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, Article 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 AND PERFORMANCE STANDARDS 

The following tables list the citation for the “applicable requirement” in the second column. The 

third column (Date) contains the adoption or effective date of the requirement. In some cases, 

the effective dates of the Federally 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 either the state has not submitted 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 requirement. 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 & Recordkeeping Method) identifies the methods 

described in Section II of the permit. Following these methods is an enforceable requirement of 

this permit. The sixth (Emission Standard Period) column identifies the averaging time for the 

reference test method. The last column (Reference Test Method) identifies 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 omission between the information contained in the fourth and sixth 

columns and the actual statute or regulation cited 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. 
Expir

Ash Grove Operating Permit, May 15, 2004 

A. FACILITY-WIDE APPLICABLE REQUIREMENTS 

The requirements in this section apply facility-wide to all the emission units regulated by this permit, except as otherwise s

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

Opacity Standards I.A.1 Puget Sound Clean Air Agency 

Reg I: 9.03(a)-(c) 

09/08/94 Ash Grove shall not emit more than 20% 

opacity for a period or periods aggregating more than 3 minutes in any 1-hour period 

II.A.1 General Opacity Monitoring 

More min. ihr 

I.A.2 WAC 173-400-040(1) 09/20/93 Ash Grove shall not emit more than 20% 

opacity for more than 3 minutes in any 1-hour period. 

II.A.1 General Opacity Monitoring 

More min. ihr 

Particulate Standards I.A.3 Puget Sound Clean Air Agency 

Reg. I: 9.09(a) This requirement shall be superseded by the 4/9/98 version of Reg. I: 9.09 upon its adoption into the SIP

02/10/94 Ash Grove shall not emit particulate matter 

in excess of 0.05 gr/dscf from equipment used in a manufacturing process uncorrected for excess air 

II.A.1 General Opacity Monitoring 

(3) 1-runs 

I.A.4 WAC 173-400-060 

This requirement shall be superseded by the 9/15/01 version of WAC 173-400-060 upon its adoption into the SIP WAC 173-400-060 (State Only) This requirement will become federally enforceable upon adoption into the SIP and will replace the 3/22/91 version of WAC 173-400-060.

3/22/91 9/15/01

Ash Grove shall not emit particulate matter in excess of 0.10 gr/dscf from general process units, uncorrected for excess air 

II.A.1 General Opacity Monitoring 

(3) 1-runs 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

I.A.5 Puget Sound Clean Air Agency 

Order of Approval No. 7381, Condition 4 

6/6/01 PM-10 emissions from each baghouse 

except the main stack baghouse, shall not exceed 0.005 grains /dscf over a 24 hour 

period. 

II.A.1 General Opacity Monitoring 

24 ho

SO2 Standards I.A.6 Puget Sound Clean Air Agency 

Reg I: 9.07 WAC 173-400-040(6) first paragraph only. 

04/14/9409/20/93

Ash Grove shall not emit SO2 in excess of 

1,000 ppmv (dry) corrected to 7% O2 for 

fuel burning equipment 

No monitoring required 

(3) 1-runs 

Nuisance Standards I.A.7 Puget Sound Clean Air Agency 

Reg I: 9.11(a) WAC 173-400-040(5) RCW 70.94.040 (State Only) WAC 173-400-040(2) (State Only) 

06/9/83 09/20/931996 9/15/01 

Ash Grove shall not emit air contaminants in sufficient quantities and of such characteristics and duration as is, or is likely to be, injurious to human health, plant or animal life, or property, or which unreasonably interferes with enjoyment of life and property Ash Grove shall not deposit particulate matter beyond property boundary in sufficient quantity to interfere unreasonably with the use and enjoyment of the property 

II.A.2 Complaint Response II.A.3 Rooftop Inspections II.A.4 O&M Plan Inspections 

NA 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

I.A.8 WAC 173-400-040(4) (State Only) 9/15/01 Ash Grove shall use recognized good 

practice and procedures to reduce odors which may unreasonably interfere with any other property owners’ use and enjoyment of their property 

II.A.2 Complaint Response II.A.3 Rooftop Inspections 

NA 

Fugitive Dust Standards I.A.9 Puget Sound Clean Air Agency 

Reg. I: 9.15(a) This requirement shall be superseded by the 3/11/99 version of Reg. I: 9.15(a) upon its adoption into the SIP

8/10/89 Ash Grove shall employ BACT for fugitive 

dust 

II.A.4 O&M Plan Inspections 

NA 

I.A.10 Puget Sound Clean Air Agency 

Reg. I: 9.15(c) This requirement shall be superseded by the 3/11/99 version of Reg. I: 9.15(a) upon its adoption into the SIP

8/10/89 Ash Grove shall not cause or allow the 

emission of fugitive dust from refuse burning equipment, fuel burning equipment, equipment used in a manufacturing process or control equipment. 

II.A.3 Rooftop Inspections II.A.4 O&M Plan Inspections 

NA 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

I.A.11 WAC 173-400-040(3)(a) 

WAC 173-400-040(8)(a) These requirements shall be superseded by the 9/15/02 versions of SIP WAC 173-400-040(3)&(8) upon adoption into the SIP WAC 173-400-040(3)(a) (State Only)WAC 173-400-040(8)(a) (State Only)These requirements will become federally enforceable upon adoption into the SIP and will replace the 9/20/93 versions of WAC 173-400-040(3)&(8)

9/20/93 9/20/93 9/15/01 9/15/01 

Ash Grove shall take reasonable precautions to prevent the release of fugitive emissions and to minimize emissions of fugitive dust. 

II.A.3 Rooftop Inspections II.A.4 O&M Plan Inspections 

NA 

I.A.12 Puget Sound Clean Air Agency 

Reg. I: 9.15(b) This requirement shall be superseded by the 3/11/99 version of Reg. I: 9.15(a) upon its adoption into the SIP.

8/10/89 Ash Grove shall employ measures to 

prevent track-out and spillage of particulate matter on paved public roadways 

II.A.5 Vehicle Track Out 

NA 

I.A.13 Puget Sound Clean Air Agency 

Reg. I: 9.15(a) (State Only) This requirement will become federally enforceable upon adoption into the SIP and will replace the 8/10/98 version of Reg. 

I: 9.15 into the SIP.

3/11/99 Ash Grove shall not cause or allow visible 

emissions of fugitive dust unless reasonable precautions are employed to minimize the 

emissions. 

II.A.3 Rooftop Inspections II.A.4 O&M Plan Inspections 

NA 

Operation and Maintenance Standards 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

I.A.14 Puget Sound Clean Air Agency 

Reg. I: 9:20 RCW 70.94.152(7) (State Only) 

6/09/88 1996 

Ash Grove shall maintain equipment in good working order Equipment described in plans, specifications or other information submitted in support of a notice of construction application shall be maintained and operate in good working order 

II.A.4 O&M Plan Inspections 

NA 

I.A.15 Puget Sound Clean Air Agency 

Reg. I: 7.09(b) 

9/12/96 Ash Grove shall develop and implement an 

O&M Plan to assure continuous compliance with Puget Sound Clean Air Agency Regulations I, II and III NOTE: See EU 1.31 for 40 CFR Part 63 O&M plan requirements for the kiln 

II.A.4 O&M Plan Inspections 

NA 

Emissions from common stack I.A.16 WAC 173-400-040 09/20/93 Emissions from a common stack must meet 

the most restrictive standard of any of the connected emissions units 

No monitoring required 

NA 

HCl Standards I.A.17 Puget Sound Clean Air Agency 

Reg. I: 9.10(a) (State Only)

06/09/88 Ash Grove shall not emit HCl in excess of 

100 ppm (dry) corrected to 7% O2 for 

combustion sources 

No monitoring required 

(3) 1-runs 

Visible Emissions per WAC 173-434 (see EU-1) 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

I.A.18 WAC 173-434-130(4)(c) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP.

10/18/90 Ash Grove shall not exceed visible 

emissions from emission units (other than the kiln) greater than an average of 0 percent opacity for more than six consecutive minutes in any sixty minute period. 

II.A.1 General Opacity Monitoring 

6-minperiod 

NA = Not Applicable 
Expir

Ash Grove Operating Permit, May 15, 2004 

B. EMISSION UNIT SPECIFIC APPLICABLE REQUIREMENTS 

The requirements in Section I.B. apply only to the specific emission units cited; however, the requirements in Se

those units, except as otherwise provided in this section.

1. Emission Unit #1 (EU-1): Rotary Cement Kiln, Main Stack and Coal Mills 

This emission unit consists of a nominal 2400 ton/day capacity rotary Portland cement kiln, primarily fired with 

controlled by a nominal 177,000 acfm baghouse. The main stack emissions are monitored for opacity, carbon mand sulfur dioxide emissions by a continuous emission monitoring system. Fuels include bituminous coal, whole 

internally generated waste lubricating oils and greases, and natural gas. Dust entrained in the flue gases is collecBaghouse. Although most of the kiln emissions exit from the kiln/raw mill through the main stack, a small portion of the ho

routed directly from the kiln exhaust to the coal mills for use in thermally drying coal prior to grinding. Each co

nominal 10,400 acfm baghouse. This emission unit includes the coal mills because a small portion of kiln exhau

atmosphere through the coal mill baghouse stacks. Emission Unit (EU-1) 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

Opacity Standards EU 1. 1 Puget Sound Clean Air 

Agency Reg. I: 9.09(b)(1) This requirement shall be superseded by the 4/9/98 version of Reg. I: 9.04(c)(2) upon its adoption into the SIP.

02/10/94 Ash Grove shall not cause or 

allow the emission of any air contaminant (as determined by the COMS) from the kiln stack that exceeds 20% opacity for a period aggregating more than 3 minutes in any 1 hour. 

II.B.1 Continuous Opacity Monitoring System 

More than 3 min. in any hr 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 2 Puget Sound Clean Air 

Agency Reg. I: 9.04(c)(2) (State Only) This requirement will become federally enforceable upon adoption into the SIP. 

04/09/98 Ash Grove shall not cause or 

allow the emission of any air contaminant (as determined by the COMS) from the kiln stack during any hour that contains any consecutive 6-minute period averaging greater than 20% opacity.

II.B.1 Continuous Opacity Monitoring System 

6-minute period 

EU 1. 3 Puget Sound Clean Air 

Agency Reg. I: 9.09(b)(2) This requirement shall be superseded by the 4/9/98 version of Reg. I: 9.04(c)(1) upon its adoption into the SIP.

02/10/94 Ash Grove shall not cause or 

allow the emissions of any air contaminant (as determined by the COMS) from the kiln stack that averages greater than 5% opacity for a 1-hour average. 

II.B.1 Continuous Opacity Monitoring System 

1-hour average 

EU 1. 4 Puget Sound Clean Air 

Agency Reg. I: 9.04(c)(1) (State Only) This requirement will become federally enforceable upon adoption into the SIP

04/09/98 Ash Grove shall not cause or 

allow the emission of any air contaminant (as determined by the COMS) from the kiln stack during any hour that averages greater than 5% opacity for a one hour average. 

II.B.1 Continuous Opacity Monitoring System 

1-hour average 

Puget Sound Clean Air Agency Orders of Approval NC 5687 – Waste Derived Fuels EU 1. 5 Puget Sound Clean Air 

Agency Order of Approval No. 5687 Condition 4 

1/11/95 Ash Grove shall burn in the kiln 

only waste derived fuels generated on site and not to exceed 6,000 pounds of greases and 4,800 pounds of oils per year. 

II.B.5 Waste Derived Fuel Consumption 

Annual 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 6 Puget Sound Clean Air 

Agency Order of Approval No. 5687 Condition 5 

1/11/95 Ash Grove shall limit waste 

derived fuels to fuels that are nonhazardous as defined in WAC 173-303-515, Special Requirements for Used Oil Burning for Energy Recovery, or by WAC 173-303-090, Dangerous Waste Characteristics as appropriate. 

II.B.5 Waste Derived Fuel Consumption 

NA 

Puget Sound Clean Air Agency Orders of Approval NOC 5755 – Tire Derived Fuel EU 1. 7 Puget Sound Clean Air 

Agency Order of Approval No. 5755, Condition 4 

3/30/95 Tire derived fuel substitutes shall 

be nonhazardous as defined by WAC 173-303-515 or WAC 173-303-090, as appropriate. 

No monitoring required. 

NA 

EU 1. 8 Puget Sound Clean Air 

Agency Order of Approval No. 5755, Condition 5 

3/30/95 Daily weight of whole tires 

burned in the kiln shall not exceed 30 % of the total weight of fuels consumed in the kiln. 

II.B.6 Tire Derived Fuel Consumption Daily 

Puget Sound Clean Air Agency Order of Approval NOC 7381 and PSD Permit 90-03 -- Kiln BACT limits. EU 1. 9 Puget Sound Clean Air 

Agency Order of Approval No. 7381 Condition 5(a). PSD Permit 90-03, Amendment 3, Condition 3 

6/06/01 

10/08/01 

CO emissions shall not exceed 1045 ppm at 10% O2 for an 8-

hour average. CO emissions shall not exceed 538 lbs/hour for an 8-hour average. CO shall not exceed 2353 tons per year including startup, shut down and malfunction periods. 

II.B.2 SO2, CO and NOx CEMS II.B.3 SO2, CO and NOx Mass Emission Rate Monitoring 

8 hours and annual 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 10 Puget Sound Clean Air 

Agency Order of Approval No. 7381 Condition 5(b). PSD Permit 90-03, Amendment 3, Condition 1 

6/06/01 10/08/01 

NOx emissions shall not exceed 

650 ppm at 10% O2 as a 24-hour 

rolling average. NOx emissions shall not exceed 

1846 tons as a 12-month running total including startup, shut down and malfunction periods. If NOx emissions exceed 1400 tons as a 12-month running total, Ash Grove shall notify the Puget Sound Clean Air Agency (Attn. Permit Certification) describing actions that will be implemented to assure compliance with the annual NOx limit. 

II.B.2 SO2, CO and NOx CEMS II.B.3 SO2, CO and NOx Mass Emission Rate Monitoring 

24-hours and annual 

EU 1. 11 Puget Sound Clean Air 

Agency Order of Approval No. 7381 Condition 5(c). PSD Permit 90-03, Amendment 3, Condition 2 

6/06/01 

10/08/01 

Except during startup and shutdown of the kiln and scheduled maintenance SO2

emissions from the main stack shall not exceed 180 ppm at 10% O2 for a one-hr average. 

During startup following the introduction of feed to the kiln, SO2 emissions from the main 

stack shall not exceed 200 ppm at 10% O2 for a one-hr average. 

SO2 emissions shall not exceed 176 tons per year including startup, shut down and malfunction periods. 

II.B.2 SO2, CO and NOx CEMS II.B.3 SO2, CO and NOx Mass Emission Rate Monitoring 

One hour & annual 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 12 Puget Sound Clean Air 

Agency Order of Approval No. 7381 Condition 6(a). PSD Permit 90-03, Amendment 3, Condition 2(c) 

06/06/01 10/08/01 

During kiln startup-preheat periods prior to feed introduction, shutdown and scheduled maintenance on the main baghouse the SO2 emission limit 

for the main baghouse shall consist of compliance with the following work practices and fuel restrictions: (i) Only natural gas shall be used as fuel. (ii) Sulfur rings shall be removed from the Kiln prior to startup if sulfur rings formation had required the kiln to be shut down.(iii) Ash Grove shall follow the kiln startup and shutdown procedures in Appendix A to Order of Approval No. 7381. 

II.B.8 Kiln Work Practice Monitoring 

NA 

EU 1. 13 Puget Sound Clean Air 

Agency Order of Approval No. 7381 Condition 5(d). 

06/06/01 Except during startup and 

shutdown of the kiln, scheduled maintenance and emissions considered unavoidable under WAC 173-400-107, PM emissions shall not exceed 10.6 pounds per hour. 

II.B.9 PM Monitoring Main Baghouse 

(3) 1-hour runs 

EU 1. 14 Puget Sound Clean Air 

Agency Order of Approval No. 7381 Condition 5(d). 

06/06/01 PM emissions shall not exceed 46 

tons per year including startup, shut down and malfunction periods. 

II.B.9 PM Monitoring Main Baghouse II.B.10 Production Rate Monitoring 

annual 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

40 CFR Part 60 Subpart F Standards of Performance for Portland Cement Plants EU 1. 15 40 CFR §60.62(a)(1) 

40 CFR §60.8(c) 

10/6/75 2/12/99 

Kiln exhaust shall not exceed 0.30 lb of particulate per ton of feed (dry basis), except during SSM periods. 

II.B.9 PM Monitoring Main Baghouse II.B.10 Production Rate Monitoring 

(3) 1-hour runs 

EU 1. 16 40 CFR §60.62(a)(2) 

40 CFR 60.11(c) 

10/6/75 

10/17/00 

Kiln exhaust shall not exceed 20 percent opacity, except during startup, shutdown and malfunction periods. 

II.B.1 Opacity COMS 

6 min. average 

EU 1. 17 40 CFR §60.63(a) 12/14/88 Ash Grove shall record the daily 

production rates and kiln feed rates. 

II.B.10 Production Rate Monitoring 

NA 

40 CFR Part 60 Subpart Y Standards of Performance for Coal Preparation Facilities EU 1. 18 40 CFR 60.252(a)(1) 

40 CFR §60.8(c) 

10/17/00 

2/12/99 

Coal mill exhaust shall not exceed 0.031 gr/dscf, except during SSM periods. 

II.A.1 General Opacity Monitoring II.B.12 Coal Prep Facility Performance Test 

3 one-hour runs 

EU 1. 19 40 CFR 60.252(a)(2) 

40 CFR 60.11(c) 

10/17/00 10/17/00 

Coal mill exhaust shall not exceed 20 percent opacity except during SSM periods 

II.A.1 General Opacity Monitoring II.B.12 Coal Prep Facility Performance Test 

More than 6 min. in any hr. 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 20 40 CFR 60.253(a)(1) and 

(b) 

10/17/00 Ash Grove shall calibrate, 

maintain and continuously operate a temperature monitor at the inlet to each coal mill baghouse. 

II.B.13 Temperature CMS 

N/A 

40 CFR Part 63, Subparts A and LLL EU 1. 21 40 CFR §63.6(e)(1) 5/30/03 At all times, including periods of 

startup, shutdown, and malfunction, Ash Grove shall operate and maintain the kiln and raw mill, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. During an SSM period this general duty to minimize emissions requires that Ash Grove reduce emissions from the kiln and raw mill to the greatest extent which is consistent with safety and good air pollution control practices. The general duty to minimize emissions during an SSM event does not require Ash Grove to achieve emission levels required by Conditions EU 1.26 through 1.29 at other times if this is not consistent with safety and good air pollution control practices, nor does it require Ash Grove to make any further efforts to reduce emissions if levels required by Conditions EU 1.26 through 1.29 have been achieved. 

II.B.14 Kiln Combustion System Inspections 

N/A 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 22 40 CFR §63.6(e)(3)(i) 5/30/03 Ash Grove shall develop and 

implement a written startup, shutdown, and malfunction (SSM) plan that describes, in detail, procedures for operating and maintaining the kiln and raw mill during SSM periods, and a program of corrective action for malfunctioning process and air pollution control equipment used to comply with Subpart LLL standards. The SSM plan shall include the elements set forth in 40 CFR 63.6(e)(3). 

II.D.8 NESHAP Subpart LLL Recordkeeping II.C.3 Immediate SSM Plan Deviation Report II.C.7 Semi-annual Subpart LLL SSM Plan Report 

N/A 

EU 1. 23 40 CFR 63.6(e)(3)(ii) 

40 CFR 63.6(e)(1)(ii) 

5/30/03 5/30/03 

During SSM periods Ash Grove shall operate and maintain the kiln and raw mill (including associated air pollution control equipment) in accordance with the SSM plan. Malfunctions shall be corrected as soon as possible after their occurrence in accordance with the SSM plan 

II.D.8 NESHAP Subpart LLL Recordkeeping II.C.3 Immediate SSM Plan Deviation Report II.C.7 Semi-annual Subpart LLL SSM Plan Report 

N/A 

EU 1. 24 40 CFR §63.6(e)(3)(vii) 5/30/03 Ash Grove shall change the SSM 

plan if required by the Puget Sound Clean Air Agency if it is determined to be unacceptable under §63.6(e)(2). 

No monitoring required 

N/A 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 25 40 CFR §63.6(e)(3)(viii) 5/30/03 Ash Grove shall update the SSM 

plan within 45 days of an SSM event that the plan failed to address or inadequately addressed. If Ash Grove makes SSM plan revisions which alter the scope of activities which are deemed a SSM or modifies the applicability of any limit or requirement under Subpart(s) A and LLL, the revisions shall not take effect until Ash Grove has provided written notification describing the revision to the Puget Sound Clean Air Agency. 

No monitoring required 

N/A 

EU 1. 26 40 CFR §63.1343(d) 

40 CFR §63.6(f) 

6/14/99 5/30/03 

Ash Grove shall not cause to be discharged into the atmosphere from the kiln exhaust Dioxin/furan (D/F) exceeding 0.20 ng/dscm (8.7x10-11

gr/dscf)(TEQ) @ 7% O2 when the 

raw mill is OFF, and 0.40 ng/dscm (8.7x10-11 gr/dscf)(TEQ) 

@ 7% O2 when the raw mill is 

ON. Standards apply at all times except during SSM periods. 

II.B.13 Temperature CMS 

(3) 3-hour runs 

EU 1. 27 40 CFR §63.1343(d) 

40 CFR §63.6(f) 

6/14/99 5/30/03 

Ash Grove shall not cause to be discharged into the atmosphere from either coal mill stack Dioxin/furan (D/F) exceeding 0.40 ng/dscm (8.7x10-11

gr/dscf)(TEQ) @ 7% O2. 

Standards apply at all times except during SSM periods. 

II.B.13 Temperature CMS 

(3) 3-hour runs 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 28 40 CFR §63.1344(a) 

40 CFR 63.6(f) 

12/6/02 5/30/03 

Ash Grove shall operate the kiln such that the temperature of the gas inlet to the kiln/raw mill baghouse does not exceed the applicable temperature limits established during a performance test for periods when the raw mill does and does not operate. (§63.1349(b)). Standards apply at all times except during SSM periods. 

II.B.13 Temperature CMS 

3-Hour Rolling Average 

EU 1. 29 40 CFR §63.1344(a), as 

modified by 10/18/02 letter from Puget Sound Clean Air Agency to Robert Vantuyl establishing alternative monitoring methods for the coal mill 40 CFR 63.6(f) 

12/6/02 5/30/03 

Ash Grove shall operate the kiln such that the inlet temperature to each coal mill baghouse does not exceed 200 degrees F. Standards apply at all times except during SSM periods. 

II.B.13 Temperature CMS 

3-Hour Rolling Average 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 30 40 CFR 63.1349(b)(3) and 

(d); 10/18/02 letter from Puget Sound Clean Air Agency to Robert Vantuyl establishing alternative monitoring methods for the coal mill 

12/6/02 Except as waived or modified 

pursuant to 40 CFR 63.7 or 63.8, every 30 months Ash Grove shall conduct a performance test on the kiln and the two coal mill baghouse exhaust vents for dioxin/furans, using test methods described in 40 CFR 63.1349(b)(3). In any performance test conducted on the coal mills, Ash Grove may measure dioxin/furan emissions from one of the two coal mills, but the flow rate shall be measured from both coal mills. The first such test shall occur no later than 30 months after the initial performance test performed on October 22-24, 2002. 

II.C.8 Subpart LLL Performance Test Reporting II.D.8 NESHAP Subpart LLL Recordkeeping 

(3) 3-hour runs 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 31 40 CFR 63.1349(e)(3)(i) 12/6/02 Provide Puget Sound Clean Air 

Agency written notice at least 60 days prior to undertaking any operational change that may adversely affect compliance with the D/F emission standards in Conditions EU 1.26 and 1.27, or as soon as practicable where 60 days advance notice is not feasible. Notice shall include a description of the planned change, the emissions standards that may be affected by the change, and a schedule for completion of the performance test required by Condition EU 1.32, including when the planned operational change would begin. 

N/A N/A 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 32 40 CFR 63.1349(b)(3) and 

(e) 

12/6/02 Conduct a dioxin/furan 

performance test whenever Ash Grove plans to undertake a change in operations that may adversely affect compliance with the D/F emission standards in Conditions EU 1.26 or 1.27. In preparation for and while conducting the performance test, the kiln and raw mill may operate under the planned operational change conditions for a period not to exceed 360 hours, provided that Ash Grove notifies Puget Sound Clean Air Agency as described in Condition EU 1.31, that the performance test results are documented in a test report containing the information listed in 40 CFR 63.1349(a), and that a test plan is made available for Puget Sound Clean Air Agency review prior to testing, if requested. The performance test must be completed within 360 hours after the planned operational change begins. Ash Grove shall submit to Puget Sound Clean Air Agency temperature and other monitoring data recorded during any period of pretest operations. 

II.C.8 Subpart LLL Performance Test Reporting II.D.8 NESHAP Subpart LLL Recordkeeping 

(3) 3-hour runs 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 33 40 CFR 63.1349(e)(1) 12/6/02 Data collected during a 

performance test under Condition EU 1.32 shall be used to establish new temperature limits for the kiln, supplanting the limits established under 40 CFR 63.1349(b). 

N/A N/A 

EU 1. 34 40 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) 

4/5/02 

5/30/03 6/14/99 5/30/03 

4/5/02 

Ash Grove shall conduct a performance evaluation of the temperature CMS required by Conditions EU 1.29 and 1.30 whenever requested by EPA under Clean Air Act Section 114. Any performance evaluation shall be conducted in accordance with the requirements of 40 CFR 63.8(e). Notification of the performance evaluation shall be provided as required in 40 CFR 63.1353(b)(4). Results of the performance evaluation shall be reported as provided in 40 CFR 63.1354(b)(6). 

N/A N/A 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1. 35 40 CFR §63.1350(a)-(b) 12/6/02 Ash Grove shall prepare for the 

kiln and raw mill an O&M plan including the following provisions: (a) Procedures for proper operation and maintenance of the kiln and associated air pollution control equipment to meet the dioxin/furan emission limits and parametric limits in conditions EU 1.26, 1.27 and 1.28; (b) Procedures to be used during an inspection of the components of the kiln and raw mill at least once per year. Failure to comply with those procedures shall be a violation of Subpart LLL. Ash Grove submitted the O&M plan for this requirement to the Puget Sound Clean Air Agency for approval on May 24, 2002. Ash Grove shall submit updates of the O & M Plan to the Agency upon adoption. Ash Grove may elect to integrate the Subpart LLL O&M Plan into the general O&M plan required by Condition I.A.15. If so the general O&M plan shall specifically identify those provisions required by this condition. 

II.B.14 Kiln Combustion System Inspection II.D.8 NESHAP Subpart LLL Recordkeeping 

NA 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

WAC 173-434 Solid Waste Incineration Facilities These requirements apply as a result of waste fuels burned (see Conditions EU 1.5 through 1.8) and the SIP approved version of WAC WAC 173-434 was updated (effective 1/22/04) and will exempt certain waste fuels from the applicability of this regulation. Once the 

173-434 is incorporated into the SIP, Conditions EU 1.36 through 1.48 of this permit (along with the associated monitoring, recordkeeprovisions of this regulation) will be superceded and inapplicable for this permit, based on the presently approved operations at Ash G

EU 1.36 WAC 173-434-130(3) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall meet the SO2

emission limits established by BACT in Order of Approval No. 7381 (see EU 1.11) since more than 50% of the heat input to the kiln is fossil fuel. 

II.B.2 SO2, CO and NOx CEMS 

N/A 

EU 1.37 WAC 173-434-130(4)(a) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall not exceed 

visible emissions from the kiln greater than an average of 5 percent opacity for more than six consecutive minutes in any sixty minute period. 

II.A.1 General Opacity Monitoring 

6-minute period 

EU 1.38 WAC 173-434-130(4)(b) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Visible emissions from the kiln, 

as measured by a transmissometer, shall not exceed an average of 10 percent opacity for more than six consecutive minutes in any sixty minute period during which Ash Grove combusts solid waste. 

II.B.1 Continuous Opacity Monitoring System 

6-minute period 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1.39 WAC 173-434-130(5) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall take reasonable 

precautions to prevent fugitive emissions from solid waste handling operations, which includes paving of all normally traveled roadways within the plant boundary and enclosing or hooding material transfer points. 

no monitoring required 

N/A 

EU 1.40 WAC 173-434-160(1) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 When combusting solid waste, 

Ash Grove shall operate the kiln such that the final combustion zone temperature shall not be below 1800oF for a 15 minute average nor below 1600oF for any reading. 

II.B.15 Operational Monitoring for Solid Waste Incinerator Facilities 

15-minute average and instantaneou

EU 1.41 WAC 173-434-160(2) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall maintain a 

combustion gas residence time of 1.0 seconds in the kiln when combusting solid waste. 

II.B.15 Operational Monitoring for Solid Waste Incinerator Facilities 

N/A 

EU 1.42 WAC 173-434-160(3) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall operate the kiln 

when combusting solid waste such that combustion gases leaving the kiln have at least 3% oxygen measured on a wet basis. 

II.B.15 Operational Monitoring for Solid Waste Incinerator Facilities 

24-hour average 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1.43 WAC 173-434-160(4) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall minimize odor 

and fugitive emissions from the tipping area. 

II.A.3 Rooftop Inspections II.A.4 O&M Plan Inspections 

EU 1.44 WAC 173-434-160(5) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall control air 

distribution where pressurized air is introduced into the kiln and the air flow shall be monitored and recorded. 

II.B.15 Operational Monitoring for Solid Waste Incinerator Facilities 

EU 1.45 WAC 173-434-160(6) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall operate the kiln 

when combusting solid waste such that the inlet temperature to the baghouse shall not exceed 350oF. 

II.B.15 Operational Monitoring for Solid Waste Incinerator Facilities 

24-hour average 

EU 1.46 WAC 173-434-160(7) 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall operate the kiln 

when combusting solid waste consistent with good air pollution control practice. 

II.A.4 O&M Plan Inspections 

N/A 
Expir

Ash Grove Operating Permit, May 15, 2004 

Reqmt. 

No. 

Enforceable 

Requirement 

Adoption or 

Effective Date

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Emission 

Standard 

Period 

EU 1.47 WAC 173-434-090 

This requirement shall be superseded and become inapplicable by the 1/22/04 version of WAC 173-434 once it is adopted into the SIP

10/18/90 Ash Grove shall develop a plan 

for operation and maintenance of the kiln to maintain compliance with the requirements of WAC 173-434. Ash Grove shall update the plan as warranted, and shall submit the plan for Puget Sound Clean Air Agency approval every 24 months, commencing August 1, 2004. Ash Grove may elect to integrate the WAC 173-434 O&M Plan into the general O&M Plan required by Condition I.A.15. If so the general O&M Plan shall specifically identify those provisions required by this condition. 

II.A.4 O&M Plan Inspections 

N/A 

N/A = Not Applicable. A specific reference test method and/or emission standard period is specified in the requirement. A test method is neithe
Expir

Ash Grove Operating Permit, May 15, 2004 

2. Emission Unit Group #2 (EU-2): Coal Processing, Storage and Transfer Facilities 

This group consists of four coal storage, processing and transfer and loading systems that are subject to NSPS SuPerformance For Coal Preparation Plants. The affected facilities are Equipment Numbers 41B.FN1 (Coal Feeder 

Feeder #2), 41A.BF3 (Raw Coal Silo), and 41C.BF1 (PF Bin). Subpart Y also regulates the #1 and #2 coal mills

requirements for those units appear in Section I.B.1 above. APPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

P

EU 2. 1 40 CFR §60.11(d) 10/17/00 At all times, including SSM periods Ash 

Grove shall to the extent practicable maintain and operate Subpart Y affected facilities including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. 

I.A.4 O&M Plan Inspections 

N/A 

EU 2. 2 40 CFR 60.252(c) 

40 CFR 60.11(c) 

10/17/0010/17/00 

Exhaust gases shall not exceed 20 percent opacity except during SSM periods. 

II.A.1 General Opacity Monitoring II.B.12 Coal Prep Facility Performance Test 

6 miavera
Expir

Ash Grove Operating Permit, May 15, 2004 

3. Emission Unit Group #3 (EU-3): Portland Cement NSPS Affected Facilities 

This group consists of certain equipment subject to 40 CFR Part 60, Subpart F, the New Source Performance StaCement Plants. The affected facilities included in this group are Transfer Towers 2, 3, 5, 6, 7, 8 and 10A, Equipm

(Stacker), 311.RE1 (Reclaimer), 315.BN1 (Limestone Storage Bin), P11.TD (Truck Dump), 41B.SX1 (Raw Coa(Feeder), 312.7G1(Clay Storage Shed), 315.BN2 (Clay Storage Bin), 315.BN3 (Silica Storage Bin), 315.BN4 (S

(Clay Apron Feeder), 411.SX1, 411.SX 2(Raw Meal Blending, 411.SX3, 411.SX4 (Raw Meal Storage Silos), 61Dome), 419.BC6 (Clinker Shed Tripper), 41G (Clinker Loadout Railcar) and 611.BK1 (Cement Loadout Bulk B

regulates the kiln and raw mill, but the Subpart F requirements for those units are set forth in Conditions EU 1.15

APPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

P

EU 3. 1 40 CFR §60.11(d) 10/17/00 At all times, including SSM periods Ash 

Grove shall to the extent practicable maintain and operate Subpart F affected facilities including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. 

I.A.4 O&M Plan Inspections 

N/A 

EU 3. 2 40 CFR 60.62(c) 

40 CFR 60.11(c) 

10/17/0010/17/00 

Exhaust gases shall not equal or exceed 10 percent opacity except during SSM periods. 

II.A.1 General Opacity Monitoring 

6 miavera
Expir

Ash Grove Operating Permit, May 15, 2004 

4. Emission Unit #4 (EU-4): Finish Mills 

The two finish mills are each rated at 55 tons per hour, installed in 1968 and controlled by two nominal 77separator baghouses and two nominal 20,000 acfm mill sweep baghouses.. The clinker from the kiln that is passed through the G-Cooler becomes processed in the ball mills by grinding wiand 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 requAPPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

Puget Sound Clean Air Agency Orders of Approval NOC 5276 EU 4. 1 Puget Sound Clean Air Agency 

Order of Approval No. 5276 Condition 4. 

1/19/94 Ash Grove shall not allow particulate 

emissions from the (2) mill sweep baghouses to exceed 0.01 gr/dscf. 

II.B.4 Finish Mill Baghouse Monitoring. 

Averathree-runs 

EU 4. 2 Puget Sound Clean Air Agency 

Order of Approval No. 5276 Condition 6. 

1/19/94 Ash Grove shall not allow particulate 

emissions from the (2) mill sweep baghouses to exceed 10% opacity. 

II.B.4 Finish Mill Baghouse Monitoring. 

More min. ihr 
Expir

Ash Grove Operating Permit, May 15, 2004 

5. Emission Unit #5 (EU-5): Cement Dome & Steel Scale Tanks 

The Cement Storage Dome is a 45,000 ton finished product storage facility controlled by a 6000 acfm Alanco ba

installed in 1998. The four steel scale tanks are finished product loading facilities, used to load cement into truckwere installed prior to 1971, but in 1998 Ash Grove replaced one of two baghouses that control emissions from tacfm Alanco baghouse. NOC 7242 approves construction of the Cement Storage Dome and the two Alanco baghIn addition to the applicable requirements listed in this section, the Cement Storage Dome is subject to the planin Section I.A and to the NSPS Subpart F requirements listed in Section I.B.3 of the permit. The Steel Scal

affected facilities. APPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Stan

Pe

Puget Sound Clean Air Agency Orders of Approval NOC 7242 - Cement Storage Dome EU 5. 1 Puget Sound Clean Air Agency 

Order of Approval No. 7242, Condition 7 

1/06/98 Ash Grove shall not allow PM-10 emissions 

from the Alanco baghouses mounted on the cement storage dome and the steel scale tanks to exceed 0.005 grains/dscf over a twenty-four hour period. 

II.A1 General Opacity Monitoring II.B.7 Cement Storage Dome Monitoring 

Sourcfor a 2period 
Expir

Ash Grove Operating Permit, May 15, 2004 

6. Emission Unit #6 (EU-6): Bulk Bag Loading Station 

Bulk Bag Loading Station controlled with a 500 cfm baghouse. In addition to the applicable requirements listed iBag Loading Station is subject to the plant-wide requirements listed in Section I.A and to the NSPS Subpart F re

Section I.B.3 of the permit. APPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoptio

n or 

Effective 

Date 

Requirement Paraphrase 

(Information Only)

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

Puget Sound Clean Air Agency Orders of Approval NOC 8318 – Bulk Loading Station EU-6.1 Puget Sound Clean Air Agency 

Order of Approval No. 8318 Condition 3. 

1/8/01 Ash Grove shall allow no visible emissions 

or fallout from the 500 cfm baghouse controlling the bulk bag loading station. 

II.B.11 Bulk Bag Loading Station Monitoring 

NA 

EU 6. 2 Puget Sound Clean Air Agency 

Order of Approval No. 8318 Condition 5. 

1/8/01 If visible emissions, abnormal pressure drop 

or fallout are observed Ash Grove shall investigate the cause and either initiate repairs or shut down the equipment vented to the baghouse within 24 hours of the observation. 

II.B.11 Bulk Bag Loading Station Monitoring 

NA 
Expir

Ash Grove Operating Permit, May 15, 2004 

7. Emission Unit #7 (EU-7): Clinker Storage Shed 

In addition to the applicable requirements listed in this section, the Clinker Storage Shed is subject to the plant-w

Section I.A. APPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

Puget Sound Clean Air Agency Orders of Approval NOC 8600 – Clinker Storage Shed EU-7.1 Puget Sound Clean Air Agency 

Order of Approval No. 8600 Condition 3. 

2/8/02 Ash Grove shall not allow the PM-10 

emissions from the Pulse Jet R-08-88-81 baghouse to exceed 0.005 grains/dscf over a twenty-four hour period. 

II.A1 General Opacity Monitoring 

Sourcfor a 2period 
Expir

Ash Grove Operating Permit, May 15, 2004 

8. Emission Unit #8 (EU-8): Group II Cement Silos

In addition to the applicable requirements listed in this section, the Group II Silos are subject to the plant-wSection I.A. APPLICABLE REQUIREMENTS 

Reqmt 

No. 

Enforceable 

Requirement 

Adoption 

or 

Effective 

Date 

Requirement Paraphrase 

(Information Only) 

Monitoring, 

Maintenance & 

Recordkeeping 

Method 

(See Section II)

Em

Sta

Pe

Puget Sound Clean Air Agency Orders of Approval NOC 8643 – Group II Silos EU-8.1 Puget Sound Clean Air Agency 

Order of Approval No. 8643 Condition 3. 

2/8/02 Ash Grove shall not allow the PM-10 

emissions from each of the Pulse Jet Dust 

Collectors to exceed 0.005 grains/dscf over a twenty-four hour period. 

II.A.1 General Opacity Monitoring 

Sourcfor a 2period 
Permit No. 11339 

Expiration Date: May 15, 2009 

Page 36 of 81 

 

Ash Grove Operating Permit, May 15, 2004 

II. MONITORING, REPORTING AND RECORDKEEPING METHODS 

A. Facility Wide Monitoring Methods 

1. General Opacity Monitoring 

Ash Grove shall conduct monthly inspections of the 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 reference method opacity observation. If a reference 

method opacity observation reveals an exceedance of the applicable 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 reveals no visible emissions. Report deviations 

as provided in Condition II.C.2. Maintain records 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 Section 7.09(b). The Complaint Response Program 

shall be annually reviewed and updated along with the O&M Plan. This Program shall include: 

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

• Complaint forms available to the public; 

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

dust or other air contaminant impacts on neighboring property; 

• Format of communicating results of investigations and advising complainants of Ash 

Grove's corrective actions and preventive maintenance; 

• Ash Grove shall record air pollution complaints (including those forwarded to Ash Grove 

from this Agency) and findings of investigations as provided in Condition II.D.6. 

Investigations shall be initiated within 1 day of receipt of a complaint on Ash Grove’s 24 

hour complaint reporting phone line. Ash Grove’s Complaint Response Program shall 

describe the procedures for investigating complaints. Complaint investigation procedures 

shall include efforts to contact the complainant, to inspect the conditions described in the 

complaint, to determine whether Seattle plant sustained a malfunction or other operating 

or site conditions that might have generated abnormal levels of fugitive emissions, and to 

determine the wind speed, direction and/or other meteorological 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 the 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 receipt 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 monthly as provided in Condition 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-top1 inspection at least weekly. These inspections shall include 

inspection for odor-bearing contaminants and for fugitive 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 after discovered, begin corrective action, shut the 

operation down until the problem can be corrected, 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 WAC 173-401-615(2), 10/17/02] 

4. O & M Plan Inspections 

Ash Grove shall conduct a facility wide equipment inspection at least monthly. These 

inspections shall include: 

• checking for prohibited activities under Section III of the permit and activities that 

require additional approval under 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 requirement(s) are discovered by an 

inspection, Ash Grove shall as soon as possible, 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 deviation 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 point(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 condition as provided in Condition II.D.5 and report 

any deviation as provided in Condition II.C.2. 

[WAC 173-401-615(1) and WAC 173-401-615(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 monitoring data for at least 95% of the 

hours that the kiln operates during 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 maintenance, or any other reasonably preventable 

condition, and any necessary repairs to the monitoring 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 this monitoring system in accordance with the 

U.S. Environmental Protection Agency’s “Recommended Quality Assurance Procedures for 

Opacity Continuous Monitoring Systems” (EPA 340/1-86-010). 

iv. Data Recording. Monitoring data commencing on the clock hour and containing at least 45 

minutes of monitoring data shall be reduced to 1-hour averages. Monitoring data for opacity 

shall also be reduced to 6-minute averages. All monitoring data shall be included in these 

averages except for data collected during calibration 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 applicable) each occasion on which the COMS records a violation of 

applicable opacity limit(s), or on which the COMS sustains an unexcused failure to meet the data 

recovery requirements of this condition. Maintain 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 Emissions 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 monitoring data for at least 95% of the 

hours that the kiln is operated during each calendar month except for periods of monitoring 

system downtime, provided that Ash Grove demonstrates to the Control Officer that the 
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Expiration Date: May 15, 2009 

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Ash Grove Operating Permit, May 15, 2004 

downtime was not a result of inadequate design, operation, or maintenance, or any other 

reasonably preventable condition, and any necessary repairs to the monitoring system are 

conducted in a timely manner. 

iii. Quality Assurance. The CEMS for each pollutant shall 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 quality assurance procedures in 40 CFR Part 60, 

Appendix F in effect July 1, 1992. 

iv. Data Recording. Monitoring data commencing on the clock hour and containing 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 collected during calibration 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. 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 applicable emission limit(s), or on which the CEMS 

sustains an unexcused failure to meet the data recovery requirements 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); Puget 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 emissions from the cement kiln operation on a 12-month rolling 

total basis, using the CEMS data collected under 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 requirements of Section II.B.2 of this permit. Each 

day shall consist of three 8-hour CO compliance intervals, the first interval commencing at 12:00 

AM. When CEM data is not available or not required to be collected as identified by this permit, 

other information available to Ash Grove shall be used to compile 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 the pressure drop across the 20,000 cfm mill sweep 

baghouses. If a measurement reveals a pressure drop reading outside the range of 3 to 6 inches, 

take corrective action as soon as possible, but no later than 24 hours after the 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 action 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 tires injected into the kiln following the Fuel 

Monitoring Plan required by Order of Approval 5755, Condition 6. Report a deviation per 

Condition II.C.2 if the daily weight of whole tires injected during each calendar 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 tires 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 monitor 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 baghouse is used, record the 

pressure drop across the exhaust filter of that baghouse. If the pressure drop falls outside the 

acceptable range, take corrective action as specified in the facility's O & M plan. If, following 

corrective action, the pressure drop remains outside 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 fuels used for kiln startup-preheat periods 

prior to feed introduction; 

(ii) The date and time of sulfur ring removal from the kiln, if the ring formation required 

the kiln to be shut down; 
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Ash Grove Operating Permit, May 15, 2004 

(iii) The date, start and end times for kiln startup-feed introduction periods; and 

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

schedule in kiln cool down. 

Report as provided in Condition II.C.4 the information described above. Report as a deviation 

any unexcused departure from the startup and shutdown work practice requirements of Order of 

Approval 7381, Conditions 6(a) and (c) Maintain 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 Method 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. Revise 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 revised 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 production. 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 production rate and kiln feed rate. Records may be maintained in 

electronic format. Report per Condition II.C.2 any failure to maintain 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 operation, Ash Grove shall inspect the 

dust collector for visible emissions, fallout and pressure drop across the filters. Record the time 

and results of each inspection. If visible emissions, 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 observation as a deviation as provided in Condition 

II.C.2. Keep a log of inspections and of any corrective 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 

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Ash Grove Operating Permit, May 15, 2004 

12. Coal Prep Facility Performance Test 

Within 180 days of permit issuance, Ash Grove shall 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 Subpart Y affected facilities]. Source 

testing methods required by 40 CFR 60.254 shall be used. 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, calibrate, maintain and continuously operate 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 specifications in 40 CFR 63.1350(f) (4/5/02). Each CMS 

shall meet the O & M and data availability requirements of 40 CFR 63.8(c), (d) and (e). The 

calibration of the CMS shall be verified at least 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 Conditions 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 CFR 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 the 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) (6/14/99); 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 record 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 minute block in which the combustion zone 

temperature averages less than 1800° F. 

• Particulate control device temperature (kiln baghouse inlet). The average temperature 

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 temperature exceeds 

350° F. 
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Expiration Date: May 15, 2009 

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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 for each 15 minute block interval. 

The continuous monitoring systems described in this condition shall meet the data recovery and 

data recording requirements set forth in Condition II.B.2, except that the 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 sustains an unexcused failure to meet the data 

recovery and data recording requirements of this condition. This condition shall be inapplicable 

once the updated regulation (WAC 173-434, effective 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 with 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 once every six months, or more frequently where 

specified in the permit. All instances of deviations from permit requirements must be clearly 

identified in such reports. All reports must be certified by the responsible official consistent with 

Condition V.Q. Where an applicable requirement requires reporting more frequently than once 

every six months, the responsible official’s certification needs to only be submitted once every 

six months, covering all required reporting since the date of the last 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 Puget Sound Clean Air Agency Operating Permit 

Certification all instances of deviations from permit 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 threat 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 report other deviations in writing to Puget Sound Clean Air Agency 

Operating Permit Certification no later than 30 days after the end of the month during which the 

deviation is discovered. Deviations revealed by a continuous monitoring system shall be 

reported as provided in Condition 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 Conditions 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 commencing actions inconsistent with the plan. That 

immediate report shall be followed by a letter delivered or postmarked within 7 working days 

after the end of the event, explaining the circumstances of the event, the reasons for not 

following the plan, and describing all Subpart LLL excess emissions and/or parameter 

monitoring exceedances are believed to have occurred. The letter must contain the name, title 

and signature of the responsible official 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 the end of the month in which the data were 

recorded. This report 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 applicable 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 any actions taken to prevent its recurrence; 

c. The number of hours that the kiln operated each month and the number of valid hours of 

monitoring data for each parameter that the 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 

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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 monitoring 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 periods during which the 

average opacity measured by the kiln COMS exceeds 20 percent. If the total duration of excess 

emissions for the reporting period is less than 1 percent of the total operating time for the 

reporting period and COMS downtime for the reporting 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 duration of excess emissions for the reporting period 

equals 1 percent or greater of the total operating time for the reporting period or total COMS 

downtime for the reporting period is 5 percent or greater of the total operating time for the 

period, Ash Grove shall submit both the Summary 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 time 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 excess emissions that occurs during startups, 

shutdowns and malfunctions of the kiln, the nature and cause of any malfunction (if known), 

the corrective action taken or preventative measures adopted; 

d. The date and time identifying each period during 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 COMS 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 shall contain the following information: 
Permit No. 11339 

Expiration Date: May 15, 2009 

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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 limits in Conditions EU 1.29 and 1.30; 

f. Description of the manufacturer and model number(s) of the temperature monitor systems 

installed on the kiln and coal mills; 

g. Date of the most recent temperature 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 each 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 expressed as a percent of the total 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 temperature monitor, including the total number of 

hours of CMS downtime during the reporting period, total duration 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 during the reporting period 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, processes or controls since the last reporting period; 

l. All failures to calibrate thermocouples and temperature sensors 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 official 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 percent or greater of the total operating time for the 

monitored unit during the reporting period, Ash Grove shall submit an excess emissions and 

continuous monitoring system report in addition to the summary report described in this 

condition. 
Permit No. 11339 

Expiration Date: May 15, 2009 

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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 Shutdown 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 include 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 Grove’s SSM plan, the SSM report for the month of 

December shall include a statement to that effect. Each SSM report shall identify any instance 

where an action taken by Ash Grove during an SSM 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 failure of kiln air pollution control equipment or the kiln process 

to operate in a normal or usual manner which causes, 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 careless 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/furan 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 Sound 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 

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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 the nearest whole ton per year for only those 

contaminants that equal or exceed the thresholds above. 

[Puget Sound Clean Air Agency Regulation I, Section 7.09(a), 10/6/97] [Puget Sound Clean Air 

Agency Regulation I, Section 7.09(a), 9/10/98 (State only)] 

10. Complaint Response Reporting 

Ash Grove shall submit in writing to Puget Sound Clean Air Agency a report documenting all 

complaints received with a summary of the nature of the complaint, the conclusion of the 

investigation, and any corrective action taken in response. This report shall be submitted as an 

attachment to the CEM report required by Condition 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 Sound 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 concentration 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 continuous monitoring systems for opacity, 

combustion zone temperature, particulate control device temperature and air flow, sulfur 

dioxide, oxygen and/or carbon monoxide do not meet the applicable data recovery 

requirements of Section II.B of this permit . 

This condition shall be inapplicable once the 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 condition occurs that could result in a 

violation of one or more of Conditions EU 1.36 and EU 1.37 or a violation 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 advance of its occurrence. 

• For unplanned conditions, such as a breakdown or upset, the condition 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 the 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 subject to an applicable requirement, 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 and 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 calibration 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 readily 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 and raw mill, or until the 

kiln/raw mill are no longer subject to the provisions of 40 CFR Part 63. If the SSM Plan is 

revised, Ash Grove shall keep previous (i.e. superseded) versions of the Plan on record, to be 

made available for inspection, upon request, by the 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 general 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 inspections, tests and other actions required by the O&M Plan, 

including who conducted the inspection, tests or other actions; and the date and the results of the 

inspection, tests or other actions including corrective 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, 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), 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 conclusions 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 and by the continuous temperature 

monitors installed at the inlet 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 the 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 malfunction of the air pollution control equipment 

serving 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; 

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 CFR 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 startup, shutdown or malfunction of 

operation of the kiln and the raw mill; 

b) The occurrence and duration of each malfunction of the air pollution control 

equipment; 

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

d) Actions taken during SSM periods (including corrective actions to restore 

malfunctioning process and air pollution control 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 demonstrate conformance with the kiln/raw mill 

SSM Plan when all actions taken during SSM periods (including corrective 

actions to restore malfunctioning process and air pollution control equipment to 

its normal or usual manner of operation) are consistent with the procedures 

specified in the SSM Plan. (The information 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 inoperative (including out of control 

periods); 

g) All required measurements needed to demonstrate compliance with the 

dioxin/furan standards in 40 CFR 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 performed 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 reporting 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 criterion 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 notifications and notifications of compliance 

status under 40 CFR 63.9; 

o) All required temperature CMS measurements (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 inoperative except for zero (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 that 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 that 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 determination. The analysis shall be sufficiently 

detailed to allow EPA or the Puget Sound Clean 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 year calculations for SO2 and CO emissions from 

the kiln and summary 8-hour block average CO mass emission rates from the cement kiln. The 

records shall include the monthly calculations for each annual pollutant value, sufficient 

documentation to demonstrate the conversions from 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 all 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 rate estimates used for 

operational periods lacking CEM data also 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 prohibited, 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 shall not conduct any open burning other 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) and WAC 173-425-030(21) 

and 

2. Fires for instruction in the methods of fighting 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 State/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 Grove 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 installation 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 installation 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 conceals 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 allow the emission of air contaminants in sufficient quantity as to 

exceed any ambient air quality standard in Puget Sound Clean Air Agency Regulation I Section 

11.01. [Puget Sound Clean Air Agency Regulation 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 monitoring device or method required under Chapter 

70.94 RCW, or any ordinance, resolution, regulation, permit, or order in force pursuant thereto. 

[WAC 173-400-105(8), 8/21/98 STATE ONLY] 

H. False Statements 

Ash Grove shall not make any false material statement, representation or certification in any 

form, notice, or report required under Chapter 70.94 RCW, or any ordinance, resolution, 

regulation, permit, or order in force pursuant thereto. 

[WAC 173-400-105(7), 8/21/98 STATE ONLY] 
Permit No. 11339 

Expiration Date: May 15, 2009 

Page 56 of 81 

 

Ash Grove Operating Permit, May 15, 2004 

IV. ACTIVITIES REQUIRING ADDITIONAL APPROVAL 

Ash Grove shall file notification and obtain the necessary approval from Puget Sound Clean Air 

Agency before conducting any of the following: 

A. New Source Review 

Ash Grove shall not construct, install, establish, or modify an air contaminant source, except 

those sources that are excluded by Puget Sound Clean Air Agency Regulation I, Section 6.03(b), 

unless a “Notice of Construction and Application for Approval” 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 State/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 before replacing or substantially altering any 

emission control technology installed at the facility. [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 demolition 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 Air Agency Regulation I, Section 9.16(a) when 

conducting or allowing any operation that involves the use of spray equipment to apply any 

VOC-containing material. 

[Puget Sound Clean Air Agency Reg. I: 9.16 (7/12/01), State/Puget Sound Clean Air Agency 

only; however, will become federally enforceable 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 (FCAA). Such violations are grounds for 

enforcement action; for permit termination, revocation and re-issuance, or modification; 

or for denial of a permit renewal application. 

[Puget Sound Clean Air Agency Regulation 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 notification 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 rights 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 Clean 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 modifying, 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 copies 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 criminal 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 provisions 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 appealed only by filing an appeal with the 

Pollution Control Hearings Board and serving 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 contained therein, including any permit shield 

provided under WAC 173-401-640, shall not expire 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 terms 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 Agency 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 regulated 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 parameters 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 compliance with permit terms and conditions 

once per year. The first such certification shall cover a one-year period commencing 

upon the date of issuance of this permit. 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 compliance status of the 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 State 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 Regulation I, Section 3.05(b), 2/10/94; WAC 173-400-

105(4), 8/20/93] 

Ash Grove shall notify Puget Sound Clean Air 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. Provided, Ash Grove shall 

provide the Puget Sound Clean Air Agency at least 30 days prior notice 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 procedures 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, reported in units and for averaging periods consistent with 

the applicable emission standard; 

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

(e) The amount of fuel burned and raw material 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 source and control equipment during the test; 

(g) Field data and example calculations; and 

(h) A statement signed by the senior management official of the testing firm 

certifying the validity of the source test report. 

[Puget Sound Clean Air Agency Regulation 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 RCW, any rule enacted pursuant to that chapter, or any 

permit or order issued thereunder, nothing in Puget Sound Clean Air Agency Regulation I 

shall preclude the use, including the exclusive use of any credible evidence or 

information, relevant to whether a source would 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 compliance 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 conducted and data reduced in accordance with 

procedures contained in 40 CFR 60.8 and in each applicable subpart of 40 CFR Part 60. 

Performance tests required under 40 CFR Part 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 compliance certification submitted pursuant to this 

permit shall contain certification by a responsible official of truth, accuracy, and 

completeness. This certification and any other certification required under this permit 

shall state that, based on information and belief 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 emission limitation if the 

conditions of WAC 173-401-645(3) are met. 

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

contemporaneous operating logs, or other relevant evidence that: 

1. An emergency occurred and that Ash Grove 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 shorter periods of time specified in an 

applicable requirement. This notice fulfills the requirement of WAC 173-401-

615(3)(b) unless the excess emissions represent a potential 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 has 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 under 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 submit the information required under WAC 

173-400-107. 

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

T. Need to halt or reduce 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, Subpart F, except as provided for motor 

vehicle air conditioners (MVACs) in Subpart B: 

i) Persons opening appliances for maintenance, service, repair, or disposal must 

comply with the required practices 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 maintenance, service, repair, or disposal of appliances 

must be certified by an approved technician 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 New Alternatives Program (SNAP), 40 CFR 

Part 82, Subpart G, without a permit revision but shall not switch to a substitute 

listed as unacceptable pursuant to such program. [40 CFR 82.174] 

3. Any certified technician employed by Ash Grove shall keep a copy of their 

certification at their place of employment. [40 CFR 82.166(1)] 

4. Ash Grove shall not willfully release any regulated refrigerant and shall use 

refrigerant extraction equipment to recover regulated refrigerant when servicing, 

repairing or disposing of commercial air conditioning, heating, or refrigeration 

systems. 

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

V. RACT satisfied 

Emission standards and other requirements contained in rules or regulatory orders in 

effect at the time of this permit issuance shall 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 process, 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 later than the following dates: 

1. Three years after the date on which a regulated substance is first listed under 

40 CFR 68.130, or 

2. The date on which a regulated substance 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 this 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 information in a permit application, Ash Grove shall 

promptly submit such supplementary facts or corrected information 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 months prior to the expiration of this permit. 

Puget Sound Clean Air Agency will send Ash Grove a renewal application 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 from 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 Grove's right to operate 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 Sound 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 notice 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 final decision. A revocation issued under this 

condition may be issued conditionally with a future 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 Sound 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 monitoring or reporting by Ash Grove; 

d) Allows for a change in ownership 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 agreement containing a specific date for transfer of permit 

responsibility, coverage, and liability between 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 applications processed under an EPA-approved program, provided 

that such a program meets procedural requirements substantially equivalent to the 

requirements of WAC 173-401-700, 173-401-725, and 173-401-800 that would be 

applicable to the change if it were subject to review as a permit modification, and 

compliance requirements substantially equivalent to those contained 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 Agency 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 revisions as having been made pursuant to 

this paragraph. 

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

c) Ash Grove may implement the changes addressed in the request for an administrative 

amendment immediately upon submittal 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 amendments made pursuant to Part (1)(e) of 

this condition. 

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

C. Changes not Requiring Permit Revisions 

1) General. 

a) Ash Grove is authorized to make the changes described in this section 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 rate 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 Puget Sound Clean Air Agency with written 

notification at least seven days prior to making the proposed changes except that 

written notification of a change 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 notification required under Subsection (1)(a)(iv) of 

this condition shall include a brief description of the change within the permitted facility, 

the date on which the change will occur, any change in emissions, and any permit term 

or condition that is no longer applicable 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 increases and decreases in emissions in the 

permitted facility, where the Washington state implementation plan provides for such 

emissions trades without requiring a permit revision. This provision 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 under Subsection (1)(a)(iv) 

of this condition shall include such information as may be required by the provision in 

the Washington state implementation plan authorizing the emissions trade, including at a 

minimum, when the proposed change will occur, 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 Washington state implementation plan, and the 

pollutants emitted subject to the emissions trade. 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 determined according to requirements of the 

applicable implementation plan authorizing 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 addressed or prohibited by the 

permit terms and conditions without requiring a permit revision, provided that the proposed 

changes do not weaken the enforceability of existing permit conditions. Any change that is 

a Title I modification or is a change 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 contemporaneous 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 describe each such change, including the date, 

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

apply as a result of the change. 

4) The change shall not qualify for the 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 emissions resulting from those changes. 

6) When making a change under this section, Ash Grove shall comply with applicable 

preconstruction review requirements established 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 revision to this permit that cannot be 

accomplished under provisions for administrative permit amendments under WAC 173-401-

720. 

2) Procedures. Minor permit modification procedures. 

a) Criteria. 

i) Minor permit modification procedures shall 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 source-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 requirement and that Ash Grove has 

assumed to avoid an applicable requirement to which Ash Grove would 

otherwise be subject. Such terms and conditions include: 

(1) A federally enforceable emissions cap 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 subsection, and Subsection (3) of this section, the 

Puget Sound Clean Air Agency may allow the use of minor permit modification 

procedures for permit modifications involving the use of economic incentives, 

marketable permits, emissions trading, and other similar approaches, to the extent 

that the use of such minor permit modification procedures is explicitly 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 the use of minor permit modification procedures 

shall meet the requirements of WAC 173-401-510 and shall include the following: 

i) A description of the change, the emissions resulting from the change, and any new 

applicable requirements that will apply if the change occurs; 

ii) Ash Grove's suggested draft permit; 

iii) Certification by a responsible official, consistent with WAC 173-401-520, of the 

truth, accuracy, and completeness of the 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. Ash Grove may make the change proposed in its 

minor permit modification application immediately after it files such application 

provided that those changes requiring the submissions of a notice of construction 

application have been reviewed and approved 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 permit terms and conditions it seeks to modify. 

However, if Ash Grove fails to comply with its proposed permit terms and conditions 

during this time period, the existing permit terms and conditions it seeks to modify may 

be enforced against it. 

d) Permit shield. The permit shield under 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 groups 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 modification 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 relaxation of reporting or recordkeeping permit 

terms or conditions shall be considered significant. Nothing herein shall be construed to 

preclude Ash Grove from making changes consistent with Chapter 173-401 WAC that 

would render existing permit compliance terms and conditions irrelevant. 

b) Significant permit modifications shall meet all requirements of Chapter 173-401 WAC, 

including those for applications, 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 and 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 applicable requirement. No such reopening is 

required if the effective date of the requirement is later than the date on which the permit 

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

extended pursuant to WAC 173-401-620(2)(j); 

b) Additional requirements (including excess emissions 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 determines that the permit contains a material 

mistake or that inaccurate statements were made in establishing the emissions standards 

or other terms or conditions of the permit; or 

d) Puget Sound Clean Air Agency or EPA determines that the permit must be revised or 

revoked to assure compliance with the applicable requirements. 

2) Procedures. Proceedings to reopen and 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 expeditiously 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 Puget Sound Clean Air Agency at least thirty days in advance 

of the date that the permit is to be reopened, except that the 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 shall 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 (emergency 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 rain 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 technology (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 issuance, the requirements listed 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 SO2 or HCl. PSAPCA and Ecology 

elected to require an SO2 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 chapter 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 Approval 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 plant 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 inapplicable for specific emission units or for rule 

and unit specific reasons. The requirements identified 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 not 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 5th 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 Determinations 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 plant 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 intermediate 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 recordkeeping for insignificant emission units or activities 

except as required by Puget Sound Clean Air Agency 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 known instances of noncompliance during the 

reporting period. Where this permit requires 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 during 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 emission thresholds specified in WAC 173-401-

530(4) until this permit is modified pursuant 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 units listed below are defined as insignificant for 

the reasons indicated. 

Unit Basis for IEU Designation

Lubricating oil storage 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 conditioners WAC 173-401-532(46) 

Bathroom vents WAC 173-401-532(48) 

Fuel and exhaust emissions from vehicles 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 Tank 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 equipment) 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 Monitoring Performance Specification 

(by reference only, not attached) 

(1) EPA Performance Specification 1 (Opacity Monitoring), [40 CFR 60, Appendix 

B, July 1, 1992] 

(2) EPA Performance Specification 2 (SO2 and NOx Monitoring) [40 CFR 60, 

Appendix B, July 1, 1992] 

(3) EPA Performance Specification 3 (O2 Monitoring) [40 CFR 60, Appendix B, July 

1, 1992] 

(4) EPA Performance Specification 4 (CO 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 Continuous 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; Company name and address; Process unit(s) 

description; Emission limits; Monitor manufacturer and model no.; Date of latest CMS 

Certification or Audit; Total source operating time in reporting period1
Permit No. 11339 

Expiration Date: May 15, 2009 

Page 81 of 81 

Ash Grove Operating Permit, May 15, 2004 

Include with the Emission Data Summary1: 

1. The duration of excess emissions in reporting period that was due to: (a) 

Startup/Shutdown, (b) Control equipment problems, (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]/[Total source operating time]*(100) = %2

Include with the CMS Performance Summary1: 

1. The CMS downtime in reporting period due to: (a) Monitor equipment Malfunctions, (b) 

Non-Monitor equipment Malfunctions, (c) Quality 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 quarter 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.