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

Hol cim (US), Inc.

SRN: B1743

LOCATED A

T

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 (A ir 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 con ditions 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 operat ing permit does not obviate the necessity of obtaining such permits or approvals from other units of gove rnment as required by law.

This permit does not relieve the permittee from any responsibilities or obligations imposed on the permittee, at this sourc e, under Consent Order No. 22

- 1999, entered on August 11, 1999, bet ween the MDEQ and the permittee and Conse nt Judgment 00

- 11363

- CZ

, entered on July 14, 2000.

The conditions contained in this Renewable Operating Permit for which a Consent Judgment or Cons ent 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 DivisionPermit Number: MI

- ROP

- B1743

- 2004 Expiration Date: April 27, 2009

Page 2 of 136 

## Table of Contents

A. GE NERAL 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 SUMMAR Y TABLE 13

D. FLEXIBLE GROUPIN GS SUMMARY TABLE 17

E. EMISSION UNIT/PR OCESS GROUP REQUIREM ENTS 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 GROUPIN G 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 46Permit 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 REQUIREME NTS 85

APPENDICES 87

Appendix 1. Abbreviations Used in This Permit 87

Appendix 2. Schedule of Compliance 89

Appendix 3. Monitoring Requirements 90

Appendix 4. Re cordkeeping 109

Appendix 5. Testing Procedures 110

Appendix 6. Permits to Install/Operate 119

Appendix 7. Emission Calculations 120

Appen dix 8. Reporting 121Permit 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 w hich a RO Permit has been issued. This permit

is issued to Hol cim (US) , Inc. Manufacturer of Portland C ement , hereinafter the permittee for this RO Permit. The department is defined in R 336.1104(d) as the Director of the Department of Environmental Qua lity 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 336.121 3(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

oth er 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 densit y greater than the most stringent of R 336.1301(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% op acity, 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 requi red 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 contamina nt 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) Unre asonable 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 Admi nistrator of the EPA and by citizens under the provisions of the CAA. Any terms and conditions based on applicablePermit 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 sha ll 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 modi fied, 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 336.121 5 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 w hether 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 an d 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 complian ce 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 exc lusive 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 depart ment 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 ef fective 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 depart ment 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 R eporting

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, loca

tion, 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 proce ss 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 furni shed 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 recordi ngs, 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 reason s 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, withi n 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 w hich states that, based on information and belief formed after reasonable inquiry, the statements and information contained inPermit 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 lis ting 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 certific ation 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 continui ng 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

discover y 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 w ithin 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 Certificati on

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 ar e 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 r easonable 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. Com pliance 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 th e 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 p ermit 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 res ults 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 a ction 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 336.121 7(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 t o 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, orPermit 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 ag ency 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 Cond itions 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 informa tion 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 wh ich 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 t he 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

- Wi de 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

Ge neral 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, operat ional 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,

a nd 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 Maxim um 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, erec t, 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/

Modificat ion 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 Lim e stone 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 p roduct) silo

11,780 ft3 01/01/1958

01/19/1992 DV030

- 2 baghouse

- pulse jet

5 ,0 00 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

cli nker & 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 R everse air

baghouse, 35 ,000 acfm SV028 F

- 1.1

E G 001

- 5 DV001

- 5

- 1 No. 2 Finish mill feed end

separator 10/15/1958

01/01/1967 DV001

- 5

- 3 Reverse ai r

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,

bagho use

3,000 acfm SV007 F

- 1.2

EG005

- 1 DV005

- 1

- 1 One customer cement silo

( N orth section) (Silo No. 20) 01/01/1958 DV005

- 1

- 2 Reverse air baghouse

3,500 acfm SV008 F

- 1.2Permit Number: MI

- ROP

- B1743

- 2004 Expiration Date: April 27, 2009

Page 14 of 136 Unit/Group ID Emission Unit/Process Group Description Installation/

Modificat ion 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 ai r 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 baghous e 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 a i r bagh ouse 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

EG0 06

- 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 01/0 1/1958

8/1/2000 DV009

- 2

- 2 p ulse 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 Bu ell 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 /0 5 /2003 DV011

- 1

- 2 cartridge filter pulse

jet air 1,800 acfm SV019 F

- 1.3

EG011

- 2 DV011

- 2

- 1 Bulk cement lo ading to trucks

NE scale #2 (Packhouse silos) 01/01/1958

05 /0 5 /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

0 5 /0 5 /2003 DV011

- 3

- 2 cartridge filte r pulse

jet 1,800 acfm SV021 F

- 1.3

EG011

- 4 DV011

- 4

- 1 Bulk cement loading to trucks

SE s c ale #4 (Packhouse silos) 01/01/1958

0 5/05 /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

- 1.4Permit Number: MI

- ROP

- B1743

- 2004 Expiration Date: April 27, 2009

Page 15 of 136 Unit/Group ID Emission Unit/Process Group Description Installation/

Modificat ion Date Control Device Description Stack/Vent ID Requirement

Table No.

10/01/1993 19,000 acfm

EG032 DV032

- 1 C ement bagging (3 units) 09/15/199 3 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 DV00 3

- 5 Dry sc rubber

(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 DV00 3

- 10 Dry scrubber

(carbon) DV 003

- 7 baghouse, 260,000 acfm, DV003

- 8 we t 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 rai l 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

s crubber

- packed tower, DV003

- 4(3) regenerative thermal SV001 F

- 1.11Permit Number: MI

- ROP

- B1743

- 2004 Expiration Date: April 27, 2009

Page 16 of 136 Unit/Group ID Emission Unit/Process Group Description Installation/

Modificat ion 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 3,0 00 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

- 1.15Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 17 of 136 

## D. Flexible Groupings Summary Table

Flexible Grouping

ID Emis

sion 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

EG0 06

- 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

EG036Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 18 of 136 EG037

EG038Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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, mon itoring, 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 r

equirements. 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, re cordkeeping, 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 Expir ation 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. CO MPLIANCE 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 rec orded once per day when filling. Recordings reflecting val u es outside of the range

set forth in V

- OPERATIONA L PARAMETERS w ill 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 Additio n to General Requirements in Part A

1. Parameter to be Tested/

Recorded Opacity (40 CFR 63, subpart LLL, S ection 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 mustPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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

annua lly. 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 co nduct 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 C FR 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 file s 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 mag netic 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 de viations 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 appropri ate 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 operatin g 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 LL L , Section 63.1350( a ))

2. The facility shall comply with all applicable requirements in Subpart LL L

– 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 Expir ation Date: April 27, 2009

Page 22 of 136 

### TABLE E

- 1. 2 EG013

EMISSION U NIT/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 Exha ust

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. COMPLIA

NCE 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 Cond itions 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

NAPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 23 of 136 

### TABLE E

- 1. 2 EG013

EMISSION U NIT/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 Expir ation 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 meth od 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 Ge neral 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 liq uid flow rate and liquid conc entration 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 Addi tion 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 Expir ation Date: April 27, 2009

Page 25 of 136 

### TABLE E

- 1. 3 EG014

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

V. OPERATIONAL PARAMETERS

NA



### VI. OTHER R EQUIREMENTS

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 Expir ation Date: April 27, 2009

Page 26 of 136 

### TABLE E

- 1. 4 EG023

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG023 20,000 gal lon (75.7 m 3 ) 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 (fee t) 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 m 3 with 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 Mo nitoring 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 60.11 6b (a)&(b))

B. TESTING/RECO RDKEEPING (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 deviat ions 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 t o 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 PAR AMETERS

NAPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 Expir ation Date: April 27, 2009

Page 28 of 136 

### TABLE E

- 1. 5 E G024

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG024 1,200 gallon Water Treatment Chemicals Tank
Flexible Grouping ID NA



### I. DESIGN PARA

METERS

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 m 3 (40 CFR 60, Subpart Kb, Section 60.110b(b))



### II. MATERIAL USAGE/EMISSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Max imum 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 an alysis 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

NAPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 29 of 136 

### TABLE E

- 1. 5 E G024

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

VI. OTHER REQUIREMENTS

NA
* This requirement is state enforceable only.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 30 of 136 

### TABLE E

- 1. 6 EG030

EMISSION UNIT/PRO CESS 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 upward s 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 LIMI TS

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 Requ irements 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 refle cting 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

Reco rdkeeping 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 s ix consecutive months (utilizing Method 22), testing may be decreased from mont hly 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 Expir ation Date: April 27, 2009

Page 31 of 136 

### TABLE E

- 1. 6 EG030

EMISSION UNIT/PRO CESS 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 t hat 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 fac ility must

con duct 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 f iles 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 occu rrence 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 63.1 55(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 ca lendar 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 (R3 36.1213(2 ))


### VI. OTHER REQUIREMENTS

1. The facility shall have in place a written operations and ma intenance plan. Included in th is plan shall be procedures for proper operation and maintenance of the source and air pollution cont rol 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 para graphs 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 Portlan d 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 Expir ation Date: April 27, 2009

Page 32 of 136 

### TABLE E

- 1. 7 EG031

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION GROUP EG031 Two Fuel Reclaim System s (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

Di mension (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/RECORDKEE PING (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 reco rded 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. Me thod/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 fac ility 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 (utilizin g 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 Expir ation 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 inspecti on 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 report ing 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 previou s 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 c ontrol devices in order to meet the e mission and operatin g 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 paragr aphs 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 Manuf acturing Industry. (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 34 of 136 

### TABLE E

- 1.8 E G03 5

EMISSION UNIT/PROCESS GROUP REQUIREMENTS

EMISSION UNIT EG035 Clinker Baghouse Dust Transfer

Fl exible 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 an d/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 (4 0 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 visiblePermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 35 of 136 

### TABLE E

- 1.8 E G03 5

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 co mputer, 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 Januar y 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

6 3.1350 (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 Expir ation Date: April 27, 2009

Page 36 of 136 

## F. Flexible Grouping Requirements

The tables in Part F outline t he 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 condit ions 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

Tab les 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 r

equirements 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 parent heses. 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 Expir ation Date: April 27, 2009

Page 37 of 136 

### TABLE F

- 1.1 FG001

FLEXIBLE GROUP ING 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

EG 001

- 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 opera tion

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 fee d 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 Exh aust

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 63.134 7 )



### III. COMPLIANCE EVALUATION

Records of all of the following shall b e 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

S ystem 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 Expir ation Date: April 27, 2009

Page 38 of 136 

### TABLE F

- 1.1 FG001

FLEXIBLE GROUP ING 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 o bservations of each finish mill

s weep and air separator PMCDs in accordance with Method 22. The Method 22 test shall be conducted while the affected source is operating at the hig hest load expected t hat day. The duration of the Method 22 test shall be si x 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 emissio ns 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 fi les 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 occur rence 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 rep orting 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 ce rtification 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 pla ce 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 proced ures 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 Expir ation Date: April 27, 2009

Page 39 of 136 

### TABLE F

- 1.1 FG001

FLEXIBLE GROUP ING REQUIREMENTS

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

* T his requirement is state enforceable only.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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)

EG00 5

- 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 Sil o 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 Filte r
DV00 6

- 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.

Stac k/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 16 0 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 NAPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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/EMI SSION LIMITS

A. Material Maximum Usage Rate

NA

B. Pollutant Maximum Emission Limit PM (Opacity) 10% Opacity (40 CFR63, Subpart LLL, Section 63.134 8 )



### III. COMPLIANCE EVALUATION

Records of all of the following shall be maintained on file f or 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 Recordkeepin g The pressure drop across the fabric filter s shall be monitored and included 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

th e 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 a re 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 ar e 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 s chedule 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 observ ed during any Method 22 test, t he facility must

co nduct a 6

- minute test of opacity i n 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 i n 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 Expir ation Date: April 27, 2009

Page 42 of 136 

### TABLE F

- 1.2 FG002

FLEXIBLE GROUPING REQUIREMENTS

IV. REPORTING

Reports and Schedules 1. P rompt 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

rep orting 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 orde r to meet the emission and oper atin g 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 Expir ation 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

loadi ng 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 Cartrid ge 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

63.134 8 )



### 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 acr oss the cartridge filter collectors shall be monitored and recorded once per day when filling. Recordings reflecting val u es 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 Expir ation 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 ca r tridge filte r 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 fo rth 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. (R336.12 01(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 b asis 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 observati on 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 micro film, 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 Perfor mance 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 1 0 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 Expir ation 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 18 0 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 Sched ules 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 f or 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 re sults 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 dev ices 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

63.13 50 (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 Manufactur ing 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 manufact urer 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 Expir ation Date: April 27, 2009

Page 46 of 136 

### TABLE F

- 1.4 FG004

FLEXIB LE 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 Para meters 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 LIMI TS

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 Expir ation Date: April 27, 2009

Page 47 of 136 

### TABLE F

- 1.4 FG004

FLEXIB LE GROUPING REQUIREMENTS

V. OPERATIONAL PARAMETERS

N A


### VI. OTHER REQUIREMENTS

Fugitive emission s control addressed in the “Fugitive Dust Plan” Attachment 1. (R336.1201(3))
* This requirement is state enforceable only.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 48 of 136 

### TABLE F

- 1.5 FG005

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GRO UPING 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 Paramet ers 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 1 40,000 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 Ad dition 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 fil ling bags. Recordings reflecting val u es 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 Meth od 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 LL L 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 tes ting on a monthly basis until no visible emissions are observed in six consecutive monthlyPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 fac ility 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 re adings. (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 b e 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. A nnual 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 fabri c 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 pr oduct 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 f orth 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 Manufacturi ng Industry. (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 DV0 11

- 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

SV0 41 52 20 NA NA NA

SV042 52 20 NA NA NA 

### C. Other Design Param eters

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 al l 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 b

ags. Recordings reflecting valu es outside of the range set forth in V

OPERATIONAL PARAMETERS will requir e 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. P arameter 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 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),

testi ng 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 Expir ation 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 tes t, 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. Th e 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

foll owing 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 Ma rch 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 pollut ion 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 Portla nd 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 Expir ation Date: April 27, 2009

Page 52 of 136 

### TABLE F

- 1.7 FG007

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG007 Clinker Coolers

Emissio n 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

- C Z , Part IV 4.1.C.)

DV002

- 3 Baghouse on No. 2 Clinker Cooler (Consent Judgment 00

- 1363

- C Z , 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. Polluta nt 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. 0 50 Kg per Mg of dry feed to the kiln (40 CFR 63, Subpa rt 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 EV

ALUATION
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) Syst em 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 Specificati on 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, Su bpart 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 NAPermit Number: MI

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Page 53 of 136 

### TABLE F

- 1.7 FG007

FLEXIBLE GROUPING REQUIREMENTS

3. Frequency and Schedule of Testing/Recordkeeping NA



### IV. REPORTING

Reports and S chedules 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. O PERATIONAL PARAMETERS

NA


### VI. OTHER REQUIREMENTS

1. The facility will have in place a Preventative Maintenance/Malfunction Abatement Program for the baghouse contro l
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 mal function and a program of corrective action for malfunct ion ing 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, Sub part 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

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- 2004 Expir ation Date: April 27, 2009

Page 54 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

FL EXIBLE 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 Bag house;

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

Rat e (acfm) Applicable

Requirement

1. SV001 350 180 R336.12 2 5
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)) & (R336.1 205(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 (AF M 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. Specif ication used oil generated on site and off site 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

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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. (RC RA 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 = 4 9 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 kil n. (R336.1201(1)(a)) & (R336.1205(1))

B. Pollutants Maximum Emission Limit

1. Particulate Matter 1. 0.3 0 lbs/ton of dry feed to the kiln , based on a 12

- month rolling time period as

determined at the end of each c alendar 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 k iln ( 40 CFR 63, Subpart LLL, Section 63.1343(b)(1))

2. PM (Opacity) Except as provided in V OPERATIONAL PARAMETER S, 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

emis sion 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 L LL, 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. SO 2 11,940 tpy based on a 12

- month rolling pe riod as determined at the end of each

calendar month for both kilns DV003

- 1 & DV003

- 6. (R336.1201(1)(a)) & (R336.1205(1))

4. NO

x 1. 3,377 tpy b a sed 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. Co mpliance 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 d etermined at the end of eachPermit Number: MI

- ROP

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### 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 dsc f )(TEQ) corrected to 7% O 2 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 perfor mance tests, utilizing EPA Method 23. ( S ee Appendix 5 )

(R336.1205(1), (40 CFR 63, S u bpart LLL, Section 63.1343(d) (1) )

2. 0.40 ng per dscm (1.7 x 10 - 10 gr per dscf) (TEQ) corrected to 7% O 2 for inlet temperatures to the baghouse of = 2 04°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 11 5 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

. C ompliance with the limit shall be demonstrated by the methodology contained in

Table F

- 1.8, V.18 O PERATIONAL 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 th e 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 p eriod for both kiln s . (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 m g/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack concentration) (R336.1225)

11. As 0.00 02 μ g /cubic meter, based on a 12

- month rolling time per iod 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 )

6 7 .2 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack

concentration. (R336.1225)

12. Ba 5 μ g/cubic meter, based on a 8

- hour averaging period

. (AFM Firing Mode) (expressed as a maximum ambient concentration) compliance with the l imit shall be demonstrated by the methodology contained in Table F

- 1.8, V.18

OPERATIONAL PARAMETERS. (R336.1225)

65.2 m g/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack

concentration. (R336.1225)

13. Be 0.0 2 μg/cubic meter, ba sed 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 m eter (AFM Firing Mode) (Limit is expressed as an in stack concentration). (R336.1225)

14. Cd 0.000 6 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 maximumPermit Number: MI

- ROP

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### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

amb ient 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 sta ck concentration). (R336.1225)

15. Cr 0.000083 μg/cubic meter, b ased 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 m g/cubic meter (AFM Fi ring Mode) (Limit is expressed as an in stack concentration). (R336.1225)

17. Mn 0.0 5 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 demonstrate

d by the methodology contained in Table F

- 1.8, V.18

OPERATIONAL PARAMETERS. (R336.1225)

1.4 m g/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 rolli ng time period as determined at the end of each calendar month. (AFM Fir i ng 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 m g/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) complian ce with the limit shall be demonstrated by the methodology contained in Table F

- 1.8, V.18

OPERATIONAL PARAMETERS. (R336.1225)

26.1 m g/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack concentration). (R336.1225)

20. Ag 0.1 μg/cu bic 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 m g/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 m aximum ambient concentration) compliance with the limit shall be demonstrated by thePermit Number: MI

- ROP

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- 2004 Expir ation Date: April 27, 2009

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### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

methodology contained in Table F

- 1.8, V.18 OPERATIONAL PARAMETERS. (R336.1225)

33.6 m g/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack

concentr ation)

. (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 m g/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack concentration)

. (R336.1225)

23. C 10 H 7 NH 2 436.8 μg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack concentration)

. (R336.1225)

24. C 6 H 3 ClNH 2 C 6 H 3 ClNH 2 6.7 m g/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack concentration)

. (R336.1225)

25. BrCH 2 CH 2 Br 16.8 m g/cubic meter (AFM Firing Mode) (Limi t is expressed as an in stack concentration)

. (R336.1225)

26. C 6 Cl 6 6.7 m g/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 ma intained 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 emission s from the cem ent 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 SO 2

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 procedur es 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 regu lations. (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 shal l be inPermit Number: MI

- ROP

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### 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 installatio n 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 NO

x an d SO 2 , 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 4 0 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 e

ach 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 occurrence s.
2. A report of all periods of CEMS downtime and corre ctive action.

3. A report of the total operating time of the cement kilns during the reporting period.

4. If no exceedances o r CEMS downtime occurred during the reporting period, the facility shall report that fact.

5. A report of any periods that t he 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 LIMITS

POLLUTANTS. The date collected from the T H C 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 recordsPermit Number: MI

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### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

including the measured TDF and coal/coke mixture hourly usage rate, the

calculated TDF an d 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 m onitor 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 fiv e years and made available to the AQD
upon request. (R336.1201(1)(a)) & (R336.1205(1))

3. Facility shall monitor and record the g a s 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 recorde r 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 metho d 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 calcula ting 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 o

f 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 ( C onvention al F iring M ode). 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 lea st 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))

- P eriods of time when one

- minute averages are not available shall be ignored when calculating three

- hour rolling averages

. W hen one

- minute averages become available, the first one

- minute average is adde d to the previous 179

values to calculate the three

- hour rolling average.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 61 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

(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 inject ion 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

- ho ur 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

averag es 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 sha ll 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 instrument at ion acceptable to the District Supervisor AQD.

The facility shall use all reasonable measures necessary to operate the continuous opacity monitoring s ystems 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 a verages 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 th e COM using the procedures put forth in U.S. EPA publication No.

A 50/4

- 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. F urther, 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 fi ve years.

a. Date and time

b. O perating mode of the kiln(s)

c. Heat input of all AFM used in the kilns and rel ative contri bution of each components heat input.

d. Amount of AFM combusted.

e. Kiln feed rate.

f. Visible emissions

g. Oxygen content at th e outlet of the kiln

h. Temperat ure at the inlet of the PMCD

i. SO 2 emission rate j. NO

x emission rate

k. VOC emission ratePermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 62 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

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 i n 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 con tent (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 ma de 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 Supervis or, 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 res ults 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, SO 2 , NO

x , 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 inclu des 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 fol lowing the last date of testing.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 63 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

(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 Fu els 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

Tes ted/ 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. T he purpose of the testing is to verify that the kiln is capable of achieving a destruction removal efficiency of 99.9 9 % 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

, verifi catio n of the destruction removal ef ficiency of either kiln shall have been

determined

. N o 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 fa cility 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 SO 2 , CO, & VOC (Consent Judgment No. 0 0

- 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 mentione d 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 Jun e 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. T he facility shall report the results of the QAP of the CEMS, within 30 days following the end of ea ch 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 com pletion of the audit. (40 CFR 60, Appendix F)

6. The facility shall submit the copies of an EER and Summary Report inPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 64 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

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 t emperature 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 devel oped 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 follo wing 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 t he kiln

- Used oil generated on site and offsite that meets specifications contained in App endix 5, including during startup.

- Natural gas

- Silica Gel

- Diesel Fuel (R336.1201(1)(a)) & (R336.1205(1))

2. “ AFM ” m ode is defined as th o se ti mes that a k iln 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

- U sed oil other than that under “Conventional Mode”above. (R336.1201(1)(a)) & (R336.1205(1))

3. The facilit y 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 highPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 65 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

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 k ilns 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 f abric 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, sha ll 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

t h e 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 no minal 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 roll ing 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 performa nce testing. (40 CFR 63, Subpart LLL, Sections 63.1344(c)(1) & 63.134 9 (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 63.13 4 4(c)(2))

1 2 . 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 Sup ervisor. 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 facili ty 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

m aterial. (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))

1 4 . The facility is allowed to burn AFM in the kilns when the following conditions are being met:

- The NO 2

, SO 2. CO, and THC CEM s are installed and are operating properly

.

- The COM is installed and is operating properly

.

- The excess O 2 monitor is installed and operating properly and O 2 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 c ombustion 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 Expir ation Date: April 27, 2009

Page 66 of 136 

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- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

- The device measuring exhaust gas temperature at the inlet to air pollution control device is installed and is opera ting properly. The temperature shall be measured on a 3

- hour rolling average updated every minute per 40 CFR 63, S ubpart LLL requirements.

- A negative pressure is established and maintained at the kiln inlet measured as a 60

- minute rolling average update d every minute. (R336.1201(1)(a)) & (R336.1205(1)) & (R336.1225)

1 5 . The facility shall automatically and immediately discontinue operating in the AFM mode per kiln under any one of the following conditions:

- Clinker p ro duction 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))

1 7 . 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) (R336.12 01(1)(a)) & (R336.1205(1))

1 8 . The facility shall not process any AFM in the kilns which h as 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. OT HER REQUIREMENTS

1. The facility shall develop a “ W ritten O perations and M aintenance P lan.” 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 pil es 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 emi ssions. (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 ( ab sorbent ma terials) 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 referenc ed 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 sha ll 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 disp ersion 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 ha ve sample(s) independently

tested. (R336.1201(1)(a)) & (R336.1205(1))

8. Upon issuance of the ROP

, the facility shall have submit ed to the District Supervisor a notification protocol for AFM which qualify for use under the “M aterials M a nagement P lan. ” The notification protocol shall have the written approvalPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 67 of 136 

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FLEXIBLE GROUPING REQUIREMENTS

of the District Supervisor. (R336.1201(1)(a)) & (R336.1205(1))

9. The facility shall notify the District Supervisor whenever there are unant icipated 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 t wo 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 emission s (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 mont hs 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 a ll 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 S tandards 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 s ource.

• 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 su ch 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 ar e 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)

SO 2 11,309.2 40 11,349.2

NO

x 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 l ess 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 t esting 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 concu rrent with the facility’s PC MACT kiln testing requirements.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 68 of 136 

### TABLE F

- 1.8 FG008

FLEXIBLE GROUPING REQUIREMENTS

(R336.1201(a)) & (R336.1205(1))

* This requirement is state enforceable only.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 69 of 136 

### TABLE F

- 1.9 FG009

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG009 Cement Loading to Ra ilcars 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 fil ter

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

Req uirement

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 R equirements 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 moni tored and recorded once per day if rail car silos are being filled

. Recordings reflecting valu es 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

Recordke eping 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 M ethod 22), testing may be decreased from monthly to semi

- annually. If visible emissions are observed during any semiannual test, the facility must

resume testin g 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 Expir ation 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 duri ng 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 o bserved 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 fi ve 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 Cond ition 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. Du e 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 th e 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 mai ntenance 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 pro cedures 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

Haza rdous 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 Expir ation 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 Param eters

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 valu es outside of the range set forth in V

- OPERATIONAL PARA METERS 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 Requirem ents 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 Schedu le 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 d ecreased from mont hly to semi annually. If visible

emissio ns are observed during any semi annual test, the facility must

resume testin g 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 (utilizingPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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

facil ity 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 o f 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 rep orting 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 c alendar 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 Expir ation 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.

Te mp. (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 p er 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 R ecordkeeping 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 NO 2 CEMS 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 Expir ation 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 a nd 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 fu el 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 contr

ol 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 Expir ation Date: April 27, 2009

Page 75 of 136 

### TABLE F

- 1. 12 FG012

FLEXIBLE GROUPING REQUIREMENTS

FLEXIBLE GROUPING FG012 Clin ker 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 Requi rements 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 val u es 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 M ethod 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 i n 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

obser ved in six consecutive monthly tests.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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. I f 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 CF R 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 file s 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 mag netic 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 dev iations 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 p roper 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 63.1 350 (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 Emissio n 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 Expir ation Date: April 27, 2009

Page 77 of 136 

### TABLE F

- 1.13 FGCOLDCLEANERS

FLEXIBLE GROUPING REQU IREMENTS

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) Applicabl e

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, perchloroet hylene, 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

a nd 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 c ontent) 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 ba sis. (R 336.1213(3))Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 78 of 136 

### TABLE F

- 1.13 FGCOLDCLEANERS

FLEXIBLE GROUPING REQU IREMENTS

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 app licable, 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. Frequenc y 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 p ursuant 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 complia nce 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 clean ers 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

- pl ant

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 int o 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 col d 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 l east 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 cover ed with water if the solvent is insoluble and has a specific gravity of more than 1.0.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 79 of 136 

### TABLE F

- 1.13 FGCOLDCLEANERS

FLEXIBLE GROUPING REQU IREMENTS

(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 compou nds, 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 monox ide, 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 ca

tegories, 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 Expir ation 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.

Em ission 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. Partic ulate 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 Requ irements 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 shal l be monitored and recorded in 4 hour intervals when drilling for later install ed 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 a nd 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
REQUIRE MENTS, the drilling process will cease operation until such time repairs/corrections have been made. A 6

- minute observation shallPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 336.1 213(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 pre ssure 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 Expir ation Date: April 27, 2009

Page 82 of 136 

### TABLE F

- 1.1 5 FG01 5

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 buck et & 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

h orizontally through natural draft storage h all 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 h all (SV048).

Stack/Vent ID a. Minimum Heig ht (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, Sec tion 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 Recordkeep ing 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 63.13 4 9(a))

2. Method/Analysis EPA Method 9 (as modified)

– T he performance test shall be conducted under representative performance conditions in accordance with 40 CFR 63,Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 83 of 136 

### TABLE F

- 1.1 5 FG01 5

FLEXIBLE GROUPING REQUIREMENTS

Subpart A, Section 60.7(c) per revised (12/2002) 40 CFR 63, S ubpart LLL, Section 63.1349(b)(2). The maximum six

- minute average opacity exhibit ed 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 approv al 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 faci lity 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 i n 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 mus t 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 inspectio n 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 Expir ation Date: April 27, 2009

Page 84 of 136 

### TABLE F

- 1.1 5 FG01 5

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) (4 0 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. S uch 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

Hazar dous 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 Expir ation 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 pu rsuant 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 NO

x control 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 6 0, Subpart OOO, Section 60.670(e ) Particulate emission and opacit y

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 f rom 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 60.6 7 0( e ) Particulate emission and opacity

limit standards for bucke t 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

bu cket elevator and conveyor

material transf

er 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 60.67 0 (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. Ex empt from this subpart as the operation is now applicable to 40 CFR 63, Subpart LLL, promulgated June 14, 1999 (reference Section

63.1 3 56 for exemption)

FG009 40 CFR 60, Subpart OOO, Section 60.670(e) Particulate emission and opacity

limit standards for e nclosed 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
syst em is now applicable to 40 CFR 63, Subpart LLL, promulgated June 14, 1999 (reference sectionPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 applica ble as construction,

reconstruction or modification was prior to August 31, 1983.

EG03 5 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 prov

isions in Subpart

F.

EG03 5 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 S ection 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

Sub part 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, Sect ion 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,

Secti on 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 syste ms. 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 f

or 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 a pplicable 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

recordk eeping. 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 Expir ation Date: April 27, 2009

Page 87 of 136 

## Appendices

Appendix 1. Abbreviations Used in This Permit

The following is an alph abetical 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

A s Arsenic

Ba Barium Baghouse Fabric Filter Collector

Be Beryllium

BrCH 2 CH 2 Br Ethylene Dibromide

BTU British Thermal Unit

CAA Federal Clean Air Act

C 6 Cl 6 Hexachlorobenzene

Cd Cadmium

CDDs Chlorinated Dibenzo

- p

- dioxins

CDFs Chlorinated Dibenzofurans

CEM Continuous Emission Monitor(ing)

CFR Code of Federal Regulations

C 6 H 3 ClNH 2 C 6 H 3 ClNH 2 3,3

- Dichlorobenzidine

C 10 H 7 NH 2 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 Michi gan 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 M egagram (1 million grams)

μ g Microgram (10 - 6 grams)Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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

NO 2 Nitrogen Dioxide

O 2 Oxygen

Pb Lead

PCB Pol ychlorinated 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 Resour ce Conservation and Recovery Act

RMP Risk Management Plan

RO Ren e wable Operating Plan

RTO Regenerative Thermal Oxydizer

Sb Antimony

Se Selenium

SRN State Registration Number

SV Stack/Vent ID

SO 2 Sulfur Dioxide

TEQ International method of expressin g 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

Tonn e Metric ton (2,20 5 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 thanPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 89 of 136 

### Appendix 2. Schedule of Compliance

The permittee has certified that this source is in complia nce 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 Expir ation 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.



# A LTERNATIVE 

# F UELS AND 

# M ATERIALS



# M ANAGEMENT 

# P ROCESSPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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

t o 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 An alysis, 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 m eet 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 as sure 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 Expir ation 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 a ssure 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 mu st 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 c hemical 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 cur rent 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 cons istency 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 un der 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 AF M at the Plant.

7) Perform applicable requirement review using the POMSPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 accepta nce 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 AF M 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 logistic s 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 Qualificat ion 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 qu ality 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 corres ponds 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

SUMMARYPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 94 of 136 The AFM Management Plan is a systematic approach that will r eview 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 Expir ation 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 Add ress:

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 Expir ation Date: April 27, 2009

Page 96 of 136 

## IV. Samp ling 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 mate rial 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 custo dy 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 70 o 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)? ( ) Stro ng ( ) 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 concentra tions expected.

Constituent Minimum MaximumPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 To xics):

Metal Constituent (mg/Kg) Minimum Maximum

Antimony (Sb)

Arsenic (As)Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 Expir ation 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)? ( ) Y es ( ) 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 co mpounds 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 resul ts). 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 con stituent.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 Ch lorobenzene 100.0 10.0

D022 Chloroform 6.0 0.6Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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

- Dic hloroethylene 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 0.02Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 s hipped 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 DescriptionPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 informatio n 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 c onstituents 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 pu rpose 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 Expir ation Date: April 27, 2009

Page 104 of 136 Holcim’s Acceptance is based on the information provided by your company on thi s 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, a gents 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 a rising 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 fro m 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 soug ht 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 clai m, 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 Expir ation Date: April 27, 2009

Page 105 of 136 

## 1 AFM Management ProgramPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 106 of 136Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 107 of 136 

## 2 Potential AFM Qualification AnalysisPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 108 of 136Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 109 of 136 

### Appendix 4. Recordkeeping

Specific recordkeeping requiremen t 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 Expir ation 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 Tes t 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 Secti on 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 pe rpendicular to the plume direction and approximately 4 feet directly above the surface of the road or parking area from which the emission are being genera ted. The observer shall not loo k continuously at the plume, but instead shall observe the plume mome ntarily 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” s hall 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 plu me 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 repres ent 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 f rom 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 per pendicular 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 s ource, the observer should normally concentrate on the area or areas of the plume close to the source.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 peri od.

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 = 1 00 ° F

Total Halogens = 1,000 ppm

PCB’s = 49 ppm

*These values are maximums, except for flash point which is a minim um. 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 Expir ation Date: April 27, 2009

Page 112 of 136 Definition of Hazardous Waste

A chem ical 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 co ntaining 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 o r 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 sufficien t 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 rea ction 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 Expir ation 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 (V I), L e ad, 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

- Dinit rotoluene

Endrin Heptachlor

Hexachlorobenzene

Hexachloro

- 1,3

- butadiene

Hexachloroethane

Lindane Methoxychlor Methyl ethyl ketone

Nitrobenzene Pentachlorphenol Pyridine Tetrachloroethylene Toxaphene Trichloroethylene Toxaphene Trichloroethylene
2,4,5

- Trichl orophenol
2,4,6

- Trichlorophenol Vinyl chloride
2,4

- D
2,4,5

- TP SilvexPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 hy draulic 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 liqui ds

• 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 nav igation Liquid (non

- hazardous) Waste from organic dyes and pigments • Aqueous wa shing liquids and mother liquids.

• Aqueous liquids containing

adhesive and sealants Liquid (non

- hazardous) Wastes from the manufacturing of plastics, synthetic rubber and man

ma de fibers Aqueous washing liquids and mother liqu ids.

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, di sinfectants

and cosmetics. Aqueous washing liquids and mother liqu ids.

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, et c.

• 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

opera tions Paint and coating sludges

Sludges (non

- hazardous) Wastes from the manufacture and Adhesive and sealants wastesPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 sim ilar 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 Sludg es

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 t ank cleaning

• Oily wastes from storage tank cleaning Sludges (non

- hazardous) Petroleum refinery waste Waste water treatment sludges Sludges (non

- hazardous) Food processing wastes Foo d processing waste sludges Solids (non

- hazardous) Non

- metallic wastes fr om 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 pr otective 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 rend ering 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 wastewaterPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 116 of 136 treatment plants treatment plants

Sol ids (non

- hazardous) Salvage and recycling industry Salvage material 1
Solids (non

- hazardous) Wastes from the manufacturing and production of construction materials • Wood waste

• Salvage material 1
Solids (non

- hazardous) Petroleum refinery waste Waste solids i ncluding 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 mixin g/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 f rom 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 Expir ation 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 em issions 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 4 0 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 tr averse for stationary sources. (b) Method 1A

–

Sample and velocity traverses for stati onary 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 veloci ty 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 m oisture 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 em issions 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 fr om 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 Dib enzofurans 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 re lated 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 station ary 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 Expir ation 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 Expir ation 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 F G00 8 Primary crusher quarried limestone EG013 Transfer of limestone from secondary crusher building

onto stock belt no. 3 EG014

60

- 71O Raw Material s 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 Ce ment 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 FG002Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 c ement 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 ceme nt loading time (hours/yr)Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 re porting 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 60.7 I 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, o f 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 operati ng 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 submit ted 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 dem onstrate 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 limitatio ns, 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 Expir ation 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.

Av erage 50,000 tons Discharge onto pile is from a

t ube spout that has auto controls

to r aise/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.

Av era ge 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 restric ted to low level discharge.

Stockpiles (inactive) Outside

C linker S outh of Clinker S torage H all

. Clinker forms hard covering which stabilize the pile

. Very low fines content.

Removal of clinker is performed in a manner that minimizes dust generation.

St ockpiles Conditioned

Flyash South Quarry Stockpile Area. Delivery in covered trucks and

material has been w etted

. Minimize inventories.

Transport Gypsum From stockpile to feeder 4

. Material is purchased as 2X

size.

Low fines content.
Transport Limes tone 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 Expir ation 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 Recla im 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

. Comp letely 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

R oad 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

R oads Main Plant Concrete construction. Dry sweeper with Vacuum Filter for maintaining clean paved

surfaces

. Swept every weekday . (1)

Road Ma in 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 lea st 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 week s. (1)

* Wet weather may negate these interval requirements.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 124 of 136 A TTAC HMENT 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 b y 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 purp ose 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

- minu te 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 prev entive 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 r eplacement 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 ran ge 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 FACILI TY 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 verticall y 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. Activate d 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 require ment in Table F

- 1.8, VI, OTHER REQUIREMENTS , Article 11.

3.0 PREVENTIVE MAINTENANCE PROGRAMPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 pollutio n 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 info rmation 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 adjust ments

• 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 tim

e 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 occurren ce 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 fa ilure 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, H olcim shall take the compartment off

- line until repairs are performed.Permit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 System s ( DV003

- 2 and

DV003

- 7 ) H ousing 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 Ti

pping 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 Main tenance 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 ba nds, 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 Compress ors 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 EngineerPermit Number: MI

- ROP

- B1743

- 2004 Expir ation Date: April 27, 2009

Page 127 of 136 KILN PR EVENTIVE 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

- An nual 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 Scrub ber System s (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 Expir ation 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 Syst

em s (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 Expir ation Date: April 27, 2009

Page 129 of 136 MONTHLY

INSPECTION LOGSHEET
Items Inspected Equipment ID Inspection Date Conditio n 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 Expir ation Date: April 27, 2009

Page 130 of 136 SEMI

- ANNUAL

IN SPECTION 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 Expir ation 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 Valv e 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 Expir ation Date: April 27, 2009

Page 132 of 136 REPAIR LOGSHEET
Equipment ID Date Malfunction Description Time Malfunction

Detected Time Repair Completed Repair Descrip tion
(See Note 1) Initials

Note:

1. If repair time exceeds two hours, see not e 3 of the Abatement and Equipment Monitoring ProgramPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 Monitorin g Corrective Procedure or Operational Change in the Event of a Malfunction or Failure to Achieve Compliance Baghouse system s (DV003

- 2 and
DV003

- 7) Inlet Gas temperature 280 ° F to 475 ° F Display Screen Frequently Kiln Burner Operator If the malfunction is i n 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 R ecorder Continuous Kiln Burner Operator In Stack Opacity 5 to 10% Strip Chart Recorder Continuous Kiln Burner Operator

. Dry Venturi Scrubber s (DV 003

- 5 and
DV003

- 10) Inlet Gas Temperature 370

– 425 ° F Display Screen Frequently Kiln Burner Operator The i njection 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 ° D isplay Screen Frequently Kiln Burner Operator Tempering Air Damper
Position 40

– 100% Display Screen Frequently Kiln Burner OperatorPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 Displa y Screen Frequently Kiln Burner Operator Dry Venturi Scrubber s (DV 003

- 5 and DV

003 ) Actual PPH Injection 300 pounds Display Screen Frequently Kiln Burner Operator see previous page

Total Pounds Injection Totalizer Display Screen Frequently Kiln Burner O peratorPermit Number: MI

- ROP

- B1743

- 2004 Expir ation 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 Chan ge 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 K iln 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 Com pleted, 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 pr obably 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 Expir ation Date: April 27, 2009

Page 136 of 136 ATTACHMENT 

### 3

Holcim (US), Inc.

, Dundee Plant

Cem ent 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 prompt ly. 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 ga thering screw conveyor:

1) Open and inspect screw hangers, bearings, and shafts. Bar end bearings, inspect

drive sheaves and b elts. 2) Check screw housing thickness and insulation. 3) Replace screw seals. 4) When above work done, put screws into service.

Schedulin g and recordkeeping of maintenance performed will be tracked using Hol cim ’s electronic maintenance system.