### K A N S A S

RODERICK L. BREMBY, SECRETARY KATHLEEN SEBELIUS, GOVERNOR DEPARTMENT OF HEALTH AND ENVIRONMENT



### AIR EMISSION SOURCE **CLASS I OPERATING PERMIT** Source ID No.: 1330001 Effective Date: **DRAFT** Expiration Date: June 21, 2009 Source Name: Ash Grove Ce ment Company SI C Code: 3241, 4953 Portland Cement Manufacturing Industries NAICS Code: 327310, Cement Manufacturing Source Location: 1801 North Santa Fe

Chanute, Kansas 66720 Mailing Address: P.O. Box 519

Chanute, Kansas 66720

DIVISION OF ENVIRONMENT Bureau of Air & Radiation Air Construction/Operating Permits & Compliance Section CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE 310, TOPEKA, KS 66612 - 1366 Voice 785 - 296 - 1570 Fax 785 - 291 - 3953 http://www.kd he.state.ks.us Printed on Recycled Paper**Authority**

This permit, developed in accordance with the provisions of K.A.R. 28 - 19 - 500 et seq., Operating Permit, meets the requirements of K.A.R. 28 - 19 - 510 et seq., Class I Operating Permits and Title V of the f ederal Clean Air Act. **Permit Intent** The purpose of this Class I Air Operating Permit is to identifythe emission sources, types of regulated air pollutants emitted from the facility , the emission limitations, standards and requirements applicable to each e mission source, and the monitoring, record keeping and reporting requirements applicable to each source as of the effective date of this permit. At the time of permit issuance, a Class I Air Emission Source Operating Permit was required because the facilit y’ s potential - to - emit PM 10, NO x , SO 2 , CO, and VOC is above 100 tons per y ear, the potential to emit a single Hazardous Air Pollutant (HAP) is above 10 tons per year, and combined HAPs is above 25 tons per y ear.**TABLE OF CONTENTS**

**Section Page**  Facility Description ................................ ................................ ................................ .......................... 4 Summary of Applicable Requirements ................................ ................................ ............................ 6 Emission Source Information ................................ ................................ ................................ .......... 6 Applicable Requirements ................................ ................................ ................................ ................. 6 Facility Wide Applicable Requirements ................................ ................................ ........................ 62 Opacity Monitoring Section ................................ ................................ ................................ ........... 64 Requirements Which Will Become Applicable During the Permit Term ................................ ..... 66 Permit Shield ................................ ................................ ................................ ................................ .. 66 Testing, Monitoring, Recordkeeping, and Reporting ................................ ................................ .... 67 Reporting of Deviations from Permit Terms ................................ ................................ ................. 67 General Provisions ................................ ................................ ................................ ......................... 68 1. K.A.R. 28 - 19 - 11: Exceptions Due to Breakdowns or Scheduled Maintenance ............ 68 2. K.A.R. 28 - 19 - 752a: Hazardous Air Pollutants; Limitations Applicable to Construction of New Major Sources or Reconstruction of Existing Major Sources ...... 68 3. K.A.R. 28 - 19 - 753: Hazardous Air Pollutants; Limitations Applicable to Sources for Which the U.S. EPA Fails to Meet Certain Deadlines ................................ .............. 68 4. Permit Term and Renewal ................................ ................................ .............................. 69 5. Severability ................................ ................................ ................................ ..................... 69 6. Property

Rights ................................ ................................ ................................ ............... 69 7. Compliance ................................ ................................ ................................ ..................... 69 8. Compliance Certification ................................ ................................ ............................... 69 9. Emergency ................................ ................................ ................................ ...................... 70 10. Inspection and Entry ................................ ................................ ................................ ....... 70 11. Permit Amendment, Modification, Reopening, and Changes Not Requiring a Permit Action ................................ ................................ ................................ .................. 71 12. Duty

to Provide Information ................................ ................................ .......................... 71 13. Duty

to Supplement ................................ ................................ ................................ ........ 71 14. Other Permits and Approvals; Applicability ................................ ................................ .. 72 15. Submissions ................................ ................................ ................................ .................... 72 Attachment A. Site Diagram Attachment B. Acronym s and Sy mbols Attachment C. Emission Sources Listed with Their Applicable Requirements (Regulatory Classif ications) Attachment D. Emission Points with Very L ow or Nonexistent Visible Emissions Attachment E. 40 CFR 60 Subpart A Attachment F. 40 CFR 61 Subpart A Attachment G. 40 CFR 63 Subpart APage 4 of 77

**Facility Description I.**  **Introduction** Ash Grove Cement Company (A sh Grove) of Overland Park, Kansas, is a major manufacturer of Portland cement in the United States. Ash Grove owns and operates numerous cement manufacturing facilities located across the country . One such facility is the Ash Grove Cement Plant (Plant) lo cated at the corner of North Santa Fe Street and Ash Grove Road adjacent to the northern limits of the city of Chanute, Kansas. The plant is located within the city

limits of Chanute in Neosho County . Cement production has been conducted at this site sinc e 1908. The latest wet-process cement operation was constructed in 1964 and continued operation until 2001. Numerous technical advances have occurred over the last three decades to make the Portland cement manufacturing process more energy efficient. Ash Grove intends to take advantage of these advances to maintain its competitive position in the market and to provide its customers with increased quantities of quality cement products. The new plant is significantly larger than the existing operation and emp loys the latest technology in all phases of cement production. The two pre - existing wet-process kilns and the associated raw mill have been replaced with a single preheater/precalciner kiln design and an in- line raw mill for dry raw material preparation. With these kiln design changes came modifications in the various material conveyance and storage operations at the facility . These modifications were designed to minimize air emissions. Even with the increase in production, certain pollutant emissions have decreased over previous operations. Ash Grove received authorization to modify and modernize the existing Plant on August 27, 1999 from the Kansas Department of Health & Environment (KDHE) and on October 28, 1999 from Region VII of the United States Environmental Protection Agency (USEPA). Authorizations for additional systems were received from the agency after these dates for other supporting s ys tems. A Modification of Permit Conditions June 22, 2004 has modified previously

established permit conditions. Ash Grove received authorization from KDHE on December 30, 2004 to modify the kiln to utilize alternative non - hazardous waste fuels. Ash Grove also received authorization from KDHE to utilize petroleum coke during all modes of operation on March 30, 200 6. The operating permit was updated on May 29, 2007 to incorporate these two PSD permits, as well as a number of construction approvals that were issued since the last update. **II. General Description**  Ash Grove’s Plant manufactures various Portland cement products for shipment throughout a large geographical area in the Midwest region of the United States. The cement manufacturing process involves the following steps: 1) Quarrying and crushing limestone and acquisition of other raw materials. 2) Proportioning and grinding of the raw materials. 3) Py

roprocessing the raw material mix in the cement kiln system to form Portland cement clinker. 4) Grinding the clinker with gy psum and other additives to form Portland cement products.Page 5 of 77

Ash Grove acquires much of the raw materials for the cement production operation from adjacent quarries. Materials such as limestone are mined from these quarries and transported to the primary

crusher. Once initial sizing has occurred, the limestone material is then tran sported through a secondary crusher unit and conveyed into a storage dome. Additional raw materials such as clay, sand, and iron ore are received from on - site and off - site sources, unloaded into receiving bins, and conveyed into a covered storage buildin g. From these two storage operations, raw materials are transported into holding bins for proper proportioning into the raw mill grinding s ys tems. Predetermined ratios of the various materials are determined b y the cement laboratory and depend on the cement chemical composition of the individual components within each raw material. The ground raw materials, known as the raw material mix or kiln feed, are stored in a blending silo system prior to introduction into the top portion of the preheater/prec alciner tower. Features of the p yroprocessing s ys tem include a relatively short rotary

kiln, five stages of cyclone - ty

pe preheater vessels located in a tall tower adjacent to the kiln, and a precalciner vessel at the base of the tower in which burning f uel is intimately

mixed with raw materials. Coal, petroleum coke, natural gas, used oil, hazardous waste - derived fuels (WDF), and alternative non - hazardous waste - derived fuels are used to provide thermal energy to the py roprocess in both the preheater/precalciner tower and the rotary kiln. The Plant has been permitted for, and continues to use liquid (pumpable) and solid (containerized and bulk) WDF for beneficial energy recovery in the new py

roprocessing system. Flame temperatures of approximately 34 00 o F must be reached within the rotary kiln to produce material temperatures in the range of 270 0 oF to bring about the final chemical reactions that turn the raw materials into clinker. The hot exhaust gases from the tower are used to dry the raw materi als in the vertical roller raw mill. In conjunction with the kiln and raw mill replacement, Ash Grove has expanded the finished cement grinding capacity of the plant through the conversion of the existing raw mill into a finish mill system and the addition of a new finish mill. The two existing finish mills will remain in production. All finish mill operations are ty pical ball mill systems that include the rotary ball mill, a high efficiency separator, dust collectors, material bins and feeders, and material handling/conveyance equipment. The finished cement products are stored in existing silos systems for bulk transport loading. Aside from the described major processes, there are numerous minor operations such as cement bagging operations, coal unloading/storage, and diesel/gasoline storage tanks. **III. 40 CFR Part 63, Subpart LLL and EEE Transition**  Various operations at the facility were previousl y subject to 40 CFR Part 60, Subpart F, Cement Manufacturing. As of June 14, 2002 all such operations, other than the kiln system, are now subject to the provisions of 40 CFR Part 63, Subpart LLL, National Emission Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry . Therefore the Subpart F requirements do not app ly . The kiln system is subject to 40 CFR Part 63, Subpart EEE, National Emission Standard for Hazardous Air Pollutants from Hazardous Waste Combustors.Page 6 of 77

**Summary of Applicable Requirements** A. K.A.R. 28 - 19 - xx ................................ ................................ ................................ ........................ 7 B. 40 CFR 60 Subpart A ................................ ................................ ................................ ................ 8 C. 40 CFR 60 Subpart Kb ................................ ................................ ................................ .............. 8 D. 40 CFR 60 Subpart Y ................................ ................................ ................................ ................ 9 E. 40 CFR 60 Subpart OOO ................................ ................................ ................................ ........ 11 F. 40 CFR 61 Subpart A ................................ ................................ ................................ .............. 13 G. 40 CFR 61 Subpart V ................................ ................................ ................................ .............. 13 H. 40 CFR 61 Subpart FF ................................ ................................ ................................ ............ 21 I. 40 CFR 63 Subpart A ................................ ................................ ................................ .............. 29 J. 40 CFR 63 Subpart DD ................................ ................................ ................................ ........... 29 K. 40 CFR 63 Subpart PP ................................ ................................ ................................ ............ 32 L. 40 CFR 63 Subpart EEE ................................ ................................ ................................ .......... 35 M. 40 CFR 63 Subpart LLL ................................ ................................ ................................ .......... 42 N. State C onstruction Permit Conditions ................................ ................................ ..................... 50 **Emission Source Information** A list of emission sources including emission source IDs, emission source descriptions, Stack/Vent ID ’s, and Control Equipment ID Numbers is included as Attachment C. **Applicable Requirements** The following provides a listing of the regulatory and permit requirements that are applicable to the facility and the method(s) the facility will use to comply with the requirements. A listing of the sources subject to each of the specific regulatory cla ssifications, if any, is provided as Attachment C. **A. Kansas Administrative Regulations**  **A.1 K.A.R. 28**  **- 19**  **- 20, Particulate matter emission limitations**  **- Processing Equipment**  Limitation/ Standard: PM emissions are limited according to the following equati ons: for Process weight # 30

tons/hr, E = 4.1( P 0.67 ), for Process weight > 30 tons/hr, E = 55( P 0.11 ) - 40. Where: E = the rate of emissions in lb/hr, P = the process weight rate in tons/hrPage 7 of 77

Monitoring Due to potentially very low or nonexistent emissions, no monitoring is required at time of permit issuance. If, however, any factors change that wo uld affect the potential particulate matter emission rate (process changes, emission factor increases, fuel changes, etc.), the potential particulate matt er emission rate must be recalculated and evaluated against the rule limitation. Permit Condition Reporting and Recordkeeping Records shall be maintained to ensure that this particulate matter emission source is in compliance with the particulate matter e mission rate limitation. If, however, any factors change that would affect the potential particulate matter emission rate, records shall be maintained of any recalculations and evaluations. These records shall include the design rate capacity of the unit, emission factors used in calculations and potential/allowable emission rates. Permit Condition

**A.2 K.A.R 28**  **- 19**  **- 650(a)(2), Opacity Limitations, Stationary Sources, Existing as of 1971**  Limitation/ Standard: Opacity of visible emissions from any emission unit shall not exceed 40% opacity for any emission

unit, other than a portable source, existing on or before January 1, 1971 and that has not been relocated after January 1, 1971. Monitoring Conduct 1 - min visible emissions (VE) test using Method 22. I f visible emissions are observed conduct an additional 1 - minute Method 22 within twenty- four hours with a result of “No visible emissions,” or conduct a 6 - minute Method 9. The Method 9 test must begin within twenty- fo ur hours of the original, or follow- up (if conducted), Method 22 during which visible emissions were observed, unless a follow- up Method 22 demonstrated no visible emission. See NonMACT Visible Emissions Monitoring Plan for more details. Permit Condition

Reporting The owner or operator shall prom ptly report deviations from permit requirements, the probable cause of such deviations, and any corrective actions or preventive measures taken. To be considered prom pt, deviations shall be reported as part of the routine semi annual reporting requirements under K.A.R. 28 - 19 - 512(11)(A), and, if applicable, in accordance with the malfunction reporting requirements under K.A.R. 28 - 19 - 11, unless otherwise specified in an applicable requirement. K.A.R. 28 - 19 - 512(11)(A), 28 - 19 - 11

Recordkeeping Maintain r ecords of the monthly VE tests for a period of five years. Permit Condition **A.3 K.A.R 28**  **- 19**  **- 650(a)(3), Opacity Limitations, New Sources**  Limitation/ Standard: Opacity of visible emissions from any emission unit shall not exceed 20% opacity for any emissio n

unit that existed or was relocated after January 1, 1971.Page 8 of 77

Monitoring Conduct 1 - min visible emissions (VE) test using Method 22. If

visible emissions are observed conduct an additional 1 - mi nute Method 22 within twenty - four hours with a resu lt of “No visible emissions,” or conduct a 6 - minute Method 9. The Method 9 test must begin within twenty - fo ur hours of the original, or follow - up (if conducted), Method 22 during which visible emissions were observed, unless a follow - up Method 22 demonstrated no visible emission. See Non - MACT Visible Emissions Monitoring Plan for mo re details. Permit Condition

Reporting The Permittee shall promptly report deviations from permit

requirements, the probable cause of such deviations, and any corrective action s or preventive measures taken. To be considered prompt, deviations shall be reported as part of the routine semi annual reporting requirements under K.A.R. 28 - 19 - 512(11)(A), and, if applicable, in accordance with the malfunction reporting requirements un der K.A.R. 28 - 19 - 11, unless otherwise specified in an applicable requirement. K.A.R. 28 - 19 - 512(11)(A), K.A.R. 28 - 19 - 11

Recordkeeping Maintain records of the monthly VE tests for a period of five years. **B. 40 CFR 60 Subpart A**  Applicable citations for 40 CFR 60 Subpart A are provided in Attachment E. **C. 40 CFR 60 Subpart Kb**  Equipment subject to 40 CFR 60 Subpart Kb must comply with the requirements of 40 CFR 60 Subpart A - General Provisions except where Subpart Kb provides for explicit exemptions to S ubpart A. The 40 CFR 60 Subpart A - General Provisions are found in Attachment E of this permit. Except as provided in §60.1 10b(b), (c), and (d), the affected facility to which this subpart applies is each storage vessel with a capacity greater than or e qual to 40 cubic meters (m 3 ) that is used to store volatile organic liquids (VOLs) for which construction, reconstruction, or modification is commenced after July 23, 1984. 60.1 10b(a)

**C.1 40 CFR 60 NSPS**  **- Kb, Tank**  a. Limitation/Standard: 60.1 12b(a)(3) (i) Must have a closed vent system designed to collect all VOC vapors and operate with no detectable emission as indicated by an instrument reading of less than 500 ppm above background and visual inspection as determined in §60.485(b). Monitoring Co mp liance with LDAR program of 40 CFR 61 Subpart FF demonstrates compliance with this requirement. N/A Testing Method 21 and visual inspection 60.485(b)Page 9 of 77

b. Limitation/Standard: 60.1 12b(a)(3)(ii) Must have a control device designed to reduce VOC emissions by 95% Monitoring Closed vent system and control device must be monitored according to the operating plan 60.1 13b(c)(2) One or more devices which vent directly to the atmosphere may be used on the closed - vent system provided each device remai ns in a closed, sealed position during normal operations 61.349(a)(1)(iv) Reporting An operating plan must be submitted with the startup notification that documents that the combustion device will have a minimum residence time of 0.75 seconds and a minimum temp. of 816  C 60.1 13b(c)(1) Recordkeeping Keep records of 1) Operating plan and 2) Measured values of mo nitored parameters for life of control equipment 60.115b(c) Records must be kept for the life of the source 60.1 16b(a) Keep records of the dim ension and capacity of the storage vessel for the life of the control device 60.1 16b(b) Testing The source of each vessel storing a waste mixture of indeterminate or variable composition shall be subject to these requirements: Prior to initial filling o f the vessel, the highest maximum true vapor pressure for the range of anticipated liquid compositions to be stored will be determined using the methods described in paragraph (e). For vessels in which the vapor pressure of the anticipated liquid compositi on is above the cutoff for monitoring but below the cutoff for controls as defined in §60.1 12b(a), an initial physical test of the vapor pressure is required; and a physical test at least once every 6 months thereafter is required as determined by the fol lowing methods: ASTM Method D2879 - 83 (incorporated by reference - see §60.17); ASTM Method D323 - 82 (incorporated by reference - see §0.17); or as measured by an appropriate approved method. 60.1 16b(f)

The owner or operator of each vessel equipped with a clo sed vent system and control device meeting the specifications of § 60.1 12b is exempt from the requirements of §60.1 16b(c) and (d). 60.1 16b(g)

**D. 40 CFR 60 Subpart Y Standards of Performance for Coal Preparation Plants**  **Applicable Requirem ent (Summary)**  Equipment subject to 40 CFR 60 Subpart Y must comply with the requirements of 40 CFR 60 Subpart A

– General Provisions except where Subpart Y provides for explicit exemptions to Subpart A. The 40 CFR 60 Subpart A - General Provisions are found in Attachm ent E of this permit. The provisions of this subpart are applicable to any of the following affected facilities in coal preparation plants which process more than 200 tons per day: Thermal dryers, pneumatic coal cleaning equipment (air tables), coal proc essing and conveying equipment (including breakers and crushers), coal storage systems, and coal transfer and loading systems. 60.250(a) Any facility under §60.250(a) that commences construction or modification after October 24, 1974, is subject to the re quirements of this subpart. 60.250(b) **D.1 40 CFR 60 Subpart Y, 60.252(c) Opacity Limitations for coal processing,**  **conveying, storage, transfer, or loading equipment**  Limitation/ Emissions from coal processing and conveying equipment, coal storage systems , and coal transfer Standard and loading systems shall not exhibit 20% opacity or greater except during startups, shutdowns, &

malfunctionsPage 10 of 77

Monitoring Conduct 1 - min visible emissions (VE) test using Method 22. If visible

emissions are observed conduct an additional 1 - minute Method 22 within tw enty - four hours with a result of “No visible emissions,” or conduct a 6 - mi nute Method 9. The Method 9 test must begin within twenty - four hours of the original, or follow - up (if conducted), Method 22 during which vis ible emissions were observed, unless a follow - up Method 22 demonstrated no visible emission. See Non - MACT Visible Emissions Monitoring Plan for more details. Permit Condition

Reporting The Permittee shall promptly report deviations from permit requirement s,

the probable 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 semi - annual reporting requirements under K.A.R. 28 - 19 - 512(11)(A), and, if applic able, in accordance with the malfunction reporting requirements under K.A.R. 28 - 19 - 11, unless otherwise specified in an applicable requirement. K.A.R. 28 - 19 - 512(ii)(A) K.A.R. 28 - 19 - 11 Recordkeeping Maintain records of the monthly VE tests for a period o f five years. Permit Condition **D.2 40 CFR 60 Subpart, 60.252(a)(1) Thermal dryer particulate standard**  a. Limitation/Standard Thermal Dryers. Shall not emit particulate matter in excess of 0.031 gr/scf. 8/26/99 Monitoring Due to potentially very low or nonexistent emissions, no monitoring is required at time of permit issuance. If, however, any factors change that wo uld affect the potential particulate matter emission rate (process changes, emission factor increases, fuel changes, etc.), the potential particulate matter emission rate must be recalculated and evaluated against the rule limitation. Permit Condition 8/26/99 Recordkeeping No recordkeeping is required at time of permit issuance. If, however, any factors change that would affect the potenti al particulate matter emission rate, records shall be maintained of any recalculations and evaluations. These records shall include the design rate capacity of the unit, emission factors used in calculations and potential/allowable emission rates. Permit C ondition Testing Test methods. Method 5 sampling time and volume shall be at least 60 minutes and 30 dscf. 60.254(b)(1) b. Limitation/Standard 60.252(a)(2): Thermal dryers. Shall not exhibit greater than 20% opacity except during startups, shutdowns, & malfunctions Monitoring Reporting See Section L, 40 CFR 63 Subpart EEE, for details on compliance with this limit Recordkeeping Testing c Limitation/Standard 60.253(a)(1): Thermal dryers shall be monitored using a CMS for the measurement of the temperature of the gas stream at the exit of the dryer. CMS shall be calibrated and certified by the manufacturer to be accurate within ±3  F annually.Page 11 of 77

Monitoring All monitoring devices under (a) of this section are to be recalibrated annually in accordance with procedures under §60.13 (b). 60.253(b) Recordkeeping Records of requirements requested in CEMS conditions are included in the facility wide requirements N/A **E. 40 CFR 60 Subpart OOO Standards of performance for nonmetallic mineral pr** **ocessing plants**  Equipment subject to 40 CFR 60 Subpart OOO must comply with the requirements of 40 CFR 60 Subpart A - General Provisions except where Subpart OOO provides for explicit exemptions to Subpart A. The 40 CFR 60 Subpart A - General Provisions are found in Attachment E of this permit. Except as provided in §60.670(a)(2), (b), (c), and (d), the provisions of this subpart are applicable to the following affected facilities in fixed or portable nonmetallic mineral processing plants: each crusher, g rinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading station. 60.670(a)(1) An affected facility under § 60.670(a) that commences construction, reconstruction, or mo dification after August 31, 1983 is subject to the requirements of this part. 60.670(e) **One -**  **Time Initial Performance Testing Related Requirements** Reporting Submit written reports of the results of all performance tests conducted to demonstrate compliance with th e standards set forth in § 60.672 of this subpart. 60.676(f) Testing Method 9 and the procedures in §60.11 shall be used to determine opacity. 60.675(b)(2) In determining compliance with the particulate matter standards [opacity] in § 60.672 (b) and (c) , the owner or operator shall use Method 9 and the procedures in § 60.11, with additions as given in § 60.675(c)(1)(i) - (iii). 60.675(c)(1) Testing If emissions from two or more facilities continuously interfere so that the opacity of fugitive emissio ns from an individual affected facility cannot be read, either of the following procedures may be used: (i) Use for the combined emission stream the highest fugitive opacity standard applicable to any of the individual affected facilities contributing to the emissions stream. (ii) Separate the emissions so that the opacity of emissions from each affected facility can be read. 60.675(e)

Non - crushers - When determining compliance with the opacity standard, the duration of the initial performance test, Me thod 9 observations, may be reduced from 3 hours (thirty 6 - minute averages) to 1 hour (ten 6 - minute averages) if there are no individual readings greater than 10 percent opacity; and there are no more than 3 readings of 10 percent for the 1 - hour period. 60 .675(c)(3)

Crushers - When determining compliance with the fugitive emissions standard for any crusher at which a capture system is not used as described under § 60.672(c) of this subpart, the duration of the Method 9 observations ma y be reduced from 3 h ours (thirty 6 - minute averages) to 1 hour (ten 6 - mi nute averages) only if the following conditions apply: (i) There are no individual readings greater than 15 percent opacity; and (ii) There are no more than 3 readings of 15 percent for the 1 - hour period. 60.675(c)(4)Page 12 of 77 Storage Bins Controlled by a Baghouse - The duration of the initial Method 9 observations shall be 1 hour (ten 6 - minute averages). 60.675(c)(2) Structures. Shall use Method 22 to determine fugitive emissions. The performance test shall be conducted while all affected facilities inside the building are operating. The performance test for each building shall be at least 75 minutes in duration, with each side of the building and the roof being observed for at least 15 minutes. 60.675(d)

**E.1 40 CFR 60 NSPS OOO, Belt Conveyor Transfer Point, Grinding Mill, Screen,**  **Bagging Operation, Storage Bin**  **– Fugitive Source**  Limitation/ 60.672(b): Shall not cause to be discharged into the atmosphere from any transfer point on belt Standard conveyors or fro m any other affected facility any fugitive emissions which exhibit greater

than 10% opacity except during startups, shutdowns, & malfunctions. Monitoring Conduct 1 - min visible emissions (VE) test using Method 22. If visible emissions are observed conduct an additional 1 - minute Method 22 within tw enty - four hours with a result of “No visible emissions,” or conduct a 6 - mi nute Method 9. The Method 9 test must begin within twenty - four hours of the original, or follow - up (if conducted), Method 22 during whi ch visible emissions were observed, unless a follow - up Method 22 demonstrated no visible emission. See Non - MACT Visible Emissions Monitoring Plan for more details. Permit Condition

If emissions from two or more facilities continuously interfere so that the opacity of fugitive emissions from an individual affected facility cannot be read, either of the following procedures may be used: (i) Use for the combined emission stream the highest fugitive opacity standard applicable to any of the individual affecte d facilities contributing to the emissions stream. (ii) Separate the emissions so that the opacity of emissions from each affected facility can be read. 60.675(e)

Reporting The Permittee shall promptly report deviations from permit requirements, the probable 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 semi - annual reporting requirements under K.A.R. 28 - 19 - 512(11)(A), and, if applicable, in acc ordance with the malfunction reporting requirements under K.A.R. 28 - 19 - 11, unless otherwise specified in an applicable requirement.. Permit Condition

Recordkeeping Maintain records of the monthly VE tests for a period of five years. Permit Condition **E.2 40 CFR 60 NSPS OOO, Belt Conveyor Transfer Point, Crusher, Grinding Mill,**  **Screen, Bagging Operation, Storage Bin**  **– Affected Sources in Buildings**  Limitation/ 60.672(e): No owner or operator shall cause to be discharged into the atmosphere from any Standard building enclosing any transfer point on a conveyor belt or any other affected facility any visible

fugitive emissions except during startups, shutdowns, & malfunction.Page 13 of 77

Monitoring Conduct 1 - min visible emissions (VE) test using Method 22. If visible emissions are observed conduct an additional 1 - minute Method 22 within tw enty - four hours with a result of “No visible emissions,” or conduct a 6 - minute Method 9. The Method 9 test must begin within twenty - four hours of the original, or follow - up (if condu cted), Method 22 during which visible emissions were observed, unless a follow - up Method 22 demonstrated no visible emission. See Non - MACT Visible Emissions Monitoring Plan for more details. Permit Condition

Reporting The Permittee shall promptly report d eviations from permit requirements, the probable 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 semi - annual reporting requirements under K.A.R. 28 - 19 - 512(11)(A), and, if applicable, in accordance with the malfunction reporting requirements under K.A.R. 28 - 19 - 11, unless otherwise specified in an applicable requirement. K.A.R. 28 - 19 - 512(11)(A) K.A.R. 28 - 19 - 11

Recordkeeping Maintain records of the mo nthly VE tests for a period of five years. Permit Condition **F. 40 CFR 61 Subpart A**  Applicable citations for 40 CFR 61 Subpart A are provided in Attachment F. **G. 40 CFR 61 Subpart V National Emission Standard for Equipment Leaks**  **General Requirem ents**  **Applica ble Requirem**  **ent (Summary) Citation**  Equipment subject to 40 CFR 61 Subpart V must comply with the requirements of 40 CFR 61 Subpart A - General Provisions except where Subpart V provides for explicit exemptions to Subpart A. The 40 CFR 61 Subpart A

– Gener al Provisions are found in Attachment F of this permit. The provisions of this subpart apply to each of the following sources that are intended to operate in volatile hazardous air pollutant (VHAP) service: pumps, compressors, pressure relief devices, sampling connection systems, open - ended valves or lines, valves, flanges and other connectors, product accumulator vessels, and control devices or systems required by this subpart. 61.240(a) The provisions of this subpart shall demonstrate compliance with the requirements of §§61.242 - 1 to 61.242 - 11 for each new and existing source as required in 40 CFR 61.05, except as provided in §§61.243 and 61.244. 61.242 - 1(a) Compliance with this subpart will be determined by review of records, review of performance t est results, and inspection using the methods and procedures specified in §61.245. 61.242 - 1(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. 61.242 - 7(b) **G.1 40 CFR 61 Subpart V, General Requirements**  a. Limitation/Stan dard 61.242 - 1(d) Standards: General. Each piece of equipment to which this subpart applies shall be marked in such a manner that it can be distinguished readily from other pieces of equipment. b. Limitation/Standard 61.242 - 1(e) Standards: Equipment that is in vacuum service is excluded from the requirements of §61.242 - 2, to §61.242 - 11 if it is identified as required in §61.246(e)(5).Page 14 of 77

Reporting A statement must be submitted to the Administrator notifying them that the

requirements of §§61.242, 61.245, 61.246, and 61.247 are being implemented. 61.247(a)(1) Statement is to be submitted within 90 days of the effective date 61.247(a)(2) In the case of new sources which did not have an initial startup date preceding the effective date, the statement shall be submitted with the application for approval of construction, as described in § 61.07. 61.247(a)(3) The statement shall contain the listed information for each source. 61.247(a)(4) A report shall be submitted to the Administrator semiannually starting 6 m onths after the initial report that includes the information detailed in §61.247(b)(1 - 5) 61.247(b) In the first report submitted as required in paragraph (a) of this section, the report shall include a reporting schedule stating the months that semiannua l reports shall be submitted. Subsequent reports shall be submitted according to that schedule, unless a revised schedule has been submitted in a previous semiannual report. 61.247(c)

Recordkeeping Record in a log a list of identification numbers for equi pm ent (except welded

fittings) subject to the requirements of this subpart. 61.246(e)(1) Record in a log a list of identification numbers for equipment that the owner or operator elects to designate for no detectable emissions as indicated by an instrume nt reading of less than 500 ppm above background, the designation of this equipment for no detectable emissions shall be signed by the owner or operator. 61 .246(e)(2) Record in a log a list of equipment identification numbers for pressure relief devices required to comply with §61.242 - 4(a). 61.246(e)(3) Record in a log the dates of each compliance test required in §61.242 - 2(e), §61.242 - 3(l), §61.242 - 4, §61.242 - 7(f), and §61.135(g) as well as the background level measure during each test and the maximum instrument reading measured at the equipment during each test. 61.246(e)(4) Record in a log a list of identification numbers for equipment in vacuum service. 61 .246(e)(5) Record in a log an analysis demonstrating the design capacity of the process un it and an analysis demonstrating that the equipment is not in VHAP service for use in determining exemptions as provided in 40 CFR 61, Subpart V. 61.246(i) Record in a log information and data used to demonstrate that a piece of equipment is not in VHAP service. 61.246(j) **G.2 40 CFR 61 NESHAP**  **- Subpart V, Pumps**  a. Limitation/Standard 61.242 - 2(a)(1) Standards: Each pump shall be monitored monthly to detect leaks, except as provided in §61.242 - 1(c) and §61.242 - 2(d), (e), (f) and (g). b. Limitation/Standard 61 .242 - 2(a)(2) Standards: Each pump shall be checked by visual inspection each calendar we ek for indications of liquids dripping from the pump seal. Monitoring Test methods and procedures. Monitoring, as required in §§ 61.242, 61.243,

61.244, and 61.135, shall comply with the following requirements: (1) Monitoring shall comply with Method 21 of appendix A of 40 CFR part 60. 61.245(b)(1)Page 15 of 77 Test methods and procedures. Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the f ollowing requirements: (2) The detection instrument shall meet the performance criteria of Reference Method 21. 61.245(b)(2) Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the following requirements: (3) The instrument shall be calibrated before use on each day of its use by the procedures specified in Reference Method 21. 61.245(b)(3) Calibration gases shall be: (i) Zero air (less than 10 ppm of hydrocarbon in air); and (ii) A mixture of methane or n - hexane and air at a concentration of approximately, but less than, 10,000 ppm methane or n - hexane. 61.245(b)(4) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. 61.242 - 2(b)(1) If there are indications of liquids dripping from the pump seal, a leak is detected. 61.242 - 2(b)(2) Delay of repair of equipment for which leaks have been detected will be allowed if the repair is technically infeasible without a process unit shutdown. Repair of this equipment shall occur before the end of the next process unit shutdown. 61.242 - 10(a) Delay of repair for equipment for which leaks have been detected will be allowed for equipment that is isolated from the process and that does not remain in VHAP service. 61.242 - 10(b) Delay of repair for pumps will be allowed if: (1) Repair requires the use of a dual mechanical seal system that includes a barrier fluid system, and (2) Repair is completed as soon as practicable, but not later than 6 months after the leak was detected. 61.242 - 10(d) Delay of repa ir beyond a process unit shutdown will be allowed if supplies depleted and had previously been stocked. 61.242 - 10(e) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in §61.242

– 10. 61.242 - 2(c)(1) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 61 .242 - 2(c)(2) Recordkeeping When each leak is detected, a weatherproof and readily visible identification,

marke d with the equipment identification number shall be attached to the leaking equipment. 61.246(b)(1) When each leak is detected as specified in §§ 61.242

– 2, 61.242

– 3, 61.242

– 7, 61.242

– 8, and 61.135, the following requirements apply: (3) The identification on equipment, except on a valve, may be removed after it has been repaired. 61.246(b)(3) When each leak is detected, record the instrument and operator identification numbers and the equipment identification number. 61.246(c)(1) When each leak is dete cted, record the date the leak was detected and the dates of each attempt to repair the leak. 61 .246(c)(2) Recordkeeping When each leak is detected record ‘‘Above 10,000’’ if the maximum instrument

reading measured by the methods specified in § 61.2 45(a) after each repair attempt is equal to or greater than 10,000 ppm 61.246(c)(4) When leak is detected record ‘‘Repair delayed’’ and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. 61.246(c)(5 ) When each leak is detected, record the signature of the owner or operator (or designate) whose decision it was that repair could not be effected without a process shutdown. 61 .246(c)(6)Page 16 of 77 When each leak is detected the following information shall be reco rded in a log and shall be kept for 2 years in a readily accessible location: (7) The expected date of successful repair of the leak if a leak is not repaired within 15 calendar days. 61 .246(c)(7) When each leak is detected, the following information sh all be recorded in a log and shall be kept for 2 years in a readily accessible location: (8) Dates of process unit shutdowns that occur while the equipment is unrepaired. 61 .246(c)(8) When each leak is detected, the following information shall be record ed in a log and shall be kept for 2 years in a readily accessible location: (9) The date of successful repair of the leak. 61 .246(c)(9) **G.2a 40 CFR 61 Subpart V, Pumps Equipped with Dual Mechanical Seal System**  Limitation/ 61.242 - 2(d) Each pump equipped with a dual mechanical seal system that includes a barrier fluid Standard system is exempt from the requirements of §61.242 - 2(a) and (b), provided that the

requirements listed in §61.242 - 2(d) are met. **G.2b 40 CFR 61 Subpart V, Pumps Designated as “no**  **detectable emissions”** Limitation/ 61.242 - 2(e) Any pump designated, as described in §61.246(e)(2), for no detectable emissions, as Standard indicated by an instrument reading of less than 500 ppm above background, is exempt from the

requirements of §61.242 - 2(a), (c), and (d) as long as the pum p meets the requirements listed in §61.242 - 2(e). **G.2c 40 CFR 61 Subpart V, Pumps with a Closed**  **- vent System**  Limitation/ 61.242 - 2(f) If any pump is equipped with a closed - vent sy stem capable of capturing and Standard transporting any leakage from the seal or seals to a process or fuel gas system or to a

control device that complies with the requirements of §61.242 - 11, it is exempt from the requirements of §61.242 - 2(a - e). **G.2 d**  **40 CFR 61 Subpart V, Pumps that are Unsafe to Monitor** Limitation/ 61.242 - 2(g) Any pump that is designated, as described in §61.246(f)(1), as an unsafe - to - mo nitor Standard pump is exempt from the monitoring and inspection requirements of §61.242 - 2(a) and (d)(4 - 6) as

long as the requirements of §61.242 - 2(g) are met. **G.2e 40 CFR 61 Subpart V, Unmanned Plant Site**  Limitation/ 61.242 - 2(h) Any pump that is located within the boundary of an unmanned plant site is exempt Standard from the weekly visual inspection requirement of §61.242 - 2(a)(2) and (d)(4) of this

section, and the daily requirements of paragraph §61.242 - 2(d)(5), provided that each pump is visually inspected as often as practicable and at least monthly. **G.3 40 CFR 61 Subpart V, Compressors**  Limitation/ 61.242 - 3(a) Each compressor shall be equipped with a seal system that includes a barrier fluid Standard system and that prevents leakage of process fluid to atmosphere, except as provided in §61.242 - 1(c)

and §61.242 - 3(h) and (i).Page 17 of 77

Monitoring Each compressor seal system required shall follow the requirements of §61.242 -

3(b)(1 - 3). 61.242 - 3(b) The barrier fluid shall not be in VHAP service and, if the compressor is covered by standards under 40 CFR part 60, shall not be in VOC service. 61.242 - 3(c) Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal system, barrier fluid system, or both. 61.242 - 3(d) Each sensor shall be checked daily or shall be checked daily or shall be equipped with an audible alarm unless the compressor is located within the boundary of an unmanned plant site. 61.242 - 3(e)(1) The owner or operator shall determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. 61.242 - 3(e)(2) If the sensor indicates failure of the seal system, the barrier fluid system, or both based on the criterion determined under §61.242 - 3(e)(2), a leak is detected. 61.242 - 3( f) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in §61.242 - 10. 61.242 - 3(g)(1) A first attempt at repair shall be made no later than 5 calendar days af ter each leak is detected. 61.242 - 3(g)(2) A compressor is exempt from the requirements of §61.242 - 3(a) and (b) if it is equipped with a closed - vent system to capture and transport leakage from the compressor drive shaft back to a process or fuel gas syst em or to a control device that complies with the requirements of §61.242 - 11, except as provided in §61.242 - 3(h)(i). 61.242 - 3(h)

**G.4 40 CFR 61 Subpart V, Pressure Relief Devices in gas/vapor service**  Limitation/ 61.242 - 4(a) Except during pressure releases, each pressure relief device in gas/vapor service shall be Standard operated with no detectable emissions, as indicated by an instrument reading of less than 500ppm

above background, as measured by the method specified in §61.245(c ). Monitoring After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions, as indicated by the instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in §61.242 - 10. 61.242 - 4(b)(1) No later than 5 calendar days after the pressure release, the pressure relief device shall be monitored to confirm the condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as measured by the method specified in §61.245(c). 61.242 - 4(b)(2) Any pressure relief device that is routed to a process or fuel gas system or equipped with a closed - vent system capable of capturing and transporting leakage from the pressure relief device as described in §61.242 - 11 is exempt from the requirements of §61.242 - 4(a) and (b). 61.242 - 4(c) Any pressure relief device that is equipped with a rupture disk upstream of the pr essure relief device is exempt from the requirements of §61.242 - 4(a) and (b), provided the owner or operator complies with §61.242 - 4(d)(2). 61.242 - 4(d)(1) After each pressure release, a new rupture disk shall be installed upstream of the pressure relief device as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in §61.242 - 10. 61.242 - 4(d)(2)Page 18 of 77

**G.5 Subpart V, Sampling connecting systems**  Limitation/ 61.242 - 5(a) Each sampling connection system shall be equ ipped with a closed - purge system or Standard closed vent system, except as provided in § 61.242

– 1(c). Gases displaced during filling

of the sample container are not required to be collected or captured. Monitoring Each closed - purge system or closed - vent system as required in paragraph (a) shall: (1) Return the purged process fluid directly to the process line (2) Collect and recycle the purged process fluid; or (3) Be designed and operated to capture and transport all the purged process fluid to a contro l device that complies with the requirements of §61.242 - 11; or (4) Collect, store and transport the purged process fluid to any of the systems or facilities listed in §61.242 - 5(b)(4)(i iii). 61.242 - 5(b)(1 - 4)

In - situ sampling systems and sampling systems without purges are exempt from the requirements of §61.242 - 5(a) and (b). 61.242 - 5(c) **G.6 40 CFR 61 Subpart V, Open**  **- ended valves or lines**  Limitation/ 61.242 - 6(a)(1) Each open - ended valve or line shall be equipped with a cap, blind flange, plug, or a Standard second valve, except as provided in § 6 1.242

– 1(c). Monitoring Open - ended valves or lines. The cap, blind flange, plug, or second valve

shall seal the open end at all times except during operations requiring process fluid flow through the open - e nded valve or line. 61.242 - 6(a)(2) Open - ended valves or lines. Each open - ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. 61.242 - 6(b) When a double block and bleed system is being used, the bleed valve or line ma y remain open during operations that require venting the line between the block valves but shall comply with paragraph (a) at all other times. 61.242 - 6(c) Open - ended valves o r lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt from the requirements of §61.242 - 6(a - c). 61.242 - 6(d) Open - ended valves or lines containing materials which would autocatalytically polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and bleed system as specified in §61.242 - 6(a - c) are exempt from the requirements of §61.242 - 6(a - c). 61.242 - 6(e)

**G.7 40 CFR 6**  **1 Subpart V, Valves** Limitation/ 6 1.242 - 7(a) Each valve shall be monitored monthly to detect leaks by the method specified in Standard §61.245(b) and shall comply with paragraphs (b)

– (e), except as provided in paragraphs (f), (g), and (h) of

this section , § 61.243

– 1 or § 61.243

–2, and § 61.242

– 1(c). Monitoring Test methods and procedures. Monitoring, as required in §§ 61.242, 61.243,

61.244, and 61.135, shall comply with the following requirements: (1) Monitoring shall comply with Method 21 of append ix A of 40 CFR part 60. 61.245(b)(1)Page 19 of 77 Test methods and procedures. Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the following requirements: (2) The detection instrument shall meet the performance criteria of Referenc e Method 21. 61.245(b)(2) Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the following requirements: (3) The instrument shall be calibrated before use on each day of its use by the procedures specified in Reference Me thod 21. 61.245(b)(3) Calibration gases shall be: (i) Zero air (less than 10 ppm of hydrocarbon in air); and (ii) A mixture of methane or n - hexane and air at a concentration of approximately, but less than, 10,000 ppm methane or n - hexane. 61.245(b)(4) Monitoring shall comply with the following requirements: (5) The instrument probe shall be traversed around all potential leak interfaces as close to the interface as possible as described in Reference Method 21. 61.245(b)(5) Any valve for which a leak i s not detected for 2 successive months may be mo nitored the first month of every quarter, beginning with the next quarter, until a leak is detected. 61.242 - 7(c)(1) If a leak is detected, the valve shall be monitored monthly until a leak is not detected f

or 2 successive months. 61.242 - 7(c)(2) Monitoring When a leak is detected, it shall be repaired as soon as practicable, but no

later than 15 calendar days after the leak is detected, except a provided in §61.242

– 10. 61.242 - 7(d)(1) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 61.242 - 7(d)(2) Any valve that is designated for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background as described in §61.246( e)(2), is exempt from the requirements of §61.242 - 7(a) if the valve meets the requirements in §61.242 - 7(f)(1 - 3). 61.242 - 7(f) Unsafe to monitor valves are exempt is personnel would be in danger and there is a written plan to monitor during safe times. 61. 242 - 7(g) Difficult to monitor valves are exempt if monitoring personnel must be elevated 2 meters, in existing process unit, follows yearly written monitor plan. 61.242 - 7(h) **G.8 40 CFR 61 Subpart V, Pressure Relief Services in liquid service and conne**  **ctors** Limitation/ 61.242 - 8(a) Pressure relief devices in liquid service and flanges and other connectors shall be Standard mo nitored within 5 days by the method specified in § 61.245(b) if evidence of a potential leak is

found by visual, audible, olfactory , or any other detection method. Monitoring Test methods and procedures. Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the following requirements: (1) Monitoring shall comply with Method 21 of appendix A of 40 CFR p art 60. 61.245(b)(1) Test methods and procedures. Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the following requirements: (2) The detection instrument shall meet the performance criteria of Reference Method 21. 61. 245(b)(2) Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135, shall comply with the following requirements: (3) The instrument shall be calibrated before use on each day of its use by the procedures specified in Reference Method 21. 61.245(b)(3)Page 20 of 77 Calibration gases shall be: (i) Zero air (less than 10 ppm of hydrocarbon in air); and (ii) A mixture of methane or n - hexane and air at a concentration of approximately, but less than, 10,000 ppm methane or n hexane. 61.245(b)(4) Monitoring shall comply with the following requirements: (5) The instrument probe shall be traversed around all potential leak interfaces as close to the interface as possible as described in Reference Method 21. 61.245(b)(5) Pressure relief devices in liquid service an d flanges and other connectors. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in §61.242

– 10. 61.242 - 8(c)(1) Pressure relief devices in liquid service and flanges and other connectors. The first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 61.242 - 8(c)(2) **G.9 40 CFR 61 Subpart V, Surge Control Vessels and bottoms receivers**  Limitation/ 6 1.242 - 9(a) ach surge control vessel or bottoms receiver that is not routed back to the process and Standard: that meets the conditions specified in table 1 or table 2 of 40 CFR 61 Subpart V shall be equipped

with a closed - vent system capable of capturing and transporting any leak age from the vessel back to the process or to a control device as described in §61.242 - 11, except as provided in §61.242 - 1(c). **G.10 40 CFR 61 Subpart V, Closed**  **- vent systems and control devices**  Limitation/ 61.242 - 11(a) Owners or operators of close - vent sys tems and control devices used to comply with Standard provisions of this subpart shall comply with the provisions of this section, except as

provided in §61.242 - 1(c). Monitoring Vapor recovery systems shall be designed and operated to recover organic

vapors vented to them with an efficiency of 95 percent or greater or to an exit concentration of 20 ppmv, whichever is less stringent. 61.242 - 11(b) Enclosed combustion devices shall be designed and operated to reduce the VHAP emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 ppmvd, corrected to 3 percent oxygen, whichever is less stringent, or to provide a minimum residence time of 0.50 seconds at a mi nimum temperature of 760 o C. 61.242 - 11(c)

Flares that are used for compliance with 40 CFR 61 Subpart V shall comply with the requirements of §60.18. 61.242 - 11(d) Owners or operators of control devices that are used to comply with the provisions of 40 CFR 61 Subpart V shall monitor these control devices to ensure that they are operated and maintained in conformance with their design. 61.242 - 11(e) Except as provided in §61.242 - 1 1(i - k), each closed vent system shall be inspected according to the procedures and schedule specified in §61.242 - 11(f)(1) or (2) . 61.242 - 1 1(f) Leaks, as indicated by an instrument reading greater than 500 ppmv above background or by visual inspections, shall be repaired as soon as practicable except as provided in §61.242 - 11(h). 61.242 - 11(g)Page 21 of 77 Delay of repair of a closed vent sy stem for which leaks have been detected is allow ed if the repair is technically infeasible without a process unit shutdown, or if the owner or operator determines that emissions resulting from immediate repair would be greater than the fugitive emissions l ikely to result from the delay of the repair. Repair of such equipment shall be complete by the end of the next process unit shutdown. 61.242 - 11(h)

If a vapor collection system or closed vent system is operated under a vacuum, it is exempt from the inspe ction requirements of §61.242 - 1 1(f)(1)(i) and (2). 61.242 - 11(i) Any parts of the closed vent system that are designated, as described in paragraph as described in §61.242 - 1 1(l)(1) as unsafe - to - inspect are exempt from the inspection requirements of §61. 242 - 1 1(f)(1)(i) and (2) if they comply with the requirements listed in §61.242 - 1 1(j)(1 - 2). 61.242 - 11(j) Any parts of the closed vent system that are designated, as described in §61.242 - 1 1(l)(2) as difficult - to - inspect are exempt from the inspection re quirements of §61.242 - 1 1(f)(1)(i) and (2) if they comply with the requirements listed in §61.242 - 11(k)(1 - 2). 61.242 - 11(k) Closed vent systems and control devices used to comply with provisions of 40 CFR 61 Subpart V shall be operated at all times when emissions may be vented to them. 61.242 - 11(m) Recordkeepin g The owner or operator shall record the information listed in §61.242 - 1 1(l)(1 - 5) 61.242 - 11(l) **H. 40 CFR 61 Subpart FF National Emission Standard for Benzene Waste Operations**  Equipment subject t o 40 CFR 61 Subpart FF must comply with the requirements of 40 CFR 61 Subpart A - General Provisions except where Subpart FF provides for explicit exemptions to Subpart A. The 40 CFR 61 Subpart A - General Provisions are found in Attachment F of this permi t. The provisions of this subpart apply to owners and operators of hazardous waste treatment, storage, and disposal facilities that treat, store, or dispose of hazardous waste generated by any facility listed in §61.340(a). The waste streams at hazardous wa ste treatment, storage, and disposal facilities subject to the provisions of this subpart are the benzene - containing hazardous waste from any facility listed in §61.340(a). 61.340

An owner or operator of a facility at which the total annual benzene quantity from facility waste is less than 10 megagrams per year (Mg/yr) shall be exempt from the requirements of §61.342(b) and (c). The total annual benzene quantity from facility waste is the sum of the annual benzene quantity for each waste stream at the fa cility that has a flow - we ighted annual average water content greater than 10 percent or that is mixed with water, or other wastes, at any time and the mi xture has an annual average water content greater than 10 percent. 61.342(a)

Each owner or operator of a facility at which the total annual benzene quantity from facility waste is =10 Mg/yr as determined in §61.342 (a) shall manage and treat the facility waste as follows: (1) For each waste stream that contains benzene, including (but not limited to) organ ic waste streams that contain < 10 % water and aqueous waste streams, even if the wastes are not discharged to an individual drain system, the owner or operator shall be subject to the provisions of §61.342(c)(1)(i

– iii). 61.342(c)(1)

A wa ste stream is e xempt from §61.342 (c)(1) provided that the owner or operator demonstrates initially and, thereafter, at least once per year that the flow - weighted annual average benzene concentration for the waste stream is less than 10 ppmw as determined by the procedur es specified in §61.355(c)(2) or §61.355(c)(3). 61.342(c)(2)Page 22 of 77

Rather than treating the waste onsite, an owner or operator may elect to comply with §61.342(c)(1)(i) by transferring the waste offsite to another facility where the waste is treated in accordan ce with the requirements of §61.342(c)(1)(i). The owner or operator transferring the waste shall abide by the listed provisions. 61.342(f) Compliance with this subpart will be determined by review of facility records and results from tests and inspections using methods and procedures per §61.355. 61.342(g) The owner or operator shall meet the standards for each container in which waste is placed in accordance with §61.342(c)(1)(ii). 61.345(a) Each cover and all openings shall be visually inspected initia lly and quarterly thereafter to ensure that they are closed and gasketed properly. 61.345(b) Except as provided in §61.350, when a broken seal or gasket or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 61.345(c) Except as provided in§61.348(a)(5), the owner or operator shall treat the waste stream in accordance with 61.348(a)(1 - 5). 61.348(a) The owner and operator shall demonstrate that each treatment process or wastewater treatment system unit, except per §61.348(d), achieves the appropriate conditions specified in §61.348(a) or (b) in accordance with 61.348(c)(1 - 2). 61.348(c) A treatment process or waste stream is in compliance with the requirements of this subpart and exempt from the requirements of §61.348(c) provided that the owner or operator documents that the treatment process or waste stream is in compliance with other regulatory requirements per 61.348(d)(1 - 5) 61.348(d) Except as specified in §61.348(e)(3), if the treatment process or wastewater treatment system unit has any openings (e.g., access doors, hatches, etc.), all such openings shall be sealed (e.g., gasketed, latched, etc.) and kept closed at all times when waste is being treated, e xcept during inspection and maintenance as listed in this section. 61.348(e) Except for treatment processes complying with §61.348(d), the Administrator may request at any time an owner or operator demonstrate that a treatment process or wastewater treatm ent system unit meets the applicable requirements specified in §61.348(a) or (b) by conducting a performance test using the test methods and procedures as required in §61.355. 61.348(f) The owner or operator of a treatment process or wastewater treatment system unit that is used to comply with the provisions of this section shall monitor the unit in accordance with the applicable requirements in §61.354. 61.348(g) Except as provided in §61.350, if visible defects are observed during an inspection, or if o ther problems are identified, or if detectable emissions are measured, a first effort to repair the closed vent system and control device shall be made as soon as practicable but no later than 5 calendar days after detection. Repair shall be completed no l ater than 15 calendar days after the emissions are detected or the visible defect is observed. 61.349(g)

Specifications for monitoring non - regenerative carbon adsorption systems. 61.354(d) An owner or operator shall determine the total annual benzene quantity from facility waste by the procedures in accordance with 61.355(a)(1 - 6). 61.355(a) For purposes of the calculation required by §61.355(a), an owner or operator shall determine the annual waste quantity at the point of waste generation, unless otherwise provided in §61.355(b) (1), (2), (3), and (4), by one of the methods given in §61.355 (b) (5) through (7). 61.355(b) For the purposes of the calculation required by §61.355(a), an owner or operator shall determine the flow - we ighted annual average benz ene concentration in a manner that meets the requirements given in §61.355 (c)(1) using either of the methods given in §61.355 (c)(2) and (c)(3). 61.355(c) Each owner or operator shall maintain records that identify each waste stream at the facility subje ct to this subpart, and indicate whether or not the waste stream is controlled for benzene emissions in accordance with this subpart. In addition the owner or operator shall maintain the records as required under sections 1 - 6 of 61.356(b)(1 - 6). 61.356(b)Page 23 of 77

An owner or operator transferring waste off - site to another facility for treatment in accordance with §61.342(f) shall maintain documentation for each offsite waste shipment that includes the listed information. 61.356(c) An owner or operator using a treatment process or wastewater treatment system unit in accordance with §61.348 shall maintain the records in accordance with §61.356(e)(1 - 4). The documentation shall be retained for the life of the unit. 61.356(e) For each treatment process and wastewater treatment system unit operated to comply with §61.348, the owner or operator shall maintain documentation that includes the listed information. 61.356(i) **H.1 40 CFR 61 Subpart FF, Control device, thermal oxidizer**  a. Limitation/ 61.349(a)(2)(i) Enclosed c ombustion device shall be designed and operated with a minimum Standard residence time of 0.5 seconds and a minimum temperature of 760 C

Monitoring Quarterly visual inspections for each closed - vent system and control

device including ductwork, piping, connections to cover and control devices. 61.349(f)(ii) The owner or operator of a control device that is used to comply with the provisions of this section shall monitor the control device in accordance with §61.354(c). 61.349(h) Except for a treatment process or waste stream complying with §61.348(d), the owner or operator shall monitor each treatment process or wastewater treatment system unit to ensure the unit is properly operated and maintained by the monitoring procedures in accordance with secti ons 1 - 2 of 61.354(a) 61.354(a) Inspect control device monitoring equipment daily. 61.354(c) Install a temperature sensor with a continuous recorder in thermal vapor incinerator 61.354(c)(1) Owners or operators using a closed - vent system that contains any bypass line that could divert a vent stream from a control device used to comply with the provisions of this subpart shall do the listed items. 61.354(f) Reporting Submit quarterly certifications that all of the required inspections

have been carried out 61.357(d)(6) Submit quarterly reports recording each three hour period when average temperature of gas stream in combustion zone of thermal vapor incinerator is greater than 28 deg Celsius below the design combustion zone temperature. 61.357(d)(7)(i v)(A) Submit annual report that summarizes all inspections required by 61.342 - 61.345 during which detectable emissions are measured or a problem that could result in benzene emissions is identified, including repair or corrective taken. 61.357(d)(8)

R ecordkeeping Maintain records onsite for at least two years. 61.356(a)

Maintain engineering design documentation for all control equipment installed on the waste management unit for the life of the equipment. Also maintain control device records require by paragraph (f) 61.356(d)Page 24 of 77 Retain a signed statement certifying design of the closed - vent system and control device for the life of the device 61.356(f)(1) Maintain visual inspection records required by 61.343 through 61.347 that identify a problem whi ch could result in benzene emissions 61.356(g) For each control device, the owner or operator shall maintain documentation that includes the following information regarding the control device operation: (1) Dates of startup and shutdown of the closed - vent system and control device. 61.356(j)(1)

Recordkeeping Record description and explanation of parameters to be monitored

to ensure compliance, keep for life of source. 61.356(j)(2) Record periods when the closed vent system and control device are not operated as designed, including any valve car - seal or closure mechanism that is broken or when vapors are not routed to control device. 61.356(j)(3) If a thermal vapor incinerator is used, then the owner or operator shall maintain continuous records of the temperature of the gas stream in the combustion zone of the incinerator 61.356(j)(4) An owner or operator shall demonstrate compliance of each flare in accordance with (a)(2)(iii) of this section. 61.349(d) Testing Demonstrate control device ach ieves required control efficiency by

using engineering calculations as specified in 61.356(f) or performance test as specified in 61.355. 61.349(c) Initial visual inspections for each closed - vent system and control device including ductwork, piping, conn ections to cover and control devices. 61.349(f)(i)

b. Limitation/ 61.349(b) Must operate all closed - vent systems and control devices when waste is in the system. Standard Monitoring None required. N/A Reporting None required. N/A Recordkeeping F or each control device, the owner or operator shall maintain documentation that includes the following information regarding the control device operation: (1) Dates of startup and shutdown of the closed - vent system and control device. 61.356(j)(1)

c. Limitation/ 6 1.350(a) Delay of repair will be allowed if the repair is technically impossible without a Standard complete or partial facility or unit shutdown. Monitoring Must make delayed repairs before end of the next facility or unit shutdown. 61.350(b) **H.2 40 CFR 61 Subpart FF, Closed**  **- vent system**  a. Limitation/ 61.349(a)(1)(i) Must have closed - vent system and control device with no detectable emissions Standard (No readings >500 ppmv above background). (Per 61.349(a)(1)(iii) gauging and samp ling devices

must be gas - tight)Page 25 of 77

Monitoring One or more devices which vent directly to the atmosphere may be used on the closed - vent system provided each device remains in a closed, sealed position during normal operations 61.349(a)(1)(iv) Quarterly visual inspections for each closed - vent system and control device including ductwork, piping, connections to cover and control devices. 61.349(f)(ii) Reporting None required. N/A Recordkeeping Maintain records onsite for at least two years. 61.356(a) Maintain visual inspection records required by 61.343 through 61.347 that identify a problem which could result in benzene emissions 61.356(g) Testing Initial visual inspections for each closed - vent system and control device including ductwork, piping, c onnections to cover and control devices. 61.349(f)(i) Monitor emissions for compliance with no detectable emissions. Use Method 21 from Appendix A of 40 CFR 60. 61.355(h) b. Limitation/ 61.349(a)(1)(i) Must have closed - vent system and control device with no detectable emissions Standard (No readings >500 ppmv above background). (Per 61.349(a)(1)(iii) gauging and sampling

devices must be gas - tight) Reporting Submit quarterly certifications that all of the required inspections have been carried out. 61.357(d)(6) Submit annual report that summarizes all inspections required by 61.342 - 61.345 during which detectable emissions are measured or a problem that could result in benzene emissions is identified, including repair or corrective taken. 61.357( d)(8) Recordkeeping Maintain records for each test of no detectable emissions 61.356(h)

c. Limitation/ 61.349(b) Must operate all closed - vent systems and control devices when waste is in the Standard: sy stem. Recordkeeping For each control devic e, the owner or operator shall maintain documentation that includes the following information regarding the control device operation: (1) Dates of startup and shutdown of the closed - vent system and control device. 61.356(j)(1)

**H.3 40 CFR 61 Subpart FF,**  **Tank** a. Limitation/ 61.342(b) Must be in compliance with requirements of paragraphs c through h of this section Standard within 90 days of effective date.Page 26 of 77

Reporting Submit a report to the Administrator summarizing regulatory status

of each waste stream. This report must be submitted within 90 days after January 7, 1993 or by initial startup for a new source that starts after January 7,1993 61.357(a) If the total annual benzene quantity from facility waste is less than 1 Mg/yr, then the owner or operato r shall submit to the Administrator a report that updates the information listed in paragraphs (a)(1) - (a)(3) of this section whenever there is a change in the process generating the waste stream that could cause the total annual benzene quantity from facil ity waste to increase to 1 Mg/yr or more. 61.357(b)

If the total annual benzene quantity from facility waste < 10 Mg/yr but is equal to or greater than 1 Mg/yr, then the owner or operator shall submit to the Administrator a report that updates the inform ation listed in (a)(1) - (a)(3) of this section. The report shall be submitted annually and whenever there is a change in the process generating the waste stream that could cause the total annual benzene quantity from facility waste to increase to 10 Mg/yr o r more. 61.357(c)

Unless a waiver of compliance is granted, submit a cert that the equip necessary to comply with these stds has been installed and that the required initial inspections or tests have been carried out. Submit by date of initial startup fo r new source. 61.357(d)(1) Submit annual report updating information in paragraphs (a)(1) through (a)(3). 61.357(d)(2) b. Limitation/ 61.343(a)(1)(i)(A) No detectable emissions (>500 ppm above background) from tank cover or Standard openings. (Per 61 .349(a)(1)(iii) gauging and sampling devices must be gas tight except when

gauging or sampling is taking place.) Monitoring No detectable emissions (>500 ppm above background) from tank

cover or openings. (Per 61.349(a)(1)(iii) gauging and sampling de vices must be gas - tight) 61.343(a)(1)(i)(A) Monitor once per year in accordance with Method 21 61.343(a)(1)(i)(A) Reporting Submit quarterly certifications that all of the required inspections

have been carried out 61.357(d)(6) Submit annual report th at summarizes all inspections required by 61.342 - 61.345 during which detectable emissions are measured or a problem that could result in benzene emissions is identified, including repair or corrective taken. 61.357(d)(8) Recordkeeping Maintain records o nsite for at least two years. 61.356(a)

Maintain records for each test of no detectable emissions 61.356(h) Testing Monitor emissions for compliance with no detectable emissions.

Use Method 21 from Appendix A of 40 CFR 60. 61.355(h) c. Limitation/ 61 .343(a)(1)(i)(B) Close and seal tank openings. (Per 61.349(a)(1)(iv), pressure relief valves can Standard be used when necessary to prevent physical damage or permanent deformation of tank) Testing Complete quarterly visual inspections of openings f or closure and tightness 61.343(c)(ii) One or more devices which vent directly to the atmosphere may be used on the closed - vent system provided each device remains in a closed, sealed position during normal operations 61.349(a)(1)(iv)Page 27 of 77

d. Limitation/ 61.34 3(a)(1)(i)(B) Close and seal tank openings. (Per 61.349(a)(1)(iv), pressure relief valves can Standard be used when necessary to prevent physical damage or permanent deformation of tank) Monitoring Complete initial visual inspections of openings for c losure and tightness. 61.343(c)(i) Repair broken seals or gaskets and fix emission leaks on tanks within 45 calendar days of problem identification. 61.343(d) Reporting Submit quarterly certifications that all of the required inspections have been carri ed out 61.357(d)(6) Submit annual report that summarizes all inspections required by 61.342 - 61.345 during which detectable emissions are measured or a problem that could result in benzene emissions is identified, including repair or corrective taken. 6 1.357(d)(8) Recordkeeping Maintain records onsite for at least two years. 61.356(a) Maintain visual inspection records required by 61.343 through 61.347 that identify a problem which could result in benzene emissions . 61.356(g)

e. Limitation/ 6 1.350(a) Delay of repair will be allowed if the repair is technically impossible without a Standard complete or partial facility or unit shutdown. Monitoring Must make delayed repairs before end of the next facility or unit shutdown. 61.350(b) **H.4 40 CFR 61 S**  **ubpart FF, Control device, carbon absorption system that does not regenerate the carbon bed directly**  a. Limitation/ 61.349(a)(2)(ii) The vapor recovery system must have > or = 95 weight % control of organics or > Standard or = 98 weight % control of benz ene. Monitoring Quarterly visual inspections for each closed - vent system and control

device . including ductwork, piping, connections to cover and control devices. 61.349(f)(ii) Inspect control device monitoring equipment daily. 61.354(c) Monitor c ontrol device daily and replace carbon when breakthrough is indicated, or replace the carbon at a regular predetermined time interval. 61.354(d) Recordkeeping Maintain records onsite for at least two years. 61.356(a) Maintain engineering design documentation for all control equipment installed on the waste management unit for the life of the equipment. Also maintain control device records require by paragraph (f) 61.356(d) Retain a signed statement certifying design of the closed - vent system and co ntrol device for the life of the device . 61.356(f)(1)Page 28 of 77 Retain documentation of engineering calculations used to determine control device (carbon absorption system that does not regenerate the carbon bed directly) perf for the life of the control device. M aintain a design analysis for the control device. 61.356(f)(2)( i)(G) Maintain visual inspection records required by 61.343 through 61.347 that identify a problem which could result in benzene emissions . 61.356(g) For each control device, the owner or o perator shall maintain documentation that includes the following information regarding the control device operation: (1) Dates of startup and shutdown of the closed vent system and control device. 61.356(j)(1) Record description and explanation of parame ters to be monitored to ensure compliance, keep for life of source. 61.356(j)(2) Testing Demonstrate control device achieves required control efficiency by using

engineering calculations as specified in 61.356(f) or performance test as specified in 61.355 . 61.349(c) Initial visual inspections for each closed - vent system and control device including ductwork, piping, connections to cover and control devices. 61.349(f)(i) b. Limitation/ 61.349(a)(2)(ii) The vapor recovery system must have 95 weight % contro l of organics or 98 Standard weight % control of benzene. Reporting Submit quarterly certifications that all of the required inspections have been carried out . 61.357(d)(6) Submit annual report that summarizes all inspections required by 61.342 - 6 1.345 during which detectable emissions are measured or a problem that could result in benzene emissions is identified, including repair or corrective taken. 61.357(d)(8) Recordkeeping Record periods when the closed vent system and control device are not operated as designed, including any valve car - seal or closure mechanism that is broken or when vapors are not routed to control device. 61.356(j)(3) If a carbon adsorber is not regenerated directly on site, owner shall record times of monitoring, breakthrough, and r eplacement. 61.356(j)(10)

c. Limitation/ 61.349(b) Must operate all closed - vent systems and control devices when waste is in the Standard: sy stem. Recordkeeping For each control device, the owner or operator shall maintain documentation that i ncludes the following information regarding the control device operation: (1) Dates of startup and shutdown of the closed - vent system and control device. 61.356(j)( 1 ) d. Limitation/ 61.350(a) Delay of repair will be allowed if the repair is technicall y impossible without a Standard: complete or partial facility or unit shutdown. Monitoring Must make delayed repairs before end of the next facility or unit shutdown. 61.350(b) **H.5 40 CFR 61 Subpart FF, Treatment process**  a. Limitation/ 61.348(a)(1) (iii) Must have waste treatment process (combustion unit) that destroys 99% ofPage 29 of 77

Standard: benzene. Monitoring Install, calibrate, operate, maintain, and inspect the data each day

from a CEM for a process parameter that indicates proper system operation. 61.354(a) Recordkeeping Maintain records onsite for at least two years. 61.356(a) Retain a signed statement certifying design of the waste treatment process unit for the life of the unit . 61.356(e)(1) Maintain documentation of the dates of start up and shut down of the treatment process . 61.356(i)(1) The owner or operator shall maintain documentation that includes the following information regarding the unit operation: (5) Periods when the unit is not operated as designed. 61.356(i)(5) Testin g The treatment process is exempt from performance testing since Ash Grove has been issued a final permit under 40 CFR 266 subpart D. 61.348(d)(2) b. Limitation/ 61.348(e) Openings shall be sealed and kept closed at all times except during inspection and Standard: maintenance Monitoring Complete initial and quarterly visual inspections of openings for closure and tightness. 61.348(e)(1) Install, calibrate, maintain, and operate continuous pressure monitor . 61.354(g) Recordkeeping Maintain records on site for at least two years. 61.356(a) Maintain records of monitoring device and records of all periods when pressure is greater than atmospheric . 61.356(m)

c. Limitation/ 6 1.350(a) Delay of repair will be allowed if the repair is technically impossible without a Standard: complete or partial facility or unit shutdown. Monitoring Must make delayed repairs before end of the next facility or unit . shutdown. 61.350(b) Recordkeeping Maintain documentation of the dates of start up and shut down of the treatment process . 61.356(i)(1) The owner or operator shall maintain documentation that includes the following information regarding the unit operation: (5) Periods when the unit is not operated as designed. 61.356(i)(5)

**I. 40 CFR Part 63 Subpart A Ge**  **neral Provisions** Applicable citations for 40 CFR 63 Subpart A are provided in Attachment G. **J. 40 CFR 63 Subpart DD**  **General Requirem ents**  **Applicable Requirem ent (Summary)**  Equipment subject to 40 CFR 63 Subpart DD must comply with the requirements of 40 CFR 63 Subpart A

– General Provisions except where Subpart DD provides for explicit exemptions to Subpart A. The 40 CFR 63 Subpart A - General Provisions are found in Attachment G of this permit.Page 30 of 77

The provisions of this subpart apply to the owner and operator of a plant site for which both of the conditions specified in §63.680(a)(1) and (a)(2) are applicable according to the definitions and exemptions presented in §63.680(b) - (d), (f), and §63.681 and the dates in §63.680(e). 63.680 Definitions 63.681 Thi s section applies to owners and operators of affected sources as defined in §63.680(c) of this subpart. 63.683(a) Air emissions from each affected source must be controlled per one of the requirements in §63.683(b)(1) (i) - (iii). 63.683(b)(1) Exempted off

- site material management units. An off - site material management unit is exempted from the requirements specified in §63.683(b) when the unit meets any one of the exemptions provided in §63.683(c)(1 - 5). 63.683(b)(2) The provisions of this section apply to the control of air emissions from tanks for which §63.683(b)(1)(i) references the use of this section for such air emission control. 63.685(a) The owner or operator shall control air emissions from each tank subject to this section in accordance with the applicable requirements listed in §63.685(1) - (4). 63.685(b) Owners and operators controlling air emissions from a tank using Tank Level 2 controls shall use one of the requirements listed as §63.685(1) - (5). 63.685(d) The owner or operator who controls t ank air emissions by venting to a control device shall meet the requirements in §63.685(g)(1 - 3). 63.685(g) The provisions of this section apply to the control of air emissions from containers for which §63.683 (b)(1)(i) references the use of this section for such air emission control. 63.688(a) The owner or operator shall control air emissions from each container subject to this section in accordance with the requirements, as applicable to the container, of §63.688(1) - (3). 63.688(b) The provisions of thi s section apply to the control of air emissions from transfer systems for which §63.683 (b)(1)(i) references the use of this section for such air emission control. 63.689(a) For each transfer system that is subject to this section, but is not an individua l drain system, the owner or operator shall control air emissions by using one of the listed systems in §63.689(c)(1) through (c)(3). 63.689(c) The provisions of this section apply to the control of air emissions from equipment leaks for which §63.683 (b) references the use of this section for such air emission control. 63.691 The provisions of this section apply to closed - vent systems and control devices used to control air emissions for which another standard references its use. 63.693(a) For each clos ed - vent system and control device used to comply with this section, the owner or operator shall meet the requirements of §63.693 (1) - (8). 63.693(b) Closed - vent system requirements. The vent stream required to be controlled shall be conveyed to the control device by either of the closed - vent systems detailed in § 63.693 (1) and (2). 63.693(c) Carbon adsorption control device requirements 63.693(d) The carbon adsorption system shall be designed and operated to achieve one of the performance specifications detailed in §63.693(d)(1) (i) or (ii). 63.693(d)(1) **Applicable Requirem ent (Summary)**  The owner or operator shall demonstrate that the carbon adsorption system achieves the performance requirements of §63.693(d)(1) by one of the methods detailed in §63.6 93 (d)(2)(i) or (ii). 63.693(d)(2) The owner or operator must monitor the operation of the carbon adsorption system in accordance with the requirements of § 63.695(e) using one of the continuous monitoring systems specified in §63.693(d)(3) (i) - (iii). Mon itoring of non - regenerative carbon adsorption systems using continuous monitoring systems is not required when the carbon is replaced on a regular basis per §63.693(d)(4)(iii). 63.693(d)(3)Page 31 of 77

The owner or operator shall manage the carbon used for the carbon adsorption system, as described in §63.693(i) - (iii). 63.693(d)(4) Flare control device requirements. 63.693(h) The flare must be designed and operated in accordance with 40 CFR 63.11(b) 63.693(h)(1) The owner or operator must demonstrate that the flare achieves the requirements in §63.693 (h)(1) by the procedures in §63.693 (h)(2)(i) or (ii). 63.693(h)(2) The owner or operator must monitor the operation of the flare using a heat sensing monitoring device that continuously detects the presence of a pi lot flame in accordance with the listed parameters. 63.693(h)(3) This section specifies the testing methods and procedures required for this subpart to determine HAP and VOHAP concentrations, rates, and limits for the items listed in §63.694(1) - (12). 63.6 94 This section specifies the inspection and monitoring procedures required to perform the items listed in §63.695 (1) - (4). 63.695(a) Tank Level 2 fixed roof and floating roof inspection requirements. 63.695(b) Fixed roof provisions 63.695(b)(3) The owner or operator will repair each defect detected during an inspection in the listed manner. 63.695(b)(4) Owners and operators that use a closed vent system in accordance with the provisions of §63.693 shall meet the inspection and monitoring requirements of this section. 63.695(c) The owner or operator subject to this subpart shall comply with the record keeping requirements in §63.10 under 40 CFR 63 subpart A - General Provisions that are applicable to this subpart as specified in Table 2. 63.696(a) The o wner or operator of a control device subject to this subpart shall maintain the records in accordance with 40 CFR 63.10. 63.696(b) Each owner or operator using a fixed roof to comply with the tank control requirements specified in §63.685(g) shall prepare and maintain the records specified in this section. 63.696(e) An owner or operator shall record, on a semiannual basis, the information specified in §63.696(g)(1 - 2) for those planned routine maintenance operations that would require the control device no t to meet the requirements of §63.693 (d - h), as applicable. 63.696(g) An owner or operator shall record the information specified in §63.696(h)(1 - 3) for those unexpected control device system malfunctions that would require the control device not to meet the requirements of §63.693 (d - h), as applicable. 63.696(h) The owner or operator of a control device used to meet the requirements of §63.693 shall submit the reports specified in this section to the Administrator. 63.697(b) Delegation of authority 63.6 98 **J.1 40 CFR 63 NESHAP -**  **DD, Equipment leak** a. Limitation/ Standard 63.683(d) Must control equipment leaks from each equipment component of a transfer system by implementing leak detection and control measures per 63.69 1 (40 CFR 61 Subpart V)

b. Limitation/ 63.691(b)(1) Must control equipment leaks from each equipment component of a transfer system Standard: b y implementing leak detection and control measures per 63.69 1 (40 CFR 61 Subpart V) Monitoring Monitoring and Recordkeeping in accordance with 40 CFR 61 Subpart V 40 CFR 61 Sections 61.242 - 61.247 Subpart VPage 32 of 77

Monitoring Monitoring and Recordkeeping in accordance with 40 CFR 61 Subpart V Sections 61.242 - 61.247 40 CFR 61 Subpart V **J.2 40 CFR 63 NESHAP**  **- DD, Transfer syst**  **em** a. Limitation/ 63.689(c)(2) Transfer system must consist of continuous hard piping, joints to be welded or Standard: flanged with gasket and bolts. Monitoring an annual walkthrough b. Limitation/ 63.697(a)(1) Must submit notifications in 63.9(b)( 2) before October 9, 1999 Standard: Monitoring Compliance with other sections of this rule demonstrates compliance with this rule. No Regulatory Requirements c. Limitation/ 63.697(a)(2) Must submit notifications in 63.10 Standard: Monitoring Comp liance with other sections of this rule demonstrates compliance with this rule. No Regulatory Requirements **K. 40 CFR Part 63 Subpart PP**  **General Requirem ents**  **Applicable Requirem ent (Summary)**  Equipment subject to 40 CFR 63 Subpart PP must comply with th e requirements of 40 CFR 63 Subpart A

– General Provisions except where Subpart PP provides for explicit exemptions to Subpart A. The 40 CFR 63 Subpart A - General Provisions are found in Attachment G of this permit. The provisions of this subpart apply t o the control of air emissions from containers for which another subpart of 40 CFR parts 60, 61, or 63 references its use in accordance with the definitions in §63.921. 63.920 The owner or operator shall inspect containers using Container Level 1 controls in accordance with the procedures specified in §63.926 (a) of this subpart. 63.922(e) For the purpose of compliance with §63.922(b)(1), containers shall be used that meet the applicable U.S. DOT regulations on packaging hazardous materials for transporta tion as detailed in §63.922(f)(1) - (3). 63.922(f) **Applicable Requirem ent (Summary)**  This section applies to owners and operators subject to this subpart and required to control air emissions from containers using Container Level 2 controls. 63.923(a)

The o wner or operator shall inspect containers using Container Level 2 controls in accordance with the procedures specified in §63.926(a). 63.923(e) For the purpose of compliance with §63.923(b)(1), containers shall be used that meet the applicable U.S. DOT re gulations on packaging hazardous materials for transportation as detailed in §63.923(f)(1) - (3). 63.923(f)Page 33 of 77

**40 CFR 63 MACT –**  **PP, Containers –**  **Level 1 Controls (Emissions from containers for which**  **another subpart of 40 CFR 60, 61 or 63 references this subp**  **art)** a. Limitation/ Standard: 63.922(b) Containers required to use Level 1 controls shall meet the U.S. Department of

Transportation regulations, be equipped with a cover and closure device that form a continuous barrier over the container, or be equippe d with an open - top container in which an organic vapor - suppressing barrier is placed on or over the regulated - material in the container such that no regulated - material is exposed to the atmosphere. Monitoring None required at this time Reporting None required at this time Recordkeeping None required at this time Testing None required at this time b. Limitation/ 63 .922(d) All covers and closure devices shall be maintained in the closed position except as Standard: provided in 63.922(d)(1) - (5). Monitoring If regulated material is in the container at the time the owner/operator

first accepts possession and not emptied within 24 hours, the owner/operator shall visually inspect the container and its cover and closure device. This inspection shal l occur on or before the container is accepted at the facility. If a defect is detected the repair shall be conducted as specified in 63.926(a)(3); 63.926(a)(1)

If a container containing regulated material remains unopened at the facility site for one ye ar or more, the container shall be inspected initially and at least once every calendar year. If a defect is detected the repair shall be conducted as specified in 63.926(a)(3). 63.922(a)(2)

**K.2 40 CFR 63 MACT**  **– PP, Containers**  **– Level 2 Controls (Emissions f**  **rom containers**  **for which another subpart of 40 CFR 60, 61 or 63 references this subpart)**  a. Limitation/ 63.923(b)(1) & (2) Containers required to use Level 2 controls shall meet the U.S. Department of Standard: Transportation (DOT) regulations, operate with no detectable emissions as defined in 40

CFR 63.921, or have demonstrated within the previous twelve months that the container is vapor - tight Monitoring None required at this time Reporting None required at this time Recordkeeping None required at this time Testing Demonstrate no detectable organic emissions at each potential leak interface on the cover and associated closure device using the procedures specified in Method 21 of 40 CFR part 60, appendix A. 63.925(a) Demonstrate vapor - tightness in accordance with Method 27 of 40 CFR part 60, Appendix A. 63.925(b) b. Limitation/ 63.923(c) Transfer of regulated - material into or out of Level 2 Container shall be conducted so as Standard: to minimize exposure of the regulated material to the atmo sphere.Page 34 of 77

Monitoring None required at this time Reporting None required at this time Recordkeeping None required at this time Testing None required at this time c. Limitation/ 63.923(d) All covers and closure devices shall be maintained in the closed po sition except as Standard: provided in 63.923(d)(1) - (5).

Monitoring If regulated material is in the container at the time the owner/operator first

accepts possession and not emptied within 24 hours, the owner/operator shall visually inspect the container and its cover and closure device. This inspection shall occur on or before the container is accepted at the facility. If a defect is detected the repair shall be conducted as specified in 63.926(a)(3); 63.926(a)(1)

If a container containing regulated material remains unopened at the facility site for one year or more, the container shall be inspected initially and at least once every calendar year. If a defect is detected the repair shall be conducted as specified in 63.926(a)(3). 63.922(a)(2)

**K.3 40 CFR 63 MACT**  **– PP, Containers**  **– Level 3 Controls (Emissions from**  **containers for which another subpart of 40 CFR 60, 61 or 63 references this subpart)**  Limitation/ 63.924(b) Containers required to use Level 3 controls shall be vented directly through a Standard: closed - vent system to a control device or vented inside an enclosure which is exhausted through a

closed - vent system to a control device. Monitoring The closed - vent system shall be inspected and monitored in accordance

with § 63.693 i n 40 CFR part 63, subpart DD

– National Emission Standards for Hazardous Air Pollutants from Off - Site Waste and Recovery Operations. 63.926(b) Reporting Prepare and submit reports required for closed - vent systems and control

devices in accordance with § 6 3.693 in 40 CFR part 63, subpart DD

– National Emission Standards for Hazardous Air Pollutants form Off - Site Waste and Recovery Operations. 63.928(a) Recordkeeping Maintain records of the most recent set of calculations performed to

verify that the enclos ure meets the criteria of a permanent total enclosure as specified in “Procedure T

– Criteria for and Verification of a Permanent or Temporary Total Enclosure” under 40 CFR 52.741, Appendix B. 63.927(a)(1) Recordkeeping Maintain records required for the c losed - vent system and control device

in accordance with the requirements of § 63.693 in 40 CFR part 63, subpart DD

– National Emission Standards for Hazardous Air Pollutants form Off - Site Waste and Recovery Operations. 63.927(a)(2)Page 35 of 77 

### Section L **Subpart EE E**  **- National Emission Standards for Hazardous Air Pollutants** 

**from Hazardous Waste Combustors** Note: All regulatory

references pertain to 40 CFR Part 63, unless otherwise noted. **1.0 Modes of Operation**  The hazardous waste combustion system has four Subpart EEE compliance modes of operation:

Mode 1: raw mill on with no hazardous waste in the chamber; Mode 2: raw mill off with no hazardous waste in the chamber; Mode 3: raw mill on with hazardous waste in the chamber; and Mode 4: raw mill off with hazardous waste in the chamber. In accordance with 40 CFR 63.1 209(q)( 1), Ash Grove may elect to operate in modes 1 and 2 when not burning hazardous waste and the hazardous waste residence time has expired. Both modes contain the otherwise applicable requirements o f 40 CFR Part 63, Subpart LLL. These requirements become applicable requirements under Subpart EEE and are presented in this section. While operating under different modes of operation: 1. The facility

must document in the operating record a change in a mod e of operation and compliance with the operating limits for an alternative mode of operation (63.1204(d)(1 )(ii)). 2. The facilit

y shall calculate averages under the different modes of operation per alternate monitoring approved by

the EPA on July

9, 2001 (63 .1209(g) and 63.8(f)). Comparable fuels, used oils and other non-hazardous wastes that are blended with hazardous are considered hazardous wastes and shall be burned under the definition and requirements of hazardous wastes. **2.0 Em** **ission Standards and Op erating Limits**  The owner or operator shall comply with the applicable section of 40 CFR Part 63, Subpart A (Attachment **G)** as identified in Table 1 to 40 CFR Part 63, Subpart EEE, 40 CFR Part 63, Subpart EEE and when operating in modes 1 and 2, the otherwis e applicable standards of 40 CFR Part 63, Subpart LLL in lieu of the substantive requirements of 40 CFR Part 63, Subpart EEE. The facilit

y shall comply

with the EPA- approved alternative monitoring methods and procedures dated February 6, 2001 and July 9, 2 001. Operating parameter limits were established through performance testing and/or equipment manufacturer specifications and ensure compliance with the emission standards. The operating parameter limits are included in the most recent Notification of Compliance (NOC). These operating parameters may

change if performance testing is conducted per Subsection 3.0. Inthe event of subsequent changes to the NOC, the permittee shall:Page 36 of 77

a. operate in accordance with the most recent NOC (based on postmark date o f the submittal), and b. together with the revised NOC, submit a permit modification application to incorporate any necessary revision s into the Title V permit (K.A.R. 28 - 19 - 513, 40 CFR 63.1206, 40 CFR 63.1210, and 40 CFR 70.7(e)(2)(v)) . The EPA finalized Phase I replacement standards for Subpart EEE on October 12, 2005. The facilit y will comply

with the replacement standards per the timeframe specified in the regulation. **2.1 Destruction and Removal Efficiency**  Emissions Limitation The owner or operator shall achieve a destruction and removal efficiency (DRE) of 99.99% (63. 1204(c)(1 )). Monitoring The facility

shall demonstrate continuous compliance with the DRE standards by comply ing with the operating parameter limits specified in the most recent Notifica tion of Compliance. Modes 3 and 4 1. Minimum combustion chamber temperature profile on a three -hour rolling time block (63.1209(j)(1)); 2. Maximum gas flowrate on an hourly rolling average (63.1209(j)(2)); 3. Maximum MCBP LWDF feedrate on an hourly rolling average (63.1209(j)(3)); 4. Maximum DDC LWDF feedrate (including BWF)on an hourly rolling average (63.1209(j)(3)); and 5. Maximum SEI SWDF feedrate on an hourly rolling average (63.1209(j)(3)). **2.2 Dioxins/Furans**  Emissions Limitation The owner or operator shall not cause combustion gases to be emitted into the atmosphere that contain dioxins/furans: i Emissions in excess of 0.20 ng TEQ/dscm corrected to 7 percent oxy gen (63. 1204(b)(1)(i)); or ii Emissions in excess of 0.40 ng TEQ/dscm corrected to 7 percent oxygen provided that the combustion gas temperature at the inlet to the initial dry p articulate matter control device is 400  F or lower based on the average of the test run average temperatures (63. 1204(b)(1)(ii)).Page 37 of 77

Monitoring The facilit y shall demonstrate continuous compliance with the dioxin/furans emission standards by complying with the operating parameter limits specified in the most recent Notification of Compliance. Modes 1 and 2 1. Maximum inlet gas temperature to the kiln/raw mill baghouse on a three -hour rolling average (63.1350(f)(2)); 2. Maximum inlet gas temperature to the by pass baghouse on a three -hour rolling average (63.1350(f)(2)); and 3. Maximum inlet gas temperature to the coal mill baghouse on a three -hour rolling average (63.8(g) alternative to 63.1350(f)(2)). Modes 3 and 4 1. Maximum inlet gas temperature to the kiln/raw mill baghouse on an hourly rolling average (63.1209(k)(1 )(i)); 2. Maximum inlet gas temperature to the by pass baghouse on an hourly rolling average (63.1209(k)(1 )(i)); 3. Maximum inl et gas temperature to the coal mill baghouse on an hourly rolling average (63.1209(g) alternative to 63.1209(k)(1 )(i)); 4. Minimum combustion chamber temperature profile on a three -hour rolling time block (63.1209(g) alternative to 63.1209(k)(2)); 5. Maximum stack gas flowrate on an hourly rolling average (63.1209(k)(3)(i) & (ii)); 6. Maximum MCBP LWDF feedrate on an hourly rolling average (63.1 209(k)(4)(i) & (ii)); 7. Maximum DDC LWDF feedrate (including BWF) on an hourly rolling average (63. 1209(k)(4)(i) & ii)) ; and 8. Maximum SEI SWDF feedrate on an hourly rolling average (63. 1209(k)(4)(i) & (ii)). **2.3 Mercury**  Emissions Limitation The owner or operator shall not cause combustion gases to be emitted into the atmosphere that contain mercury

in excess of 120  g/dscm corrected to 7 percent oxygen. The facility

shall demonstrate compliance with the mercury emission standards by

comply ing with the following equation (63. 1204(d)(2)) on an annual basis based on a one - ye ar block average performed June 12 of every year:Page 38 of 77

Where: C HG,Total

C HG,millo n C HG,millo ff

Tmillon

Tmillo ff = Time -weighted average concentration of mercury

= Extrapolated emission concentration of mercury with the raw mill on line (operating mode 3)

= Extrapolated emission concentration of mercury with the raw mill off line (operating mode 4)

= Time when kiln gases are routed through the raw mill (operating mode 3)

= Time when kiln gases are not routed through the raw mill (operating mode 4) Monitoring The facility

shall demonstrate compliance with the mercury emission standards by comply ing with the operating parameter limits specified in the most recent Notification of Compliance. Modes 3 and 4 1. Maximum total mercury feedrate on a 12 -hour rolling average (63.1209(l)).                     millon milloff millon millon HG, millon milloff milloff milloff HG, Total HG, T T T C T T T C C **2. 4**  **Particulate Matter** Emissions Limitation The owner or operator shall not cause combustion gases to be emitted into the atmosphere that contain particulate matter in excess of 0.15 kg/Mg dry feed and opacity g reater than 20 percent (63.1 204(b) (7)). Monitoring The facilit y shall demonstrate continuous compliance with the particulate matter emission standards by

comply ing with the operating parameter limits specified in the most recent Notification of Compliance. Modes 1 and 2 1. Continuously

monitor the average opacity for each six -minute block period with a Continuous Opacity

Monitor S ystem (COMS) (63.1350(c)(3)). Modes 3 and 4 1. Continuously monitor the average opacity for each six -minute block period with a COMS (63.1209(a)(1 )(ii)(B)); 2. Maximum stack gas flowrate on an hourly rolling average (63.1209(m)(2)(i) & (ii)).Page 39 of 77

3. Continuously monitor the particulate matter emission rate with a Continuous Emission Monitor System (CEMS). The compliance date and performance specification for the PM CEMS has not be en established. **2.5 Semivolatile Metals and Low** **- Volatile Metals**  Emissions Limitation The owner or operator shall not cause combustion gases to be emitted into the atmosphere that contain: i. Lead and cadmium in excess of 180  g/dscm, combined emissions, corrected to 7 percent oxygen (63.1204(b)(3)); or ii. Arsenic, beryllium, and chromium in excess of 54  g/dscm, combined emissions, corrected to 7 percent oxygen (63.1204(b)(4)). Monitoring The facility

shall demonstrate continuous compliance with the semivolatil e metals and lowvolatile metals emission standards by c omplying with the operating parameter limits specified in the most recent Notification of Compliance. Modes 3 and 4 1. Maximum inlet gas temperature to the kiln/raw mill baghouse on an hourly rolling a verage (63.1209(n)(1)); 2. Maximum inlet gas temperature to the by pass baghouse on an hourly rolling average (63.1209(n)(1)); 3. Maximum inlet gas temperature to the coal mill baghouse on an hourly rolling average 63.1209(g) alternative to (63.1209(n)( 1)); 4. Maximum feedrate of semivolatile metals on a 12 - hour rolling average limit (63. 1209(n)(2)); 5. Maximum feedrate of low volatile metals on a 12 - hour rolling average limit (63.1209(n)(2)); 6. Maximum pumpable low volatile metal feedrate on a 12 -hour rolling average (63. 1209(n)(2)); 7. Maximum total chlorine and chloride feedrate on a 12 -hour rolling average (63. 1209(n)(4)); and 8. Maximum stack gas flowrate on an hourly rolling average (63.1209(n)(5)). **2.6 Hydrocarbons**  Emissions Limitation The owner or operator shall not cause combustion gases to be emitted into the atmosphere that contain total hy

drocarbons in excess of 10 ppm, dry b asis, corrected to 7 percent oxygen, and reported as propane (63.1204(b)(5)(A)(2)).Page 40 of 77

Monitoring The facilit y shall demonstrate continuous compliance with the total hy drocarbon emission standards by comply ing with the operating parameter limits specified in the most recent Notification of Compliance. Modes 3 and 4 1. Continuously

monitor the maximum total hy drocarbon emission rate at the preheater tower on an hourly

rolling average with a CEMS (63.1204(b)(5)(A)(2)). 2. Continuously

monitor the maximum total hy drocarbon emission rate at the alkali by pass baghouse outlet on an hourly rolling average with a CEMS (63.1204(b)(5)(A)(2)). **2.7 Hydrochlo**  **ric Acid and Chlorine Gas** Emissions Limitation The owner or operator shall not cause combustion gases to be emitted into the atmosphere that contain hy drochloric acid and chlorine gas in excess of 86 ppm, combined emissions, expressed as hy drochloric acid equivalents, dry basis and corrected to 7 percent oxygen (63.1204(b)(6)). Monitoring The facility shall demonstrate continuous compliance with the hy drochloric acid and chlorine emission standards by

comply ing with the operating parameter limits specified in the most recent Notification of Compliance. Modes 3 and 4 1. Maximum chlorine/chloride feedrate on a 12 -hour rolling average (63.1209(o)(1)); and 2. Maximum stack gas flowrate on an hourly rolling average (63.1209(o)(2)). **2.8 Combustion System Leaks**  Emi ssions Limitation The owner or operator shall control the combustion system leaks of hazardous air pollutants by maintaining the maximum combustion chamber pressure lower than ambient pressure (63. 1206(c)(5)). Monitoring The facility

shall demonstrate c ontinuous compliance with the limitation by comply ing with the operating parameter limits specified in the most recent Notification of Compliance. Modes 3 and 4 1. Maximum combustion chamber kiln differential pressure; and 2. Maximum combustion chamber tower di fferential pressure.Page 41 of 77

**3.0 Performance Testing**  An initial performance test was conducted from December 11 through 15, 2001 and March 11 through 14, 2002. Modes 1 and 2 In accordance with the provisions of 63.1209(q)(1)(ii), the facility has identified the otherwise applicable requirements of Subpart LLL emission standards, monitoring and compliance, notification, reporting, and recordkeeping for modes 1 and 2. S pecific provisions for each of these otherwise applicable requirements are listed in the following sections of this permit:

**Otherwise Applicable Requirements for Modes 1 and 2** Emission Standards Section 2.2 (D/F) and Section 2.4 (PM) Monitoring and Compliance Section 2.2 (D/F), Section 2.4 (PM), Section 4.0, and the most recent Notification of Comp liance Performance Testing Section 3.0 Operating Requirements Section 5.4 Reporting and Recordkeeping Requirements Section 6.0 The facility

must comply with 63.1206(b)(ii) and 1209(q) to meet the otherwise applicable requirements of Subpart LLL for performance testing, as listed below . Ash Grove submitted a waiver request on May

28, 2004 for the dioxin/furan testing due on June 11, 2004; the EPA issued a waiver on June 16, 2004. Per EPA’s July

9 , 2001 compliance determination, when Ash Grove is require d to test for modes 3 and 4 (burning hazardous waste), the results may be used to demonstrate compliance in modes 1 and 2. P ursuant to the provisions of 63.1206(b)(ii), 6 3.1209(q) and this waiver, all future testing for modes 1 and 2 is waived in lieu of testing performed in modes 3 and 4 according to all the specific provisions of Subpart EEE, so long as the source remains subject to Subpart EEE. The APCD inlet temperature limits established for modes 3 and 4 will be used to establish the respective temperature limits for modes 1 and 2. The temperature limits shall be established as the average of the test run averages, in accordance with 63.1209(k)(1) and 63.1349(b)(3)(iv). Modes 3 and 4 Periodic comprehensive performance tests and confirmatory p erf ormance tests are not required until the EPA promulgates permanent replacement standards. If the facility c onducts testing for other reasons (such as a change in operation that adversely effects emissions), a test plan shall be submitted in accordance with 40 CFR 63.1207 and submitted at least one ye ar before the performance test and performance evaluation are scheduled to begin in accordance with 40 CFR 63.1207(e)(1)(i). The facility must also submit a notification of intention to conduct the comprehensive performance test at least 60 calendar days before the test is scheduled to begin. Current operating parameter limits are waived during testing if approved in the test plan according to 40 CFR 63.1207(h). The facility must submit a Notification of Complian ce within 90 days of the completion of testing documenting compliance or noncompliance with the emission standards and continuous monitoring requirements and identifying operating parameter limits.Page 42 of 77

The coal mill baghouse inlet temperature OPL is not to be established by testing and is set at 20 0  F per the alternate monitoring approved by the EPA on July

9, 2001 (63.1209(g) and 63.8(f)(2)). **4.0 Continuous Monitoring Requirements**  Inaccordance with 63.1209(a) and (b) and approved alternatives, the facility is required to use the following to monitor the stack gas:

 two total hydrocarbon (THC) Continuous Emissions Monitoring Sy stems (CEMS) to demonstrate and monitor compliance with the plant specific alternative THC standard approved on February 6, 2001;

 Continuous Opacity M onitoring Sy stem (COMS) to demonstrate and monitor compliance with the opacity s tandard. The COMS shall be maintained and operated in accordance with the requirements of 63.8(c);

 when applicable, PM CEMS to demonstrate and monitor complian ce with the PM standard (the compliance date and performance specification for the PM CEMS has not been established); and

 the facility

must operate two oxygen CEMS. The inlet temperatures for the kiln/raw mill baghouse, by pass baghouse and the coal mill baghouse are each measured with a thermocouple system located in the inlet duct to the respective baghouses. The recorder response range must include zero and 1.5 times the average temperature of the exhaust gas (63.1 350(f)(1)(i)). These thermocouples shall meet the requirements of 63.1209(b)(1) and 63.1350(f). The minimum combustion chamber temperature profile which is an alternative to the combustion chamber ex it temperature is also measured with a thermocouple, which is located in the outlet duct from th e in - line calciner. This thermocouple shall meet the requirements of 63.1209(c)(1). The maximum combustion chamber pressure is monitored to control the combustion system fugitive emissions by m aintaining the differential pressure lower than ambient pressu re using an instantaneous monitor in accordance with 63.1206(c)(5)(i)(B). The pressure is monitored with pressure transmitters located at rotary kiln raw material feed hood, rotary

kiln fuel firing hood and in the tower gas exit ducts. **5.0 Operating Requ**  **irements 5.1**  **Startup, Shutdown and Malfunction Plan** The owner or operator shall develop and implement a written startup, shutdown and malfunction plan (SSM) in accordance with 40 CFR 63.6(e)(3). During the periods of startup, shutdown and malfunction, th e owner or operator shall comply with the SSM plan in accordance with procedures specified in 40 CFR 63.1206(c)(2). The SSM plan dated June 5, 2001, is incorporated into the permit by reference. The facility shall describe any

r evisions to the plan in the semiannual report. Revisions to the SSM plan are automaticall y incorporated by reference and do not require a permit modification.Page 43 of 77

Revisions to the SSM plan must be recorded in the operating record and detailed in the periodic SSM reports. **5.2 Automatic**  **Waste Feed Cutoff System Operability** The owner or operator shall operate the hazardous waste combustor with a functioning Automatic Waste Feed Cutoff System per 40 CFR63.1206(c)(3). The purpose of the AWFCO system is to instantaneously and automatically stop the flow of hazardous waste derived fuel to the kiln in the event that any of the OPL s in the most recent Notification of Compliance are exceeded. During an AWFCO period, hazardous waste fuel will not be used; other fuels will be used to replace the thermal energy supplied from the waste - derived fuel (WDF) to maintain the sy stem operation along with the sy stem’s capacity to destro y constituents of WDF remaining in the sy stem. Ina ccordance with the Operation and Maintenance Plan, the AWFCO system and a ssociated alarms operability must be verified weekly . The facility

s hall take corrective measures to minimize future AWFCOs and record the findings and corrective measures in the operating record. AWFCOs also appl y when burning hazardous waste during startup and shutdown. **5.3 Operator Training and Certification**  The facility

must establish and implement training and, as appropriate, certification programs for all categories of personnel whose activities may be expected to directly

affect emissions of hazardous air pollutants from the source in accordance with 40 CFR 63.1 206(c)(6). The operator training and certification program must be recorded in the facility operating record. **5.4 Operation and Maintenance Plan**  The facility

s hall operate according to an operation and maintenance (O&M) plan as required under 40 CFR 63.1206(c)(7). The O&M plan describes in detail procedures for operation, inspection, maintenance, and corrective action measures for all components of the sy stem, including the combustion system of the kiln and associated pollution control equipment that could affect emissions of regulated HAPs. The inspections must be conducted at least once per year. The O&M plan shall ensure compliance with the operation and maintenance requirements of 40 CF R 63.6(e), 63.1206(c)(7) and 63.1350(a). The plan must be recorded in the operating record. The O&M plan dated May 22, 2001, is incorporated in the permit by reference. Revisions to the O&M plan are automatically incorporated by

reference and do not requi re a permit modification. Revisions must be recorded in the operating record. **5.5 Feedstream Analysis Plan**  The facility

must develop and implement a feedstream analy sis plan (FAP) and record it in the operating record in accordance with 63.1209(c)(2). Th e plan must specify at a minimum: i. the parameters for which each feedstream is analyzed to ensure compliance with applicable operating parameter limits; ii. whether the analy sis will be obtained by performing sampling and analysis or by other methods;Page 44 of 77

iii. how the analy sis will be used to document compliance with applicable feedrate limits; iv. the test methods used to obtain the analy ses; v. the sampling methods used to obtain a representative sample of each feedstream to be analyzed; and vi. the frequency with which initial analysis of the feedstream will be reviewed or repeated to ensure that the analy sis is accurate and up to date. The feedstream analysis plan dated October 17, 2001, is incorporated in the permit by reference. The facility shall notify KDHE within 7 calendar days after the revision is put into effect. Revisions to the FAP are automatically i ncorporated by

reference and do not require a permit modification. **6.0 Reporting and Recordkeeping Requirements**  The owner or operator shall meet all applicable report ing and recordkeeping requirements as specified in 40 CFR 63.1211, 63.1354, 63.1355 and Subpart A. These records shall be maintained in accordance with the requirements of 63.10(b)(1) and made available for inspection upon request. The facility

shall subm it, at minimum, the reports of the following to KDHE: 1. Periodic startup, shutdown and malfunction reports postmarked by the 30 th day following the end of each calendar half or as established otherwise by KDHE (63.10(d)(5)(i)); 2. Only

i f the source ex ceeds a relevant emission standard, an immediate startup, shutdown and malfunction reports consisting of a telephone call (or facsimile transmission) to KDHE within 2 working day s after commencing actions inconsistent with the plan, followed by a letter, postmarke d within 7 working day s after the end of the event (63.10(d)(5)(ii)); 3. Ex cess emissions and continuous monitoring system performance report and summary report semiannually

(63.1 0(e)(3)); 4. Ex cessive exceedances reports within 5 calendar day s of the 1 0 th ex c eedance during a 60 - day

block period (63.1206(c)(3)(vi)); and 5. Any

c hanges in design, operation and maintenance practices of the source in a manner that may

a dversely

a ffect compliance with any e mission standard that is not monitored with a CEMS at least 60 day s prior to the change (63.1206(b)(5)). Send copies of submissions required by this section to Hazardous Waste Section in Bureau of Waste Management in addition to submissions to Bureau of Air and Radiation.Page 45 of 77

The facility

shall keep, at minimum, the records of the following: 1. Documentation of mode of operation changes (63.1 204(d)( 1 )(ii)); 2. Documentation of compliance demonstration with the emission averaging requirements (63.1 204(d)(2)(ii)); 3. Corrective measures for any AWFCO that results in an exceedance of an emission standard or operating parameter limit (63.1 206(c)(3)(v)); 4. Documentation and results of the AWFCO operability test procedures and results (63.1 206(c)(3)(vii); 5. Differential pressure readings used for control of combustion system leaks (63.1 206(c)(5)(ii)); 6. Operator training and certification program (63.1206(c)(6)); 7. Operation and maintenance plan (63.1206(c)(7)(i)(D)); 8. Feedstream analys is plan (63.1209(c)(2)); 9. The value of the parameter for each feedstream by sampling and analysis or other method (63.1209(c)(4)(i)); 10. The mass or volume flowrate of each feedstream, except process air and natural gas, by a CMS (63.1209(c)(4)(ii)); 11. The mass feedrate of the parameter per unit time (63. 1209(c)(4)(iii)).Page 46 of 77

The following tab le details the fuels and feed locations approved for the in - line kiln/raw mill system: **P ERMITTED**  **F UEL**  **T YPES AND**  **F EED**  **L OCATIONS** 

**Fuel Feed Location**  **Perm itted Fuel Types** **C o** **a l** **P e** **t r** **o l** **e u** **m C** **o k** **e N** **a t** **u r** **a l** **G a** **s L** **W D** **F 1** **U s** **e d** **O i** **l 2** **S W** **D F** **3 B** **W F** **4 T** **D F** **5** Approved Operating Mod

e 1,2,3,4 1,2,3,4 1,2,3,4 3,4 1,2,3,4 3,4 3,4 3,4 Kiln MCBP ✓ ✓ ✓ ✓ ✓ In Line Calciner ✓ ✓ Down Draft Calciner ✓ ✓ ✓ ✓ ✓ ✓ Solid Entry Interlock ✓ ✓ Tire Entry Interlock ✓ 1. LWDF = Liquid Waste Derived Fuel. This feedstream may be composed of any RCRA approved hazardous waste and may also contain non -hazardous liquid wastes mixed with hazardous waste liquids, including solids and sludges that can be blended and fed through the liquid fuel storage tanks and feed nozzles. 2. Used Oil = non - hazardous used oil handled under the provisions of 40 CFR 279 through the LWDF system. 3. SWDF = Solid Waste Derived Fuel. This feedstream is containerized in pails and may be composed of any RCRA approved hazardous waste codes. This feedstream may also include containerized non - hazardous waste solid s. 4. BWF = Bulk Waste Fuel. This may be composed of any non - containerized solid material that contains no free liquids. This feedstream may include RCRA approved hazardous waste and non- hazardous waste solids. 5. TDF = Tire Derived Fuel. This feedstre am is composed of whole passenger and truck tires.Page 47 of 77

**M. 40 CFR Part 63 Subpart LLL**  Equipment subject to 40 CFR 63 Subpart LLL must comply with the requirements of 40 CFR 63 Subpart A

- General Provisions except where Subpart LLL provides for explicit exempt ions to Subpart A. The 40 CFR 63 Subpart A - General Provisions are found in Attachment G of this permit. **M.1 All equipment subject to 40 CFR 63, Subpart LLL**  a. Limitation/ Part 63 Subpart LLL Standard. Standard: Monitoring Reporting Submit result s of all PM performance tests within 60 days of the test, Opacity tests within 30 days of the test 63.1354(b)(1),(2) Submit progress reports by the dates specified in written extension of compliance. 63.1354(b)(3) State that actions taken during startups, shutdowns, or malfunctions were consistent with the SSMP in semi - annual report and K.A.R. 28 - 19 - 11. 63.1354(b)(4) K.A.R. 28 - 19 - 11 Report actions taken during startup, shutdown, or malfunction that were inconsistent with the SSMP, if an exceedance of the standard occurs (63.6(e)(1)(iv)), within 2 working days (telephone or fax) and follow up with letter within 7 days 63.1354(b)(5) Recordkeeping Maintain files required by this section for at least 5 years. 63.1355(a) Testing Repeat performance tests e very 5 years. 63.1349(c) b. Limitation/ 63.1350(b) Failure to comply with O and M plan is a violation of the standard Standard: Monitoring Monitor according to O and M plan. 63.1350(j) **M.2 Source Specific**  **- all CMS systems required by 40 CFR 63, S**  **ubpart LLL** Limitation/ Part 63 Subpart LLL - CMS Requirements Standard: Monitoring Reporting Report results of CMS performance evaluation. 63.1354(b)(6) Report results of COMS performance evaluation. 63.1354(b)(7) Submit excess emissions and CMS performance report whenever source is not in compliance with applicable limits. 63.1354(b)(8) Submit excess emissions and CMS performance report with summary report if CMS downtime is > 10% of total operating time. 63.1354(b)(10)Page 48 of 77

**M.3 40 CFR 63 NESH** **AP -**  **LLL, Clinker Cooler (major source; new or existing), Effective June 14, 2002)**  a. Limitation/ 63.1345(a)(1) PM < or = 0.10 lb per ton of feed to kiln: Standard Testing Demonstrate initial compliance by performance testing 63.1349(a) Conduct performance tests in accordance with 63.1349(b)(1) - (4) 63.1349(b) b. Limitation/ 63.1345(a)(2) Opacity < or = 10% except during startups, shutdowns, & malfunctions Standard: Monitoring Submit operations and maintenance plan as part of a Title V applicati on 63. 1350(a)(1 - 3) Monitor opacity at each point where emissions are vented. 63.1350(d) Opacity < or = 10% for each 6 - minute average except during startups, shutdowns, & Malfunctions 63.1350(d)(3) Operate a COM at the outlet of the clinker cooler PM control device. 63.1350(d)(1) Testing Demonstrate initial compliance by performance testing 63.1349(a) Demonstrate opacity using COM during Method 5 performance tests. 63.1349(b)(1)(v) **M.4 40 CFR 63 NESHAP**  **- LLL, Raw or Finish Mill, Existing, Effectiv**  **e June 14, 2002** Limitation/ 63.1347 Opacity < or = 10% except during startups, shutdowns, & malfunctions Standard: Monitoring Conduct daily 6 - minute visible emissions test (Method 22) of mill

sw eep and air separator PMCDs, unless a BLDS is installed. I f visible emissions are observed, initiate corrective action within 1 hr, conduct follow - up Method 22 test within 24 - hours and then 30 - mi nute Method 9 if further emissions. 63.1350(e)

If a BLDS is installed, the BLDS must be certified by the manufacturer to detect PM emissions at concentrations of 10 mg per actual cubic meter or less. 63.1350(m)(1) If a BLDS is installed, the sensor must provide output of relative PM emissions. 63.1350(m)(2) If a BLDS is installed, the BLDS must have an alarm that activates automatically when it detects a significant increase in PM emissions. 63.1350(m)(3) If a BLDS is installed, the presence of an alarm condition should be apparent to facility . 63.1350(m)(4) If a BLDS is installed, For a positive pressure fabric f ilter, each compartment should have a bag leak detector. For a negative - pressure or induced - air fabric filter, the bag leak detector must be installed downstream of the fabric filter. 63.1350(m)(5) If a BLDS is installed, it must be operated, adjusted, and maintained based on manufacturer's written specifications and recommendations. 63.1350(m)(6)Page 49 of 77 If a BLDS is installed, the baseline output of the system must be established by adjusting the range and averaging period of the device, and establishing the alarm set points and delay time. 63.1350(m)(7) If a BLDS is installed, after the initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be adjusted except as specified in the operations and maintenance plan. 63.135 0(m)(8) If a BLDS is installed, the fabric filter must be maintained and operated such that the bag leak detector alarm condition does not exist mo re than 5 percent of the total operating time for a 6 - mo nth block period. 63.1350(m)(9)

If a COMS is used in Lieu of M22/M9s, it must be installed at the outlet of the APCD and in accordance with PS - 1. Compliance is demonstrated when the 6 minute block average is less than 10% . 63.1350(m) Testing Conduct an initial 3 - hour (30 6 - minute averages) Method 9 test . 63.1349(b)(2)(ii) **M.5 40 CFR 63 NESHAP**  **- LLL, Open or Partially Enclosed**  **- Conveying System**  **Transfer Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs**  **– With the potential to emit particulate matter**  Limitation/ 63.1348 Opacity < or = 10% except during startups, shutdowns, & malfunctions Standard: Monitoring Conduct 1 - min visible emissions (VE) test using Method 22. If

visible emissions are observed during any Method 22 test, conduct a 6 - mi nute M ethod 9 within one hour. See Opacity Monitoring Section for more details. 63.13 50(a)(4)(i - vii) Testing Conduct an initial 3 - hour (30 6 - minute averages) Method 9 test.

The test time may be reduced to 1 - hour if there are no readings greater than 10% opaci ty and there are no more than three readings of 10% opacity are observed in the first hour. 63.1349(b)(2)(i)(ii)

**M.6 40 CFR 63 NESHAP**  **- LLL, NON EMITTING**  **- Conveying System Transfer**  **Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging**  Limitation/ 63.1348 Opacity < or = 10% except during startups, shutdowns, malfunctions Standard: Monitoring Quarterly visual inspections for leaks will be conducted. If visible emissions are observed during these inspections, the requirements of 63.13 50(a)(4)(i) - (iv) will apply to that source . Alternative Monitoring Request

– 12/04/2001 Testing None Required at this time since one was conducted on 12/04/2001 Initial Performance Testing Waiver

– 12/04/2001Page 50 of 77

**M.7 40 CFR 63 NESHAP**  **- LLL, Conveying Syst** **em Transfer Points with Limited Operation**  Limitation/ 63.1348 Opacity < or = 10% except during startups, shutdowns, & malfunctions Standard: Monitoring Conduct a monthly Method 22 test when the emission source is operating. Alternative Monitoring Requests

– 04/25/2002 and 08/21/2002 Testing Waiver of initial Method 9 Performance test. Initial Performance Testing Waiver

– 04/25/2002 and 08/21/2002 **M.8 40 CFR 63 NESHAP**  **- LLL, Inaccessible Conveying System Transfer Points**  **(601 .CH3)** Limitation/ 63.13 48 Opacity < or = 10% except during startups, shutdowns, & malfunctions Standard: Monitoring Conduct monthly visual inspections for leaks or evidence of leaks

when the emission source is operating. The frequency of these visual inspections can be redu ced to semi - annually if no leaks are observed in six consecutive monthly tests and further reduced to annually if no leaks are observed in the semi - annual inspection. Alternative Monitoring Request

– 04/17/2001 Testing Waiver of initial Method 9 Performan ce test and Method 22 test. Initial Performance Testing Waiver

– 04/17/2001 **M.9 40 CFR 63 NESHAP**  **- LLL, Inaccessible Conveying System Transfer Points**  **(601 .CH4)** Limitation/ 63.1348 Opacity < or = 10% except during startups, shutdowns, & malfunctions Standard: Testing In lieu of performing an initial Method 9 Performance Test, Initial Performance Testing conduct an initial visual inspection for leaks or evidence of leaks followed by a 6 - minute Method 9 test. Waiver

– 04/17/2001 **N. State Construct** **ion Permit Conditions N.1**  **KDHE Construction Permit 8 -**  **26 -**  **99 (superseded by 3 -** **30 -**  **06 permit) Air Emission Unit Technical Specifications**  Limitation/Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Preheater/precalciner and kiln to be fire d with coal and/or petroleum coke, natural gas, used oil, solid and liquid hazardous waste - derived fuel, and alternative non - hazardous waste - derived fuels. Monitoring Monitor fuel used for the preheater/ precalciner . Recordkeeping Record fuel used for the preheater/ precalciner.Page 51 of 77

**N.2 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Maximum kiln annual feed of

2,899 ,560 tons/year. Monitoring Monitor kiln feed on a rolling 12 - mo nth basis in units of (tons/year). Recordkeeping Record kiln feed on a rolling 12 - mo nth basis (tons/year). **N.3 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission**  **Unit Technical Specifications**  Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Maximum raw mill annual

throughput 3,285,000 tons/year Monitoring Monitor raw mill throughput on a rolling 12 - mo nth basis in units of (tons/ye ar). Recordkeeping Record raw mill throughput on a rolling 12 - mo nth basis (tons/year). **N.4 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (sup erseded by 3 - 30 - 06 permit) Maximum clinker cooler annual

throughput of 1,699,440 tons/year Monitoring Monitor clinker cooler throughput on a rolling 12 - mo nth basis (tons/year). Recordkeeping Record clinker cooler throughput on a rolling 12 - mo nth basis ( tons/year). **N.5 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Maximum coal mill annual

throughput of 245,280 to ns/year Monitoring Monitor coal mill throughput on a rolling 12 - mo nth basis (tons/year). Recordkeeping Record coal mill throughput on a rolling 12 - mo nth basis (tons/year). **N.6 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit)**  **Air Emissio n Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Maximum finish mills #1 and #3

throughput of 876,000 tons/year Monitoring Monitor finish mills #1 and #3 throughput on a rolling 12 - mo nth ba sis (tons/year). Recordkeeping Record finish mills #1 and #3 throughput on a rolling 12 - mo nth basis (tons/year).Page 52 of 77

**N.7 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Maximum finish mill #4

throughput of 1,314,000 tons/year Monitoring Monitor finish mill #4 throughput on a rolling 12 - mo nth basis (tons/year). Recordkeeping Record finish mill #4 throughput on a rol ling 12 - mo nth basis (tons/year). **N.8 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Fabric filters shall be ins talled,

operated and maintained to control particulate matter from conveyor transfer points (Belt conveyors, screw conveyors, drag chain conveyors, pneumatic conveyors, metal pan conveyors and bucket elevators for moving raw material, clinker, additives an d finished cement). Monitoring All APCDs must be operating when the emission source it is designated to control

is operating. Each mandated APCD designed to capture particulate matter emitted from in - plant material conveyance system transfer points s hall be operated and maintained such that particulate matter is diverted to and captured by the control device at all times that a conveyance system is operating. Recordkeeping Record that all APCDs are operated and maintained according to manufacturer’s

specifications or recommendations. **N.9 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission Unit**  **Technical Specifications** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Fabric filters shall be

i nstalled, operated and maintained to control particulate matter from new storage bins and silos for raw and in - process materials. Monitoring All APCDs must be operating when the emission source it is designated to control is operating. Recordkeeping R ecord that all APCDs are operated and maintained according to manufacturer’s specifications or recommendationsPage 53 of 77

**N.10 KDHE Construction Permit**  **8 -**  **26 -**  **99 (superseded by 3**  **- 30**  **- 06 permit)**  **BACT Air Emission Limitations**  Limitation/ Standard: Construction Permit 8 - 26 - 99, Modification of Permit/Approval Conditions June 22, 2004

(superseded by 3 - 30 - 06 permit) Maximum plant wide emission of carbon monoxide limited to 5,000 lb/hr, measured as an 8 - hour block average. Monitoring CEMS required for CO

Ash Grove sh all operate all CEMS in accordance with the applicable procedures under Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B. Ash Grove shall perform quarterly accuracy determinations and daily calibration drift tests in accordance with Procedure 1 in 40 CFR 60, Appendix F. For the CO monitors, the span values of each CEMS shall be 800 ppm. When there are gaps in emissions data recorded by CO CEMS, use the average of the one - minute values of data previously recorded during the last 30 days. Recordkeeping Record each 8 - hour block average CO emission rate 3 times each day. Maintain records of CEMS data for the previous 2 years. **N.11 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) BACT Air**  **Emission Limitations** Limitation/ Standard: Construction Permit 8 - 26 - 99, Modification of Permit/Approval Conditions June 22, 2004

(superseded by 3 - 30 - 06 permit) Maximum annual plant - wide emissions of carbon monoxide limited to 1,169 tons, measured as a 12 - mo nth rolling average. Moni toring CEMS required for CO

Ash Grove shall operate all CEMS in accordance with the applicable procedures under Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B. Ash Grove shall perform quarterly accuracy determinations and daily calibration drift tests in accordance with Procedure 1 in 40 CFR 60, Appendix F. For the CO monitors, the span values of each CEMS shall be 800 ppm. When there are gaps in emissions data recorded by CO CEMS, use the average of the one - minute values of data pr eviously recorded during the last 30 days. Recordkeeping Maintain monthly emission rates based on hourly averages of CEMS data and compute

and record the 12 - mo nth rolling total emission rate. Maintain records of CEMS data for the previous 2 years. **N.12 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission**  **Limitations** Limitation/ Standard: Construction Permit 8 - 26 - 99, Modification of Permit/Approval Conditions June 22, 2004

(superseded by 3 - 30 - 06 permit) Maximum annual plant - wide emissions of sulfur - oxides limited to 1,037 tons, measured as a 12 -mo nth rolling average.Page 54 of 77

Monitoring CEMS required for SO x

Ash Grove shall operate all CEMS in accordance with the applicable procedures under Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B. Ash Grove shall perform quarterly accuracy determinations and daily calibration drift tests in accordance with Procedure 1 in 40 CFR 60, Appendix F. For the SO x mo nitors, the span values of each CEMS shall be 600ppm. When there are gaps in emissions data recorded by SO x CEMS, use the average of the one - minute values of data previously recorded during the last 30 days. Recordkeeping Maintain monthly emission rates based on hourly averages of CEMS data and compute and

record the 12 - mo nth rolling total emission rate. Maintain records of CEMS data for the previous 2 years. **N.13 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Air Emission**  **Limitations** Limitation/ Standard: Construction Permit 8 - 26 - 99Modification of Permit/Approval Conditions June 22, 2004 (superseded

by 3 - 30 - 06 permit), Maximum annual plant - wide emissions of nitrogen oxides limited to 2,623 tons, measured as a 12 - mo nth rolling average. Monitoring CEMS required for NO x . Ash Grove shall operate all CEMS in accordance with the applicable procedures under Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B. Ash Grove shall perform quarterly accuracy determinations and daily calibration drift tests in accordance with Procedure 1 in 40 C FR 60, Appendix F. For the NO x mo nitors, the span values of each CEMS shall be 1000 ppm. When there are gaps in emissions data recorded by NO x CEMS, use the average of the one - minute values of data previously recorded during the last 30 days. Recordke eping Maintain monthly emission rates based on hourly averages of CEMS data and compute

and record the 12 - mo nth rolling total emission rate. Maintain records of CEMS data for the previous 2 years. **N.14 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Permit**  **Conditions** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) A dust - abating surfactant shall be

applied to all unpaved haul roads leading from the quarry to the cement plant and to all unpaved roadw ay s that are located on or within the cement plant perimeter that are traveled by haul trucks, regardless of whether the haul truck(s) are owned by Ash Grove. At a minimum, dust abating surfactant shall be applied in a manner and at a frequency consistent with the manufacturer’s specifications as necessary to achieve a 90% control efficiency of PM 10 emissions. Recordkeeping Record w hen surfactant is applied to unpaved haul roads.Page 55 of 77

**N.15 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) P**  **ermit Conditions** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) To implement BACT for the

preheater/precalciner kiln system, Ash Grove shall install, operate and maintain a “Good Combustion Practices” or GCP emission control system, as described in the permit application, to minimize emission of carbon monoxide. The GCP emission control system shall be implemented to minimize emissions of all criteria air pollutants at all times. Monitoring Reporting Recordkeeping Each person working at the Ash Grove Chanute, Kansas facility in the capacity of a production manager, production supervisor, process engineer, shift supervisor or control room operator shall successfully complete the GCP Training Program, or an equivalent pro gram, prior to assuming duties related to, or involving implementation of, the GCP BACT technology. Provide a course of training consisting of classroom and hands - on training in GCP to cover topics as outlined in the Construction Permit The GCP Trainin g Program shall be administered by a qualified instructor(s) Employees shall be tested on their understanding of the contents of the GCP program. Written records shall be maintained, as necessary, to document successful completion of the GCP training pro gram by each person working in the capacities listed above. Maintain employee - training records relating to GCP training program. **N.16 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Monitoring**  **Requirements and Compliance** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Ash Grove shall install, calibrate,

maintain and operate a system to continuously measure and record the volumetric flow rate and tem perature of gas discharged to the atmosphere from the main stack. Monitoring Continuously monitor the stack gas flow rate and temperature. Recordkeeping Continuously record the stack gas flow rate and temperature. **N.17 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Monitoring**  **Requireme nts**  Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Ash Grove shall install, calibrate,

maintain and operate a system to continuously measure and record the stack gas oxygen concentration in the alkali bypass system and be tween the second and third preheater stages. Monitoring Continuously monitor the stack gas oxygen concentration in the alkali bypass system and

betw een the second and third preheater stages. Recordkeeping Continuously record the stack gas oxygen conce ntration in the alkali bypass system and

betw een the second and third preheater stages.Page 56 of 77

**N.18 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Monitoring**  **Requirements** Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Ash Grove shall operate all of the

CEMS and stack gas flow rate monitor when the kiln system is operated, except for CEMS breakdow ns, repairs, calibration checks and zero span adjustments. Monitoring Continuously monitor the stack gas flow rate when the kiln system is operating. **N.19 KDHE Construction Permit 8**  **- 26**  **- 99 (superseded by 3**  **- 30**  **- 06 permit) Notification**  Limitation/ Standard: Construction Permit 8 - 26 - 99 (superseded by 3 - 30 - 06 permit) Ash Grove shall submit a written

excess emission s and monitoring systems performance report to the Department each calendar quarter. The reports shall include the information required in § 60.7(c) and (d) and shall be postmarked by the 30 th day following the end of the calendar quarter. Reporting S ubmit the excess emissions and monitoring systems performance report quarterly. **N.20 KDHE Construction Permit 10**  **- 03**  **- 00 Cement Unloading**  Limitation/ Standard: Construction Permit 10 - 03 - 00 The railcar unloading connectors (“boot- lift”) must be properly

engaged and operating when the railcar unloading station is in operation.

**N.21 KDHE Construction Permit 1**  **- 16**  **- 01 Modified CKD Handling and Storage**  Limitation/ Standard: Construction Permit 1 - 16 - 0 1 Exhaust gases from the processing equipment shall be vented through

the air emission control equipment. Recordkeeping Compliance with this limit is demonstrated by complying with the opacity limitations of

M.5 40 CFR 63 NESHAP - LLL, Conveying System Trans fer Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs With the potential to emit particulate matter. **N.22 KDHE Construction Permit 1**  **- 16**  **- 01 Modified CKD Handling and Storage**  Limitation/ Standard: Con struction Permit 1 - 16 - 0 1 The enclosures and covers on the raw material handling equipment

shall be in place and tightly secure when material is being moved through this equipment so that a capture efficiency of 100% is maintained. Recordkeeping Compliance with this limit is demonstrated by complying with the opacity limitations of

M.5 40 CFR 63 NESHAP - LLL, Conveying System Transfer Points, Storage Bins, unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs

– With the potenti al to emit particulate matter. Recordkeeping Com pliance with this limit is demonstrated by complying with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying System Transfer Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs

– With the potential to emit particulate matter.Page 57 of 77

**N.23 KDHE Construction Permit 1**  **- 16**  **- 01 Modified CKD Handling and Storage**  Limitation/ Standard: Construction Permit 1 - 16 - 0 1 The control equipment with at least 99% control efficiency shall be

in place and continuously ope rate to control emission of PM and PM 10 from the raw material handling equipment when in operation. Recordkeeping Compliance with this limit is demonstrated by complying with the opacity limitations of

M.5 40 CFR 63 NESHAP - LLL, Conveying System Trans fer Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs

– With the potential to emit particulate matter. **N.24 KDHE Construction Permit 5**  **- 01**  **- 01 Clinker**  **Loadout** Limitation/ Standard: Construction Permit 5 - 01 - 01 The APCD (baghouse) shall be operated at all times and emissions

routed to the baghouse whenever the load - out chute is being operated. Recordkeeping Compliance with this limit is demonstrated by complying with the opacity limitations of

M.5 40 CFR 63 NESHAP - LLL, Conveying System Transfer Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs

– With the potential to emit particulate matter. **N.25 KDHE Construction Permit 8**  **- 08**  **- 02 Fly Ash Permit**  Limitation/ Standard: Construction Permit 8 - 08 - 02 Baghouse 535.BF2 shall be operating at all times and emissions

from the cement load - out system shall be routed to baghouse 535.BF2, whenever the load - out chute is being operated to transfer fly ash to cement storage silo #38. (Not applicable, refer to construction permit 1 - 20 - 05, Condition N.30) Recordkeeping Compliance with this limit is demonstrated by complying with the opacity limitations of

M.5 40 CFR 63 NESHAP - LLL, Conveying System Transfer Points , Storage Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs

– With the potential to emit particulate matter. Limitation/ Standard: Construction Permit 8 - 08 - 02 A magnahelic or similar type device shall be installed on the

baghouse to enable accurate monitoring of the pressure drop across the baghouse. Recordkeeping Compliance with this limit is demonstrated by complying with the opacity limitations of

M.5 40 CFR 63 NESHAP - LLL, Conveying System Transfer Points, Stora ge Bins, Unloading Systems, Raw Material Dryers, Bagging Systems, or the associated APCDs

– With the potential to emit particulate matter. The Construction Permit 8 - 26 - 99 has been modified by a Modification of Permit/Approval Conditions June 22, 2004.Page 58 of 77

**N.2 6**  **KDHE Construction Permit 2 -**  **25 -**  **04 Meat and Bone Meal Feasibility Test** Limitation/ Standard: Construction Permit 2 - 25 - 04 The feed rate of meat and bone meat to the calciner shall not

exceed ten (10) tons per hour. The total amount of meat and bo ne meal burned to the calciner during the testing shall not exceed 50 tons. (This test has been completed and the system has been removed.) Recordkeeping Record the feed rate of meat and bone meal fed to the calciner.

Maintain records on - site at the f acility for at least two (2) years from the date of the record. **N.2 7**  **KDHE Construction Permit 6 -**  **01 -**  **04 Selective Non -**  **Catalytic Reduction Feasibility Test** Limitation/ Standard: Construction Permit 6 - 1 - 04 The testing associated with the injection of ammon ium hydroxide

shall be limited to no more than 168 hours of kiln operating time. (This test has been completed and the system has been removed.) Recordkeeping Record the feed rate(s) and duration (in hours) of injection of the ammonium hydroxide fed to

the kiln. Maintain records on - site at the facility for at least two (2) years from the date of the record. **N. 28**  **KDHE Modification of Permit/Approval Conditions, June 22, 2004** Limitation/ Standard: The overall maximum combined production rate for all finish mill systems shall not exceed

2,100,000 tons in any consecutive 12 month period. Monitoring Recordkeeping The owner or operator is required to monitor and record the production rate of each finish mill

system and the combined production total of all finish mill systems. Each record shall be updated monthly, no later than the last day of the month following the month to which the record relates. Each record shall be kept on- site for a minimum of five (5) years from the date of the record. **N. 29**  **KDHE Construction Permit 12**  **- 16**  **- 05 Selective Non**  **- Catalytic Reduction System**  Limitation/ Standard: Construction Permit 12 - 16 - 05 Selective Non - Catalytic Reduction System is subject to all

conditions, operating limits, and monitoring requirements specified for the kiln system as stated in Condition N.2 according to the 3 - 30 - 06 Construction Permit Recordkeeping Maintain written records of the feed rate(s) and duration (in hours) of injection of the ammonium hydroxide fed

to the kiln Keep all records on - sit e for at least two (2) years from the date of the record. **N. 30**  **KDHE Construction Permit 3 -** **30 -**  **06 PM Emission Limits** Limitation/ Standard: Construction Permit 3 - 30 - 06 PM emissions are limited to 0.02 grains/dscf for the following

facilities: in - line r awmill/kiln, coal mill, and clinker cooler. Monitoring Compliance with this limit is demonstrated by following the procedures under 40 CFR 60.13 for

installation, evaluation, and operation of the COMS, including operation of the COM system at all times , except during period of COM system breakdown, repair, calibration checks and zero and span adjustments. Ash Grove shall operate all COMS in accordance with the applicable procedures under Performance Specification 1 in 40 CFR 60, Appendix B.Page 59 of 77

**N. 31**  **KDHE Construction Permit 3**  **- 30**  **- 06 Monitoring Requirements**  Limitation/ Standard: Construction Permit 3 - 30 - 06 The primary (211.CR1) and secondary crushers (211.CR2) are subject

to: A. K.A.R. 28 - 19 - 20 Particulate matter emission limitation which limits the quanti ty of particulate emissions from processing equipment in proportion to the rate at which materials are processed. B. K.A.R. 28 - 19 - 650(a) Opacity of visible emissions from the crushers shall not exceed 40 percent. Monitoring, Reporting, and Recordkeeping Compliance with this limit is demonstrated by complying with monitoring, reporting, and

recordkeeping requirements as specified for K.A.R. 28 - 19 - 20 and K.A.R. 28 - 19 - 650(a) above.

**N. 3**  **2 KDHE Construction Permit 3**  **- 30**  **- 06 Monitoring Requirements**  Limi tation/ Standard: Construction Permit 3 - 30 - 06 Alternative fuels and pails of non - hazardous waste fuel may be fed

to the preheater/precalciner kiln system using the existing feed systems and those included in this permit, so long as the total feed stream c haracteristics or emissions from the kiln system do not result in an exceedance of the operating parameter limits specified in the mo st recent Notification of Compliance . Alternative waste fuels may only be fed in Modes 3 and 4, except upon approval by KD HE to burn in Modes 1 and 2. After successful demonstration of compliance while burning TDF, BWF, and/or non - hazardous waste fuel pails in Modes 3 and 4, Ash Grove may, upon approval from KDHE, begin feeding TDF, BWF, and non - hazardous waste fuel pails in Modes 1 and 2. Monitoring If an exceedance of operating parameter limits occurs while feeding TDF, BWF, or non-hazardous pail in

Modes 3 or 4, take immediate steps to ramp down the alternate waste fuel feedrate. Completely stop burning of all non-hazardous alternative waste fuels within 10 minutes or the first recorded exceedance of any operating parameter limit. Feeding of alternate waste fuel shall not be resumed unless/until all operating parameters are within acceptable limits, as defined in the mo st recent Notification of Co mpliance. Burning of non-hazardous alternative waste fuels shall not impact the AWFCO requirements for hazardous waste - derived fuel. Hazardous waste - derived fuels shall be controlled by an AWFCO system and shall be used to instantaneously and automatically stop the flow of hazardous waste - derived fuel to the kiln in the event that any of the operating parameter limits in the mo st recent Notification of Compliance are exceeded. Reporting and Recordkeeping Only exceedances that occur while hazardous waste remains in the combustion chamber shall be

counted towards the excessive exceedance reporting requirements of 40 CFR 63.1206(c)(3)(vi). Since qualitative assessments and/or Method 9 evaluations or any other reporting requirements are required in the **Applicable Requirements Section** of this permit, the facility is required to submit a semi - annual report every six months. Refer to the **Testing, Monitoring, Record Keeping and Reporting Section**  of this permit for the submittal dates o f these reports. **Facility -** **Wide Applicable Requirements** The permittee shall comply with the following when required by the relevant regulations: K.A.R. 28 - 19 - 20 Particulate Matter Emission Limitations The permittee shall comply with the requirements of K.A .R. 28 - 19 - 20. This regulation applies to handling and processing equipment for dry bulk materials, excluding indirect heatingPage 60 of 77

equipment and incinerators K.A.R. 28 - 19 - 30 through K.A.R. 28 - 19 - 32. Emission Limitations (Indirect Heating Equipment): The permittee shall comply with the requirements of K.A.R. 28 - 19 - 30 through 28 - 19 - 32. These regulations apply to installations in which fuel is burned for the primary purpose of producing steam, hot water, or hot air, or other indirect heating of liquids, gases, or solids and, in the course of doing so, the products of combustion do not come into contact with process materials. K.A.R. 28 - 19 - 55 through K.A.R. 28 - 19 - 58. Emergency Episode Plans The permittee shall comply with the requirements of K.A.R. 28 - 19 - 55 through 28 - 19 - 58, Emergency

Episode Plans, and shall maintain on site an emergency episode plan if KDHE requires an emergency

episode plan be developed pursuant to K.A.R. 28 - 19 - 58. K.A.R. 28 - 19 - 202. Annual Fee Pay ment The owner or operator of a permitted emissions unit or stationary s ource is required to pay

f ees to the permitting authority consistent with the fee schedule set out in the regulations pursuant to K.A.R. 28 - 19 - 202. K.A.R. 28 - 19 - 210, Calculation of Actual Emissions The following applies to emission c ontrol equipment not otherwise addressed in this permit: If the owner or operator uses air emission control equipment, not otherwise addressed in this permit, to calculate actual emissions, the air emission control equipment shall be maintained in accordance with the manufacturer’s recommendation. The owner or operator shall keep a written log recording the date and type of action taken when performing preventive or other maintenance on the air emission control equipment. K.A.R. 28 - 19 - 517. Annual Emission Inventory The owner or operator shall submit all operating or relevant information to estimate emissions for the preceding ye ar to the KDHE. This information shall be submitted before the date specified at K.A.R. 28 - 19 - 517 or amendments thereto and shall b e submitted on forms provided or approved by the KDHE. At the time of permit issuance, the due date for submittal of this information is June 1 . K.A.R. 28 - 19 - 645. Open Burning The permittee is prohibited from conducting open burning, except as allowed by K.A.R. 28 - 19 - 647 and K.A.R. 28 - 19 - 648. K.A.R. 28 - 19 - 735 which adopted by reference 40 CFR Part 61, Subpart A and 40 CFR 61, Subpart M The permittee shall comply with the National Emission Standard for Hazardous Air Pollutants (NESHAP) 40 CFR Part 61, Subp art A, General Provisions and Subpart M, National Emission Standard for Asbestos, adopted by K.A.R. 28 - 19 - 735, and K.A.R. 28 - 50 - 1 et seq. when conducting any renovation or demolition activities at the facility.Page 61 of 77

40 CFR Part 68. Chemical Accident Prevention Provisions Chemical Accident Prevention Provisions, 40 CFR Part 68, is applicable to an owner or operator of a stationary

source that has more than a threshold quantity of a regulated substance in a process, as determined in 40 CFR 68.115. If the stationary source is subject to 40 CFR Part 68, but is not required to comply with those requirements as of the effective date of this operating permit, the stationary source shall be in compliance with the requirements of 40 CFR Part 68 no later than the latest of the following dates: a. Three ye ars after the date on which a regulated substance is first listed in 40 CFR 68.130; or b. The date on which a regulated substance is first present above a threshold quantity in a process. On the effective date of this permit, Ash Grove Cement Company, as reviewed, does not have more than the threshold quantity of any regulated substance. 40 CFR Part 82, Protection of Stratospheric Ozone The permittee shall comply with 40 CFR Part 82, Protection of Stratospheric Ozone. Affected controlled substances include, but are not limited to, chlorofluorocarbons, hydrochlorofluorocarbon refrigerants, halons, carbon tetrachloride, and methyl chloroform (specific affected controlled substances are listed in 40 CFR Part 82, Subpart A, appendices A {Class I } and B {Class II}). The following subparts and sections of 40 CFR Part 82 are conditions of this permit: Subpart A - Production and Consumption Controls Subpart B - Servicing of Motor Vehicle Air Conditioners Subpart E - Labeling of Products Using Ozone - Depleting Substances: Section; 82.106 Warning statement requirements, 82.108 Placement of warning statement, 82.110 Form of label bearing warning statement, and 82.112 Removal of label bearing warning statement Subpart F - Recycling and Emission s Reduction: Sections; 82.156 Required practices, 82.158 Standards for recycling and recovery equipment, 82.161 Technician certification, and 82.166 Reporting and recordkeeping requirements Subpart G - Significant New Alternatives Policy Program

**Opacity M onitoring**  Facilities are required to perform qualitative (Method 22) and potentially quantitative (Method 9) visible emissions assessments to ensure compliance with opacity standards identified in the applicable requirements section of this permit.Page 62 of 77

The person responsible for making qualitative (Method 22) opacity assessments must be knowledgeable about the effects on visibility of emissions caused by background contrast, ambient lighting, observer position relative to lighting, wind, and the presence of unc ombined water. The person responsible for making quantitative opacity assessments must be certified to conduct Method 9 observations. The records kept of visible emissions assessments shall include the specific requirements of Method 22 and/or Method 9 as required as well as any steps taken to correct any opacity standard exceedances, plus information required under the Testing, Monitoring, Record keeping, and Reporting section of this permit. The detection of visible emissions is not considered to be a deviation subject to reporting in accordance with the Reporting of Deviations from Permit Terms portion of this permit. **Portland Cement MACT Visible Emissions Monitoring Plan (63.1350(a)(4)(i -** **vii))** (i) The facility

must conduct a monthly

1 - minute visible emis sions test of each affected (or listed) source in accordance with Method 22 of Appendix A to part 60. The test must be conducted while the affected (or listed) source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests fo r any affected (or listed) source, the owner or operator may decrease the frequency

of testing from monthly to semi - annuall y for that affected (or listed) source. If visible emissions are observed during any semi - annual test, the owner or operator must resume testing of that affected (or listed) source on a monthly

basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi - annual test for any affected (or li sted) source, the owner or operator may decrease the frequency

of testing from semi - annually to annually for that affected (or listed) source. If visible emissions are observed during any annual test, the owner or operator must resume testing of that affected (or listed) source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly

tests. (iv) If visible emissions are observed during any Method 22 test, the owner or operator must conduct a 6 - minute test o f opacity in accordance with Method 9 of appendix A to part 60 of this chapter. The Method 9 test must begin within one hour of the original Method 22 during which visible emissions were observed. (v) The requirement to conduct Method 22 visible emissions monitoring under this paragraph shall not apply

to any totally

enclosed conveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying s ys tem transfer point” shall mean a conveying s ys tem transfer point that is enclosed on all sides, top and bottom. (vi) If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner or operator of the portland cement plant shall have the option to conduct a Method 22 visible emissions monitoring test according to the requirements of paragraphs (a)(4)(i) through (iv) of this section for each such conveying s ys tem transfer point located within the building, or for the building itself (according to paragraph (a)(4)(vii) of this section. (vii) If visib le emissions from a building are monitored, the requirements of paragraphs (a)(4)(i) through (iv) of this section apply to the monitoring of the building, and you must also do the following: Test visible emissions from each side, roof, and vent of the building for at least 1 minute. The test must be conducted under normal operating conditions.Page 63 of 77

**Non -**  **MACT Sources -**  **Visible Emissions Monitoring Plan (63.1350(a)(4)(i -** **vii))** (i) The facility

must conduct a monthly 1 - minute visible emissions test of each affected (or listed) source in accordance with Method 22 of Appendix A to part 60. The test must be conducted while the affected (or listed) source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected (or listed) sourc e, the owner or operator may decrease the frequency

of testing from monthly to semi - annuall y for that affected (or listed) source. If visible emissions are observed during any semi - annual test, the owner or operator must resume testing of that affected (or listed) source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi - annual test for any affected (or listed) source, the owner or operator may decrease the frequency

of testing from semi - annually to annually for that affected (or listed) source. If visible emissions are observed during any annual test, the owner or operator must resume testing of that affected (or listed) source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly

tests. (iv) If visible emissions are observed during any Method 22 test, the owner or operator must either conduct an additional 1 - minute Method 22 within tw enty- four hours with a result of “No visible emissions,” or conduct a 6 - minute test of opacity in accordance with Method 9 of appendix A to part 60 of this chapter. The Method 9 test must begin within twenty- four hours of the original, or follow-up (if conducted), Method 22 during which visible emissions were observed, unless a follow -up Method 22 demonstrated no visible emission. (v) The requirement to conduct Method 22 visible emissions monitoring under this paragraph shall not apply

to any totally

enclosed c onveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying s ys tem transfer point” shall mean a conveying s ys tem transfer point that is enclosed on all sides, top and bottom. (vi) If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner or operator of the portland cement plant shall have the option to conduct a Method 22 visible emissions monitoring test according to the requirements of paragraphs (a)(4)(i) through (iv) of this section for each such conveying s ys tem transfer point located within the building, or for the building itself (according to paragraph (a)(4)(vii) of this section. (vii) If visible emissions from a building are monitored, the requirements of paragraphs (a)(4)(i) through (iv) of this section apply to the monitoring of the building, and you must also do the following: Test visible emissions from each side, roof, and vent of the building for at least 1 minute. The test must be conducted under normal operating conditions.

**Emission Points with Very Low or Nonexistent Visible Emissions** Some emission points subject to opacity requirements may be identified as not requiring compliance demonstration due to potentially very low or nonexistent visible emissi ons. These may include: Degreasing operations, painting operations which filter particulate emissions, non - heat set printingPage 64 of 77

operations, other non - heat set evaporative VOC sources, petroleum product storage tanks, gl ycol dehydrators and sources which are v ented inside a building which is usually occupied may be presumed to be in compliance with any opacity limit of 20% or greater. Burners in indirect heating applications, space heaters, turbines, internal combustion engines or boilers may be presumed to be in compliance with any opacity limit of 20% or greater when burning natural gas or propane/LPG. Opacity increases as particulate content of emissions increase. The particulate content of emissions from burning natural gas or propane/LPG is small and the pa rticulate content of emissions from the evaporation of volatile organic compounds is zero. Particulate emissions inside an occupied building must be small to protect the health of the occupants. The possibility of emissions from these ty pes of sources exce eding an opacity of 20% is therefore potentially very low or nonexistent. If an operation in one of the above categories changes such that visible emissions are no longer, very low or nonexistent, the owner or operator shall apply for the appropriate permit or approval in accordance with K.A.R. 28 - 19 - 300 and commence appropriate qualitative opacity assessments pursuant to the above schedule. If a permit or approval is not required b y K.A.R. 28 - 19 - 300 the owner or operator shall notify KDHE within thirty daysof the change in operations and commence appropriate qualitative opacity assessments pursuant to the above schedule. Sources specificall y identified as being in this category are listed in Attachment D. **Requirements Which Will Become Applicable During t he Permit Term**  The owner or operator, in accordance with the provisions of K.A.R. 28 - 19 - 511 (b)(16)(C)(ii) and K.A.R. 28 - 19 - 512(a)(23) shall comply in a timely

manner with those applicable requirements that become effective during the permit term, unless a detailed schedule is expressly required b y applicable requirements. **Permit Shield** Compliance with the conditions of this permit shall be deemed in compliance with the applicable requirements of the Kansas air quality program as of the date of permit issuance. This shield applies only to: a. applicable requirements included, and specificall y identified in the permit; b. applicable requirements that KDHE has specifically identified in writing as not being applicable to the emissions unit or stationary sources and the determination or a concise summary thereof is included in the permit. Nothing in this permit shall alter or affect: a. the liability

of a permittee for any violation of an applicable requirement occurring prior to or at the time of issuance of this permit; b. U.S. EPA’s ability

to obtain information under Section 114 of the Clean Air Act; or c. the provisions of Section 303, Emergency orders, of the Clean Air Act, including the authority of the administrator of the U.S. EPA under that section of the air pollution emergency provisions of the Kansas air quality

program regulations, K.A.R. 28 - 19 - 55 through 28 - 19 - 58. d. the applicable requirements of the acid rain program, consistent with section 408(a) of the Act.Page 65 of 77

**Testing, Monitoring, Recordkeeping, & Reporting** Testing, monitoring, recordkeeping, and reporting requirements sufficient to assure compliance with the terms and conditions of the permit are required. In addition to any

testing, monitoring, recordkeeping, or reporting requirement contained in the Applicable Req

uirements section of this permit, monitoring and reporting may be required under the provisions of K.A.R. 28 - 19 - 12, Measurement of Emissions, or as required by any other provision of the federal Clean Air Act. Records to support all monitoring and copies of all reports required by the permit must be maintained for a period of at least five years from the date of the activity . Summary reports of any

routine, continuous or periodic monitoring must be submitted at six - month intervals on a calendar ye ar basis. The first report being due 30 days after each subsequent six month period for the duration of the permit (i.e. January

3 0 th and July

3 0 th). All instances of deviations from permit requirements, including perceived opacity exceedances, shall be clearly identified in the report. Submission of quarterly

or semi - annual reports required by any applicable requirement which duplicate the reporting required in the previous paragraph will satisfy the reporting requirements of the previous paragraph if noted on the submitted report. Records of required monitoring shall include: a. The date, place, and time of sampling or measurement; b. The date or dates analyses were performed; c. The company or entity which performed the analyses; d. The anal ytical techniques or methods used; e. The result of the anal ys es; and f. The operating conditions that existed at the time of sampling or measurement. **Reporting of Deviations from Permit Terms** Unless a different time period is specified in this permit, deviations from the requirements of this permit shall be reported to KDHE as follows: a. Deviations which result in emissions exceeding those allowed in this permit shall be reported the next business day following the discovery

of the release, with follow -up written notice within five business days following discovery of the release. The report shall include the probable cause of such deviations and any corrective actions or preventive measures taken. b. Deviations which do not result in emissions exceeding those allowed in this permit shall be reporte d in writing within 10 business days following discovery of the deviation. Oral notifications may

be made to the air program field staff at the Southeast District Office in Chanute or to the KDHE central office in Topeka. Written notifications shall be made to the KDHE central office with a cop y to the Southeast District Office.Page 66 of 77

**General Provisions** 1. K.A.R. 28 - 19 - 11: Exceptions Due to Breakdowns or Scheduled Maintenance a. Abnormal operating conditions resulting from malfunction breakdown, or necessary repairs to control or processing equipment and appurtenances which cause emissions in excess of the limitations specified in K.A.R. 28 - 19 - 20, K.A.R. 28 - 19 - 30 through K.A.R. 28 - 19 - 32 and K.A.R. 28 - 19 - 650 shall not be deemed violations provided that: i. Th e person responsible for the operation of the emission source notifies the department of the occurrence and nature of such malfunctions, breakdown, or repairs, in writing, within ten days of noted occurrence. ii. The number of occurrences of such breakdowns is not deemed excessive b y the department and appropriate reasonable action is taken to initiate and complete any necessary repairs and place the equipment back in operation as quickly as possible. b. Emissions in excess of the limitations specified in K.A. R. 28 - 19 - 20, K.A.R. 28 - 19 - 30 through K.A.R. 28 - 19 - 32 and K.A.R. 28 - 19 - 650 resulting from scheduled maintenance of control equipment and appurtenances will be permitted only on the basis of prior approval by the department and upon demonstration that such maintenance cannot be accomplished by maximum reasonable effort, including off - shift labor where required, during periods of shutdown of any related equipment. 2. K.A.R. 28 - 19 - 752a: Hazardous Air Pollutants; Limitations Applicable to Construction of New Major Sources or Reconstruction of Existing Major Sources This regulation shall continue in effect for an emissions unit or stationary source until a standard has been promulgated which is applicable to such source pursuant to Section 112(d) of the federal Clean Air Act. This regulation shall apply whenever construction of a new major source or reconstruction of an existing major source of hazardous air pollutants is proposed. 3. K.A.R. 28 - 19 - 753: Hazardous Air Pollutants; Limitations Applicable to Sources for Which the U.S. EPA Fails to Meet Certain Deadlines This regulation shall be applicable to a source only if the U.S. EPA fails to promulgate an emission standard for the subcategory applicable to the source within the time frame scheduled by the U.S. EPA at the most recent revision of 58 Federal Register 63941. The Federal 112(j) rule (promulgated on May 20, 1994) has been amended. A direct final rule, published in Federal Register on April 16, 1999, delays the permit application deadline for 7 - year source categories listed in the regulatory schedule until December 15, 1999. The previous deadline was May 15, 1999 which was 18 months after the original November 15, 1997 promulgation date for 7 - ye ar MACTs. The deadline for the 10 - year MACTs was May 15, 2002, which was 18 months after the original November 15, 2000 promulgation date for the 10 - ye ar MACTs. 4. Permit Term and RenewalPage 67 of 77

This permit has a term of five years unless otherwise stated in this permit. A complete application, as defined in K.A.R. 28 - 19 - 518, and any applicable fee, must be submitted to KDHE not less than six months and not more than 18 months prior to the expiration date. This operating permit shall not expire on the expiration date if a complete and timely application has been filed with the KDHE. 5. Severability The provisions of this permit are severable, and if any p ortion of this permit, or the application of any provision of this permit to any c ircumstance, is held invalid, the application of such provision to other circumstance, and the rem ainder of this permit, shall not be affected thereby . 6. Property

Rights This permit does not convey any property rights of any sort or any exclusive privilege. 7. Compliance The owner or operator shall comply with all conditions of the permit and shall continue to comply with applicable requirements with which the owner or operator is in compliance. Any permit noncompliance shall constitute a violation of the Kansas Air Quality Act and shall be grounds for enforcement action, for permit revocation or amendment, or for denial of a permit renewal application. Any

credible evidence may

be used for the purpose of establishing noncompliance with an emission limit or standard. All permit terms and conditions are federall y enforceable. It shall not be a defense for a p ermittee in an enforcement action to contend that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. 8. Compliance Certification The permittee shall annually submit to the Air and Asbestos Compliance Section of the KDHE, and a copy to the Air Permitting and Compliance Branch of the U.S. EPA, Region 7, a certification of compliance (Form CR- 02, Annual Certification.). The due date of the certification is July 22 of each year, beginning July 22, 2005 for the period June 22, 2004 through June 21, 2005. The certification shall include the permit term or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the method or methods used for determining the compliance, currently and over the reporting period; and a statement that the emission unit or stationary source shall continue to comply with all applicable requirements. Any document required to be submitted in accordance with this permit shall be certified b y a responsible official. The certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. 9. Emergency a. An emergency

means any situation arising 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 that causes the source to exceed a technology- based emission limitation under this permit, due to unavoidable increases inPage 68 of 77

emissions attributable to the emergency . An emergency shall not include noncompliance to the extent caused by

improperly

design ed equipment, lack of preventative maintenance, careless or improper operation, or operator error. b. An emergency

shall constitute an affirmative defense to an action brought for noncompliance with such technology- based emission limitation if the conditions of paragraph (c) below are met. c. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs or relevant evidence that: i. an emergency

occurred and that the permittee can identify the cause or cause s of the emergency ; ii. the permitted facility was at the time being properly operated; iii. 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 iv. the permittee submitted notice of the emergency, containing a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken, to KDHE within two working days of the time when emission limitations were exceede d due to the emergency . d. Inany

enforcement proceeding, the permittee seeking to establish the occurrence of an emergency

shall have the burden of proof. e. These emergency

provisions are in addition to any emergency

or upset provisions contained in any applicable requirement. Whenever these emergency provisions conflict with the provisions of K.A.R. 28 - 19 - 11, these emergency provisions shall control. 10. In spection and Entry Upon presentation of credentials and other documents as may be required by law, representatives of KDHE, including authorized contractors of KDHE, shall be allowed b y the permittee to: a. enter upon the premises where a regulated facility or activity is located or conducted and where records are kept under conditions of this document; b. have access to and copies of, at reasonable times, any records that must be kept under conditions of this document;

c. inspect at reasonable times, any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or re quired under this document; and d. as authorized by

the Kansas Air Quality A ct, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit or applicable requirements. 11. Permit Amendment, Modifi cation, Reopening, and Changes Not Requiring a Permit ActionPage 69 of 77

a. The permit may

be modified, revoked, reopened, reissued, or terminated for cause. The filing of a request b y the permittee for a permit modification, revocation, reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition. b. The permitting authority will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: i. Additional requirements under the Clean Air Act become applicable to the source three or more years prior to the expiration date of this permit. Such a reopening shall be completed no later than 18 months after promulgation of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the expiration date of this permit. ii. KDHE determines that this permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of this permit. iii. KDHE determines that it is necessary to revise or revoke this permit in order to assure compliance with applicable requirements. c. This document is subject to periodic review and amending as deemed necessary to fulfil l the intent and purpose of the Kansas Air Quality Statutes and the Kansas Air Quality Regulations. d. No permit revision shall be required under any approved economic incentives, pollution prevention incentives, marketable permits, emissions trading, and other similar programs or processes for changes that are provided for in the permit. 12. Duty to Provide Information Unless a different time frame is specified in this permit, the permittee shall furnish to the KDHE any information that the KDHE may request in writing within 60 days of the request, unless the KDHE specifies another time period. Submittal of confidential business information must be in accordance with KDHE procedures. 13. Duty to Supplement The permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in any

submittal, shall promptly submit such supplementary facts or corrected information. 14. Other Permits and Approvals; Applicability a. A construction permit or approval must be obtained from KDHE prior to commencing any construction or modification of equipment or processes that results in potential emission increases equal to or greater than the thresholds specified at K.A.R. 28 - 19 - 300. b. This document does not relieve the permittee of the oblig ation to obtain other approvals, permits, licenses, or documents of sanction that may be required by

other federal, state, or local government agencies.Page 70 of 77

15. Submissions All reports, notifications, information, and other correspondence concerning complianc e issues (including the submission of the Annual Certification Form CR- 02) shall be submitted to: Air Construction/Operating Permits & Compliance Section Bureau of Air and Radiation Kansas Department of Health and Environment 1000 SW Jackson, Suite 310 Topeka, KS 66612 - 1366 (785) 296 - 1550 A cop y of each Annual Certification Form CR- 02 shall be submitted to: Kansas Compliance Officer Air Permitting and Compliance Branch U.S. EPA, Region 7 901 North 5 th Street Kansas City, KS 66101 Any documents required to be submitted in accordance with this permit shall be certified b y a responsible official. This certification shall state that, based on the information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. This certification shall be submitted with original signatures. When specified in the permit, contact the district office at: Southeast District Office 1500 West 7th Chanute, Kansas 66720 (620) 431 - 2390 All other correspondence concerning the permit itself shall be submitted to: Air Construction/Operating Permits & Compliance Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612 - 1366 (785) 296 - 1570Page 71 of 77

**Permit Engineer** 

________________________________________________ _______________ Herbert Buckland Date Signed Engineering Associate Air Permitting Section

HB:saw C: SEDO O - 6855 & O - 6905

### Attachment A **Site Diagram**

### Attachmen **t B List of Acronyms and Symbols** 

### LIST OF ACRONYMS AND SYMBOLS

**ACRONYM or SYMBOL DESCRIPTION**  < less than > greater than acfm actual cubic feet per minute AP - 42 U.S. EPA publication of emission factors BACT Best Available Control Technology APCD Air Pollution Control Device BAR Bureau of Air and Radiation BTU British thermal unit CAA Federal Clean Air Act CAAA Clean Air Act Amendments of 1990 CAS Chemical Abstract Service CDE Control Device Efficiency CEM Continuous Emission Monitor CFC Chl orofluorocarbon cfm cubic feet per minute CFR Code of Federal Regulations CMS Continuous Monitoring System CO Carbon Monoxide COM Continuous Opacity Monitor CTG Control Techniques Guideline dscf dry standard cubic feet dscm dry standard cubic meter s EG Emission Guideline EPA Environmental Protection Agency EU Emission Unit FGR Flue Gas Recirculation g gram

### LIST OF ACRONYMS AND SYMBOLS

**ACRONYM or SYMBOL DESCRIPTION**  GOP General Operating Permit gph gallons per hour gpm gallons per minute gr grains HAP Hazardous Air Pollutant HC Hydrocarbon hp hors epower KDHE Kansas Department of Health and Environment HON Hazardous Organic NESHAP IA Insignificant Activity JCED Johnson County Environmental Department K.A.R. Kansas Administrative Regulation K.S.A Kansas Statutes Annotated LAER Lowest Achievabl e Emission Rate MACT Maximum Achievable Control Technology MBTU Thousand Btu Mg Mega grams MMBTU Million Btu MON Miscellaneous Organic NESHAP MSDS Material Safety Data Sheet MWC Municipal Waste Combustor MWI Medical Waste Incinerator NAAQS National Ambient Air Quality Standards NCDO North Central District Office NEDO Northeast District Office NESHAP National Emission Standards for Hazardous Air Pollutants NMOC Non - Methane Organic Compound NO X Nitrogen Oxides

### LIST OF ACRONYMS AND SYMBOLS

**ACRONYM or SYMBOL DESCRIPTION**  NOC Notification of Compliance NS PS New Source Performance Standard NSR New Source Review NWDO Northwest District Office OAQPS Office of Air Quality Planning and Standards P2 Pollution Prevention PAL Plant wide Applicability Limitation PM Particulate Matter PM 10 PM with an aerodynamic diameter of less than or equal to 10 microns PM 2.5 PM with an aerodynamic diameter of less than or equal to 2.5 microns PCD Pollution Control Device ppmv parts per million, volumetric basis ppmw parts per million, weight basis PSD Prevention of Si gnificant Deterioration psia pounds per square inch, absolute psig pounds per square inch, gage PTE Potential to Emit QA/QC plan Quality Assurance/Quality

Control plan RACT Reasonable Available Control Technology RMP Risk Management Plan SCDO South Central District Office SCHA Shawnee County Health Agency SEDO Southeast District Office SIC Standard Industrial Classification SIP State Implementation Plan SO X Oxides of Sulfur SOCMI Sy nthetic Organic Chemical Manufacturing Industry SWDO Southwest District Office

### LIST OF ACRONYMS AND SYMBOLS

**ACRONYM or SYMBOL DESCRIPTION**  TOC Total Organic Carbon tph tons per hour tpy tons per year TRS Total Reduced Sulfur TSDF Hazardous waste treatment, storage and disposal facilities TSP Total Suspended Particulate VOC Volatile Organic Compound VOL Volatile Organi c Liquid WCHD Wyandotte County Health Department WDF Waste Derived Fuel W - SCDCH Wichita- Sedgwick County Department of Community Health