Permit No 47259 Page 1 of 40 May 21, 2010 TECHNICAL SUPPORT DOCUMENT
CALPORTLAND COMPANY – RILLITO CEMENT PLANT AIR QUALITY PERMIT NO.47259

I. INTRODUCTION

Permit No. 47259 is a Title V renewal permit for Permit No. M190310P1-00 issued to CalPortland Company (previously Arizona Por tland Cement Company) for the continued operation of a limestone quarry, a Portland ceme nt manufacturing plant, and a rock and stone aggregate plant in Rillito, Arizona.

This Technical Support Document (TSD) pertains to the existing plant operations (Kilns 1-4). This permit also includes the requirements for Kiln 6 project from Significant Permit Revision No. 38592, issued on December 16, 2008. The TSD for the Significant Permit Revision No.
38592 is attached for reference.

A. Company Information

Facility Name: CalPortland Company

Facility Address: 11115 N. Casa Grande Highway Rillito, Pima County, Arizona 85654

Mailing Address: P.O. Box 338 Rillito, AZ 85654

B. Attainment Classification

The facility is located in an area that is classified as nonattainment with respect to particulate matter with aerodynamic diameter less than 10 microns (PM 10 ) and is either
classified attainment or unclassifiable with respect to all remaining criteria pollutants.

C. Learning Sites Evaluation

In accordance with ADEQ’s “Environmental Permits and Approvals Near Learning Sites” Policy, the Department is required to evaluate if any nearby learning sites would be adversely impacted by the facility. L earning sites consist of all existing public schools, charter schools and private schools at the K-12 level, and all planned sites for schools approved by the Arizona School Facilities Board. The learning sites policy was established to ensure that the protection of child ren at learning sites is considered before a permit approval is issued by ADEQ.

The Department identified 4 learning sites within two miles of the facility.

The facility had previously conducted a comp rehensive dispersion modeling analysis as part of RIMOD 3 expansion project in the la te 1990s for the existing configuration which demonstrated compliance with all applicable thresholds.

The facility was issued a significant permit revision (Permit Number 38592) on December 16, 2008, for construction of the Kiln 6 (K6) Project. As this project was a major modification subject to PSD review with respect to SO 2 emissions increases, the Permittee had conducted a compre hensive ambient air quality impact analysis as part of the permit application for the project. The analysis demonstrated compliance with the National Ambient Air Quality Sta ndards (NAAQS) and PSD increments.Permit No 47259 Page 2 of 40 May 21, 2010 The Permittee had also conducted a dispersion modeling analysis in 2005 in order to demonstrate compliance with the Arizona Am bient Air Quality Guidelines (AAAQG) as a part of K6 project. The modeled impacts from the plant were below all the AAAQG guidelines.

II. BACKGROUND INFORMATION

The Permittee was issued Permit Number M190310P 1-00, a Class I Operating Permit, on October 7, 2003. The facility was issued a significant revision, Permit Number 38592 on December 16, 2008, for construction of the “Kiln 6 Project,” a major modification of the existing major stationary source. Those conditions will be c onsidered an alternate operating scenario and are contained in Attachment “D” of this permit. The requirements in Attachment “D” will become applicable on the earlier of the first calendar day when the Kiln 6 production rate exceeds 6,480 tons of cement clinker, or on the 180 th day following initial firing of fuel in Kiln 6.

III. FACILITY DESCRIPTION

The existing facility includes a limestone quarry, a Portland cement manufacturing plant, and a rock and stone aggregate plant. The existing Po rtland cement plant includes four cement kilns and clinker coolers, with a total clinker produc tion capacity of 264 tons per hour, and ancillary equipment for fuel receiving and handling, feed materials receiving and handling, clinker grinding, and Portland cement manufacturing and shipping.

The facility was issued a significant permit revi sion No. 38952 on December 16, 2008, for the construction of the Kiln 6 Project. The project , when implemented, will have following major changes to the Portland cement manufacturing plant:

 A new pyroprocessing system featuring a dry process, preheater/precalciner kiln with inline raw mill, tire-derived fuel firing syst em, clinker cooler, and air pollution control systems. The new pyroprocessing line will ha ve a clinker production capacity of 300 tons per hour, approximately 14 percent more than the total capacity of the four existing kilns;

 Revisions to the rail unloading, handling, an d storage facilities for coal and petroleum coke;

 New solid fuel grinding system;

 Expanded and upgraded facilities for raw materials storage and reclaim, milling, and homogenizing;

 Expanded and upgraded facilities fo r clinker storage and handling;

 Expanded and upgraded facilities for cement milling, storage, and handling; and

 A new diesel-powered emergency generator.

The utilization of the quarry will increase as a result of the Kiln 6 Project, but no physical or operational changes will be made to the quarry equi pment. The Kiln 6 Project will not have any effect on the rock and stone aggregate plant.

The Permittee is required to permanently cease operation of Kilns 1, 2, 3, and 4 on or before the date Kiln 6 becomes operational.

IV. EMISSIONS

The potential to emit of the criteria pollutants for the existing operations are provided in Table 1 below. Emissions estimates subsequent to the K6 Project implementation are available in the attached Technical Support Document for the significant Permit revision number 38592.Permit No 47259 Page 3 of 40 May 21, 2010 TABLE 1: POTENTIAL EMISSIONS FROM EXISTING FACILITY

Pollutant Emissions* (Tons per year)

PM 3,150.27

PM 10 2,202.57

NO X 5,199.37

CO 5,156.03

SO 2 10,849.43

VOC 13.99

Fluorides 0.96

Lead 0.03

Sulfuric Acid Mist 2.29

Total HAPs 55.71

*Emission numbers are referenced from the permit renewal application.

V. COMPLIANCE HISTORY

There have been seven Air Quality cases associated with this facil ity since 2001. There have been eighty-three facility inspections and forty file revi ews of this facility since October of 1994. The details of the violations are as following:

1. Case Number 4638 (25795)

A Notice of Violation was issued to APCC-Rillito on May 10, 2001, for one alleged permit violation based on an inspection pe rformed on April 24, 2001 (Inspection ID: 25582). ADEQ personnel conducted a formal visual emission observation of coal conveyor belt section R6BC-2 to R6BC-3, utilizing EPA Reference Method 9, and observed over a six minute period, an average opacity of 39%. The facility’s deadlines for compliance were May 22 and June 14, 2001. A response was received from the facility on June 15, 2001, and the case was clo sed on July 3, 2001, but violations from
this case were resolved under Consen t Judgment Docket No. CV2006-016354.

2. Case Number 23682

A Notice of Violation was issued to APCC–Rillito on January 14, 2003, for one alleged violation based on a January 13, 2003, file re view (Inspection ID: 31993). As referenced in R18-2-312(B), the Arizona Testing Manual as per Section 1.4.3 requires submittal of final test reports to ADEQ within four weeks of completion of the test. During file review, it was observed that ADEQ had not received the final performance test report conducted on November 17, 2002. The fac ility’s deadline to achieve compliance was January 23, 2003. A response letter was r eceived on January 17, 2003, fulfilling the compliance conditions, and the NOV was closed on February 11, 2003. The case was later resolved under Consent Judgment Docket No. CV2006-016354.Permit No 47259 Page 4 of 40 May 21, 2010 3. Case Number 23730

A Notice of Violation was issued for one a lleged violation based on a January 15, 2003, file review (Inspection ID: 32044). According to the factual description of the violation, the Permittee reportedly failed a test for diox ins/furans completed November 17, 2002. The Permittee subsequently conducted a sec ond test in December 2002. The second test results were reported to ADEQ and showed th at the NESHAP for dioxins and furans was exceeded. The facility’s deadline to achie ve compliance was January 31, 2003. A response letter was received on January 21, 2003 and March 31, 2003, and the NOV was closed on May 27, 2003. The case was later resolved under Consent Judgment Docket
No. CV2006-016354.

4. Case Number 25292

A Notice of Violation was issued to APCC on May 28, 2003, for four alleged permit violations based on an inspection conducte d on March 25, 2003 (Ins pection ID: 35443).
The violations are as follows:

1. Pursuant to 40 CFR Part 63, Subpart LLL promulgated on June 14, 2002, APCC was required to install, calibrate, ma intain, and continuously operate and continuously monitor and record the temperature of the exhaust gases from the kilns. APCC failed to provide records demonstrating that 40 CFR 63.1350(f)(1) was implemented for the period of June 14, 2002, through November 4, 2002, as required in Subpart LLL of 40 CFR, Part 63.

2. Failure to calculate the 3-hour rolling av erage temperature from the average of 180 successive one-minute average temperatures as required by 40 CFR 63.1350(f)(3). According to the factual description of the violation, APCC provided one-minute temperature profiles from November 5, 2002, through January 26, 2003, and not the thr ee hour rolling average as required.

3. APCC failed to submit an annual compliance certification for calendar year 2002.

4. According to the factual description of the violation, during the inspection conducted on March 25, 2003, several manometer gauges on baghouse H5-5 were found to be no longer filled with fluid. This violation was documented during a previous inspection on April 24, 2001. If permanently installed, the gauges must be maintained and operated at all times during the operation of the process unit served by the baghouse.

The facility’s deadline for achieving comp liance was June 27, 2003. A response was received from the facility on June 16, 2003. The case was later resolved under Consent Judgment Docket No. CV2006-016354.

5. Case Number 28002

A Notice of Violation was issued to AP CC on December 11, 2003, for three alleged permit violations based on a file review conducted on December 10, 2003 (Inspection ID: 43273). The violations are as follows:

1. Failure to submit a plan to continuously monitor, during daylight hours, visible emissions across the property boundary line with the Rillito Community withinPermit No 47259 Page 5 of 40 May 21, 2010 60 days of the issuance of the permit, and failure to submit a permit revision application. According to the factual description of the violation, this APC permit was issued on October 7, 2003. The plan and permit revision were therefore due on December 6, 2003.

2. Failure to submit a revised Phase I Du st Control Plan within 60 days of the issuance of this permit. According to the factual description of the violation, the plan and permit revision, due on December 6, 2003, had not been received prior to the compliance date.

3. Failure to submit a visual observati on plan to be approved by the Department within 30 days of the issuance of this permit. According to the factual description of the violation, this plan was due by November 6, 2003, but was not submitted until November 20, 2003.

The facility’s deadline for achieving comp liance was December 27, 2003. Compliance was achieved on December 22, 2003, and the case was subsequently closed. The
violations from this case were later r esolved under Consent Judgment Docket No.
CV2006-016354.

6. Case Number 32857

A Notice of Violation was issued to APCC on October 28, 2004 for four alleged permit violations based on an inspection conducted on June 3, 2004 (Insp ection ID: 50899). The
violations are as follows:

1. Failure to comply with a National Em issions Standard for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. According to the factual description of the violation, the average of the three runs for performance testing of Kilns 1, 2, and 3 on June 2-3, 2004, by EPA Reference Method 23, indicated 0.22 ng TEQ/dscm dioxins/furans (D/F), which was in excess of the 0.20 ng TEQ/dscm standard for D/F.

2. Failure to provide ADEQ with a detailed written notification of air emissions in excess of an applicable emission limitation within 72 hours of telephonic notification. According to the factual description of the violation, ADEQ did not
receive a written notification within 72 hours after the July 13, 2004, telephonic notification of the June 2-3, 2004, test results indicating emissions in excess of the D/F standard from Kilns 1, 2 and 3.

3. Kilns 2 and 3 were operated in excess of the established temperature limits on June 2 and 3, 2004. During the June 2-3, 2004, EPA Reference Method 23 performance tests, Kiln 2 was operated with an average inlet temperature of 720 degrees F, and Kiln 3 was operated with an average inlet temperature of 705 degrees F. The applicable temperature limits established during testing on February 28, 2003, were 619 degrees F for Kiln 2 and 646 degrees F for Kiln 3. APCC did not qualify for the exemption from the requirement to operate above established temperature limits as spec ified in 40 CFR 63.1349(e)(3)(i) and Attachment “B,” Section V.A.5.a(3)(a) because the written notifications (test plans and testing schedules) for D/F testing received by ADEQ on March 1 and 26 and April 6 and 15, 2004, failed to include the operational changes which resulted in the elevated temperatures described above.Permit No 47259 Page 6 of 40 May 21, 2010 4. Failure to include in a compliance certification report submitted to ADEQ an identification of each deviation from comp liance with terms or conditions of an air quality control permit. According to the factual description of the violation, the semi-annual compliance certification report received by ADEQ, dated August 13, 2004, failed to indicate the deviation in compliance with permit condition Attachment “B,” Section V.A.1.d, for ope ration of Kilns 1, 2, and 3 on June 2 and 3, 2004 (emissions in excess of the D/F standard).

The facility’s deadline for achieving complia nce was December 1, 2004. A response was received from the facility on November 19, 20 04. This case was later resolved under Consent Judgment CV2006-016354.

7. Case Number 33475

A Notice of Violation was issued to APCC on December 8, 2004, for three alleged violations based on an inspection conduct ed on August 24, 2004 (Inspection ID: 52711). The significant violations are as follows:

1. During the inspection on August 24, 2004, the six minute opacity average of fugitive dust coming off this drop point of an unmarked Belt Conveyor connected
to the B9-DC5 Dust Collector was 25.2 percent. This was above the 20 percent limit referenced in the permit.

2. During the inspection on August 24, 2004, the six minute opacity average of fugitive dust coming off the drop point of the B6-BC1 Belt Conveyor was 33.9 percent. This is in excess of the 20 percent opacity limit.

3. Failure to clearly mark all equipment c overed by the permit with serial number or other equipment number that is also listed in the permit to identify that piece of equipment. According to the factual d escription of the violation, during the August 24, 2004, inspection of the B9 Screen building, the inspection team could not clearly identify the process and dust c ontrol equipment associated with the “Stacker/Reclaimer and Storage Area” and with the “Raw Feed Materials to Rock Storage” list of equipment as identified in the equipment list of the permit.

The facility’s deadlines to achieve complian ce were February 9 and April 10, 2005. The facility responded on February 1 and April 11 and 12, 2005. Compliance was documented and the NOV was closed on May 18, 2005. The case was closed on October 12, 2006, and the violations from this case were resolved under Consent Judgment
Docket No. CV2006-016354.

Consent Judgment Docket No. CV2006-016354

All the above cases resulted in a complaint and con sent judgment being filed against Arizona Portland Cement Co. for allegations contained in the Noti ces of Violation associated with these cases and any alleged violations of A.R.S. Title 49, Chapters 2 and 3, and regulations promulgated thereunder.

On December 27, 2006, Arizona Portland Cement Co. paid a civil penalty of $300,000. Additionally, Consent Judgment Docket No. CV2006-016354 required the facility to perform various Supplementary Environmental Projects (SEPs) in the community of Rillito which amounted to $89,000.Permit No 47259 Page 7 of 40 May 21, 2010 VI. APPLICABLE REGULATIONS

The Per mittee has identified the applicable regul ations that apply to each unit in its permit application. The following table summarizes the findings of the Department with respect to the regulations that are applicable to each emissions unit. Previous permit conditions are discussed
under Section VI of this technical review document. Applicable Regulations

Unit ID Control Equipment Applicable Regulations Verification

T win Peaks Rock

C rushing and Screening plant
Q uarry and

L imestone

P rocessing

P ortable screen

w hen used for screening

g ypsum/limestone. Dust collectors
water sprays A.A.C. R18-2-702 and -722,
Arizona SIP R9-3-

522.A

NSPS 40 CFR 60 Subpart OOO The affected facilities are subject to
Arizona SIP R9-3-522/ A.A.C R18-2-722. Particulate matter (PM) process weight rate equations in the Arizona SIP are more stringent than the A.A.C. Thus these are applicable to the equipment constructed prior to 1983.
NSPS 40 CFR 60 Subpart OOO is applicable to the equipment constructed
after 1983.

Coal Mill System Dust collectors Arizona SIP R9-3-

516.A.2

A.A.C. R18-2-

702.B.1
40 CFR 63 Subpart

LLL Portions of the coal mill system are subject
to Arizona SIP R9-3-516/ A.A.C R18-2- 716. PM process weight rate equations in the Arizona SIP are more stringent than the A.A.C. Thus these are applicable to the equipment constructed prior to October 28, 1974, and not modified after October 27, 1974. The opacity limit in A.A.C. R18-2- 702.B.1 is also applicable to this equipment.

As per 40 CFR 63.1340(b)(7), conveying system transfer points from the mill to the kiln are subject to NESHAPS requirements under 40 CFR 63 Subpart LLL. Additionally, as per 40 CFR 63.1356(b), these conveying system transfer points are exempt from any otherwise applicable new source performance standard contained in 40 CFR 60 Subpart Y.Permit No 47259 Page 8 of 40 May 21, 2010 Unit ID Control Equipment Applicable Regulations Verification

Kilns 1-3, and
In-line Kiln4/Raw Mill,
Clinker Coolers Dust collectors 40 CFR 63 Subpart

LLL
Arizona SIP R9-3-

505
40 CFR 60 Subpart

F Kilns and clinker coolers are subject to
Arizona SIP R9-3-505. Facilities
constructed after August 17, 1971 are subject to 40 CFR 60 Subpart F.

The facility is a major source of Hazardous Air Pollutant (HAP) emissions. Thus Kilns 1-3, and In-line Kiln-4/Raw Mill and Clinker Coolers are also subject to NESHAPS requirements under 40 CFR 63 Subpart LLL.

As per 40 CFR 63.1356(a), affected sources subject to the provisions of 40 CFR Subpart LLL are exempt from any otherwise applicable new source performance standard contained in 40 CFR 60 Subpart F.

Finish Mills,
Raw Material
and Clinker Storage and Handling, Bulk Unloading and Loading, and Bagging Systems Dust collectors 40 CFR 63 Subpart

LLL
40 CFR 60 Subpart

F

Arizona SIP R9-3-

505
40 CFR 64 (CAM) These facilities are subject to Arizona SIP
R9-3-505/ A.A.C R18-2-705. For facilities constructed prior to August 17, 1971, Arizona SIP R9-3-505 is applicable as it is more stringent than A.A.C R18-2-705.

The facility is a major source of Hazardous Air Pollutant (HAP) emissions. The facility is, therefore, subject to NESHAPS requirements under 40 CFR 63 Subpart

LLL.

40 CFR 60 Subpart F is applicable to any facility constructed after August 17, 1971. However, as per 40 CFR 63.1356(a), affected sources subject to the provisions of 40 CFR Subpart LLL are exempt from any otherwise applicable new source performance standard contained in 40 CFR 60 Subparts F or OOO.

40 CFR 64 Compliance Assurance Monitoring (CAM) requirements are applicable to various emission units as the potential pre-control particulate matter emissions for these units are greater than 100 tons/year.Permit No 47259 Page 9 of 40 May 21, 2010 Unit ID Control Equipment Applicable Regulations Verification

Natural Gas-fired Auxiliary engines None A.A.C. R18-2-719 Existing stationary rotating machinery is subject to requirements under A.A.C. R18-
2-719.

The engines are not subject to NSPS Subpart JJJJ because it was constructed prior to July 1, 2008

.

The National Emission Standard for Hazardous Air Pollutants (NESHAP) Subpart ZZZZ is applicable to reciprocating internal combustion engines (RICE) located at major and area sources of HAPs. Existing emergency stationary
RICE does not have to meet the requirements of 40 CFR §63 Subpart ZZZZ (40 CFR §63.6590(b)(3)).

Natural Gas-fired
Heaters and
Boilers None A.A.C. R18-2-724
40 CFR 60 Subpart

Dc The natural gas-fired heaters and boilers are subject to the requirements under

A.A.C. R18-2-724. Heater D4-RM1-HTR (75 MMBtu per hour) is not subject to NSPS requirements under 40 CFR 60 Subpart Dc as this is a process heater.

Diesel and used oil storage tanks

Portable screen
when used for screening
iron/clinkers None A.A.C. R18-2-730 These requirements are applicable to
unclassified sources.

Fugitive dust

sources Water and
other
reasonable precautions A.A.C. R18-2,
Article 6

A.A.C. R18-2-702 These are applicable to fugitive dust sources at the facility.

Mobile sources Water Sprays/Water
Truck for dust
control A.A.C. R18-2,
Article 8 This Article is applicable to mobile sources which either move while emitting air contaminants or are frequently moved during the course of their utilization but are not classified as motor vehicles, agricultural vehicles, or agricultural equipment used in normal farm operations.

Spray Painting N/A A.A.C. R18-2-
702.B
A.A.C. R-18-2-727 These standards are applicable to any spray painting operation.Permit No 47259 Page 10 of 40 May 21, 2010 Unit ID Control Equipment Applicable Regulations Verification

Abrasive Blasting Wet blasting, Dust collecting equipment or other approved
methods A.A.C. R-18-2-
702.B
A.A.C. R-18-2-726 These standards are applicable to any abrasive blasting operation.

Demolition or
Renovation Operations N/A A.A.C. R18-2-
1101.A.8 This standard is applicable to any asbestos
related demolition or renovation operations.

VII. PREVIOUS PERMITS AND PERMIT CONDITIONS

The following Section discusses the previous perm it conditions and their treatment with respect to the renewal permit. The TSD for the Permit No. 38592 discusses in details the issues related to the revision, and is incorporated as a part of this permit by reference.

A. PREVIOUS PERMITS

Table 3: PREVIOUS PERMITS

Permit # Issue Date Application Basis

M190310P1-00 October 7, 20 03 Title V Renewal Permit

33464 March 29, 2005 Minor Permit Revision

39066 January 31, 2007 Significant Permit Revision

43448 August 29, 2007 Minor Permit Revision

31767* February 12, 2008 Significant Permit Revision

38592 December 16, 2008 Significant Permit Revision

49991 December 16, 2009 Minor Permit Revision

50408 December 16, 2009 Minor Permit Revision

* Under appealPermit No 47259 Page 11 of 40 May 21, 2010 B. PREVIOUS PERMIT CONDITIONS

1. Operating Permit No. M190310P1-00

Table-4

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Attachment A x This Attachment has been revised and most
recent Attachment “A” is used for this permit.

Attachment B

Condition I.A x This requirement for compliance
certification is relocated as Condition I.B.

Condition I.C x This requirement for Method 9 observer is
relocated as Condition I.A.

Condition I.D.1 x The Pima county requirements for visible
emissions are relocated under Condition

II.B.2.

Condition I.D.2 x The requirements for visible emissions monitoring are relocated as Condition II.C.1.

Condition I.E x The Visible Emissions Observation requirements are relocated under Condition

II.C.2.

Condition I.F x This Condition describi ng various definitions is deleted. These are included in the specific permit conditions, wherever necessary.

Condition I.G through I.M x The general NESHAP requirement applicable to K1-K4 facility are relocated
Section II of Attachment “C”.

Section II x This Section for “Open Areas, Roadways/Streets, Material handling, storage Piles” is renamed as “Fugitive Dust
Sources” Section of Attachment “B”.

Sections III/VII x The requirements for quarry, lime stone and material handling are moved to Section III of
Attachment “C”.Permit No 47259 Page 12 of 40 May 21, 2010 Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Section IV x The requirements for Coal Mill system are
moved to Section IV of Attachment “C”. As
dust collectors H3-K4-DC1 and DC2 are subject to NESHAP requirements, these are exempt from NSPS requirements. Hence,
this Section is revised to remove NSPS requirements, and include NESHAP requirements.

Section V x The requirements for Kilns 1-4, and Clinker
coolers are moved to section V of
Attachment “C”.

Sections VI and

VIII x The requirements for all affected sources (except Kilns and clinker coolers) subject to 40 CFR 63 Subpart LLL are moved to
Section VI of Attachment “C”

Section IX x The requirements for boilers and heaters are
moved to Section IV of Attachment “B”.

Section X x The Section for “Secondary Materials
Utilization Procedures and Fuels” is moved
to Section VII of Attachment “C”.

Section XI x The ambient monitoring requirements are updated to reflect the latest ADEQ/EPA guidance documents, and are relocated under
Section X of Attachment “B”.

Section XII x This Section for Gasoline Storage Tank is revised to include all applicable requirements under A.A.C. 18-2-710, and is
relocated under Section VI of Attachment

“B”.

Section XIII x The equipment is now moved to Attachment “E” of the permit.

Section XIV x The road diagram is not required in the permit. This is now included in the recordkeeping requirements of the permit.Permit No 47259 Page 13 of 40 May 21, 2010 2. Significant Permit Revision No. 31767

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Condition I.D.2.a
of Attachment

“B” x The visible emissions monitoring requirements are now located under
Condition II.C.1.a of Attachment “B”.

3. Significant Permit Revision No. 38592

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Attachment “E” x The requirements for K6 significant permit
revision are now located under Attachment “D” of the permit.

4. Significant Permit Revision No. 39066

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Attachment “D” x The requirements for Twin Peak Rock crushing and screening plant are now located
under Section III of Attachment “B”.

5. Minor Permit Revision No. 43448

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Appendix “A” to
Attachment “B” x The Section “Alternate Raw Material Screening for Dioxins, Furans and
Precursors” is moved to Section X of
Attachment “C”.

. 6. Minor Permit Revision No. 49991

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Condition XV.A x Portable Grizzly Screen, when used for processing gypsum/limestone, shall follow the requirements under Section III.B of
Attachment "B".Permit No 47259 Page 14 of 40 May 21, 2010 Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Condition XV.B x The requirements for portable grizzly screen, when used for processing iron/clinkers, are
relocated under Section VIII of Attachment

"B".

7. Minor Permit Revision No. 50408

Determination Comments Condition # in

permit nos.
M190310P1-00 Delete Kept Revise Streamline

Section XVI x The requirements for the gasoline dispensing facility are deleted as these are applicable only to area source of HAPs.

VIII. MONITORING, RECORDKEEPING, REPORTING AND TESTING REQUIREMENTS

A. Rock Crushing and Screening Operations

A certified EPA Reference Method 9 observer is required to conduct a monthly survey of visible emissions emanating from the affected sources. If the opacity of the emissions observed appears to exceed the standard, the observer must conduct a certified EPA
Reference Method 9 observation. If the ob servation results in a Method 9 opacity reading in excess of the opacity standards, the Permittee must report this to ADEQ as excess emission, and initiate appropriate corr ective action to reduce the opacity. The Permittee is required to keep records of th e initial survey, any EPA Reference Method 9 observations performed and the corrective action performed.

B. Quarry, Limestone and other Material Handling Operations (Kiln Feed Silos, Proportioning Silos, Bagging System, Bulk Loading and Unloading systems and Transfer points)

1. The Permittee must conduct a monthly 1-minute visible emissions test of the
affect ed source in accordance with Method 22 of appendix A to 40 CFR part 60. If visible emissions are observed during any Method 22 test, the Permittee must conduct a 6-minute test of opacity in accordance with Method 9 of Appendix A to 40 CFR Part 60. The Method 9 test must begin within one hour of any
observation of visible emissions.

If no visible emissions are observed in six consecutive monthly tests for an affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If no visible emissions are observed during the semi-annual test for an affected source, the Permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any semi-annual or annual test, the Permittee must resume testing of that affected source on a monthly basis and
maintain that schedule until no visible em issions are observed in six consecutive monthly tests.Permit No 47259 Page 15 of 40 May 21, 2010 2. The Permittee is required to conduct pe rformance tests for opacity on all dust collectors once during the permit term in accordance with EPA Reference Method 9 of 40 CFR Part 60, Appendix A.

3. The Permittee is required to conduct one performance test once during the permit term for particulate matter emissions on some collectors in accordance with EPA Reference Method 5 of 40 CFR 60, Appendix A.

C. Coal Mill System

1. The Permittee must conduct a monthly 1-minute visible emissions test of the
affect ed sources in the coal mill syst em in accordance with Method 22 of appendix A to 40 CFR Part 60. If visible emissions are observed during any Method 22 test, the Permittee must conduct a 6-minute test of opacity in accordance with Method 9 of Appendix A to 40 CFR part 60. The Method 9 test must begin within one hour of any observation of visible emissions.

If no visible emissions are observed in six consecutive monthly tests for an affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If no visible emissions are observed during the semi-annual test for an affected source, the Permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any semi-annual or annual test, the Permittee must resume testing of that affected source on a monthly basis and
maintain that schedule until no visible em issions are observed in six consecutive monthly tests.

2. The Permittee is required to conduct EPA Reference Method 9 performance test for opacity on the dust collect ors once in the permit term.

D. Kilns and Clinker Coolers

1. The Permittee is required to operate continuous opacity monitoring systems (COMS) to continuously monitor the opac ity of visible emissions from each kiln stack, and clinker cooler No. 4 stack. The Permittee is required to perform daily visual opacity observation from each stack of clinker coolers 1, 2 and 3 in accordance with the procedures of EPA Reference Method 9 of 40 CFR 60, Appendix A. The Method 9 test must be conducted while each cooler is operating at the representative perform ance conditions. The duration of the Method 9 test must be at least 30 minutes each day.

2. The Permittee is required to install a particulate matter continuous emission monitoring system (PM CEMS) to measure the particulate matter discharged to the atmosphere from Kilns 1, 2, 3, and K iln 4 in-line kiln/raw mill. Until such time that a PM CEMS is installed, the Permittee must evaluate opacity measurements from the COMS on a 2-hour rolling average. If the 2-hour rolling average opacity exceeds 15 percent, the Permittee must investigate within 24 hours, and initiate corrective action, if required, as soon as practicable to avert or minimize possible exceedances of the particulate matter standards. The Permittee is required to maintain a reco rd of 2-hour rolling average opacity measurements, and of any corrective actions taken.

3. The Permittee is required to continuously monitor and record the temperature of the exhaust gases from Kilns 1, 2, 3 and K iln 4 in-line kiln/ raw mill at the inletPermit No 47259 Page 16 of 40 May 21, 2010 to, or upstream of, the particulate matte r control devices to demonstrate control
of dioxins/furans emissions.

4. The Permittee is required to operate co ntinuous emission monitoring systems to measure carbon monoxide (CO) and nitrogen oxides (NO X ) mass emissions from Kilns 1, 2, 3 and Kiln 4 in-line kiln/raw mill.

5. To demonstrate compliance with the par ticulate matter and opacity standards, the Permittee is required to perform annual pe rformance tests in accordance with test methods and procedures under 40 CFR § 63.1349(b)(1) on all kilns and clinker
coolers.

6. To demonstrate compliance with th e dioxins/furans emission standard, the Permittee is required to perform EPA Re ference Method 23 performance test once every 30 months. The Permittee is required to determine the applicable temperature limit for each kiln in accord ance with test methods and procedures under 40 CFR § 63.1349(b)(3).

7. To demonstrate compliance with the SO 2 emission standard, the Permittee is required to perform annual EPA Refere nce Method 6 performance test on all
kilns.

E. Raw Mills and Finish Mills

1. The Permittee is required to monitor opacity of emissions from the raw mills and finish mills by conducting daily visual emissions observations in accordance with the procedures of EPA Reference Method 22 of 40 CFR 60, Appendix A for six minutes. If visible emissions are observed during any EPA Reference Method 22 visible emissions test, the Permittee is required to initiate, within one-hour, the corrective actions specified in the Opera tion and Maintenance Plan. Within 24
hours of the end of the EPA Reference Method 22 test in which visible emissions were observed, the Permittee must conduct a follow-up Method 22 test of each stack from which visible emissions were observed during the previous Method 22 test. If visible emissions are observed during the follow-up Method 22 test from any stack from which visible emissions were observed during the previous Method 22 test, the Permittee must conduct a visual opacity test of each stack from which emissions were observed during the follow-up Method 22 test in accordance with Method 9 of Appendix A to 40 CFR Part 60. The duration of
the Method 9 test must be 30 minutes.

2. To demonstrate compliance with the op acity standards, the Permittee is required to perform annual EPA Method 9 performan ce tests on all affected sources in accordance with 40 CFR § 63.1349(b)(2).

3. To demonstrate compliance with the par ticulate matter standards, the Permittee is required to perform EPA Method 5 performance tests on dust collectors H2-DC2, C2-DC3, D4-DC2, D4-DC1, F2-DC4, AC-DC1, CM-DC17, D2-DC4.

F. Fugitive Dust Sources

1. Property Boundary Visible Emissions Monitoring

a. Propert y Boundary Line with the Rillito Community: The Permittee is required to install, and operate, dur ing daylight hours, cameras forPermit No 47259 Page 17 of 40 May 21, 2010 monitoring and recording visible emissions across the property boundary line with the Rillito Community.

b. For all property boundary lines other than the property boundary line with the Rillito Community, the Permittee is required to conduct a daily visible emissions survey during daylight hours in accordance with EPA
Reference Method 22. If visible em issions related to the Permittee’s operations are observed to cross a pr operty boundary line, the Permittee must report the emissions using the excess emission reporting procedures.

2. A certified EPA Reference Method 9 ob server is required to conduct a monthly survey of visible emissions emanating from nonpoint sources and, where applicable, fugitive emissions from a central lookout station or multiple observation points, as appropriate, in accordance with the Visible Emissions Observation Plan. If the opacity of the emissions observed appears to exceed the standard, the observer must conduct a certified EPA Reference Method 9 observation. If the observation results in a Method 9 opacity reading in excess of the opacity standards, the Permittee must report this to ADEQ as excess emission, and initiate appropriate correc tive action to reduce the opacity. The
Permittee must conduct another method 9 ob servation within 48 hours of taking
the corrective action. The Permittee is re quired to keep records of the initial survey, any EPA Reference Method 9 observations performed and the corrective action performed.

G. Ambient PM 10 and Meteorological Monitoring

The Permittee is required to opera te and maintain the ambient PM 10 particulate samplers at the existing Rillito Northwest (NW) monitoring site (8840 W. Robinson St. Rillito, AZ 85653), and the meteorological sensors at the existing Rillito Southeast (SE) monitoring site. The Permittee is required to use EPA approved samplers. Th e list of EPA approved samplers is available at:

http://www.epa.gov/ttn/amtic/files/ambient/crite ria/reference-equivalent-m ethods-list.pdf

IX. COMPLIANCE ASSURANCE MONITORING (CAM) (40 CFR 64)

A. The CAM rule applies to "pollutant-specific emission units" (PSEU) at a major Title V source if the unit meets all of the following criteria:

1. The unit is subject to an emission limit or standard for the applicable regulated air pollutant;

2. The unit uses a control device to achieve compliance with the emission limit or standard; and

3. The unit has "potential pre-control device emissions" of the applicable regulated air pollutant equal to or greater than 100% of the amount (tons/year) required for a source to be classified as a major source. "Potential pre-control device emissions" means potential to emit (PTE, as defined in Title V) except emissions reductions achieved by the applicable c ontrol device are not taken into account.

The purpose of monitoring required by the CAM rule is to assure compliance with emission standards by ensuring that control devices meet and maintain the assumedPermit No 47259 Page 18 of 40 May 21, 2010 control efficiencies. Compliance is ensured through requiring monitoring of the operation and maintenance of the control equipment and, if applicable, operating conditions of the pollutant-specific emissions unit. For the PSEU s that have post control potential to emit equal to or greater than 100 percent of the amount, in tons per year, required for a source to be classified as a major source, for each parameter monitored (“large” PSEUs), the
Permittee shall collect four or more data va lues equally spaced over each hour. For all other PSEUs (“small” PSEUs), the monitoring sh all include some data collection at least once per 24-hour period. All the affected PSEUs at CalPortland’s Rillito plant have post control emission below the major source threshold and therefore require data collection once in 24-hour period.

B. Monitoring Approach

The following dust collectors are used as th e control devices for controlling the emissions of particulate matter (both PM and PM 10 ) for the units subject to CAM requirements:

AC-DC1, BL-DC1, BL-DC2, BL-DC3, BL-D C4, BL-DC6, BL-DC7, BL-SB5-DC1, BLSB5-DC2, BL-SB5-DC3, AC-BE2-DC, F2-PS-DC1, F2-PS-DC2, F2-PS-DC3, F3-KSDC1, CM-DC8, CM-DC9, CM-DC10, CM-D C11, CM-DC12, CM-DC14, CM-DC15,
CM-DC16 and CM-DC17

The monitoring approach for the dust collectors is detailed below.

Indicator Visible emissions

Indicator Range No visible emissions.

Measurement approach Visible emissions from the control device exhaust will be monitored daily using EPA Reference
Method 22.

Bags, seals, and baghouse compartments shall be inspected annually for each baghouse.

QA/QC practices and
criteria Operate and maintain the control device in a manner consistent with good air pollution control practice.

Excursion Range Any opacity observed during the visible emission

survey.

Any bags or seals in poor condition, or accumulation of dust in the baghouse compartment during annual inspection

.

X. LIST OF ABBREVIATIONS

AAAQG ............................................................................. Arizona Ambient Air Quality Guideline
A.A.C.................................................................................................. Arizona Administrative C ode ADEQ ......................................................................Arizona Department of Environmental Quality AQD.................................................................................................................. Air Qualit y Division AQG...............................................................................................................Ai r Quality G uidelines
Btu/ft 3 ..................................................................................... British Thermal Units per Cubic Foot
CO......................................................................................................................... Carb on Monoxide

CO 2 ............................................................................................................................Car bon DioxidePermit No 47259 Page 19 of 40 May 21, 2010 DEGF.................................................................................................................. Degrees F ahrenheit DEGK ....................................................................................................................... Degr ees Kelvin FERC .................................................................................Federal Energy Regulatory Commission
ft............................................................................................................................. ..................... Feet

g .............................................................................................................................. .................Grams
HAP ............................................................................................................ Hazardous Air Po llutant hp ............................................................................................................................. .......Horsepower
hr ................................................................................................................................................Hour

IC ...................................................................................................................... Interna l Combustion
lb ............................................................................................................................. .................Pound

m .............................................................................................................................. .................Meter
MMBtu............................................................................................... Million British Thermal Uni ts

 g/m 3 ..................................................................................................... Microgram per Cubic Meter
MMCFD.................................................................................................Million Cubic Feet Per Da y NAAQS............................................................................... National Ambient Air Quality Standard

NO

x .......................................................................................................................... Nitr ogen Oxide

NO 2 ........................................................................................................................ Nitroge n Dioxide

O 3

.............................................................................................................................. ..............Ozone
Pb ............................................................................................................................. .................. Lead

PM..........................................................................................................................Par ticulate Matter

PM 10 ........................................................... Particulate Matter Nominall y less than 10 Micrometers Psia...............................................................................................Pounds per s quare Inch (abso lute)

PTE .........................................................................................................................Pot ential-to-Emit

s.............................................................................................................................. ...............Seconds
SO 2 ............................................................................................................................. Sulfur Dioxide

TPY............................................................................................................................ . Tons per Year TSP ....................................................................................................... Total Suspended Part iculate USEPA ................................................................. United States Environmental Protection Agency
VOC......................................................................................................Volatile Organic Compo und

yr ............................................................................................................................. .................... yearPermit No 47259 Page 20 of 40 May 21, 2010 TECHNICAL REVIEW AND EVALUATION FOR

ARIZONA PORTLAND CEMENT COMPANY AIR QUALITY PERMIT NO. 38592 (ATTACHMENT-SIGNIFICANT REVISION TO OPERATING PERMIT NO. M190310P1-00)

I. INTRODUCTION

Arizona Portland Cement Company and other subsidiaries of California Portland Cement Company own and operate a limestone quarry, a Po rtland cement manufacturing plant, and a rock and stone aggregate plant in Rillito, Arizona.

Company Information

Facility Name: Arizona Portland Cement Company

Facility Address: 11115 N. Casa Grande Highway Rillito, Pima County, Arizona 85654

Mailing Address: P.O. Box 338 Rillito, AZ 85654

The Permittee was issued Permit Number M190310P1-00, a Class I operating permit, on October 7, 2003. The present application for a signifi cant permit revision was received on December 14, 2005. The proposed significant revision, Permit Nu mber 38592, will provide for the construction of the “Kiln 6 Project,” a major modification of the existing major stationary source. The new conditions will be considered an alternate operati ng scenario and will be contained in Attachment “E” to the Operating Permit. The requirements in Attachment “E” will become applicable on the earlier of the first calendar day when the Kiln 6 production rate exceeds 6,480 tons of cement clinker, or on the 180th day following initial firing of fuel in Kiln 6.

The existing major source is located in an area that is classified as nonattainment with respect to particulate matter with aerodynamic diameter less than 10 microns (“PM-10”) and is either
classified attainment or unclassifiable with respect to all remaining criteria pollutants.

II. FACILITY DESCRIPTION

A. EXISTING FACILITY

The existing major stationary source includes a limestone quarry, a Portland cement manufacturing plant, and a rock and stone aggreg ate plant. The existing Portland cement plant includes four cement kilns and clinker coolers, with a total clinker production capacity of 264 tons per hour, and ancillary equipment for fuel receiving and handling, feed materials receiving and handling, clinker grinding, and Port land cement manufacturing and shipping.

The existing source has the potential to emit several regulated air pollutants at rates exceeding the major source thresholds at A.A.C. R18-2-101(64)(b )(i) and R18-2-401(9). Therefore, the facility is classified as a major source as defined in A. A.C. R18-2-101(64) and is a major stationary source for the purposes of A.A.C. R18-2-403 and -406.

B. PROPOSED MODIFICATION

The present significant permit revision application is for the construction of the Kiln 6 Project. This proposed project involves significant chang es to the Portland cement manufacturing plant,Permit No 47259 Page 21 of 40 May 21, 2010 including the following major items:

A new pyroprocessing system featuring a dry process, preheater/precalciner kiln with inline raw mill, tire-derived fuel firing syst em, clinker cooler, and air pollution control systems. The new pyroprocessing line will ha ve a clinker production capacity of 300 tons per hour, approximately 14 percent more than the total capacity of the four existing kilns; Revisions to the rail unloading, handling, an d storage facilities for coal and petroleum coke; New solid fuel grinding system; Expanded and upgraded facilities for raw materials storage and reclaim, milling, and homogenizing; Expanded and upgraded facilities fo r clinker storage and handling; Expanded and upgraded facilities for cement milling, storage, and handling; and A new Diesel-powered emergency generator.

The utilization of the quarry will increase as a result of the Kiln 6 Project, but no physical or operational changes will be made to the quarry equi pment. The Kiln 6 Project will not have any effect on the rock and stone aggregate plant.

Additional detail regarding the proposed modificatio n is provided in Section 2.0 of the December 2005 permit application.

III. EMISSIONS

The proposed Kiln 6 Project will result in a net in crease in PM-10 emissions of 45.8 tons per year (“tpy”), in excess of the PM-10 significant level of 15 tpy as defined at A.A.C. R18-2- 101(106)(a). Therefore, the proposed modification is a major modification with respect to PM-10 emissions pursuant to the Nonattainment New S ource Review (NNSR) rule at A.A.C. R18-2- 403(A).

The proposed Kiln 6 Project will result in a net increase in SO 2 emissions of 127.2 tpy, in excess
of the SO 2 significant level of 40 tpy as defined at A.A.C. R18-2-101(106)(a). Therefore, the proposed modification is a major modification with respect to SO 2 emissions pursuant to the Prevention of Significant Deterioration (PSD) rule at A.A.C. R18-2-406(A). In addition, because the project will result in a significant increase in PM-10 emissions, the project is considered a major modification under the PSD rule with respect to PM-2.5 emissions. 1 Net emissions increases of all other regulated air pollutants are less than the corresponding significant levels.

The emissions increases from th e proposed Kiln 6 Project and the new facility-wide potential to
emit are summarized in Table 1. Detailed docum entation of the emissions calculations and net emissions increase determinations is provided in the December 2005 permit application and in the April 2007 supplement to the permit application.



### TABLE 1: EMISSIONS CHANG ES FROM KILN 6 PROJECT

Pollutant Net Emissions Increase or Decrease Potential to Emit

1 PM-2.5 is a criteria pollutant, and the proposed project s ite is in an area designated as unclassifiable/attainment with respect to the PM-2.5 National Ambient Air Quality Standard, so PM-2.5 is a regulated pollutant under the PSD rule. Pending further rulemaking, the Department and the U.S. EPA are implementing applicable new source review requirements for PM-10 emissions as a surrogate for PM-2.5 emissions.Permit No 47259 Page 22 of 40 May 21, 2010 PM-10 45.8 482.3

SO 2 127.2 186.4

NO X -1,674.1 2,302.4

CO -762.0 3,783.7

VOC 35.4 42.6

Fluorides 0.4 0.95

PM -2.8 936.9

Lead 0.0 0.03

Sulfuric Acid Mist 0.9 2.3

IV. APPLICABLE REGULATIONS

A. APPLICABILITY SUMMARY

Table 2 summarizes the findings of the Department with respect to the applicability or non-applicability of specific regulations to em ission units proposed to be constructed or modified as part of the Kiln 6 Project.



### TABLE 2: REGULATORY ANALYSIS

Unit ID Regulation(s) Applicable? (Y/N) Verification

PSD
A.A.C R18-2-406 Y Project will result in significant net
emissions increases of SO 2 and PM-10 (as surrogate for PM-2.5).

Project will not result in significant net
emissions increases of other PSD regulated pollutants. See Table 1. Entire
Project

NNSR
A.A.C R18-2-403 Y Project will result in significant net
emissions increase of PM-10.

Kiln 6 New Source Performance Standards (NSPS)
A.A.C R18-2-901 N Unit is subject to 40 CFR 63 subpart LLL and is exempt from NSPS pursuant to 40 CFR § 63.1356(a).Permit No 47259 Page 23 of 40 May 21, 2010 Unit ID Regulation(s) Applicable? (Y/N) Verification

National Emission Standards
for Hazardous Air Pollutants

(NESHAP) for Portland Cement Manufacturing A.A.C. R18-2-1101(B)(50) Y The Permittee has indicated that the facility is a major source of Hazardous Air Pollutant (HAP) emissions and that Kiln 6 and the raw mill will comprise an in-line kiln/raw mill under 40 CFR § 63.1341. The facility is subject to applicable emission standards for new inline kiln/raw mills at major sources.

Compliance Assurance Monitoring
40 CFR 64 Y The kiln is subject to PM-10 emission limits, uses a control device to comply with those limits, and has the uncontrolled potential to emit PM-10 in amounts greater than 100 tons per year.

Raw Mill NESHAP for Portland Cement Manufacturing A.A.C. R18-2-1101(B)(50) Y The Permittee has indicated that Kiln 6 and the raw mill will comprise an in-line kiln/raw mill under 40 CFR § 63.1341. Accordingly, the raw mill is prohibited from operating independently of the kiln and is not subject to the separate
standards for raw mills and raw material dryers.

NESHAP for Portland Cement Manufacturing A.A.C. R18-2-1101(B)(50) Y Facility meets the definition of a clinker cooler under 40 CFR § 63.1341. Clinker
Cooler

Compliance Assurance Monitoring

40 CFR 64 Y The kiln is subject to PM-10 emission limits, uses a control device to comply with those limits, and has the uncontrolled potential to emit PM-10 in amounts greater than 100 tons per year.

Finish Mills,
Raw Material

and Clinker Storage and Handling,
Bulk Unloading and Loading, and

Bagging Systems NESHAP for Portland Cement Manufacturing A.A.C. R18-2-1101(B)(50) Y Several facilities within the cement plant
meet the affected source definitions under 40 CFR §§ 63.1340 and 63.1341.

Coal Preparation
Plant New Source Performance Standards (NSPS) for Coal Preparation Plants A.A.C R18-2-901(32) Y The Permittee has indicated that both coal mills and several coal conveying systems will be modified, constructed, or
reconstructed. Coal mills use heated air to dry the coal and ar e considered thermal dryers under 40 CFR § 60.251.

Quarry and
Limestone Processing NSPS for Nonmetallic Mineral Processing Plants

A.A.C R18-2-901(66) N N o new, modified, or reconstructed limestone crushers, grinding mills, screening operations, bucket elevators,
b elt conveyors, bagging operations, storage bins, or enclosed truck or railcar loading stations.Permit No 47259 Page 24 of 40 May 21, 2010 Unit ID Regulation(s) Applicable? (Y/N) Verification

A.A.C R18-2-702(B)(1) Y Equipment is subject to the generally applicable opacity emission standard because it is not subject to any other opacity standard.

P.C.C. § 17.16.370.B.1 Y Limestone processing equipment includes rock crushers, screens, conveyors and conveyor transfer points, stackers, reclaimers, and rock storage piles.

NSPS for Stationary Compression Ignition Internal Combustion Engines 40 CFR 60 subpart IIII Y Unit is an emergency engine and an affected facility and must meet emission specifications for CO, PM, and total NO X plus nonmethane hydrocarbons. Emergency
Generator

NESHAP for Stationary Reciprocating Internal Combustion Engines 40 CFR 63 subpart ZZZZ Y Engine meets the applicability criteria but is subject only to recordkeeping requirements because it is an emergency engine.

B. PSD APPLICABILITY

As provided by A.A.C. R18-2-306.01, the Permittee has voluntarily proposed several emission limits and operational requirements that have the effect of constraining the emissions increases from the Kiln 6 project. As a result, the project will not cause significant emissions increases and will not be subject to applicable requirements under the PSD program with respect to emissions of NO X , PM, CO, or VOC. The Permittee’s PSD applicability analysis for these polluta nts is presented in Section 6.0 of the December 2005 Class I permit application. These “synthetic minor” permit terms include the following:

 The existing Kilns 1-4, associated Clinker Coolers, and numerous other emissions units are required to shut down concurrently with the Kiln 6 project. These emissions units are currently aut horized to operate under Sections I through VIII of Attachment “B” of the Class I Permit Number M190310P1-00. The shutdown requirements are effected in the permit by superseding those sections; only the emissions units that are authorized to continue to operate are
carried forward into the new Attachment “E.”

 The production of cement clinker in Kiln 6 is limited to 2.3 million tons per year.

 The Kiln 6 Stack will be limited to emission rates of 28.03 lbs of PM-10 per hour; 2,245.5 tons of NO X per year; 3,680 tons of CO per year; and 44.25 tons of VOC per year. 2

 All baghouses and dust collectors other than the Kiln 6 baghouse will be limited to a PM-10 emission rate of 0.005 grains per dry standard cubic foot and to corresponding limits on mass emission rate.

 The operations at the quarry, including the number of blasts, the use of explosives, and the amount of limestone quarried, are subject to enforceable

2 These mass emission limits are enforceable only in term s of mass emission rate, rega rdless of clinker production rate. For reference purposes, the Department notes that, assuming constant operation at the allowable clinker production rate of 2.3 million tons per year, these emission rates are equivalent to 0.11 lb of PM-10, 1.95 lbs of

NO X , 3.2 lbs of CO, and 0.04 lb of VOC per ton of clinke r produced. At lower clinker production rates, the allowable emissions per ton of clinker are higher.Permit No 47259 Page 25 of 40 May 21, 2010 limits.

 The Permittee is required to implement an improved dust control plan, sufficient to ensure a minimum 85 percent control efficiency for PM and PM-10 emissions from unpaved roads.

V. CONTROL TECHNOLOGY DETERMINATIONS

A. Best Available Control Technology (BACT) for SO 2 Emissions

As noted in Section III, the Kiln 6 project is a major modification subject to PSD review with respect to SO 2 emissions increases. Pursuant to A.A.C. R18-2-406(A)(2), for a major modification, BACT is required for “ea ch proposed emissions unit at which a net emissions increase in the pollutant would occur as a result of a physical change or change in the method of operation in the unit.” This includes the new Kiln 6 inline kiln/raw mill and the new emergency generator.

1. SO 2 BACT Analysis for Kiln 6 Inline Kiln/Raw Mill

The Permittee submitted an SO 2 BACT analysis for Kiln 6 in its April 2007 supplement to the Class I permit application. The Department concurs with this analysis, including the Permittee’s conclusion that BACT is an SO 2 emission limit of 0.16 lb per ton of clinker, based on a 30-day rolling average. This BACT determination is based on the following key points:

 The SO 2 emissions are primarily dependent on the sulfur content of the
feed materials and on the inherent SO 2 removal in the raw mill.

 SO 2 emissions from Kiln 6 will be higher than those from the existing Kiln 4 because a smaller fraction of the exhaust gas from the kiln and preheater will be routed through the raw mill.

 The raw mill does not operate continuously.

 The continuously achievable SO 2 emission limit, based on feed material
sulfur content and SO 2 removal in the raw mill, is 0.16 lb per ton of clinker, as determined on a 30-day rolling average.

 Additional SO 2 control could be achieved with a flue gas desulfurization system, but the SO 2 emission reductions achievab le with such technology are outweighed by the adverse environmental, energy, and economic impacts.

2. SO 2 BACT Analysis for Emergency Generator

The Permittee submitted an SO 2 BACT analysis for the Diesel-powered emergency generator internal combustion engine in its April 2007 supplement to the Class I permit application. The Department concurs with this analysis, including the Permittee’s conclusion that BACT is a fuel specification requiring the use of fuel meeting the requirements of 40 CFR § 80.510(b), including a sulfur limit of 15 parts per million by weight.

B. Lowest Achievable Emission Rate (LAER) for PM-10 Emissions

As noted in Section III, the Kiln 6 project is a major modification subject to NNSR with respect to PM-10 emissions increases. Pursuant to A.A.C. R18-2-403(A)(1), LAER is required for each proposed emissions unit at which a net emissions increase in the pollutant would occur as a result of a physical change or change in the method ofPermit No 47259 Page 26 of 40 May 21, 2010 operation in the unit. This includes the new Kiln 6 inline kiln/raw mill; numerous dust collectors serving the limestone processing, coal preparation, and cement plant operations; fugitive emission sources associated with materials handling; and the new
emergency generator.

1. PM-10 LAER Analysis for Kiln 6 Inline Kiln/Raw Mill

The Permittee submitted a PM-10 LAER an alysis for Kiln 6 in its December 2005 Class I permit application. The Depa rtment concurs with this analysis, including the Permittee’s conclusion that LAER is a PM-10 emission limit of 0.008 grain per dry standard foot of exha ust gas. This emission rate is more stringent than any emission limitation achiev ed in practice or contained in a State Implementation Plan for any similar source.

2. PM-10 LAER Analysis for Clinker Cooler

The Permittee submitted a PM-10 LAER analysis for the new Clinker Cooler in its December 2005 Class I permit application. The Department concurs with this analysis, including the Permittee’s conclusion that LAER is a PM-10 emission limit of 0.005 grain per dry standard foot of exhaust gas. This emission rate is more stringent than any emission limitation achieved in practice or contained in a State Implementation Plan for any similar source.

Of particular note with regard to the Clinker Cooler LAER analysis is the
Permittee’s evaluation of ventless Clinke r Cooler technology as documented in the April 2007 supplement to the Class I permit application. The Department requested that the Permittee perform this evaluation pursuant to a comment from U.S. EPA during its review of the Kiln 6 permit application. The Permittee concluded, and the Department concurs, that the emissions limitations achievable with this technology do not represent LAER. This conclusion is based primarily on the fact that the California facility using ventless clinker cooler technology does not achieve more stringent emission limitations than that proposed by the
Permittee. The filterable PM emission limit for that facility’s combined exhaust, through which both the kiln and the clinke r cooler are exhausted, is equal to approximately 0.25 lb per ton of clinker produced. The limits for the kiln and clinker cooler being installed as part of the proposed Kiln 6 project are equal to approximately 0.12 lb per ton of clinke r produced, including both filterable and condensible PM-10. In addition, the ventless clinker cooler system is not technically feasible for the proposed Kiln 6 without significantly redefining the design of the process.

3. PM-10 LAER Analysis for Materials Handling Dust Collectors

The Permittee submitted a PM-10 LAER anal ysis for the new and modified nonfugitive materials handling sources in its December 2005 Class I permit application. The Department concurs with this analysis, including the
Permittee’s conclusion that LAER for each of these units is a PM-10 emission limit of 0.005 grain per dry standard foot of exhaust gas. This emission rate is more stringent than any emission limitation achieved in practice or contained in a State Implementation Plan for any similar sources.

4. PM-10 LAER Analysis for Materials Handling Fugitive Dust

The Permittee submitted a PM-10 LAER analysis for the new and modifiedPermit No 47259 Page 27 of 40 May 21, 2010 equipment for handling of solid fuels that will emit fugitive dust in an August 29, 2007, supplement to its Class I permit application. The Department concurs with this analysis, including the Permittee’s conclusion that LAER for these activities is the use of water sprays to keep the material sufficiently moist. The Department is not aware of any more stringent emission limitation achieved in practice or contained in a State Implementation Plan for any similar sources.

5. PM-10 LAER Analysis for Emergency Generator

The Permittee submitted a PM-10 LAER analysis for the Diesel-powered emergency generator internal combustion engine in its April 2007 supplement to the Class I permit application. The Department concurs with this analysis, including the Permittee’s conclusion that LAER is a PM-10 emission limit of 0.20 grams per kilowatt-hour, determined in accordance with the certification requirements at 40 CFR § 60.4202.

VI. EMISSIONS OFFSET REQUIREMENTS

As noted in Section III, the Kiln 6 project is a major modification subject to NNSR with respect
to PM-10 emissions increases. Pursuant to A.A.C. R18-2-403(A)(3) and R18-2-404, PM-10 emission reductions meeting certain criteria are re quired to be obtained as a condition of the Class I permit. As described more fully in the December 2005 Class I permit application and the April 2007 supplement to that application, the PM-10 emissions increases from the Kiln 6 project are 294.3 tons per year. The emissions offset and net air quality benefit requirements are met using emission reductions totaling 298.9 t ons per year, determined as follows:

 249.2 tons per year from emissions decreases occurring at the Arizona Portland Cement plan as a result of the Kiln project, primarily involving shutdown of existing equipment;
and

 49.7 tons per year from emissions decreas es achieved by Arizona Portland Cement Company by installing gates to preclude pu blic vehicle access to a segment of the unpaved road crossing the facility’s property.

VII. ALTERNATIVES ANALYSIS

As noted in Section III, the Kiln 6 project is a major modification subject to NNSR with respect
to PM-10 emissions increases. Pursuant to A. A.C. R18-2-403(B), the Permittee performed an analysis of alternative sites, sizes, production processes, and environmental control techniques for the proposed Kiln 6 project. This analysis is presented in Section 6.0 of the April 2007 supplement to the Class I permit application. The Department has reviewed this analysis and has determined that the benefits of the project si gnificantly outweigh the environmental and social costs imposed as a result of its plant’s modification at its existing location. Of particular importance in the Department’s determ ination are the following key points:

 The proposed modification of the existing plan t will result in substantial reductions in

NO X and CO emissions. If the proposed Kiln 6 were sized differently or located at a different site, these emission reductions at the Rillito site would likely not be realized.

 The proposed Kiln 6 inline kiln/raw mill will use state-of-the-art technology for Portland cement production, and no known alternative production process would have less environmental impact.

VIII. STATEWIDE COMPLIANCE CERTIFICATION

As noted in Section III, the Kiln 6 project is a major modification subject to NNSR with respectPermit No 47259 Page 28 of 40 May 21, 2010 to PM-10 emissions increases. Pursuant to A.A.C. R18-2-403(A)(2), the Permittee is required to demonstrate that that all existing major sources ow ned or operated by the Permittee, or any entity controlling, controlled by, or under common control with the Permittee, in Arizona are in compliance with, or on a schedule of compliance for, all conditions contained in permits of each of the sources and all other applicable emission li mitations and standards under the Act and under A.A.C. title 18, chapter 2. Section 4.3 of the April 2007 supplement to the Class I permit application stated that the Rillito facility is th e only existing major source in Arizona owned or operated by the Permittee, or any entity controllin g, controlled by, or under common control with the Permittee. APCC certified that it is currently in compliance with all applicable requirements as identified in its Title V permit. In 2003, EPA issued a Notice of Violation (NOV) to the Permittee for violations of applicable state im plementation plan requirements. The NOV has not yet been closed. A schedule of compliance is not required in this significant revision to Operating Permit No. M190310P1-00 under A.A.C. R 18-2-403(A)(2) to address any issues in the

NOV.

IX. MONITORING AND RECORDKEEPING REQUIREMENTS

A. KILN 6 INLINE KILN/RAW MILL

1. Portland Cement NESHAP

As noted in Table 2, the inline kiln/raw mill is an affected source under the NESHAP for Portland cement plants, subpa rt LLL of 40 CFR part 63. This rule, as all NESHAP regulations promulgated after 1990, includes monitoring and recordkeeping requirements that satisfy the enhanced monitoring requirements of the 1990 Clean Air Act Amendments. The NESHAP monitoring and recordkeeping requirements included in th e permit, as required by A.A.C. R18-2- 306(A)(3) and R18-2-306(A)(4), include the following:

 Continuous opacity monitoring system, operated in accordance with Performance Specification 1 in appendix B to 40 CFR part 60. This system is used to determine continuous compliance with the NESHAP opacity limit of 20 percent;

 Continuous emission monitoring system for total hydrocarbon emissions, operated in accordance with Performance Specification 8a in appendix B to 40 CFR part 60. This system is used to determine continuous compliance with the NESHAP total hydrocarbon concentration limit of 20 parts per million by volume, dry basis, corrected to 7 percent oxygen;

 Continuous monitoring of the temperature of the exhaust gases at the inlet to, or upstream of, the Kiln 6 baghouse. This temperature monitoring device is used to dete rmine continuous compliance with temperature limits that serve as surrogates for the NESHAP dioxin/furan emission limit. The temperature limits are established based on the baghouse inlet temperature during successful dioxin/furan performance testing;

 Bag leak detection system for the Kiln 6 baghouse. This monitoring is used, in conjunction with other recordkeeping described below, to determine continuous compliance w ith the NESHAP mercury emission standard of 41 micrograms per dry standard cubic meter, corrected to 7 percent oxygen. It should be noted th at the bag leak detection system is not directly required by the subpart LLL regulation; instead, subpart LLL requires compliance with the baghouse monitoring requirements in the NESHAP for control devices, subpart SS of 40 CFR part 63, but that rule does not specify monitoring for baghou ses. A bag leak detection systemPermit No 47259 Page 29 of 40 May 21, 2010 was proposed by the Permittee, pursuant to 40 CFR § 63.995(c), and was subsequently approved by the Department;

 Recordkeeping for fly ash derivation. This recordkeeping, including certification from the supplier of each shipment of fly ash received, is required to demonstrate continuous compliance with the conditional prohibition on burning any fly ash that is derived from a source in which the use of activated carbon, or any ot her sorbent, is used as a method of mercury emissions control. The NESHAP permits the use of such fly ash only if the Permittee makes a dem onstration that such use will not increase mercury emissions above the level achieved without such fly ash; and

 Operations and maintenance plan. This plan is required to include adequate procedures for proper ope ration and maintenance of the affected source and air pollution control devices in order to meet the NESHAP emission limits and operating limits.

2. Other Requirements

In addition to the NESHAP monitoring and recordkeeping requirements, the permit also includes monitoring and reco rdkeeping requirements sufficient to ensure continuous compliance with the limits established pursuant to PSD and NNSR program requirements as described in Sections V and XI herein, and voluntarily accepted “synthetic minor” emission limits as described in Section IV.B herein. These requirements include the following:

 Continuous monitoring of kiln f eed rate to determine continuous compliance with the daily and annual clinker production rates;

 Continuous emission rate monitoring system for SO 2 , to determine continuous compliance with the SO 2 BACT limit;

 Continuous emission rate monitoring systems for CO, VOC, and NO X , to determine continuous compliance with the synthetic minor limits;

 Bag leak detection system for the Kiln 6 baghouse. This monitoring is the basis for the Comp liance Assurance Monitoring plan submitted by the Permittee for determining contin uous compliance with the BACT, LAER, and dispersion modeling based PM-10 emission limits.

B. CLINKER COOLER

The Clinker Cooler monitoring and recordk eeping requirements included in the permit include the following:

 Continuous opacity monitoring system, operated in accordance with Performance Specification 1 in appendix B to 40 CFR part 60. This system is used to determine continuous compliance with the NESHAP opacity limit of 10 percent;

 Bag leak detection system for the Clinker Cooler baghouse. This monitoring is the basis for the Compliance Assurance Monitoring plan submitted by the Permittee for determining continuous compliance with the BACT, LAER, and dispersion modeling based PM-10 emission limits;

 Operations and maintenance plan. This plan is required to include adequate procedures for proper operation and mainte nance of the affected source and air pollution control devices in order to meet the NESHAP emission limits and operating limits.Permit No 47259 Page 30 of 40 May 21, 2010 C. FINISH MILLS

The permit includes the following monitoring and recordkeeping requirements for finish
mills:

 Bag leak detection systems, used to determine continuous compliance with the NESHAP opacity limit of 10 percent and the BACT, LAER, and dispersion modeling based PM-10 emission limits; and

 Operations and maintenance plan. This plan is required to include adequate procedures for proper operation and mainte nance of the affected source and air pollution control devices in order to meet the NESHAP emission limits and operating limits.

D. PORTLAND CEMENT PLANT STORAGE BINS, CONVEYING SYSTEM TRANSFER POINTS, BAGGING SYSTEMS, BULK UNLOADING SYSTEMS,
AND BULK LOADING SYSTEMS

The permit includes the following monitoring and recordkeeping requirements for the materials handling operations with in the Portland cement plant:

 Bag leak detection systems for certain dust collectors. These systems will be used to determine continuous compliance with the NESHAP opacity limit of 10 percent and the BACT, LAER, and dispersion modeling based PM-10 emission limits; and

 For all dust collectors not equipped with ba g leak detection systems, continuous monitoring of pressure drop across the dust collector in conjunction with periodic
visible emissions observations in order to determine continuous compliance with the NESHAP opacity limit of 10 percent and the BACT, LAER, and dispersion modeling based PM-10 emission limits; and

 Operations and maintenance plan. This plan is required to include adequate procedures for proper operation and mainte nance of the affected source and air pollution control devices in order to meet the NESHAP emission limits and operating limits.

E. MATERIALS HANDLING IN THE QUARRY AND LIMESTONE PROCESSING
PLANT

The permit includes the following monitoring and recordkeeping requirements for the quarrying and limestone materials handling operations:

 Daily recording of the number of blasts performed in the quarry, the amount of limestone quarried, and the amount of expl osive used, in order to determine continuous compliance with the ope rational limits on these parameters;

 Continuous monitoring of pressure drop across all dust collectors. This monitoring is used to determine con tinuous compliance with the BACT, LAER, and dispersion modeling based PM-10 emission limits; and

 Periodic visible emissions observations . These observations are used to determine continuous compliance with the process weight rate based PM emission limits under the Pima County Code; and the opacity limits for existing
sources under Article 7.

F. MATERIALS HANDLING IN THE COAL PREPARATION PLANT

The permit includes the following monitoring and recordkeeping requirements for thePermit No 47259 Page 31 of 40 May 21, 2010 coal preparation plant:

 Continuous monitoring of exhaust gas temp erature at the exit of each coal mill, upstream of the coal mill dust collectors. This monitoring is required by the NSPS for coal preparation plants because the coal mills are considered thermal dryers under that regulation;

 Continuous monitoring of pressure drop across all dust collectors. This monitoring is used to determine con tinuous compliance with the BACT, LAER, and dispersion modeling based PM-10 emission limits;

 Periodic visible emissions observations . These observations are used to determine continuous compliance with the process weight rate based PM emission limits under the Pima County Code and the opacity limits for existing sources under the NSPS for coal preparation plants.

G. EMERGENCY GENERATOR

The permit includes the following monitoring and recordkeeping requirements for the
emergency generator:

 Continuous monitoring of the operating ho urs of the emergency generator, using a non-resettable hour meter. This monitoring is used to determine continuous compliance with the operational limits voluntarily accepted by the Permittee in order to qualify the emergency generato r internal combustion engine as an emergency engine under the applicable NSPS and NESHAP, subpart IIII of 40 CFR part 60 and subpart ZZZZ of 40 CFR part 63;

 Daily records of the type, quantity, and sulfur content of fuel used. These
records are used to determine continuou s compliance with the BACT and NSPS fuel restrictions; and

 Daily visible emissions observations for each day on which the generator operates, other than emergency operation. These observations are used to determine continuous compliance with the opacity limit under Article 7.

X. PERFORMANCE TESTING REQUIREMENTS

A. KILN 6 INLINE KILN/RAW MILL

1. Portland Cement NESHAP

As noted in Table 2, the inline kiln/raw mill is an affected source under the NESHAP for Portland cement plants, s ubpart LLL of 40 CFR part 63. The NESHAP performance testing is required to be performed within 60 days after achieving the maximum production rate at which the affected source will be operated, or within 180 days after initia l startup, whichever is earlier. The NESHAP performance testing requirement s included in the permit, as required by A.A.C. R18-2-306(A)(3), include the following:

 Performance testing for PM emissi ons using EPA Reference Method 5, with separate tests run with and without the raw mill in operation;

 Performance testing for opacity of visible emissions, based on the data gathered by the continuous opacity monitoring system described in Section IX.A.1 herein, concurrent with the PM performance tests described above;

 Performance testing for dioxin/fura n emissions using EPA Reference Method 23, with separate tests run with and without the raw mill inPermit No 47259 Page 32 of 40 May 21, 2010 operation. This testing is required to be repeated once every thirty months;

 Performance testing for total hydrocarbons emissions, using the data gathered by the total hydrocarbon continuous emission monitoring system described in Section IX.A.1 herein, with separate tests run with and without the raw mill in operation; and

 Performance testing for mercury emi ssions using either EPA Reference Method 29 or ASTM Method D6784-02, with separate tests run with and without the raw mill in operation.

2. Other Requirements

In addition to the NESHAP performance testing requirements, the permit also requires performance testing to dem onstrate compliance with the PM-10 emission limits established pursuant to PSD and NNSR program requirements as described in Sections V and XI herein. Separate tests are required to be run with and without the raw mill in operation. This testing, as the NESHAP performance testing, is required to be performed once within 60 days after achieving the maximum production rate at which the affect ed source will be operated, or within 180 days after initial startup, whichever is earlier. Testing is required to be repeated annually. The Permittee has sever al options for the test methods to be
used:

 EPA Reference Methods 5 or 201a for filterable PM emissions, plus;

 EPA Reference Method 202 or EPA Other Test Method 28 (OTM-28)
for condensable PM-10 emissions.

B. CLINKER COOLER

1. Portland Cement NESHAP

The NESHAP performance testing is requi red to be performed within 60 days after achieving the maximum production rate at which the affected source will be operated, or within 180 days after initial startup, whichever is earlier. The permit includes the following NESHAP perfo rmance testing requirements:

 Performance testing for PM emissi ons using EPA Reference Method 5, with separate tests run with and without the raw mill in operation; and

 Performance testing for opacity of visible emissions, based on the data gathered by the continuous opacity monitoring system described in Section IX.B herein, concurrent with the PM performance tests described
above.

2. Other Requirements

In addition to the NESHAP performance testing requirements, the permit also requires performance testing to dem onstrate compliance with the PM-10 emission limits established pursuant to PSD and NNSR program requirements as described in Sections V and XI herein. This testing, as the NESHAP performance testing, is required to be performed once within 60 days after achieving the maximum production rate at which the affected source will be operated, or within 180 days after initial startup, whichever is earlier. Testing is required to be repeated annually. The Permittee has several options for the test
methods to be used:Permit No 47259 Page 33 of 40 May 21, 2010  EPA Reference Methods 5 or 201a for filterable PM emissions, plus;

 EPA Reference Method 202 or EPA Other Test Method 28 (OTM-28)
for condensable PM-10 emissions.

C. PORTLAND CEMENT PLANT FINISH MILLS, STORAGE BINS, CONVEYING
SYSTEM TRANSFER POIN TS, BAGGING SYSTEMS, BULK UNLOADING SYSTEMS, AND BULK LOADING SYSTEMS

The permit includes the following performance testing requirements for the finish mills and materials handling operations w ithin the Portland cement plant:

 Initial performance testing for opacity of visible emissions, using EPA Reference Method 9, to demonstrate compliance with the NESHAP opacity limits. This performance testing is required to be pe rformed within 60 days after achieving the maximum production rate at which the affected source will be operated, or within 180 days after initial startup, wh ichever is earlier. The 180-day deadline applies to the Method 9 performance t est pursuant to 40 CFR §§ 63.7(a)(2)(ii) and 63.1349(b)(2).

 Performance testing for PM emissions, using EPA Reference Method 5, to demonstrate compliance with the PM emission limits required under BACT, LAER, and dispersion modeling requirements. This testing is required to be performed once within 60 days after ac hieving the maximum production rate at which the affected source will be opera ted, or within 180 days after initial startup, whichever is earlier. In addition, if there are three years or more remaining in the term of the Class I pe rmit at the time the initial testing is performed, the permit requires that this performance testing be repeated once during the permit term, not more than 12 months prior to permit expiration.

D. MATERIALS HANDLING IN THE QUARRY AND LIMESTONE PROCESSING
PLANT

The permit includes performance testing requi rements for each dust collector associated with the limestone processing plant in orde r to determine compliance with the BACT, LAER, and dispersion modeling based PM-10 emission limits and the process weight rate based PM emission limits under the Pima County Code. The testing is required to be
conducted in accordance with EPA Reference Methods 1-4, plus EPA Reference Method 5 for PM. The Permittee has the option using the Method 5 test results to demonstrate compliance with the PM-10 emission limits, or conducting separate tests using EPA
Reference Methods 201 or 201a for filterab le PM-10 emissions. Because the limestone processing operations occur at ambient temperatures, no condensible particulate matter is expected and no testing for that fraction is required.

For each dust collector, the testing is required to be performed within 60 days after achieving the maximum production rate at which th e affected facility will be operated, or within 180 days after initial startup, whichever is earlier.

E. MATERIALS HANDLING IN THE COAL PREPARATION PLANT

The permit includes performance testing requirements for each dust collector and each conveyor transfer point associated with the coal preparation plant in order to determine compliance with the PM emission limits required under BACT, LAER, NSPS, and dispersion modeling requirements. The testing is required to be conducted in accordance
with EPA Reference Methods 1-5 for PM a nd EPA Reference Method 9 for opacity. ThePermit No 47259 Page 34 of 40 May 21, 2010 initial testing is required to be performed within 60 days after achieving the maximum production rate at which the affected facility will be operated, or within 180 days after initial startup, whichever is earlier. If there ar e three years or more remaining in the term of the Class I permit at the time the initial testing is performed, the permit requires that the performance testing be repeated once during the permit term, not more than 12 months prior to permit expiration.

XI. PSD AIR QUALITY IMPACTS ANALYSIS

As noted in Section III, the Kiln 6 project is a major modification subject to PSD review with respect to SO 2 emissions increases. Accordingly, the Permittee conducted an ambient air quality impact analysis as required by A.A.C. R18-2- 406(A)(5) and R18-2-407. This analysis was submitted as part of the April 2007 supplement to the Class I permit application. As detailed below, the Department has reviewed this analys is and concurs with the Permittee’s conclusions.

A. GROWTH ANALYSIS

Pursuant to A.A.C. R18-2-407(I), the Permitte e was required to perform an analysis of general commercial, residential, industrial, and other growth associated with the proposed modification. The projected growth is require d to be considered in other portions of the the ambient air quality impact analysis, as d escribed below. The Permittee submitted, in Section 8.3.5 of the April 2007 supplement to the Class I permit application, a brief analysis showing that the Kiln 6 Project will not require any additional employees over the current workforce to oper ate the cement plant. Becau se no additional workforce is needed, there will be no associated growth.

B. DEMONSTRATION OF COMPLIANCE WITH AMBIENT STANDARDS

The Permittee conducted dispersion modeli ng analyses in order to demonstrate compliance with the National Ambient Ai r Quality Standards (NAAQS) and PSD increments. The results of this analysis were submitted in the December 2005 permit application and in Section 8 of the April 2007 supplement to the permit application. The Department has reviewed this analysis a nd has determined that it was performed in accordance with Section 5.0 of the Department ’s “Air Dispersion Modeling Guidelines for Arizona Air Quality Permits.”

1. Model Description and Data Processing

Based on recommendations from the Department, the Permittee’s dispersion modeling analysis used U.S. EPA’s refined model ISCPRIME (version 04269) with the regulatory default option set. This option requires the use of terrain elevation data, stack-tip downwash, se quential date checking, and does not permit the use of the model in the SCR EEN mode. In the regulatory default mode, pollutant half life or decay options are not employed . The non-guideline model OBODM (Open Burning/Open Detonation Model) was also used to assess impacts from Quarry blasting.

Receptor density was adequate to demonstrate assessment of maximum concentrations. Receptor elevations were calculated from USGS DEM data.

2. Emission and Stack Data

Table 3a presents a summary of the mode led emission rates a nd stack parameters for each major point source. Additionally there were over 90 baghouse emissionPermit No 47259 Page 35 of 40 May 21, 2010 points modeled for PM-10 emissions th roughout the facility, having a total maximum hourly emission rate of 42 lbs/hour. Numerous area and volume sources were also included to portray va rious handling and haul road emissions
These are summarized in Table 3b.

The Permittee’s dispersion modeling an alysis included a Good EngineeringPractice (GEP) stack height analysis. The latest version of U.S. EPA’s BPIPPRIME program was used to calculate GEP stack heights. The GEP heights were compared to actual stack heights to demonstrate compliance with the stack height regulations codified at 40 CFR part 51. For any stack that was calculated to be less than GEP height, the BPIP dow nwash parameters were included in the ISCPRIME analysis.



### TABLE 3a: MAJOR POINT SOURCE MODELING PARAMETERS

Stack ID Stack Height

(m) Exit T (k) Exit velocity (m/s) Exit Diam (m) SO 2 Emissions

(lb/hr) NO 2 Emissions

(lb/hr) CO
Emissions

(lbs/hr) PM-10
Emissions

(lbs/hr)

H5GB 39.624 477.59 14.578 4. 877 53.02 512.0159 167.57 28.0279

HEATBOIL 12.192 533 7.831 0.152 0.0004 0.0651 0.0069 0.0048

DFH1 1.83 Ambient Horizontal 0.001 0.0009 0.1587 0.017 0.0 19 1

DFH2 1.83 Ambient Horizontal 0.001 0.0009 0.1587 0.017 0.0119

D5PC 40.54 366.48 20.3 1. 22 0.0063 1.1112 0.117 1.22

DGEN 2.438 814.82 155.61 0. 67 0.0002 0.5794 1.21 0.5 40 5

POO 2.438 814.82 155.61 0.67 0.0002 0.0000 NA NA



### TABLE 3b: SUMMARY OF FUGITIVE EMISSIONS

PM-10 Emissions

TPY PM-10 Emissions
lbs/hr

Area
Sources 4.3 2962

Volume

Sources 162 148

Total 166.3 3,110

3. Ambient Background Concentration Data

Ambient background concentrations are added to the maximum modeled concentrations to determine compliance with the NAAQS. In Arizona, ambient monitoring is conducted by a number of governmental agencies and regulated industries. As recommended by the Department’s Modeling Guidelines, the Permittee’s NAAQS demonstration used background air quality concentrations
that were derived from the latest three years of available monitoring data from the nearest representative monitoring stations for CO, SO 2 , and NO 2

. The selected background concentrations are presented in Table 4.

A refined method was used to calculate the PM-10 ambient background data,Permit No 47259 Page 36 of 40 May 21, 2010 based upon the daily monitored values. The procedure used to determine the background 24-hour average PM-10 concentration for the NAAQS modeling, as approved by the Department, added modeled impacts to day-specific background
concentrations measured at the Pima County DEQ’s Tangerine monitoring station. The day-specific 24-hour average PM-10 background concentrations
were determined as either the monitored va lue for that specific day, or the greater of the two surrounding monitored values. The value listed in Table 4 below is the maximum day-specific ambient PM-10 background value used.


### TABLE 4: AMBIENT BACKGROUND CONCENTRATIONS

Pollutant Station Background Conc. (μg/m 3 ) NAAQS (μg/m 3 )

NO 2 Annual (μg/m 3 ) Pima Co 32.3 100 PM-10 24-hr (μg/m 3 ) Tangerine 81 150 PM-10 Annual (μg/m 3 ) Tangerine 19 50

SO 2 3-hr (μg/m 3 ) Pima Co 26.2 1,300

SO 2 24-hr (μg/m 3 ) Pima Co 10.5 365

SO 2 Annual (μg/m 3 ) Pima Co 4.0 80 CO 1-hr (μg/m 3 ) Pima Co 4,923 40,000 CO 8-hr (μg/m 3 ) Pima Co 2,176 10,000

4. Modeling Results

The NAAQS modeling results for the f acility are presented in Table 5a. The total modeled impacts (modeled concentr ations plus background concentrations) are less than the corresponding NAAQS.

PSD Class II SO 2 Increment modeling was performed. The project impacts were above the significant impact levels (SIL’s) for the 3-hr and 24-hr SO 2 averaging intervals, therefore cumulative SO 2 PSD increment consumption modeling was performed. The Significant Impact Area was less than two kilometers from the plant. Since there are no major SO 2 PSD sources within 50 km of the APCC Rillito cement plant, only the Perm ittee’s sources were included in the SO 2 Class II PSD increment analysis.

Table 5b shows that maximum predicted impacts are below PSD Class II
increment levels.



### TABLE 5A: NAAQS MODELING RESULTS

Maximum Modeled Concentration (μg/m 3 ) Pollutant Averaging

Interval NAAQS (μg/m 3 ) Source Only Including Background Exceeds NAAQS

NO 2 Annual 100 4.97 37.3 No

SO 2 3-Hour

24-Hour
Annual 1300
365
80 95.7

17.1
0.4 121.7
27.1
4.4 No

No

No

PM-10 24-Hour 1

Annual 150
50 126.2
26.5 135.2
45.5 No

No

CO 1-Hour
8-Hour 40,000 10,000 3,209
493 8,133 2,669 No

No

1 – The maximum values shown are the source-only predicted concentration impactPermit No 47259 Page 37 of 40 May 21, 2010 and the total predicted concentration corresponding to the day with the highest sixth high. As described in Section XI.B.3, day-specific ambient 24-hour background PM10 concentration values were used in the NAAQS analysis.



### TABLE 5B: PSD CLASS II INCREMENT MODELING RESULTS

Maximum Modeled Concentration (μg/m 3 ) SIA (km) SIL (μg/m 3 ) Pollutant Averaging

Interval PSD

Increment

(μg/m 3 ) Source Only 1 Including PSD Inventory 2

SO 2 3-Hour

24-Hour
Annual 512
91
20 35.7
8.8
0.4 34.4
6.0
NA 1.2
1.4
NA 25
5

1

1 – Highest concentration

2 – High second-highest

5. Class I PSD Increment

The Permittee’s facility is located within 20 0 kilometers of seven Class I areas. Because the proposed major modification w ill result in a significant net increase
in SO 2 emissions, the Permittee performed an analysis to demonstrate that the project would not cause or contribute to a violation of a PSD Class I increment in any of these areas. This analysis is documented in Section 8.4 of the April 2007 supplement to the permit application of PSD. The Class I areas evaluated are as
follows:

 Saguaro National Park

 Chiricahua Wilderness Area

 Chiricahua National Monument

 Galiuro National Monument

 Mount Baldy Wilderness Area

 Sierra Ancha Wilderness Area

 Superstition Wilderness Area

Because the boundary of Saguaro National Park is within 50 kilometers of the Permittee’s facility, the ISCPRIME model was used to determine air quality impacts at that park. All other Class I areas are greater than 50 kilometers, and have been modeled using the CALPUFF ai r quality model, with three years of MM5 gridded data (2002-2004).

Modeling demonstrated that the Class I SO 2 SIL for the 3-hour and 24-hour averaging periods were exceeded at th e nearby Saguaro National Park western unit. No other SIL’s were reached at any other Class I. Table 6 lists the significant Impact Results for PSD Class I SO 2 Increment analysis.

Therefore, cumulative modeling analy ses were done using all PSD increment consuming sources in the Saguaro National Park western unit. Sulfur dioxide
emission sources within 300 km of the Sa guaro National Park western unit were evaluated initially to determine the sour ces to include in the cumulative Class I increment modeling. These source data were incorporated from Maricopa County, Pinal County, Pima County, NEI, and the New Mexico Environment Department’s databases. Based on guid ance from the National Park Service, only sources with an SO 2 emission rate, in tons per year that exceeded 0.8 times the distance from the Saguaro National Park western unit, in kilometers were included in the modeling.Permit No 47259 Page 38 of 40 May 21, 2010 Cumulative PSD increment results show im pacts to be less than the Class I PSD Increment levels, as shown in Table 7.



### TABLE 6: CLASS I SO 2 

### INCREMENT SIL RESULTS

Area Averaging
Period Maximum SIL ( μ g/m 3 ) (2) Above SIL?

3-hour 0.060 1.0 No

24-hour 0.019 0.2 No Chiricahua

WA

Annual 0.001 0.1 No

3-hour 0.045 1.0 No

24-hour 0.012 0.2 No Chiricahua

NM

Annual 0.001 0.1 No

3-hour 0.239 1.0 No

24-hour 0.056 0.2 No Galiuro WA

Annual 0.006 0.1 No

3-hour 0.023 1.0 No

24-hour 0.004 0.2 No Mt. Baldy

WA

Annual 0.000 0.1 No

3-hour 0.062 1.0 No

24-hour 0.010 0.2 No Sierra Ancha

WA

Annual 0.001 0.1 No

3-hour 0.147 1.0 No

24-hour 0.033 0.2 No Superstition

WA

Annual 0.002 0.1 No

3-hour 11.06 1.0 Yes

24-hour 1.90 0.2 Yes Saguaro NP

West

Annual 0.09 0.1 No

3-hour 0.98 1.0 No

24-hour 0.16 0.2 No Saguaro NP

East

Annual 0.02 0.1 No



### TABLE 7: CLASS I INCREMENT SO 2 

### IMPACTS AT SAGUARO NP

Maximum Modeled Concentration (μg/m 3 ) Pollutant Averaging

Interval PSD Class I

Increment

(μg/m 3 ) Plant Only 1 Including PSD Inventory 2

SO 2 3-Hour
24-Hour 25
5 11.1
1.9 10.1
1.4

1 – Highest concentration

2 – High second-highest

G. SOILS, VEGETATION, AND VISIBILITY IMPACTS ANALYSISPermit No 47259 Page 39 of 40 May 21, 2010 Pursuant to A.A.C. R18-2-407(A)(1), the Perm ittee performed an analysis of the project’s impacts on soils and vegetation in the vicinity of the project site. This analysis included dispersion modeling with ISCPRIME and show ed that maximum predicted impacts for

SO 2 were less than six percent of the EPA ’s screening threshold values for sensitive species. The analysis is presented in detail in Section 8.3.4 of the April 2007 supplement to the Class I permit application. The Depart ment has reviewed this analysis and agrees with the Permittee’s conclusions. In particular, the Department notes that the Permittee’s analysis was conservative, as it did not take into account the significant NO X emission reductions to be achieved, and the resultant benefits in terms of synergistic impacts of

SO 2 and NO X ambient concentrations.

XII. CLASS I AREA IMPACTS ANALYSIS

The Permittee submitted Class I Air Quality Relate d Values (AQRV) impact analyses in its April 2007 supplement to the permit application. This analysis included assessment of both visibility and deposition impacts. This analysis is reviewed by the Federal Land Manager (FLM) responsible for each affected Class I areas, in this case the U.S. Forest Service and the National Park Service. The Department transmitted the Class I permit application, including the Class I AQRV impact analyses, to the FLM agencies a nd to date has not received any comments indicating concerns regarding adverse impacts on any AQRV’s.

XIII. ARIZONA AMBIENT AIR QUALITY GUIDELINES (AAAQG)

The Permittee conducted a dispersion modeling analys is in order to demonstrate compliance with the AAAQG and submitted the results of this analysis as Appendix G to the December 2005 permit application. The Department has reviewed this analysis, has determined that it was performed in accordance with Section 5.0 of the Department’s “Air Dispersion Modeling Guidelines for Arizona Air Quality Permits.”

The AAAQG modeling results are presented in Ta ble 8. The modeled impacts from the plant were below all the AAAQG threshold levels. Ther efore, the Department has concluded that the Permittee’s AAAQG modeling r esults are acceptable.



### TABLE 8: AAAQG MODELING RESULTS

Modeled Ambient Concentration (μg/m 3 ) AAAQG (μg/m 3 )

Annual 24-Hour 1-Hour Annual 24-Hour 1-Hour Acetaldehyde 3.24E-05 7.80E-04 4.45E-03 5.00E-01 1.40E+03 2.30E+03

Aluminum 6.00E-04 1.44E-02 8.24E-02
-- 1.50E+02 4.50E+02

Ammonia 2.29E-02 5.52E-01 3.15E+00
-- 1.40E+02
--

Arsenic 7.98E-06 1.92E-04 1.10E-03 2.00E-04 7.30E-02 2.80E-01

Barium 2.12E-03 5.12E-02 2.92E-01
-- 4.00E+00 1.5-E+01

Benzene 4.03E-03 9.71E-02 5.54E-01 1.40E-01 5.10E+01 6.30E+02
Benz(a)anthracene 2.44E-07 5.88E-06 3.35E-05 5.70E-04 2.10E-02 7.90E-02

Benzo(a)pyrene 1.56E-08 3.76E-07 2.15E-06 5.70E-04 2.10E-01 7.90E-01 Beryllium 1.60E-05 3.84E-04 2.19E-03 5.00E-04 1.60E-02 6.00E-02

Cadmium 4.36E-05 1.05E-03 6.00E-03 2.90E-04 1.10E-01 1.70E+00

Chlorobenzene 3.15E-04 7.57E-03 4.32E-02
-- 2.56E+03

Chromium 8.10E-06 1.95E-04 1.11E-03
-- 3.80E+00 1.10E+01

Copper 6.82E-05 1.64E-03 9.38E-03
-- 7.50E-01 2.30E+00Permit No 47259 Page 40 of 40 May 21, 2010 Modeled Ambient Concentration (μg/m 3 ) AAAQG (μg/m 3 )

Annual 24-Hour 1-Hour Annual 24-Hour 1-Hour Ethylbenzene 6.82E-04 1.64E-02 9.37E-02
-- 3.50E+03 4.50E+03 Formaldehyde 2.05E-02 4.94E-01 2.82E+00 8.00E-02 1.20E+01 2.00E+01 Hydrogen Chloride 4.75E-02 1.14E+00 6.52E+00 7.00E+00 5.60E+01 2.10E+02 Hydrogen Fluoride 3.16E-03 7.61E-02 4.35E-01
-- 1.88E+02 5.63E+02

Iron 5.99E-04 1.44E-02 8.24E02
-- 4.00E+01 8.30E+01
Manganese 3.14E-02 7.56E-01 4.31E+00
-- 8.00E+00 2.50E+01

Mercury 1.81E-05 4.35E-04 2.48E-03
-- 4.00E-01 1.50E+00 Methylene Chloride 1.83E-04 4.40E-03 2.51E-02 5.60E+00 2.00E+03 7.60E+03 Molybolenum 1.25E-05 3.02E-04 1.72E-03
-- 4.00E-01 8.30E+01 Napththalene 5.94E-04 1.43E-02 8.16E-02
-- 4.00E+02 6.30E+02

Nickel 2.15E-05 5.18E-04 2.96E-03 4.00E-03 1.50E+00 5.70E+00 Pentachlorophenol 1.56E-05 3.76E-04 2.15E-03
-- 4.00E+00 1.30E+01

Phenol 1.21E-04 2.91E-03 1.66E-02
-- 1.50E+02 3.20E+02 Polychlorinated Biphenyls 4.22E-06 1.02E-04 5.80E-04 6.10E-04 7.90E-02 3.00E-01

Selenium 1.60E-05 3.84E-04 2.19E-03
-- 1.60E+00 6.00E+00

Silver 1.40E-05 3.37E-05 1.92E-04
-- 7.90E-02 3.00E-01

Sulfuric Acid Mist 4.54E-03 1.09E-01 6.24E-01
-- 7.50E+00 2.25E+1
2,3,7,8-Tetrachlorodibenzo-pdioxin 5.30E-09 1.28E-07 7.28E-07 2.40E-05 1.10E-02 4.30E-02

Thallium 1.24E-05 2.98E-04 1.70E-03
-- 7.90E-01 3.00E+00

Toluene 8.46E-04 2.04E-02 1.16E-01
-- 3.00E+03 4.70E+03 m-& p-Xylenes 3.10E-04 7.47E-03 4.26E-02
-- 3.50E+03 5.50E+03

O-Xylenes 1.36E-04 3.28E-03 1.87E-02
-- 3.50E+03 5.50E+03

Xylenes 4.46E-04 1.07E-02 6.13E-02
-- 3.50E+03 5.50E+03
Zinc (Total Dust) 1.57E-03 3.79E-02 2.16E-01
-- 8.00E-01 3.00E+02