AIR QUALITY PERMIT

Issued to: Holnam, Inc. Permit: #0982-09 

4070 Trident Road Application Complete: 08/10/00 

Three Forks, MT 59752 Preliminary Determination Issued: 09/15/00 

 Department Decision Issued: 10/04/00 

 Final Permit Issued: 10/20/00 

 AFS #031-0005 

An air quality permit, with conditions, is hereby granted to Holnam, Inc. (Holnam) pursuant to 

Sections 75-2-204 and 211 of the Montana Code Annotated (MCA), as amended, and 

Administrative Rules of Montana (ARM) 17.8.701, et seq., as amended, for the following: 

SECTION I: Permitted Facilities 

A. Plant Location 

The Holnam facility is located in the Northeast 1⁄4 of Section 9, Southeast 1⁄4 of 

Section 4, Southwest 1⁄4 of Section 3, Northwest 1⁄4 of Section 10, Township 2 North, 

Range 2 East, Gallatin County, Montana. 

B. Current Permit Action 

On August 10, 2000, Holnam submitted a permit application to request federally 

enforceable permit conditions 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 source” 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 allow the public to comment on the permit. In 

addition, approved de minimis changes were included in the permit. 

SECTION II: Conditions and Limitations 

A. Emission Control Requirements 

Holnam shall install, operate, and maintain the following emission control equipment 

and practices, and all emission control equipment and practices as specified in their 

Montana air quality permit applications. 

1. Holnam shall operate and maintain the Finish Mill #2 pulsejet baghouse to control 

emissions from the equipment listed below (ARM 17.8.715). 

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 

Permit #0982-09 1 FINAL:10/20/00 
2. Holnam shall install, operate, and maintain the following baghouses to control 

emissions from the equipment listed below (ARM 17.8.715). 

a. A 3,800-acfm baghouse will control the following equipment: 

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

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

iii. The coke storage silo. 

b. A 1,500-acfm baghouse will control the following equipment:

i. Two diverter valves; 

ii. The hammermill; and 

iii. The bucket elevator. 

c. A 1,500-acfm baghouse will control the coal storage silo. 

3. Holnam shall operate and maintain the coke system pulsejet baghouse to control 

emissions from the equipment 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 grinding mill 

c. A 220-ton “fine” coke storage silo 

4. Holnam shall operate and maintain an electrostatic precipitator to control kiln 

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

5. Holnam shall operate and maintain a pulsejet baghouse to control clinker cooler 

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

6. Holnam shall operate and maintain 4 Micro-pulsaire dust collectors on the rock 

silos (ARM 17.8.710). 

7. Holnam shall operate and maintain 2 Micro-pulsaire dust collectors to control 

emissions from crushing and screening (ARM 17.8.710). 

8. Holnam shall operate and maintain a baghouse to control emissions at the clinker 

belt conveyor (ARM 17.8.710). 

9. Holnam shall operate and maintain a baghouse to control emissions at the dust bin 

near the precipitator (ARM 17.8.710). 

10. Holnam shall operate and maintain a baghouse to control emissions from the 

Portland cement silos (ARM 17.8.710). 

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11. Holnam shall operate and maintain a baghouse to control emissions from the 

Finish Mill #4 system (ARM 17.8.710). 

12. Holnam shall install, operate, and maintain a baghouse to control emissions from

the pozzolan material storage silo (ARM 17.8.715). 

13. Holnam shall install, use, and maintain enclosures around the pozzolan material 

system components listed below (ARM 17.8.715). 

a. Rotary feeder 

b. Weighbelt conveyor 

c. Screw line (conveyor) 

14. Holnam shall use water spray, as necessary, to maintain compliance with the 

opacity limitation in Section II.C.9 when handling landfilled cement kiln dust 

(ARM 17.8.715).

15. Whenever process equipment is operating, Holnam shall use and maintain, as they 

were intended, conveyor covers, transfer point covers, or structural enclosures 

surrounding process equipment (ARM 17.8.710).

B. Operational Limitations 

1. In the cement kiln, Holnam is authorized to burn up to 100% natural gas, up to 

100% coal, up to 25% coke, or any combination of these fuels within the 

previously stated limits (ARM 17.8.710). 

2. Holnam shall comply with ARM 17.8.322. 

3. Holnam shall not use, in any rolling 12-month period, greater than 50,000 tons of 

pozzolan material in the pozzolan material system (ARM 17.8.715). 

4. The amount of post-consumer recycled container glass used by Holnam in the 

cement kiln shall be limited to 800 tons during any rolling 12-month period 

(ARM 17.8.715). 

5. Holnam shall not handle, in any rolling 12-month period, greater than 85,000 tons 

of landfilled cement kiln dust (ARM 17.8.715). 

6. Holnam shall limit kiln production to 425,000 tons of clinker during any rolling 

12-month period (ARM 17.8.710). 

7. Holnam shall limit clinker handling to 500,000 tons during any rolling 12-month 

period (ARM 17.8.710). 

Permit #0982-09 3 FINAL:10/20/00 
C. Emission Limitations 

1. Holnam shall not cause or authorize to be discharged into the atmosphere any 

visible fugitive emissions that exhibit an opacity of 20% or greater averaged over 

6 consecutive minutes (ARM 17.8.308). 

2. Holnam shall not cause or authorize the use of any street, road or parking lot 

without taking reasonable precautions to control emissions of airborne particulate 

matter (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 chemical dust suppressant as 

necessary to maintain compliance with the reasonable precaution limitation

(ARM 17.8.710). 

4. Holnam shall not cause or authorize to be discharged into the atmosphere visible 

emissions from any source installed on or before November 23, 1968, that exhibit 

an opacity of 40% or greater averaged over 6 consecutive minutes (ARM 

17.8.304). 

5. Holnam shall not cause or authorize to be discharged into the atmosphere visible 

emissions from any source installed after November 23, 1968, that exhibit an 

opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304). 

6. Holnam shall not cause or authorize to be discharged into the atmosphere, from

the Finish Mill #2 baghouse: 

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

b. Visible emission which exhibit an opacity of 10% or greater averaged over 6 

consecutive minutes (ARM 17.8.340). 

7. Holnam shall not cause or authorized to be discharged into the atmosphere from

the 3,800 acfm and two 1,500 acfm baghouses (formerly the coal/coke baghouse): 

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

b. Visible emissions that exhibit an opacity of 20% or greater averaged over 6 

consecutive minutes (ARM 17.8.340). 

8. Holnam shall not cause or authorized to be discharged into the atmosphere from

the coke system baghouse: 

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

b. Visible emissions that exhibit an opacity of 20% or greater averaged over 6 

consecutive minutes (ARM 17.8.340). 

Permit #0982-09 4 FINAL:10/20/00 
9. Holnam shall not cause or authorize to be discharged into the atmosphere from

the pozzolan material silo baghouse (ARM 17.8.715): 

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

b. Visible emissions that exhibit an opacity of 20% or greater averaged over 6 

consecutive minutes. 

10. Holnam shall comply with all applicable requirements of ARM 17.8.340, which 

references 40 CFR Part 60, Standards of Performance for New Stationary 

Sources. 

a. Subpart F - Standards of Performance for Portland Cement Plants 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. 

b. Holnam shall not cause or authorize to be discharged into the atmosphere 

from the Finish Mill #4, visible emissions that exhibit 10% opacity or 

greater, as required by Subpart F of 40 CFR Part 60 (ARM 17.8.340). 

c. Holnam shall not cause or authorize to be discharged into the atmosphere 

from the Finish Mill #2, visible emissions that exhibit 10% opacity or 

greater, as required by Subpart F of 40 CFR Part 60 (ARM 17.8.340). 

d. Holnam shall not cause or authorize to be discharged into the atmosphere 

from Storage Silos #26 through 30, visible emissions 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 atmosphere visible 

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

minutes when handling landfilled cement kiln dust (ARM 17.8.710). 

12. Particulate matter emissions from the kiln are limited to 0.77 lb/ton of clinker 

produced (ARM 17.8.710). 

D. Testing Requirements 

1. Holnam shall conduct initial visible emission observations to assess compliance 

with the opacity limit in Section II.C.6 for the Finish Mill #2 baghouse within 180 

days of installation of the system. Holnam shall conduct additional visible 

emission observations at least once every 4 years thereafter, or according to 

another testing/monitoring schedule as may be approved by the Department of 

Environmental Quality (department) (ARM 17.8.105 and ARM 17.8.340). 

Permit #0982-09 5 FINAL:10/20/00 
2. Holnam shall conduct an initial performance source test on the Finish Mill #2 

baghouse to determine compliance with the applicable particulate emission limit 

in Section II.C.6 within 180 days of installation of the system. Holnam shall 

conduct additional particulate emission limit tests at least once every 4 years 

thereafter, or according to another testing/monitoring schedule as may be 

approved by the department (ARM 17.8.105, ARM 17.8.710, and ARM 

17.8.340). 

3. Holnam shall conduct initial visible emission observations to assess compliance 

with the opacity limit in Section II.C.7 for the coal/coke baghouse within 180 

days of installation of the system. Holnam shall conduct additional visible 

emission observations at least once every 4 years thereafter, or according to 

another testing/monitoring schedule as may be approved by the department (ARM 

17.8.105 and ARM 17.8.710). 

4. Holnam shall conduct an initial performance source test on the coal/coke 

baghouse to determine compliance with the applicable particulate emission limit 

in Section II.C.7 within 180 days of installation of the system. Holnam shall 

conduct additional particulate emission limit tests at least once every 4 years 

thereafter, or according to another testing/monitoring schedule as may be 

approved by the department (ARM 17.8.105 and ARM 17.8.710). 

5. Holnam shall conduct initial visible emission observations to assess compliance 

with the opacity limit in Section II.C.8 for the coke system baghouse within 180 

days of installation of the system. Holnam shall conduct additional visible 

emission observations at least once every 4 years thereafter, or according to 

another testing/monitoring schedule as may be approved by the department (ARM 

17.8.105 and ARM 17.8.710). 

6. Holnam shall conduct an initial performance source test on the coke system 

baghouse to determine compliance with the applicable particulate emission limit 

in Section II.C.8 within 180 days of installation of the system. Holnam shall 

conduct additional particulate emission limit tests at least once every 4 years 

thereafter, or according to another testing/monitoring schedule as may be 

approved by the department (ARM 17.8.105 and ARM 17.8.710). 

7. Holnam shall conduct an initial performance source test on the kiln to determine 

compliance with the applicable particulate emission limit in Section II.C.12 

within 180 days of installation of the system. Holnam shall conduct additional 

particulate emission limit tests at least once every 4 years thereafter, or according 

to another testing/monitoring schedule as may be approved by the department 

(ARM 17.8.105 and ARM 17.8.710). 

8. All compliance source tests shall conform to the requirements of the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.106). 

9. The department may require further testing (ARM 17.8.105). 

Permit #0982-09 6 FINAL:10/20/00 
E. Operational Reporting Requirements

1. Holnam shall supply the department with annual production information for all 

emission points, as required by the department in the annual emission inventory

request. The request will include, but is not limited to the amount of pozzolan 

material used, the amount of post-consumer recycled container glass used in the kiln, 

the amount of landfilled cement kiln dust handled, the amount of clinker produced in 

the kiln, and the amount of total product handled (ARM 17.8.710). 

Production information shall be gathered on a calendar-year basis and submitted to 

the department by the date required in the emission inventory request. Information 

shall be in the units required by the department. This information may be used for 

calculating operating fees, based on actual emissions from the facility, and/or to 

verify compliance with permit limitations (ARM 17.8.505). 

2. Holnam shall notify the department of any construction or improvement project 

conducted, pursuant to ARM 17.8.705(1)(r), that would include a change in control 

equipment, stack height, stack diameter, stack flow, stack gas temperature, source 

location, or fuel specifications, or would result in an increase in source capacity

above its permitted operation or the addition of a new emission unit. The notice must 

be submitted to the department, in writing, 10 days prior to start up or use of the 

proposed de minimis change, or as soon as reasonably practicable in the event of an 

unanticipated circumstance causing the de minimis change, and must include the 

information requested in ARM 17.8.705(1)(r)(iv) (ARM 17.8.705). 

3. Holnam shall document, by month, the amount of pozzolan material used in the 

pozzolan material system. By the 3rd day of each month, Holnam shall total the 

amount of pozzolan material use during the previous 12 months to verify compliance 

with the limitation in Section II.B.5. The records compiled shall be maintained by

Holnam as a permanent business record for at least 5 years following the date of the 

recording, shall be submitted to the department upon request, and shall be available at 

the plant site for inspection by the department (ARM 17.8.710).

4. Holnam shall document, by month, the amount of post-consumer recycled container 

glass used in the kiln. By the 3rd day of each month, Holnam shall total the amount of 

recycled glass used in the kiln during the previous 12 months to verify compliance 

with the limitation in Section II.B.6. A written report of the compliance verification, 

including the previous 12-month totals of recycled glass used, shall be submitted 

annually to the department no later than March 1 and may be submitted along with 

the annual emission inventory (ARM 17.8.710). 

5. Holnam shall document, by month, the amount of landfilled cement kiln dust 

handled. By the 3rd day of each month, Holnam shall total the amount of cement kiln 

dust handled during the previous 12 months to verify compliance with the limitation 

in Section II.B.7. A written report of the compliance verification, including the 

previous 12-month totals of landfilled cement kiln dust handled, shall be submitted 

annually to the department no later than March 1 and may be submitted along with 

the annual emission inventory (ARM 17.8.710). 

Permit #0982-09 7 FINAL:10/20/00 
6. Holnam shall document that conveyor covers, transfer point covers, or structural 

enclosures surrounding process equipment were maintained and in place during 

operation of process equipment. The records shall include all repair and 

maintenance activity to all conveyor covers, transfer point covers, or structural 

enclosures. The records must include, but is not limited to, the date, time, and 

action(s) taken for repair and maintenance. 

F. Petroleum Coke Test Burn Limitations 

1. Operating Conditions 

a. Holnam is authorized to burn petroleum coke in excess of 25% (based on the 

total BTU input required) in conjunction with natural gas and coal during the 

test burn (ARM 17.8.710). 

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

limited to 30,400.0 tons. The test burn period begins on the date that greater 

than 25% coke is burned in the kiln and ends one year from the starting date 

(ARM 17.8.710). 

c. Holnam shall notify the department, in writing, within 10 days of the 

beginning of the test burn period. Notification was received by the 

department that test burning began on November 14, 1999 (ARM 17.8.710). 

d. Holnam shall comply with ARM 17.8.322(6)(c). 

e. Holnam shall maintain a log of the amount of coke used in the kiln each day 

during the test burn period (ARM 17.8.710). 

2. Testing Requirements 

a. Holnam shall conduct source tests on the kiln for NOx and SO2, 

concurrently. The tests must be conducted at least once during the test burn. 

The timing of the test is at the discretion of Holnam, but must occur during 

the test burn when the maximum amount of petroleum coke is being fired in 

conjunction with natural gas. In addition, a test is required when the 

maximum amount of petroleum coke is being fired in conjunction with coal. 

These testing requirements may be modified upon written agreement with 

the department (ARM 17.8.105). 

b. During the source tests required in Section II.F.2.a, Holnam shall conduct an 

analysis of the clinker produced and the cement kiln dust to determine the 

concentration of sulfur in each. This information shall be submitted to the

department, along with the results of the source tests (ARM 17.8.710). 

c. During the source tests required in Section II.F.2.a, Holnam shall record the 

following information: 

Permit #0982-09 8 FINAL:10/20/00 
(i) Clinker production rate, 

(ii) Coke combustion rate, 

(iii) Natural gas combustion rate, 

(iv) Coal combustion rate, and 

(v) Percent oxygen at the kiln outlet. 

This information shall be recorded on an hourly basis during the 

performance of the source tests and shall be submitted with the source tests 

report (ARM 17.8.710). 

d. All source tests required by the department shall be conducted in accordance 

with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106). 

e. The department may require further testing (ARM 17.8.105). 

SECTION III: General Conditions 

A. Inspection – Holnam shall allow the department's representatives access to the source 

at all times for the purpose of making inspections or surveys, collecting samples, 

obtaining data, auditing any monitoring equipment (CEMS, CERMS) or observing 

any monitoring or testing, and otherwise conducting all necessary functions related to 

this permit. 

B. Waiver – The permit and all the terms, conditions, and matters stated herein shall be 

deemed accepted if Holnam fails to appeal as indicated below. 

C. Compliance with Statutes and Regulations – Nothing in this 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 17.8.701, 

et seq. (ARM 17.8.717). 

D. Enforcement – Violations of limitations, conditions and requirements contained 

herein may constitute grounds for permit revocation, penalties or other enforcement 

as specified in Section 75-2-401, et seq., MCA. 

E. Appeals – Any person or persons jointly or severally adversely affected by the 

department's decision may request, within 15 days after the department renders its 

decision, upon affidavit setting forth the grounds therefor, a hearing before the Board 

of Environmental Review (Board). A hearing shall be held under the provisions of 

the Montana Administrative Procedures Act. The department's decision on the 

application is not final unless 15 days have elapsed and there is no request for a 

hearing under this section. The filing of a request for a hearing postpones the 

effective date of the department's decision until the conclusion of the hearing and 

issuance of a final decision by the Board. 

Permit #0982-09 9 FINAL:10/20/00 
F. Permit Inspection – As required by ARM 17.8.716, Inspection of Permit, a copy of 

the air quality permit shall be made available for inspection by department personnel 

at the location of the permitted source. 

G. Permit Fee – Pursuant to Section 75-2-220, MCA, as amended by the 1991 

Legislature, failure to pay the annual operation fee by Holnam may be grounds for 

revocation of this permit, as required by that Section and rules adopted thereunder by 

the Board. 

Permit #0982-09 10 FINAL:10/20/00 
Permit #0982-09 FINAL:10/20/0 1 0 

PERMIT ANALYSIS 

Holnam, Inc. 

Permit #0982-09 

I. Introduction 

A. Facility Description 

Holnam, Inc. (Holnam) operates a cement manufacturing 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 materials and iron ore purchased from outside 

vendors are crushed, screened, and stored in dedicated silos. 

Measured amounts of each material are conveyed 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 clinker is then sent to the clinker cooler 

where it is cooled from 2,500 °F to 150 °F. The clinker is then transferred to storage 

silos or alternative storage sites (usually covered) 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 2 0 

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 Kiln 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 pieces of control equipment, as follows: 

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

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

2. A pulsejet type baghouse to control clinker 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 ft2 cloth area, Model IF124 

2 @ 7.8:1 air/cloth ratio, 670 ft2

 cloth area 

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

screening: 

Crushing – Micro-pulsaire model IFI-48, 7200 cfm capacity fan 

Screening – Micro-pulsaire model IFI-24, 6400 cfm capacity fan 
Permit #0982-09 FINAL:10/20/0 3 0 

5. One small baghouse to control emissions 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. These silos are controlled by a baghouse. 

On January 6, 1984, a modification to permit #811-050475 was issued to Ideal Basic 

Industries, which allowed the gas/coal-fired 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 existing dust collectors on the coal/coke 

process with one unit; and construct a separate coke grinding, storage, and transport 

system with dust collection. 

The Finish Mill #2 baghouse, which replaced 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 necessary for the transport of cement from the 

elevator to the product separator (air separator). 
Permit #0982-09 FINAL:10/20/0 4 0 

The replacement of two existing dust collectors 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 coal/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/coke storage silo. The proposed raw coke 

storage silo gravity feeds onto a covered belt 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 “fine” coke storage silo. Pneumatic 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 application 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 pozzolan 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 that were outdated. 
Permit #0982-09 FINAL:10/20/0 5 0 

Permit #0982-03 had included conditions from permits #282-072171, #293-080471, 

#811-050475, #982, and modification #811-050475. Therefore, 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 operational limit in Section II.B.1. The amount 

of petroleum coke burned in the kiln was limited so that 15 tons per year of SO2 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 maintain records to demonstrate compliance 

with the petroleum coke limitation in Section 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 the kiln exhaust through the use of an 

electrostatic precipitator (ESP) in Section 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 pollutants being emitted as a result of using 

post-consumer recycled container glass. Holnam submitted a health risk assessment, 

which demonstrated that this proposal would 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 landfill with a front-end loader to a truck. 

The cement kiln dust would be sold for use 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 material 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 collector, and not the entire facility. Also, 

condition II.E.3 was updated to reflect this correction. Permit #0982-08 replaced 

permit #0982-07. 
Permit #0982-09 FINAL:10/20/0 6 0 

D. Current Permit Action 

On August 10, 2000, Holnam submitted a permit application to request federally 

enforceable permit conditions 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 source” 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 allow 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 explanations of some applicable rules and regulations that apply 

to the facility. The complete rules are stated 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 and regulations or copies where appropriate. 

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

1. ARM 17.8.101 Definitions. This section includes a list of applicable definitions 

used in this chapter, unless indicated otherwise in a specific subchapter. 

2. ARM 17.8.105 Testing Requirements. Any person or persons responsible for the 

emission of any air contaminant into the outdoor atmosphere shall, upon written 

request of the department, provide the facilities and necessary equipment 

(including instruments and sensing devices) and shall conduct tests, emission or 

ambient, for such periods of time as may 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 the 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 provisions of the Clean Air Act of Montana, 75-2-

101, et seq., MCA.

Holnam shall comply with the requirements contained in the Montana Source 

Test Protocol and Procedures Manual, including, but not limited to, using the 

proper test methods and supplying the required reports. A copy of the Montana 

Source Test Protocol and Procedures Manual is available from the department 

upon request. 
Permit #0982-09 FINAL:10/20/0 7 0 

4. ARM 17.8.110 Malfunctions. The department must be notified promptly by 

telephone whenever a malfunction occurs that can be expected to create emissions 

in excess of any applicable emission limitation, 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, without resulting in reduction in the total 

amount of air contaminant emitted, conceals or dilutes an emission of air 

contaminant which would otherwise violate an air pollution control regulation. 

No equipment that may produce emissions shall 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 Standards for Nitrogen Dioxide,

4. ARM 17.8.212 Ambient Air Quality Standards for Carbon Monoxide, 

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

6. ARM 17.8.221 Ambient Air Quality Standard for Visibility, 

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

8. ARM 17.8.223 Ambient Air Quality Standard for PM10. 

Holnam must maintain compliance with the applicable ambient air quality standards. 

C. ARM 17.8, Subchapter 3 - Emission Standards, 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 discharged 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 particulate matter are 

taken. Such emissions of airborne particulate 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 cause, 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 Matter, 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 8 0 

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, gases, dusts, or any combination thereof 

which create odors, shall provide, properly install, and maintain in good working 

order and operation such odor control devices 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 Performance for New Stationary Sources. This 

section incorporates, by reference, 40 CFR Part 60, Standards of Performance for 

New Stationary Sources (NSPS). The owner and operator of any stationary 

source or modification, as defined and applied 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 are applicable to the following affected facilities in 

Portland cement plants: kiln, clinker cooler, raw mill system, finish mill system, 

raw mill dryer, raw material storage, clinker 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 modification 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 Finish Mill #1 in 1988 and the product storage silos were 

installed in 1976. Since commencement of construction occurred after August 17, 

1971 for both of these sources, 40 CFR 60 Subpart 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 modification 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 reference, 40 CFR Part 63, National 

Emission Standards for Hazardous Air Pollutants (NESHAPs). The owner and 

operator of any stationary source or modification, as defined and applied in 40 

CFR Part 63, shall comply with the standards and provisions of 40 CFR Part 63. 
Permit #0982-09 FINAL:10/20/0 9 0 

Subpart LLL – National Emission Standards for Hazardous Air Pollutants for The 

Portland Cement Manufacturing Industry. The Holnam Trident Plant must 

comply with all applicable requirements of this Subpart. On October 14, 1999, 

the department received initial notification 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 application. A permit application is incomplete 

until the proper application fee is paid to the department. Holnam submitted the 

appropriate permit application fee 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 operation, be submitted to the department by 

each source of air contaminants holding an air quality permit, excluding an open 

burning permit, issued by the department; and the air quality operation fee is 

based on the actual or estimated actual amount 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 and collection of the air 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 air quality operation 

fee on a calendar-year basis, including provisions which pro-rate the required fee 

amount. 

E. ARM 17.8, Subchapter 7 - Permit, Construction and Operation of Air Contaminant 

Sources, including, but not limited to: 

1. ARM 17.8.704 General Procedures for Air Quality Preconstruction Permitting. 

This air quality preconstruction permit contains requirements and conditions 

applicable to both construction and subsequent 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 alteration if they construct, alter, or use 

any air contaminant sources which have the 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 the current permit action. 
Permit #0982-09 FINAL:10/20/0 10 0 

4. ARM 17.8.710 Condition of Issuance of Permit. This section requires that 

Holnam demonstrate compliance with applicable 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 applicable 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 control 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 administrative 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 with the public notice requirements. 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 altered source may contain a condition providing 

that the permit will expire unless construction 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 source or stack which do not result in an 

increase in emissions because of those 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 person to another if written notice of intent to transfer, 

including the names of the transferor and the transferee, is sent to the department. 
Permit #0982-09 FINAL:10/20/0 11 0 

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 Stationary Sources and Major Modifications--

Source Applicability and Exemptions. The requirements contained in ARM 

17.8.819 through 17.8.827 shall apply to any major stationary source and any 

major modification with respect to each pollutant 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 emissions as a result of this permitting action. 

G. ARM 17.8, Subchapter 12 - Operating Permit 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/year of any one hazardous air pollutant 

(HAP), 

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

c) Lesser quantity as the department 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 that all sources, as defined in ARM 

17.8.1204 (1), obtain a Title V Operating Permit. 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, except that best available control 

technology shall be utilized. 

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

administrative action and no new or altered sources were addressed. 

 
Permit #0982-09 FINAL:10/20/0 12 0 

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 (National 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 Table 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 (1999 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)– 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 

 Xfer: 211BC4 to 1 of 7 Silos 

Max Thruput: 450 tph; 865,500 tpy 

Control: Enclosed conveyors (in building)– 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 

 Xfer: 1 of 7 Silos to 331BC1 

Max Thruput: 130 tph; 865,500 tpy 

Control: Enclosed in building and 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 

 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 – control 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 tpy 
Permit #0982-09 FINAL:10/20/0 13 0 

 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 11.19.2-2, 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 11.19.2-2, 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 11.19.2-2, 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/dscf (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 (Control 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 – 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 Precipitator to 421SC1,2,3 

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 421SC1 to 421SC4 

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 
Permit #0982-09 FINAL:10/20/0 14 0 

 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 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: 421SC5 to Dustless Unloader 

Max Thruput: 10 tph; 79,244 tpy 

Control: Enclosed (wet material in dustless unloader) – 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 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: 0.021 tpy 

 Xfer: #491CV1 to 491CV2 

Max Thruput: 75 tph; 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy

Xfer: 491CV2 to 491BE2 

Max Thruput: 75 tph; 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy 

 Xfer: 491BE2 to 491CV3 

Max Thruput: 75 tph; 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy 

 Xfer: 491CV3 to Emergency Storage Silos 

Max Thruput: 75 tph; 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy 

 Xfer: Emergency Storage Silos 1 - 4 to Truck 

Max Thruput: 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy 

 Xfer: #491CV1 to 491BE1 

Max Thruput: 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy 

 Xfer: #491BE1 to #491BC1 

Max Thruput: 75 tph; 425,000 tpy 

Control: Enclosure – 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: 0.021 tpy 

 Xfer: #491BC1 to Clinker Storage Silos 

Max Thruput: 75 tph; 425,000 tpy 

Control: Conveyors have tall sides and carry large material – control 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: 0.021 tpy 
Permit #0982-09 FINAL:10/20/0 15 0 

 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 11.19.2-2, 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 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: 0.004 tpy 

 Import Clinker Xfer: Belt Conveyor to Silos 2A and 2B 

Max Thruput: 75,000 tpy 

Control: Enclosure – 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: 0.004 tpy 

 Overflow Clinker Xfer: Clinker Storage 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 11.19.2-2, 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 11.19.2-2, 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 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: 0.013 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 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: 0.013 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 11.19.2-2, 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 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: 0.002 tpy 

 Gypsum Xfer: Belt Conveyor to Interstice Bin 

Max Thruput: 100 tph; 48,000 tpy 

Control: Enclosure – 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: 0.002 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 11.19.2-2, 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 11.19.2-2, 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 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: 0.002 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 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: 0.002 tpy 
Permit #0982-09 FINAL:10/20/0 16 0 

 Xfer: Clinker Silos 1A, 1B, & Interstice to 534BC1 

Max Thruput: 66.5 tph; 395,000 tpy 

Control: Enclosure – 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: 0.020 tpy 

 Xfer: 534BC1 to #4 Finish Mill 

Max Thruput: 395,000 tpy 

Control: Enclosure – control efficiency 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 efficiency 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 efficiency 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 efficiency 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 efficiency 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 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: 0.012 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 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: 0.012 tpy 

 Xfer: 533BC1 to Finish Mill #3 

Max Thruput: 245,280 tpy 

Control: Enclosure – control efficiency included in emission factor 

Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) 

Annual particulate emissions: 0.926 tpy 

 Xfer: Finish Mill #3 to 593BE1 

Max Thruput: 245,280 tpy 

Control: Enclosure – control efficiency included in emission factor 

Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) 

Annual particulate emissions: 0.926 tpy 

 Xfer: 593BE1to 593AS1 

Max Thruput: 245,280 tpy 

Control: Enclosure – control efficiency included in emission factor 

Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) 

Annual particulate emissions: 0.926 tpy 

 Xfer: 593AS1 thru 593SR1 to 592SC2 or 593AS2 

Max Thruput: 245,280 tpy 

Control: Enclosure – control efficiency included in emission factor 

Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) 

Annual particulate emissions: 0.926 tpy 

 Xfer: Cement to Cement Cooler 

Max Thruput: 94 tph; 525,000 tpy 

Control: Enclosure – control 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 
Permit #0982-09 FINAL:10/20/0 17 0 

 Xfer: Cement Cooler to Silos and Bins 

Max Thruput: 525,000 tpy 

Control: Enclosure – control 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 

 Xfer: Silos 1 - 13 to Screw Conveyors 

Max Thruput: 525,000 tpy 

Control: Enclosure – control 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 

 Xfer: Screw Conveyors to 612BE2 or 612BE1 

Max Thruput: 103 tph; 525,000 tpy 

Control: Enclosure – control 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 

 Scalping Screen 601SV1 

Max Thruput: 103 tph; 525,000 tpy 

Control: Enclosure – control efficiency included in emission factor 

Emission factor: 0.001764 lb/ton (AP-42 Table 11.19.2-2, 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 efficiency 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 efficiency 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 efficiency 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 efficiency 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 efficiency 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 efficiency 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 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 

 Xfer: Conveyors 612SC1-5 to 642BE1 or 641BE1 

Max Thruput: 110 tph; 525,000 tpy 

Control: Enclosure – control 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 

 Xfer: 641BE1 to Screw Conveyor 

Max Thruput: 525,000 tpy 

Control: Enclosure – control 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 
Permit #0982-09 FINAL:10/20/0 18 0 

 Pre-sacking Screen 

Max Thruput: 525,000 tpy 

Control: Enclosure – control efficiency included in emission factor 

Emission factor: 0.001764 lb/ton (AP-42 Table 11.19.2-2, 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 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 

 Xfer: From 641PM1-4 to Packer 

Max Thruput: 525,000 tpy 

Control: Enclosure – control 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: Bags from Packer to One of 651BC1-4 

Max Thruput: 525,000 tpy 

Control: Material in bags and 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: 1.983 tpy 

 Bags Xfer: 651BC1-4 to 651BC5 

Max Thruput: 525,000 tpy 

Control: Material in bags and 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: 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 (includes 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 Mobile 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 (1999 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 (1999 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 – control efficiency included in emission factor 

Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) 

Annual particulate emissions: 0.323 tpy 

 Slag Grinding Agent Xfer: Bins to Conveyor 

Max Thruput: 85,410 tpy 

Control: Bins act as enclosure – control efficiency included in emission factor 

Emission factor: 0.008 lb/ton (AP-42 13.2.4. Eq. 1 (1/95)) 

Annual particulate emissions: 0.323 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 tpy 
Permit #0982-09 FINAL:10/20/0 19 0 

 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 headwaters of the Missouri River in Gallatin 

County, Montana. Gallatin County is currently classified as attaining 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 assessment and has determined there are no taking or 

damaging implications. 

VIII. Environmental Assessment 

An environmental assessment, required by the Montana Environmental Policy Act, was 

completed for this project. A copy is attached. 
Permit #0982-09 FINAL:10/20/0 20 0 

DEPARTMENT OF ENVIRONMENTAL 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 ENVIRONMENTAL 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 Section 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 conditions 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 source” 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 allow the public to comment on the permit. 

3. Objectives of Project: To allow for potential emission calculations that would 

demonstrate the Holnam Trident Facility would 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 permit, making this environmental assessment 

unnecessary. The permit would not be issued without appropriate permit limitations 

allowing the source to maintain compliance with 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, stipulations 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 21 0 

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 are reasonably necessary to ensure compliance 

with applicable requirements and to demonstrate compliance with those requirements and 

do not unduly restrict private property rights. 

7. The following table summarizes the potential 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 Resource 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 POTENTIAL PHYSICAL AND BIOLOGICAL 

EFFECTS: The following comments have been prepared by the department. 

 A. Terrestrial and Aquatic Life and Habitats 

This permitting action would reduce allowable emissions. No impacts to terrestrial life, 

aquatic life, and habitats are expected. This area does not appear 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 action 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 22 0 

 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 the soil stability or geologic 

substructure or result in any increased disruption, displacement, 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. Therefore, no impacts to geology and 

soil quality, stability, and moisture would occur.

 D. Vegetation Cover, Quantity, and Quality 

This project involves the addition of emission limits only; therefore, 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 emission 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 impacts 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 surrounding the facility. 

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

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

 I. Historical and Archaeological Sites 

This project would not disturb a greater land surface than has already been occupied by 

the facility. To the best of the department’s knowledge, there is no historical or 

archaeological site in this area. According to the Montana State Historic Preservation 

Office, there would be low likelihood of disturbance to any known archaeological or 

historic site given any previous industrial disturbance in the area. Therefore, no impacts 

to any historical or archaeological sites would occur. 

 J. Cumulative and Secondary Impacts 

The emission limitations reflected in this permit action would result in no cumulative and 

secondary impacts to terrestrial and aquatic habitats, water quality, and air quality. 
Permit #0982-09 FINAL:10/20/0 23 0 

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 moral 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 would 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 24 0 

 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 human health are water and air. This 

permitting action would not result in a change in the amount or characteristics 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 allowable pollutant and production levels. No health impacts from 

either water or air would occur. 

 F. Access to and Quality of Recreational and Wilderness Activities 

This project would not alter any existing access to or quality of any recreational or 

wilderness area. This project would not have an impact on recreational or wilderness 

activities because the project would take place within an existing facility’s boundaries. 

 G. Quantity and Distribution of Employment 

This project would not result in any impacts 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 plans and goals that would be affected by the 

current permit action. 

 L. Cumulative and Secondary Impacts 

No cumulative or secondary impacts would 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, with no increase in pollutant levels. The analysis indicates 

compliance with all applicable air quality rules and regulations. 

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

Individuals or groups contributing 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