### 1 

## Permit **Amendment Source Analysis & Technical Review**  Company **Ash Grove Texas, L.P.** Permit Number **1** City **Midlothian** Project Number **173601** County **Ellis** Account Number **ED -**  **0034 -**  **O** Project Type **Am end**  Regulated Entity Number **RN100225978** Project Reviewer **Mr. T an Nguyen, P.E.**  Customer Reference Number **CN600132161** Site Name **Cem ent Manufacturing Facility**  

### Project Overview Ash Grove Texas, L.P. (Ash Grove) owns and operates a portland cement manufacturing plant in Midl othian, Texas . Ash Grove submitted a permit amendment application on January 17, 2012. The amendment propos es to dec om mission Kilns 1 and 2 and reconstruct Kiln 3 from a 1,080 ton per day (tpd) clinker wet process kiln to a preheater/precalciner kiln system with an average production rate of 2,600 tpd clinker. With the project, the plant -wide maximum annual clinker production will drop from 1,182,600 tons per year (tpy) to 949,000 tpy. Other new sources to be constructed include a clinker cooler, a clinker cooler discharge belt, two solid fuel mill feed belts, a solid fuel mill, two pulverized fuel bins and an emergency generator. Additionally, various permits by rule ( PBRs ) , standard exemptions ( SEs ) , and standard permits (SPs) are being incorporated by consolidation or reference . 

### Emission Summa **ry**

**Air Contam inant**  **Current Allowable Em ission**  **Rates (tpy) Proposed Allowable**  **Emission Rates (tpy) Change in Allowable Em** **ission Rates (tpy)**  PM 805.24 301.64 - 503.60 PM 10 682.56 279.86 - 402.70 PM 2.5 1.21 (a) 169.35 168.14 VOC 122.4 69.52 - 52.88 NO X 9528 721.39 - 8806.61 CO 1314 587.59 - 726.41 SO 2 9198 190.04 - 9007.96 H 2 SO 4 -- (b ) 38.22 38. 22 Pb -- (b ) 0.04 0.04 Hg -- (b ) 0.01 0.01 NH 3 -- 78.03 (c) 78.03 (a) PM 2.5 was not speciated for almost all EPNs in the previously issued MAERT because it was not required at the time those sources were permitted. This project is expected to result in a decrease in PM 2.5 since PM is decreasing. (b) These emissions are not in the current permit but they are inherent in the process and have always existed at the plant site. These emissions are expected to decrease as a result of this project. (c) SNCR was authorized under SP Registration No. 80048; this registration is being incorporated by consolidation into the NSR permit. 

### Compliance History Evaluation **- 30 TAC Chapter 60**  **Rules** A compliance history report was reviewed on: **05/16/2012** Compliance period: **01/17/2007 -**  **01/17/2012** Site rating & classification: **1.63 -**  **average** Company rating & classification: **2.39 -**  **average** If the rating is 40<RATING<45, what wa s the outcome, if any, based on the findings in the formal report: **n/a** Has the permit changed o n the basis of the compliance history or rating? **No**

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### 2 **Public Notice Information -**  **30 TAC Chapter 39 Rules**  **Rule Citation Requirem**  **ent** 39.403 Is Public Notice Required? **No**

If no, give reason: **This p roject**  **will not result in a net em** **issions increase for**  **any pollutants .**  

### Construction Permit & **Amendment Requirements -**  **30 TAC Chapter 116 Rules Rule Citation**  **Requirem ent**  116.111(a)(2)(G) Is the facility expected to perform as represented in the application? **Yes** 116.111 (a) (2)(A)(i) Are emissions from this facility expected to comply with all TCEQ air quality Rules &

Regulations, and the intent of the Texas Clean Air Act? **Yes** 116.111 (a) (2)(B) Emissions will be measured using the following

method: **Existing kilns: NOx, CO, and SO2 CEMS; Reconstructed kiln:**  **N Ox, CO, SO2, PM,** 

**THC, and**  **Hg CEMS.**  Comments on emission verification: 116.111 (a) (2)(D) Subject to NSPS? **Yes**

Subparts **A, F, Y, OOO, and IIII** 116.111 (a) (2)(E) Subject to NESHAP ? **No**

Subparts 116.111 (a) (2)(F) Subject to NESHAP (MACT) for source categories? **Yes**

Subparts **A, LLL, and Z ZZZ**  116.111 (a) (2)(H) Is nonattainment review required? **No**

Is the site located in a nonattainment area? **Yes** Is the site a federal major source for a nonattainment pollutant? **Yes** Is the project a federal major source for a nonattainment pollutant by itself? **No** Is the project a federal major modification for a nonattainment pollutant? **No** Did the project emission increases for nonattainment pollutant minus the two -year average actual emissions trigger netting? **Yes** Is the contemporaneous increase significant? **No** If the contemporaneous increase is significant a nonattainment review is required. 116.111 (a) (2)(I) Is PSD applicable? **No**

Is the site a federal major source (100/250 tons/yr)? **Yes** Is the project a federal major source by itself? **No** Is the project a federal major modification? **No** Did project emission increases, without decreases, for pollutant of concern, minus the two year average actual emissions trigger netting? **Yes** Was the contemporaneous increase significant? **No** If yes, explain : Is the change excluded by 40 CFR 52.21(b)(2)(iii)? **No** If yes, explain : 116.111(a)(2)(L) Is Mass Emissions Cap and Trade applicable to the new or modified facilities? **No** If yes, did the proposed faci lity, group of facilities, or account obtain allowances to operate: **n/a** 116.140 - 141 Permit Fee: $ **75,000** Fee certification: **Yes** 

### Title V Applicability **- 30 TAC Chapter 122 Rules**  **Rule Citation Requirem**  **ent** 122.10(13)(A) Is the site a major source under FCAA Section 112(b)? **No**

Does the site emit 10 tons or more of any single HAP? **No** Does the site emit 25 tons or more of a combination? **No** 122.10(13)(C) Does the site emit 100 tons or more of any air pollutant? **Yes** 122.10(13)(D) Is the site a non - attainment major source? **Yes**

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### 3 122.602 **Periodic Monitoring (PM) applicability:**

PM is applicable since the site is subject to 30 TAC Chapter 122 and currently holds Title V Permit No. O 1054 . The NSR permit specifies the following Periodic Monitoring requirements to demonstrate compliance: we ekly visible emission/opacity observations for applicable EPNs, quarterly property line visible emission observations, mo nthly sorbent or stain tube testing for ammonia or alternately use an ammonia CEMS for the kilns, and annual fuel sulfur analysis or recordkeeping of vendor fuel specifications for the emergency diesel generator . 122.604 **Com pliance Assurance Monitoring (CAM) applicability:** 

CAM is potentially applicable since the site is subject to 30 TAC Chapter 122 . T he existing kilns use ESPs and SNCR and the reconstructed kiln will use a baghouse and SNCR to control PM and NOx emissions, respectively . Also, the kilns each have a pre - control potential - to - emit (PTE) for PM and NOx emissions greater than the associ ated major source thresholds; therefore, CAM is applicable to these emission sources and the specific pollutants. The NSR permit requires PM and NOx CEMS to demonstrate compliance. T he permit also requires CEMS for other pollutants, however, these are no t specific to CAM. EPNs 3, 7 , 5 , 9, 10, 11, and 5 - 2A for the clinker coolers, finish mills, cement silos, and silo No. 3 each have the pre - control PTE for PM emissions greater than the major source threshold and are equipped with baghouses to control PM emissions. T herefore, CAM is applicable and the NSR permit requires daily visible emission/opacity observations to demonstrate compliance. 

### Request for Comments **Received From Program** **/Area Nam e**  **Reviewed By Com** **me nts**  Region: **4 Luke Jones/Sam**  **Madison The re**  **gional office had com me**  **nts on recordkeeping and sam** **pling requirem ents.**  City: **Midlothian n/a**  County : **Ellis n/a**  T oxicology: **n/a** Comp liance: **n/a** Legal : **n/a** Comment resolution and/or unresolved issues: **The draft perm it was revised to add recordke**  **eping requirem ents and revise/clarify sam** **pling requirem**  **ents as requested by the regional office.** 

### Process**/Project Description**  The Ash Grove Midlothian plant currently has three existing wet kilns . F or a wet kiln, raw materials are mixed with water, and the resulting slurry is fed directly to the kiln . A sh Grove is proposing to decommission Kilns 1 and 2 and reconstruct Kiln 3 from a 1,080 tpd clinker wet process kiln to a preheater/precalciner kiln system with an average production rate of 2,600 tpd clinker . T he reconstruction primarily involves reducing the existing Kiln 3 length by half and adding a preheater/precalciner tower. Ash Grove will continue to create raw material slurry using the existing equipment . H owever, rather than feeding the slurry directly to the reconstructed kiln, the slurry will be fed into a new dryer/crusher where the slurry will be flash dried by hot kiln and precalciner gases . T he flash dried material will be crushed and preheated as it passes through the dryer/crusher and into a preheater cyclone . T he preheater cyclone will separate the preheated kiln feed from the gas that will exhaust through a new baghouse and stack . T he preheated material will then enter the precalciner to be calcined . T he hot gases leaving the kiln as well as gases generated from fuel combustion in the precalciner will provide the heat to the precalciner . A cyclone will separate the calcined kiln feed from the hot kiln and precalciner gases and send the kiln feed to the kiln . T he kiln and precalciner gases will then be routed to the dryer/crusher to provide the heat source for the flash drying of the slurry . T he “kiln system” refers to the entire pyroprocess comprised of the kiln, preheater, precalciner, and dryer/crusher . According to Ash Grove, there is only one other kiln system in the country that is configured similar to the new kiln system that Ash Grove is proposing - the kiln system at the Buzzi Unicem plant in Greencastle, Indiana . T he reconstructed kiln will be capable of burning the same fuels that the existing wet kilns are capable of burning, including coal, petroleum coke, natural gas, fuel oil, used oil, tire derived fuel (TDF), and woodchips.

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### 4 While the majority of the kiln gas will be routed directly to the precalciner, some gas wi ll be diverted to a new bypass baghouse . D ust removed from the bypass baghouse will be transferred to the existing cement kiln dust (CKD) handling system . T he exhaust from the bypass dust collector will rejoin the kiln exhaust entering the dryer/crusher. The precalciner will have the ability to combust coal, petroleum coke, natural gas, TDF, and wo odchips . F urther, the precalciner can be fueled by tires, where the tires will be combusted in a “hot disk reactor” . T he combustion of fuel in the precalciner will generate significant heat that together with the heat in the kiln gas will serve to calcine the kiln feed coming from the preheater cyclone . T he heat that remains in the kiln and precalciner gases is used to flash dry the slurry in the dryer/crusher, and further preheat the kiln feed that has been flash dried. In addition to the main baghouse for particulate matter (PM) control, other emission reduction measures have been designed into the reconstructed kiln system . D ry low-NOx burner s (DLN) and S elective Noncatalytic Reduction (SNCR) will be used to reduce NOx emissions from the kiln, and activated carbon injection (ACI) or other sorbent may be used to reduce mercury emissions from the kiln . F urther, the dryer/crusher is being designed to be in - l ine with the reconstructed kiln . C onstructing the kiln and dryer/crusher as an inline system allows the kiln exhaust to pass through the dryer/crusher to provide a heat source to flash dry the slurry (in addition to heat generated from combustion in the precalciner) . T his heat recovery mechanism reduces the kiln system’s fuel requirements, thus, lowers combustion emissions . F urther, it allows any sulfur compounds or acid gases in the kiln exhaust to be absorbed by the kiln feed. Clinker produced in the reconstructed kiln will be transferred to a new clinker cooler where it will be cooled using ambient air . C linker leaving the new clinker cooler will be handled by a new conveyor belt (FIN 3 - 4H) that will transport the material to existing material handl ing equipment . When the solid fuel mill is operating, the hot (ambient) air from the clinker cooler will pass through a new cyclone that will capture any coarse clinker material entrained in the air and combine it with the product from the clinker cooler . T he hot air will then route to a new indirect fired solid fuel mill, where the heat in the air will dry the coal (and other applicable solid fuels) in the mill . When the solid fuel mill is not operating, the cooler exhaust will pass through a process du st collector and heat exchanger (existing) and be recirculated back to the clinker cooler . T he material collected in the process dust collector will be combined with the product from the clinker cooler . S ome recirculation of the clinker cooler exhaust through the process dust collector and heat exchanger may also occur when the solid fuel mill is operating, although at a significantly lower rate. The pulverized fuel from the mill will be transferred with the exhaust from the solid fuel mill to a new baghouse . T he baghouse will separate the pulverized coal (and other applicable solid fuels) from the exhaust air and the pulverized solid fuel will be routed to the two new pulverized fuel bins . E ach bin has a vent with a small dedusting filter . P ulverized solid fuel from the new bins will be conveyed to the kiln and the precalciner burner pipes . A s Ash Grove is uncertain on the VOC emission rate from the solid fuel mill, Ash Grove will install a regenerative thermal o xidizer (RTO) on the solid fuel mill to maintain VOC emissions from the project to less than the calculated potential emissions. In order to ensure adequate drying of the solid fuel, a natural gas fired hot gas generator (15 MMBtu/hr) will be used to make hot gas that can supplement the heat in the clinker cooler air on an as needed basis or that can be used as the sole heat source for the solid fuel drying if the kiln and clinker cooler are not operating at adequate temperature to dry the solid fuel . Any clinker cooler gas that cannot be sent to the solid fuel mill will be diverted back to the clinker cooler heat exchanger, cooled and used to cool the hot clinker . D ue to the design of the clinker cooling system, there will not be a dedicated clinker cooler exhaust stack emission point. After the new clinker cooler belt, FIN 3 - 4H, the clinker produced in the reconstructed kiln will be handled using existing equipment . S ince both raw

materials and product will be handled using existing equipment, the changes to the plant are limited to construction of the converted preheater/precalciner kiln system, a clinker cooler (and associated conveyor belt), and a solid fuel mill . T wo new belt conveyors will be installed to transfer coal and other applicable solid fuels from the existing Solid Fuel Day T ank (FIN 6 - 9) to the new solid fuel mill . B oth of the conveyors will utilize baghouses for dust control . F or emergency situations, a 400 kW output (473 kW input , 635 hp input, 536 hp output) emergency generator will be installed . It will only operate du ring critical times, such as power outages, to run the auxiliary kiln drive, burner pipe emergency fan, and other sensitive equipment and will replace old units currently in use at the plant. A summary of the new emission sources to be added (or reconstructed in the case of Kiln 3) as a result of the Kiln 3 reconstruction project is as follows:  Kiln 3 (part of kiln system)

– FIN 431.KL100, EPN 331.SK410  Dryer/Crusher (part of kiln system)

– FIN 411.DC100, EPN 331.SK410

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### 5  Precalciner (part of kiln system)

– F IN 421.CI400, EPN 331.SK410  Preheater Cyclone (part of kiln system)

– FIN 421.CN010, EPN 331.SK410  Precalciner Cyclone (part of kiln system)

– FIN 421.CN110, EPN 331.SK410  Clinker Cooler

– FIN 441.CC100, EPN 461.SK405  Solid Fuel Mill

– FIN 461.RM100, EPN 4 61.SK405  Hot Gas Generator

– FIN 461.HG700, EPN 461.SK405  Clinker Cooler Belt

– FIN 3 - 4H, EPN F - MB2  Solid Fuel Transfer Solid Fuel Day Tank to BC050

– FIN 6 - 15A/B/C, EPN 6 - 15  Solid Fuel Transfer BC050 to BC080

– FIN 461.BC050, EPN 461.BF020  Solid Fuel Tran sfer BC080 to Solid Fuel Mill

– FIN 461.BC080, EPN 461.BF040  Pulverized Fuel Bin A

– FIN 461.BI550A, EPN 461.BF560A  Pulverized Fuel Bin B

– FIN 461.BI550B, EPN 461.BF560B  Emergency Diesel Generator

– FIN EG1, EPN EG1.SK1 A summary of existing equipment as sociated with the Kiln 3 reconstruction project is as follows:  Slag/Mill Scale Silo 3 Weigh Belt

– FIN 1 - 16A, EPA 1 - 16A1 and 1 - 16A2 The existing weigh belt listed above is the conveyor that currently sends raw materials, such as slag, to the existing Kiln 3. Following the Kiln 3 reconstruction project, the conveyor will continue to handle raw material or product, but the amount handled could be greater than it is now. A summary of equipment to be decommissioned as a result of the Kiln 3 reconstruction pro ject is as follows:  Kiln 1 and the associated electrostatic precipitator (ESP) (FIN 2 - 1, EPN 2)  Kiln 2 and the associated ESP (FIN 2 - 2, EPN 6)  Kiln 3 ESP (EPN 12)  Kiln 1 Clinker Cooler (FIN 3 - 1, EPN 3)  Kiln 2 Clinker Cooler (FIN 3 - 2, EPN 7)  Kiln 3 Clinker Cooler (FIN 3 - 3, EPN 131)  Kiln 1 Clinker Cooler Belt (FIN 3 - 4A, EPN F - MB22)  Kiln 2 Clinker Cooler Belt (FIN 3 - 4B, EPN F - MB23)  Kiln 3 Clinker Cooler Belt (FIN 3 - 4C, EPN F - MB24)  Solid Fuel Mills 1, 2, and 3 (FIN 6 - 10A/B/C, EPN 6 - 10)  Slag/Mill Scale Silo 1 (F IN 1 - 14, EPN 1 - 125)  Slag/Mill Scale Silo 1 Weigh belt (FIN 1 - 14A, EPN 1 - 14A1, EPN 1 - 14A2)  Slag/Mill Scale Silo 2 (FIN 1 - 15, EPN 1 - 126)  Slag/Mill Scale Silo 2 Weigh Belt (FIN 1 - 15A, EPN 1 - 15A1, EPN 1 - 5A2)  Kiln 1 Auxiliary Drive Engine (FIN 1 - 43, EPN 1 - 43)  Kiln 2 Auxiliary Drive Engine (FIN 1 - 44, EPN 1 - 44)  Kiln 3 Auxiliary Drive Engine (FIN 1 - 45, EPN 1 - 45) Additionally, various permits by rule (PBRs), standard exemptions (SEs), and standard permits (SPs) are being incorporated by consolidation. They are as follows: (See BACT below for additional information.)  PBR Regi stration No. 82608 ( EPNs F - RM2, 1 - 29, 1 - 30, 1 - 31 , 3 - 19 and F - RM4 )  PBR Registration No. 90808 ( EPNs 6 - 11, 6 - 13, 6 - 14 , and 6 - 12 )  PBR Registration No. 76379 ( EPNs 6 - 1, 6 - 2, 6 - 3, 23, and 6 - 4D )  PBR Registration No. 74145 ( EPNs 3 - 15, F - RM1, F - RM2, 1 - 29, 1 - 30, and 1 - 31 )  SE 91 Registration No. 34329 (EPNs 10 and 11 )  SE 106 (APD - CERT 03/11/2005 ) (EPN 6 - 4C)  SP Registration No. 74149 ( EPN 3 - 15 )  SP Registration No. 80048 (EPNs 7 - 1 - 1, 7 - 1 - 3, 7 - 4, 7 - 5, 7 - 6, and 7 - 7 ) PBR Registration No. 71845 ( CKD Silo 3 and Pug Mill ) is being incorporated by reference per the applicant's request since the authorized sources do not directly impact any permitted facilities .

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### 6 **Pollution Prevention, Sources, Controls and BACT -**  **[ 30 TAC 116.111(a)(2)(C)]**  Reconstructed No. 3 Cement Kiln (kiln, dryer/crusher, precalciner, and preheater) , EPN 331.SK410 **NOx** NSPS Subpart F limits emissions of NOx for new and reconstructed kilns to less than 1.5 lb/ton clinker, based on a 30 - day rolling average . A sh Grove will comply with the NOx limit by using DLN (staged combustion) in combination with SNCR . S NCR is the most efficient NOx reduction technology demonstrated on U.S . c ement kilns . A NOx limit of 1.5 lb/ton clinker (30 - day rolling average), as required by NSPS Subpart F, is lower than the NOx BACT determinations made for other recently permitted kilns . T hus, using DLN in combination with SNCR to meet a limit of 1.5 lb/ton clinker (3 0 - day rolling average) for NOx i s BACT f or the kiln sys tem. **CO and VOC** CO and VOC emissions are generated as products of incomplete combustion and as a result of the decomposition of organic material in the kiln feed . T here are add - on control devices such as oxidizers that can reduce emissions of CO and VOC . H owever, there are no kilns in the U.S . f

or w hich a BACT determination has resulted in the installation of these devices . Recent BACT determinations for CO and VOC have relied on good combustion practices as a means of limiting CO and VOC emissions . A sh Grove evaluated the economic feasibility of an RTO . T he methodology specified in the EPA Air Pollution Control Cost Manual - Sixth Edition (EPA 452/B - 02 - 001) wa s used to calculate the economic feasibility in annual $/ton pollutant removed . T he resulting economic cost was $132,318/ton VOC controlled, $11,464/ton CO controlled, or $10,277/ton CO+VOC controlled . N one of the costs are economically feasible . S ince RTO is not cost effective, and recent BACT determinations have relied on good combustion prac tice, Ash Grove will use good combustion practice s as BACT for CO ( 1.23 lb/ton clinker, 30 - day rolling average ) and VOC (0.138 lb/ton clinker, 12 - mo nth rolling period) f or the kiln system. **PM /PM**  **10 /PM**  **2.5** The new kiln system will be subject to both NSPS Subpart F and NESHAP Subpart LLL . T he NSPS and NESHAP limit emissions of filterable PM for new

and reconstructed kilns to 0.01 lb/ton clinker, based on a 30 - day rolling average . T his is an extremely low PM limit, resulting in potential filterable PM emissio ns from the new kiln system of less than 5 tpy . A baghouse is the most efficient control device for controlling filterable PM, as well as PM 10 and PM 2.5 . A sh Grove will install a baghouse to meet a limit of 0.01 lb/ton clinker for filterable PM/PM 10/PM 2. 5 , based as a 30 - day rolling average , to comply with the NSPS and NESHAP limits . T his is BACT for the kiln system. **SO 2**  **and H**

**2 SO** **4** NSPS Subpart F limits emissions of SO 2 for new and reconstructed kilns to less than 0.4 lb/ton clinker, based on a 30 - day rol ling average, or 90% control . T his limit is lower than the SO 2 BACT determinations made for other similar kilns in Texas . A sh Grove will comply with the SO 2 limit by operating a dryer/crusher in line with the kiln . T he dryer/crusher is part of the “preheat” portion of the overall preheater/precalciner kiln system, with the primary purpose of grinding, flash drying and preheating the wet kiln feed slurry using heat contained in the kiln and precalciner gases . While the primary purpose of the dryer/crusher is to heat, dry and grind the slurry, it also acts as an inherent scrubber for SO 2 and acid gases in the kiln exhaust (similar to the inherent scrubbing experienced in an in - line raw mill) . T hus, meeting a limit of 0.4 lb/ton clinker (30 - day rolling average) for SO 2 through process inherent scrubbing i s BACT f or the kiln system. A portion of the SO 2 generated in the process is converted to H 2 SO 4 . Therefore, limiting SO 2 emissions will also limit H 2 SO 4 emissions, which is BACT. **Hg** NESHAP Subpart LLL limits emissions of Hg for new and reconstructed kilns to 21 lb/million tons clinker, based on a 30 - day rolling average . This is a very low emission limit, and BACT for Hg has generally not been evaluated for previous similar kilns in Texas . A sh Grove will comply with the NESHAP limit by installing an activated carbon injection system or other sorbent system to control Hg emissions from the kiln . This is BACT. **NH 3**  An alternative case specific specification (pursuant to 30 TAC 117.3125 ) for an ammonia emis sion limit of 35 ppm for the kilns wa s approved under a permit alteration issued on June 1, 2010. This is BACT and will apply to the reconstructed kiln.

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### 7 Clinker Cooler/ Solid Fuel Mill (EPN 461.SK405 ) / Pulverized Fuel Bins (EPNs 461.BF560A and 461.BF560B ) / Solid Fuel Transfers (EPNs 461.BF020 and 461.BF0 4 0 ) / Clinker Cooler Belt (EPN F - MB2) The new clinker cooler wil l not have a direct emission point ; emissions will be routed to the solid fuel mill. Emissions from the solid fuel mill stack and the two so lid fuel transfer points preceding the solid fuel mill will be routed to baghouses that will control emissions of filterable PM for these sources to 0.01 gr/dscf. This is BACT. Emissions from the pulverized fuel bins will be routed to dedusting filters t hat will control emissions of filterable PM for these sources to 0.01 gr/dscf. This is BACT. Solid fuel from the exiting solid fuel day tank will be transferred to a new belt conveyor. The transfer will occur inside a we ll - enclosed building . The inherent moisture content of the fuel (> 7%) along with the well - enclosed building will control PM emissions to at least 90% . This is BACT. Similarly, the new clinker cooler belt conveyor will transfer material to the existing clinker handling system in an enclosure and within a building to obtain at least 90% PM control . This is BACT . Ash Grove does not have VOC data for the new solid fuel mill. Further, no BACT determinations have ever been made for VOC from solid fuel mills (i.e., coal mills). Ash Grove is estimating that the concentration of VOCs in the exhaust gas, resulting from the hot air drying the coal (and other applicable solid fuels), is 10 percent of the NESHAP standard for THCs for the kiln system. The NESHAP standard is 24 ppmvd at 7% oxygen . The actual predicted conditions for the kiln stack are 5.7% oxygen and 40.4% moisture, resulting in an actual stack THC concentration of 15.6 ppmv. This results in a concentration of 1.56 ppmv VOC for the solid fuel mill. Thus, Ash Grove is expecting to achieve a VOC concentration in the solid fuel mill exhaust of 1.56 ppm v or less. This is much less than the VOC limit that qualifies for an exemption from control requirements in 30 TAC Chapter 115, Subpart B, Division 2. This is BACT. Hot Gas Generator The hot gas generator will be fired with natural gas and operated with good combustion practices. NO x emissions will be limited to 30 ppm vd corrected to 3 percent O 2 . T his is BACT. Emergency Generator The emergency generator will be fired with diesel containing no more than 15 ppm sulfur and will be certified to NSPS Subpart IIII Tier 3 standards. This is BACT . PBR Sources Incorporated by Consolidation EPN Facility BACT 6 - 2 Coal Unloading Conveyor Belt Limited drop distance and high inherent mo isture content (> 7%) and low emissions. 6 - 3 Drop from Coal Stacker to Stockpile 6 - 4D Stacker Pile Movement 6 - 12 Reserve Solid Fuel Stockpile 6 - 4C Solid Fuel Unloading - Drop from Front End Loader to Stockpile 6 - 11 Reserve Solid Fuel Transfer Point (at Main Stockpile) 6 - 13 Reserve Solid Fuel Reclamation Transfer Point (at Reserve Stockpile) 6 - 14 Reserve Solid Fuel Reclamation Transfer Point (at Main Stockpile) F - RM1 Raw Material Building (Transfer onto Limestone Inside Stockpile) Building enclosu re and limited drop distance and low emissions. F - RM2 Raw Material Building (Limestone Feed Hopper/Incline Conveyor) F - RM4 Clinker Transfer to Inside Pile (RM Building) 6 - 1 Railcar Unloading Hopper

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### 8 EPN Facility BACT 3 - 19 Clinker Transport Loading (outside pile) Limited drop distance and low emissions (< 0.01 tpy PM). 3 - 15 Clinker Reclaim Conveyor No. 6 Baghouse Emissions routed to fabric filter dust collector with an outlet grain loading of equal to or less than 0.01 gr/dscf. 1 - 29 Limestone Bin Dust Collector 1 - 30 Limestone Transfer onto Finish Mill Collection Belt 1 1 - 31 Limestone Transfer onto Finish Mill Collection Belt 2 23 Railcar Unloading Baghouse 32 CKD Tank 1 Baghouse 10 Cement Silo 1 Baghouse 11 Cement Silo 2 Baghouse 

### Impacts Evaluation **- 3**  **0 TAC 116.111(a)(2)(J)** Was modeling conducted? **Yes** Ty pe of Modeling: **AERMOD** Will GLC of any air contaminant cause violation of NAAQS? **No** Is this a sensitive location with respect to nuisance? **No** [§116.111(a)(2)(A)(ii)] Is the site within 3000 feet of any school? **No** Additional site/land use information: 

### Summary **of Modeling Results** AERMOD mo deling was submitted by the applicant. The modeling was audited and approved by the Air Dispersion Modeling Team. The modeling results indicate that the maximu m off -property predicted concentrations for SO 2 (1 -hr, 3 -hr, 24 -hr , and annual averaging periods) , PM 10 (24 -hr averaging period), PM 2.5 (24 -hr and annual averaging periods) , NO 2 (1 -hr and annual averaging period s ) , and CO ( 1 -hr and 8 -hr averaging periods ) are below the respective de minimis concentrations and no further analysis is required. **Modeling Results for Minor NSR De Minim is**  **Pollutant Averaging Tim**  **e GLCmax (μg/m**  3 **) De Minim** **is (μg/m** 3 **)** SO 2 1 -hr 6.9 7.8 SO 2 3 -hr 5 25 SO 2 24 -hr 1.5 5 SO 2 Annual 0. 01 1 PM 10 24 -hr 2.8 5 PM 2.5 24 -hr 1.18 1.2 PM 2.5 Annual 0.003 0.3 NO 2 1 -hr 6.9 7.5 NO 2 Annual 0.04 1 CO 1 -hr 22 2000 CO 8 -hr 9 500 Additionally, the modeling results indicate that the state property line regulations for SO 2 (1 -hr averaging period) and H 2 SO 4 (1 -hr and 24 -hr averaging periods) are not exceeded.

## Perm **it Am endm**  **ent Source Anal** 

**ysis & Technical Review**  Permit No. 1 Regulated Entity No. RN100225978 Page 9



### 9

**Project -**  **Related Modeling Results for State Property Line Pollutant**  **Averaging Tim e**  **GLCmax (μg/m** 3 **) De Minim** **is (μg/m** 3 **)** SO 2 1 -hr 11.2 20.4 H 2 SO 4 1 -hr 0.05 1 H 2 SO 4 24 -hr 0.01 0.3 The Modeling and Effects Review Applicability (MERA) analysis wa s conducted for non - criteria pollutants . All pollutants for the project fell off the MERA at Step 1C (there is no overall net increase in both short - term and annual emissions ). Therefore, no further analysis is necessary. Based on the above information, the project is not expected to have an adverse effect on human health or the environment. 

### Permit Concurrence and Related Authorization Actions Is the applicant in agreement with special conditions? **Ye s**  Company representative(s): **Scott Nielson** Contacted Via: **phone** Date of contact: **05/23/2012** Other permit(s) or permits by rule affected by this action: **Yes** List permit and/or PBR number(s) and actions required or taken: **PBR, SE, and SP Registration No s.**  **34329, 74145, 74149, 76379, 80048, 82608, and 90808**  **have been incorporated by**  **consolidation and will be voided with this perm** **it action.**

Project Reviewer Date Team Leader/Section Manager/Backup Date