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 Portland Cement Company) for the continued 

operation of a limestone quarry, a Portland cement 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 (PM10) 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. Learning 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 children 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 comprehensive dispersion modeling analysis as 

part of RIMOD 3 expansion project in the late 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 SO2 emissions increases, the 

Permittee had conducted a comprehensive ambient air quality impact analysis as part of 

the permit application for the project. The analysis demonstrated compliance with the 

National Ambient Air Quality Standards (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 Ambient 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 M190310P1-00, 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 considered 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 180th 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 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 Portland cement manufacturing and shipping. 

The facility was issued a significant permit revision 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 system, clinker cooler, and air pollution control 

systems. The new pyroprocessing line will have 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, and 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 for 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 equipment. 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 

PM10 2,202.57 

NOX 5,199.37 

CO 5,156.03 

SO2 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 facility since 2001. There have been 

eighty-three facility inspections and forty file reviews 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 performed 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 closed on July 3, 2001, but violations from 

this case were resolved under Consent 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 review (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 facility’s deadline to achieve compliance was 

January 23, 2003. A response letter was received 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 alleged 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 dioxins/furans completed November 17, 2002. 

The Permittee subsequently conducted a second test in December 2002. The second test 

results were reported to ADEQ and showed that the NESHAP for dioxins and furans was 

exceeded. The facility’s deadline to achieve 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 conducted on March 25, 2003 (Inspection 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, maintain, 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 average 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 three 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 compliance 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 APCC 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 within 
Permit 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 Dust 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 observation 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 compliance was December 27, 2003. Compliance 

was achieved on December 22, 2003, and the case was subsequently closed. The 

violations from this case were later resolved 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 (Inspection ID: 50899). The 

violations are as follows: 

1. Failure to comply with a National Emissions 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 specified 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 compliance 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 operation 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 compliance was December 1, 2004. A response was 

received from the facility on November 19, 2004. 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 conducted 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 covered 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 description 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 control 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 compliance 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 consent judgment being filed against Arizona Portland 

Cement Co. for allegations contained in the Notices 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 Permittee has identified the applicable regulations 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 

Twin Peaks Rock 

Crushing and 

Screening plant 

Quarry and 

Limestone 

Processing 

Portable screen 

when used for 

screening 

gypsum/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 permit 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, 2003 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 appeal 
Permit No 47259 Page 11 of 40 May 21, 2010 

 

B. PREVIOUS PERMIT CONDITIONS

 1. Operating Permit No. M190310P1-00 

Table-4 

Condition # in Determination Comments

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 describing 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 

 

Condition # in Determination Comments

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 

Condition # in Determination Comments 

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 

Condition # in Determination Comments 

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 

Condition # in Determination Comments 

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 

Condition # in Determination Comments 

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 

Condition # in Determination Comments 

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 

 

Condition # in Determination Comments 

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 

Condition # in Determination Comments 

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 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 corrective action to reduce the opacity. The 

Permittee is required to keep records of the 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 

affected 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 emissions are observed in six consecutive 

monthly tests. 
Permit No 47259 Page 15 of 40 May 21, 2010 

 

2. The Permittee is required to conduct performance 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 

affected sources in the coal mill system 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 emissions 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 collectors 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 opacity 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 performance 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 Kiln 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 record 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 Kiln 4 in-line kiln/ raw mill at the inlet 
Permit No 47259 Page 16 of 40 May 21, 2010 

 

to, or upstream of, the particulate matter control devices to demonstrate control 

of dioxins/furans emissions. 

4. The Permittee is required to operate continuous emission monitoring systems to 

measure carbon monoxide (CO) and nitrogen oxides (NOX) mass emissions from 

Kilns 1, 2, 3 and Kiln 4 in-line kiln/raw mill. 

5. To demonstrate compliance with the particulate matter and opacity standards, the 

Permittee is required to perform annual performance 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 the dioxins/furans emission standard, the 

Permittee is required to perform EPA Reference Method 23 performance test 

once every 30 months. The Permittee is required to determine the applicable 

temperature limit for each kiln in accordance with test methods and procedures 

under 40 CFR § 63.1349(b)(3). 

7. To demonstrate compliance with the SO2 emission standard, the Permittee is 

required to perform annual EPA Reference 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 Operation 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 opacity standards, the Permittee is required 

to perform annual EPA Method 9 performance tests on all affected sources in 

accordance with 40 CFR § 63.1349(b)(2). 

3. To demonstrate compliance with the particulate 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. Property Boundary Line with the Rillito Community: The Permittee is 

required to install, and operate, during daylight hours, cameras for 
Permit 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 emissions related to the Permittee’s 

operations are observed to cross a property boundary line, the Permittee 

must report the emissions using the excess emission reporting 

procedures. 

2. A certified EPA Reference Method 9 observer 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 corrective action to reduce the opacity. The 

Permittee must conduct another method 9 observation within 48 hours of taking 

the corrective action. The Permittee is required to keep records of the initial 

survey, any EPA Reference Method 9 observations performed and the corrective 

action performed. 

G. Ambient PM10 and Meteorological Monitoring 

The Permittee is required to operate and maintain the ambient PM10 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. The list of EPA approved 

samplers is available at: 

http://www.epa.gov/ttn/amtic/files/ambient/criteria/reference-equivalent-methods-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 control 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 assumed 
Permit 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 PSEUs 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 values equally spaced over each hour. For all 

other PSEUs (“small” PSEUs), the monitoring shall 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 the control devices for controlling the emissions 

of particulate matter (both PM and PM10) for the units subject to CAM requirements: 

 

AC-DC1, BL-DC1, BL-DC2, BL-DC3, BL-DC4, 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-DC11, 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 Code 

ADEQ ......................................................................Arizona Department of Environmental Quality 

AQD.................................................................................................................. Air Quality Division 

AQG...............................................................................................................Air Quality Guidelines 

Btu/ft3

..................................................................................... British Thermal Units per Cubic Foot 

CO......................................................................................................................... Carbon Monoxide 

CO2............................................................................................................................Carbon Dioxide 
Permit No 47259 Page 19 of 40 May 21, 2010 

 

DEGF.................................................................................................................. Degrees Fahrenheit 

DEGK ....................................................................................................................... Degrees Kelvin 

FERC .................................................................................Federal Energy Regulatory Commission 

ft.................................................................................................................................................. Feet 

g ...............................................................................................................................................Grams 

HAP ............................................................................................................ Hazardous Air Pollutant 

hp ....................................................................................................................................Horsepower 

hr ................................................................................................................................................Hour 

IC ...................................................................................................................... Internal Combustion 

lb ..............................................................................................................................................Pound 

m ...............................................................................................................................................Meter 

MMBtu............................................................................................... Million British Thermal Units 

g/m3

..................................................................................................... Microgram per Cubic Meter 

MMCFD.................................................................................................Million Cubic Feet Per Day 

NAAQS............................................................................... National Ambient Air Quality Standard 

NOx .......................................................................................................................... Nitrogen Oxide 

NO2 ........................................................................................................................ Nitrogen Dioxide 

O3 ............................................................................................................................................Ozone 

Pb ............................................................................................................................................... Lead 

PM..........................................................................................................................Particulate Matter 

PM10 ........................................................... Particulate Matter Nominally less than 10 Micrometers 

Psia...............................................................................................Pounds per square Inch (absolute) 

PTE .........................................................................................................................Potential-to-Emit 

s.............................................................................................................................................Seconds 

SO2 ............................................................................................................................. Sulfur Dioxide 

TPY............................................................................................................................. Tons per Year 

TSP ....................................................................................................... Total Suspended Particulate 

USEPA ................................................................. United States Environmental Protection Agency 

VOC......................................................................................................Volatile Organic Compound 

yr ................................................................................................................................................. year 
Permit 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 Portland 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 significant permit revision was received on December 14, 

2005. The proposed significant revision, Permit Number 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 operating 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 aggregate 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 Portland 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 changes 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 system, clinker cooler, and air pollution control 

systems. The new pyroprocessing line will have 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, and 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 for 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 equipment. The Kiln 6 Project will not have any 

effect on the rock and stone aggregate plant. 

Additional detail regarding the proposed modification is provided in Section 2.0 of the December 

2005 permit application. 

III. EMISSIONS 

The proposed Kiln 6 Project will result in a net increase 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 Source Review (NNSR) rule at A.A.C. R18-2-

403(A). 

The proposed Kiln 6 Project will result in a net increase in SO2 emissions of 127.2 tpy, in excess 

of the SO2 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 SO2 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 the proposed Kiln 6 Project and the new facility-wide potential to 

emit are summarized in Table 1. Detailed documentation 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 CHANGES 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 site 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 

SO2 127.2 186.4 

NOX -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 emission 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 SO2 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 are 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 No new, modified, or reconstructed 

limestone crushers, grinding mills, 

screening operations, bucket elevators, 

belt 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 NOX

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 NOX, PM, CO, or VOC. The Permittee’s 

PSD applicability analysis for these pollutants 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 authorized 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 NOX 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 terms of mass emission rate, regardless 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 

NOX, 3.2 lbs of CO, and 0.04 lb of VOC per ton of clinker 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 SO2 Emissions 

As noted in Section III, the Kiln 6 project is a major modification subject to PSD review 

with respect to SO2 emissions increases. Pursuant to A.A.C. R18-2-406(A)(2), for a 

major modification, BACT 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 of operation in the unit.” This includes the new Kiln 6 inline kiln/raw mill 

and the new emergency generator. 

1. SO2 BACT Analysis for Kiln 6 Inline Kiln/Raw Mill 

The Permittee submitted an SO2 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 SO2 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 SO2 emissions are primarily dependent on the sulfur content of the 

feed materials and on the inherent SO2 removal in the raw mill. 

 SO2 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 SO2 emission limit, based on feed material 

sulfur content and SO2 removal in the raw mill, is 0.16 lb per ton of 

clinker, as determined on a 30-day rolling average. 

 Additional SO2 control could be achieved with a flue gas desulfurization 

system, but the SO2 emission reductions achievable with such technology 

are outweighed by the adverse environmental, energy, and economic 

impacts. 

2. SO2 BACT Analysis for Emergency Generator 

The Permittee submitted an SO2 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 of 
Permit 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 analysis for Kiln 6 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 

0.008 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. 

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 Clinker 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 clinker 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 clinker 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 analysis 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 modified 
Permit 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 required 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 tons 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 decreases achieved by Arizona Portland Cement 

Company by installing gates to preclude public 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 significantly 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 determination are the following key points: 

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

NOX 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 respect 
Permit 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 owned 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 limitations 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 the only existing major source in Arizona owned or 

operated by the Permittee, or any entity controlling, 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 implementation 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. R18-2-403(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, subpart 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 the 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 determine 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 with the NESHAP mercury emission 

standard of 41 micrograms per dry standard cubic meter, corrected to 7 

percent oxygen. It should be noted that 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 baghouses. A bag leak detection system 
Permit 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 other 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 demonstration 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 operation 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 recordkeeping 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 feed rate to determine continuous 

compliance with the daily and annual clinker production rates; 

 Continuous emission rate monitoring system for SO2, to determine 

continuous compliance with the SO2 BACT limit; 

 Continuous emission rate monitoring systems for CO, VOC, and NOX, 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 Compliance Assurance Monitoring plan submitted by 

the Permittee for determining continuous compliance with the BACT, 

LAER, and dispersion modeling based PM-10 emission limits. 

B. CLINKER COOLER 

The Clinker Cooler monitoring and recordkeeping 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 maintenance 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 maintenance 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 within 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 bag 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 maintenance 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 explosive used, in order to determine 

continuous compliance with the operational limits on these parameters; 

 Continuous monitoring of pressure drop across all dust collectors. This 

monitoring is used to determine continuous 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 the 
Permit No 47259 Page 31 of 40 May 21, 2010 

 

coal preparation plant: 

 Continuous monitoring of exhaust gas temperature 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 continuous 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 hours 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 generator 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 continuous 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, subpart 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 initial startup, whichever is earlier. The 

NESHAP performance testing requirements included in the permit, as required 

by A.A.C. R18-2-306(A)(3), include the following: 

 Performance testing for PM emissions 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/furan emissions using EPA Reference 

Method 23, with separate tests run with and without the raw mill in 
Permit 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 emissions 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 demonstrate 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 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: 

 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 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 initial startup, whichever is earlier. The permit 

includes the following NESHAP performance testing requirements: 

 Performance testing for PM emissions 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 demonstrate 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 POINTS, 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 within 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 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 180-day deadline 

applies to the Method 9 performance test 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 achieving the maximum production rate at 

which the affected source will be operated, 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 permit 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 requirements for each dust collector associated 

with the limestone processing plant in order 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 filterable 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 the 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 and EPA Reference Method 9 for opacity. The 
Permit 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 are 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 SO2 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 analysis and concurs with the Permittee’s conclusions. 

A. GROWTH ANALYSIS 

Pursuant to A.A.C. R18-2-407(I), the Permittee was required to perform an analysis of 

general commercial, residential, industrial, and other growth associated with the proposed 

modification. The projected growth is required to be considered in other portions of the 

the ambient air quality impact analysis, as described 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 operate the cement plant. Because no additional workforce is 

needed, there will be no associated growth. 

B. DEMONSTRATION OF COMPLIANCE WITH AMBIENT STANDARDS 

The Permittee conducted dispersion modeling analyses in order to demonstrate 

compliance with the National Ambient Air 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 and 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, sequential date checking, and does not 

permit the use of the model in the SCREEN 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 modeled emission rates and stack parameters 

for each major point source. Additionally there were over 90 baghouse emission 
Permit No 47259 Page 35 of 40 May 21, 2010 

 

points modeled for PM-10 emissions throughout the facility, having a total 

maximum hourly emission rate of 42 lbs/hour. Numerous area and volume 

sources were also included to portray various handling and haul road emissions 

These are summarized in Table 3b. 

The Permittee’s dispersion modeling analysis included a Good Engineering 

Practice (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 downwash 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) 

SO2

Emissions 

(lb/hr) 

NO2

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, SO2, and NO2. 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 value 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/m3

) 

NAAQS 

(μg/m3) 

NO2 Annual (μg/m3) Pima Co 32.3 100 

PM-10 24-hr (μg/m3) Tangerine 81 150 

PM-10 Annual (μg/m3) Tangerine 19 50 

SO2 3-hr (μg/m3) Pima Co 26.2 1,300 

SO224-hr (μg/m3) Pima Co 10.5 365 

SO2 Annual (μg/m3) Pima Co 4.0 80 

CO 1-hr (μg/m3) Pima Co 4,923 40,000 

CO 8-hr (μg/m3) Pima Co 2,176 10,000 

4. Modeling Results 

The NAAQS modeling results for the facility are presented in Table 5a. The 

total modeled impacts (modeled concentrations plus background concentrations) 

are less than the corresponding NAAQS. 

PSD Class II SO2 Increment modeling was performed. The project impacts were 

above the significant impact levels (SIL’s) for the 3-hr and 24-hr SO2 averaging 

intervals, therefore cumulative SO2 PSD increment consumption modeling was 

performed. The Significant Impact Area was less than two kilometers from the 

plant. Since there are no major SO2 PSD sources within 50 km of the APCC 

Rillito cement plant, only the Permittee’s sources were included in the SO2 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/m3

) 

Pollutant Averaging 

Interval 

NAAQS 

(μg/m3

) 

Source Only Including 

Background

Exceeds 

NAAQS 

NO2 Annual 100 4.97 37.3 No 

SO2 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 impact 
Permit 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/m3

) 

SIA 

(km) 

SIL 

(μg/m3) 

Pollutant Averaging 

Interval 

PSD 

Increment 

(μg/m3

) Source 

Only 1

Including PSD 

Inventory 2

SO2 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 200 kilometers of seven Class I areas. 

Because the proposed major modification will result in a significant net increase 

in SO2 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 air quality model, with three years of 

MM5 gridded data (2002-2004). 

Modeling demonstrated that the Class I SO2 SIL for the 3-hour and 24-hour 

averaging periods were exceeded at the 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 SO2 Increment analysis. 

Therefore, cumulative modeling analyses were done using all PSD increment 

consuming sources in the Saguaro National Park western unit. Sulfur dioxide 

emission sources within 300 km of the Saguaro National Park western unit were 

evaluated initially to determine the sources 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 guidance from the National Park Service, 

only sources with an SO2 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 impacts to be less than the Class I PSD 

Increment levels, as shown in Table 7. 

TABLE 6: CLASS I SO2 INCREMENT SIL RESULTS

Area Averaging 

Period Maximum SIL 

(μg/m3)(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 SO2 IMPACTS AT SAGUARO NP

Maximum Modeled 

Concentration (μg/m3

) 

Pollutant Averaging 

Interval 

PSD Class I 

Increment 

(μg/m3

) Plant 

Only 1

Including PSD 

Inventory 2

SO2 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 ANALYSIS 
Permit No 47259 Page 39 of 40 May 21, 2010 

 

Pursuant to A.A.C. R18-2-407(A)(1), the Permittee 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 showed that maximum predicted impacts for 

SO2 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 Department 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 NOX emission 

reductions to be achieved, and the resultant benefits in terms of synergistic impacts of 

SO2 and NOX ambient concentrations. 

XII. CLASS I AREA IMPACTS ANALYSIS 

The Permittee submitted Class I Air Quality Related 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 and 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 analysis 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 Table 8. The modeled impacts from the plant 

were below all the AAAQG threshold levels. Therefore, the Department has concluded that the 

Permittee’s AAAQG modeling results are acceptable. 

TABLE 8: AAAQG MODELING RESULTS

Modeled Ambient 

Concentration (μg/m3

) AAAQG (μg/m3 ) 

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+00 
Permit No 47259 Page 40 of 40 May 21, 2010 

 

Modeled Ambient 

Concentration (μg/m3

) AAAQG (μg/m3 ) 

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