Air Perm it No. PSD-FL-352 Project No. 1210465-014-AC New Kiln Line No. 2 Sy stem Perm it Expires: February 15, 2010 PERMITTEE:
Suwannee Am erican Cem e nt, L.L.C. Branford Cem e nt Plant 5117 US Highway 27 Branford, FL 32008 Authorized Representative: Tom Messer, Plant Manager

FACILITY AND LOCATION
Suwannee Am erican Cem e nt, LLC operates an existing portland cem ent m a nufacturing plant (SIC No. 3241), which is located at 5117 US Highway 27 in Suwannee County
, Florida. The UTM coordinates are: Zone 17; 321.4 km E and 3315.9 km N.

STATEMENT OF BASIS This perm it authorizes the construction of a second dry pr ocess, preheater/precalciner k iln sy stem with in-line

raw m ill at the existing plant. The perm it is issued under the provisions of Chapter 403 of the Florida Statutes (F.S.), and Chapters 62-4, 62-204, 62-210, 62-212, 62- 296, and 62-297 of the Florida Adm i nistrative Code (F.A.C.). The perm ittee is authorized to perform the proposed work in accordance w ith the conditions of this perm it and as described in the application, approved dr awings, plans, and other docum ents on file with the Departm e nt.

___________________________________ Michael G. Cooke, Director Division of Air Resource Managem e nt

Effective Date: ______________________SECTION 1. GENERAL INFORMATION

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 2 of 21 FACILITY DESCRIPTION The existing facility consists of a portland cement manufact uring plant, the associated quarry, and raw material and cement handling operations. The plant combines raw ma terials and utilizes a preheater/calciner kiln system with inline mill to produce cement clinker. The cli nker is milled and combined with gypsum to produce portland cement. The existing plant has a capacity of 210 t ons per hour of dry preheater feed materials, 120 tons per hour of clinker production, a nd 150 tons per hour of portland cemen t production. Annual production is limited to the following 12-month rolling totals: 1,648,578 tons per year of dry preheater feed materials; 965,425 tons per year of clinker pr oduction; and 1,191,360 tons per year of portland cement production. Fuel authorized for the pyroprocessing system includes natural g as, coal, petroleum coke, and whole or chipped tires. The plant also operates a coal processing operation to cr ush coal and petroleum coke with a monthly processing capacity of 13,360 tons of coal and/or petroleum coke , combined. The plant uses Selective Non-Catalytic Reduction (SNCR) to control NOx emissions from the existing pyroprocessing system.
REGULATORY CLASSIFICATION
Title III : The cement plant is a major source of hazardous air pollutants (HAP).
Title IV : The cement plant operates no units subject to the acid rain provisions of the Clean Air Act.
Title V: The cement plant is a Title V major s ource in accordance with Chapter 213, F.A.C.
PSD : The cement plant is a PSD-major facility in acco rdance with Rule 62-212.400, F.A.C. The proposed project is a major PSD modification.
NSPS : Portions of the cement plant are subject to th e following New Source Performance Standards (NSPS) in 40 CFR 60: Subpart A (General Provisions); Subpart F (Portland Cement Plants); Subpart Y (Coal Preparation Plants); and Subpart OOO (Nonmetallic Mineral Processing).
NESHAP : Portions of the cement plant are subject to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR 63: Subpart A (Gen eral Provisions); and Subpart LLL (Portland Cement Manufacturing Industry).
State Rules : The cement plant is subject to state Rule 62-296.407, F.A.C. (Portland Cement Plants).

PROJECT DESCRIPTION This permit authorizes the construction of a new cement manufacturing line (Kiln Line No. 2) at the existing facility. The project will affect the following existing and new emissions units.

ID No. Emissions Unit Description

001 (Existing) Primary crusher and associated belt conveyors
003 (Existing) Raw material processing with une nclosed conveyor transfer points - D conveyors
009 (Existing) Unenclosed coal conveying equipment - S Conveyors
011 (New) Clinker and cement handling and storage with baghouse controls for miscellaneous emissions points
012 (New) Coal mill and coal transfer system with baghouse controls for emissions points
013 (New) Dry process preheater/precalcine r rotary kiln with in-line raw mill
014 (New) Raw material handling and storage with baghouse controls for miscellaneous emissions points
015 (New) Fugitive dust from storage piles, paved roads, and unpaved roads

Kiln Line No. 2 will have the following capacities: 215 t ons per hour of dry preheater feed materials; 127 tons per hour of clinker production; and 175 tons per hour of portland cement pr oduction. The permit limits annual clinker production from Kiln Line No. 2 to no more than 1,055,500 tons during any consecutive 12 months.SECTION 1. GENERAL INFORMATION

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 3 of 21 This project is subject to preconstruction review for the Prevention of Significant Deterioration (PSD) of Air Quality for emissions of carbon monoxide (CO), nitrogen oxides (NOx), particulate matter (PM/PM 10 ), sulfur dioxide (SO 2 ), and volatile organic compounds (VOC). The permit includes emissions standards and work practices that represent determinations of the Best Available Control Technology (BACT) for each of these pollutants. NOx emissions from the pyroprocessing system will be controlled with a Selectiv e Non-Catalytic Reduction (SNCR) system. Particulate matter emissions from the kiln system will be controlled by a single baghouse control system. Authorized fuels for the pyroprocessing system include natural gas, fuel oil, on specification used oil fuel, coal, petroleum coke, and tires (whole, chi pped, or gasified tires). The plant will also include a coal processing operation designed to crush coal and pe troleum coke with an annual processing capacity of 150,000 tons per year of coal and/or petroleum coke.

CONTENTS
Section 1. General Information Section 2. Administrative Requirements Section 3. Emissions Units Specific Conditions Subsection A. Kiln Line No. 2 System Subsection B. Primary Crusher Subsection C. Miscellaneous Handling and Storage of Raw Materials Subsection D. Coal Mill and Conveying Equipment Subsection E. Miscellaneous Fugitive Emissions Sources Section 4. Appendices Appendix A. Citation Formats Appendix B. General Conditions Appendix C. Common State Rules Appendix D. Used Oil Fuel Requirements Appendix E. Summary of Final BACT Determinations Appendix F. Quarterly Report Appendix G. NSPS Subpart F Provi sions – Portland Cement Plants Appendix H. NSPS Subpart Y Provisions – Coal Preparation Plants Appendix I. NSPS Subpart OOO Provisions – Nonmetallic Mineral Processing Plants Appendix J. NESHAP Subpart LLL Provisions – Portland Cement Manufacturing Industry

RELEVANT DOCUMENTS The permit application, additional information received to make it complete, and the Department’s Technical Evaluation and Preliminary Determination are not a part of this permit; however, this information is specifically related to the permitting action and is on file with the Department.SECTION 2. ADMINISTRATIVE REQUIREMENTS

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 4 of 21 1. Permitting Authority : All documents related to PSD applicati ons for permits to construct or modify emissions units shall be submitted to the Bureau of Air Regulation of the Florida Department of Environmental Protection (DEP) at 2600 Blair Stone Road (MS #5505), Tallahassee, Florida 32399-2400. All documents related to applications for permits to construct minor sour ces of air pollution or to operate the facility shall be submitted to the Air Resources Section of the Department’s Northeast District Office at 7825 Baymeadows Way, Suite 200-B, Jacksonville, FL 32256-7590.
2. Compliance Authority : All documents related to compliance activities such as reports, tests, and notifications shall be submitted to the Air Resources S ection of the Department’s Northeast District Office at 7825 Baymeadows Way, Suite 200-B, Jacksonville, FL 32256-7590.
3. Appendices : The following appendices are attached as a part of this permit: Appendix A (Citation Formats); Appendix B (General Conditions); Appendi x C (Common State Rules); Appendix D (Used Oil Fuel Requirements); Appendix E (Summary of Fina l BACT Determinations); Appendix F (Quarterly Report); Appendix G (NSPS Subpart F Provisions - Por tland Cement Plants); Appendix H (NSPS Subpart Y Provisions – Coal Preparation Plants); Appendix I (NSPS Subpart OOO Provisions – Nonmetallic Mineral Processing Plants); and Appendix J (NESHAP Subpart LLL Provisions – Portland Cement Manufacturing Industry).
4. Applicable Regulations, Forms and Application Procedures : Unless otherwise indicated in this permit, the construction and operation of the subject emissions unit shall be in accordan ce with the capacities and specifications stated in the application. The facility is subject to all applicable provisions of: Chapter 403 of the Florida Statutes (F.S.); Chapters 62-4, 62- 204, 62-210, 62-212, 62-213, 62-296, and 62-297 of the Florida Administrative Code (F.A.C.); and Title 40 of the Code of Federal Regulations (CFR) adopted by reference in Rule 62-204.800, F.A.C. The terms used in this permit have specific meanings as defined in the applicable chapters of the Florida Administrative Code . The permittee shall use the applicable forms listed in Rule 62-210.900, F.A.C. and follow the application pr ocedures in Chapter 62-4, F.A.C. Issuance of this permit does not relieve the permittee from compliance with any applicable federal, state, or local permitting or regulations. [Rules 62-204.800, 62-210.300 and 62-210.900, F.A.C.]
5. Construction and Expiration : The permit expiration date includes sufficient time to complete construction, perform required testing, submit test reports, and submit an application for a Title V operation permit to the Department. Approval to construct shall become inva lid for any of the following reasons: construction is not commenced within 18 months after issuance of this permit; construction is discontinued for a period of 18 months or more; or construction is not completed within a reasonable time. The Department may extend the 18-month period upon a satisfactory showing that an extension is justified. In conjunction with an extension of the 18-month period to commence or con tinue construction (or to construct the project in phases), the Department may require the permittee to demonstrate the adequacy of any previous determination of Best Available Control Technology (B ACT) for emissions units regulated by the project. For good cause, the permittee may request that this PSD ai r construction permit be extended. Such a request shall be submitted to the Department’s Bureau of Ai r Regulation at least sixty (60) days prior to the expiration of this permit. [Rules 62-4.070(4), 62-4.080, 62-210.300(1), and 62-212.400(6)(b), F.A.C.; 40 CFR 52.21(r)(2); 40 CFR 51.166(j)(4)]

6. New or Additional Conditions : For good cause shown and after notice and an administrative hearing, if requested, the Department may require the permittee to conform to new or additional conditions. The Department shall allow the permittee a reasonable time to conform to the new or additional conditions, and on application of the permittee, the Department may grant additional time. [Rule 62-4.080, F.A.C.]
7. Relaxations of Restrictions on Pollutant Emitting Capacity

. If a previously permitted facility or modification becomes a facility or modification whic h would be subject to the preconstruction review requirements of this rule if it were a proposed new facility or modification solely by virtue of a relaxation inSECTION 2. ADMINISTRATIVE REQUIREMENTS

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 5 of 21 any federally enforceable limitation on the capacity of th e facility or modification to emit a pollutant (such as a restriction on hours of operation), which limitation was established after August 7,1980, then at the time of such relaxation the preconstructi on review requirements of this rule shall apply to the facility or modification as though construction had not yet commenced on it. [Rule 62-212.400(2)(g), F.A.C.]
8. Modifications : No emissions unit or facility subject to this permit shall be constructed or modified without obtaining an air construction permit from the Department . Such permit shall be obtained prior to beginning construction or modification. [Rule 62- 4.030 and Chapters 62-210 and 62-212, F.A.C.]
9. Title V Permit : This permit authorizes construction of the permitted emissions units and initial operation to determine compliance with Department rules. A T itle V operation permit is re quired for regular operation of the permitted emissions unit. The permittee shall apply for a Title V operation permit at least 90 days prior to expiration of this permit, but no later than 180 days after commencing operation. To apply for a Title V operation permit, the applicant shall submit the appropriate application form, compliance test results, and such additional information as the Department may by law require. The application shall be submitted to the Air Resources Section of the Department’s No rtheast District Office at 7825 Baymeadows Way, Suite 200-B, Jacksonville, FL 32256-7590. [Rules 62-4.030, 62-4.050, 62-4.220 and Chapter 62-213, F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 6 of 21 The following specific conditions apply to the following emissions units after construction:

ID No. Emissions Unit Description

013 Kiln Line No. 2 – Dry process preheater/pr ecalciner rotary kiln with in-line raw mill

{Permitting Note: This emissions unit is subject to th e following applicable requirement s: NSPS Subpart A (General Provisions) and NSPS Subpart F (Portland Cement Plants) in 40 CFR 60; NESHAP Subpart A (General Provisions) and NESHAP Subpart LLL (Portland Cement Manuf acturing Industry) in 40 CFR 63; and Rule 62-296.407, F.A.C. (Portland Cement Plants). This unit is also subject to the Best Available Control Technology (BACT) requirements in Rule 62- 212.400, F.A.C. as specified in this section.}
P ERFORMANCE R EQUIREMENTS 1. Kiln Line No. 2 : The permittee is authorized to install a second pyroprocessing system consisting of a dry process pre-heater/precalciner rotary k iln with in-line raw mill, clinker c ooler, air heater (associated with raw mill), exhaust stack and other ancillary equipmen t subject to the capacities and maximum process rates specified in this permit. All exhaust from the pyr oprocessing system (including the air heater) shall be controlled by a single baghouse and shall pass through a single stack (Emissions Point No. 2K-06). {Permitting Note: The exhaust stack will be no more t han 9.42 feet in diameter and no less than 315 feet tall.} [Rules 62-4.070(3) and 62-210.200(PTE), F.A. C.; Application No. 1210465-014-AC]
2. Hours of Operation : The hours of operation for this emissions unit are not limited (8760 hours per year). [Rule62-210.200(PTE), F.A.C.]
3. Facility Portland Cement Production : The facility shall (Kiln Line Nos. 1 and 2) not produce more than 2,382,720 tons of portland cement during any consecu tive 12 months. [Rule 62-4.070(3), 62-212.200(PTE), and 62-212.400(BACT), F.A.C.]
4. Kiln Process and Production Rate Limitations : The dry preheater feed material rate (excluding dry fly ash injected directly into the calciner) to the kiln shall not exceed 1,789,230 tons during any consecutive 12 months. The clinker production rate of the kiln sha ll not exceed 127 tons per hour (24-hour rolling average) and 1,055,500 tons during any consecutive 12-months. Th e clinker production rate shall be determined by the following equation: Clinker Production = [(Kiln Feed) (Kiln Feed LOI Factor) + (Fly Ash Injection) (Fly Ash LOI Factor)]
Where:

• “Kiln Feed” as determined by kiln feed control system

• “Fly Ash Injection” as determined from the rotary feed system or equivalent.

• The “Kiln Feed LOI Factor” and the “Fly Ash LOI Factor” shall be based on a 30 operating-day block average of daily measurements. For purposes of this requirement, an operating day is any day that the kiln produces clinker or fires fuel. {Permitting Note: For reference, the kiln will be de signed to process approximatel y 215 tons per hour of dry preheater feed material (excluding dry fly ash injected directly in to the calciner) through the kiln.} [Rules 62- 4.070(3) and 62-210.200(PTE), F.A.C.; Application No. 1210465-014-AC]
5. Authorized Fuels : The maximum heat input rate to the pyroprocessing system (kiln and calciner) shall not exceed 364 MMBtu per hour. Only the following authorized fuels shall be fired: coal, petroleum coke, fly ash, gasified tires, whole or chipped tires, natural gas, distillate oil, and/or on-specification used oil fuel.

a. The permittee is authorized to install a tire gasificati on system with an airlock on the feed mechanism. The maximum heat input rate from gasified tires sh all not exceed 40% of the total pyroprocessing heat input rate (kiln and calciner) and shall not exceed 146 MMBtu per hour at any time. The remaining 60% of the total pyroprocessing heat input rate sha ll come from other authorized fuels. The permitteeSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 7 of 21 shall provide details of the gasifier system within 30 days of finalizing the design.
b. The maximum heat input rate from firing whole or chipped tire derived fuel (TDF) shall not exceed 15% of the total pyroprocessing heat input rate (kiln and calciner) and shall not exceed 54.6 MMBtu per hour at any time. The remaining 85% of the total pyroprocessing heat input rate shall be from the firing of other authorized fuels. TDF shall be directly fed into the kiln system at the transition section between the base of the calciner and the point where gases ex it the kiln. The tire feed mechanism shall be designed with an airlock/gate system. Tires sha ll be stored, handled and managed in accordance with the provisions of Chapter 62-711, F.A.C.

c. The firing of “on-specification” used oil fuel shall not exceed 1000 gallons per hour and 1,500,000 gallons during any consecutive 12 months. See Appendix D for “on-specification” used oil fuel requirements.
d. Fly ash may be introduced as a raw material supplemen t or a fuel through either the preheater tower or directly into the calciner. {Permitting Note: “Fly ash” may consist of fly or bottom ash from a power plant.}

e. The air heater shall fire only natural gas with a design maximum heat input rate of 32 MMBtu per hour. The permittee may submit an application for an air cons truction permit requesting authorization to fire other additional fuels (non-hazardous solids and liquids) in th e pyroprocessing system (kiln and calciner). [Rules 62-4.070(3) and 62-210.200(PTE), F.A. C.; Application No. 1210465-014-AC]
6. Prohibited Fuels and Materials : The owner or operator shall not introduce into any part of the process or emission control equipment (i.e., staged combustion in calciner) any of the following fuels and materials: hazardous wastes; petroleum contaminated soil or material s; oil, used oil, or solid fuels other than those allowed by this permit; or solid wastes other than tires as allowed by this permit. [Rule 62-4.070(3), F.A.C.]
7. Cement Kiln Dust : Cement kiln dust shall be recirculated in the process and shall not be directly discharged from process or emission control equipment unless authorized by the Department. Cement kiln dust removed from process equipment during maintenance and repair shall be confined and controlled at all times and shall be managed in accordance with the applicable provisions of 40 CFR 261. [Rule 62- 4.070(3), F.A.C.]
8. Emissions Controls

a. Nitrogen Oxides (NOx) : The kiln system design shall incor porate staged combustion in the calciner (SCC) to reduce NOx emissions. An ammonia-b ased Selective Non-Catalytic Reduction (SNCR) system shall be installed to further control NOx em issions. The SNCR system consists of an ammonia tank, pumps, piping, compressed air delivery, injectors, control system, and other ancillary equipment. Ammonia solutions (i.e., 19% ammonia, urea, etc.) shall be injected at a location with an appropriate temperature profile to support the SNCR process. To prevent excessive ammonia slip, the ammonia injection rate shall not exceed a NH 3 /NOx molar ratio of 1.0. The Title V air operation permit shall specify a maximum ammonia injection rate (gph) that represents a NH 3 /NOx molar ratio of less than 1.0. SCC and/or SNCR shall be used to achieve th e NOx emissions standards specified in this permit.
b. Particulate Matter (PM/PM 10 ) : The permittee shall install a baghouse control system to remove particulate matter emissions from the exhaust gas st ream (kiln/raw mill/clinker cooler) to achieve the PM/PM 10 emissions standards specified in this permit.

c. Sulfur Dioxide (SO 2 ) : The owner or operator shall control SO 2 emissions through design and control of the clinker production process. In addition, the owner or operator shall install a hydrated lime injection system to reduce SO 2 emissions. The hydrated lime injecti on system shall be used as necessary to achieve the SO 2 emissions standards specified in this permit.
d. Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) : The owner or operator shall control CO and VOC emissions through design and contro l of the combustion process with good operatingSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 8 of 21 practices. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
9. O&M Plan for Baghouse : The permittee shall prepare an operation and maintenance (O&M) plan to address the schedule for inspection and preventive maintenan ce of the baghouse control system. The O&M plan shall be submitted to the Compliance Authority prior to expiration of this permit. The permittee shall maintain records of the condition of the control equipment for each inspection and any maintenance activities performed. [Rule 62-4.070(3), F.A.C.]

E MISSION L IMITATIONS AND P ERFORMANCE S TANDARDS 10. Kiln Line No. 2 : Emissions from the pyroprocessing system (including emissions from the air heater) shall not exceed the following emissions standards.

Pollutant Emissions Standards Averaging Time Best Available Control Technology (BACT) - Rule 62-212.400(6), F.A.C.
CO a 2.90 lb/ton of clinker 368.3 lb/ hour 30-day rolling CEMS average
NOx b 1.95 lb/ton of clinker 247.7 lb/ hour 30-day rolling CEMS average
NOx b (Initial Startup) (3.0 lb/ton of clinker) ( 381.0 lb/hour) (30-day rolling CEMS average)
PM/PM 10 c, d 0.10 lb/ton of dry PHFM 21.5 lb/hour Average of three, 1-hour test runs 10% opacity 6-minute block average w/COMS
SO 2 e 0.20 lb/ton of clinker 25.4 lb/ hour 24-hour rolling CEMS average
VOC f 0.12 lb/ton of clinker 15.2 lb/hour 30-day block CEMS average PSD Preconstruction Review Avoidance – Rule 62-212.400(2)(g), F.A.C. Mercury g 117.5 pounds per consecutive 12 months See permit Condition No. 19. State Rule for Portland Cement Plants – Rule 62-296.407, F.A.C. PM (Kiln) d 0.3 lb/ton of dry PHFM Average of three, 1-hour test runs PM (Clinker Cooler) d 0.1 lb/ton of dry PHFM Average of three, 1-hour test runs NSPS Subpart F – 40 CFR 60.62 (See Appendix G in Section 4 of this permit for full requirements.) PM (Kiln) h 0.30 lb/ton of dry PHFM Average of three, 1-hour test runs 20% opacity 6-minute block average w/COMS PM (Clinker Cooler) h 0.10 lb/ton of dry PHFM Average of three, 1-hour test runs 10% opacity 6-minute block average NESHAP Subpart LLL – 40 CFR 63.1343 (See Appendix J in S ection 4 of this permit for full requirements.)
PM i 0.30 lb/ton of dry PHFM Average of three, 1-hour test runs Opacity i 20% opacity 6-minute block average w/COMS
Dioxin/Furan i, j 0.20 ng/dscm (TEQ) @ 7% oxygen Average of three test runs
THC i 50 ppmvd (as propane) @ 7% oxygen 30-day block CEMS average

a. Compliance shall be demonstrated by CO CEMS.
b. Compliance shall be demonstrated by NOx CEMS. For an “initial startup” period, NOx emissions shall not exceed 3.0 lb/ton of clinker (381.0 lb/hour) based on a 30-day rolling average. The “initial startup” period shall begin after initial certification of the NOx CEMS and shall end when any of the following conditions are met:SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 9 of 21 1) The Kiln Line No. 2 system produces 75,000 tons of clinker or more in any 30-day rolling period. 2) The Kiln Line No. 2 system produces 150,000 tons of clinker. 3) 365 days calendar days elapse after initial certification of the NOx CEMS. After the “initial startup” period ends, NOx emissi ons shall not exceed 1.95 lb/ton of clinker (247.7 lb/hour) based on a 30-day rolling average. These re quirements do not waive or vary any applicable NSPS or NESHAP monitoring or record keeping requirements.

c. Compliance with the opacity standard shall be dem onstrated by COMS and/or EPA Method 9. Opacity shall be based on a 6-minute block average computed from at least one observation (measurement) every 15 seconds. For the COMS, the 6-minute block averages shall begin at the top of each hour.
d. “PHFM” means preheater feed material. Complian ce with the particulate matter standard shall be demonstrated based on stack testing conducted in accordance with EPA Method 5. All PM emitted from baghouse exhaust is assumed to be PM 10

. {Permitting Note: The BACT standard is equivalent to approximately 0.17 lb of PM per ton of clinker and includes the clinker cooler emissions. The emissions limits for particulate matter and visible emissions imposed by Rule 62-212.400(BACT) are as stringent as or more stringent than the limits imposed by the applicable NSPS or NESH AP provisions. Neverthele ss, the BACT requirements do not waive or vary any applicable NSPS or NESHAP monitoring or record keeping requirements.}

e. Compliance shall be demonstrated by SO 2 CEMS. f. Compliance shall be demonstrated by THC CEMS. VOC emissions shall be measured as total hydrocarbons (THC) and expressed as “propane” for the mass emissions rate. The 30-day block CEMS average shall be consistent with the averaging period specified in §63.1350(h).
g. The total mass of mercury compounds (expressed as Hg ) introduced into the pyroprocessing system of the raw mill feed and fuels shall not exceed 117.5 pounds during any consecutive 12-month period. Compliance shall be demonstrated using the sampli ng, analysis, and calculation methods specified in permit Condition No. 19.
h. See Appendix G of this permit for the NSPS Subpart F requirements.
i. See Appendix J of this permit for the NESHAP Subpart LLL requirements. j. Alternatively, dioxin/furans shall not exceed 0.40 ng/dscm (TEQ) @ 7% oxygen when the average of the performance test run average temperatures at the in let to the particulate matter control device is 204° C (400° F) or less. {Permitting Note: In combination with the annual raw material process rate limitation of 1,789,230 tons per year and annual clinker production limitation of 1,055,500 tons per year, the above emissions standards effectively limit annual potential emissions to: 89 tons/year of PM/PM 10 ; 106 tons/year of SO 2 ; 1029 tons/year of NOx (after year one); 1530 tons/year of CO; and 63 tons/year of VOC. Note that first year annual NOx emissions could be as high as 1583 tons/year.} [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 11. Excess Emissions : Continuous monitoring data collected during periods of startup, shutdown, and malfunction may be excluded from the compliance demonstrations only in accordance with the following requirements, provided that best operational practices to minimize emissions are adhered to and the duration of excess emissions are minimized. As provided by the authority in Rule 62-210.700(5), F.A.C., the following conditions replace the provisions in Rule 62-210.700(1), F.A.C.

a. Definitions : “Startup” means the commencement of operation of any emissions unit which has shut down or ceased operation for a period of time sufficient to cause temperature, pressure, chemical or pollution control device imbalances, which result in excess emissions. “Shutdown” means the cessation of the operation of an emissions unit for any purpose. “Malfunction” means any unavoidable mechanical and/or electrical failure of air pollution control equipment or process equipment or of a process resulting in operation in an abnormal or unusual manner.SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 10 of 21 b. CO Data : Each 30-day rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited pe riods due to equipment malfunctions. No more than 30 hours in any calendar month shall be excl uded from the compliance determinations due to equipment malfunctions. Malfunctions do not include process upsets that occur as a normal part of cement production.

c. NOx Data : Each 30-day rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited periods due to malfunctions of the SNCR system, which are defined as any unavoidable mechanical and/or electrical failure that prevents introduction of ammonia-based solutions into the kiln system. No more than 30 hours in any calendar month shall be excluded from the compliance determinations due to malfunctions of the SNCR system.
d. SO 2 Data : Each 24-hour rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited pe riods due to malfunctions of the hydrated lime system, which are defined as any unavoidable mechan ical and/or electrical failure that prevents introduction of lime into the kiln system. No more than 30 hours of data in any calendar month shall be excluded from the compliance determinations due to malfunctions of the hydrated lime system.

e. Other Data : All opacity and VOC data shall be in cluded in the compliance determination. Within one working day of occurrence, the owner or operator shall notify the Compliance Authority of any malfunction resulting in the exclusion of CEMS data. Excess emissions caused entirely or in part by poor maintenance, poor operation or any other equipment or process failure that may reasonably be prevented during startup, shutdown or malfuncti on shall be prohibited. All such reasonably preventable emissions shall be included in any CEMS compliance determina tions. All valid emissions data (including data collected during startup, shutdown and malfunction) shall be used to report emissions for the Annual Operating Report. [Rules 62-210.200, 62-212.400(BACT) and 62-210.700, F.A.C.]
C ONTINUOUS M ONITORING R EQUIREMENTS 12. Continuous Emission Monitoring Systems (CEMS) : The permittee shall install, calibrate, operate and maintain CEMS to measure and record concentrations of CO, NOx, SO 2 , and VOC in the kiln system exhaust stack in a manner sufficient to demonstrate continuous compliance with the emissions standards specified in this permit. All continuous monitoring systems and monitoring devices shall be installed and operational prior to conducting initial performance t ests. The permittee shall notify the Compliance Authority within one working day of discovering emi ssions in excess of a CEMS standard subject to the specified averaging period. Each monitoring system sh all be installed, calibrate d, and properly functioning prior to the initial stack tests.

a. CO Monitor. A monitor shall be installed to determine CO emissions from the stack and shall meet the requirements of Performance Specification 4 or 4A in Appendix B of 40 CFR 60. The required RATA tests shall be performed using EPA Method 10 in Appendix A of 40 CFR 60. Quality assurance procedures shall conform to the requirements of Appendix F in 40 CFR 60.
b. NOx Monitor. A monitor shall be installed to determin e NOx emissions from the stack and shall meet the requirements of Performance Specification 2 in Appendix B of 40 CFR 60. The required RATA tests shall be performed using EPA Method 7E in Appendix A of 40 CFR 60. Quality assurance procedures shall conform to the requirements of Appendix F in 40 CFR 60.

c. SO 2 Monitor. A monitor shall be installed to determine SO 2 emissions from the stack and shall meet the requirements of Performance Specification 2 in Appe ndix B of 40 CFR 60. The required RATA tests shall be performed using EPA Method 6C in Appe ndix A of 40 CFR 60. Quality assurance procedures shall conform to the requirements of Appendix F in 40 CFR 60.SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 11 of 21 d. VOC Monitor. A monitor shall be installed to determin e THC emissions from the stack and shall meet the requirements of NESHAP Subpart LLL in 40 CFR 63 (§63.1349 and §63.1350). The THC monitor shall include provisions to determine the moisture c ontent of the exhaust gas and an algorithm to enable correction of the monitoring results to a dry basis (0% moisture). An oxygen monitor shall also be installed at the THC monitor location to correct measured THC emissions to the required oxygen concentration.

e. Emissions Data. Each CEMS shall be designed and operated to sample, analyze, and record data evenly spaced over the hour at a minimum of one measurement per minute. All valid measurements collected during an hour shall be used to calculate a 1-hour bl ock average that begins at the top of each hour. Each 1-hour block average shall be computed using at least one data point in each fifteen-minute quadrant of an hour, where the unit combusted fuel (or produced clinker) during that quadrant of an hour. Notwithstanding this requirement, a 1-hour aver age shall be computed from at least two data points separated by a minimum of 15 minutes. If less th an two such data points are available, there is insufficient data and the 1-hour block average is not valid. Hours during which there is no kiln feed and no fuel fired are not valid hours. The CEMS sha ll express emissions in units of “pounds per ton of clinker produced” and “pounds per hour”. THC emissi ons data shall also be expressed as “ppmvd (as propane) @ 7% oxygen”. f. Emissions Averaging Periods

. 1) SO 2 : Each 24-hour rolling average shall be the ar ithmetic average of the last 24 valid hourly averages. A new 24-hour rolling average shall be recomputed after every valid hour of operation for the new hour and the preceding 23 valid operating hours. 2) CO and NOx: Each 30-day rolling average shall be the arithmetic average of all valid hourly averages collected during the last 30 operating days. A new 30-day rolling average shall be recomputed after every day of operation for the new day and the preceding 29 operating days. 3) VOC: Each 30-day block average shall be the arithmetic average of all valid emissions data collected during the 30-day block of operation. Emissions data shall be collected at least once each minute of operation. A new 30-day block average shall be recomputed based on 30 new days of operation. This averaging period applies only to VOC emissions and shall be consistent with the averaging period specified in §63.1350(h) for THC emissions.
g. Data Exclusion. Except for monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments, each CEMS shall monitor and record emissions during all operations including episodes of startups, shutdowns, and malfunctions. Limited amounts of CEMS emissions data recorded during some of these episodes may be excluded from the corresponding compliance demonstration as provided by Condition No. 11 in this section. Th e permittee shall minimize the duration of data excluded for such episodes to the extent practicable.
h. Availability . Monitor availability for each CEMS shall be 95% or greater in any calendar quarter. Monitor availability shall be reported in the quart erly excess emissions report. In the event 95% availability is not achieved, the permittee shall pr ovide the Department with a report identifying the problems in achieving 95% availability and a plan of corrective actions that will be taken to achieve 95% availability. The permittee shall implement the re ported corrective actions within the next calendar quarter. Failure to take corrective actions or continued failure to achieve the minimum monitor availability shall be violations of this permit, except as otherwise authorized by the Compliance Authority. CEMS are also subject to the General Provisions specified in Subpart A of 40 CFR 60 (CO, NOx, and SO 2 ) and Subpart A of 40 CFR 63 (THC/VOC). [R ules 62-4.070(3), 62-210.800, 62-212.400(BACT) and 62- 297.520, F.A.C.]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 12 of 21 13. Flow Monitoring : To support the CEMS monitoring data, a m onitor shall be installed to determine the representative stack exhaust flow rate in acco rdance with Performance Specification No. PS-6 (Specifications and Test Procedures For Continuous Emission Rate Monitoring Systems in Stationary Sources) in Appendix B of 40 CFR 60. [Rules 62-4.070(3), F.A.C.; Appendix B in 40 CFR 60]
14. Continuous Opacity Monitoring System (COMS) : A COMS shall be installe d, calibrated, operated, and maintained in the kiln system exhaust stack afte r the baghouse in a manner sufficient to demonstrate continuous compliance with the opacity standards speci fied in this permit. The COMS shall meet the applicable requirements of §63.1350. [NESHAP Subpart LLL in 40 CFR 63]
15. CEMS/COMS Certification and Initial Startup : Each CEMS/COMS required by this permit shall be installed prior to startup. Within 60 calendar days of achieving an average daily clinker production rate of 105 tons per hour, but no later than 180 calendar days afte r initial startup, the owner or operator shall certify each CEMS/COMS. Upon certification of each CEMS/C OMS, the owner or operator shall demonstrate compliance with all applicable standards as specifi ed in this permit. [Rules 62-4.070(3), 62-210.800, 62- 212.400(BACT) and 62-297.520, F.A.C.; 40 CFR 60.7( a), 60.13(b) and Appendix B; and 40 CFR 63.7(a)(2)]
16. Baghouse Temperature Monitor : A continuous temperature monitor sha ll be installed, calibrated, operated, and maintained at the inlet to the baghouse for the k iln system exhaust in accordance with the requirements of §63.1350(f). [NESHAP Subpart LLL in 40 CFR 63]
17. Ammonia Injection : A monitoring system to continuously monitor and record the ammonia injection rate of the SNCR system (1-hour block averages) shall be in stalled, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations. [Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
18. Continuous Monitor Data Retrieval System : At its sole expense, the owner or operator shall:

a. Ensure all of the CEMS are operational, recording and continuously transmitting available data to the Compliance Authority.
b. Provide the Compliance Authority with one personal computer equipped with a modem and software (as necessary), and corresponding hardware at the owner’s facility, to enable the Compliance Authority at any time to connect to the CEMS and access the fo llowing: emissions data from the continuous monitors for CO, NOx, SO 2 , and VOC expressed in terms of the units of the emission limiting standards of this permit; opacity data from the COMS; temper ature data from the monitor at the inlet to the baghouse for the in-line kiln/raw mill system; ammoni a injection rate data from the continuous monitor for the SNCR system; dry preheater feed material rate data; and clinker pr oduction rate data. The computer and software shall also: provide a numerical and graphical display of these data in real time pursuant to the averaging requirements of this perm it; allow the Compliance Authority to electronically store, retrieve, and print such data; and allow the Compliance Authority to review the exception log for any previous period of time accessible through the continuous monitor data management system.

c. Post emissions to an Internet web site, accessible to the Compliance Authority and public at any time via standard Internet browser software, the following data on a real-time basis: emissions data from the continuous monitors for CO, NOx, SO 2 , and VOC expressed in terms of the units of the emission limiting standards of this permit; opacity data from th e COMS; temperature data from the monitor at the inlet to the baghouse for the in-line kiln/raw mill system; and ammonia injection rate data from the continuous monitor for the SNCR system. [Rule 62-4.070(3), F.A.C]
C OMPLIANCE T ESTING R EQUIREMENTS 19. Mercury Compliance Demonstration : The owner or operator shall demonstrate compliance with the mercury throughput limitation by material balance and mainta ining records of the monthly and rolling 12-monthSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 13 of 21 mercury throughput. Samples of the raw mill feed, fly ash and all fuels shall be collected each day. A single composite daily sample shall be made from all samples collected during a day. A monthly composite sample shall be made from each of the daily composite samples. Each monthly composite sample shall be analyzed to determine the representativ e mercury concentration for the month. The analytical methods used to determine mercury concentration shall be EPA or ASTM methods such as EPA Method 7471A (Mercury in Solid or Semisolid Waste). No other methods ma y be used unless prior written approval is received from the Department. For samples with levels below the de tection limit, the permittee shall report the detection limit as the corresponding level. For each composite sample, the mercury throughput rate (pounds per month) shall be the product of the mercury concentration from the monthly composite sample and the corresponding monthly processing rate. For each month, the mass of mercury introduced into the pyroprocessing system (pounds per month) shall be the sum of the monthly mercury throughput rates for the raw mill feed, fly ash and fuel. The consecutive 12-m onth mercury throughput rate shall be the sum of the individual monthly records for the current month and the preceding eleven months (pounds of mercury per consecutive 12-months). Such records, including calcula tions and data, shall be completed no later than 25 days following the month of the records. [Rules 62-4.070(3) and 62-212.400(2)(g), F.A.C.]
20. Test Method s : Any required stack tests shall be perform ed in accordance with the following methods.

EPA Method Description of Method and Comments
1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content Methods shall be performed as n ecessary to support other methods.
5 Measurement of Particulate Matter Emissions The minimum sample volume shall be 30 dry standard cubic feet.
6C Measurement of SO 2 Emissions (Instrumental)
7E Measurement of NOx Emissions (Instrumental) NOx emissions testing shall be conducted with the air heater operating at the highest heat input possible during the test.
9 Visual Determination of the Opacity
10 Measurement of Carbon Monoxide Emissions (Instrumental) The method shall be based on a continuous sampling train.
19 Calculation Method for NOx, PM, and SO2 Emission Rates
23 Measurement of Dioxin/Furan Emissions
25A Measurement of Gaseous Organic Concentrations (Flame Ionization – Instrumental) The methods are specified in Appendix A of 40 CFR 60, adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written appr oval is received from the Department. Tests shall be conducted in accordance with the appropriate test method and the applicable requirements specified in Appendix C of this permit, NSPS Subparts A and F in 40 CFR 60, and NESHAP Subparts A and LLL in 40 CFR 63. [Rules 62-204.800, F.A.C.; 40 CFR 60, Appendix A]
21.SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 14 of 21 Initial and Subsequent Tests

a. Pollutants : In accordance with the test methods specified in this permit, the kiln system exhaust stack shall be tested to demonstrate compliance with the emission standards for particulate matter and dioxins/furans. Compliance with the permit standards for opacity and emissions of CO, NOx, SO 2 , and VOC shall be demonstrated with data collected from the required continuous monitoring systems. Compliance with the mercury throughput limitation sh all be demonstrated in accordance with the sampling, analysis, and record keeping requirements specified in Condition No. 19 of this permit. The permittee shall provide the Compliance Authority with any initial emissions performance tests conducted to satisfy vendor guarantees.
b. Deadline for Tests : Initial compliance stack tests shall be conducted within 60 days after achieving a daily average clinker production rate of 105 tons pe r hour, but not later than 180 days after the initial startup. Subsequent annual compliance stack tests for particulate matter shall be conducted during each federal fiscal year (October 1 st to September 30 th ). Subsequent dioxins/furans tests shall be conducted in accordance with the provisions of §63.1349 a nd Condition No. 22 of this subsection.

c. Test Conditions : Initial tests shall be conducted betw een 90% and 100% of permitted capacity; otherwise, this permit shall be modified to re flect the true maximum capacity as constructed. Subsequent annual tests shall be conducted between 90% and 100% of permitted capacity in accordance with the requirements of Rule 62-297.310(2), F.A. C. Tests shall be conducted for each required pollutant under the fuel scenario representing the highest potential for generating emissions. In general, this fuel scenario is firing coal as the primary fu el and firing tires, petroleum coke, and fly ash as secondary fuels. If a secondary fuel listed above is not available at the time of testing, tests shall be based on the fuels that are available. If a secondary fuel is added later, additional tests shall be conducted with that fuel scenario within 60 da ys of first fire of the new secondary fuel.
d. Monitoring Data : CEMS and COMS data shall be reported and summarized for each required test run. [Rules 62-212.400(5)(c) and 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8]
22. Supplemental Dioxin/Furan and PM/PM 10 Tests : The owner or operator shall notify the Compliance Authority prior to initiating any significant change in th e feed or fuel used in the most recent satisfactory compliance performance test for dioxin/furan or PM/PM 10 . For purposes of this condition, significant means any of the following: a physical or chemical change in the feed or fuel ; the use of a raw material not previously used; a change in the LOI of the fly ash; a change between non-beneficiated fly ash and beneficiated fly ash. Based on the information provide d, the Compliance Authority will promptly determine if performance testing pursuant to §63.1349 will be require d for the new feed or fuel. A significant change shall not include switching to a feed/fuel mix for whic h the permittee already tested in compliance with the dioxin/furan and PM/PM 10 emission limits. [62-4.070(3), F.A.C.]
23. Special Compliance Tests : When the Department, after investig ation, has good reason (such as complaints, increased visible emissions or questionable maintenance of control equipment) to believe that any applicable emission standard contained in a Department rule or in a permit issued pursuant to those rules is being violated, it shall require the owner or operator of the emissions unit to conduct compliance tests which identify the nature and quantity of pollutant emissions from the emissions unit and to provide a report on the results of said tests to the Department. [Rule 62-297.310(7)(b), F.A.C.]

R EPORTING AND R ECORD K EEPING R EQUIREMENTS 24. Operational Records : To demonstrate compliance with the limitati ons specified in this section, the owner or operator shall maintain the following records on site.

a. For each 1-hour block of operation, continuously mon itor and record: the dry preheater feed rate, clinker production rate, fuel firing rate, heat input rate (as determined by the representative heating value of each fuel and the hourly fuel firing rate), and NH 3 /NOx molar ratio or ammonia injection rate.SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS A. Kiln Line No. 2 System

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 15 of 21 Records shall also document the dry preheater feed rate and clinker production rates for each 24-hour rolling period and consecutive 12 months.
b. No later than the 10th day of the following month, calculate and record the cement production rate (tons per month and tons per consecutive 12 months).

c. For each fuel delivery, maintain reco rds of the quantity of fuel delivered and a representative analysis of the fuel. Records shall include the sulfur content, higher and lower heating value, proximate analysis, and ultimate analyses.
d. Maintain records demonstrating compliance with the mercury throughput limitation as required in Condition No. 19 of this permit.

e. Maintain the following records for each equipment malfunction resulting in excluded monitoring data: date and time of event, duration of event, suspected cause of event, and any corrective actions taken. All records shall be made available to the Depart ment and Compliance Authority upon request. [Rules 62- 4.070(3) and 62-212.400(BACT), F.A.C.]
25. Stack Test Reports : The owner or operator of an emissions unit for which a compliance test is required shall file a report with the Compliance Authority on the results of each such test. The required test report shall be filed with the Compliance Authority as soon as practical but no later than 45 days after the last sampling run of each test is completed. The test report shall provi de sufficient detail on the emissions unit tested and the test procedures used to allow the Compliance Authority to determine if the test was properly conducted and the test results properly computed. As a minimum, th e test report, other than for an EPA or DEP Method 9 test, shall provide the specified in Rule 62-297.310(8), F.A.C. [Rule 62-297.310(8), F.A.C.]
26. Malfunction Notifications : If temporarily unable to comply with any condition of the permit due to breakdown of equipment (malfunction) or destructi on by hazard of fire, wind or by other cause, the permittee shall immediately (within one working day) notify the Compliance Authority. Notification shall include pertinent information as to the cause of the pr oblem, and what steps are being taken to correct the problem and to prevent its recurrence, and where applicable, the owner’s intent toward reconstruction of destroyed facilities. Such notification does not release the permittee from any liability for failure to comply with Department rules. If requested by the Comp liance Authority, the owner or operator shall submit a quarterly written report describing the malfuncti on. [Rules 62-210.700(6) and 62-4.130, F.A.C.]
27. Quarterly Report : Within 30 days following the end of each calendar quarter, the permittee shall submit a report to the Compliance Authority summarizing: equipment malfunctions resulting in excluded CEMS data; mercury throughput rates; and the monitor availa bility of each CEMS. The report shall contain the information and follow the general format specified in Appendix F of this permit. [Rules 62-4.070(3), 62- 4.130, and 62-212.400(BACT), F.A.C.]

NSPS SUBPART F OF 40 CFR 60 - PORTLAND CEMENT PLANTS
28. NSPS Subpart F : The affected emissions units are subject to the applicable requirements for Portland Cement Plants specified in NSPS Subpart F of 40 CFR 60. For the full NSPS provisions, see Appendix G in Section 4 of this permit. [40 CFR 60, Subparts A and F]

NESHAP SUBPART LLL OF 40 CFR 63 - PORTLAND CEMENT MANUFACTURING INDUSTRY
29. NESHAP Subpart LLL : The affected emissions units are subject to the applicable requirements for the Portland Cement Manufacturing Industry specified in NESHAP Subpart LLL of 40 CFR 63. For the full NESHAP provisions, see Appendix J in Section 4 of this permit. [40 CFR 63, Subparts A and LLL]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS B. Primary Crusher

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 16 of 21 The specific conditions of this subsection apply to the following emissions unit after construction is complete.

ID Emission Unit Description
001 (Existing) Primary crusher and associated belt conveyors
{Permitting Note: This emissions unit is subject to th e following applicable requirement s: NSPS Subpart A (General Provisions) and NSPS Subpart OOO (Nonmetallic Mineral Processing Plants) in 40 CFR 60. It was originally constructed in accordance with Permit No. PSD-FL-259. For this unit, the emissions limiting and performance standards specified in this section also satisfy the requirements of Best Available Control Technology (BACT) in Rule 62-212.400, F.A.C.} PERFORMANCE REQUIREMENTS
1. Hours of Operation : The hours of operation of this emissions unit are not limited (8760 hours per year). [Rule62-210.200(PTE), F.A.C.]
2. Process Rate Limitation : The crusher shall not process more than 3,450,000 tons of raw materials during any consecutive 12 months. The permittee shall mainta in written records of the monthly processing rate. Such records shall be recorded a nd available for inspection no later than 10 days following the end of the month. {Permitting Note: The process rate is based on an estimated raw materials moisture content of 15% by weight and includes the weight of this moisture. This is an increase of 1,771,000 tons per year over the existing annual crushing capacity of 1,679,000 tons per year.} [Rules 62-210.200(PTE) and 62-4.070(3), F.A.C.]
3. Opacity Standards : As determined in accordance with EPA Method 9 observations:

a. Visible emissions from any crusher, at which a cap ture system is not used, shall not exceed 15% opacity.
b. Visible emissions from any transfer point on belt conveyors or from any other affected facility shall not exceed 10% opacity. These opacity standards do not apply to truck dum ping of nonmetallic minerals into any screening operation, feed hopper, or crusher. [Rule 62-212.400(BACT), F.A.C.] TESTING REQUIREMENTS
4. Visible Emissions Tests : The permittee shall demonstrate compliance with the visible emission limits specified in this subsection by conducting tests in accordance with EPA Method 9. Initial tests shall be conducted within 60 days after achieving the maximum production rate at which th e unit will be operated, but not later than 180 days after initial startup. Thereafter, the permittee shall demonstrate compliance during each federal fiscal year (October 1 st to September 30 th ) for the primary crusher. Tests shall be conducted in accordance with the applicable require ments in Appendix C of this permit as well as the applicable NSPS. {Permitting Note: Unless requested by the Comp liance Authority, annual compliance tests for the conveyors are not required.} [Rules 62-297.310(7)(a), F.A.C.]
5. Test Reports . For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the Depa rtment as soon as practical, but no later than 45 days after the last sampling run of each test is completed. [Rules 62-297.310(8), F.A.C.]
NSPS SUBPART OOO OF 40 CFR 60 - NONMETALLIC MINERAL PROCESSING PLANTS

6. NSPS Subpart OOO : The affected emissions units are subj ect to the applicable requirements for Nonmetallic Mineral Processing Plants specified in NSPS Subpart OOO of 40 CFR 60. For the full NSPS provisions, see Appendix I in Section 4 of this permit. [40 CFR 60, Subparts A and OOO]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS C. Miscellaneous PM Sources – Handling/Storage of Raw Materials and Clinker

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 17 of 21 This section of the permit addresses the following emissions unit.

ID Emission Unit Description
003 (Existing) Raw material processing - unenc losed conveyor transfer points (D conveyors) (New) Clinker and cement processing with the following emissions points:
Point ID No. Description

L-03-02 Baghouse for clinker pan conveyor
L-06-02 Baghouse for clinker silo inlet
L-25-02 Baghouse for gypsum/off-specification clinker transport
M-08-02 Baghouse for clinker silo outlet conveyor
M-09-02 Baghouse for gypsum/off-spec. clinker silo outlet
N-09-02 Baghouse for finish mill separator (1)
N-12-02 Baghouse for finish mill vent (2)
N-36-02 Baghouse for fringe cement bin
N-91-02 Baghouse for finish mill (3)
P-03-02 Baghouse for cement transport conveyor
P-11-02 Baghouse for cement silos 011

Q-17-02 Baghouse for cement truck load out No. 3 (New) Baghouses for raw material processing
Point ID No. Description
E28-02 Baghouse for raw mill
E34-02 Baghouse for off-specification feed handling
G07-02 Baghouse for homogenizing silo
H08-02 Baghouse for Poldos homogenizing silo
H08A-02 Baghouse for hydrated lime silo 014

U-05-02 Baghouse for fly ash silo
{Permitting Note: These emissions units are subject to the following applicable requireme nts: NSPS Subpart A (General Provisions) and NSPS Subpart F (Portland Cement Plants) in 40 CFR 60; NESHAP Subpart A (General Provisions) and NESHAP Subpart LLL (Portland Cement Manufactu ring Industry) in 40 CFR 63. EU- 003 was originally constructed in accordance with Permit No. PSD-FL-259. For new units EU-011 and EU-014, the emissions limiting and performance standards specified in this section also sa tisfy the requirements of Best Availabl e Control Technology (BACT) in Rule 62- 212.400, F.A.C.} PERFORMANCE REQUIREMENTS
1. Hours of Operation : The hours of operation of this emissions unit are not limited (8760 hours per year). [Rule62-210.200(PTE), F.A.C.]
2. Baghouse Controls (EU-011 and EU-014) : Each emissions point identified for clinker and cement processing (EU-011) and raw material processing (EU-014) shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a particulate matter design specification of 0.0085 grains/dscf. For each new ba ghouse, the permittee shall prepare an operation and maintenance (O&M) plan to address: proper operation; parametric monitoring; and a regular schedule for conducting periodic inspections and preventive main tenance. Baghouse inspections and maintenanceSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS C. Miscellaneous PM Sources – Handling/Storage of Raw Materials and Clinker

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 18 of 21 activities shall be recorded in a written log. The O& M plan shall be submitted to the Compliance Authority prior to expiration of this permit. [R ules 62-4.070(3) and 62-212.400(BACT), F.A.C.]
3. Particulate Matter Standard : For Emissions Point N-09-02 of Emissions Unit 011, particulate matter emissions shall not exceed 0.0085 grains/dscf based on a performance test conducted in accordance with EPA Method 5. {Permitting Note: This emissions point is cont rolled by the largest baghouse of the group with a design flow rate of nearly 130,000 acfm.} [Rule 62-212.400(BACT), F.A.C.]
4. Opacity Standards : As determined in accordance with EPA Method 9 observations, the following standards apply to each emissions point of Emissions Units 003, 011, and 014 including the finish mill system, raw mill, raw material storage, clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems.

a. Visible emissions from each baghouse exhaust point shall not exceed 5% opacity, and b. Visible emissions from any emissions point not controlled by a baghouse (i.e., conveyors) shall not exceed 10% opacity. [Rule 62-212.400(BACT), F.A.C.] TESTING REQUIREMENTS
5. Particulate Matter Tests : The permittee shall demonstrate compliance with the particulate matter emission standard specified for Emissions Point N-09-02 of Emissions Unit 011 by conducting tests in accordance with EPA Method 5. Initial tests shall be conduc ted within 60 days after achieving the maximum production rate at which the unit w ill be operated, but not later than 180 days after initial startup. Thereafter, the permittee shall demonstrate compliance during 12 months prior to renewal of the operation permit. Tests shall be conducted in accordance with the applicable requirements in Appendix C of this permit as well as applicable NSPS and NESHAP provisions. [Rules 62-297.310(7)(a), F.A.C.]

6. Visible Emissions Tests : The permittee shall demonstrate compliance with the visible emission limits specified in this subsection by conducting EPA Method 9 tests. The initial tests shall be conducted within 60 days after achieving the maximum production rate at wh ich the affected facility will be operated, but not later than 180 days after initial startup of such f acility. Thereafter, the permittee shall demonstrate compliance during each federal fiscal year (October 1 st to September 30 th ). Tests shall be conducted in accordance with the applicable requirements in Appe ndix C of this permit as well as the applicable NSPS and NESHAP provisions. [Rules 62-297.310(7)(a), F.A.C.]
7. Test Reports : For each test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the Depa rtment as soon as practical, but no later than 45 days after the last sampling run of each test is completed. [Rules 62-297.310(8), F.A.C.]

NSPS SUBPART F OF 40 CFR 60 - PORTLAND CEMENT PLANTS
8. NSPS Subpart F : The affected emissions units are subject to the applicable requirements for Portland Cement Plants specified in NSPS Subpart F of 40 CFR 60. For the full NSPS provisions, see Appendix G in Section 4 of this permit. [40 CFR 60, Subpart F]

NESHAP SUBPART LLL OF 40 CFR 63 - PORTLAND CEMENT MANUFACTURING INDUSTRY
9. NESHAP Subpart LLL : The affected emissions units are subject to the applicable requirements for the Portland Cement Manufacturing Industry specified in NESHAP Subpart LLL of 40 CFR 63. For the full NESHAP provisions, see Appendix J in Section 4 of this permit. [40 CFR 63, Subparts A and LLL]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS D. Coal Mill and Conveying Equipment

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 19 of 21 The specific conditions of this subsection apply to the following emissions unit.

ID No. Emissions Unit Description

009 (Existing) Unenclosed coal conveying equipment (New) Coal mill and coal transfer system with the following emissions points:
Point ID No. Description
S-17-02 Baghouse for coal mill (1 and 2) 012

S-21-02 Baghouse for pulverized coal bin
{Permitting Note: The above emissions units are subject to the following applicable require ments in 40 CFR 60: NSPS Subpart A (General Provisions) and NSPS Subpart Y (Coal Pr eparation Plants). Some equipment was originally constructed pursuant to Permit No. PSD-FL-259. The units ar e also subject to the Best Available Control Technology (BACT) requirements in Rule 62-212.400, F. A.C. as specified in this section.}
PERFORMANCE REQUIREMENTS
1. Hours of Operation : The hours of operation for this emissions unit are not limited (8760 hours per year). [Rule62-210.200(PTE), F.A.C.]
2. Process Rate Limitation : This permit authorizes construction of a new coal mill, which shall not crush more than 150,000 tons of coal and/or petroleum coke (combined) during any consecutive 12 months. The permittee shall maintain written records of the monthly processing rate. Such records shall be recorded and available for inspection no later than 10 days fo llowing the end of the month. [Rule 62-210.200(PTE), F.A.C.]
3. Baghouse Controls (EU-012) : Each emissions point associated with the coal mill and coal transfer station (EU-012) shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a particulate matter design specification of 0.0085 grains per dscf. For each new baghouse, the permittee shall prepare an operation a nd maintenance (O&M) plan to address: proper operation; parametric monitoring; and a regular sche dule for conducting periodic inspections and preventive maintenance. Baghouse inspections and maintenance ac tivities shall be recorded in a written log. The O&M plan shall be submitted to the Compliance Author ity prior to expiration of this permit. [Rules 62- 4.070(3) and 62-212.400(BACT), F.A.C.]
4. Particulate Matter Standards : As determined by EPA Method 5, particulate matter emissions from any thermal dryer shall not exceed 0.0085 grains per dscf of exhaust. “Thermal dryer” means any facility in which the moisture content of bituminous coal is redu ced by contact with a heated gas stream which is exhausted to the atmosphere. [Rules 62-212.400(BACT), F.A.C.]
5. Opacity Standards : As determined by EPA Method 9:

a. Visible emissions shall not exceed 5% opacity from any emissions point controlled by a baghouse. b. Visible emissions shall not exceed 20% opacity from any coal processing and conveying equipment or coal storage system. [Rule 62-212.400(BACT), F.A.C.]
TESTING REQUIREMENTS

6. Particulate Matter Tests (EU-012) : The permittee shall conduct the st ack tests in accordance with EPA Method 5 to demonstrate initial compliance with the par ticulate matter emissions standard for any coal mill thermal dryer. Initial tests shall be conducted with in 60 days after achieving the maximum production rate at which the unit will be operated, but not later than 180 days after initial startup. Thereafter, the permittee shall demonstrate compliance during 12 months prior to renewal of the operation permit. Tests shall beSECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS D. Coal Mill and Conveying Equipment

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 20 of 21 conducted in accordance with the applicable requirement s in Appendix C of this permit as well as applicable NSPS and NESHAP provisions. [Rules 62-212.400(BACT), 62-297.310(7)(a), F.A.C.]
7. Visible Emissions Tests (EU-009 and EU-012) : The permittee shall demonstrate compliance with the visible emission limits specified in this subsection by conducting test in accordance with EPA Method 9. Initial tests shall be conducted within 60 days after achieving the maximum production rate at which the unit will be operated, but not later than 180 days after initial startup. Thereafter, the permittee shall demonstrate compliance during each federal fiscal year (October 1 st to September 30 th ). Tests shall be conducted in accordance with the applicable requirements in Appe ndix C of this permit as well as the applicable NSPS (initial tests). For each test conducted, the permitt ee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the Depa rtment as soon as practical, but no later than 45 days after the last sampling run of each test is completed. [Rules 62-297.310(7)(a), F.A.C.]
8. Test Reports : For each test conducted, permittee shall file a test report including the information specified in Rule 62-297.310(8), F.A.C. with the Department as soon as practical, but no later than 45 days after the last sampling run of each test is completed. [Rules 62-297.310(8), F.A.C.]

NSPS SUBPART Y OF 40 CFR 60 - COAL PREPARATION PLANTS
9. NSPS Subpart Y : The affected emissions units are subject to the applicable requirements for Coal Preparation Plants specified in NSPS Subpart Y of 40 CFR 60. For the full NSPS provisions, see Appendix H in Section 4 of this permit. [40 CFR 60, Subparts A and Y]SECTION 3. EMISSIONS UNIT SPECIFIC CONDITIONS E. Miscellaneous Fugitive Emissions Sources

Suwannee American Cement, LLC Project No. 1210465-014-AC Branford Cement Plant, Kiln Line No. 2 System Air Permit No. PSD-FL-352 Page 21 of 21 The following specific conditions apply to the following emissions units after construction.

ID No. Emissions Unit Description

015 (New) Storage Piles, Paved Roads and Unpaved Roads

P ERFORMANCE R EQUIREMENTS
1. Unconfined Emissions of Particulate Matter

a. No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from any activity without taking reasonable precautions to prevent such emissions. Such activities include, but are not limited to: vehicular movement; transpor tation of materials; construction, alteration, demolition or wrecking; or industrially related activiti es such as loading, unloading, storing or handling.
b. Reasonable precautions shall include the following: (1) Landscaping and planting of vegetation. (2) Application of water to control fugitive dus t from activities such as demolition of buildings, grading roads, construction, and land clearing. (3) Water supply lines, hoses and sprinklers shall be locat ed near all stockpiles of raw materials, coal, and petroleum coke. (4) All plant operators shall be trained in basic e nvironmental compliance and shall perform visual inspections of raw materials, coal and petroleu m coke periodically and before handling. If the visual inspections indicate a lack of surface mo isture, such materials shall be wetted with sprinklers. Wetting shall continue until the poten tial for unconfined particulate matter emissions are minimized. (5) Water spray shall be used to wet the materials a nd fuel if inherent moisture and moisture from wetting the storage piles are not sufficient to prevent unconfined particulate matter emissions. (6) As necessary, applications of asphalt, water, or dust suppressants to unpaved roads, yards, open stockpiles and similar activities. (7) Paving of access roadways, parking areas, and manufacture area. (8) Removal of dust from buildings, roads, and othe r paved areas under the control of the owner or operator of the facility to prevent particulate matter from becoming airborne. (9) A vacuum sweeper shall be used to remove dust from paved roads, parking, and other work areas. (10) Enclosure or covering of conveyor systems where practicably feasible. (11) All materials, coal, and petroleum coke shall be stored under roof on compacted clay or concrete, or in enclosed vessels. (12) Use of hoods, fans, filters, and similar equipment to contain, capture and/or vent particulate matter. (13) Confining abrasive blasting where possible.

c. In determining what constitutes reasonable precautions for a particular source, the Department shall consider the cost of the control technique or work practice, the environmental impacts of the technique or practice, and the degree of reduction of emissions expected from a particular technique or practice. [Rules 62-212.400(BACT) and 62-296.320(4)(c), F.A.C.]