State of Montana Depart ment of Environm en tal Quality Helena, Montana 59620

AIR QUALITY OPERATING PERMIT NUMBER OP2005-03

Renewal Application Recei ved: April 23 , 200 3 Application Deemed Ad ministratively Co m p lete: May 2 3 , 2 003 Application Deemed Tech nically Com p lete: May 23, 200 3
AFS Nu m b er: 030- 043-0 0 01A

Draft Issue D a te: October 6, 20 04 Proposed Issue Date: June 23, 20 05
End of EPA 45-da y Review: August 12, 200 5
Date of Decision: August 26, 2 005
Effective Dat e : September 27, 2005 Expiration D a te: Septem ber 27, 201 0

In accordance with the Montana Code Annotated sections 75-2- 217 and 218, and the Adm i nistr a tive Rules of Montana (ARM) Title 17, Cha p ter 8, Subchapter 12, Operating Perm it Program , ARM
17.8. 120 1, et seq

.,

Ash Grove Cem e nt Com p any Montana Cit y Plant Sections 12 and 13, Township 9 North, Range 3 West 100 MT Hig h way 51 8

Clancy, MT 596 34

hereinafter, r e ferred to as “Ash Grove”, is authorized to operate a stationary sour ce of air contam inants consisting of the em ission units described in this pe rmit. Until this per m it expires or is m odifi ed or revoked, Ash Grove is allowed to discharge air po llut a nts in accordance with the conditions of this

per m it. All c onditions in this pe rm it are federally and state enforce a ble unless otherwise spe c i f ied. Requirem e nts that are state onl y enf o rceable are identif ied as such in the perm it. A copy of th i s perm it

m u st be kept on site at the above named facility

.

Issued by the Depart ment of Environm en tal Quality

Signature Date

Permit Issua n ce and Appeal Process : In accordance with ARM 17.8.1210(j), t h e Depart ment of
Environm ental Quality’s ( D epart m ent) decision regardi ng issuanc e of an operating perm it is not effective
until 30 da y s have elapsed from the date of the deci sion issued August 26, 2005. The decision may be appealed to the Board of E nvironm ental Review by fi l i ng a request for a hearing within 30 da ys after the
date of decision. If no appealed is filed then th e Depart m e nt will send notification and a final perm it cover page to be attached to this docum ent stating that the perm it is fi nal. Questions regardin g the final
issuance date and status of appeals should be directed to the Department at (406) 444-3 490

.

OP2005- 03 i Date o f Decisio n : 0 8 / 2 6 / 0 5

E ffective Date: 09/27/ 05OP2005-03 ii Date of Decision: 08/26/05
Effective Date: 09/27/05 Montana Air Quality Operating Permit Department of Environmental Quality

SECTION I. GENERAL INFORMATION..........................................................................................1

SECTION II. SUMMARY OF EMISSION UNITS ..........................................................................2

SECTION III. PERMIT CONDITIONS .............................................................................................3

A. F ACILITY -W IDE ....................................................................................................................3
B. EU001 – A IR S EPARATOR (AS)...........................................................................................6
C. EU002 – C LINKER C OOLER (CLC)......................................................................................7
D. EU003 – C ONVEY /P RIMARY C RUSHING (CPC) ..................................................................9
E. EU004 – F UEL C ONVEYORS (FC)......................................................................................11
F. EU004 – F UEL T RANSFER (FT) ..........................................................................................12
G. EU004 – C EMENT K ILN (KILN)........................................................................................13
C EMENT K ILN (KILN) A LTERNATIVE O PERATING S CENARIO .......................17
H. EU004 – P RODUCT S EPARATOR AND C EMENT C OOLERS (PSC).......................................20
I. EU004 – R OAD D UST (RD) ...............................................................................................21
J. EU004 – S TORAGE L OADOUT – B (SLB)..........................................................................22
K. EU004 – S TONE T RANSFER (ST).......................................................................................23
L. EU004 – T RANSFER B ELT C ONVEYORS (TBC).................................................................24
M. EU004 – T RANSFER /C ONVEY TO B ALL M ILL (TBM)........................................................25
N. EU004 – T RANSFER TO / FROM F INISH M ILL (TFM) ...........................................................26
O. EU004 – T RANSFER TO L IMESTONE S ILOS (TLS)..............................................................27
P. EU004 – W IND E ROSION (WE) .........................................................................................28

SECTION IV. NON-APPLICABLE REQUIREMENTS ................................................................30

A. F ACILITY -W IDE ..................................................................................................................30

B. E MISSION U NITS .................................................................................................................31

SECTION V. GENERAL PERMIT CONDITIONS.......................................................................32

A. C OMPLIANCE R EQUIREMENTS ............................................................................................32
B. C ERTIFICATION R EQUIREMENTS ........................................................................................32
C. P ERMIT S HIELD ...................................................................................................................33

D. M ONITORING , R ECORDKEEPING

, AND R EPORTING R EQUIREMENTS ..................................34

E. P ROMPT D EVIATION R EPORTING ........................................................................................35

F. E MERGENCY P ROVISIONS ...................................................................................................35
G. I NSPECTION AND E NTRY .....................................................................................................36

H. F EE P AYMENT .....................................................................................................................36

I. M INOR P ERMIT M ODIFICATIONS ........................................................................................36
J. C HANGES N OT R EQUIRING P ERMIT R EVISION ...................................................................37
K. S IGNIFICANT P ERMIT M ODIFICATIONS ...............................................................................38

L. R EOPENING FOR C AUSE ......................................................................................................38

M. P ERMIT E XPIRATION AND R ENEWAL ..................................................................................38
N. S EVERABILITY C LAUSE ......................................................................................................39
O. T RANSFER OR A SSIGNMENT OF O WNERSHIP ......................................................................39

P. E MISSIONS T RADING , M ARKETABLE P ERMITS , E CONOMIC I NCENTIVES ..........................39 Q. N O P ROPERTY R IGHTS C ONVEYED .....................................................................................39

R. T ESTING R EQUIREMENTS ....................................................................................................40
S. S OURCE T ESTING P ROTOCOL .............................................................................................40

T. M ALFUNCTIONS ..................................................................................................................40
U. C IRCUMVENTION ................................................................................................................40OP2005-03 iii Date of Decision: 08/26/05
Effective Date: 09/27/05 V. M OTOR V EHICLES ..............................................................................................................40
W. A NNUAL E MISSIONS I NVENTORY .......................................................................................40
X. O PEN B URNING ...................................................................................................................40

Y. M ONTANA A IR Q UALITY P ERMITS .....................................................................................40

Z. N ATIONAL E MISSION S TANDARD FOR A SBESTOS ..............................................................41
AA. A SBESTOS ...........................................................................................................................41
BB. S TRATOSPHERIC O ZONE P ROTECTION – S ERVICING OF M OTOR V EHICLE A IR C ONDITIONERS

............................................................................................................................. .........41
CC. S TRATOSPHERIC O ZONE P ROTECTION – R ECYCLING AND E MISSION R EDUCTIONS ..........42

DD. E MERGENCY E PISODE P LAN ...............................................................................................42

EE. D EFINITIONS .......................................................................................................................42

APPENDIX A INSIGNIFICANT EMI SSION UNITS...................................................................A-1

APPENDIX B DEFINITIONS AND ABBREVIATIONS.............................................................. B-1

APPENDIX C NOTIFICATION ADDRESSES .............................................................................C-1

APPENDIX D AIR QUALITY INSPECTOR INFORMATION ..................................................D-1

APPENDIX E POLLUTION CONTROL DEVICE INSPECTION AND MAINTENANCE
PLAN .......................................................................................................................... .......... E-1

APPENDIX F CAM PLAN – KILN STACK ELECTROSTATIC PRECIPITATOR............... F-1

APPENDIX G CAM PLAN – FINISH MILL HOUSE BAGHOUSE...........................................G-1

APPENDIX H CAM PLAN – CLINKER COOLER STACK BAGHOUSE ...............................H-1OP2005-03 1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Terms not otherwise defined in this permit or in the Definitions and Abbrev iations Appendix of this permit have the meaning assigned to them in the referenced regulations.

SECTION I. GENERAL INFORMATION

The following general information is provided pursuant to ARM 17.8.1210(1).

Company Name: Ash Grove Cement Company

Mailing Address: 100 Montana Highway 518

City: Clancy State: Montana Zip: 59634

Plant Location: Approximately 1.8 km east of the I-15 and Highway 518 interchange near Montana City and approximately 5 km south of East Helena.

Responsible Official: Richard Johnson Phone: (406) 442-8855

Facility Contact Person: Joseph Scheeler Phone: (406) 442-8855

Primary SIC Code: 3241 (plant), 1422 (quarry)

Nature of Business: Portland Cement Manufacturing

Description of Process:

The production of Portland cement begins at the qua rry. For Ash Grove, approximately 85 to 99 percent of the raw material used in the cement process are combined high and low-grade limestone quarried from Clark’s Gulch quarry. Limestone rock and other ra w materials are blasted and loaded onto trucks and transported to the crusher or to stockpiles. The raw materials are conveyed from the primary and secondary crushers and delivered by bucket elevator to the storage bins. From the storage bins, the raw materials are conveyed to the ball mill where the ore is ground with water to form a slurry and sent to storage tanks. In the tanks, the slurry is blended thor oughly before entering the kiln. Slurry is pumped to the uphill end of the kiln and heated, evaporating wa ter from the slurry forming clinker. The Ash Grove plant uses a combination of natural gas, coal and/or coke, heavy oils and pitch as fuel sources for the clinker production. When the clinker leaves the k iln, it is cooled, transported by drag chains, pan conveyor and bucket elevator to the clinker bins or ou tside storage. From there, clinker and gypsum go to the finish ball mill, where it is ground together with gypsum to produce Portland cement. The final cement product is conveyed to storage silos where it is loaded into railroad cars, bulk trucks, or bagged
and loaded onto trucks.OP2005-03 2 Date of Decision: 08/26/05
Effective Date: 09/27/05 SECTION II. SUMMARY OF EMISSION UNITS

The emission units regulated by this permit are the following (ARM 17.8.1211):

Emissions Unit

ID Description Pollution Control
Device/Practice

AS Air Separator Baghouse (DA-21)

CLC Clinker Cooler Baghouse (DA-23)

CPC Convey/Primary Crusher Baghouse (DA-1)

FC Fuel Conveyors None/ Conveyor and Transfer Point Covers, and Structural
Enclosures

FT Fuel Transfer None/Structural Enclosures

KILN Cement Kiln Electrostatic Precipitator

PSC Product Separator and Cement Coolers Baghouse (DA-9 East)

RD Road Dust None/Reasonable Precautions

SLB Storage Loadout - B Baghouse (DA-15)

ST Stone Transfer None

TBC Transfer Belt Conveyors Baghouse (DA-4)

TBM Transfer/Convey to Ball Mill Baghouse (DA-6)

TFM Transfer to/from Finish Mill Baghouse (DA-9 West)

TLS Transfer to Limestone Silos Baghouse (DA-5)

WE Wind Erosion NoneOP2005-03 3 Date of Decision: 08/26/05
Effective Date: 09/27/05 SECTION III. PERMIT CONDITIONS

The following requirements and conditions are applicab le to the facility or to specific emission units located at the facility (ARM 17.8.1211, 1212, and 1213).

A. Facility-Wide

Conditions Rule Citation Rule De scription Pollutant/Parameter Limit

A.1 ARM 17.8.105 Testing Requiremen ts Testing Requirements
------- A.2 ARM 17.8.304(1) Visible Air Contaminants Opacity 40%

A.3 ARM 17.8.304(2) Visible Air Contaminants Opacity 20%

A.4 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20%

A.5 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions
------- A.6 ARM 17.8.308 Particulate Matte r, Airborne Reasonable Precaution,
Construction 20%

A.7 ARM 17.8.309 Particulate Matter, Fuel Burning Equipment Particulate Matter E= 0.882 * H -0.1664 Or
E= 1.026 * H -0.233

A.8 ARM 17.8.310 Particulate Matter, Industrial

Processes Particulate Matter E= 4.10 * P 0.67 or E= 55 * P 0.11 - 40

A.9 ARM 17.8.322(4) Sulfur Oxide Emissions,
Sulfur in Fuel Sulfur in Fuel (liquid or solid fuels) 1 lb/MMBtu fired

A.10 ARM 17.8.322(5) Sulfur Oxide Emissions,
Sulfur in Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF

A.11 ARM 17.8.324(3) Hydrocarbon Emissions,
Petroleum Products Gasoline Storage Tanks
-------

A.12 ARM 17.8.324 Hydrocarbon Emissions,
Petroleum Products 65,000 Gallon Capacity
-------

A.13 ARM 17.8.324 Hydrocarbon Emissions,
Petroleum Products Oil-effluent Water Separator -------

A.14 ARM 17.8.342 NESHAPs General
Provisions SSM Plans Submittal

A.15 ARM 17.8.1212 Reporting Requirements Compliance Monitoring
------- A.16 ARM 17.8.1207 Reporting Requirem ents Annual Certification
-------

Conditions7

A.1. Pursuant to ARM 17.8.105, any person or pe rsons responsible for the emission of any air contaminant into the outdoor atmosphere shall, upon written request of the Department, provide the facilities and necessary equipment (including instruments and sensing devices) and shall conduct test, emission or ambient, for such pe riods of time as may be necessary using methods approved by the Department.

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 17.8.105. In addition, for such sources, complia nce with limits and conditions listing “as required by the Department” as the frequency, is verified annually using emission factors and engineering calculations by the Department’s compliance in spectors during the annual emission inventory review; in the case of Method 9 tests, compliance is monitored during the annual inspection by the compliance inspector.

A.2. Pursuant to ARM 17.8.304(1), Ash Grove shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source inst alled on or before November 23, 1968, that exhibit an opacity of 40% or greater averaged over six consecutive minutes, unless otherwise specified by rule or in this permit.OP2005-03 4 Date of Decision: 08/26/05
Effective Date: 09/27/05 A.3. Pursuant to ARM 17.8.304(2), Ash Grove shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged over six consecutive minutes, unless otherwise specified by rule or in this permit.

A.4. Pursuant to ARM 17.8.308(1), Ash Grove shall not cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over six consecutive minutes, unless otherwise specified by rule or in this permit.

A.5. Pursuant to ARM 17.8.308(2), Ash Grove shall not cause or authorize the use of any street, road or parking lot without taking reasonable precautions to control emissions of airborne particulate matter, unless otherwise specified by rule or in this permit.

A.6. Pursuant to ARM 17.8.308, Ash Grove shall not operate a construction site or demolition project unless reasonable precautions are taken to control emi ssions of airborne particulate matter. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over six consecutive minutes , unless otherwise specified by rule or in this permit.

A.7. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, Ash Grove shall not cause or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphe re in excess of the maximum allowable emissions of particulate matter for existing fuel burni ng equipment and new fuel burning equipment calculated using the following equations:

For existing fuel burning equipment (ins talled before November 23, 1968):
E =0.882 * H -0.1664

For new fuel burning equipment (insta lled on or after November 23, 1968):
E =1.026 * H -0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum allowable particulate emissions rate in pounds per MMBtu.

A.8. Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, Ash Grove shall not cause or authorize particulate matter to be discharged from any operation, process, or activity into the outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate matter calculated using the following equations:

For process weight rates up to 30 tons per hour: E = 4.10 * P 0.67 For process weight rates in excess of 30 tons per hour: E = 55.0 * P 0.11 – 40

Where E = rate of emissions in pounds per hour and p = process weight rate in tons per hour.

A.9. Pursuant to ARM 17.8.322(4), Ash Grove shall not burn liquid or solid fuels containing sulfur in excess of 1 pound per million BTU fired, unless otherwise specified by rule or in this permit.

A.10. Pursuant to ARM 17.8.322(5), Ash Grove shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions, unless otherwi se specified by rule or in this permit.OP2005-03 5 Date of Decision: 08/26/05
Effective Date: 09/27/05 A.11. Pursuant to ARM 17.8.324(3), Ash Grove shall not load or permit the loading of gasoline into any stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except through a permanent submerged fill pipe, unless such tank is equipped with a vapor loss control device or is a pressure tank as described in AR M 17.8.324(1), unless otherwise specified by rule or in this permit.

A.12. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, Ash Grove shall not place, store or hold in any stationary tank, reservoir or other containe r of more than 65,000 gallon capacity any crude oil, gasoline or petrol eum distillate having a vapor pressure of 2.5 pounds per square inch absolute or greater under actual storage conditions, unless such tank, reservoir or other container is a pressure tank maintaining working pressure sufficient at all times to prevent hydrocarbon vapor or gas loss to the at mosphere, or is designed and equipped with a vapor loss control device, properly installed, in good working order and in operation.

A.13. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, Ash Grove shall not use any compartment of any single or multiple-compartment oil-effluent water separator, which compartment receives effluent water containi ng 200 gallons a day or more of any petroleum product from any equipment processing, refining, treating, storing or handling kerosene or other petroleum product of equal or greater volatility than kerosene, unless such compartment is equipped with a vapor loss control device, cons tructed so as to prevent emission of hydrocarbon vapors to the atmosphere, properly installed, in good working order and in operation.

A.14. Pursuant to ARM 17.8.342 and 40 CFR 63.6, Ash Grove shall submit to the Department a copy of any startup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6(e)(3) within 30 days of the effective date of th is operating permit (if not previously submitted), within 30 days of the compliance date of any new National Em ission Standard for Hazardous Air Pollutants (NESHAPs) or Maximum Achievable Control Tech nology (MACT) standard, and within 30 days of the revision of any such SSM plan, when a pplicable. The Department requests submittal of such plans in electronic form, when possible.

A.15. On or before February 15 and August 15 of each year, Ash Grove shall submit to the Department the compliance monitoring reports required by Section V.D. These reports must contain all information required by Section V.D, as well as the information required by each individual emissions unit. For the reports due by February 15 of each year, Ash Grove may submit a single report, provided that it contains all the inform ation required by Section V.B & V.D. Per ARM 17.8.1207,

any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including semiannual monitoring reports), shall contain certification by a responsible official of truth, a ccuracy and completeness. This certification and any other certificati on required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inqui ry, the statements and information in the document are true, accurate and complete.”

A.16. By February 15 of each year, Ash Grove shall submit to the Department the compliance certification required by Section V.B. The annual certification required by Section V.B must include a statement of compliance based on the information available that identifies any observed, documented or otherwise known instance of noncomp liance for each applicable requirement. Per ARM 17.8.1207,

any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including annual certifications), shall c ontain certification by a responsible official ofOP2005-03 6 Date of Decision: 08/26/05
Effective Date: 09/27/05 truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.”

B. EU001 – Air Separator (AS)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
B.1, B.4, B.7,

B.9., B.10.,
B.11 Opacity 10% Method 9 As Required by the Department
and Section

III.A.1 Semi-Annual

B.2, B.5, B.7,

B.9., B.10.,
B.11 Particulate Matter 0.01 gr/dscf Method 5 Once during 5- year permit

term Semi-Annual

B.3, B.6, B.8,

B.9B.10.,

B.11 Emission Control Equipment Operation and
maintenance of
emission control equipment Operation and
maintenance of baghouse Whenever

process equipment is

operating Semi-Annual

Conditions

B.1. Ash Grove shall not cause or authorize emissions to be discharged into the outdoor atmosphere from the air separator baghouse that exhibit an opacity of 10% or greater averaged over six consecutive minutes (ARM 17.8.304).

B.2. Particulate emissions from the air separator baghouse shall not exceed 0.01 gr/dscf (ARM 17.8.752).

B.3. Ash Grove shall operate and maintain the baghouse when process equipment is operating (ARM 17.8.749).

Compliance Demonstration

B.4. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 test, to demonstrate compliance with the 20% opacity lim it in Section III.B.1. The test methods and procedures shall be conducted in accordance w ith the Montana Source Test Protocol and Procedures manual (ARM 17.8.106 and ARM 17.8.1213).

B.5. A Method 5 or other Department approved test shall be performed once during the 5-year permit period, to monitor compliance with the particulate emission limit in Section III.B.2. The test shall
be conducted in accordance with the Montana Source Test Protocol and Procedures Manual and maintained on site (ARM 17.8.106 and ARM 17.8.1213).

B.6. Ash Grove shall operate, inspect, and mainta in the baghouse in accordance with Appendix E to monitor compliance with Section III.B.3 (ARM 17.8.1213).

Recordkeeping

B.7. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).OP2005-03 7 Date of Decision: 08/26/05
Effective Date: 09/27/05 B.8. Ash Grove shall maintain, on site, records of all inspection and maintenance activities performed on the baghouse in accordance w ith the requirements in Appendix E. All inspection and maintenance records must be available to the Depa rtment for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

Reporting

B.9. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106).

B.10. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

B.11. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed;

b. Certification that the baghouse was operated and maintained as required by Section III.B.6;
and

c. Certification that the documents required in Section III.B.7 and Section III.B.8 were
maintained.

C. EU002 – Clinker Cooler (CLC)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
C.1, C.5., C.9., C.12.,
C.13 Opacity 40% Method 9 As Required by the Department
and Section

III.A.1 Semiannual

Operation and
maintenance of baghouse Whenever

process equipment is

operating Semiannual C.2, C.3., C.6., C.7., C.9., C.10., C.12., C.13 Particulate Matter E=55.0P 0.11 - 40

Method 5 Once during 5- year permit

term As required by
the Protocol

C.4., C.8., C.11., C.12.,
C.13 PM CAM Plan ARM 17.8.1506 Provisions
from CAM Plan, Appendix H Ongoing Semiannual

Conditions

C.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from the clinker cooler baghouse that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304(1)).

C.2. Pursuant to ARM 17.8.310, the particulate em issions from process weight shall not exceed the value calculated by E=55.0P 0.11 - 40, where E = rate of emission in pounds per hour and P = process weight rate in tons per hour (ARM 17.8.310).OP2005-03 8 Date of Decision: 08/26/05
Effective Date: 09/27/05 C.3. Ash Grove shall operate and maintain the baghouse when process equipment is operating (ARM 17.8.749).

C.4. Ash Grove shall provide a reasonable assurance of compliance with emission limitations or standards for the anticipated range of operations at the Clinker Cooler for PM (ARM 17.8.1504).

Compliance Demonstration

C.5. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 test, to demonstrate compliance with the 40% opacity lim it in Section III.C.1. The test methods and procedures shall be conducted in accordance w ith the Montana Source Test Protocol and
Procedures manual and maintained on site (ARM 17.8.106 and ARM 17.8.1213).

C.6. A Method 5 or other Department approved test shall be performed once during the 5-year permit period, to monitor compliance with the particulate emission limit in Section III.C.2. The test shall
be conducted in accordance with the Montana Source Test Protocol and Procedures Manual and maintained on site (ARM 17.8.106 and ARM 17.8.1213).

C.7. Ash Grove shall operate, inspect, and mainta in the baghouse in accordance with Appendix E to monitor compliance with Section III.C.3 (ARM 17.8.1213).

C.8. Ash Grove shall monitor compliance by following the Compliance Assurance Monitoring (CAM) Plan (Appendix H). The CAM Plan, written by As h Grove in accordance with ARM 17.8.1504 is summarized in Appendix H and is available in full upon request by the Department or the facility (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

C.9. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

C.10. Ash Grove shall maintain, on site, records of all inspection and maintenance activities performed on the baghouse in accordance w ith the requirements in Appendix E. All inspection and maintenance records must be available to the Depa rtment for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

C.11. Ash Grove shall prepare and keep data in accordance with 40 CFR Part 64 and the CAM Plan, Appendix H of this permit (ARM 17.8.1212 and 40 CFR 64).

Reporting

C.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

C.13. The semiannual reporting shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed;

b. Certification that the baghouse was operated and maintained as required by Section III.C.3;

c. Certification that the documents require d in Section III.C.10 were maintained; and

d. Certification of compliance with 40 CFR Part 64.OP2005-03 9 Date of Decision: 08/26/05
Effective Date: 09/27/05 D. EU003 – Convey/Primary Crushing (CPC)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
D.1., D.5., D.9., D.12.,
D.13 Opacity 7% Method 9 Once during 5-year permit term As required by the
Protocol

D.2.,D.6., D.9., D.12.,
D.13 Particulate Matter 0.02 gr/dscf Method 5 Once during 5-year permit term As required by the
Protocol

D.3.,D.7., D.10., D.12.,
D.13 Emissions Control Equipment Operation and
maintenance
of emission

control equipment Operation and
maintenance of baghouse Semiannual Semiannual

D.4.,D.8., D.11., D.12.,
D.13 Crusher Production 300 tons/hour Recordkeeping Daily Semiannual

Conditions

D.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any transfer point or belt conveyor or from any other affected facility any stack emissions that exhibit great than 7 percent opacity (40 CFR 60.672(a)(2)).

D.2. Particulate emissions from the dust collection system shall not exceed 0.02 gr/dscf (ARM 17.8.752).

D.3. Ash Grove shall operate and maintain emissi on control equipment when process equipment is operating (ARM 17.8.749).

D.4. Crusher production from the primary crusher sh all be limited to 300 tons/hour (ARM 17.8.749).

Compliance Demonstration

D.5. A Method 9 test shall be performed once during the 5-year permit period to monitor compliance with the 7% opacity limit in Section III.D.1. The test methods and procedures shall be conducted
in accordance with the Montan a Source Test Protocol and Pr ocedures Manual (ARM 17.8.106 and ARM 17.8.1213).

D.6. A Method 5 or other Department approved test shall be performed once during the 5-year permit period to monitor compliance with the particulate emission limitation in Section III.D.2. The test methods and procedures shall be conducted in accordance with 40 CFR 60.675(b) and the
Montana Source Test Protocol and Procedur es Manual (ARM 17.8.106 and ARM 17.8.1213).

D.7. Ash Grove shall inspect and maintain the ba ghouse in accordance with Appendix E of this permit to monitor compliance with Section III.D.3 (ARM 17.8.1213).

D.8. Ash Grove shall record the amount of material crushed (tons/day) and the hours of operation of the primary crusher (hours/day) in a log to monitor compliance with the crusher production limit in Section III.D.4 (ARM 17.8.1213).OP2005-03 10 Date of Decision: 08/26/05
Effective Date: 09/27/05 Recordkeeping

D.9. All source testing recordkeeping shall be perfo rmed in accordance with the Source Test Protocol
and Procedures Manual and maintained on site (ARM 17.8.106 and ARM 17.8.1212).

D.10. Ash Grove shall maintain records of all in spection and maintenance activities performed on the baghouse in accordance with the requirements in Appendix E of this permit. All inspection and maintenance records must be available to the Depa rtment for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

D.11. Ash Grove shall maintain a log on site to record the requirements in Section III.D.8. The log must be available to the Department for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

Reporting

D.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

D.13. The semiannual reporting shall provide (ARM 17.8.1212):

a. Annual submittal of the amount of material crushed in the primary crusher (tons/yr);

b. Annual hours of operation of th e primary crusher (hours/yr);

c. Certification that the records required by Section III.D.10 were maintained;

d. A summary of any source testing conducted during the period; and

e. A summary of the log required in Section III.D.11.OP2005-03 11 Date of Decision: 08/26/05
Effective Date: 09/27/05 E. EU004 – Fuel Conveyors (FC)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements

Method 9 As required by the Department and
Section III.A.1 Semiannual E.1., E.3., E.4., E.5., E.6., E.7 Opacity 20%

Use and
maintenance of
structural
enclosures and

covers Whenever process equipment is operating Semiannual

E.2., E.4., E.5., E.6., E.7 Particulate Matter E=55.0p 0.11 -40 Use and
maintenance of
structural
enclosures and

covers Whenever process equipment is operating Semiannual

Conditions

E.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed after November 23, 1968 that exhibit an opacity of 20% or greater averaged over six consecutive minutes (ARM 17.8.304).

E.2. Pursuant to ARM 17. 8.310, the particulate emissions from process weight shall not exceed the value calculated by E=55.0p 0.11 -40, where E = rate of emission in pounds per hour and p = process weight rate in tons per hour (ARM 17.8.310).

Compliance Demonstration

E.3. As required by the Department, and Section III. A.1, Ash Grove shall perform a Method 9 opacity test in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

E.4. Whenever process equipment is operating, As h Grove shall use and maintain, as they were intended, all conveyor covers, transfer point c over, or structural enclosures surrounding process equipment to monitor compliance with Section III.E.1 and III.E.2 (ARM 17.8.1213).

Recordkeeping

E.5. Ash Grove shall maintain on site a log of a ll repair and maintenance activity to structural enclosures. The log must include, but is not limite d to, the date, time, and action(s) taken. The maintenance log shall be maintained as a perm anent business record for at least five years following the activity. The log shall be available to the Department for inspection and must be submitted to the Department upon reque st (ARM 17.8.106 and ARM 17.8.1212).

Reporting

E.6. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

E.7. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed; and

b. Certification that the log was maintained as required in Section III.E.5.OP2005-03 12 Date of Decision: 08/26/05
Effective Date: 09/27/05 F. EU004 – Fuel Transfer (FT)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
F.1., F.3., F.5., F.6., F.7 Opacity 20% Method 9 Semiannual Semiannual

F.2., F.4., F.5., F.6., F.7 Particulate Matter E=55.0p 0.11 -40 Use and
maintenance
of structural
enclosure Whenever

process equipment is operating Semiannual

Conditions

F.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged over six consecutive minutes (ARM 17.8.304(2)).

F.2. Pursuant to ARM 17. 8.310, the particulate emissions from process weight shall not exceed the value calculated by E = 55.0p 0.11 -40, where E = rate of emission in pounds per hour and p = process weight rate in tons per hour (ARM 17.8.310).

Compliance Demonstration

F.3. A Method 9 test shall be performed semiannua lly to monitor compliance with the 20% opacity
limit in Section III.F.1 in accordance with the Montana Source Test Protocol and Procedures Manual. A Method 9 test only needs to be conducted on uncovered/uncontrolled process equipment and/or transfer points (ARM 17.8.106 and ARM 17.8.1213).

F.4. During truck or rail car unloading, Ash Grove shall use and maintain the structural enclosure surrounding the hopper, dual flow feeder, and a portion of a conveyor belt CB-22 for monitoring pertaining to the particulate matter limit in Section III.F.2 (ARM 17.8.309).

Recordkeeping

F.5. Ash Grove shall maintain on site a log of a ll repair and maintenance activity to structural enclosures. The log must include, but is not limite d to, the date, time, and action(s) taken. The maintenance log shall be maintained as a perm anent business record for at least five years following the activity. The log shall be available to the Department for inspection and must be submitted to the Department upon reque st (ARM 17.8.106 and ARM 17.8.1212).

Reporting

F.6. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

F.7. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed; and

b. Certification that the structural enclosure surrounding the hopper, dual flow feeder, and part of conveyor belt CB-22 was used and maintained during operation of process equipment.OP2005-03 13 Date of Decision: 08/26/05
Effective Date: 09/27/05 G. EU004 – Cement Kiln (KILN)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements Operation and
maintenance of
ESP Whenever

process equipment is operating Semiannual G.1., G.8., G.9., G.10., G.17., G.89., G.22., G.25.,
G.26 Opacity 40%

Method 9 Annually As required by
Protocol Operation and
maintenance of
ESP Whenever

process equipment is operating Semiannual G.2., G.8., G.10., G.17., G.18., G.23., G.25., G.26 Particulate Matter 40%

Method 5 Annually As required by
Protocol G.3., G.12., G.18., G.22., G.25., G.26 Sulfur Oxide As allowed in
ARM 17.8.322 Method 6 Every 5 years As required by
the Protocol

G.4., G.13., G.19., G.25.,
G.26 Operational Limit 250 tons/year Recordkeeping When using glass Semiannual

Method 23 Every 30
Months Semiannual G.5., G.8., G.10., G.14., G.23., G.25.,
G.26 D/F 0.20 ng per dscm Corrected to 7% Oxygen Inspection of
Combustion Components Annual Annual

G.6., G.15., G.20., G.23., G.25., G.26 Operational Limit Inlet
temperature to PMCD Continuous
Monitor Ongoing Semiannual

G.7., G.16., G.21., G.25.,
G.26 PM CAM Plan ARM 17.8.1506 Provisions from CAM Plan, Appendix F Ongoing Semiannual

Conditions

G.1. Ash Grove may not cause or authorize to be di scharged into the atmosphere from the cement kiln any stack emissions that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304 and ARM 17.8.752).

G.2. Ash Grove shall not cause or authorize to be di scharged into the atmosphere from the cement kiln any stack emissions which contain particulate matter in excess of the amount allowed by the following equations (ARM 17.8.310 and ARM 17.8.752):

a. If the process weight rate of the kiln is less than or equal to 30 tons per hour, then the emission limit shall be calculated using E=4.10p 0.67 where E = rate of emission in pounds per hour and p = process weight rate in tons per hour.

b. If the process weight rate of the kiln is greater than 30 tons per hour, then the emission limit shall be calculated using E = 55.0p 0.11 , where E = rate of emission in pounds per hour and P = process we ight rate in tons per hour.

G.3. Ash Grove shall apply a sulfur dioxide control process (the kiln) to remove the sulfur dioxide from the gases emitted by burning of fuel of any sulfur content which results in an emission of sulfur in pounds per hour not in excess of the pounds per hour of sulfur th at would have been emitted by burning fuel of the sulfur content indicated without such a cleaning device (ARM 17.8.322).OP2005-03 14 Date of Decision: 08/26/05
Effective Date: 09/27/05 G.4. The amount of post-consumer recycled glass u sed by Ash Grove in the cement kiln shall be limited to 250 tons during any ro lling 12-month period (ARM 17.8.752).

G.5. Ash Grove shall not cause to be discharged in to the atmosphere from the kiln any gases that contain dioxins and furans (D/F) in excess of:

a. 0.20 ng per dscm (8.7x10 -11 gr per dscf) (TEQ) corrected to 7% oxygen; or

b. 0.40 ng per dscm (1.7x10 -10 gr per dscf) (TEQ) corrected to 7% oxygen, when the average of the performance test run average temperatures at the in let to the particulate matter control device is 204° C (400° F) or less (40 CFR 63.1343).

G.6. Ash Grove shall operate the kiln such that th e temperature of the gas at the inlet to the kiln particulate matter control device (PMCD) does not exceed the applicable temperature limit specified in 40 CFR 63.1344(b) (NESHAP, 40 CFR 63, Subpart LLL).

G.7. Ash Grove shall provide a reasonable assura nce of compliance with emission limitations or standards for the anticipated range of operations at the Cement Kiln for PM (ARM 17.8.1504).

Compliance Demonstration

G.8. Ash Grove shall inspect and maintain the El ectrostatic Precipitator (ESP) in accordance with Appendix E of this permit to monitor compliance with the opacity limit in Section III.G.1 and Section III.G.2 (ARM 17.8.749).

G.9. Ash Grove shall perform a Method 9 test at l east once per calendar year. The test methods shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

G.10. Ash Grove shall perform a Method 5 test at l east once per calendar year. The test methods shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

G.11. Ash Grove shall conduct a Method 6 or other test approved by the Department at least once every five years. The tests shall be conducted in accord ance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

G.12. Ash Grove shall maintain a log of the amount of recycled glass used in the kiln each month. By
the 25 th day of each month, Ash Grove shall total the amount of recycled glass used in the kiln during the previous 12 months to monitor complia nce with the limitation in Section III.B.4 (ARM 17.8.749 and ARM 17.8.1213).

G.13. Ash Grove shall monitor compliance with the D/F emission limit by conducting a performance test using Method 23 of Appendix A of 40 CFR 60. The performance test shall be conducted every 30 months. Ash Grove shall repeat the pe rformance test for the kiln within 90 days of initiating any significant change in the feed or fuel from that used in the previous performance test (40 CFR 63.1349 and ARM 17.8.1213).

G.14. Ash Grove shall install, calibrate, maintain and continuously operate a continuous monitor to record the temperature of the exhaust gases from the kiln for monitoring of D/F emissions. The calibration of all thermocouples and other temperat ure sensors shall be completed at least once every 3 months (40 CFR 63.1350 and ARM 17.8.1213).

G.15. Ash Grove shall conduct an inspection of the co mponents of the combustion system of the kiln at least once per year (40 CFR 63.1350 and ARM 17.8.1213).OP2005-03 15 Date of Decision: 08/26/05
Effective Date: 09/27/05 G.16. Ash Grove shall monitor compliance by following the Compliance Assurance Monitoring (CAM) Plan (Appendix F). The CAM Plan, written by As h Grove in accordance with ARM 17.8.1504 is summarized in Appendix F and is available in full upon request by the Department or the facility (ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

G.17. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the ESP in accordance with the requirements in A ppendix E of this permit. All inspection and
maintenance records must be available to the Department upon request (ARM 17.8.1212).

G.18. All test records must be maintained on site and submitted to the Department in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

G.19. Ash Grove shall maintain on site, records as required by Section III.G.12 and submit the information to the Department upon request (ARM 17.8.1212).

G.20. Ash Grove shall maintain on site, records of calibration as required by Section III.G.14 (ARM 17.8.1212).

G.21. Ash Grove shall be prepared and data kept in accordance with 40 CFR Part 64 and the CAM Plan, Appendix F of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

G.22. Ash Grove shall submit Method 9, Method 5, Met hod 6 or other Department approved test reports
in accordance with the Montan a Source Test Protocol and Pr ocedures Manual (ARM 17.8.106 and ARM 17.8.1212).

G.23. Ash Grove shall submit a summary report semia nnually, which contains the information specified in 40 CFR 63.10(e)(3)(vi). In addition, the su mmary report shall include the following (ARM 17.8.1212):

a. All exceedances of maximum control device inlet gas temperature limits;

b. All failures to calibrate thermoc ouples and other temperature sensors;

c. The results of any combustion system component inspections conducted within the reporting period; and

d. All failures to comply with any provis ion of the Operation and Maintenance Plan (40 CFR 63.1354).

G.24. If an action taken by Ash Grove during a startup, shutdown, or malfunction is not consistent with the procedures specified in the affected source’ s startup, shutdown, and malfunction plan, Ash Grove shall record the actions taken and shall repor t such actions within 2 working days followed by a letter within 7 working days after the event (40 CFR 63.6(e)(3)).

G.25. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

G.26. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed;OP2005-03 16 Date of Decision: 08/26/05
Effective Date: 09/27/05 b. Certification that the ESP was inspected and maintained as required by Section III.G.7 and Section III.G.9;

c. Certification that the tests required in Sections III.G.8, G.10, and G.11 were conducted;

d. Certification that the logs required in Section III.G.12 and G.16 were maintained;

e. Annual certification that the written report required in Section III.B.12 was submitted; and

f. Certification of compliance with 40 CFR Part 64 (CAM), Appendix F.OP2005-03 17 Date of Decision: 08/26/05
Effective Date: 09/27/05 Cement Kiln (KILN) Alternative Operating Scenario

The use of post-consumer recycled container glass as a ra w material substitute in the cement kiln shall be considered an alternative operating scenario pursuan t to ARM 17.8.1215. When the revisions to ARM 17.8.316 adopted by the Board of Environmental Re view (Board) and effective on July 8, 1997, are incorporated into the State Implementation Plan (SIP ), the applicability of the version of ARM 17.8.316 currently in the SIP will no longer be federally en forceable and this alternative operating scenario will no longer be applicable.

Condition(s) Pollutant/

Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements Operation and
maintenance of
ESP Whenever

process equipment is operating Semiannual G.27., G.34., G.35., G.41., G.42., G.44.,
G.45 Opacity 10%

Method 9 As required by the Department
and Section
III.A.1 As required by
Protocol

Operation and
maintenance of
ESP Whenever

process equipment is operating Semiannual G.28., G.36., G.37., G.41., G.43., G.44.,
G.45 Particulate

Matter 0.10 gr/dscf of dry flue gas, adjusted to 12% CO 2 and calculated as if no auxiliary
fuel had been used

Method 5 As required by the Department
and Section
III.A.1 As required by
Protocol

Operation and
Maintenance of
ESP Whenever

process equipment is operating Semiannual G.29., G.34., G.35., G.41., G.43., G.44.,
G.45 Opacity 40%

Method 9 As required by the Department
and Section
III.A.1 As required by
the Protocol

Operation and
maintenance of
ESP Whenever

process equipment is operating Semiannual G.30., G.36., G.37., G.41., G.43., G.44.,
G.45 Particulate

Matter E=4.10P 0.67 or E=55.0P 0.11 -40 (depending on process weight rate)

Method 5 As required by the Department
and Section
III.A.1 As required by
the Protocol

G.31., G.38., G.44., G.45 Recordkeeping Log operating scenario when switching from one
scenario to another Reporting As required by the Department
and Section
III.A.1 Semiannual

G.30., G.39., G.44., G.45 Written
Notification Written notification to the Department when switching
from one scenario to another Reporting As required by
ARM 17.8.1215 Annual

G.33., G.40., G.42., G.44.,
G.45 PM CAM Plan ARM 17.8.1506 Provisions from CAM Plan, Appendix F Ongoing SemiannualOP2005-03 18 Date of Decision: 08/26/05
Effective Date: 09/27/05 Conditions

G.27. Ash Grove may not cause or authorize to be di scharged into the atmosphere from the cement kiln any stack emissions that exhibit an opacity of 10% or greater averaged over six consecutive minutes (ARM 17.8.316).

G.28. Ash Grove shall not cause or authorize to be discharged into the outdoor atmosphere, particulate matter in excess of 0.10 grains per standard cubic f oot (gr/dscf) of dry flue gas, adjusted to 12% carbon dioxide and calculated as if no auxiliary fuel had been used (ARM 17.8.316).

G.29. Ash Grove shall not cause or authorize to be di scharged into the atmosphere from the cement kiln any stack emissions which exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304 and ARM 17.8.752). {Sta te Enforceable Only Until SIP Approval}

G.30. Ash Grove shall not cause or authorize to be di scharged into the atmosphere from the cement kiln any stack emissions which contain particulate matter in excess of the amount allowed by the following equations (ARM 17.8.310 and ARM 17.8.752):

a. If the process weight rate of the kiln is less than or equal to 30 tons per hour, then the emission limit shall be calculated using E=4.10p 0.67 where E = rate of emission in pounds per hour and p = process weight rate in tons per hour.

b. If the process weight rate of the kiln is greater than 30 tons per hour, then the emission limit shall be calculated using E = 55.0p 0.11 , where E = rate of emission in pounds per hour and P = process we ight rate in tons per hour.

{State Enforceable Only Until SIP Approval}

G.31. When making a change from one operati ng scenario to another, Ash Grove shall contemporaneously record in a log at the Ash Gr ove facility a record of the operating scenario under which the facility is operating (ARM 17.8.1215).

G.32. Ash Grove shall provide co ntemporaneous written notification when shifting from one operating scenario to another (ARM 17.8.1215).

G.33. Ash Grove shall provide a reasonable assura nce of compliance with emission limitations or standards for the anticipated range of operations at the Cement Kiln for PM (ARM 17.8.1504).

Compliance Demonstration

G.34. Ash Grove shall inspect and maintain the El ectrostatic Precipitator (ESP) in accordance with Appendix E of this permit to monitor compliance with the opacity limits in Sections III.G.27 and III.G.29 (ARM 17.8.749 and ARM 17.8.1213).

G.35. Ash Grove shall perform a Method 9 test as required by the Department and Section III.A.1 to monitor compliance with the opacity limits in Sections III.G.27 and III.G.29. The test methods
shall be conducted in accordance with the Mont ana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

G.36. Ash Grove shall inspect and maintain the ESP in accordance with Appendix E of this permit to monitor compliance with the particulate emissions limit in Section III.G.28 (ARM 17.8.756 and ARM 17.8.1213).OP2005-03 19 Date of Decision: 08/26/05
Effective Date: 09/27/05 G.37. Ash Grove shall perform a Method 5 or anot her Department approved test as required by the Department and Section III.A.1 to monitor comp liance with the particulate emissions limits in
Sections III.G.28 and III.G.30. The test met hods shall be conducted in accordance with the
Montana Source Test Protocol and Procedur es Manual (ARM 17.8.106 and ARM 17.8.1213).

G.38. Within 24-hours of making a change from one operating scenario to another, Ash Grove shall record in a log the date and time when Ash Grove switches to or from using post-consumer recycled glass in the kiln. The log shall be maintained as a permanent business record for at least five years following the activity. The log shall be available to the Department for inspection and must be submitted to the Depart ment upon request (ARM 17.8.1213).

G.39. Ash Grove shall submit written notification to the Department within 24-hours of switching to or from using post-consumer recycled glass in the kiln (ARM 17.8.1213).

G.40. Ash Grove shall monitor compliance by following the CAM Plan (Appendix F). The CAM Plan, written by Ash Grove in accordance with ARM 17.8.1504 is summarized in Appendix F and is available in full upon request by the Department or the facility (ARM 17.8.1504 and ARM 17.8.1213).

Recordkeeping

G.41. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the ESP in accordance with the requirements in A ppendix E of this permit. All inspection and
maintenance records must be available to the Department upon request (ARM 17.8.1212).

G.42. Ash Grove shall be prepared and data kept in accordance with 40 CFR Part 64 and the CAM Plan, Appendix F of this permit (ARM 17.8.1212 and 40 CFR 64).

Reporting

G.43. Ash Grove shall submit Method 9, Method 5, or other Department approved test reports in
accordance with the Montana Source Test Protoc ol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

G.44. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

G.45. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. Certification that the ESP was inspected and maintained as required by Section III.G.34 and III.G.36;

b. Certification that the log require d in Section III.G.38 was maintained;

c. A summary of results of the last source testing that was performed; and

d. Certification of compliance with 40 CFR Part 64 (CAM), Appendix F

.OP2005-03 20 Date of Decision: 08/26/05
Effective Date: 09/27/05 H. EU004 – Product Separator and Cement Coolers (PSC)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
H.1., H.4., H.7., H.8., H.9., H.10.,
H.11 Opacity 40% Method 9 Once during 5- year permit

term As required by
Protocol

H.2., H.5., H.8., H.9., H.10., H.11 Particulate Matter 0.02 gr/dscf Method 5 Once during 5- year permit

term As required by
Protocol

H.3., H.6., H.7., H.10.,
H.11 Emission Control Equipment Operation and
maintenance of
emission control equipment Operation and
maintenance of baghouse Whenever

process equipment is operating Semiannual

Conditions

H.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304).

H.2. Particulate emissions from the dust collection system shall not exceed 0.02 gr/dscf (ARM 17.8.752).

H.3. Ash Grove shall operate and maintain emissi ons control equipment when process equipment is operating (ARM 17.8.729).

Compliance Demonstration

H.4. Ash Grove shall perform a Method 9 test once during the 5-year permit period to monitor compliance with the 40% opacity limit in Secti on III.H.1. The test shall be conducted in
accordance with the Montana Source Test Protoc ol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

H.5. A Method 5 or other Department approved test shall be performed once during the 5-year permit period to monitor compliance with the particulate em ission limit in Section III.H.2. The test shall
be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

H.6. Ash Grove shall operate, inspect, and mainta in a baghouse in accordance with Appendix E to monitor compliance with Section III.H.3 (ARM 17.8.1213).

Recordkeeping

H.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the baghouse in accordance with the requirements in Appendix E. All inspections and maintenance records must be available to the Depa rtment for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

H.8. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).OP2005-03 21 Date of Decision: 08/26/05
Effective Date: 09/27/05 Reporting

H.9. All test reports shall be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

H.10. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

H.11. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed; and

b. Certification that the baghouse was operated, inspected, and maintained as required by Section III.H.6.

I. EU004 – Road Dust (RD)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
I.1., I.3.,I.5., I.6., I.7 Opacity 20% Visual Survey Weekly Semiannual

I.2., I.4., I.5., I.6., I.7 Airborne Particulate

Matter Reasonable
Precautions Water and/or
chemical dust
suppressants As needed Semiannual

Conditions

I.1. Ash Grove may not cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of airborne particulate matter are taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over six consecutive minutes (ARM 17.8.308(1)).

I.2. Ash Grove shall not cause or authorize the use of any street, road, or parking lot without taking reasonable precautions to control emissions of ai rborne particulate matter (ARM 17.8.308(2)).

Compliance Demonstration

I.3. Once per calendar week during daylight hours, As h Grove shall visually survey the road dust for any sources of excessive emissions. For the pur pose of this survey, excessive emissions are considered to be any visible emissions, wh ich meet or exceed 15% opacity. The person conducting the survey does not have to be an EPA Method 9 observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of excessive emissions are identified, Ash Grove shall immediately
conduct a Method 9 or take corrective action to c ontain or minimize the source of emissions. If corrective actions are taken, then Ash Grove sha ll immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall reco rd the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Ash Grove of a liability for a violation de termined using Method 9 (ARM 17.8.1213).

I.4. Ash Grove shall treat all unpaved portions of the haul roads, access roads, parking lots, or the general plant area with water and/or chem ical dust suppressant as necessary to maintain compliance with the reasonable precautions limitation (ARM 17.8.752).OP2005-03 22 Date of Decision: 08/26/05
Effective Date: 09/27/05 Recordkeeping

I.5. Ash Grove shall maintain on site a weekly log r ecording the results of the visual surveys. The log shall include, but is not limited to, the date, time, observer(s), observer(s) location, the area being surveyed, and the results of the visual survey(s). If any preventative or corrective action is required, the time, date, and a description of the ac tion taken must be included in the log. The log shall be maintained as a permanent business record for at least five years following the activity. The log shall be available to the Department for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

Reporting

I.6. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

I.7. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. Certification that the visual surveys were performed and recorded on a weekly basis as required by Section III.I.3; and

b. A summary of the log of any preventa tive and corrective actions as required by
Section III.I.5.

J. EU004 – Storage Loadout – B (SLB)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements

Method 9 As required by
the Department
and Section
III.A.1 As required by
the Protocol J.1., J.3., J.4., J.5., J.6., J.7 Opacity 40%

Operation and
maintenance of baghouse Whenever

process equipment is operating Semiannual

Method 5 As required by
the Department
and Section
III.A.1 As required by
the Protocol J.2., J.3., J.4., J.5., J.6., J.7 Particulate Matter E=55.0P 0.11 -40

Operation and
maintenance of baghouse Whenever

process equipment is operating Semiannual

Conditions

J.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968 that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304).

J.2. Pursuant to ARM 17.8.310, the particulate em issions from process weight shall not exceed the value calculated by E=55.0P 0.11 -40, where E = rate of emission in pounds per hour and P = process weight rate in tons per hour (ARM 17.8.310).OP2005-03 23 Date of Decision: 08/26/05
Effective Date: 09/27/05 Compliance Demonstration

J.3. Ash Grove shall inspect and maintain a baghou se in accordance with Appendix E to monitor the opacity limit in Section III.J.1 and Sectio n III.J.2 (ARM 17.8.304 and Appendix E).

Recordkeeping

J.4. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the baghouse in accordance with the requirements in Appendix E of this permit. All inspection and maintenance records must be available to the Department for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

J.5. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

J.6. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

J.7. The semiannual reporting shall provide certification that the baghouse was inspected and maintained as required by Section III.J.3 and Section III.J.4 (ARM 17.8.1212).

K. EU004 – Stone Transfer (ST)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
K.1., K.2., K.3., K.4.,
K.5 Opacity 20% Method 9 As required by
the Department
and Section
III.A.1 Annually

Conditions

K.1. Ash Grove may not cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of airborne particulate matter are taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater over six consecutive minutes (ARM 17.8.308).

Compliance Demonstration

K.2. Ash Grove shall perform a Method 9 test on transfer points as requested by the Department and Section III.A.1 to monitor compliance with Secti on III.K.1. The test and procedures shall be
conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

Recordkeeping

K.3. Ash Grove shall maintain on site a log of any Method 9 tests conducted at the facility to monitor compliance with Section III.K.2. All compliance s ource test recordkeeping shall be performed in
accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on s ite (ARM 17.8.106 and ARM 17.8.1212).OP2005-03 24 Date of Decision: 08/26/05
Effective Date: 09/27/05 Reporting

K.4. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

K.5. The annual monitoring report shall provide cer tification that a log was maintained in accordance with Section III.K.3 (ARM 17.8.1212).

L. EU004 – Transfer Belt Conveyors (TBC)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements

Method 9 As required by
the Department
and Section
III.A.1 As required by
the Protocol L.1., L.3., L.5., L.6., L.7., L.8.,
L.9. Opacity 40%

Operation and
maintenance of baghouse Whenever

process equipment is operating Semiannual

Method 5 As required by
the Department
and Section
III.A.1 As required by
the Protocol L.2., L.4., L.5., L.6., L.7., L.8.,
L.9. Particulate Matter E=55.0P 0.11 -40

Operation and
maintenance of baghouse Whenever

process equipment is operating Semiannual

Conditions

L.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968 that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304).

L.2. The particulate emissions from process weight shall not exceed the value calculated by E=55.0 *

P 0.11 -40, where E is the rate of emissions in po unds/hour and P is the process weight rate in tons/hour (ARM 17.8.310).

Compliance Demonstration

L.3. As required by the Department and Section III.A. 1, a Method 9 opacity test shall be performed in
accordance with the Montana Source Test Protoc ol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

L.4. Ash Grove shall inspect and maintain a baghou se in accordance with Appendix E to monitor the opacity limit in Section III.L.1 (ARM 17.8.304 and Appendix E).

L.5. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 5 test or another approved test to monitor compliance w ith the particulate emissions limit in Section III.L.2. The test shall be performed in accord ance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).OP2005-03 25 Date of Decision: 08/26/05
Effective Date: 09/27/05 Recordkeeping

L.6. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

L.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the baghouse in accordance with the requirements in Appendix E of this permit. All inspection and maintenance records must be available to the Department for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

Reporting

L.8. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

L.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. Certification that the baghouse was insp ected and maintained as required by Section III.L.4; and

b. A summary of any testing that was performed.

M. EU004 – Transfer/Convey to Ball Mill (TBM)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements

Method 9 As required by the Department and
Section III.A.1 As required by
the Protocol M.1., M.3., M., M.5., M.6., M.7., M.8., M.9 Opacity 40%

Operation and
Maintenance of baghouse Whenever process equipment is operating Semiannual

Method 5 As required by the Department and
Section III.A.1 As required by the Department M.2., M.4., M.5., M.6., M.7., M.8.,
M.9 Particulate Matter E=55.0P 0.11 -40

Operation and
maintenance of baghouse Whenever process equipment is operating Semiannual

Conditions

M.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968 that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304).

M.2. The particulate emissions from process weight shall not exceed the value calculated by E=550 *

P 0.11 -40, where E is the rate of emissions in pounds /hour and P is the process weight in tons/hour (ARM 17.8.310).

Compliance Demonstration

M.3. As required by the Department and Section III.A.1, Ash Grove shall conduct a Method 9 opacity test in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).OP2005-03 26 Date of Decision: 08/26/05
Effective Date: 09/27/05 M.4. As required by the Department and Section III. A.1, Ash Grove shall conduct a Method 5 test or another Department approved test to monitor comp liance with the particulate emissions limit in
Section III.M.2. The test shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

M.5. Ash Grove shall inspect and maintain the ba ghouse in accordance with Appendix E of this permit to monitor compliance with the limits in Sections III.M.1 and III.M.2 (ARM 17.8.1213).

Recordkeeping

M.6. All source test recordkeeping shall be perform ed in accordance with the test method used and the
Montana Source Test Protocol and Procedures Ma nual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

M.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the baghouse in accordance with Appendix E of this permit. All inspection and maintenance records shall be available to the Department for inspection and shall be submitted to the Department upon request (ARM 17.8.1212).

Reporting

M.8. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

M.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. Certification that records were main tained for all inspection and maintenance activities performed on the baghouse as required in Section III.M.5; and

b. A summary of any testing that was performed.

N. EU004 – Transfer to/from Finish Mill (TFM)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
N.1., N.4., N.8., N.9., N.10., N.11 Opacity 40% Method 9 Every 2 years As required by
the Protocol

N.2., N.5., N.8., N.9., N.10., N.11 Particulate Matter 0.02 gr/dscf Method 5 Every 2 years As required by
the Protocol

N.3., N.6., N.7., N.10.,
N.11 Emission Control Equipment Operation and
maintenance of
emission control equipment Operation and
maintenance of baghouse Whenever

process equipment is operating Semiannual

Conditions

N.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304).

N.2. Particulate emissions from the dust collection system shall not exceed 0.02 gr/dscf (ARM 17.8.752).OP2005-03 27 Date of Decision: 08/26/05
Effective Date: 09/27/05 N.3. Ash Grove shall operate and maintain emissi on control equipment when process equipment is operating (ARM 17.8.749).

Compliance Demonstration

N.4. Ash Grove shall perform a Method 9 test every two years to monitor compliance with the opacity
limit in Section III.N.1. The test methods and procedures shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

N.5. Ash Grove shall conduct a Method 5 or anothe r Department approved test every two years to monitor compliance with the particulate emission li mit in Section III.N.2. The test shall be
conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

N.6. Ash Grove shall operate, inspect, and maintain a baghouse in accordance with Appendix E of this permit to monitor compliance with Section III.N.3 (ARM 17.8.1213).

Recordkeeping

N.7. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

N.8. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the baghouse in accordance with the requirements in Appendix E of this permit. All inspection and maintenance records must be available to the Department for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

Reporting

N.9. Any compliance source test reports must be submitted in accordance with the Montana Source
Test Protocol and Procedures Manua l (ARM 17.8.106 and ARM 17.8.1212).

N.10. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

N.11. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. Certification that the baghouse was opera ted, inspected, and maintained as required by Section III.N.6; and

b. A summary of any testing that was performed.

O. EU004 – Transfer to Limestone Silos (TLS)

Condition(s) Pollutant/

Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

Method 9 As required by the Department and Section
III.A.1 As required by
the Protocol O.1., O.3., O.5., O.6., O.7., O.8.,
O.9 Opacity 40%

Operation and
maintenance of baghouse Whenever process equipment is operating Semiannual

Method 5 As required by the Department and Section
III.A.1 As required by
the Protocol O.2.,O.4., O.5., O.6., O.7., O.8.,
O.9 Particulate

Matter E=55.0P 0.11 -40

Operation and
maintenance of baghouse Whenever process equipment is operating SemiannualOP2005-03 28 Date of Decision: 08/26/05
Effective Date: 09/27/05 Conditions

O.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere from any source intalled on or before November 23, 1968, that exhibit an opacity of 40% or greater averaged over six consecutive minutes (ARM 17.8.304).

O.2. The particulate emissions from process weight shall not exceed the value calculated by E=55.0 *

P 0.11 – 40, where e is the rate of emissions in pounds/hour and P is the process weight rate in tons/hour (ARM 17.8.310).

Compliance Demonstration

O.3. As required by the Department and Section III. A.1, Ash Grove shall perform a Method 9 opacity test in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

O.4. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 or another Department approved test to monitor comp liance with the particulate emissions limit in
Section III.O.2. The test shall be conducted in accordance with the Montana Source Test Protocol and Procedures (ARM 17.8.106 and ARM 17.8.1213).

O.5. Ash Grove shall inspect and maintain the ba ghouse in accordance with Appendix E of this permit to monitor compliance with the limits in Section III.O.1 and 2 (ARM 17.8.1213).

Recordkeeping

O.6. All compliance source test recordkeeping shall be performed in accordance with the test method
used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106).

O.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on the baghouse in accordance with the requirements in Appendix E of this permit. All inspection and maintenance records must be available to the Department for inspection and must be submitted to the Department upon request (ARM 17.8.1212).

Reporting

O.8. The annual compliance certification must contai n a certification statement for the above applicable requirements (ARM 17.8.1212).

O.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. Certification that the baghouse was insp ected and maintained as required by Section III.O.5 ; and

b. A summary of any testing that was performed.

P. EU004 – Wind Erosion (WE) – (from quarry activities)

Condition(s) Pollutant/Parameter Pe rmit Limit Compliance Demonstration Method Frequency Reporting Requirements
P.1., P.2., P.3., P.4., P.5 Airborne Particulate

Matter 20% Method 9 As required by
the Department
and Section
III.A.1 AnnuallyOP2005-03 29 Date of Decision: 08/26/05
Effective Date: 09/27/05 Conditions

P.1. Ash Grove may not cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of airborne particulate matter are taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over six consecutive minutes (ARM 17.8.308(1)).

Compliance Demonstration

P.2. Ash Grove shall perform a Method 9 test as required by the Department and Section III.A.1. The test methods and procedures shall be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (A RM 17.8.106 and ARM 17.8.1213).

Recordkeeping

P.3. Ash Grove shall maintain on site any Method 9 test report. The test report shall be submitted in
accordance with the Montana Source Test Protoc ol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

Reporting

P.4. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

P.5. The semiannual monitoring report shall provide a summary of any testing that was performed (ARM 17.8.1212).OP2005-03 30 Date of Decision: 08/26/05
Effective Date: 09/27/05 SECTION IV. NON-APPLICABLE REQUIREMENTS

Air Quality Administrative Rules of Montana (ARM) a nd Federal Regulations identified as not applicable to the facility or to a specific emissions unit at th e time of the permit issuance are listed below (ARM 17.8.1214). The following list does not preclude the n eed to comply with any new requirements that may become applicable during the permit term.

A. Facility-Wide

The following table contains non-applicable require ments that are administrated by the Air Resources Management Bureau of the Department of Environmental Quality.

Rule Citation Reason

ARM 17.8.320
ARM 17.8.321
ARM 17.8.323 ARM 17.8.330 through 334
ARM 17.8.340 These rules are not applicable because the facility is not listed in the source category cited
in the rule.

ARM 17.8.1106 to 1107
ARM 17.8.1110 to 1111 These rules do not apply because no changes have been made at the facility that would trigger these procedural requirements. 40 CFR 60, Subparts C, Ca, Cb, Cc, Cd 40 CFR 60, Subparts D, Da, Db, Dc 40 CFR 60, Subparts E, Ea, Eb 40 CFR 60, Subpart G, H, I, J 40 CFR 60, Subparts K, Ka, Kb 40 CFR 60, Subparts L-X 40 CFR 60, Subpart Z 40 CFR 60, Subparts AA-EE 40 CFR 60, Subparts GG-HH 40 CFR 60, Subparts KK-NN 40 CFR 60, Subparts PP-XX 40 CFR 60, Subparts AAA-BBB 40 CFR 60, Subparts DDD 40 CFR 60, Subparts FFF-LLL 40 CFR 60, Subpart NNN 40 CFR 60, Subparts PPP-QQQ 40 CFR 60, Subparts RRR-WWW 40 CFR 60, Subparts BBBB-DDDD 40 CFR 61, Subparts B-F 40 CFR 61, Subparts H-L 40 CFR 61, Subparts N-R 40 CFR 61, Subpart T 40 CFR 61, Subparts V-W 40 CFR 61, Subpart Y 40 CFR 61, Subpart BB 40 CFR 61, Subpart FF 40 CFR 63, Subparts F-I 40 CFR 63, Subparts L-O 40 CFR 63, Subparts Q-U 40 CFR 63, Subparts W-Y 40 CFR 63, Subparts AA-EE 40 CFR 63, Subparts GG-MM 40 CFR 63, Subparts OO-WW These requirements are not applicable because the facility is not an affected source as defined in these regulations.OP2005-03 31 Date of Decision: 08/26/05
Effective Date: 09/27/05 40 CFR 63, Subpart YY 40 CFR 63, Subparts CCC-EEE 40 CFR 63, Subparts GGG-JJJ 40 CFR 63, Subparts MMM-RRR 40 CFR 63, Subparts TTT-VVV 40 CFR 63, Subpart XXX 40 CFR 63, Subpart CCCC 40 CFR 63, Subparts GGGG-HHHH 40 CFR 63, Subparts SSSS-VVVV 40 CFR 63, Subpart XXXX 40 CFR 63, Subpart QQQQQ 40 CFR 63, Appendices B-E
40 CFR 68
40 CFR 72-78
40 CFR 79-80 40 CFR 85-97 (83 and 84 are reserved)

B. Emission Units

The permit application identified applicable requireme nts: non-applicable requirements for individual or specific emission units were not listed. The Depart ment has listed all non-applicable requirements in Section IV.A, these requirements relate to each specific unit, as well as facility wide.OP2005-03 32 Date of Decision: 08/26/05
Effective Date: 09/27/05 SECTION V. GENERAL PERMIT CONDITIONS

A. Compliance Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)-(c)& (e), §1206(6)(c)&(b)

1. The permittee must comply with all conditions of the permit. Any noncompliance with the terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and may result in enforcement action, permit modification, revocation and reissuance, or termination, or denial of a permit renewal application under ARM Title 17, Chapter 8, Subchapter 12.

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned ch anges or anticipated noncompliance does not stay any permit condition.

3. It shall not be a defense for a 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 the permit. If appropriate, this factor may be considered as a mitigating factor in assessing a penalty for noncompliance with an applicable requirement if the source demonstrates that both the health, safety or environmental impacts of halting or reducing operations would be more serious than the impa cts of continuing operations, and that such health, safety or environmental impacts were unf oreseeable and could not have otherwise been
avoided.

4. The permittee shall furnish to the Department, within a reasonable time set by the Department (not to be less than 15 days), any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Department copies of those records that are required to be kept pursuant to the terms of the permit. This subsection does not impair or otherwise limit the right of the permittee to assert the confidentiality of the information requested by the Department, as provided in 75-2-105, MCA.

5. Any schedule of compliance for applicable requirements with which the source is not in compliance with at the time of permit issuance sh all be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it was based.

6. For applicable requirements that will become effective during the perm it term, the source shall meet such requirements on a timely basis unless a more detailed plan or schedule is required by the applicable requirement or the Department.

B. Certification Requirements ARM 17.8, Subchapter 12, Operating Pe rmit Program §1207 a nd §1213(7)(a)&(c)-(d)

1. Any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12, shall contain certifica tion by a responsible official of truth, accuracy and completeness. This certification and any other certification require d under ARM Title 17, Chapter 8, Subchapter 12, shall state that, based on information and belief formed after reasonable inquiry, the statements and inform ation in the document are true, accurate and complete.

2. Compliance certifications shall be submitted by February 15 of each year, or more frequently if otherwise specified in an applicable requirement or elsewhere in the permit. Each certification must include the required information for th e previous calendar year (i.e., January 1 – December 31).OP2005-03 33 Date of Decision: 08/26/05
Effective Date: 09/27/05 3. Compliance certifications shall include the following:

a. The identification of each term or condition of the permit that is the basis of the certification;

b. The identification of the method(s) or other means used by the owner or operator for determining the status of compliance with each term and condition during the certification period, consistent with ARM 17.8.1212;

c. The status of compliance with each term and condition for the period covered by the certification, including whether compliance during the period was continuous or

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as described above); and

d. Such other facts as the Department may requi re to determine the compliance status of the

source.

4. All compliance certifications must be submitted to the Environmental Protection Agency, as well as to the Department, at the addresses liste d in the Notification Addresses Appendix of this permit.

C. Permit Shield ARM 17.8, Subchapter 12, Oper ating Permit Program §1214(1)-(4)

1. The applicable requirements and non-federa lly enforceable requirements are included and specifically identified in this permit and the permit includes a precise summary of the requirements not applicable to the source. Compliance with the conditions of the permit shall be deemed compliance with any applicable re quirements and any non-federally enforceable requirements as of the date of permit issuance.

2. The permit shield described in 1 above shall re main in effect during the appeal of any permit action (renewal, revision, reopening, or re vocation and reissuance) to the Board of Environmental Review (Board), until such time as the Board renders its final decision.

3. Nothing in this permit alters or affects the following:

a. The provisions of Sec. 7603 of the FCAA, including the authority of the administrator under that section;

b. The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance;

c. The applicable requirements of the Acid Ra in Program, consistent with Sec. 7651g(a) of the FCAA;

d. The ability of the administrator to obtain information from a source pursuant to Sec. 7414 of the FCAA;

e. The ability of the Department to obtain in formation from a source pursuant to the Montana Clean Air Act, Title 75, Chapter 2, MCA;

f. The emergency powers of the Department under the Montana Clean Air Act, Title 75, Chapter 2, MCA; andOP2005-03 34 Date of Decision: 08/26/05
Effective Date: 09/27/05 g. The ability of the Department to establish or revise requirements for the use of Reasonably Available Control Technology (RACT) as define d in ARM Title 17, Chapter 8. However, if the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s existing permit, shall remain in effect until such time as the Board has rendered its final
decision.

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 17.8.106, Source Testing Protocol.

5. Pursuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in these rules shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance. However, when compliance or noncompliance is demonstrated by a test or procedure provided by permit or other applicable requirements, the source sha ll then be presumed to be in compliance or noncompliance unless that presumption is overcom e by other relevant credible evidence.

6. The permit shield will not extend to minor pe rmit modifications or changes not requiring a permit revision (see Sections I & J).

7. The permit shield will extend to significant pe rmit modifications and transfer or assignment of ownership (see Sections K & N).

D. Monitoring, Recordkeeping, and Reporting Requirements ARM 17.8, Subchapter 12, Oper ating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, th e permittee shall maintain compliance monitoring records that include the following information:

a. The date, place as defined in the permit, and time of sampling or measurement;

b. The date(s) analyses were performed;

c. The company or entity th at performed the analyses;

d. The analytical techniques or methods used;

e. The results of such analyses; and

f. The operating conditions at the time of sampling or measurement.

2. The permittee shall retain records of all requi red monitoring data and s upport information for a period of at least five years from the date of the monitoring sample, measurement, report, or application. Support information includes a ll calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. All monitoring data, support information, and required reports and summaries may be maintained in computerized form at the plant site if the information is made available to Department personnel upon request, which may be for either hard copies or computerized format. Strip-charts must be mainta ined in their original form at the plant site
and shall be made available to Department personnel upon request.OP2005-03 35 Date of Decision: 08/26/05
Effective Date: 09/27/05 3. The permittee shall submit to the Department , at the addresses located in the Notification Addresses Appendix of this permit, reports of any required monitoring by February 15 and August 15 of each year, or more frequently if othe rwise specified in an applicable requirement or elsewhere in the permit. The monitoring report submitted on February 15 of each year must include the required monitoring information for the period of July 1 through December 31 of the previous year. The monitoring report submitted on August 15 of each year must include the required monitoring information for the period of Ja nuary 1 through June 30 of the current year. All instances of deviations from the permit requi rements must be clearly identified in such reports. All required reports must be certified by a responsible official, consistent with ARM
17.8.1207.

E. Prompt Deviation Reporting ARM 17.8, Subchapter 12, Oper ating Permit Program §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those attributable to upset conditions as defined in the permit, the pr obable cause of such deviations, and any corrective actions or preventive measures taken. To be considered prompt, deviations shall be reported as part of the routine reporting requirements under ARM 17. 8.1212(3)(b) and, if applicable, in accordance with the malfunction reporting requirements under ARM 17.8.110, unless otherwise specified in an applicable requirement.

F. Emergency Provisions ARM 17.8, Subchapter 12, Operating Perm it Program §1201(13) and §1214(5), (6)&(8)

1. An “emergency” means any situation arisi ng from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation and causes the source to exceed a technologybased emission limitation under this permit due to the unavoidable increases in emissions attributable to the emergency. An emergenc y shall not include noncompliance to the extent caused by improperly designed equipment, lack of reasonable preventive maintenance, careless or improper operation, or operator error.

2. An emergency constitutes an affirmative defen se to an action brought for noncompliance with a technology-based emission limitation if the pe rmittee demonstrates through properly signed, contemporaneous logs, or othe r relevant evidence, that:

a. An emergency occurred and the permittee can identify the cause(s) of the emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in the permit; and

d. The permittee submitted notice of the emergenc y to the Department within 2 working days
of the time when emission limitations were ex ceeded due to the emergency. This notice fulfills the requirements of ARM 17.8.1212(3)(c ). This notice must contain a description of the emergency, any steps taken to mitiga te emissions, and corrective actions taken.

3. These emergency provisions are in addition to any emergency, malfunction or upset provision contained in any applicable requirement.OP2005-03 36 Date of Decision: 08/26/05
Effective Date: 09/27/05 G. Inspection and Entry ARM 17.8, Subchapter 12, Oper ating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the permittee shall allow the Department, the admini strator, or an authorized representative (including an authorized contractor acting as a representative of the Department or the administrator) to perform the following:

a. Enter the premises where a source required to obtain a permit is located or emissionsrelated activity is conducted, or where record s 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 facilities, emission units, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder, sample or monitor, at reasonable times, any substances or parameters at any location for the purpose of assuring compliance with the permit or applicable requirements.

2. The permittee shall inform the inspector of a ll workplace safety rules or requirements at the time of inspection. This section shall not limit in any manner the Department’s statutory right of entry and inspection as provided for in 75-2-403, MCA.

H. Fee Payment ARM 17.8, Subchapter 12, Opera ting Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation, and Open Burning Fees §505(3)-(5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Chapter 8, Subchapter 5.

2. Annually, the Department shall provide the permittee with written notice of the amount of the fee and the basis for the fee assessment. The air quality operation fee is due 30 days after receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days after receipt of the notice. Any remaining fee, which may be due after the completion of an appeal, is due immediately upon issuance of the Board’s decision or upon completion of any judicial
review of the Board’s decision.

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 90 days of the due date of the fee, the Depart ment may impose an additional assessment of 15% of the fee (or any required portion of an appeal ed fee) or $100, whichever is greater, plus interest on the fee (or any required portion of an appealed fee), computed at the interest rate established under 15-31-510(3), MCA.

I. Minor Permit Modifications ARM 17.8, Subchapter 12, Opera ting Permit Program §1226(3)&(11)

1. An application for a minor permit modification n eed only address in detail those portions of the permit application that require revision, updatin g, supplementation, or deletion, and may reference any required in formation that has been previously submitted.OP2005-03 37 Date of Decision: 08/26/05
Effective Date: 09/27/05 2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed pursuant to ARM 17.8.1226.

J. Changes Not Requiring Permit Revision ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)-(3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided the following conditions are met:

a. The proposed changes do not require the perm ittee to obtain an air quality preconstruction permit under ARM Title 17, Chapter 8, Subchapter 7;

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in ARM Title 17, Chapter 8, Subchapters 8, 9, or 10;

c. The emissions resulting from the proposed ch anges do not exceed the emissions allowable under this permit, whether expressed as a rate of emissions or in total emissions;

d. The proposed changes do not alter permit te rms that are necessary to enforce applicable
emission limitations on emission un its covered by the permit; and

e. The facility provides the administrator and th e Department with written notification at least seven days prior to making the proposed changes.

2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to their respective copies of this permit.

3. Pursuant to the conditions above, the permittee is authorized to make Sec. 502(b)(10) changes, as defined in ARM 17.8.1201(30), without a permit revision. For each such change, the written notification required under 1.e above shall include a description of the change within the source, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer app licable as a result of the change.

4. The permittee may make a change not specifica lly addressed or prohibited by the permit terms and conditions without requiring a permit revision, provided the following conditions are met:

a. Each proposed change does not weaken the enforceability of any existing permit conditions;

b. The Department has not objected to such change;

c. Each proposed change meets all applicable requirements and does not violate any existing permit term or condition; and

d. The permittee provides contemporaneous written notice to the Department and the administrator of each change that is above the level for insignificant emission units as defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each such change, including the date of the change , any change in emissions, pollutants emitted, and any applicable requirement that would apply as a result of the change.

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases and decreases in emissions pursuant to ARM 17.8.1224(4).OP2005-03 38 Date of Decision: 08/26/05
Effective Date: 09/27/05 K. Significant Permit Modifications ARM 17.8, Subchapter 12, Operati ng Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 belo w must be used for any application requesting a significant modification of this permit. Signi ficant modifications include the following:

a. Any permit modification that does not qualify as either a minor modification or as an administrative permit amendment;

b. Every significant change in existing permit monitoring terms or conditions;

c. Every relaxation of permit reporting or recordkeeping terms or conditions that limit the Department’s ability to determine compliance with any applicable rule, consistent with the requirements of the rule; or

d. Any other change determined by the Department to be significant.

2. Significant modifications shall meet all requi rements of ARM Title 17, Chapter 8, including those for applications, public participation, and re view by affected states and the administrator, as they apply to permit issuance and renewal, excep t that an application for a significant permit modification need only address in detail those porti ons of the permit application that require revision, updating, supplementation or deletion.

3. The permit shield provided for in ARM 17.8 .1214 shall extend to significant modifications.

L. Reopening for Cause ARM 17.8, Subchapter 12, Oper ating Permit Program §1228(1)&(2)

This permit may be reopened and revi sed under the following circumstances:

1. Additional applicable requirements under the FC AA become applicable to the facility when the permit has a remaining term of 3 or more years. Reopening and revision of the permit shall be completed not later than 18 months after promulgation of the applicable requirement. No reopening is required under ARM 17.8.1228(1)(a) if the effective date of the applicable requirement is later than the date on which th e permit is due to expire, unless the original permit or any of its terms or conditions have been extended pursuant to ARM 17.8.1220(12) or 17.8.1221(2);

2. Additional requirements (including excess emission requirements) become applicable to an affected source under the Acid Rain Program. Upon approval by the administrator, excess emission offset plans shall be deemed incorporated into the permit;

3. The Department or the administrator determines that the permit contains a material mistake or
that inaccurate statements were made in estab lishing the emission standards or other terms or conditions of the permit; or

4. The administrator or the Department determin es that the permit must be revised or revoked and reissued to ensure compliance w ith the applicable requirements.

M. Permit Expiration and Renewal ARM 17.8, Subchapter 12, Operating Permit Pr ogram §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of five years.OP2005-03 39 Date of Decision: 08/26/05
Effective Date: 09/27/05 2. Renewal of this permit is subject to the sa me procedural requirements that apply to permit issuance, including those for application, content, public participation, and affected state and
administrator review.

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and administratively complete renewal applicati on has been submitted consistent with ARM 17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been submitted, all terms and conditions of the permit, including the application shield, remain in effect after the permit expires until the pe rmit renewal has been issued or denied.

4. For renewal, the permittee shall submit a comp lete air quality operating permit application to the Department not later than six months prior to the expiration of this permit, unless otherwise specified. If necessary to ensure that the terms of the existing permit will not lapse before renewal, the Department may specify, in wr iting to the permittee, a longer time period for submission of the renewal application. Such written notification must be provided at least 1 year before the renewal application due date established in the existing permit.

N. Severability Clause ARM 17.8, Subchapter 12, Opera ting Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judici al review of the issuance by the Department of an initial permit under this subchapter sha ll not impair in any manner the underlying applicability of all applicable requirements, a nd such requirements continue to apply as if a final permit decision had not been reached by the Department.

2. If any provision of a permit is found to be invalid, all valid parts that are severable from the invalid part remain in effect. If a provision of a permit is invalid in one or more of its applications, the provision remains in effect in all valid applications that are severable from the invalid applications.

O. Transfer or Assignment of Ownership ARM 17.8, Subchapter 12, Oper ating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, the applicant must include in its request to the Department a written agreement containing a specific date for the transfer of permit responsib ility, coverage and liability between the current and new permittee.

2. The permit shield provided for in ARM17.8.1 214 shall not extend to administrative permit
amendments.

P. Emissions Trading, Marketable Permits, Economic Incentives ARM 17.8, Subchapter 12, Op erating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), mi nor air quality operating permit modification procedures may be used for permit modificati ons involving the use of economic incentives, marketable permits, emissions trading, and other si milar approaches, to the extent that such minor permit modification procedures are explicitly provide d for in the Montana State Implementation Plan or in applicable requirements promulgated by the administrator.

Q. No Property Rights Conveyed ARM 17.8, Subchapter 12, Oper ating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privilege.OP2005-03 40 Date of Decision: 08/26/05
Effective Date: 09/27/05 R. Testing Requirements ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105.

S. Source Testing Protocol ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106.

T. Malfunctions ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110.

U. Circumvention ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111.

V. Motor Vehicles ARM 17.8, Subchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325.

W. Annual Emissions Inventory ARM 17.8, Subchapter 5, Air Quality Permit A pplication, Operation and Open Burning Fees §505 (STATE ONLY)

The permittee shall supply the Department with annual production and other information for all emission units necessary to calculate actual or estimated actual amount of air pollutants emitted during each calendar year. Information shall be gathered on a calendar-year basis and submitted to the Department by the date required in the emi ssion inventory request, unless otherwise specified in this permit. Information shall be in the units required by the Department.

X. Open Burning ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606.

Y. Montana Air Quality Permits ARM 17.8, Subchapter 7, Permit, Construction a nd Operation of Air Contaminant Sources §745 and
764 (ARM 17.8.745(1) and 764(1)(b) are STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP)

1. Except as specified, no person shall construct, in stall, alter or use any air contaminant source or stack associated with any source without first obt aining a permit from the Department or Board. A permit is not required for those sources or stacks as specified by ARM 17.8.744(1)(a)-(k).

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748, and 764.OP2005-03 41 Date of Decision: 08/26/05
Effective Date: 09/27/05 3. ARM 17.8.745(1) specifies de minimis cha nges as construction or changed conditions of operation at a facility holding an air quality pr econstruction permit issued under Chapter 8 that does not increase the facility’s potential to emit by more than 15 tons per year of any pollutant, except (STATE ENFORCEABLE ONLY until approv ed by the EPA as part of the SIP):

a. Any construction or changed condition that would violate any condition in the facility’s existing air quality preconstruction permit or any applicable rule contained in Chapter 8 is prohibited, except as provided in ARM 17.8.745(2);

b. Any construction or changed conditions of operation that would qualify as a major modification under Subchapters 8, 9 or 10 of Chapter 8;

c. Any construction or changed condition of operation that would affect the plume rise or dispersion characteristic of emissions that w ould cause or contribute to a violation of an ambient air quality standard or ambient air increment as defined in ARM 17.8.804;

d. Any construction or improvement project with a potential to emit more than 15 tons per year may not be artificially split into smalle r projects to avoid air quality preconstruction permitting; or

e. Emission reductions obtained through offsetting within a facility are not included when determining the potential emission increase fro m construction or ch anged conditions of operation, unless such reductions are made federally enforceable.

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the Department if the change would include a change in control equipment, stack height, stack diameter, stack gas temperature, source location or fuel specifications, or would result in an increase in source capacity above its permitted opera tion or the addition of a new emission unit. The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de minimis change, or as soon as reasonably prac ticable in the event of an unanticipated circumstance causing the de minimis change, and must include the information requested in ARM 17.8.745(1) (STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP).

Z. National Emission Standard for Asbestos 40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abat ement activities except in accordance with 40 CFR 61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos).

AA. Asbestos ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq ., and ARM 17.74.401, et seq . (State only)

BB. Stratospheric Ozone Protection – Serv icing of Motor Vehicle Air Conditioners 40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and this service involves ozone-depleting substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40 CFR 82, Subpart B.OP2005-03 42 Date of Decision: 08/26/05
Effective Date: 09/27/05 CC. Stratospheric Ozone Protection – Recycling and Emission Reductions 40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 82, Subpart F, except as provided for MVACs in Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to §82.156;

2. Equipment used during the maintenance, service, repair or disposal of appliances must comply with the standards for recycling and r ecovery equipment pursuant to §82.158;

3. Persons performing maintenance, service, repair or disposal of appliances must be certified by an approved technical certification program pursuant to §82.161;

4. Persons disposing of small appliances, MVACs and MVAC-like (as defined at §82.152) appliances must comply with recordkeep ing requirements pursuant to §82.166;

5. Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to §82.156; and

6. Owners/operators of appliances normally cont aining 50 or more pounds of refrigerant must keep records of refrigerant purchased and adde d to such appliances pursuant to §82.166.

DD. Emergency Episode Plan

The permittee shall comply with the requirements c ontained in Chapter 9.7 of the State of Montana Air Quality Control Implementation Plan.

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, shall submit to the Department a legally enforceable Em ergency Episode Action Plan (EEAP) that details how the source will curtail emissions during an ai r pollutant emergency episode. The industrial EEAP shall be in accordance with the Department ’s EEAP and shall be submitted according to a timetable developed by the Department, following Priority I reclassification.

EE. Definitions

Terms not otherwise defined in this permit or in the Definitions and Abbrev iations Appendix of this permit, shall have the meaning assigned to them in the referenced regulations.OP2005-03 43 Date of Decision: 08/26/05
Effective Date: 09/27/05 APPENDICESOP2005-03 A-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix A INSIGNIFICANT EMISSION UNITS

Disclaimer: The information in this appendix is not Stat e or Federally enforceable, but is presented to assist Ash Grove, the permitting author ity, inspectors, and the public.

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emissions unit located within a source that: (i) has a potential to emit less than five tons per year of any regulated pollutant; (ii) has a potential to emit less than 500 pounds per year of l ead; (iii) has a potential to emit less than 500 pounds per year of hazardous air pollutant s listed pursuant to Sec. 7412 (b) of the FCAA; and (iv) is not regulated by an applicable requirement, other than a generally applicable requirement that applies to all emission units subject to Subchapter 12.

List of Insignificant Activities:

The following table of insignificant sources and/or activities were provided by Ash Grove. Because there are no requirements to update such a list, the emi ssion units and/or activities may change from those specified in the table.

Emissions Unit ID Description

CCP Coal/Coke Preparation

CDA Clinker Drag Conveyor A

CDB Clinker Drag Conveyor B

CSA Transfer to/from Cement Storage Silos A

CSB Transfer to/from Cement Storage Silos B

DL Dust Loadout

DT Dust Return System

EC Clinker Bucket Conveyor

PLO2 Product Loadout 2

PST Petroleum Storage Tanks QA Quarry Activities

RT Raw Material Transfer

SC Slag/Silica/Clinker Conveyors

SLA Storage Loadout A

SLM Specialty Bin

SLN Storage Loadout at New Silos

TFS Transfer from Silos

TSC Transfer/Secondary Crushing

VE Vehicle Emissions

.OP2005-03 B-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix B DEFINITION S and ABBREVIATIONS

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq

.

"Administrative permit amendment" means an air quality operating permit revision that:

(a) Corrects typographical errors;

(b) Identifies a change in the name, address or phone number of any person identified in the air quality operating permit, or identifies a similar minor administrative change at the source;

(c) Requires more frequent monitoring or reporting by Ash Grove;

(d) Requires changes in monitoring or reporting re quirements that the Department deems to be no less stringent than current monitoring or reporting requirements;

(e) Allows for a change in ownership or operati onal control of a source if the Department has determined that no other change in the air qua lity operating permit is necessary, consistent with ARM 17.8.1225; or

(f) Incorporates any other type of change that th e Department has determined to be similar to those revisions set forth in (a)-(e), above.

"Applicable requirement" means all of the following as they apply to emission units in a source requiring an air quality operating permit (including requi rements that have been promulgated or approved by the Department or the administrator through rule making at the time of issuance of the air quality operating permit, but have future-effective compliance dates, provided that such requirements apply to sources covered under the operating permit):

(a) Any standard, rule, or other requirement, in cluding any requirement contained in a consent decree or judicial or administrative order entere d into or issued by the Department, that is contained in the Montana state implementa tion plan approved or promulgated by the administrator through rule making under Title I of the FCAA;

(b) Any federally enforceable term, conditi on or other requirement of any air quality preconstruction permit issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter, or pursuant to regu lations approved or promulgated through rule making under Title I of the FCAA, including parts C and D;

(c) Any standard or other requirement under Sec. 7411 of the FCAA, including Sec. 7411(d);

(d) Any standard or other requirement under Sec. 7412 of the FCAA, including any requirement concerning accident prevention under Sec. 7412(r)(7), but excluding the contents of any risk management plan required under Sec. 7412(r);

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or regulations promulgated thereunder;

(f) Any requirements established pursuant to S ec. 7661c(b) or Sec. 7414(a)(3) of the FCAA;

(g) Any standard or other requirement governing solid waste incineration, under Sec. 7429 of the FCAA;OP2005-03 B-2 Date of Decision: 08/26/05
Effective Date: 09/27/05 (h) Any standard or other requirement for consumer and commercial products, under Sec. 7511b(e) of the FCAA;

(i) Any standard or other requirement for tank vessels, under Sec. 7511b(f) of the FCAA;

(j) Any standard or other requirement of the re gulations promulgated to protect stratospheric ozone under Title VI of the FCAA, unless the administrator determines that such requirements need not be contained in an air quality operating permit;

(k) Any national ambient air quality standard or increment or visibility requirement under part C of Title I of the FCAA, but only as it would ap ply to temporary sources permitted pursuant to Sec. 7661c(e) of the FCAA; or

(l) Any federally enforceable term or condition of any air quality open burning permit issued by the Department under subchapter 6.

"Department" means the Montana Department of Environmental Quality.

“Excess Emissions” means any visible emissions from a stack or source, viewed during the visual surveys, that meets or exceeds 15% opacity (or 30% opacity if associ ated with a 40% opacity limit) during normal operating conditions.

"Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit any regulated air pollutant or any pollutant listed under Sec. 7412(b) of the FCAA. This term is not
meant to alter or affect the definition of the te rm "unit" for purposes of Title IV of the FCAA.

"FCAA" means the Federal Clean Air Act, as amended.

"Federally enforceable" means all limitations and conditi ons which are enforceable by the administrator, including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana state implementation plan, and any permit requirement established pursuant to 40 CFR 52.21 or under regulations approved pursuant to 40 CFR Part 51, Subpart I, including operating permits issued under an EPA approved program th at is incorporated into the Montana state implementation plan and expressly requires adhere nce to any permit issued under such program.

"Fugitive emissions" means those emissions that could not reasonably pass through a stack, chimney, vent, or other functionall y equivalent opening.

"General air quality operating permit" or "general permit" means an air quality operating permit that meets the requirements of ARM 17.8.1222, covers multip le sources in a source category, and is issued in lieu of individual permits being issued to each source.

"Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to Sec. 112(b) of the FCAA.

"Non-federally enforceable requirement" means the following as they apply to emission units in a source requiring an air quality operating permit:

(a) Any standard, rule, or other requirement, in cluding any requirement contained in a consent decree, or judicial or administrative order entered into or issued by the Department, that is not contained in the Montana state implementa tion plan approved or promulgated by the administrator through rule making under Title I of the FCAA;OP2005-03 B-3 Date of Decision: 08/26/05
Effective Date: 09/27/05 (b) Any term, condition or other requirement c ontained in any air quality preconstruction permit issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter that is not federally enforceable;

(c) Does not include any Montana am bient air quality standard contained in Subchapter 2 of this chapter.

"Permittee" means the owner or operator of any source s ubject to the permitting requirements of this subchapter, as provided in ARM 17.8.1204, that hol ds a valid air quality operating permit or has submitted a timely and complete perm it application for issuance, renewal, amendment, or modification pursuant to this subchapter.

"Regulated air pollutant" means the following:

(a) Nitrogen oxides or any volatile organic compounds;

(b) Any pollutant for which a national ambient air quality standard has been promulgated;

(c) Any pollutant that is subject to any standard promulgated under Sec. 7411 of the FCAA;

(d) Any Class I or II substance subject to a standa rd promulgated under or established by Title VI of the FCAA; or

(e) Any pollutant subject to a standard or ot her requirement established or promulgated under Sec. 7412 of the FCAA, including but not limited to the following:

(i) Any pollutant subject to requirements under Sec. 7412(j) of the FCAA. If the administrator fails to promulgate a standard by the date established in Sec. 7412(e) of the FCAA, any pollutant for which a subject source would be major shall be considered to be regulated on the date 18 months after the app licable date established in Sec. 7412(e) of the FCAA;

(ii) Any pollutant for which the requirements of Sec. 7412(g)(2) of the FCAA have been met but only with respect to the individual source subject to Sec. 7412(g)(2) requirement.

"Responsible official" means one of the following:

(a) For a corporation: a president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or a ny other person who performs similar policy or decision-making functions for the corporation, or a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a permit and
either:

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars); or

(ii) The delegation of authority to such representative is approved in advance by the Department.

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively.OP2005-03 B-4 Date of Decision: 08/26/05
Effective Date: 09/27/05 (c) For a municipality, state, federal, or other public agency: either a pr incipal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a federal agency includes the chief executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., a regional administrator of the environmental protection agency).

(d) For affected sources: the designated repr esentative in so far as actions, standards, requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated thereunder are concerned, and the designated representative for any other purposes under this subchapter.OP2005-03 B-5 Date of Decision: 08/26/05
Effective Date: 09/27/05 Abbreviations:

ARM Administrative Rules of Montana ASTM American Society of Testing Materials BACT Best Available Control Technology BDT bone dry tons
BTU British Thermal Unit CFR Code of Federal Regulations
CO carbon monoxide DEQ Department of Environmental Quality dscf dry standard cubic foot dscfm dry standard cubic foot per minute EEAP Emergency Episode Action Plan EPA U.S. Environmental Protection Agency EPA Method Test methods contained in 40 CFR 60, Appendix A
EU emissions unit
FCAA Federal Clean Air Act gr grains HAP hazardous air pollutant IEU insignificant emissions unit
Mbdft thousand board feet Method 5 40 CFR 60, Appendix A, Method 5 Method 9 40 CFR 60, Appendix A, Method 9
MMbdft million board feet
MMBTU million British Thermal Units NOx oxides of nitrogen
NO 2 nitrogen dioxide
O 2 oxygen Pb lead PM particulate matter PM10 particulate matter less than 10 microns in size psi pounds per square inch
scf standard cubic feet
SIC Source Industrial Classification
SO 2 sulfur dioxide
SOx oxides of sulfur
tpy tons per year U.S.C. United States Code
VE visible emissions VOC volatile organic compoundOP2005-03 C-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix C NOTIFICATION ADDRESSES

Compliance Notifications:

Montana Department of Environmental Quality Permitting and Compliance Division Air Resources Management Bureau
P.O. Box 200901 Helena, MT 59620-0901

United States EPA Air Program Coordinator Region VIII, Montana Office
10 W. 15 th Street, Suite 3200 Helena, MT 59626

Permit Modifications:

Montana Department of Environmental Quality Permitting and Compliance Division Air Resources Management Bureau
P.O. Box 200901 Helena, MT 59620-0901

Office of Partnerships and Regulatory Assistance Air and Radiation Program US EPA Region VIII 8P-AR
999 18 th Street, Suite 300 Denver, CO 80202-2466OP2005-03 D-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix D AIR QUALITY INSPECTOR INFORMATION

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to assist Ash Grove, permitting authorit y, inspectors, and the public.

1. Direction to Plant:

Exit Interstate 15 at the Montana City exit. Pro ceed east on Highway 518 for approximately 1 mile. The facility is located directly south of Highway 518.

2. Safety Equipment Required:

a. All inspectors will be required to wear hard hats at all times when in the plant area. Hard hats will be furnished by the inspector and ar e to be maintained in good repair.

b. Protective eye equipment will be used. Eye pr otection is mandatory in all plant areas. Safety glasses will meet or exceed ANSI Standard Z-87.

c. Respirators and other personal equipment are to be used where needed and all such equipment will be provided by the inspector.

d. Steel-toed safety boots shall be worn by all inspectors.

e. Hearing protection with a minimum noise reduc tion rating of 24 DBA is mandatory in posted

areas.

3. Facility Plot Plan:

A copy of the facility Plot Plan is on file with th e Department or may be received by contacting an Ash Grove representative.OP2005-03 E-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix E Pollution Control Device Inspection and Maintenance Plan

A. Initial Submittal

Ash Grove Cement Company shall submit to the Department, no later than 60 days from the date the operating permit is deemed effective, a Pollution Control Device Inspection and Maintenance Plan (Plan). The Plan shall cover all pollution control devices in accordance with the operating permit.

Ash Grove Cement Company shall implement the requirements of Section C of this Appendix no later than 60 days from the date the operating permit is deemed final.

B. Provisions For Changing the Plan

The requirements of Appendix E or the Plan may be changed if both Ash Grove Cement Company and the Department mutually agree in writing to any changes. Changes to Appendix E or the Plan cannot be implemented until both Ash Grove Cement Company and the Department agree in writing.

C. Minimum Requirements for Pollution Control Device Inspection and Maintenance Plan

At a minimum, the Plan shall include the information outlined below unless otherwise approved in writing by the Department.

I. Pollution Control Device Equipment Information

For each pollution control device, Ash Grove Cement Company shall provide the following information as applicable:

• Collector identification

• Plant location

• Point and equipment th e collector controls

• Manufacturer

• Model number

• Serial number

• Rated capacity

• Airlock information

• Existence of magnahelic gages etc.

• Bag cleaning type (i.e. puls e-jet, reverse air, shaker)

• Number of bags or cartridges

• Bags or cartridge length

• Bag material

• Number of compartments per unit

• Air flow rate

• Air to cloth ratios

• Exit gas temperature

• Plate and wire cleaning mechanism

• Number of plates

• Number of wires

• Number of compartments

• Transformer-rectifier set information

• Rapper system information

II. Schedule for Regular Inspection and Preventative Maintenance for Pollution Control Devices.

A. Calendar DayOP2005-03 E-2 Date of Decision: 08/26/05
Effective Date: 09/27/05 Ash Grove Cement Company shall perform the following activities at least daily.

1. ESP

a. Check exhaust for excess visible emissions (during daylight hours).

b. If excess visible emissions are observed, Ash Grove Cement Company shall investigate to determine the reason for the excess visible emissions. Ash Grove’s actions shall include, but are not limited to:

(1) Check dust discharge system for proper operation.

(2) Check that the rappers are operating.

(3) Observe transformer-rec tifier control meter readings.

2. Fabric Filters

a. Check exhaust for excess visible emissions (during daylight hours).

b. If excess visible emissions are observed, Ash Grove shall investigate to
determine the reason for the excess visible emissions. Ash Grove’s actions shall include, but are not limited to:

(1) Check and record fabric pressure loss and fan static pressure or fan amps (if available).

(2) Check compressed air system fo r air leakage (if applicable).

3. Multiclones

a. Check exhaust for excess visible emissions.

b. If excess visible emissions are observed, Ash Grove shall investigate to
determine the reason for the excess visible emissions.

B. Calendar Quarter

Ash Grove shall perform the following list of activities on the ESP at least once per calendar quarter.

1. Check all rappers for proper operation.

2. Check hopper heaters for prop er operation (if applicable).

3. Check hopper-level alarm systems for proper operation (if applicable).

C. Annually

The following inspections and preventative maintenance shall be performed at least once per calendar year. At minimum, the fo llowing items shall be inspected on each
dust collector:

1. ESPOP2005-03 E-3 Date of Decision: 08/26/05
Effective Date: 09/27/05 a. Collector Items

(1) Ducting to ESP and ducting from ESP (2) Condition of exterior shell (3) Doors and door seals (4) Hopper including hopper level detectors and vibrators

b. Rapping System

(1) Motors (2) Hammers (3) Hammer shaft bearings (4) Drive chains (5) Sprockets

c. Fan Items

(1) Fan(s) for corrosion and material buildup (2) Fan bearings (3) Bearing lubrication (4) Fan housing (5) Fan exit damper

d. Electrical/Instrumentation

(1) Transformer/rectifiers sets (2) Oil filled cables and insulators (3) Rapper shaft insulators (4) High voltage controls (5) Electrical cabinet cleanliness (6) Instrumentation in cluding voltage and current meters (check and calibrate)

e. Collecting and Discharge Electrodes

(1) Check particle buildups (2) Alignment and spacing

2. Fabric Filters

a. Collector Items

(1) Ducting to fabric filter and ducting from fabric filter (2) Condition of exterior shell (3) Doors including seals (4) Hopper (5) Screw conveyor

b. Bag Cleaning System

(1) Pulse-Jet (a) Inlet diffuser or blast plate (b) Air pulse diaphragms (c) Solenoid(s) that ac tivate pulse-pipes (i.e. check that cleaning sequence and cycle times for proper valve and timer operation) (d) Pulse-pipe alignment and clamps (e) Compressed air lines incl uding oilers and filtersOP2005-03 E-4 Date of Decision: 08/26/05
Effective Date: 09/27/05 (2) Shaker (a) Shaker motors an d shaker mechanisms (b) Bag tension and bag suspension (c) Inlet diffuser or blast plate

(3) Reverse Air (a) Reverse air fan (b) Dampers and damper drive systems (pistons, etc.) (c) Bag tension (d) Inlet diffuser or blast plate

c. Bags

(1) Proper fastening, bag tension, hanging, and excess particle
accumulation.

(2) Thoroughly inspect bags for possible leaks (e.g. tears, holes, and abrasions).

d. Fan Items

(1) Fan(s) for corrosion and material buildup (2) Fan bearings (3) Bearing lubrication (4) Fan housing

e. Airlock

(1) Rotary feeder rotor condition (2) Rotor bearing (3) Drive sprocket (4) Driven sprocket (5) Drive chain (6) Lubrication

f. Electrical/Instrumentation

(1) Fan motor (2) Airlock motor (3) Magnahelic tubing and en closures (where applicable)

3. Multiclones

a. Check for erosion of the outlet tubes b. Check gaskets on the clean side tube sheet c. Check for erosion of the axial inlet spinner vanes d. Hopper e. Screw conveyor

III. Documentation

A. Daily Observations

Ash Grove Cement Company shall record the iden tification information for the dust collector, the date and time of inspecti on, the inspector’s name, if excess visible emissions are
observed. If excess visible emissions are ob served, the corrective action taken shall be
recorded.OP2005-03 E-5 Date of Decision: 08/26/05
Effective Date: 09/27/05 B. Quarterly and Annual Inspections

Ash Grove Cement Company shall record the iden tification information for the dust collector, the date of inspection, the inspector(s) name(s), and the items inspected for each piece of pollution control equipment. The report shall state whether maintenance or repairs were
warranted. If maintenance is performed, Ash Grove Cement Company shall record the date(s) of the maintenance activity and the item(s) repaired or replaced.

C. Component Failure Records

Ash Grove Cement Company shall keep records of component failure that are discovered during daily or annual inspections or that become apparent at any other time. The action taken upon discovery of a component failure shall be recorded.

D. Record Retention

Pursuant to ARM 17.8.1212(2)(b), Ash Grove Cement Company shall retain records of all required monitoring data and support information for a period of at least five years from the date of the monitoring sample, measurement, report, or application.OP2005-03 F-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix F CAM Plan – Kiln Stack Electrostatic Precipitator

Monitoring Approach -- ESP

I. Indicator ESP Power: Average ho urly electrical power (Kw) to the ESP II. Measurement Approach The electrical power input is measur ed using a voltmeter and an ammeter. The total power (P) input to the ESP is the sum of the products of the secondary voltage (V) and current (I) in each field. (P = V1I + V2I2 + V3I3). The one-minute total power values collected will be summed and averaged hourly.

III. Indicator Value Because of the natu re of the ESP, a lower end value will be established for power input. An excursion occurs if the hourly average power input drops below its respective hourly average indicator value (i.e., a total ESP power input less than the lowest average Kw). The indicator value will be established during a source test. Excursions trigger an inspection, corrective action, and a reporting requirement. If ap propriate corrective action does not expeditiously return the indicator parameter to within 48 hours, all reasonable efforts will be taken to remedy the malfunction as expeditiously as possible.

The voltage and current are measured using the instrumentation specifically designed and installed on the ESP to measure and control the performance of the ESP. Kw: Continuous monitoring of total ESP power input Kw: Validate voltage controller output on an annual basis in accordance with good engineering practice Kw: The secondary voltage monitor and current monitor will measure their respective values on a fifteen second or less basis. The plant will calculate a one-hour block Kw arithmetic mean value based on the available values. The plant will record at least ninety-five percent of the one-hour values. Kw: Record one-hour average Kw: One-hour average IV. Performance Criteria

A. Data Representativeness

B. Verification of Operational Status C. QA/QC Practices and Criteria

D. Monitoring Frequency

E. Data Collection Procedures F. Averaging period G. Performance Testing After conducting the initial performance test to establish the indicator parameter values, Ash Grove will perform a 40 CFR Part 60, Appendix A, Method 5 test once per calendar year to verify compliance with the kiln particulate matter emissions standards set out in the air permit.

Although the complete hard copy of Appendix F is not included in the permit, the contents of Appendix F, Ash Grove’s CAM plan remain as applicable requirements as stated in the Title V Operat ing Permit #OP2005-03. To receive a hard copy of this appendix, please contact one of the following:

The Department of Environmental Quality Permitting and Compliance Division
Air Resources Mana gement Bureau
1520 E. Sixth Ave.
P.O. Box 200901 Helena, Montana 59620-0901 Bureau Phone (406) 444-3490

OR

Ash Grove Cement Company. Montana City Plant 100 MT Highway 518

Clancy, MT 59634 Phone (406) 442-8855OP2005-03 G-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix G CAM Plan – Finish Mill House Baghouse

Monitoring Approach - Baghouse Baghouse Differential Pressure I. Indicator Measurement Approach Inlet and outlet of the baghouse is monitored using a differential pressure transducer. The signal from the pressure transducer is recorded using a data acquisition system. II. Indicator Range 1 An excursion is defined as a daily average differential pressure of below 2 or above 10 inches of water pressure. An excursion triggers an inspection and possible corrective action.

Pressure drop across the baghouse is measured across the tube sheet. The minimum accuracy of the device is + 1 inch water pressure

N/A
Pressure transducer is calibrated in accordance with manufacturer’s
recommendations. Pressure drop is continuously monitored and recorded. Data is stored in the plant histories and is accessed by the data acquisition
system. A data acquisition system measures pressure drop continuously III. Performance Criteria

A. Data Representativeness

B. Verification of Operational Status C. QA/QC Practices and Criteria

D. Monitoring Frequency

E. Data Collection Procedures F. Averaging Period 24-hour

1 The above indicator ranges are a 24-hour average pressure rang e. Short-term spikes abov e or below this average do not necessarily indicate upset conditions. After cleaning, there may be a period of time required for the bags to build up a coating. During this period of time, th e baghouse differential pressure may be out of range.

Although the complete hard copy of Appendix G is not in cluded in the permit, the contents of Appendix G, Ash Grove’s CAM plan remain as applicable requirements as stated in the Title V Operat ing Permit #OP2005-03. To receive a hard copy of this appendix, please contact one of the following:

The Department of Environmental Quality Permitting and Compliance Division
Air Resources Mana gement Bureau
1520 E. Sixth Ave.
P.O. Box 200901 Helena, Montana 59620-0901 Bureau Phone (406) 444-3490

OR

Ash Grove Cement Plant. Montana City Plant 100 MT Highway 518

Clancy, MT 59634 Phone (406) 442-8855OP2005-03 H-1 Date of Decision: 08/26/05
Effective Date: 09/27/05 Appendix H CAM Plan – Clinker Cooler Stack Baghouse

Monitoring Approach Baghouse Differential Pressure I. Indicator

Measurement Approach Inlet and outlet of the baghouse is monitored using a differential pressure transducer. The signal from the pressure transducer is recorded using a data acquisition system. II. Indicator Range 1 An excursion is defined as a daily average differential pressure of below 3 or above 10 inches of water pressure. An excursion triggers an inspection and possible corrective action.

Pressure drop across the baghouse is measured across the tube sheet. The minimum accuracy of the device is + 1 inch water pressure

N/A
Pressure transducer is calibrated in accordance with manufacturer’s
recommendations Pressure drop is continuously monitored and recorded. Data is stored in the plant histories and is accessed by the data acquisition
system. A data acquisition system measures pressure drop continuously. III. Performance Criteria

A. Data Representativeness

B. Verification of Operational Status C. QA/QC Practices and Criteria

D. Monitoring Frequency

E. Data Collection Procedures F. Averaging Period 24-hour

1 The above indicator ranges are a 24-hour average pressure range. Short-term spikes above or below this average do not necessarily indicate upset conditio ns. After cleaning, there may be a pe riod of time required for the bags to build up a coating. During this period of time, th e baghouse differential pressure may be out of range.

Although the complete hard copy of Appendix H is not incl uded in the permit, the cont ents of Appendix H, Grove’s CAM plan remain as applicable requirements as stated in the Title V Operating Permit #OP2005-03. To receive a hard copy of this appendix, please contact one of the following:

The Department of Environmental Quality Permitting and Compliance Division
Air Resources Mana gement Bureau
1520 E. Sixth Ave.
P.O. Box 200901 Helena, Montana 59620-0901 Bureau Phone (406) 444-3490

OR

Ash Grove Cement Company Montana City Plant 100 MT Highway 518

Clancy, MT 59634 Phone (406) 442-8855