Air Permit No. PSD-FL-352 

Project No. 1210465-014-AC 

New Kiln Line No. 2 System

Permit Expires: February 15, 2010

PERMITTEE: 

Suwannee American Cement, L.L.C. 

Branford Cement Plant 

5117 US Highway 27 

Branford, FL 32008 

Authorized Representative: 

Tom Messer, Plant Manager 

FACILITY AND LOCATION 

Suwannee American Cement, LLC operates an existing portland cement manufacturing 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 permit authorizes the construction of a second dry process, preheater/precalciner kiln system with in-line 

raw mill at the existing plant. The permit 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 Administrative Code 

(F.A.C.). The permittee is authorized to perform the proposed work in accordance with the conditions of this 

permit and as described in the application, approved drawings, plans, and other documents on file with the 

Department. 

___________________________________ 

Michael G. Cooke, Director 

Division of Air Resource Management 

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 manufacturing plant, the associated quarry, and raw material 

and cement handling operations. The plant combines raw materials and utilizes a preheater/calciner kiln system 

with inline mill to produce cement clinker. The clinker is milled and combined with gypsum to produce 

portland cement. The existing plant has a capacity of 210 tons per hour of dry preheater feed materials, 120 tons 

per hour of clinker production, and 150 tons per hour of portland cement 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 production; and 1,191,360 tons per year of portland cement production. Fuel 

authorized for the pyroprocessing system includes natural gas, coal, petroleum coke, and whole or chipped tires. 

The plant also operates a coal processing operation to crush 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 source in accordance with Chapter 213, F.A.C. 

PSD: The cement plant is a PSD-major facility in accordance 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 the 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 (General 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 unenclosed 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/precalciner 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 tons per hour of dry preheater feed materials; 127 tons 

per hour of clinker production; and 175 tons per hour of portland cement production. 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/PM10), sulfur 

dioxide (SO2), 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 Selective 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, chipped, or gasified tires). The plant will also include a 

coal processing operation designed to crush coal and petroleum 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 Provisions – 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 applications 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 sources 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 Section 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); 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 Provisions - Portland 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 accordance 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 procedures 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 invalid 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 continue 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 (BACT) for emissions units regulated by the project. 

For good cause, the permittee may request that this PSD air construction permit be extended. Such a request 

shall be submitted to the Department’s Bureau of Air 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 which 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 in 
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 5 of 21 

any federally enforceable limitation on the capacity of the 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 preconstruction 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 Title V operation permit is required 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 Northeast 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/precalciner rotary kiln with in-line raw mill 

{Permitting Note: This emissions unit is subject to the following applicable requirements: 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 Manufacturing 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.} 

PERFORMANCE REQUIREMENTS

1. Kiln Line No. 2: The permittee is authorized to install a second pyroprocessing system consisting of a dry 

process pre-heater/precalciner rotary kiln with in-line raw mill, clinker cooler, air heater (associated with 

raw mill), exhaust stack and other ancillary equipment subject to the capacities and maximum process rates 

specified in this permit. All exhaust from the pyroprocessing 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 than 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 consecutive 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 shall not exceed 127 tons per hour (24-hour rolling average) 

and 1,055,500 tons during any consecutive 12-months. The 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 designed to process approximately 215 tons per hour of dry 

preheater feed material (excluding dry fly ash injected directly into 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 gasification system with an airlock on the feed mechanism. 

The maximum heat input rate from gasified tires shall 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 shall come from other authorized fuels. The permittee 
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 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 exit the kiln. The tire feed mechanism shall be 

designed with an airlock/gate system. Tires shall 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 supplement 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 construction permit requesting authorization to fire other 

additional fuels (non-hazardous solids and liquids) in the 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 materials; 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 incorporate staged combustion in the calciner 

(SCC) to reduce NOx emissions. An ammonia-based Selective Non-Catalytic Reduction (SNCR) 

system shall be installed to further control NOx emissions. 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 NH3/NOx molar ratio of 1.0. The Title V air operation permit shall 

specify a maximum ammonia injection rate (gph) that represents a NH3/NOx molar ratio of less than 

1.0. SCC and/or SNCR shall be used to achieve the NOx emissions standards specified in this permit. 

b. Particulate Matter (PM/PM10): The permittee shall install a baghouse control system to remove 

particulate matter emissions from the exhaust gas stream (kiln/raw mill/clinker cooler) to achieve the 

PM/PM10 emissions standards specified in this permit. 

c. Sulfur Dioxide (SO2): The owner or operator shall control SO2 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 SO2 emissions. The hydrated lime injection system shall be used as necessary to 

achieve the SO2 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 control of the combustion process with good operating 
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 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 maintenance 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.] 

EMISSION LIMITATIONS AND PERFORMANCE STANDARDS

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/PM10 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 

SO2

 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 Section 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 emissions shall not exceed 1.95 lb/ton of clinker (247.7 

lb/hour) based on a 30-day rolling average. These requirements do not waive or vary any applicable 

NSPS or NESHAP monitoring or record keeping requirements. 

c. Compliance with the opacity standard shall be demonstrated 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. Compliance 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 PM10. {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 NESHAP provisions. Nevertheless, the BACT requirements do 

not waive or vary any applicable NSPS or NESHAP monitoring or record keeping requirements.}

e. Compliance shall be demonstrated by SO2 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 sampling, 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 inlet 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/PM10; 106 tons/year of SO2; 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 periods due to equipment malfunctions. No more 

than 30 hours in any calendar month shall be excluded 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. SO2 Data: Each 24-hour rolling average shall include all periods of operation (including startup, 

shutdown, and malfunction), but may exclude limited periods due to malfunctions of the hydrated lime 

system, which are defined as any unavoidable mechanical 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 included 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 malfunction shall be prohibited. All such reasonably preventable emissions 

shall be included in any CEMS compliance determinations. 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.] 

CONTINUOUS MONITORING REQUIREMENTS

12. Continuous Emission Monitoring Systems (CEMS): The permittee shall install, calibrate, operate and 

maintain CEMS to measure and record concentrations of CO, NOx, SO2, 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 tests. The permittee shall notify the Compliance 

Authority within one working day of discovering emissions in excess of a CEMS standard subject to the 

specified averaging period. Each monitoring system shall be installed, calibrated, 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 determine 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. SO2 Monitor. A monitor shall be installed to determine SO2 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 6C in Appendix 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 determine 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 content 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 block 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 average shall be computed from at least two data 

points separated by a minimum of 15 minutes. If less than 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 shall express emissions in units of “pounds per ton of 

clinker produced” and “pounds per hour”. THC emissions data shall also be expressed as “ppmvd (as 

propane) @ 7% oxygen”. 

f. Emissions Averaging Periods. 

1) SO2: Each 24-hour rolling average shall be the arithmetic 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. The 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 quarterly excess emissions report. In the event 95% 

availability is not achieved, the permittee shall provide 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 reported 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 SO2) 

and Subpart A of 40 CFR 63 (THC/VOC). [Rules 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 monitor shall be installed to determine the 

representative stack exhaust flow rate in accordance 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 installed, calibrated, operated, and 

maintained in the kiln system exhaust stack after the baghouse in a manner sufficient to demonstrate 

continuous compliance with the opacity standards specified 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 after initial startup, the owner or operator shall certify 

each CEMS/COMS. Upon certification of each CEMS/COMS, the owner or operator shall demonstrate 

compliance with all applicable standards as specified 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 shall be installed, calibrated, operated, 

and maintained at the inlet to the baghouse for the kiln 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 installed, 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 following: emissions data from the continuous 

monitors for CO, NOx, SO2, and VOC expressed in terms of the units of the emission limiting standards 

of this permit; opacity data from the COMS; temperature data from the monitor at the inlet to the 

baghouse for the in-line kiln/raw mill system; ammonia injection rate data from the continuous monitor 

for the SNCR system; dry preheater feed material rate data; and clinker production 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 permit; 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, SO2, and VOC expressed in terms of the units of the emission 

limiting standards of this permit; opacity data from the 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] 

COMPLIANCE TESTING REQUIREMENTS

19. Mercury Compliance Demonstration: The owner or operator shall demonstrate compliance with the mercury 

throughput limitation by material balance and maintaining records of the monthly and rolling 12-month 
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 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 representative 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 may be used unless prior written approval is received from 

the Department. For samples with levels below the detection 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-month 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 calculations 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 Methods: Any required stack tests shall be performed 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 necessary to support other methods. 

5 Measurement of Particulate Matter Emissions 

The minimum sample volume shall be 30 dry standard cubic feet. 

6C Measurement of SO2 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 approval 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, SO2, and 

VOC shall be demonstrated with data collected from the required continuous monitoring systems. 

Compliance with the mercury throughput limitation shall 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 per 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 1st to September 30th). Subsequent dioxins/furans tests shall be conducted in 

accordance with the provisions of §63.1349 and Condition No. 22 of this subsection. 

c. Test Conditions: Initial tests shall be conducted between 90% and 100% of permitted capacity; 

otherwise, this permit shall be modified to reflect 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 fuel 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 days 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/PM10 Tests: The owner or operator shall notify the Compliance 

Authority prior to initiating any significant change in the feed or fuel used in the most recent satisfactory 

compliance performance test for dioxin/furan or PM/PM10. 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 provided, the Compliance Authority will promptly determine 

if performance testing pursuant to §63.1349 will be required for the new feed or fuel. A significant change 

shall not include switching to a feed/fuel mix for which the permittee already tested in compliance with the 

dioxin/furan and PM/PM10 emission limits. [62-4.070(3), F.A.C.] 

23. Special Compliance Tests: When the Department, after investigation, 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.] 

REPORTING AND RECORD KEEPING REQUIREMENTS

24. Operational Records: To demonstrate compliance with the limitations specified in this section, the owner or 

operator shall maintain the following records on site. 

a. For each 1-hour block of operation, continuously monitor 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 NH3/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 records 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 Department 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 provide 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, the 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 destruction 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 problem, 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 Compliance Authority, the owner or operator shall submit a 

quarterly written report describing the malfunction. [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 availability 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 the following applicable requirements: 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 maintain written records of the monthly processing rate. 

Such records shall be recorded and 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 capture 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 dumping 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 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 1st to September 30th) for the primary crusher. Tests shall be 

conducted in accordance with the applicable requirements in Appendix C of this permit as well as the 

applicable NSPS. {Permitting Note: Unless requested by the Compliance 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 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 OOO OF 40 CFR 60 - NONMETALLIC MINERAL PROCESSING PLANTS 

6. NSPS Subpart OOO: The affected emissions units are subject 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 - unenclosed 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 requirements: 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 Manufacturing 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 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. 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 baghouse, 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 maintenance. Baghouse inspections and maintenance 
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 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. [Rules 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 controlled 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 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 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 which the affected facility will be operated, but not 

later than 180 days after initial startup of such facility. Thereafter, the permittee shall demonstrate 

compliance during each federal fiscal year (October 1st to September 30th). Tests shall be conducted in 

accordance with the applicable requirements in Appendix 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 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 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 requirements in 40 CFR 60: NSPS 

Subpart A (General Provisions) and NSPS Subpart Y (Coal Preparation Plants). Some equipment was originally 

constructed pursuant to Permit No. PSD-FL-259. The units are 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 following 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 and maintenance (O&M) plan to address: proper 

operation; parametric monitoring; and a regular schedule for conducting periodic inspections and preventive 

maintenance. Baghouse inspections and maintenance 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. [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 reduced 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 stack tests in accordance with EPA 

Method 5 to demonstrate initial compliance with the particulate matter emissions standard for any coal mill 

thermal dryer. 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 12 months prior to renewal of the operation permit. Tests shall be 
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 20 of 21 

conducted in accordance with the applicable requirements 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 1st to September 30th). Tests shall be conducted in 

accordance with the applicable requirements in Appendix C of this permit as well as the applicable NSPS 

(initial tests). 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 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(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 

PERFORMANCE REQUIREMENTS

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; transportation of materials; construction, alteration, 

demolition or wrecking; or industrially related activities 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 dust from activities such as demolition of buildings, 

grading roads, construction, and land clearing. 

(3) Water supply lines, hoses and sprinklers shall be located near all stockpiles of raw materials, coal, 

and petroleum coke. 

(4) All plant operators shall be trained in basic environmental compliance and shall perform visual 

inspections of raw materials, coal and petroleum coke periodically and before handling. If the 

visual inspections indicate a lack of surface moisture, such materials shall be wetted with 

sprinklers. Wetting shall continue until the potential for unconfined particulate matter emissions 

are minimized. 

(5) Water spray shall be used to wet the materials and 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 other 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.]