AIR QUALITY PERMI T

Issued to : Holnam , Inc

. Perm it: #0982-09

4070 Trident Road Application Com p lete: 08/10/00 Three Forks, MT 59752 Prelim inary Determ ination Issued: 09/15/00 Departm e nt Decision Issued: 10/04/00

Final Perm it Issued: 10/20/00

AFS #031-0005

An air quality perm it, with conditions, is hereby granted to Holnam , Inc. (Holnam ) pursuant to
Sections 75-2-204 and 211 of the Montana Code Annotated (MCA), as am ended, and

Adm i nistrative Rules of Montana (A RM) 17.8.701, et seq. , as am ended, for the following:

SECTION I: Perm itted Facilities

A. Plant Location

The Holnam f acility is lo cated in the No rtheast 1⁄4 of Section 9, Southeast 1⁄4 of Section 4, S outhwest 1⁄4 of Section 3, Nort hwest 1⁄4 of Section 10, Township 2 North, Range 2 East, Gallatin C ounty, Montana.

B. Current Perm it Action

On August 10, 2000, Holnam subm itted a perm it application to request federally enforceable perm it conditions to lim it potenti al particulate m a tter em ission s. Holnam requested th e federally enforceable conditions to ensure th at the facility’s potential

em issions would be with in the “ a rea sour ce” d e finition as defined in the P o rtland

Ce m e nt Maxim u m Achievable Control Technology (PC MACT). Although this

perm it actio n could have been accom p lished thro ugh a perm it m odificatio n, an alteration was requested by Holnam to allow the public to comment on the perm it. In addition, approved de minim i s change s were included in the perm it.

SECTION I I : Conditions and Lim itations

A. Em ission Control Requirem ents

Holnam shall install, ope rate, and m a inta in the following em ission control equipm ent and practices, and all emission control equipm ent and pra c tic e s as spec if ied in the i r Montana a i r quality perm it app lica tio ns.

1. Holnam shall operate and m a intain the Finish Mill #2 pulsejet baghouse to control

em issions from the equipm ent listed below (ARM 17.8.715).

a. A replacem ent air slide

b. The clinker/gypsum fee d belt via a booster fan

c. The Finish Mill #2

d. The bucket elevator

e. The product separator

Perm it #0982- 09 FI NAL : 10/20/0 0 12. Holnam shall install, operate, and m a in tain the following baghouses to control

em issions from the equipm ent listed below (ARM 17.8.715).

a. A 3,800-acfm baghouse will con t rol the followin g equipm ent:

i. A 24-inch covered screw conve yor that transports the coke;

ii. A 290-ton “raw” coke storage silo; and

iii. The coke sto r age silo.

b. A 1,500-acfm baghouse will con t rol the followin g equipm ent:

i. Two diverter valves;

ii. The hammerm ill; and

iii. The bucket eleva t or.

c. A 1,500-acfm baghouse will con t rol the coal sto r age silo.

3. Holnam shall operate and m a intain the coke system pulsejet baghouse to control

em issions from the equipm ent listed below (ARM 17.8.715)

a. A belt conveyor with weighing system at the base of the raw coke storage

silo

b. A coke grin ding m ill

c. A 220-ton “fine” coke storage silo

4. Holnam shall opera te an d m a intain a n elec tros tatic pre c ipita t or to con t rol kiln

em issions, sized for 300,000 cfm @ 700 ° F, 0.15 gr/acfm outlet (ARM 17.8.715).

5. Holnam shall operate and m a intain a pul sejet baghouse to control clinker cooler

em issions, sized for 100,000 cfm @ 350 ° F (ARM 17.8.710).

6. Holnam shall opera te an d m a intain 4 Micro-pulsaire dust collectors on the rock silos (ARM 17.8.710).

7. Holnam shall opera te an d m a intain 2 Micro

- puls a ire dus t co llecto r s to co ntrol

em issions from crushing and screening (ARM 17.8.710).

8. Holnam shall operate and m a intain a ba ghouse to control em issions at the clinker belt conveyor (ARM 17.8.710).

9. Holnam shall operate and m a intain a ba ghouse to control em issions at the dust bin near the precipitator (A RM 17.8.710).

10. Holnam shall operate and m a intain a baghouse to control em issions from the

Portland cem e nt silos (ARM 17.8.710).

Perm it #0982- 09 FI NAL : 10/20/0 0 211. Holnam shall operate and m a intain a baghouse to control em issions from the Finish Mill #4 system (ARM 17.8.710).

12. Holnam shall install, operate, and m a inta in a baghouse to control em issions from the pozzolan m a terial storage silo (A RM 17.8.715).

13. Holnam shall install, use, and m a inta in enclosures around the pozzolan m a terial

system components listed below (ARM 17.8.715).

a. Rotary feed er b. Weighbelt conveyor c. Screw line (conveyor)

14. Holnam shall use water spray, as nece ssary, to maintain compliance with the opacity lim itation in Section II.C.9 wh en handling landfilled cem ent kiln dust (ARM 17.8.715).

15. Whenever process equipm ent is operating, Holnam shall use and m a intain, as they were intended, conveyor covers, transfer point covers, or structural enclosures surrounding process equipm ent (ARM 17.8.710).

B. Operation a l Lim itations

1. In the cem e nt kiln, Holnam is authori zed to burn up to 100% natural gas, up to 100% coal, up to 25% coke, or any com b ination of these fuels within the previously stated lim its (ARM 17.8.710).

2. Holnam shall com p ly with ARM 17.8.322.

3. Holnam shall not use, in any rolling 12-m onth period, greater than 50,000 tons of pozzolan m a terial in the pozzola n m a terial system (ARM 17.8.715).

4. The am ount of post-consum er recycled c ontainer glass used by Holnam in the

cem ent kiln shall be lim ited to 800 tons during any rolling 12-month period (ARM 17.8.715).

5. Holnam shall not handle, in any rolli ng 12-m ont h period, greater than 85,000 tons

of landfilled cem ent kiln dust (ARM 17.8.715).

6. Holnam shall lim it kiln p r oduction to 425,000 tons of clinker during any rolling

12-m onth period (ARM 17.8.710).

7. Holnam shall lim it clinker handling to 500,000 tons during any rolling 12-month period (AR M 17.8.710).

Perm it #0982- 09 FI NAL : 10/20/0 0 3C. Em ission Lim itations

1. Holnam shall not cause or authorize to be discharged into the atm o sphere any visible fugitive em issions that exhibit an opacity of 20% or greater averag ed over

6 consecutive m i nutes (ARM 17.8.308).

2. Holnam shall not cause or authorize the use of any street, road or parking lot without taking reasonab l e precau tion s to cont rol em issions of airborn e particu l ate

m a tter (ARM 17.8.308[2]).

3. Holnam shall treat all unpaved portions of the haul roads, access roads, parking lots, or the general plant area with water and/or chem ical dust suppressant as

necessary to m a intain co mpliance with the reason able precaution lim itatio n (ARM 17.8.710).

4. Holnam shall not cause or authorize to be discharged into the atm o sphere visible

em issions from any source installed on or before Nove m b er 23, 1968, that exhibit an opacity of 40% or greater averag ed over 6 consecutive m i nutes (ARM 17.8.304).

5. Holnam shall not cause or authorize to be discharged into the atm o sphere visible

em issions from any source installed af ter November 23, 1968, that exhibit an opacity of 20% or greater averaged over 6 consecutive m i nutes (ARM 17.8.304).

6. Holnam shall not cause or authorize to be discharged into the atm o sphere, from

the Finish M ill #2 b a gho use:

a. Particulate m a tter in excess of 0.02 gr/dscf (ARM 17.8.715), and

b. Visible em ission which exhibit an opac ity of 10% or greater averaged over 6

consecutive m i nutes (ARM 17.8.340).

7. Holnam shall not cause or authorized to be discharged into the atm o sphere from the 3,800 acfm and two 1,500 acfm baghouses (f orm e rly the coal/coke baghouse):

a. Particulate m a tter in excess of 0.02 gr/dscf (ARM 17.8.715):, and

b. Visible em issions that exhibit an opac ity of 20% or grea ter av eraged over 6

consecutive m i nutes (ARM 17.8.340).

8. Holnam shall not cause or authorized to be discharged into the atm o sphere from the coke system baghouse:

a. Particulate m a tter in excess of 0.02 gr/dscf (ARM 17.8.715), and

b. Visible em issions that exhibit an opac ity of 20% or grea ter av eraged over 6

consecutive m i nutes (ARM 17.8.340).

Perm it #0982- 09 FI NAL : 10/20/0 0 49. Holnam shall not cause or authorize to be discharged into the atm o sphere from the pozzolan m a terial s ilo baghouse (ARM 17.8.715):

a. Particulate m a tter in excess of 0.02 gr/dscf, and

b. Visible em issions that exhibit an opac ity of 20% or grea ter av eraged ove r 6

consecutive m i nutes.

10. Holnam shall com p ly with all app licable requirem ents of ARM 17.8.340, which references 40 CFR Part 60, Standards of Perfor mance for New Stationary

Sources.

a. Subpart F - Standards of Perform a nc e for Portland Ce m e nt Plants shall apply to sources at Holnam includi ng, but not lim ited to, the following:

(i) Finish Mill #2, (ii) Finish Mill #4, and (iii)Storage Silos #26 through 30.

b. Holnam shall not cause or authorize to be discharged into the atm o sphere

from the Finish Mill #4, visible em i ssions that exhibit 10% opacity or greater, as required by S ubpart F of 40 CFR Part 60 (ARM 17.8.340).

c. Holnam shall not cau se o r authorize to be discharged into the atm o sphere

from the Finish Mill #2, visible em i ssions that exhibit 10% opacity or greater, as required by S ubpart F of 40 CFR Part 60 (ARM 17.8.340).

d. Holnam shall not cause or authorize to be discharged into the atm o sphere

from Storage Silos #26 through 30, visi ble em issions that exhibit 10% opacity or greater, as required by Subpart F of 40 CFR Part 60 (ARM 17.8.340).

11. Holnam shall not cause or authorize to be discharged into the atm o sphere visible

em issions that exhibit an opacity of 20 % or greater averaged over 6 consecutive

m i nutes when handling landfilled cem ent kiln dust (ARM 17.8.710).

12. Particulate m a tter em issions from the kiln are lim ited to 0.77 lb/ton of clinker produced (A RM 17.8.710).

D. Testing Req u irem ents

1. Holnam shall conduct initial visible em ission observations to assess com p liance with the opacity lim it in Section II.C.6 for the Fini sh Mill #2 baghouse within 180 days of installation of the system

. Holnam shall conduct additional visible

em ission observations at leas t once ever y 4 years thereafter, o r acco rding to another testing/m onitoring schedule as m a y be approved by the Departm e nt of

Environm ental Quality (depar tm ent) (ARM 17.8.105 and ARM 17.8.340).

Perm it #0982- 09 FI NAL : 10/20/0 0 52. Holnam shall conduct an initial perfor m a nce source test on the Finish Mill #2 baghouse to determ ine com p liance with th e applicable particulate em ission lim it in Section II.C.6 within 180 days of inst allation of the syst em. Holna m shall

conduct add ition a l particulate em ission lim it tests at least on ce every 4 y ears thereafter, o r acco rding to another te s ting/m onitoring schedu le as m a y be approved by the department (ARM 17.8.105, ARM 17.8.710, and ARM 17.8.340).

3. Holnam shall conduct initial visible em ission observations to assess com p liance with the opacity lim it in Section II.C. 7 for the coal/coke baghouse within 180 days of installation of the system

. Holnam shall conduct additional visible

em ission observations at leas t once ever y 4 years thereafter, o r acco rding to another testing/m onitoring schedule as m a y be approved by the departm e nt (ARM 17.8.105 and ARM 17.8.710).

4. Holnam shall conduct an initial perf orm a nce source test on the coal/coke baghouse to determ ine com p liance with th e applicable particulate em ission lim it in Section II.C.7 within 180 days of inst allation of the syst em. Holna m shall

conduct add ition a l particulate em ission lim it tests at least on ce every 4 y ears thereafter, o r acco rding to another te s ting/m onitoring schedu le as m a y be approved by the department (ARM 17.8.105 and ARM 17.8.710).

5. Holnam shall conduct initial visible em ission observations to assess com p liance with the opacity lim it in Section II.C.8 for the coke system baghouse within 180 days of installation of the system

. Holnam shall conduct additional visible

em ission observations at leas t once ever y 4 years thereafter, o r acco rding to another testing/m onitoring schedule as m a y be approved by the departm e nt (ARM 17.8.105 and ARM 17.8.710).

6. Holnam shall conduct an initial perfor m a nce source test on the coke system baghouse to determ ine com p liance with th e applicable particulate em ission lim it in Section II.C.8 within 180 days of inst allation of the syst em. Holna m shall

conduct add ition a l particulate em ission lim it tests at least on ce every 4 y ears thereafter, o r acco rding to another te s ting/m onitoring schedu le as m a y be approved by the department (ARM 17.8.105 and ARM 17.8.710).

7. Holnam shall conduct an initial perform a nce source test on the kiln to determ ine

com p liance with the app licab le pa rticulate em ission lim it in Section II.C. 12 within 180 days of installation of the system . Hol n am shall conduct additional particula t e e m ission lim it tes t s a t lea s t on ce every 4 years th ereafter, or ac cording to another testing/m onitoring schedule as m a y be approved by the department (ARM 17.8.105 and ARM 17.8.710).

8. All com p liance source tests shall conf or m to the requirem e nts of the Montana

Source Test Protoc ol and Procedures Manual (AR M 17.8.106).

9. The departm e nt m a y require further testing (ARM 17.8.105).

Perm it #0982- 09 FI NAL : 10/20/0 0 6E. Operational Reporting R e quirem e nts

1. Holnam shall suppl y the departm e nt with annual production inform ation for all

em ission points, as required b y the de pa rtm e nt in the annual emission invent ory request. The request will include, but is not lim ited to the am oun t of pozzolan

m a ter i al used, the am ount of post-con s um er recy cl ed container glass used in the kiln,

the am ount o f landfilled cem ent kiln dust handled, the am ount o f clinker produced in the kiln, and the am ount o f total produ ct handled (ARM 17.8.7 10).

Production i n form ation shall be gathered on a calendar-y ear ba sis and subm itted to the departm e nt by the date required in the em ission inventory re quest. Info rm ation shall be in the units required b y the de partm e nt. This inform ation m a y be used for calculating operating fees, based on actual emissions from the facility , and/or to verify c o m p liance with perm it lim itatio ns (ARM 1 7

. 8.505).

2. Holnam shall notify the d e partm e nt of any co nstruc tion or im provem e nt project conducted, p u rsuant to ARM 17.8 .705 (1)(r), that would include a change in control equipm ent, stack height, stack diam eter, stack flow, stack gas te m p erature, source location, or fuel specifications, or woul d result in an increase in source capacity above its perm itted operation or the addition of a new em ission unit. The notice m u st
be subm itted to the departm e nt, in writing, 10 da y s prior to start up or use of t h e proposed de m i nimis change, or as so on as reaso n a bly practica b le in the event of an unanticipated circum stan ce causing the de m i nimis change, and m u st include the

inform ation r e quested in ARM 17.8.7 05(1)(r) (iv) ( A RM 17.8.7 05).

3. Holnam shall docum ent, by m onth, th e am ount of pozzolan m a terial used in the pozzolan m a terial sy stem . B y the 3 rd day of each m onth, Holna m shall tota l the

am ount of pozzolan m a ter i al use durin g the previou s 12 m onths to verify c o m p liance

with the limitation in Section II.B.5. T h e records com p iled shall be m a intained by

Holnam as a perm anent b u siness record for at least 5 y ears following the dat e of the recording, sh all be subm itted to the departm e nt upo n request, an d shall be av ailable at the plant site for inspectio n b y the dep a rtm e nt (ARM 17.8. 710).

4. Holnam shall docum ent, by m onth, th e am ount of post-consumer recy cled c ontainer glass used in the kiln. By the 3 rd day of each m onth

, Holnam shall total the am ount of

recy cled glass used in the kiln during the previous 12 m onths to verify com p liance

with the limitation in Section II.B.6. A written report of the compliance verification, including the previous 12 -m onth totals of rec y cled g l ass used, sh all be subm itted annually to t h e departm e nt no later than March 1 a nd m a y be su bm itted along with

the annual em ission inventory (AR M 17.8.710).

5. Holnam shall docum ent, by m onth, the am ount of landfilled cem ent kiln du st
handled. B y the 3 rd day of each m onth, Holnam shall total the amount of cem ent kiln

dust handled during the previous 12 m onths to verify com p liance with the lim itation

in Section II.B.7. A written report of t h e com p lian ce verificatio n, including the previous 12-m onth totals of landfilled cem ent ki ln dust handled, shall be subm i tted annually to t h e departm e nt no later than March 1 a nd m a y be su bm itted along with

the annual em ission inventory (AR M 17.8.710).

Perm it #0982- 09 FI NAL : 10/20/0 0 76. Holnam shall docum ent that conveyor covers , transfer point cove rs, or structural enclosures surrounding process equipm ent were m a intained and in place during operation of process equipm ent. The records shall include all repair and

m a intenance activity to all conveyor covers, transfer poi nt covers, or structural

enclosures. The record s must includ e, but is not lim ited to, the date, time, and action(s) taken for repair and m a intenance.

F. Petroleum Coke Test Burn Lim itations

1. Operating C onditions

a. Holnam is authorized to burn petroleu m coke in excess of 25% (based on the total BTU input required) in conjunction with natural gas and coal during the test burn (A RM 17.8.710).

b. The am ount of petroleum coke used during the test burn period shall be

lim ited to 30,400.0 tons. The test burn pe riod begins on the date that greater

than 25% coke is burned in the kiln a nd ends one year from the starting date (ARM 17.8.710).

c. Holnam shall notify the departm e nt , in writing, within 10 days of the beginning of the test burn period. N o tification w a s received by the departm e nt that test burning be gan on Nove m b er 14, 1999 (ARM 17.8.710).

d. Holnam shall com p ly with ARM 17.8.322(6)(c).

e. Holnam shall m a intain a log of the am ount of coke used in the kiln each day during the test burn period (ARM 17.8.710).

2. Testing Requirem ents

a. Holnam shall conduct sour ce tests on the kiln for NO

x and SO 2 , concurrently. The tests must be conduc ted at least once during the test burn.

The tim ing of the test is at the d i sc retion of Holnam, but m u st occur during

the test burn when the maxim u m a m ount of petroleum coke is being fired in conjunction with natural gas. In a ddition, a test is required when the

m a xi m u m a m ount of petroleum coke is be ing fired in conjunc tion with coal. These testing requirem e nts m a y be m odified upon written agreem ent with the department (ARM 17.8.105).

b. During the source tests required in S ec tion II.F.2.a, Holnam s h all conduct an analysis of the clinker produced and the cem ent kiln dust to de term ine the

concentratio n of sulf ur in each. This inf o rm ation shall b e sub m itted to the departm e nt, along with the results of the source tests (ARM 17.8.710).

c. During the source tests required in S ec tion II.F.2

. a, Holnam shall record the

f

o llowing in f o rm ation:

Perm it #0982- 09 FI NAL : 10/20/0 0 8(i) Clinker production rate, (ii) Coke com b ustion rate, (iii) Natural g a s com bustion rate, (iv) Coal com b ustion rate, and (v) Percent oxygen at the kiln outlet.

This information shall be record ed on an hourly basis during the perform a nce of the source tests and sh all be submitted with th e source tes t s report (ARM 17.8.710).

d. All source tests requ ired by the depa rtm e nt shall be conducted in acco rdance

with the Montana Source Test Prot ocol and Procedures Manual (ARM 17.8.106).

e. The departm e nt m a y require further testing (ARM 17.8.105).

SECTION I II: General Conditions

A. Inspection – Holnam shall allow the depart m e nt' s repres entatives access to the source

at all tim e s for the purpose of m a king insp ec tion s or survey s, colle cting s a m p les, obtaining data, auditing any m onitoring e quipm ent (CEMS, CERMS) or observing

any m onitoring or testing, and otherwise c onducting all necessary f unctions related to this pe rm it.

B. Waiver – The perm it and all the terms, c onditions, and m a tters stated herein shall be

deem ed accepted if Holnam fails to appeal as in dicated belo w.

C. Com p liance with Statutes and Regulations – Nothing in th is perm it shall be constru e d as relieving Holnam of the re sponsibility for complying with any applicable federal or Montana statute, rule or standard, except as speci fically provided in ARM 17.8.701,

et seq. (AR M 17.8.717).

D. Enforcem ent – Violations of lim itatio ns, conditions and requirem e nts contained

herein m a y constitute grounds for perm it re vocation, penalties or other enforcem ent as specified in Section 75-2-401, et s e q. , MCA.

E. Appeals – Any person or persons jointly or severally adversely affected by the departm e nt' s decision m a y request, w ithin 15 days after the departm e nt renders its decision, upon affidavit setting forth the gr ounds therefor, a hearing before the Board of Environmental Review (Board). A heari ng shall be held under the provisions of

the Montana Adm i nistrative Procedures Act. The departm e nt' s decision on the application is not final unless 15 days ha ve elapsed and there is no request for a hearing und er th is sectio n. The filin g of a request for a hearing postpones the effective date of the departm e nt' s decisi on until the conclusion of the hearing and issuance of a final decision by the Board.

Perm it #0982- 09 FI NAL : 10/20/0 0 9F. Perm it Inspection – As required by ARM 17.8.716, Inspection of Per m it, a copy of the air quality perm it shall be m a de available for inspection by departm e nt personnel

at the loca tion of the per m itted sourc e

.

G. Perm it Fee – Pursuant to Secti on 75-2-220, MCA, as am ended by the 1991 Legislature, failure to pa y the annual operation fee by Holnam m a y be grounds for revocation of this perm it, as required by th at Section and rules adopted thereunder by

the Board.

Perm it #0982- 09 FI NAL : 10/20/0 0 10Permit #0982-09 FINAL:10/20/0 0 1 PERMIT ANALYSIS Holnam, Inc.

Permit #0982-09

I. Introduction

A. Facility Description

Holnam, Inc. (Holnam) operates a cement manu facturing plant at their Trident facility in Three Forks, Montana. This facility was acquired by Holnam from the Ideal Cement Company (Ideal Basic Industries) in 1990. They operate 24 hours per day, 365 days per year. Raw materials, such as limestone, shale, and sandstone, are all

mined at the Trident Site. These raw mate rials and iron ore purchased from outside vendors are crushed, screened, and st ored in dedicated silos.

Measured amounts of each material are c onveyed to the raw mill where water is added and the mixture is pulverized to a fine slurry. The slurry is sent to Trident’s only kiln where clinker is produced. The cli nker is then sent to the clinker cooler where it is cooled from 2,500 °F to 150 °F. Th e clinker is then tr ansferred to storage silos or alternative storage sites (usually co vered) if the silos are full. Clinker is mixed with 5% gypsum and pulverized to produce Portland cement. The cement enters a high efficiency air separator and is sent to a dust collector. Cement from the

dust collector is sent to a cement cooler via an air slide. The cooled cement is then pneumatically conveyed to cement storage silos.

B. Existing Equipment and Activities

Source Description Control Equipment Efficiency
Disturbed Area – Fugitive Drilling Blasting
Limestone, Sand, Shale Removal Transfer, Conveying, and Screening Raw Material Storage Piles Haul Roads – Fugitives dust suppression 85% Primary Crusher fabric filter 99%

Crusher Screen fabric filter 99%

Raw Material Silo #1 fabric filter 99%

Raw Material Silos #2 and 3 fabric filter 99%

Raw Material Silos #4 and 5 fabric filter 99%

Raw Material Silos #6 and 7 fabric filter 99% Coal/Coke Unload Fugitive Coal/Coke Transfer Handling Fugitive Coal Outside Storage Pile Coke Outside Storage Pile

Coal Crusher fabric filter 99% Coal Silo – Loading fabric filter 99% Coal Silo - Unloading fabric filter 99% Fluid Coke Silo – Loading Fluid Coke Silo Unloading

Kiln ESP

Clinker Cooler fabric filter 99.8%

Inside Clinker Transfer fabric filter 99.8% Gypsum/Clinker Storage Silo fabric filter 99% Cement Kiln Dust Storage Load fabric filter 99%Permit #0982-09 FINAL:10/20/0 0 2 Source Description Control Equipment Efficiency
Cement Kiln Dust Storage Unloading dust suppression 50% Emergency Clinker Bins Loading fabric filter 99% Emergency Clinker Storage Silo 1 Emergency Clinker Storage Silo 2 Emergency Clinker Storage Silo 3 Emergency Clinker Storage Silo 4

#2 Finish Mill fabric filter 99%

Clinker Transfer #2 Finish Mill fabric filter 99%

#3 Finish Mill Transfer fabric filter 99%

#3 Finish Mill fabric filter 99%

Clinker Transfer #4 Finish Mill fabric filter 99% #4 Finish Mill Product Separator fabric filter 99.8%

#4 Finish Mill Vent fabric filter 99.8% Masonry Storage Bins 1- 3 fabric filter 95% Cement Storage Silos 4 – 5 fabric filter 99%

Cement Sack Machine #1 fabric filter 98%

Cement Sack Machine #2 fabric filter 98%

Cement Sack Machine #3 fabric filter 98%

Cement Sack Machine #4 fabric filter 98%
Cement Silos 1-7, 10, 11, 13 fabric filter 99%
Cement Silos #8, 9, 12 fabric filter 99%

Cement Transfer 1-13 to Bulk fabric filter 99% Cement Storage Silo 14-25 fabric filter 99% Cement Storage Silo 26-30 fabric filter 99%

Bulk Cement Transfer and Truck Loadout 1 fabric filter 99%

Bulk Cement Transfer and Truck Loadout 2 fabric filter 99%

Bulk Cement Rail Car Loadout fabric filter 99%

Diesel Fuel

Gasoline Pozzolan Material Storage Silo fabric filter 99% Rotary Feeder fabric filter 95% Weighbelt Conveyor fabric filter 95% Screw Line (conveyor) fabric filter 95% Handling Landfilled Cement Ki ln Dust water spray 50%

Waste Oil Burner

C. Permit History

On April 27, 1971, the Ideal Cement Company received permit # 282-072171 . This permit approved the construction of ten pi eces of control equipment, as follows:

1. An electrostatic precipitator to cont rol kiln emissions – sized for 300,000 cfm @

700 ° F, 15 gr/acfm inlet, 0.15/acf m outlet, 99.9% efficient.

2. A pulsejet type baghouse to control cli nker cooler emissions – sized for 100,000

cfm @ 350 ° F, 8.3: 1 air/cloth ratio, Nomex bags.

3. Four Micro-pulsaire dust collectors on the rock silos:

2 @ 7.4:1 air/cloth ratio, 843 ft 2 cloth area, Model IF124 2 @ 7.8:1 air/cloth ratio, 670 ft 2 cloth area

4. Two Micro-pulsaire dust collectors to control emissions from crushing and screening:

Crushing – Micro-pulsaire mode l IFI-48, 7200 cfm capacity fan Screening – Micro-pulsaire m odel IFI-24, 6400 cfm capacity fanPermit #0982-09 FINAL:10/20/0 0 3 5. One small baghouse to control emi ssions at the clinker belt conveyor.

6. One small baghouse to control emissions at the dustbin near the precipitator.

On May 3, 1971, the Ideal Cement Company received permit # 293-080471 to construct five pieces of equipment.

1. Primary Crusher, 450 tons per hour 2. Vibrating Screen, 6 ft x 12 ft, Missouri-Rodgers 3. Raw Mill, 11 ft x 34 ft, Bawl Mill, 2,000 hp, F.L. Smith 4. Kiln, 12 ft x 450 ft, Wet Process Rotary Kiln, F.L. Smith, 400 hp, kiln draft fan 5. Clinker Cooler, Folax Grates, F.L. Smith

Commitments to the construction of this equipment were made prior to August 17, 1971, so the equipment is not subject to New Source Performance Standards (NSPS) Subpart F.

On April 16, 1975, the Ideal Cement Company was issued permit # 811-050475 to
combust coal in their cement kiln.

On July 19, 1976, Ideal Basic Industries was issued permit # 982 to construct four Portland cement storage silos. Thes e silos are contro lled by a baghouse.

On January 6, 1984, a modification to permit # 811-050475 was issued to Ideal Basic Industries, which allowed the gas/coal-f ired cement kiln to burn a coal/coke

combination fuel.

On August 9, 1990, Holnam submitted a permit application # 0982-01 for use of

alternative fuels in the cement kiln. This permit application was withdrawn.

On November 22, 1993, Holnam submitted permit application # 0982-02 for replacement of sections of the cement kiln. The changes proposed in the application were determined to be maintenance and did not require a permit change.

Permit # 0982-03 was issued to Holnam on July 29, 1995. Holnam proposed to: upgrade the existing cement Finish Mill #2 baghouse to a modern baghouse; replace the Finish Mill #2 air slide; replace two ex isting dust collectors on the coal/coke process with one unit; and construct a sepa rate coke grinding, storage, and transport system with dust collection.

The Finish Mill #2 baghouse, which repla ced an existing baghouse, controls the

emission units listed below.

a. A replacement air slide b. The clinker/gypsum feed belt via a booster fan

c. The Finish Mill #2

d. The bucket elevator e. The product separator

The air slide is totally enclosed and is n ecessary for the transport of cement from the elevator to the product separator (air separator).Permit #0982-09 FINAL:10/20/0 0 4 The replacement of two existing dust colle ctors with the coal/coke baghouse on the existing coal/coke diversion, crushing, and storage system controls the equipment

listed below.

a. A diverter valve at the top of the existing coal/coke storage silo b. A 24-inch covered screw conveyor that transports the coke from the above

diverter valve c. A 290-ton “raw” coke storage silo

d. Two diverter valves

e. The hammermill

f. The bucket elevator g. The coal/coke storage silo h. The covered screw conveyor

The separate coke system transports coke on the existing path up to the point of delivery into the top of the co al/coke storage silo. At this point, the proposed system incorporates a gate that will discharge into a 290-ton capacity “raw” coke storage silo. Coal is diverted into the existing coal/c oke storage silo. The proposed raw coke storage silo gravity feeds onto a covered be lt assembly, where the material is weighed before it is gravity fed into the proposed coke grinding mill. The ground coke fines are then evacuated from the grinding mill by a 15,400-cfm fan that pneumatically transports the crushed coke to the proposed coke system baghouse where the gas and solid phases are separated. The ground, “fine” coke material discharges from this

dust collector into a 220-ton “f ine” coke storage silo. Pneu matic transport of the fine coke particles from this silo to the kiln hood are facilitated by a coke blower system.

The proposed coke system baghouse and fan would control the equipment listed

below.

a. A belt conveyor with weighing system at the base of the raw coke storage silo b. A coke grinding mill c. A 220-ton “fine” coke storage silo

The emission increase due to the proposed changes was estimated at 10.84 tons/year of particulate matter.

Permit # 0982-04 was issued on May 8, 1998. Holnam submitted a complete permit application on March 30, 1998. The applica tion proposed a pozzolan material (fly ash) system that included the following new equipment: pozzolan material storage silo with bin vent dust collector, rotary feeder, weighbelt conveyor, and screw line (conveyor). Holnam intended to introduce po zzolan material at the finish mill to produce Holnam Performance Cement (HPC). Controlled PM-10 emissions from the proposed equipment would be approximately 2.10 tons per year. The permit was also updated to reflect compliance demonstrations and notifications that were completed

and rule references th at were outdated.Permit #0982-09 FINAL:10/20/0 0 5 Permit #0982-03 had included conditions from permits #282-072171, #293-080471, #811-050475, #982, and modification #811-050475. Th erefore, permit #0982-04 also replaced these permits.

Permit modification # 0982-05 was issued on September 3, 1998 to allow Holnam to conduct a test burn that exceeds the operati onal limit in Section II.B.1. The amount of petroleum coke burned in the kiln wa s limited so that 15 tons per year of SO 2 was not exceeded; therefore, this test burn could be completed according to ARM 17.8.705(1)(q).

However, as described in ARM 17.8.733(1)(c), the permit needed to be modified to allow the temporary burning of petroleum coke in excess of the limitation in Section II.B.1. Holnam was required to comply with the sulfur-in-fuel requirements contained in ARM 17.8.322(6)(c) and to main tain records to demonstrate compliance with the petroleum coke limitation in Sec tion II.F.1.b of the permit. In addition, testing was required to determine emissions at the maximum rate of petroleum coke burned. Permit #0982-05 replaced permit #0982-04.

Permit # 0982-06 was issued on January 24, 1999. The 99.9% control efficiency for removal of particulate emissions from th e kiln exhaust through the use of an electrostatic precipitator (ESP) in Secti on II.A.4 of the permit was removed. The change did not result in an increase in allowable particulate emission rates from the kiln. Permit #0982-06 replaced permit #0982-05.

Holnam proposed (in permit application # 0982-07 ) to use 800 tons/yr of postconsumer recycled container glass in the kiln and handle 85,000 ton/year of landfilled cement kiln dust. Holnam submitted an emission inventory that identified 5.13 lbs/year of emissions of hazardous air po llutants being emitted as a result of using post-consumer recycled container glass. Holnam submitted a health risk assessment, which demonstrated that this proposal woul d constitute a negligible risk to human health and the environment. Handling 85,000 tons/year of landfilled cement kiln dust involved moving landfilled dust from the landf ill with a front-end loader to a truck.

The cement kiln dust would be sold for us e in reclamation projects. Handling the

cement kiln dust would result in an emissions increase of approximately 23.8 tons per year of total particulate matter and 11.9 tons per year of PM-10. Permit #0982-07 replaced permit #0982-06.

Permit #0982-08 was issued on December 29, 1999 to correct condition II.B.5, which was intended to limit the use of pozzolan ma terial fed through the pozzolan material system. This is specific to the pozzolan material storage silo, rotary feeder, weighbelt conveyor, screw line, and bin vent dust collec tor, and not the entire facility. Also, condition II.E.3 was updated to reflect th is correction. Permit #0982-08 replaced permit #0982-07.Permit #0982-09 FINAL:10/20/0 0 6 D. Current Permit Action

On August 10, 2000, Holnam submitted a permit application to request federally enforceable permit conditions to limit potenti al particulate matter emissions. Holnam requested the federally enforceable conditions to ensure that the facility’s potential

emissions would be within the “area sour ce” definition as defined in the Portland Cement Maximum Achievable Control Technology (PC MACT). Although this permit action could have been accomplished through a permit modification, an alteration was requested by Holnam to allo w the public to comment on the permit. De minimis changes were also included in the permit (Department Decision) during the comment period. Permit #0982-09 replaces permit #0982-08.

E. Additional Information

Additional information, such as applicable rules and regulations, best available control technology (BACT) determinations, air quality impacts, and environmental assessments, is included in the analysis associated with each change to the permit.

II. Applicable Rules and Regulations

The following are partial explana tions of some applicable rule s and regulations that apply to the facility. The complete rules are stat ed in the Administrative Rules of Montana (ARM) and are available, upon request, from the Department of Environmental Quality (department). Upon request, the department will provide references for locations of complete copies of all applicable rules a nd regulations or copi es where appropriate.

A. ARM 17.8, Subchapter 1 - General Pr ovisions, including, but not limited to:

1. ARM 17.8.101 Definitions . This section includes a lis t of applicable definitions used in this chapter, unl ess indicated otherwise in a specific subchapter.

2. ARM 17.8.105 Testing Requirements . Any person or persons responsible for the emission of any air contam inant into the outdoor atmo sphere shall, upon written request of the department, provide th e facilities and necessary equipment (including instruments and sensing devices ) and shall conduct tests, emission or ambient, for such periods of time as ma y be necessary using methods approved by the department.

3. ARM 17.8.106 Source Testing Protocol . The requirements of this rule apply to any emission source testing conducted by th e department, any source, or other entity as required by any rule in this chapter, or any permit or order issued pursuant to this chapter, or the provisi ons of the Clean Air Act of Montana, 75-2- 101, et seq. , MCA.

Holnam shall comply with the requirem ents contained in the Montana Source Test Protocol and Procedures Manual, including, but not limited to, using the proper test methods and supplying the re quired reports. A copy of the Montana

Source Test Protocol and Procedures Manual is av ailable from the department

upon request.Permit #0982-09 FINAL:10/20/0 0 7 4. ARM 17.8.110 Malfunctions . The department must be notified promptly by telephone whenever a malfuncti on occurs that can be expected to create emissions in excess of any applicable emission limita tion, or to continue for a period greater

than 4 hours.

5. ARM 17.8.111 Circumvention . No person shall cause or permit the installation or use of any device or any means which, w ithout resulting in re duction in the total amount of air contaminant emitted, con ceals or dilutes an emission of air

contaminant which would otherwise violat e an air pollution c ontrol regulation. No equipment that may produce emissions sh all be operated or maintained in such a manner that a public nuisance is created.

B. ARM 17.8, Subchapter 2 - Ambient Air Quality, including, but not limited to:

1. ARM 17.8.204 Ambient Air Monitoring

, 2. ARM 17.8.210 Ambient Air Quality Standards for Sulfur Dioxide

, 3. ARM 17.8.211 Ambient Air Quality St andards for Nitrogen Dioxide,

4. ARM 17.8.212 Ambient Air Quality Standards for Carbon Monoxide

, 5. ARM 17.8.220 Ambient Air Quality Standa rd for Settled Particulate Matter

, 6. ARM 17.8.221 Ambient Air Qualit y Standard for Visibility

, 7. ARM 17.8.222 Ambient Air Quality Standard for Lead , and

8. ARM 17.8.223 Ambient Air Qu ality Standard for PM 10

.

Holnam must maintain compliance with the ap plicable ambient air quality standards.

C. ARM 17.8, Subchapter 3 - Emission Sta ndards, including, but not limited to:

1. ARM 17.8.304 Visible Air Contaminants . This rule requires that no person may

cause or authorize emissions to be disc harged into an outdoor atmosphere from any source installed after November 23, 1968, that exhibits an opacity of 20% or greater averaged over 6 consecutive minutes.

2. ARM 17.8.308 Particulate Matter, Airborne . No person shall cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of airborne par ticulate matter are taken. Such emissions of airborne partic ulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive

minutes.

3. ARM 17.8.309 Particulate Matter , Fuel Burning Equipment . This section requires that no person shall cau se, allow, or permit to be discharged into the atmosphere particulate matter caused by the combustion of fuel in excess of the amount determined by this section.

4. ARM 17.8.310 Particulate Matt er, Industrial Process . This section requires that no person shall cause, allow, or permit to be discharged into the atmosphere particulate matter in excess of the amount set forth in this section.Permit #0982-09 FINAL:10/20/0 0 8 5. ARM 17.8.315 Odors . This rule requires that no person shall cause, suffer, or allow any emissions of gases, vapors, or odors beyond his property line in such manner as to create a public nuisance. A person operating any business or using any machine, equipment, device, facility or process which discharges into the outdoor air any odorous matter or vapors, ga ses, dusts, or any combination thereof which create odors, shall provide, properly install, and maintain in good working order and operation such odor control devi ces or procedures as may be specified by the department.

6. ARM 17.8.322 Sulfur Oxide Emissions--Sulfur in Fuel . This section requires that no person shall burn liquid, solid, or gaseous fuel in excess of the amount set forth

the in this section.

7. ARM 17.8.340 Standard of Performa nce for New Stationary Sources . This section incorporates, by reference, 40 CF R Part 60, Standards of Performance for New Stationary Sources (NSPS). The ow ner and operator of any stationary source or modification, as defined and a pplied in 40 CFR Part 60, shall comply with the standards and provisions of 40 CFR Part 60.

Subpart F – Standards of Performance for Portland Cement Plants. The provisions of this Subpart ar e applicable to the followi ng affected facilities in Portland cement plants: kiln, clinker cool er, raw mill system, finish mill system, raw mill dryer, raw material storage, c linker storage, finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems. Sources subject to the requirements of this Subpart are applicable if the facility

commences construction or modificati on of that source after August 17, 1971. This Subpart shall apply to sources at Holnam, including, but not limited to, the following:

(i) Finish Mill #2; (ii) Finish Mill #4; and (iii) Storage Silos #26 through 30.

Finish Mill #4 replaced Fini sh Mill #1 in 1988 and the product storage silos were

installed in 1976. Since commencement of construction occu rred after August 17, 1971 for both of these sources, 40 CFR 60 Subpa rt F applies. The replacement of

the air slide in the Finish Mill #2 system was considered a modification of the Finish Mill #2 system. Since this m odification was proposed to occur after August 17, 1971, then 40 CFR Part 60 Subpart F was also considered applicable

to Finish Mill #2.

8. ARM 17.8.342 Emission Standards for Hazardous Air Pollutants for Source Categories . This section incorporates, by re ference, 40 CFR Part 63, National

Emission Standards for Hazardous Air Po llutants (NESHAPs). The owner and operator of any stationary source or modi fication, as defined and applied in 40 CFR Part 63, shall comply with the sta ndards and provisions of 40 CFR Part 63.Permit #0982-09 FINAL:10/20/0 0 9 Subpart LLL – National Emission Standard s for Hazardous Air Pollutants for The Portland Cement Manufacturing Industr y. The Holnam Trident Plant must comply with all applicable requirements of this Subpart. On October 14, 1999, the department received initial notificati on designating the Trident Plant a major source. Holnam is currently testing the facility to determine emissions of HAPs, which could re-designate the facility as an area source.

D. ARM 17.8, Subchapter 5 - Air Quality Permit Application, Operation and Open Burning Fees, including, but not limited to:

1. ARM 17.8.504 Air Quality Permit Application Fees . This section requires that an applicant submit an air quality permit application fee concurrent with the submittal of an air quality permit applica tion. A permit application is incomplete until the proper application fee is paid to the department. Holnam submitted the appropriate permit application f ee for the current permit action.

2. ARM 17.8.505 Air Quality Operation Fees . An annual air quality operation fee must, as a condition of continued operat ion, be submitted to the department by each source of air contaminants holding an air quality permit, excluding an open burning permit, issued by the departmen t; and the air quality operation fee is

based on the actual or estimated actual am ount of air pollutants emitted during the previous calendar year.

An air quality operation fee is separate and distinct from an air quality permit application fee. The annual assessment a nd collection of the ai r quality operation fee, described above, shall take place on a calendar-year basis. The department may insert into any final permit issued after the effective date of these rules, such conditions as may be necessary to require the payment of an ai r quality operation fee on a calendar-year basis, including provi sions which pro-rate the required fee

amount.

E. ARM 17.8, Subchapter 7 - Permit, Construc tion and Operation of Air Contaminant Sources, including, but not limited to:

1. ARM 17.8.704 General Procedures for Ai r Quality Preconstruction Permitting

. This air quality preconstruction permit contains requirements and conditions applicable to both construction and subse quent use of the permitted equipment.

2. ARM 17.8.705 When Permit Required--Exclusions . This rule requires a facility to obtain an air quality permit or permit alte ration if they construct, alter, or use any air contaminant sources which have th e potential to emit more than 25 tons per year of any pollutant.

3. ARM 17.8.706 New or Altered Sources and Stacks--Permit Application Requirements . This section requires that a permit application be submitted prior to installation, alteration or use of a source. Holnam submitted the appropriate permit application for th e current permit action.Permit #0982-09 FINAL:10/20/0 0 10 4. ARM 17.8.710 Condition of Issuance of Permit . This section requires that Holnam demonstrate compliance with appl icable rules and standards before a permit can be issued. Also, a permit may be issued with such conditions as are necessary to assure compliance with all applicable rules and standards. Holnam has demonstrated compliance with applicab le rules and standards as required for permit issuance.

5. ARM 17.8.715 Emission Control Requirements . This section requires a source to install the maximum air pollution cont rol capability which is technically practicable and economically feasible, except that BACT shall be utilized. Holnam was not required to submit a BACT analysis for the current permitting

action because it is considered an admi nistrative action and no new or altered sources are being addressed.

6. ARM 17.8.716 Inspection of Permit . This rule requires that air quality permits shall be made available for inspection by the department at the location of the

source.

7. ARM 17.8.717 Compliance with Other Statutes and Rules . This rule states that nothing in the permit shall be construed as relieving Holnam of the responsibility for complying with any applicable federal or Montana statute, rule or standard, except as specifically provided in ARM 17.8.101, et seq.

8. ARM 17.8.720 Public Review of Permit Applications . This rule requires that the applicant notify the public by means of legal publication in a newspaper of general circulation in the area affected by the application for a permit. Holnam submitted an affidavit of publication on August 18, 2000 from the Three Forks

Herald , a newspaper of general circulation printed and published in Three Forks, as proof of compliance w ith the public notice require ments. The notice was published on August 16, 2000.

9. ARM 17.8.731 Duration of Permit . An air quality permit shall be valid until revoked or modified as provided in this subchapter, except that a permit issued prior to construction of a new or alte red source may contai n a condition providing that the permit will expire unless constr uction is commenced within the time specified in the permit, which in no event may be less than 1 year after the permit

is issued.

10. ARM 17.8.733 Modification of Permit . An air quality permit may be modified for changes in any applicable rules and standards adopted by the Board or changed conditions of operation at a s ource or stack which do not result in an

increase in emissions because of thos e changed conditions. A source may not increase its emissions beyond those found in its permit unless the source applies for and receives another permit, except as specifically provided in the regulations.

11. ARM 17.8.734 Transfer of Permit . This section states an air quality permit may be transferred from one pers on to another if written notic e of intent to transfer, including the names of the tr ansferor and the transferee, is sent to the department.Permit #0982-09 FINAL:10/20/0 0 11 F. ARM 17.8, Subchapter 8 - Prevention of Significant Deterioration of Air Quality (PSD), including, but not limited to:

1. ARM 17.8.801 Definitions . This rule is a list of applicable definitions used in this subchapter.

2. ARM 17.8.818 Review of Major Stationa ry Sources and Major Modifications-- Source Applicability and Exemptions . The requirements contained in ARM 17.8.819 through 17.8.827 shall apply to any ma jor stationary source and any major modification with respect to each po llutant subject to regulation under the Federal Clean Air Act (FCAA) that it would emit, except as this subchapter would

otherwise allow.

Holnam is a major stationary source. Permit #0982-09 does not require PSD review

because there will be no increase in emissi ons as a result of this permitting action.

G. ARM 17.8, Subchapter 12 - Operating Pe rmit Program Applicability, including, but

not limited to:

1. ARM 17.8.1201 Definitions . (23) Major Source under Section 7412 of the FCAA is defined as any stationary source having:

a) Potential to Emit (PTE) > 10 tons/y ear of any one hazardous air pollutant (HAP),

b) PTE > 25 tons/year of a combination of all HAPs,

c) Lesser quantity as the depart ment may establish by rule,

d) PTE > 100 tons/year of any pollutant, or

e) Sources with the PTE > 70 tons/year of PM-10 in a serious PM-10

nonattainment area.

2. ARM 17.8.1204 Air Quality Operating Permit Program Applicability . Title V of the FCAA Amendments of 1990 requires th at all sources, as defined in ARM 17.8.1204 (1), obtain a Title V Operating Pe rmit. Holnam submitted a Title V operating permit application on 06/06/96.

III. BACT Determination

A BACT determination is required for each new or altered source. Holnam shall install

on the new or altered source the maximum air pollution control capability which is technically practicable and economically feasible, excep t that best available control technology shall be utilized.

The current permitting action did not require a BA CT analysis because it is considered an

administrative action and no new or altered sources were addressed.Permit #0982-09 FINAL:10/20/0 0 12 IV. Emission Inventory (Permit #0982-09)

Total potential particulate emissions (from the inventory below): 523 tons/year Calculated potential metal HAPs emissions (as 1% of potential PM emissions): 5.23 tons/year

Fugitive Emissions: Disturbed Areas Max Thruput: 288 acres

Control: 0 % Emission factor: 74.5 lb/acre (Nati onal AFS Emission Factor, SCC 30502010) Annual particulate emissions: 10.728 tpy Quarry Drilling Max Thruput: 1,000,000 tpy Control: 0 % (Quarry drill has built-in control equipment) Emission factor: 1.68E-04 lb/ton material (AP-42 Ta ble 11.19.2-2, Footnote c (1/95), SCC 3-05-020-10) Annual particulate emissions: 0.084 tpy Quarry Blasting Max Thruput: 75 blasts/yr

Control: 0 % Emission factor: 50 lb/blast (Montana Hard Rock Mining Factor) Annual particulate emissions: 1.875 tpy Limestone, Sand, and Shale Removal Max Thruput: 865,500 tpy

Control: 0 % Emission factor: 0.010 lb/ton (199 9 AFS Plant Emission Inventory) Annual particulate emissions: 4.328 tpy Xfer: Truck Dump to Hopper to Apron Feeder 211AF1 Max Thruput: 750 tph; 865,500 tpy Control: 50% (Truck dumps to below ground hopper) Emission factor: 2.94E-03 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.636 tpy

Xfer: 211AF1 to Covered 211BC1 Max Thruput: 750 tph; 865,500 tpy Control: Enclosed conveyors – control efficiency included in emission factor Emission factor: 1.01E-04 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.044 tpy Primary Crusher 211HC1 Max Thruput: 750 tph; 865,500 tpy Control: 90% (Enclosed) Emission factor: 5.04E-03 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-03) Annual particulate emissions: 0.218 tpy Enclosed Vibrating Screen 211VS1 Max Thruput: 750 tph; 865,500 tpy Control: Enclosed – control efficiency included in emission factor Emission factor: 1.76E-03 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-02-03) Annual particulate emissions: 0.763 tpy Xfer: Surge Hopper to Ground Pile or 211BC3 Max Thruput: 750 tph; 865,500 tpy

Control: 0% Emission factor: 2.94E-03 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 1.272 tpy

Xfer: 211BC3 to 211BC4 Max Thruput: 450 tph; 865,500 tpy Control: Enclosed conveyors (in building)– c ontrol efficiency included in emission factor Emission factor: 1.01E-04 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.044 tpy

Xfer: 211BC4 to 1 of 7 Silos Max Thruput: 450 tph; 865,500 tpy Control: Enclosed conveyors (in building)– c ontrol efficiency included in emission factor Emission factor: 1.01E-04 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.044 tpy

Xfer: 1 of 7 Silos to 331BC1 Max Thruput: 130 tph; 865,500 tpy Control: Enclosed in building and enclosed conveyor s – control efficiency included in emission factor Emission factor: 1.01E-04 lb/ton ore (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.044 tpy Raw Material Storage Piles Max Thruput: 25.6 acres (Thru-put conservatively assumed to cover all available storage area) Control: Enclosed in old quarry floor – c ontrol efficiency included in emission factor Emission factor: 3.151 lb/day/acre (Control of Fugitive Dust Sources 4.1.3 (9/88)) Annual particulate emissions: 14.721 tpyPermit #0982-09 FINAL:10/20/0 0 13 Fugitive Emissions: Haul Roads Max Thruput: 40,012 vmt/yr Control: 50% (for water on roads) Emission factor: 6 lb/vmt (1999 AFS Plant Emission Inventory) Annual particulate emissions: 63.018 tpy

Coal/Coke Unloaded (Coal is pneumatically unloaded; coke is dumped) Max Thruput: 143,258 tpy

Control: 0% Emission factor: 0.005 lb/ton (AP- 42 Table 11.9-4 (1/95) (Class III)) Annual particulate emissions: 0.358 tpy

Coal/Coke Xfer: L11HP1 and L11HP2 to L21BC1 Max Thruput: 300 tph; 143,258 tpy Control: 50% (hopper is underground) Emission factor: 0.00294 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.105 tpy

Coal/Coke Xfer: L21BC1 to L21DG1 and L21DG2 Max Thruput: 300 tph; 143,258 tpy Control: Equipment is enclosed and inside buildings – control efficiency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.007 tpy

Coal/Coke Crusher L315HC1 Max Thruput: 300 tph; 143,258 tpy Control: Equipment is enclosed and inside buildings – control efficiency included in emission factor Emission factor: 1.01E-04 (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.007 tpy

Coal/Coke Xfer: L315C2 to L31BE1 Max Thruput: 300 tph; 143,258 tpy Control: Equipment is enclosed and inside buildings – control efficiency included in emission factor Emission factor: 1.01E-04 (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.007 tpy Coal/Coke Silo Loading and Unloading Max Thruput: 37,059 dscfm

Control: #L11BF1 Emission factor: 0.02 gr/d scf (Baghouse Specification) Annual particulate emissions: 27.826 tpy Coal and Coke Outside Storage Piles Max Thruput: 143,258 tons

Control: 0% Emission factor: 3.151 lb/day/acre (Cont rol of Fugitive Dust Sources 4.1.3 Eqn. (9/88), see permit application for calculations) Annual particulate emissions: 2.337 tpy

Kiln Max Thruput: 425,000 tpy Control: ESP (Production limit required by permit) Emission factor: 0.77 lb/ton clinker (AP- 42 Table 11.6-2 (1/95), SCC 3-05-007-06) Annual particulate emissions: 163.625 tpy Post Consumer Recycled Glass Max Thruput: 800 tpy

Control: 0%

Emission factor: 2.7 lb/ton handled (1999 AFS Plant Emission Inventory) Annual particulate emissions: 1.080 tpy
Clinker Cooler Max Thruput: 425,000 tpy Control: #471BF1 (Dust collector required by permit, 100,000 cfm flow rate) Emission factor: 0.13 lb/ton (AP-42 Table 11. 6-2 (1/95) controlled EF, SCC 3-05-006-14) Annual particulate emissions: 27.625 tpy Dust Discharge Spout between Kiln and Precipitator Max Thruput: 79,244 tpy

Control: Has wind barrier on three sides – c ontrol efficiency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpy Xfer: Kiln Dust from Precipitator to 421SC1,2,3 Max Thruput: 10 tph; 79,244 tpy

Control: Enclosed – control effi ciency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpy
Xfer: Kiln Dust from 421SC1 to 421SC4 Max Thruput: 10 tph; 79,244 tpy

Control: Enclosed – control effi ciency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpyPermit #0982-09 FINAL:10/20/0 0 14 Xfer: Kiln Dust from 421SC4 to 421BE1 Max Thruput: 10 tph; 79,244 tpy Control: Enclosed – control efficiency included in emission factor

Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpy

Xfer: Kiln Dust from 421BE1 to 421TK1 Max Thruput: 10 tph; 79,244 tpy Control: Enclosed – control efficiency included in emission factor

Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpy

Xfer: Kiln Dust from 421TK1 to 421SC5 Max Thruput: 10 tph; 79,244 tpy

Control: Enclosed– control effici ency included in emission factor

Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpy

Xfer: 421SC5 to Dustless Unloader Max Thruput: 10 tph; 79,244 tpy Control: Enclosed (wet material in dustless unloade r) – control efficiency included in emission factor

Emission factor: 0.008 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 0.299 tpy

Xfer: Dustless Unloader to Truck Max Thruput: 90 tph; 79,244 tpy Control: 50% (wet material in dustless unloader)

Emission factor: 0.182 lb/ton (AP-42 13.2.4, Eq.1 (1/95)) Annual particulate emissions: 3.596 tpy

Xfer: Kiln to Clinker Cooler #471CC1 Max Thruput: 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy

Xfer: #491CV1 to 491CV2 Max Thruput: 75 tph; 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy

Xfer: 491CV2 to 491BE2 Max Thruput: 75 tph; 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy

Xfer: 491BE2 to 491CV3 Max Thruput: 75 tph; 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy Xfer: 491CV3 to Emergency Storage Silos Max Thruput: 75 tph; 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy Xfer: Emergency Storage Silos 1 - 4 to Truck Max Thruput: 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy

Xfer: #491CV1 to 491BE1 Max Thruput: 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy

Xfer: #491BE1 to #491BC1 Max Thruput: 75 tph; 425,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpy Xfer: #491BC1 to Clinker Storage Silos Max Thruput: 75 tph; 425,000 tpy Control: Conveyors have tall sides and carry large material – control efficien cy included in emission factor

Emission factor: 1.01E-04 lb/ton (AP-42 Table 11.19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.021 tpyPermit #0982-09 FINAL:10/20/0 0 15 Import Clinker Xfer: Dump to Apron Feeder to 595BE1 Max Thruput: 75,000 tpy Control: 50% (enclosure, bottom dump to underground) Emission factor: 0.003 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.055 tpy Import Clinker Xfer: 595BE1 to Belt Conveyor Max Thruput: 75,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.004 tpy Import Clinker Xfer: Belt Conveyor to Silos 2A and 2B Max Thruput: 75,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.004 tpy

Overflow Clinker Xfer: Clinker St orage Silos 2A and 2B to Ground Max Thruput: 250,000 tpy (clinker may have to go through system twice)

Control: 0% Emission factor: 0.003 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.368 tpy Overflow Clinker Xfer: Dump to Apron Feeder to 595BE1 Max Thruput: 250,000 tpy (clinker may have to go through system twice) Control: 50% (Bottom dump to underground) Emission factor: 0.003 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.184 tpy Overflow Clinker Xfer: 595BE1 to Belt Conveyor Max Thruput: 250,000 tpy (clinker may have to go through system twice)

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.013 tpy Overflow Clinker Xfer: Belt Conveyor to Silos 2A and 2B Max Thruput: 250,000 tpy (clinker may have to go through system twice)

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.013 tpy Gypsum Xfer: Rail Car to Apron Feeder to 595BE1 Max Thruput: 100 tph; 48,000 tpy Control: 50% (Bottom dump to underground) Emission factor: 0.003 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.035 tpy Gypsum Xfer: 595BE1 to Belt Conveyor Max Thruput: 100 tph; 48,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.002 tpy Gypsum Xfer: Belt Conveyor to Interstice Bin Max Thruput: 100 tph; 48,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.002 tpy Overflow Gypsum Xfer: Interstice Bin to Ground Max Thruput: 48,000 tpy (gypsum may go through system twice) Control: 50% (3-sided enclosure) Emission factor: 0.003 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.035 tpy Overflow Gypsum Xfer: Dump to Apron Feeder to 595BE1 Max Thruput: 100 tph; 48,000 tpy (gypsum may go through system twice) Control: 50% (Bottom dump to underground) Emission factor: 0.003 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.035 tpy Overflow Gypsum Xfer: 595BE1 to Belt Conveyor Max Thruput: 100 tph; 48,000 tpy (gypsum may go through system twice)

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.002 tpy Overflow Gypsum Xfer: Belt Conveyor to Interstice Bin Max Thruput: 100 tph; 48,000 tpy (gypsum may go through system twice)

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.002 tpyPermit #0982-09 FINAL:10/20/0 0 16 Xfer: Clinker Silos 1A, 1B, & Interstice to 534BC1 Max Thruput: 66.5 tph; 395,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.020 tpy

Xfer: 534BC1 to #4 Finish Mill Max Thruput: 395,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.492 tpy

Xfer: #4 Finish Mill to 594ASA or 594ASB Max Thruput: 395,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.492 tpy

Xfer: 594ASA or 594ASB to 594BE1 Max Thruput: 395,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.492 tpy

Xfer: 594BE1 to 594ASJ Max Thruput: 395,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.492 tpy

Xfer: 594ASJ to 594ASF-G or 594ASC Max Thruput: 395,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.492 tpy

Xfer: Silo 2A or 2B & Interstice to 532BC1 or 533BC1 Max Thruput: 28 tph; 245,280 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.012 tpy

#2 Finish Mill Max Thruput: 74,118 dscfm

Control: 562BF1 Emission factor: 0.02 gr/dscf (Baghouse specification) Annual particulate emissions: 55.652 tpy

Xfer: Silo 2A or 2B & Interstice to 532BC1 or 533BC1 Max Thruput: 28 tph; 245,280 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 1.01E-04 lb/ton (AP-42 Table 11 .19.2-2, Footnote c (1/95), SCC 3-05-020-06) Annual particulate emissions: 0.012 tpy

Xfer: 533BC1 to Finish Mill #3 Max Thruput: 245,280 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.926 tpy

Xfer: Finish Mill #3 to 593BE1 Max Thruput: 245,280 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.926 tpy

Xfer: 593BE1to 593AS1 Max Thruput: 245,280 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.926 tpy

Xfer: 593AS1 thru 593SR1 to 592SC2 or 593AS2 Max Thruput: 245,280 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.926 tpy

Xfer: Cement to Cement Cooler Max Thruput: 94 tph; 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpyPermit #0982-09 FINAL:10/20/0 0 17 Xfer: Cement Cooler to Silos and Bins Max Thruput: 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Xfer: Silos 1 - 13 to Screw Conveyors Max Thruput: 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Xfer: Screw Conveyors to 612BE2 or 612BE1 Max Thruput: 103 tph; 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Scalping Screen 601SV1 Max Thruput: 103 tph; 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.001764 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-02-03) Annual particulate emissions: 0.463 tpy

Xfer: Overs to Ground Max Thruput: 3,833 tpy

Control: 0% Emission factor: 0.182 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.348 tpy Xfer: Surge Hopper 601PP1 to Bulk Cement Silos Max Thruput: 103 tph; 521,168 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.968 tpy

Xfer: 592SC1 to Silos 26-30 Max Thruput: 278,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.050 tpy

Xfer: Silos 26-30 to Silos 14-25 Max Thruput: 278,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.050 tpy

Xfer: Silos 14-25 to 621SC1 Max Thruput: 278,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.050 tpy

Xfer: 621SC1 to 631AS1 Max Thruput: 278,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.050 tpy

Xfer: 631AS1 to Railroad Car Max Thruput: 278,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.050 tpy Xfer: Bins 1-5 to Conveyors 612SC1-5 (for Sacks) Max Thruput: 52 tph; 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Xfer: Conveyors 612SC1-5 to 642BE1 or 641BE1 Max Thruput: 110 tph; 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Xfer: 641BE1 to Screw Conveyor Max Thruput: 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpyPermit #0982-09 FINAL:10/20/0 0 18 Pre-sacking Screen Max Thruput: 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.001764 lb/ton (AP-42 Table 11.1 9.2-2, Footnote c (1/95), SCC 3-05-020-02-03) Annual particulate emissions: 0.463 tpy Xfer: To One of Packing Bins 641PM1-4 Max Thruput: 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy

Xfer: From 641PM1-4 to Packer Max Thruput: 525,000 tpy

Control: Enclosure – control effici ency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Bags Xfer: Bags from Packer to One of 651BC1-4 Max Thruput: 525,000 tpy Control: Material in bags and enclosed – co ntrol efficiency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Bags Xfer: 651BC1-4 to 651BC5 Max Thruput: 525,000 tpy Control: Material in bags and enclosed – co ntrol efficiency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 1.983 tpy Bags Xfer: Maximum of 6 to Rail Loadout Max Thruput: 525,000 tpy Control: Material in bags – control efficiency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 11.897 tpy (i ncludes the maximum of six pathways) Fuel Usage: Diesel Fuel Max Thruput: 150,000 gal/yr

Control: 0% Emission factor: 17.7 lb/1000 gal (AP-42 Vol. II Mobile Sources, Supplement. A, Table II-7.1, off-highway trucks) Annual particulate emissions: 1.328 tpy Fuel Usage: Gasoline Max Thruput: 18,000 gal/yr

Control: 0% Emission factor: 6.1 lb/1000 gal (AP-42 Vol. II Mob ile Sources, Supplement A, Table II-7.2, miscellaneous) Annual particulate emissions: 0.055 tpy

Landfilled Cement Kiln Dust Max Thruput: 79,244 tpy Control: 50% (water spray as necessary in permit) Emission factor: 0.56 lb/ton produced (1999 AFS Plant Emission Inventory – 50% controlled EF) Annual particulate emissions: 22.188 tpy Pozzolan Material System Max Thruput: 7,412 dscfm Control: Baghouse (permit limit = 50,000 tons, 0.02 gr/dscfm) Emission factor: 0.02 gr/dscf (1 999 AFS Plant Emission Inventory) Annual particulate emissions: 5.565 tpy Slag Grinding Agent Storage Pile Max Thruput: 85,410 tpy

Control: 0% Emission factor: 1.1343 lb/ton (19 99 AFS Plant Emission Inventory) Annual particulate emissions: 48.440 tpy Slag Grinding Agent Xfer: Pile to Bins Max Thruput: 85,410 tpy

Control: Bins act as enclosure – contro l efficiency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.323 tpy Slag Grinding Agent Xfer: Bins to Conveyor Max Thruput: 85,410 tpy

Control: Bins act as enclosure – contro l efficiency included in emission factor Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 0.323 tpy Slag Grinding Agent Xfer: Conveyor to XXXXXX Max Thruput: 85,410 tpy

Control: 0% Emission factor: 0.182 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) Annual particulate emissions: 7.753 tpyPermit #0982-09 FINAL:10/20/0 0 19 Waste Oil Burner Max Thruput: 14,717 gal/yr

Control: 0% Emission factor: 39.98 lb/1000 gal (AP-42 Table 1.3-1 (9/98)) Annual particulate emissions: 0.294 tpy

V. Existing Air Quality

Holnam’s cement plant is located near the h eadwaters of the Missour i River in Gallatin County, Montana. Gallatin County is curren tly classified as a ttaining the National Ambient Air Quality Standards (NAAQS) for PM -10. The area’s climate is semi-arid and the primary land utilization in the area is agricultural.

VI. Ambient Air Impact Analysis

Because the current permitting action actually limits allowable particulate emissions, the department does not believe a violation of ambient air standards will occur as a result. No physical changes, no changes in the methods of operations, and no increases in actual emissions are included in this permit action.

VII. Taking or Damaging Implication Analysis

As required by 2-10-101 through 105, MCA, the department has conducted a private property taking and damaging a ssessment and has determined there are no taking or damaging implications.

VIII. Environmental Assessment

An environmental assessment, required by th e Montana Environmental Policy Act, was completed for this project. A copy is attached.Permit #0982-09 FINAL:10/20/0 0 20 DEPARTMENT OF ENVI RONMENTAL QUALITY Permitting and Compliance Division Air and Waste Management Bureau

1520 East Sixth Avenue P.O. Box 200901, Helena, Montana 59620-0901 (406) 444-3490

FINAL ENVIRONMENTA L ASSESSMENT (EA)

Issued For: Holnam, Inc.

4070 Trident Road Three Forks, MT 59752

Permit Number: 0982-09

Preliminary Determination on Permit Issued: 09/15/00 Department Decision Issued: 10/04/00

Final Permit Issued: 10/20/00

1. Legal Description of Site: The Holnam, Inc. (Holnam) facility is located in the Northeast 1⁄4 of Section 9, Southeast 1⁄4 of S ection 4, Southwest 1⁄4 of Section 3, Northwest 1⁄4 of Section 10, Township 2 North, Range 2 East, Gallatin County, Montana.

2. Description of Project: On August 10, 2000, Holnam submitted a permit application to request federally enforceable permit condi tions to limit potential particulate matter emissions. Holnam requested the federally enforceable conditions to ensure that the facility’s potential emissions would be within the “area sour ce” definition as defined in

the Portland Cement Maximum Achievable Control Technology (PC MACT). Although this permit action could have been acco mplished through a permit modification, an alteration was requested by Holnam to al low the public to comment on the permit.

3. Objectives of Project: To allow for potential emission calculations that would demonstrate the Holnam Trident Facility woul d be an area source for the purposes of PC MACT applicability.

4. Alternatives Considered: The only alternative would be the “no action” alternative which would include not issuing the perm it, making this environmental assessment unnecessary. The permit would not be issu ed without appropriate permit limitations allowing the source to maintain compliance w ith air standards. Because Holnam has demonstrated compliance with all applicable rules and regulations as required for permit issuance, the department has eliminated the “no action” alternative from further consideration. This permit action would not include any increase in emissions from the facility. New permit limitations would be added to the permit.

5. A listing of mitigation, sti pulations and other controls: A list of enforceable permit conditions and a complete permit analysis would be contained in Air Quality Permit

#0982-09.Permit #0982-09 FINAL:10/20/0 0 21 6. Regulatory effects on private property: The department has considered alternatives to the conditions imposed in this permit as part of the permit development. The department has determined that the permit conditions ar e reasonably necessary to ensure compliance with applicable requirements and to demons trate compliance with those requirements and do not unduly restrict private property rights.

7. The following table summarizes the potent ial physical and biological effects of the proposed project on the human environment. The "no action alternative" was discussed previously.

Major Moderate Minor None Unknown Comments

Included

A Terrestrial and Aquatic Life and Habitats X Yes

B Water Quality, Quantity, and Distribution X Yes

C Geology and Soil Quality, Stability, and Moisture X Yes

D Vegetation Cover, Quantity, and Quality X Yes

E Aesthetics X Yes

F Air Quality X Yes

G Unique Endangered, Fragile, or Limited Environmental

Resource X Yes

H Demands on Environmental Res ource of Water, Air, and Energy X Yes

I Historical and Archaeological Sites X Yes

J Cumulative and Secondary Impacts X Yes

SUMMARY OF COMMENTS ON POTENTI AL PHYSICAL AND BIOLOGICAL

EFFECTS: The following comments have b een prepared by the department.

A. Terrestrial and Aquatic Life and Habitats

This permitting action would re duce allowable emissions. No impacts to terrestrial life, aquatic life, and habitats are e xpected. This area does not ap pear to contain any critical or unique wildlife habitat or aquatic life.

B. Water Quality, Quantity, and Distribution

The actions addressed in this permit would not result in a change in the amount or characteristics of surface water discharged or the alteration of the course or magnitude of any drainage system. Furthermore, this acti on would not result in a change in the quality or quantity of ground water. Therefore, no impacts to water quality, quantity, and/or

distribution would occur.Permit #0982-09 FINAL:10/20/0 0 22 C. Geology and Soil Quality, Stability, and Moisture

No additional disturbance would be created from this action either inside or outside the current facility boundary. This project would not change th e soil stability or geologic

substructure or result in a ny increased disruption, displa cement, erosion, compaction, or moisture loss, which would reduce productivity or fertility at or near the site. No unique geologic or physical features would be disturbed. Theref ore, no impacts to geology and soil quality, stability, an d moisture would occur.

D. Vegetation Cover, Quantity, and Quality

This project involves the addi tion of emission limits only; th erefore, vegetative cover, quantity, and quality would not be disturbed inside or outside the facility boundaries. This action would not affect the diversity, productivity, or abundance of plant species in the surrounding areas.

E. Aesthetics

There would be no significant change in appearance or noise level.

F. Air Quality

Previously modeled levels of pollutants (prior to the emissi on limitations to be added in this action) show compliance with the National Ambient Air Quality Standards (NAAQS) and the Montana Ambient Air Quality Standards (MAAQS). No impact on air quality is expected.

G. Unique Endangered, Fragile, or Limited Environmental Resources

This permitting action would not result in imp acts to terrestrial and aquatic life and/or their habitat. The department is not aware of any unique, rare, threatened, or endangered species in the area surro unding the facility.

H. Demands on Environmental Resource of Water, Air, and Energy

This project would not consume any addi tional energy, air, or water resources.

I. Historical and Archaeological Sites

This project would not disturb a greater land surface than ha s already been occupied by the facility. To the best of the depart ment’s knowledge, there is no historical or archaeological site in this area. Accordi ng to the Montana State Historic Preservation Office, there would be low likelihood of di sturbance to any know n archaeological or historic site given any previ ous industrial disturbance in the area. Therefore, no impacts to any historical or archaeol ogical sites would occur.

J. Cumulative and Secondary Impacts

The emission limitations reflected in this pe rmit action would result in no cumulative and secondary impacts to terrestrial and aquati c habitats, water quality, and air quality.Permit #0982-09 FINAL:10/20/0 0 23 8. The following table summarizes the potential economic and social effects of the proposed project on the human environment. The "no action alternative" was discussed previously.

Major Moderate Minor None Unknown Comments

Included

A Social Structures and Mores X Yes

B Cultural Uniqueness and Diversity X Yes

C Local and State Tax Base and Tax Revenue X Yes

D Agricultural or Industrial Production X Yes

E Human Health X Yes

F Access to and Quality of Recreational and Wilderness

Activities X Yes

G Quantity and Distribution of Employment X Yes

H Distribution of Population X Yes

I Demands for Government Services X Yes

J Industrial and Commercial Activity X Yes

K Locally Adopted Environmental Plans and Goals X Yes

L Cumulative and Secondary Impacts X Yes

SUMMARY OF COMMENTS ON POTENTIAL ECONOMIC AND SOCIAL EFFECTS: The following comments have been prepared by the department.

A. Social Structures and Mores B. Cultural Uniqueness and Diversity H. Distribution of Population

This project would not involve any significant physical or operational change that would affect the location, distribution, density, or growth rate of the human population. In addition, the project would not alter the cultural uniqueness or diversity of the community surrounding the facility. The fundamental mo ral views of a social group would not be altered as a result of this permitting action.

C. Local and State Tax Base and Tax Revenue

I. Demands of Government Services

The changes to Holnam’s air quality permit w ould not result in a need for new or altered governmental services, nor adversely affect local or state tax bases or revenues.Permit #0982-09 FINAL:10/20/0 0 24 D. Agricultural or Industrial Production J. Industrial and Commercial Activity

This project would not result in a reduction of available acreage or productivity of any agricultural land; therefore, agricultural production would not be affected. Industrial production and commercial activity at the facility or in the neighboring area would not be altered by issuing permit #0982-09.

E. Human Health

The two primary vehicles for impact upon hum an health are water and air. This permitting action would not result in a change in the amount or charac teristics of surface water discharged or the quality or quantity of ground water. Therefore, human health impacts from water would not occur. The permit limitations reflected in this permit

action would decrease allowabl e pollutant and production levels . No health impacts from

either water or air would occur.

F. Access to and Quality of R ecreational and Wilderness Activities

This project would not alter any existing acce ss to or quality of any recreational or wilderness area. This project would not ha ve an impact on recreational or wilderness activities because the project would take pl ace within an existing facility’s boundaries.

G. Quantity and Distribution of Employment

This project would not result in any imp acts to the quantity and distribution of employment at the facility or surrounding community.

K. Locally Adopted Environmental Plans and Goals

There are no locally adopted environmental pl ans and goals that woul d be affected by the current permit action.

L. Cumulative and Secondary Impacts

No cumulative or secondary impacts woul d occur as a result of this action.

Recommendation: An EIS is not required.

If an EIS is not required, explain why the EA is an appropriate level of analysis: The action involves adding permit limitations, w ith no increase in pollutant le vels. The analysis indicates compliance with all applicable air quality rules and regulations.

Other groups or agencies contacted or wh ich may have overlapping jurisdiction: None.

Individuals or groups co ntributing to this EA: Department of Environmental Quality, Permitting and Compliance Division - Air and Waste Management Bureau.

EA prepared by: Debbie Skibicki

Date: 09/07/00