Michigan Department Of Environmental Quality

Air Quality Division

State Registration 

Number

RO Permit Number

B1743 RENEWABLE OPERATING PERMIT MI-ROP-B1743-2004

IS HEREBY ISSUED TO

Holcim (US), Inc.

SRN: B1743

LOCATED AT

15215 Day Rd., Dundee Township, Michigan 48131

Permit Number: MI-ROP-B1743-2004

Effective Date: April 27, 2004

Expiration Date: April 27, 2009

This permit is issued in accordance with and subject to Part 5506(3) of Article II, Chapter 1, Part 55 (Air 

Pollution Control) of P.A. 451 of 1994. Pursuant to Air Pollution Control Rule 336.1210(1), this permit 

constitutes the permittee’s authority to operate the major stationary source identified above in 

accordance with the general conditions, special conditions and attachments contained herein. Operation 

of the major stationary source and all emission unit/process groups listed in the permit are subject to all 

applicable future or amended rules and regulations pursuant to P.A. 451 and the Clean Air Act.

This permit does not relieve the permittee from the responsibility to obtain the necessary permits to 

install pursuant to Air Pollution Control Rule 336.1201 for new or modified process or process equipment. 

In addition, issuance of this renewable operating permit does not obviate the necessity of obtaining such 

permits or approvals from other units of government as required by law.

This permit does not relieve the permittee from any responsibilities or obligations imposed on the 

permittee, at this source, under Consent Order No. 22-1999, entered on August 11, 1999, between the 

MDEQ and the permittee and Consent Judgment 00-11363-CZ, entered on July 14, 2000.

The conditions contained in this Renewable Operating Permit for which a Consent Judgment or Consent 

Order identified applicable requirement shall be considered null and void upon the effective date of 

termination of the Consent Judgment or Consent Order. The effective date of termination is defined for 

the purposes of this condition as the date upon which the Termination Order is signed by the Chief of the 

Air Quality Division.

Michigan Department of Environmental Quality

______________________________________

G. Vinson Hellwig, Chief

Air Quality Division
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 2 of 136

Table of Contents

A. GENERAL REQUIREMENTS 4

Enforceability 4

General Conditions 4

Recordkeeping and Reporting 6

Compliance Reporting and Certification 7

Permit Shield 7

Stratospheric Ozone Protection 8

Risk Management Plan 8

B. SOURCE-WIDE REQUIREMENTS 11

C. EMISSION UNIT/PROCESS GROUP SUMMARY TABLE 13

D. FLEXIBLE GROUPINGS SUMMARY TABLE 17

E. EMISSION UNIT/PROCESS GROUP REQUIREMENTS 19

TABLE E-1.1 EG001-9 20

TABLE E-1.2 EG013 22

TABLE E-1.3 EG014 24

TABLE E-1.4 EG023 26

TABLE E-1.5 EG024 28

TABLE E-1.6 EG030 30

TABLE E-1.7 EG031 32

TABLE E-1.8 EG035 34

F. FLEXIBLE GROUPING REQUIREMENTS 36

TABLE F-1.1 FG001 37

TABLE F-1.2 FG002 40

TABLE F-1.3 FG003 43

TABLE F-1.4 FG004 46
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 3 of 136

TABLE F-1.5 FG005 48

TABLE F-1.6 FG006 50

TABLE F-1.7 FG007 52

TABLE F-1.8 FG008 54

TABLE F-1.9 FG009 69

TABLE F-1.10 FG010 71

TABLE F-1-11 FG011 73

TABLE F-1.12 FG012 75

TABLE F-1.13 FGCOLDCLEANERS 77

TABLE F-1.14 FG014 80

TABLE F-1.15 FG015 82

G. NON-APPLICABLE REQUIREMENTS 85

APPENDICES 87

Appendix 1. Abbreviations Used in This Permit 87

Appendix 2. Schedule of Compliance 89

Appendix 3. Monitoring Requirements 90

Appendix 4. Recordkeeping 109

Appendix 5. Testing Procedures 110

Appendix 6. Permits to Install/Operate 119

Appendix 7. Emission Calculations 120

Appendix 8. Reporting 121
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 4 of 136

A. General Requirements

For the purpose of this Renewable Operating (RO) Permit, the permittee is defined as any person who owns or 

operates a process or process equipment at a stationary source for which a RO Permit has been issued. This permit 

is issued to Holcim (US), Inc. Manufacturer of Portland Cement, hereinafter the permittee for this RO Permit. The 

department is defined in R336.1104(d) as the Director of the Department of Environmental Quality or his or her 

designee. 

Enforceability

All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. Those 

requirements which are enforceable by the state only are designated by an asterisk. (R 336.1213(5))

General Conditions

1. A challenge by any person, the Administrator of the EPA, or the department to a particular condition or a part 

of this RO Permit shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any 

other condition or part of this RO Permit. (R 336.1213(1)(f))

2. Except as provided in subrules 2, 3, and 4 of R 336.1301, a person shall not cause or permit to be discharged 

into the outer air from an emission unit/process group a visible emission of a density greater than the most 

stringent of R336.1301(1)(a) or (b) unless otherwise specified in this RO Permit. The grading of visible 

emissions shall be determined in accordance with R 336.1303. (R 336.1301(1) in pertinent part):

a) A 6-minute average of 20% opacity, except for one 6-minute average per hour of not more than 27% 

opacity. 

b) A limit specified by an applicable federal new source performance standard.

3. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 

and II areas requires the use of material handling methods specified in R 336.1370(2). (R 336.1370)

4. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in

accordance with the Michigan Air Pollution Control rules and existing law. (R 336.1910)

5. The department may require the owner or operator of any source of an air contaminant to conduct acceptable 

performance tests, at the owner’s or operator’s expense, in accordance with R 336.2001 and R 336.2003, 

under any of the conditions listed in R 336.2001(1). (R 336.2001)

6. A change in ownership or operational control of a stationary source covered by a RO Permit shall be made 

pursuant to R 336.1216(1). (R 336.1219(3)) 

7. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that 

cause, alone or in reaction with other air contaminants, either of the following: 

a) Injurious effects to human health or safety, animal life, plant life of significant economic value, or 

property. (R 336.1901(a)*)

b) Unreasonable interference with the comfortable enjoyment of life and property. (R 336.1901(b)*)

8. The permittee shall comply with all conditions of this RO Permit. Any permit noncompliance constitutes a 

violation of Act 451 of 1994, as amended, Part 55, (Air Pollution Control) and is grounds for enforcement 

action, for permit revocation or revision, or for denial of the renewal of the RO Permit. All terms and conditions 

of this RO Permit that are designated as federally enforceable are enforceable by the Administrator of the 

EPA and by citizens under the provisions of the CAA. Any terms and conditions based on applicable 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 5 of 136

requirements which are designated as “state only” are not enforceable by the EPA or citizens pursuant to the 

CAA. (R 336.1213(1)(a))

9. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt 

or reduce the permitted activity in order to maintain compliance with the conditions of this RO Permit. 

(R 336.1213(1)(b))

10. This RO Permit may be modified, revised, or revoked for cause. The filing of a request by the permittee for a 

permit modification, revision, or termination, or a notification of planned changes or anticipated noncompliance 

does not stay any permit condition. Pursuant to R 336.1215 and R 336.1216 the permittee may make 

changes at a stationary source at his/her own risk. (R 336.1213(1)(c))

11. The permittee shall furnish to the department, within a reasonable time, any information the department may 

request, in writing, to determine whether cause exists for modifying, revising, or revoking the RO Permit or to 

determine compliance with this RO Permit. Upon request, a person shall also furnish to the department 

copies of any records that are required to be kept as a term or condition of this RO Permit. (R 336.1213(1)(e))

12. The permittee shall allow the department, or an authorized representative of the department, upon

presentation of credentials and other documents as may be required by law and upon stating the authority for 

and purpose of the investigation, to perform any of the following activities (R 336.1213(1)(d)):

a) Enter, at reasonable times, a stationary source or other premises where emissions-related activity is 

conducted or where records must be kept under the conditions of the permit. 

b) Have access to and copy, at reasonable times, any records that must be kept under the conditions of 

the permit. 

c) Inspect, at reasonable times, any of the following:

i) Any stationary source

ii) Any process

iii) Any process equipment, including monitoring and air pollution control equipment. 

iv) Any work practices or operations regulated or required under the RO Permit. 

d) As authorized by Section 5526 of the act, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the permit or applicable requirements. 

13. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Part 5522 of Act 

451, P.A. 1994. (R 336.1213(1)(g))

14. This RO Permit does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h))

15. For renewal of this RO Permit, an administratively complete application shall be considered timely if it is 

received by the department not more than 18 months, but not less than 6 months, before the expiration date 

of the RO Permit. (R 336.1210(7))

16. For modifications to this RO Permit, an administratively complete application shall be considered timely if it is 

received by the department in accordance with the time frames specified in R 336.1216. (R 336.1210(9))

17. For changes to any process or process equipment covered by this RO Permit that do not require a revision of 

the RO Permit pursuant to R 336.1216, the permittee must comply with R 336.1215. (R 336.1215,

R 336.1216)

18. A RO Permit shall be reopened by the department prior to the expiration date and revised by the department 

under any of the following circumstances:

a) If additional requirements become applicable to this stationary source with three or more years 

remaining in the term of the permit, but not if the effective date of the new applicable requirement is 

later than the RO Permit expiration date. (R 336.1217(2)(a)(i))

b) If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. 

(R 336.1217(2)(a)(ii))

c) If the department determines the permit contains a material mistake, that information required by any 

applicable requirement was omitted, or that inaccurate statements were made in establishing

emission limits or the terms or conditions of the permit. (R 336.1217(2)(a)(iii))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 6 of 136

d) If the department determines the permit must be revised to ensure compliance with the applicable 

requirements. (R 336.1217(2)(a)(iv))

19. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and Rule 

1003. (R 336.2001(2), R336.2001(3), R336.2003(1)) 

20. Any required test results shall be submitted to the AQD in the format prescribed by the applicable reference 

test method within 60 days following the last date of the test. (R 336.2001(4))

Recordkeeping and Reporting

21. Records of any periodic emission or parametric monitoring required by Parts B, E, F and Appendices of this 

RO Permit, shall include the following information specified in R 336.1213(3)(b)(i), where appropriate. 

(R 336.1213(3)(b)):

a) The date, location, time and method of sampling or measurements.

b) The dates analyses of the samples were performed.

c) The company or entity that performed the analyses of the samples.

d) The analytical techniques or methods used.

e) The results of the analyses.

f) The related process operating conditions or parameters that existed at the time of sampling or

measurement.

22. All required monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and furnished to the department upon request for a period of not less 

than 5 years from the date of the monitoring sample, measurement, report or application. Support information 

includes all calibration and maintenance records and all original strip-chart recordings, or other original data 

records for continuous monitoring instrumentation and copies of all reports required by the RO Permit. (R 

336.1213(1)(e), R 336.1213(3)(b)(ii))

23. Semiannually for the term of the permit as detailed in the requirement tables, or more frequently if specified in 

an applicable requirement in this RO Permit, the permittee shall submit certified reports of any required 

monitoring to the appropriate District Office of the AQD. All instances of deviations from permit requirements 

during the reporting period shall be clearly identified in the reports. (R 336.1213(3)(c)(i)) 

24. The permittee shall promptly report any deviations from permit requirements and certify the reports. The 

prompt reporting of deviations from permit requirements is defined in R 336.1213(3)(c)(ii) as follows, unless 

otherwise described in this RO Permit: (R 336.1213(3)(c)):

a) For deviations that exceed the emissions allowed under the RO Permit, prompt reporting means 

reporting consistent with the requirements of R 336.1912 as detailed in Condition 26. All reports 

submitted pursuant to this paragraph shall be promptly certified as specified in R 336.1213(3)(c)(iii).

b) For deviations which exceed the emissions allowed under the RO Permit and which are not reported 

pursuant to R 336.1912 due to the duration of the deviation, prompt reporting means the reporting of 

all deviations in the semi-annual reports required by R 336.1213(3)(c)(i). The report shall describe 

reasons for each deviation and the actions taken to minimize or correct each deviation.

c) For deviations that do not exceed the emissions allowed under the RO Permit, prompt reporting 

means the reporting of all deviations in the semi-annual reports required by R 336.1213(3)(c)(i). The 

report shall describe the reasons for each deviation and the actions taken to minimize or correct each 

deviation. 

For reports required pursuant to R 336.1213(3)(c)(ii), prompt certification of the reports is described in

R 336.1213(3)(c)(iii) as either of the following (R 336.1213(3)(c)):

d) Submitting a certification by a responsible official with each report which states that, based on

information and belief formed after reasonable inquiry, the statements and information in the report are 

true, accurate, and complete. 

e) Submitting, within 30 days following the end of a calendar month during which one or more prompt 

reports of deviations from the emissions allowed under the permit were submitted to the department 

pursuant to R 336.1213(3)(c)(ii), a certification by a Responsible Official which states that, based on 

information and belief formed after reasonable inquiry, the statements and information contained in 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 7 of 136

each of the reports submitted during the previous month were true, accurate, and complete. The 

certification shall include a listing of the reports that are being certified. Any report submitted 

pursuant to R 336.1213(3)(c)(ii) that will be certified on a monthly basis pursuant to this paragraph 

shall include a statement that certification of the report will be provided within 30 days following the 

end of the calendar month. 

25. Except for the alternate certification schedule provided in R 336.1213(3)(c)(iii)(B), any document required to be 

submitted to the department as a term or condition of this RO Permit shall contain a certification by a 

responsible official which states that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

26. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any 

applicable standard or limitation, or emissions of any air contaminant continuing for more than two hours in 

excess of an applicable standard or limitation, as required in R 336.1912, to the appropriate District Office of 

the AQD. The notice shall be provided not later than two business days after the start-up, shutdown, or 

discovery of the abnormal conditions or malfunction. Notification shall be by any reasonable means, including 

electronic, telephonic, or oral communication. Written reports, if required under R 336.1912, must be

submitted to the appropriate District Supervisor within 10 days after the start-up or shutdown occurred, within 

10 days after the abnormal conditions or malfunction has been corrected, or within 30 days of discovery of the 

abnormal conditions or malfunction, whichever is first. The written reports shall include all of the information 

required in R 336.1912(5) and shall be certified by a Responsible Official in a manner consistent with the 

Clean Air Act. (R 336.1912)

27. On an annual basis, the permittee shall report the actual emissions, or the information necessary to 

determine the emissions, of each regulated air pollutant as defined in R 336.1212(7) for each emission

unit/process group utilizing the emissions inventory forms provided by the department. (R 336.1212(7))

Compliance Reporting and Certification

28. A Responsible Official shall certify to the appropriate District Office of the AQD and the EPA, that the

stationary source is and has been in compliance with all terms and conditions contained in the RO Permit 

except for deviations that have been or are being reported to the appropriate District Office of the AQD 

pursuant to Condition 24. This certification shall include all the information specified in R 336.1213(4)(c)(i) 

through (v) and shall state that, based on information and belief formed after reasonable inquiry, the

statements and information in the certification are true, accurate, and complete. The EPA address is: US 

EPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Jackson Boulevard, Chicago, IL, 

60604 (R 336.1213(4)(c))

29. The certification of compliance shall be submitted annually for the term of this RO Permit as detailed in the 

requirement tables, or more frequently if specified in an applicable requirement or in this RO Permit. 

(R 336.1213(4)(c))

Permit Shield

30. Compliance with the conditions of the RO Permit shall be considered compliance with any applicable

requirements as of the date of RO Permit issuance, if either of the following provisions is satisfied 

(R 336.1213(6)(a)(i)and (ii):

a) The applicable requirements are included and are specifically identified in the permit. 

b) The permit includes a determination or concise summary of the determination by the department that 

other specifically identified requirements are not applicable to the stationary source. 

Any requirements identified in Part G of this RO Permit have been identified as non-applicable to this RO 

Permit and are included in the permit shield. 

31. Nothing in this RO Permit shall alter or affect any of the following:
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 8 of 136

a) The provisions of Section 303 of the CAA, emergency orders, including the authority of the EPA under 

Section 303 of the Act. (R 336.1213(6)(b)(i))

b) The liability of the owner or operator of this stationary source for any violation of applicable

requirements prior to or at the time of this permit issuance. (R 336.1213(6)(b)(ii))

c) The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA. 

(R 336.1213(6)(b)(iii))

d) The ability of the EPA to obtain information from a source pursuant to Section 114 of the CAA. 

(R 336.1213(6)(b)(iv))

32. The permit shield shall not apply to provisions incorporated into this permit through procedures for any of the 

following:

a) Changes for operational flexibility made pursuant to R 336.1215. (R 336.1215(5))

b) Administrative amendments made pursuant to R 336.1216(1)(a)(i-iv) until the changes have been

approved by the department. (R 336.1216(1)(b)(iii))

c) Administrative amendments made pursuant to R 336.1216(1)(a)(v) until the amendment has been 

approved by the department. (R 336.1216(1)(c)(iii))

d) Minor permit modifications made pursuant to R 336.1216(2). (R 336.1216(2)(f))

e) State-only modifications made pursuant to R 336.1216(4) until the changes have been approved by 

the department. (R 336.1216(4)(e)) 

33. Expiration of this RO Permit results in the loss of the permit shield. If a timely and administratively complete 

application for renewal is submitted not more than 18 months, but not less than 6 months before the

expiration date of the RO Permit, but the department fails to take final action before the end of the permit 

term, the existing RO Permit does not expire until the renewal is issued or denied, and the permit shield shall 

extend beyond the original permit term until the department takes final action. (R 336.1217(1)(c),

R 336.1217(1)(a)) 

Stratospheric Ozone Protection

34. If the permittee is subject to 40 CFR Part 82 and services, maintains, or repairs appliances except for motor 

vehicle air conditioners (MVAC), or disposes of appliances containing refrigerant, including MVAC and small 

appliances, or if the permittee is a refrigerant reclaimer, appliance owner or a manufacturer of appliances or 

recycling and recovery equipment, the permittee shall comply with all applicable standards for recycling and 

emissions reduction pursuant to 40 CFR Part 82, Subpart F.

35. If the permittee is subject to 40 CFR Part 82 and performs a service on motor (fleet) vehicles when this service 

involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified in 40 

CFR Part 82, Sub-part B, Servicing of Motor Vehicle Air Conditioners. The term “motor vehicle” as used in 

Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed 

refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using 

HCFC-22 refrigerant. 

Risk Management Plan

36. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall register and submit to the 

EPA the required data related to the risk management plan (RMP) for reducing the probability of accidental 

releases of any regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in 68.130. 

The list of substances, threshold quantities, and accident prevention regulations promulgated under Part 68 do 

not limit in any way the general duty provisions under section 112(r)(1).

37. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall comply with the requirements 

of Part 68 no later than the latest of the following dates as provided in 68.10(a):

a) June 21, 1999,

b) Three years after the date on which a regulated substance is first listed under 68.130, or 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 9 of 136

c) The date on which a regulated substance is first present above a threshold quantity in an emission 

unit.

38. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall submit any additional relevant 

information requested by any regulatory agency necessary to ensure compliance with the requirements of 40 

CFR Part 68.

39. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance 

with all applicable requirements of Section 112(r) as detailed in Conditions 28 and 29 of this RO Permit. 

(40 CFR Part 68)
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 10 of 136

Alternative Operating Scenarios

The permittee shall maintain contemporaneous records at the facility of any changes from one operating scenario 

to another. This can be any means of recording information associated with the scenario in question, including 

but not limited to: batch records, fuel records, operating schedule, or emission unit/process group records. (R 

336.1213(8)(a))

Consent Orders

The conditions contained in this RO Permit for which a Consent Order is the only identified applicable requirement 

shall be considered null and void upon the effective date of termination of the Consent Order. The effective date of 

termination is defined for the purposes of this condition as the date upon which the Termination Order is signed by 

the Chief of the Air Quality Division. 

Consent Judgment

The conditions contained in this RO Permit for which a Consent Judgment is the only identified applicable

requirement shall be considered null and void upon the effective date of termination of the Consent Judgment. The 

effective date of termination is defined for the purposes of this condition as the date upon which the Stipulation and 

Order for Termination is signed by a Circuit Court Judge. 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 11 of 136

B. Source-Wide Requirements

The table in Part B outlines the source-wide applicable requirements which apply to all emission unit/process groups 

at this stationary source. The permittee is subject to these requirements for the stationary source in addition to the 

General Requirements in Part A and any other terms and conditions contained in this RO Permit.

The stationary source shall meet the design parameters, material usage/emission limitations, monitoring,

recordkeeping, reporting and testing requirements, operational parameters, and any other requirements listed in the 

following table as well as other terms and conditions specified in this RO Permit to assure compliance with all 

applicable requirements. The permittee shall comply with all specific details in the special conditions and the 

underlying applicable requirements cited in the table. The underlying applicable requirements for the material 

usage/emission limitations, monitoring, recordkeeping, reporting and testing requirements, operational parameters, 

and any other requirements are identified in parentheses. If a specific requirement type does not exist for the 

stationary source, NA (not applicable) has been used in the table. Those requirements which are enforceable by the 

state only are designated by an asterisk.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 12 of 136

TABLE B

SOURCE-WIDE REQUIREMENTS

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

NA

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless

otherwise noted. 

Stack/Vent 

ID

a. Minimum

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp 

(°F)

d. Air Flow 

Rate (acfm)

Applicable 

Requirement

NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

NA

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3)) 

In Addition to General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and 

Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/

Recorded 

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping 

NA

IV. REPORTING

Reports and Schedules NA

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

The facility shall not build, erect, install, or use any article, machine equipment, or other contrivance if the sole 

purpose is to dilute or conceal an emission without resulting in a reduction in the total release of air contaminated into 

the atmosphere. This rule does not apply to the control of odors. (R336.1906)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 13 of 136

C. Emission Unit/Process Group Summary Table

Unit/Group ID Emission Unit/Process Group 

Description

Installation/

Modification Date 

Control Device Description Stack/Vent ID Requirement 

Table No. 

EG001-9 DV001-9-1, Additive Silo No. 1, 

24,000 cubic ft

09/01/1997 DV001-9-2 Mikro Pulsaire 

baghouse, 3,000 acfm

SV045 E-1.1

EG013 DV013-1 Primary crusher 01/01/1958 NA NA E-1.2

EG014 DV014-1 Limestone transfer from 

secondary crusher building to stock belt 

no. 3

01/01/1958

06/19/2001

01/31/2002

DV014-2 surfactant and spray 

system DV014-3 extended 

spout piling system

N/A E-1.3

EG023 DV023-1 20,000 gallon fixed roof No. 2 

diesel oil storage tank

10/11/1992 NA SV037 E-1.4

EG024 DV024-1 1,200 gallon fixed roof water 

treatment chemicals storage tank

01/01/1986 NA SV038 E-1.5

EG030 DV030-1 Leach dust (CKD product) silo 

11,780 ft3

01/01/1958

01/19/1992

DV030-2 baghouse-pulse jet 

5,000 acfm

SV033 E-1.6

EG031 DV031-1 & DV031-2 Two fuel reclaim 

systems (coal & coke) and six silos

01/01/1958

04/01/1992

12/1/2002

DV031-4 baghouse, reverse air

7,000 acfm

SV034 E-1.7

EG035 DV035-1 Clinker Baghouse Dust Transfer 7/1/2000 DV035-2 Mikropul pulsaire 

baghouse 7947 acfm

SV046 E-1.8

EG001-1 DV001-1-1 No. 1 Finish Mill-Grinding of 

clinker & additives to produce cement

10/15/1958 DV001-1-3, Norblo reverse air 

baghouse, 16,000 acfm

SV-004 F-1.1

EG001-2 DV001-2-1 No. 2 Finish mill-grinding of 

clinker & additives to produce cement

10/15/1958 DV001-2-3 Norblo reverse air 

baghouse, 16,000 acfm

SV-005 F-1.1

EG001-3 DV001-3-1 No. 3 Finish mill-grinding of 

clinker & additives to produce cement

10/15/1958

4/1/2001

DV001-3-3 Norblo pulse jet

baghouse, 16,000 acfm

SV-006 F-1.1

EG001-4 DV001-4-1 No. 1 Finish mill feed end 

separator

10/15/1958 

10/01/1997

DV001-4-3 Reverse air 

baghouse, 35,000 acfm

SV028 F-1.1

EG001-5 DV001-5-1 No. 2 Finish mill feed end 

separator

10/15/1958

01/01/1967

DV001-5-3 Reverse air 

baghouse 35,000 acfm

SV029 F-1.1

EG001-6 DV001-6-1 No. 3 Finish mill feed end 

separator

10/15/1958 DV001-6-3 Reverse air 

baghouse 35,000 acfm

SV030 F-1.1

EG004 DV004-1 Additive silo No. 2, 20,000 cu ft 01/01/1958

10/30/1973

DV004-2 Buell norblo, 

baghouse 3,000 acfm

SV007 F-1.2

EG005-1 DV005-1-1 One customer cement silo 

(North section) (Silo No. 20)

01/01/1958 DV005-1-2 Reverse air 

baghouse 3,500 acfm

SV008 F-1.2
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 14 of 136

Unit/Group ID Emission Unit/Process Group 

Description

Installation/

Modification Date 

Control Device Description Stack/Vent ID Requirement 

Table No. 

EG005-2 DV005-2-1 Eleven customer cement silos

Nos. 9-19

01/01/1958 DV005-2-2 Reverse air 

baghouse and/or DV005-2-3

Reverse air baghouse each

3,500 acfm

SV009 and/or 

SV010

F-1.2

EG006-1 DV006-1-1 Packhouse cement silo no. 1 01/01/1958 DV006-1-2 Reverse air 

baghouse 3,500 acfm

SV017 F-1.2

EG006-2 DV006-2-1 Packhouse cement silo no. 2 01/01/1958 DV006-2-2 Reverse air 

baghouse 3,500 acfm

SV015 F-1.2

EG006-3 DV006-3-1 Packhouse cement silo no. 3 01/01/1958 DV006-3-2 Reverse air 

baghouse 3,500 acfm

SV013 F-1.2

EG006-4 DV006-4-1 Packhouse cement silo no. 4 01/01/1958 DV006-4-2 Reverse air 

baghouse 3,500 acfm

SV011 F-1.2

EG006-5 DV006-5-1 Packhouse cement silo no. 5 01/01/1958 DV006-5-2 Reverse air 

baghouse 3,500 acfm

SV018 F-1.2

EG006-6 DV006-6-1 Packhouse cement silo no. 6 01/01/1958 DV006-6-2 Reverse air 

baghouse 3,500 acfm

SV016 F-1.2

EG006-7 DV006-7-1 Packhouse cement silo no. 7 01/01/1958 DV006-7-2 Reverse air 

baghouse 3,500 acfm

SV014 F-1.2

EG006-8 DV006-8-1 Packhouse cement silo no. 8 01/01/1958 DV006-8-2 Reverse air 

baghouse 3,500 acfm

SV012 F-1.2

EG009-2 DV009-2 Dust silo, D-1 01/01/1958

8/1/2000

DV009-2-2 pulse jet baghouse 

16,000 acfm

SV026 F-1.2

EG009-3 DV009-3-1 Dust silo, D-2 01/01/1958

8/1/2000

DV009-3-2 pulse jet baghouse 

16,000 acfm

SV027 F-1.2

EG029 DV029-1 Additive 5.40 No. 3, 2,500 cu ft 01/01/1958

10/30/1973

DV004-2 Buell Norblo 

baghouse reverse air

3,000 acfm

SV007 F-1.2

EG011-1 DV0011-1-1 Bulk cement loading to trucks 

NW scale #1 (Packhouse silos)

01/01/1958

05/05/2003

DV011-1-2 cartridge filter pulse 

jet air 1,800 acfm

SV019 F-1.3

EG011-2 DV011-2 -1 Bulk cement loading to trucks 

NE scale #2 (Packhouse silos)

01/01/1958

05/05/2003

DV011-2-2 cartridge filter pulse 

jet 1,800 acfm

SV020 F-1.3

EG011-3 DV011-3-1 Bulk cement loading to trucks

(SW scale #3) (Packhouse silos)

01/01/1958

05/05/2003

DV011-3-2 cartridge filter pulse 

jet 1,800 acfm

SV021 F-1.3

EG011-4 DV011-4-1 Bulk cement loading to trucks 

SE scale #4 (Packhouse silos)

01/01/1958

05/05/2003

DV011-4-2 cartridge filter pulse 

jet 1,800 acfm

SV022 F-1.3

EG012 DV012-1 Secondary crusher-stone quarry 01/01/1958

10/01/1993

DV012-3 material screening, 

DV008-2 baghouse, pulse jet

19,000 acfm

SV025 F-1.4

EG015 EV015-1 Tertiary crusher-stone quarry 01/01/1958 DV008-2 baghouse, pulse jet SV025 F-1.4
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 15 of 136

Unit/Group ID Emission Unit/Process Group 

Description

Installation/

Modification Date 

Control Device Description Stack/Vent ID Requirement 

Table No. 

10/01/1993 19,000 acfm

EG032 DV032-1 Cement bagging (3 units) 09/15/1993 DV032-2 baghouse, pulse jet

6,600 acfm

SV035 F-1.5

EG033 DV033-1 Cement bagging (3 units) 9/15/1993 DV033-2 baghouse, pulse jet

6,600 acfm

SV036 F-1.5

EG011-7 DV011-7 Bulk cement loading to trucks 

scale #5 (customer silos)

01/01/1958

3/1/1984

DV011-7-2 pulse jet baghouse, 

1,000 acfm

SV041 F-1.6

EG011-8 DV0110801 Bulk cement loading to trucks 

scale #6 (customer silos)

01/01/1958

3/1/1984

DV011-8-2 pulse jet baghouse

1,000 acfm

SV042 F-1.6

EG002-1 DV002-1 Clinker Cooler No. 1 10/08/1958

06/09/2000

DV002-2 Procedaire pulse jet 

baghouse 106,000 acfm

SV002-1 F-1.7

EG002-2 DV002-4 Clinker Cooler No. 2 10/10/1958

06/09/2000

DV002-3 Procedaire pulse jet 

baghouse 106,000 acfm

SV002-2 F-1.7

EG003-1 DV003-1 Cement Kiln No. 1 10/08/1958

05/08/2000

DV003-5 Dry scrubber 

(carbon), DV003-2 baghouse, 

260,000 acfm, DV003-3 wet 

scrubber-packed tower, DV003-

4 (3) thermal oxidizers

SV001 F-1.8

EG003-2 DV003-6 Cement Kiln No. 2 10/08/1958

05/08/2000

DV003-10 Dry scrubber 

(carbon) DV003-7 baghouse, 

260,000 acfm, DV003-8 wet 

scrubber packed tower, DV003-

9 (3) thermal oxiders

SV001 F-1.8

EG011-5 DV011-5-1 Bulk cement loading to rail cars 

N scale #1

1/01/01958

1/1/1966

DV011-5-2 norblo baghouse, 

reverse air 4,400 acfm

SV023 F-1.9

EG011-6 DV011-6-1 Bulk cement loading to rail cars 

S scale # 2

01/01/1958

1/1/1966

DV011-6-2 norblo baghouse, 

reverse air 4,400 acfm

SV024 F-1.9

EG008 DV008-1 Raw materials reclaim system 

gypsum, limestone, coal, petroleum coke

01/01/1958

10/01/1993

DV008-2 baghouse, pulse jet 

19,000 acfm

SV025 F-1.10

EG010 DV010- Raw material conveyor (belt #2) 

(limestone, coal, coke, gypsum

01/01/1958

10/01/1993

DV008-2 baghouse, pulse jet 

19,000 acfm

SV025 F-1.10

EG021 DV021-1 Gypsum, ashes, coal, limestone, 

shale and coke transfer from belt 2 to belt 

5

01/01/1958

10/01/1993

DV008-2 baghouse, pulse jet

19,000 acfm

SV025 F-1.10

EG DRYER – 1 DVDRYER-1 Natural gas fired solid fuel 

dryer (feeding DV003-1, No. 1 kiln)

8/1//2001 DV003-5 dry scrubber (carbon), 

DV003-2 baghouse reverse air, 

260,000 acfm, DV003-3 wet 

scrubber-packed tower, DV003-

4(3) regenerative thermal 

SV001 F-1.11
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 16 of 136

Unit/Group ID Emission Unit/Process Group 

Description

Installation/

Modification Date 

Control Device Description Stack/Vent ID Requirement 

Table No. 

oxidizers

EGDRYER-2 DVDRYER-2 natural gas fired solid fuel 

dryer (feeding DV003-2, No. 2 kiln

8/1/2001 DV003-10 dry scrubber 

(carbon), DV003-7 baghouse, 

reverse air, 260,000 acfm, 

DV003-8 wet scrubber-packed 

tower, DV003-9 (3) regenerative 

thermal oxidizers

SV001 F-1.11

EG009-1 DV009-1-1 Clinker transfer, bucket 

elevators

01/01/1958 DV009-1-2 baghouse, reverse 

air 7,000 acfm

SV003 F-1.12

EG009-4 DV009-4-1 Clinker transfer, apron 

conveyors

01/01/1958

8/1/2000

DV009-4-2 baghouse, pulsejet 

6,000 acfm

SV032 F-1.12

EG025-1 DV025-1 Open top cold cleaner 12/11/1987

7/1/2002

F-1.13

EG025-2 DV025-2 Open top cold cleaner 12/18/198

7/1/2002

F-1.13

EG018 DV018-1 Quarry drilling 01/01/1958

02/13/1980

9/28/1986

01/01/1996

DV018-2 baghouse, pulse jet

550 acfm

SV031 F-1.14

EG034 DV034-1 Clinker Storage Hall approx. 

114,000 sq ft and 200,000 tons storage 

capacity

8/1/2000 DV034-2 baghouse pulse jet 

3,000 acfm

DV034-3 baghouse pulse jet 

collector 3,000 acfm

DV034-4 baghouse pulse jet 

collector 3,000 acfm

SV047

&

SV048

F-1.15

EG036 DV036-1 No. 1 Open top clinker storage 

silo No. 1 – 1,000 ton capacity & No. 3 

Open top clinker storage silo No. 3 – 1,000 

ton capacity

1959 SV047

&

SV048

F-1.15

EG037 DV037 Clinker discharge or clinker well –

30 ft wide x 18 ft deep x 66 ft high

1959 SV047

&

SV048

F-1.15

EG038 DV038 Crane/Clam Bucket & Mobile 

Equipment

1959 SV047

&

SV048

F-1.15
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 17 of 136

D. Flexible Groupings Summary Table

Flexible Grouping 

ID

Emission Unit/Process Groups Included in Flexible Grouping Requirement 

Table No. 

FG001 EG001-1 F-1.1

EG001-2

EG001-3

EG001-4

EG001-5

EG001-6

FG002 EG004 F-1.2

EG005-1

EG005-2

EG006-1

EG006-2

EG006-3

EG006-4

EG006-5

EG006-6

EG006-7

EG006-8

EG009-2

EG009-3

EG029

FG003 EG011-1 F-1.3

EG011-2

EG011-3

EG011-4

FG004 EG012 F-1.4

EG015

FG005 EG032 F-1.5

EG033

FG006 EG011-7 F-1.6

EG011-8 F-1.6

FG007 EG002-1 F-1.7

EG002-2

FG008 EG003-1 F-1.8

EG003-2

FG009 EG011-5 F-1.9

EG011-6

FG010 EG008 F-1.10

EG010

EG021

FG011 EGDRYER-1 F-1.11

EGDRYER-2

FG012 EG009-1 F-1.12

EG009-4

FGCOLDCLEANERS EG025-1 F-1.13

EG025-2

FG014 EG018 F-1.14

FG015 EG034 F-1.15

EG036
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 18 of 136

EG037

EG038
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 19 of 136

E. Emission Unit/Process Group Requirements

The tables in Part E outline the applicable requirements for each emission unit/process group listed in the Emission 

Unit/Process Group Summary Table. The permittee is subject to the requirements for each emission unit/process 

group in addition to the General Requirements in Part A and any other terms and conditions contained in this RO 

Permit.

Each emission unit/process group shall meet the design parameters, material usage/emission limitations, monitoring, 

recordkeeping, reporting and testing requirements, operational parameters, and any other requirements listed in

Tables E-1.1 through E-1.9 as well as other terms and conditions specified in this RO Permit to assure compliance 

with all applicable requirements. The permittee shall comply with all specific details in the special conditions and the 

underlying applicable requirements cited in the tables. The underlying applicable requirements for the material 

usage/emission limitations, monitoring, recordkeeping, reporting and testing requirements, operational parameters, 

and any other requirements are identified in parentheses. If a specific requirement type does not exist for the

emission unit/process group, NA (not applicable) has been used in the table. Those requirements which are

enforceable by the state only are designated by an asterisk.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 20 of 136

TABLE E-1.1 EG001-9

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION UNIT EG001-9 Additive Silo No. 1

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control Equipment DV001-9-2 Fabric filter

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless 

otherwise noted.

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum 

Exhaust Dimension 

(inches)

c.

Temp

.(°F)

d. Air Flow 

Rate 

(acfm)

Applicable 

Requirement

SV045 NA NA NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate 

NA

B. Pollutant Maximum Emission Limit

1. Particulate matter 0.02 lbs/1000 lbs exhaust gas, calculated on a dry basis

 (R336.1201(3))

2. Particulate matter 1.9 lbs/hr (R336.1201(3))

3. PM (Opacity) 10% opacity

 (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

The pressure drop across the fabric filter shall be monitored and recorded 

once per day when filling. Recordings reflecting values outside of the range 

set forth in V-OPERATIONAL PARAMETERS will require the facility to initiate 

corrective action per the facility’s operations and maintenance plan.

 (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/ 

Recorded 

Opacity (40 CFR 63, subpart LLL, Section 63.1350 (a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix A-7)

2. EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Monthly 1-minute visible emissions test in accordance with Method 22. 

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))

2. If no emissions are observed in six consecutive months (utilizing Method 

22), testing may be decreased from monthly to semiannually. If visible 

emissions are observed during any semiannual test, the facility must 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 21 of 136

TABLE E-1.1 EG001-9

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

resume testing on a monthly basis until no visible emissions are 

observed in six consecutive monthly tests.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a) (4) (ii))

3. If no visible emissions are observed during the semi-annual test (utilizing 

Method 22) the facility may decrease the frequency of testing to 

annually. If visible emissions are observed during any annual test, the 

facility must resume testing on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive 

months. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility 

must conduct a 6-minute test of opacity in accordance with Method 9. 

The Method 9 test must begin within one hour of any observation of 

visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv)

5. The facility shall maintain files of the required visible emission records in 

a form suitable and readily available for inspection and review as required 

by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be 

retained for at least five years following the date of each occurrence and 

measurement. At a minimum, the most recent two years of data shall 

be retained on site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche. 

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. 

Due March 15 for reporting period July 1 to December 31 and September 

15 for reporting period January 1 to June 30.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD 

within 90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be 

procedures for proper operation and maintenance of the source and air pollution control devices in order to meet 

the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the sourcesubject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions 

of paragraphs 63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 22 of 136

TABLE E-1.2 EG013

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG013 Primary crusher quarried limestone

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

NA

B. Stack/Vent Parameters NA

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

NA

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semi-annual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting period 

January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 23 of 136

TABLE E-1.2 EG013

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

VI. OTHER REQUIREMENTS

Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1. (R336.1201(3))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 24 of 136

TABLE E-1.3 EG014

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG014 Transfer of limestone from secondary crusher building onto stock belt no. 3

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

Surfactant spray system with extended spout piling system

B. Stack/Vent Parameters NA

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

PM (Opacity) 20% opacity utilizing reference method 9D (Appendix 5). (R336.1301)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

The surfactant spray system shall be monitored daily, when limestone stockpiling is 

being conducted. The liquid flow rate and liquid concentration shall be recorded and

made available, upon request by AQD. 

(R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting period 

January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 25 of 136

TABLE E-1.3 EG014

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

1. Fugitive emission control addressed in the “Fugitive Dust Plan” Attachment 1. (R336.1201(3))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 26 of 136

TABLE E-1.4 EG023

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG023 20,000 gallon (75.7 m3

) above ground No. 2 Diesel Oil Tank

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

NA

B. Stack/Vent Parameters Exhaust gases are discharged via a u-shaped rain deflector.

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV037 NA NA NA NA NA

C. Other Design Parameters 

Storage vessels greater or equal to 75 m3with liquid V.P. of = 15.0 KPa

 (40 CFR 60, Subpart Kb, Section 60.110(c))

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

NA

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

The facility shall have accessible records showing the dimensions of the storage tank 

and an analysis showing the capacity of the storage tank.

 (40 CFR 60, Subpart Kb, Section 60.116b (a)&(b))

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting 

period January 1 to June 30. (R336.1213(3)(c)(ii))

3. Annual Certification of compliance pursuant to conditions 28 and 29 of Part A. 

Due annually March 15 for the previous calendar year. (R336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 27 of 136

TABLE E-1.4 EG023

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

VI. OTHER REQUIREMENTS

NA

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 28 of 136

TABLE E-1.5 EG024

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG024 1,200 gallon Water Treatment Chemicals Tank

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

NA

B. Stack/Vent Parameters Exhaust gases are discharged via a u-shaped rain deflector. 

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable

Requirement

SV038 NA NA NA NA NA

C. Other Design Parameters 

Storage vessels less than 75 m3 (40 CFR 60, Subpart Kb, Section 60.110b(b))

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

NA

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

The facility shall keep accessible records showing the dimension of the storage tank 

and an analysis showing the capacity of the storage tank.

 (40 CFR 60, Subpart Kb, Section 60.116b (a)&(b))

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting 

period January 1 to June 30. (R336.1213(3)(c)(ii))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually March 15 for the previous calendar year. (R336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 29 of 136

TABLE E-1.5 EG024

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

VI. OTHER REQUIREMENTS

NA

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 30 of 136

TABLE E-1.6 EG030

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG030 CKD Product Silo

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV030-2 Fabric Filter

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise 

noted. 

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV033 NA NA NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

1. Particulate Matter 0.1 lbs/1000 lbs exhaust gas, calculated on a dry gas basis (R336.1201(3))

2. PM (Opacity) 10% opacity

 (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

The pressure drop across the fabric filter shall be monitored and recorded once per 

day when filling. Recordings reflecting values outside of the range set forth in VOPERATIONAL PARAMETERS will require the facility to initiate corrective action per 

the facility’s operations and maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.1350 

(a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix 

A-7)

2. EPA Method 9 (40 CFR 60, Appendix 

A-4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22 .

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))

2. If no visible emissions are observed in six consecutive months (utilizing Method 

22), testing may be decreased from monthly to semi-annually. If visible 

emissions are observed during any semi-annual test, the facility must resume 

testing on a monthly basis until no visible emissions are observed in six 

consecutive monthly tests.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 31 of 136

TABLE E-1.6 EG030

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

3. If no visible emissions are observed during the semi-annual test (utilizing Method 

22), the facility may decrease the frequency of testing to annually. If visible 

emissions are observed during any annual test, the facility must resume testing 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility must 

conduct a 6-minute test of opacity in accordance with Method 9. The Method 9 

test must begin within one hour of any observation of visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv)

5. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due 

March 15 for reporting period July 1 to December 31 and September 15 for 

reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD 

within 90 days of the effective date of the ROP (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv).

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)) & (R336.1201(3))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 32 of 136

TABLE E-1.7 EG031

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG031 Two Fuel Reclaim Systems (coal and coke)

Flexible Grouping ID NA

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV031-4 – Fabric Filter

B. Stack/Vent Parameters Exhaust gases discharged horizontally.

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV034 NA NA NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

PM (Opacity) 10% opacity

 (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

The pressure drop across the fabric filter shall be monitored and recorded once per 

day during coal/coke transfer. Recordings reflecting values outside of the range set 

forth in V-OPERATIONAL PARAMETERS will require the facility to initiate corrective 

action per the facility’s operations and maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity 40 CFR 63, Subpart LLL, Section 63.1350(a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix A-7)

2. EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))

2. If no emissions are observed in six consecutive months (utilizing Method 22), 

testing may be decreased from monthly to semi-annually. If visible emissions are 

observed during any semi-annual test, the facility must resume testing on a 

monthly basis until no visible emissions are observed in six consecutive monthly 

tests. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing Method 

22), the facility may decrease the frequency of testing to annually. If visible 

emission are observed during any annual test, the facility must resume testing on 

a monthly basis and maintain that schedule until no visible emission are observed 

in six consecutive readings.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 33 of 136

TABLE E-1.7 EG031

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

 (40 CFR 63, Subpart LLL, Section 63.1350(a)(4)(iii))

4. If visible emission are observed during any Method 22 test, the facility must 

combat a 6-minute test of opacity in accordance with Method 9. The Method 9 

test must begin within one hour of any observation of visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii)

2. Quarterly reporting of deviations pursuant to Condition 23 of Part A. Due June 15 

for reporting period January 1 to March 31, September 15 for reporting period April 

1 to June 30, December 15 for reporting period July 1 to September 30, and 

March 15 for reporting period October 1 to December 31. 

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD 

within 90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv).

 (40 CFR 63, Subpart LLL, Section 63.1350 (a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 34 of 136

TABLE E-1.8 EG035

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION UNIT EG035 Clinker Baghouse Dust Transfer

Flexible Grouping ID

I. DESIGN PARAMETERS

A. Pollution Control Equipment Pulsejet Baghouse

A. Stack/Vent Parameters Exhaust gases discharged horizontally vertically.

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum

Exhaust Dimension

(inches)

c. Temp 

(°F)

d. Air

 Flow Rate 

(acfm)

Applicable 

Requirement

SV046 30 22 392 7947 NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate 

NA

B. Pollutant Maximum Emission Limit

PM (Opacity) 10% opacity

 (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System and 

Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

The pressure drop across the fabric filters shall be monitored and recorded once 

per day when filling bags. Recordings reflecting values outside of the range set 

forth in V-OPERATIONAL PARAMETERS will require the facility to initiate 

corrective action per the facility’s operations and maintenance plan.

(R336.1213(3)

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))

2. Method/Analysis EPA Method 22 (40 CFR 60, Appendix A-7)

EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))

2. If no visible emissions are observed in six consecutive months (utilizing 

Method 22), testing may be decreased from monthly to semiannually. If visible 

emissions are observed during any semiannual test, the facility must resume 

testing on a monthly basis until no visible emissions are observed in six 

consecutive monthly tests.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semiannual test (utilizing 

Method 22), the facility may decrease the frequency to testing to annually. If 

visible emissions are observed during any annual test, the facility must resume 

testing on a monthly basis and maintain that schedule until no visible 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 35 of 136

TABLE E-1.8 EG035

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

emissions are observed in six consecutive readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility must 

conduct a 6-minute test of opacity in accordance with Method 9. The Method 

9 test must begin within one hour of any observation of visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in a 

form suitable and readily available for inspection and review as required by 40 

CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at 

least five years following the date of each occurrence and measurement. At a 

minimum, the most recent two years of data shall be retained on site. The 

files may be maintained on microfilm, on a computer, on floppy disks, on 

magnetic tape, or on microfiche.

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 

336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due 

March 15 for reporting period July 1 to December 31 and September 15 for 

reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually March 15 for the previous calendar year. 

 R336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD within 

90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures for 

proper operations and maintenance of the source and air pollution control devices in order to meet the emission and 

operating limits under 40 CFR 63.1348. Procedures will be set forth to periodically monitor the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for Hazardous 

Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

3. Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1. (R336.1201(3))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 36 of 136

F. Flexible Grouping Requirements

The tables in Part F outline the applicable requirements for each flexible grouping listed in the Flexible Groupings 

Summary Table. The permittee is subject to the requirements for each flexible grouping in addition to the General 

Requirements in Part A and any other terms and conditions contained in this RO Permit.

Each flexible grouping shall meet the design parameters, material usage/emission limitations, monitoring, 

recordkeeping, reporting and testing requirements, operational parameters, and any other requirements listed in 

Tables F-1.1 through F-1.4 as well as other terms and conditions specified in this RO Permit to assure compliance 

with all applicable requirements. The permittee shall comply with all specific details in the special conditions and the 

underlying applicable requirements cited in the tables. The underlying applicable requirements for the material 

usage/emission limitations, monitoring, recordkeeping, reporting and testing requirements, operational parameters, 

and any other requirements are identified in parentheses. If a specific requirement type does not exist for the flexible 

grouping , NA (not applicable) has been used in the table. Those requirements which are enforceable by the state 

only are designated by an asterisk.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 37 of 136

TABLE F-1.1 FG001 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG001 No. 1, No. 2, & No. 3 Finish Mill Systems

Emission Unit/Process 

Groups

EG001-1 No. 1 Finish Mill Grinding Operation, 

EG001-2 No. 2 Finish Mill Grinding Operation

EG001-3 No. 3 Finish Mill Grinding Operation

EG001-4 No. 1 Finish Mill feed end separator

EG001-5 No. 2 Finish Mill feed end separator

EG001-6 No. 3 Finish Mill feed end separator

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV001-1-3 Fabric filter for No. 1 Finish Mill grinding operation

DV001-2-3 Fabric filter for No. 2 Finish Mill grinding operation

DV001-3-3 Fabric filter for No. 3 Finish Mill grinding operation

DV001-4-3 Fabric filter on No. 1 Finish Mill feed end separator

DV001-5-3 Fabric filter for No. 2 Finish Mill feed end separator

DV001-6-3 Fabric filter for No. 3 Finish Mill feed end separator

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise 

noted. 

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV004 52 24 NA NA NA

SV005 52 24 NA NA NA

SV006 52 24 NA NA NA

SV028 100 40 NA NA NA

SV029 100 40 NA NA NA

SV030 100 40 NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

PM (Opacity) 10% Opacity (40 CFR63, Subpart LLL, Section 63.1347)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.1350)(a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix A-
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 38 of 136

TABLE F-1.1 FG001 

FLEXIBLE GROUPING REQUIREMENTS

7)

2. EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. The facility will conduct daily visual emissions observations of each finish mill 

sweep and air separator PMCDs in accordance with Method 22. The Method 22 

test shall be conducted while the affected source is operating at the highest load 

expected that day. The duration of the Method 22 test shall be six minutes.

 (40 CFR 63, Subpart LLL, Section 63.1350(e))

2. If visible emissions are observed during the Method 22 test, the facility must 

initiate, within one hour, the corrective actions specified in the site specific 

operating and maintenance plan.

 (40 CFR 63, Subpart LLL, Section 63.1350(e)(1))

3. Within 24 hours of the end of the Method 22 test in which visible emissions were 

observed, conduct a follow up Method 22 test of each stack from which visible 

emissions were observed during the previous Method 22 test. If visible emissions 

are observed during the follow up Method 22 test from any stack from which 

visible emissions were observed during the previous Method 22 test, conduct a 

visual opacity test of each stack from which emissions were observed during the 

follow up Method 22 test in accordance with Method 9 of Appendix A, Part 60. 

The duration of the Method 9 test shall be 30 minutes.

 (40 CFR 63, Subpart LLL, Section 63.1350(e)(2))

4. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche.

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Quarterly reporting of deviations pursuant to Condition 23 of Part A. Due June 15 

for reporting period January 1 to March 31, September 15 for reporting period April 

1 to June 30, December 15 for reporting period July 1 to September 30, and 

March 15 for reporting period October 1 to December 31.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1347 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1347. Such procedures shall include provisions to address 

paragraphs in 63.1350 (e). (40 CFR 63, Subpart LLL, Section 63.1350 (a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 39 of 136

TABLE F-1.1 FG001 

FLEXIBLE GROUPING REQUIREMENTS

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 40 of 136

TABLE F-1.2 FG002 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG002 Storage Silos

Emission Unit/Process 

Groups

EG004 Additive Silo No. 2

EG005-1 One Customer Cement Silo (North Section) (No. 20)

EG005-2 Eleven Customer Cement Silos (Middle South Sections) (Nos. 9 thru 19)

EG006-1 Packhouse Cement Silo No. 1

EG006-2 Packhouse Cement Silo No. 2

EG006-3 Packhouse Cement Silo No. 3

EG006-4 Packhouse Cement Silo No. 4

EG006-5 Packhouse Cement Silo No. 5

EG006-6 Packhouse Cement Silo No. 6

EG006-7 Packhouse Cement Silo No. 7

EG006-8 Packhouse Cement Silo No. 8

EG009-2 Insulflation (CKD) Silo, D-1

EG009-3 Insulflation (CKD) Silo, D-2

EG029 Additive Silo No. 3

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV004-2 Fabric Filter

DV005-1-2 Fabric Filter

DV005-2-2 Fabric Filter

DV005-2-3 Fabric Filter

DV006-1-2 Fabric Filter

DV006-2-2 Fabric Filter

DV006-3-2 Fabric Filter

DV006-4-2 Fabric Filter

DV006-5-2 Fabric Filter

DV006-6-2 Fabric Filter

DV006-7-2 Fabric Filter

DV006-8-2 Fabric Filter

DV009-2-2 Fabric Filter

DV009-3-2 Fabric Filter

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise 

noted. 

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV007 90 13 NA NA NA

SV008 167 12 NA NA NA

SV009 167 12 NA NA NA

SV010 167 12 NA NA NA

SV017 160 14 NA NA NA

SV015 160 14 NA NA NA

SV013 160 14 NA NA NA

SV011 160 14 NA NA NA

SV018 160 14 NA NA NA

SV016 160 14 NA NA NA

SV014 160 14 NA NA NA

SV012 160 14 NA NA NA

SV026 100 36 NA NA NA
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 41 of 136

TABLE F-1.2 FG002 

FLEXIBLE GROUPING REQUIREMENTS

SV027 100 36 NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

PM (Opacity) 10% Opacity (40 CFR63, Subpart LLL, Section 63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

The pressure drop across the fabric filters shall be monitored and included once per 

day when filling. Recordings reflecting values outside of the range-set forth in VOPERATIONAL PARAMETERS will require the facility to initiate corrective action per 

the facility’s operations and maintenance plan. (R336.1213 (3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.150 (a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix A-7)

2. EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))

2. If no emissions are observed in six consecutive months (utilizing Method 22), 

testing may be decreased from monthly to semi-annually. If visible emissions are 

observed during any semi-annual test, the facility must resume testing on a 

monthly basis until no visible emissions are observed in six consecutive monthly 

tests. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing Method 

22), the facility may decrease the frequency of testing to annually. If visible 

emissions are observed during any annual test, the facility must resume testing 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility must 

conduct a 6-minute test of opacity in accordance with Method 9. The Method 9 

test must begin within one hour of any observation of visible emissions. 

 (40 CFR 63, Subpart LLL, Section 63.150(a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. (40 CFR 63, Subpart LLL, Section 63.155(a))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 42 of 136

TABLE F-1.2 FG002 

FLEXIBLE GROUPING REQUIREMENTS

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due 

March 15 for reporting period July 1 to December 31 and September 15 for 

reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year.

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filters will be provided to the appropriate District Office of the ROP 

within 90 days of the effective date of the ROP. (R336.1213(2)

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 43 of 136

TABLE F-1.3 FG003 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG003 Cement Loading to Trucks (Packhouse Silos)

Emission Unit/Process 

Groups

EG011-1 Bulk Cement Loading to Trucks – NW Scale No. 1 loading spout with cone 

including lump crusher

EG011-2 Bulk Cement Loading to Trucks – NE Scale No. 2 loading spout with cone 

including lump crusher

EG011-3 Bulk Cement Loading to Trucks – SW Scale No. 3 loading spout with cone 

including lump crusher

EG011-4 Bulk Cement Loading to Trucks – SE Scale No. 4 loading spout with cone 

including lump crusher

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV011-1-2 Cartridge Fabric Filter

DV011-2-2 Cartridge Fabric Filter

DV011-3-2 Cartridge Fabric Filter 

DV011-4-2 Cartridge Fabric Filter

B. Stack/Vent Parameters Horizontal vent discharge

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV019 18 10 NA NA (R336.1201(3))

SV020 18 10 NA NA (R336.1201(3))

SV021 18 10 NA NA (R336.1201(3))

SV022 18 10 NA NA (R336.1201(3))

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

1. Particulate Matter 0.04 lbs/1000 lbs exhaust gas, calculated on a dry gas basis (R336.1201(3))

0.32 #/hr per loading scale (R336.1201(3))

5.6 ton/yr for total loading operation. (R336.1213(2)), (Appendix 7)

2. PM Opacity 10% Opacity (40 CFR63, Subpart LLL, Section 

63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

1. The pressure drop across the cartridge filter collectors shall be monitored and 

recorded once per day when filling. Recordings reflecting values outside of the 

range set forth in V-OPERATIONAL PARAMETERS will require the facility to 

initiate corrective action per the facility’s operations and maintenance plan.

 (R336.1213(3))

2. The facility shall keep a written record of the following information for each filter 

collector each calendar month.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 44 of 136

TABLE F-1.3 FG003 

FLEXIBLE GROUPING REQUIREMENTS

- Daily recording of the pressure drop reading across each cartridge filter dust 

collector.

- The permittee shall keep the records in a format acceptable to the AQD 

District Supervisor. The facility shall keep these records on file for a period of 

at least five years and made them available to AQD upon request.

 (R336,1201(3)), (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

The facility shall keep records of emission information and operating maintenance 

information for the collector/material feed systems to comply with the visible emission 

standards as set forth in 40 CFR 63, Subpart LLL, Section 63.1348. The permittee 

shall keep all source emissions and operating and maintenance information on file for 

a period of at least five years and make the information available to the AQD upon 

request. (R336.1201(3)) (R336.1213(3))

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.150 (a)(4))

2. Method/Analysis 1. EPA Method 22. (40 CFR 60, Appendix A-7)

2. EPA Method 9. (40 CFR 60, Appendix A-4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))

2. If no emissions are observed in six consecutive months (utilizing Method 22), 

testing may be decreased from monthly to semi-annually. If visible emissions are 

observed during any semi-annual test, the facility must resume testing on a 

monthly basis until no visible emissions are observed in six consecutive monthly 

tests. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing Method 

22) , the facility may decrease the frequency to testing to annually. If visible 

emissions are observed during any annual test, the facility must resume testing 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility must 

conduct 6-minute test of opacity in accordance with Method 9. The Method 9 

test must begin within one hour of any observation of visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. (40 CFR 63, Subpart LLL, Section 63.155(a))

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.1349(a))

2. Method/Analysis EPA Method 9 (as modified) – The performance test shall be conducted at the highest 

load or capacity as reasonably can be expected. The maximum six-minute average 

opacity exhibited during the test period shall determine compliance. The duration of 

the Method 9 Performance Test shall be 3-hours (30-6 minute averages), except that 

the duration of the Method 9 Performance Test may be reduced to 1-hour if it is found 

that no individual readings greater than 10 percent opacity and there are no more than 

three readings of 10 percent for the first 1-hour period.

(40 CFR 60, Appendix A-4), (40 CFR 63, Subpart LLL, Section 63.1349 (b)(2))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 45 of 136

TABLE F-1.3 FG003 

FLEXIBLE GROUPING REQUIREMENTS

3. Frequency and Schedule 

of Testing/Recordkeeping

Performance tests shall be conducted in accordance with Method 9 (as modified) 

within 180 days after initial startup. Visible emission observation procedure must 

have prior approval by the AQD. (40 CFR 63, Subpart A, Sections 

63.7(a)(2)), (40 CFR 63, Subpart LLL, Section 63.1349(a)), (R336.1213(3))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part a> Due 

March 15 for reporting period July 1 to December 31 and September 15 for 

reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year.

 (R 336.1213(4)(c))

4. The results of opacity or visible emission evaluations as required under 

performance test requirements utilizing EPA Method 9 (as modified) shall be 

submitted to AQD within 60 days following the last date of the evaluation. 

(See Appendix 5)

 (40 CFR 63, Subpart A, Section 63.7 (g)(1)

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD at

the effective date of the ROP. 

(R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

3. The facility shall install and maintain devices for the measurement of pressure drop across each fabric filter. The 

monitoring device shall be certified by the manufacturer to be accurate within ± 1 inch water gauge pressure and 

must be calibrated on an annual basis in accordance with manufacturer’s instruction. (R336.1201(3))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 46 of 136

TABLE F-1.4 FG004 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG004 Stone Quarry Crushing

Emission Unit/Process 

Groups

EG012 Secondary Crusher

EG015 Tertiary Crusher

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV008-2 Baghouse, Pulse Jet

B. Stack/Vent Parameters Horizontal exhaust.

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV025 30 32 NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

NA

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semi-annual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting period 

January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 47 of 136

TABLE F-1.4 FG004 

FLEXIBLE GROUPING REQUIREMENTS

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1. (R336.1201(3))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 48 of 136

TABLE F-1.5 FG005 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG005 Cement Bagging Operation

Emission Unit/Process 

Groups

EG032 Masonry bagging (3 units)

EG033 Cement bagging (3 units)

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV032-2 Fabric Filter

DV033-2 Fabric Filter

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise 

noted. 

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV035 53 18 NA NA NA

SV036 53 18 NA NA NA

C. Other Design Parameters 

Collectors DV032-2 & DV033-2 will each be equipped with pressure drop gauge approved by District Staff

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

Cement, Mortar 140,000 tpy (R336.1201(3))

B. Pollutant Maximum Emission Limit

1. Particulate Matter 0.04 lbs/1000 lbs exhaust gas, calculated on a dry basis. (R336.1201(3))

2. PM (Opacity) 5% Opacity 

(R336.1201(3))

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

The pressure drop across the fabric filters shall be monitored and recorded once per 

day when filling bags. Recordings reflecting values outside of the range set forth in VOPERATIONAL PARAMETERS will require the facility to initiate corrective action per 

the facility’s operations and maintenance plan. (R336.1213(3))

3. Other Monitoring and/or

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.1350 

(a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix A-7)

2. EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))

2. If no emissions are observed in six consecutive months (utilizing Method 22), 

testing may be decreased from monthly to semi-annually. If visible emissions are 

observed during any semi-annual test, the facility must resume testing on a 

monthly basis until no visible emissions are observed in six consecutive monthly 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 49 of 136

TABLE F-1.5 FG005 

FLEXIBLE GROUPING REQUIREMENTS

tests. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing Method 

22) , the facility may decrease the frequency to testing to annually. If visible 

emissions are observed during any annual test, the facility must resume testing 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility must 

conduct a 6-minute test of opacity in accordance with Method 9. The Method 9 

test must begin within one hour of any observation of visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting 

period January 1 June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filters will be provided to the appropriate District Office of the AQD 

within 90 days of the effective date of the ROP. (R336.1201(3) & R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall immediately clean up and properly dispose of any product spillage. (R336.1201(3))

2. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350 (a) & (R336.1201(3))

3. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 50 of 136

TABLE F-1.6 FG006

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG006 Bulk cement loading to trucks (customer silos)

Emission Unit/Process 

Groups

EG011-7 Bulk cement loading to trucks – Scale No. 5

EG011-8 Bulk cement loading to trucks – Scale No. 6

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV011-7-2 Fabric Filter

DV011-8-2 Fabric Filter

B. Stack/Vent Parameters Exhaust gases discharged horizontally.

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV041 52 20 NA NA NA

SV042 52 20 NA NA NA

C. Other Design Parameters 

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

PM (Opacity) 10% Opacity (40 CFR 63, Subpart LLL, Section 63.1348)

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

2. Process Monitoring 

System and Recordkeeping

The pressure drop across the fabric filters shall be monitored and recorded once per 

day when filling bags. Recordings reflecting values outside of the range set forth in VOPERATIONAL PARAMETERS will require the facility to initiate corrective action per 

the facility’s operations and maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

Opacity (40 CFR 63, Subpart LLL, Section 63.150 (a)(4))

2. Method/Analysis EPA Method 22 (40 CFR 60, Appendix A7)

EPA Method 9 (40 CFR 60, Appendix A4)

3. Frequency and Schedule 

of Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))

2. If no emissions are observed in six consecutive months (utilizing Method 22), 

testing may be decreased from monthly to semi-annually. If visible emissions are 

observed during any semi-annual test, the facility must resume testing on a 

monthly basis until no visible emissions are observed in six consecutive monthly 

tests. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 51 of 136

TABLE F-1.6 FG006

FLEXIBLE GROUPING REQUIREMENTS

3. If no visible emissions are observed during the semi-annual test (utilizing Method 

22) , the facility may decrease the frequency to testing to annually. If visible 

emissions are observed during any annual test, the facility must resume testing 

on a monthly basis and maintain that schedule until no visible emissions are 

observed in six consecutive readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility must 

conduct a 6-minute test of opacity in accordance with Method 9. The Method 9 

test must begin within one hour of any observation of visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in a form 

suitable and readily available for inspection and review as required by 40 CFR 63, 

Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five years 

following the date of each occurrence and measurement. At a minimum, the 

most recent two years of data shall be retained on site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on 

microfiche. (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due March 

15 for reporting period July 1 to December 31 and September 15 for reporting 

period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range of the fabric filters will be provided to the appropriate District Office of the AQD 

within 90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures 

for proper operation and maintenance of the source and air pollution control devices in order to meet the emission 

and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-subject to the 

opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions of paragraphs 

63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 52 of 136

TABLE F-1.7 FG007 

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG007 Clinker Coolers

Emission Unit/Process 

Groups

EG002-1 Clinker Cooler No. 1

EG002-2 Clinker Cooler No. 2

I. DESIGN PARAMETERS

A. Pollution Control 

Equipment

DV002-2 Baghouse on No. 1 Clinker Cooler (Consent Judgment 00-1363-CZ, Part IV 

4.1.C.)

DV002-3 Baghouse on No. 2 Clinker Cooler (Consent Judgment 00-1363-CZ, Part IV 

4.1.C.)

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless otherwise 

noted. 

Stack/Vent ID a. Minimum 

Height (feet)

b. Maximum Exhaust 

Dimension (inches)

c. Temp (°F) d. Air Flow 

Rate (acfm)

Applicable 

Requirement

SV002-1 92 78 NA NA NA

SV002-2 92 78 NA NA NA

C. Other Design Parameters 

N/A, not necessary due to COM

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit

1. Particulate Matter 1. 0.10 lbs/1000 lbs exhaust gas, calculated on a dry basis.

 (R336.331(a)(1) & Consent Judgment 00-1363-CZ, Part IV 4.1.D)

2. 0.050 Kg per Mg of dry feed to the kiln

 (40 CFR 63, Subpart LLL, Section 63.1345 (a)(1))

3. 0.1 lb per ton of dry feed to the kiln

 (40 CFR 63, Subpart LLL, Section 63.1345 (a)(1))

2. PM (Opacity) 10% Opacity (R336.1213(3) (40 CFR 63, Subpart LLL, Section 63.1345(2))

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring 

System and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

COMs shall be installed, calibrated, maintained, and operated in accordance with the 

procedures in 40 CFR 60.13 and Performance Specification 1 (“PS1”) of Appendix B, 

40 CFR Part 60. The span value shall be 2.0 times the lowest emission standard or 

as specified in the federal regulations.

(Consent Judgment 00-1363-CZ, Part 4.3.A.) & (40 CFR 63, Subpart LLL, Section 

63.1350(d)(1)&(40CFR60, Subpart F 60.63(b))

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 53 of 136

TABLE F-1.7 FG007 

FLEXIBLE GROUPING REQUIREMENTS

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 336.1213(3)(c)(ii))

2. Quarterly reporting of EER and summary report, due 30 days at the end of 

each calendar quarter. (Consent Judgment 00-1363-CZ, Part 4.3.B.), 

(R336.1213(3)(c)(i), (40 CFR 63, Subpart A, Section 63.10(e)(3))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A. 

Due annually by March 15 for the previous calendar year.

(R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

1. The facility will have in place a Preventative Maintenance/Malfunction Abatement Program for the baghouse control 

system. (R336.911) (Consent Judgment 00-1363-CZ, Part 4.1.E)

2. The facility will have in place a written operations and maintenance plan which will include:

Procedures for proper operation and maintenance of the affected source and baghouse control devices in order to 

meet the emission limits and operating limits noted in 63.1345.

 (40 CFR 63, Subpart LLL, Section 63.1350(a))

3. The facility shall have in place a written “startup, shutdown, and malfunction plan,” that describes in detail, 

procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction and a 

program of corrective action for malfunctioning process and air pollution control equipment used to comply with the 

relevant standard. The plan shall identify all routine or otherwise predictable CMS malfunctions.

 (40 CFR 63, Subpart A, Section 63.6 (e))

4. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a))&(R336.1205(1)) (40 CFR 63, Subpart LLL)

5. The facility shall perform an annual audit of the COMs using the procedures set forth in the USEPA publication No. 

450/4-92-010, “Performance Audits Procedures for Opacity Monitors,” and all amendments thereto. The results of 

the annual audit shall be submitted to the AQD Jackson District Supervisor within 30 days of completion.

 (Consent Judgment 00-1363-CZ, Part 4.3.C)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 54 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG008 No. 1 & No. 2 Wet process cement kilns

Emission Unit/Process Groups EG003-1 No. 1 Cement Kiln

EG003-2 No. 2 Cement Kiln

I. DESIGN PARAMETERS 

A. Pollution Control Equipment DV003-5 Dry Scrubber (with activated carbon) & DV003-2 Baghouse; 

or

DV003-2 Baghouse & DV003-3 Limestone Slurry Scrubber-Packed Tower & 

DV003-4 Three RTO’s in Parallel

DV003-10 Dry Scrubber (with activated carbon) & DV003-7 Baghouse

or

DV003-7 Baghouse & DV003-8 Limestone Slurry Scrubber-Packed Tower & 

DV003-9 Three RTO’s in Parallel 

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless

otherwise noted. 

Stack/Vent ID a. Minimum 

Height 

 (feet)

b. Maximum 

Exhaust Dimension

 (inches)

c. Temp 

(°F)

d. Air 

Flow 

Rate 

(acfm)

Applicable 

Requirement

1. SV001 350 180 R336.1225

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

1. Kiln Feed 1. 2,237,596 tons of dry feed in both kilns, DV003-1 & DV003-6 per year based 

on a 12-month rolling time period as determined at the end of each calendar 

month. Dry feed shall be defined as any dry material fed to the kiln(s), 

including: limestone, clay, flyash, bottom ash, silica gel, by-product and 

excluding solid fuels such as coal and pet coke. 

 (R336.1201(1)(a)) & 

(R336.1205(1))

2. TDF 1. < 4.6 tph per kiln, based upon a 24-hour average calculated at the and of 

each hour. (Conventional Firing Mode). (R336.1201(1)(a)) & (R336.1205(1))

2. < 21% of the total fuel heat input to a kiln (Conventional Firing Mode) 

 (R336.1201(1)(a)) & (R336.1205(1))

3. = 4.6% tph fuel or = 21% of the total fuel heat input to a kiln (AFM Firing 

Mode) (R336.1201(1)(a)) & (R336.1205(1))

3. Coke 1. 25% of the total hourly fuel heat input to a kiln (Conventional Firing Mode) 

 (R336.1201(1)(a)) & (R336.1205(1))

2. >25% of the total fuel heat input to a kiln (AFM Firing Mode)

 (R336.1201(1)(a)) & (R336.1205(1))

4. Coal Up to 100% of the total fuel heat input to a kiln.

 (R336.1201(1)(a)) & 

(R336.1205(1))

5. Used/Waste Oil 1. Specification used oil generated onsite and offsite for kiln startups. 

(Conventional Firing Mode) (See Appendix 5)

 (R336.1201(1)(a)) & 

(R336.1205(1))

2. Up to 100% of the total fuel heat input to a kiln (AFM Firing Mode) 

 (R336.1201(1)(a)) & (R336.1205(1))

6. Asbestos No detectable amounts (AFM Firing Mode) (R336.1225)
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 55 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

7. Chloride Content in the fuels (AFM Firing Mode) shall be = 5,000 ppm. (R336.1225)

8. Hazardous Waste 1. No fuels shall contain such materials as defined in RCRA.

 (See Appendix 5) (RCRA 40 CFR 261)

2. No fuels shall be applicable to F, K, P, or U Hazardous Waste Listing 

Description of RCRA. (RCRA 40 CFR 261)

9. Radioactive Materials No fuels shall contain such materials (R336.1201(1)(a)) & (R336.1205(1))

10. Biological or Infectious Waste No fuels shall contain such materials including but not limited to hospital or 

medical wastes. (R336.1201(1)(a)) & (R336.1205(1))

11. PCB Content in fuels shall be = 49 ppm (RCRA 40 CFR 261)

12. Heating Content No fuels, in the AFM Firing Mode, shall have a heat content of <4,000 BTU’s per 

pound. (R336.1201(1)(a)) & (R336.1205(1))

13. Municipal Solid Waste No fuels shall contain such materials. (R336.1201(1)(a)) & (R336.1205(1))

14. Natural Gas Up to 100% of the total fuel heat input to a kiln. 

 (R336.1201(1)(a)) & 

(R336.1205(1))

15. Diesel Fuel Up to 100% of the total fuel heat input to a kiln.

 (R336.1201(1)(a)) & 

(R336.1205(1))

B. Pollutants Maximum Emission Limit

1. Particulate Matter 1. 0.30 lbs/ton of dry feed to the kiln, based on a 12-month rolling time period as 

determined at the end of each calendar month.

(40 CFR 63, Subpart LLL, Section 63.1343(b)(1)) & (R336.1201(1)(a)) & 

(R336.1205(1))

2. 0.15 Kg per Mg of dry feed to the kiln

 (40 CFR 63, Subpart LLL, Section 63.1343(b)(1))

2. PM (Opacity) Except as provided in V OPERATIONAL PARAMETERS, Article 7, visible 

emissions from the kilns shall not exceed a 6-minute average of 15 percent 

opacity in the stack based on the continuous opacity monitoring system. When 

there is a detached plume from the kilns during, but not limited to, visible 

emission monitoring outages, malfunction and/or calibrations, the visible 

emissions shall not exceed a 6-minute average of 20 percent opacity at the 

stack. If the COM downtime, during daylight hours, exceeds 6 hours, Holcim 

(US) Inc. staff or representatives certified in performing visible emission 

evaluations in accordance with 40 CFR Part 60, Appendix A, Reference Method 

9, as modified to read only at the top of the kiln stack, shall conduct visual 

opacity observations in accordance with 40 CFR 63, Subpart LLL, Section 

63.1350(c)(2). The duration of the Method 9 observation shall be for at least 30 

minutes in duration for each day.

 (R336.1201(1)(a)) & (R336.1205(1)), (R336.1213(2))

3. SO2 11,940 tpy based on a 12-month rolling period as determined at the end of each 

calendar month for both kilns DV003-1 & DV003-6.

 (R336.1201(1)(a)) & 

(R336.1205(1))

4. NOx 1. 3,377 tpy based on a 12-month rolling period as determined at the end of 

each calendar month for kilns DV003-1 & DV003-6.

 (R336.1201(1)(a)) & 

(R336.1205(1))

2. 6 lbs of NOx per ton of clinker produced. Compliance shall be attained after 

May 31, 2004. Compliance with this emission limit shall be maintained 

between the time period of May 1 thru September 30 for year 2004 and future 

years. (R336.1201(1)(a)) & (R336.1205(1)), (R336.1817(5)(b)(i))

5. CO 3,515 tpy, based on a 12-month rolling period as determined at the end of each 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 56 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

calendar month. (R336.1201(1)(a)) & (R336.1205(1))

6. VOC 7,217 tpy, based on a 12-month rolling period as determined at the end of each 

calendar month. (R336.1201(1)(a)) & (R336.1205(1))

7. D/F 1. 0.20 ng per dscm (8.7 x 10-11 gr per dscf)(TEQ) corrected to 7% O2 for inlet 

temperatures to the baghouse of >204°C (400°F). Compliance shall be based 

on inlet temperatures to the baghouse control system average over the 

performance tests, utilizing EPA Method 23. (See Appendix 5) 

 (R336.1205(1), (40 CFR 63, Subpart LLL, Section 63.1343(d)(1))

2. 0.40 ng per dscm (1.7 x 10-10 gr per dscf) (TEQ) corrected to 7% O2 for inlet 

temperatures to the baghouse of = 204°C (400°F). Compliance shall be based 

on inlet temperatures to the baghouse control system average over the 

performance tests, utilizing EPA Method 23. See Appendix 5) 

(R336.1201(1)(a)) & (R336.1205(1)), (40 CFR 63, Subpart LLL, Section 

63.1343(d)(2))

8. Hg 115 ppy for both kilns DV003-1 & DV003-6. (AFM Firing Mode), based on a 12-

month rolling time period, as determined at the end of each calendar month. 

Compliance with the limit shall be demonstrated by the methodology contained in 

Table F-1.8, V.18 OPERATIONAL PARAMETERS. (R336.1225)

9. Pb 0.6 tpy, for both kilns, (AFM Firing Mode), based on a 12-month rolling time 

period, as determined at the end of each calendar month compliance with the 

limit shall be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

10. Sb 0.2 μg/cubic meter, based on a 24 hour averaging period for both kilns. (AFM 

Firing Mode) (expressed as a maximum ambient concentration) compliance with 

the limit shall be demonstrated by the methodology contained in Table F-1.8, 

V.18 OPERATIONAL PARAMETERS. (R336.1225)

5.6 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration) (R336.1225)

11. As 0.0002 μg/cubic meter, based on a 12-month rolling time period as determined at 

the end of each calendar month. (AFM Firing Mode) (expressed as a maximum 

ambient concentration) compliance with the limit shall be demonstrated by the 

methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.

 (R336.1225)

67.2 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration. (R336.1225)

12. Ba 5 μg/cubic meter, based on a 8-hour averaging period. (AFM Firing Mode) 

(expressed as a maximum ambient concentration) compliance with the limit shall 

be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

65.2 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration. (R336.1225)

13. Be 0.02 μg/cubic meter, based on a 24-hour averaging period. (AFM Firing Mode) 

(expressed as a maximum ambient concentration) compliance with the limit shall 

be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

560 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

14. Cd 0.0006 μg/cubic meter, based on a 12-month rolling time period as determined at 

the end of each calendar month. (AFM Firing Mode) (expressed as a maximum 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 57 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

ambient concentration) compliance with the limit shall be demonstrated by the 

methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.

 (R336.1225)

201.6 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

15. Cr 0.000083 μg/cubic meter, based on a 12-month rolling time period as determined 

at the end of each calendar month. (AFM Firing Mode) (expressed as a 

maximum ambient concentration) compliance with the limit shall be demonstrated 

by the methodology contained in Table F-1.8, V.18 OPERATIONAL 

PARAMETERS. (R336.1225)

27.9 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

16. Cu 2 μg/cubic meter, based on an 8-hour averaging period. (AFM Firing Mode) 

(expressed as a maximum ambient concentration) compliance with the limit shall 

be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

26.1 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

17. Mn 0.05 μg/cubic meter, based on a 24-hour averaging period. (AFM Firing Mode)

(expressed as a maximum ambient concentration) compliance with the limit shall 

be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

1.4 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

18. Ni 0.0042 μg/cubic meter, based on a 12 month rolling time period as determined at 

the end of each calendar month. (AFM Firing Mode) (expressed as a maximum 

ambient concentration) compliance with the limit shall be demonstrated by the 

methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.

 (R336.1225)

1.4 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

19. Se 2 μg/cubic meter, based on an 8-hour averaging period. (AFM Firing Mode) 

(expressed as a maximum ambient concentration) compliance with the limit shall 

be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

26.1 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

20. Ag 0.1 μg/cubic meter, based on an 8-hour averaging period. (AFM Firing Mode)

(expressed as a maximum ambient concentration) compliance with the limit shall 

be demonstrated by the methodology contained in Table F-1.8, V.18 

OPERATIONAL PARAMETERS. (R336.1225)

1.3 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

21. Tl 0.1 μg/cubic meter, based on a 12- month rolling time period as determined at the 

end of each calendar month. (AFM Firing Mode) (expressed as a maximum 

ambient concentration) compliance with the limit shall be demonstrated by the 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 58 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.

 (R336.1225)

33.6 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

22. Zn 0.1 μg/cubic meter, based on a 12-month rolling time period as determined at the 

end of each calendar month. (AFM Firing Mode) (expressed as a maximum 

ambient concentration) compliance with the limit shall be demonstrated by the 

methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.

 (R336.1225)

33.6 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

23. C10H7NH2 436.8 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

24. C6H3ClNH2C6H3ClNH2 6.7 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

25. BrCH2CH2Br 16.8 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

26. C6Cl6 6.7 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack 

concentration). (R336.1225)

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System and 

Recordkeeping

1. Facility shall monitor and record the sulfur dioxide, nitrogen dioxide, carbon 

monoxide, and total hydrocarbon emissions from the cement kiln’s common 

exhaust duct or stack on a continuous basis in a manner and with 

instrumentation acceptable to the AQD.

 (R336.1201(1)(a)) & (R336.1205(1))

2. The NOx CEM shall be installed, calibrated, maintained, and operated in 

accordance with the procedures set forth in 40 CFR 60.13 and PS2 of 

Appendix B of 40 CFR Part 60 and quality assurance procedures in Appendix 

F, 40 CFR Part 60; or utilize 40 CFR, Part 75 and Appendices A & B for 

these similar requirements. The span value shall be 2.0 times the lowest 

emission standard or as specified in the federal regulations.

 (R336.1201(1)(a)) & (R336.1213(3)) & (R336.1817(8)(b))

3. The SO2 CEM shall be installed, calibrated, maintained, and operated in 

accordance with the procedures set forth in 40 CFR 60.13 and PS2 of 

Appendix B of 40 CFR Part 60. Quality assurance procedures shall be in 

place utilizing 40 CFR Part 60, Appendix F. The span value shall be 2.0 

times the lowest emission standard or as specified in the federal regulations.

 (R336.1201(1)(a)) & (R336.1213(3))

4. The CO CEM shall be installed, calibrated, maintained, and operated in 

accordance with the procedures set forth in 40 CFR 60.13 and PS4B of 

Appendix B of 40 CFR Part 60. Quality assurance procedures shall be in 

place utilizing 40 CFR Part 60, Appendix F. The span value shall be 2.0 

times the lowest emission standard or as specified in the federal regulations.

 (R336.1201(1)(a)) & (R336.1213(3))

5. The THC CEM shall be installed, calibrated, maintained, and operated in 

accordance with the procedures set forth in 40 CFR 60.13 and PS8A of 

Appendix B of 40 CFR Part 60. Quality assurance procedures shall be in 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 59 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

place utilizing 40 CFR Part 60, Appendix F. The span value shall be 2.0 

times the lowest emission standard or as specified in the federal regulations.

 (R336.1201(1)(a)) & (R336.1213(3))

6. Installation and operation of the SO2, NOx, CO and the CEM monitoring 

systems shall meet the following timelines:

a. Upon issuance of the ROP, the facility shall submit two copies of a 

Monitoring Plan to the AQD, for review and approval. The Monitoring 

Plan shall include drawings on specifications showing proposed 

locations and descriptions of the required CEMS. The CEMS 

monitoring system will replace the proposed scrubber/RTO CEMS 

monitoring system required under Permit 60-71L as proposed in the 

monitoring plan previously submitted under Permit 60-71L on 

October 18, 2000.

b. By April 24, 2004, the facility shall submit two copies of a complete test 

plan for the CEMS to the AQD for approval.

c. Within 90 calendar days after AQD’s approval of the test plan, the facility 

shall complete the installation and testing of the CEMS.

d. Within 60 days after completion and testing of the CEMS, the facility 

shall submit to the AQD two copies of the final report demonstrating 

the CEMS comply with the requirements of Performance. 

Specifications PS2 for NOx and SO2, Performance Specification PS4B 

for CO and Performance Specification PS8A for THC.

e. Each calendar quarter, the facility shall perform QAP of the CEMS as 

set forth in Appendix F of 40 CFR, Part 60.

f. In accordance with 40 CFR 60.7(c) & (d), and 40 CFR 63.10 (e)(3) the 

facility shall generate an EER and Summary Report in an acceptable 

format to the AQD. The Summary Report shall follow the format of 

Figure 1 in 40 CFR 60.7 (d). The EER shall include the following 

information.

1. A report of each exceedance above the limits specified in II.B. 2 

& 3. MATERIAL USAGE/EMISSION LIMITS – POLLUTANTS. 

This includes the date, time, magnitude, cause and corrective 

actions of all occurrences.

2. A report of all periods of CEMS downtime and corrective action.

3. A report of the total operating time of the cement kilns during 

the reporting period.

4. If no exceedances or CEMS downtime occurred during the 

reporting period, the facility shall report that fact.

5. A report of any periods that the CEMS exceed the instrument 

range.

g. The SO2, NO2, and CO CEMS shall be used to determine compliance 

with the respective limits noted in II.B. MATERIAL USAGE/EMISSION 

LIMITS- POLLUTANTS.

h. The THC CEM shall be used to determine compliance with the VOC 

emission limit, as noted in II.B. MATERIAL USAGE/EMISSION LIMITSPOLLUTANTS. The date collected from the THC CEM will be adjusted to 

subtract non-VOC emissions. Within 60 days from issuance of the ROP the 

facility shall submit to the District Supervi sor, AQD for approval a protocol 

depicting the method of converting THC CEM data to VOC emissions.

 (R336.1201(1)(a)) & (R336.1205(1))

2. Process Monitoring System 

and Recordkeeping

1. Facility shall monitor and record hourly the amount of TDF and coal/coke 

mixture fired in the kilns and calculate the TDF 24-hour average usage rate in 

a manner and with instrumentation acceptable to the AQD. All records 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 60 of 136

TABLE F-1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

including the measured TDF and coal/coke mixture hourly usage rate, the 

calculated TDF and coke hourly heat input rates, and the calculated TDF 24-

hour average usage rate shall be kept on file for a period of at least five years 

and made available to the AQD upon request.

 (R336.1201(1)(a)) & (R336.1205(1))

2. Facility shall monitor and record the kiln feed rate every two hours in a 

manner and with instrumentation acceptable to the AQD. Facility shall use 

the kiln feed rate to calculate bi-hourly production rates. All records shall be 

kept on file for a period of at least five years and made available to the AQD 

upon request. (R336.1201(1)(a)) & (R336.1205(1))

3. Facility shall monitor and record the gas temperature at the inlet of the kiln’s 

particulate control device on a continuous basis in a manner and with 

instrumentation acceptable to the AQD. All records shall be kept on file for a 

period of at least five years and made available to the AQD upon request.

(40 CFR 63, Subpart LLL, Section 1350 (f)(1)&(f)(2), (R336.1201(1)(a)) & 

(R336.1205(1))

- The recorder response range must include zero and 1.5 times the average 

temperatures established from performance tests as required under 40 CFR 

63, Subpart LLL, Section 1349(b)(3)(iv).

 (40 CFR 63, Subpart LLL, Section 1350 (f)(1)(i)

- The reference method must be a National Institute of Standards and 

Technology calibrated reference thermo couple potentiometer system or 

alternate reference, subject to approval by AQD.

 (40 CFR 63, Subpart lll, Section 1350(f)(1)(ii))

- The three-hour rolling average temperature shall be calculated as the 

average of 180 successive one-minute average temperatures.

 (40 CFR 63, Subpart LLL, Section 1350(f)(3))

- Periods of time when one-minute averages are not available shall be ignored 

when calculating three-hour rolling averages. When one-minute averages 

become available, the first one-minute average is added to the previous 179 

values to calculate the three hour rolling average.

(40 CFR 63, Subpart LLL, Section 1350(f)(4))

- The calibration of all thermocouples and other temperatures sensors shall 

be verified at least once every three months.

 (40 CFR 63, Subpart LLL, Section 1350(f)(6))

4. Facility shall keep a record of the monthly usage rate of specification used oil 

(Conventional Firing Mode). Such records shall be kept on file for a period of 

at least five years and made available to the AQD upon request.

 (R336.1213(3))

5. The facility shall install, operate, calibrate and maintain a continuous monitor 

to record the rate of activated carbon injection. The accuracy of the rate 

measurement device must be ± l percent of the rate being measured.

 (40 CFR 63, Subpart LLL, Section 1350(g)(1))

- The facility will verify the calibration of the device at least once every three 

months. (40 CFR 63, Subpart LLL, Section 1350(g)(2))

- The three-hour rolling average activated carbon injection rate shall be 

calculated as the average of 180 successive one-minute average activated 

carbon injection rates. (40 CFR 63, Subpart LLL, Section 1350(g)(3))

- Periods of time when one-minute averages are not available shall be ignored 

when calculating three-hour rolling averages. When one-minute averages 

become available, the first one-minute average is added to the previous 179 

values to calculate the three-hour rolling average. 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 61 of 136

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 (40 CFR 63, Subpart LLL, Section 1350(g)(4))

- The facility must install, operate, calibrate and maintain a continuous 

monitor to record the activated carbon injection system carrier gas parameter 

(either the carrier gas flow rate or the carrier gas pressure drop) established 

during the D/F performance tests.

 (40 CFR 63, Subpart LLL, Section 1350(g)(6)(i))

- The facility must calculate and record three-hour rolling averages of the 

parameter value. (40 CFR 63, Subpart LLL, Section 1350(g)(6)(ii))

- The periods of time when one-minute averages are not available shall be 

ignored when calculating three-hour rolling averages. When one-minute 

averages become available, the first one-minute average shall be added to the 

previous 179 values to calculate the three-hour rolling average. 

 (40 CFR 63, Subpart LLL, Section 1350(g)(6)(iii))

3. Other Monitoring and/or 

Recordkeeping 

1. The facility shall monitor and record the visible emissions from the cement 

kilns on a continuous basis. The COM shall be installed, calibrated, 

maintained and operated in accordance with the procedures in 40 CFR 60.13 

and Performance Specification 1 (“PS1”) of Appendix B, 40 CFR Part 60. The 

span value shall be 2.0 times the lowest emission standard as specified in 

the federal regulations. 

 (40 CFR 63, Subpart LLL, Section 63.1350 (c)(1).

2. Data collected by the opacity monitoring system shall be collected for a 

minimum of 95 percent of the operating hours of kiln(s) per month and in a 

manner and with instrumentation acceptable to the District Supervisor AQD. 

The facility shall use all reasonable measures necessary to operate the 

continuous opacity monitoring systems during periods of startup, shutdown 

and malfunction. In accordance with 40 CFR Parts 60.7 and 60.13(h) the 

magnitude, in actual percent opacity, of all six minute averages of opacity 

greater than 15 percent and the time period represented by such averages 

and any deficiencies of the opacity monitoring system up-time shall be 

submitted in an acceptable format to the District Supervisor, AQD, within 30 

days following the end of the quarter. The facility shall perform an annual 

audit of the COM using the procedures put forth in U.S. EPA publication No. 

A50/4-92-010, “Performance Audits Procedures for Opacity Monitors,” and all 

amendments thereto. The results of the annual audit shall be submitted to 

the District Supervisor within 15 days of receipt. Further, all monitoring data 

shall be kept on file for a period of at least five years and made available to 

the District Supervisor upon request.

 (R336.1201(1)(a)) & (R336.1205(1))

3. The facility shall keep the following records during AFM firing mode and shall 

be in a format acceptable to the District Supervisor, and shall be kept on file 

for a period of at least five years.

a. Date and time

b. Operating mode of the kiln(s)

c. Heat input of all AFM used in the kilns and relative contribution of each 

components heat input.

d. Amount of AFM combusted.

e. Kiln feed rate.

f. Visible emissions

g. Oxygen content at the outlet of the kiln

h. Temperature at the inlet of the PMCD

i. SO2 emission rate

j. NOx emission rate

k. VOC emission rate 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

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l. CO emission rate

m. Results of AFM Quality Analysis. 

 (R336.1201(1)(a)) & (R336.1205(1))

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/

 Recorded

Heat content and metal content (Mn, Hg, Ni, as a minimum).

 (R336.1201(1)(a)) & (R336.1205(1))

2. Method/Analysis Analyze TDF, coal and coke fuels using methods acceptable to AQD.

 (R336.1201(1)(a)) & (R336.1205(1))

3. Frequency and Schedule of 

Testing/Recordkeeping

Analyzed on a semiannual basis with analyses kept on file for a period of at least 

five years and made available to the AQD upon request. After two years from the 

date of approval of this ROP the facility may apply for a change in frequency of 

testing. The change in testing frequency request shall be submitted to and 

approved by the District Supervisor, AQD.

 (R336.1201(1)(a)) & (R336.1205(1))

1. Parameter to be 

Tested/Recorded

Metal content (Mn, Hg, Ni, as a minimum). (R336.1201(1)(a)) & (R336.1205(1))

2. Method/Analysis Analyze raw materials fed to the kilns utilizing method(s) acceptable to the AQD, 

testing/analysis procedures(s) protocol shall be submitted to the District 

Supervisor, AQD, for approval. (See Appendix 5 for list of raw materials).

 (R336.1201(1)(a)) & (R336.1205(1))

3. Frequency and Schedule of 

Testing/Recordkeeping

Analyzed on a semiannual basis with analyses kept on file for a period of at least 

five years and made available to the AQD, upon request. After two years from the 

date of approval of this ROP, the facility may apply for a change in frequency of 

testing. The change in testing frequency request shall be submitted to and 

approved by the District Supervisor, AQD.

 (R336.1201(1)(a)) & (R336.1205(1))

1. Parameter to be 

Tested/Recorded

As, Cd, Cr, Pb, PCBs, Total Halogen, and Flashpoint.

 (R336.1201(1)(a)) & (R336.1205(1))

2. Method/Analysis Sampling procedures and analytical techniques, including quality assurance 

procedures, acceptable to the AQD. To verify the physical and chemical 

properties of the used oil comply with the specifications listed in Appendix 5.

 (R336.1201(1)(a)) & (R336.1205(1))

3. Frequency and Schedule of 

Testing/Recordkeeping

Samples shall be collected at least twice per calendar year for used oil generated 

“onsite.” For used oil generated “offsite,” all shipments to the facility will be 

analyzed and screened per “Alternative Fuels and Materials Management 

Process” referenced in Appendix 5. Upon request of the AQD, the facility shall 

collect and analyze representative individual samples of each category of the 

used oil. All sampling records and analytical results shall be kept on file for a 

period of at least five years and made available to the AQD upon request.

 (R336.1201(1)(a)) & (R336.1205(1))

1. Parameter to be 

Tested/Recorded

PM, SO2, NOx, CO, all heavy metals & VOC.

 (R336.1201(1)(a)) & (R336.1205(1))

2. Method/Analysis Verification of emission rates from the kilns by testing, at owner’s expense, in 

accordance with Department requirements, may be required. (See Rule 1004, 

Appendix 5) Verification of emission rates includes the submittal of a complete 

report of the test results. If testing is required, a complete test plant must be 

submitted to the AQD. The final plan must be approved by the Division prior to 

testing. (R336.1201(1)(a)) & (R336.1205(1))

3. Frequency and Schedule of 

Testing/Recordkeeping

Testing shall be conducted within 60 days following the receipt of the written 

notification of the requirement. A complete report of test results must be 

submitted to the Division within 60 days following the last date of testing. 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 63 of 136

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 (R336.1001, 1003, and 1004)

1. Parameter to be 

Tested/Recorded

AFM Materials (R336.1201(1)(a)) & (R336.1205(1))

2. Method/Analysis Procedures set forth in Appendix 5, titled “Alternative Fuels and Materials 

Management Process.” (R336.1201(1)(a)) & (R336.1205(1))

3. Frequency and Schedule of 

Testing/Recordkeeping

Ongoing program when system is in place.

 (R336.1201(1)(a)) & (R336.1205(1))

1. Parameter to be 

Tested/Recorded

Destruction Efficiency

 (R336.1201(1)(a)) & (R336.1205(1))

2. Method/Analysis Testing will be conducted at either kiln to verify the destruction removal efficiency 

by testing in accordance with Department requirements. The purpose of the 

testing is to verify that the kiln is capable of achieving a destruction removal 

efficiency of 99.99% DRE testing shall be conducted at representation operating 

conditions, agreed to in the test plan. The test plan shall also address all points 

on the kiln where AFM’s will be introduced.

 (R336.1201(1)(a)) & (R336.1205(1))

3. Frequency and Schedule of 

Testing/Recordkeeping

Previous to processing AFM in the kilns, and upon issuance of the ROP, 

verification of the destruction removal efficiency of either kiln shall have been

determined. No less than 60 days prior to testing, a complete test plan shall 

have been submitted to AQD for approval. The final plan must be approved by 

AQD prior to testing. The facility shall not operate in the AFM mode until the 

results of the destruction efficiency tests have been approved by the AQD.

 336.1205(1))

1. Parameter to be 

Tested/Recorded

SO2, CO, & VOC

 (Consent Judgment No. 00-1163-CZ(Modification), Article 4.4(B)

2. Method/Analysis Emission rates from the kilns, with emissions being controlled by the baghouse, 

slurry scrubber, and RTO’s Methods. Test Methods are referenced in Appendix 

5. Any method deviating from mentioned must have approval from AQD.

 (Consent Judgment No. 00-1163-CZ(Modification), Article 4.4(B)

3. Frequency and Schedule of 

Testing/Recordkeeping

The tests will be completed by March 31, 2004, unless an extension is approved 

by AQD due to “Force Majeure.”

 (Consent Judgment No. 00-1163-CZ(Modification), Article 4.4(B)

IV. REPORTING

1. Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

(R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due 

March 15 for reporting period July 1 to December 31 and September 15 for 

reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part 

A. Due March 15. (R 336.1213(4)(c))

4. The facility shall report the results of the QAP of the CEMS, within 30 days 

following the end of each calendar quarter, the facility shall submit the

results to the AQD in the format of the data assessment report.

 (Figure 1, 40 CFR 60, Appendix F)

5. The results of the annual audit of the COM shall be submitted to the AQD 

within 30 days after completion of the audit. (40 CFR 60, Appendix F)

6. The facility shall submit the copies of an EER and Summary Report in 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 64 of 136

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addressing CEMS data recording. It shall be submitted to AQD within 30 

days following the end of each calendar quarter. (40 CFR 63.10 (e)(3)(v))

In addition, the summary report shall include:

- All exceedances of maximum control device inlet gas temperature limits 

specified in 40 CFR 63, Subpart LLL, Section 63.144 (a) & (b).

- All failures to calibrate thermocouples and other temperature sensors as 

required under 40 CFR 63, Subpart LLL, Section 63.1350 (f)(7).

- All failures to maintain the activated carbon injection carrier gas flow rate or 

pressure drop, as applicable, as required under 40 CFR 63, Subpart LLL, 

Section 63.1344 (c).

- The results of any combustion system component inspections conducted 

within the reporting period as required under 40 CFR 63, Subpart LLL, 

Section 63.1350(i).

- All failures to comply with any provision of the operation and maintenance 

plan developed in accordance with 40 CFR 63, Subpart LLL, Section 63.1350 

(a). (40 CFR 63, Subpart LLL, Section 63.1354 (b)(9))

See Appendix 8.

V. OPERATIONAL PARAMETERS

1. “Conventional Mode” is defined as those times that a kiln is being fired with the following materials, alone or in 

combination with each other.

- Coal, up to 100% of the total heat released to a kiln

- Pet Coke, up to 25% of the total heat released to the kiln

- TDF, less than 4.6 tons/hr/kiln or less than 21% of the total heat released to the kiln

- Used oil generated onsite and offsite that meets specifications contained in Appendix 5, including during startup.

- Natural gas

- Silica Gel

- Diesel Fuel

 (R336.1201(1)(a)) & (R336.1205(1))

2. “AFM” mode is defined as those times that a kiln is being fired with any of the following fuels, alone or in combination 

with any alternative fuel(s)/material(s) listed in Appendix 5 and materials listed for “Conventional Mode” of this ROP.

- Petroleum Coke greater than 25% of the total heat input to a kiln

- TDF, greater than 4.6 tons per hour, or greater than 21% of the total heat input to a kiln

- Used oil other than that under “Conventional Mode”above.

 (R336.1201(1)(a)) & (R336.1205(1))

3. The facility shall not operate a kiln unless the respective fabric filter collector and either the activated carbon absorbent 

injection system or the limestone slurry scrubber and three RTO’s are installed and operating properly.

 (R336.1201(1)(a)) & (R336.1205(1))

4. The fabric filter collectors shall be operating when the fabric filter inlet temperature is between 280 and 475 

degrees F., except during startup when the fabric filter inlet temperature is less than 310 degrees F.

 (R336.1201(1)(a)) & (R336.1205(1))

5. Bypassing of the collector, will be allowed during start-up, as outlined in Article 4 above, provided no raw materials are 

fed to the kiln(s) and firing is either with natural gas, diesel, or used oil. Bypassing of the collectors due to high 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 65 of 136

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temperatures (above 475 degrees F.) will be permitted, provided all raw materials and fuels fed to the kiln(s) cease. 

 (R336.1201(1)(a)) & (R336.1205(1))

6. Raw material input feed to the kilns shall cease immediately, consistent with safe operating procedures, upon an 

initiation of the fabric filter collector bypass. Input feed to the kilns shall not restart until the fabric filter collector is back on 

line and functioning properly. The fabric filter collector(s) may be routinely bypassed only during the portion of startup as 

outlined in Article 4 above. (R336.1201(1)(a)) & (R336.1205(1))

7. The visible emission limitations in VI. OTHER REQUIREMENTS, Article 11, shall not be applicable during periods of 

startup and shutdown. Startup shall be defined as the period of time when only natural gas, fuel oil, or used oil is put to 

the burner pipe for the purpose of heating up the kiln and no other raw materials or AFM is being introduced. Shutdown 

shall be defined as a halting of the production. (R336.1201(1)(a)) & (R336.1205(1))

8. The facility must operate the kilns such that the temperature of the gas at the inlet to the kiln PMCD does not exceed 

the average of the run average temperature calculated for each run as determined during performance tests. 

(40 CFR 63, Subpart LLL, Sections 63.1344(a) & 63.1349 (b)(3)(iv))

9. During times that the carbon injection system is being operated, the nominal amount of carbon injected into each kiln 

exhaust ahead of the fabric filter collector shall be uniformly distributed throughout the hour, not including startup and 

shutdown and shall not be less than 295 pounds per hour calculated as a five-hour rolling average updated each hour, or 

less than 280 pounds for any individual hour for each operating kiln. For purposes of calculating the five-hour rolling 

average, all hourly carbon injection feeds in excess of 305 pounds shall be set equal to 305 pounds. Alternate substances 

and/or injection rates may be established by the Department after an acceptable demonstration has been made by the 

facility that compliance with the particulate emission and visible emission limitations will be achieved.

 (R336.1201(1)(a)) & (R336.1205(1)) (R336.1213(3))

10. The activated carbon injection rate shall be based on a three-hour rolling average that is equal to or greater than the 

average of the run average injection rates determined during performance testing.

 (40 CFR 63, Subpart LLL, Sections 63.1344(c)(1) & 63.1349(b)(3)(vi))

11. The facility shall maintain the minimum carbon injection carrier gas flow rate as a three-hour rolling average, based on 

the manufactures specifications and documents during test plan development, or maintain the minimum activated carbon 

injection carrier gas pressure drop, as a three hour rolling average, based on the manufacturer’s specifications and 

document during test plan development. (40 CFR 63, Subpart LLL, Section 63.1344(c)(2))

12. The facility must specify and use the brand and type of activated carbon used during the performance test. A 

complete copy of these specifications supplied by the vendor shall be submitted to the District Supervisor. Changes to the 

brand or type of activated carbon may necessitate subsequent performance tests unless the replacement has equivalent or 

improved properties compared to the activated carbon specifications cited during performance tests. The facility must 

maintain documentation that the substitute activated carbon will provide the same or better level of control as the original 

activated carbon. This documentation shall be submitted to the District Supervisor immediately upon delivery of such new 

material.

 (R336.1201(1)(a)) & (R336.1205(1) & (40CFR 63, Subpart LLL, Sections 63.1344 (d) & (e))

13. The facility shall only inject AFM into the hot end of the kilns; which means that portion of the mid kiln injection to the 

flame. (R336.1201(1)(a)) & (R336.1205(1))

14. The facility is allowed to burn AFM in the kilns when the following conditions are being met:

- The NO2, SO2. CO, and THC CEMs are installed and are operating properly.

- The COM is installed and is operating properly.

- The excess O2 monitor is installed and operating properly and O2 as measured at the kiln gas exit is maintained at 0.5% 

or greater, based upon a 60-minute rolling average period, updated each minute.

- The kiln temperature, as measured in the combustion zone of the kiln is operating at or above, 2100°F or greater based 

upon a 60-minute rolling average period, updated each minute.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

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- The device measuring exhaust gas temperature at the inlet to air pollution control device is installed and is operating 

properly. The temperature shall be measured on a 3-hour rolling average updated every minute per 40 CFR 63, Subpart 

LLL requirements.

- A negative pressure is established and maintained at the kiln inlet measured as a 60-minute rolling average updated 

every minute. (R336.1201(1)(a)) & (R336.1205(1)) & (R336.1225)

15. The facility shall automatically and immediately discontinue operating in the AFM mode per kiln under any one of the 

following conditions:

- Clinker production in the kilns is halted

- The carbon injection system, or the limestone slurry scrubber RTO’s are malfunctioning 

- During periods of startup, shutdown, or malfunction

- Kiln fabric filter collector bypass mode. (R336.1201(1)(a)) & (R336.1205(1))

16. The facility shall automatically and immediately take corrective action if there is a measured opacity of 15% or 

greater. If the measured opacity reading is over two hours in duration, the facility will discontinue the use of AFM. 

 (R336.1201(1)(a)) & (R336.1205(1))

17. The facility shall not process any AFM in the kilns which has not been through the Qualification Analysis of the 

“Alternative Fuels and Materials Management Process.” (See Appendix 3) (R336.1201(1)(a)) & (R336.1205(1))

18. The facility shall not process any AFM in the kilns which has not been recorded in POMS and shown to be in 

compliance with the appropriate screening levels. (See Appendix 3) (R336.1201(1)(a)) & (R336.1205(1))

VI. OTHER REQUIREMENTS

1. The facility shall develop a “Written Operations and Maintenance Plan.” It shall be submitted to the AQD for approval 

and shall include the following information:

- Procedures for proper operation and maintenance of the kiln process and all air pollution control devices in order to 

meet the emission limits and operating limits

- Procedures to be used during an inspection of the components of the combustion system of each kiln at least once 

per year. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(1) & 

(3))

2. The facility shall not operate the kilns unless the program for continuous fugitive dust control for all plant roadways, the 

plant yard, all material storage piles and all material handling operations specified in Attachment 1 has been 

implemented and maintained. Daily records will be kept, addressing noted conditions of operations listed in the 

referenced program and warranted actions taken to abate fugitive emissions.

 (R336.371) & (R336.1201(1)(a)) & (R336.1205(1))

3. The facility shall not operate the kilns unless the malfunction abatement plan/preventative maintenance program 

specified in Attachment 2 for the dry injection (absorbent materials) scrubber and handling system and fabric filter 

control system has been implemented and is maintained. (R336.1911) & (R336.1201(1)(a)) & (R336.1205(1))

4. The facility shall abide by the Supplemental Preventative Maintenance Program referenced in Attachment 3. Each 

inspection required by this program will have an appropriate log entry and be available upon request by the AQD 

District Supervisor. (Consent Order AQD No. 22-1999, Article 10) & (R336.1201(1)(a)) & (R336.1205(1))

5. Facility shall not make any changes to the POMS without the written approval of the District Supervisor.

 (R336.1201(1)(a)) & (R336.1205(1))

6. Upon issuance of the ROP, the facility shall have provided the District Supervisor with an updated copy of the 

Parametric Operating Monitoring System, which will be used by the facility for recordkeeping and for demonstrating 

compliance with the appropriate emission limitations. The Parametric Operating Monitoring System shall be based 

upon the AERMOD dispersion model. The permittee shall modify POMS to incorporate any subsequent EPA 

approved AERMOD modification which has impact on the predicted ambient concentrations used in POMS within 90 

days of such modification. Any modifications to the POMS shall be provided to the District Supervisor within 60 days 

of the AERMOD model modifications becoming effective. (R336.1201(1)(a)) & (R336.1205(1))

7. The AQD reserves the right to obtain samples of any AFM used at the facility and to have sample(s) independently 

tested. (R336.1201(1)(a)) & (R336.1205(1))

8. Upon issuance of the ROP, the facility shall have submited to the District Supervisor a notification protocol for AFM 

which qualify for use under the “Materials Management Plan.” The notification protocol shall have the written approval 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

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of the District Supervisor. (R336.1201(1)(a)) & (R336.1205(1))

9. The facility shall notify the District Supervisor whenever there are unanticipated interruptions in the use of AFM to the 

kilns as a result of any type of malfunction or equipment failure not covered under the facility’s startup, shutdown, and 

malfunction abatement plan. The notification of the actions taken must occur within two working days from 

commencing such actions and shall include:

- Date

- Time

- Materials being fired in the kiln(s)

-Reason for interrupting AFM to the kiln

- Corrective action(s) taken to address the malfunction (R336.1912) & (R336.1201(1)(a)) & (R336.1205(1))

10. Upon issuance of the ROP, the facility shall have in place a Malfunction Abatement Plan/Preventative Maintenance 

Program for the scrubber/oxidizer controls on the kilns. (R336.1911) & (R336.1201(1)(a)) & (R336.1205(1))

11. The facility shall monitor and/or calculate, and record the annual emissions (tons/year) of each calculated NSR 

pollutant that could increase as a result of this project. Annual emissions, as used in this special condition, means 

12 consecutive calendar months beginning with initial operation of either kiln in AFM mode. Annual emissions shall be 

maintained for a period of at least 5 years after initial use of AFM in either kiln.

 (R336.1201(1)(a)) & (R336.1205(1))

12. The facility shall comply with all applicable provisions of R336.1817 – Emission limitations and restrictions for Portland 

cement kilns. (R336.1201(1)(a)) & (R336.1205(1)) & (R336.1817)

13. The facility shall comply with all applicable provisions of Subpart LLL – National Emission Standards for Hazardous Air 

Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

14. In the event that annual emissions (tons/year) of each NSR pollutant, as indicated below, exceeds baseline actual 

emissions by a significant amount as a result of this project, the facility shall submit a report to the Administrator. 

The report shall contain the following information:

• The name, address, and telephone number of the stationary source.

• The annual emissions calculated pursuant to Article 12 above,

• An explanation as to why annual emissions exceeded the pre-construction projected actual emissions.

This information shall be submitted to the MDEQ-AQD within 60 days after the end of such calendar year.

Following are the projected actual emissions for this project which are not emission limits but are only for 

purposes of indicating when the reporting requirements for this article are applicable. The projected actual 

emissions of CO are capped at the current allowable level. (R336.1201(1)(a)) & (R336.1205(1))

NSR Pollutant Baseline Emissions 

(tons/year)

PSD Significant Level 

(tons/year)

Baseline & 

Significance Level 

(tons/year)

SO2 11,309.2 40 11,349.2

NOx 2,400.2 40 2,440.2

CO 3,427.3 100 3,515

VOC 4,187.2 40 4.227.2

PM, total 143.5 25 168.5

PM 10, filterable 45.6 15 60.6

Lead 0.1 0.6 0.7

15. No later than August 1, 2004, the facility shall conduct POMS validation according to an approved test plan. No less 

than 60 days prior to testing, a complete test plan shall be submitted to the AQD. The final plan must be approved by 

the AQD prior to testing. The test results shall be submitted to the AQD within 60 days of completion testing. The 

purpose of the testing is to document the validity of POMS for mercury. POMS shall be the means for assessing 

compliance with the annual limit in Condition II.B.8. which applies at all times. After initial testing, subsequent tests 

shall be conducted on a schedule concurrent with the facility’s PC MACT kiln testing requirements. 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

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 (R336.1201(a)) & (R336.1205(1))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

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TABLE F-1.9 FG009

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG009 Cement Loading to Railcars

Emission Unit/Process Groups EG 011-5 Bulk cement loading to railcars – N scale No. 1

EG 011-6 Bulk cement loading to railcars – S scale No. 2

I. DESIGN PARAMETERS 

A. Pollution Control Equipment DV011-5-2 Fabric filter

DV011-6-2 Fabric filter

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless 

otherwise noted. 

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum 

Exhaust Dimension

(inches)

c.

Temp.

(F)

d. Air 

Flow Rate

(acfm)

Applicable 

Requirement

1. SV023 52 20 NA NA NA

2. SV024 52 20 NA NA NA

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

PM (Opacity) 10% Opacity (40 CFR 63, Subpart LLL, Section 

63.1348)

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

The pressure drop across the fabric filters shall be monitored and recorded 

once per day if rail car silos are being filled. Recordings reflecting values 

outside of the range set forth in V-OPERATIONAL PARAMETERS will require 

the facility to initiate corrective action per the facility’s operations and 

maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/ 

Recorded 

NA

2. Method/Analysis EPA Method 22 (40 CFR 60, Appendix A-7)

EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))

2. If no emissions are observed in six consecutive months (utilizing Method 

22), testing may be decreased from monthly to semi-annually. If visible 

emissions are observed during any semiannual test, the facility must 

resume testing on a monthly basis until no visible emissions are 

observed in six consecutive monthly tests.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 70 of 136

TABLE F-1.9 FG009

FLEXIBLE GROUPING REQUIREMENTS

3. If no visible emissions are observed during the semiannual test (utilizing 

Method 22) , the facility may decrease the frequency to testing to 

annually. If visible emissions are observed during any annual test, the 

facility must resume testing on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive 

readings. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility 

must conduct a 6-minute test of opacity in accordance with Method 9. 

The Method 9 test must begin within one hour of any observation of 

visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in 

a form suitable and readily available for inspection and review as required 

by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be 

retained for at least five years following the date of each occurrence and 

measurement. At a minimum, the most recent two years of data shall be 

retained on site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche.

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. 

Due March 15 for reporting period July 1 to December 31 and September 

15 for reporting period January 1 to June 30.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the 

AQD within 90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be 

procedures for proper operation and maintenance of the source and air pollution control devices in order to 

meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the 

source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include 

provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).

 (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 71 of 136

TABLE F-1.10 FG010

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG010 Raw Material Transfer

Emission Unit/Process Groups EG008 Raw materials reclaim

EG010 Raw material conveyor (belt #2)

EG021 Raw material transfer (belt #2 to belt #5)

I. DESIGN PARAMETERS 

A. Pollution Control Equipment DV008-2 Fabric filter

B. Stack/Vent Parameters Exhaust gases discharged horizontally. 

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum Exhaust 

Dimension

(inches)

c.

Temp.

(F)

d. Air 

Flow Rate

(acfm)

Applicable 

Requirement

SV025 30 32 NA NA NA

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

PM (Opacity) 10% Opacity (40 CFR 63, Subpart LLL, Section 

63.1348)

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

The pressure drop across the fabric filters shall be monitored and recorded 

once per day when material is being transferred. Recordings reflecting values 

outside of the range set forth in V-OPERATIONAL PARAMETERS will require

the facility to initiate corrective action per the facility’s operations and 

maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/ 

Recorded 

Opacity (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))

2. Method/Analysis EPA Method 22 (40 CFR 60, Appendix A-7)

EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))

2. If no emissions are observed in six consecutive months (utilizing Method 

22), testing may be decreased from monthly to semiannually. If visible 

emissions are observed during any semiannual test, the facility must 

resume testing on a monthly basis until no visible emissions are 

observed in six consecutive monthly tests.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 72 of 136

TABLE F-1.10 FG010

FLEXIBLE GROUPING REQUIREMENTS

Method 22) , the facility may decrease the frequency to testing to 

annually. If visible emissions are observed during any annual test, the 

facility must resume testing on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive 

readings. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility 

must conduct a 6-minute test of opacity in accordance with Method 9. 

The Method 9 test must begin within one hour of any observation of 

visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in 

a form suitable and readily available for inspection and review as required 

by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be 

retained for at least five years following the date of each occurrence and 

measurement. At a minimum, the most recent two years of data shall be 

retained on site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche.

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. 

Due March 15 for reporting period July 1 to December 31 and September 

15 for reporting period January 1 to June 30.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the 

AQD within 90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be 

procedures for proper operation and maintenance of the source and air pollution control devices in order to 

meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the 

source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include 

provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).

 (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

3. Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1. (R336.1201(3))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 73 of 136

TABLE F-1-11 FG011

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG011 Natural Gas-Fired Solid Fuel Dryers

Emission Unit/Process Groups EGDRYER-1, 8.5 mm BTU/Hr gas-fired solid fuel dryer for No. 1 kiln

EGDRYER-2, 8.5 mm BTU/Hr gas-fired solid fuel dryer for No. 2 kiln

I. DESIGN PARAMETERS 

A. Pollution Control Equipment DRYER-1, DV03-5 Dry Scrubber (Carbon), DV003-2 Baghouse or DV003-2 

Baghouse, DV003-3 Limestone slurry scrubber, DV003-4 Three (3) RTOs

DRYER-2 , DV003-10 Dry Scrubber (Carbon), DV003-7 Baghouse, or DV003-

7 Baghouse, DV003-8 Limestone slurry scrubber, DV003-9 Three (3) RTOs

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards unless 

otherwise noted. 

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum 

Exhaust Dimension

(inches)

c.

Temp.

(F)

d. Air 

Flow Rate

(acfm)

Applicable 

Requirement

1. SV001 350 180 NA NA (R336.1225)

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

NOx 3,377 Tons/Yr per 12-month rolling time period. (Included under Table F-1.8)

 (R336.1201(1)(a)) & (R336.1205(1))

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

For audit and reporting requirements, see Table F-1.8 III.A.1.

2. Process Monitoring System 

and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/ 

Recorded 

NA

2. Method/Analysis NA

3. Frequency and Schedule of 

Testing/Recordkeeping 

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

 (R 336.1213(3)(c)(ii))

2. The facility shall submit the copies of an EER and Summary Report in 

addressing the NO2CEMS data recording. It shall be submitted to AQD 

within 30 days following the end of each calendar quarter. (Reference in 

Table F-1.8 IV. G. REPORTING)

 (40 CFR 63.10(c)(3)(v)) & (R 336.1213(3)(c)(i))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 74 of 136

TABLE F-1-11 FG011

FLEXIBLE GROUPING REQUIREMENTS

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

4. The facility shall report the results of the QAP of the NO2 CEM, with 30 

days following the end of each calendar quarter, the facility shall submit 

the results to the AQD in the format of the data assessment report. 

(Referenced in Table F-1.8 IV.4. REPORTING.)

 (Figure 1, 40 CFR 60, Appendix F)

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

1. The solid fuel dryers shall be fired with pipeline natural gas (or equivalent) only. 

(R336.1201(1)(a)) & (R336.1205(1))

2. The solid fuel dryers shall not operate unless the exhaust gases are directed to the kilns, through the kiln(s) 

emission control system and exhausted through the existing kiln stack. 

(R336.1201(1)(a)) & (R336.1205(1))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 75 of 136

TABLE F-1.12 FG012

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG012 Clinker Transfer

Emission Unit/Process Groups EG009-1 – Clinker transfer, bucket elevators

EG009-4 – Clinker transfer, apron conveyors

I. DESIGN PARAMETERS 

A. Pollution Control Equipment DV009-1-2 Fabric filter

DV009-4-2 Fabric filter

B. Stack/Vent Parameters Exhaust gases shall be discharged unobstructed vertically upwards for 

SV003 and horizontal for SV032.

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum 

Exhaust Dimension

(inches)

c.

Temp.

(F)

d. Air 

Flow Rate

(acfm)

Applicable 

Requirement

1. SV003 NA NA NA NA NA

2. SV032 NA NA NA NA NA

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

PM (Opacity) 10% (40 CFR 63, Subpart LLL, Section 

63.1348)

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

The pressure drop across the fabric filters shall be monitored and recorded 

once per day during material transfer. Recordings reflecting values outside of 

the range set forth in V-OPERATIONAL PARAMETERS will require the

facility to initiate corrective action per the facility’s operations and

maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/ 

Recorded 

Opacity (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))

2. Method/Analysis EPA Method 22 (40 CFR 60, Appendix A-7)

EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))

2. If no emissions are observed in six consecutive months (utilizing Method 

22), testing may be decreased from monthly to semi-annually. If visible 

emissions are observed during any semi-annual test, the facility must 

resume testing on a monthly basis until no visible emissions are 

observed in six consecutive monthly tests.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 76 of 136

TABLE F-1.12 FG012

FLEXIBLE GROUPING REQUIREMENTS

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing 

Method 22) , the facility may decrease the frequency to testing to 

annually. If visible emissions are observed during any annual test, the 

facility must resume testing on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive 

readings. (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

4. If visible emissions are observed during any Method 22 test, the facility 

must conduct 6-minute test of opacity in accordance with Method 9. The 

Method 9 test must begin within one hour of any observation of visible 

emissions.

 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in 

a form suitable and readily available for inspection and review as required 

by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be 

retained for at least five years following the date of each occurrence and 

measurement. At a minimum, the most recent two years of data shall be 

retained on site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche.

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. 

Due March 15 for reporting period July 1 to December 31 and September 

15 for reporting period January 1 to June 30.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually by March 15 for the previous calendar year.

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filters will be provided to the appropriate District Office of the 

AQD within 90 days of the effective date of the ROP. (R336.1213(2))

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be 

procedures for proper operation and maintenance of the source and air pollution control devices in order to 

meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the 

source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include 

provisions of paragraphs 63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 77 of 136

TABLE F-1.13 FGCOLDCLEANERS

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FGCOLDCLEANERS - Any existing cold cleaner (placed into operation prior to 

7/1/79) or new cold cleaner (placed into operation after 7/1/79) that is exempt 

from NSR permitting by R 336.1281(h) or R 336.1285 (r)(iv). 

Emission Unit/Process Groups EG025-1 & EG025-2

I. DESIGN PARAMETERS

A. Pollution Control Equipment NA

B. Stack/Vent Parameters NA

Stack/Vent 

ID

a. Minimum 

Height

 (feet)

b. Maximum 

Exhaust Dimension 

(inches)

c. 

Temp 

(°F)

d. Air 

Flow Rate 

(acfm)

Applicable 

Requirement

1. NA NA NA NA NA NA

C. Other Design Parameters 

1. A cover shall be installed and the cover shall be closed whenever parts are not being handled in the cleaner.

 (R 336.1611(2)(a), R 336.1707(3)(a))

2. The cover shall be mechanically assisted if the Reid vapor pressure of the solvent is more than 0.3 psia, or if the 

solvent is agitated or heated. (R 336.1707(3)(a))

3. A device shall be available for draining cleaned parts. (R 336.1611(2)(b), R 336.1707(3b))

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate 

Cleaning Solvents The facility shall not use cleaning solvents containing more than 5 percent by 

weight of the following halogenated compounds: methylene chloride, 

perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride, 

chloroform, or any combination thereof. (R 336.1213(3))

B. Pollutant Maximum Emission Limit

NA NA

III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition To General Requirements in Part A 

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

1. The date of installation of each cold cleaner. (R 336.1213(3))

2. The identification name/number, air/vapor interface area and type of solvent 

used (including Reid vapor pressure and VOC content) shall be maintained 

for each cold cleaner. (R 336.1213(3))

3. As noted in R 336.1611(2)(c) and R 336.1707(3)(c), if applicable, an initial 

demonstration that the waste solvent is a safety hazard shall be made prior 

to storage in non-closed containers. If the waste solvent is a safety hazard 

and is stored in non-closed containers, verification that the waste solvent is 

disposed of so that not more than 20%, by weight, is allowed to evaporate 

into the atmosphere shall be made on a monthly basis. (R 336.1213(3))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 78 of 136

TABLE F-1.13 FGCOLDCLEANERS

FLEXIBLE GROUPING REQUIREMENTS

4. For new cold cleaners, if the solvent is heated, the solvent temperature shall 

be monitored and recorded on a monthly basis, during peak operating 

conditions. (R 336.1213(3))

5. As noted in R 336.1707(2), if applicable, the option chosen to comply with 

R 336.1707(2) shall be recorded. (R 336.1213(3))

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Parameter to be 

Tested/Recorded

NA

2. Method/Analysis NA

3. Frequency and Schedule 

of Testing/Recordkeeping

NA

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to condition 24 of Part A, using the 

format in Appendix 8. (R 336.1213(3)(c)(ii))

2. Semi-annual reporting of deviations pursuant to condition 23 of Part A, 

using the format in Appendix 8. Due March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to 

June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to conditions 28 and 29 of Part 

A. Due annually by March 15 for the previous calendar year.

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

1. The facility may install or construct an unlimited number of new cold cleaners that meet one of the following 

requirements:

a. The air/vapor interface of the cold cleaner is no more than 10 square feet. (R 336.1281(h))

b. The cold cleaner is used for cleaning metal parts and the emissions are released to the general in-plant 

environment. (R 336.1285(r)(iv))

2. Waste solvent shall be stored only in closed containers, unless the stored solvent is demonstrated to be a safety 

hazard and is disposed so that not more than 20%, by weight, is allowed to evaporate into the atmosphere.

 (R 336.1611(2)(c), R 336.1707(3)(c))

3. Parts shall be drained for not less than 15 seconds or until dripping ceases.

 (R 336.1611(2)(b),(R 336.1707(3b))

4. The facility shall perform routine maintenance on each cold cleaning machine as recommended by the 

manufacturer. (R 336.1213(3))

5. Each new cold cleaner shall not be operated using a solvent having a Reid vapor pressure of more than 0.6 psia 

or heated above 120 degrees Fahrenheit, unless at least one of the following is met: (R 336.1707(2))

a. The cold cleaner is designed such that the ratio of the freeboard height to the width of the cleaner is equal to 

or greater than 0.7. (R 336.1707(2)(a))

b. The solvent bath is covered with water if the solvent is insoluble and has a specific gravity of more than 1.0.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 79 of 136

TABLE F-1.13 FGCOLDCLEANERS

FLEXIBLE GROUPING REQUIREMENTS

 (R 336.1707(2)(b))

c. The cold cleaner is controlled by a carbon adsorption system, condensation system, or other method of 

equivalent control approved by the AQD. (R 336.1707(2)(c))

VI. OTHER REQUIREMENTS

1. The facility shall maintain written procedures to demonstrate compliance with the requirements of 

 R 336.1611 and R 336.1707. Such procedures shall be posted in an accessible, conspicuous location near 

each machine. (R 336.1611(3), R 336.1707(4))

2. The facility may construct, reconstruct, modify, install or commence operation of any new or existing emission 

units under FGCOLDCLEANERS without modifying the RO Permit provi ding that it is not defined as a minor or 

significant modification to the RO Permit, as defined by R 336.1216(2) and R 336.1216(3), respectively, and the 

following provisions are met:

a. It is not a major stationary source or major modification as defined in the prevention of significant 

deterioration regulations in 40 CFR 52.21. (R 336.1278(a))

b. It is not a major offset source or a major offset modification as defined in R 336.1113(c) and (b), respectively, 

for which volatile organic compounds, particulate matter, PM-10, carbon monoxide, nitrogen oxides, sulfur 

dioxide, or lead is a non-attainment air contaminant. (R 336.1278(b))

c. It does not have actual emissions of volatile organic compounds, particulate matter, carbon monoxide, 

nitrogen oxides, sulfur dioxide, or lead above the significance levels as defined in R 336.1119.

 (R 336.1278(c))

d. It is not a major source as defined in the National Emission Standards for Hazardous Air Pollutants for 

source categories, 40 CFR 63.2, and it is subject to the provisions of 40 CFR 63.40 through 63.44.

 (R 336.1278(d))

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 80 of 136

TABLE F-1.14 FG014

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG014 The existing portable quarry drilling system (placed into operation in 

1996) and any new or replacement or backup system that would be 

considered exempt from NSR permitting (R336.1285(t)), while meeting the 

design parameters and emission limits below.

Emission Unit/Process Groups

I. DESIGN PARAMETERS 

A. Pollution Control Equipment Fabric Filter

B. Stack/Vent Parameters Exhaust gases shall be discharged horizontally.

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum 

Exhaust Dimension

(inches)

c.

Temp.

(F)

d. Air 

Flow 

Rate

(acfm)

Applicable 

Requirement

SV031 4.0 10.0 NA 550 (R336.1201(3))

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

1. Particulate Matter 0.10 lbs/1,000 lbs. exhaust gas calculated on a dry gas basis.

 (R336.1201(3))

2. PM (Opacity) 1. 20% opacity for the drill face. 

(R336.1301(1)(a))

2. 10% opacity from the exhaust stack. 

(R336.1301(1)(c))

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System 

and Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

The pressure drop across the fabric filter shall be monitored and recorded in 4

hour intervals when drilling for later installed explosive charges. Recordings 

reflecting values outside of the range set forth in V-OPERATIONAL 

PARAMETERS will require the facility to initiate corrective action per the

facility’s operations and maintenance plan. (R336.1213(3))

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be Tested/ 

Recorded 

Visible emissions (opacity)

2. Method/Analysis Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping 

1. Visible emission observations will be made for a minimum 6 minute

period at the exhaust outlet and at the drilling face during a drilling

project.

2. If the opacity limits are exceeded, as set forth in II IV-OTHER 

REQUIREMENTS, the drilling process will cease operation until such

time repairs/corrections have been made. A 6-minute observation shall 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 81 of 136

TABLE F-1.14 FG014

FLEXIBLE GROUPING REQUIREMENTS

subsequently be made to assure compliance with the opacity limits set 

forth.

3. Record logs will be kept of all observations and any repairs or remedial 

actions taken to address exceedances in opacity or operational in 

opacity or operational ranges. (R336.1213(3))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A. 

 (R 336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. 

Due March 15 for reporting period July 1 to December 31 and September 

15 for reporting period January 1 to June 30.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

See Appendix 8.

V. OPERATIONAL PARAMETERS

Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the 

AQD within 90 days of the effective date of the ROP.

VI. OTHER REQUIREMENTS

NA

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 82 of 136

TABLE F-1.15 FG015

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG015 Clinker storage and handling operation.

Emission Unit/Process Groups EG034 Clinker storage hall

EG036 No. 1 & No. 3 Open top clinker storage silos

EG037 Hot clinker discharge/well

EG038 Crane/clam bucket & mobile equipment

I. DESIGN PARAMETERS 

A. Pollution Control Equipment DV-034-2 Fabric Filter

DV-034-3 Fabric Filter

DV-034-4 Fabric Filter

B. Stack/Vent Parameters Filtered exhausts and emissions from clinker transfer operations exhausted 

horizontally through natural draft storage hall louvered ventilator (SV047) or 

horizontally from openings at the point where the containment walls meet the 

descending roof, and the mobile vehicle openings to the hall (SV048).

Stack/Vent ID a. Minimum 

Height

(feet)

b. Maximum 

Exhaust Dimension

(inches)

c.

Temp.

(F)

d. Air 

Flow 

Rate

(acfm)

Applicable 

Requirement

SV047 Approx 50 960 x 48 louvered 

vent

NA NA NA

SV048 1. NA

2. 8

1. 2 - 264 x 348 

door openings

2. 52 x 9,660 

ventilation opening

NA NA NA

C. Other Design Parameters

NA

II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutants Maximum Emission Limit

1. PM (Opacity) 10% Opacity (EG036 & EG037)

 (R336.1201(3)) & (40CFR63, Subpart LLL, Section 63.1348)

2. PM (Opacity) 20% Opacity (EG034 & EG038) 

(R336.1301(a))

III. COMPLIANCE EVALUATION 

Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

A. MONITORING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A

1. Continuous Emission 

Monitoring (CEM) System and 

Recordkeeping

NA

2. Process Monitoring System 

and Recordkeeping

NA

3. Other Monitoring and/or 

Recordkeeping

NA

B. TESTING/RECORDKEEPING (R 336.1213(3))

In Addition to General Requirements in Part A 

1. Parameter to be 

Tested/Recorded

Opacity (EG036 & EG037) (40 CFR 63, Subpart LLL, Section 63.1349(a))

2. Method/Analysis EPA Method 9 (as modified) – The performance test shall be conducted 

under representative performance conditions in accordance with 40 CFR 63, 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 83 of 136

TABLE F-1.15 FG015

FLEXIBLE GROUPING REQUIREMENTS

Subpart A, Section 60.7(c) per revised (12/2002) 40 CFR 63, Subpart LLL, 

Section 63.1349(b)(2). The maximum six-minute average opacity exhibited 

during the test period shall determine compliance either from the hall louvered 

vent, access openings or ventilation openings. The duration of the Method 9 

Performance Test shall be 3-hours (30-6 minute averages), except that the 

duration of the Method 9 Performance Test may be reduced to 1-hour if it is 

found that no individual readings greater than 10 percent opacity and there are 

no more than three readings of 10 percent for the first 1-hour period.

(40 CFR 60, Appendix A-4), (40 CFR 63, Subpart LLL, Section 

63.1349(b)(2))

3. Frequency and Schedule of 

Testing/Recordkeeping

Performance tests shall be conducted in accordance with Method 9 (as 

modified within 180 days after initial startup. Visible emission observation 

procedure must have prior approval by the AQD. (40 CFR 63, Subpart A, 

Sections 63.7(a)(2)), (40 CFR 63, Subpart LLL, Section 63.1349(a)), 

(R336.1213(3))

1. Parameter to be 

Tested/Recorded

Opacity (EG036 & EG037)

 (40 CFR 63, Subpart LLL, Section 63.150(a)(4))

2. Method/Analysis 1. EPA Method 22 (40 CFR 60, Appendix A-7)

2. EPA Method 9 (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of 

Testing/Recordkeeping

1. Monthly 1-minute visible emissions test in accordance with Method 22.

 (40 CFR 63, Subpart LLL, Section 63.1350(a)(4)(i))&(4)(vi))

2. If no emissions are observed in six consecutive months (utilizing Method 

22), testing may be decreased from monthly to semi-annually. If visible 

emissions are observed during any semi-annual test, the facility must 

resume testing on a monthly basis until no visible emissions are 

observed in six consecutive monthly tests.

 (40 CFR 63, Subpart LLL, Section 63. 1350 (a)(4)(ii))

3. If no visible emissions are observed during the semi-annual test (utilizing

Method 22), the facility may decrease the frequency of testing to 

annually. If visible emissions are observed during any annual test, the 

facility must resume testing on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive 

readings.

 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4(iii))

4. If visible emissions are observed during any Method 22 test, the facility 

must conduct a 6-minute test of opacity in accordance with Method 9. 

The Method 9 test must begin within one hour of any observation of 

visible emissions.

 (40 CFR 63, Subpart LLL, Section 63.150(a)(4)(iv))

5. The facility shall maintain files of the required visible emission records in 

a form suitable and readily available for inspection and review as required 

by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be 

retained for at least five years following the date of each occurrence and 

measurement. At a minimum, the most recent two years of data shall be 

retained on site. The files may be maintained on microfilm, on a 

computer, on floppy disks, on magnetic tape, or on microfiche.

 (40 CFR 63, Subpart LLL, Section 63.155(a))

IV. REPORTING

Reports and Schedules 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.

 (R 

336.1213(3)(c)(ii))

2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 84 of 136

TABLE F-1.15 FG015

FLEXIBLE GROUPING REQUIREMENTS

Due March 15 for reporting period July 1 to December 31 and September 

15 for reporting period January 1 to June 30.

 (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to Conditions 28 and 29 of 

Part A. Due annually March 15 for the previous calendar year. 

R336.1213(4)(c))

4. The results of opacity or visible emission evaluations as required under 

performance test requirements utilizing EPA Method 9 (as modified) shall 

be submitted to AQD within 60 days following the last date of the 

evaluation. 

(See Appendix 5) (40 CFR 63, Subpart A, Section 63.7 (g)(1))

See Appendix 8.

V. OPERATIONAL PARAMETERS

NA

VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be 

procedures for proper operation and maintenance of the source and air pollution control devices in order to 

meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the 

source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include 

provisions of paragraphs 63.1350 (a)(4)(i) thru (iv). (40 CFR 63, Subpart LLL, Section 63.1350(a))

2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.

 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 85 of 136

G. Non-Applicable Requirements

{CHOOSE: FIRST PARAGRAPH AND TABLE } 

At the time of issuance, the AQD has determined the following requirements are not applicable to this source. 

This determination is incorporated into the permit shield provision set forth in Part A (Conditions 30 through 33) of 

this RO Permit pursuant to R 336.1213(6)(a)(ii). 

NON-APPLICABLE REQUIREMENTS TABLE

Unit/Group ID Rule/Regulation 

Citation 

Requirement Description Justification 

FG008 40 CFR 60, 

Subpart F, Section 

60.60(b)

Standards for particulate emission 

limits & opacity limits for cement 

kilns with related testing, 

monitoring and recordkeeping.

Exempt from this subpart as the 

kilns are now applicable to 40 CFR 

63, Subpart LLL, promulgated June 

14, 1999 (reference Section 

63.1356 for exemption)

FG008 Rule 336.1801 

Article 4(e) & 8

Schedule of NOxcontrol and CEM 

requirement for cement kilns.

Revised December 4, 2002, to only 

include non-sip sources. Rule 

336.1817 now supercedes as to 

applicability.

FG010 40 CFR 60, 

Subpart OOO, 

Section 60.670(e)

Particulate emission and opacity 

limit standards for screening and 

conveyance of materials.

Not applicable as construction, 

reconstruction or modification was 

prior to August 31, 1983.

FG010 40 CFR 60, 

Subpart F, Section 

60.60(b)

Opacity limit standard for material 

conveyance.

Exempt from this subpart as the 

operations are now applicable to 

40 CFR 63, subpart LLL 

promulgated June 14, 1999. 

(reference Section 63.1356 for 

exemption)

FG012 40 CFR 60, 

Subpart OOO, 

Section 60.670(e)

Particulate emission and opacity 

limit standards for bucket elevator 

and conveyor material transfer.

Not applicable as constructing 

reconstruction or modification was 

prior to August 31, 1983.

FG012 40 CFR 60 

Subpart F, Section 

60.60(b)

Opacity limit standards for the 

bucket elevator and conveyor 

material transfer

Exempt from this subpart as the 

operations are now applicable to 

40 CFR 63, Subpart LLL, 

promulgated June 14, 1999 

(reference Section 63.1356 for 

exemption).

FG003 & FG006 40 CFR 60, 

Subpart OOO, 

Section 60.670(e)

Particulate emission and opacity 

limit standards for an enclosed 

truck loading station.

Not applicable as construction, 

reconstruction or modification was 

prior to August 31, 1983.

FG003 & FG006 40 CFR 60, 

Subpart F, Section 

60.60(b)

Opacity limit standards for a truck 

bulk loading system.

Exempt from this subpart as the 

operation is now applicable to 40 

CFR 63, Subpart LLL, promulgated 

June 14, 1999 (reference Section 

63.1356 for exemption)

FG009 40 CFR 60, 

Subpart OOO, 

Section 60.670(e)

Particulate emission and opacity 

limit standards for enclosed railcar 

station.

Not applicable as construction, 

reconstruction or modification was 

prior to August 31, 1983.

FG009 40 CFR 60, 

Subpart F, Section 

60.60b

Opacity limit standards for a 

railcar bulk loading system

Exempt from this subpart as the 

system is now applicable to 40 

CFR 63, Subpart LLL, promulgated 

June 14, 1999 (reference section 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 86 of 136

63.156 for exemption)

FG004 & EG013 40 CFR 60, 

Subpart OOO, 

Section 60.670(e)

Particulate emission and opacity 

limit standards for limestone 

crushing.

Not applicable as construction, 

reconstruction or modification was 

prior to August 31, 1983.

EG035 40 CFR 60 

Subpart OOO 

Section 60.670(b)

Particulate emission opacity limit 

standards for material convey or 

transfer

Not applicable as operation is 

subject to the provisions in Subpart 

F.

EG035 40 CFR 60 

Subpart F, Section 

60.60(b)

Opacity limit standards for 

conveyor material transfer

Exempt from this subpart as the 

operations are now applicable to 

40 CFR 63, Subpart LLL, 

promulgated June 14, 1999,

(reference Section 63.1356 for 

exemption).

EG034 & EG001-9 40 CFR 60 

Subpart OOO 

Section 60.670(b)

Particulate emission and opacity 

limit standards for storage bins 

(silos)

Not applicable as operation is 

subject to the provisions in Subpart 

F.

EG034 & EG001-9 40 CFR 60 

Subpart F, Section 

60.60(b)

Opacity limit standards for 

storage bins (silos)

Exempt from this subpart as the 

operations are now applicable to 

40 CFR 63, Subpart LLL 

promulgated June 14, 1999 

(reference section 63.1356 for 

exemption).

FG002 & EG030 & 

EG031

40 CFR 60, 

Subpart OOO, 

Section 60.670(e)

Particulate emission and opacity 

limit standards for storage bins 

(silos)

Not applicable as construction, 

reconstruction or modification was 

prior to August 31, 1983.

FG002 & EG030 & 

EG031

40 CFR 60, 

Subpart F, Section 

60.60(b)

Opacity limit standards for 

storage bins (silos)

Exempt from this subpart as the 

operations are now applicable to 

40 CFR 63, Subpart LLL, 

promulgated June 14, 1999 

(reference Section 63.1356 for 

exemption).

FG005 40 CFR 60, 

Subpart OOO, 

Section 60.670(b)

Particulate emission and opacity 

limit standards for bagging 

operations.

Exempt from this subpart as the 

systems were applicable to 40 

CFR 60, Subpart F.

FG005 40 CFR, Subpart 

F, Section 

60.60(b)

Standards for opacity limits for 

bagging systems.

Exempt from this subpart as the 

systems are now applicable to 40 

CFR 63, Subpart LLL promulgated 

June 14, 1999 (reference section 

63.1356 for exemption).

FG001 40 CFR 60, 

Subpart OOO

Section 60.670(e)

Particulate emission and opacity 

limit standards for grinding mills.

Not applicable as construction, 

reconstruction or modification was 

prior to August 31, 1983.

FG001 40 CFR, Subpart 

F, Section 

60.60(b)

Opacity limit standards for finish 

mill systems.

Exempt from this subpart as the 

operations are now applicable to 

40 CFR 63, Subpart LLL, 

promulgated June 14, 1999 

(reference Section 63.156 for 

exemption).

FG007 40 CFR 60, 

Subpart F, Section 

60.60(b)

Standards for particulate emission 

limits for clinker coolers with 

related testing monitoring and 

recordkeeping.

Exempt from this subpart as the 

clinker coolers are now applicable 

to 40 CFR 63, Subpart LLL, 

promulgated June 14, 1999 

(reference Section 63.1356 for 

exemption)
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 87 of 136

Appendices

Appendix 1. Abbreviations Used in This Permit

The following is an alphabetical listing of all abbreviations/acronyms used in this RO Permit. 

acfm Actual cubic feet per minute

AFM Alternative Fuel/Material

Ag Silver

AQD Air Quality Division

As Arsenic

Ba Barium

Baghouse Fabric Filter Collector

Be Beryllium

BrCH2CH2Br Ethylene Dibromide

BTU British Thermal Unit

CAA Federal Clean Air Act

C6Cl6 Hexachlorobenzene

Cd Cadmium 

CDDs Chlorinated Dibenzo-p-dioxins

CDFs Chlorinated Dibenzofurans

CEM Continuous Emission Monitor(ing)

CFR Code of Federal Regulations

C6H3ClNH2C6H3ClNH2 3,3-Dichlorobenzidine

C10H7NH2 2-Naphthylamine

CKD Cement Kiln Dust

°C Degrees Centigrade

CMS Continuous Monitoring System (Emissions or Opacity)

CO Carbon Monoxide

COM Continuous Opacity Monitoring

Cr Chromium

Cu Copper

DEQ Michigan Department of Environmental Quality

D/F Dioxin Furan

DRE Destructive Removal Efficiency

dscf Dry Standard Cubic Foot

dscm Dry Standard Cubic Meter

DV Process or Control Device ID

EER Excess Emission Report

EG Emission Unit/Process Group ID

EPA United States Environmental Protection Agency

°F Degree Fahrenheit

FG Flexible Group ID

gr Grain (7000 gr= 1 lb.)

HCFC Hydrochlorofluorocarbon

Hg Mercury

hr Hour

ID Identification (Number)

Kg Kilogram (1000 grams)

lbs Pounds

M

3 Cubic Meters

Mg Megagram (1 million grams)

μg Microgram (10-6 grams)
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 88 of 136

MMBTU 1 million BTUs

MVAC Motor vehicle air conditioner

Mn Manganese

Ni Nickel

NA Not applicable

Ng Nanograms (10-g grams)

NOx Oxides of Nitrogen

NO2 Nitrogen Dioxide

O2 Oxygen

Pb Lead

PCB Polychlorinated Biphenyl

Pet Petroleum

PM Particulate Matter

PMCD Particulate Matter Control Device

POMS Parametric Operating Monitoring System

pph Pounds per hour

ppm Parts per million

ppy Pounds per year

QAP Quality Assurance Procedures

RCRA Resource Conservation and Recovery Act

RMP Risk Management Plan

RO Renewable Operating Plan

RTO Regenerative Thermal Oxydizer

Sb Antimony

Se Selenium

SRN State Registration Number

SV Stack/Vent ID

SO2 Sulfur Dioxide

TEQ International method of expressing toxicity equivalents for dioxins and furans as defined in 

U.S.E.P.A., Interim Procedures for Estimating Risks Associated with Exposures to 

Mixtures of CDDs and CDFs, 1989.

TDF Tire Derived Fuel

THC Total Hydrocarbon

Tl Thallium

Tonne Metric ton (2,205 lbs)

tpy Tons per year

VOC Volatile Organic Compound

yr Year

Zn Zinc

= Less than or equal to

= Greater than or equal to

< Less than

> Greater than
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 89 of 136

Appendix 2. Schedule of Compliance 

The permittee has certified that this source is in compliance with all applicable requirements as of the date of 

issuance of this RO Permit and the permittee shall continue to comply with all applicable requirements listed in 

this RO Permit. A detailed Schedule of Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii))
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 90 of 136

Appendix 3. Monitoring Requirements

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements and 

referenced in Table F-1.8.

ALTERNATIVE FUELS AND MATERIALS 

MANAGEMENT PROCESS
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 91 of 136

Executive Summary

The Dundee Plant of Holcim (US) Inc., located in Monroe County, Michigan, is supplying additional information to 

clarify the Alternative Fuels and Materials Management Program. The AFM Management Program would be used 

to assure all non-hazardous alternative fuels and materials are having a quality control process through the three 

(3) process controls prior to Co-processing these AFM into the kiln. The three(3) quality process control are: 

Potential AFM Qualification Analysis, Individual Shipments, and POMS Control. 

In the Qualification Analysis Process, the potential AFM is thoroughly reviewed for non-hazardous characteristics, 

consistency with generator information, requirements for handling and storage, ability to meet POMS

requirements, internal use fitness for use, and approval by the plant manager. Basically this is the first screening 

level for the potential use of the AFM from a specific source.

The Individual Shipment Module will screen the incoming AFM to assure conformance with the non-hazardous 

characteristics and to verify that the characteristics of the material are the same as analyzed previously.

Finally, the POMS Control Module will control the final AFM blend ready to be co-processed in to the kiln, and to 

assure a consistent quality of the AFM stream.

The proposed AFM Management Process will be used for all AFM assuring a controlled and documented system, 

and will provide a system easily audited by MDEQ.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 92 of 136

AFM MANAGEMENT PROCESS

The AFM Management Program (see Figure 1) would be used to assure all non-hazardous fuels and materials are 

thoroughly reviewed using the three (3) process controls prior to co-processing. The three- (3) process controls are: 

Potential AFM Pre-Qualification Analysis, Indivi dual Shipments, and POMS Control.

QUALIFICATION ANALYSIS

In the Potential AFM Qualification Analysis process control (see Figure 2), the potential AFM is thoroughly reviewed 

prior to being approved for its usage. This module has many steps included to assure that all potential issues can be 

identified and considered in the ultimate use, or rejected from consideration. The steps are:

1) AFM Generator identified as a potential candidate.

Generator is a producer of a non-hazardous industrial waste (e.g. car that generates used oil).

In this step, a Generator, could be previously identified by the Plant, or can be a company, which ask for 

an environmental way of disposal of their by-products.

At this point all the information related with this potential AFM must be documented in a proper manner, 

following a consecutive order on the file numbering.

2) Non-Hazardous review performed.

The potential AFM must be analyzed under the MI Act 451 Part III, [40 CFR Part 261], to determine if the 

material is considered a non-hazardous waste material. In case that this material falls under the

hazardous waste classification, the AFM candidate must be rejected and documented in their respective 

file. 

3) Complete AFM Profile Form to identify generator information and additional chemical characteristics.

See attached Holcim Material Profile (Attachment A)

4) Completeness checks of AFM Profile Form.

At this point the evaluation of the Profile must have: (1) The business activity or process type of waste 

generation, (2) Storage and current treatment, 

(3) physical and chemical characteristics of the AFM candidate, (4) Health and Safety data (MSDS if 

available), (5) Existing stock volumes and monthly generated volumes, (6) Transport conditions 

5) Perform analysis of AFM candidate for consistency with AFM Profile Form.

Take a representative sample from the projected generated volume, and run a laboratory test to confirm 

the data provided at the Profile. If the laboratory results shows a sustainable difference with the data 

provided from the Generator and the AFM results hazardous the candidate must be rejected, documenting 

with all this information.

6) Review the handling and storage requirements based on chemical characteristics to determine

cost/benefit.

The AFM candidate must be reviewed under the applicable regulations for its handling requirements, 

storage conditions, and under the MSHA rules.

Once that all this requirements are reviewed, a cost-benefit evaluation must be performed in order to 

determine the feasibility of accepting this AFM at the Plant.

7) Perform applicable requirement review using the POMS
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 93 of 136

Feed the Parametric Operating Monitoring System with the information of the AFM candidate and

determine if the material is suitable to co-process in the kiln

8) Perform an internal acceptance review including Quality Department, Environmental Health and Safety 

Department, and the Kiln Processing Area.

A process review must be performed in all the areas related with the cement manufacturing process at the 

plant level. At this material the AFM candidate can be rejected for any of the involved areas.

9) Present to Plant Manager for AFM approval.

With all the 8 steps documented, the file is submitted to the Plant Manager for review and further 

approval or rejection

10) Address financial and logistics issues with AFM Generator.

At this point a financial analysis is performed in order to determine the disposal fee. 

11) Approved AFM

A contract and arrangement for AFM deliveries must be created.

At any point in the above process, the AFM Candidate could be rejected from consideration in the AFM Program, for 

every AFM candidate there has to be a file, even if the material is rejected all of the information must be documented.

INDIVIDUAL SHIPMENTS

The Individual Shipment Module (see Figure 1) will provide on-site screening of the incoming AFM to assure

conformance with the AFM Profile characteristics. Individual shipments will have a fingerprint analysis performed to 

verify that the AFM received meets the original characteristics defined in the Qualification Analysis process control. 

AFM that passes the fingerprint analysis will be accepted on-site. AFM that fails the fingerprint analysis will be 

rejected and the proper notifications made to the appropriate MDEQ agency and the AFM Generator.

Periodic quality control checks will be performed to assure that the fingerprint analysis accurately identifies the AFM 

characteristics.

Every load of AFM that comes to the plant must be documented with a consecutive number indicating all the

information that corresponds to that shipment.

PARAMETRIC OPERATING AND MONITORING SYSTEM (“POMS”) Control

The POMS Control Module (see Figure 1) will control the final AFM blend previous to be co-processed in to the kiln. 

Each individual shipment that passes the fingerprint analysis will be blended with other approved AFM. The final blend 

will be input into the POMS for final confirmation with applicable requirements.

An analysis of the blending material must be perform in order to assure the compliance with all applicable regulations 

and process control, to assure health and safety standards and to prevent any environmental risks. 

Once confirmed using POMS, the AFM will be co-processed in to the kiln 

SUMMARY
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 94 of 136

The AFM Management Plan is a systematic approach that will review and check all potential AFM candidates. All 

AFM received by Holcim will be pre-approved according to procedures identified in Holcim’s AFM Management 

Process. By taking a potential AFM through the Qualification Analysis Module, Holcim will insure that the approved 

AFM will be non-hazardous, and storage and handling requirements identified. The analysis of individual shipments 

will verify conformance with previous approval. A final use of the POMS will control and document the introduction of 

the AFM in the kiln co-processing.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 95 of 136

MATERIAL PROFILE FORM

Profile No. _______________

I. General Information

1. Material Common Name: 

2. Provide a description of the process(es) generating this material:

3. Estimated Volume of Material available (total & per month): Units: 

4. Location of Material: 

II. Generator Information

1. Generator Name: 2. Telephone No.: 

3. Address: 4. Fax No.: 

5. Email Address:

6. Contact: 7. Title:

III. Billing Information

1. Invoicing Name: 2. Telephone No.:

3. Address: 4. Fax No:

5. Email Address:

6. Contact: 6. Title:

7. Purchase Order No.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 96 of 136

IV. Sampling Information

Sample Instructions:

1. A representative one-quart sample of the material must accompany this profile form to initiate the approval 

process.

2. The sample taken should be representative of the material intended for shipment.

3. Sampling of the material should be completed as per standard regulatory guidelines.

4. Sampling equipment used must be those specified in standard regulatory guidance.

5. The sample label must include generator name, profile number and material description.

6. A completed sample custody transfer record must accompany the sample.

Sampling completed by (print): 

Sampler signature: 

Date sample was collected:

V. Physical Characteristics

1. Select one or more general descriptions for the material at 70o F:

Powdery Solid Sludge (non pumpable)

Dry Solid Liquid (pumpable)

Solids with free liquid Liquid (multi-phase)

Debris or Other Soils

Describe additional physical characteristics:

2. Does the waste have a characteristic odor(s)? ( ) Strong ( ) Moderate ( ) Slight ( ) 

None

Describe characteristic odor(s):

3. Color description:

4. Heat value (Btu/lb):

5. Density: Units:

6. pH: Water Extract pH:

7. Flash Point (°F):

8. Reactive with air or water? ( ) Yes ( ) No

V. Chemical Parameters

1. Based upon lab analyses and/or knowledge of the process(es) generating the material, list the chemical

 components with the minimum and maximum concentrations expected.

Constituent Minimum Maximum
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 97 of 136

Total

2. Water Content (%): 3. Sulfur Content (ppm):

4. Halogen Content (ppm):

5. Total Metal Concentration (MI Air Toxics):

Metal Constituent (mg/Kg) Minimum Maximum

Antimony (Sb) 

Arsenic (As) 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 98 of 136

Barium (Ba) 

Beryllium (Be) 

Cadmium (Cd) 

Chromium (Cr) 

Copper (Cu) 

Lead (Pb) 

Manganese (Mn) 

Mercury (Hg) 

Nickel, soluble salts (Ni) 

Selenium (Se) 

Silver (Ag) 

Thallium (Tl) 

Zinc (Zn) 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 99 of 136

VI. Material Hazards

1. Based upon RCRA Hazardous Waste Regulations (40 CFR 261):

Does this waste meet any F, K, P or U Hazardous Waste Listing Description(s)? ( ) Yes ( ) No

List any applicable Listed Waste Code(s):

Does this waste exhibit Ignitability (D001), Corrosivity (D002) or Reactivity (D003)? ( ) Yes ( ) No

List any applicable Characteristic Waste Code(s):

Does this waste contain cyanide amenable to chlorination above 250 ppm? ( ) Yes ( ) No

Does this waste contain reactive sulfide above 500 ppm? ( ) Yes ( ) No

Is this a California List hazardous waste containing halogenated organic compounds found in 

Appendix III of 40 CFR 268 in total concentrations greater than or equal to 1000 mg/L? ( ) Yes 

( ) No

2. Does the waste exhibit Toxicity characteristics defined by the Toxicity Characteristic Leaching 

Procedure (TCLP) test (See 40 CFR 261.24, Table 1, D004 – D043)? ( ) Yes ( ) No

3. Other regulated waste materials:

Does the waste contain any radioactive material? ( ) Yes ( ) No

Does the waste contain any biological or infectious waste(s)? ( ) Yes ( ) No

Does the waste contain asbestos? ( ) Yes ( ) No

Does this waste contain PCBs greater than 49 ppm? ( ) Yes ( ) No

If “Yes” indicate which TCLP constituent has been tested (Attach laboratory results). For those constituents not tested mark 

“No”. If the reason that the waste has not been tested is because the constituent is not believed to be applicable to the 

material mark “N/A”. Either “Yes”, “No” or “N/A” MUST be checked for each and every constituent.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 100 of 136

Code Constituent

40 CFR, Part 

261.24

Regulatory 

Limit

(mg/l)

MI R 299.4114

Regulatory 

Limit

(mg/l)

TCLP Analytical 

Test Level

(mg/l)

Testing:

Yes, No, N/A

Metals

D004 Arsenic 5.0 0.5

D005 Barium 100.0 10.0

D006 Cadmium 1.0 0.1

D007 Chromium 5.0 0.5

Copper N/A 10.0

D008 Lead 5.0 0.5

Manganese N/A 0.5

D009 Mercury (inorganic) 0.2 0.02

Nickel (soluble salts) N/A 1.0

D010 Selenium 1.0 0.1

D011 Silver 5.0 0.5

Zinc N/A 50.0

Organics

D012 Endrin 0.02

D013 Lindane 0.04

D014 Methoxychlor 10.0

D015 Toxaphene 0.5

D016 2,4-D 10.0

D017 2,4,5-TP 1.0

D018 Benzene 0.5 0.05

D019 Carbon Tetrachloride 0.5 0.05

D020 Chlordane 0.03

D021 Chlorobenzene 100.0 10.0

D022 Chloroform 6.0 0.6
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 101 of 136

D023 o-Cresol 200.0 20.0

D024 m-Cresol 200.0 20.0

D025 p-Cresol 200.0 20.0

D026 Cresol 200.0 20.0

D027 1,4-Dichlorobenzene 7.5 0.75

D028 1,2-Dichloroethane 0.5 0.05

D029 1,1-Dichloroethylene 0.7 0.07

D030 2,4-Dinitrotoluene 0.13

D031 Heptachlor 0.008

D032 Hexachlorobenzene 0.13

D033 Hexachlorobutadiene 0.5

D034 Hexachloroethane 3.0

D035 Methyl Ethyl Ketone 200.0 10.0

D036 Nitrobenzene 2.0

D037 Pentachlorophenol 100.0 10.0

D038 Pyridine 5.0

D039 Tetrachloroethylene 0.7 0.07

D040 Tricholorethylene 0.5 0.05

D041 2,4,5-Trichlorophenol 400.0 40.0

D042 2,4,6-Trichlorophenol 2.0 0.2

D043 Vinyl Chloride 0.2 0.02
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 102 of 136

VII. List Of Attachments

List and attach all analytical data, MSDSs or other information that will help to characterize this waste material.

Informational Instructions:

1. All forwarded analytical data must be applicable to the actual material intended to be shipped and come from a 

representative sample of that material.

2. Please attach all applicable QA/QC and chain of custody documentation for the sample data must also be forwarded 

with the data.

3. Please attach information about the laboratory conducting of any of the reported analyses including the name, 

address, phone number and laboratory contact. 

Attachment Description
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 103 of 136

VIII. Generator Certifications

I, the Supplier, certify, represent and warrant that the material presented and described herein is not a listed or characteristic 

hazardous waste and that the information presented in this profile and any attachment is complete and accurate to the best 

of my knowledge. I further certify that the analytical data and other information submitted with this AFR profile is applicable 

to the material intended for shipment and was obtained according to proper sampling and analytical guidelines.

I further certify, represent and warrant that, to the best of its knowledge, there have been no changes in the process 

generating the waste that would alter the characterization of the material described herein and in any of the attachments.

I certify that based upon my knowledge of the waste material and the process generating the waste, the TCLP constituents 

listed as N/A in Section VI Material Hazards are not present in the waste in concentrations above hazardous classification 

levels.

I understand that it is my obligation to immediately inform Holcim of any changes in the generating process that may alter 

the characteristics of the material described herein.

For brokered account, the brokering agent must include a signed affidavit from the generating company authorizing the broker 

to act as the representative of the generating company for the purpose of profiling the waste material and contracting with 

Holcim for it deliver to the facility.

Date:

Name: Signature:

Company: Title:
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 104 of 136

Holcim’s Acceptance is based on the information provided by your company on this Certification Form, the associated test 

data and other representations of your company. Your company shall absolutely and unconditionally protect, defend, 

indemnify and save harmless Holcim and its present and future officers, directors, shareholders, agents and employees of 

Holcim from and against any and all fines, loss, damage, injury, liability to or death of any person, costs of response to any 

governmental inquiry, request, or requirement or for loss of or damage to property or for loss or damage arising from 

attachments, liens or claims of material men or laborers, claims and reasonable attorneys’ fees and costs relating to any of 

the foregoing (“Claims”), resulting from Company’s activities, from Company’s tender of Non-conforming Materials or from 

Company’s breach of the Agreement, whether or not Holcim, or its officers, directors, shareholders, agents or employees 

was or is claimed to be concurrently or comparatively negligent, and regardless of whether liability without fault is imposed, 

or sought to be imposed, on Holcim. The foregoing indemnification shall not apply to the extent that such indemnity is void 

or otherwise unenforceable under applicable law in effect on or validly retroactive to the date of this Agreement, or the date of 

the claim, and shall not apply where such Claims are the result of the sole negligence or willful misconduct of Holcim. It is 

intended that the foregoing indemnity shall be broad and comprehensive. This indemnity shall survive the expiration or other 

termination of this Agreement. This indemnity is for the sole benefit of Holcim and not for the benefit of any third party.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 105 of 136

1 AFM Management Program
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 106 of 136
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 107 of 136

2 Potential AFM Qualification Analysis
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 108 of 136
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 109 of 136

Appendix 4. Recordkeeping

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate Requirement 

Tables. Therefore, this appendix is not applicable.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 110 of 136

Appendix 5. Testing Procedures

The facility shall use the following test method to measure the visible emissions for the applicable requirements 

referenced in Table E-1.3.

R 336.2034 REFERENCE METHOD 9D

Rule 1034 Reference Method 9D, Opacity Measurement for Fugitive Dust Sources Reads as Follows:

(A) Visible emissions of fugitive dust shall be determined according to Test Method 9 as set forth in the “Appendix on 

Test Methods” in 40 CFR, Part 60, “Standards of Performance for New Stationary Sources” as such appendix existed 

on October 31, 1984, with the following modifications:

(i) The data reduction provisions of Section 2.5 of Method 9 shall be based on an average of 12 consecutive readings 

recorded at 15 second intervals.

(ii) For roadways and parking lots, opacity observations shall be made from a position such that the observer’s line of 

vision is approximately perpendicular to the plume direction and approximately 4 feet directly above the surface of the 

road or parking area from which the emission are being generated. The observer shall not look continuously at the 

plume, but instead shall observe the plume momentarily at 15-second intervals at the point of maximum plume 

density. Consecutive readings must be suspended for any 15-second period if a vehicle is in the observer’s line of 

sight. If this occurs, a “V” shall be used in lieu of a numerical value, and a footnote shall be made to indicate that “V”

signifies that the observer’s view was obstructed by a vehicle. Readings shall continue at the next 15-second period, 

and they shall be considered consecutive to the reading immediately preceeding the 15-second period denoted by a 

“V.” Consecutive readings also must be suspended for any 15-second period if a vehicle passes through the area 

traveling in the opposite direction and creates a plume that is intermixed with the plume being read. If this occurs, an 

“I” shall be used in lieu of a numerical value, and a footnote shall be made to indicate that “I” signifies that the readings 

were terminated due to interference from intermixed plumes. Readings shall continue when, in the judgment of the 

observer, the plume created by the vehicle traveling in the opposite direction no longer interferes with the plume 

originally being read; and they shall be considered consecutive to the reading immediately preceeding the 15-second 

period denoted by an “I.” Intermixing of plumes from vehicles traveling in the same direction represents the road 

conditions, and reading shall continue in the prescribed manner. A reading encompassing an unusual condition (such 

as a broken bag of cement of the pavement) cannot be used to represent the entire surface condition involved. In such 

cases, another set of reading, encompassing the average surface condition, must be conducted. For all other sources 

of fugitive dust except roadways and parking lots, opacity observations shall be made from a position that provides the 

observer a clear view of the source and the fugitive dust with the sun behind the observer. A position at least 15 feet 

from the source is recommended. To the extent possible, the line of sight should be approximately perpendicular to 

the flow of fugitive dust and to the longer axis of the emissions. Opacity observations shall be made for the point of 

highest opacity within the fugitive dust. Since the highest opacity usually occurs immediately above or downwind of 

the source, the observer should normally concentrate on the area or areas of the plume close to the source.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 111 of 136

APPENDIX 5. Testing Procedures (continued)

The facility shall use the following approval test plans, procedures, and average times to measure the vi sible 

emissions for the applicable requirements referenced in Table F-1.3

The source will run at the highest load or capacity level reasonably expected to occur. The maximum 6 minute 

average will be utilized to determine initial compliance. The duration of the performance test shall be 3-hours (thirty 

(30) 6-minute averages. This duration may be reduced to 1-hour if no individual reading are greater than 10 percent 

opacity and there are no more than three readings of 10 percent for the first 1-hour period.

The facility shall use the following procedures and specifications in measuring material limits for the applicable 

requirements referenced in Table F-1.8.

USED OIL FUEL SPECIFICATION

Constituent/Property Allowable Level*

Arsenic = 5 parts per million (PPM) by weight

Cadium = 2 ppm

Chromium = 10 ppm

Lead = 100 ppm

Flash Point = 100°F

Total Halogens = 1,000 ppm

PCB’s = 49 ppm

*These values are maximums, except for flash point which is a minimum. A halogen level exceeding 1000 ppm is 

presumed to be a hazardous waste unless otherwise demonstrated. Used oil that has been contaminated with any 

halogenated solvents shall not be used as supplemental fuel.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 112 of 136

Definition of Hazardous Waste

A chemical waste is considered to be hazardous if the waste exhibits any of the following characteristics:

Ignitability

A substance is considered to be ignitable if it exhibits any of the following properties

1. It is a liquid, other than an aqueous solution containing less than 24% alcohol by volume and has a flash point 

less than 60 degree C (140 degrees F), as determined by the Pensky-Martens Closed Cup Tester.

2. It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, 

absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently 

that it creates a hazard.

3. It is a flammable compressed gas.

4. It is an oxidizer such as chlorates, permanaganates, inorganic peroxides, or nitrates that yield oxygen readily to 

stimulate the combustion of organic matter.

Corrosivity

A substance if considered to be corrosive if it exhibits any of the following properties:

1. It is aqueous and has a pH less than or equal 2 or greater than or equal 12.5 as determined by a pH meter using 

either en EPA or equivalent test method.

2. It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm/year at 55 degrees C.

Reactivity

A substance is considered to be reactive if it exhibits any of the following properties:

1. It is normally unstable and readily undergoes violating change without detonating.

2. It reacts violently with water.

3. It forms potentially explosive mixtures with water.

4. When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to 

human health or the environment.

5. It is a cyanide of sulfide bearing waste which, when exposed to Ph conditions between 2 and 12.5, can generate 

toxic gases, vapors, or fumes in a quantity sufficient to present danger to human health of the environment.

6. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under 

confinement.

7. It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

8. It is a forbidden explosive as defined by 49 CFR 173.53, or a class B explosive as defined in 49 CFR 173.88.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 113 of 136

Toxicity Characteristic Leaching Procedure (TCLP)

This characteristic identifies wastes from which certain toxic materials could be leached into groundwater supplies and 

is defined by a prescribed test procedure for water extraction of the waste. The extract us analyzed for concentrations 

of eight elements or ions; Arsenic, Barium, Cadmium, Chromium (VI), Lead, Mercury, Selenium, and Silver: and the 

thirty-one organic substances listed below.

Benzene

Carbon Tetrachloride

Chlordane

Chlorobenzene

Chloroform

o-Cresol

m-Cresol

p-Cresol

1,4-Dichlorobenzene

1,2-Dichloroethylene

1,1-Dichloroethylene

2,4-Dinitrotoluene

Endrin

Heptachlor

Hexachlorobenzene

Hexachloro-1,3-butadiene

Hexachloroethane

Lindane

Methoxychlor

Methyl ethyl ketone

Nitrobenzene

Pentachlorphenol

Pyridine

Tetrachloroethylene

Toxaphene

Trichloroethylene

Toxaphene

Trichloroethylene

2,4,5-Trichlorophenol

2,4,6-Trichlorophenol

Vinyl chloride

2,4-D

2,4,5-TP Silvex
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 114 of 136

Acceptable Fuels and Materials Generated Offsite

Waste Type Process of Generation Typical Waste

Liquid (Non-hazardous) Waste from machining, lubricating, 

and cooling operations

• Waste machine oils

• Waste machining oils (not 

emulsioned)

• Waste machining emulsions

• Synthetic machining oils

Liquid (non-hazardous) Waste hydraulic oils and brake fluids • Hydraulic oils (not emulsions)

• Emulsions

• Hydraulic oils containing only 

mineral oil

• Other hydraulic oils

Liquid (non-hazardous) Waste engine, gear and lubricating 

oils

Waste engine, gear and lubricating 

oils

Liquid (non-hazardous) Waste insulating and heat 

transmission oils and other liquids

• Insulating and heat transmission 

oils and other liquids

• Synthetic insulating and heat 

transmission oils and other 

liquids

• Mineral insulating and heat 

transmission oils and other 

liquids

Liquid (non-hazardous) Bilge Oils • Bilge oils from inland navigation

• Bilge oils from jetty sewers

• Bilge oils from other navigation

Liquid (non-hazardous) Waste from organic dyes and 

pigments

• Aqueous washing liquids and 

mother liquids.

• Aqueous liquids containing 

adhesive and sealants

Liquid (non-hazardous) Wastes from the manufacturing of 

plastics, synthetic rubber and manmade fibers

Aqueous washing liquids and mother 

liquids.

Liquid (non-hazardous) Wastes from the manufacturing of 

pharmaceuticals

Aqueous washing liquids and mother 

liquids.

Liquid (non-hazardous) Wastes from the manufacturing of 

fats, grease, detergents, disinfectants 

and cosmetics.

Aqueous washing liquids and mother 

liquids.

Liquid (non-hazardous) Waste from oil regeneration Aqueous liquid waste from oil 

regeneration.

Agricultural oils and wastes • Vegetable oil, soy bean oil, 

canola oil, sunflower oil, etc.

• Products from animal and food 

rendering industry

Liquid (non-hazardous) Petroleum refinery wastes Waste oils

Liquid (non-hazardous) Iron and steel manufacturing wastes Waste oils and liquids

Liquid (non-hazardous) Food Processing Wastes Liquid food processing wastes

Sludges (non-hazardous) Oil/water separator contents • Oil/water separator sludges

• Interceptor sludges

• Desalter sludges or emulsions

• Other emulsions

Sludges (non-hazardous) Waste paint and coatings from 

manufacturing and productions 

operations

Paint and coating sludges

Sludges (non-hazardous) Wastes from the manufacture and Adhesive and sealants wastes
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 115 of 136

application of printing inks

Sludges (non-hazardous) Wastes from pulp, paper and 

cardboard productions and 

processing

• Sludges from paper recycling

• Fiber, pulp, and paper sludges

Sludges (non-hazardous) Wastes from the manufacturing and 

application or printing inks.

Ink wastes

Sludges (non-hazardous) Wastes from anaerobic treatment of 

wastes

Anaerobic treatment sludges of 

municipal and similar wastes

Sludges (non-hazardous) Wastes from wastewater treatment 

plants

Grease and oil mixture from oil/waste 

water separation

Sludges (non-hazardous) Wastes from the manufacturing of 

fats, grease, soaps, detergents, 

disinfectants and cosmetics

Sludges

Sludges (non-hazardous) Wood preservation waste Waste organic wood preservatives

Sludges (non-hazardous) Waste from transport and storage 

tank cleaning

• Oil wastes from marine transport 

tank cleaning

• Oily wastes from railway and 

tanker tank transport tank 

cleaning

• Oily wastes from storage tank 

cleaning

Sludges (non-hazardous) Petroleum refinery waste Waste water treatment sludges

Sludges (non-hazardous) Food processing wastes Food processing waste sludges

Solids (non-hazardous) Non-metallic wastes from inorganic 

chemical processes

• Spent activated carbon (except 

from chlorine production)

• Carbon black

Solids (non-hazardous) Oil/water separator contents Oil/water separator solids

Solids (non-hazardous) Absorbents, filter materials, wiping 

cloths and protective clothing

Absorbents, filter materials, wiping 

cloths and protective clothing

Solids (non-hazardous) Wastes from wastewater treatment 

plants

Grease and oil mixture for oil/water 

separation

Solids (non-hazardous) Organic packaging wastes • Paper and cardboard

• Plastic 

• Wooden

• Composite packing

• Mixed

Solids (non-hazardous) Wastes from synthetic materials and 

rubbers manufacturing and 

processing

Waste plastics, rubbers, and other 

synthetic materials, including, but not 

limited to:

• Automobile and parts 

manufacturing

• Plastics manufacturing

• Tire and rubber manufacturing

Solids (non-hazardous) Wastes from textile industry Wastes from unprocessed textile 

fibers

Solids (non-hazardous) Agricultural wastes • Sugar beet waste

• Seed corn waste

• Animal and food rendering waste

• Other organic agriculture wastes

Solids (non-hazardous) Printer toner waste Waste printer toner

Solids (non-hazardous) Wastes from wood processing and 

the production of furniture products

• Waste bark and cork

• Sawdust

• Shavings, cuttings

Solids (non-hazardous) Wastes from pulp, paper and 

cardboard production and processing

Solids from pulp, paper and 

cardboard industry

Solids (non-hazardous) Waste from water and waste water Solids from water and wastewater 
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 116 of 136

treatment plants treatment plants

Solids (non-hazardous) Salvage and recycling industry Salvage material1

Solids (non-hazardous) Wastes from the manufacturing and 

production of construction materials

• Wood waste

• Salvage material1

Solids (non-hazardous) Petroleum refinery waste Waste solids including spent catalyst 

and caustics

Solids (non-hazardous) Iron, steel, and foundry wastes Waste solids

Solids (non-hazardous) Food processing wastes Food processing waste solids

1

”Salvage material” is defined as items reclaimed before or after mixing/grinding/disposal/storage where multiple 

components have been mixed together, and the products are easily separated into lesser components and the 

components were not exposed to asbestos, lead mercury or PCB containing materials. Specifically excluded from 

this definition are such materials as “auto fluff.” Included in the definition are items such as “oil filter fluff.”
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 117 of 136

The facility shall use the following approved test plans, procedures, specifications, and averaging times to measure the 

pollutant emissions for the applicable requirements referenced in Table F-1.8.

R 336.2004 Appendix A; reference test methods; adoption of federal reference test methods.

Rule 1004. (1) The following federal reference test methods, described in the provisions of 40 C.F.R. part 60, appendix 

A (2000), are the reference test methods for performance tests required pursuant to the provisions of this part:

(a) Method 1 – Sample and velocity traverse for stationary sources.

(b) Method 1A – Sample and velocity traverses for stationary sources with small stacks or ducts.

(c) Method 2 – Determination of stack gas velocity and volumetric flow rate (type-S pitot tube).

(d) Method 2A – Direct measurement of gas volume through pipes and small ducts.

(e) Method 2C – Determination of stack gas velocity and volumetric flow rate in small stacks and ducts (standard 

pitot tube).

(f) Method 2D – Measurement of gas volumetric flow rates in small pipes and ducts.

(g) Method 3 – Gas analysis for the determination of dry molecular weight.

(h) Method 4 – Determination of moisture content in stack gases.

(i) Method 6 – Determination of sulfur dioxide emissions from stationary sources.

(j) Method 7 – Determination of nitrogen oxide emissions from stationary sources.

(k) Method 8 – Determination of sulfuric acid mist and sulfur dioxide emissions from stationary sources.

(l) Method 9 – Visual determination of the opacity of emissions from stationary sources.

(m) Method 10 – Determination of carbon monoxide emissions from stationary sources.

(n) Method 10B – Determination of carbon monoxide emissions from stationary sources.

(o) Method 18 – Measurement of gaseous organic compound emissions by gas chromatography.

(p) Method 21 – Determination of volatile organic compound leaks.

(q) Method 23 – Determination of Polychlorinated Dibenzo-p-Dioxins and Polychlorinated Dibenzofurans from 

stationary sources.

(r) Method 24 – Determination of volatile matter content, water content, density, volume solids and weight solids of 

surface coatings.

(s) Method 24A – Determination of volatile matter content and density of printing inks and related coatings.

(t) Method 25 – Determination of total gaseous nonmethane organic emissions as carbon.

(u) Method 25A – Determination of total gaseous organic concentration using a flame ionization analyzer.

(v) Determinations of particulate emission rates for stationary sources shall be conducted as specified in 1 or more of 

the following reference test methods:

(a) Reference test method 5B which is described in R336.2011.

(b) Reference test method 5C, which is described in R336.2012.

(c) Reference test method 5D, which is described in R336.2013

(d) Reference test method 5E, which is described in R336.2014.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 118 of 136

This permit allows the use of only the following materials and fuels listed below:

Raw Materials

Limestone

Clay/Shale

Sand

Gypsum

Clinkers

Recycled kiln dust

Leached kiln dust

Alternate Raw Materials

Conditioned flyash

Bottom ash

Fuels

Natural Gas

Pulverized coal

Petroleum coke

Specification used oil

Tire-derived fuel (TDF)

Silica Gel

This condition does not preclude the use of alternative raw materials and fuels allowed by Rule 285 (b) and (c).
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 119 of 136

Appendix 6. Permits to Install/Operate

The following table lists the Permits to Install and/or Operate which relate to the identified Emission Units or Flexible 

Grouping: 

Permit to 

Install/Operate 

Number

Description of Equipment

Corresponding Emission 

Unit 

or

Flexible Grouping ID

60-71O Cement Kilns FG008

Primary crusher quarried limestone EG013

Transfer of limestone from secondary crusher building 

onto stock belt no. 3

EG014

60-71O Raw Materials Reclaim FG010

60-71O Raw Materials Conveyor (Belt No. 2) FG010

60-71O Raw Material Transfer (Belt No. 2 to No. 5) FG010

4-80, 519-86 Quarry drilling FG014

824-90 CKD Product Silo EG030

60-71N Natural Gas-Fired Solid Fuel Dryers (2) EGDRYERS

4-03 Cement Loading to Trucks FG003

721-93 Cement Bagging FG005

60-71J Slag Storage Silo EG001-9

224-73 Clinker Coolers FG007

352-73 Flyash Storage Silo FG002
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 120 of 136

Appendix 7. Emission Calculations 

In calculating the tons per year emission in Table F-1.3, II.B., the actual operating hours will be calculated using the 

following information:

- truck cycle time (minutes/truck)

- average cement truck load (tonnes/truck)

- calculate the cement truck loading timer per load (minutes/tonne)

- annual tonnes of cement loaded (tonnes/yr)

- calculate the actual cement loading time (minutes/yr or hours/yr)

- calculate the actual emissions based on particulate matter emission limit rate of either 0.32 lb/hr or 

 emission rate from source test data and the actual cement loading time (hours/yr)
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 121 of 136

Appendix 8. Reporting

A. Annual and Deviation Certification Reporting

The permittee shall use the DEQ Report Certification form (EQP 5736) and DEQ Deviation Report form (EQP 5737) for 

the annual and deviation certification reporting referenced in Section IV of the Requirement Tables. Alternative formats 

must meet the provisions of R 336.1213(4)I and R 336.1213(3)I(i), respectively, and be approved by the AQD District 

Supervisor. 

B. Other Reporting

The permittee shall use the following approved formats and procedures for the reporting requirements referenced in 

Table F-1.7. Alternative formats must be approved by the AQD District Supervisor. 

The following reporting requirement from Table F-1.7, IV.4. :

• In accordance with 40 CFR 60.7I and (d), Holcim shall submit a written EER and summary report in an acceptable 

format to the AQD Jackson District Supervisor within 30 days of the end of each calendar quarter. The EER shall 

include the magnitude, in actual percent opacity, of each six-minute average of opacity greater than the permit 

limit and the time period represented by such averages. The EER shall include the cause of the excess 

emission, if known, period of COMS downtime, any corrective actions taken, and total operating time of the 

source. If no exceedances of COMS downtime occurred during the time period, Holcim shall report that fact.

The following reporting requirement from Table F-1.7, IV.5. :

• Under 40 CFR 63, Subpart A, Section 63.10 (e)(3), EER could be submitted on an semiannual basis for a CMS. 

That presently is not applicable as Consent Judgment 60-1363-CZ, Part 4.3.B. requires a quarterly submittal. If at 

some point this Consent Order is voided and one full year (four (4) quarterly periods) of reports demonstrate 

continual compliance and continues to comply with recordkeeping requirements, the facility may request that the 

reporting frequency be on a semiannual basis

As soon as CMS data indicates that the source is not in compliance with opacity limitations, emissions limits for 

operating parameters specified in the permit, the frequency of reporting will revert back to a quarterly basis. The 

facility can petition the reporting frequency to be reduced after one full year of ongoing compliance.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 122 of 136

Attachment 1

FUGITIVE DUST PLAN

Section Equipment 

Item

Location Control Methods/Control 

Equipment

Operation

Stockpiles Limestone South end of plant under Belt 

Conveyor #3. 

Average 50,000 tons

Discharge onto pile is from a 

tube spout that has auto controls 

to raise/lower spout. Dust 

Suppression System

• Residual Foaming Dust 

Suppressant

• Applied after tertiary crusher

• Normal Operating Range

ÿ Water = 800 to 1100 gph

ÿ Chemical = 0.8 to 2 gph

Low fines content.

Stockpiles Bottom Ash South Quarry Stockpile Area. 

Average 10,000 tons

Delivery in covered trucks. High moisture.

Stockpiles Gypsum

(Natural and 

Synthetic)

West of Limestone Stockpile. 

Average 5,000 tons

Deliver in covered trucks. Gypsum 2X size. 

Very low fines content.

Stockpiles Clinker Main storage hall. 

Storage hall capacity 200,000 

tons.

Discharge into hall is through 

gravity controlled discharge 

doors. Transport conveyors at 

transfer points are dedusted with 

baghouse collection. Hall is 

partially enclosed.

Storage crane bucket 

operation is restricted to low 

level discharge.

Stockpiles 

(inactive)

Outside 

Clinker 

South of Clinker Storage Hall. Clinker forms hard covering 

which stabilize the pile.

Very low fines content.

Removal of clinker is 

performed in a manner that 

minimizes dust generation.

Stockpiles Conditioned 

Flyash

South Quarry Stockpile Area. Delivery in covered trucks and 

material has been wetted.

Minimize inventories.

Transport Gypsum From stockpile to feeder 4. Material is purchased as 2X 

size. 

Low fines content.

Transport Limestone Haulage from rockface to 

primary crusher.

Average (D50) size is 10”. 

Low fines content.

Transport Clay Haulage is from stripping to 

clay crusher.

Material typically contains 9 

to 13% moisture.

Transport Top Stripping Haulage to stripping dump . High moisture material.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 123 of 136

Section Equipment 

Item

Location Control Methods/Control 

Equipment

Operation

Conveying Belt 1 Quarry crusher to belt 2. Completely enclosed in an 

underground tunnel.

Conveying Belt 2 Belt 2 to secondary and 

tertiary crushing.

Crushing system dedusted by a 

baghouse collector.

Completely enclosed in a 

gallery structure. 

Conveying Belt 3 Tertiary crushing to stockpile. Tube Spout and Dust 

Suppression System.

Completely enclosed in a 

gallery structure. 

Conveying Belt 4 Reclaim conveyor from 

stockpile.

Transfer point dedusted by a 

baghouse collector.

Completely enclosed in a 

gallery structure.

Conveying Belt 5 Reclaim conveyor from 

secondary building to feed 

silos.

Initial transfer point dedusted by 

a baghouse collector.

Completely enclosed in a 

gallery structure. 

Conveying Belt 6 Short transfer in secondary 

crusher building to Road 

Stone Pile.

Transfer point dedusted by a 

baghouse collector.

Low fines content.

Conveying Belt 7 Short transfer in secondary 

crusher building to outside 

silo.

Transfer point dedusted by a 

baghouse collector.

Low fines content.

Road Quarry Roads Main Entrance road to quarry. 

Clay haul road. 

Stone haul road.

Gravel construction sealed with a 

road stabilization agent. 

Treatment with agent at least 

4 times per year.

Road Temporary 

Road

Road to overburdened dump . Graded regularly and usage of 

water to control fugitive dust.

Once per day and more 

during dry weather stripping 

operations.(1)

Road Landfill Road Landfill perimeter. Graded regularly and usage of 

water to control fugitive dust.

Treatment with agent at least 

4 times per year.

Road Main Plant 

Roads

Main Plant Concrete construction. 

Dry sweeper with Vacuum Filter 

for maintaining clean paved 

surfaces.

Swept every weekday. (1)

Road Main Plant 

Roads

Main Plant Truck Wash Facility Operated Apr.- Oct.

Road Secondary 

Roads

Clinker Storage Hall to water 

plant.

Contractor Road to Clinker 

Cooler Baghouse.

Gravel construction sealed with a 

road stabilization agent.

Treatment with agent at least 

4 times per year.

Road Parking lots Employee and Visitor Parking 

Lots.

Concrete construction. 

Dry sweeper with Vacuum Filter 

for maintaining clean paved 

surfaces.

Swept every 2 weeks. (1)

*Wet weather may negate these interval requirements.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 124 of 136

ATTACHMENT 2

MALFUNCTION ABATEMENT PLAN/PREVENTIVE MAINTENANCE PROGRAM

FOR THE KILN OPERATIONS

1.0 INTRODUCTION

1.1 PLAN REQUIREMENT

This Malfunction Abatement Plan/Preventive Maintenance Program (“Plan”) is developed pursuant to the Administrative Rules

of the Michigan Department of Natural Resources, Part 9, Rules 910, 911, and 912. The Plan describes the method by which 

anticipated malfunction situations at the Holcim Inc.’s Dundee Cement Plant (“Dundee”) located in Dundee, Michigan, will be 

managed by the owner, or operator, of the facility. This will constitute the standard operating procedures to be implemented at 

the Dundee facility for the kiln(s) processes and related controls, not including the scrubber oxidizer systems.

1.2 PLAN PURPOSE

The purpose of this Plan is to describe the standard operating procedures to be used to abate or minimize potential abnormal 

conditions that may occur at the facility resulting in an in-stack opacity that exceeds the opacity limitation of 15 percent using a 

6-minute average, from the kiln(s) stack. The Plan consists of two parts: 1) The preventive maintenance program, and 2) The 

malfunction abatement and equipment monitoring program. The on-duty shift supervisor is responsible for implementing the 

Plan.

The preventive maintenance program includes the following elements:

• Items or equipment that are to be inspected

• Frequency of inspection

• Method of inspection

• Personnel responsible for overseeing the inspection

• Scheduled maintenance and repairs of equipment

• Major replacement parts that are to be kept in inventory

The malfunction abatement and equipment monitoring program includes the following elements:

• Equipment operating variables that are to be monitored to detect any malfunction or failure

• Normal operating range of these variables

• Description of the method of monitoring

• Personnel responsible for monitoring

• Frequency of monitoring

• Description of the corrective procedures or operational changes aimed at abating a malfunction or equipment 

failure situation

2.0 FACILITY BACKGROUND

The Dundee Cement Plant began operation in 1959. The plant produces cement clinker in two rotary kilns using a wet process. 

The exhaust from each kiln is treated separately by an air pollution control device before it is released vertically upward into the 

atmosphere through a common single stack that is 350 feet tall and 15 feet in diameter.

The air pollution control system at the Dundee facility consists of a dry injection venturi scrubber followed by fabric filter 

collectors. Activated carbon is injected into the exhaust gas ahead of the fabric filters at a nominal rate of 295 lbs/hr, consistent 

with Table F-1.8, V, OPERATIONAL PARAMETERS, Article 9. This control system will maintain particulate emissions below 

the emission limitation of 0.10 lb/1000 lb stack gas corrected at 6% oxygen. The control device will also allow the company to 

meet a 6 minute opacity limitation of 15 percent opacity in the stack based on the continuous opacity monitoring system and 

consistent with the requirement in Table F-1.8, VI, OTHER REQUIREMENTS, Article 11.

3.0 PREVENTIVE MAINTENANCE PROGRAM
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 125 of 136

This program is designed to minimize equipment malfunctions by establishing an inspection schedule for all equipment and 

accessories associated with the air pollution control system. Table 1 lists the items to be inspected, the frequency of inspection, 

the person responsible for overseeing the inspection, and the replacement parts kept in inventory. This program will help 

identify ahead of time any malfunction that may arise, and by conducting an effective maintenance program, equipment 

malfunctions will be kept to a minimum. The method of inspection and maintenance procedures will be conducted per the 

vendor’s recommendations. During inspection, the following information will be recorded in a log sheet (see attached 

Inspection Log sheet) or equivalent:

• Items inspected

• Equipment identification number

• Date of inspection

• The condition of the equipment

• General comments pertaining to the necessity for repairs or adjustments

• The initials of the person conducting the inspection

4.0 MALFUNCTION ABATEMENT AND EQUIPMENT MONITORING PROGRAM

This program is intended to identify any abnormal conditions or equipment malfunctions. Table 2 lists the equipment that are 

anticipated to break down or cause an exceedance of the opacity limitation, the operating variables to be monitored, the normal 

operating range, the method of monitoring, the frequency of monitoring, the person monitoring the equipment, and the 

corrective procedures or operational changes that achieve compliance during a malfunction or failure of the equipment. This 

program helps detecting any malfunctions and initiates the required corrective actions to achieve compliance in a timely manner. 

During a malfunction event, the following information will be recorded in a log sheet (see attached Repair Log sheet) or 

equivalent:

• Equipment identification number

• The date the malfunction was detected

• A description of the malfunction

• The time the malfunction was detected

• The time the repair was completed

• A description of the required repair

• The initials of the person conducting the repair

Except during startup as defined in V Operational Parameters Article 7, Holcim shall undertake an investigation into the cause of 

any occurrence of opacity of three consecutive 6 minute averages in excess of 10% opacity based on the continuous opacity 

monitoring system. The results of this investigation shall be recorded in the operating log.

a) If the cause of excessive opacity is general bag failure requiring rebagging, Holcim shall either take the 

compartment off-line or rebag the faulty compartment in the dust collector within 180 days of the completion of the 

investigation.

b) If the cause of the excessive opacity is only isolated bag failure, Holcim shall take the compartment off-line until 

repairs are performed.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 126 of 136

ATTACHMENT 2

KILN PREVENTIVE MAINTENANCE PROGRAM

TABLE 1

ITEMS INSPECTED FREQUENCY RESPONSIBILITY REPLACEMENT PARTS KEPT 

IN INVENTORY

Baghouse Systems

(DV003-2 and 

DV003-7)

Housing and Duct Conditions Semi-Annual Maintenance Engineer

bags, kiln exhaust fan

Bag Condition and Tension Semi-Annual Maintenance Engineer motor, programmable

Collection Screws Semi-Annual Maintenance Engineer controller, Computer , air

Double Tipping Valves Semi Annual Maintenance Engineer compressor and motor,

Hopper Screws Semi-Annual Maintenance Engineer damper solenoids, dust pod

Bypass Dampers Semi-Annual Maintenance Engineer valves, differential pressure

Seal Air Fan Semi-Annual Maintenance Engineer cells, thermocouples,

Dust Pods Semi-Annual Maintenance Engineer hopper and collect screws,

Baghouse Cleaning System Semi-Annual Maintenance Engineer gear reducer and motor, bag

Reverse Air Dampers Semi-Annual Maintenance Engineer bands, tension springs, bag

Reverse Air Fans Semi-Annual Maintenance Engineer caps, filters, drive belts,

Shakers (Variable Speed Drives) Semi-Annual Electrical Engineer reverse air fan motor.

Sonic Horns Semi-Annual Electrical Engineer

Air Compressors LP Semi-Annual Maintenance Engineer

Kiln Exhaust Fan Semi-Annual Maintenance Engineer

Electric Motors Semi-Annual Electrical Engineer

Programmable Controller Semi-Annual Electrical Engineer

Alarms Semi-Annual Electrical Engineer
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 127 of 136

KILN PREVENTIVE MAINTENANCE PROGRAM

TABLE 1 (continued)

ITEMS INSPECTED FREQUENCY RESPONSIBILITY REPLACEMENT PARTS KEPT 

IN INVENTORY

Baghouse System (DV003-2 and 

DV003-7)

Instrumentation Semi-Annual Electrical Engineer see previous page

Computer Semi-Annual Electrical Engineer

Control Logic Semi-Annual Electrical Engineer

Air Valve Operators Semi Annual Maintenance Engineer

Air Dryer H.P. Monthly Electrical Engineer

Filter Regulator Lubricators Monthly Maintenance Engineer

Dry Venturi Scrubber Systems 

(DV003-5 and DV003-10)

Feed System Calibration Once/shift (minimum) Kiln Burner Operator weigh system load cell, weigh 

system control package, 

injection air blower motor, silo 

alleviator bags.

Scrubber System Once/shift (minimum) Kiln Burner Operator

Notes:

1. Inspection procedures will be based on vendor’s recommendations

2. Maintenance is performed as necessary when the inspection reveals problems

3. Equipment inspection and maintenance date, equipment name, equipment identification numb er, repairs resulting from inspection will be recorded in a log sheet (see attached 

log sheets).
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 128 of 136

SHIFT

 INSPECTION LOGSHEET

Items Inspected Equipment ID Inspection Date Condition Comment 

(see note 1)

Initials

Dry Venturi Feed System

Scrubber Systems 

(DV003-5 and

 DV003-10)

Scrubber System

Note:

1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 129 of 136

MONTHLY

 INSPECTION LOGSHEET

Items Inspected Equipment ID Inspection Date Condition Comment 

(see note 1)

Initials

Baghouse System (BH1 

and BH2)

Air Dryer H.P.

Filter Regulator 

Lubricators

Note:

1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 130 of 136

SEMI-ANNUAL

INSPECTION LOGSHEET FOR MISCELLANEOUS EQUIPMENT

Equipment Name Items Inspected Equipment I.D. Inspection Date Condition Comment

(see note 1)

Initials

Note:

1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 131 of 136

SEMI-ANNUAL

INSPECTION LOGSHEET

Items Inspected Equipment I.D. Inspection Date Condition Comment

(see note 1)

Initials

Baghouse System House and Duct Conditions

(BH1 and BH2) Bag Condition and Tension

Collection Screws

Double Tipping Valves

Hopper Screws

Bypass Dampers

Seal Air Fan

Dust Pods

Baghouse Cleaning System

Reverse Air Dampers

Reverse Air Fans

Shakers (Variable Speed 

Drives)

Sonic Horns

Air Compressors LP

Kiln Exhaust Fan

Electric Motors

Programmable Controller

Alarms

Instrumentation

Computer

Control Logic

Air Valve Operators

Note:

1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 132 of 136

REPAIR LOGSHEET

Equipment ID Date Malfunction 

Description

Time Malfunction 

Detected

Time Repair Completed Repair Description

(See Note 1)

Initials

Note:

1. If repair time exceeds two hours, see note 3 of the Abatement and Equipment Monitoring Program
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 133 of 136

ATTACHMENT 2

MALFUNCTION ABATEMENT AND EQUIPMENT MONITORING PROGRAM

TABLE 2

Equipment Operating Variables 

Monitored

Normal Operating 

Range

Method of Monitoring Frequency of 

Monitoring

Person Monitoring Corrective Procedure or 

Operational Change in the 

Event of a Malfunction or 

Failure to Achieve 

Compliance

Baghouse systems

(DV003-2 and

 DV003-7)

Inlet Gas temperature 280°F to 475°F Display Screen Frequently Kiln Burner Operator If the malfunction is in one or 

more compartments, those

compartments will be taken 

out of service until repairs are 

performed. 

If the malfunction which 

results in emissions that 

exceed the emission 

limitations for more than two 

hours, see Note 3.

Outlet Gas 

Temperatures

275°F to 320°F Display Screen Frequently Kiln Burner Operator

Inlet Pressure -6” W.G. to -8.5” W.G. Differential Pressure 

Trend Display

Continuous Kiln Burner Operator

Outlet Pressure -14” W.G. to -16.5” 

W.G.

% Oxygen 0.5 to 2.0% Strip Chart Recorder Continuous Kiln Burner Operator

In Stack Opacity 5 to 10% Strip Chart Recorder Continuous Kiln Burner Operator .

Dry Venturi Scrubbers

(DV003-5 and

DV003-10)

Inlet Gas Temperature 370 – 425°F Display Screen Frequently Kiln Burner Operator The injection feed system for 

each source has redundant 

sources of injection material 

(2 silos) and load cells for 

measuring each batch 

injection.

In the event of a problem 

with the feed system, the 

operator selects the alternate 

equipment, and repairs will be 

made as soon as feasible.

Redundancy is also built into 

the computer control of the 

system.

The number of batches per 

hour and batch weight 

setpoint are determined by 

material density and desired 

pounds-per-hour (PPH).

Outlet Gas Temperature 280 – 325° Display Screen Frequently Kiln Burner Operator

Tempering Air Damper 

Position

40 – 100% Display Screen Frequently Kiln Burner Operator
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 134 of 136

Batch Weight 10 – 20 pounds Display Screen Frequently Kiln Burner Operator

Batch Time Based on Batch Weight Display Screen Frequently Kiln Burner Operator

Dry Venturi Scrubbers

(DV003-5 and DV003)

Actual PPH Injection 300 pounds Display Screen Frequently Kiln Burner Operator see previous page

Total Pounds Injection Totalizer Display Screen Frequently Kiln Burner Operator
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 135 of 136

ATTACHMENT 2

MALFUNCTION ABATEMENT AND EQUIPMENT MONITORING PROGRAM

TABLE 2

Equipment Operating

Variables

Monitored

Normal Operating

Range

Method of

Monitoring

Frequency of

Monitoring

Person Monitoring Corrective Procedure or Operational Change in

the Event of a Malfunction or Failure to Achieve

Compliance

ALARMS

Batch Weight

UNDER

Setpoint

Display Screen

& Panalarm

Continuous Kiln Burner Operator see previous page

Batch Weight

OVER Setpoint

Display Screen 

& Panalarm

Continuous Kiln Burner Operator

Selected

Equipment OFF

Display Screen

& Panalarm

Continuous Kiln Burner Operator

Notes:

1. A repair log sheet will be maintained. The log sheet will include: Equipment ID, Date, Time Malfunction Detected, Time Repair Completed, Repair Procedures (see attached Repair Log

sheet) or equivalent.

2. The person monitoring the equipment will notify his or her supervisor promptly of any abnormal operating variables that cannot be corrected through normal adjustments and procedur es.

Pursuant to the Michigan Air Pollution Control Commission Rules, Part 9, Rule 912, emissions that exceed the applicable emission limitations due to abnormal conditions in, or breakdown of, 

process or control equipment which continue for more than two hours will be reported as soon as possible but not later than 9:00 a.m. of the next working day to the District Supervisor. Within ten 

days of this occurrence, a detailed report will be submitted to the District Supervisor. The report will include the probably causes, duration of violation, remedial action taken, and the steps that are 

being undertaken to prevent a reoccurrence. The preventive steps will become a part of the Malfunction Abatement Plan.
Permit Number: MI-ROP-B1743-2004

Expiration Date: April 27, 2009

Page 136 of 136

ATTACHMENT 3

Holcim (US), Inc., Dundee Plant

Cement Kiln Baghouse

Supplemental Preventive Maintenance Program

For the Abatement of Dust Accumulation

April 6, 1999

A. Slide Gates

By April 23, 1999 (when Kiln 2 is scheduled to come out of it major outage), slide gates will be 

installed on all four dust transport pod systems. This will enable the individual pods to be isolated 

for maintenance purposes.

B. Baghouse Inspections/Housekeeping

The baghouse will be inspected for dust accumulation once per shift. Any visible leaks will be 

corrected promptly. Clean up of accumulated dust will begin not later than the start of the next 

scheduled labor shift. In addition, the sweeper operator will inspect the baghouse and baghouse 

floor at least twice per week of operation and sweep the baghouse floor as necessary.

C. Baghouse/Cleaning Cycle

Continue to conduct regular cleaning of the baghouse compartments to maximize the 

performance of the baghouse. Any excessive dust will be cleaned as soon as practicable, not 

later than the start of the next labor shift.

D. Screw System Alarm

A hard wire alarm has been installed to notify kiln operators if the screw system has been disabled 

for a long duration.

E. Gathering Screw Conveyors

The following activities will be performed every 6 months for each gathering screw conveyor:

1) Open and inspect screw hangers, bearings, and shafts. Bar end bearings, inspect 

drive sheaves and belts.

2) Check screw housing thickness and insulation.

3) Replace screw seals.

4) When above work done, put screws into service.

Scheduling and recordkeeping of maintenance performed will be tracked using Holcim’s 

electronic maintenance system.