## State of Utah

Department of Environmental Quality

Dianne R. Nielson, Ph.D. Executive Director

DIVISION OF AIR QUALITY Richard W. Sprott Director JON M. HUNTSMAN, JR. Governor

GARY HERBERT Lieutenant Governor Site ID: 10007



### Title V Operating Permit

PERMIT NUMBER: 2900001001 DATE OF PERMIT: July 19, 2004 Date of Last Revision: November 13, 2006

This Operating Permit is issued to, and applies to the following:

Name of Permittee:

Holcim (US) Inc. 6055 East Croydon Road Morgan, UT 84050 Permitted Location:

Devil's Slide Plant 6055 E. Croydon Rd. Morgan, UT 84050

UTM coordinates: 4,545,500 meters No rthing, 455,500 meters Easting SIC code: 3241



### ABSTRACT

Holcim Inc. operates the Devil’s Slide cement manuf acturing plant near Morgan , Utah. This plant has been in operation since 1947, with recent major modifications made to most of the process during 1996 and 1997. At the Devil’s Slide plant, cement is made when raw materials such as limestone & sandstone (quarried on-site), iron ore, and gypsum are proportione d, ground, and mixed and then fed into a rotating kiln. The intense heat of the kiln alters the ma terials and recombines them into small stones called cement clinker. The clinker is cooled and ground with gypsum into a fine powdered cement. The final product is stored on site for later packaging and sh ipping. The major sources of air emissions are the combustion of fuels for the kiln operation and from the kiln and clinker cooling process. The Devil’s Slide plant is a major source for emissions of PM 10 , SO 2 , NO x and HAPs. This source is subject to NSPS Subparts A, Y, OOO, and MACT Subpart LLL.

UTAH AIR QUALITY BOARD

By: Prepared By:

M. Cheryl Heying, Acting Executive Secretary Brandy Cannon Utah Air Quality Board

150 North 1950 West • PO Box 144820 • Salt Lake City, UT 84114-4820 • phone (801) 536-4000 • fax (801) 536-4099
T.D.D. (801) 536-4414 • www.deq.utah.gov

## Operating Permit History

7/19/2004 - Permit issued Action initiated by an initial operating permit application

4/4/2005 -Permit modified Action initiated by an administrative amendment (initiated by DAQ) To incorporate changes approved in DAQE-AN0007018-05, dated January 31, 2005, including the following: replace the clinker cooler cooling fans, add a heat exchanger, extend the clinker cooler length, and add two compartments to the clinker cooler dust collector.

11/7/2005 -Permit modified Action initiated by an administrative amendment (initiated by DAQ) To incorporate the changes approved in DAQE-AN0007019-05, dated August 18, 2005, including the following: re-expression of the inline kiln/raw mill SO 2 emission limit from 104 lb SO 2 /hr to 475 lb SO 2 /hr on a rolling 24-hour average, addition of an SO 2 limit not to exceed 457 tons per rolling 12-month period, continuous emission monitoring system applied to the kiln stack for SO 2 instead of the previous stack testing required every two years, change the underlying approval order number to the current number, and correction of any typographical errors.

11/13/2006 -Permit modified Action initiated by an administrative amendment (initiated by DAQ) To incorporate changes approved in DAQE-AN0007019-06, dated August 30, 2006, which was a PSD major modification. Changes to the permit include a production increase, a restriction on PM 10 stack venting, a schedule limitation for mining and material transport operations, a silt loading level for paved surfaces, and a requirement for off-site PM 10 monitoring.

## Table of Contents

SECTION I: GENERAL PROVISIONS .................................................................................................. 1 I.A. F EDERAL E NFORCEMENT ..............................................................................................................1 I.B. P ERMITTED A CTIVITY ( IES ). ..........................................................................................................1 I.C. D UTY TO C OMPLY . .......................................................................................................................1 I.D. P ERMIT E XPIRATION AND R ENEWAL ............................................................................................2 I.E. A PPLICATION S HIELD . ..................................................................................................................2 I.F. S EVERABILITY . .............................................................................................................................2 I.G. P ERMIT F EE ...................................................................................................................................2 I.H. N O P ROPERTY R IGHTS ..................................................................................................................2 I.I. R EVISION E XCEPTION . ..................................................................................................................2 I.J. I NSPECTION AND E NTRY ...............................................................................................................2 I.K. C ERTIFICATION . ............................................................................................................................3 I.L. C OMPLIANCE C ERTIFICATION .......................................................................................................3 I.M. P ERMIT S HIELD .............................................................................................................................4 I.N. E MERGENCY P ROVISION ...............................................................................................................4 I.O. O PERATIONAL F LEXIBILITY ..........................................................................................................5 I.P. O FF

- PERMIT C HANGES ..................................................................................................................5 I.Q. A DMINISTRATIVE P ERMIT A MENDMENTS . ...................................................................................5 I.R. P ERMIT M ODIFICATIONS ...............................................................................................................5 I.S. R ECORDS AND R EPORTING . ..........................................................................................................5 I.T. R EOPENING FOR C AUSE . ...............................................................................................................7 I.U. I NVENTORY R EQUIREMENTS . .......................................................................................................7 SECTION II: SPECIAL PROVISIONS................................................................................................. ..8 II.A. E MISSION U NIT ( S ) P ERMITTED TO D ISCHARGE A IR C ONTAMINANTS ..........................................8 II.B. R EQUIREMENTS AND LIMITATIONS ...............................................................................................9 II.B.1 Conditions on permitted source (Source-wide) ................................................................. 9 II.B.2 Conditions on Emergency Generators (Unit GEN) ........................................................ 19 II.B.3 Conditions on Quarry Operation s & Stockpiles (Unit Quarry) .................................... 20 II.B.4 Conditions on Impact Crusher & Co nveying Operations (Unit Crusher) ................... 22 II.B.5 Conditions on Coal Milling, Processing & Conveying (Unit Coal) ................................ 25 II.B.6 Conditions on In-Line Kiln/Raw Mill (Unit C-Kiln) ...................................................... 26 II.B.7 Conditions on Clinker Cooler (Unit C-Cooler) ............................................................... 34 II.B.8 Conditions on Finish Mill Operations (Unit C-FinishMill) ............................................ 37 II.B.9 Conditions on Material handling operations - Group 1 (Unit MHO-1) ........................ 37 II.B.10 Conditions on Material handling operations - Group 2 (Unit MHO-2) ........................ 38 II.B.11 Conditions on Material handling operations - Group 3 (Unit MHO-3) ........................ 39 II.C. E MISSIONS T RADING ...................................................................................................................40 II.D. A LTERNATIVE O PERATING S CENARIOS ......................................................................................40 SECTION III: PERMIT SHIELD..................................................................................................... ......40 SECTION IV: ACID RAIN PROVISIONS............................................................................................40Issued under authority of Utah Code Ann. Sect ion 19-2-104 and 19-2-109. 1, and in accordance with Utah Administrative Code R307-415 Operating Permit Requirements.
All definitions, terms and abbreviations used in this permit conform to those used in Utah Administrative Code R307-101 and R307-415 (Rules), and 40 Code of Federa l Regulations (CFR), except as otherwise defined in this permit. Unl ess noted otherwise, references cited in the permit conditions refer to the Rules.

Where a permit condition in Section I, General Provisions, partially recites or summarizes an applicable rule, the full text of the applicable por tion of the rule shall govern interpretations of the requirements of the rule. In the case of a conflict between the Rules and the permit terms and conditions of Section II, Special Provisions, the perm it terms and conditions of Section II shall govern except as noted in Provision I.M, Permit Shield.



## Section I: General Provisions

I.A. Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the potential to emit, are enforceable by the EPA and citizen s under the Clean Air Act of 1990 (CAA) except those terms and conditions that are specifically designated as "State Requirements". (R307-415- 6b)

I.B. Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permitt ee may not operate except in compliance with this permit. (See also Provision I.E, Application Shield)

I.C. Duty to Comply.

I.C.1 The permittee must comply with all conditi ons of the operating permit. Any permit noncompliance constitutes a violation of the Air C onservation Act and is grounds for any of the following: enforcement action; permit termination; revocation and reissuance; modification; or denial of a permit renewal a pplication. (R307-415-6a(6)(a))

I.C.2 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 perm it. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Executive Secret ary, within a reasonable time, any information that the Executive Secretary may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Execu tive Secretary copies of records required to be kept by this permit or, for information claimed to be confidential, the permittee may furnish such records directly to the EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned ch anges or anticipated noncompliance shall not stay any permit condition, except as provided under R307 -415-7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Revised November 13, 2006 Page 1 Title V Operating Permit #2900001001I.D. Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on July 19, 2009 . (R307-415- 6a(2))

I.D.2 Application for renewal of this permit is due by January 19, 2009. An application may be submitted early for any reas on. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for processing, but shall not be considered a timely application and shall not relieve the permittee of any enforcement actions resulting from submitti ng a late application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted consistent with R307-415-7b (see also Prov ision I.E, Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

I.E. Application Shield.

If the permittee submits a timely and complete app lication for renewal, the permittee's failure to have an operating permit will not be a violation of R307-415, until the Executive Secretary takes final action on the permit renewal application. In such case, the terms and conditions of this permit shall remain in force until permit renewal or denial. This protection shall cease to apply if, subsequent to the completeness determinati on required pursuant to R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline specified in writing by the Executive Secretary any additional informa tion identified as being needed to process the application. (R307-415-7b(2))

I.F. Severability.

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 rema in valid and in force. (R307-415-6a(5))

I.G. Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Executive Secretary consistent with R307- 415-9. (R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

I.H. No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege. (R307- 415-6a(6)(d))

I.I. Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar pr ograms or processes for changes that are provided for in this permit. (R307-415-6a(8))

I.J. Inspection and Entry.

Revised November 13, 2006 Page 2 Title V Operating Permit #2900001001I.J.1 Upon presentation of credentials and other documen ts as may be required by law, the permittee shall allow the Executive Secretary or an aut horized representative to perform any of the following:

I.J.1.a Enter upon the permittee's prem ises where the source is located or emissions related activity is conducted, or where records are kept under the conditions of this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the conditions of this perm it. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practice, or ope ration regulated or required under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with this permit or app licable requirements. (R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

I.K. Certification.

Any application form, report, or compliance certif ication submitted pursuant to this permit shall contain certification as to its truth, accuracy, and completeness, by a responsible official as defined in R307-415-3. This cer tification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (R307-415-5d)

I.L. Compliance Certification.

I.L.1 Permittee shall submit to the Executive Secretar y an annual compliance certification, certifying compliance with the terms and conditions containe d in this permit, including emission limitations, standards, or work practices. This certif ication shall be submitted no later than July 30, 2005 and that date each year following until this permit e xpires. The certification shall include all the following (permittee may cross-reference this pe rmit or previous repor ts): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the certification;

I.L.1.b The identification of the methods or other m eans used by the permittee for determining the compliance status with each term and condition during the certification period. Such methods and other means shall include, at a minimum, the monitoring and related recordkeeping and reporting requirements in th is permit. If necessary, the permittee also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Act, which prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms a nd conditions of the permit for the period covered by the certification, including whether compliance during the period was continuous or intermittent. The certificat ion shall be based on the method or means

Revised November 13, 2006 Page 3 Title V Operating Permit #2900001001designated in Provision I.L.1.b. The certifica tion shall identify each deviation and take it into account in the compliance certification. The certification shall also identify as possible exceptions to compliance any peri ods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 occurred; and

I.L.1.d Such other facts as the Executive Secretar y may require to determine the compliance
status.

I.L.2 The permittee shall also submit all compliance cer tifications to the EPA, Region VIII, at the following address or to such other address as ma y be required by the Executive Secretary: (R307-415-6c(5)(d))

Office of Enforcement, Compliance and Environmental Justice (Mail code 8ENF) EPA, Region VIII 999 18th Street, Suite 300 Denver, CO 80202-2466

I.M. Permit Shield.

I.M.1 Compliance with the provisions of this permit sh all be deemed compliance with any applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the sour ce are specifically identified and listed in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of th e source for any violation of applicable requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Executive Secretary to obtain information from the source under Utah Code Ann. Section 19-2-120, and the ability of the EPA to obtain information from the source under the CAA Section 114. (R307-415-6f(3)(d))

I.N. Emergency Provision.

I.N.1 An “emergency” is any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, an d that causes the source to exceed a technologyRevised November 13, 2006 Page 4 Title V Operating Permit #2900001001based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. An emergenc y shall not include noncompliance to the extent caused by improperly designed equi pment, lack of preventive maintenance, careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defen se to an action brought for noncompliance with such technology-based emission limitations if the affirmative defense is demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency. (R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time bei ng properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emissi on standards, or other requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergenc y to the Executive Secretary within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any other section of this permit. (R307-415-6g(5))

I.O. Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P. Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q. Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R. Permit Modifications.

Permit modifications are governed by R307-415-7f.

I.S. Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data a nd support information shall be retained by the permittee for a period of at least five years from the date of the monitoring sample,

Revised November 13, 2006 Page 5 Title V Operating Permit #2900001001measurement, report, or application. Su pport information includes all calibration and maintenance records, all original strip-charts or appropriate recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. (R307-415- 6a(3)(b)(ii)

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall record the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to th e Executive Secretary every six months, or more frequently if specified in Section II. All instances of deviation from permit requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I. S.2.a shall be certified by a responsible official in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c The Executive Secretary shall be notified promptly of any deviations from permit requirements including those attributable to up set conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventative measures taken. Prompt, as used in this condition, sha ll be defined as written notification within 14 days . Deviations from permit requirements due to unavoidable breakdowns shall be reported in accordance with the provi sions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the Executive Secretary are to be sent to the following address or to such other address as may be required by the Executive Secretary:

Utah Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84114-4820 Phone: 801-536-4000

Revised November 13, 2006 Page 6 Title V Operating Permit #2900001001I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to the EPA should be sent to one of the follow ing addresses or to such other address as may be required by the Executive Secretary:

For annual compliance certifications For reports, notifications, or other correspondence related to permit modifications, applications, etc. Environmental Protection Agency, Region VIII Office of Enforcement, Compliance and Environmental Justice (mail code 8ENF) 999 18th Street, Suite 300 Denver, CO 80202-2466 Environmental Protection Agency, Region VIII Office of Partnerships & Regulatory Assistance Air & Radiation Program (mail code 8P-AR) 999 18th Street, Suite 300 Denver, CO 80202-2466 Phone: 303-312-6440

I.T. Reopening for Cause.

I.T.1 A permit shall be reopened and revised u nder any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining permit term of three or more years. No such reopening is required if the effective date of the requirement is later than the date on wh ich this permit is due to expire, unless the terms and conditions of this permit have been extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Executive Secretary or EPA determines that this permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Executive Secretary determines that this permit must be revised or revoked to assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to beco me effective before the renewal date of this permit and are in conflict with ex isting permit conditions. (R307-415-7g(1)(e))

I.T.2 Proceedings to reopen and issue a permit sha ll follow the same procedures as apply to initial permit issuance and shall affect only those parts of this permit for which cause to reopen exists. (R307-415-7g(2))

I.U. Inventory Requirements.

Emission inventories shall be submitted in acco rdance with the procedures of R307-150, Emission Inventories. (R307-150)

Revised November 13, 2006 Page 7 Title V Operating Permit #2900001001

## Section II: SPECIAL PROVISIONS

II.A. Emission Unit(s) Permitted to Discharge Air Contaminants. (R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Emergency Generators (designated as Unit GEN) Unit Description: Two diesel-powered emerge ncy backup generators, approx 755 HP and 166 HP. II.A.2 Quarry Operations & Stockpiles (designated as Unit Quarry) Unit Description: Drilling operations, rock blas ting, truck loading, rock fall from dozer push, haul roads, limestone & sand storage piles and Cement Kiln Dust (CKD) storage pile. The drill rig is equipped with a baghouse. II.A.3 Impact Crusher & Conveying Operations (designated as Unit Crusher) Unit Description: Dump pocket/feeder (#211-AF1), impact crusher, conveyors and associated transfer points, with emissions controlled by baghouses (#291-BFx) or enclosures. II.A.4 Preblending Hall (designated as Unit MSA) Unit Description: Limestone & sandstone are pr e-blended in an enclosed blending hall. II.A.5 Coal Milling, Processing & Conveying (designated as Unit Coal) Unit Description: Equipment for the handling, conveying, storage and milling of coal. Emissions are controlled by baghouses: HAC #L61-BF1 (mill discharge) and #L91-BF1 (bin vent). Equipment does not include conveying system used to convey coal from the mill to the kiln. II.A.6 Raw Meal Preparation System (designated as Unit C-RawMealPrep) Unit Description: Equipment used in preparation of kiln feed (raw meal), including material transfer points, conveyors, ba g filters, bins. (HAC #31x-xxx to 39x-xxx excluding #361-RM1) II.A.7 Clinker Manufacture System - MHO (designated as Unit C-Clinker) Unit Description: Equipment for the calcination of raw material, including material transfer points, conveyors, bag filters, bins (HAC #411-xxx, 431-xxx, 4A1-xxx except 4A1-BFx). II.A.8 Coal Transfer Equipment (designated as Unit C-Coal) Unit Description: Equipment in the clinker manufacturing system for transfers from coal mill to the kiln (HAC #L91-xxx). II.A.9 In-Line Kiln/Raw Mill (designated as Unit C-Kiln) Unit Description: Emissions from five-stage kiln system (HAC #44 1-xxx, 461-xxx) and raw mill (#361-RM1) are controlled by main baghouse (#421-BF1). Alkali bypass emissions are controlled by baghouse (#4A1-BF1). Both baghouses exit through the main stack. II.A.10 Clinker Cooler (designated as Unit C-Cooler) Unit Description: Grate cooler (#417-GQ1) fo r cooling clinker, controlled by baghouse (#471-BF1). II.A.11 Clinker Cooler System - MHO (designated as Unit C-CoolerSys) Unit Description: Transfer equipment and dust control for clinker cooler system. (HAC #47x-xxx to 49x-xxx excluding 471-BF1, 471-GQ1). II.A.12 Finish Mill Operations (designated as Unit C-FinishMill) Unit Description: Equipment for grinding of clinker and additive addition, including material transfer points, conveyors, bag f ilters, bins. (HAC #52x- xxx to 59x-xxx, K93- xxx & T93-xxx)

Revised November 13, 2006 Page 8 Title V Operating Permit #2900001001II.A.13 Packing & Distribution system (designated as Unit C-Packing) Unit Description: Equipment for shipping of cement products: conveyor transfer points, bins, bag filters and other mi scellaneous transfer points. (HAC #61x-xxx to 6Ex-xxx) II.A.14 Material handling operations - Group 1 (designated as Unit MHO-1) Unit Description: All totally-enclosed storag e bins, conveying system transfer points, bagging systems, and bulk loading/unloading systems identified in 40 CFR 63.1340, Subpart LLL as affected sources. II.A.15 Material handling operations - Group 2 (designated as Unit MHO-2) Unit Description: All partially-enclosed or unenclosed storage bins, conveying system transfer points, bagging systems, and bulk loading/unloading systems identified in 40 CFR 63.1340, Subpart LLL as affected sources. II.A.16 Material handling operations - Group 3 (designated as Unit MHO-3) Unit Description: All partially- or totally-enclosed storage bins, conveying system transfer points, bagging systems, and bulk loading/unloading systems identified in 40 CFR 63.1340, Subpart LLL as affected sour ces and that are equipped with a control device (PMCD).

II.B. Requirements and limitations. The following emission limitations, standards, and operational limitations apply to the permitted facility as indicated: (R307-415-6a(1))

II.B.1 Conditions on permitted source (Source-wide)

II.B.1.a Condition: Sulfur content of coal or any mixture of coals burned shall be no greater than 1.0 lb sulfur per MMBTU heat input. [Authority grante d under R307-401-8(1 )(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.1.a.1 Monitoring: Certification of fuels shall be either by permittee’s testing or test reports from the fuel marketer. Methods for determining su lfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307- 203-1(4)

( a ) For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used. ( b ) For determining sulfur content in oil, ASTM Methods D2880-71 or D4294- 89 are to be used. ( c ) For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used.

II.B.1.a.2 Recordkeeping: Results from laboratory analysis or vendor certifications shall be maintained in accordance with Provision S.1 in Section I of this permit.

II.B.1.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

Revised November 13, 2006 Page 9 Title V Operating Permit #2900001001II.B.1.b Condition: The permittee shall prepare and implement an operation and maintenance (O & M) plan in accordance with 40 CFR 63.1350(a). The pl an shall include the following elements:

(A) Procedures for proper operation and main tenance of the affected source and air pollution control devices in order to meet the emission and operating limits of this permit.

(B) Corrective actions to be taken if visibl e emissions are observed from the raw mill and finish mill sweep and air separator pollution control devices during a daily Method 22
test.

(C) Procedures to be used during an inspection of the components of the combustion system of the in-line kiln/raw mill which is to be performed at least once per year.

(D) Procedures to be used to periodically m onitor affected sources other than in-line kiln/raw mills, clinker coolers, and finish mills which are subject to opacity standards.

Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard. [Authority granted under 40 CFR 63.1350; condition originated in 40 CFR 63 Subpart LLL]

II.B.1.b.1 Monitoring: Records required for this permit cond ition will serve as monitoring.

II.B.1.b.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.1.b.3 Reporting: In addition to the requirements in Secti on I of this permit, one summary report shall be submitted semiannually for th e hazardous air pollutants monitored at each affected source. The summary re port shall be entitled "Summary Report - Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the following information:

(A) The company name and address of the affected source; (B) An identification of each hazardous air pollutant monitored at the affected
source; (C) The beginning and ending dates of the reporting period; (D) A brief description of the process units; (E) The emission and operating parame ter limitations from 40 CFR 63 Subpart LLL; (F) The monitoring equipment manufacturer(s) and model number(s);

Revised November 13, 2006 Page 10 Title V Operating Permit #2900001001(G) All exceedances of maximum control device inlet gas temperature limits; (H) All failures to calibrate thermoc ouples and other temperature sensors as required, (I) All failures to maintain the activated carbon injection rate, and the activated carbon injection carrier gas flow rate or pressure drop, as applicable; (J) The results of any combustion sy stem component inspections conducted within the reporting period; (K) All failures to comply with any provision of the operation and maintenance plan; (L) The date of the latest CMS certification or audit; (M) The total operating time of the affected source during the reporting period; (N) An emission data summary (or similar summary if the owner or operator monitors control system parameters), including the total duration of excess emissions during the reporting period (recorded in minutes for opacity and hours for gases), the total duration of excess emissions expressed as a percent of the total source operating time during that re porting period, and a breakdown of the total duration of excess emissions during the reporting period into those that are due to startup/shutdown, control equipment problems, process problems, other known causes, and other unknown causes; (O) A CMS performance summary (or similar summary if the owner or operator monitors control system parameters), including the total CMS downtime during the reporting period (recorded in minutes for opacity and hours for gases), the total duration of CMS downtime expressed as a percent of the total source operating time during that reporting period, and a breakdown of the total CMS downtime during the reporting period into periods that are due to monitoring equipment malfunctions, nonmonitoring equipment malfunctions, quality assurance/quality control calibrations, other known causes, and other unknown
causes; (P) A description of any changes in CMS, processes, or controls since the last reporting period; (Q) The name, title, and signature of the r esponsible official who is certifying the accuracy of the report; and (R) The date of the report.

The owner or operator shall submit all reports to the Executive Secretary as well as a copy of each report to the EPA Regional office at:

EPA Region VIII Director Air and Toxics Division 999 18th St. 1 Denver Place, Suite 300 Denver, CO 80202-2405

The regional office may waive this requirement for any reports at its discretion. (origin: 40 CFR 63.10(e)(3)(vi) via 40 CFR 63.1354(b)(9))

Revised November 13, 2006 Page 11 Title V Operating Permit #2900001001II.B.1.c Condition: For all emission units subject to 40 CFR 63 Subpart LLL:

(i) The permittee must implement a written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining the affected emission unit during periods of startup, shutdown, and ma lfunction, and a program of corrective action for malfunctioning process and air pollution c ontrol and monitoring equipment used to comply with the relevant standard. [40 CFR 63.6(e)(3)(i)]

(ii) During periods of startup, shutdown, a nd malfunction, the permittee must operate and maintain the affected emission unit (incl uding associated air pollution control and monitoring equipment) in accordance with th e procedures specified in the startup, shutdown, and malfunction plan developed under paragraph (i) of this condition. [40 CFR 63.6(3)(3)(ii)]

(iii) The permittee must maintain a current startup, shutdown, and malfunction plan and must make the plan available upon request for inspection and copying by the Executive Secretary. In addition, if the startup, s hutdown, and malfunction pl an is subsequently revised as provided in paragraph (v) of this condition, the permittee must maintain each previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, and must make each such previous version av ailable for inspection and copying by the Executive Secretary for a period of 5 years after revision of the plan. If at any time after adoption of a startup, shutdown, and malfunction plan the affected emission unit ceases operation or is otherwise no longer subject to the provisions of 40 CFR 63, the permittee must retain a copy of the most recent plan for 5 years from the date the affected emission unit ceases operation or is no longer subject to 40 CFR 63 and must make the plan available upon request for inspection and co pying by the Executive Secretary. [40 CFR 63.6(e)(3)(v)]

(iv) To satisfy the requirements of this c ondition to develop a startup, shutdown, and malfunction plan, the permittee may use the affected emission unit's standard operating procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) or other plan, provided the alternative plans meet all the requirements of this condition and are made available for inspection when requested by the Executive Secretary. [40 CFR 63.6(e)(3)(vi)]

(v) The permittee may periodically revise the startup, shutdown, and malfunction plan as necessary to satisfy the requirements of 40 CF R 63 or to reflect changes in equipment or procedures at the affected emission unit. Ho wever, each such revision to a startup, shutdown, and malfunction plan must be reported in the semiannual report required by this permit. If the startup, shutdown, and ma lfunction plan fails to address or inadequately addresses an event that meets the characteris tics of a malfunction but was not included in the startup, shutdown, and malfunction plan at the time the permittee developed the plan, the permittee must revise the startup, shutdown, and malfunction plan within 45 days after the event to include detailed procedur es for operating and maintaining the affected emission unit during similar malfunction events and a program of corrective action for similar malfunctions of process or air polluti on control and monitoring equipment. In the event that the permittee makes any revision to the startup, shutdown, and malfunction plan which alters the scope of the activiti es at the affected emission unit which are deemed to be a startup, shutdown, or malfunction, or otherwise modifies the applicability

Revised November 13, 2006 Page 12 Title V Operating Permit #2900001001of any emission limit, work practice requirement, or other requirement in a standard established under 40 CFR 63, the revised plan shall not take effect until after the permittee has provided a written notice d escribing the revision to the permitting authority. [40 CFR 63.6(e)(3)(viii)]

(vi) Any revisions made to the startup, shutdown, and malfunction plan in accordance with the procedures established by 40 CFR 63 shall not be deemed to constitute permit revisions under this permit. Moreover, none of the procedures specified by the startup, shutdown, and malfunction plan shall be deemed to fall within the permit shield provision in this permit. [40 CFR 63.6(e)(3)(ix)] [Authority granted under 40 CFR 63 Subpart A, LLL; condition originated in DAQE-AN0007019-06]

II.B.1.c.1 Monitoring: Records required for this permit cond ition will serve as monitoring.

II.B.1.c.2 Recordkeeping: The permittee shall maintain relevant records for the affected emission unit of—

(i) The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment); [40 CFR 63.10(b)(2)(i)]

(ii) The occurrence and duration of each malfunction of the required air pollution control and monitoring equipment; [40 CFR 63.10(b)(2)(ii)]

(iii) All required maintenance performed on the air pollution control and monitoring equipment; [40 CFR 63.10(b)(2)(iii)]

(iv) Actions taken during periods of startup, shutdown, and malfunction (including corrective actions to rest ore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) when such actions are different from th e procedures specified in the startup, shutdown, and malfunction plan; [40 CFR 63.10(b)(2)(iv)]

(v) All information necessary to demons trate conformance with the startup, shutdown, and malfunction plan when all ac tions taken during periods of startup, shutdown, and malfunction (including corrective actions to restore malfunctioning process and air pollution cont rol and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. These records may take the fo rm of a "checklist," or other effective form of recordkeeping that confirms conformance with the startup, shutdown, and malfunction plan for that event. [40 CFR 63.6(e)(3)(iii) & 40 CFR 63.10(b)(2)(v)]

(vi) If an action taken by the permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the startup, shutdown, and malfunction plan, and the affected emission unit exceeds any applicable emission limitation in the relevant emission standard, then the permittee must record the actions taken for that event. [40 CFR 63.6(e)(3)(iv)]

Revised November 13, 2006 Page 13 Title V Operating Permit #2900001001The permittee shall maintain files of all information (including all reports and notifications) required by this condition r ecorded in a form suitable and readily available for expeditious inspection and revi ew. 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 s ite. The remaining three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. [40 CFR 63.1355(a) & 40 CFR 63.10(b)(1)]

Requirements of Provision I.S.1 of this permit also apply.

II.B.1.c.3 Reporting: In addition to the reporting requirements speci fied in Section I of this permit, in the event of a startup, shutdown or malfunction, the following reporting requirements shall be followed:

Periodic startup, shutdown, and malfunc tion reports. 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 startup, shutdown, and malfunction plan, the permitt ee shall state such information in a startup, shutdown, and malfunction report. Otherwise, such a report shall identify any instance where any action taken by a permittee during a startup, shutdown, or malfunction (including actions taken to co rrect a malfunction) is not consistent with the startup, shutdown, and malfunction plan, but the affected emission unit does not exceed any applicable emission limitation in the relevant emission standard. Such a report shall also incl ude the number, duration, and a brief description for each type of malfuncti on which occurred during the reporting period and which caused or may have cau sed any applicable emission limitation to be exceeded. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the responsible official who is certifying its accuracy, that shall be submitted to the Executive Secretary semi annually. The startup, shutdown, and malfunction report shall be delivered or postmarked by the 30th day following the end of each calendar half. The start up, shutdown, and malfunction report may be submitted simultaneously with th e excess emissions and continuous monitoring system performance reports. [40 CFR 63.1354(b)(4) & 40 CFR 63.10(d)(5)(i) & 40 CFR 63.6(e)(3)(iii)]

Immediate startup, shutdown, and malfunction reports. If 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 specified in the startup, shutdown, and malfunction plan , the permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event. The immediate report required unde r this paragraph shall consist of a telephone call or facsimile (FAX) transmission to the Executive Secretary within 2 working days after commencing actions in consistent with the plan, and it shall be followed by a letter, delivered or pos tmarked within 7 working days after the end of the event, that contains the na me, title, and signature of the responsible

Revised November 13, 2006 Page 14 Title V Operating Permit #2900001001official who is certifying its accuracy, expl aining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and describing all excess emissions and/or parameter monitoring exceedances which are believed to have occurred. [40 CFR 63.6(e)(3)(iv) & 40 CFR 63.10(d)(5)(ii) & 40 CFR 63.1354(b)(5)]

II.B.1.d Condition: Sulfur content of the any fuel oil combusted shall be no greater than 0.85 lbs sulfur per MMBTU heat input. [Authority granted under R307-401-8(1)(a ) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.1.d.1 Monitoring: Certification of fuels shall be either by permittee’s testing or test reports from the fuel marketer. Methods for determining su lfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307- 203-1(4)

( a ) For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used. ( b ) For determining sulfur content in oil, ASTM Methods D2880-71 or D4294- 89 are to be used. ( c ) For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used.

II.B.1.d.2 Recordkeeping: Results from laboratory analysis or vendor certifications shall be maintained in accordance with Provision S.1 in Section I of this permit.

II.B.1.d.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.e Condition: At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent practicable, maintain and opera te any permitted plant equipment, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are be ing used will be based on information available to the Executive Secretary which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [Authority grante d under R307-401-8(2) and 40 CFR 60.11(d); condition originated in DAQE-AN0007019-06]

II.B.1.e.1 Monitoring: Records required for this permit cond ition will serve as monitoring.

II.B.1.e.2 Recordkeeping: Permittee shall document activities performed to assure proper operation and maintenance. Records shall be maintain ed in accordance with Provision I.S.1 of this permit.

Revised November 13, 2006 Page 15 Title V Operating Permit #2900001001II.B.1.e.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.f Condition: All unpaved roads and other unpaved operati onal areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. Treatment shall be of sufficient frequency and quantity to maintain surface material in a damp/moist condition unless the temperature is below freezing. If chemical treatment is to be used, the plan must be approved by the Executive Secretary. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.1.f.1 Monitoring: Records required for this permit cond ition will serve as monitoring.

II.B.1.f.2 Recordkeeping: Instances of water and/or chemical appli cation to unpaved areas shall be recorded and maintained by the permittee. The r ecords shall include the following:

(1) Date. (2) Number of treatments made, dilution ratio, and quantity. (3) Precipitation received, if any, and approximate amount. (4) Time of day that treatments are made. (5) Records of temperature if the temperature is below freezing.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit. II.B.1.g Condition: The permittee shall comply with the appli cable requirements for servicing of motor vehicle air conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. [Authority granted under 40 CFR 82.30(b); condition originated in 40 CFR 82] II.B.1.g.1 Monitoring: The permittee shall certify, in the a nnual compliance statement required in Section I of this permit, its compliance status with the requirements of 40 CFR 82, Subpart B. II.B.1.g.2 Recordkeeping: All records required in 40 CFR 82, Subpart B shall be maintained consistent with the requirements of Provision S.1 in Section I of this permit. II.B.1.g.3 Reporting: All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no additional reporting requiremen ts except as outlined in Section I of this permit.

Revised November 13, 2006 Page 16 Title V Operating Permit #2900001001II.B.1.h Condition: The permittee shall comply with the applicab le requirements for recycling and emission reduction for class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction. [Authority granted under 40 CFR 82.150(b); condition originated in 40 CFR 82]

II.B.1.h.1 Monitoring: The permittee shall certify, in the a nnual compliance statement required in Section I of this permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.h.2 Recordkeeping: All records required in 40 CFR 82, Subpart F shall be maintained consistent with the requirements of Provision S.1 in Section I of this permit.

II.B.1.h.3 Reporting: All reports required in 40 CFR 82, Subpar t F shall be submitted as required. There are no additional reporting requiremen ts except as outlined in Section I of this permit.

II.B.1.i Condition:

Emissions of SO 2 shall be no greater than 457 tons per rolling 12 month total. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019- 06]

II.B.1.i.1 Monitoring: The permittee shall install, calibrate, maintain, and continuously operate a continuous emissions monitoring system on the kiln main stack. The permittee shall record the output of the system for measuring the SO 2 emissions. The monitoring system shall comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B. Except for system breakdown, repairs, calibration checks, and zero and span adjustment s required under paragraph (d) 40 CFR 60.13, the permittee shall continuously operate all required continuous monitoring devices and shall meet mini mum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

II.B.1.i.2 Recordkeeping: The permittee shall keep the records spec ified in R307-170-8 and any additional records required by provision I.S.1 of this permit. These records shall be maintained in accordance with Provision I.S.1.

II.B.1.i.3 Reporting: The permittee shall comply with the re porting provisions in R307-170-7(5), R307-170-9 and Section I of this permit. For the purposes of I.S.2.c of this permit, prompt for this condition sha ll be defined as written notification by January 30, April 30, July 30, and October 30 for any deviations which occurred during the quarter which ended 30 days earlier.

Revised November 13, 2006 Page 17 Title V Operating Permit #2900001001II.B.1.j Condition: Mining operations and transporting of materi als from the mine to the plant shall be limited to between 5:00 a.m. and 8:00 p.m. each day. [Authority granted under R307- 401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06] II.B.1.j.1 Monitoring: Records required for this permit cond ition will serve as monitoring. II.B.1.j.2 Recordkeeping: Records shall be kept when mining opera tions and transporting of materials from the mine to the plant occur outside of th e schedule listed above. Records shall be maintained in accordance with Provision I.S.1 of this permit. II.B.1.j.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.k Condition:

Emissions of PM 10 from fugitive sources at and around th e plant shall be controlled to a level consistent with maintaining a 0.2 g/m 2 silt loading level on paved surfaces. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0007019-06]

II.B.1.k.1 Monitoring: Silt loading shall be measured at least once each month under a protocol submitted to the Executive Secretary for approval.

II.B.1.k.2 Recordkeeping: Results of monitoring shall be recorded at least once each month and shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.k.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.l Condition: The permittee shall continue off-site post-construction monitoring of PM 10 for a minimum of one year beginning January 12, 2006. [Authority granted under R307-401- 8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.1.l.1 Monitoring: The permittee shall perform the off-sit e post-construction monitoring of PM 10 on a daily basis. After the one-year minimum, and upon acceptance and approval of the monitoring results, the permittee ma y petition the Executive Secretary to cease monitoring.

II.B.1.l.2 Recordkeeping: Results of monitoring shall be maintain ed in accordance with Provision I.S.1 of this permit.

Revised November 13, 2006 Page 18 Title V Operating Permit #2900001001II.B.1.l.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.m Condition:

All PM 10 stack emission releases shall be vented vertically without any restriction to upward momentum at or beyond the stack ope ning. [Authority granted under R307-401- 8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.1.m.1 Monitoring: Records required for this permit cond ition will serve as monitoring.

II.B.1.m.2 Recordkeeping: Records shall be kept of each PM 10 stack that does not meet the venting requirements in the above condition. Re cords shall be main tained in accordance with Provision I.S.1 of this permit.

II.B.1.m.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.2 Conditions on Emergency Generators (Unit GEN)

II.B.2.a Condition: Hours of operation for maintenance purposes sh all be no greater than 60 hours total per generator per rolling 12-month period. [A uthority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.2.a.1 Monitoring: By the 20th day of each month, the permittee shall calculate the total hours of operation in the previous 12 months for maintenance firing purposes for each affected emission unit. Hours of operation for each affected emission unit shall be determined by an hour meter and/or a log.

II.B.2.a.2 Recordkeeping: Records of hours of operation for maintenance firing purposes shall be kept on a monthly basis. Results of monitoring shall be maintained as described in Provision I.S.1 of this permit.

II.B.2.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.2.b Condition: Visible emissions shall be no greater than 10 percent opacity. [Authority granted under R307-401-8(1)(a) [BACT]; condition or iginated in DAQE-AN0007019-06]

II.B.2.b.1 Monitoring: During any period that the emergency ge nerator(s) is(are) operated for longer than 12 hours consecutively, visual observa tion(s) of each generator exhaust shall be made by an individual trained on the observation procedures of 40 CFR 60,

Revised November 13, 2006 Page 19 Title V Operating Permit #2900001001Appendix A, Method 9. The individual is not required to be a certified visual emissions observer (VEO). If any visi ble emissions are observed, then an opacity determination shall be perfo rmed in accordance with 40 CFR 60, Appendix A, Method 9, by a certified VE O. If the generator(s) continue to operate on consecutive days following the initial observation, an opacity determination shall be performed on a daily basis.

II.B.2.b.2 Recordkeeping: The permittee shall record the date of eac h visual opacity survey and keep a list of the emission points checked during the visual opacity survey. The permittee shall also keep a log of the following information for each observed visual emission: date and time visual emissions observed, emission point location and description, time and date of opacity test, and percent opacity. The records required by this provision and all data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance w ith Provision I.S.1 of this permit.

II.B.2.b.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.3 Conditions on Quarry Operation s & Stockpiles (Unit Quarry)

II.B.3.a Condition: Visible emissions shall be no greater th an 20 percent opacity from unpaved roads & unpaved operational areas used by mobile equipment. [Authority granted under R307- 401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.3.a.1 Monitoring: An opacity survey of haul road traffi c and mobile equipment in operational areas shall be performed on a monthly basis in accordance with procedures similar to 40 CFR 60, Appendix A, Method 9. Th e opacity determination shall be performed as follows: The requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Six points, distributed along the length of the haul road or in the operational area shall be chosen either by the permittee or by the executive secretary or his/her representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made one-half the vehicle length or greater behind the vehicle and at approximately one-half the height of the vehicle or greater. The accumulated six readings shall be averaged for the compliance value.

II.B.3.a.2 Recordkeeping: Results of opacity observations shall be r ecorded and maintained as described in Provision S.1 in Section I of this permit.

II.B.3.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

Revised November 13, 2006 Page 20 Title V Operating Permit #2900001001II.B.3.b Condition: Visible emissions shall be no greater than 20 percent opacity from stockpiles. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019- 06]

II.B.3.b.1 Monitoring: A visual opacity survey of each affect ed emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9 for point sources, and in accordance 58 FR 61640 Method 203A for fugitive sources.

II.B.3.b.2 Recordkeeping: The permittee shall record the date of each visual opacity survey and a list of the emission points checked during the visual opacity survey. The permittee shall maintain all records required by this pr ovision and all data required by 40 CFR 60, Appendix A, Method 9 or by Method 203A in accordance with Provision I.S.1 of this permit.

II.B.3.b.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.3.c Condition: Visible emissions shall be no greater than 7 percent opacity from drill rig baghouse. [Authority granted under 40 CFR 60.672; condition originated in 40 CFR 60 Subpart OOO]

II.B.3.c.1 Monitoring: A visual opacity survey of each affect ed emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam are observed from an emission unit, an opacity determ ination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be perfo rmed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.3.c.2 Recordkeeping: The permittee shall record the date of each visual opacity survey and a list of the emission points checked during the visual opacity survey. The permittee shall maintain all records required by this pr ovision and all data required by 40 CFR 60, Appendix A, Method 9 or by Method 203A in accordance with Provision I.S.1 of this permit.

II.B.3.c.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

Revised November 13, 2006 Page 21 Title V Operating Permit #2900001001II.B.4 Conditions on Impact Crusher & Co nveying Operations (Unit Crusher)

II.B.4.a Condition: Visible emissions shall be no greater than 15 percent opacity from the crusher. [Authority granted under 40 CFR 60.672; condition originated in 40 CFR 60 Subpart OOO]

II.B.4.a.1 Monitoring: A visual opacity survey of each affect ed emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9 for point sources, and in accordance 58 FR 61640 Method 203A for fugitive sources.

II.B.4.a.2 Recordkeeping: The permittee shall record the date of each visual opacity survey and a list of the emission points checked during the visual opacity survey. The permittee shall maintain all records required by this pr ovision and all data required by 40 CFR 60, Appendix A, Method 9 or by Method 203A in accordance with Provision I.S.1 of this permit.

II.B.4.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4.b Condition: Visible emissions shall be no greater than 7 percent opacity from baghouse stacks. [Authority granted under 40 CFR 60.672; condition originated in 40 CFR 60 Subpart OOO]

II.B.4.b.1 Monitoring: A visual opacity survey of each affect ed emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam are observed from an emission unit, an opacity determ ination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be perfo rmed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.4.b.2 Recordkeeping: The permittee shall record the date of each visual opacity survey and a list of the emission points checked during the visual opacity survey. The permittee shall maintain all records required by this pr ovision and all data required by 40 CFR 60, Appendix A, Method 9 or by Method 203A in accordance with Provision I.S.1 of this permit.

Revised November 13, 2006 Page 22 Title V Operating Permit #2900001001II.B.4.b.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4.c Condition: Permittee shall install water sprays to control fugitive emissions in the crusher dump pocket. The sprays shall operate whenever dry conditions warrant or as determined necessary by the Executive Secret ary. Sprays shall not be required to operate during periods of freezing temperatures. [Author ity granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.4.c.1 Monitoring: Visual inspections shall be made monthl y to demonstrate compliance with this condition.

II.B.4.c.2 Recordkeeping: A log of the visual inspections shall be maintained in accord ance with Provision I.S.1 of this permit, including the date and time of each inspection and the name of the person making the inspection.

II.B.4.c.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4.d Condition: Visible emissions shall be no greater than 10 percent opacity for fugitive emissions from transfer points on belt conveyors or any other Subpart OOO affected facility. [Authority granted under 40 CFR 60.672; condition originated in 40 CFR 60 Subpart OOO]

II.B.4.d.1 Monitoring: A visual opacity survey of each affect ed emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are observed from an emission unit, an opacity determination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9 for point sources, and in accordance 58 FR 61640 Method 203A for fugitive sources.

II.B.4.d.2 Recordkeeping: The permittee shall record the date of each visual opacity survey and a list of the emission points checked during the visual opacity survey. The permittee shall maintain all records required by this pr ovision and all data required by 40 CFR 60, Appendix A, Method 9 or by Method 203A in accordance with Provision I.S.1 of this permit.

II.B.4.d.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

Revised November 13, 2006 Page 23 Title V Operating Permit #2900001001II.B.4.e Condition: Permittee shall install and operate baghouse dust collectors at all conveyor transfer points. The collectors shall operate whenev er dry conditions warrant or as determined necessary by the Executive Secretary. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.4.e.1 Monitoring: Visual inspections shall be made monthl y to demonstrate compliance with this condition.

II.B.4.e.2 Recordkeeping: A log of the visual inspections shall be maintained in accord ance with Provision I.S.1 of this permit, including the date and time of each inspection and the name of the person making the inspection.

II.B.4.e.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4.f Condition: Emissions of particulate matter (PM) shall be no greater than 0.05 g/dscm (0.022 gr/dscf) from the baghouse stacks. [Authority granted under 40 CFR 60.672; condition originated in 40 CFR 60 Subpart OOO]

II.B.4.f.1 Monitoring: Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested at least once every five years, based on the date of the last test. Tests may also be required at the direction of the Executive Secretary.

(b) Notification. At least 30 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) or Mi ne Safety and Health Administration (MSHA) approved access shall be provided to the test location.

(2) Sample Method - 40 CFR 60. Appendix A, Method 5 or Method 17 shall be used to determine the particulate matter concentration. The minimum sample volume shall be 1.70 dscm (60 dscf). 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 operate d at a temperature high enough, but no higher than 121 deg. C (250 deg F), to prevent water condensation on the filter.

Revised November 13, 2006 Page 24 Title V Operating Permit #2900001001(d) Calculations. To determine mass emi ssion rates (lb./hr., etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to gi ve the results in the specified units of the emission limitation.

(e) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years.

II.B.4.f.2 Recordkeeping: Results of all stack testing shall be r ecorded and maintained in accordance with the associated test method and Provision S. 1 in Section I of this permit.

II.B.4.f.3 Reporting: The results of stack testing shall be s ubmitted to the Executive Secretary within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. There are no additional reporting requirements for th is provision except those specified in Section I of this permit.

II.B.5 Conditions on Coal Milling, Processing & Conveying (Unit Coal)

II.B.5.a Condition: Visible emissions shall be no greater than 20 percent opacity. [Authority granted under 40 CFR 60.252; condition originated in 40 CFR 60 Subpart Y]

II.B.5.a.1 Monitoring: A visual opacity survey of each affect ed emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam are observed from an emission unit, an opacity determ ination of that emission unit shall be performed by a certified observer within 24 hours of the initial survey. The opacity determination shall be perfo rmed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.5.a.2 Recordkeeping: A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of this permit. If an opacity determination is performed, a notation of the determination will be made in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in accordance with Provision I.S.1 of this permit.

II.B.5.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

Revised November 13, 2006 Page 25 Title V Operating Permit #2900001001II.B.6 Conditions on In-Line Kiln/Raw Mill (Unit C-Kiln)

II.B.6.a Condition: Visible emissions shall be no greater than 20 percent opacity for all 6-minute block averages. [Authority granted under 40 CFR 63.1343; condition originated in 40 CFR 63 Subpart LLL]

II.B.6.a.1 Monitoring: Monitoring for this provision shall be as follows:

(1) Except as provided in paragraph (2) below, the permittee shall install, calibrate, maintain, and continuously opera te a COM located at the outlet of the affected unit's particulate matter contro l device to continuously monitor the opacity. The COM shall be installed, maintained, calibrated, and operated as required by R307-170, 40 CFR 63 subpart A and according to PS-1 of 40 CFR 60 appendix B.

(2) If an affected unit subject to this opa city limitation is controlled by a fabric filter with multiple stacks or an electrosta tic precipitator with multiple stacks, the permittee may, in lieu of installing the continuous opacity monitoring system required by paragraph (1), mon itor opacity in accordance with paragraphs (2)(i) through (ii) below. If the control device exhausts through a monovent, or if the use of a COM in accordance with the installation specifications of PS-1 of 40 CFR 60 appendix B is not feasible, the permittee shall monitor opacity in accordance with paragraphs (2)(i) through (ii) below. (i) Perform daily visual opacity ob servations of each stack in accordance with the procedures of 40 CFR 60 Method 9. The Method 9 test shall be conducted while the affected sour ce is operating at representative performance conditions. The duration of th e Method 9 test shall be at least 30 minutes each day. (ii) Use the Method 9 procedures to m onitor and record the average opacity for each six-minute period during the test. (origin: 40 CFR 63.1350)

II.B.6.a.2 Recordkeeping: Results of opacity observations from the COM shall be recorded and maintained as required in R307-170, 40 CFR 63.10(c), and as described in Provision I.S.1 of this permit. If a COM is not used, r ecords shall be main tained in accordance with the test method and Provision I.S.1 of this permit.

II.B.6.a.3 Reporting: Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring Program. The reports are considered prompt notification of permit deviation required in Provision I.S. 2.c of this permit, if all information required by Provision I.S.2.c is included in the report. If a COM is not used for monitoring, reports shall be submitted as required in Provision I.S.2 and the definition of 'prompt' shall be as given in I.S.2.c.

II.B.6.b Condition:

Emissions of PM 10 shall be no greater than 14 lbs/hr. [Authority granted under R307- 401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

Revised November 13, 2006 Page 26 Title V Operating Permit #2900001001II.B.6.b.1 Monitoring: Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every five years.

(b) Notification. The Executive Secretary shall be notified at least 30 days prior to conducting any required emission testi ng. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Executive Secretary. The source test protocol sh all be approved by the Executive Secretary prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1.

(2) For stacks in which no li quid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201A. 40 CFR 51, Appendix M, Method 202 shall be used to determine condensibles.

(3) For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5 or 5I as appropriate. The portion of the front half catch considered PM 10 shall be based on information in Appendix B of the fifth addition of the EPA document, AP-42, or other data acceptable to the Executive Secretary. Condensibles shall be determined using the back half catch.

(4) The condensibles shall not be used for compliance demonstration but shall be used for inventory purposes.

(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to gi ve the results in the specified units of the emission limitation.

(e) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years.

II.B.6.b.2 Recordkeeping: Results of all stack testing shall be r ecorded and maintained in accordance with the associated test method and Provision S. 1 in Section I of this permit.

II.B.6.b.3 Reporting: In addition to the reporting requirements of Section I of this permit, the permittee shall submit the results of the stack test s to the Executive Secretary within 60

Revised November 13, 2006 Page 27 Title V Operating Permit #2900001001days of completion of the testing. Resu lts shall clearly identify test results as compared to permit limits and indicate compliance status.

II.B.6.c Condition:

Emissions of SO 2 shall be no greater than 475 lbs/hr on a rolling 24-hour average. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0007019-06]

II.B.6.c.1 Monitoring: The permittee shall install, calibrate, maintain, and continuously operate a continuous emissions monitoring system on the kiln main stack. The permittee shall record the output of the system for measuring the SO 2 emissions. The monitoring system shall comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B. Except for system breakdown, repairs, calibration checks, and zero and span adjustment s required under paragraph (d) 40 CFR 60.13, the permittee shall continuously operate all required continuous monitoring devices and shall meet mini mum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

II.B.6.c.2 Recordkeeping: The permittee shall keep the records spec ified in R307-170-8 and any additional records required by provision I.S.1 of this permit. These records shall be maintained in accordance with Provision I.S.1.

II.B.6.c.3 Reporting: The permittee shall comply with the re porting provisions in R307-170-7(5), R307-170-9 and Section I of this permit. For the purposes of I.S.2.c of this permit, prompt for this condition sha ll be defined as written notification by January 30, April 30, July 30, and October 30 for any deviations which occurred during the quarter which ended 30 days earlier.

II.B.6.d Condition: Emissions of CO shall be no greater than 438 lbs/hr. [Authority granted under R307- 401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06]

II.B.6.d.1 Monitoring: Stack testing shall be performed as specified here:

(a) Frequency. The unit shall be tested at least once every two years based on the year of the most recent stack test. Tests may also be required at the direction of the Executive Secretary if the source is suspected to be in violation with other conditions of this permit.

(b) Notification. At least 30 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1. In addition, access that meets the standards of the Occupational Safety an d Health Administration (OSHA) or the

Revised November 13, 2006 Page 28 Title V Operating Permit #2900001001Mine Safety and Health Administration (MSHA) shall be provided to the test location.

(d) Methods.

(1) 40 CFR 60, Appendix A, Method 10 shall be used to determine CO emissions;

(2) 40 CFR 60, Appendix A, Method 2 shall be used to determine stack gas velocity and volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to gi ve the results in the specified units of the emission limitation.

(f) Production Rate During Testing. Th e operational rate during all compliance testing shall be no less than 90% of the maximum rate achieved in the previous three (3) years.

II.B.6.d.2 Recordkeeping: Results of all stack testing shall be r ecorded and maintained in accordance with the associated test method and Provision S. 1 in Section I of this permit.

II.B.6.d.3 Reporting: In addition to the reporting requirements of Section I of this permit, the permittee shall submit the results of the stack test s to the Executive Secretary within 60 days of completion of the testing. Resu lts shall clearly identify test results as compared to permit limits and indicate compliance status.

II.B.6.e Condition:

Emissions of NO x shall be no greater than 1,817 tons per rolling 12 month total. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0007019-06]

II.B.6.e.1 Monitoring: The permittee shall install, calibrate, maintain, and continuously operate a continuous emissions monitoring system on the kiln main stack. The permittee shall record the output of the system for measuring the NO x emissions. The monitoring system shall comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B. Except for system breakdown, repairs, calibration checks, and zero and span adjustment s required under paragraph (d) 40 CFR 60.13, the permittee shall continuously operate all required continuous monitoring devices and shall meet mini mum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

II.B.6.e.2 Recordkeeping: The permittee shall keep the records spec ified in R307-170-8 and any additional records required by provision I.S.1 of this permit. These records shall be maintained in accordance with Provision I.S.1.

Revised November 13, 2006 Page 29 Title V Operating Permit #2900001001II.B.6.e.3 Reporting: The permittee shall comply with the re porting provisions in R307-170-7(5), R307-170-9 and Section I of this permit. For the purposes of I.S.2.c of this permit, prompt for this condition sha ll be defined as written notification by January 30, April 30, July 30, and October 30 for any deviations which occurred during the quarter which ended 30 days earlier.

II.B.6.f Condition: The permittee shall use only the following fuels in the kiln:

A. Coal B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF) D. Natural Gas E. Coke F. Fuel Oil G. Used Oil H. Synthetic Fuel I. Wood J. Coal Additives consisting of alternative fuels approved by the Executive Secretary. Prior to burning any proposed coal additive, the permittee shall obtain approval from the Executive Secretary. To obtain approval, the permittee shall submit Material Safety Data Sheets (MSDS) or the resu lts of suitable tests giving data similar to a Proximate and Ultimate analysis of the proposed coal additive.

Approval by the Executive Secretary shall consist of a letter approving the use of the proposed coal additive. Approval is not required to change from one previously approved coal additive to anot her previously approved coal additive.

The average quantity of coal add itives burned shall not be greater than 15% of the total daily heat input of the k iln and precalciner. The permittee may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Executive Secretary in accordance with the approval process described for new coal a dditives above. [Authority granted under R307- 401- 8(1)(a) (BACT); condition originated in DAQE-AN0007019-06]

II.B.6.f.1 Monitoring: Records required for this permit cond ition will serve as monitoring.

II.B.6.f.2 Recordkeeping:

Records of material used as fuel in th e kiln shall be maintained. Copies of Executive Secretary approval of each coal additive shall be maintained. All records shall be maintained in accordance w ith provision I.S.1 of this permit.

II.B.6.f.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit. II.B.6.g Condition: The concentration of contaminants or paramete rs in any used oil fuel shall not exceed the following levels: Arsenic 5 ppm by weight, Cadmium 2 ppm by weight, Chromium 10

Revised November 13, 2006 Page 30 Title V Operating Permit #2900001001ppm by weight, Lead 100 ppm by weight, To tal Halogens 1,000 ppm by weight, Sulfur 0.5 percent by weight. Flash point of any used oil shall not be less than 100 degrees F. Any used oil fuel that contains more than 1, 000 ppm by weight of total halogens shall be considered a hazardous waste and shall not be burned in the kiln. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0007019-06] II.B.6.g.1 Monitoring: The permittee shall provide test certificat ion for each load of used oil fuel received. Certification shall be made either by permittee's testing or through test reports from the used oil fuel marketer. The oil shall be tested for halogen content using ASTM Method D-808-81, EPA Method 8240 or EPA Method 8260 before used oil fuel is burned. II.B.6.g.2 Recordkeeping: The permittee shall maintain records of fuel analyses or vendor documentation showing contaminant levels or property values for all used oil combusted. All records shall be documented and maintained consistent with the requirements of Provision S.1 in Section I of this permit. II.B.6.g.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.h Condition: As part of demonstration of compliance with the dioxin/furan emission limitation in this permit, the permittee shall operate the kiln such that the temperature of the gas at the inlet to the kiln particulate matter control device (PMCD) and alkali bypass PMCD, if applicable, does not exceed the applicable temperature limits (for both raw mill operating and not operating) as determined and established in accordance with 40 CFR 63.1349(b)(3)(iv). The permittee shall conduct an inspection of the components of the combustion system of each kiln or in-line kiln/raw mill at least once per year. [Authority granted under 40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 Subpart LLL]

II.B.6.h.1 Monitoring: (1) The permittee shall install, calibrate , maintain, and continuously operate a continuous monitor to record the temperature of the exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to, or upstream of, PM control devices. The recorder response range shall include zero and 1.5 times either of the average temperatures established during the performance test. The reference method shall be a National Institute of Standards and Technology calibrated reference thermocouple-potentiome ter system or alternate reference, subject to approval.

(2) The permittee shall monitor and cont inuously record the temperature of the exhaust gases from the kiln, in-line kiln/r aw mill and alkali bypass, if applicable, at the inlet to the PM control device.

(3) The three hour rolling average temper ature shall be calculated as the average 180 successive one-minute average temperatures.

Revised November 13, 2006 Page 31 Title V Operating Permit #2900001001(4) Periods of time when one-minute aver ages are not available shall be ignored when calculating three-hour rolling av erages. 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.

(5) When the operating status of the ra w mill of the in-line kiln/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.

(6) The calibration of all thermocouples a nd other temperature sensors shall be verified at least once every three months.

II.B.6.h.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.6.h.3 Reporting: Results shall be reported in the requi red MACT semi-annual summary report, and in accordance with Section I of this permit.

II.B.6.i Condition: Emissions of Dioxins/Furans (D/F) shall be no greater than 0.20 ng per dscm (8.7 x 10 ^- 11 gr per dscf) (TEQ) corrected to seven percent oxygen or 0.40 ng per dscm (1.7 x 10 ^- 10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the average of the performance test run average temperatures at th e inlet to the particulate matter control device is 204 deg. C (400 deg. F) or less. [Authority granted under 40 CFR 63 (Subpart LLL); condition originated in 40 CFR 63 Subpart LLL]

II.B.6.i.1 Monitoring: (a) Frequency. Emissions shall be test ed every 30 months based on the date of the most recent stack test. The source may also be tested at any time if directed by the Executive Secretary.

(b) Notification. At least 60 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved access shall be provided to the test location.

Revised November 13, 2006 Page 32 Title V Operating Permit #2900001001(2) 40 CFR 60, Appendix A, Method 23 shall be used to determine the pollutant emission rate.

(3) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate.

(4) Performance tests shall be conducted sep arately while the raw mill of the inline kiln/raw mill is under normal operati ng conditions and while the raw mill of the in-line kiln/raw mill is not operating. If the kiln or in-line kiln/raw mill is equipped with an alkali bypass, simultaneous performance tests of the kiln or inline kiln/raw mill exhaust and the alka li bypass shall be performed; however, a performance test of the alkali bypass exhaust may be conducted when the raw mill of the in-line kiln/raw mill is not operating.

(5) Each performance test shall consist of three separate runs; each run shall be conducted under the conditions that exist wh en the affected source is operating at the representative performance conditions in accordance with 40 CFR 63.7(e). The duration of each run shall be at least 3 hours, and the sample volume for each run shall be at least 2.5 dscm (90 dscf).

(6) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD, and where applicable, the temperature at the inlet to the alkali bypass PMCD, 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.

(7) One-minute average temperatures sh all be calculated for each minute of each run of the test.

(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 and will determine the applicable temperature limit in accordance with 40 CFR 63.1344(b).

(9) If activated carbon injection is used for D/F control, the rate of activated carbon injection to the kiln or in-line kiln /raw mill exhaust, and where applicable, the rate of activated carbon injection to the alkali bypass exhaust, must be continuously recorded during the period of the Method 23 test, and the continuous injection rate record(s) mu st be included in the performance test report. In addition, the performance test re port must include the brand and type of activated carbon used during the performance test and a continuous record of either the carrier gas flow rate or the carrier gas pressure drop for the duration of the test. The run average injection rate must be calculated for each run, and the average of the run average injection rates must be determined and included in the performance test report and will determine th e applicable injection rate limit in accordance with §63.1344(c)(1).

(d) Calculations. The concentration sha ll be determined for each test run, and the arithmetic average of the concentrati ons measured for the three runs shall be calculated and used to determine compliance.

Revised November 13, 2006 Page 33 Title V Operating Permit #2900001001II.B.6.i.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.6.i.3 Reporting: In addition to the reporting requirements of Section I of this permit, the permittee shall submit the results of the performan ce tests to the Executive Secretary in a notification of compliance status within 60 days of completion of the testing. Results shall clearly identify test results as compared to permit limits and indicate compliance status. (origin: 40 CFR 63.1354(b)(1)) II.B.6.j Condition: Emissions of particulate matter (PM) sha ll be no greater than 0.15 kilograms per megagram (0.30 lb/ton) of feed (dry basi s). [Authority granted under 40 CFR 63.1343; condition originated in 40 CFR 63 Subpart LLL] II.B.6.j.1 Monitoring: The permittee shall conduct performance testing in accordance with 40 CFR 63.1349(b)(1) at least once every five years, based on the date of the initial performance test. II.B.6.j.2 Recordkeeping: Results of all stack testing shall be r ecorded and maintained in accordance with the associated test method and Provision S. 1 in Section I of this permit. II.B.6.j.3 Reporting: In addition to the reporting requirements of Section I of this permit, the permittee shall submit the results of the stack test s to the Executive Secretary within 60 days of completion of the testing. Resu lts shall clearly identify test results as compared to permit limits and indicate compliance status.

II.B.7 Conditions on Clinker Cooler (Unit C-Cooler)

II.B.7.a Condition: Production of clinker shall be no greater than 930,000 tons per rolling 12 month total. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0007019-06]

II.B.7.a.1 Monitoring: Compliance with the limitation shall be demonstrated through a rolling 12-month total. The permittee shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 m onths. Records shall be kept on a daily basis when in operation.

Revised November 13, 2006 Page 34 Title V Operating Permit #2900001001II.B.7.a.2 Recordkeeping: Results of monitoring shall be maintain ed in accordance with Provision I.S.1 of this permit.

II.B.7.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.7.b Condition: Visible emissions shall be no greater than 10 percent opacity for all 6-minute block averages. [Authority granted under 40 CFR 63.1345; condition originated in 40 CFR 63 Subpart LLL]

II.B.7.b.1 Monitoring: Monitoring for this provision shall be as follows:

(1) Except as provided in paragraph (2) below, the permittee shall install, calibrate, maintain, and continuously opera te a COM located at the outlet of the affected unit's particulate matter contro l device to continuously monitor the opacity. The COM shall be installed, maintained, calibrated, and operated as required by R307-170, 40 CFR 63 subpart A and according to PS-1 of 40 CFR 60 appendix B.

(2) If an affected unit subject to this opa city limitation is controlled by a fabric filter with multiple stacks or an electrosta tic precipitator with multiple stacks, the permittee may, in lieu of installing the continuous opacity monitoring system required by paragraph (1), mon itor opacity in accordance with paragraphs (2)(i) through (ii) below. If the control device exhausts through a monovent, or if the use of a COM in accordance with the installation specifications of PS-1 of 40 CFR 60 appendix B is not feasible, the permittee shall monitor opacity in accordance with paragraphs (2)(i) through (ii) below. (i) Perform daily visual opacity ob servations of each stack in accordance with the procedures of 40 CFR 60 Method 9. The Method 9 test shall be conducted while the affected sour ce is operating at representative performance conditions. The duration of th e Method 9 test shall be at least 30 minutes each day. (ii) Use the Method 9 procedures to m onitor and record the average opacity for each six-minute period during the test. (origin: 40 CFR 63.1350)

II.B.7.b.2 Recordkeeping: Results of opacity observations from the COM shall be recorded and maintained as required in R307-170, 40 CFR 63.10(c), and as described in Provision I.S.1 of this permit. If a COM is not used, r ecords shall be main tained in accordance with the test method and Provision I.S.1 of this permit.

II.B.7.b.3 Reporting: Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring Program. The reports are considered prompt notification of permit deviation required in Provision I.S. 2.c of this permit, if all information required by Provision I.S.2.c is included in the report. If a COM is not used for

Revised November 13, 2006 Page 35 Title V Operating Permit #2900001001monitoring, reports shall be submitted as required in Provision I.S.2 and the definition of 'prompt' shall be as given in I.S.2.c.

II.B.7.c Condition: Emissions of particulate matter (PM) sha ll be no greater than 0.05 kilograms per megagram (0.10 lb per ton) of feed (dry basis) to the kiln. [Authority granted under 40 CFR 63.1345 (LLL); condition originated in 40 CFR 63 Subpart LLL]

II.B.7.c.1 Monitoring: Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every five (5) years, based on the year of the initial performance test. Tests may al so be required at the direction of the Executive Secretary.

(b) Notification. At least 60 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) or Mi ne Safety and Health Administration (MSHA) approvable access shall be provided to the test location.

(2) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine particulate matter emissions. Each test shall consist of three separate runs under the conditions that exis t when the affected source is operating at the representative performance conditi ons in accordance with 40 CFR 63.7(e). Each run shall be conducted for at least one hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). The average of the three runs shall be used to determine compliance. A determination of the particulate matter collected in the impingers ('back half') of the Method 5 particulate sampling train is not required to demonstrate compliance with this particulate matter limitation, but may be used for purposes as directed by the Executive Secretary. (origin: 40 CFR 63.1349(b))

II.B.7.c.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

Revised November 13, 2006 Page 36 Title V Operating Permit #2900001001II.B.7.c.3 Reporting: In addition to the reporting requirements of Section I of this permit, the permittee shall submit the results of the stack test s to the Executive Secretary within 60 days of completion of the testing. Resu lts shall clearly identify test results as compared to permit limits and indicate compliance status.

II.B.8 Conditions on Finish Mill Operations (Unit C-FinishMill)

II.B.8.a Condition: Visible emissions shall be no greater than 10 percent opacity from the mill sweep or air separator air pollution control devices. [Authority granted under 40 CFR 63.1347; condition originated in 40 CFR 63 Subpart LLL]

II.B.8.a.1 Monitoring: The permittee shall monitor opacity by conducting daily visible emissions observations of the mill sweep and air se parator PMCD of these affected sources in accordance with Method 22 of Appendix A to 40 CFR 60. The Method 22 test shall be conducted while the affected source is operating at the representative performance conditions. The duration of the Method 22 test shall be six (6) minutes.

If visible emissions are observed during any Method 22 test the permittee must:

(A) Initiate, within one hour, the correctiv e actions specified in the site specific operating and maintenance plan; and

(B) Within twenty-four (24) hours of the end of the Method 22 test in which visible emissions were observed, conduct a 30-minute visual opacity test of each stack from which visible emissions were observed in accordance with 40 CFR 60 Method 9. (origin: 40 CFR 63.1350(e))

II.B.8.a.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.8.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.9 Conditions on Material handling operations - Group 1 (Unit MHO-1)

II.B.9.a Condition: Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 40 CFR 63.1348; condition originated in 40 CFR 63 Subpart LLL]

Revised November 13, 2006 Page 37 Title V Operating Permit #2900001001II.B.9.a.1 Monitoring: In lieu of opacity monitoring, the affect ed transfer points shall be inspected monthly to ensure that the enclosures are operated and maintained as total enclosures. (origin: 40 CFR 63.1350(a)(4)(v))

II.B.9.a.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.9.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.10 Conditions on Material handling operations - Group 2 (Unit MHO-2)

II.B.10.a Condition: Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 40 CFR 63.1348; condition originated in 40 CFR 63 Subpart LLL]

II.B.10.a.1 Monitoring: Monitoring of visible emissions shall be performed as follows:

(1) The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance w ith 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation.

(2) If no visible emissions are observed in six consecutive monthly tests for any 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 pe rmittee must resume testing of that affected source on a monthly basis and ma intain that schedule until no visible emissions are observed in six consecutive monthly tests.

(3) If no visible emissions are observed during the semi-annual test for anyaffected source, the permittee may decrease the frequency of testing from semiannually to annually for that affected source. If visible emissions are observed during any annual test, the permittee shall 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.

(4) If visible emissions are observed during any Method 22 test, the permittee shall conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions.

Revised November 13, 2006 Page 38 Title V Operating Permit #2900001001(5) [reserved - this paragraph no t applicable to this provision]

(6) If any partially enclosed or unenclosed conveying system transfer point is located in a building, the permittee shal l have the option to conduct a Method 22 visible emissions monitoring test according to the requirements of paragraphs 1 through 4 of this condition for each such conveying system transfer point located within the building, or for the building itself, according to paragraph 7 of this condition.

(7) If visible emissions from a building are monitored, the requirements of paragraphs 1 through 4 of this condition apply to the monitoring of the building, and the permittee shall 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. (origin: 40 CFR 63.1350(a)(4))

II.B.10.a.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.10.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.11 Conditions on Material handling operations - Group 3 (Unit MHO-3)

II.B.11.a Condition: Visible emissions shall be no greater than 10 percent opacity at the outlet of the associated PMCD. [Authority granted under 40 CFR 63.1348; condition originated in 40 CFR 63 Subpart LLL]

II.B.11.a.1 Monitoring: The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A to 40 CFR 60. The test must be conducted while the affected source is in operation.

If no visible emissions are observed in six consecutive monthly tests for anyaffected source, the testing frequency may decrease from monthly to semiannually for that affected source. If visible emissions are observed during any semi-annual test, testing must resume on a monthly basis and maintain that schedule until no visible emissions are ob served in six consecutive monthly tests.

If no visible emissions are observed during the semi-annual test for any affected source, the test frequency may decrease from semi-annually to annually for that

Revised November 13, 2006 Page 39 Title V Operating Permit #2900001001affected source. If visible emissions ar e observed during any annual test, testing must resume on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a 6-minute test, performed in accordance with 40 CFR 60 Method 9, must begin within one hour of observation of visible emissions.

II.B.11.a.2 Recordkeeping: The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese 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 remain ing 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 . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.11.a.3 Reporting: There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.C. Emissions Trading.
(R307-415-6a(10)) Not applicable to this source.

II.D. Alternative Operating Scenarios.
(R307-415-6a(9)) Not applicable to this source.



## Section III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with Provision I.M, Permit Shield:

III.A. R307-301-11, R307-301-12 (Gasoline Dispensi ng Facilities, Prohibited Activities.)

This regulation is not applicab le to the permitted source (Source-wide) because the plant is not located in a control area as defined in UACR 307- 301-1, and the plant does not sell or dispense oxygenated gasoline



## Section IV: ACID RAIN PROVISIONS.

This source is not subject to Title IV. This section is not applicable.

Revised November 13, 2006 Page 40 Title V Operating Permit #2900001001

## REVIEWER COMMENTS

This operating permit incorporates all appli cable requirements contained in the following documents:

DAQE-AN0007019-06 date d August 30, 2006

1. Comment on an item originating in Perm it Application regarding permitted source (Source-wide) Denial of permit application shield request s: Shielding from the following regulatory citations was requested in the permittee's application, based on construction of the facilities being completed prior to the 1 971 applicable dates: UACR R307-1-4.5.1 (20% opacity limitation for fugitives); UA CR R307-1-4.1 (20% opacity limitation for visible emissions); 40 CFR Part 60, Subpart F (Standards of performance for portland cement plant); 40 CFR sec. 60.11(a),(b),(c), and (e), (Determining compliance with opacity limitations); 40 CFR 60.11(d) (Gen eral operating practices); 40 CFR 60.12 (Prohibition of concealing emissions). Sin ce the application submittal date of October 10, 1995, the permittee has modified th e existing facilities and constructed new facilities, making the permit shield request s non-grantable. [Comment last updated on 10/16/1998]

2. Comment on an item originating in 40 CFR 63 Subpart LLL regarding permitted source (Source-wide) Exemption from NSPS: 40 CFR 63.1356 provides that "any affected source subject to the provisions of this subpart is exem pt from otherwise applicable new source performance standard contained in subpart F or subpart OOO of part 60". All Subpart F affected facilities are covered by Subpart LLL, so no requirement from Subpart F is included in this permit. Requirements from Subpart OOO are included for those emission points that precede raw material storage. [Comment last updated on 12/23/2003]

3. Comment on an item originating in 40 CF R 63 Subpart LLL regarding In-Line Kiln/Raw Mill (Unit C-Kiln) Raw mill & raw material dryer opacity limits: This source uses kiln exhaust to dry raw material as it is ground in the raw mill. The raw mill baghouse vents to the same stack as the kiln, so only the kiln opacity require ment is included in this permit. To do otherwise would cause continual deviations due to the kiln exhaust. [Comment last updated on 12/24/2003]

4. Comment on an item originating in 40 CF R 63 Subpart LLL regarding In-Line Kiln/Raw Mill (Unit C-Kiln) Kiln particulate matter emission limit vs PM 10 limit: The kiln is subject to a limit of 0.15 g/Mg (0.30 lb/ton) of dry feed. The MACT requires a PM CEMS, but defers it until later rulemaking. The current AO includes a PM 10 limit of 14 lb/hr for the kiln, while clinker production is limited to 930,00 0 tons/yr. At full-time operation, which gives the lowest hourly production rate and thus highest PM 10 /production ratio, the

Revised November 13, 2006 Page 41 Title V Operating Permit #2900001001existing PM 10 limit equates to 0.132 lb/ton. If 51% or more of the particulate emissions are PM 10 , the existing limit is more stringent than the MACT. However, confirming information is not available at this time, so both limits are included. Further information may result in subsuming the MACT limit under the PM 10 limit. [Comment last updated on 4/14/2004]

5. Comment on an item originating in 40 CF R 63 Subpart LLL regarding In-Line Kiln/Raw Mill (Unit C-Kiln) Activated carbon injection not included: There is no information that activated carbon injection is used at this source, so none of the requirements from 63 Subpart LLL dealing with the issue are included unless le ft in for completeness of quotation of the MACT. [Comment last updated on 3/15/2004]

6. Comment on an item originating in 40 CF R 63 Subpart LLL regarding In-Line Kiln/Raw Mill (Unit C-Kiln) Kiln performance testing: Due to the co mplications and equations involved in the testing for the kiln, this permit refere nces the MACT language rather than incorporating it. [Comment last updated on 12/24/2003]

7. Comment on an item originating in this pe rmit regarding permitted source (Source-wide) Description of "opacity survey" for permitt ee: Several opacity limits are monitored using an opacity survey. For these, the pe rson must read and understand the approach of Method 9 observations, though the person does not need to be certified. When required, the person moves to a position that would be allowed for a Method 9 observation, and looks at the emission point to see if anything is visible, similar to a Method 22. If nothing is visible besides steam, this is noted in the records and the next point is checked. If visible emissions are seen, a formal observation is required as described in the permit condition. [Comment last updated on 3/15/2004]

8. Comment on an item originating in 40 CF R 63 Subpart A, LLL regarding permitted source (Source-wide) Startup, Shutdown and Malfunction Plan (SSMP), Permit Condition II.B.1.c: Location of copies of the SSMP All of Holcim’s affected emission units subject to Subpart LLL are controlled from a central control room except for cement loadout, which is locally controlled due to the need for weigh scales. Maintaining one copy of the SSMP in the central control room and additional copies, as needed, for each local ly controlled affected emission unit, is considered reasonable. [Comment last updated on 8/22/2005]

Revised November 13, 2006 Page 42 Title V Operating Permit #2900001001