Permit No. 1001770 Page 1 of 99 April 12, 2006

 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY CLASS I PERMIT

COMPANY: Drake Cement, LLC

FACILITY: Drake Cement, LLC

PERMIT #: 1001770

DATE ISSUED: April 12, 2006

EXPIRY DATE: April 12, 2011

SUMMARY

This Class I, Title V permit is issued to Drake Cement, LLC, the Permittee, for construction and operation 

of a Portland cement plant located in Drake, Arizona. 

This permit is issued in accordance with Title 49, Chapter 3 of the Arizona Revised Statutes. All 

definitions, terms, and conditions used in this permit conform to those in the Arizona Administrative 

Code (A.A.C.) R18-2-101 et. seq., Arizona State Implementation Plan (SIP), Code of Federal Regulations 

(CFR) Title 40 - Parts 60, 63, and 70 except as otherwise defined in this permit. All terms and conditions 

in this permit are enforceable by the Administrator of the U.S. Environmental Protection Agency.

The potential emission rates of the following pollutants are greater than major source thresholds: (i) 

nitrogen oxides, (ii) carbon monoxide, (iii) hydrogen chloride, and (iv) total hazardous air pollutants. 

Therefore, the facility is classified as a major source as defined in A.A.C. R18-2-101(64), and requires a 

Class I permit pursuant to A.A.C. R18-302(B)(1)(a).
Permit No. 1001770 Page 2 of 99 April 12, 2006

TABLE OF CONTENTS

ATTACHMENT “A”: GENERAL PROVISIONS .........................................................................3

I. PERMIT EXPIRATION AND RENEWAL........................................................................3

II. COMPLIANCE WITH PERMIT CONDITIONS...............................................................3

III. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, OR 

TERMINATION FOR CAUSE...........................................................................................3

IV. POSTING OF PERMIT.......................................................................................................4

V. FEE PAYMENT..................................................................................................................4

VI. ANNUAL EMISSION INVENTORY QUESTIONNAIRE ...............................................4

VII. COMPLIANCE CERTIFICATION ....................................................................................4

VIII. CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS.........................5

IX. INSPECTION AND ENTRY ..............................................................................................5

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT 

STANDARD........................................................................................................................6

XI. ACCIDENTAL RELEASE PROGRAM.............................................................................6

XII. EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCY REPORTING...6

XIII. RECORD KEEPING REQUIREMENTS .........................................................................11

XIV. REPORTING REQUIREMENTS .....................................................................................11

XV. DUTY TO PROVIDE INFORMATION...........................................................................11

XVI. PERMIT AMENDMENT OR REVISION........................................................................12

XVII. FACILITY CHANGE WITHOUT A PERMIT REVISION.............................................12

XVIII. TESTING REQUIREMENTS...........................................................................................13

XIX. PROPERTY RIGHTS........................................................................................................14

XX. SEVERABILITY CLAUSE ..............................................................................................15

XXI. PERMIT SHIELD..............................................................................................................15

XXII. PROTECTION OF STRATOSPHERIC OZONE.............................................................15

XXIII. APPLICABILITY OF NSPS GENERAL PROVISIONS.................................................15

XXIV. APPLICABILITY OF NESHAP GENERAL PROVISIONS...........................................15

ATTACHMENT “B”: SPECIFIC CONDITIONS ........................................................................16

I. KILN, CLINKER COOLER, RAW MILL, AND COAL MILL ......................................16

II. FINISH MILLS, STORAGE BINS, BULK LOADING AND UNLOADING SYSTEMS, 

AND CONVEYING SYSTEM TRANSFER POINTS SUBJECT TO 40 CFR 63 

SUBPART LLL .................................................................................................................42

III. LIMESTONE PROCESSING PLANT .............................................................................62

IV. OTHER MATERIAL HANDLING ACTIVITIES ...........................................................68

V. EMERGENCY GENERATOR .........................................................................................73

VI. QUARRY OPERATIONS AND VEHICLE TRAFFIC....................................................77

VII. MISCELLANEOUS SOURCES .......................................................................................80

VIII. AMBIENT AIR QUALITY MONITORING....................................................................89

ATTACHMENT “C”: EQUIPMENT LIST..................................................................................90
Permit No. 1001770 Page 3 of 99 April 12, 2006

ATTACHMENT “A”: GENERAL PROVISIONS

Air Quality Control Permit No. 1001770

for

Drake Cement, LLC

I. PERMIT EXPIRATION AND RENEWAL [ARS § 49-426.F, A.A.C. R18-2-304.C.2, and -306.A.1]

A. This permit is valid for a period of five years from the date of issuance.

B. The Permittee shall submit an application for renewal of this permit at least 6 months, but 

not more than 18 months, prior to the date of permit expiration.

II. COMPLIANCE WITH PERMIT CONDITIONS [A.A.C. R18-2-306.A.8.a and b]

A. The Permittee shall comply with all conditions of this permit including all applicable 

requirements of the Arizona air quality statutes and air quality rules. Any permit 

noncompliance constitutes a violation of the Arizona Revised Statutes and is grounds for 

enforcement action; for permit termination, revocation and reissuance, or revision; or for 

denial of a permit renewal application. In addition, noncompliance with any federally 

enforceable requirement constitutes a violation of the Clean Air Act.

B. It shall not be a defense for a Permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of this permit.

III. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, OR 

TERMINATION FOR CAUSE

[A.A.C. R18-2-306.A.8.c, -321.A.1, and -321.A.2]

A. The permit may be revised, reopened, revoked and reissued, or terminated for cause. The 

filing of a request by the Permittee for a permit revision, revocation and reissuance, 

termination, or of a notification of planned changes or anticipated noncompliance does 

not stay any permit condition.

B. The permit shall be reopened and revised under any of the following circumstances

1. Additional applicable requirements under the Clean Air Act become applicable to 

the Class I source. Such a reopening shall only occur if there are three or more 

years remaining in the permit term. The reopening shall be completed no later 

than 18 months after promulgation of the applicable requirement. No such 

reopening is required if the effective date of the requirement is later than the date 

on which the permit is due to expire, unless an application for renewal has been 

submitted pursuant to A.A.C. R18-2-322.B. Any permit revision required 

pursuant to this subparagraph shall comply with the provisions in A.A.C. R18-2-

322 for permit renewal and shall reset the five-year permit term.

2. Additional requirements, including excess emissions requirements, become 

applicable to an affected source under the acid rain program. Upon approval by 

the Administrator, excess emissions offset plans shall be deemed to be

incorporated into the Class I permit.
Permit No. 1001770 Page 4 of 99 April 12, 2006

3. The Director or the Administrator determines that the permit contains a material 

mistake or that inaccurate statements were made in establishing the emissions 

standards or other terms or conditions of the permit.

4. The Director or the Administrator determines that the permit needs to be revised 

or revoked to assure compliance with the applicable requirements.

C. Proceedings to reopen and reissue a permit, including appeal of any final action relating 

to a permit reopening, shall follow the same procedures as apply to initial permit issuance 

and shall, except for reopenings under Condition III.B.1 above, affect only those parts of 

the permit for which cause to reopen exists. Such reopenings shall be made as 

expeditiously as practicable. Permit reopenings for reasons other than those stated in 

Condition III.B.1 above shall not result in a resetting of the five-year permit term.

IV. POSTING OF PERMIT [A.A.C. R18-2-315]

A. The Permittee shall post this permit or a certificate of permit issuance where the facility 

is located in such a manner as to be clearly visible and accessible. All equipment covered 

by this permit shall be clearly marked with one of the following:

1. Current permit number; or

2. Serial number or other equipment ID number that is also listed in the permit to 

identify that piece of equipment.

B. A copy of the complete permit shall be kept on site.

V. FEE PAYMENT [A.A.C. R18-2-306.A.9 and -326]

The Permittee shall pay fees to the Director pursuant to ARS § 49-426(E) and A.A.C. R18-2-326.

VI. ANNUAL EMISSION INVENTORY QUESTIONNAIRE [A.A.C. R18-2-327.A and B]

A. The Permittee shall complete and submit to the Director an annual emissions inventory 

questionnaire. The questionnaire is due by March 31st or ninety days after the Director 

makes the inventory form available each year, whichever occurs later, and shall include 

emission information for the previous calendar year.

B. The questionnaire shall be on a form provided by the Director and shall include the 

information required by A.A.C. R18-2-327.

VII. COMPLIANCE CERTIFICATION [A.A.C. R18-2-309.2.a, -309.2.c-d, and -309.5.d]

A. The Permittee shall submit a compliance certification to the Director semiannually, which 

describes the compliance status of the source with respect to each permit condition. The 

first certification shall be submitted no later than May 15th, and shall report the 

compliance status of the source during the period between October 1

st of the previous 

year and March 31st of the current year. The second certification shall be submitted no 

later than November 15th, and shall report the compliance status of the source during the 

period between April 1st and September 30th of the current year.
Permit No. 1001770 Page 5 of 99 April 12, 2006

The compliance certifications shall include the following:

1. Identification of each term or condition of the permit that is the basis of the 

certification;

2. Identification of the methods or other means used by the Permittee for 

determining the compliance status with each term and condition during the 

certification period,

3. The status of compliance with the terms and conditions of the permit for the 

period covered by the certification, including whether compliance during the 

period was continuous or intermittent. The certification shall be based on the 

methods or means designated in Condition VII.A.2 above. The certifications 

shall identify each deviation and take it into account for consideration in the 

compliance certification;

4. For emission units subject to 40 CFR Part 64, the certification shall also identify 

as possible exceptions to compliance any period during which compliance is 

required and in which an excursion or exceedance defined under 40 CFR Part 64 

occurred;

5. All instances of deviations from permit requirements reported pursuant to 

Condition XII.B of this Attachment; and 

6. Other facts the Director may require to determine the compliance status of the 

source.

B. A copy of all compliance certifications shall also be submitted to the EPA Administrator.

C. If any outstanding compliance schedule exists, a progress report shall be submitted with 

the semi-annual compliance certifications required in Condition VII.A above.

VIII. CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS

[A.A.C. R18-2-304.H]

Any document required to be submitted by this permit, including reports, shall contain a 

certification by a responsible official of truth, accuracy, and completeness. This certification 

shall state that, based on information and belief formed after reasonable inquiry, the statements 

and information in the document are true, accurate, and complete.

IX. INSPECTION AND ENTRY [A.A.C. R18-2-309.4]

Upon presentation of proper credentials, the Permittee shall allow the Director or the authorized 

representative of the Director to:

A. Enter upon the Permittee’s premises where a source is located, emissions-related activity 

is conducted, or where records are required to be kept under the conditions of the permit;

B. Have access to and copy, at reasonable times, any records that are required to be kept 

under the conditions of the permit;
Permit No. 1001770 Page 6 of 99 April 12, 2006

C. Inspect, at reasonable times, any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under the 

permit;

D. Sample or monitor, at reasonable times, substances or parameters for the purpose of 

assuring compliance with the permit or other applicable requirements; and

E. Record any inspection by use of written, electronic, magnetic and photographic media.

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT 

STANDARD [A.A.C. R18-2-304.C]

If this source becomes subject to a standard promulgated by the Administrator pursuant to Section 

112(d) of the Act, then the Permittee shall, within twelve months of the date on which the 

standard is promulgated, submit an application for a permit revision demonstrating how the 

source will comply with the standard.

XI. ACCIDENTAL RELEASE PROGRAM [40 CFR Part 68]

If this source becomes subject to the provisions of 40 CFR Part 68, then the Permittee shall 

comply with these provisions according to the time line specified in 40 CFR Part 68.

XII. EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCY REPORTING

A. Excess Emissions Reporting [A.A.C. R18-2-310.01.A and -310.01.B]

1. Excess emissions shall be reported as follows:

a. The Permittee shall report to the Director any emissions in excess of the 

limits established by this permit. Such report shall be in two parts as 

specified below:

(1) Notification by telephone or facsimile within 24 hours of the 

time when the Permittee first learned of the occurrence of excess 

emissions including all available information from Condition 

XII.A.1.b below.

(2) Detailed written notification by submission of an excess 

emissions report within 72 hours of the notification pursuant to 

Condition XII.A.1.a.(1) above.

b. The report shall contain the following information:

(1) Identity of each stack or other emission point where the excess 

emissions occurred;

(2) Magnitude of the excess emissions expressed in the units of the 

applicable emission limitation and the operating data and 

calculations used in determining the magnitude of the excess 

emissions;
Permit No. 1001770 Page 7 of 99 April 12, 2006

(3) Date, time and duration, or expected duration, of the excess 

emissions;

(4) Identity of the equipment from which the excess emissions 

emanated;

(5) Nature and cause of such emissions;

(6) If the excess emissions were the result of a malfunction, steps 

taken to remedy the malfunction and the steps taken or planned 

to prevent the recurrence of such malfunctions; and 

(7) Steps taken to limit the excess emissions. If the excess 

emissions resulted from start-up or malfunction, the report shall 

contain a list of the steps taken to comply with the permit 

procedures.

2. In the case of continuous or recurring excess emissions, the notification 

requirements of this section shall be satisfied if the source provides the required 

notification after excess emissions are first detected and includes in such 

notification an estimate of the time the excess emissions will continue. Excess 

emissions occurring after the estimated time period, or changes in the nature of 

the emissions as originally reported, shall require additional notification pursuant 

to Condition XII.A.1 above.

[A.A.C. R18-2-310.01.C]

B. Permit Deviations Reporting [A.A.C. R18-2-306.A.5.b]

The Permittee shall promptly report deviations from permit requirements, including those 

attributable to upset conditions as defined in the permit, the probable cause of such 

deviations, and any corrective actions or preventive measures taken. Prompt reporting 

shall mean that the report was submitted to the Director by certified mail, facsimile, or 

hand delivery within two working days of the time when emission limitations were 

exceeded due to an emergency or within two working days of the time when the owner or 

operator first learned of the occurrence of a deviation from a permit requirement.

C. Emergency Provision [A.A.C. R18-2-306.E]

1. An “emergency” means any situation arising from sudden and reasonable 

unforeseeable events beyond the control of the source, including acts of God, that 

require immediate corrective action to restore normal operation, and that causes 

the source to exceed a technology-based emission limitation under the permit, 

due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly 

designed equipment, lack of preventative maintenance, careless or improper 

operation, or operator error.

2. An emergency constitutes an affirmative defense to an action brought for 

noncompliance with such technology-based emission limitations if Condition 

XII.C.3 is met.
Permit No. 1001770 Page 8 of 99 April 12, 2006

3. The affirmative defense of emergency shall be demonstrated through properly 

signed, contemporaneous operating logs, or other relevant evidence that:

a. An emergency occurred and that the Permittee can identify the cause(s) 

of the emergency;

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

c. During the period of the emergency, the Permittee took all reasonable 

steps to minimize levels of emissions that exceeded the emissions 

standards or other requirements in the permit; and

d. The Permittee submitted notice of the emergency to the Director by 

certified mail, facsimile, or hand delivery within two working days of the 

time when emission limitations were exceeded due to the emergency. 

This notice shall contain a description of the emergency, any steps taken 

to mitigate emissions, and corrective action taken.

4. In any enforcement proceeding, the Permittee seeking to establish the occurrence 

of an emergency has the burden of proof.

5. This provision is in addition to any emergency or upset provision contained in 

any applicable requirement.

D. Compliance Schedule [ARS § 49-426.I.5]

For any excess emission or permit deviation that cannot be corrected with 72 hours, the 

Permittee is required to submit a compliance schedule to the Director within 21 days of 

such occurrence. The compliance schedule shall include a schedule of remedial 

measures, including an enforceable sequence of actions with milestones, leading to 

compliance with the permit terms or conditions that have been violated.

E. Affirmative Defenses for Excess Emissions Due to Malfunctions, Startup, and Shutdown

[A.A.C. R18-2-310]

1. Applicability

This rule establishes affirmative defenses for certain emissions in excess of an 

emission standard or limitation and applies to all emission standards or 

limitations except for standards or limitations:

a. Promulgated pursuant to Sections 111 or 112 of the Act;

b. Promulgated pursuant to Titles IV or VI of the Clean Air Act;

c. Contained in any Prevention of Significant Deterioration (PSD) or New 

Source Review (NSR) permit issued by the U.S. EPA;

d. Contained in A.A.C. R18-2-715.F; or
Permit No. 1001770 Page 9 of 99 April 12, 2006

e. Included in a permit to meet the requirements of A.A.C. R18-2-

406(A)(5).

2. Affirmative Defense for Malfunctions

Emissions in excess of an applicable emission limitation due to malfunction shall 

constitute a violation. When emissions in excess of an applicable emission 

limitation are due to a malfunction, the Permittee has an affirmative defense to a 

civil or administrative enforcement proceeding based on that violation, other than 

a judicial action seeking injunctive relief, if the Permittee has complied with the 

reporting requirements of A.A.C. R18-2-310.01 and has demonstrated all of the 

following:

a. The excess emissions resulted from a sudden and unavoidable 

breakdown of process equipment or air pollution control equipment 

beyond the reasonable control of the Permittee;

b. The air pollution control equipment, process equipment, or processes 

were at all times maintained and operated in a manner consistent with 

good practice for minimizing emissions;

c. If repairs were required, the repairs were made in an expeditious fashion 

when the applicable emission limitations were being exceeded. Off-shift 

labor and overtime were utilized where practicable to ensure that the 

repairs were made as expeditiously as possible. If off-shift labor and 

overtime were not utilized, the Permittee satisfactorily demonstrated that 

the measures were impracticable;

d. The amount and duration of the excess emissions (including any bypass 

operation) were minimized to the maximum extent practicable during 

periods of such emissions;

e. All reasonable steps were taken to minimize the impact of the excess 

emissions on ambient air quality;

f. The excess emissions were not part of a recurring pattern indicative of 

inadequate design, operation, or maintenance;

g. During the period of excess emissions there were no exceedances of the 

relevant ambient air quality standards established in Title 18, Chapter 2, 

Article 2 of the Arizona Administrative Code that could be attributed to 

the emitting source;

h. The excess emissions did not stem from any activity or event that could 

have been foreseen and avoided, or planned, and could not have been 

avoided by better operations and maintenance practices;

i. All emissions monitoring systems were kept in operation if at all 

practicable; and

j. The Permittee's actions in response to the excess emissions were 

documented by contemporaneous records
Permit No. 1001770 Page 10 of 99 April 12, 2006

3. Affirmative Defense for Startup and Shutdown

a. Except as provided in Condition XII.E.3.b below, and unless otherwise 

provided for in the applicable requirement, emissions in excess of an 

applicable emission limitation due to startup and shutdown shall 

constitute a violation. When emissions in excess of an applicable 

emission limitation are due to startup and shutdown, the Permittee has an 

affirmative defense to a civil or administrative enforcement proceeding 

based on that violation, other than a judicial action seeking injunctive 

relief, if the Permittee has complied with the reporting requirements of 

A.A.C. R18-2-310.01 and has demonstrated all of the following:

(1) The excess emissions could not have been prevented through 

careful and prudent planning and design;

(2) If the excess emissions were the result of a bypass of control 

equipment, the bypass was unavoidable to prevent loss of life, 

personal injury, or severe damage to air pollution control 

equipment, production equipment, or other property;

(3) The air pollution control equipment, process equipment, or 

processes were at all times maintained and operated in a manner 

consistent with good practice for minimizing emissions;

(4) The amount and duration of the excess emissions (including any 

bypass operation) were minimized to the maximum extent 

practicable during periods of such emissions;

(5) All reasonable steps were taken to minimize the impact of the 

excess emissions on ambient air quality;

(6) During the period of excess emissions there were no 

exceedances of the relevant ambient air quality standards 

established in Title 18, Chapter 2, Article 2 of the Arizona 

Administrative Code that could be attributed to the emitting 

source;

(7) All emissions monitoring systems were kept in operation if at all 

practicable; and

(8) Contemporaneous records documented the Permittee’s actions in 

response to the excess emissions.

b. If excess emissions occur due to a malfunction during routine startup and 

shutdown, then those instances shall be treated as other malfunctions 

subject to Condition XII.E.2 above.

4. Affirmative Defense for Malfunctions during Scheduled Maintenance

If excess emissions occur due to a malfunction during scheduled maintenance, 

then those instances will be treated as other malfunctions subject to Condition 

XII.E.2 above.
Permit No. 1001770 Page 11 of 99 April 12, 2006

5. Demonstration of Reasonable and Practicable Measures

For an affirmative defense under Condition XII.E.2 or XII.E.3 above, the 

Permittee shall demonstrate, through submission of the data and information 

required by Condition XII.E and A.A.C. R18-2-310.01, that all reasonable and 

practicable measures within the Permittee’s control were implemented to prevent 

the occurrence of the excess emissions.

XIII. RECORD KEEPING REQUIREMENTS [A.A.C. R18-2-306.A.4]

A. The Permittee shall keep records of all required monitoring information including, but 

not limited to, the following:

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

2. The date(s) analyses were performed;

3. The name of the company or entity that performed the analyses;

4. A description of the analytical techniques or methods used;

5. The results of such analyses; and

6. The operating conditions as existing at the time of sampling or measurement.

B. The Permittee shall retain records of all required monitoring data and support information 

for a period of at least 5 years from the date of the monitoring sample, measurement, 

report, or application. Support information includes all calibration and maintenance 

records and all original strip-chart recordings or other data recordings for continuous 

monitoring instrumentation, and copies of all reports required by the permit.

C. All required records shall be maintained either in an unchangeable electronic format or in 

a handwritten logbook utilizing indelible ink.

XIV. REPORTING REQUIREMENTS [A.A.C. R18-2-306.A.5.a]

The Permittee shall submit the following reports:

A. Compliance certifications in accordance with Section VII of Attachment “A”.

B. Excess emission; permit deviation, and emergency reports in accordance with Section XII 

of Attachment “A”.

C. Other reports required by any condition of Attachment “B”.

XV. DUTY TO PROVIDE INFORMATION [A.A.C. R18-2-304.G and -306.A.8.e]

A. The Permittee shall furnish to the Director, within a reasonable time, any information that 

the Director may request in writing to determine whether cause exists for revising, 

revoking and reissuing, or terminating the permit, or to determine compliance with the 

permit. Upon request, the Permittee shall also furnish to the Director copies of records 

required to be kept by the permit. For information claimed to be confidential, the 
Permit No. 1001770 Page 12 of 99 April 12, 2006

Permittee shall furnish an additional copy of such records directly to the Administrator 

along with a claim of confidentiality.

B. If the Permittee has failed to submit any relevant facts or has submitted incorrect 

information in the permit application, the Permittee shall, upon becoming aware of such 

failure or incorrect submittal, promptly submit such supplementary facts or corrected 

information.

XVI. PERMIT AMENDMENT OR REVISION [A.A.C. R18-2-318, -319, and -320]

The Permittee shall apply for a permit amendment or revision for changes to the facility which do 

not qualify for a facility change without revision under Section XVII, as follows:

A. Administrative Permit Amendment (A.A.C. R18-2-318);

B. Minor Permit Revision (A.A.C. R18-2-319); and

C. Significant Permit Revision (A.A.C. R18-2-320)

The applicability and requirements for such action are defined in the above referenced 

regulations.

XVII. FACILITY CHANGE WITHOUT A PERMIT REVISION [A.A.C. R18-2-306.A.4 and -317]

A. The Permittee may make changes at the permitted source without a permit revision if all 

of the following apply:

1. The changes are not modifications under any provision of Title I of the Act or 

under ARS § 49-401.01(19);

2. The changes do not exceed the emissions allowable under the permit whether 

expressed therein as a rate of emissions or in terms of total emissions;

3. The changes do not violate any applicable requirements or trigger any additional 

applicable requirements;

4. The changes satisfy all requirements for a minor permit revision under A.A.C.

R18-2-319.A; and

5. The changes do not contravene federally enforceable permit terms and conditions 

that are monitoring (including test methods), recordkeeping, reporting, or 

compliance certification requirements.

B. The substitution of an item of process or pollution control equipment for an identical or 

substantially similar item of process or pollution control equipment shall qualify as a 

change that does not require a permit revision, if it meets all of the requirements of 

Conditions XVII.A and XVII.C of this Attachment.

C. For each change under Conditions XVII.A and XVII.B above, a written notice by 

certified mail or hand delivery shall be received by the Director and the Administrator a 

minimum of 7 working days in advance of the change. Notifications of changes 

associated with emergency conditions, such as malfunctions necessitating the 
Permit No. 1001770 Page 13 of 99 April 12, 2006

replacement of equipment, may be provided less than 7 working days in advance of the 

change, but must be provided as far in advance of the change, as possible or, if advance 

notification is not practicable, as soon after the change as possible.

D. Each notification shall include:

1. When the proposed change will occur;

2. A description of the change;

3. Any change in emissions of regulated air pollutants; and

4. Any permit term or condition that is no longer applicable as a result of the 

change.

E. The permit shield described in A.A.C. R18-2-325 shall not apply to any change made 

under this Section, other than implementation of an alternate to Conditions XVII.A and 

XVII.B above.

F. Except as otherwise provided for in the permit, making a change from one alternative 

operating scenario to another as provided under A.A.C. R18-2-306.A.11 shall not require 

any prior notice under this Section.

G. Notwithstanding any other part of this Section, the Director may require a permit to be 

revised for any change that, when considered together with any other changes submitted 

by the same source under this Section over the term of the permit, do not satisfy 

Condition XVII.A above.

XVIII. TESTING REQUIREMENTS [A.A.C. R18-2-312]

A. The Permittee shall conduct performance tests as specified in the permit and at such other 

times as may be required by the Director.

B. Operational Conditions during Testing

Tests shall be conducted during operation at the maximum possible capacity of each unit under 

representative operational conditions unless other conditions are required by the applicable test 

method or in this permit. With prior written approval from the Director, testing may be 

performed at a lower rate. Operations during periods of start-up, shutdown, and malfunction (as 

defined in A.A.C. R18-2-101) shall not constitute representative operational conditions unless 

otherwise specified in the applicable standard.

C. Tests shall be conducted and data reduced in accordance with the test methods and 

procedures contained in the Arizona Testing Manual unless modified by the Director 

pursuant to A.A.C. R18-2-312.B.

D. Test Plan

At least 14 calendar days prior to performing a test, the Permittee shall submit a test plan 

to the Director in accordance with A.A.C. R18-2-312.B and the Arizona Testing Manual. 

This test plan must include the following:
Permit No. 1001770 Page 14 of 99 April 12, 2006

1. Test duration;

2. Test location(s);

3. Test method(s); and

4. Source operation and other parameters that may affect test results.

E. Stack Sampling Facilities

The Permittee shall provide, or cause to be provided, performance testing facilities as 

follows:

1. Sampling ports adequate for test methods applicable to the facility;

2. Safe sampling platform(s);

3. Safe access to sampling platform(s); and

4. Utilities for sampling and testing equipment.

F. Interpretation of Final Results

Each performance test shall consist of three separate runs using the applicable test 

method. Each run shall be conducted for the time and under the conditions specified in 

the applicable standard. For the purpose of determining compliance with an applicable 

standard, the arithmetic mean of the results of the three runs shall apply. In the event that 

a sample is accidentally lost or conditions occur in which one of the three runs is required 

to be discontinued because of forced shutdown, failure of an irreplaceable portion of the 

sample train, extreme meteorological conditions, or other circumstances beyond the 

Permittee’s control, compliance may, upon the Director’s approval, be determined using 

the arithmetic mean of the results of the other two runs. If the Director or the Director’s 

designee is present, tests may only be stopped with the Director’s or such designee’s 

approval. If the Director or the Director’s designee is not present, tests may only be 

stopped for good cause. Good cause includes: forced shutdown, failure of an 

irreplaceable portion of the sample train, extreme meteorological conditions, or other 

circumstances beyond the Permittee’s control. Termination of any test without good 

cause after the first run is commenced shall constitute a failure of the test. Supporting 

documentation, which demonstrates good cause, must be submitted.

G. Report of Final Test Results

A written report of the results of all performance tests shall be submitted to the Director 

within 30 days after the test is performed. The report shall be submitted in accordance 

with the Arizona Testing Manual and A.A.C. R18-2-312.A.

XIX. PROPERTY RIGHTS [A.A.C. R18-2-306.A.8.d]

This permit does not convey any property rights of any sort, or any exclusive privilege.
Permit No. 1001770 Page 15 of 99 April 12, 2006

XX. SEVERABILITY CLAUSE [A.A.C. R18-2-306.A.7]

The provisions of this permit are severable. In the event of a challenge to any portion of this 

permit, or if any portion of this permit is held invalid, the remaining permit conditions remain 

valid and in force.

XXI. PERMIT SHIELD [A.A.C. R18-2-325]

Compliance with the conditions of this permit shall be deemed compliance with all applicable 

requirements identified in the portions of this permit subtitled “Permit Shield.” The permit shield 

shall not apply to minor revisions pursuant to Condition XVI.B of this Attachment and any 

facility changes without a permit revision pursuant to Section XVII of this Attachment.

XXII. PROTECTION OF STRATOSPHERIC OZONE [40 CFR part 82]

If this source becomes subject to the provisions of 40 CFR Part 82, then the Permittee shall 

comply with these provisions accordingly.

XXIII. APPLICABILITY OF NSPS GENERAL PROVISIONS [40 CFR 60 subpart A]

For all equipment subject to a New Source Performance Standard, the Permittee shall comply 

with all applicable requirements contained in subpart A of title 40, part 60 of the Code of Federal 

Regulations.

XXIV. APPLICABILITY OF NESHAP GENERAL PROVISIONS [40 CFR 63 subpart A]

For all equipment subject to a National Emission Standard for Hazardous Air Pollutants, the 

Permittee shall comply with all applicable requirements contained in subpart A of title 40, parts 

61 and 63 of the Code of Federal Regulations.
Permit No. 1001770 Page 16 of 99 April 12, 2006

ATTACHMENT “B”: SPECIFIC CONDITIONS

Air Quality Control Permit No. 1001770

for

Drake Cement, LLC

I. KILN, CLINKER COOLER, RAW MILL, AND COAL MILL 

A. List of Emission Units

Emission Unit Name

(Equipment ID Number)

Emission Unit 

Description

Control Measure

(Control Device ID 

Number)

Emission Point 

ID Number

Raw Mill

(BM-5.16)

164 tons raw meal per 

hour

Baghouse

(BH-5.30)

Main Stack

(MS-5.38)

Rotary Kiln

(RK-9.1)

Dry process, 83.33 tons 

clinker per hour

Selective Non-Catalytic 

Reduction

Baghouse (BH-5.30)

Main Stack

(MS-5.38)

Clinker Grate Cooler

(CGC-10.1)

83.33 tons clinker per 

hour

Baghouse

(BH-10.13)

Cooler Stack

(CS-10.16)

Coal Mill

(VM-12.9)

14 tons coal per hour Baghouse

(BH-12.18)

Main Stack

(MS-5.38)

B. Emission Limits and Standards

1. Operational Limitations

a. Cement clinker produced in the Rotary Kiln shall not exceed 83.33 tons 

per hour based on an hourly rolling 3-hour average.

[A.A.C. R18-2-306(A)(2)] 

b. Cement clinker produced in the Rotary Kiln shall not exceed 660,000 

tons per year based on a monthly rolling 12-month sum. 

[A.A.C. R18-2-306(A)(2)] 

c. The Rotary Kiln shall not be equipped with an alkali bypass.

[A.A.C. R18-2-306(A)(2) and R18-2-331(A)(3)(a)]

Material Permit Conditions are indicated with underline and italics.

2. Particulate Matter Emission Standards

a. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Main Stack any gases which contain PM10 in excess of 0.010 

grains per dry standard cubic feet.

[A.A.C. R18-2-406(A)(4)}]

b. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Cooler Stack any gases which contain PM10 in excess of 0.005 

grains per dry standard cubic feet. [A.A.C. R18-2-406(A)(4)}]
Permit No. 1001770 Page 17 of 99 April 12, 2006

c. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Main Stack any gases which contain PM10 in excess of 5.967 

lbs/hr. 

[A.A.C. R18-2-406(A)(5)]

d. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Cooler Stack any gases which contain PM10 in excess of 2.223

lbs/hr. 

[A.A.C. R18-2-406(A)(5)]

e. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Rotary Kiln and Raw Mill any gases which contain particulate 

matter (PM) in excess of 0.30 lb per ton of feed (dry basis) to the Rotary 

Kiln.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1343(c)(1)}]

f. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Clinker Grate Cooler any gases which contain particulate matter 

(PM) in excess of 0.10 lb per ton of feed (dry basis) to the Rotary Kiln.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1345(a)(1)}]

g. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Coal Mill any gases which contain particulate matter (PM) in 

excess of 0.031 grains per dry standard cubic feet.

 [A.A.C. R18-2-901(32) {40 CFR § 60.252(a)(1)}]

h. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Main Stack any gases which exhibit opacity greater than 20 

percent, based on a 6-minute block average.

[A.A.C. R18-2-331(A)(3)(f), R18-2-901(32) {40 CFR § 60.252(a)(2)}, and R18-2-1101(B)(49) {40 CFR § 63.1343(c)(2)}]

Material Permit Conditions are indicated with underline and italics.

i. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Cooler Stack any gases which exhibit opacity greater than 10 

percent, based on a 6-minute block average.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-1101(B)(49) {40 CFR § 63.1345(a)(2)}]

Material Permit Conditions are indicated with underline and italics.

3. Sulfur Dioxide Emission Standard

The Permittee shall not cause or allow to be emitted into the atmosphere from the 

Main Stack any gases which contain sulfur dioxide (SO2) emissions in excess of 

21.9 tons per year based on a daily rolling 365-day sum.

[A.A.C. R18-2-306.01(A) and R18-2-331(A)(3)(a)]

Material Permit Conditions are indicated with underline and italics.

4. Nitrogen Oxides Emission Standards

a. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Main Stack any gases which contain NOX in excess of 95 lbs/hr 

based on an hourly rolling 24-hour average.

[A.A.C. R18-2-406(A)(5)]
Permit No. 1001770 Page 18 of 99 April 12, 2006

b. Except as provided in Condition I.B.4.c, the Permittee shall not cause or 

allow to be emitted into the atmosphere from the Main Stack any gases 

which contain NOX in excess of 1.95 lbs per ton of clinker based on a 

daily rolling 30-day average.

[A.A.C. R18-2-406(A)(4)]

c. For the first 180 operating days after initial startup of the Rotary Kiln,

the Permittee shall not cause or allow to be emitted into the atmosphere 

from the Main Stack any gases which contain NOX in excess of 2.45 lbs 

per ton of clinker based on a daily rolling 30-day average.

[A.A.C. R18-2-406(A)(4)]

5. Carbon Monoxide Emission Standard

The Permittee shall not cause or allow to be emitted into the atmosphere from the 

Main Stack any gases which contain CO in excess of 3.6 lbs per ton of clinker 

based on an hourly rolling 3-hour average.

[A.A.C. R18-2-406(A)(4)]

6. Volatile Organic Compounds and Organic HAP Emission Standards 

a. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Rotary Kiln and Raw Mill any gases which contain total 

hydrocarbon (THC) emissions in excess of 50 ppmvd as propane, 

corrected to seven percent oxygen, based on a 30-day block average.

[A.A.C. R18-2-1101(B)(49) {40 CFR §§ 63.1343(c)(4), 63.1346(c)(1)}, and 63.1350(h)(3)}] 

b. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Main Stack any gases which contain total hydrocarbon (THC) 

emissions in excess of 39.0 tons per year, based on a daily rolling 365-

day sum.

[A.A.C. R18-2-306.01(A) and R18-2-331(A)(3)(a)]

Material Permit Conditions are indicated with underline and italics.

7. Dioxins/Furans Emission Standards

a. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Rotary Kiln and Raw Mill any gases which contain

dioxins/furans (D/F) in excess of:

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1343(c)(3)}]

(1) 0.20 ng per dscm (8.7 × 10-11 gr/dscf) (toxicity equivalent 

(TEQ)) corrected to seven percent oxygen; or

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1343(c)(3)(i)}]

(2) 0.40 ng per dscm (1.7 × 10-10 gr per dscf) (TEQ) corrected to 

seven percent oxygen, when the average of the performance test 

run average temperatures at the inlet to the particulate matter 

control device is 400 °F or less.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1343(c)(3)(ii)}]
Permit No. 1001770 Page 19 of 99 April 12, 2006

b. The Permittee shall operate the Rotary Kiln and Raw Mill such that:

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1344(a)}]

(1) When the Raw Mill is operating, the temperature of the gas at 

the inlet to Baghouse BH-5.30 does not exceed the applicable 

temperature limit, determined in accordance with Condition 

I.E.5.a(9) and established during the performance test when the 

Raw Mill was operating.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1344(a)(1)}]

(2) When the Raw Mill is not operating, the temperature of the gas 

at the inlet to Baghouse BH-5.30 does not exceed the applicable 

temperature limit, determined in accordance with Condition 

I.E.5.a(9) and established during the performance test when the 

Raw Mill was not operating.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1344(a)(2)}]

8. Ammonia Emission Standards

The Permittee shall not cause or allow to be emitted into the atmosphere from the 

Main Stack any gases which contain ammonia in excess of 19.8 tons per year, 

based on a rolling 12-month sum.

[A.A.C. R18-306.A.2]

C. Air Pollution Control Requirements

1. At all times when the Rotary Kiln is in operation, including periods of startup, 

shutdown, and malfunction, the Permittee shall, to the extent practicable, install,

maintain and operate the Selective Non-Catalytic Reduction system in a manner 

consistent with good air pollution control practice for minimizing NOX emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)]

Material Permit Conditions are indicated with underline and italics.

2. At all times when the Rotary Kiln or Raw Mill is in operation, including periods 

of startup, shutdown, and malfunction, the Permittee shall, to the extent 

practicable, install, maintain and operate Baghouse BH-5.30 in a manner 

consistent with good air pollution control practice for minimizing PM and PM10 

emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.

3. At all times when the Clinker Grate Cooler is in operation, including periods of 

startup, shutdown, and malfunction, the Permittee shall, to the extent practicable,

install, maintain and operate Baghouse BH-10.13 in a manner consistent with 

good air pollution control practice for minimizing PM and PM10 emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.

4. At all times when the Coal Mill is in operation, including periods of startup, 

shutdown, and malfunction, the Permittee shall, to the extent practicable, install,
Permit No. 1001770 Page 20 of 99 April 12, 2006

maintain and operate Baghouse BH-12.18 in a manner consistent with good air 

pollution control practice for minimizing PM and PM10 emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e), R18-2-406(A)(4), and R18-2-901(1) {40 CFR § 60.11(d)}]

Material Permit Conditions are indicated with underline and italics. 

D. Monitoring, Recordkeeping, and Reporting Requirements

1. Monitoring and Recordkeeping for Operational Limitations

a. The Permittee shall install, calibrate, maintain, and operate monitoring 

devices for measuring and recording the process weights of total kiln 

feed and clinker produced in the Rotary Kiln. Two monitoring devices 

shall be employed: one for measuring total feed rate to the Rotary Kiln

and one for measuring clinker production rate.

[A.A.C. R18-2-306(A)(3)(c) and R18-2-331(A)(3)(c)]

Material Permit Conditions are indicated with underline and italics.

b. Each monitoring device shall have an accuracy of ± 2% over its 

operating range.

[A.A.C. R18-2-306(A)(3)(c)]

c. The calibration of each monitoring device shall be verified at least once

every three months.

[A.A.C. R18-2-306(A)(3)(c)]

d. The Permittee shall maintain daily records of rolling 365-day total 

clinker production.

[A.A.C. R18-2-306(A)(3)(c)]

2. Monitoring and Recordkeeping for Opacity of Visible Emissions

a. The Permittee shall install, calibrate, maintain, and operate continuous 

opacity monitoring systems (COMS) to continuously monitor the opacity

of visible emissions from the Main Stack and the Cooler Stack.

[A.A.C. R18-2-331(A)(3)(c) and R18-2-1101(B)(49) {40 CFR §§ 63.1350(c) and (d)}]

Material Permit Conditions are indicated with underline and italics. 

b. Each COMS required by Condition I.D.2.a shall meet the requirements

of Performance Specification 1, Specifications and test procedures for 

opacity continuous emission monitoring systems in stationary sources, in 

appendix B to 40 CFR Part 60.

[A.A.C. R18-2-1101(B)(49) {40 CFR §§ 63.1350(c) and (d)}]

c. For each COMS required by Condition I.D.2.a, the Permittee shall 

maintain all records required by 40 CFR § 63.10(c). 

[A.A.C. R18-2-1101(B)(49) {40 CFR §§ 63.1355(c) }]

d. If the average opacity for any 6-minute block period exceeds 20 percent, 

this shall constitute a period of excess emissions and a violation of 

Condition I.B.2.h.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(c)(3)}]
Permit No. 1001770 Page 21 of 99 April 12, 2006

e. If the average opacity for any 6-minute block period exceeds 10 percent, 

this shall constitute a period of excess emissions and a violation of 

Condition I.B.2.i.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350 (d)(3)}]

f. The Permittee shall report excess emissions and deviations in accordance 

with Sections XII.A and XII.B, respectively, in Attachment “A” of this 

permit.

[A.A.C. R18-2-306(A)(5)(b)]

3. Monitoring and Recordkeeping for SO2, NOX, and CO emissions

a. The Permittee shall install, calibrate, maintain, and operate continuous 

emission rate monitoring systems (CERMS) for monitoring and 

recording the SO2, NOX,, CO and ammonia emission rates to the 

atmosphere from the Main Stack.

[A.A.C. R18-2-331(A)(3)(c)]

Material Permit Conditions are indicated with underline and italics. 

b. The CERMS required by Condition I.D.3.a shall meet the following

requirements:

(1) 40 CFR Part 60, Appendix B, “Performance Specifications”

(a) The SO2 and NOX CERMS shall meet the 

requirements of Performance Specification 2, 

Specifications and test procedures for SO2 and NOX

continuous emission monitoring systems in stationary 

sources, in Appendix B to 40 CFR Part 60.

(b) The CO CERMS shall meet the requirements of 

Performance Specification 4a, Specifications and test 

procedures for carbon monoxide continuous emission 

monitoring systems in stationary sources, in Appendix B 

to 40 CFR Part 60.

(c) The ammonia CERMS shall be maintained and operated 

in accordance with performance specifications approved 

by the Director prior to startup of the Rotary Kiln. The 

proposed performance specifications shall be 

substantially equivalent to those set forth in Performance 

Specification 5 in Appendix B to 40 CFR Part 60.

(d) The SO2, NOX, CO and ammonia CERMS shall meet the 

requirements of Performance Specification 6, 

Specifications and test procedures for continuous 

emission rate monitoring systems in stationary sources, 

in Appendix B to 40 CFR Part 60.
Permit No. 1001770 Page 22 of 99 April 12, 2006

(2) 40 CFR Part 60, Appendix F, “Quality Assurance Procedures.”

(3) The Permittee shall submit a Quality Assurance/Quality Control 

Plan to the Director 30 days prior to the instrument start-up 

including procedures for dealing with data gaps based on the 

procedures contained in 40 CFR 75, Subpart D (§ 75.30). When 

approved by the Director, this plan shall be implemented.

[A.A.C. R18-2-306(A)(4), -406(A)(4)]

c. The Permittee shall maintain a file of all measurements, including 

continuous monitoring system, monitoring device, and performance 

testing measurements; all continuous monitoring system performance 

evaluations; all continuous monitoring system or monitoring device 

calibration checks; adjustments and maintenance performed on these 

systems or devices; and all other information required by this part 

recorded in a permanent form suitable for inspection. The file shall be 

retained for at least five years following the date of such measurements, 

maintenance, reports, and records.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

d. Each continuous monitoring system shall be installed and operational 

prior to conducting required initial performance tests. Verification of 

operational status shall, at a minimum, include completion of the 

manufacturer’s written requirements or recommendations for installation, 

operation, and calibration of these devices. Notification of the 

operational status of the continuous monitoring system shall be provided 

to the Director within 30 days after the system becomes operational, or 

by the date on which the initial performance test is conducted, whichever 

occurs first.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

e. Except for system breakdowns, repairs, calibration checks, and zero and 

span adjustments, the Permittee shall meet minimum frequency of 

operation requirements as follows: the continuous monitoring system 

shall complete a minimum of one cycle of operation (sampling, 

analyzing, and data recording) for each successive 15-minute period. 

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

f. For continuous monitoring system measurements, one-hour arithmetic 

averages shall be computed from four or more data points equally spaced 

over each one-hour period. Data recorded during periods of continuous 

monitoring system breakdowns, repairs, calibration checks, and zero and 

span adjustments shall not be included in the data averages computed 

under this condition.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

g. For the purposes of demonstrating compliance with emission standards 

expressed as mass emissions per unit of clinker production, averages 

shall be calculated as the total emission rate over the averaging period, as 

measured and recorded in accordance with Conditions I.D.3.a through 
Permit No. 1001770 Page 23 of 99 April 12, 2006

I.D.3.f, divided by the total clinker production rate over the averaging 

period, as measured and recorded in accordance with Condition I.D.1.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

h. The following shall be considered periods of excess emissions:

(1) All 365-day periods for which the SO2 emission rate to the 

atmosphere as determined in accordance with Condition I.D.3 

exceeds the emission standard in Condition I.B.3.

[A.A.C. R18-2-306(A)(3)]

(2) All 24-hour periods for which the NOX emission rate to the 

atmosphere as determined in accordance with Condition I.D.3 

exceeds the emission standard in Condition I.B.4.a.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

(3) All 30-day periods for which the NOX emission rate to the 

atmosphere as determined in accordance with Condition I.D.3

exceeds the applicable emission standard in either Condition 

I.B.4.b. or Condition I.B.4.c.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(5)]

(4) All 3-hour periods for which the CO emission rate to the 

atmosphere as determined in accordance with Condition I.D.3 

exceeds the emission standard in Condition I.B.5.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4)]

(5) All 365-day periods for which the ammonia emission rate to the 

atmosphere as determined in accordance with Condition I.D.3 

exceeds the emission standard in Condition I.B.5.

[A.A.C. R18-2-306(A)(3)]

i. The Permittee shall report excess emissions and deviations in accordance 

with Sections XII.A and XII.B, respectively, in Attachment “A” of this 

permit.

[A.A.C. R18-2-306(A)(5)(b)]

4. Monitoring and Recordkeeping for VOC and Organic HAP.

a. The Permittee shall install, calibrate, maintain, and operate a continuous 

emission rate monitoring system (CERMS) for monitoring and recording 

the concentration by volume (dry basis, corrected to 7.0 percent oxygen) 

and the rate of THC emissions into the atmosphere from the Rotary Kiln 

and Raw Mill.

[A.A.C. R18-2-306(A)(3), R18-2-331(A)(3)(c), and R18-2-1101(B)(49) {40 CFR § 63.1350(h)(1)}] 

Material Permit Conditions are indicated with underline and italics.

b. The CERMS required by Condition I.D.4.a shall meet the following

requirements:
Permit No. 1001770 Page 24 of 99 April 12, 2006

(1) 40 CFR Part 60, Appendix B, “Performance Specifications”

(a) The CERMS shall meet the requirements of 

Performance Specification 8a, Specifications and test 

procedures for total hydrocarbon continuous monitoring 

systems in stationary sources.

[A.A.C. R18-2-306(A)(3) and R18-2-1101(B)(49) {40 CFR § 63.1350(h)(1)}] 

(b) The Permittee is not required to calculate hourly 

rolling averages in accordance with section 4.9 of 

Performance Specification 8A.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(h)(2)}] 

(c) The CERMS shall meet the requirements of 

Performance Specification 6, Specifications and test 

procedures for continuous emission rate monitoring 

systems in stationary sources.

[A.A.C. R18-2-306(A)(3)] 

(2) 40 CFR Part 60, Appendix F, “Quality Assurance Procedures.”

[A.A.C. R18-2-306(A)(3)] 

(3) The Permittee shall submit a Quality Assurance/Quality Control 

Plan to the Director 30 days prior to the instrument start-up 

including procedures for dealing with data gaps based on the 

procedures contained in 40 CFR Part 75, Subpart D (§ 75.30). 

When approved by the Director, this plan shall be implemented. 

[A.A.C. R18-2-306(A)(3)] 

c. For the CERMS required by Condition I.D.4.a, the Permittee shall 

maintain all records required by 40 CFR § 63.10(c). 

[A.A.C. R18-2-1101(B)(49) {40 CFR §§ 63.1355(c) }]

d. Any thirty-day block average THC concentration in any gas discharged 

from the Rotary Kiln or Raw Mill, exceeding 50 ppmvd, reported as 

propane, corrected to seven percent oxygen, this shall constitute a period 

of excess emissions and a violation of Condition I.B.6.b.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1350(h)(3)}]

e. Any 365-day period for which the THC emission rate to the atmosphere

as determined in accordance with Condition I.D.4.a, reported as propane, 

exceeds the emission standard in Condition I.B.6.a shall constitute a 

period of excess emissions.

[A.A.C. R18-2-306(A)(3), R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1350(h)(3)}] 

f. The Permittee shall report excess emissions and deviations in accordance 

with Sections XII.A and XII.B, respectively, in Attachment “A” of this

permit.

[A.A.C. R18-2-306(A)(5)(b)]
Permit No. 1001770 Page 25 of 99 April 12, 2006

5. Monitoring and Recordkeeping for Dioxin/Furan Emissions

a. The Permittee shall install, calibrate, maintain, and operate a continuous 

monitor to record the temperature of the exhaust gases from the Rotary 

Kiln and Raw Mill at the inlet to, or upstream of, Baghouse BH-5.30.

[A.A.C. R18-2-331(A)(3)(c) and R18-2-1101(B)(49) {40 CFR § 63.1350(f)(1) and (f)(2)}]

Material Permit Conditions are indicated with underline and italics. 

(1) The recorder response range must include zero and 1.5 times 

either of the average temperatures established according to the 

requirements in Condition I.E.5.a(8).

[R18-2-1101(B)(49) {40 CFR § 63.1350(f)(1)(i)}]

(2) The reference method must be a National Institute of Standards 

and Technology calibrated reference thermocouplepotentiometer system or alternate reference, subject to approval 

by the Director.

[R18-2-1101(B)(49) {40 CFR § 63.1350(f)(1)(ii)}] 

b. The three-hour rolling average temperature shall be calculated as the 

average of 180 successive one-minute average temperatures.

[R18-2-1101(B)(49) {40 CFR § 63.1350(f)(3)}]

c. Periods of time when one-minute averages are not available shall be 

ignored when calculating three-hour rolling averages. When one-minute 

averages become available, the first one-minute average is added to the 

previous 179 values to calculate the three-hour rolling average.

[R18-2-1101(B)(49) {40 CFR § 63.1350(f)(4)}]

d. When the operating status of the Raw Mill is changed from off to on, or 

from on to off, the calculation of the three-hour rolling average 

temperature must begin anew, without considering previous recordings.

[R18-2-1101(B)(49) {40 CFR § 63.1350(f)(5)}]

e. The calibration of all thermocouples and other temperature sensors shall 

be verified at least once every three months.

[A.A.C. R18-2-331(A)(3)(c) and R18-2-1101(B)(49) {40 CFR § 63.1350(f)(6)}]

Material Permit Conditions are indicated with underline and italics.

f. For the continuous temperature monitoring system required by Condition 

I.D.5.a, the Permittee shall maintain all records required by 40 CFR § 

63.10(c). 

[A.A.C. R18-2-1101(B)(49) {40 CFR §§ 63.1355(c) }]

g. The Permittee shall conduct an inspection of the components of the 

combustion system of the Rotary Kiln at least once per year.

[R18-2-1101(B)(49) {40 CFR § 63.1350(i)}]
Permit No. 1001770 Page 26 of 99 April 12, 2006

6. Monitoring and Recordkeeping for Baghouses BH-5.30 and BH-10.13

a. For the purpose of demonstrating compliance with Conditions I.B.2.a

through I.B.2.d, and in accordance with the requirements of 40 CFR Part 

64, the Permittee shall maintain and implement the approved Compliance 

Assurance Monitoring (CAM) Plans for Baghouses BH-5.30 and BH10.13.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM} and R18-2-406(A)(4)]

b. Prior to startup of the Rotary Kiln, Raw Mill, or Clinker Grate Cooler, 

the Permittee shall obtain the Director’s written approval of the CAM 

Plans for Baghouses BH-5.30 and BH-10.13 and shall submit an

application for revising the permit to include the monitoring and analysis 

procedures in the approved CAM Plans. These monitoring and analysis 

procedures shall be incorporated into the permit through a significant 

permit revision, which includes a 30-day public notice period and a 45-

day EPA review period per A.A.C. R18-2-320(D).

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}]

c. Operation of approved monitoring in accordance with 40 CFR 64.7 shall 

commence upon startup of the Rotary Kiln, Raw Mill, and Clinker Grate 

Cooler.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR part 64 - CAM} and R18-2-406(A)(4)]

d. The CAM Plans shall describe in detail the maintenance procedures for 

Baghouses BH-5.30 and BH-10.13.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR part 64 - CAM} and R18-2-406(A)(4)]

e. The Permittee shall install, calibrate, operate, and maintain, according to 

the manufacturer's specifications, continuous parameter monitoring 

systems capable of measuring pressure drop across Baghouses BH-5.30 

and BH-10.13.

[A.A.C. R18-2-306(A)(3)(b) & (4) -331(A)(3)(c){40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

f. The Permittee shall continuously monitor and record the pressure drop 

across Baghouses BH-5.30 and BH-10.13. The output of the pressure 

drop continuous parameter monitoring systems shall be recorded on 

circular charts or other permanent format and shall be maintained on site 

readily available for inspection.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

g. The pressure drop continuous parameter monitoring systems shall meet 

the performance criteria contained in the approved CAM plans.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

h. Each time the pressure drop across Baghouse BH-5.30 falls outside the 

range established pursuant to Condition I.E.4.g shall constitute an 

excursion.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]
Permit No. 1001770 Page 27 of 99 April 12, 2006

i. Each instance of visible emissions from the Main Stack with opacity, as 

determined in accordance with Condition I.D.2.a, in excess of the value 

established pursuant to Condition I.E.4.g shall constitute an excursion.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

j. Each time the pressure drop across Baghouse BH-10.13 falls outside the 

range established pursuant to Condition I.E.4.h shall constitute an 

excursion.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

k. Each instance of visible emissions from the Cooler Stack with opacity, as 

determined in accordance with Condition I.D.2.a, in excess of the value 

established pursuant to Condition I.E.4.h shall constitute an excursion.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

l. The Permittee shall take corrective action following each pressure drop 

or opacity excursion as defined in Conditions I.D.6.h through I.D.6.k.

Corrective action to restore the baghouse(s) to normal operation shall be 

taken as expeditiously as practicable in accordance with good air 

pollution control practices for minimizing emissions, and in all cases 

shall be initiated within 24 hours following detection of an excursion.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

m. The Permittee shall perform monthly inspections of Baghouses BH-5.30 

and BH-10.13 and the associated pressure drop continuous parameter 

monitoring systems in accordance with the manufacturers’ recommended 

procedures. The Permittee shall take corrective action following the 

discovery of any abnormal operation or required maintenance of 

Baghouses BH-5.30 and BH-10.13 or the associated pressure drop 

continuous parameter monitoring systems as expeditiously as practicable 

in accordance with good air pollution control practices for minimizing 

emissions, but no later than within 24 hours following detection.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

n. Annual inspections, maintenance, excursions, and corrective action

measures for Baghouses BH-5.30 and BH-10.13 and the associated 

COMS and pressure drop continuous parameter monitoring systems shall 

be recorded and reported in accordance with Condition XII.B of 

Attachment “A.”

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, and R18-2-406(A)(4)]

7. Monitoring and Recordkeeping for the Coal Mill and Baghouse BH-12.18:

a. The Permittee shall install, calibrate, maintain, and continuously operate 

a device for monitoring the temperature of the gas stream at the exit of 

the Coal Mill.

[A.A.C. R18-2-331(A)(3)(c) and R18-2-901(32) {40 CFR § 60.253(a)}] 

(1) The temperature monitoring device is to be certified by the 

manufacturer to be accurate within ± 3 °F. 

[A.A.C. R18-2-901(32) {40 CFR § 60.253(a)}] 
Permit No. 1001770 Page 28 of 99 April 12, 2006

(2) The temperature monitoring device shall be recalibrated 

annually in accordance with procedures under 40 CFR § 

60.13(b).

[A.A.C. R18-2-331(A)(3)(c) and R18-2-901(32) {40 CFR § 60.253(b)}] 

b. The Permittee shall install, calibrate, maintain, and operate, according to 

the manufacturer’s specifications, a device for monitoring and recording 

the pressure drop across Baghouse BH-12.18. 

[A.A.C. R18-2-331(A)(3)(c) and R18-2-406(A)(4)]

c. The Permittee shall perform monthly inspections of Baghouse BH-12.18

and the associated pressure drop continuous parameter monitoring 

system in accordance with the manufacturers’ recommended procedures. 

The Permittee shall take corrective action following the discovery of any

abnormal operation or required maintenance of Baghouse BH-12.18 or 

the associated pressure drop continuous parameter monitoring system as 

expeditiously as practicable in accordance with good air pollution control 

practices for minimizing emissions, but no later than within 24 hours 

following detection.

[A.A.C. R18-2-406(A)(4)]

d. If the pressure drop across Baghouse BH-12.18 is outside the range ± 20 

percent from the average pressure drop measured during the most recent 

performance test, the Permittee shall initiate investigation of the control 

equipment within 24 hours of the occurrence, to identify any need for 

corrective action. If corrective action is required, the Permittee shall 

implement such corrective action as soon as practicable in order to avert 

or minimize possible exceedances of the emission standards in 

Conditions I.B.2.a and I.B.2.b. If the pressure drop remains outside of 

the range for 72 consecutive hours after the first occurrence, the 

Permittee shall submit a compliance schedule to the Director in 

accordance with Condition XII.D of Attachment “A.”

[A.A.C. R18-2-406(A)(4)]

8. Operations and Maintenance Plan

a. The Permittee shall prepare written operations and maintenance plans for 

the Rotary Kiln and Raw Mill, the Clinker Grate Cooler, and the Coal 

Mill.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)}]

(1) Each plan required by Condition I.D.8.a shall be submitted to the 

Director for review and approval.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)}]

(2) Prior to startup of the Rotary Kiln, Raw Mill, or Clinker Grate 

Cooler, the Permittee shall obtain the Director’s written approval 

for the corresponding operations and maintenance plan and shall 

submit an application for revising the permit to include the 

monitoring procedures in the approved plan. These monitoring

procedures shall be incorporated into the permit through a 
Permit No. 1001770 Page 29 of 99 April 12, 2006

significant permit revision, which includes a 30-day public 

notice period and a 45-day EPA review period per A.A.C. R18-

2-320(D).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)}]

b. Each plan required by Condition I.D.8.a shall include procedures for 

proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits and operating limits 

of Conditions I.B.2.e, I.B.2.f, I.B.2.h, I.B.6, I.B.7.a, and I.B.7.b.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(1)}]

c. Each plan required by Condition I.D.8.a shall include procedures to be 

used during an inspection of the components of the combustion system 

of the Rotary Kiln and Raw Mill at least once per year; and

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(3)}]

d. Failure to comply with any provision of the operations and maintenance 

plan approved by the Director in accordance with Condition I.D.8.a(2)

shall be a violation.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(b)}]

9. Recordkeeping, Reporting, and Notification Requirements for HAP Emission 

Standards

a. The Permittee shall maintain the following records:

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)}]

(1) All records as required by 40 CFR §§ 63.10(b)(2) and (b)(3).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)}]

(2) All documentation supporting initial notifications and 

notifications of compliance status under 40 CFR § 63.9.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)(1)}]

(3) All records of applicability determination, including supporting 

analyses.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)(2)}]

(4) If the Permittee has been granted a waiver under 40 CFR § 

63.8(f)(6), any information demonstrating whether the source is 

meeting the requirements for a waiver of recordkeeping or 

reporting requirements. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)(3)}]

b. The Permittee shall comply with the reporting requirements specified in 

40 CFR § 63.10 as follows:

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)}]

(1) As required by 40 CFR § 63.10(d)(2), the Permittee shall report 

the results of performance tests as part of the notification of 

compliance status. 

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(1)}]
Permit No. 1001770 Page 30 of 99 April 12, 2006

(2) As required by 40 CFR § 63.10(d)(3), the Permittee shall report 

the opacity results from tests required by Conditions I.E.4.a and 

I.E.4.b.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(2)}]

(3) As required by 40 CFR § 63.10(d)(5), if actions taken by a 

Permittee during a startup, shutdown, or malfunction (including 

actions taken to correct a malfunction) are consistent with the 

procedures specified in the Permittee’s startup, shutdown, and 

malfunction plan specified in 40 CFR § 63.6(e)(3), the Permittee 

shall state such information in a semi-annual report. Reports 

shall only be required if a startup, shutdown, or malfunction 

occurred during the reporting period. The startup, shutdown, and 

malfunction report may be submitted simultaneously with the 

excess emissions and continuous monitoring system performance 

reports.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(4)}]

(4) Any time an action taken by the Permittee during a startup, 

shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the Permittee shall make an 

immediate report of the actions taken for that event within 2 

working days, by telephone call or facsimile (fax) transmission. 

The immediate report shall be followed by a letter, certified by 

the Permittee, explaining the circumstances of the event, the 

reasons for not following the startup, shutdown, and malfunction 

plan, and whether any excess emissions and/or parameter 

monitoring exceedances are believed to have occurred.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(5)}]

(5) As required by 40 CFR § 63.10(e)(2), the Permittee shall submit 

a written report of the results of the performance evaluation for 

the continuous monitoring system required by 40 CFR § 63.8(e). 

The Permittee shall submit the report simultaneously with the 

results of the performance test.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(6)}]

(6) As required by 40 CFR § 63.10(e)(2), when a COMS is used to 

determine opacity compliance during any performance test 

required under 40 CFR § 63.7 and described in 40 CFR § 

63.6(d)(6), the Permittee shall report the results of the COMS

performance evaluation conducted under 40 CFR § 63.8(e).

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(7)}]

(7) As required by 40 CFR § 63.10(e)(3), the Permittee shall submit 

an excess emissions and continuous monitoring system 

performance report for any event when the data provided by the 

continuous monitoring system indicate the source is not in 
Permit No. 1001770 Page 31 of 99 April 12, 2006

compliance with the applicable emission limitation or operating 

parameter limit. 

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(8)}]

(8) The Permittee shall submit a summary report semiannually, 

along with the compliance certification, which contains the 

information specified in 40 CFR § 63.10(e)(3)(vi). In addition, 

the summary report shall include:

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(9)}]

(a) All exceedances of maximum baghouse inlet gas 

temperature limits specified in Conditions I.B.7.b(1) and

I.B.7.b(2);

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(9)(i)}]

(b) All failures to calibrate thermocouples and other 

temperature sensors as required under Condition I.D.5.e; 

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(9)(ii)}]

(c) The results of any combustion system 

component inspections conducted within the reporting 

period as required under Condition I.D.5.g; and

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(9)(iv)}]

(d) All failures to comply with any provision of the 

operation and maintenance plan required by Condition 

I.D.8.a.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(9)(v)}]

(9) If the total continuous monitoring system downtime for any

continuous monitoring system for the reporting period is 10 

percent or greater of the total operating time for the reporting

period, the Permittee shall submit an excess emissions and 

continuous monitoring system performance report along with the 

summary report required by Condition I.D.9.b(8).

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(10)}]

c. The Permittee shall comply with the notification requirements in 40 CFR 

§ 63.9 as follows:

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)}]

(1) Notification of performance tests, as required by 40 CFR §§ 63.7 

and 63.9(e). 

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(2)}]

(2) Notification of opacity and visible emission observations 

required by Condition I.E.4.c in accordance with 40 CFR §§ 

63.6(h)(5) and 63.9(f).

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(3)}]
Permit No. 1001770 Page 32 of 99 April 12, 2006

(3) Notification, as required by 40 CFR § 63.9(g), of the date that 

the CEMS or COMS performance evaluation required by 40 

CFR § 63.8(e) is scheduled to begin.

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(4)}]

(4) Notification of compliance status, as required by 40 CFR § 

63.9(h).

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(5)}]

d. The Permittee shall maintain files of all information (including all reports 

and notifications) required in a form suitable and readily available for 

inspection and review as required by 40 CFR § 63.10(b)(1). The files 

shall be retained for at least five years following the date of each 

occurrence, measurement, maintenance, corrective action, report, or 

record. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(a)}]

E. Testing Requirements 

1. The Permittee shall perform initial and periodic performance tests in accordance 

with Conditions I.E.2 through I.E.6. Initial performance tests shall be performed 

within 60 days after achieving the maximum production rate at which the 

affected facility will be operated, but not later than 180 days after initial startup 

of such facility.

[A.A.C. R18-2-406(A)(4), R18-2-901(1) {40 CFR 60.8(a)}, and R18-2-1101(B)(1) {40 CFR § 63.7(a)}]

2. For each performance test required pursuant to Condition I.E.1, the Permittee 

shall submit a test plan to the Director in accordance with Condition XVIII.D of 

Attachment “A.”

[A.A.C. R18-2-312(B) and R18-2-1101(B)(49) {40 CFR § 63.1349(a)}]

3. Performance test results shall be documented in complete test reports that contain 

the information required by Conditions I.E.3.a through I.E.3.k.

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)}]

a. A brief description of the process and the air pollution control system;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(1)}]

b. Sampling location description(s);

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(2)}]

c. A description of sampling and analytical procedures and any

modifications to standard procedures;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(3)}]

d. Test results;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(4)}]
Permit No. 1001770 Page 33 of 99 April 12, 2006

e. Quality assurance procedures and results; 

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(5)}]

f. Records of operating conditions during the test, preparation of standards, 

and calibration procedures;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(6)}]

g. Raw data sheets for field sampling and field and laboratory analyses;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(7)}]

h. Documentation of calculations;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(8)}]

i. All data recorded and used to establish parameters for compliance 

monitoring;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(9)}]

j. Any other information required by the test method; and 

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(10)}]

k. All other relevant information.

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)}]

4. Test Methods and Procedures for Particulate Matter and Opacity of Visible 

Emissions

a. The Permittee shall demonstrate initial compliance with Condition 

I.B.2.e using the test methods and procedures in Conditions I.E.4.a(1) 

through I.E.4.a(7). 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)}]

(1) The Permittee shall demonstrate initial compliance by 

conducting two separate performance tests: 1) while the Raw 

Mill is under normal operating conditions, 2) while the Raw Mill 

is not operating.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)}]

(2) EPA Reference Method 5 in Appendix A to 40 CFR Part 60 shall 

be used to determine particulate matter emissions. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(3) Each performance test shall consist of three separate runs under 

the conditions that exist when the affected source is operating at 

the representative performance conditions in accordance with 40 

CFR § 63.7(e).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(4) Each run shall be conducted for at least one hour, and the 

minimum sample volume shall be 30 dscf. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]
Permit No. 1001770 Page 34 of 99 April 12, 2006

(5) The average of the three runs shall be used to determine 

compliance.

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(6) Suitable methods shall be used to determine the Rotary Kiln feed 

rate, except for fuels, for each run. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(ii)}]

(7) The emission rate, E, shall be computed for each run using the 

following equation:

P

C Q

E

s  sd



Where: 

E = emission rate of particulate matter, lb per ton of Rotary 

Kiln feed.

Cs = concentration of PM, lb/dscf.

Qsd = volumetric flow rate of effluent gas, dscf/hr.

P = total Rotary Kiln feed (dry basis), tons/hr.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(iii)}]

b. The Permittee shall demonstrate initial compliance with Condition 

I.B.2.f using the test methods and procedures in Conditions I.E.4.b(1) 

through I.E.4.b(6). 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)}]

(1) The performance test shall consist of three separate runs under 

the conditions that exist when the affected source is operating at 

the representative performance conditions in accordance with 40 

CFR § 63.7(e).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(2) EPA Reference Method 5 in Appendix A to 40 CFR Part 60 shall 

be used to determine particulate matter emissions. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(3) Each run shall be conducted for at least one hour, and the 

minimum sample volume shall be 30 dscf. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(4) The average of the three runs shall be used to determine 

compliance.

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(i)}]

(5) Suitable methods shall be used to determine the Rotary Kiln feed 

rate, except for fuels, for each run. 
Permit No. 1001770 Page 35 of 99 April 12, 2006

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(ii)}]

(6) The emission rate, E, shall be computed for each run using the 

following equation:

P

C Q

E

s  sd



Where: 

E = emission rate of particulate matter, lb per ton of Rotary 

Kiln feed.

Cs = concentration of PM, lb/dscf.

Qsd = volumetric flow rate of effluent gas, dscf/hr.

P = total Rotary Kiln feed (dry basis), tons/hr.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(iii)}]

c. The opacity exhibited during the period of the EPA Reference Method 5 

performance tests required by Conditions I.E.4.a and I.E.4.b shall be 

determined through the use of the COMS required by Condition I.D.2.a. 

The maximum six-minute average opacity during the three EPA 

Reference Method 5 test runs shall be determined during each EPA 

Reference Method 5 test run, and used to demonstrate initial compliance 

with Condition I.B.2.h.

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(1)(v)}]

d. The Permittee shall determine compliance with Condition I.B.2.g using 

the test methods and procedures in Conditions I.E.4.d(1) through 

I.E.4.d(3). 

[A.A.C. R18-2-901(32) {40 CFR § 60.254(b)}]

(1) EPA Reference Method 5 in appendix A to 40 CFR part 60 shall 

be used to determine the particulate matter concentration. 

[A.A.C. R18-2-901(32) {40 CFR § 60.254(b)(1)}]

(2) The sampling time and sample volume for each run shall be at 

least 60 minutes and 30 dscf. 

[A.A.C. R18-2-901(32) {40 CFR § 60.254(b)(1)}]

(3) Sampling shall begin no less than 30 minutes after startup and 

shall terminate before shutdown procedures begin.

[A.A.C. R18-2-901(32) {40 CFR § 60.254(b)(1)}]

e. The Permittee shall determine compliance with Condition I.B.2.i using 

EPA Reference Method 9 in appendix A to 40 CFR part 60 and the 

procedures in 40 CFR § 60.11 to determine opacity. 

[A.A.C. R18-2-901(32) {40 CFR § 60.254(b)(2)}]
Permit No. 1001770 Page 36 of 99 April 12, 2006

f. The Permittee shall demonstrate initial compliance with Conditions 

I.B.2.a through I.B.2.d using the test methods and procedures in 

Conditions I.E.4.f(1) through I.E.4.f(6). 

(1) The Permittee shall demonstrate initial compliance with 

Conditions I.B.2.a and I.B.2.c by conducting two separate 

performance tests as follows.

(a) One performance test shall be performed under 

the conditions that exist when the Rotary Kiln, Raw 

Mill, and Coal Mill all are operating at the highest load 

or capacity level reasonably expected to occur.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(b) One performance test shall be performed under 

the conditions that exist when the Raw Mill is not 

operating and the Rotary Kiln and Coal Mill are 

operating at the highest load or capacity level reasonably 

expected to occur.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(2) The Permittee shall use any of the following test methods to 

determine the PM10 concentration: 

(a) EPA Reference Method 5 in Appendix A to 40 

CFR Part 60 in conjunction with EPA Reference Method 

202 in Appendix M to 40 CFR Part 51;

(b) EPA Reference Method 201 in Appendix M to 

40 CFR Part 51 in conjunction with EPA Reference 

Method 202 in Appendix M to 40 CFR Part 51;

(c) EPA Reference Method 201a in Appendix M to 

40 CFR Part 51 in conjunction with EPA Reference 

Method 202 in Appendix M to 40 CFR Part 51; or

(d) EPA Conditional Test Method Number CTM039, included as Attachment “D” to this permit.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(3) Each performance test shall consist of three separate runs.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(4) Each run shall be conducted for at least one hour, and the 

minimum sample volume shall be 30 dscf. 

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(5) The average of the three runs shall be used to determine 

compliance.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]
Permit No. 1001770 Page 37 of 99 April 12, 2006

(6) Suitable methods shall be used to determine the Rotary Kiln feed 

rate and clinker rate, except for fuels, for each run. Kiln feed 

and clinker production rates shall be confirmed by a material 

balance over the production system.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

g. For each pair of performance tests conducted at the Main Stack under 

Condition I.E.4.f(1), the Permittee shall determine a range of pressure 

drop values for Baghouses BH-5.30 and BH-12.18 and a range of opacity

values for the Main Stack using the following procedures: 

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(1) During each performance test run, continuously monitor and 

record the pressure drop across each baghouse as required under 

Conditions I.D.6.e and I.D.7.a;

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(2) During each performance test run, continuously monitor and 

record the opacity of visible emissions from the Main Stack as 

required under Condition I.D.2.a;

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(3) For each baghouse, determine a range of pressure drop values 

and associated averaging time, based on the pressure drop data 

monitored during the performance test, supplemented by 

engineering assessments and the manufacturer's 

recommendations, as applicable;

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(4) Determine a range of opacity values and associated averaging 

time, based on the opacity data monitored during the 

performance test, supplemented by engineering assessments and 

the manufacturer's recommendations, as applicable; and

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(5) Provide for the Director’s approval the rationale for the selected 

ranges of pressure drop values and opacity values and the 

associated averaging times. Include data and calculations used 

to develop these ranges and a description of why the ranges, 

monitoring frequencies, and averaging times demonstrate 

continuous compliance with the emission standards in 

Conditions I.B.2.a and I.B.2.c.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

h. For each performance test conducted at the Cooler Stack under Condition 

I.E.4.f, the Permittee shall determine a range of pressure drop values for 

Baghouse BH-10.13 and a range of opacity values for the Cooler Stack 

using the following procedures: 

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]
Permit No. 1001770 Page 38 of 99 April 12, 2006

(1) During each performance test run, continuously monitor and 

record the pressure drop across Baghouse BH-10.13 as required 

under Condition I.D.6.e;

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(2) During each performance test run, continuously monitor and 

record the opacity of visible emissions from the Cooler Stack as 

required under Condition I.D.2.a;

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(3) Determine a range of pressure drop values and associated 

averaging time, based on the pressure drop data monitored 

during the performance test, supplemented by engineering 

assessments and the manufacturer's recommendations, as 

applicable; and

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(4) Determine a range of opacity values and associated averaging 

time, based on the opacity data monitored during the 

performance test, supplemented by engineering assessments and 

the manufacturer's recommendations, as applicable; and

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

(5) Provide for the Director’s approval the rationale for the selected 

ranges of pressure drop values and opacity values and the 

associated averaging times. Include data and calculations used 

to develop these ranges and a description of why the ranges, 

monitoring frequencies, and averaging times demonstrate 

continuous compliance with the emission standards in 

Conditions I.B.2.b and I.B.2.d.

[A.A.C. R18-2-306(A)(3) & (4) {40 CFR Part 64 - CAM}, R18-2-406(A)(4), and R18-2-406(A)(5)]

i. If the Permittee plans to undertake a change in operations that may 

adversely affect compliance with Condition I.B.2.e or I.B.2.h, the 

Permittee must conduct a performance test as specified in Conditions 

I.E.4.a and I.E.4.c.

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(2)}]

5. Test Methods and Procedures for Dioxins/Furans Emissions

a. The Permittee shall demonstrate initial compliance with Condition 

I.B.7.a using the test methods and procedures in Conditions I.E.5.a(1) 

through I.E.5.a(9). 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)}]

(1) The Permittee shall demonstrate initial compliance by 

conducting two separate performance tests: 1) while the Raw 

Mill is under normal operating conditions, 2) while the Raw Mill 

is not operating.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)}]
Permit No. 1001770 Page 39 of 99 April 12, 2006

(2) EPA Reference Method 23 in appendix A to 40 CFR part 60 

shall be used to determine D/F emissions.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)}]

(3) Each performance test shall consist of three separate runs; each 

run shall be conducted under the conditions that exist when the 

affected source is operating at the representative performance 

conditions in accordance with §63.7(e).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)(i)}]

(4) The duration of each run shall be at least 3 hours, and the sample 

volume for each run shall be at least 88.3 dscf.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)(i)}]

(5) The concentration shall be determined for each run, and the 

arithmetic average of the concentrations measured for the three 

runs shall be calculated and used to determine compliance. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)(i)}]

(6) The temperature at the inlet to Baghouse BH-5.30 must be 

continuously recorded during the period of the Method 23 test, 

and the continuous temperature record(s) must be included in the 

performance test report.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)(ii)}]

(7) One-minute average temperatures must be calculated for each 

minute of each run of the test. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)(iii)}]

(8) The run average temperature must be calculated for each run, 

and the average of the run average temperatures must be 

determined and included in the performance test report. The 

average of the run average temperatures will determine the 

applicable temperature limit in accordance with Condition 

I.E.5.a(9).

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(3)(iv)}] 

(9) The temperature limits for the Rotary Kiln and Raw Mill in 

Conditions I.B.7.a(1) and I.B.7.a(2) are determined in 

accordance with I.E.5.a(8).

[R18-2-1101(B)(49) {40 CFR § 63.1344(b)}] 

b. Performance tests required under Condition I.E.5.a shall be repeated 

every 30 months.

[R18-2-1101(B)(49) {40 CFR § 63.1349(d)}]

c. If the Permittee plans to undertake a change in operations that may 

adversely affect compliance with the D/F standard under Condition 

I.B.7.a, the Permittee must conduct a performance test and establish new 

temperature limit(s) as specified in Conditions I.E.5.a(1) through 

I.E.5.a(8).

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(1)}]
Permit No. 1001770 Page 40 of 99 April 12, 2006

d. In preparation for and while conducting a performance test required in 

Condition I.E.5.c, the Permittee may operate under the planned 

operational change conditions for a period not to exceed 360 hours, 

provided that Conditions I.E.5.d(1) through (4) are met. The source shall 

submit temperature and other monitoring data that are recorded during 

the pretest operations.

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(3)}]

(1) The Permittee shall provide the Director written notice at least 

60 days prior to undertaking an operational change that may 

adversely affect compliance with an applicable standard under 

this subpart, or as soon as practicable where 60 days advance 

notice is not feasible. This notice shall include a description of 

the planned change, the emissions standards that may be affected 

by the change, and a schedule for completion of the performance 

test required under Condition I.E.5.c, including when the 

planned operational change period would begin. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(3)(i)}]

(2) The performance test results must be documented in a test report 

according to Condition I.E.3.

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(3)(ii)}]

(3) A test plan must be made available to the Director prior to 

testing, if requested.

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(3)(iii)}]

(4) The performance test must be conducted, and it must be 

completed within 360 hours after the planned operational change 

period begins. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(e)(iv)}]

6. Test Methods and Procedures for Total Hydrocarbons Emissions

a. The Permittee shall demonstrate initial compliance with Condition I.B.6 

using the test methods and procedures in Conditions I.E.6.b through 

I.E.6.d. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(4)}]

b. The Permittee shall demonstrate initial compliance by operating a CEMS

in accordance with Performance Specification 8A in appendix B to 40 

CFR part 60. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(4)}]

c. The Permittee shall demonstrate initial compliance by conducting two 

separate performance tests: 1) while the Raw Mill is under normal 

operating conditions, 2) while the Raw Mill is not operating.

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(4)}]
Permit No. 1001770 Page 41 of 99 April 12, 2006

d. The duration of the performance test shall be three hours, and the 

average THC concentration (as calculated from the one-minute averages) 

during the three hour performance test shall be calculated. 

[R18-2-1101(B)(49) {40 CFR § 63.1349(b)(4)}]

F. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following 

applicable requirement(s) in effect on the date of permit issuance: 40 CFR § 63.1343(c), 

40 CFR § 63.1344(a), 40 CFR § 63.1344(b), 40 CFR § 63.1345(a), 40 CFR § 

60.252(a)(1), 40 CFR § 60.252(a)(2), 40 CFR § 63.1349(a), 40 CFR § 63.1349(b)(1), 40 

CFR § 63.1349(b)(3), 40 CFR § 63.1349(b)(4), 40 CFR § 63.1349(d), 40 CFR § 

63.1349(e), 40 CFR § 63.1350(c), 40 CFR § 63.1350(d), 40 CFR § 63.1350(f), 40 CFR § 

63.1350(i), 40 CFR § 63.1350(h), 40 CFR § 63.1350(k), 40 CFR § 60.253(a), 40 CFR § 

63.1353(a), 40 CFR § 63.1353(b), 40 CFR § 63.1354(a), 40 CFR § 63.1354(b), 40 CFR § 

63.1355(a), and 40 CFR § 63.1355(b).
Permit No. 1001770 Page 42 of 99 April 12, 2006

II. FINISH MILLS, STORAGE BINS, BULK LOADING AND UNLOADING SYSTEMS, 

AND CONVEYING SYSTEM TRANSFER POINTS SUBJECT TO 40 CFR 63 SUBPART 

LLL

A. List of Emission Units and Affected Sources

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge of Belt Conveyor for 

Collecting Limestone from 

Stockpile

(BC-2.4)

Transfer Point, 495 tons 

per hour

Dust Collector

(DC-2.5)

DC-2.5

Discharge of Belt Conveyors 

(BC-2.8 and BC-2.12) to 

Limestone Silos (RMS-3.1 and 

RMS-3.3) 

Transfer Point, 495 tons 

per hour

Dust Collector

(DC-2.9)

DC-2.9

Discharge of Belt Conveyors 

(BC-2.8 and BC-2.13) to 

Limestone Silos (RMS-3.2) and 

Iron Ore Silo (RMS-3.4) 

Transfer Point, 495 tons 

per hour

Dust Collector

(DC-2.10)

DC-2.10

High Limestone Silo 1

(RMS-3.1)

Storage Bin, 550 tons n/a n/a

High Limestone Silo 2 (RMS3.2)Storage Bin, 450 tons n/a n/a

Low Limestone Silo

(RMS-3.3)

Storage Bin, 550 tons n/a n/a

Iron Ore Silo 

(RMS-3.4)

Storage Bin, 510 tons n/a n/a

Gypsum Silo 

(RMS-3.5)

Storage Bin, 450 tons n/a n/a

Clinker Silo 

(RMS-3.6)

Storage Bin, 550 tons n/a n/a

Aluminum Source Silo 

(RMS-3.7)

Storage Bin, 330 tons n/a n/a

Raw Coal Silo

(RMS-3.8)

Storage Bin, 300 tons n/a n/a

Receiving Hopper for Railroad 

Cars (RHR-4.1)

Bulk Unloading System 

(250 tons per hour)

Water Dedusting System 

(WD-4.4)

FE-11

Receiving Hopper for Trucks 

(RHT-4.5)

Bulk Unloading System 

(150 tons per hour)

Water Dedusting System 

(WD-4.6)

FE-12

Discharge of Belt Conveyor 

under Coal and Iron Ore 

Stockpile (BC-4.11) to Belt 

Conveyor (BC-4.15)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-4.18)

DC-4.18
Permit No. 1001770 Page 43 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge of Belt Conveyor 

(BC-4.15) to Coal Silo (RMS3.8) and Aluminum Silo (RMS3.7)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-4.19)

DC-4.19

Discharge of Reversible Belt 

Conveyor (BC-4.17) to Coal 

Silo (RMS-3.8) and Aluminum 

Silo (RMS-3.7)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-4.19)

DC-4.19

Discharge of Belt Conveyor 

under Rail Car and Truck 

Discharge (BC-4.8) to Belt 

Conveyors (BC-4.9 and BC4.22)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-4.20)

DC-4.20

Discharge of 1st Belt Conveyor 

for Limestone Unloaded from 

Rail Cars (BC-4.22) to Belt 

Conveyor (BC-4.24)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-4.23)

DC-4.23

Discharge of 2nd Belt 

Conveyor for Limestone 

Unloaded from Rail Cars (BC4.24) to Belt Conveyor (BC4.26)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-4.25)

DC-4.25

Discharge of 3rd Belt 

Conveyor for Limestone 

Unloaded from Rail Cars (BC4.26) to Stockpile

Transfer Point, 495 tons 

per hour

Dust Collector

(DC-1.11)

DC-1.11

Discharge from Weighfeeder 

for High Limestone (WF-5.1.1) 

to Belt Conveyor (BC-5.6)

Transfer Point, 150 tons 

per hour

Dust Collector

(DC-5.5)

DC-5.5

Discharge from Weighfeeder 

for High Limestone (WF-5.1.2) 

to Belt Conveyor (BC-5.6)

Transfer Point, 150 tons 

per hour

Dust Collector

(DC-5.5)

DC-5.5

Discharge from Weighfeeder 

for Low Limestone (WF-5.2) to 

Belt Conveyor (BC-5.6)

Transfer Point, 100 tons 

per hour

Dust Collector

(DC-5.5)

DC-5.5

Discharge from Weighfeeder 

for Iron Ore (WF-5.3.1) to Belt 

Conveyor (BC-5.4)

Transfer Point, 10 tons per 

hour

Dust Collector

(DC-5.5)

DC-5.5

Discharge from Weighfeeder 

for Aluminum Source (WF5.3.2) to Belt Conveyor (BC5.4)

Transfer Point, 10 tons per 

hour

Dust Collector

(DC-5.5)

DC-5.5

Discharge from Belt Conveyor 

for Iron Ore and Aluminum 

Source (BC-5.4) to Belt 

Conveyor (BC-5.6)

Transfer Point, 20 tons per 

hour

Dust Collector

(DC-5.5)

DC-5.5

Discharge of Screw Conveyor 

for Raw Meal (SC-5.18.1)

Transfer Point, 90 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22
Permit No. 1001770 Page 44 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge of Screw Conveyor 

for Raw Meal (SC-5.18.2)

Transfer Point, 90 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of First Airslide for 

Raw Meal (SC-5.19)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Second Airslide 

for Raw Meal (SC-5.21)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Screw Conveyor 

under Baghouse (SC-5.31.1)

Transfer Point, 6 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Screw Conveyor 

under Baghouse (SC-5.31.2)

Transfer Point, 6 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Screw Conveyor 

under Baghouse (SC-5.31.3)

Transfer Point, 6 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Screw Conveyor 

which Collects Dust from 

Baghouse (SC-5.32)

Transfer Point, 18 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Screw Conveyor 

for Taking Dust to Blending 

Silo (SC-5.33)

Transfer Point, 18 tons per 

hour

Dust Collector

(DC-5.22)

DC-5.22

Discharge of Bucket Elevator 

to Blending Silo (BE-6.1)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Airslide for Raw 

Meal on Top of Blending Silo 

(AS-6.2)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Short Airslide on 

Top of Blending Silo (AS6.4.1)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Short Airslide on 

Top of Blending Silo (AS6.4.2)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Long Airslide on 

Top of Blending Silo (AS6.5.1)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Long Airslide on 

Top of Blending Silo (AS6.5.2)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Long Airslide on 

Top of Blending Silo (AS6.5.3)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Discharge of Long Airslide on 

Top of Blending Silo (AS6.5.4)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-6.10)

DC-6.10

Blending Silo

(SI-6.7)

Storage Bin, 9000 tons n/a n/a
Permit No. 1001770 Page 45 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge of Raised Airslide 

from Blending Silo (AS-7.4)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.16)

DC-7.16

Discharge of Base Airslide 

from Blending Silo (AS-7.5)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.16)

DC-7.16

Discharge of Airslide

(AS-7.12)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.16)

DC-7.16

Feed of Bucket Elevator for 

Feeding Pre-Heater Tower 

(BE-7.15.1)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.16)

DC-7.16

Feed of Bucket Elevator for 

Feeding Pre-Heater Tower 

(BE-7.15.2)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.16)

DC-7.16

Discharge of Airslide

(AS-7.17)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.23)

DC-7.23

Discharge of Recirculating 

Airslide (AS-7.22)

Transfer Point, 170 tons 

per hour

Dust Collector

(DC-7.23)

DC-7.23

Discharge of Screw Conveyor 

for Clinker Dust (SC-10.12)

Transfer Point, 6 tons per 

hour

Dust Collector

(DC-11.2)

DC-11.2

Discharge of Screw Conveyor 

for Clinker Dust (SC-10.14)

Transfer Point, 6 tons per 

hour

Baghouse

(BH-10.13)

CS-10.16)

Discharge of Clinker Cooler to 

Hot Pan Conveyor (HPC-11.1)

Transfer Point, 83.33 tons 

per hour

Dust Collector

(DC-11.2)

DC-11.2

Discharge of Hot Pan 

Conveyor (HPC-11.1) to 

Storage Dome (CDO-11.3) and 

Belt Conveyor (BC-11.5)

Transfer Point, 83.33 tons 

per hour

Dust Collector

(DC-11.6.1)

DC-11.6.1

Discharge of Belt Conveyor 

(BC-11.5) to Emergency 

Clinker Silo (SI-11.7)

Transfer Point, 83.33 tons 

per hour

Dust Collector

(DC-11.6.2)

DC-11.6.2

Clinker Storage Dome

(CDO-11.3)

Storage Bin,

50,000 tons

Dust Collector

(DC-11.11)

DC-11.11

Emergency Clinker Silo

(SI-11.7)

Storage Bin,

13,800 tons

Dust Collector

(DC-11.11)

DC-11.11

Discharge from Clinker 

Storage Dome (CDO-11.3) to 

Belt Conveyor (BC-11.8)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-11.11)

DC-11.11

Discharge from Clinker Silo 

(SI-11.7) to Belt Conveyor 

(BC-11.8)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-11.11)

DC-11.11

Discharge from Belt Conveyor 

under Clinker Dome and 

Clinker Silo (BC-11.8) to Belt 

Conveyor (BC-11.10)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-11.11)

DC-11.11
Permit No. 1001770 Page 46 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge of Belt Conveyor 

(BC-11.10) to Reversible Belt 

Conveyor (BC-11.14)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-11.15)

DC-11.15

Discharge of Reversible Belt 

Conveyor (BC-11.14) to Finish 

Mill Clinker Silo (RMS-3.6)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-11.15)

DC-11.15

Discharge of Reversible Belt 

Conveyor (BC-11.10) to Finish 

Mill Gypsum Silo (RMS-3.5)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-11.15)

DC-11.15

Discharge from Coal Mill 

Baghouse (BH-12.18) to 

Pneumatic Coal Conveying 

System

Transfer Point, 20 tons per 

hour

Dust Collector

(DC-12.7.2)

DC-12.7.2

Discharge from Pneumatic 

Coal Conveying System to 

Pulverized Coal Silo 

Transfer Point, 20 tons per 

hour

Dust Collector

(DC-12.26)

DC-12.26

Pulverized Coal Silo with 

incorporated dust collector 

(DC-12.26)

Storage Bin, 240 tons Dust Collector

(DC-12.26)

DC-12.26

Discharge from Rotor 

Weighfeeder (RWF-12.35.1) to 

Pneumatic Conveying Pipe 

(PCP-12.37)

Transfer Point, 7.0 tons 

per hour

Dust Collector

(DC-12.26)

DC-12.26

Discharge from Rotor 

Weighfeeder (RWF-12.35.2) to 

Pneumatic Conveying Pipe 

(PCP-12.38)

Transfer Point, 7.0 tons 

per hour

Dust Collector

(DC-12.26)

DC-12.26

Discharge from Pneumatic 

Conveying Pipe (PCP-12.37) to 

Calciner (CAL-8.13)

Transfer Point, 7.0 tons 

per hour

Dust Collector

(DC-12.26)

DC-12.26

Discharge from Pneumatic 

Conveying Pipe (PCP-12.38) to 

Rotary Kiln

Transfer Point, 7.0 tons 

per hour

Dust Collector

(DC-12.26)

DC-12.26

Finish Mill Clinker Feed Silo 

(RMS-3.6)

Storage Bin,

550 tons

n/a n/a

Discharge from Weighfeeder 

for Clinker (WF-13.1.1) to Belt 

Conveyor (BC-13.3)

Transfer Point, 143 tons 

per hour

Dust Collector

(DC-13.4)

DC-13.4

Finish Mill Gypsum Feed Silo 

(RMS-3.5)

Storage Bin,

450 tons

n/a n/a

Discharge from Weighfeeder 

for Gypsum (WF-13.1.2) to 

Small Belt Conveyor (BC-13.2)

Transfer Point, 10 tons per 

hour

Dust Collector

(DC-13.4)

DC-13.4

Finish Mill Limestone Feed 

Silo (RMS-3.2)

Storage Bin,

450 tons

n/a n/a
Permit No. 1001770 Page 47 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge from Weighfeeder 

for Limestone (WF-13.1.3) to 

Small Belt Conveyor (BC-13.2)

Transfer Point, 10 tons per 

hour

Dust Collector

(DC-13.4)

DC-13.4

Discharge from Small Belt 

Conveyor (BC-13.2) to Belt 

Conveyor (BC-13.3)

Transfer Point, 50 tons per 

hour

Dust Collector

(DC-13.4)

DC-13.4

Discharge from Belt Conveyor 

(BC-13.3) to Bucket Elevator 

(BE-13.5)

Transfer Point, 143 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Bucket 

Elevator (BE-13.5) to Belt 

Conveyor (BC-13.6)

Transfer Point, 143 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Belt Conveyor 

(BC-13.6) to Special Chute 

(RP-13.9.1)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Special Chute 

(RP-13.9.1) to Roller Press 

(RP-13.10)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Roller Press

(RP-13.10) 

Finish Mill, 517 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Roller Press 

(RP-13.10) to Special Chute 

(CH-13.10.1)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Special Chute 

(CH-13.10.1) to 

Disagglomerator (DIS-13.11)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from 

Disagglomerator (DIS-13.11) 

to Belt Conveyor (BC-13.12)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Belt Conveyor 

(BC-13.12) to Special Chute 

(CH-13.12.1)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Special Chute 

(CH-13.12.1) to Bucket 

Elevator (BE-13.13)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Bucket 

Elevator (BE-13.13) to Special 

Chute (CH-13.13.1)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Special Chute 

(CH-13.13.1) to HighEfficiency Separator (HES13.15)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

High-Efficiency Separator

(HES-13.15) 

Finish Mill, 578 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20
Permit No. 1001770 Page 48 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge from HighEfficiency Separator (HES13.15) to Special Chute (CH13.16)Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Special Chute 

(CH-13.16) to Airslides (AS13.17.1 through AS-13.17.4)

Transfer Point, 578 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from HighEfficiency Separator (HES13.15) to Screw Conveyors 

(SC-13.21 and SC-13.22)

Transfer Point, 17 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Screw 

Conveyor (SC-13.21) to ByPass Hopper (BPH-13.30)

Transfer Point, 17 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Screw 

Conveyors (SC-13.21 and SC13.22) to Belt Conveyor (BC13.31)

Transfer Point, 17 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Belt Conveyor 

(BC-13.31) to Transfer Chute 

(CH-13.34)

Transfer Point, 17 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Transfer Chute 

(CH-13.34) to Belt Conveyor 

(BC-13.6)

Transfer Point, 17 tons per 

hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Discharge from Airslides (AS13.17.1 through AS-13.17.4) to 

Ball Mill (BM-13.39)

Transfer Point, 240 tons 

per hour

Dust Collectors

(DC-13.19 and DC-13.20)

DC-13.19 and 

DC-13.20

Ball Mill

(BM-13.39)

Finish Mill, 100 tons per 

hour

Dust Collector

(DC-13.40)

DC-13.40

Discharge from Ball Mill (BM13.39) to Airslide (AS-13.42)Transfer Point, 100 tons 

per hour

Dust Collector

(DC-13.40)

DC-13.40

Discharge from Ball Mill Dust 

Collector (DC-13.40) to Screw 

Conveyor (SC-13.41)

Transfer Point, 5 tons per 

hour

Dust Collector

(DC-13.40)

DC-13.40

Discharge from Screw 

Conveyor (SC-13.41) to 

Airslide (AS-13.42)

Transfer Point, 5 tons per 

hour

Dust Collector

(DC-13.40)

DC-13.40

Discharge from Airslide (AS13.42) to Bucket Elevator (BE14.1)Transfer Point, 143 tons 

per hour

Dust Collector

(DC-13.40)

DC-13.40

Discharge from Bucket 

Elevator (BE-14.1) to Airslide 

(AS-14.2)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.10

Discharge from Airslide (AS14.2) to Airslides (AS-14.4.1 

through AS-14.4.4)

Transfer Point, 180 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.10
Permit No. 1001770 Page 49 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge from Airslides (AS14.4.1 through AS-14.4.4) to 

Cement Silo (SI-14.6)

Transfer Point, 240 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.10

Cement Silo (SI-14.6) Storage Bin,

10,000 tons 

n/a n/a

Discharge from Cement Silo 

(SI-14.6) to Airslide (AS14.13)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.21

Discharge from Airslide (AS14.13) to Bucket Elevator (BE14.14)Transfer Point, 400 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.21

Discharge from Bucket 

Elevator (BE-14.14) to Airslide 

(AS-14.15)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.21

Discharge from Airslide (AS14.15) to Cement Metallic Silo 

(CMS-14.17.1)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.21

Discharge from Airslide (AS14.15) to Cement Metallic Silo 

(CMS-14.17.2)

Transfer Point, 400 tons 

per hour

Dust Collector

(DC-14.10)

DC-14.21

Cement Metallic Silo (CMS14.17.1)Storage Bin, 125 m3n/a n/a

Cement Metallic Silo (CMS14.17.2)Storage Bin, 125 m3n/a n/a

Discharge from Cement 

Metallic Silo (CMS-14.17.1) to 

Double Mobile Articulated 

Screw Conveyor (ASC14.20.1)

Transfer Point, 330 tons 

per hour

Dust Collector

(DC-14.21)

DC-14.21

Discharge from Cement 

Metallic Silo (CMS-14.17.2) to 

Double Mobile Articulated 

Screw Conveyor (ASC14.20.2)

Transfer Point, 330 tons 

per hour

Dust Collector

(DC-14.21)

DC-14.21

Double Mobile Articulated 

Screw Conveyor (ASC14.20.1)

Bulk Loading, 330 tons 

per hour

Dust Collector

(DC-14.21)

DC-14.21

Double Mobile Articulated 

Screw Conveyor (ASC14.20.2)

Bulk Loading, 330 tons 

per hour

Dust Collector

(DC-14.21)

DC-14.21

Discharge from Cement 

Metallic Silo (CMS-14.17.1) to 

Pneumatic Conveying Pipe 

(PCP-14.27)

Transfer Point, 165 tons 

per hour

Dust Collector

(DC-14.29)

DC-14.29

Cement Metallic Silo for Train 

Bulk Loading (CMS-14.28)

Storage Bin, 450 m3n/a n/a
Permit No. 1001770 Page 50 of 99 April 12, 2006

Emission Unit/Affected Source 

Name

(Equipment ID Number)

Emission Unit/ Affected 

Source Description

Control Measure

(Control Device ID Number)

Emission Point 

ID Number

Discharge from Cement 

Metallic Silo (CMS-14.28) to 

Loading Head (LBR-14.32)

Transfer Point, 330 tons 

per hour

Dust Collector

(DC-14.29)

DC-14.29

Loading Head for Rail Cars 

(LBR-14.32)

Bulk Loading, 330 tons 

per hour

Dust Collector

(DC-14.29)

DC-14.29

B. Emission Standards

1. Operational Limitations

a. The Permittee shall not cause or allow the amount of material unloaded 

at the Receiving Hopper for Railroad Cars to exceed 750 tons in any 3-

hour period.

[A.A.C. R18-2-306(A)(2)] 

b. The Permittee shall not cause or allow the amount of material unloaded 

at the Receiving Hopper for Trucks to exceed 450 tons in any 3-hour 

period.

[A.A.C. R18-2-306(A)(2)] 

c. Except as provided in Condition II.B.1.e, the Permittee shall not cause or 

allow the amount of material unloaded at the Receiving Hopper for 

Railroad Cars to exceed 2,000 tons in any 24-hour period.

[A.A.C. R18-2-306(A)(2)] 

d. Except as provided in Condition II.B.1.e, the Permittee shall not cause or 

allow the amount of material unloaded at the Receiving Hopper for 

Trucks to exceed 600 tons in any 24-hour period.

[A.A.C. R18-2-306(A)(2)] 

e. Alternate Operating Scenario

(1) When operating under the Alternate Operating Scenario, the 

Permittee shall not cause or allow the amount of material 

unloaded at the Receiving Hopper for Railroad Cars to exceed 

3,000 tons in any 24-hour period.

[A.A.C. R18-2-306(A)(11)] 

(2) When operating under the Alternate Operating Scenario, the 

Permittee shall not cause or allow the amount of material 

unloaded at the Receiving Hopper for Trucks to exceed 900 tons 

in any 24-hour period.

[A.A.C. R18-2-306(A)(11)] 
Permit No. 1001770 Page 51 of 99 April 12, 2006

2. Particulate Matter Emission Standards

a. The Permittee shall not cause or allow to be emitted into the atmosphere 

from Dust Collectors DC-13.19, DC-13.20, or DC-13.40 any gases 

which exhibit opacity greater than 10 percent.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-1101(B)(49) {40 CFR § 63.1347}]

Material Permit Conditions are indicated with underline and italics.

b. The Permittee shall maintain and operate Dust Collectors DC-13.19, DC13.20, or DC-13.40 such that the alarm of the associated Bag Leak

Detection System, as required by Condition II.D.2.a(1), is not activated 

and alarm condition does not exist for more than 5 percent of the total 

operating time in a 6-month block period.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(9)}]

c. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any Storage Bin, Conveying System Transfer Point, Bulk Unloading 

System, or Bulk Loading System, listed in Condition II.A, any gases 

which exhibit opacity greater than 10 percent.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-1101(B)(49) {40 CFR § 63.1348}]

Material Permit Conditions are indicated with underline and italics.

d. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any Dust Collector listed in Condition II.A any gases which contain 

particulate matter (PM) in excess of 0.008 gr/dscf.

[A.A.C. R18-2-406(A)(4)}]

e. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any Dust Collector gases which contain particulate matter (PM) in 

excess of the following emission rates, based on a 3-hour average.

Emission Point ID Number PM Emission Limit (lbs/hr)

DC-1.11 0.305

DC-2.5 0.153

DC-2.9 0.411

DC-2.10 0.411

DC-4.18 0.120

DC-4.19 0.439

DC-4.20 0.257

DC-4.23 0.120

DC-4.25 0.120

DC-5.5 0.451

DC-5.22 0.253

DC-6.10 0.268

DC-7.16 0.167

DC-7.23 0.121
Permit No. 1001770 Page 52 of 99 April 12, 2006

Emission Point ID Number PM Emission Limit (lbs/hr)

DC-11.2 0.201

DC-11.6.1 0.129

DC-11.6.2 0.148

DC-11.11 0.487

DC-11.15 0.421

DC-12.7.2 0.018

DC-12.26 0.102

DC-13.4 0.136

DC-13.19 0.875

DC-13.20 0.875

DC-13.40 1.040

DC-14.10 0.142

DC-14.21 0.360

DC-14.29 0.236

[A.A.C. R18-2-406(A)(5)]

C. Air Pollution Control Requirements

1. At all times when any Finish Mills, Conveying System Transfer Points, or Bulk 

Loading Systems listed in Condition II.A are in operation, including periods of 

startup, shutdown, and malfunction, the Permittee shall, to the extent practicable,

install, maintain and operate the associated Dust Collector(s) in a manner 

consistent with good air pollution control practice for minimizing particulate 

matter emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.

2. At all times when the Receiving Hoppers for Trucks or Railroad Cars are in 

operation, including periods of startup, shutdown, and malfunction, the 

Permittee shall, to the extent practicable, install, maintain and operate the 

associated Water Dedusting System in a manner consistent with good air 

pollution control practice for minimizing particulate matter emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.

D. Monitoring, Recordkeeping, and Reporting Requirements

1. Monitoring and Recordkeeping for Operational Limitations 

a. The Permittee shall install, calibrate, maintain, and operate monitoring 

devices for measuring and recording the weight of material unloaded at 

the Receiving Hoppers for Trucks and Railroad Cars.

[A.A.C. R18-2-306(A)(3)(c) and R18-2-331(A)(3)(c)]

Material Permit Conditions are indicated with underline and italics.
Permit No. 1001770 Page 53 of 99 April 12, 2006

b. Each weighing device shall have an accuracy of ± 2% over its operating 

range.

[A.A.C. R18-2-306(A)(3)(c)]

c. The calibration of each weighing device must be verified at least once 

every three months.

[A.A.C. R18-2-306(A)(3)(c)]

d. The Permittee shall maintain hourly records of the weight of material 

unloaded at each Receiving Hopper.

[A.A.C. R18-2-306(A)(3)(c)]

e. Contemporaneously with making a change from the Primary Operating 

Scenario to the Alternate Operating Scenario or vice versa, the Permittee 

shall make a record of the scenario under which it is operating.

[A.A.C. R18-2-306(A)(11)]

2. Operations and Maintenance Plans

a. The Permittee shall prepare written operations and maintenance plans for 

each Finish Mill, Storage Bin, Conveying System Transfer Point, Bulk 

Unloading System, and Bulk Loading System listed in Condition II.A.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)}]

(1) Each plan required by Condition II.D.2.a shall be submitted to 

the Director for review and approval.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)}]

(2) Prior to startup of each Finish Mill, Storage Bin, Conveying 

System Transfer Point, Bulk Unloading System, and Bulk 

Loading System listed in Condition II.A, the Permittee shall 

obtain the Director’s written approval for the corresponding 

operations and maintenance plan and shall submit an application 

for revising the permit to include the monitoring procedures in 

the approved plan. These monitoring procedures shall be 

incorporated into the permit through a significant permit 

revision, which includes a 30-day public notice period and a 45-

day EPA review period per A.A.C. R18-2-320(D).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)}]

b. Each plan required by Condition II.D.2.a shall include procedures for 

proper operation and maintenance of the affected source and air pollution 

control devices in order to meet the emission limits of Conditions 

II.B.2.a and II.B.2.c.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(1)}]

c. For each Storage Bin, Conveying System Transfer Point, Bulk 

Unloading System, and Bulk Loading System listed in Condition II.A, 

the plan required by Condition II.D.2.a shall include procedures to be 

used to periodically monitor the affected source. Such procedures must 

include the provisions of Condition II.D.4.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)}]
Permit No. 1001770 Page 54 of 99 April 12, 2006

d. Failure to comply with any provision of an operations and maintenance 

plan approved by the Director in accordance with Condition II.D.2.a(2) 

shall be a violation.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(b)}]

3. Monitoring and Recordkeeping for Finish Mill Dust Collectors 

a. The Permittee shall install, calibrate, maintain, and operate Bag Leak 

Detection Systems for detecting leaks in Dust Collectors DC-13.19, DC13.20, and DC-13.40.

[A.A.C. R18-2-331(A)(3)(c) and R18-2-1101(B)(49) {40 CFR § 63.1350(m)}]

Material Permit Conditions are indicated with underline and italics.

b. Each Bag Leak Detection System required by Condition II.D.3.a shall 

meet the requirements of Conditions II.D.3.b(1) through II.D.3.b(11).

(1) Each Bag Leak Detection System must be certified by the 

manufacturer to be capable of detecting PM emissions at 

concentrations of 0.0044 grains per actual cubic foot or less. 

“Certify” shall mean that the instrument manufacturer has tested 

the instrument on gas streams having a range of particle size 

distributions and confirmed by means of valid filterable PM tests 

that the minimum detectable concentration limit is 0.0044 grains 

per actual cubic foot or less.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(1)}]

(2) The sensor on each Bag Leak Detection System must provide 

output of relative PM emissions.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(2)}]

(3) Each Bag Leak Detection System must have an alarm that will 

activate automatically when it detects a significant increase in 

relative PM emissions greater than a preset level.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(3)}]

(4) The presence of an alarm condition should be clearly apparent to 

facility operating personnel.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(4)}]

(5) For a positive-pressure fabric filter, each compartment or cell 

must have a bag leak detector. For a negative-pressure or 

induced-air fabric filter, the bag leak detector must be installed 

downstream of the fabric filter. If multiple bag leak detectors are 

required (for either type of fabric filter), detectors may share the 

system instrumentation and alarm.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(5)}]

(6) Each Bag Leak Detection System must be installed, operated, 

adjusted, and maintained so that it is based on the manufacturer’s 

written specifications and recommendations.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(6)}]
Permit No. 1001770 Page 55 of 99 April 12, 2006

(7) The baseline output of each Bag Leak Detection System must be 

established as follows:

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(7)}]

(a) Adjust the range and the averaging period of the 

device; and

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(7)(i)}]

(b) Establish the alarm set points and the alarm 

delay time.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(7)(ii)}]

(8) After initial adjustment, the range, averaging period, alarm set 

points, or alarm delay time may not be adjusted except as 

specified in the operations and maintenance plan required by 

Condition II.D.2.a. In no event may the range be increased by 

more than 100 percent or decreased by more than 50 percent 

over a 1 calendar year period unless a responsible official as 

defined in 40 CFR § 63.2 certifies in writing to the Director that 

the Dust Collector has been inspected and found to be in good 

operating condition.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(8)}]

(9) The Permittee shall continuously record the output from the Bag 

Leak Detection System during periods of normal operation. 

Normal operation does not include periods when the Bag Leak 

Detection System is being maintained or during startup, 

shutdown or malfunction.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(9)}]

(10) Except as provided in Condition II.D.3.b(11), each time the 

alarm activates, alarm time will be counted as the actual amount 

of time taken by the Permittee to initiate corrective actions.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(9)}]

(11) If inspection of the Dust Collector demonstrates that no 

corrective actions are necessary, no alarm time will be counted.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(m)(9)}]

c. Each 6-month block period for which the Bag Leak Detection System 

alarm time, as determined in accordance with Conditions II.D.3.b(9) 

through II.D.3.b(11), exceeds the limit established in Condition II.B.2.b

shall be considered a period of excess emissions.

[A.A.C. R18-2-306(A)(3)]

d. The Permittee shall report excess emissions and deviations in accordance 

with Sections XII.A and XII.B, respectively, in Attachment “A” of this 

permit.

[A.A.C. R18-2-306(A)(5)(b)]
Permit No. 1001770 Page 56 of 99 April 12, 2006

4. Periodic Visible Emissions Observations

For each Storage Bin, Conveying System Transfer Point, Bulk Unloading 

System, and Bulk Loading System listed in Condition II.A, the Permittee shall 

conduct periodic visible emissions observations in accordance with Conditions 

II.D.4.a through II.D.4.g. 

a. Except as provided in Condition II.D.4.e, 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. The test 

must be conducted while the affected source is in operation.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(i)}]

b. 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 visible 

emissions are observed during any semi-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.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(ii)}]

c. 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 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.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(iii)}]

d. 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.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(iv)}]

e. The requirement to conduct Method 22 visible emissions monitoring 

under this paragraph shall not apply to any totally enclosed conveying 

system transfer point, regardless of the location of the transfer point. 

“Totally enclosed conveying system transfer point” shall mean a 

conveying system transfer point that is enclosed on all sides, top, and 

bottom. The enclosures for these transfer points shall be operated and 

maintained as total enclosures on a continuing basis in accordance with 

the facility operations and maintenance plan.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(v)}]

f. If any partially enclosed or unenclosed conveying system transfer point 

is located in a building, the Permittee shall have the option to conduct a 

Method 22 visible emissions monitoring test according to the 

requirements of Conditions II.D.4.a through II.D.4.d for each such 
Permit No. 1001770 Page 57 of 99 April 12, 2006

conveying system transfer point located within the building, or for the 

building itself, according to Condition II.D.4.g.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(vi)}]

g. If visible emissions from a building are monitored pursuant to Condition 

II.D.4.f, the requirements of Conditions II.D.4.a through II.D.4.d apply

to the monitoring of the building, and the Permittee must also test visible 

emissions from each side, roof and vent of the building for at least 1 

minute. The test must be conducted under normal operating conditions.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1350(a)(4)(vii)}]

5. Recordkeeping, Reporting, and Notification Requirements for HAP Emission 

Standards

a. The Permittee shall maintain the following records:

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)}]

(1) All records as required by 40 CFR §§ 63.10(b)(2) and (b)(3).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)}]

(2) All documentation supporting initial notifications and 

notifications of compliance status under 40 CFR § 63.9.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)(1)}]

(3) All records of applicability determination, including supporting 

analyses.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)(2)}]

(4) If the Permittee has been granted a waiver under 40 CFR § 

63.8(f)(6), any information demonstrating whether the source is 

meeting the requirements for a waiver of recordkeeping or 

reporting requirements. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(b)(3)}]

b. The Permittee shall comply with the reporting requirements specified in 

40 CFR § 63.10 as follows:

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)}]

(1) As required by 40 CFR § 63.10(d)(2), the Permittee shall report 

the results of performance tests as part of the notification of 

compliance status. 

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(1)}]

(2) As required by 40 CFR § 63.10(d)(3), the Permittee shall report 

the opacity results from tests required by Conditions II.E.4.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(2)}]

(3) As required by 40 CFR § 63.10(d)(5), if actions taken by the

Permittee during a startup, shutdown, or malfunction (including 

actions taken to correct a malfunction) are consistent with the 

procedures specified in the Permittee’s startup, shutdown, and 
Permit No. 1001770 Page 58 of 99 April 12, 2006

malfunction plan specified in 40 CFR § 63.6(e)(3), the Permittee 

shall state such information in a semi-annual report. Reports 

shall only be required if a startup, shutdown, or malfunction 

occurred during the reporting period. The startup, shutdown, and 

malfunction report may be submitted simultaneously with the 

excess emissions and continuous monitoring system performance 

reports.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(4)}]

(4) Any time an action taken by the Permittee during a startup, 

shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, 

shutdown, and malfunction plan, the Permittee shall make an 

immediate report of the actions taken for that event within 2 

working days, by telephone call or facsimile (fax) transmission. 

The immediate report shall be followed by a letter, certified by 

the Permittee, explaining the circumstances of the event, the 

reasons for not following the startup, shutdown, and malfunction 

plan, and whether any excess emissions and/or parameter 

monitoring exceedances are believed to have occurred.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(5)}]

(5) As required by 40 CFR § 63.10(e)(2), the Permittee shall submit 

a written report of the results of the performance evaluation for 

the continuous monitoring system required by 40 CFR § 63.8(e). 

The Permittee shall submit the report simultaneously with the 

results of the performance test.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(6)}]

(6) As required by 40 CFR § 63.10(e)(3), the Permittee shall submit 

an excess emissions and continuous monitoring system 

performance report for any event when the data provided by the 

continuous monitoring system indicate the source is not in 

compliance with the applicable emission limitation or operating 

parameter limit. 

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(8)}]

(7) The Permittee shall submit a summary report semiannually, 

along with the compliance certification, which contains the 

information specified in 40 CFR § 63.10(e)(3)(vi). In addition, 

the summary report shall include all failures to comply with any 

provision of any operation and maintenance plan required by 

Condition II.D.2.a.

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(9)}]

(8) If the total continuous monitoring system downtime for any

continuous monitoring system for the reporting period is 10 

percent or greater of the total operating time for the reporting

period, the Permittee shall submit an excess emissions and 

continuous monitoring system performance report along with the 

summary report required by Condition II.D.5.b(7).

[R18-2-1101(B)(49) {40 CFR § 63.1354(b)(10)}]
Permit No. 1001770 Page 59 of 99 April 12, 2006

c. The Permittee shall comply with the notification requirements in 40 CFR 

§ 63.9 as follows:

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)}]

(1) Notification of performance tests, as required by 40 CFR §§ 63.7 

and 63.9(e). 

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(2)}]

(2) Notification of opacity and visible emission observations 

required by Condition II.E.4 in accordance with 40 CFR §§ 

63.6(h)(5) and 63.9(f).

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(3)}]

(3) Notification of compliance status, as required by 40 CFR § 

63.9(h).

[R18-2-1101(B)(49) {40 CFR § 63.1353(b)(5)}]

d. The Permittee shall maintain files of all information (including all reports 

and notifications) required in a form suitable and readily available for 

inspection and review as required by 40 CFR § 63.10(b)(1). The files 

shall be retained for at least five years following the date of each 

occurrence, measurement, maintenance, corrective action, report, or 

record. At a minimum, the most recent two years of data shall be 

retained on site. The remaining three years of data may be retained off 

site. The files may be maintained on microfilm, on a computer, on 

floppy disks, on magnetic tape, or on microfiche.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1355(a)}]

E. Testing Requirements 

1. The Permittee shall perform initial and periodic performance tests in accordance 

with Conditions II.E.2 through II.E.5. Initial performance tests shall be 

performed within 60 days after achieving the maximum production rate at which 

the affected source will be operated, but not later than 180 days after initial 

startup of such affected source.

[A.A.C. R18-2-406(A)(4) and R18-2-1101(B)(1) {40 CFR § 63.7(a)}]

2. For each performance test required pursuant to Condition II.E.1, the Permittee 

shall submit a test plan to the Director in accordance with Condition XVIII.D of 

Attachment “A.”

[A.A.C. R18-2-312(B) and R18-2-1101(B)(49) {40 CFR § 63.1349(a)}]

3. Performance test results shall be documented in complete test reports that contain 

the information required by Conditions II.E.3.a through II.E.3.k.

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)}]

a. A brief description of the process and the air pollution control system;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(1)}]

b. Sampling location description(s);

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(2)}]
Permit No. 1001770 Page 60 of 99 April 12, 2006

c. A description of sampling and analytical procedures and any

modifications to standard procedures;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(3)}]

d. Test results;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(4)}]

e. Quality assurance procedures and results; 

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(5)}]

f. Records of operating conditions during the test, preparation of standards, 

and calibration procedures;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(6)}]

g. Raw data sheets for field sampling and field and laboratory analyses;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(7)}]

h. Documentation of calculations;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(8)}]

i. All data recorded and used to establish parameters for compliance 

monitoring;

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(9)}]

j. Any other information required by the test method; and 

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)(10)}]

k. All other relevant information.

[A.A.C. R18-2-406(A)(4), R18-2-1101(B)(49) {40 CFR § 63.1349(a)}]

4. Test Methods and Procedures for Opacity of Visible Emissions

a. The Permittee shall demonstrate initial compliance with Conditions 

II.B.2.a and II.B.2.c by conducting tests in accordance with Method 9 of 

Appendix A to 40 CFR Part 60. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(2)}]

b. Each performance test required by Condition II.E.4.a shall be conducted 

under the conditions that exist when the affected source is operating at 

the representative performance conditions in accordance with 40 CFR § 

63.7(e).

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(2)}]

c. The maximum 6-minute average opacity exhibited during the test period 

shall be used to determine whether the affected source is in initial 

compliance with the opacity standard. 

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(2)}]

d. The duration of the Method 9 performance test shall be 3 hours (thirty 6-

minute averages), except that the duration of the Method 9 performance 
Permit No. 1001770 Page 61 of 99 April 12, 2006

test may be reduced to 1 hour if Conditions II.E.4.d(1) and II.E.4.d(2) are 

met:

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(2)}]

(1) There are no individual readings greater than 10 percent opacity;

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(2)(i)}]

(2) There are no more than three readings of 10 percent for the first 

1-hour period.

[A.A.C. R18-2-1101(B)(49) {40 CFR § 63.1349(b)(2)(ii)}]

5. Test Methods and Procedures for Particulate Matter

a. The Permittee shall demonstrate initial compliance with Conditions 

II.B.2.d and II.B.2.e by conducting performance tests as follows. 

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(1) Performance tests shall be conducted using Method 5 of 

Appendix A to 40 CFR Part 60. 

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(2) Each performance test shall consist of three separate runs.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(3) Each test run shall be conducted for at least one hour, and the 

minimum sample volume shall be 30 dscf. 

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

(4) The average of the three runs shall be used to determine 

compliance.

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

b. The performance tests required by Condition II.E.5.a shall be repeated 

once at least 6 months, but not more than 18 months, prior to the date of 

permit expiration. 

[A.A.C. R-18-406(A)(4) and R-18-406(A)(5)]

F. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following 

applicable requirement(s) in effect on the date of permit issuance: 40 CFR § 63.1347, 40 

CFR § 63.1348, 40 CFR § 63.1349(b)(2), 40 CFR § 63.1350(b), 40 CFR § 63.1353(a), 40 

CFR § 63.1353(b), 40 CFR § 63.1354(a), 40 CFR § 63.1354(b), 40 CFR § 63.1355(a), 

and 40 CFR § 63.1355(b), and 40 CFR § 63.1350(e).
Permit No. 1001770 Page 62 of 99 April 12, 2006

III. LIMESTONE PROCESSING PLANT

A. List of Emission Units

Emission Unit/Affected 

Source Name

(Equipment ID Number)

Emission Unit/ 

Affected Source 

Description

Control Measure

(Control Device ID 

Number)

Emission 

Point ID 

Number

Impact Primary Crusher

(IPC-1.3)

Limestone Crusher, 

495 tons per hour

Dust Collector (DC-1.6) DC-1.6

First Overland Belt 

Conveyor

(OC-1.5)

Belt Conveyor, 500 

tons per hour

Dust Collector (DC-1.8) DC-1.8

Second Overland Belt 

Conveyor

(OC-1.7)

Belt Conveyor, 500 

tons per hour

Dust Collector (DC1.10)DC-1.10

Third Overland Belt 

Conveyor

(OC-1.9)

Belt Conveyor, 500 

tons per hour

Dust Collector (DC1.11)DC-1.11

Belt Conveyor with 

Tripper

(BC-2.1)

Belt Conveyor, 500 

tons per hour

Dust Collector (DC1.11)DC-1.11

Limestone Covered 

Stockpile Building (CS2.2)

Storage Building,

51,000 tons

n/a n/a

B. Emission Limits/Standards

1. Operating Limitation

The Permittee shall not cause or allow the Impact Primary Crusher or any belt 

conveyor listed in Condition III.A to operate for more than 3,120 hours in any 

consecutive 365-day period.

[A.A.C. R18-2-306(A)(2)]

2. Particulate Matter Emission Standards

a. Except as provided in Condition III.B.2.d, the Permittee shall not cause 

or allow to be emitted into the atmosphere from any transfer point on a 

belt conveyor any stack emissions which contain particulate matter (PM) 

in excess of 0.008 gr/dscf, based on a 3-hour average.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.672(a)(1)}]

b. Except as provided in Condition III.B.2.d, the Permittee shall not cause 

or allow to be emitted into the atmosphere from any transfer point on a

belt conveyor any visible stack emissions which exhibit opacity greater 

than 7 percent, based on a 6-minute average.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-901(66) {40 CFR § 60.672(a)(2)}]
Permit No. 1001770 Page 63 of 99 April 12, 2006

c. Except as provided in Condition III.B.2.d, the Permittee shall not cause 

or allow to be emitted into the atmosphere from any transfer point on a 

belt conveyor any fugitive emissions which exhibit opacity greater than 

10 percent, based on a 6-minute average.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-901(66) {40 CFR § 60.672(b)}]

d. Conditions III.B.2.a through III.B.2.c shall not apply to any transfer point 

that is located within the Limestone Covered Stockpile Building.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.672(e)}]

e. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Impact Primary Crusher any stack emissions which contain 

particulate matter (PM) in excess of 0.008 grains per dry standard cubic 

feet, based on a 3-hour average.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.672(a)(1)}]

f. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Impact Primary Crusher any visible stack emissions which 

exhibit opacity greater than 7 percent, based on a 6-minute average.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-901(66) {40 CFR § 60.672(a)(2)}]

Material Permit Conditions are indicated with underline and italics.

g. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Impact Primary Crusher any visible fugitive emissions which 

exhibit opacity greater than 10 percent, based on a 6-minute average.

[A.A.C. R18-2-331(A)(3)(f) and R18-2-901(66) {40 CFR § 60.672(b)}]

Material Permit Conditions are indicated with underline and italics.

h. The Permittee shall not cause or allow to be emitted into the atmosphere 

from the Limestone Covered Stockpile Building any visible fugitive 

emissions.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.672(e)(1)}]

i. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any Dust Collector gases which contain particulate matter (PM) in 

excess of the following emission rates, based on a 3-hour average.

Emission Point ID Number PM Emission Limit (lbs/hr)

DC-1.6 0.810

DC-1.8 0.153

DC-1.10 0.153

DC-1.11 0.305

[A.A.C. R18-2-406(A)(5)]
Permit No. 1001770 Page 64 of 99 April 12, 2006

3. Alternate Operating Scenario

During any calendar day in which the facility operates under the Alternate 

Operating Scenario, as described in Condition II.B.1.e herein, the following

emissions units shall not be operated:

a. Impact Primary Crusher (IPC-1.3);

b. First Overland Belt Conveyor (OC-1.5);

c. Second Overland Belt Conveyor (OC-1.7); and 

d. Third Overland Belt Conveyor (OC-1.9).

[A.A.C. R18-2-306(A)(11)] 

C. Air Pollution Control Requirements

At all times when the Impact Primary Crusher or any Belt Conveyors listed in Condition 

III.A are in operation, including periods of startup, shutdown, and malfunction, the 

Permittee shall, to the extent practicable, install, maintain and operate the associated 

Dust Collector(s) in a manner consistent with good air pollution control practice for 

minimizing particulate matter emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.

D. Monitoring, Recordkeeping, and Reporting Requirements

1. Monitoring and Recordkeeping for Operational Limitation 

The Permittee shall maintain daily records of the operating time for the Impact 

Primary Crusher and for each belt conveyor listed in Condition III.A.

[A.A.C. R18-2-306(A)(3)(c)]

2. Monitoring and Recordkeeping for Dust Collectors:

a. The Permittee shall install, calibrate, maintain, and operate, according to 

the manufacturer’s specifications, devices for monitoring and recording 

the pressure drop across each dust collector listed in Condition III.A. 

[A.A.C. R18-2-331(A)(3)(c) and R18-2-406(A)(4)]

b. The Permittee shall perform monthly inspections of each dust collector 

listed in Condition III.A, and the associated pressure drop continuous 

parameter monitoring systems, in accordance with the manufacturers’ 

recommended procedures. The Permittee shall take corrective action 

following the discovery of any abnormal operation or required 

maintenance of any dust collector pressure drop continuous parameter 

monitoring system as expeditiously as practicable in accordance with 

good air pollution control practices for minimizing emissions, but no 

later than within 24 hours following detection.

[A.A.C. R18-2-406(A)(4)]
Permit No. 1001770 Page 65 of 99 April 12, 2006

c. If the pressure drop across any dust collector is outside the range ± 20 

percent from the average pressure drop measured during the most recent 

performance test for that dust collector, the Permittee shall initiate 

investigation of the dust collector within 24 hours of the occurrence, to 

identify any need for corrective action. If corrective action is required, 

the Permittee shall implement such corrective action as soon as 

practicable in order to avert or minimize possible exceedances of the 

emission standards in Conditions III.B.2.a, III.B.2.b, III.B.2.e, III.B.2.f, 

and III.B.2.i. If the pressure drop remains outside of the range for 72 

consecutive hours after the first occurrence, the Permittee shall submit a 

compliance schedule to the Director in accordance with Condition XII.D 

of Attachment “A.”

[A.A.C. R18-2-406(A)(4)]

3. Reporting of Performance Test Results

The Permittee shall submit written reports of the results of all performance tests 

required by Conditions III.E.1 and III.E.2. 

[A.A.C. 406(A)(4) and R18-2-901(66) {40 CFR § 60.676(f)}]

4. Notifications Required by New Source Performance Standards

a. The requirement under 40 CFR § 60.7(a)(2) for notification of the 

anticipated date of initial startup of the affected facilities listed in 

Condition III.A.

[A.A.C. R18-2-901(66) {40 CFR § 60.676(h)}]

b. A notification of the actual date of initial startup of each affected facility

listed in Condition III.A shall be submitted to the Director.

[A.A.C. R18-2-901(66) {40 CFR § 60.676(i)}]

c. If, after 30 days notice for an initially scheduled performance test, there 

is a delay (due to operational problems, etc.) in conducting any 

performance test required by Conditions III.E.1 and III.E.2, the Permittee 

shall submit a notice to the Director at least 7 days prior to any 

rescheduled performance test.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(g)}]

E. Testing Requirements

1. The Permittee shall perform initial and periodic performance tests in accordance 

with Condition III.E.2. Initial performance tests shall be performed within 60 

days after achieving the maximum production rate at which the affected source 

will be operated, but not later than 180 days after initial startup of such affected 

source.

[A.A.C. R18-2-406(A)(4) and R18-2-901(1) {40 CFR 60.8(a)}]

2. Test Methods and Procedures for Particulate Matter

a. The Permittee shall determine compliance with Conditions III.B.2.a, 

III.B.2.e, and III.B.2.i as follows:
Permit No. 1001770 Page 66 of 99 April 12, 2006

(1) EPA Reference Method 5 or EPA Reference Method 17 shall be 

used to determine the particulate matter concentration. The 

sample volume shall be at least 60 dscf.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.675(b)(1)}]

(2) For Method 5, if the gas stream being sampled is at ambient 

temperature, the sampling probe and filter may be operated 

without heaters. If the gas stream is above ambient temperature, 

the sampling probe and filter may be operated at a temperature 

high enough, but no higher than 250 °F, to prevent water 

condensation on the filter.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.675(b)(1)}]

b. The Permittee shall determine compliance with Conditions III.B.2.b and 

III.B.2.f using EPA Reference Method 9 and the procedures in 40 CFR § 

60.11.

[A.A.C. R18-2-406(A)(4) and R18-2-901(66) {40 CFR § 60.675(b)(2)}]

c. The Permittee shall determine compliance with Conditions III.B.2.c and 

III.B.2.g as follows:

(1) Except as provided in Conditions III.E.2.c(4) and III.E.2.c(5), 

the Permittee shall use EPA Reference Method 9 and the 

procedures in 40 CFR § 60.11.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(c)(1)}]

(2) The minimum distance between the observer and the emission 

source during Method 9 tests shall be 4.57 meters (15 feet).

[A.A.C. R18-2-901(66) {40 CFR § 60.675(c)(1)(i)}]

(3) The observer shall, when possible, select a position that 

minimizes interference from other fugitive emission sources 

(e.g., road dust). The required observer position relative to the 

sun (Method 9, Section 2.1) must be followed.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(c)(1)(ii)}]

(4) The duration of the Method 9 observations may be reduced from 

3 hours (thirty 6-minute averages) to 1 hour (ten 6-minute 

averages) only if the following conditions apply:

[A.A.C. R18-2-901(66) {40 CFR § 60.675(c)(3)}]

(a) There are no individual readings greater than 10 percent 

opacity; and

[A.A.C. R18-2-901(66) {40 CFR § 60.675(c)(3)(i)}]

(b) There are no more than 3 readings of 10 percent for the 

1-hour period.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(c)(3)(ii)}]

(5) If emissions from two or more facilities continuously interfere so 

that the opacity of fugitive emissions from an individual affected 
Permit No. 1001770 Page 67 of 99 April 12, 2006

facility cannot be read, either of the following procedures may 

be used:

[A.A.C. R18-2-901(66) {40 CFR § 60.675(e)(1)}]

(a) Use for the combined emission stream the highest 

fugitive opacity standard applicable to any of the 

individual affected facilities contributing to the 

emissions stream.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(e)(1)(i)}]

(b) Separate the emissions so that the opacity of emissions 

from each affected facility can be read.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(e)(1)(ii)}]

d. The Permittee shall determine initial compliance with Condition III.B.2.h 

as follows.

(1) The Permittee shall use EPA Reference Method 22 to determine 

fugitive emissions. 

[A.A.C. R18-2-901(66) {40 CFR § 60.675(d)}]

(2) The performance test shall be conducted while all conveyor belts 

inside the Limestone Covered Stockpile Building are operating.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(d)}]

(3) The performance test shall be at least 75 minutes in duration, 

with each side of the building and the roof being observed for at 

least 15 minutes.

[A.A.C. R18-2-901(66) {40 CFR § 60.675(d)}]

e. The performance tests required by Conditions III.E.2.a through III.E.2.d 

shall be repeated once at least 6 months, but not more than 18 months, 

prior to the date of permit expiration. 

[A.A.C. R-18-406(A)(4)]

F. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following 

applicable requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-901(66) 

{40 CFR § 60.672, 40 CFR § 60.675(b)(1), 40 CFR § 60.675(c), 40 CFR § 60.675(d), 40 

CFR § 60.675(e), 40 CFR § 60.675(g), 40 CFR § 60.675(h), 40 CFR § 60.676(a), 40 

CFR § 60.676(f), and 40 CFR § 60.676(g).
Permit No. 1001770 Page 68 of 99 April 12, 2006

IV. OTHER MATERIAL HANDLING ACTIVITIES

A. List of Emission Units

Emission Unit/Affected 

Source Name

(Equipment ID Number)

Emission Unit/ 

Affected Source 

Description

Control Measure

(Control Device ID 

Number)

Emission 

Point ID 

Number

First Belt Conveyor for 

Transporting Coal to Mill 

(BC-12.3)

Belt Conveyor, 20 

tons per hour

Dust Collector (DC12.7.1)DC-12.7.1

Second Belt Conveyor for 

Transporting Coal to Mill 

(BC-12.4)

Belt Conveyor, 20 

tons per hour

Dust Collector (DC12.7.1)DC-12.7.1

High-Calcium Limestone 

Storage Pile (FE1)

Storage Pile, 495 tons 

per hour

Permanent Total 

Enclosure

(CS-2.2)

FE1

Low-Calcium Limestone 

Storage Pile (FE2)

Storage Pile, 495 tons 

per hour

Permanent Total 

Enclosure

(CS-2.2)

FE2

Coal Storage Pile (FE3) Storage Pile, 400 tons 

per hour

Permanent Total 

Enclosure

(CS-4.10)

FE3

Iron Ore Storage Pile 

(FE4)

Storage Pile, 400 tons 

per hour

Permanent Total 

Enclosure

(CS-4.10)

FE4

Aluminum Source 

Storage Pile (FE5)

Storage Pile, 400 tons 

per hour

Permanent Total 

Enclosure

(CS-4.10)

FE5

Front End Loader Dump -

Coal Reclaim (FE6)

Reclaim Operation, 

250 tons per hour

Permanent Total 

Enclosure

(CS-4.10)

FE6

Front End Loader Dump -

Iron Ore Reclaim (FE7)

Reclaim Operation, 

250 tons per hour

Permanent Total 

Enclosure

(CS-4.10)

FE7

Front End Loader Dump -

Aluminum Reclaim 

(FE8)

Reclaim Operation, 

250 tons per hour

Permanent Total 

Enclosure

(CS-4.10)

FE8

End Dump Transport 

Truck to Gypsum Storage 

Pile (FE9)

Storage Pile, 100 tons 

per hour

n/a FE9

Front End Loader Dump -

Gypsum Reclaim (FE10)

Reclaim Operation, 

250 tons per hour

n/a FE10
Permit No. 1001770 Page 69 of 99 April 12, 2006

B. Emission Limits/Standards

1. Operating Limitations

a. The Permittee shall not cause or allow the amount of material transferred 

to the Gypsum Storage Pile to exceed any of the following rates:

(1) 300 tons in any 3-hour period;

(2) 400 tons in any 24-hour period; nor

(3) 124,800 tons in any 365-day period.

[A.A.C. R18-2-306(A)(2)] 

b. The Permittee shall not cause or allow the amount of material reclaimed 

from the Gypsum Storage Pile to exceed any of the following rates:

(1) 750 tons in any 3-hour period;

(2) 1,000 tons in any 24-hour period; nor

(3) 312,000 tons in any 365-day period.

[A.A.C. R18-2-306(A)(2)] 

2. Particulate Matter Emission Standards

a. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any transfer point on any belt conveyor listed in Section IV.A any 

gases which contain particulate matter (PM) in excess of 0.008 grains per 

dry standard cubic feet, based on a 3-hour average.

[A.A.C. R18-2-406(A)(4)]

b. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any transfer point on any belt conveyor listed in Section IV.A any 

gases which contain particulate matter (PM) in excess of 0.104 lbs per 

hour, based on a 3-hour average.

[A.A.C. R18-2-406(A)(5)}]

c. The Permittee shall not cause or allow to be emitted into the atmosphere 

from any enclosed storage pile or reclaim operation listed in Condition 

IV.A any visible fugitive emissions.

[A.A.C. R18-2-406(A)(4)]

C. Air Pollution Control Requirements

At all times when any belt conveyor listed in Section IV.A is in operation, including 

periods of startup, shutdown, and malfunction, the Permittee shall, to the extent 

practicable, install, maintain and operate the associated Dust Collector(s) in a manner 

consistent with good air pollution control practice for minimizing particulate matter 

emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.
Permit No. 1001770 Page 70 of 99 April 12, 2006

D. Monitoring, Recordkeeping, and Reporting Requirements

1. Monitoring and Recordkeeping for Operational Limitations

The Permittee shall maintain hourly and daily records of the amount of material 

transferred to and reclaimed from the Gypsum Storage Pile.

[A.A.C. R18-2-306(A)(3)(c)]

2. Monitoring and Recordkeeping for Particulate Matter Emission Standards

a. The Permittee shall install, calibrate, maintain, and operate, according 

to the manufacturer’s specifications, a device for monitoring and 

recording the pressure drop across Dust Collector DC-12.7.1.

[A.A.C. R18-2-331(A)(3)(c) and R18-2-406(A)(4)]

b. The Permittee shall perform monthly inspections of Dust Collector DC12.7.1, and the associated pressure drop continuous parameter 

monitoring system, in accordance with the manufacturers’ recommended 

procedures. The Permittee shall take corrective action following the 

discovery of any abnormal operation or required maintenance of the dust 

collector pressure drop continuous parameter monitoring system as 

expeditiously as practicable in accordance with good air pollution control 

practices for minimizing emissions, but no later than within 24 hours 

following detection.

[A.A.C. R18-2-406(A)(4)]

c. If the pressure drop across Dust Collector DC-12.7.1 is outside the range 

± 20 percent from the average pressure drop measured during the most 

recent performance test, the Permittee shall initiate investigation of the 

dust collector within 24 hours of the occurrence, to identify any need for 

corrective action. If corrective action is required, the Permittee shall 

implement such corrective action as soon as practicable in order to avert 

or minimize possible exceedances of the emission standards in 

Conditions IV.B.2.a and IV.B.2.b. If the pressure drop remains outside 

of the range for 72 consecutive hours after the first occurrence, the 

Permittee shall submit a compliance schedule to the Director in 

accordance with Condition XII.D of Attachment “A.”

[A.A.C. R18-2-406(A)(4)]

d. Periodic Visible Emissions Observations

For each building or enclosure listed in Condition IV.A, the Permittee 

shall conduct periodic visible emissions observations in accordance with 

Conditions IV.D.2.d(1) through IV.D.2.d(7). 

(1) Except as provided in Condition IV.D.2.d(5), 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. The test must be conducted while the affected source is 

in operation.

[A.A.C. R18-2-406(A)(4)]
Permit No. 1001770 Page 71 of 99 April 12, 2006

(2) 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 visible emissions are observed during any 

semi-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.

[A.A.C. R18-2-406(A)(4)]

(3) 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 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.

[A.A.C. R18-2-406(A)(4)]

(4) 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.

[A.A.C. R18-2-406(A)(4)]

(5) The requirement to conduct Method 22 visible emissions 

monitoring under this paragraph shall not apply to any totally 

enclosed conveying system transfer point, regardless of the 

location of the transfer point. “Totally enclosed conveying 

system transfer point” shall mean a conveying system transfer 

point that is enclosed on all sides, top, and bottom. The 

enclosures for these transfer points shall be operated and 

maintained as total enclosures on a continuing basis in 

accordance with the facility operations and maintenance plan.

[A.A.C. R18-2-406(A)(4)]

(6) If any partially enclosed or unenclosed conveying system 

transfer point is located in a building, the Permittee shall have 

the option to conduct a Method 22 visible emissions monitoring

test according to the requirements of Conditions IV.D.2.d(1)

through IV.D.2.d(4) for each such conveying system transfer 

point located within the building, or for the building itself, 

according to Condition IV.D.2.d(7).

[A.A.C. R18-2-406(A)(4)]

(7) If visible emissions from a building are monitored pursuant to 

Condition IV.D.2.d(6), the requirements of Conditions 

IV.D.2.d(1) through IV.D.2.d(4) apply to the monitoring of the 

building, and the Permittee must also test visible emissions from 
Permit No. 1001770 Page 72 of 99 April 12, 2006

each side, roof and vent of the building for at least 1 minute. 

The test must be conducted under normal operating conditions.

[A.A.C. R18-2-406(A)(4)]

E. Testing Requirements

1. The Permittee shall perform initial and periodic performance tests in accordance 

with Condition IV.E.2. Initial performance tests shall be performed within 60 

days after achieving the maximum production rate at which the Belt Conveyor to 

Coal Grinding Department will be operated, but not later than 180 days after 

initial startup of such affected source.

[A.A.C. R18-2-406(A)(4)]

2. Test Methods and Procedures for Particulate Matter

a. The Permittee shall determine initial compliance with Conditions 

IV.B.2.a and IV.B.2.b as follows:

(1) Except as provided in Condition IV.E.2.a(2), EPA Reference 

Method 5 shall be used to determine the particulate matter 

concentration. The sample volume shall be at least 60 dscf.

[A.A.C. R18-2-406(A)(4)]

(2) If the gas stream being sampled is at ambient temperature, the 

sampling probe and filter may be operated without heaters. If 

the gas stream is above ambient temperature, the sampling probe 

and filter may be operated at a temperature high enough, but no 

higher than 250 °F, to prevent water condensation on the filter.

[A.A.C. R18-2-406(A)(4)]

b. The performance test required by Condition IV.E.2.a shall be repeated 

once at least 6 months, but not more than 18 months, prior to the date of 

permit expiration. 

[A.A.C. R-18-406(A)(4)]

F. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following 

applicable requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-

406(A)(4)
Permit No. 1001770 Page 73 of 99 April 12, 2006

V. EMERGENCY GENERATOR

A. List of Emission Units

Emission Unit Name

(Equipment ID Number)

Emission Unit Description Control Measure

(Control Device ID 

Number)

Emission Point 

ID Number

Emergency Generator

(DEG-9.11)

Reciprocating internal

combustion engine, diesel

fuel-fired, driving

emergency electrical

generator, 210 kW output

Not applicable DEG-9.11

B. Emission Limits/Standards

1. The Permittee shall not cause or allow to be combusted in the Emergency 

Generator any fuel other than No. 2 diesel fuel.

[A.A.C. R18-2-306(A)(2)]

2. The Permittee shall not cause or allow the operation of the Emergency Generator 

to exceed the limits listed in Conditions V.B.2.a and V.B.2.b.

[A.A.C. R18-2-306(A)(2)]

a. The Permittee shall not cause or allow the fuel usage in the Emergency 

Generator to exceed 4,533 gallons per year. Compliance with this fuel 

usage limit shall be determined on a monthly rolling 12-month sum basis 

and shall exclude fuel burned during periods of emergency situations.

[A.A.C. R18-2-306(A)(2)]

b. The Permittee shall not cause or allow the Emergency Generator to 

operate in excess of 50 hours per year. The following shall be excluded 

from consideration in determining compliance with this limitation:

(1) Operation for the purpose of maintenance checks and readiness

testing, provided that the tests are recommended by the

manufacturer, the vendor, or the insurance company associated

with the engine.

(2) Operation in emergency situations.

[A.A.C. R18-2-306.01(A)]

3. The Permittee shall design, install, maintain, and operate the Emergency 

Generator internal combustion engine in such a manner as to ensure the 

following:

[A.A.C. R-18-406(A)(4)]

a. The internal combustion engine shall be certified by the manufacturer to 

be compliant with the following non-road engine emission standards, for 

engines with rated power not less than 130 kilowatts and nor more than 

225 kilowatts, as codified at 40 CFR § 89.112:
Permit No. 1001770 Page 74 of 99 April 12, 2006

(1) For NOX plus nonmethane hydrocarbons, the “Tier 3” emission

standard of 4.0 grams per kilowatt-hour.

(2) For CO, the “Tier 3” emission standard of 3.5 grams per

kilowatt-hour.

(3) For PM, the “Tier 2” emission standard of 0.20 grams per

kilowatt-hour.

[A.A.C. R-18-406(A)(4)]

b. The internal combustion engine shall be installed, maintained, and 

operated in accordance with manufacturer’s instructions and

recommendations.

[A.A.C. R-18-406(A)(4)]

4. The Permittee shall not cause or allow to be emitted to the atmosphere from the 

Emergency Generator smoke for any period greater than 10 consecutive seconds 

which exceeds 40 percent opacity. Visible emissions when starting cold 

equipment shall be exempt from this requirement for the first 10 minutes.

[A.A.C. R18-2-719(E)]

5. Except as provided by Conditions V.B.5.a and V.B.5.b, fuel shall not be

combusted in the Emergency Generator except during periods when a valid 

visible emissions observation can be conducted in accordance with EPA 

Reference Method 9.

a. Condition V.B.5 shall not apply to periods of emergency usage.

b. Operation of an internal combustion engine may occur during periods 

when a valid visible emissions observation in accordance with EPA 

Reference Method 9 is not possible, provided that the requirements of 

Conditions V.C.1.a and V.C.1.b are met for that calendar day.

[A.A.C. R18-2-306(A)(3)]

C. Monitoring, Recordkeeping, and Reporting Requirements

1. The Permittee shall demonstrate compliance with the opacity limitation in 

Condition V.B.4 as follows:

a. A certified EPA Reference Method 9 observer shall conduct visible

emissions observations on the Emergency Generator. All visible 

emissions observations shall be conducted in accordance with EPA 

Reference Method 9.

b. Except as provided by Conditions V.C.1.c and V.C.1.d, visible emissions 

observations required by Condition V.C.1.a shall be conducted for the 

Emergency Generator for at least one six-minute period each calendar 

day.
Permit No. 1001770 Page 75 of 99 April 12, 2006

c. Visible emissions observations shall not be required for the Emergency 

Generator for any calendar day on which no fuel is combusted in the 

Emergency Generator.

d. Visible emissions observations shall not be required for the Emergency 

Generator for any calendar day on which the only fuel combustion in the 

Emergency Generator occurs during emergency operation.

[A.A.C. R18-2-306(A)(3)]

2. The Permittee shall maintain on-site, and readily available for inspection, a 

record of each visible emissions observation conducted as required by Conditions

V.C.1.a and V.C.1.b. Each visible emissions observation record shall include the 

following:

a. The emissions unit for which the visible emissions observation was 

performed;

b. Location, date, and time of the visible emissions observation;

c. The results of the visible emissions observation;

d. The operating conditions existing at the time of the visible emissions

observation; and

e. The name of the observer.

[A.A.C. R18-2-306(A)(4)]

3. The Permittee shall maintain readily available records of the following:

a. Records of the type and quantity of fuel combusted in the Emergency 

Generator.

(1) Records required by Condition V.C.3.a shall be created and

maintained for each calendar day on which fuel is combusted in 

the Emergency Generator.

(2) Records required by Condition V.C.3.a shall indicate the sulfur 

content of the fuel combusted and the method of determination.

(3) At the end of each calendar month, the Permittee shall calculate 

and record the rolling 12-month fuel usage for the Emergency 

Generator. This value shall be calculated as the sum of the 

monthly fuel usage for the most recent month and the 11 

previous months, and shall be recorded within three calendar 

days after the end of each calendar month.

b. Records of the manufacturer’s certification of conformity, demonstrating

compliance with Condition V.B.3.a or V.B.3.b, as applicable. These 

records shall be maintained for the life of the Emergency Generator.
Permit No. 1001770 Page 76 of 99 April 12, 2006

c. Records of the manufacturer’s instructions and recommendations relating

to operation and maintenance. These records shall be maintained for the

life of the Emergency Generator.

d. Records of all maintenance performed on the internal combustion engine. 

These records shall be created and maintained for each calendar day on

which maintenance is performed on the Emergency Generator.

[A.A.C. R18-2-306(A)(3)]

4. The Permittee shall submit the initial notification in 40 CFR §§ 63.9 (b) by the 

date specified. The notification should include the following:

a. The information in 40 CFR §§ 63.9(b)(2)(i) through (v).

b. A statement that the internal combustion engine has no additional

requirements.

c. An explanation of the basis of the exclusion (i.e., that it operates 

exclusively as an emergency, stationary, reciprocating internal 

combustion engine).

[40 CFR 63.6590(b), 40 CFR 63.6645(d)]

D. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following 

applicable requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-

406(A)(4), R18-2-719(E). 

[A.A.C. R18-2-325]
Permit No. 1001770 Page 77 of 99 April 12, 2006

VI. QUARRY OPERATIONS AND VEHICLE TRAFFIC

A. List of Emission Units

Emission Unit/Affected 

Source Name

(Equipment ID Number)

Emission Unit/ 

Affected Source 

Description

Control Measure

(Control Device ID 

Number)

Emission 

Point ID 

Number

Wet Drilling (DR-1) Drilling of limestone n/a DR-1

Limestone Blasting (BL-1) Blasting with 

Ammonium 

Nitrate/Fuel Oil 

mixture

n/a BL-1

Truck Loading with 

Payloader (QE-1)

495 tons per hour n/a QE-1

Truck Unloading (QE-2) 

into Primary Crusher 

Hopper 

495 tons per hour Water Dedusting System 

(WD-1.4)

QE-2

Unpaved roads Used by Payloader, 

haul trucks, and water 

truck

Water application n/a

Paved roads Used by plant

maintenance trucks, 

gypsum trucks, and 

customer cement 

trucks

Water application and 

vacuuming

n/a

B. Emission Limits/Standards

1. Operational Limitations

a. The Permittee shall not cause or allow blasting in the quarry to exceed 1 

blast per day nor 48 blasts per year.

[A.A.C. R18-2-306(A)(2)] 

b. The Permittee shall not cause or allow the use of any explosive other 

than Ammonium Nitrate/Fuel Oil mixture in the quarry.

[A.A.C. R18-2-306(A)(2)] 

c. The Permittee shall not cause or allow explosive usage in the quarry to 

exceed 5.26 tons per blast.

[A.A.C. R18-2-306(A)(2)] 

d. The Permittee shall not cause or allow the amount of limestone quarried 

and processed to exceed 8,123.1 tons per calendar day nor 1,056,000 

tons per 365-day period.

[A.A.C. R18-2-306(A)(2)] 
Permit No. 1001770 Page 78 of 99 April 12, 2006

2. Particulate Matter Emission Standards

a. All roads within the Cement Plant Process Area Boundary shall be paved 

and shall be maintained in a paved condition.

[A.A.C. R18-2-306(A)(2)] 

b. Dust Control Procedures for Paved Roads

(1) All paved roads shall be watered and vacuumed on all operating 

days except when roads are damp due to normal precipitation.

[A.A.C. R18-2-406(A)(4)] 

(2) The maximum speed on paved roads shall be restricted to 20 

miles per hour;

[A.A.C. R18-2-406(A)(4)] 

c. Dust Control Procedures for Unpaved Roads

(1) All unpaved roads subject to vehicle traffic shall be watered on 

all operating days except when roads are damp due to normal 

precipitation.

[A.A.C. R18-2-406(A)(4)] 

(2) The maximum speed on unpaved roads shall be restricted to 15 

miles per hour;

[A.A.C. R18-2-406(A)(4)] 

(3) The roadways shall be watered frequently enough to assure 

compliance;

[A.A.C. R18-2-406(A)(4)] 

(4) Berms shall be installed around the areas which are not used by 

traffic to restrict usage;

[A.A.C. R18-2-406(A)(4)] 

(5) Spilled materials shall be removed within eight hours of 

occurrence. This material shall be collected either manually or 

by using a vacuum equipped truck.

[A.A.C. R18-2-406(A)(4)] 

3. Alternate Operating Scenario

During any calendar day in which the facility operates under the Alternate 

Operating Scenario, as described in Condition II.B.1.e herein, no emissions units 

or emitting activities listed in Condition VI.A shall be operated, except that 

vehicle traffic on paved roads within the Cement Plant Process Area Boundary 

may continue.

[A.A.C. R18-2-306(A)(11)] 
Permit No. 1001770 Page 79 of 99 April 12, 2006

C. Air Pollution Control Requirements

At all times when material is being unloaded into the Primary Crusher Hopper, including 

periods of startup, shutdown, and malfunction, the Permittee shall, to the extent 

practicable, install, maintain and operate the Water Dedusting System in a manner 

consistent with good air pollution control practice for minimizing particulate matter 

emissions.

[A.A.C. R18-2-331(A)(3)(d) and (e) and R18-2-406(A)(4)] 

Material Permit Conditions are indicated with underline and italics.

D. Monitoring, Recordkeeping, and Reporting Requirements

1. Monitoring and Recordkeeping for Operational Limitations

a. The Permittee shall maintain daily records of the number of blasts 

performed in the quarry.

[A.A.C. R18-2-306(A)(2)] 

b. The Permittee shall maintain daily records of the quantity and type of 

explosive used.

[A.A.C. R18-2-306(A)(2)] 

c. The Permittee shall maintain daily records of the amount of limestone 

quarried.

[A.A.C. R18-2-306(A)(2)] 

2. Recordkeeping for Particulate Matter Emission Standards

a. The Permittee shall maintain daily records of watering and vacuuming 

performed at all paved roads.

b. The Permittee shall maintain monthly records of maintenance activities 

conducted on paved roads within the Cement Plant Process Area 

Boundary.

c. The Permittee shall maintain daily records of watering performed at all 

unpaved roads.

[A.A.C. R18-2-306(A)(3)(c)] 

E. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following 

applicable requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-602, 

A.A.C. R18-2-604, A.A.C. R18-2-605, A.A.C. R18-2-606, A.A.C. R18-2-607, A.A.C. 

R18-2-612, and A.A.C. R18-2-804. 

[A.A.C. R18-2-325]
Permit No. 1001770 Page 80 of 99 April 12, 2006

VII. MISCELLANEOUS SOURCES

A. List of Emission Units

This section of the permit presents requirements that are applicable to miscellaneous 

activities throughout the quarry and plant. This section of the permit does not cover a 

specific process unit or emission unit.

B. Emission Limits and Standards

1. Requirements for All Fugitive Dust Sources

a. General

(1) As used in Conditions VII.B.1.a through VII.B.1.c, all terms 

shall have the meaning given in A.A.C. R18-2-101.

(2) Conditions VII.B.1.b and VII.B.1.c shall apply only to fugitive 

dust sources.

[A.A.C. R18-2-601]

(3) For the purposes of Condition VII.B.1.a(2), fugitive dust sources

are sources of air contaminants which, due to lack of an 

identifiable emission point or plume, cannot be considered point 

sources.

[A.A.C. R18-2-601]

(4) In applying the criterion in Condition VII.B.1.a(3), such items as

air-curtain destructors, heater-planers, and conveyor transfer

points shall be considered to have identifiable plumes.

[A.A.C. R18-2-601]

b. Visible Emissions

The Permittee shall not cause, allow or permit visible emissions from

fugitive dust sources in excess of 40 percent opacity measured in 

accordance with the Arizona Testing Manual, Reference Method 9. 

Open fires permitted under Condition VII.B.2 are exempt from this 

requirement.

[A.A.C. R18-2-612]

c. Work Practice Requirements

The Permittee shall employ the following reasonable precautions to 

prevent excessive amounts of particulate matter from becoming airborne:

(1) Use approved dust suppressants, adhesive soil stabilizer, paving,

covering, detouring, or wetting agents on, or bar access to open

areas during construction operations, repair operations, 
Permit No. 1001770 Page 81 of 99 April 12, 2006

demolition activities, clearing operations, and leveling 

operations, or when any earth is moved or excavated.

[A.A.C. R18-2-604(A)]

(2) Use approved dust suppressants, adhesive soil stabilizer, or 

paving on, or bar access to driveways, parking areas, and vacant 

lots where motor vehicular activity occurs.

[A.A.C. R18-2-604(B)]

(3) Use approved dust suppressants, temporary paving, detouring or

wetting agents when a roadway is repaired, constructed, or

reconstructed.

[A.A.C. R18-2-605(A)]

(4) Use dust suppressants, spray bars, hoods, wetting agents, or 

cover the load adequately when transporting material likely to 

give rise to airborne dust.

[A.A.C. R18-2-605(B) and R18-2-606]

(5) Use spray bars, hoods, wetting agents, dust suppressants, or 

cover when crushing, handling, or conveying material that is 

likely to give rise to airborne dust.

[A.A.C. R18-2-606]

(6) Adequately cover, or use wetting agents, chemical stabilization, 

or dust suppressants when stacking, piling, or otherwise storing

organic or inorganic dust producing material.

[A.A.C. R18-2-607(A)]

(7) Operate stacking and reclaiming machinery utilized at storage 

piles at all times with a minimum fall of material and with the 

use of spray bars and wetting agents.

[A.A.C. R18-2-607(B)]

2. Additional Requirements for Certain Fugitive Dust Sources

a. The Permittee shall not cause, allow, or permit bulk material to be 

hauled, either on-site or off-site, except in accordance with Conditions

VII.B.2.b(1) through VII.B.2.b(3).

[A.A.C. R18-2-406(A)(4)]

(1) All haul trucks shall be loaded such that the freeboard is not less

than three inches.

[A.A.C. R18-2-406(A)(4)]

(2) All haul trucks shall be loaded in such a manner as to prevent

spillage or loss of bulk material from holes or other openings in 

the cargo compartment’s floor, sides, or tailgate(s).

[A.A.C. R18-2-406(A)(4)]
Permit No. 1001770 Page 82 of 99 April 12, 2006

(3) No bulk material shall be transported in haul trucks unless the

cargo compartment is covered with a tarp or other suitable 

closure.

[A.A.C. R18-2-406(A)(4)]

b. The Permittee shall not cause, allow, or permit any empty haul truck to

leave the site unless the interior of the cargo compartment has been 

cleaned or the cargo compartment is covered with a tarp or other suitable 

closure.

[A.A.C. R18-2-406(A)(4)]

c. The Permittee shall not cause, allow, or permit any haul truck to leave 

the site without first utilizing a device that removes from its tires and 

exterior surfaces mud, dirt, debris, or other accumulation that may cause 

particulate matter emissions. Acceptable devices include:

(1) Wheel wash system.

(2) Gravel pad at least 30 feet wide, 50 feet long, and 6 inches deep.

(3) Paved roadway at least 20 feet wide and 100 feet long.

(4) Rails, pipes, or grates of sufficient width and length to remove

debris effectively.

[A.A.C. R18-2-406(A)(4)]

d. The Permittee shall operate at all times in conformance with the current

Dust Control Plan prepared pursuant to Condition VII.C.1.a.

[A.A.C. R18-2-406(A)(4)]

3. Open Burning

a. Except as provided in Condition VII.B.3.b, and except when permitted to 

do so by either the Director or the local officer delegated the authority 

for issuance of open burning permits, the Permittee shall not ignite, cause 

to be ignited, permit to be ignited, or suffer, allow or maintain any open 

outdoor fire.

[A.A.C. R18-2-602(A)]

(1) “Open outdoor fire,” as used in Condition VII.B.3.a, means any 

combustion of combustible material of any type outdoors, in the 

open where the products of combustion are not directed through

a flue.

[A.A.C. R18-2-602(B)]

(2) “Flue,” as used in Condition VII.B.3.a(1), means any duct or

passage for air, gases or the like, such as a stack or chimney.

[A.A.C. R18-2-602(B)]

b. The following fires are excepted from the prohibition in Condition

VII.B.3.a:

[A.A.C. R18-2-602(C)]
Permit No. 1001770 Page 83 of 99 April 12, 2006

(1) Fires used only for cooking of food or for providing warmth for

human beings or for recreational purposes or the branding of

animals or the use of orchard heaters for the purpose of frost

protection in farming or nursery operations.

[A.A.C. R18-2-602(C)(1)]

(2) Any fire set or permitted by any public officer in the 

performance of official duty, if such fire is set or permission 

given for the purpose of weed abatement, the prevention of a fire 

hazard, or instruction in the methods of fighting fires.

[A.A.C. R18-2-602(C)(2)]

(3) Fires set by or permitted by the state entomologist or county

agricultural agents of the county for the purpose of disease and 

pest prevention.

[A.A.C. R18-2-602(C)(3)]

(4) Fires set by or permitted by the federal government or any of its

departments, agencies or agents, the state or any of its agencies,

departments or political subdivisions, for the purpose of 

watershed rehabilitation or control through vegetative 

manipulation.

[A.A.C. R18-2-602(C)(4)]

4. Point Sources

a. General

(1) As used in Conditions VII.B.4.a through VII.B.4.e, all terms 

shall have the meaning given in A.A.C. R18-2-101 and R18-2-

701.

(2) Conditions VII.B.4.b through VII.B.4.e shall apply only to 

sources that are all of the following:

[A.A.C. R18-2-702(A)]

(a) Existing sources;

[A.A.C. R18-2-702(A)(1)]

(b) Point sources. For the purposes of this condition, “point

source” means a source of air contaminants that has an

identifiable plume or emissions point; and

[A.A.C. R18-2-702(A)(2)]

(c) Stationary sources.

[A.A.C. R18-2-702(A)(3)]

b. Visible Emissions

The Permittee shall not cause, allow, or permit visible emissions in 

excess of 20 percent opacity as determined by Reference Method 9 in 

appendix A to 40 CFR part 60.

[A.A.C. R18-2-406(A)(4), R18-2-702(B)]
Permit No. 1001770 Page 84 of 99 April 12, 2006

c. Abrasive Blasting

The Permittee shall not cause or allow sandblasting or other abrasive

blasting without minimizing dust emissions to the atmosphere through 

the use of good modern practices. Good modern practices include, but 

are not limited to, wet blasting and the use of effective enclosures with 

necessary dust collecting equipment.

[A.A.C. R18-2-726]

d. Spray Painting Operations

While performing spray painting operations the Permittee shall comply 

with the following requirements:

(1) The Permittee shall not conduct or cause to be conducted any 

spray painting operation without minimizing organic solvent 

emissions. Such operations, other than architectural coating and 

spot painting, shall be conducted in an enclosed area equipped 

with controls containing no less than 96 percent of the overspray.

[A.A.C. R18-2-727(A)]

(2) The Permittee shall not employ, apply, evaporate or dry any

architectural coating containing photochemically reactive 

solvents for industrial or commercial purposes.

[A.A.C. R18-2-727(B), R18-2-727(B)(1)]

(3) The Permittee shall not thin or dilute any architectural coating 

with a photochemically reactive solvent.

[A.A.C. R18-2-727(B), R18-2-727(B)(2)]

(4) For the purposes of Conditions VII.B.4.d(2) and VII.B.4.(3), a 

photochemically reactive solvent shall be any solvent with an 

aggregate of more than 20 percent of its total volume composed 

of the chemical compounds classified in Conditions 

VII.B.4.d(4)(a) through VII.B.4.d(4)(c), or which exceeds any of 

the following percentage composition limitations, referred to the 

total volume of solvent:

[A.A.C. R18-2-727(C)]

(a) A combination of the following types of compounds

having an olefinic or cycle-olefinic type of unsaturation -

hydrocarbons, alcohols, aldehydes, esters, ethers, or

ketones: five percent.

[A.A.C. R18-2-727(C)(1)]

(b) A combination of aromatic compounds with eight or 

more carbon atoms to the molecule except ethylbenzene: 

eight percent.

[A.A.C. R18-2-727(C)(2)]
Permit No. 1001770 Page 85 of 99 April 12, 2006

(c) A combination of ethylbenzene, ketones having 

branched hydrocarbon structures, trichloroethylene or 

toluene: 20 percent.

[A.A.C. R18-2-727(C)(3)]

(5) Whenever any organic solvent or any constituent of an organic

solvent may be classified from its chemical structure into more 

than one of the groups or organic compounds described in 

Conditions VII.B.4.d(4)(a) through VII.B.4.d(4)(c), it shall be

considered to be a member of the group having the least 

allowable percent of the total volume of solvents.

[A.A.C. R18-2-727(D)]

e. Solvent Cleaning / Degreasing / Dipping Operations

The Permittee shall process, store, use, and transport materials including

solvents or volatile compounds in such a manner and by such means that

they will not evaporate, leak, escape, or be otherwise discharged into the

atmosphere so as to cause or contribute to air pollution. Where means 

are available to reduce effectively the contribution to air pollution from

evaporation, leakage, or discharge, the installation and usage of such 

control methods, devices, or equipment shall be mandatory.

[A.A.C. R18-2-730(F)]

f. Air Pollution

(1) The Permittee shall not cause, allow, or permit gaseous or 

odorous materials to be emitted from equipment, operations or 

premises under its control in such quantities or concentrations as 

to cause air pollution.

[A.A.C. R18-2-730(D)]

(2) Where a stack, vent or other outlet is at such a level that fumes, 

gas mist, odor, smoke, vapor or any combination thereof 

constituting air pollution is discharged to adjoining property, the 

Director may require the installation of abatement equipment or 

the alteration of such stack, vent, or other outlet by the owner or 

operator thereof to a degree that will adequately dilute, reduce or 

eliminate the discharge of air pollution to adjoining property.

[A.A.C. R18-2-730(G)]

5. Mobile Sources

a. General

(1) The requirements of Conditions VII.B.5.b and VII.B.5.c are 

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 are agricultural equipment used in 

normal farm operations.

[A.A.C. R18-2-801]
Permit No. 1001770 Page 86 of 99 April 12, 2006

(2) The requirements of Conditions VII.B.5.b and VII.B.5.c shall not 

apply to portable sources.

[A.A.C. R18-2-801]

b. Off-road Machinery

The Permittee shall not cause, allow, or permit to be emitted into the

atmosphere from any off-road machinery, smoke for any period greater 

than ten consecutive seconds, the opacity of which exceeds 40 percent. 

Visible emissions when starting cold equipment shall be exempt from 

this requirement for the first ten minutes. Off-road machinery shall 

include trucks, graders, scrapers, rollers and other construction and 

mining machinery not normally driven on a completed public roadway.

[A.A.C. R18-2-802]

c. Roadway and Site Cleaning Machinery

(1) The Permittee shall not cause, allow, or permit to be emitted into

the atmosphere from any roadway and site cleaning machinery

smoke or dust for any period greater than ten consecutive

seconds, the opacity of which exceeds 40 percent. Visible 

emissions when starting cold equipment shall be exempt from 

this requirement for the first ten minutes.

[A.A.C. R18-2-804(A)]

(2) The Permittee shall not cause, allow, or permit the cleaning of 

any site, roadway, or alley without taking reasonable precautions 

to prevent particulate matter from becoming airborne.

Reasonable precautions may include applying dust suppressants. 

Earth or other material shall be removed from paved streets onto 

which earth or other material has been transported by trucking or 

earth moving equipment, erosion by water or by other means.

[A.A.C. R18-2-804(B)]

6. Demolition/Renovation

The Permittee shall comply with all applicable requirements of 40 CFR part 61,

subpart M.

[A.A.C. R18-2-1101(A)(8) {40 CFR 61 subpart M by ref.}]

7. Nonvehicle Air Conditioner Maintenance and/or Services

The Permittee shall comply with all applicable requirements of 40 CFR part 82,

subpart F.

[40 CFR 82 subpart F]

C. Monitoring, Recordkeeping, and Reporting Requirements

1. Fugitive Dust Control Plan
Permit No. 1001770 Page 87 of 99 April 12, 2006

a. The Permittee shall prepare a Dust Control Plan and shall submit the plan 

to the Department for its approval at least 180 days prior to beginning 

any site clearing activities or on-site construction of the refinery. The 

Permittee shall maintain at all times a copy of the approved plan, readily 

available for inspection.

[A.A.C. R18-2-306(A)(4)]

b. The Dust Control Plan shall contain, at a minimum, all of the following

information:

(1) Names, address(es), and phone numbers of person(s) responsible

for the preparation, maintenance, and implementation of each

element of the Dust Control Plan.

[A.A.C. R18-2-306(A)(4)]

(2) Control measures or a combination thereof to be applied to all

actual and potential fugitive dust sources, before, after, and while

conducting any dust generating operation, including during

weekends, after work hours, and on holidays. The control

measures specified in the Dust Control Plan shall address and 

shall be sufficient to ensure compliance with Conditions VII.B.1 

and VII.B.2.

[A.A.C. R18-2-306(A)(4)]

(3) A drawing that shows:

(a) Entire project site boundaries;

(b) Acres to be disturbed with linear dimensions;

(c) Nearest public roads;

(d) North arrow; and

(e) Planned exit locations onto paved public roadways.

[A.A.C. R18-2-306(A)(4)]

(4) Dust suppressants to be applied, including product specifications

or label instructions for approved usage and other information

required by Conditions VII.C.1.b(4) through VII.C.1.b(4).

(a) Method, frequency, and intensity of dust suppressant

application.

(b) Type, number, and capacity of dust suppressant 

application equipment.

(c) Information on environmental impacts and approvals or

certifications related to appropriate and safe use for 

ground application of dust suppressants.

[A.A.C. R18-2-306(A)(4)]
Permit No. 1001770 Page 88 of 99 April 12, 2006

(5) Specific surface treatment(s) or other control measures utilized 

to control material trackout and sedimentation where unpaved or

access points join paved public roadways.

[A.A.C. R18-2-306(A)(4)]

c. The Permittee shall maintain records of each instance of operation not

consistent with the Dust Control Plan. Each such instance shall be

considered a period of excess emissions.

[A.A.C. R18-2-306(A)(4)]

d. The Permittee shall report excess emissions and deviations in accordance

with Sections XII.A and XII.B, respectively, in Attachment “A” of this

permit.

[A.A.C. R18-2-306(A)(5)(b)]

2. Abrasive Blasting

Each time an abrasive blasting project is conducted, the Permittee shall log in ink

or in an electronic format, a record of the following:

a. The date the project conducted;

b. The duration of the project; and

c. Type of control measures employed.

[A.A.C. R18-2-306(A)(4)]

3. Spray Painting Operations

a. Except as provided in Condition VII.C.3.b, each time a spray painting

project is conducted, the Permittee shall log in ink or in an electronic

format, a record of the following:

(1) The date the project was conducted;

(2) The duration of the project;

(3) Type of control measures employed; and

(4) Material Safety Data Sheets for all paints and solvents used in 

the project.

b. Architectural coating and spot painting projects shall be exempt from the

recordkeeping requirements of part a. above.

[A.A.C. R18-2-306(A)(4)]

4. Mobile Sources

The Permittee shall keep a record of all emissions-related maintenance activities

performed on all mobile sources subject to Condition VII.B.5.

[A.A.C. R18-2-306(A)(4)]
Permit No. 1001770 Page 89 of 99 April 12, 2006

5. Demolition/Renovation

The Permittee shall comply with all applicable monitoring, recordkeeping, and

reporting requirements of 40 CFR part 61, subpart M.

[A.A.C. R18-2-1101(A)(8) {40 CFR 61 subpart M by ref.}]

6. Nonvehicle Air Conditioner Maintenance and/or Services

The Permittee shall comply with all applicable monitoring, recordkeeping, and

reporting requirements of 40 CFR part 82, subpart F.

[40 CFR 82 subpart F]

D. Permit Shield

Compliance with the terms of this section shall be deemed compliance with the following

applicable requirement(s) in effect on the date of permit issuance: A.A.C. R18-2-

406(A)(4), R18-2-601, R18-2-602, R18-2-604, R18-2-605, R18-2-606, R18-2-607, R18-

2-612, R18-2-702(A), R18-2-702(B), R18-2-726, R18-2-727, R18-2-730(D), R18-2-

730(F), R18-2-730(G), R18-2-730(H), R18-2-801, R18-2-802, R18-2-804.

[A.A.C. R18-2-325]

VIII. AMBIENT AIR QUALITY MONITORING

A. The Permittee shall submit to the Director for approval an Ambient Monitoring Plan to 

monitor PM10, PM2.5, and ambient contributors to nitrogen deposition. This submittal 

shall occur by the date that actual construction begins, or the date 6 months after permit 

issuance, whichever is later. 

[A.A.C. R18-2-306.B.2] 

B. The monitoring plan shall include the number and location of monitors or sampling 

stations, and a description of the proposed monitoring systems. At a minimum, the 

Permittee should propose to operate monitors at two locations; one location within the 

facility and one offsite location to assess plant impacts in the Sycamore Canyon area. 

The plan should also contain a proposed date or milestone for terminating all 

requirements pertaining to the ambient air quality monitoring network. 

[A.A.C. R18-2-306.B.2] 

C. The Permittee shall implement the approved Ambient Monitoring Plan beginning at least 

12 months prior to initial startup of the Rotary Kiln. 

[A.A.C. R18-2-306.B.2] 

D. The Permittee shall continue the monitoring activities for at least three years after the 

start of operations. 

[A.A.C. R18-2-306.B.2] 
Permit No. 1001770 Page 90 of 99 April 12, 2006

ATTACHMENT “C”: EQUIPMENT LIST

Air Quality Control Permit No. 1001770

for

Drake Cement, LLC

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

Department 1

IPC-1.3 Impact Primary Crusher 495 tph Titan TBD TBD TBD

WD-1.4 Water Dedusting System (Truck Unloading) 4 gpm TBD TBD TBD TBD

OC-1.5 First Overland Belt Conveyor 500 tph TBD TBD TBD TBD

DC1.6 Dust Collector for Primary Crusher 14,619 acfm TBD TBD TBD TBD

OC-1.7 Second Overland Belt Conveyor 500 tph TBD TBD TBD TBD

DC1.8 Dust Collector for Belt Conveyor Transfer 2,757 acfm TBD TBD TBD TBD

OC-1.9 Third Overland Belt Conveyor 500 tph TBD TBD TBD TBD

DC1.10 Dust Collector for Belt Conveyor Transfer 2,757 acfm TBD TBD TBD TBD

DC1.11 Dust Collector for Belt Conveyor Transfer 5,515 acfm TBD TBD TBD TBD

Department 2

BC-2.1 Belt Conveyor with Tripper for Limestone 500 tph TBD TBD TBD TBD

CS-2.2 Limestone Covered Stockpile 51,000 tons TBD TBD TBD TBD

PS-2.3 Portal Scraper 500 tph TBD TBD TBD TBD

BC-2.4

Belt Conveyor for Collecting Limestone from 

Stockpile 500 tph TBD TBD TBD TBD

DC2.5 Dust Collector for Belt Conveyor Transfer 2,757 acfm TBD TBD TBD TBD

BC-2.8 Belt Conveyor to Raw Material Silos 500 tph TBD TBD TBD TBD

DC2.9

Dust Collector for Belt Conveyor Transfer to 

Silos 7,418 acfm TBD TBD TBD TBD

DC2.10

Dust Collector for Belt Conveyor Transfer to 

Silos 7,418 acfm TBD TBD TBD TBD

BC-2.12 Reversible Conveyor on Top of Raw Material 500 tph TBD TBD TBD TBD
Permit No. 1001770 Page 91 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

Silo

BC-2.13

Reversible Conveyor on Top of Raw Material 

Silo 500 tph TBD TBD TBD TBD

Department 3

RMS-3.1 High Limestone Silo 1 550 tons TBD TBD TBD TBD

RMS-3.2 High Limestone Silo 2 450 tons TBD TBD TBD TBD

RMS-3.3 Low Limestone Silo 550 tons TBD TBD TBD TBD

RMS-3.4 Iron Ore Silo 510 tons TBD TBD TBD TBD

RMS-3.5 Gypsum Silo 450 tons TBD TBD TBD TBD

RMS-3.6 Clinker Silo 550 tons TBD TBD TBD TBD

RMS-3.7 Aluminum Source Silo 330 tons TBD TBD TBD TBD

RMS-3.8 Raw Coal Silo 300 tons TBD TBD TBD TBD

Department 4

RHR-4.1 Receiving Hopper for Railroad Cars 26' x 14' TBD TBD TBD TBD

VF-4.3 Vibrating Feeder 400 tph TBD TBD TBD TBD

WD-4.4 Water Dedusting System (Rail Car Discharge) 4 gpm TBD TBD TBD TBD

RHT-4.5 Receiving Hopper for Trucks

approx. 16.4' x 

10' TBD TBD TBD TBD

WD-4.6 Water Dedusting System (Truck Discharge) 2 gpm TBD TBD TBD TBD

VF-4.7 Vibrating Feeder 400 tph TBD TBD TBD TBD

BC-4.8

Belt Conveyor under Rail Car and Truck 

Discharge 400 tph TBD TBD TBD TBD

BC-4.9

Belt Conveyor with Tripper for Coal, Iron Ore, 

etc. 400 tph TBD TBD TBD TBD

CS-4.10

Coal, Iron Ore, and Aluminum Covered 

Stockpile 8,300 tons TBD TBD TBD TBD

BC-4.11

Belt Conveyor under Coal and Iron Ore 

Stockpile 400 tph TBD TBD TBD TBD

VF-4.12.1 Vibrating Feeder under Covered Stockpile 400 tph TBD TBD TBD TBD

VF-4.12.2 Vibrating Feeder under Covered Stockpile 400 tph TBD TBD TBD TBD

VF-4.12.3 Vibrating Feeder under Covered Stockpile 400 tph TBD TBD TBD TBD
Permit No. 1001770 Page 92 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

VF-4.12.4 Vibrating Feeder under Covered Stockpile 400 tph TBD TBD TBD TBD

VF-4.12.5 Vibrating Feeder under Covered Stockpile 400 tph TBD TBD TBD TBD

VF-4.12.6 Vibrating Feeder under Covered Stockpile 400 tph TBD TBD TBD TBD

BC-4.15 Belt Conveyor to Raw Material Silos 400 tph TBD TBD TBD TBD

BC-4.17

Reversible Conveyor on Top of Raw Material 

Silo 400 tph TBD TBD TBD TBD

DC4.18 Dust Collector for Belt Conveyor Transfer 2,158 acfm TBD TBD TBD TBD

DC4.19

Dust Collector for Belt Conveyor Transfer to 

Silos 7,925 acfm TBD TBD TBD TBD

DC4.20 Dust Collector for Belt Conveyor Transfer 4,640 acfm TBD TBD TBD TBD

BC-4.22

1st Belt Conveyor for Limestone Unloaded 

from Rail Cars 400 tph TBD TBD TBD TBD

DC4.23 Dust Collector for Belt Conveyor Transfer 2,158 acfm TBD TBD TBD TBD

BC-4.24

2nd Belt Conveyor for Limestone Unloaded 

from Rail Cars 400 tph TBD TBD TBD TBD

DC4.25 Dust Collector for Belt Conveyor Transfer 2,158 acfm TBD TBD TBD TBD

BC-4.26

3rd Belt Conveyor for Limestone Unloaded 

from Rail Cars 400 tph TBD TBD TBD TBD

Department 5

WF-5.1.1 Weighfeeder for High Limestone 15-150 tph TBD TBD TBD TBD

WF-5.1.2 Weighfeeder for High Limestone 15-150 tph TBD TBD TBD TBD

WF-5.2 Weighfeeder for Low Limestone 10-100 tph TBD TBD TBD TBD

WF-5.3.1 Weighfeeder for Iron Ore 1-10 tph TBD TBD TBD TBD

WF-5.3.2 Weighfeeder for Aluminum Source 1-10 tph TBD TBD TBD TBD

BC-5.4

Small Belt Conveyor for Iron Ore and 

Aluminum Source 50 tph TBD TBD TBD TBD

DC5.5 Dust Collector for Weighfeeders 8,135 acfm TBD TBD TBD TBD

BC-5.6 Belt Conveyor to Raw Grinding Building 180 tph TBD TBD TBD TBD

TIHM-5.10 Tandem Impact Hammer Mill 180 tph KHD TBD TBD TBD

SS-5.11 Static Separator 6.0 m dia. ARPL TBD TBD

BC-5.13 Belt Conveyor to Ball Mill 210 tph TBD TBD TBD TBD
Permit No. 1001770 Page 93 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

BM-5.16 Ball Mill 14' x 23' 9", 2500 hp 164 tph Hardinge TBD TBD TBD

C-5.17.1 Cyclone 2.8 m dia. Duda TBD TBD TBD

C-5.17.2 Cyclone 2.8 m dia. Duda TBD TBD TBD

C-5.17.3 Cyclone 2.8 m dia. Duda TBD TBD TBD

C-5.17.4 Cyclone 2.8 m dia. Duda TBD TBD TBD

SC-5.18.1 Screw Conveyor for Raw Meal 90 tph TBD TBD TBD TBD

SC-5.18.2 Screw Conveyor for Raw Meal 90 tph TBD TBD TBD TBD

AS-5.19 First Airslide for Raw Meal 180 tph TBD TBD TBD TBD

AS-5.21 Second Airslide for Raw Meal 180 tph TBD TBD TBD TBD

DC5.22 Dust Collector for Raw Grinding System 5,334 acfm TBD TBD TBD TBD

BH 5.30 Baghouse for Raw Mill and Kiln

108,341-165,325 

acfm TBD TBD TBD TBD

SC-5.31.1 Screw Conveyor under Baghouse 6 tph TBD TBD TBD TBD

SC-5.31.2 Screw Conveyor under Baghouse 6 tph TBD TBD TBD TBD

SC-5.31.3 Screw Conveyor under Baghouse 6 tph TBD TBD TBD TBD

SC-5.32

Screw Conveyor which Collects Dust from 

Baghouse 18 tph TBD TBD TBD TBD

SC-5.33

Screw Conveyor for Taking Dust to Blending 

Silo 18 tph TBD TBD TBD TBD

MS5.38 Main Stack

118,956-165,325 

acfm TBD TBD TBD TBD

GAN-5.39

Gas Analyzer on Main Stack (O2, CO, NOx, and 

SO2) Not Applicable TBD TBD TBD TBD

CPM-5.40

Continuous Particulate Monitor on Main Stack 

(PM and PM10) Not Applicable TBD TBD TBD TBD

THCGAN5.41Total Hydrocarbon Gas Analyzer on Main Stack 

(THC) Not Applicable TBD TBD TBD TBD

Department 6

BE-6.1 Bucket Elevator to Blending Silo 180 tph TBD TBD TBD TBD

AS-6.2 Airslide for Raw Meal on Top of Blending Silo 180 tph TBD TBD TBD TBD

PDAS-6.3 Pneumatic Parallel Distribution for Airslides 830 mm dia. TBD TBD TBD TBD
Permit No. 1001770 Page 94 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

AS-6.4.1 Short Airslide on Top of Blending Silo 180 tph TBD TBD TBD TBD

AS-6.4.2 Short Airslide on Top of Blending Silo 180 tph TBD TBD TBD TBD

AS-6.5.1 Long Airslide on Top of Blending Silo 180 tph TBD TBD TBD TBD

AS-6.5.2 Long Airslide on Top of Blending Silo 180 tph TBD TBD TBD TBD

AS-6.5.3 Long Airslide on Top of Blending Silo 180 tph TBD TBD TBD TBD

AS-6.5.4 Long Airslide on Top of Blending Silo 180 tph TBD TBD TBD TBD

SI-6.7 Blending Silo 9,000 tons TBD TBD TBD TBD

DC6.10 Dust Collector on Top of Blending Silo 5,632 acfm TBD TBD TBD TBD

Department 7

AS-7.4 Raised Airslide from Blending Silo 170 tph TBD TBD TBD TBD

AS-7.5 Base Airslide from Blending Silo 170 tph TBD TBD TBD TBD

MWB-7.8 Metallic Weighing Bin 33 m3 TBD TBD TBD TBD

FPD-7.10 Fluidization and Pneumatic Discharge of Bin TBD TBD TBD TBD TBD

AS-7.12 Airslide 170 tph TBD TBD TBD TBD

BE-7.15.1 Bucket Elevator for Feeding Pre-Heater Tower 170 tph TBD TBD TBD TBD

BE-7.15.2 Bucket Elevator for Feeding Pre-Heater Tower 170 tph TBD TBD TBD TBD

DC7.16 Dust Collector 3,519 acfm TBD TBD TBD TBD

AS-7.17 Airslide 170 tph TBD TBD TBD TBD

AS-7.22 Recirculating Airslide 170 tph TBD TBD TBD TBD

DC7.23 Dust Collector on Top of Preheater Tower 2,548 acfm TBD TBD TBD TBD

Department 8

PRE-8.3 Six-Stage Preheater 5.2/5.0 m dia. TBD TBD TBD TBD

CAL-8.13 Calciner ( 6.0 m diameter ) 83.33 tph TBD TBD TBD TBD

GAN-8.16 Gas Analyzer for Kiln Inlet (O2, CO, and NOx) Not Applicable TBD TBD TBD TBD

GAN-8.17 Gas Analyzer for Preheater (O2 and CO) Not Applicable TBD TBD TBD TBD

TAD-8.18 Tertiary Air Duct 1.8 m dia. TBD TBD TBD TBD

SNCR-8.19

SNCR Equipment inc. Pumps, Tanks, etc. for 

NH3 aqueous solution 200 lph TBD TBD TBD TBD

Department 9
Permit No. 1001770 Page 95 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

RK-9.1 Rotary Kiln 12' x 143' with 2 Supports 83.33 tph TBD TBD TBD TBD

DEG-9.11 Diesel Emergency Generator 210 kW TBD TBD TBD TBD

Department 10

CGC-10.1 Clinker Grate Cooler 83.33 tph TBD TBD TBD TBD

CRC-10.3 Cooler Roller Crusher with 4 Rollers TBD TBD TBD TBD TBD

SC-10.12 Screw Conveyor for Clinker Dust 6 tph TBD TBD TBD TBD

BH10.13 Baghouse for Cooler 105,932 acfm TBD TBD TBD TBD

SC-10.14 Screw Conveyor for Clinker Dust 6 tph TBD TBD TBD TBD

CS10.16 Cooler Stack 105,932 acfm TBD TBD TBD TBD

CPM-10.17 Continuous Particulate Matter Monitor on 

Cooler Stack (PM and PM10)

Not Applicable TBD TBD TBD TBD

Department 11

HPC-11.1 Hot Pan Conveyor 83.33 tph TBD TBD TBD TBD

DC11.2 Dust Collector 4,164 acfm TBD TBD TBD TBD

CDO-11.3 Clinker Dome 50,000 tons TBD TBD TBD TBD

BC-11.5 Belt Conveyor to Emergency Clinker Silo 83.33 tph TBD TBD TBD TBD

DC11.6.1 Dust Collector for Belt Transfer 2,564 acfm TBD TBD TBD TBD

DC11.6.2 Dust Collector for Emergency Clinker Silo 2,935 acfm TBD TBD TBD TBD

SI-11.7 Emergency Clinker Silo 13,800 tons TBD TBD TBD TBD

BC-11.8

Belt Conveyor under Clinker Dome and Clinker 

Silo 400 tph TBD TBD TBD TBD

BC-11.10

Belt Conveyor for Transporting Clinker and 

Gypsum to Silos 400 tph TBD TBD TBD TBD

DC11.11 Dust Collector for Belt Transfer 8,792 acfm TBD TBD TBD TBD

OS-11.12 Open Stockpile for Gypsum 2,000 tons TBD TBD TBD TBD

HGP-11.13 Hopper with Grid to be Fed by Payloader 10 m3 TBD TBD TBD TBD

BC-11.14

Reversible Belt Conveyor for Clinker and 

Gypsum 400 tph TBD TBD TBD TBD

DC11.15 Dust Collector for Clinker and Gypsum Silos 7,592 acfm TBD TBD TBD TBD

Department 12
Permit No. 1001770 Page 96 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

WF-12.1 Weighfeeder for Coal 2-20 tph TBD TBD TBD TBD

BC-12.3

First Belt Conveyor for Transporting Coal to 

Mill 20 tph TBD TBD TBD TBD

BC-12.4

Second Belt Conveyor for Transporting Coal to 

Mill 20 tph TBD TBD TBD TBD

DC12.7.1 Dust Collector for Coal Belt Transfer 1,883 acfm TBD TBD TBD TBD

DC12.7.2 Dust Collector for Coal Pump 388 acfm TBD TBD TBD TBD

VM-12.9 Vertical or Bowl Mill for Coal 14 tph TBD TBD TBD TBD

C-12.14 Cyclone 1.6 m dia. Duda TBD TBD TBD

RV-12.15 Rotary Valve below the Dedusting Cyclone 1.6 m dia. Duda TBD TBD TBD

BH12.18 Baghouse for Coal Mill 17,878 acfm TBD TBD TBD TBD

SC-12.20 Screw Conveyor for Coal Dust 20 tph TBD TBD TBD TBD

PPU12.22.1 Pneumatic Pump for Coal 20 tph TBD TBD TBD TBD

PPU12.22.2 Pneumatic Pump for Coal 20 tph TBD TBD TBD TBD

PCP-12.24 Pneumatic Conveying Pipe 6 in. dia. TBD TBD TBD TBD

DC12.26 Pulverized Silo with Dust Collector 1,835 acfm TBD TBD TBD TBD

PH-12.33.1 Pre-Hopper 3 m3 TBD TBD TBD TBD

PH-12.33.2 Pre-Hopper 3 m

3 TBD TBD TBD TBD

RWF12.35.1 Rotor Weighfeeder 0.7- 7.0 tph TBD TBD TBD TBD

RWF12.35.2 Rotor Weighfeeder 0.7- 7.0 tph TBD TBD TBD TBD

PCP-12.37 Pneumatic Conveying Pipe to Calciner 6 in. dia TBD TBD TBD TBD

PCP-12.38 Pneumatic Conveying Pipe to Kiln Hood 6 in. dia TBD TBD TBD TBD

Department 13

WF-13.1.1 Weighfeeder for Clinker 14-143 tph TBD TBD TBD TBD

WF-13.1.2 Weighfeeder for Gypsum 1-10 tph TBD TBD TBD TBD

WF-13.1.3 Weighfeeder for Limestone 1-10 tph TBD TBD TBD TBD

BC-13.2 Small Belt Conveyor for Transporting 50 tph TBD TBD TBD TBD
Permit No. 1001770 Page 97 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

Limestone and Gypsum 

BC-13.3 Belt Conveyor to Cement Mill 143 tph TBD TBD TBD TBD

DC13.4 Dust Collector for Belt Transfer 2,451 acfm TBD TBD TBD TBD

BE-13.5 Bucket Elevator 143 tph TBD TBD TBD TBD

BC-13.6 Belt Conveyor to Roller Press 578 tph TBD TBD TBD TBD

CH-13.9.1 Special Transfer Chute of Gate 578 tph TBD TBD TBD TBD

RP-13.10 Roller Press 517 tph Polysius TBD TBD TBD

CH-13.10.1 Special Chute of Roller Press 578 tph TBD TBD TBD TBD

DIS-13.11 Dissaglomerator 792 tph Polysius TBD TBD TBD

BC-13.12 Belt Conveyor under Dissaglomerator 578 tph TBD TBD TBD TBD

CH-13.12.1 Special Chute of Dissaglomerator 578 tph TBD TBD TBD TBD

BE-13.13 Recirculating Bucket Elevator 578 tph TBD TBD TBD TBD

CH-13.13.1 Special Chute of Bucket Elevator 578 tph TBD TBD TBD TBD

HES-13.15 High Efficiency Separator 578 tph TBD TBD TBD TBD

CH-13.16 Special Chute of High Efficiency Separator 578 tph TBD TBD TBD TBD

AS-13.17.1 Airslide 60 tph TBD TBD TBD TBD

AS-13.17.2 Airslide 60 tph TBD TBD TBD TBD

AS-13.17.3 Airslide 60 tph TBD TBD TBD TBD

AS-13.17.4 Airslide 60 tph TBD TBD TBD TBD

DC13.19 Dust Collector 18,924 acfm TBD TBD TBD TBD

DC13.20 Dust Collector 18,924 acfm TBD TBD TBD TBD

SC-13.21 Screw Conveyor 5 MT/h TBD TBD TBD TBD

SC-13.22 Screw Conveyor 10 MT/h TBD TBD TBD TBD

BPH-13.30 By-Pass Hopper 15 m3 TBD TBD TBD TBD

BC-13.31 Small Belt Conveyor 17 tph TBD TBD TBD TBD

CH-13.34 Transfer Chute 17 tph TBD TBD TBD TBD

MWB13.35 Metallic Weighing Silo or Bin 70 m3 TBD TBD TBD TBD

FPD-13.37

Fluidization and Pneumatic Discharge of Bin or 

Silo TBD TBD TBD TBD TBD

BM-13.39 Ball Mill 14' x 23' 9", 2500 hp 100 tph Hardinge TBD TBD TBD
Permit No. 1001770 Page 98 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

DC13.40 Dust Collector for Ball Mill 22,499 acfm TBD TBD TBD TBD

SC-13.41 Screw Conveyor 5 tph TBD TBD TBD TBD

AS-13.42 Airslide for Transporting Final Cement Product 143 tph TBD TBD TBD TBD

BBD-13.44

Broken Bag Detection System for Dust 

Collector DC13.19 0-100% scale TBD TBD TBD TBD

BBD-13.45

Broken Bag Detection System for Dust 

Collector DC13.20 0-100% scale TBD TBD TBD TBD

BBD-13.46

Broken Bag Detection System for Dust 

Collector DC13.40 0-100% scale TBD TBD TBD TBD

Department 14

BE-14.1 Bucket Elevator for Feeding Cement Silo 180 tph TBD TBD TBD TBD

AS-14.2 Airslide on Top of Cement Silo 180 tph TBD TBD TBD TBD

PDAS-14.3 Pneumatic Parallel Distribution for Airslides 830 mm dia. TBD TBD TBD TBD

AS-14.4.1 Airslide on Top of Cement Silo 30-60 tph TBD TBD TBD TBD

AS-14.4.2 Airslide on Top of Cement Silo 30-60 tph TBD TBD TBD TBD

AS-14.4.3 Airslide on Top of Cement Silo 30-60 tph TBD TBD TBD TBD

AS-14.4.4 Airslide on Top of Cement Silo 30-60 tph TBD TBD TBD TBD

SI-14.6 Cement Silo 10,000 tons TBD TBD TBD TBD

DC14.10 Dust Collector on Top of Cement Silo 2,988 acfm TBD TBD TBD TBD

AS-14.13 Airslide 400 tph TBD TBD TBD TBD

BE-14.14 Bucket Elevator 400 tph TBD TBD TBD TBD

AS-14.15 Airslide for Feeding 2 Metallic Silos 400 tph TBD TBD TBD TBD

CMS14.17.1 Cement Metallic Silo 125 m3 TBD TBD TBD TBD

CMS14.17.2 Cement Metallic Silo 125 m3 TBD TBD TBD TBD

ASC14.20.1Double Mobile Articulated Screw Conveyor for 

Bulk Cement 330 tph TBD TBD TBD TBD

ASC14.20.2Double Mobile Articulated Screw Conveyor for 

Bulk Cement 330 tph TBD TBD TBD TBD

DC14.21 Dust Collector for Bulk Loading 7,561 acfm TBD TBD TBD TBD
Permit No. 1001770 Page 99 of 99 April 12, 2006

Equipment 

ID Equipment Description Capacity Make Model

Serial 

Number

Date of 

Manufacture

ETBL14.23 Emergency Truck Bulk Loading 165 tph TBD TBD TBD TBD

SD-14.24 Metallic Silo Side Discharge 165 tph TBD TBD TBD TBD

PPU-14.25

Pneumatic Pump for Transporting Cement to 

Railroad Silo 165 tph TBD TBD TBD TBD

PCP-14.27 Pneumatic Conveying Pipe 6 in. dia. TBD TBD TBD TBD

CMS-14.28 Cement Metallic Silo for Train Bulk Loading 450 m3 TBD TBD TBD TBD

DC14.29 Dust Collector for Train Bulk Loading 4,964 acfm TBD TBD TBD TBD

LBR-14.32 Loading Head to Bulk Loading of Rail Cars TBD TBD TBD TBD TBD