### Permit No. 11339 Expiration Date: May 15, 2009 Page 1 of 81

Ash Grove Operating Permit, May 15, 2004 

# AIR OPERATING PERMIT

Puget Sound Clean Air Agency 110 Union Street, Suite 500 Seattle, Washington 98101

Issued in accordance with the provisions of Puget Sound Clean Air Agency (previously known as Puget Sound Air Pollution Control Agency ) Regulation I, Articl e 7 and Chapter 173-401

WAC.

Ash Grove Cement Company, Inc. is authorized to operate subject to the terms and conditions in this permit.



## PERMIT NO.: 11339 DATE OF ISSUANCE : May 15, 2004

ISSUED TO: Ash Grove Cement Company, Inc.



## PERMIT EXPIRATION DATE : May 15, 2009

SIC Code, Primary: 3241 Hydraulic Cement Manufacturing

NAICS Code 32731 Hydraulic Cement Manufacturing

Nature of Business: Hydraulic Cement Manufacturing

Mailing Address: 3801 E Marginal Way South, Seattle WA, 98106-1599

Facility Address: 3801 E Marginal Way South, Seattle WA, 98106-1599

Responsible Official: Craig Puljan, Plant Manager

Telephone No.: (206) 623-5596

FAX No.: (206) 623-5355

Site Contact: Gerry Brown, Safety/Environmental Manager

Telephone No.: (206) 623-5596

FAX No.: (206) 623-5355



## Puget Sound Clean Air Agency Approval :



### Fred L. Austin, P.E.

Permit Engineer Steven M. Van Slyke, P.E. Supervisory Engineer

### Permit No. 11339 Expiration Date: May 15, 2009 Page 2 of 81

Ash Grove Operating Permit, May 15, 2004 

# TABLE OF CONTENTS

I. EMISSION LIMITS AND PERFORMANCE STANDARDS 3

II. MONITORING, MAINTENANCE AND RECORDKEEPING

METHODS DESCRIPTION 35

III. PROHIBITED ACTIVITIES 53

IV. ACTIVITIES REQUIRING ADDITIONAL APPROVAL 56

V. STANDARD TERMS AND CONDITIONS 57

VI. PERMIT ACTIONS 65

VII. PERMIT SHIELD 71

VIII. INAPPLICABLE REQUIREMENTS 72

IX. INSIGNIFICANT EMISSION UNITS 78

X. APPENDIXES 78

### Permit No. 11339 Expiration Date: May 15, 2009 Page 3 of 81

Ash Grove Operating Permit, May 15, 2004 

## I. EMISSION LIMITS AN D PERFORMANCE STANDARDS

The following tables list the citation for the “appli cable requirement” in the second column. The third column (Date) contains the adoption or eff ective date of the requirement. In some cases,

the effective dates of the Federa lly Enforceable Requirement and the State Only Requirement are different because only rules approved by EPA through Sections 110, 111, and 112 of the federal Clean Air Act are federally enforceable and eith er the state has not su bmitted the regulation to the EPA or the EPA has not approved it.

The first column is used as an identifier for the requirement, and the fourth (Requirement Paraphrase) column paraphrases the requireme nt. The first and fourth columns are for information only and are not enforceable conditions of this permit. The actual enforceable requirement is embodied in the requirement cited in the second and third columns.

The fifth column (Monitoring, Maintenance & R ecordkeeping Method) identifies the methods described in Section II of the permit. Followi ng these methods is an enforceable requirement of this permit. The sixth (Emission Standard Period) column identi fies the averaging time for the reference test method. The last column (Referen ce Test Method) identifie s the reference method associated with an applicable emission limit that is to be used if and when a source test is required. In some cases where the applicable requirement does not cite a test method, one has

been added.

In the event of conflict or omi ssion between the information cont ained in the f ourth and sixth columns and the actual statute or regulation c ited in the second column, the requirements and language of the actual statute or regulation cited shall govern. For more information regarding any of the requirements cited in the second and third columns, refer to the actual requirements

cited.Permit No. 11339Expiration Date: May 15, 2009Page 4 of 81Ash Grove Operating Permit, May 15, 2004A. FACILITY-WIDE APPLICABLE REQUIREMENTSThe requirements in this section apply facility-wide to all theemission units regulated by this permit, except as otherwise stated in a permit condition.Reqmt.No.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodOpacity StandardsI.A.1Puget Sound Clean Air AgencyReg I: 9.03(a)-(c)09/08/94Ash Grove shall not emit more than 20%opacity for a period or periods aggregatingmore than 3 minutes in any 1-hour periodII.A.1 GeneralOpacityMonitoringMore than 3min. in any 1hrEcologyMethod 9A7/12/1990(See Section X)I.A.2WAC 173-400-040(1)09/20/93Ash Grove shall not emit more than 20%opacity for more than 3 minutes in any 1-hour period.II.A.1 GeneralOpacityMonitoringMore than 3min. in any 1hrEcologyMethod 9A7/12/1990(See Section X)Particulate StandardsI.A.3Puget Sound Clean Air AgencyReg. I: 9.09(a)This requirementshallbesuperseded by the 4/9/98 version ofReg. I: 9.09 upon its adoption intothe SIP02/10/94Ash Grove shall not emit particulate matterin excess of 0.05 gr/dscf from equipmentused in a manufacturing processuncorrected for excess airII.A.1 GeneralOpacityMonitoring(3) 1-hourrunsPuget SoundClean AirAgency Method5(See Section X)I.A.4WAC 173-400-060This requirementshallbesuperseded by the 9/15/01 versionof WAC 173-400-060 upon itsadoption into the SIPWAC 173-400-060(State Only)This requirement will becomefederally enforceable uponadoption into the SIP and willreplace the 3/22/91 version ofWAC 173-400-060.3/22/919/15/01Ash Grove shall not emit particulate matterin excess of 0.10 gr/dscf from generalprocess units, uncorrected for excess airII.A.1 GeneralOpacityMonitoring(3) 1-hourrunsEPA Method 5(40 CFR Part60, AppendixA, July 1, 2002)Permit No. 11339Expiration Date: May 15, 2009Page 5 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodI.A.5Puget Sound Clean Air AgencyOrder of Approval No. 7381,Condition 46/6/01 PM-10 emissionsfrom each baghouseexcept the main stack baghouse, shall notexceed 0.005 grains /dscf over a 24 hourperiod.II.A.1 GeneralOpacityMonitoring24 hoursEPA Methods 5or 201A (40CFR Part 60,Appendix A,July 1, 2002; 40CFR Part 51,Appendix M,July 1, 2001)SO2StandardsI.A.6Puget Sound Clean Air AgencyReg I: 9.07WAC 173-400-040(6) firstparagraph only.04/14/9409/20/93Ash Grove shall not emit SO2in excess of1,000 ppmv (dry) corrected to 7% O2forfuel burning equipmentNo monitoringrequired(3) 1-hourrunsEPA Method6C(40 CFR Part60, AppendixA, July 1, 2002)Nuisance StandardsI.A.7Puget Sound Clean Air AgencyReg I: 9.11(a)WAC 173-400-040(5)RCW 70.94.040 (State Only)WAC 173-400-040(2)(State Only)06/9/8309/20/9319969/15/01Ash Grove shall not emit air contaminantsin sufficient quantities and of suchcharacteristics and duration as is, or is likelyto be, injurious to human health, plant oranimal life, or property, or whichunreasonably interferes with enjoyment oflife and propertyAsh Grove shall not deposit particulatematter beyond property boundary insufficient quantity to interfere unreasonablywith the use and enjoyment of the propertyII.A.2 ComplaintResponseII.A.3 RooftopInspectionsII.A.4 O&M PlanInspectionsNA NAPermit No. 11339Expiration Date: May 15, 2009Page 6 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodI.A.8WAC 173-400-040(4)(State Only)9/15/01 Ash Grove shall use recognized goodpractice and procedures to reduce odorswhich may unreasonably interfere with anyother property owners’ use and enjoymentof their propertyII.A.2 ComplaintResponseII.A.3 RooftopInspectionsNA NAFugitive Dust StandardsI.A.9Puget Sound Clean Air AgencyReg. I: 9.15(a)This requirementshallbesuperseded by the 3/11/99 versionof Reg. I: 9.15(a) upon its adoptioninto the SIP8/10/89 Ash Grove shall employ BACT for fugitivedustII.A.4 O&M PlanInspectionsNA NAI.A.10Puget Sound Clean Air AgencyReg. I: 9.15(c)This requirementshallbesuperseded by the 3/11/99 versionof Reg. I: 9.15(a) upon its adoptioninto the SIP8/10/89 Ash Grove shall not cause or allow theemission of fugitive dust from refuseburning equipment, fuel burning equipment,equipment used in a manufacturing processor control equipment.II.A.3 RooftopInspectionsII.A.4 O&M PlanInspectionsNA NAPermit No. 11339Expiration Date: May 15, 2009Page 7 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodI.A.11WAC 173-400-040(3)(a)WAC 173-400-040(8)(a)These requirementsshallbesuperseded by the 9/15/02 versionsof SIP WAC 173-400-040(3)&(8)upon adoption into the SIPWAC 173-400-040(3)(a)(StateOnly)WAC 173-400-040(8)(a)(StateOnly)These requirements will becomefederally enforceable uponadoption into the SIP and willreplace the 9/20/93 versions ofWAC 173-400-040(3)&(8)9/20/939/20/939/15/019/15/01Ash Grove shall take reasonable precautionsto prevent the release of fugitive emissionsand to minimize emissions of fugitive dust.II.A.3 RooftopInspectionsII.A.4 O&M PlanInspectionsNA NAI.A.12Puget Sound Clean Air AgencyReg. I: 9.15(b)This requirementshallbesuperseded by the 3/11/99 versionof Reg. I: 9.15(a) upon its adoptioninto the SIP.8/10/89 Ash Grove shall employ measures toprevent track-out and spillage of particulatematter on paved public roadwaysII.A.5 VehicleTrack OutNA NAI.A.13Puget Sound Clean Air AgencyReg. I: 9.15(a)(State Only)This requirement will becomefederally enforceable uponadoption into the SIP and willreplace the8/10/98version of Reg.I: 9.15 into the SIP.3/11/99 Ash Grove shall not cause or allow visibleemissions of fugitive dust unless reasonableprecautions are employed to minimize theemissions.II.A.3 RooftopInspectionsII.A.4 O&M PlanInspectionsNA NAOperation and Maintenance StandardsPermit No. 11339Expiration Date: May 15, 2009Page 8 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodI.A.14Puget Sound Clean Air AgencyReg. I: 9:20RCW 70.94.152(7) (State Only)6/09/881996Ash Grove shall maintain equipment ingood working orderEquipment described in plans,specifications or other informationsubmitted in support of a notice ofconstruction application shall be maintainedand operate in good working orderII.A.4 O&M PlanInspectionsNA NAI.A.15Puget Sound Clean Air AgencyReg. I: 7.09(b)9/12/96 Ash Grove shall develop and implement anO&M Plan to assure continuous compliancewith Puget SoundClean Air AgencyRegulations I, II and IIINOTE: See EU 1.31 for 40 CFR Part 63O&M plan requirements for the kilnII.A.4 O&M PlanInspectionsNA NAEmissions from common stackI.A.16WAC 173-400-040 09/20/93 Emissions from a common stack must meetthe most restrictive standard of any of theconnected emissions unitsNo monitoringrequiredNA NAHCl StandardsI.A.17Puget Sound Clean Air AgencyReg. I: 9.10(a)(State Only)06/09/88 Ash Grove shall not emit HCl in excess of100 ppm (dry) corrected to 7% O2forcombustion sourcesNo monitoringrequired(3) 1-hourrunsEPA Method 26or 26A(40 CFR Part60, AppendixA; July 1, 2002)Visible Emissions per WAC 173-434 (see EU-1)Permit No. 11339Expiration Date: May 15, 2009Page 9 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodI.A.18WAC 173-434-130(4)(c)This requirement shall besuperseded and becomeinapplicable by the 1/22/04 versionof WAC 173-434 once it is adoptedinto the SIP.10/18/90 Ash Grove shall not exceed visibleemissions from emission units (other thanthe kiln) greater than an average of 0percent opacity for more than sixconsecutive minutes in any sixty minuteperiod.II.A.1 GeneralOpacityMonitoring6-minuteperiodEPA Method 9(40 CFR Part60, AppendixA, July 1, 2002(See Section X)NA = Not ApplicablePermit No. 11339Expiration Date: May 15, 2009Page 10 of 81Ash Grove Operating Permit, May 15, 2004B. EMISSION UNIT SPECIFICAPPLICABLE REQUIREMENTSThe requirements in Section I.B. apply onlyto the specific emission unitscited; however, the requirements in Section I.A. also apply tothose units, except as otherwise provided in this section.1.Emission Unit #1 (EU-1): Rotary Cement Kiln, Main Stack and Coal MillsThis emission unit consists of a nominal 2400 ton/day capacity rotary Portland cement kiln, primarilyfired with coal and natural gas, andcontrolled by a nominal 177,000 acfm baghouse. The main stack emissions are monitored for opacity, carbon monoxide, nitrogen oxidesand sulfur dioxide emissions by a continuous emission monitoring system. Fuels include bituminous coal, whole tires, a small amount ofinternally generated waste lubricating oilsand greases, and natural gas. Dust entrained in the flue gases is collected in theFullerBaghouse.Although most of the kiln emissions exit from the kiln/raw millthrough the main stack, a small portion of the hot kiln exhaustgases arerouted directly from the kiln exhaust to the coal mills for use in thermally drying coal priorto grinding. Each coal mill iscontrolled by anominal 10,400 acfm baghouse. This emission unit includes the coalmills because a small portion ofkiln exhaust gases vent totheatmosphere through the coal mill baghouse stacks.Emission Unit (EU-1)Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodOpacity StandardsEU 1. 1Puget Sound Clean AirAgency Reg. I: 9.09(b)(1)This requirementshallbesuperseded by the 4/9/98version of Reg. I: 9.04(c)(2)upon its adoption into theSIP.02/10/94 Ash Grove shall not cause orallow the emission of any aircontaminant (as determined bythe COMS) from the kiln stackthat exceeds 20% opacity for aperiod aggregating more than 3minutes in any 1 hour.II.B.1 ContinuousOpacity MonitoringSystemMore than 3min. in any 1hrEPA PerformanceSpecification 1(40 CFR 60, AppendixB July 1, 1997)Ecology Method 9A7/12/1990(See Section X)Permit No. 11339Expiration Date: May 15, 2009Page 11 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 2Puget Sound Clean AirAgency Reg. I: 9.04(c)(2)(State Only)This requirement willbecome federallyenforceable upon adoptioninto the SIP.04/09/98 Ash Grove shall not cause orallow the emission of any aircontaminant (as determined bythe COMS) from the kiln stackduring any hour that contains anyconsecutive 6-minute periodaveraging greater than 20%opacity.II.B.1 ContinuousOpacity MonitoringSystem6-minuteperiodEPA PerformanceSpecification 1(40 CFR 60, AppendixB, July 1, 1997)EPA Method 9(40 CFR 60, AppendixA, July 1, 2002.EU 1. 3Puget Sound Clean AirAgency Reg. I: 9.09(b)(2)This requirementshallbesuperseded by the 4/9/98version of Reg. I: 9.04(c)(1)upon its adoption into theSIP.02/10/94 Ash Grove shall not cause orallow the emissions of any aircontaminant (as determined bythe COMS) from the kiln stackthat averages greater than 5%opacity for a 1-hour average.II.B.1 ContinuousOpacity MonitoringSystem1-houraverageEPA PerformanceSpecification 1(40 CFR 60, AppendixB July 1, 1997)EU 1. 4Puget Sound Clean AirAgency Reg. I: 9.04(c)(1)(State Only)This requirement willbecome federallyenforceable upon adoptioninto the SIP04/09/98 Ash Grove shall not cause orallow the emission of any aircontaminant (as determined bythe COMS) from the kiln stackduring any hour that averagesgreater than 5% opacity for a onehour average.II.B.1 ContinuousOpacity MonitoringSystem1-houraverageEPA PerformanceSpecification 1(40 CFR 60, AppendixB, July 1, 1997)EPA Method 9(40 CFR 60, AppendixA, July 1, 2002.Puget Sound Clean Air Agency Orders ofApproval NC 5687 – Waste Derived FuelsEU 1. 5Puget Sound Clean AirAgency Order of ApprovalNo. 5687Condition 41/11/95Ash Grove shall burn in the kilnonly waste derived fuelsgenerated on site and not toexceed 6,000 pounds of greasesand 4,800 pounds of oils per year.II.B.5 Waste DerivedFuel ConsumptionAnnual NAPermit No. 11339Expiration Date: May 15, 2009Page 12 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 6Puget Sound Clean AirAgency Order of ApprovalNo. 5687Condition 51/11/95Ash Grove shall limit wastederived fuels to fuels that are nonhazardous as defined in WAC173-303-515, SpecialRequirements for Used OilBurning for Energy Recovery, orby WAC 173-303-090,Dangerous Waste Characteristicsas appropriate.II.B.5 Waste DerivedFuel ConsumptionNA NAPuget Sound Clean Air Agency Orders ofApproval NOC 5755 – Tire Derived FuelEU 1. 7Puget Sound Clean AirAgency Order of ApprovalNo. 5755, Condition 43/30/95Tire derived fuel substitutes shallbe nonhazardous as defined byWAC 173-303-515 or WAC 173-303-090, as appropriate.No monitoringrequired.NA NAEU 1. 8Puget Sound Clean AirAgency Order of ApprovalNo. 5755, Condition 53/30/95Daily weight of whole tiresburned in the kiln shall notexceed 30 % of the total weight offuels consumed in the kiln.II.B.6 Tire DerivedFuel ConsumptionDaily NAPuget Sound Clean Air Agency Order of Approval NOC 7381 and PSD Permit 90-03 -- Kiln BACT limits.EU 1. 9Puget Sound Clean AirAgency Order of ApprovalNo. 7381Condition 5(a).PSD Permit 90-03,Amendment 3, Condition 36/06/0110/08/01CO emissions shall not exceed1045 ppm at 10% O2for an 8-hour average.CO emissions shall not exceed538 lbs/hour for an 8-houraverage.CO shall not exceed 2353 tonsper year including startup, shutdown and malfunction periods.II.B.2 SO2, CO andNOx CEMSII.B.3 SO2, CO andNOx Mass EmissionRate Monitoring8 hours andannualEPA Method 10(40 CFR Part 60,Appendix A, July 1,2002)EPA PerformanceSpecification 4(40 CFR Part 60,Appendix B, July 1,1997)Permit No. 11339Expiration Date: May 15, 2009Page 13 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 10Puget Sound Clean AirAgency Order of ApprovalNo. 7381Condition 5(b).PSD Permit 90-03,Amendment 3, Condition 16/06/0110/08/01NOxemissions shall not exceed650 ppm at 10% O2as a 24-hourrolling average.NOxemissions shall not exceed1846 tons as a 12-month runningtotal including startup, shut downand malfunction periods.If NOx emissions exceed 1400tons as a 12-month running total,Ash Grove shall notify the PugetSound Clean Air Agency (Attn.Permit Certification) describingactions that will be implementedto assure compliance with theannual NOx limit.II.B.2 SO2, CO andNOx CEMSII.B.3 SO2, CO andNOx Mass EmissionRate Monitoring24-hours andannualEPA Method 7E(40 CFR Part 60,Appendix A, July 1,2002)EPA PerformanceSpecification 2(40 CFR 60, AppendixB, July 1, 1997)EU 1. 11Puget Sound Clean AirAgency Order of ApprovalNo. 7381Condition 5(c).PSD Permit 90-03,Amendment 3, Condition 26/06/0110/08/01Except during startup andshutdown of the kiln andscheduled maintenance SO2emissions from the main stackshall not exceed 180 ppm at 10%O2for a one-hr average.During startup following theintroduction of feed to the kiln,SO2emissions from the mainstack shall not exceed 200 ppm at10% O2for a one-hr average.SO2 emissions shall not exceed176 tons per year includingstartup, shut down andmalfunction periods.II.B.2 SO2, CO andNOx CEMSII.B.3 SO2, CO andNOx Mass EmissionRate MonitoringOne hour &annualEPA Method 6C(40 CFR Part 60,Appendix A, July 1,2002)EPA PerformanceSpecification 2(40 CFR 60, AppendixB, July 1, 1997)Permit No. 11339Expiration Date: May 15, 2009Page 14 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 12Puget Sound Clean AirAgency Order of ApprovalNo. 7381Condition 6(a).PSD Permit 90-03,Amendment 3, Condition2(c)06/06/0110/08/01During kiln startup-preheatperiods prior to feed introduction,shutdown and scheduledmaintenance on the mainbaghouse the SO2emission limitfor the main baghouse shallconsist of compliance with thefollowing work practices and fuelrestrictions:(i) Only natural gas shall be usedas fuel.(ii) Sulfur rings shall be removedfrom the Kiln prior to startup ifsulfur rings formation hadrequired the kiln to be shut down.(iii) Ash Grove shall follow thekiln startup and shutdownprocedures in Appendix A toOrder of Approval No. 7381.II.B.8 Kiln WorkPractice MonitoringNA NAEU 1. 13Puget Sound Clean AirAgency Order of ApprovalNo. 7381Condition 5(d).06/06/01 Except during startup andshutdown of the kiln, scheduledmaintenance and emissionsconsidered unavoidable underWAC 173-400-107, PMemissions shall not exceed 10.6pounds per hour.II.B.9 PMMonitoring MainBaghouse(3) 1-hourrunsPuget Sound Clean AirAgency Method 5(See Section X)EU 1. 14Puget Sound Clean AirAgency Order of ApprovalNo. 7381Condition 5(d).06/06/01 PM emissions shall not exceed 46tons per year including startup,shut down and malfunctionperiods.II.B.9 PMMonitoring MainBaghouseII.B.10 ProductionRate Monitoringannual NAPermit No. 11339Expiration Date: May 15, 2009Page 15 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest Method40 CFR Part 60 Subpart F Standards ofPerformance for Portland Cement PlantsEU 1. 1540 CFR §60.62(a)(1)40 CFR §60.8(c)10/6/752/12/99Kiln exhaust shall not exceed0.30 lb of particulate per ton offeed (dry basis), except duringSSM periods.II.B.9 PMMonitoring MainBaghouseII.B.10 ProductionRate Monitoring(3) 1-hourrunsEPA Method 5 (40CFR 60, Appendix A,July 1, 2002)EU 1. 1640 CFR §60.62(a)(2)40 CFR 60.11(c)10/6/7510/17/00Kiln exhaust shall not exceed 20percent opacity, except duringstartup, shutdown andmalfunction periods.II.B.1 OpacityCOMS6 min.averageEPA Method 9(40 CFR 60, AppendixA, July 1, 2002.EU 1. 1740 CFR §60.63(a) 12/14/88 Ash Grove shall record the dailyproduction rates and kiln feedrates.II.B.10 ProductionRate MonitoringNA NA40 CFR Part 60 Subpart Y Standards of Performance for Coal Preparation FacilitiesEU 1. 1840 CFR 60.252(a)(1)40 CFR §60.8(c)10/17/002/12/99Coal mill exhaust shall not exceed0.031 gr/dscf, except during SSMperiods.II.A.1 GeneralOpacity MonitoringII.B.12 Coal PrepFacility PerformanceTest3 one-hourrunsEPA Method 5 (40CFR 60, Appendix A,July 1, 2002)EU 1. 1940 CFR 60.252(a)(2)40 CFR 60.11(c)10/17/0010/17/00Coal mill exhaust shall not exceed20 percent opacity except duringSSM periodsII.A.1 GeneralOpacity MonitoringII.B.12 Coal PrepFacility PerformanceTestMore than 6min. in any 1hr.EPA Method 9 (40CFR 60, Appendix A,July 1, 2002)Permit No. 11339Expiration Date: May 15, 2009Page 16 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 2040 CFR 60.253(a)(1) and(b)10/17/00 Ash Grove shall calibrate,maintain and continuouslyoperate a temperature monitor atthe inlet to each coal millbaghouse.II.B.13 TemperatureCMSN/A N/A/40 CFR Part 63, Subparts A and LLLEU 1. 2140 CFR §63.6(e)(1) 5/30/03At all times, including periods ofstartup, shutdown, andmalfunction, Ash Grove shalloperate and maintain the kiln andraw mill, including associated airpollution control equipment, in amanner consistent with good airpollution control practice forminimizing emissions. Duringan SSM period this general dutyto minimize emissions requiresthat Ash Grove reduce emissionsfrom the kiln and raw mill to thegreatest extent which is consistentwith safety and good air pollutioncontrol practices. The generalduty to minimize emissionsduring an SSM event does notrequire Ash Grove to achieveemission levels required byConditions EU 1.26 through 1.29at other times if this is notconsistent with safety and goodair pollution control practices, nordoes it require Ash Grove tomake any further efforts to reduceemissions if levels required byConditions EU 1.26 through 1.29have been achieved.II.B.14 KilnCombustion SystemInspectionsN/A N/APermit No. 11339Expiration Date: May 15, 2009Page 17 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 2240 CFR §63.6(e)(3)(i) 5/30/03 Ash Grove shall develop andimplement a written startup,shutdown, and malfunction(SSM) plan that describes, indetail, procedures for operatingand maintaining the kiln and rawmill during SSM periods, and aprogram of corrective action formalfunctioning process and airpollution control equipment usedto comply with Subpart LLLstandards. The SSM plan shallinclude the elements set forth in40 CFR 63.6(e)(3).II.D.8 NESHAPSubpart LLLRecordkeepingII.C.3 ImmediateSSM Plan DeviationReportII.C.7 Semi-annualSubpart LLL SSMPlan ReportN/A N/AEU 1. 2340 CFR 63.6(e)(3)(ii)40 CFR 63.6(e)(1)(ii)5/30/035/30/03During SSM periods Ash Groveshall operate and maintain thekiln and raw mill (includingassociated air pollution controlequipment) in accordance withthe SSM plan. Malfunctions shallbe corrected as soon as possibleafter their occurrence inaccordance with the SSM planII.D.8 NESHAPSubpart LLLRecordkeepingII.C.3 ImmediateSSM Plan DeviationReportII.C.7 Semi-annualSubpart LLL SSMPlan ReportN/A N/AEU 1. 2440 CFR §63.6(e)(3)(vii) 5/30/03 Ash Grove shall change the SSMplan if required by the PugetSound Clean Air Agency if it isdetermined to be unacceptableunder §63.6(e)(2).No monitoringrequiredN/A N/APermit No. 11339Expiration Date: May 15, 2009Page 18 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 2540 CFR §63.6(e)(3)(viii) 5/30/03 Ash Grove shall update the SSMplan within 45 days of an SSMevent that the plan failed toaddress or inadequatelyaddressed. If Ash Grove makesSSM plan revisions which alterthe scope of activities which aredeemed a SSM or modifies theapplicability of any limit orrequirement underSubpart(s) Aand LLL, the revisions shall nottake effect until Ash Grove hasprovided written notificationdescribing the revision to thePuget Sound Clean Air Agency.No monitoringrequiredN/A N/AEU 1. 2640 CFR §63.1343(d)40 CFR §63.6(f)6/14/995/30/03Ash Grove shall not cause to bedischarged into the atmospherefrom the kiln exhaustDioxin/furan (D/F) exceeding0.20 ng/dscm (8.7x10-11gr/dscf)(TEQ) @ 7% O2when theraw mill is OFF, and 0.40ng/dscm (8.7x10-11gr/dscf)(TEQ)@ 7% O2when the raw mill isON. Standards apply at all timesexcept during SSM periods.II.B.13 TemperatureCMS(3) 3-hourrunsEPA Method 23 (40CFR 60, Appendix A,July 1, 2002)EU 1. 2740 CFR §63.1343(d)40 CFR §63.6(f)6/14/995/30/03Ash Grove shall not cause to bedischarged into the atmospherefrom either coal mill stackDioxin/furan (D/F) exceeding0.40 ng/dscm (8.7x10-11gr/dscf)(TEQ) @ 7% O2.Standards apply at all timesexcept during SSM periods.II.B.13 TemperatureCMS(3) 3-hourrunsEPA Method 23 (40CFR 60, Appendix A,July 1, 2002)Permit No. 11339Expiration Date: May 15, 2009Page 19 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 2840 CFR §63.1344(a)40 CFR 63.6(f)12/6/025/30/03Ash Grove shall operate the kilnsuch that the temperature of thegas inlet to the kiln/raw millbaghouse does not exceed theapplicable temperature limitsestablished during a performancetest for periods when the raw milldoes and does not operate.(§63.1349(b)). Standards apply atall times except during SSMperiods.II.B.13 TemperatureCMS3-HourRollingAverageNIST CalibratedReferenceThermocouple –Potentiometer systemEU 1. 2940 CFR §63.1344(a), asmodified by 10/18/02 letterfrom Puget Sound Clean AirAgency to Robert Vantuylestablishing alternativemonitoring methods for thecoal mill40 CFR 63.6(f)12/6/025/30/03Ash Grove shall operate the kilnsuch that the inlet temperature toeach coal mill baghouse does notexceed 200 degrees F. Standardsapply at all times except duringSSM periods.II.B.13 TemperatureCMS3-HourRollingAverageNIST CalibratedReferenceThermocouple –Potentiometer systemPermit No. 11339Expiration Date: May 15, 2009Page 20 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 3040 CFR 63.1349(b)(3) and(d);10/18/02 letter from PugetSound Clean Air Agency toRobert Vantuyl establishingalternative monitoringmethods for the coal mill12/6/02 Except as waived or modifiedpursuant to 40 CFR 63.7 or 63.8,every 30 months Ash Grove shallconduct a performance test on thekiln and the two coal millbaghouse exhaust vents fordioxin/furans, using test methodsdescribed in 40 CFR63.1349(b)(3). In anyperformance test conducted onthe coal mills, Ash Grove maymeasure dioxin/furan emissionsfrom one of the two coal mills,but the flow rate shall bemeasured from both coal mills.The first such test shall occur nolater than 30 months after theinitial performance test performedon October 22-24, 2002.II.C.8 Subpart LLLPerformance TestReportingII.D.8 NESHAPSubpart LLLRecordkeeping(3) 3-hourrunsEPA Method 23 (40CFR 60, Appendix A,July 1, 2002)Permit No. 11339Expiration Date: May 15, 2009Page 21 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 3140 CFR 63.1349(e)(3)(i) 12/6/02 Provide Puget Sound Clean AirAgency written notice at least 60days prior to undertaking anyoperational change that mayadversely affect compliance withthe D/F emission standards inConditions EU 1.26 and 1.27, oras soon as practicable where 60days advance notice is notfeasible. Notice shall include adescription of the planned change,the emissions standards that maybe affected by the change, and aschedule for completion of theperformance test required byCondition EU 1.32, includingwhen the planned operationalchange would begin.N/A N/A N/APermit No. 11339Expiration Date: May 15, 2009Page 22 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 3240 CFR 63.1349(b)(3) and(e)12/6/02 Conduct a dioxin/furanperformance test whenever AshGrove plans to undertake achange in operations that mayadversely affect compliance withthe D/F emission standards inConditions EU 1.26 or 1.27. Inpreparation for and whileconducting the performance test,the kiln and raw mill may operateunder the planned operationalchange conditions for a period notto exceed 360 hours, providedthat Ash Grove notifies PugetSound Clean Air Agency asdescribed in Condition EU 1.31,that the performance test resultsare documented in a test reportcontaining the information listedin 40 CFR 63.1349(a), and that atest plan is made available forPuget Sound Clean Air Agencyreview prior to testing, ifrequested. The performance testmust be completed within 360hours after the plannedoperational change begins. AshGrove shall submit to PugetSound Clean Air Agencytemperature and other monitoringdata recorded during any periodof pretest operations.II.C.8 Subpart LLLPerformance TestReportingII.D.8 NESHAPSubpart LLLRecordkeeping(3) 3-hourrunsEPA Method 23 (40CFR 60, Appendix A,July 1, 2002)Permit No. 11339Expiration Date: May 15, 2009Page 23 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 3340 CFR 63.1349(e)(1) 12/6/02 Data collected during aperformance test under ConditionEU 1.32 shall be used to establishnew temperature limits for thekiln, supplanting the limitsestablished under 40 CFR63.1349(b).N/A N/A N/AEU 1. 3440 CFR 63.8(e);40 CFR 63.9(g)40 CFR 63.1353(b)(4)40 CFR 63.10(e)(2)40 CFR 63.1354(b)(6)4/5/025/30/036/14/995/30/034/5/02Ash Grove shall conduct aperformance evaluation of thetemperature CMS required byConditions EU 1.29 and 1.30whenever requested by EPAunder Clean Air Act Section 114.Any performance evaluation shallbe conducted in accordance withthe requirements of 40 CFR63.8(e). Notification of theperformance evaluation shall beprovided as required in 40 CFR63.1353(b)(4). Results of theperformance evaluation shall bereported as provided in 40 CFR63.1354(b)(6).N/A N/A N/APermit No. 11339Expiration Date: May 15, 2009Page 24 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1. 3540 CFR §63.1350(a)-(b) 12/6/02 Ash Grove shall prepare for thekiln and raw mill an O&M planincluding the followingprovisions:(a) Procedures for properoperation and maintenance of thekiln and associated air pollutioncontrol equipment to meet thedioxin/furan emission limits andparametric limits in conditionsEU 1.26, 1.27 and 1.28;(b) Procedures to be used duringan inspection of the componentsof the kiln and raw mill at leastonce per year.Failure to comply with thoseprocedures shall be a violation ofSubpart LLL.Ash Grove submitted the O&Mplan for this requirement to thePuget Sound Clean Air Agencyfor approval on May 24, 2002.Ash Grove shall submit updatesof the O & M Plan to the Agencyupon adoption.Ash Grove may elect to integratethe Subpart LLL O&M Plan intothe general O&M plan requiredby Condition I.A.15. If so thegeneral O&M plan shallspecifically identify thoseprovisions required by thiscondition.II.B.14 KilnCombustion SystemInspectionII.D.8 NESHAPSubpart LLLRecordkeepingNA NAPermit No. 11339Expiration Date: May 15, 2009Page 25 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodWAC 173-434 Solid Waste Incineration FacilitiesThese requirements apply as a result of waste fuels burned (see Conditions EU 1.5 through 1.8) and the SIP approved version ofWAC 173-434 (10/18/90).WAC 173-434 was updated (effective 1/22/04) and will exempt certain waste fuels from the applicability of this regulation. Once the 1/22/04 version of WAC173-434 is incorporated into the SIP, Conditions EU 1.36 through 1.48 of this permit (along with the associated monitoring, recordkeeping, and reportingprovisions of this regulation) will be superceded and inapplicable for this permit, based on the presently approved operationsat Ash Grove.EU 1.36WAC 173-434-130(3)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall meet the SO2emission limits established byBACT in Order of Approval No.7381 (see EU 1.11) since morethan 50% of the heat input to thekiln is fossil fuel.II.B.2 SO2, CO andNOx CEMSN/A EPA Method 6C(40 CFR Part 60,Appendix A, July 1,2002)EPA PerformanceSpecification 2(40 CFR 60, AppendixB, July 1, 1997)EU 1.37WAC 173-434-130(4)(a)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall not exceedvisible emissions from the kilngreater than an average of 5percent opacity for more than sixconsecutive minutes in any sixtyminute period.II.A.1 GeneralOpacity Monitoring6-minuteperiodEPA Method 9(40 CFR Part 60,Appendix A, July 1,2002)EU 1.38WAC 173-434-130(4)(b)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Visible emissions from the kiln,as measured by atransmissometer, shall not exceedan average of 10 percent opacityfor more than six consecutiveminutes in any sixty minuteperiod during which Ash Grovecombusts solid waste.II.B.1 ContinuousOpacity MonitoringSystem6-minuteperiodEPA PerformanceSpecification 1(40 CFR 60, AppendixB July 1, 1997)Permit No. 11339Expiration Date: May 15, 2009Page 26 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1.39WAC 173-434-130(5)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall take reasonableprecautions to prevent fugitiveemissions from solid wastehandling operations, whichincludes paving of all normallytraveled roadways within theplant boundary and enclosing orhooding material transfer points.no monitoringrequiredN/AEU 1.40WAC 173-434-160(1)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 When combusting solid waste,Ash Grove shall operate the kilnsuch that the final combustionzone temperature shall not bebelow 1800oF for a 15 minuteaverage nor below1600oF for anyreading.II.B.15 OperationalMonitoring for SolidWaste IncineratorFacilities15-minuteaverage andinstantaneousEU 1.41WAC 173-434-160(2)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall maintain acombustion gas residence time of1.0 seconds in the kiln whencombusting solid waste.II.B.15 OperationalMonitoring for SolidWaste IncineratorFacilitiesN/AEU 1.42WAC 173-434-160(3)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall operate the kilnwhen combusting solid wastesuch that combustion gasesleaving the kiln have at least 3%oxygen measured on a wet basis.II.B.15 OperationalMonitoring for SolidWaste IncineratorFacilities24-houraveragePermit No. 11339Expiration Date: May 15, 2009Page 27 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1.43WAC 173-434-160(4)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall minimize odorand fugitive emissions from thetipping area.II.A.3 RooftopInspectionsII.A.4 O&M PlanInspectionsEU 1.44WAC 173-434-160(5)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall control airdistribution where pressurized airis introduced into the kiln and theair flow shall be monitored andrecorded.II.B.15 OperationalMonitoring for SolidWaste IncineratorFacilitiesEU 1.45WAC 173-434-160(6)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall operate the kilnwhen combusting solid wastesuch that the inlet temperature tothe baghouse shall not exceed350oF.II.B.15 OperationalMonitoring for SolidWaste IncineratorFacilities24-houraverageEU 1.46WAC 173-434-160(7)This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall operate the kilnwhen combusting solid wasteconsistent with good air pollutioncontrol practice.II.A.4 O&M PlanInspectionsN/APermit No. 11339Expiration Date: May 15, 2009Page 28 of 81Ash Grove Operating Permit, May 15, 2004Reqmt.No.EnforceableRequirementAdoption orEffective DateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 1.47WAC 173-434-090This requirement shall besuperseded and becomeinapplicable by the 1/22/04version of WAC 173-434once it is adopted into theSIP10/18/90 Ash Grove shall develop a planfor operation and maintenance ofthe kiln to maintain compliancewith the requirements of WAC173-434.Ash Grove shall update the planas warranted, and shall submit theplan for Puget Sound Clean AirAgency approval every 24months, commencing August 1,2004.Ash Grove may elect to integratethe WAC 173-434 O&M Planinto the general O&M Planrequired by Condition I.A.15. Ifso the general O&M Plan shallspecifically identify thoseprovisions required by thiscondition.II.A.4 O&M PlanInspectionsN/AN/A = Not Applicable. A specificreference test method and/or emission standard period is specified in the requirement. A test method is neither needed nor appropriate.Permit No. 11339Expiration Date: May 15, 2009Page 29 of 81Ash Grove Operating Permit, May 15, 20042.Emission Unit Group #2 (EU-2): Coal Processing, Storage and Transfer FacilitiesThis group consists of four coal storage, processing and transferand loading systems that are subject to NSPS Subpart Y, Standards ofPerformance For Coal Preparation Plants.The affected facilities are Equipment Numbers 41B.FN1 (Coal Feeder #1), 41B.FN2 (CoalFeeder #2), 41A.BF3 (Raw Coal Silo), and41C.BF1 (PF Bin). Subpart Y also regulatesthe #1 and #2 coal mills, but the applicablerequirements for those units appear in Section I.B.1 above.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 2. 140 CFR §60.11(d) 10/17/00At all times, including SSM periods AshGrove shall to the extent practicablemaintain and operateSubpart Y affectedfacilities including associated air pollutioncontrol equipment, in a manner consistentwith good air pollution control practice forminimizing emissions.I.A.4 O&M PlanInspectionsN/A N/AEU 2. 240 CFR 60.252(c)40 CFR 60.11(c)10/17/0010/17/00Exhaust gases shall not exceed 20 percentopacity except during SSM periods.II.A.1 GeneralOpacityMonitoringII.B.12 Coal PrepFacilityPerformance Test6 minuteaverageEPA Method 9(40 CFR 60,Appendix A,July 1, 2002)40 CFR 60.254,2/14/89Permit No. 11339Expiration Date: May 15, 2009Page 30 of 81Ash Grove Operating Permit, May 15, 20043.Emission Unit Group #3 (EU-3): Portland Cement NSPS Affected FacilitiesThis group consists of certain equipment subject to 40 CFR Part 60, Subpart F, the New Source Performance Standards for PortlandCement Plants. The affected facilities included in this group are Transfer Towers 2, 3, 5, 6,7, 8 and 10A, Equipment Numbers311.ST1(Stacker), 311.RE1 (Reclaimer), 315.BN1 (Limestone Storage Bin), P11.TD (Truck Dump), 41B.SX1 (Raw CoalStorage Silos), 312.FA1(Feeder), 312.7G1(Clay Storage Shed), 315.BN2 (Clay Storage Bin), 315.BN3 (Silica Storage Bin), 315.BN4 (Slag Storage Bin), 315.FA1(Clay Apron Feeder), 411.SX1, 411.SX 2(Raw Meal Blending, 411.SX3, 411.SX4 (Raw MealStorage Silos), 612.DM1 (Cement StorageDome), 419.BC6 (Clinker Shed Tripper), 41G (Clinker Loadout Railcar) and 611.BK1 (Cement LoadoutBulk Bag). Subpart F alsoregulates the kiln and raw mill, but theSubpart F requirements for those units are set forth in Conditions EU 1.15, 1.16 and 1.17.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodEU 3. 140 CFR §60.11(d) 10/17/00At all times, including SSM periods AshGrove shall to the extent practicablemaintain and operateSubpart F affectedfacilities including associated air pollutioncontrol equipment, in a manner consistentwith good air pollution control practice forminimizing emissions.I.A.4 O&M PlanInspectionsN/A N/AEU 3. 240 CFR 60.62(c)40 CFR 60.11(c)10/17/0010/17/00Exhaust gases shall not equal or exceed 10percent opacity except during SSM periods.II.A.1 GeneralOpacityMonitoring6 minuteaverageEPA Method 9(40 CFR 60,Appendix A,July 1, 2002)Permit No. 11339Expiration Date: May 15, 2009Page 31 of 81Ash Grove Operating Permit, May 15, 20044.Emission Unit #4 (EU-4): Finish MillsThe two finish mills are each rated at 55 tons per hour, installed in 1968 and controlled bytwo nominal 77,000 acfm high efficiencyseparator baghouses and two nominal 20,000 acfm mill sweep baghouses..The clinker from the kiln that is passedthrough the G-Cooler becomes processed inthe ball mills by grinding with gypsum to form cementand sent to the cement silos for storage.In addition to the applicable requirements listed in this section, the finish mills are subject to the plant-wide requirementsin Section I.A.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodPuget Sound Clean Air Agency Orders of Approval NOC 5276EU 4. 1Puget Sound Clean Air AgencyOrder of Approval No. 5276Condition 4.1/19/94 Ash Grove shall not allow particulateemissions from the (2) mill sweepbaghouses to exceed 0.01 gr/dscf.II.B.4 Finish MillBaghouseMonitoring.Average of 3three-hourrunsPuget SoundClean AirAgency Method5(See Section X)EU 4. 2Puget Sound Clean Air AgencyOrder of Approval No. 5276Condition 6.1/19/94Ash Grove shall not allow particulateemissions from the (2) mill sweepbaghouses to exceed 10% opacity.II.B.4 Finish MillBaghouseMonitoring.More than 3min. in any 1hrEcologyMethod 9A(See Section X)Permit No. 11339Expiration Date: May 15, 2009Page 32 of 81Ash Grove Operating Permit, May 15, 20045.Emission Unit #5 (EU-5): CementDome & Steel Scale TanksThe Cement Storage Dome is a 45,000 ton finished product storagefacility controlled by a 6000 acfm Alanco baghouse. The Domewasinstalled in 1998. The four steelscale tanks are finished productloading facilities, used to loadcement into trucks or railcars. The tankswere installed prior to 1971, but in 1998 Ash Grove replaced one of two baghouses thatcontrol emissions from the tanks with anew 6000acfm Alanco baghouse. NOC 7242 approves construction of the Cement Storage Dome and the two Alanco baghouses.In addition to the applicable requirements listed in this section,the Cement Storage Dome is subject to the plant-wide requirements listedin Section I.A and to the NSPS Subpart F requirements listed inSection I.B.3 of the permit. The Steel Scale Tanks are not Subpart Faffected facilities.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodPuget Sound Clean Air Agency Orders ofApproval NOC 7242 - Cement Storage DomeEU 5. 1Puget Sound Clean Air AgencyOrder of Approval No. 7242,Condition 71/06/98 Ash Grove shall not allow PM-10 emissionsfrom the Alanco baghouses mounted on thecement storage dome and the steel scaletanks to exceed 0.005 grains/dscf over atwenty-four hour period.II.A1 GeneralOpacityMonitoringII.B.7 CementStorage DomeMonitoringSource testfor a 24 hrperiodParticulate byEPA Method 5or EPA Method201A(40 CFR Part60, AppendixA, July 1, 2002;40 CFR Part 51,Appendix M,July 1, 2001)Permit No. 11339Expiration Date: May 15, 2009Page 33 of 81Ash Grove Operating Permit, May 15, 20046.Emission Unit #6 (EU-6): Bulk Bag Loading StationBulk Bag Loading Station controlled with a500 cfm baghouse. In addition to the applicable requirements listed in this section,the BulkBag Loading Station is subject to the plant-wide requirements listed in Section I.A and to the NSPS Subpart F requirements listed inSection I.B.3 of the permit.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoption orEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodPuget Sound Clean Air Agency Orders of Approval NOC 8318 – Bulk Loading StationEU-6.1Puget Sound Clean Air AgencyOrder of Approval No. 8318Condition 3.1/8/01 Ash Grove shall allow no visible emissionsor fallout from the 500 cfm baghousecontrolling the bulk bag loading station.II.B.11 Bulk BagLoading StationMonitoringNA NAEU 6. 2Puget Sound Clean Air AgencyOrder of Approval No. 8318Condition 5.1/8/01If visible emissions, abnormal pressure dropor fallout are observed Ash Grove shallinvestigate the cause and either initiaterepairs or shut down the equipment ventedto the baghouse within 24 hours of theobservation.II.B.11 Bulk BagLoading StationMonitoringNA NAPermit No. 11339Expiration Date: May 15, 2009Page 34 of 81Ash Grove Operating Permit, May 15, 20047.Emission Unit #7 (EU-7): Clinker Storage ShedIn addition to the applicable requirements listed in this section, the Clinker Storage Shed is subject to the plant-wide requirements listed inSection I.A.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodPuget Sound Clean Air Agency Orders of Approval NOC 8600 – Clinker Storage ShedEU-7.1Puget Sound Clean Air AgencyOrder of Approval No. 8600Condition 3.2/8/02Ash Grove shall not allow the PM-10emissions from the Pulse Jet R-08-88-81baghouse to exceed 0.005 grains/dscf over atwenty-four hour period.II.A1 GeneralOpacityMonitoringSource testfor a 24 hrperiodParticulate byEPA Method 5or EPA Method201A (40 CFRPart 60,Appendix A,July 1, 2002; 40CFR Part 51,Appendix M,July 1, 2001)Permit No. 11339Expiration Date: May 15, 2009Page 35 of 81Ash Grove Operating Permit, May 15, 20048.Emission Unit #8 (EU-8): Group II Cement SilosIn addition to the applicable requirementslisted in this section, the Group II Silos are subject tothe plant-wide requirements listed inSection I.A.APPLICABLE REQUIREMENTSReqmtNo.EnforceableRequirementAdoptionorEffectiveDateRequirement Paraphrase(Information Only)Monitoring,Maintenance &RecordkeepingMethod(See Section II)EmissionStandardPeriodReferenceTest MethodPuget Sound Clean Air Agency Orders of Approval NOC 8643 – Group II SilosEU-8.1Puget Sound Clean Air AgencyOrder of Approval No. 8643Condition 3.2/8/02Ash Grove shall not allow the PM-10emissions from each ofthe Pulse Jet DustCollectors to exceed 0.005 grains/dscf overa twenty-four hour period.II.A.1 GeneralOpacityMonitoringSource testfor a 24 hrperiodParticulate byEPA Method 5or EPA Method201A (40 CFRPart 60,Appendix A,July 1, 2002; 40CFR Part 51,Appendix M,July 1, 2001)

### Permit No. 11339 Expiration Date: May 15, 2009 Page 36 of 81

Ash Grove Operating Permit, May 15, 2004 

## II. MONITORING, REPORTING A ND RECORDKEEPING METHODS

A. Facility Wide Monitoring Methods

1. General Opacity Monitoring

Ash Grove shall conduct monthly inspections of th e facility for visible emissions. Inspections are to be performed while the equipment is in operation during daylight hours. If, during the scheduled inspection or at any other time, visible emissions other than uncombined water are observed, Ash Grove shall, as soon as possible, but no later than 24 hours after the initial observation, take corrective action until there are no visible emissions, shut down the unit or activity until it can be repaired or conduct a refe rence method opacity observ ation. If a reference method opacity observation reveal s an exceedance of the applicab le visible emissions limit,report the observation as a deviation and shut the unit down until repairs are complete and a nonreference method visible emissions observation re veals no visible emissions. Report deviations as provided in Condition II.C.2. Maintain record s as provided in Conditions II.D.1 and II.D.5.

[Order of Approval No. 7381, Condition 4 (6/6/01); WAC 173-401-615(1), 10/17/02]

2. Complaint Response
Ash Grove shall develop and implement an Air Pollution Complaint Response Program as part of the O&M Plan required by Regulation I S ection 7.09(b). The Complaint Response Program shall be annually reviewed and updated along wi th the O&M Plan. This Program shall include:

• An Ash Grove local contact pers on and a 24-hour telephone number;

• Complaint forms available to the public;

• Criteria and methods for establishing whethe r Ash Grove may be the source of fugitive

dust or other air contaminant impacts on neighboring property;

• Format of communicating results of investig ations and advising complainants of Ash Grove's corrective actions and preventive maintenance;

• Ash Grove shall record air pollution complain ts (including those forwarded to Ash Grove from this Agency) and findings of investig ations as provided in Condition II.D.6. Investigations shall be initiated within 1 da y of receipt of a complaint on Ash Grove’s 24 hour complaint reporting phone line. Ash Gr ove’s Complaint Response Program shall describe the procedures for investigating comp laints. Complaint investigation procedures shall include efforts to contact the complainan t, to inspect the conditions described in the complaint, to determine whether Seattle pl ant sustained a malfunction or other operating or site conditions that might have generate d abnormal levels of fugitive emissions, and to determine the wind speed, direction and/or other meteorologica l conditions during relevant times preceding receipt of the complaint.

If Ash Grove determines that emissions from its plant unreasonably impacted neighboring properties Ash Grove shall either eliminate th e problem within 24 hours of identification or report a deviation as provided in Condition II.C.2. Ash Grove also shall report as a deviation any failure to initiate investigation of a complaint within 1 day of r eceipt of the complaint. Results

### Permit No. 11339 Expiration Date: May 15, 2009 Page 37 of 81

Ash Grove Operating Permit, May 15, 2004 

### of complaint investigations shall be reported m onthly as provided in Cond ition II.C.10. Maintain records as provided in Condition II.D.6.

[WAC 173-401-615(1), 10/17/02]

3. Roof Top Inspections

Ash Grove shall conduct a roof-top 1 

### inspection at least weekly. These inspections shall include inspection for odor-bearing contaminants and for fugiti ve emissions from any part of the facility. In the event any fugitive emission release is discovered by an inspection, Ash Grove shall as soon as possible, but no later than 24 hours af ter discovered, begin corr ective action, shut the operation down until the problem can be correcte d, or report the release as a deviation as provided in Condition II.C.2. Ash Grove shall document each inspection as provided in

Condition II.D.5.

[WAC 173-401-615(1) and WA C 173-401-615(2), 10/17/02]

4. O & M Plan Inspections

Ash Grove shall conduct a facility wide e quipment inspection at least monthly. These inspections shall include:

• checking for prohibited activities under Sect ion III of the permit and activities that require additional approval unde r Section IV of the permit

• inspection for proper operation of equipment and control equipment

• inspection for evidence that fugitive dust control measures required by Section 9.15 of Regulation I are being implemented

• inspection for odor bearing contaminant emissions from the facility.

In the event any violation of the underlying applicable require ment(s) are discovered by an inspection, Ash Grove shall as soon as possibl e, but no later than 24 hours after discovered, begin corrective action, shut the operation down until the problem can be corrected, or report the

violation as a devia tion under Condition II.C.2.

Ash Grove shall document all inspections required by this condition as provided in Condition

II.D.5.

[Puget Sound Clean Air Agency Regulation I, Section 7.09(b) (9/10/1998); WAC 173-401- 615(1) (10/17/02)].

5. Vehicle Track Out

Ash Grove shall inspect East Marginal Way at the plant entrance at least weekly for vehicle track out. If any track-out onto East Marginal Way is observed, Ash Grove shall implement measures within 24 hours to control the source of the track-out, or report a deviation. Ash Grove shall

1 

### A “roof-top inspection” is a visual inspection of the overall facility from a sufficient height to allow the determination of the po int(s) of origin and possibly the cause(s) of fugitive emissions.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 38 of 81

Ash Grove Operating Permit, May 15, 2004 

### document all inspections required by this condi tion as provided in Condition II.D.5 and report any deviation as provi ded in Condition II.C.2.

[WAC 173-401-615(1) and WAC 1 73-401-615(2)(a), 10/17/02]

B. Source Specific Monitoring Methods

1. Continous Opacity Monitoring System

i. Continuous Monitoring . Ash Grove shall install, calibrate, maintain and operate, in accordance with 40 CFR 60.13, a continuous opacity monitoring system (COMS) on the main

kiln stack.

ii. Data Recovery . Ash Grove shall recover valid hourly mo nitoring data for at least 95% of the hours that the kiln operates duri ng each calendar month except for periods of monitoring system downtime, provided that Ash Grove demonstrates to the Control Officer that the downtime was not a result of inadequate design, operation, or ma intenance, or any other reasonably preventable condition, and any necessary repairs to the monito ring system are conducted in a timely manner.

iii. Quality Assurance . The COMS shall meet Performance Specification 1 in 40 CFR Part 60, Appendix B (1992), and Ash Grove shall operate th is monitoring system in accordance with the U.S. Environmental Protection Agency’s “Recommended Quality Assurance Procedures for Opacity Continuous Monitoring Sy stems” (EPA 340/1-86-010).

iv. Data Recording . Monitoring data commencing on the cl ock hour and containi ng at least 45 minutes of monitoring data shall be reduced to 1-hour averages. Mon itoring data for opacity shall also be reduced to 6-minute averages. A ll monitoring data shall be included in these averages except for data collected during calibratio n drift tests and for data collected subsequent to a failed quality assurance test or audit.

v. Relative Accuracy Tests . All relative accuracy tests shall be subject to the provisions of Regulation I, Section 3.07 (2/9/95).

vi. Reporting and Recordkeeping. Report as provided in Conditions II.C.4, II.C.5, II.C.11 and/or II.C.12 (where applicab le) each occasion on which the COMS records a violation of applicable opacity limit(s), or on which the COMS sustains an unexcused fa ilure to meet the data recovery requirements of this condition. Ma intain records as provided in II.D.1 and II.D.7.

[WAC 173-401-615(1) (10/17/02); 40 CFR 60.63(b) (12/14/88); 40 CFR 60.13(a), (d) - (f) and (h) (8/27/01); Order of Approval 7381, Condition 7 (6/6/01); Puget Sound Clean Air Agency Regulation I, Section 12.01 & 12.03 (4/9 /98); WAC 173-434-170(1) (10/18/90)]

2. SO2, CO and NOx Continuous Em issions Monitoring System

i. Continuous Monitoring . Ash Grove shall operate a continuous emission monitoring system (CEMS) for SO2, CO and NOx for the kiln main stack.

ii. Data Recovery . Ash Grove shall recover valid hourly mo nitoring data for at least 95% of the hours that the kiln is operated during each ca lendar month except for periods of monitoring system downtime, provided that Ash Grove demonstrates to the Control Officer that the

### Permit No. 11339 Expiration Date: May 15, 2009 Page 39 of 81

Ash Grove Operating Permit, May 15, 2004 

### downtime was not a result of inadequate de sign, operation, or maintenance, or any other reasonably preventable condition, and any nece ssary repairs to the monitoring system are conducted in a timely manner.

iii. Quality Assurance . The CEMS for each pollutant sha ll meet the relevant performance specification in 40 CFR Part 60, Appendix B (1990), and Ash Grove shall operate this monitoring system in accordance with the qual ity assurance procedures in 40 CFR Part 60, Appendix F in effect July 1, 1992.

iv. Data Recording . Monitoring data commencing on the cl ock hour and containi ng at least 45 minutes of monitoring data shall be reduced to 1-hour averages. All monitoring data shall be included in these averages except for data coll ected during calibration dr ift tests and for data collected subsequent to a failed qua lity assurance test or audit.

v Relative Accuracy Tests . All relative accuracy tests sha ll be subject to the provisions of Regulation I, Section 3.07 (2/9/95).

vi. Reporting. Report as provided in Condition II. C.4, II.C.11 and/or II.C.12 each occasion on which the CEMS records a violation of appli cable emission limit(s), or on which the CEMS

sustains an unexcused failure to meet the data recovery requiremen ts of this condition. Maintain records as provided in Condition II.D.1.

[WAC 173-401-615(1) (10/17/02); Order of Approval 7381, Condition 7 (6/6/01); PSD Permit 90-03, Amendment 3, Condition 7 (10/8/01); P uget Sound Clean Air Agency Regulation I, Section 12.01 & 12.03, 4/9/98; WAC 173-434-170(1) (10/18/90)]

3. SO2, CO, and NOx Mass Emission Rate Monitoring

Ash Grove shall calculate emissions of SO2 and CO from the cement kiln operation on a calendar year basis, and NOx em issions from the cement kiln operation on a 12-month rolling total basis, using the CEMS data collected unde r the requirements of Section II.B.2 of this permit. Additionally, Ash Grove shall calculate the 8-hour block average mass emission rate for CO using CEMS data collected under the requireme nts of Section II.B.2 of this permit. Each day shall consist of three 8-hour CO compliance intervals, the firs t interval commencing at 12:00

AM. When CEM data is not availa ble or not required to be collect ed as identified by this permit,

other information available to As h Grove shall be used to comp ile the emission rate values. Report deviations as provided in Condition II.C. 4. Maintain records as provided in Condition

II.D.10.

[WAC 173-401-615(1) and WAC 173-401-615(2), 10/17/02] [Order of Approval No. 7381, Condition 7, 6/6/01; PSD Permit 90-03, Amendment 3, Conditions 1-3, 10/8//01]

4. Finish Mill Baghouse Monitoring

Ash Grove shall monthly measure and record th e pressure drop across the 20,000 cfm mill sweep baghouses. If a measurement reveals a pressure dr op reading outside the range of 3 to 6 inches, take corrective action as soon as possible, but no la ter than 24 hours after th e initial observation. If, following corrective action, the pressure drop remains outside the range of 3 to 6 inches, either shut down the unit until it can be repaired, or report the reading as a deviation. Keep a log

### Permit No. 11339 Expiration Date: May 15, 2009 Page 40 of 81

Ash Grove Operating Permit, May 15, 2004 

### of pressure drop readings, and of any corrective acti on taken. Document all measurements and actions required by this condition as provided in Condition II.D.1. Report any deviation as provided in Condition II.C.2.

[Order of Approval 5276, Condition No. 7 (1/19/94); WAC 173-401-615(1) and WAC 173-401- 615(2), (10/17/02)]

5. Waste Derived Fuel Consumption

Ash Grove shall record the weight of each batch of grease and each batch of oil burned in the kiln. Maintain records showing the weight of greases and oils burned each month. Report a deviation per Condition II.C.2 if the annual total weight of oils burned exceeds 4800 pounds, or the total weight of grease burned exceeds 6,000 pounds.

[Order of Approval 5687, Condition No. 6 (1/11/95); WAC 173-434-170(2) (10/18/90); WAC 173-401-615(1) and WAC 173-401-615(2) (10/17/02)]

6. Tire Derived Fuel Consumption

Ash Grove shall monitor the weight of whole ti res injected into the kiln following the Fuel Monitoring Plan required by Order of Appr oval 5755, Condition 6. Re port a deviation per Condition II.C.2 if the daily weight of whole tires injected during each cal endar day (7 am to 7 am) exceeds 30 percent of the weight of all fuels consumed in the kiln during that day. Report the daily weight of whole tire s injected per Condition II.C.11.

[Order of Approval 5755, Condition No. 6 (1/11/95); WAC 173-434-170(2) (10/18/90; WAC 173-401-615(1) and WAC 173-401-615(2) (10/17/02)]

7. Cement Storage Dome Monitoring

Ash Grove shall install and maintain gauges to m onitor the pressure drop across each of the two Alanco Baghouse exhaust filters. The acceptable ranges for the gauges shall be clearly marked on or near the gauges. Once during each shift that either Alanco baghous e is used, record the pressure drop across the exhaust fi lter of that baghouse. If th e pressure drop falls outside the acceptable range, take corrective act ion as specified in the facil ity's O & M plan. If, following corrective action, the pressure drop remains outsi de the acceptable range, either shut down the unit until it can be repaired, or report the reading as a deviation. Keep a log of pressure drop readings, and of any corrective action taken Report deviations as provided in Condition II.C.2.

[Order of Approval 7242, Condition No. 4 - 6 (1/06/98); WAC 173- 401-615(1) and WAC 173- 401-615(2) (10/17/02)]

8. Kiln Work Practice Monitoring

Ash Grove shall log as part of the O & M Plan the following activities:

(i) The date, start and end times, and the fu els used for kiln st artup-preheat periods prior to feed introduction;

(ii) The date and time of sulf ur ring removal from the kiln , if the ring formation required the kiln to be shut down;

### Permit No. 11339 Expiration Date: May 15, 2009 Page 41 of 81

Ash Grove Operating Permit, May 15, 2004 

### (iii) The date, start and end times for k iln startup-feed in troduction periods; and

(iv) The cause for kiln shut down, the durati on of kiln cool down and the kiln rotation

schedule in kiln cool down.

Report as provided in Condition II.C.4 the informa tion described above. Report as a deviation any unexcused departure from the startup and sh utdown work practice requirements of Order of Approval 7381, Conditions 6(a) and (c) Mainta in records as provided in Condition II.D.5.

[Order of Approval 7381, Condition 6 (6 /06/01); WAC 173-401- 615(1) and WAC 173-401- 615(2), 10/17/02]

9. PM Monitoring Main Baghouse

(a) Conduct a Puget Sound Clean Air Agency Me thod 5 source test at least once per permit cycle, no later than 12 months prior to the expiration date of this permit. Report per Condition II.C.1 any exceedance of the underlying PM limit. Maintain records as provided in Condition II.D.1.

(b) Multiply the calendar year tonnage of clinker production by an emission factor of 0.0414 kg/Mg to determine annual PM10 emissions. Revi se this emission factor using data from the most recent PM source test, provided that the test yields data deemed representative of the kiln baghouse emission rate. Use the re vised emission factor to calculate annual emissions for years subsequent to the date of the source test. Record in a log the annual tonnage of clinker producti on. Report per Condition II. C.2 if calendar year PM emissions exceed 46 tons per year.

[Order of Approval 7381, Condition 5 (6 /06/01); WAC 173-401- 615(1) and WAC 173-401- 615(2), 10/17/02]

10. Production Rate Monitoring

Record on a daily basis kiln produ ction rate and kiln feed rate. Records may be maintained in electronic format. Report per C ondition II.C.2 any failure to main tain the records required by

this condition.

[40 CFR 60.63(a) (12/14/ 88); WAC 173-401-615(1) and WAC 173-401-615(2), 10/17/02]

11. Bulk Bag Loading Station Monitoring

At least once a week when the bulk loading station is in opera tion, Ash Grove shall inspect the dust collector for visible emissions, fallout and pre ssure drop across the filters. Record the time and results of each inspection. If visible emi ssions, fallout or abnormal pressure drop are observed, initiate corrective action within 24 hours or shut down the equipment vented to the baghouse within 24 hours. If, following corrective action, the problem remains, either shut down the unit until it can be repaired, or report the obs ervation as a deviation as provided in Condition II.C.2. Keep a log of inspections and of any correct ive action taken.

[Order of Approval 8318, Conditions 4-6 (1/08/01); WAC 173-401- 615(1) and WAC 173-401- 615(2), 10/17/02]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 42 of 81

Ash Grove Operating Permit, May 15, 2004 

### 12. Coal Prep Facility Performance Test
Within 180 days of permit issuance, Ash Grove sh all conduct an NSPS performance test to show compliance with Condition EU 1.18 [40 CFR 60.252( a)(1) – coal mill only] and Conditions EU 1.19 and EU 2.2 [40 CFR 60.252(a)(2) – all 40 CFR S ubpart Y affected facilities]. Source testing methods required by 40 CFR 60.254 shall be us ed. The procedures identified in Sections V.N and V.P of this permit shall apply.

[40 CFR 60.254 (2/14/89), 40 CFR 60.8 (2/12/99)]

13. Temperature CMS

Ash Grove shall install, calibra te, maintain and continuously ope rate a continuous temperature monitor system (CMS) at the kiln baghouse inlet and at the inlet to each coal mill baghouse. Each CMS shall meet performance specificati ons in 40 CFR 63.1350(f) (4/5/02). Each CMS

shall meet the O & M and data av ailability requiremen ts of 40 CFR 63.8(c), (d) and (e). The

calibration of the CMS shall be verified at l east once every three months. Ash Grove shall continuously record inlet temperatures at the kiln and coal mill baghouses as provided in § 63.1350(f). Maintain records as provided in Cond itions II.D.7 and II.D.8. Report as provided in

Conditions II.C.6 and/or II.C.12 .

[40 CFR 60.253(a)(1) and (b) (10/17/00); 40 CF R 63.1350(f) (12/6/02); 40 CFR 63.8 (4/5/02); 40 CFR 63.10(b)(2)(vi) (5/30/03); WAC 173-401-615(1) (10/17/02)].

14. Kiln Combustion System Inspections

Ash Grove shall inspect the components of th e kiln combustion system once per year for compliance with those provisions of the O&M Plan that ensure compliance with the dioxin/furan emission limits in Conditions EU 1.27 and 1.28. Maintain records as provided in Condition II.D.8. Report as provided in Condition II.C.6.

[40 CFR 63.1350(i) (12/ 6/02); 40 CFR 63.1354(a)(9)(iv) (6/1 4/99); WAC 173-401-615(1) and WAC 173-401-615(2), 10/17/02]

15. Operational Monitoring for Solid Waste Incinerator Facilities

Ash Grove shall continuously monitor and reco rd the following operational parameters during any 24 hour period (commencing 12 p.m.) in which the kiln combusts solid waste:

• Combustion zone temperature (kiln outlet). The average temperature shall be recorded for each 15 minute block interval. Report as a deviation per Condition II.C.11 any measurement below 1600° F and any 15 minut e block in which the combustion zone temperature averages less than 1800° F.

• Particulate control device temperature (kil n baghouse inlet). The average temperature shall be recorded for each 24 hour period comm encing at 12 p.m. Report as a deviation per Condition II.C.11 any 24 hour block duri ng which the average temperature exceeds

350° F.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 43 of 81

Ash Grove Operating Permit, May 15, 2004 

### • Oxygen (for excess air, preheater outlet). The average oxygen concentration shall be recorded for each 24 hour period commencing at 12 p.m. Report as a deviation per Condition II.C.11 any 24 hour block during which the average oxygen concentration measured on a dry basis is less than 3.3 percent.

• Combustion air distribution and residence time . The average air flow rate at the baghouse outlet shall be recorded fo r each 15 minute block interval.

The continuous monitoring systems described in th is condition shall meet the data recovery and data recording requirements set forth in Cond ition II.B.2, except that th e kiln baghouse inlet temperature CMS shall meet the requirements of Condition II.B.13. Report as a deviation per

Condition II.C.11 each occasion on which a CMS sustai ns an unexcused failure to meet the data recovery and data recording requ irements of this condition. This condition shall be inapplicable once the updated regulation (WAC 173-434, eff ective 1/22/04) is adopted into the SIP.

[WAC 173-434-170(1), (10/18/90), WAC 173-434-170(2) , (10/18/90)]

C. Reporting

Ash Grove shall file the following reports w ith the Puget Sound Clean Air Agency on the schedules provided herein.

1. General Reporting
Any monitoring reports required by this permit shall be submitted to Puget Sound Clean Air Agency Operating Permit Certification at least on ce every six months, or more frequently where specified in the permit. All in stances of deviations from perm it requirements must be clearly identified in such reports. All reports must be cer tified by the responsible o fficial consistent with Condition V.Q. Where an applicable requirement requires reporting more frequently than once every six months, the responsible official’s ce rtification needs to only be submitted once every six months, covering all required re porting since the date of the la st certification, provided that the certification specifically identifies all documents subject to certification.

[ WAC 173-401-615(3)(a) (10/17/02)]

2. General Deviation Reporting
Ash Grove shall report in writing to Puge t Sound Clean Air Agency Operating Permit Certification all instances of deviations from pe rmit requirements, including those attributable to upset conditions as defined in this permit, the probable cause of the deviations, and any

corrective actions taken. Ash Grove shall maintain a contemporaneous record of all deviations. Ash Grove shall report any deviations that represent a potential thr eat to human health or safety by FAX (206 343-7522) as soon as possible but no later than 12 hours after such a deviation is discovered. Ash Grove shall repor t other deviations in writing to Puget Sound Clean Air Agency Operating Permit Certification no later than 30 da ys after the end of the month during which the

deviation is discovered. Devi ations revealed by a continuous monitoring system shall be reported as provided in Conditi on II.C.4 or Condition II.C.11

### Permit No. 11339 Expiration Date: May 15, 2009 Page 44 of 81

Ash Grove Operating Permit, May 15, 2004 

### [WAC 173-401-615(3)(b) (10/17/02)]

3. Immediate Subpart LLL SSM Plan Deviation Report
Any time an action taken by Ash Grove during an SSM event (including actions taken to correct a malfunction) is not consistent with the procedures in Ash Grove’s Subpart LLL SSM Plan, and

the kiln exceeds an emission limit in Conditi ons EU1.26 or 1.28, Ash Grove shall report the

actions taken for that event to Puget Sound Clean Air Agency by telephone or facsimile transmission within 2 working days after commen cing actions inconsistent with the plan. That immediate report shall be followed by a letter de livered or postmarked within 7 working days after the end of the event, e xplaining the circumstances of th e event, the reasons for not following the plan, and describing all Subpa rt LLL excess emissions and/or parameter monitoring exceedances are believed to have occu rred. The letter must contain the name, title and signature of the responsible o fficial who certifies its accuracy.

[40 CFR 63.10(d)(5)(ii) (5/ 30/03); 40 CFR 63.1354(b)(5) (6/14/99); WAC 173-401-615(3) (10/17/02)]

4. Monthly CEM Report

Ash Grove shall file with Puget Sound Clean Air Agency a monthly CEM report, which shall be delivered or postmarked within 30 days after th e end of the month in which the data were

recorded. This re port shall include:

a. The date, time period, magnitude and cause of each emission of opacity, CO, NOx and SO2 recorded by the kiln CEMS that exceeded appl icable emission limits for that parameter;

b. The date and time of all actions taken to correct the problem, including any actions taken to minimize emissions during the exceedance and a ny actions taken to prevent its recurrence;

c. The number of hours that the kiln operated ea ch month and the number of valid hours of monitoring data for each parameter that th e respective CEMS recovered that month;

d. The date, time period and cause of each failure to meet the data recovery requirements of Puget Sound Clean Air Agency Regulation I, § 12.03(b), and any actions taken to ensure adequate collection of such data;

e. The date, time period and cause of each failure to recover valid hourly monitoring data for at least 90% of the hours that the kiln operated each day;

f. The results of all cylinder gas audits conducted during the month.

g. Demonstrations required under WAC 173-400-107 (4 ), (5) or (6) for exceedances deemed by

Ash Grove to be "unavoidable."

h. The date and time of commencement of each startup preheat, each introduction of feed to the kiln, the completion of startup and each shutdown of the kiln.

i. The Complaint Response Report required by Condition II.C.10 shall be included as an attachment to the monthly CEM Report.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 45 of 81

Ash Grove Operating Permit, May 15, 2004 

### j. The monthly CEM reports for June and December shall include, as attachments, the reports required by Conditions II.C.5, II.C.6, and II.C.7.

[PSD Permit 90-03, Amendment 3, Conditions 8 and 9 (10/8/01); Order of Approval 7381, Condition 7 (6/6/01); Puget Sound Clean Air Agency Reg. I: 12.03(f) (4/9/98); WAC 173-401- 615(3) (10/17/02)]

5. Semi-annual NSPS Report

The monthly CEM reports filed for the months of June and December shall include a semiannual NSPS Subpart F excess emissions and mon itoring system performance report, reporting

data from the kiln COMS for the six month reporting periods ending June 30 and December 31. For purposes of those reports, "excess emissions " means all 6 minute peri ods during which the average opacity measured by the kiln COMS exceed s 20 percent. If the total duration of excess emissions for the reporting peri od is less than 1 percent of the total operating time for the reporting period and COMS downtime for the reporti ng period is less than 5 percent of the total operating time for the period, Ash Grove need submit only a Summary Report in the format

shown in Section X.E below. If the total dura tion of excess emissions for the reporting period equals 1 percent or greater of the total opera ting time for the reporting period or total COMS downtime for the reporting period is 5 percent or greater of th e total operating time for the period, Ash Grove shall submit both the Summ ary Report and an Excess Emissions Report containing the following information for kiln opacity excess emissions:

a. The magnitude of excess emissions, computed in accordance with 40 CFR 60.13(h), any conversion factors used, and the date and tim e of commencement and completion of each time period of excess emissions.

b. The process operating time during the reporting period;

c. Specific identification of each period of exce ss emissions that occurs during startups,
shutdowns and malfunctions of the kiln, the na ture and cause of any malfunction (if known),

the corrective action taken or preventative measures adopted;

d. The date and time identifying each period durin g which the COMS was inoperative except for zero and span checks and the nature of the system repairs or adjustments;

When no excess emissions have occurred or the CO MS has not been inoperative, repaired or adjusted, such information shall be stated in the report.

The semi-annual NSPS report shall be submitted to both the Puget Sound Clean Air Agency and EPA Region 10.

[40 CFR 60.7(c) and (d) (2/ 12/99); 40 CFR 60.65(a) (12/ 14/88); 40 CFR 60.63(d) 12/14/88); WAC 173-401-615(3) (10/17/02)]

6. Semi-annual NESHAP Subpart LLL Summary Report

The monthly CEM reports filed for the months of June and December shall include a semiannual NESHAP Subpart LLL summary report for the six month reporting periods ending June 30 and December 31. The report shall be entitled: "Gaseous Excess Emission and Continuous Monitoring System Performance." It sh all contain the following information:

### Permit No. 11339 Expiration Date: May 15, 2009 Page 46 of 81

Ash Grove Operating Permit, May 15, 2004 

### a. Company name and address of the Seattle plant;

b. Statement that Ash Grove monitors kiln and coal mill baghouse inlet temperature as a parametric indicator of dioxin/furan emissions;

c. Beginning and ending dates of the reporting period;

d. Brief description of the kiln and in line raw mill;

e. Description of the temperature lim its in Conditions EU 1.29 and 1.30;

f. Description of the manufactur er and model number(s) of the temperature monitor systems installed on the kiln and coal mills;

g. Date of the most recent temper ature CMS certification or audit;

h. Total operating time of the kiln and raw mill during the reporting period;

i. Performance summary, including each three hour period during the reporting period in which the average temperature of the kiln and/or ea ch of the coal mills exceeded the respective temperature limits for those units as set forth in Conditions EU 1.29 and 1.30, the total duration of excess emissions expr essed as a percent of the to tal kiln and/or coal mill operating time during the reporting period, and a breakdown of the total duration of excess emissions into those that are due to startup, shutdown, control equipment problems, process problems, other known causes and unknown causes;

j. CMS performance summary for each temperat ure monitor, including the total number of hours of CMS downtime during the reporting period, total duratio n of CMS downtime expressed as a percent of the total kiln or coal mill operating hours during the reporting period, and a breakdown of total CMS downtime dur ing the reporting peri od into periods that are due to monitoring equipment malfunctions , non-monitoring equipment malfunctions, QA/QC calibrations, other known causes, and unknown causes.

k. Description of any changes in any CMS, processe s or controls since the last reporting period;

l. All failures to calibrate thermocouples and temperature se nsors as required by Condition EU 1.20 and 40 CFR 63.1350(f)(6) (4/5/02)

m. Results of any combustion system component inspections conducted in the reporting period as provided in Condition II.B.13;

n. All failures to comply with any provision of the O&M plan developed in accordance with
Condition EU 1.35;

o. Name, title and signature of the responsible offi cial who certifies the accuracy of the report;

p. Date of the report.

If the total temperature CMS downtime for the reporting period for the kiln baghouse inlet CMS or either coal mill baghouse inlet CMS is ten per cent or greater of the total operating time for the monitored unit during the repo rting period, Ash Grove shall submit an excess emissions and continuous monitoring system report in additi on to the summary report described in this

condition.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 47 of 81

Ash Grove Operating Permit, May 15, 2004 

### [40 CFR 63.10(e)(3)(v)-(viii) (5/30/03); 40 CFR 63.1354(b)(8)-(10) (6/19/99); WAC 173-401- 615(3) (10/17/02)]

7. Semi-annual Subpart LLL Startup Shutdo wn and Malfunction Report

The monthly CEM reports for June and December shall include, as an attachment, a semi-annual Subpart LLL SSM report. If actions taken by Ash Grove during SSM events occurring between January 1 and June 30 of each year were consistent with the procedures in Ash Grove’s SSM plan, the SSM report for the month of June shall in clude a statement to that effect. If actions taken by Ash Grove during SSM events occurring between July 1 and December 31 of each year were consistent with the procedures in Ash Gr ove’s SSM plan, the SSM report for the month of

December shall include a statement to that eff ect. Each SSM report shall identify any instance where an action taken by Ash Grove during an SS M event (including actions taken to correct a malfunction) is not consistent with the SSM plan but the kiln and/or coal mill did not exceed an emission limit in Conditions EU 1.26 through 1.29. The report shall also include the number, duration and brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused an emission limit in Conditions EU 1.26 through 1.29 to be exceeded. For purposes of this report, a “malfunction” means any sudden, infrequent, and not reasonably preventable failu re of kiln air pollution control equipment or the kiln process to operate in a normal or usual manner which cause s, or has the potential to cause, any of the emission limitations in Conditions 1.26 through 1.29 to be exceeded. Failures that are caused in part by poor maintenance or carele ss operation are not malfunctions.

[40 CFR 63.10(d)(5)(i) (5/30/03); 40 CFR 63. 2 (5/30/03); 40 CFR 63.1354(b)(4) (6/14/99); WAC 173-401-615(3) (10/17/02)]

8. Subpart LLL Performance Test Reporting
Ash Grove shall report the results of each dioxin/f uran performance test required by this permit. The report shall be postmarked or delivered to Puget Sound Clean Air Agency within 60 days following the completion of the performance test . With each report Ash Grove shall file a notification of compliance status as described in 40 CFR 63.9(h) (4/5/99).

[40 CFR 63.10(d)(2) (5/30/03); 40 CFR 63.9(h) (5/30/03); 40 CFR 63.1354(b)(1) (6/14/99); WAC 173-401-615(3) (10/17/02)]

9. Annual Emissions Reporting
Ash Grove shall report annually to the Puget Sou nd Clean Air Agency for those air contaminants during the previous calendar year that equal or exceed the following (tons per year):

Carbon monoxide (CO) emissions 25

Facility combined total of all toxic air contaminants (TAC) emissions 6

Any single toxic air contaminant (TAC) emissions 2

Nitrogen oxide (NOx) emissions 25

Particulate matter (PM10) emissions 25

### Permit No. 11339 Expiration Date: May 15, 2009 Page 48 of 81

Ash Grove Operating Permit, May 15, 2004 

### Particulate matter (PM2.5) emissions 25

Sulfur oxide (SOx) emissions 25

Volatile organic compounds (VOC) emissions 25

Annual emissions rates shall be reported to th e nearest whole ton per year for only those contaminants that equal or exceed the thresholds above.

[Puget Sound Clean Air Agency Regulation I, Se ction 7.09(a), 10/6/97] [Puget Sound Clean Air Agency Regulation I, Secti on 7.09(a), 9/10/98 (State only)]

10. Complaint Response Reporting
Ash Grove shall submit in writing to Puget S ound Clean Air Agency a report documenting all complaints received with a summary of the natu re of the complaint, the conclusion of the investigation, and any corre ctive action taken in response. This report shall be submitted as an attachment to the CEM report required by Conditi on II.C.4. In the event there are no reportable events, the Complaint Response Report shall consist of a statement to that effect.

[WAC 173-401-615(3) (10/17/02)]

11. Monthly Reports for Solid Waste Incinerator Facilities
Ash Grove shall file with the Puget S ound Clean Air Agency a monthly WAC 173-434 monitoring report within 15 days of end of each calendar month which will include the following:

• Average daily maximum and daily maximum co ncentration of opacity (percent), sulfur dioxide (ppm) and carbon monoxide (ppm) and the daily amount of solid waste burned.

• Date, time, and magnitude of any periods during which the standards in Conditions EU 1.11, 1.37, 1.39, 1.41, and 1.44 were exceeded, and what corrective action was or will be

taken

• Any period(s) during which the kiln c ontinuous monitoring systems for opacity, combustion zone temperature, particulate cont rol device temperature and air flow, sulfur dioxide, oxygen and/or carbon monoxide do not meet the a pplicable data recovery requirements of Section II.B of this permit .

This condition shall be inapplicable once th e updated regulation (WAC 173-434, effective 1/22/04) is adopted into the SIP.

[WAC 173-434-170(2), 10/18/90]

12. Change in Operation Reports for Solid Waste Incinerator Facilities
In the event a startup, shutdown, breakdown, or upset conditi on occurs that could result in a

violation of one or more of Conditions EU 1.36 and EU 1.37 or a violatio n of an ambient air quality standard, Ash Grove shall take the following actions as applicable:

### Permit No. 11339 Expiration Date: May 15, 2009 Page 49 of 81

Ash Grove Operating Permit, May 15, 2004 

### • For planned conditions, such as startups and shutdowns, that Ash Grove expects to cause a violation, the condition shall be reported to the Puget Sound Clean Air Agency not less

than 24-hours in advanc e of its occurrence.

• For unplanned conditions, such as a breakdow n or upset, the conditi on shall be reported to the Puget Sound Clean Air Agency as soon as possible, but no later than the end of the next business day.

This condition shall be inapplicable once th e updated regulation (WAC 173-434, effective 1/22/04) is adopted into the SIP.

[WAC 173-434-190, 10/18/90]

D. Recordkeeping

1. General Recordkeeping

Ash Grove shall maintain records of required monitoring information that include the following if applicable:

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

b) The date(s) analyses were performed;

c) The company or entity that performed the analyses;

d) The analytical techniques or methods used;

e) The results of such analyses; and

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

[WAC 173-401-615(2)(a), 10/17/02]

2. Changes made at the source

Ash Grove shall maintain records describing changes made at the source that result in emissions of a regulated air pollutant subj ect to an applicable requiremen t, but not otherwise regulated under the permit, and the emissions resulting from those changes.

[WAC 173-401-615(2)(b), (10/17/02)]

3. Record Retention

Records of all monitoring data a nd support information required by this permit shall be retained by Ash Grove for a period of five years from the date of the monitoring, sample, measurement, record, or application. Support information includes all calibrat ion and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit.

[WAC 173-401-615(2)(c), (10/17/02)]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 50 of 81

Ash Grove Operating Permit, May 15, 2004 

### 4. NESHAP Subpart LLL Record Retention
Ash Grove shall maintain files of all information (including all reports and notifications) required by 40 CFR Part 63, Subpart LLL in a form suitable and r eadily available for inspection for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks or on microfiche.

Ash Grove shall keep the SSM Plan on record to be made available for inspection, upon request, by the Puget Sound Clean Air Agency or EPA, for the life of the kiln a nd raw mill, or until the kiln/raw mill are no longer subject to the prov isions of 40 CFR Part 63. If the SSM Plan is revised, Ash Grove shall keep previous (i.e. supe rseded) versions of the Plan on record, to be made available for inspection, upon request, by th e Puget Sound Clean Air Agency or EPA, for five years following each revision of the Plan.

The provisions of this condition supplement, and do not supersede, the ge neral record retention requirements set forth in Condition II.D.3 above.

[40 CFR 63.10(b)(1) (5/30/03); 40 CFR 63.6(e)(3 )(v) (5/30/03); 40 CFR 63.1355(a) (6/14/99)]

5. O&M Plan Recordkeeping

Ash Grove shall document all in spections, tests and other acti ons required by the O&M Plan, including who conducted the inspecti on, tests or other actions; and th e date and the results of the inspection, tests or other actio ns including correc tive actions. Inspection records may be

maintained in electronic format. Ash Grove shall maintain records of all inspections, tests, and other actions required by the O&M Plan on site and available for Puget Sound Clean Air Agency

review.

[Puget Sound Clean Air Agency Regulation I, S ection 7.09(b)(6), (10/6/97)] [Puget Sound Clean Air Agency Regulation I, Section 7.09(b)(6), 9/10/98 (State Only)] [WAC 173-401-615(2)(a) (10/17/02), WAC 173-434-090, 10/18/90]

6. Complaint Response Recordkeeping

Records for complaints received concerning odor, fugitive emissions or nuisance conditions must contain the following information:

a) Date and time of the complaint,

b) Name and address of the person complaining, if known,

c) Nature of the complaint,

d) Investigation efforts and the basis for conclu sions reached regarding the complaint, and

e) Date, time and nature of any corrective action taken.

[Puget Sound Clean Air Agency Regulation I, Section 7.09(b)(6), (10/6/97)] [Puget Sound Clean Air Agency Regulation I, Section 7.09( b)(6), 9/10/98, (State Only)] [WAC 173-401- 615(2)(a) (10/17/02)]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 51 of 81

Ash Grove Operating Permit, May 15, 2004 

### 7. NSPS Recordkeeping

Ash Grove shall maintain the following information for at least two years following the date of measurements, maintenance, reports and records:

a) a file of all measurements recorded by the kiln COMS a nd by the continuous temperature

monitors installed at the in let to each coal mill baghouse;

b) all reports of performance tests conducted under 40 CFR Part 60 and all applicable subparts;

c) all reports of performance evaluations on th e kiln COMS and the coal mill temperature monitors;

d) all reports of CMS calibration checks on the kiln COMS and the coal mill temperature monitors;

e) all records of adjustments and maintenance performed on the kiln COMS and the coal mill temperature monitors;

f) all records required by Condition II.B.9 of the permit (kiln production rate and feed rate records);

g) records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the kiln and coal mills, and of the additional NSPS affected units listed in Sections I.B.2 and I.B.3 of this permit; ;

h) records of any malfunction any malfuncti on of the air pollution control equipment serving the kiln and coal mills, and of th e additional NSPS affect ed units listed in Sections I.B.2 and I.B.3 of this permit;

i) records of any period during which the kiln COMS or a coal mill temperature monitor is inoperative;

[40 CFR §60.7(b) and (f) (2/12/99); 40 CFR 60. 63(a) (12/14/88); 40 CF R 60.253(a) (10/17/00); WAC 173-401-615(2)(a) (10/17/02)]

8. NESHAP Subpart LLL Recordkeeping

Ash Grove shall maintain relevant records for the kiln and raw mill of:

a) The occurrence and duration of each st artup, shutdown or malfunction of operation of the kiln and the raw mill;

b) The occurrence and duration of each ma lfunction of the air pollution control equipment;

c) All maintenance performed on the air pollution control equipment;

d) Actions taken during SSM periods (inc luding corrective actions to restore malfunctioning process and air pollution cont rol equipment to its normal or usual manner of operation) when such actions are different from the procedures specified in the kiln SSM Plan;

### Permit No. 11339 Expiration Date: May 15, 2009 Page 52 of 81

Ash Grove Operating Permit, May 15, 2004 

### e) All information necessary to demonstrat e conformance with the kiln/raw mill

SSM Plan when all actions taken dur ing SSM periods (including corrective actions to restore malfunctioning proce ss and air pollution control equipment to its normal or usual manner of operation) are consistent with the procedures specified in the SSM Plan. (The inform ation needed to demonstrate conformance may be recorded using a checklist or other form designed to minimize the recordkeeping burden for conforming events);

f) Each period during which the kiln temperature CMS or either of the coal mill temperature CMS is malfunctioning or i noperative (including out of control periods);

g) All required measurements needed to demonstrate compliance with the

dioxin/furan standards in 40 CF R 63.1343(d), as provided in 40 CFR 63.10(b)(2)(vii);

h) All results of Subpart LLL performance tests and CMS performance evaluations;

i) All measurements as may be necessary to determine the conditions of Subpart LLL performance tests and performance evaluations;

j) All CMS calibration checks;

k) All adjustments and maintenance performe d on the kiln temperature CMS and on each coal mill temperature CMS;

l) Any information demonstrating whether Ash Grove is meeting the requirements for a waiver of recordkeeping or repo rting requirements under 40 CFR Part 63, if Ash Grove has been granted a waiver under 40 CFR 63.10(f);

m) All emission levels relative to the crite rion for obtaining permission to use an alternative to the relative accuracy test if Ash Grove has been granted such permission under 40 CFR 63.8(f)(6);

n) All documentation supporting initial notifi cations and notifications of compliance status under 40 CFR 63.9;

o) All required temperature CMS measuremen ts (including monitoring data recorded during unavoidable CMS breakdowns and out of control periods);

p) The date and time identifying each period during which the kiln temperature CMS and each coal mill temperature CMS was i noperative except for ze ro (low level) and high level checks;

q) The date and time identifying each period during which the kiln temperature CMS and each coal mill temperature CMS was out of control, as defined in 40 CFR 63.8(c)(7);

r) The date and time of commencement and completion of each period of excess emissions and parameter monitoring exceedances of the dioxin/furan emission limits in Conditions EU 1.26 through 1.29 th at occur during startups, shutdowns and malfunctions of the kiln/raw mill;

### Permit No. 11339 Expiration Date: May 15, 2009 Page 53 of 81

Ash Grove Operating Permit, May 15, 2004 

### s) The date and time of commencement and completion of each period of excess emissions and parameter monitoring exceedances of the dioxin/furan emission limits in Conditions EU 1.26 through 1.29 th at occur during periods other than SSM periods;

t) For each malfunction of the kiln, raw mill, or kiln air pollution control equipment,

the nature and cause of the malfunction (if known) and the corrective action taken or preventive measures adopted

u) For each occasion on which the temperature CMS on the kiln or either coal mill temperature CMS was inoperative or out of control, the nature of the repairs or adjustments to the CMS;

v) The total kiln, raw mill and coal mill operating time during the reporting period.

[40 CFR 63.1355(b) (6/14/99); 40 CFR 63.10(b) and (c) (5/30/03)]

9. Subpart LLL Applicability Determination Recordkeeping

Ash Grove shall maintain on site records of its determination that the Seattle plant is not a Subpart LLL major source for at least five years after the determination, or until the facility changes its operations to become a major source, whichever comes first. The record of the applicability determination must be signed by the person making the determination and include the analysis that demonstrates the basis for the de termination. The analysis shall be sufficiently detailed to allow EPA or the Puget Sound Cl ean Air Agency to make a finding about the source’s applicability status with regard to the relevant standard or other requirement.

[40 CFR 63.10(b)(3) (5/30/03)]

10. SO2, CO, and NOx Mass Emission Rate Recordkeeping

Ash Grove shall maintain on site records which document the 12-month rolling total calculations for NOx emissions from the kiln, the calendar ye ar calculations for SO2 and CO emissions from the kiln and summary 8-hour block average CO ma ss emission rates from the cement kiln. The records shall include the monthly calculations for each annual pollutant value, sufficient

documentation to demonstrate the conversions fro m CEM data to mass emission rates, sufficient

documentation to demonstrate the calculation methods used for mass emission rate data that is not CEM based, and documentation showing that al l kiln operational time is included in the

totals. The CEM data conversions used to generate mass emission rate values for these

calculations shall be documented and retained with the record. Emission ra te estimates used for operational periods lacking CEM data al so shall be documented and retained.

[WAC 173-401-615(3), 10/17/02]



## III. * 

## PROHIBITED ACTIVITIES

Ash Grove is prohibited from conducting, causing , or allowing the following activities:

### Permit No. 11339 Expiration Date: May 15, 2009 Page 54 of 81

Ash Grove Operating Permit, May 15, 2004 

### A. Adjustment for Atmospheric Conditions

Varying the rate of emissions of a pollutant according to atmospheric conditions or ambient concentrations of that pollutant is prohibite d, except as directed according to air pollution episode regulations. [WAC 173-400-205, 8/20/93]

B. Open Burning

Ash Grove shall not conduct open burning during any stage of an air pollution episode or period of impaired air quality and sh all not conduct any open burning ot her than the following types:

1. Fires consisting solely of charcoal, propane, natural gas, or wood used solely for the preparation of food that comply with WAC 173-425-020(1) a nd WAC 173-425-030(21)

and

2. Fires for instruction in the methods of figh ting fires, provided that the person conducting the training fire complies with Puget Sound Clean Air Agency Regulation I, Section 8.07.

[Puget Sound Clean Air Agency Regulation I, Sections 8.04(a), 11/09/2000 and 8.07, 9/09/1999] [WAC 173-425-020(1), 3/13/2000; WAC 173-425-030(21), 3/13/2000; RCW 70.94.743, 1998 c68 p1 and RCW 70.94.775(2), 1995 c362 p2 Stat e/Puget Sound Clean Air Agency only]

C. Refuse Burning

Ash Grove shall not cause or allow the burning of combustible refuse except in a multiple chamber incinerator provided with control equipment. Ash Gr ove shall not operate refuse burning equipment any time other than daylight hours. [Puget Sound Clean Air Agency Regulation I, Section 9.05, 12/9/93]

D. Concealment

Ash Grove shall not cause or allow the installa tion or use of any device or use of any means which, without resulting in a reduction in the total amount of air contaminant emitted, conceals

an emission of an air contaminant which would otherwise violate Puget Sound Clean Air Agency Regulation I, Article 9 or Chapter 173-400 WAC. [Puget Sound Clean Air Agency Regulation I, Section 9.13(a), 6/9/88; WAC 173-400-040(7), 8/20/93]

E. Masking

Ash Grove shall not cause or allow the installa tion or use of any device or use of any means designed to mask the emission of an air contaminant that causes detriment to health, safety or welfare of any person or conc eals or masks an emission of an air contaminant that would otherwise violate Regulation I, Article 9 or Chapter 173-400 WAC. [Puget Sound Clean Air Agency Regulation I, Section 9.13(b), 6/9/88; and WAC 173 -400-040(7), 8/20/93]

F. Ambient Standards

Ash Grove shall not cause or allo w the emission of air contaminants in sufficient quantity as to exceed any ambient air quality standard in P uget Sound Clean Air Agency Regulation I Section 11.01. [Puget Sound Clean Air Agency Re gulation I, Section 11.01(b), 4/14/94]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 55 of 81

Ash Grove Operating Permit, May 15, 2004 

### G. Tampering

Ash Grove shall not render inaccurate any mon itoring device or method required under Chapter 70.94 RCW, or any ordinance, reso lution, regulation, permit, or orde r in force pursuant thereto.

[WAC 173-400-105(8), 8/21/98 S TATE 

### O NLY 

### ]

H. False Statements

Ash Grove shall not make any false material stat ement, representation or certification in any form, notice, or report required under Chap ter 70.94 RCW, or any ordinance, resolution, regulation, permit, or order in force pursuant thereto.

[WAC 173-400-105(7), 8/21/98 S TATE 

### O NLY 

### ]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 56 of 81

Ash Grove Operating Permit, May 15, 2004 

### IV. ACTIVITIES REQUIRIN G ADDITIONAL APPROVAL

Ash Grove shall file notificati on and obtain the nece ssary approval from Puget Sound Clean Air Agency before conducting any of the following:

A. New Source Review

Ash Grove shall not construct, in stall, establish, or modify an air contaminant source, except those sources that are excluded by Puget Sound Cl ean Air Agency Regulation I, Section 6.03(b),

unless a “Notice of Constructi on and Application for Approva l” has been filed with and approved by Puget Sound Clean Air Agency. [Puget Sound Clean Air Agency Regulation I, Section 6.03, 7/12/01] [WAC 173-460-040 Stat e/Puget Sound Clean Air Agency only]

B. Replacement or Substantial Alteration of Emission Control Technology

Ash Grove shall file a Notice of Construction and Application for Approval according to WAC 173-400-114 with Puget Sound Clean Air Agency be fore replacing or subs tantially altering any emission control technology installed at the faci lity. [Puget Sound Clean Air Agency Regulation I, Section 6.03, 7/12/01] [WAC 173-400- 114, RCW 70.94.153 (1991) State/Puget Sound Clean Air Agency only]

C. Asbestos

Ash Grove shall comply with 40 CFR 61.145 and 61.150 when conducting renovation or demolition activities at the facility. [40 CFR 61.145, 4/7/1993 and 61.150, 1/16/1991]

Ash Grove shall comply with Puget Sound Clean Air Agency Regulation III, Article 4 when conducting any asbestos project, renovation, or de molition activities at the facility. [Puget Sound Clean Air Agency Regulation III, Article 4, 7/13/00 (State only)]

D. Spray Coating

Ash Grove shall comply with Puget Sound Clean Ai r Agency Regulation I, Section 9.16(a) when conducting or allowing any operatio n that involves the use of spray equipment to apply any VOC-containing material.

[Puget Sound Clean Air Agency Reg. I: 9.16 (7/1 2/01), State/Puget Sound Clean Air Agency only; however, will become federally enforceab le when EPA incorporates it into the SIP]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 57 of 81

Ash Grove Operating Permit, May 15, 2004 

### V. STANDARD TERMS AND CONDITIONS

A. Duty to comply

Ash Grove shall comply with all conditions of this permit. Any permit noncompliance constitutes a violation of Chapter 70.94 RCW and, for federally enforceable provisions, a violation of the Federal Clean Air Act (F CAA). Such violations are grounds for enforcement action; for permit termination, re vocation and re-issuance, or modification; or for denial of a permit renewal application.

[Puget Sound Clean Air Agency Regulat ion I, Section 7.05, 10/28/93, WAC 173-401- 620(2)(a), 11/4/93]

B. Permit actions

This permit may be modified, revoked, reopened and reissued, or terminated for cause. The filing of a request by Ash Grove for a permit modification, revocation and reissuance, or termination, or of a notifi cation of planned changes or anticipated noncompliance does not stay any permit condition.

[WAC 173-401-620(2)(c), 11/4/93]

C. Property rights

This permit does not convey any property right s of any sort, or any exclusive privilege.

[WAC 173-401-620(2)(d), 11/4/93]

D. Duty to provide information

Ash Grove shall furnish to the Puget Sound Cl ean Air Agency, within a reasonable time, any information that the Puget Sound Clean Air Agency may request in writing to determine whether cause exists for modifyi ng, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, Ash Grove shall also furnish to the Puget Sound Clean Air Agency copi es of records required to be kept by the permit or, for information claimed to be confidential, Ash Grove may furnish such records directly to EPA Region 10 along with a claim of confidentiality. The Puget Sound Clean Air Agency shall maintain the confidentiality of such information in

accordance with RCW 70.94.205.

[WAC 173-401-620(2)(e), 11/4/93]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 58 of 81

Ash Grove Operating Permit, May 15, 2004 

### E. Permit fees

Ash Grove shall pay fees as a condition of this permit in accordance with the Puget Sound Clean Air Agency Regulation I, Article 7. Failure to pay fees in a timely fashion shall subject Ash Grove to civil and crimin al penalties as prescribed in Chapter 70.94

RCW.

[WAC 173-401-620(2)(f), 11/4/93]

F. Emissions trading

No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading, and other similar programs or processes for changes that are provided for in this permit.

[WAC 173-401-620(2)(g), 11/4/93]

G. Severability

If any provision of this permit is held to be invalid, all unaffected pr ovisions of the permit

shall remain in effect and be enforceable.

[WAC 173-401-620(2)(h), 11/4/93]

H. Permit appeals

This permit or any condition in it may be a ppealed only by filing an appeal with the Pollution Control Hearings Board and serv ing it on the Puget Sound Clean Air Agency within thirty days of receipt, pursuant to RCW 43.21B.310 and WAC 173-401-735. The provision for appeal in this section is separate from and additional to any federal rights to petition and review found under §505(b) of the FCAA.

[WAC 173-401-620(2)(i) and WAC 173-401-735, 11/4/93]

I. Permit continuation

This permit and all terms and conditions c ontained therein, including any permit shield provided under WAC 173-401-640, shall not e xpire until the renewal permit has been issued or denied if a timely and complete application has been submitted. An application shield granted under WAC 173-401-705(2) shall remain in effect until the renewal permit has been issued or denied if a timely and complete permit application has been submitted.

[WAC 173-401-620(2)(j), 11/4/93]

J. Federal enforceability

All terms and conditions of this permit are enforceable by the EPA administrator and by citizens under the FCAA, except for those te rms and conditions designated in the permit as not federally enforceable.

[WAC 173-401-625, 11/4/93]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 59 of 81

Ash Grove Operating Permit, May 15, 2004 

### K. Inspection and entry

Upon presentation of credentials and other documents as may be required by law, Ash Grove shall allow the Puget Sound Clean Air Agen cy or an authorized representative to:

1. Enter Ash Grove's premises or where records must be kept under the conditions of this permit;

2. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit;

3. Inspect at reasonable times any facilities , equipment (including monitoring and air pollution control equipment), practices or operations regulate d or required under the permit; and

4. As authorized by WAC 173-400-105 and the FCAA, sample or monitor at reasonable times substances or paramete rs for the purpose of assuring compliance with the permit or applicable requirements.

[WAC 173-401-630(2) (11/4/93); RCW 70.94.200 (1991) State/Puget Sound Clean Air Agency only]

L. Compliance requirements

Ash Grove shall continue to comply with all applicable requirements with which the source is currently in compliance. Ash Grove shall meet on a timely basis any applicable requirements that become effective during the permit term.

[WAC 173-401-630(3), WAC 173-401- 510(2)(h)(iii) 11/4/93]

M. Compliance certifications

Ash Grove shall submit a certification of co mpliance with permit terms and conditions once per year. The first such certificati on shall cover a one-year period commencing upon the date of issuance of this perm it. Each certification shall include:

1. The identification of each term or condition of the permit that is the basis of the certification;

2. The compliance status;

3. Whether compliance was continuous or intermittent; and

4. The method(s) used for determining the co mpliance status of th e source, currently and over the reporting period. These methods must be consistent with the permit Monitoring, Maintenance and Recordkeeping Methods.

All compliance certifications shall be submitted to EPA Region 10 and to Puget Sound Clean Air Agency, at the following addresses, within 30 days after the close of the period covered by the certification:

### Permit No. 11339 Expiration Date: May 15, 2009 Page 60 of 81

Ash Grove Operating Permit, May 15, 2004 

### Puget Sound Clean Air Agency EPA Region 10, Mail Stop OAQ-107 Attn.: Operating Permit Certification Attn.: Air Operating Permits 110 Union Street, Suite 500 1200 Sixth Avenue Seattle, Washington 98101 Seattle, Washington 98101

[WAC 173-401-630(5) 11/4/93]

N. Performance Testing

For the purpose of determining compliance with an emission standard, Puget Sound Clean Air Agency or the Washington Stat e Department of Ecology may conduct testing of an emission unit or require Ash Grove to have it tested. In the event Puget Sound Clean Air Agency or Ecology conducts the test , Ash Grove shall be given an opportunity to observe the sampling and to obtain a sample at the same time.

[Puget Sound Clean Air Agency Regulati on I, Section 3.05(b), 2/10/94; WAC 173-400- 105(4), 8/20/93]

Ash Grove shall notify Puget Sound Clean Ai r Agency in writing at least 2 weeks (14 days) prior to any compliance test and provide Puget Sound Clean Air Agency an opportunity to review the test plan and to observe the test. Provi ded, Ash Grove shall provide the Puget Sound Clean Air Agency at least 30 days prior not ice of any NSPS (40 CFR Part 60) performance test, and 60 days prior notice of any NESHAP (40 CFR Part 63) performance test. If there is a delay in conducting a scheduled NSPS or NESHAP performance test, Ash Grove shall notify the Puget Sound Clean Air Agency as soon as possible of any delay, in accordance with pr ocedures specified in 40 CFR 60.8(d) (for NSPS testing) and 40 CFR 63.7(b)(2) (for NESHAP testing).

[Puget Sound Clean Air Agency Regulation I, Section 3.07(b) (2/9/95); 40 CFR 60.8(d) (2/12/99); 40 CFR 63.7(b) (10/7/00)]

If required by Puget Sound Clean Air Agency to perform a compliance test, Ash Grove shall submit a report to Puget Sound Clean Air Agency no later than 60 days after the test. The report shall include:

(a) A description of the source and the sampling location;

(b) The time and date of the test;

(c) A summary of results, repor ted in units and for averagi ng periods consistent with the applicable emission standard;

(d) A description of the test methods a nd quality assurance procedures employed;

(e) The amount of fuel burned and raw ma terial processed by the source during the

test;

### Permit No. 11339 Expiration Date: May 15, 2009 Page 61 of 81

Ash Grove Operating Permit, May 15, 2004 

### (f) The operating parameters of the sour ce and control equipment during the test;

(g) Field data and example calculations; and

(h) A statement signed by the senior mana gement official of the testing firm certifying the validity of the source test report.

[Puget Sound Clean Air Agency Regulat ion I, Section 3.07(c) (2/9/95)]

O. Credible Evidence

For the purpose of establishing whether or not a person has violated or is in violation of any provision of chapter 70.94 RC W, any rule enacted pursuant to that chapter, or any permit or order issued there under, nothing in Puget Sound Clean Air Agency Regulation I shall preclude the use, including the excl usive use of any credible evidence or information, relevant to whether a source woul d have been in compliance with applicable requirements if the appropriate performance or compliance test procedures or methods had been performed.

[Puget Sound Clean Air Agency Regulation I, Section 3.06 (10/ 08/98); State/Puget Sound Clean Air Agency only]

For purposes of Federal enforcement, nothing in 40 CFR Part 52 shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether Ash Grove would have been in complianc e with applicable requirements if the appropriate performance or compliance test procedures or methods had been performed.

[40 CFR 52.12(c) and 52.33(a) (2/24/97)]

P. NSPS and NESHAP Performance Testing

NSPS performance tests shall be conducte d and data reduced in accordance with procedures contained in 40 CF R 60.8 and in each applicable subpart of 40 CFR Part 60. Performance tests required under 40 CFR Pa rt 63, Subpart LLL shall be conducted and data reduced in accordance with relevant procedures contained in 40 CFR 63.7 and

63.1349.

[40 CFR §60.8 (2/12/99); 40 CFR 63.7 (4/5/02); 40 CFR 63.1349 (12/6/02)]

Q. Certification of Truth, Accuracy and Completeness

Any application form, report, or complian ce certification submitted pursuant to this permit shall contain certification by a re sponsible official of truth, accuracy, and completeness. This certification and any other certification required under this permit shall state that, based on information and beli ef formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

[WAC 173-401-520, 11/4/93]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 62 of 81

Ash Grove Operating Permit, May 15, 2004 

### R. Emergencies

An emergency, as defined in WAC 173-401-645(l) , constitutes an affirmative defense to an action brought for noncompliance with a technology-based emissi on limitation if the conditions of WAC 173-401-645(3) are met.

The affirmative defense of emergency sha ll be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that:

1. An emergency occurred and that Ash Gr ove can identify the cause(s) of the

emergency;

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

3. During the period of the emergency Ash Grove took all reasonable steps to

minimize levels of emissions that exceeded the emission standards or other requirements in the permit; and

4. Ash Grove submitted notice of the emergency to the Puget Sound Clean Air Agency within two (2) working days of the time when the emissions limitations were exceeded due to the emergency or s horter periods of time specified in an applicable requirement. This notice fulfills the requirement of WAC 173-401- 615(3)(b) unless the exce ss emissions represent a potenti al threat to human health or safety. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

In any enforcement proceeding, Ash Grove ha s the burden of proof to establish the occurrence of an emergency. This provision is in addition to any emergency or upset provision contained in any applicable requirement.

[WAC 173-401-645, 11/4/93]

S. Unavoidable excess emissions

Excess emissions due to startup or shutdown conditions, scheduled maintenance or upsets

that are determined to be unavoidable unde r the procedures and criteria in WAC 173-

400-107 shall be excused and not subject to penalty. For any excess emission that Ash Grove wants the Puget Sound Clean Air Agency to consider unavoidable and excusable under WAC 173-400-107, Ash Grove shall subm it the information required under WAC

173-400-107.

[WAC 173-400-107(2) (8/20/93)]

T. Need to halt or re duce activity not a defense

It shall not be a defense for Ash Grove in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

[WAC 173-401-620(2)(b), 11/4/93]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 63 of 81

Ash Grove Operating Permit, May 15, 2004 

### U. Stratospheric ozone and climate protection

1. Ash Grove shall comply with the following standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpa rt F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B:

i) Persons opening appliances for maintena nce, service, repair, or disposal must comply with the required practi ces pursuant to 40 CFR 82.156;

ii) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158;

iii) Persons performing mainte nance, service, repair, or disposal of appliances must be certified by an approved tech nician certification program pursuant to

40 CFR 82.161.

2. Ash Grove may switch from any ozone-depleting substance to any alternative approved pursuant to the Significant Ne w Alternatives Progr am (SNAP), 40 CFR Part 82, Subpart G, without a permit re vision but shall not switch to a substitute listed as unacceptable pursuant to such program. [40 CFR 82.174]

3. Any certified technician employed by As h Grove shall keep a copy of their certification at their place of employment. [40 CFR 82.166(1)]

4. Ash Grove shall not willfu lly release any regulated refrigerant and shall use refrigerant extraction equipment to recove r regulated refrigerant when servicing, repairing or disposing of commercial ai r conditioning, heating, or refrigeration

systems. [RCW 70.94.970(2) and (4), 11/12/97 State/Puget Sou nd Clean Air Agency only]

V. RACT satisfied

Emission standards and other requirements cont ained in rules or re gulatory orders in effect at the time of this permit issuance sh all be considered RACT for the purposes of issuing this permit.

[WAC 173-401-605(3), 11/4/93]

W. Risk management programs

In accordance with 40 CFR Part 68, if Ash Grove has or receives more than a threshold quantity of a regulated substance in a pr ocess, as determined under 40 CFR 68.115, Ash Grove shall comply with the requirements of the Chemical Accident Prevention

Provisions of 40 CFR Part 68 no la ter than the following dates:

1. Three years after the date on which a regul ated substance is first listed under 40 CFR 68.130, or

2. The date on which a regulated substan ce is first present above a threshold quantity in a process.

[40 CFR 68.10, 1/6/99]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 64 of 81

Ash Grove Operating Permit, May 15, 2004 

### X. Definitions

Unless otherwise defined in this permit, the terms used in th is permit shall have the same meaning ascribed to them in WAC 173-401-200.

[WAC 173-401-200, 10/17/02]

Y. Duty to supplement or correct application

Upon becoming aware that it has failed to submit any relevant facts in a permit application

or that it has submitted incorrect informatio n in a permit application, Ash Grove shall promptly submit such supplementary facts or corrected informati on to the Puget Sound Clean Air Agency.

[WAC 173-401-500(6), 10/17/02]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 65 of 81

Ash Grove Operating Permit, May 15, 2004 

### VI. PERMIT ACTIONS

A. Permit Renewal, Revocation and Expiration

1) Renewal application . Ash Grove shall submit a complete permit renewal application to the Puget Sound Clean Air Agency no later than 12 mont hs prior to the expiration of this permit. Puget Sound Clean Air Agency will send Ash Grove a renewal applic ation no later than 18 months prior to the expiration of this permit. Failure of the Puget Sound Clean Air Agency to send Ash Grove a renewal application shall not relieve Ash Grove fr om the obligation to file a timely and complete renewal application.

[WAC 173-401-710(1), WAC 173-401-500(2), 10/17/02]

2) Expired permits . Permit expiration terminates Ash Gr ove's right to oper ate unless a timely and complete renewal application has been submitted consistent with WAC 173-401-710(1)

and WAC 173-401-500. All terms and conditions of the permit shall remain in effect after this permit expires if a timely and complete permit application has been submitted.

[WAC 173-401-710(3), 10/17/02]

3) Revocation of permits . Puget Sound Clean Air Agency may revoke a permit only upon the request of Ash Grove or for cause. Puget So und Clean Air Agency shall provide at least thirty days written notice to Ash Grove prior to revocation of the permit or denial of a permit renewal application. Such noti ce shall include an explanation of the basis for the proposed

action and afford Ash Grove an opportunity to meet with the Puget Sound Clean Air Agency prior to the Puget Sound Clean Air Agency’s fina l decision. A revocation issued under this condition may be issued conditionally with a futu re effective date and may specify that the

revocation will not take effect if Ash Grove satisfies the specified conditions before the effective date. Nothing in this subsection shall limit the Puget S ound Clean Air Agency's authority to issue emergency orders.

[WAC 173-401-710(4), 10/17/02]

B. Administrative Permit Amendments

1) Definition. An "administrative permit amendment" is a permit revision that:

a) Corrects typographical errors;

b) Identifies a change in the name, address, or phone number of any person identified in the permit, or provides a similar minor administrative change at Ash Grove;

c) Requires more frequent mon itoring or reporting by Ash Grove;

d) Allows for a change in ow nership or operational control of a source where the Puget Sound Clean Air Agency determines that no other change in the permit is necessary, provided that a written agreem ent containing a specific da te for transfer of permit responsibility, coverage, and liability betw een the current and new permittee has been submitted to the Puget Sound Clean Air Agency;

### Permit No. 11339 Expiration Date: May 15, 2009 Page 66 of 81

Ash Grove Operating Permit, May 15, 2004 

### e) Incorporates into the permit the terms, conditions, and provisions from orders approving notice of construction applic ations processed under an EPA-approved program, provided that such a program meets procedural requi rements substantially equivalent to the requirements of WAC 173-401-700, 173-40 1-725, and 173-401-800 that would be applicable to the change if it were subj ect to review as a permit modification, and compliance requirements substantially equi valent to those c ontained in WAC 173-401- 600 through 173-401-650.

[WAC 173-401-720(1), 11/4/93]

2) Administrative permit amendment procedures . An administrative permit amendment may be made by the Puget Sound Clean Air Ag ency consistent with the following:

a) Puget Sound Clean Air Agency shall take no more than sixty days from receipt of a request for an administrative permit amendment to take final action on such request, and may incorporate such changes without providing notice to the public or affected states provided that it designates any such permit re visions as having been made pursuant to this paragraph.

b) Puget Sound Clean Air Agency shall subm it a copy of the revised permit to EPA.

c) Ash Grove may implement the changes addre ssed in the request fo r an administrative amendment immediately upon s ubmittal of the request.

[WAC 173-401-720(3), 11/4/93]

3) Permit shield . Puget Sound Clean Air Agency shall, upon taking final action granting a request for an administrative permit amendment, allow coverage by the permit shield in WAC 173-401-640 for administrative permit amendm ents made pursuant to Part (1)(e) of

this condition.

[WAC 173-401-720(4), 11/4/93]

C. Changes not Requi ring Permit Revisions

1) General

. a) Ash Grove is authorized to make the change s described in this se ction without a permit revision, providing the following conditions are met:

i) The proposed changes are not Title I modifications as defined in WAC 173-401- 200;

ii) The proposed changes do not result in emissions which exceed those allowable under the permit, whether expressed as a ra te of emissions, or in total emissions;

iii) The proposed changes do not alter permit terms that are necessary to enforce limitations on emissions from units covered by the permit; and

### Permit No. 11339 Expiration Date: May 15, 2009 Page 67 of 81

Ash Grove Operating Permit, May 15, 2004 

### iv) Ash Grove provides EPA and the Puge t Sound Clean Air Agency with written notification at least seven days prior to making the proposed changes except that

written notification of a cha nge made in response to an emergency shall be provided as soon as possible after the event.

b) Permit attachments. Ash Grove and the Puget Sound Clean Air Agency shall attach each notice to their copy of the relevant permit.

2) Section 502 (b)(10) changes . Pursuant to the conditions in Subsection (1) of this section,

Ash Grove is authorized to make Section 502(b)(10) changes (as defined in WAC 173-401- 200) without a permit revision.

a) For each such change, the written notific ation required under S ubsection (1)(a)(iv) of this condition shall include a brief descripti on of the change within the permitted facility, the date on which the change will occur, an y change in emissions, and any permit term or condition that is no longer applic able as a result of the change.

b) The permit shield authorized under WAC 173-401-640 shall not apply to any change made pursuant to this paragraph.

3) SIP authorized emissions trading. Pursuant to the conditions in Subsection (1) of this condition, Ash Grove is authorized to trade in creases and decreases in emissions in the permitted facility, where the Washington state implementation plan provides for such emissions trades without requi ring a permit revision. This pr ovision is available in those cases where the permit does not already provide for such emissions trading.

a) Under this Subsection (3), the written notification required unde r Subsection (1)(a)(iv)

of this condition shall include such informa tion as may be require d by the provision in the Washington state implementation plan authorizing the emissions trade, including at a minimum, when the proposed change will occu r, a description of each such change, any change in emissions, the permit requirements with which Ash Grove will comply using the emissions trading provisions of the Wa shington state implementation plan, and the pollutants emitted subject to the emissions tr ade. The notice shall also refer to the provisions with which Ash Grove will comply in the applicable implementation plan and that provide for the emissions trade.

b) The permit shield described in WAC 173-401-640 shall not extend to any change made under this paragraph. Compliance with the permit requirements that Ash Grove will meet using the emissions trade shall be de termined according to requirements of the applicable implementation plan auth orizing the emissions trade.

[WAC 173-401-722, 10/17/02]

D. Off Permit Changes

1) Ash Grove shall be allowed to make changes not specifically addresse d or prohibited by the permit terms and conditions without requiring a permit revision, provided that the proposed changes do not weaken the enfor ceability of existing permit condi tions. Any change that is

a Title I modification or is a ch ange subject to the acid rain requirements under Title IV of the FCAA must be submitted as a permit revision.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 68 of 81

Ash Grove Operating Permit, May 15, 2004 

### 2) Each such change shall meet all applicable requirements and shall not violate any existing permit term or condition.

3) Ash Grove must provide cont emporaneous written notice to the Puget Sound Clean Air Agency and EPA of each such change, except for changes that qualify as insignificant under

WAC 173-401-530. Such written notice shall descri be each such change, including the date, any change in emissions, pollutants emitted, and any applicable requirement that would apply as a result of the change.

4) The change shall not qualify for th e permit shield under WAC 173-401-640.

5) Ash Grove shall keep a record describing changes made at Ash Grove that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the em issions resulting from those changes.

6) When making a change under this section, As h Grove shall comply with applicable preconstruction review requirements esta blished pursuant to RCW 70.94.152 and Puget Sound Clean Air Agency Regulation I, Article 6.

[WAC 173-401-724, 11/4/93]

E. Permit Modification

1) Definition . A permit modification is any revi sion to this permit that cannot be accomplished under provisions for administrative permit amendments under WAC 173-401-

720.

2) Procedures . Minor permit modifi cation procedures.

a) Criteria.

i) Minor permit modification procedures shal l be used for those permit modifications

that:

a) Do not violate any applicable requirement;

b) Do not involve significant changes to existing monitoring, reporting, or recordkeeping requirements in the permit;

c) Do not require or change a case-by-case determination of an emission limitation or other standard, or a s ource-specific determination for temporary sources of ambient impacts, or a visibility or increment analysis;

d) Do not seek to establish or change a permit term or condition for which there is no corresponding underlying applicable re quirement and that Ash Grove has assumed to avoid an applicable re quirement to which Ash Grove would otherwise be subject. Such terms and conditions include:

(1) A federally enforceable emissions ca p assumed to avoid classification as a modification under any provision of Title I of the FCAA; and

### Permit No. 11339 Expiration Date: May 15, 2009 Page 69 of 81

Ash Grove Operating Permit, May 15, 2004 

### (2) An alternative emissions limit approved pursuant to regulations promulgated under section 112(i)(5) of the FCAA;

e) Are not modifications under any provision of Title I of the FCAA;

ii) Notwithstanding (a)(i) of this subsecti on, and Subsection (3) of this section, the Puget Sound Clean Air Agency may allow the use of minor permit modification procedures for permit modifications invol ving the use of economic incentives, marketable permits, emissions trading, and other similar approaches, to the extent that the use of such minor permit modificat ion procedures is e xplicitly provided for in the Washington state implementation plan or in applicable requirements promulgated by EPA and in effect on April 7, 1993.

b) Application. An application requesting th e use of minor permit m odification procedures shall meet the requirements of WAC 173-401- 510 and shall include the following:

i) A description of the cha nge, the emissions resulting fr om the change, and any new applicable requirements that wi ll apply if the change occurs;

ii) Ash Grove's suggested draft permit;

iii) Certification by a responsible offici al, consistent with WAC 173-401-520, of the truth, accuracy, and completeness of th e application and that the proposed

modification meets the criteria for use of minor permit modification procedures and a request that such procedures be used; and

iv) Completed forms for the Puget Sound Clean Air Agency to use to notify EPA and affected states as required under WAC 173-401-810 and 173-401-820.

c) Ash Grove's ability to make change. As h Grove may make the change proposed in its minor permit modification application imme diately after it files such application provided that those changes requiring the submissions of a notice of construction application have been reviewed and appr oved by the Puget Sound Clean Air Agency. After Ash Grove makes the change allowed by the preceding sentence, and until the Puget Sound Clean Air Agency takes any of the actions specified in WAC 173-401- 725(d), Ash Grove must comply with both the applicable requirements governing the change and the proposed permit terms and conditions. During this time period, Ash Grove need not comply with the existing perm it terms and conditions it seeks to modify. However, if Ash Grove fails to comply w ith its proposed permit terms and conditions during this time period, the existing permit te rms and conditions it seeks to modify may be enforced against it.

d) Permit shield. The permit shield unde r WAC 173-401-640 shall not extend to minor permit modifications.

3) Group processing of minor permit modifications. Consistent with WAC 173-401-725(3), the Puget Sound Clean Air Agency may process gr oups of a source's applications for certain modifications eligible for minor permit modification processing.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 70 of 81

Ash Grove Operating Permit, May 15, 2004 

### 4) Significant modification procedures

. a) Criteria. Significant modifi cation procedures shall be used for applications requesting permit modifications that do not qualify as minor permit modifications or as administrative permit amendments. Every significant change in existing monitoring permit terms or conditions and every relaxa tion of reporting or re cordkeeping permit terms or conditions shall be considered signifi cant. Nothing herein shall be construed to preclude Ash Grove from making changes c onsistent with Chapter 173-401 WAC that would render existing permit complian ce terms and conditions irrelevant.

b) Significant permit modifications shall meet all requirements of Chapter 173-401 WAC, including those for ap plications, public participation, review by affected states, and review by EPA, as they apply to permit issuance and permit renewal. Puget Sound Clean Air Agency shall complete review on the majority of significant permit

modifications within nine months after receipt of a complete application.

[WAC 173-401-725, 11/4/93]]

F. Reopening for Cause

1) Standard provisions. This permit shall be reopened an d revised under any of the following

circumstances:

a) Additional applicable requirements become applicable to Ash Grove with a remaining permit term of three or more years. Such a reopening shall be completed not later than eighteen months after promulgation of the app licable requirement. No such reopening is required if the effective date of the requirement is later than the date on which the permit is due to expire, unless the original permit or any of its terms and conditions have been extended pursuant to WAC 173-401-620(2)(j);

b) Additional requirements (including excess em issions requirements) become applicable

to an affected source under the acid rain program. Upon approval by EPA, excess emissions offset plans shall be deemed to be incorporated into the permit;

c) Puget Sound Clean Air Agency or EPA dete rmines that the permit contains a material

mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or

d) Puget Sound Clean Air Agency or EPA determ ines that the permit must be revised or revoked to assure compliance with the applicable requirements.

2) Procedures

. Proceedings to reopen a nd issue a permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of the permit for which cause to reopen exists. Such reopening shall be made as expeditious ly as practicable.

3) Notice . Reopenings under this section shall not be initiated before a notice of such intent is provided to Ash Grove by the Puge t Sound Clean Air Agency at le ast thirty days in advance of the date that the permit is to be reopened, except that th e Puget Sound Clean Air Agency may provide a shorter time period in the case of an emergency.

[WAC 173-401-730, 11/4/93]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 71 of 81

Ash Grove Operating Permit, May 15, 2004 

## VII. PERMIT SHIELD

Compliance with the conditions of the permit shal l be deemed compliance with any applicable requirements contained in Sections I through VI of this permit that are specifically identified in this permit as of the date of permit issuance. [WAC 173-401-640(1)]

Nothing in this permit shall alter or affect the following:

(1) The provisions of Section 303 of the FCAA (e mergency orders), including the authority

of the administrator under that section;

(2) The liability of an owner or operator of Ash Grove for any violation of applicable requirements prior to or at the time of permit issuance;

(3) The applicable requirements of the acid ra in program, consistent with Section 408(a) of the FCAA;

(4) The ability of EPA to obtain information from a source pursuant to Section 114 of the FCAA; or

(5) The ability of Puget Sound Clean Air Agency to establish or revise requirements for the use of reasonably available control t echnology (RACT) as provided in Chapter 252,

Laws of 1993.

[WAC 173-401-640(4), 11/4/93]

### Permit No. 11339 Expiration Date: May 15, 2009 Page 72 of 81

Ash Grove Operating Permit, May 15, 2004 

### VIII. INAPPLICABLE REQUIREMENTS

As of the date of permit issuan ce, the requirements lis ted below do not apply to Ash Grove, or to the specific emission units specified below for the reasons indicated. The permit shield applies to all requirements so identified.

[WAC 173-401-640(2), 11/4/1993]

Citation Type of Requirement Basis for Nonapplicability RCW 70.94.531 Transportation Demand Management This section requires, within 6 months after King County's adoption of a commute trip reduction plan, employers develop a trip reduction program and submit the program to the Puget Sound Clean Air Agency for review. This section is not an applicable requirement because it applies only to"major employers" that employ 100 or more fulltime employees at a single work site who begin their work day between 6:00 a.m. and 9:00 a.m. Ash Grove does not employ 100 or more workers; therefore, it is not an applicable requirement. This requirement does not apply to emission units or stationary sources.

WAC 173-400- 040(3)(b) and (8)(b) Fugitive emission standards

for emission units identified as “a significant contributor

to the nonattainment status of a designated

nonattainment area There are no designated nonattainment areas in the vicinity of the Seattle plant, and no emission unit at the Seattle plant has been identified as a “significant contributor” to the nonattainment status of a designated nonattainment area.

WAC 173-400-075 (except asbestos NESHAPS) Emissions Standards for Sources Emitting Hazardous

Air Pollutants This requirement adopts the national emissions standards for hazardous air pollutants in 40 CFR Part 61 by reference and gives Ecology authority

to conduct source tests and access to records to determine compliance. WAC 173-400-075 is not an applicable requirement because none of the subparts of 40 CFR Part 61 applies to any

emissions unit at Ash Grove.

WAC 173-400-151 Retrofit Requirements for Visibility Protection This is inapplicable because Ecology has not identified Ash Grove as a source causing or contributing to impaired visibility in a Class I area. If Ecology makes such a determination, Puget Sound Clean Air Agency will reopen the permit.

WAC 173-434 Solid

Waste Incinerator Facilities (as amended on 12/22/03) Emission and operational

limits for solid waste

incinerator facilities WAC 173-434 (as amended on December 22, 2003) does not apply to Ash Grove because the amendments exempt from the coverage of WAC ch. 173-434 the only solid waste materials that Ash Grove currently is authorized to combust. This inapplicability determination does not apply

to the 10/18/90 version of WAC ch. 173-434.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 73 of 81

Ash Grove Operating Permit, May 15, 2004 Citation Type of Requirement Basis for Nonapplicability

WAC 173-434-130(1) (10/18/90) particulate emission limits

for incinerators This subsection does not apply because WAC 173-434-100(2) states that “Whenever more than one regulation applies to the control of air contaminants from an incinerator facility the more stringent regulation, control or emission limit shall govern.” WAC 173-400-100(1) requires BACT for incinerator facilities that are required to file a notice of construction. Ash

Grove filed a notice of construction for the kiln in 1990, and PSAPCA established a LAER limit for particulates in Approval Order 7381 (Condition EU 1.13) that is more stringent than WAC 173- 434-130(1).

WAC 173-434-130(2) (10/18/90) 50 ppm HCl limit for

incinerators This subsection does not apply because WAC 173-434-100(2) states that “Whenever more than one regulation applies to the control of air contaminants from an incinerator facility the more stringent regulation, control or emission limit shall govern.” Ash Grove has elected to be regulated as an area source under 40 CFR Part 63, Subpart LLL. To maintain this status Ash Grove must limit its HCl emissions to approximately 18.21 ppm of HCl when the raw mill is off, and 0.2 ppm when the raw mill is on. The operational

limits needed to maintain area source status are far more stringent than the 50 ppm HCl limit in WAC 173-434-130(2).

WAC 173-434- 130(1)(a) (10/18/90) particulate emission limit for large incinerators This subsection is not applicable because Ash Grove’s kiln is not capable of burning 250 tons per day of solid waste.

WAC 173-434-130(3) (10/18/90) 50 ppm sulfur dioxide

emission limit The 50 ppm limit in this subsection does not apply to Ash Grove because more than 50 percent of the heat input to the kiln is fossil fuel and the department of ecology established a higher sulfur

dioxide limit as BACT in PSD Permit 90-03

WAC 173-434-170(1) (10/18/90) hydrogen chloride CEM requirement WAC 173-434-170(1) requires owners to install

CEMS for SO 2 or HCl. PSAPCA and Ecology elected to require an SO 2 CEM.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 74 of 81

Ash Grove Operating Permit, May 15, 2004 Citation Type of Requirement Basis for Nonapplicability
WAC 173-435 Emergency Episode Plans This ch apter is not an applicable requirement until it is triggered by a request from Ecology to prepare a Source Emission Reduction Plan (SERP). Absent a request for a SERP, nothing in this chapter (except WAC 173-435-050(2)) imposes substantive requirements on sources.

WAC 173-435-050(2) Action Procedures Subsection (2) is not an applicable requirement because Ash Grove's operations do not include open burning. The other subsections are not applicable requirements, because they do not impose substantive requirements on facilities.

WAC 173-470 Ambient Air Quality

Standards for Particulate

Matter Ambient air quality standards are not "applicable requirements" [See WAC 173-401-200(4)(a)(xii) (10/17/02); 57 Fed. Reg. 32276 (July 22, 1992)].

WAC 173-474 Ambient Air Quality

Standards for Sulfur Oxides Ambient air quality standards are not "applicable requirements" [See WAC 173-401-200(4)(a)(xii) (10/17/02); 57 Fed. Reg. 32276 (July 22, 1992)].

WAC 173-475 Ambient Air Quality

Standards for Carbon Monoxide, Ozone, and Nitrogen Dioxide Ambient air quality standards are not "applicable requirements" [See WAC 173-401-200(4)(a)(xii) (10/17/02); 57 Fed. Reg. 32276 (July 22, 1992)].



### WAC 173-480 Ambient Air Quality

Standards and Emission

Limits for Radionuclides Ambient air quality standards are not "applicable requirements" [See WAC 173-401-200(4)(a)(xii) (10/17/02); 57 Fed. Reg. 32276 (July 22, 1992)]. These standards are also not applicable requirements because Ash Grove does not emit

radionuclides.

WAC 173-481 Ambient Air Quality and

Environmental Standards for

Fluorides Ambient air quality standards are not "applicable requirements" [See WAC 173-401-200(4)(a)(xii) (10/17/02); 57 Fed. Reg. 32276 (July 22, 1992)].

Puget Sound Clean Air Agency Reg. I:

Article 5 Registration This section will not be applicable because Title V permitted sources are not subject to these registration and reporting requirements per RCW 70.94.161(17).

Puget Sound Clean Air Agency Reg. I: 9.04(e) (04/9/98) Venturi Scrubber This section does not apply because Ash Grove does not operate a Venturi scrubber and Ash Grove will apply for a permit modification before

installation.

Puget Sound Clean Air Agency Reg. I: 12.02(b) (08/10/89) Wet Control Equipment This section is not an applicable requirement

because Ash Grove does not use wet control equipment, and Ash Grove will apply for a permit

modification before installation.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 75 of 81

Ash Grove Operating Permit, May 15, 2004 Citation Type of Requirement Basis for Nonapplicability
Puget Sound Clean Air Agency Reg. I: 12.03(c) (08/10/89) Pressure Loss Through

Scrubbers This section is not applicable because Ash Grove

does not use scrubbers.

Puget Sound Clean Air Agency Reg. I: 12.03(d) (08/10/89) Scrubber Liquid Supply

Rate This section is not applicable because Ash Grove

does not use scrubbers.

Puget Sound Clean Air Agency Reg. I: 12.04(b) (08/10/89) Recordkeeping for Scrubber Operations This section is not applicable because Ash Grove

does not use scrubbers.

Puget Sound Clean Air Agency Reg. II: Articles 1, 2 & 3 Gasoline Marketing & VOC

Standards These sections are not applicable because Ash Grove does not have equipment that is governed by this regulation.

Puget Sound Clean Air Agency Reg. III:

Articles 3 Chromium Standards This section is inapplicable because Ash Grove does not have any of the listed equipment and must obtain approval before installing this type of equipment.

PSD Permit 90-03 (6/20/90) and

Amendments 1 (11/7/95) and 2 (3/8/99) PSD Permit These versions of Permit 90-03 were superseded by Amendment 3 (10/8/01).

Puget Sound Clean Air Agency Approval Orders 3382, 5730 and 7381 (6/29/98) New source approval orders Superseded by Order of Appr oval 7381, condition 8 (6/6/01)

40 CFR Part 60, Subpart OOO NSPS for Nonmetallic Mineral Processing Plants 40 CFR 60.670(b) states that a Subpart OOO “affected facility” that is subject to Subpart F or that follows in the pl ant process any facility subject to Subpart F is not subject to Subpart OOO. All equipment at the Seattle plant that falls within the Subpart OOO definition of “affected facility” is also a Subpart F “affected facility.”

### Permit No. 11339 Expiration Date: May 15, 2009 Page 76 of 81

Ash Grove Operating Permit, May 15, 2004 Citation Type of Requirement Basis for Nonapplicability

The requirements that are identified below are ina pplicable for specific emission units or for rule and unit specific reasons. The requirements identi fied in the first column for these subsequent items are inapplicable only insofar as the scope and explanation provided in the third column qualifies the limitation of inapplicability and are no t universally inapplicable to the entire site or for this permit beyond that scope and explanation.

40 CFR Part 60, Subpart A NSPS reporting requirements NSPS notices and reports required by Subparts A, F, and Y need be submitted only to Puget Sound Clean Air Agency without parallel submittal copies to EPA. Letter of February 5, 2003 from Betty Weise, EPA Region 10 to Dennis McLerran. EPA retains responsibility for review and approval of major changes to NSPS monitoring and test methods, as described in the February 5 th letter.

40 CFR 60 Part 60, Subpart F NSPS for Portland Cement

Plants Clinker storage shed, finish mills, steel scale tanks and Group I and Group II silos are not Subpart F “affected facilities” because none of

these facilities were constructed or modified after August 17, 1971. 40 CFR 60.60(b) (7/25/77).

40 CFR 60.63(b) COMS requirement Requirement to install COMS on “each bypass stack” does not apply to the coal mill stacks because coal mills are subject to 40 CFR Part 60, Subpart Y opacity limit, rather than Subpart F.

See Memo of 4/6/95 from John Rasnic to EPA Regional Directors re Opacity at Portland Cement Plants (Applicability De terminations 9600073)

and Memo of 5/12/95 from John Rasnic (Applicability Determinations 9600082).

40 CFR 60.13;

40 CFR 60.253(b) NSPS performance specifications and QA/QC requirements for continuous monitoring systems 40 CFR 60.13 does not apply to the temperature

monitors required to be installed on the coal mill

stacks by 40 CFR 60.253(a)(1) because 60.13 requirements take effect “upon promulgation of performance specifications for continuous monitoring systems under appendix B to this part,” and no performance specs have been promulgated under 40 CFR Part 60, Appendix B for continuous temperature monitors.

40 CFR Part 60, Subpart Y NSPS Standards for Coal Preparation Plants Coal loading, transfer and storage equipment upstream of the Raw Coal Silo are not Subpart Y “affected facilities.” See EPA Applicability Determinations Y002 (2/24/77) and NR90 (10/29/90)

40 CFR Part 63, Subparts A and LLL MACT standards for

Portland cement Plants All Subpart A and Subpart LLL standards that apply to emission units at a “major source” do not

### Permit No. 11339 Expiration Date: May 15, 2009 Page 77 of 81

Ash Grove Operating Permit, May 15, 2004 Citation Type of Requirement Basis for Nonapplicability (Major Source Provisions) apply to the Seattle plan t because the Seattle plant is not a “major source” within the meaning of 40

CFR 63.2.

40 CFR Part 63, Subparts A and LLL (Notifications & Reports) MACT standards for Portland cement plants All Subpart A and LLL requirements to submit notifications and reports to EPA do not apply to the Seattle plant, because EPA waived notice in its delegation action to Puget Sound Clean Air Agency. See 65 Fed. Reg. 10392 (2/28/00). All requirements in Subparts A and LLL to serve notifications and reports on “the Administrator” or EPA are amended to designate Puget Sound Clean Air Agency as the recipient.

40 CFR 63.7 and 63.1349(a) and (b) MACT initial performance test requirements The requirement to conduct a performance test to demonstrate initial compliance with the

dioxin/furan emission standards in 40 CFR 63.1343(d) was satisfied on October 22-24, 2002 The test report and compliance notification were submitted on December 20, 2002.

40 CFR 63.9 (b) through (d) and 63.1353(b)(1) MACT initial notification requirements Subpart A and LLL initial notification requirements for the kiln/raw mill were satisfied by the letter of October 7, 1999 from Henrik

Voldbaek to Tom Fitzsimmons et al..

40 CFR 63.1350(g) Dioxin/furan monitoring requirements for kilns that employ carbon injection as

an emission control technique The Seattle plant does not employ carbon injection as an emission control technique.

40 CFR 63.1351(b) Subpart LLL compliance

date for affected sources that

commence new construction

or reconstruction after March 24, 1998 Ash Grove did not commence new construction or reconstruction on any Subpart LLL affected source after March 24, 1998.

40 CFR 63.1344(b) Temperature limit for

affected sources determined through performance test The procedure in 40 CFR 1344(b) to set the temperature limit for affected sources through measurements taken during dioxin/furan performance testing does not apply to the coal

mills , because Puget Sound Clean Air Agency approved an intermedia te monitoring change establishing the coal mill temperature limit at 200 degrees F. See letter of October 18, 2002 from Steven Van Slyke to Robert Vantuyl.

### Permit No. 11339 Expiration Date: May 15, 2009 Page 78 of 81

Ash Grove Operating Permit, May 15, 2004 

## IX. INSIGNIFICANT EMISSION UNITS

A. Insignificant Emission Units and Activities

1. Insignificant emission units and activities at Ash Grove are subject to all applicable requirements set forth in Sections I.A, III and IV. This permit shall not require testing, monitoring, reporting or reco rdkeeping for insignificant em ission units or activities except as required by Puget Sound Clean Air Ag ency Regulation I, Sections 7.09(b) and 9.20. Compliance with Puget Sound Clean Air Agency Regulation I, Sections 7.09(b) and 9.20 shall be deemed to satisfy the requirements of WAC 173-401-615 and 173-401- 630(1).

[WAC 173-401-530(2)(c), 10/17/02]

2. Where this permit does not require testing, monitoring, recordkeeping and reporting for insignificant emissions units or activities, Ash Grove may certify continuous compliance if there were no observed, documented, or kno wn instances of nonc ompliance during the reporting period. Where this permit requir es testing, monitoring, recordkeeping and reporting for insignificant emission units or activities, Ash Grove may certify continuous compliance when the testing, monitoring, and recordkeeping required by the permit

revealed no violations dur ing the period, and there were no observed, documented, or known instances of noncompliance during the reporting period.

[WAC 173-401-530(2)(d), 10/17/02]

3. An emission unit or activity that qualifies as insignificant solely on the basis of WAC 173-401-530(1)(a) shall not exceed the emi ssion thresholds specified in WAC 173-401- 530(4) until this permit is modified pursuan t to Section VI.E of this permit and WAC

173-401-725.

[WAC 173-401-530(6), 10/17/02]

As of the date of permit issuance, the emission un its listed below are defi ned as insignificant for

the reasons indicated.

Unit Basis for IEU Designation

Lubricating oil storag e tanks WAC 173-401-532 (3) Vehicle maintenance WAC 173-401-532 (7) Internal combustion engines for propelling or powering a

vehicle WAC 173-401-532(10)

Welding equipment WAC 173-401-532(12) Cleaning and sweeping of streets and paved surfaces WAC 173-401-532(35) Roads (sweep and water for dust control) WAC 173-401-532(35) Steam cleaner WAC 173-401-532(39) Kerosene, grease, and oil drums WAC 173-401-532(42)

### Permit No. 11339 Expiration Date: May 15, 2009 Page 79 of 81

Ash Grove Operating Permit, May 15, 2004 

### Unit Basis for IEU Designation

Truck wash WAC 173-401-532(45)

Window air conditione rs WAC 173-401-532(46) Bathroom vents WAC 173-401-532(48)

Fuel and exhaust emissions from vehi cles in parking lots WAC 173-401-532(54)

Staff vehicles WAC 173-401-532(54) Air compressor (electric) WAC 173-401-532(88) Diesel Fuel Tank (kiln drive standby) 185 gal WAC 173-401-533(2)(a) Underground Diesel Fuel Tank 2000 gal WAC-173-401-533(2)(c) Lignite Tank WAC-173-401-533(2)(c) Finish Grinding Aid Ta nk WAC-173-401-533(2)(c) Space Heaters <5 MMBtu/hr WAC 173-401-533(2)(r) Underground Gasoline tank 1000 gal WAC 173-401-533(2)(t) Safety-Kleen station WAC 173-401-533(2)(z) Calibration gases (for equi pment) WAC 173-401-533(3)(c)

### Permit No. 11339 Expiration Date: May 15, 2009 Page 80 of 81

Ash Grove Operating Permit, May 15, 2004 

### X. APPENDIXES

A. Reference Methods (by reference only, not attached)

(1) EPA Method 5 [40 CFR 60, Appendix A, July 1, 2002]

(2) EPA Method 9 [40 CFR 60, Appendix A, July 1, 2002]

(3) EPA Method 10 [40 CFR 60, Appendix A, July 1, 2002]

(4) EPA Method 7E [40 CFR 60, Appendix A, July 1, 2002]

(5) EPA Method 6C [40 CFR 60, Appendix A, July 1, 2002]

(6) EPA Method 23 [40 CFR 60, Appendix A, July 1, 2002]

(7) EPA Method 20.A [40 CFR 51, Appendix M, July 1, 2001]

B. Non-EPA Test Methods (attached)

(1) Puget Sound Clean Air Agency Method 5 as approved by Puget Sound Clean Air Agency Board Resolution 540 dated August 11, 1983 (2) Ecology Method 9A

C. Reference Continuous Emission Mo nitoring Performance Specification (by reference only, not attached)

(1) EPA Performance Specification 1 (Op acity Monitoring), [40 CFR 60, Appendix B, July 1, 1992]

(2) EPA Performance Specification 2 (S O2 and NOx Monitoring) [40 CFR 60, Appendix B, July 1, 1992]

(3) EPA Performance Specification 3 (O2 M onitoring) [40 CFR 60, Appendix B, July 1, 1992]

(4) EPA Performance Specification 4 (C O Monitoring) [40 CFR 60, Appendix B, July 1, 1992]

D. EPA Quality Assurance Procedures (attached)

Continuous Emission Monitoring for Opacity: "Recommended Quality Assurance Procedures for Opacity Cont inuous Monitoring Systems" (EPA 340/1-86-010)

E. Elements of Opacity COMS Summary Report for 40 CFR 60.7(d) (Condition II.C.5)

Pollutant: Opacity; Reporting period dates; Co mpany name and address; Process unit(s) description; Emission limits; Monitor manufacturer and mode l no.; Date of latest CMS Certification or Audit; Total source operating time in reporting period 1

### Permit No. 11339 Expiration Date: May 15, 2009 Page 81 of 81

Ash Grove Operating Permit, May 15, 2004 

### Include with the Emission Data Summary 1 

### :

1. The duration of excess emissions in re porting period that was due to: (a) Startup/Shutdown, (b) Control equipment pr oblems, (c) Process problems, (d) Other known causes, and (e) Unknown causes;

2. The total duration of excess emission; and

3. [Total duration of excess emissions]/[Tot al source operating time]*(100) = % 2



### Include with the CMS Performance Summary 1 

### :

1. The CMS downtime in reporting period due to : (a) Monitor equipment Malfunctions, (b) Non-Monitor equipment Malfunctions, (c) Qu ality assurance calibration, (d) Other known causes, and (e) Unknown causes;

2. The Total CMS Downtime; and

3. Total CMS Downtime/[Total operating time]*(100) = % 2



### Describe any changes since last quart er in CMS, process or controls. Certify that the information attained in the report is true, accurate, and complete. Include Name and Signature (Title) of the responsible official and Date

1. For Opacity, record all times in minutes. For gases, record all times in hours.

2. For the reporting period: If the total duration of excess emissions is ≥ 1% or the total

CMS downtime is ≥ 5% of the total operating time, both the summary report form and the excess emission report described in 60.7(c) shall be submitted.