negative declaration may be entered in the record if an Emission Point is no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.a.iii.
v. The owner or operator shall submit reports of excess emis sions as defined in 40 CFR 60.6 3(d). The content of these reports must comply with th e 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. Forpurposes of reports under 40 CFR 60.65, periods of excess emission s shallbe reported are defined as all 6-minute periods during which the averag e opacity exceeds that allowed b y 40 CFR 60.62(a)(2) or 40 CFR 60(b)(2) for Stack S-30. (Regulation 40 CFR 60.63)Permit No. 156-97-TV Plant ID 0060

116 b. PM The owner or operator shall include, at a minimum, the following information in the semi-annual compliance monitoring reports for PM: i. EmissionUnit 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.Permit No. 156-97-TV Plant ID 0060

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

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

119 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 ConditionsPermit No. 156-97-TV Plant ID 0060

120 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-3 8, C-39, C-40, C-41, C-42, C-43, C-44, C-45 and C-46 to equal or exceed 10%. The owne r or operator shall not allow or cause the opacity from the fugitive Emissio n Points E-109 and E-110 to equal or exceed 10%. (40 CFR 60.62 (c) and 40 CF R 63.1348)
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity
a. Theowner or operator shall conduct a monthly 1-minute visible emissions tes t on Sta cks 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 i n operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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 weeksPermit No. 156-97-TV Plant ID 0060

121 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, an d 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.Permit No. 156-97-TV Plant ID 0060

122 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

123 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)Permit No. 156-97-TV Plant ID 0060

124 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 semiannualPermit No. 156-97-TV Plant ID 0060

125 Additional Conditions 1. Standards (Regulation 2.16, section 4.1.1)
a. Opacity The owner or operator shall not allow or cause the opaci ty from the baghouses C-47 andC-48 to equal or exceed 10%. The owner or operator shall not allow or caus e 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 own er or operator of a VOC storage vessel with a capacity of 250 gallons o r more, and the material t o 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 op erator shall, for Emission points E-115 and E-116 conduct a monthly 1-minute visible emissions test of this emission unit in accordanc e with40 CFR 60, Appendix A, Method 22. The test must be conducted whil e the emission unit is in operation. ii. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests. iii. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. iv. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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

126 v. The owner or operator shall, for control device C-47 and C-48, monito r op acity at stacks S-42 and S-43 by conducting daily visible emission s observ ations of the mill sweep and air separator particulate matter contro l devices, in accordance with procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall be conducted while the emission unit i s 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 sit e specific operating and maintenance plan; 2) Conducta Method 22 or Method 9 test after the corrective action is completed. A) If n o visible emissions are observed, return to monitorin g 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 i n whichvisible emissions were first observed, conduct a visibl e emissions test of each stack from which visible emissions were obs ervedin accordance with procedures of 40 CFR 60 , Appendix A, Method 9. The duration of the Method 9 shall be 30 minutes. g. Th e owner or operator shall test Stack S-42 once every five years usin g Method 9. The test shall occur by no later than the end o f the first quarter of the fourth year of the permit. h. The ow ner or operator shall inspect C-47 and C-48 baghouses for th e 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, an d vii. Inspect area around collectors for signs of dust every two weeks.Permit No. 156-97-TV Plant ID 0060

127 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.
b. VOCPermit No. 156-97-TV Plant ID 0060

128 No compliance reporting required, see comment 2.
Comment
1. With the owner or operator agreement, it was decided to implement the Cement MAC T opacity monitoring procedures before the required compliance date. 2. The VOC materials stored in the two grinding agent tanks and the one ai r entrainment agent tank have vapor pressures much less than 1.5 psia. Therefore, even though the regulatio n 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.Permit No. 156-97-TV Plant ID 0060

129 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)Permit No. 156-97-TV Plant ID 0060

130 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 semiannualPermit No. 156-97-TV Plant ID 0060

131 Additional Conditions 1. Standards (Regulation 2.16, section 4.1.1)

Opacity The owner or operator shall not allow or cause the opaci ty from the baghouses C-49 andC-50 to equal or exceed 10%. The owner or operator shall not allow or caus e 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 op erator shall, for Emission points E-121 and E-122 conduct a monthly 1-minute visible emissions test of this emission unit in accordanc e with40 CFR 60, Appendix A, Method 22. The test must be conducted whil e the emission unit is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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, monito r op acity at stacks S-44 and S-45 by conducting daily visible emission s observ ations of the mill sweep and air separator particulate matter contro l devices, in accordance with procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test shall be conducted while the emission unit i s 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. IfPermit No. 156-97-TV Plant ID 0060

132 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 sit e specific operating and maintenance plan; ii. Conducta Method 22 or Method 9 test after the corrective action is completed. 1. If n o visible emissions are observed, return to monitorin g 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 i n whichvisible emissions were first observed, conduct a visibl e emissions test of each stack from which visible emissions were obs ervedin accordance with procedures of 40 CFR 60 , Appendix A, Method 9. The duration of the Method 9 shall be 30 minutes. g. Th e owner or operator shall test Stack S-44 once every five years usin g Method 9. The test shall occur by no later than the end o f the first quarter of the fourth year of the permit. f. The ow ner or operator shall inspect C-49 and C-50 baghouses for th e 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, an d vii. Inspect area around collectors for signs of dust every two weeks.Permit No. 156-97-TV Plant ID 0060

133 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2. Comment
1. With the owner or operator agreement, it was decided to implement the Cement MAC T opacity monitoring procedures before the required compliance date. 2. Allthree finish mills, emission units E-20 through E-22 draw from the three tanks in Emissio n Unit E-20.Permit No. 156-97-TV Plant ID 0060

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

135 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 ConditionsPermit No. 156-97-TV Plant ID 0060

136 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-5 1, C-52, C-53 , C-54, C-55 and C-56 to equal or exceed 10%. The owner or operato r 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, Metho d 22. The test must be conducted while the emission unit is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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. Th e owner or operator shall test Stack S-51 once every five years usin g Method 9. The test shall occur by no later than the end o f 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.Permit No. 156-97-TV Plant ID 0060

137 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, an d 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 no t 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. EmissionUnit 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

138 iv. Description of any corre ctive action taken pursuant to Additional Condition 2.

Comment
1. With the owner or operator agreement, it was decided to implement the Cement MAC T opacity monitoring procedures before the required compliance date. 2. Allthree finish mills, emission units E-20 through E-22 draw from the three tanks in Emissio n Unit E-20.Permit No. 156-97-TV Plant ID 0060

139 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 controlPermit No. 156-97-TV Plant ID 0060

140 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 semiannualPermit No. 156-97-TV Plant ID 0060

141 Additional Conditions 1
. Standards (40 CFR 60, Subpart OOO)
a. Opacity i. The owner or operator shall not allow or cause the opacity from Emissio n Points E-140 and E-141 to exceed 10%; (40 CFR 60.672 (b)) ii. The owneror operator shall not allow or cause the opacity from S-52 t o exceed 7%; (40 CFR 60.672 (a)(2)) b. PM The owner or operator shall not allow PM emission s 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 standa rd, the owner or operator shall conduct a daily one-minute visible emissions survey, during normal operationand daylight hours, of the fugitive PM Emission Points identified a s 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 twelv e consecutive operating weeks, the owner or operator may elect to conduct a weekl y one-minute visible emission survey, during normal operation an d da ylight hours. No more than four Emission Points shall be observe d simultaneously. iii. For

Emission Points without observed visible emissions during twelv e consecutive operating weeks as per 2.a.ii, the owner or operator may elect to conducta monthly one-minute visible emission survey, during normal operation and daylight hours. No more than four Emission Points shall b e observed simultaneously. iv. At Emission Points where visible emissions are observed, the owner o r ope rator shall initiate corrective action within eight hours of the initial obse rvation. If the visible emissions persist, the owner or operator shal l perform or cause to be performed a Method 9 for stac k emissions or Method 22 for f ugitive emissions within 24 hours of the initial observation. If th e opa city standard is exceeded, the owner or operator shall report th e exceed ance to the District, pursuant to Regulation 1.07, and take al lPermit No. 156-97-TV Plant ID 0060

142 pr acticable 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 no t 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, an d 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 no t being operated during a given day, week or month (as appropriate)

b. PMPermit No. 156-97-TV Plant ID 0060

143 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. EmissionUnit 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 negativ e declaration if none) iv. Description of any corre ctive 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 c lients 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 continu ation of the Emission Units 1 & 2 processes.Permit No. 156-97-TV Plant ID 0060

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

145 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 semiannualPermit No. 156-97-TV Plant ID 0060

146 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 semiannualPermit No. 156-97-TV Plant ID 0060

147 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-5 8, C-59, C-60, C-61, C-62, C-63, C-64, C-65 and C-66 to equal or exceed 10%. (4 0 CFR 60.62 (c) and 40 CFR 63.1348)
2. Monitoring (Regulation 2.16, sections 4.1.9.1.2.)

Opacity
a. The owner o r 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 thi s emission unit in accordance with 40 C FR 60, Appendix A, Method 22. The test must be conducted while the emission unit is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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.Permit No. 156-97-TV Plant ID 0060

148 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, an d 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.Permit No. 156-97-TV Plant ID 0060

149 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

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

151 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 ConditionsPermit No. 156-97-TV Plant ID 0060

152 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-6 7, 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 own er 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 with40 CFR 60, Appendix A, Method 22. The test must be conducted whil e the emission unit is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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.Permit No. 156-97-TV Plant ID 0060

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

dust removal system is working properly every two weeks, an d 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.

CommentPermit No. 156-97-TV Plant ID 0060

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

155 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

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

157 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 ConditionsPermit No. 156-97-TV Plant ID 0060

158 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-7 0, C- 71, C-72, C-73 C-74, and C-75 to equal or exceed 10%. (40 CFR 60.62 (c) an d 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 mont hly 1-minute visible emissions test of this emission unit in accordance with 4 0 CFR 6 0, Appendix A, Method 22. The test must be conducted while th e emission unit is in operation. b. If no v isible emissions are observed in six consecutive monthly tests, th e owne r or operator may decrease the frequency of testing from monthly t o semi-annually

for this emission unit. If visible emissions are observed durin g any semi-annual test, the owner or operator shall resume testing on a monthl y basis and maintain that schedule until no visible emissions are observed in si x consecutive monthly tests.
c. If no vis ible emissions are observed during two consecutive tests from thi s emi ssion unit, the owner or operator may decrease the frequency of testin g from semi-annually to annually. If visible emissions are observed during an y annua l test, the owner or operator shall resume testing on a monthly basis
. and mainta in that schedule until no visible emissions are observed in si x consecutive monthly tests. d. If visible emissions are observed during any Method 22 test, the owner o r operator shall conduct a 6-minute test of opaci ty 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 s hall test Stacks S-66 and S-67 once every five years usin g Method 9. The test shall occur by no later than the end of the firs t 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.Permit No. 156-97-TV Plant ID 0060

159 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, an d 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 no t 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. EmissionUnit 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 corre ctive action taken pursuant to Additional Condition 2.Permit No. 156-97-TV Plant ID 0060

160 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

161 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 FacilityPermit No. 156-97-TV Plant ID 0060

162 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 liqui d 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 includin g gaskets. ( Regulation 7.15, sec. 3.8.1)
c. Theowner or operator shall maintain all hoses, fittings, and couplings in a vapor-tigh t condition. (Regulation 7.15, sec. 3.8.5)
2. Monitoring (Regulation 2.16, section 4.1.9.1.2) Theowner 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 rec ords 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. EmissionUnit 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 reportin g period.Permit No. 156-97-TV Plant ID 0060

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

164 Additional Conditions 1. Standards Regulation 2.16, section 4.1.1)
a. VOC i. The cle aner shall be equipped with a cover. If the VOC volatility is greater than 15 mm Hg measured at 100 E F 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 cleanershall be equipped with a drainage facility such that VOC that drains off parts removed from the cleaner will return to the cleaner. If th e VOC vol atility is greater than 32 mm Hg measured at 100 EF, then th e drain age facility shall be internal so that parts are enclosed under the cove r while draining. The drainage facility may be external if the District determine s that an internal type cannot fit into the cleaning system. iii. A permanent, conspicuous label summarizing the operating requirement s 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 showe r type spray) at a pressure that does not cause excessive splashing.
v. If the VOC volatility is greater than 32 mm Hg measured at 100 EF or if the VOC is heated above 120 E F, 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 sys tems 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 mo re than 20% by weight of the waste VOC can evaporate into th e 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 pres sure that exceeds 1.0 mm Hg (0.019 psi) measured at 20 E C (68 EF).Permit No. 156-97-TV Plant ID 0060

165 b. TAPs LimitTo xic Air Pollutant (TAP) emissions from this source to no more than th e Adjuste dSignificance Level (ASL) specified in Regulations 5.11 and 5.12 for thi s emissio n unit, unless modeling or a BACT/RACT analysis has been performed t o 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 o perator shall calculate average hourly TAP emissions, based onrecords maintained for additional condition 3.a, to assure that the ASL ha s not been exceeded. ii. Theowner or operator may submit a one time demonstration that the PTE fo r TAP emissions from this facility can not exceed the calculated ASL. Suc h submittal will negate additional conditions 3.b and 4.b. 3. Record Keeping (Regulation 2.16, section 4.1.9.2)
a. VOC i. Th e owner or operator shall keep monthly records of VOC usage for eac h 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 20 E C (68 EF). iii. The owner or operator shall maintain records of employee training for th e 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. TAPsPermit No. 156-97-TV Plant ID 0060

166 Based on 3.a, the owner or operator sh all, 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 i n Regulation 2.16, section 2.36. If no deviations occur in t hat reporting period then the owner or operator shall report a negative declaration for each of the following categories.
a. VOC The owne r or operator shall report semi-annually the following for each emissio n 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 ow ner or operator shall report any occurrence where the calculated ASL wa s exceeded.Permit No. 156-97-TV Plant ID 0060

167 No RACT Plan x Amendment 1 1. The oxides of

nitrogen (NO , expressed as NO ) emission from the cement kiln shall no t

x 2 ex ceed6.6 pounds per ton of clinker produced by the kiln, based upon a rolling 30-da y average. 2
. The NO x emission rate for the cement kiln shall be determined using the methods an d proc edures specified in NO RACT Plan Appendix A - Amendment 1 and Appendix B

- x Amendment 1. 3. TheKosmos Cement Company (Kosmos) shall install, calibrate, maintain, and operate a NO x continuous emissions monitoring system (CEMS) for the cement kiln and shall keep record s and submit reports and other notifications as specified in NO RACT Plan Appendix A

- x Amendment 1 and Appendix B - Amendment 1 . 4. Kosmos sh all keep a record identifying all deviations from the requirements of this NO x RA CT Plan and shall submit to the District a written report of all deviations that occurre d during the precedi ng 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 spec ifiedin NO RACT Plan Appendix A - Amendment 1 Section II. A. and B. If n o x deviation occurred during the semi-annual period, the report shall contain a negativ e declaratio n. Each report shall be submitted within 60 days following the end of the semi

annual period. 5. In li eu of the requirements in this NO RACT Plan, Kosmos may comply with alternativ e x requirements regarding emission limitations, equipment operation, test methods, monitoring , record keeping, or reporting, provided the following conditions are met: a. Thealternative requirements are established and incorporated into an operating permi t pursuant to a Title V Operating Permit issuance, renewal, or significant permi t revision process as established in Regulation 2.16, b. The a lternative requirements are consistent with the streamlining procedures an d guidelines set forth in section II.A. of White Paper Number 2 for Improve d Implemen tation of the Part 70 Operating Permits Program , March 5, 1996, U.S
. Environmental Protection Agency, Office of Air Quality Planning and Standards. Th e overalleffect of compliance with alternative requirements shall consider the effect o n an intrinsic basis, such as pounds per ton of clinker produced by the kiln, c. The U.S. Environmental Protection Ag ency (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 wit h the proposed permit, or e. If the EPA and public comment periods ran concurrently, then the District ha d 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

168 The District's determination of approval of any alternative requirements is not binding o n EPA. Noncomplian ce with any alternative requirement established pursuant to the Title V Operating Permit process constitutes a violation of this NO RACT Plan. xPermit No. 156-97-TV Plant ID 0060

169 Appendix A to NO RACT Plan x Amendment 1 Requirements for NO CEMS x 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 NO emission rates measured by the CEMS shall be expressed x 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 NO rates expressed in pounds per ton of clinker produced shall be calculated x 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 NO CEMS shall be installed and operated in compliance with the x 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 NO CEMS shall be determined so that all expected x concentrations can be accurately measured and recorded as indicated in NO x 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 inPermit No. 156-97-TV Plant ID 0060

170 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 xPermit No. 156-97-TV Plant ID 0060

171 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 NO per ton of clinker produced by the x 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 NO emission rates, expressed as pounds per ton x 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,Permit No. 156-97-TV Plant ID 0060

172 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 NO RACT Plan - Amendment 1 shall be maintained x by Kosmos for a period of 5 years following the date of such record.Permit No. 156-97-TV Plant ID 0060

173 NO RACT Plan Appendix B x Amendment 1 Requirements for Flow Monitors and Additional Requirements for NO CEMS x 1. Installation of the Flow Monitor In stall the flow monitor in a location that provides representative volumetric flow over al l operatingconditions. Such a location is one that provides an average velocity of the flue ga s flo w over the stack or duct cross section, provides a representative NO emission rate (i n x lb/ton of c linker produced by the cement kiln), and is representative of the pollutan t concentrationmonitor location. Where the moisture content of the flue gas affects volumetri c flow measurements, use the procedures in both Reference M ethods 1 and 4 of 40 CFR Part 60 Appendix A to establish a proper location for the flow monitor. The District recommend s (but d oes 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 level s indicated in section 5.b. to determine the acceptability of the potential flow monito r 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 evenif the flow measurement location is greater than or equal to 2 equiv alent 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) orstratifie d flow conditions exist at the potential flow monitor location that are likely t o prevent the monitor from meeting the performance specifications of th is Appendix, then the Dist rictrecommends either (1) selecting another location where there is no cyclonic (o r swirling) or stratified flow condition or (2) eliminating the cyclonic (or swirling) or stratifie d flow condition by straightening the flow, e.g., by installing straightening vanes. The Distric t also recommends selecting flow monitor l ocations to minimize the effects of condensation, coating, erosion, or o ther conditions that could adversely affect flow monitor performance. 2. Acceptability of Monitor Location If the flow monitor is in stalled in a location that does not satisfy these physical criteria, but nevertheless the monitor achieves the performance specifications o f this Appendix, then the location is acceptable, notwithstanding the requirements of this Appendix. Whenever

Kosmos successfully demonstrates that modifications to the exhaust duct or stac k (suchas installation of straightening vanes, modifications of ductwork, and the like) ar e necessar y for the flow monitor to meet the performance specifications, the District may approvean interim alternative flow monitoring methodology and an extension to the require d certification date for the flow monitor. Wh ere no location exists that satisfies the physical siting criteria in the previous tw o paragr aphs, where the results of flow profile studies performed at two or more alternativ e flow monitor locations are unacceptable, or where installation of a flow monitor in either th e stack or the ducts is demonstrated to be technically infeasible, Kosmos may petition th e District for an alternative method for monitoring flow.Permit No. 156-97-TV Plant ID 0060

174 3. Equipment Specifications
a. Instrument Span To the extent practicable, measure at a range such that the majority of reading s 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 ca n accurately measure all potential volumetric flow rates at the flow monitor installatio n sit e. For this purpose, determine the span value of the flow monitor using th e following procedure: i. Determi ne the MPV or maximum potential flow rate (MPF) in scfh (we t basis) from velocity traverse testing. ii. Use th e highest velocity measured at or near the maximum unit operatin g 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 th e measurement units used for the daily calibration error test to calculate th e span value. v. Multiplyt he MPV (in equivalent units) by 125 percent, and round up th e 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 cond itions change such that the maximum potential velocity may chang e significantly, adjust therange to assure the continued accuracy of the flow monitor. Calculate an adjusted span using the procedures in this section. Select the full-scale rangeof 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 spanvalue, MPV, and MPF, and the adjusted span v alue to the District and include this information in the monitoring plan. R ecord 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 b ased 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 mon itor's range that requires an internal modification to the monitor. b. Design for Quality Control Testing i. Design of the Flow Monitor De sign all the flow monitors to meet the applicable performanc e specifications. ii. Calibration Error TestPermit No. 156-97-TV Plant ID 0060

175 Design and equip each flow monitor to allow for a daily calibration err or 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 an y 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 an d handling system, or B) theflow monitoring system from and including the transducer throug h 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 mo isture expected to occur at the monitoring location does no t interfere withthe proper functioning of the flow monitoring system. Design a nd equip each flow monitor with a means to detect, on at least a daily basis, pluggage of each sample line and sensing port, an d mal function 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 (simultaneousl y on both si des of the probe) or equivalent method of sufficient forc e 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 t o prevent velocity sensing interference. D) Designand equip each ultrasonic flow monitor with a means to ensure on at least a daily basis that the transceivers remain suf ficiently clean (e.g., backpurging system) to prevent velocity sensing interference. 4. Performance Specifications
a. Calibration Error Thecalibration error of flow monitors shall not exceed 3.0 % based upon the span o f 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 level s of the relative accuracy test audit is less than or equal to 10.0 fps, the mean value of the fl ow monitor velocity measurements shall not exceed ±2.0 fps of the referenc ePermit No. 156-97-TV Plant ID 0060

176 method mean valu e 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 followin g procedures: i. Intro duce the reference signal corresponding to the values specified i n section 3.ii.B) to the probe tip (or equivalent) or to the transducer. ii. Duri ng the 7-day certification test period, conduct the calibration error tes t whi le the cement kiln is operating once each operating day (as close t o 24- hour intervals as practicable). In the event that extended cement kil n outages occur after the commencement of the test, the 7 consecutiv e operating days need not be 7 consecutive calendar days. iii. Recordthe flow monitor responses by means of the data acquisition an d handling system. iv. Calculate the calibration error using Equation A-6 of 40 CFR Part 7 5 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 require d for normal daily operation as specified by the monitor manufacturer or by th e NO RACT Plan - Amendment 1. x vi. Do notmake adjustments between the zero and high reference leve l measurements on any day during the 7-day test. vii. If t he flow monitor operates within the calibration error performanc e specification (i.e., less than or equal to 3 % error each day and requiring no corrective m aintenance, 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. Re cordall adjustments made during the 7-day period at the time th e 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 differen t exhaust gas velocities, expressed in terms of percent of flow monitor span, o r different operating levels. Select the operating levels as follows: A) A f

requently used low operating level selected within the rang e between the minimum safe and stable operating leve l and 50 % load,Permit No. 156-97-TV Plant ID 0060

177 B) A f

requently used high operating level selected within the rang e between80 % of the maximum operating level and the maximu m operating level, and C) The normal operating level. ii. If the normal operating level is within 10.0 % of the maximum operating leve l of either A) or B) above, use a level that is evenly spaced between the low an d high operating levels used. The maximum operating level shall be equal to th e design capacity less any physical or regulatory limitati ons or other deratings. Calculateflow monitor relative accuracy at each of the three operating levels
. If a flow monitor fails th e 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 t o 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 i n 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 a s 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 th e flue cross section, and ii. Meet

the requirements of 40 CFR Part 60 Appendix A Method 1 (or 1A)(fo r volumetric flow). f. Sampling Strategy Conduct the reference method tests so they will yield results representative of the flu e gas flow rate from the cement kiln and can be correlated with the flow monitor CEM S measurements. To properly correlate the volumetric flow rate data with the referenc e method data, mark the beginning and end of each reference method test run (includin g the exact time of day) on the individual chart recorder or other permanent recording device.Permit No. 156-97-TV Plant ID 0060

178 g. Correlationof Reference Method and Continuous Emission Monitoring Syste m i. Confirm that the monitor or monitoring system and reference method tes t results are on consistent moisture basis (e.g., since the flow monitor measure s flow rate on a wet basis, Method 2 test results shall also be on a wet basis). ii. Compare flow-monitor and reference method resul ts on an scfh basis. Also, consider the response times of the flow monitoring system to ensur e comparison of simultaneous measurements. iii. For each relative accuracy test audit run, compare the measurements obtaine d fromt he monitor or continuous emission monitoring system against th e 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 referenc e methodtest data for every required relative accuracy test. For the certification and ann ual quality assurance relative accuracy test audits for flow monitors, perform a minimum of 9 sets at each operating level as sp ecified 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 tes ts. 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 relativ e 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 Thefollowing methods from 40 CFR Part 60 Appendix or their approved alternative s are the refere nce 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 fo r moisture. 6. Calculations
a. Flow Monitor Calibration Error For each reference value, calculate the p ercentage 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 thereference method test for flow monitors using the following procedures: i. Summarize theresults on a data sheet. An example is shown in Figure 3 of 40 CFR Part 75 Appendix A. ii. Calculatethe mean of the monitor or monitoring system measurement values
. iii. Calculate the mean of the reference method values. iv. Usi ng data from the source CEMS, calculate the arithmetic difference s between the reference method and monitor measurement data sets. v. Calculat e the arithmetic mean of the difference, the standard deviation, th e confidencecoefficient, and the monitor or monitoring system relative accurac yPermit No. 156-97-TV Plant ID 0060

179 using the procedures and equations fou nd in 40 CFR Part 75 Appendix A as is specified in the following sections.
c. Arithmetic Mean Calculatethe 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 givenin 40 CFR Part 75 Appendix A.
e. Confidence Coefficient Calculate the confidence coefficie nt 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 o f 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 sinc e the previous calibration error test. For example, if the flow has not exce eded thelow scale value (based on the maximum expected concentration) since th e previous calibration error test, the calibration error test ma y be performed on the low scale only. If, however, the flow has exceeded the low scale spa n 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 da ily calibration error tests shall be performed while the unit is i n operation at normal, stable conditions (i.e. "on-line"). b. Daily Flow Interference Check Perform the daily flow monitor interference checks specified in secti on 3.b.iii. while the unit is in operation at normal, stable conditions.
c. Recalibration TheDistrict recommends adjusting the calibration, at a minimum, whenever the dail y calibrationerror exceeds the limits of the applicable performance specification for th e flow monitor in section IV. d. Out-of-Control Period i. An out-of-control period occurs when the calibration erro r of a flow monitor exceeds 6.0 % based upon the span value, which is twice the applicabl e specification of this section. Th e out-of-control period begins with the hourPermit No. 156-97-TV Plant ID 0060

180 of com pletion of the failed calibration error test and ends with the hour o f completion following an effective recalibration. Whenever the faile d calibration, corrective action, and effective recalibration occur within the sam e hour, t he hour is not out of control if 2 or more valid readings are obtaine d during that hour. ii. Anout-of-control period also occurs whenever interference of a flow monito r is identified. The out-of-control period begins with the hour of completion o f the failed interference check and ends with the hour of completion of a n 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 er ror test or daily flow interference check), data from that monitoring system are prospectivel y validated for 26 clock hours (i.e., 24 hours plus a 2-hour grace period) beginning wit h thehour in which the test is passed, unless another assessment (i.e. a daily calibratio n error te st, 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 th e 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 dail y fl ow interference check), a start-up grace period may apply when a unit begins t o operateafter a period of non-operation. The start-up grace period for a dail y calibration error test is independent of the start-up grace period for a daily flo w interferencecheck. 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 mor e hours (i.e., the unit must be in a start-up condition) as evidence d by a change inunit 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 , theprevious daily assessment of the same kind must have been passed on-lin e within 26 clock hours prior to the last hour in which theunit 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
. Du ring the start-up grace period, data generated by the monitoring system ar e considered quality-assured. For eachmonitoring 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 flo w interference check) is performed, or ii. 8 clock hours have elapsed (starting with the first hour of unit operatio n following the outage), whichever occurs first.Permit No. 156-97-TV Plant ID 0060

181 h. Data Recording Recor dand tabulate all calibration error test data according to month, day , clock-hour, and magnitude in scfh. Program monitors that aut omatically adjust data to the corrected calibration values (e.g., microprocessor control) to record either: i. The u nadjusted flow rate measured in the calibration error test prior t o 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 sys tem, perform a leak check of all sample lines (a manual check is acceptable) during each unit operating quarter. Thi s requirement

is effective as of the calendar quarter following the calendar quarter in which th e flow monitor or flow emission monitoring system is provisionally certified. 9. Annual Assessments Forth e flow monitor, perform the relative accuracy test audit (RATA) assessment onc e annually(within four calendar quarters) after the calendar quarter in which the monitor o r monitoringsystem was last tested, as specified below for the type of test and the performanc e ac hieved. 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 accu racy test audits annually and, to the extent practicable, no less than 4 m onths 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 relativ e accuracy of a flow monitor exceeds 10.0 %, for low flow situations (£10.0 fps) or th e flo w monitor mean value (if applicable) exceeds ±2.0 fps of the reference metho d mea n whenever the relative accuracy is greater than 15.0 %. For a flow relativ e accuracyt est audit at 3 operating levels, the out-of-control period begins with th e 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-leve l relative accuracy test audit. 10. Other Audits Affect edunits may be subject to relative accuracy test audits at any time. If a monitor or continuous emission monit oring system fails the relative accuracy test during the audit, the monitor or continuous emission monit oring system shall be considered to be out-of-controlPermit No. 156-97-TV Plant ID 0060

182 beginningwith the date and time of completion of the audit, and continuing until a successfu l audit test is completed following corrective action. 11. Span Determination for the NO Monitor x a. To the extent practicable, measure the NO emissions at a range such that the majority x of readings obtained during normal operatio n 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 th e maximum potential concentration (MPC) as determined below in this section
. To de termine the maximum potential concentration, Kosmos may use NO x emiss ion test results or historical fully quality assured CEMS data over th e previous 30 unit operating days. Multiply t he MPC by 125 % and round up to the nearest multiple of 100 ppm to determine the span value. The spa n value shall be used to determine the concentrations of the calibration gases. ii. Reportth e full-scale range setting and calculations of the MPC, maximu m pote ntial NO emission rate, and span to the District and record them in the

x monitoringplan. Select the full-scale range of the instrument to be consisten t with section 11.a, and to be greater than or equal to the span value. Thi s selected monitor range with a span rounded up from 125 % of the maximum potential concentration shall be the "high scale" of the NO pollutan t x concentration monitor. iii. If NO emission testing is used to determine the maximum potential NO x x concentration, use the following guidelines: A) UseMethod 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 leve l, the normal production level, and the maximum production level. If the no rmal load and maximum load are identical, an intermediate leve l need not be tested. C) Oper ateat the highest excess O level expected under normal 2 operating conditions. D) Make at lea st 3 runs with 3 traverse points of at least 20 minute s duration at each operating condition. E) Select the highest NO concentration from all measured v alues as the x maximum potential concentration for NO . If historical CEM data are x used to determine the MPC, the data must represent various operatin g conditions, includin g the minimum safe and stable production level, normal production level, and production level load. F) Calculate the MPC and span using the highest hourly NO x concentration in ppm.
c. Maximum Expected ConcentrationPermit No. 156-97-TV Plant ID 0060

183 i. If the majority of NO concentrations are expected to be less than 25 % of th e x full -scalerange of the instrument selected under section 11.b, use a "lo w scale" measurement range. ii. Calc ulatethe span for the additional (lower) range by multiplying th e maximum expected concentration by 125 % and by rounding up the resultan t conce ntration to the nearest multiple of 10 ppm. The span value of thi s additional (lower) range shall also be used to determine the concentrations o f the calibration gases. iii. Includethe full-scale range setting and calculations of the MEC and span an d report these to the District and record them in the monitoring plan. iv. Se lectthe full scale range of the instrument to be consistent with sectio n XI.A., and to be greater or equal to the lower range span value. This selecte d monitor range with a span rounded up from 125 % of the maximum expecte d 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 o f 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 th e span value for an auto-ranging monitor as 125 % of the maximum potential concentrationand 125 % of the maximum expected concentration if a second span i s de terminedto be necessary under section 11.iii. Determine concentrations of th e calibration gases based upon the span value.
e. Adjustment of Span i. Whenever

the fuel supply, emission controls, or other process parameter s chang e such that the maximum expected concentration or the maximu m poten tial concentration may change significantly, adjust the NO pollutan t x concentrationspan and monitor range to assure the continued accuracy of th e monitoring system. Determine the adjusted s pan value using the procedures insections 11.ii. or 11.iii. Select the new full scale range of the instrument t o be greater than or equal to the adjusted span value and to be consistent with the guidelines of section 11.i. ii. Reco rd and report the new full-scale range setting, calculations of the span value, MPC, and MEC (if appropriate), maximum potential NO emission rat e x and the adjusted span value to the District and record them in th e 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 base d on the most recent adjusted span value. Perfo rm 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 significan t change is made in the monitor's range that requires an internal modification t o the monitor (e.g., a change of measurement cell length).Permit No. 156-97-TV Plant ID 0060

184 12. Data Acquisition and Handling Systems Automated data acquisition and handling systems shall meet the following requirements: a. Read and r ecord the full range of potential NO emission concentrations an d x volumetricflow from zero through span, raw materials input rates to the cement kiln , and flow (if used), b. Providea continuous, permanent record of all measurements and required informatio n as an ASCII flat file capable of transmission via an IBM-compatible persona l computer diskette or other electronic media, c. Interpret and convert the individual output signals from a flo w monitor (if used) and a NO CEMS to produce a continuous readout of pollutant mass emission rates in th e x units of pounds NO per ton of clinker produced by the cement kiln, x d. Calculate and record intermediate values necessary to obtain emis sions rates such as NO concentration, raw materials input to the cement kiln, and flow (if used), and x e . Calculateand record emissions in units of the standard (pounds NO per ton of clinke r x produced by the cement kiln). 13. Data Preparation If the NO concentration is in ppm, multiply it by 1.194 × 10 (lb/dscf)/ppm to convert it to x -7 units of lb/dscf. If the NO concentration is in mg/dscm, multiply it by 6.24 x 10 x -8 (lb/dscf)/(mg /dscm) to convert it to lb/dscf. Then, use the appropriate gas flow rate an d clinker production rate to calculate the emi ssions in terms of pounds NO per ton of clinker x produced by multiplying lb/dscf by the appropriate dscf and dividing by the appropria te 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 clinke r 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 Append ix A Figure 4 (replace lb/mmBtu with lb/tons of clinker produced by the cement kiln). 15. Relative Accuracy Usethe equations and procedures in 40 CFR Part 60 Appendix B Specification 2 to calculat e the relati ve accuracy for the NO CEMS. In using Equation 2-1, "d" is, for each run, th e x difference between the NO emission rate values (in lb per ton of clinker produced by th e x cement kiln) obtained from the reference method data and the NO CEMS. x 16. Quality Assurance and Quality Control Procedures Quality Control Program D e velop and implement a quality control program for the continuous emission monitoring systems an d their components. As a minimum, include in each quality control program a writtenplan that describes in detail complete, step-by-step procedures and operations for eac h of the following activities:Permit No. 156-97-TV Plant ID 0060

185 a. Calibration Error Test and Linearity Check Procedures. Identify calibration errortest and linearity check procedures specific to the CEMS that may require variancefrom the procedures in this NO RACT Plan - Amendment x 1. b. Calibration and Linearity Adjustments. Explain how each component of the CE MS will be adjusted to provide correct responses to calibration gases , referen ce values, and/or indications of interference both initially and afte r repairs or corrective action. Identify equ ations, conversion factors, assumed moisture content, and other factors affecting calibration of each CEMS. c. Preve ntive Maintenance. Keep a written record of procedures, includin g thosespecified by the manufacturers, needed to maintain the CEMS in prope r 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 t he 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 owneror operator is hereby granted a permit shield that shall apply as long as the owner o r operator demonstrates ongoing compliance with all the conditio ns of this permit. Compliance with the condition s of this permit shall be deemed compliance with all applicable requirements of th e 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 (Emiss ion Unit) shall be listed with the specificPermit No. 156-97-TV Plant ID 0060

187 process even though there may be no applicable requirements. Information containe d inthe permit and permit summary shall clearly indicate that those items identified wit h negligible emissions have no applicable requirements. B. Activities identified In Regulation 2.02, Section 2, may not require a permit and ma y be insignificant with regard to application disclosure requirements but may still h ave genera lly applicable requirements that continue to apply to the source and must b e included in the Title V permit. i. Nofacility, having been designated as an insignificant activity, shall be exemp t 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 a s insignificant activities.