STATE OF FLORIDA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

NOTICE OF PERMIT

DEP File No. 1190042-001-AC, PSD-FL-361

Sumterville Plant

Sumter County

In the Matter of an

Application for Permit by:

Mr. Cary O. Cohrs -General Manager

Natural Resources of Central Florida, Inc. dba

American Cement Company

P.O. Box 1209

Anthony, Florida 32617

/

Enclosed is the Final Peffi1it Number 1190042-01-AC (PSD-FL-361) authorizing the construction

of a nominal 1,150,000 tons per year greenfield portland cement plant with a dry process

preheater/calciner kiln, in-line raw mill, clinker cooler and associated materials handling, storage,

conveyance and shipping facilities. The project will be located east of Sumterville and north of County

Road 470 in Sumter County. This peffi1it is issued pursuant to Chapter 403, Florida Statutes.

Any party to this order (peffi1it) has the right to seek judicial review of the peffi1it pursuant to

Section 120.68, F .S., by the filing of a Notice of Appeal pursuant to Rule 9.110, Florida Rules of

Appellate Procedure, with the Clerk of the Department in the Legal Office; and by filing a copy of the

Notice of Appeal accompanied by the applicable filing fees with the appropriate District Court of

Appeal. The Notice of Appeal must be filed within 30 (thirty) days from the date this Notice is filed

with the Clerk of the Department.

Executed in Tallahassee, Florida.

~JY .£Aa£/\

Trina L. Vielhauer, Chief

Bureau of Air Regulation
CERTIFICATE OF SERVICE

The undersigned duly designated deputy agency clerk hereby certifies that this NOTICE OF FINAL

PERMIT (including the FINAL permit) was sent by certi~1~ay Ii \*) and copies were sent by U.S.

Mail or electronic mail before the close of business on t9.! DIDio to the person(s) listed:

Cary O. Cohrs, American Cement Company* Martin Farber

Chair, Sumter County BCC Carol and Rudy Grossouw

Gregg Worley, U.S. EPA Region 4, Atlanta GA Everett Hadley

John Bunyak, National Park Service, Denver CO Lorn and Judy Kerr

Mara Nasca, DEP SWD Douglas R. Kinney

John Koogler, P.E., Koogler & Associates. John and Theresa McCormick

Joe Horton, SCC Eugenie Mamarchev

Marvin A. Beier Ivan Mamarchev

Louise Racine John Megan

Pauline T. Beier Sue Michalson

Anton and Anke Brok Lawrence H. Paser

Ruth E. Brown June B. Paser

H. Callahan Joel Rosenblum

Ann Cantlin-Elkins Karen J. Ross

Joyce Christie Joan L. Runyon

Carol Correa Lenore Smiley

Margaret Dwyer Hans Thiemann

r

(Date)

Clerk Stamp

FILING AND ACKNOWLEDGMENT FILED, on

this date, pursuant to §120.52, Florida Statutes, with

the designated Department Clerk, receipt of which is

(""-~eby acknowledged.
Twin Towers

2600 Blair

Tallahassee, Flo

Jeb Bush

Governor

Colleen M. Castille

Secretary

DEP File No. 11

Air Permit N

Sumtervill

Expiration date:

PERMITTEE:

Natural Resources of Central Florida

dba American Cement Company

Post Office Box 1209

Anthony, Florida 32617

Authorized Representative:

Cary O. Cohrs, General Manager

PROJECT AND LOCATION

This permit authorizes the construction of a nominal 1,150,000 tons per year greenfield portland cement plant

with a dry process preheater/calciner kiln, in-line raw mill, clinker cooler and associated materials handling,

storage, conveyance and shipping facilities. The project will be located east of Sumterville and north of County

Road 470 in Sumter County.

STATEMENT OF BASIS

The permit is issued under the provisions of Chapter 403 of the Florida Statutes (F .S.), and Chapters 62-4, 62-

204,62-210,62-212,62-296, and 62-297 of the Florida Administrative Code (F.A.C.). The project was

processed in accordance with the requirements of Rule 62-212.400, F.A.C., the preconstruction review program

for the Prevention of Significant Deterioration (PSD) of Air Quality. The permittee is authorized to perform the

proposed work in accordance with the conditions of this permit and as described in the application, approved

drawings, plans, and other documents on file with the Department of Environmental Protection (Department).

The attached Appendices are made a part of this permit:

Appendix BD Final BACT Determination and Emissions Standards

Appendix C Common State Rules

Appendix GC Construction Permit General Conditions

Appendix LLL NESHAP Subpart LLL Requirements

Appendix 000 NSPS Subpart 000 Requirements

Appendix Y NSPS Subpart Y Requirements

1~~t!' 1 ..-<1~ iz-7 L

Michael G. Cooke, Director

Division of Air Resources Management

Effective Date: <9/ /5/ ab

"More 

Protection. less Process'

Printed on recycled poper

Office BuildingStone 

Roadrida 

32399-~~400

90042-001-ACo. 

PSD-FL-361e 

Cement Plant

June 30, 2009
SECTION I. GENERAL INFORMATION 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 2 of 29 

FACILITY DESCRIPTION 

The proposed facility will be a nominal 1,150,000 tons per year (TPY) dry process portland cement plant 

incorporating a dry process kiln with a preheater and calciner (PH/C). Major equipment associated with the main 

components of the plant will include the following: 

• A materials storage building (MSB); 

• A primary crusher at the quarry and belt conveyors to MSB; 

• Raw material piles stored inside of the MSB. The piles will include limestone, alumina sources (e.g. bauxite, 

clay, and coal ash), iron sources (e.g. mill scale and iron ore), silica sources (e.g. sand), and additives (e.g. 

feldspar); 

• Materials handling equipment including portal reclaimers, stackers, belt conveyors, conveyor from the MSB 

to the raw mill, control system/analyzer, etc.; 

• An in-line raw mill that simultaneously dries raw materials using the exhaust gas from the kiln, PH/C, and 

clinker cooler; 

• A preheater with staged combustion and selective non-catalytic reduction (SNCR) system; 

• An air heater for use when additional drying capacity is required; 

• A nominal 10,000 ton blending silo; 

• An indirect-firing system with a low-NOX main kiln burner capable of burning coal, petroleum coke, fuel oil, 

and natural gas; 

• A whole tire feeder system; 

• A clinker cooler with reciprocating grates, cooling air fans, and hot air ducting to the kiln and PH/C; 

• Clinker storage and grinding including a finish mill with air separator, clinker silos with metering device, 

limestone and gypsum piles, and associated conveyors; 

• A cement transfer and storage facility including truck loadout and packhouse; and 

• A nominal 18 TPH coal and petroleum coke grinding system with associated mill, storage facility, conveyors, 

including a fabric filter baghouse. 

REGULATORY CLASSIFICATION 

Title III: The Department has determined the cement plant will be a major source of hazardous air pollutants 

(HAPs). 

Title V: The cement plant will be a Title V major source in accordance with Chapter 62-213, F.A.C. because the 

potential emissions of at least one regulated pollutant exceed 100 tons per year. Regulated pollutants include 

pollutants such as carbon monoxide (CO), nitrogen oxides (NOX), particulate matter (PM/PM10), sulfur dioxide 

(SO2), and volatile organic compounds (VOC). 

PSD: The facility is located in an area that is designated as “attainment”, “maintenance”, or “unclassifiable” for 

each pollutant subject to a National Ambient Air Quality Standard. It is classified as a “portland cement plant”, 

which is one of the 28 Prevention of Significant Deterioration (PSD) Major Facility Categories with the lower 

PSD applicability threshold of 100 tons per year. Potential emissions of at least one regulated pollutant exceed 

100 tons per year, therefore the facility is classified as a major source of air pollution with respect to Rule 62-

212.400 F.A.C., Prevention of Significant Deterioration of Air Quality. 

NSPS: Portions of the cement plant are subject to the following New Source Performance Standards (NSPS) in 

40 CFR 60: Subpart A (General Provisions); Subpart Y (Coal Preparation Plants); and Subpart OOO (Non 

Metallic Mineral Processing). Any affected source subject to the provisions of 40 CFR 63, Subpart LLL 
SECTION I. GENERAL INFORMATION 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 3 of 29 

(Portland Cement Manufacturing Industry) is exempt from any otherwise applicable new source performance 

standard contained in 40 CFR 60, Subpart F (Portland Cement Plants). 

NESHAP: Portions of the cement plant are subject to the National Emissions Standards for Hazardous Air 

Pollutants (NESHAP) in 40 CFR 63: Subpart A (General Provisions); and Subpart LLL (Portland Cement 

Manufacturing Industry). 

State Rules: The cement plant is subject to state Rule 62-296.407, F.A.C. (Portland Cement Plants). 

EMISSIONS UNITS 

This permit authorizes the construction of a new Portland cement plant. The project includes the following new 

emissions units: 

EU ID Emissions Unit Description 

001 Raw Material Quarrying, Crushing, and Storage. Includes raw material processing from quarry up 

to raw material storage, and additives handling from delivery to storage. 

002 Raw Materials, Conveying, Storage, and Processing. From raw material and additive storage to 

preheater (includes conveyance of raw materials and raw meal to and from raw mill, and 

homogenizing silo). 

003 Pyroprocessing System. Includes kiln, preheater/calciner, raw mill, air heater, and clinker cooler. 

004 Clinker and Additives Storage and Handling. Includes clinker handling from clinker cooler to 

clinker silo discharge, and clinker and additive handling from storage to the finish mill. 

005 Finish Mill (Cement Grinding) 

006 Cement Handling, Storage, Packing, and Loadout. Includes cement conveyance to silos, cement 

silos, loadout to trucks from silos, and cement bagging operations. 

007 Coal and Petroleum Coke Grinding System. Includes coal/petroleum coke handling from railcar 

unloading to the pulverized fuel bin. 

008 Fugitive Dust From Storage Piles, Paved Roads, and Unpaved Roads 

RELEVANT DOCUMENTS 

The documents listed are not a part of this permit; however, this information is specifically related to the 

permitting action and is on file with the Department. 

• Application received on September 30, 2005 

• Supplementary Information received on October 13, 2005 

• Public Notice of Application published November 24, 2005 

• Department’s Technical Evaluation and Preliminary Determination dated December 16, 2005 

• Department’s Intent to Issue and Public Notice Package dated December 16, 2005 

• Department’s Final Determination and Best Available Control Technology Determination issued 

concurrently with this Final Permit 
SECTION II. ADMINISTRATIVE REQUIREMENTS 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 4 of 29 

1. Permitting Authority: All documents related to PSD applications for permits to construct or modify 

emissions units shall be submitted to the Bureau of Air Regulation of the Florida Department of 

Environmental Protection (DEP) at 2600 Blair Stone Road (MS #5505), Tallahassee, Florida 32399-2400. 

Copies of all such documents shall also be submitted to the Compliance Authority. All documents related to 

applications for permits to construct minor sources of air pollution or to operate the facility shall be 

submitted to the Air Resources Section of the Department’s Southwest District Office at 13051 N. Telecom 

Parkway, Temple Terrace, FL 33637-0926. 

2. Compliance Authority: All documents related to compliance activities such as reports, tests, and 

notifications shall be submitted to the Air Resources Section of the Department’s Southwest District Office 

at 13051 N. Telecom Parkway, Temple Terrace, FL 33637-0926. 

3. Applicable Regulations, Forms and Application Procedures: Unless otherwise indicated in this permit, the 

construction and operation of the subject emissions unit shall be in accordance with the capacities and 

specifications stated in the application. The facility is subject to all applicable provisions of: Chapter 403 of 

the Florida Statutes (F.S.); Chapters 62-4, 62-204, 62-210, 62-212, 62-213, 62-296, and 62-297 of the 

Florida Administrative Code (F.A.C.); and Title 40, Parts 51, 52, 60, 63, 72, 73, and 75 of the Code of 

Federal Regulations (CFR) adopted by reference in Rule 62-204.800, F.A.C. The terms used in this permit 

have specific meanings as defined in the applicable chapters of the Florida Administrative Code. The 

permittee shall use the applicable forms listed in Rule 62-210.900, F.A.C. and follow the application 

procedures in Chapter 62-4, F.A.C. Issuance of this permit does not relieve the permittee from compliance 

with any applicable federal, state, or local permitting or regulations. [Rules 62-204.800, 62-210.300 and 62-

210.900, F.A.C.] 

4. Construction and Expiration: The permit expiration date includes sufficient time to complete construction, 

perform required testing, submit test reports, and submit an application for a Title V operation permit to the 

Department. Approval to construct shall become invalid for any of the following reasons: construction is 

not commenced within 18 months after issuance of this permit; construction is discontinued for a period of 

18 months or more; or construction is not completed within a reasonable time. The Department may extend 

the 18-month period upon a satisfactory showing that an extension is justified. In conjunction with an 

extension of the 18-month period to commence or continue construction (or to construct the project in 

phases), the Department may require the permittee to demonstrate the adequacy of any previous 

determination of Best Available Control Technology (BACT) for emissions units regulated by the project. 

For good cause, the permittee may request that this PSD air construction permit be extended. Such a request 

shall be submitted to the Department’s Bureau of Air Regulation at least sixty (60) days prior to the 

expiration of this permit. [Rules 62-4.070(4), 62-4.080, 62-210.300(1), and 62-212.400(6)(b), F.A.C.; 40 

CFR 52.21(r)(2); 40 CFR 51.166(j)(4)] 

5. New or Additional Conditions: For good cause shown and after notice and an administrative hearing, if 

requested, the Department may require the permittee to conform to new or additional conditions. The 

Department shall allow the permittee a reasonable time to conform to the new or additional conditions, and 

on application of the permittee, the Department may grant additional time. [Rule 62-4.080, F.A.C.] 

6. Relaxations of Restrictions on Pollutant Emitting Capacity. If a previously permitted facility or 

modification becomes a facility or modification which would be subject to the preconstruction review 

requirements of this rule if it were a proposed new facility or modification solely by virtue of a relaxation in 

any federally enforceable limitation on the capacity of the facility or modification to emit a pollutant (such 

as a restriction on hours of operation), which limitation was established after August 7,1980, then at the time 

of such relaxation the preconstruction review requirements of this rule shall apply to the facility or 

modification as though construction had not yet commenced on it. [Rule 62-212.400(2)(g), F.A.C.] 
SECTION II. ADMINISTRATIVE REQUIREMENTS 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 5 of 29 

7. Modifications: No emissions unit or facility subject to this permit shall be constructed or modified without 

obtaining an air construction permit from the Department. Such permit shall be obtained prior to beginning 

construction or modification. [Rule 62-4.030 and Chapters 62-210 and 62-212, F.A.C.] 

8. Title V Permit: This permit authorizes construction of the permitted emissions units and initial operation to 

determine compliance with Department rules. A Title V operation permit is required for regular operation 

of the permitted emissions units. The permittee shall apply for a Title V operation permit at least 90 days 

prior to expiration of this permit, but no later than 180 days after commencing operation. To apply for a 

Title V operation permit, the applicant shall submit the appropriate application form, compliance test results, 

and such additional information as the Department may by law require. The application shall be submitted 

to the Compliance Authority. [Rules 62-4.030, 62-4.050, 62-4.220 and Chapter 62-213, F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

A. Raw Material Quarrying, Crushing, and Storage 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 6 of 29 

The specific conditions of this subsection apply to the following emissions unit after construction is complete. 

EU ID Emission Unit Description

001 Raw Material Quarrying, Crushing, and Storage. Includes raw material processing from quarry up 

to raw material storage, and additives handling from delivery to storage. 

Raw material quarrying, crushing, and storage contains the following emissions points. 

• Primary crushing and all belt conveyor points to raw material storage. 

• All conveyors and hoppers associated with additives handling and storage. 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for 

particulate matter (PM/PM10). To satisfy the BACT requirements for this unit the visible emissions limits 

are surrogate standards for PM. 

2. NSPS Requirements: This unit shall comply with all applicable requirements of 40 CFR 60, Subparts A 

(General Provisions) and OOO (Nonmetallic Mineral Processing Plants) adopted by reference in Rule 62-

204.800(7)(b), F.A.C. The Department determines that the BACT emissions performance requirements are 

as stringent as or more stringent than the limits imposed by the applicable NSPS provisions. Some separate 

reporting and monitoring may be required by the individual subparts. 

EQUIPMENT DESCRIPTION

3. Equipment Description: The permittee is authorized to construct, operate, and maintain equipment needed for 

the raw material quarrying, crushing, and storage operation. Equipment will include a primary crusher at the 

quarry, and a raw materials storage building (MSB). Belt conveyors will be constructed between the crusher 

and the MSB. Raw material piles stored inside of the MSB will include limestone, alumina sources (e.g. 

bauxite, clay and coal ash), iron sources (e.g. mill scale and iron ore), silica sources (e.g. sand), and additives 

(e.g. feldspar). Other materials handling equipment may include portal reclaimers, stackers, hoppers, belt 

conveyors, a conveyor from the MSB to the raw mill, and a control system/analyzer. [Applicant Request] 

PERFORMANCE REQUIREMENTS

4. Hours of Operation: This emissions unit system is allowed to operate 8,760 hours per year. 

[Applicant Request, Rule 62-210.200(PTE), F.A.C.] 

5. Process Rate Specification: The crusher may process up to 750 tons per hour on a 30-day average (dry basis) 

of raw materials. No more than 1,482,000 tons (dry basis) of raw materials shall be processed during any 

consecutive 12 months. [Rules 62-210.200 (PTE) and 62-4.070(3), F.A.C.] 

EMISSIONS AND TESTING REQUIREMENTS

6. Visible Emission Standards: These opacity standards do not apply to truck dumping of nonmetallic minerals 

into any screening operation, feed hopper, or crusher. 

a. Fugitive emissions from the crusher shall not exceed 15% opacity. 

b. Fugitive emissions from any transfer point on belt conveyors or from any other affected facility shall 

not exceed 10% opacity. 

[Rule 62-212.400(BACT), F.A.C.; and 40 CFR 60, Subpart OOO] 

7. Visible Emissions Tests: Compliance with the visible emission limits shall be determined by conducting EPA 

Method 9 tests. Initial tests shall be conducted 60 days after achieving the maximum production rate at which 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

A. Raw Material Quarrying, Crushing, and Storage 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 7 of 29 

the unit will be operated, but no later than 180 days after initial startup. Thereafter, the permittee shall 

demonstrate compliance during each federal fiscal year (October 1st to September 30th) for the primary 

crusher. Tests shall be conducted in accordance with the applicable requirements in Appendix C of this 

permit as well as the applicable NSPS provisions. 

REPORTING AND RECORD KEEPING

8. Test Reports: For each test conducted, the permittee shall file a test report including the information specified 

in Rule 62-297.310(8), F.A.C. with the compliance authority no later than 45 days after the last run of each 

test is completed. [Rules 62-297.310(8), F.A.C., and 40 CFR 60, Subpart OOO] 

9. Process Rate Information: The permittee shall maintain records of the monthly processing rate. Such reports 

shall be recorded and available for inspection no later than 10 days following the end of the month. 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

B. Raw Materials Conveying, Storage, and Processing 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 8 of 29 

The specific conditions of this subsection apply to the following emissions unit after construction is complete. 

EU ID Emissions Unit Description

002 Raw Materials, Conveying, Storage, and Processing. From raw material and additive storage to 

preheater (includes conveyance of raw materials and raw meal to and from raw mill, and 

homogenizing silo). 

The following emissions points in the raw materials conveying, storage, and processing system are controlled by 

baghouses: 

Point ID Emissions Point Description

F03 Dust collector for raw meal transfer from raw grinding mill 

F10 Dust collector for raw meal transfer at air lift to homogenizing silo 

G07 Dust collector for raw meal transfer to homogenizing silo 

G10 Dust collector for homogenizing silo bin vent 

E38 Dust collector for filter dust surge bin 

H08 Dust collector for raw meal transfer from homogenizing silo 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for, 

particulate matter (PM/PM10). To satisfy the BACT requirements for this unit the visible emissions limits 

are surrogate standards for PM. 

2. NESHAP Requirements: This unit is subject to 40 CFR 63, Subpart A (Identification of General 

Provisions) and 40 CFR 63, Subpart LLL (National Emissions Standard for Hazardous Air Pollutants from 

the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions 

performance requirements are as stringent as or more stringent than the limits imposed by the applicable 

NESHAP provisions. Some separate reporting and monitoring may be required by the individual subpart. 

EQUIPMENT AND CONTROL TECHNOLOGY

3. Equipment Description: The permittee is authorized to construct, operate, and maintain equipment needed for 

the conveyance, storage, and processing of raw materials. Equipment will include one homogenizing silo 

(nominal 10,000 ton capacity), and associated transport system. [Applicant] 

4. Baghouse Controls: Each emissions point specifically identified above for raw materials conveying, storage, 

and processing shall be controlled by a baghouse system. Each required baghouse shall be designed, 

operated, and maintained to achieve a PM design specification of 0.01 gr/dscf and a PM10 design specification 

of 0.007 gr/dscf. [Rule 62-212.400(BACT), F.A.C.]

PERFORMANCE REQUIREMENTS

5. Hours of Operation: This emissions unit is allowed to operate 8,760 hours per year. [Applicant Request, 

Rule62-210.200(PTE), F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

B. Raw Materials Conveying, Storage, and Processing 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 9 of 29 

EMISSIONS AND TESTING REQUIREMENTS

6. Emissions Limits: The following standards apply to each emissions point of this unit including all raw 

material storage bins and conveying system transfer points: 

a. Visible emissions are limited to 5% opacity from each of the above listed emissions points controlled by a 

baghouse. 

b. Fugitive emissions are limited to 10% opacity from any emissions point not controlled by a baghouse. 

[Rule 62-212.400(BACT), F.A.C.] 

{Note: The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) 

and PM10 emissions to 0.007 gr/dscf. The 5% opacity limitation is consistent with this design and provides 

reasonable assurance that annual emissions of PM/PM10 for all emission points in this emission unit system 

will be less than 10.5 TPY. Exceedance of the 5% opacity limit shall be deemed an exceedance of this 

permit condition and not necessarily an exceedance of the opacity limitations given in 40 CFR 63, Subpart 

LLL.} 

[Rules 62-4.070(3), 62-212.400, F.A.C. and 40 CFR 63.1348] 

7. Compliance Demonstrations: Each emission point shall be tested to demonstrate initial compliance with the 

emission standards for visible emissions in accordance with EPA Method 9. The tests shall be conducted 

within 60 days after achieving the maximum production rate at which the unit will be operated, but not later 

than 180 days after the initial startup. Thereafter, compliance with the visible emission limits for each 

emission point controlled by a baghouse and for each unenclosed transfer point shall be demonstrated during 

each federal fiscal year (October 1st to September 30th). [Rules 62-4.070(3), 62-297.310(7)(a), F.A.C. and 40 

CFR 63.1349(b)(2)] 

8. Periodic Monitoring Requirements: Each affected source subject to an opacity standard shall be periodically 

monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance 

with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL] 

9. Test Methods: Any required tests shall be performed in accordance with the following reference methods and 

the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions. 

Method Description of Method and Comments 

9 Visual Determination of the Opacity of Emissions from Stationary Sources 

22 Visual Determination of Fugitive Emissions From Material Sources 

REPORTING AND RECORD KEEPING

10. Baghouse O&M Plan: For each baghouse the permittee shall prepare an operation and maintenance (O&M) 

plan to address proper operation, parametric monitoring, and a schedule for conducting periodic inspections 

and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written 

log. The O&M plan shall be submitted to the Compliance Authority prior to the initial compliance tests for 

this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL] 

11. Test Reports: For each test conducted, the permittee shall file a test report including the information specified 

in Rule 62-297.310(8), F.A.C. with the compliance authority no later than 45 days after the last run of each 

test is completed. [Rules 62-297.310(8), F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

C. Pyroprocessing System 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 10 of 29 

The following specific conditions apply to the following emissions unit after construction: 

ID No. Emissions Unit Description

003 Pyroprocessing System. Includes kiln, preheater/calciner, raw mill, air heater, and clinker cooler. 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for 

carbon monoxide (CO), nitrogen oxides (NOX), sulfur dioxide (SO2), volatile organic compounds (VOC), 

and particulate matter (PM/PM10). 

2. NESHAP Requirements: This unit is subject to 40 CFR 63, Subpart A (Identification of General 

Provisions) and 40 CFR 63, Subpart LLL (National Emissions Standard for Hazardous Air Pollutants from 

the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions 

performance requirements are as stringent as or more stringent than the limits imposed by the applicable 

NESHAP provisions for particulate matter. Some separate reporting and monitoring may be required by the 

individual subpart. 

EQUIPMENT AND CONTROL TECHNOLOGY

3. Pyroprocessing System: The permittee is authorized to construct a pyroprocessing system consisting of a 

dry process pre-heater/calciner rotary kiln with in-line raw mill that simultaneously dries raw materials 

using the exhaust gas from the kiln, PH/C, or cooler. The preheater is designed with a staged combustion 

calciner and a selective non-catalytic reduction (SNCR) system. The indirect-fired kiln with low-NOX main 

kiln burner will be capable of burning coal, petroleum coke, natural gas, used oil, and fuel oil. A tire feed 

mechanism with an airlock/gate system will be capable of feeding tire derived fuel (TDF) into the area just 

prior to the kiln exhaust. Other equipment includes an air heater for use when additional drying capacity is 

required, and a clinker cooler with reciprocating grates, cooling air fans, and hot air ducting to the kiln, 

PH/C or in-line raw mill. The air heater will be capable of firing fuel oil and natural gas. All emissions 

from the pyroprocessing system are directed to a single stack. The exhaust stack shall be no more than 10.2 

feet in diameter and no less than 350 feet tall. [Applicant request] 

4. Kiln Design: The kiln will be designed to process approximately 208 tons per hour of dry preheater feed 

material (including baghouse dust recirculation) with an annual nominal throughput of 1,822,080 tons per 

year. However, preheater feed rate is ultimately restricted through clinker production limitations. 

5. NOX Controls

a) Low-NOX Burners and Indirect Firing: The main kiln will be equipped with a low NOX burner that will 

create distinct combustion zones within the flame. An indirect firing system will be used to reduce the 

amount of primary air injected with the fuel used in the main kiln burner. 

b) Staged Combustion in the Calciner (SCC): The kiln system will be designed such that the introduction of 

fuel, air and meal to the calciner will be staged or sequenced for the reduction of NOX emissions. 

c) SNCR: A selective non-catalytic reduction (SNCR) system shall be designed, constructed and operated to 

achieve the permitted levels for NOX emissions from the pyroprocessing system. The SNCR system will 

consist of an aqueous ammonia tank, pumps, piping, compressed air delivery, injectors, control system, 

and other ancillary equipment. Aqueous ammonia will be injected at a location(s) in the 

preheater/calciner with an appropriate temperature profile to support the SNCR process. 

6. Particulate Matter (PM/PM10) Controls: The permittee shall install a baghouse control system to remove 

particulate matter emissions from the pyroprocessing exhaust gas stream to achieve the PM/PM10 emissions 

standards specified in this permit. 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

C. Pyroprocessing System 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 11 of 29 

7. Sulfur Dioxide Controls: The use of low-sulfur raw materials will help to keep SO2 emissions below 

permitted levels. 

PERFORMANCE REQUIREMENTS

8. Hours of Operation: The hours of operation for this emissions unit are not limited (8760 hours per year). 

[Rule62-210.200(PTE), F.A.C.] 

9. Process Rate Limitations: Kiln preheater feed rate shall be monitored and recorded for purposes of 

determining clinker production. The clinker production rate of the kiln shall not exceed 125 tons per hour 

(24-hour rolling average) and 1,095,000 tons during any consecutive 12 month period. The clinker 

production rate shall be determined using kiln feed and kiln feed loss on ignition (LOI) factors. The feed 

rates and kiln feed LOI shall be based on a 30 operating-day block average of daily measurements. For 

purposes of this requirement, an operating day is any day that the kiln produces clinker or burns fuel. 

[Rules 62-4.070(3), and 62-212.200(PTE), F.A.C.] 

10. Authorized Fuels: Only the following authorized fuels shall be fired in the pyroprocessing system (kiln and 

calciner): coal, petroleum coke, whole or chipped tires, natural gas, and No. 2 fuel oil and/or onspecification used oil fuel. The maximum heat input rate to the pyroprocessing system (kiln and calciner) 

shall not exceed 9,600 MMBtu per day (nominally 400 MMBtu/hr). 

a. The maximum heat input rate from firing whole or chipped tire derived fuel (TDF) shall not exceed 15% 

of the total pyroprocessing heat input rate (kiln and calciner) and shall not exceed 60 MMBtu per hour. 

The remaining 85% of the total pyroprocessing heat input rate shall be from the firing of other 

authorized fuels. TDF shall be directly fed into the kiln system at the transition section between the 

base of the calciner and the point where gases exit the kiln. The tire feed mechanism shall be designed 

with an airlock/gate system. Tires shall be stored, handled and managed in accordance with the 

provisions of Chapter 62-711, F.A.C. 

b. The air heater shall fire only natural gas or distillate fuel oil (No. 2 or No. 4) with a design maximum 

heat input rate of 36 MMBtu per hour. 

c. The firing of “on-specification” used oil fuel shall not exceed 1000 gallons per hour and 1,500,000 

gallons during any consecutive 12 months. On-Specification Used Oil Fuel shall meet the following 

specifications: 

1. Arsenic shall not exceed 5.0 ppm; 

2. Cadmium shall not exceed 2.0 ppm; 

3. Chromium shall not exceed 10.0 ppm; 

4. Lead shall not exceed 100.0 ppm; 

5. Total halogens shall not exceed 1000 ppm; and 

6. Flash point shall not be less than 100° F. 

Used oil fired as a fuel may be generated from on site sources or purchased from a vendor. Used oil 

shall not contain any PCB’s. [40 CFR 279.61; 40 CFR 761.20(e); Rule 62-4.070(3), F.A.C.] 

[Rules 62-4.070(3) and 62-210.200(PTE), F.A.C.; Application No. 1210465-014-AC] 

11. Prohibited Fuels and Materials: The owner or operator shall not introduce into any part of the process any 

of the following fuels and materials: hazardous wastes; petroleum contaminated soil or materials; offspecification used oil; or solid fuels other than those allowed by this permit; or solid wastes other than tires 

as allowed by this permit. [Rule 62-4.070(3), F.A.C.] 

12. Cement Kiln Dust: Cement kiln dust shall be re-circulated in the process and shall not be directly 

discharged from process or emission control equipment. Cement kiln dust removed from process equipment 
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during maintenance and repair shall be confined and controlled at all times and shall be managed in 

accordance with the applicable provisions of 40 CFR 261. [Rule 62-4.070(3), F.A.C.] 

EMISSIONS AND TESTING REQUIREMENTS

13. Emissions Standards: Emissions from the pyroprocessing system (including the air heater) shall not exceed 

the following emissions standards. 

Pollutant Emission Limit Averaging 

Time 

Compliance 

Method Basis 

2.9 lb/ton of clinker 

CO 

362.5 lb/hr 30-day rolling CEMS BACT 

1.95 lb/ton of clinker 

NOX

a

243.8 lb/hr 30-day rolling CEMS BACT

0.153 lb/ton of clinker 

19.13 lb/hr 

Three 1-hr runs 3-Run Test 

PM/PM10

b

10 % opacity 6-minute block COMS 

BACT

0.20 lb/ton of clinker 

SO2

25.0 lb/hr 24-hr rolling CEMS BACT

0.12 lb/ton of clinker 

VOCc

15.0 lb/hr 30-day block CEMS BACT

0.20 ng/dscm (TEQ) @ 7% O2

Dioxin/Furand

0.40 ng/dscm (TEQ) @ 7% O2

Three 3-hr runs Temperature 

Monitor NESHAP LLL 

THC 50 ppmvd (as propane)@ 7% O2 30-day block CEMS NESHAP LLL 

Mercurye 122 lb/12-month period 12-month 

rolling 

Fuel/Materials 

and/or CEMS Avoid PSD 

a. For an “initial startup period” NOX emissions shall not exceed 3.0 lb/ton of clinker (375.0 lb/hour) 

based on a 30-day rolling average. The “initial startup” period shall begin after initial certification of 

the NOX CEMS and shall end as soon as any of the following conditions are met: 

1) The Kiln system produces 77,500 tons of clinker or more in any 30-day rolling period. 

2) The Kiln system produces a total of 155,000 tons of clinker. 

3) 365 days calendar days elapse after initial certification of the NOX CEMS. 

After the “initial startup” period ends, NOX emissions shall not exceed 1.95 lb/ton of clinker (243.8 

lb/hour) based on a 30-day rolling average. These requirements do not waive or vary any applicable 

NSPS or NESHAP monitoring or record keeping requirements. 

b. All PM emitted from the baghouse exhaust is assumed to be PM10. The BACT standard for PM is 

equivalent to approximately 0.09 lb ton of preheater feed material. The emissions limits for particulate 

matter and visible emissions imposed by Rule 62-212.400(BACT) are as stringent as or more stringent 

than the limits imposed by the applicable NESHAP provisions. The BACT requirements do not waive 

or vary any applicable NESHAP monitoring or record keeping requirements. 
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c. Compliance shall be demonstrated by THC CEMS. VOC emissions shall be measured as total 

hydrocarbons (THC) and expressed as “propane” for the mass emissions rate. 

d. Dioxin/furans shall not exceed 0.20 ng/dscm (TEQ) @ 7% oxygen when the average of the performance 

test run temperatures at the inlet to the particulate matter control device is 204° C (400° F) or more and 

shall not exceed 0.40 ng/dscm (TEQ) @ 7% oxygen when the average of the performance test run 

average temperatures at the inlet to the particulate matter control device is 204° C (400° F) or less. 

e. Compliance shall be demonstrated using the sampling, analysis, and calculation methods specified in 

Condition No. 21. 

{Permitting Note: In combination with the annual clinker production limitation of 1,095,000 tons per year, 

the above emissions standards effectively limit annual potential emissions from this unit to: 1,588 tons/year 

of CO; 1,068 tons/year of NOX (after year one); 83.8 tons/year of PM/PM10; 110 tons/year of SO2; and 66 

tons/year of VOC. Note that first year annual NOX emissions could be as high as 1,643 tons/year.}

[Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 

14. Test Methods: Any required stack tests shall be performed in accordance with the following methods. 

EPA Method Description of Method and Comments 

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture 

Content. Methods shall be performed as necessary to support other methods.

5 Determination of Particulate Emissions. The minimum sample volume shall be 30 dry 

standard cubic feet.

6C Determination of SO2 Emissions (Instrumental). 

7E Determination of NOX Emissions (Instrumental). NOX emissions testing shall be 

conducted with the air heater operating at the highest heat input possible during the 

test. 

9 Visual Determination of Opacity 

10 Measurement of Carbon Monoxide Emissions (Instrumental). The method shall be 

based on a continuous sampling train. 

23 Measurement of Dioxin/Furan Emissions 

25A Measurement of Gaseous Organic Concentrations (Flame Ionization – Instrumental) 

The methods are specified in Appendix A of 40 CFR 60, adopted by reference in Rule 62-204.800, F.A.C. 

No other methods may be used unless prior written approval is received from the Department. Tests shall 

be conducted in accordance with the appropriate test method and the applicable requirements specified in 

Appendix C of this permit, NSPS Subpart A in 40 CFR 60, and NESHAP Subparts A and LLL in 40 CFR 

63. [Rules 62-204.800, F.A.C.; 40 CFR 60, Appendix A] 

15. Testing Requirements: Initial tests shall be conducted between 90% and 100% of permitted capacity; 

otherwise, this permit shall be modified to reflect the true maximum capacity as constructed. Subsequent 

annual tests shall be conducted between 90% and 100% of permitted capacity in accordance with the 

requirements of Rule 62-297.310(2), F.A.C. Tests shall be conducted for each required pollutant under the 

fuel scenario representing the highest potential for generating emissions. In general, this fuel scenario is 

firing coal as the primary fuel and TDF and petroleum coke, as secondary fuels. If a secondary fuel listed 

above is not available at the time of testing, tests shall be based on the fuels that are available. If a 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

C. Pyroprocessing System 

American Cement Company Project No. 1190042-001-AC 

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secondary fuel is added later, additional tests shall be conducted with that fuel scenario within 60 days of 

first fire of the new secondary fuel. 

[Rule 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] 

16. Initial Compliance Demonstration: Initial compliance stack tests shall be conducted within 60 days after 

achieving a daily average clinker production rate of 125 tons per hour, but not later than 180 days after the 

initial startup. In accordance with the test methods specified in this permit, the kiln system exhaust stack 

shall be tested to demonstrate compliance with the emission standards for particulate matter, CO, SO2, NOX, 

dioxin/furans, and THC. The initial compliance demonstration with the THC, and dioxin/furans emissions 

standards shall be carried out in accordance with 63.1349(b). The permittee shall provide the Compliance 

Authority with any other initial emissions performance tests conducted to satisfy vendor guarantees. 

[Rule 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8] 

17. Subsequent Compliance Testing: Annual compliance stack tests for particulate matter, CO, NOX, and SO2, 

shall be conducted during each federal fiscal year (October 1st to September 30th). Subsequent 

dioxins/furans tests shall be conducted in accordance with the provisions of 40 CFR 63.1349. Data 

collected from the reference method during the required RATA tests for CO, NOX, and SO2 may be used to 

satisfy the annual testing requirement provided the notification requirements and emission testing 

requirements for performance and compliance tests of this permit are satisfied. [Rules 62-297.310(7)(a) and 

(b), F.A.C.; 40 CFR 60.8] 

18. Continuous Compliance: Continuous compliance with the permit standards for opacity and emissions of 

CO, NOX, SO2, and VOC/THC shall be demonstrated with data collected from the required continuous 

monitoring systems. [Rules 62-212.400(5)(c) and 62-297.310(7)(a) and (b), F.A.C.; 40 CFR 60.8, and 

63.1350] 

19. Supplemental Dioxin/Furan and PM/PM10 Tests: The owner or operator shall notify the Compliance 

Authority prior to initiating any significant change in the feed or fuel used in the most recent compliant 

performance test for dioxin/furan or PM/PM10. For purposes of this condition, significant means any of the 

following: a physical or chemical change in the feed or fuel; the use of a raw material not previously used; 

a change in the LOI of the coal ash outside the normal range of monitored parameters; a change between 

non-beneficiated coal ash and beneficiated coal ash. Based on the information provided, the Compliance 

Authority will promptly determine if performance testing pursuant to 40 CFR 63.1349 will be required for 

the new feed or fuel. A significant change shall not include switching to a feed/fuel mix for which the 

permittee already tested in compliance with the dioxin/furan and PM/PM10 emission limits. [Rule 62-

4.070(3), F.A.C.] 

20. Special Compliance Tests: When the Department, after investigation, has good reason (such as complaints, 

increased visible emissions or questionable maintenance of control equipment) to believe that any applicable 

emission standard contained in a Department rule or in a permit issued pursuant to those rules is being 

violated, it shall require the owner or operator of the emissions unit to conduct compliance tests which 

identify the nature and quantity of pollutant emissions from the emissions unit and to provide a report on the 

results of said tests to the Department. [Rule 62-297.310(7) (b), F.A.C.] 

21. Mercury Compliance Demonstration: 

a. Material Balance Demonstration: The owner or operator shall demonstrate compliance with the 

mercury throughput limitation by material balance and maintaining records of the monthly and rolling 

12-month mercury throughput. Samples of the raw mill feed and all fuels shall be collected each day. 

A single composite daily sample shall be made from all samples collected during a day. A monthly 

composite sample shall be made from each of the daily composite samples. Each monthly composite 

sample shall be analyzed to determine the mercury concentration of the materials representative for the 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

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American Cement Company Project No. 1190042-001-AC 

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month. The analytical methods used to determine mercury concentration shall be EPA or ASTM 

methods such as EPA Method 7471A (Mercury in Solid or Semisolid Waste). No other methods may 

be used unless prior written approval is received from the Department. For each raw material and fuel, 

the monthly mercury throughput rate (pounds per month) shall be the product of the mercury 

concentration from the monthly composite sample and the mass of raw material or fuel used during the 

month. If the mercury concentration is below detection limit or below the limits of quantification, the 

detection limit will be assumed for the concentration of the raw material or fuel. For each month, the 

mass of mercury introduced into the pyroprocessing system (pounds per month) shall be the sum of the 

monthly mercury throughput rate for each raw material and fuel. The consecutive 12-month mercury 

throughput rate shall be the sum of the individual monthly records for the current month and the 

preceding eleven months (pounds of mercury per consecutive 12-months). Such records, including 

calculations and data, shall be completed no later than 25 days following the month of the records. 

[Rules 62-4.070(3) and 62-212.400(2)(g), F.A.C.] 

b. Mercury Continuous Emissions Monitoring System (Hg-CEMS): Within 60 days following the first year 

of operation, the owner or operator shall install any model of Hg-CEMS that has been demonstrated to 

meet the requirements in Performance Specification 12A (PS-12A), “Specifications and Test Procedures 

for Total Vapor phase Mercury Continuous Monitoring Systems in Stationary Sources,” or that has 

passed verification tests conducted under the auspices of the U.S. Environmental Protection Agency’s 

(EPA) Environmental Technology Verification (ETV) Program. During the subsequent 90 days, the 

owner or operator shall certify the Hg-CEMS and begin reporting Hg mass emissions data. The owner 

or operator shall adhere to the calibration drift and quarterly accuracy assessment procedures in 40 CFR 

Part 60, Appendix F or 40 CFR Part 75, Appendix B. The 12-month rolling mass emissions and 

average monthly mass emissions shall be reported based on the actual data collected not later than 10 

days following the end of month. Upon certification, the owner or operator may use the Hg-CEMS to 

demonstrate compliance with the cumulative 12-month rolling mass emission limitation (122 pounds 

per rolling 12-month period) in lieu of the procedures described in the preceding paragraph. Prior to use 

of the Hg-CEMS as the method to demonstrate compliance, the owner or operator shall submit written 

notice to the Department, and receive approval for a missing data substitution plan. For purposes of this 

requirement, the first year of operation ends 365 calendar days following the first day the kiln produces 

clinker. [Rules 62-4.070(3) and 62-212.400(2)(g), F.A.C.] 

EXCESS EMISSIONS

{Permitting Note: The following conditions apply only to the SIP-based emissions standards specified in 

Condition No. 12 of this section. Rule 62-210-700, F.A.C. (Excess Emissions) cannot vary or supersede any 

federal provision of the NSPS or the NESHAP programs.} 

22. Operating Procedures: The Best Available Control Technology (BACT) determinations established by this 

permit rely on “good operating practices” to reduce emissions. Therefore, all operators and supervisors 

shall be properly trained to operate and maintain the kiln and calciner, and pollution control systems in 

accordance with the guidelines and procedures established by each manufacturer. The training shall include 

good operating practices as well as methods for minimizing excess emissions. 

[Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 

23. Definitions:

a. Startup is defined as the commencement of operation of any emissions unit which has shut down or 

ceased operation for a period of time sufficient to cause temperature, pressure, chemical or pollution 

control device imbalances, which result in excess emissions. 

b. Shutdown means the cessation of the operation of an emissions unit for any purpose. 
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c. Malfunction means any unavoidable mechanical and/or electrical failure of air pollution control 

equipment or process equipment or of a process resulting in operation in an abnormal or unusual 

manner. 

[Rule 62-210.200(159,230,and 245), F.A.C.] 

24. Excess Emissions Prohibited: Excess emissions caused entirely or in part by poor maintenance, poor 

operation or any other equipment or process failure that may reasonably be prevented during startup, 

shutdown or malfunction shall be prohibited. All such preventable emissions shall be included in any 

compliance determinations based on CEMS data. [Rule 62-210.700(4), F.A.C.] 

25. Allowable Data Exclusions: Continuous monitoring data collected during periods of startup, shutdown, and 

malfunction may be excluded from the compliance demonstrations only in accordance with the following 

requirements, provided that best operational practices to minimize emissions are adhered to and the duration 

of excess emissions are minimized. As provided by the authority in Rule 62-210.700(5), F.A.C., the 

following conditions replace the provisions in Rule 62-210.700(1), F.A.C. 

a. CO Data: Each 30-day rolling average shall include all periods of operation (including startup, 

shutdown, and malfunction), but may exclude limited periods due to equipment malfunctions. No more 

than 30 hours in any calendar month shall be excluded from the compliance determinations due to 

equipment malfunctions. Malfunctions do not include process upsets that occur as a normal part of 

cement production. 

b. NOX Data: Each 30-day rolling average shall include all periods of operation (including startup, 

shutdown, and malfunction), but may exclude limited periods due to malfunctions of the SNCR system. 

“Malfunctions of the SNCR system” are defined as any unavoidable mechanical and/or electrical failure 

that prevents introduction of ammonia-based solutions into the kiln system. No more than 30 hours in 

any calendar month shall be excluded from the compliance determinations due to malfunctions of the 

SNCR system. 

c. SO2 Data. Each 24-hour rolling average shall include all periods of operation (including startup, 

shutdown, and malfunction). 

d. Other Data: All valid opacity and VOC data shall be included in the compliance determination. If the 

mercury CEMS is used as the method for demonstrating compliance, all valid data shall be included in 

the compliance determination. 

The permittee shall notify the Compliance Authority within one working day of discovering any emissions 

in excess of a CEMS standard subject to the specified averaging period. Within one working day of 

occurrence, the owner or operator shall notify the Compliance Authority of any malfunction resulting in the 

exclusion of CEMS data. All such reasonably preventable emissions shall be included in any CEMS 

compliance determinations. All valid emissions data (including data collected during startup, shutdown and 

malfunction) shall be used to report emissions for the Annual Operating Report. 

[Rules 62-210.200, 62-212.400(BACT), and 62-210.700, F.A.C.] 

CONTINUOUS MONITORING REQUIREMENTS

26. CEM Systems: The permittee shall install, calibrate, operate and maintain continuous emissions monitoring 

systems (CEMS) to measure and record concentrations of CO, Hg, NOX, SO2, and VOC/THC in the kiln 

system exhaust stack in a manner sufficient to demonstrate continuous compliance with the emissions 

standards specified in this section. All continuous monitoring systems other than the Hg CEMS shall be 

installed and functioning within the required performance specifications by the time of the initial 
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C. Pyroprocessing System 

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performance tests. The Hg CEMS shall be installed and functioning within the required performance 

specifications following the first year of operation as specified in condition No. 21. 

a. CO Monitor. The CO monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance 

Specification 4 or 4A. Quality assurance procedures shall conform to the requirements of 40 CFR 60, 

Appendix F. The required RATA tests shall be performed using EPA Method 10 in Appendix A of 40 

CFR 60 and shall be based on a continuous sampling train. The CO monitor span values shall be set 

appropriately, considering the expected range of emissions and corresponding emission standards. 

b. NOX Monitor. The NOX monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance 

Specification 2. Quality assurance procedures shall conform to the requirements of in 40 CFR 60, 

Appendix F. The required RATA tests shall be performed using EPA Method 7E in Appendix A of 40 

CFR 60. The NOX monitor span values shall be set appropriately, considering the expected range of 

emissions and corresponding emission standards. 

c. SO2 Monitor. The SO2 monitor shall be certified pursuant to 40 CFR 60, Appendix B, Performance 

Specification 2. Quality assurance procedures shall conform to the requirements of 40 CFR 60, 

Appendix F. The required RATA tests shall be performed using EPA Method 6C in Appendix A of 40 

CFR 60. The SO2 monitor span values shall be set appropriately, considering the expected range of 

emissions and corresponding emission standards. 

d. THC Monitor. A monitor shall be installed to determine THC emissions from the stack and shall meet 

the requirements of NESHAP Subpart LLL in 40 CFR 63 (40 CFR 63.1349 and 63.1350). The THC 

monitor shall include provisions to determine the moisture content of the exhaust gas and an algorithm 

to enable correction of the monitoring results to a dry basis (0% moisture). 

e. Diluent Monitor. An oxygen monitor shall be installed at the THC monitor location to correct measured 

THC emissions to the required oxygen concentration. 

f. Mercury Monitor. A mercury monitor (Hg-CEMS) shall be installed and operated as described in 

Condition 21 above. 

CEMS, other than the Hg-CEMS, are also subject to the General Provisions specified in Subpart A of 40 

CFR 60 (CO, NOX, and SO2) and Subpart A of 40 CFR 63 (THC/VOC). [Rules 62-4.070(3), 62-210.800, 

62-212.400(BACT) and 62-297.520, F.A.C.] 

27. COMS: A continuous opacity monitoring system (COMS) shall be installed, calibrated, operated, and 

maintained in the kiln system exhaust stack, after the baghouse, in a manner sufficient to demonstrate 

continuous compliance with the opacity standards specified in this section. Opacity shall be based on a 6-

minute block average computed from at least one observation (measurement) every 15 seconds. For the 

COMS, the 6-minute block averages shall begin at the top of each hour. The COMS shall meet the 

applicable requirements of 40 CFR 63.1350. [NESHAP Subpart LLL in 40 CFR 63] 

28. CEMS/COMS Certification and Initial Startup: Each CEMS/COMS required by this permit shall be 

installed prior to startup. Within 60 calendar days of achieving an average daily clinker production rate of 

125 tons per hour, but no later than 180 calendar days after initial startup, the owner or operator shall certify 

each CEMS/COMS. Upon certification of each CEMS/COMS, the owner or operator shall demonstrate 

compliance with all applicable standards as specified in this permit. The Hg CEMS shall be installed and 

functioning within the required performance specifications following the first year of operation as specified 

in condition No. 21. [Rules 62-4.070(3), 62-210.800, 62-212.400(BACT) and 62-297.520, F.A.C.; 40 CFR 

60.7(a), 60.13(b) and Appendix B; and 40 CFR 63.7(a)(2)] 

29. CEMS Data Requirements: The CEMS shall be installed, calibrated, maintained, and operated in the in-line 

kiln/raw mill stack to measure and record the emissions of CO, NOX, SO2, and THC/VOC in a manner 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

C. Pyroprocessing System 

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sufficient to demonstrate compliance with the emission limits of this permit. The CEMS shall express the 

results in units of pounds per ton of clinker produced, and pounds per hour. Emissions of VOC shall be 

reported in units of the standards (lb/hr, lb/ton of clinker) and ppmvd as propane corrected to 7% oxygen. 

a. Valid Hourly Averages: Each CEMS shall be designed and operated to sample, analyze, and record data 

evenly spaced over the hour at a minimum of one measurement per minute. All valid measurements 

collected during an hour shall be used to calculate a 1-hour block average that begins at the top of each 

hour. Each 1-hour block average shall be computed using at least one data point in each fifteen-minute 

quadrant of an hour, where the unit combusted fuel (or produced clinker) during that quadrant of an 

hour. Notwithstanding this requirement, a 1-hour average shall be computed from at least two data 

points separated by a minimum of 15 minutes (where the unit operates for more than one quadrant of an 

hour). If less than two such data points are available, there is insufficient data and the 1-hour block 

average is not valid. 

• Hours during which there is no kiln feed and no fuel fired are not valid hours. 

• Hours during which the plant is firing fuel but producing no clinker are valid, but these hours are 

excluded from the production-normalized emission rate computation (pounds per ton of clinker). 

These hours are included in any pollutant mass emission rate computation (pounds per hour). 

b. 24-hour Rolling Averages: Compliance with the emission limit for SO2 shall be based on a 24-hour 

rolling average that shall be recomputed after every valid hour as the arithmetic average of that hourly 

average and the preceding 23 valid hourly averages. 

c. 30-day Rolling Averages: Compliance with the emission limits for CO and NOX shall be based on a 30-

day rolling average. Each 30-day rolling average shall be the arithmetic average of all valid hourly 

averages collected during the last 30 operating days. A new 30-day rolling average shall be recomputed 

after every day of operation for the new day and the preceding 29 operating days. For purposes of 

computing these emission limits, an operating day is any day that the kiln produces clinker or fires fuel. 

d. 30-day Block Average: Compliance with the emission limit for VOC shall be based on a 30-day block 

average. Each 30-day block average shall be the arithmetic average of all valid hourly averages 

occurring within each 30 operating-day block and shall be consistent with the averaging period 

specified in 40 CFR 63.1350(h) for THC emissions. 

e. Data Exclusion: Except for monitoring system breakdowns, repairs, calibration checks, and zero and 

span adjustments, each CEMS shall monitor and record emissions during all operations including 

episodes of startups, shutdowns, and malfunctions. Limited amounts of CEMS emissions data recorded 

during some of these episodes may be excluded from the corresponding compliance demonstration 

subject to the provisions of Condition No. 25 in this section. The permittee shall minimize the duration 

of data excluded for such episodes to the extent practicable. 

f. Availability. Monitor availability for each CEMS shall be 95% or greater in any calendar quarter. 

Monitor availability shall be reported in the quarterly excess emissions report. In the event 95% 

availability is not achieved, the permittee shall provide the Department with a report identifying the 

problems in achieving 95% availability and a plan of corrective actions that will be taken to achieve 

95% availability. The permittee shall implement the reported corrective actions within the next calendar 

quarter. Failure to take corrective actions or continued failure to achieve the minimum monitor 

availability shall be violations of this permit, except as otherwise authorized by the Compliance 

Authority. 

g. Public Access: Emission data will be available in real time on the company website. 
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C. Pyroprocessing System 

American Cement Company Project No. 1190042-001-AC 

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30. Continuous Flow Monitor: A continuous flow monitor shall be installed to determine the stack exhaust flow 

rate to be used in determining mass emission rates. The flow monitor shall be certified pursuant to 40 CFR 

60, Appendix B, Performance Specification 6. 

31. Baghouse Temperature Monitor: A continuous temperature monitor shall be installed, calibrated, operated, 

and maintained at the inlet to the baghouse for the kiln system exhaust in accordance with the requirements 

of 40 CFR 63.1350(f). [NESHAP Subpart LLL in 40 CFR 63] 

32. Aqueous Ammonia Injection: A monitoring system to continuously monitor and record the aqueous 

ammonia injection rate of the SNCR system (1-hour block averages) shall be installed, calibrated, operated, 

and maintained in accordance with the manufacturer’s recommendations. 

[Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 

REPORTING AND RECORD KEEPING

33. Operational Records: To demonstrate compliance with the limitations specified in this section, the owner or 

operator shall maintain the following records on site. 

a. For each 1-hour block of operation, continuously monitor and record the dry preheater feed rate, clinker 

production rate, fuel firing rate, heat input rate (the representative heating value of each fuel and the 

hourly fuel firing rate), and NH3/NOX molar ratio or ammonia injection rate. Records shall also 

document the dry preheater feed rate and clinker production rates for each 24-hour rolling period and 

consecutive12 months. 

b. For each fuel delivery the owner or operator shall maintain records or the quantity of fuel delivered and 

a representative analysis of the fuel including the sulfur content, higher and lower heating value, 

proximate analysis, and ultimate analyses. 

c. Maintain records demonstrating compliance with the mercury throughput limitation as required in 

Condition No. 21.a. of this permit. 

All records shall be made available to the Department and Compliance Authority upon request. 

[Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 

34. Stack Test Reports: The owner or operator of an emissions unit for which a compliance test is required shall 

file a report with the Compliance Authority on the results of each such test. The required test report shall be 

filed with the Compliance Authority as soon as practical but no later than 45 days after the last sampling run 

of each test is completed. The test report shall provide sufficient detail on the emissions unit tested and the 

test procedures used to allow the Compliance Authority to determine if the test was properly conducted and 

the test results properly computed. As a minimum, the test report, other than for an EPA or DEP Method 9 

test, shall provide the specified in Rule 62-297.310(8), F.A.C. [Rule 62-297.310(8), F.A.C.] 

35. Malfunction Notifications: If temporarily unable to comply with any condition of the permit due to 

breakdown of equipment (malfunction) or destruction by hazard of fire, wind or by other cause, the 

permittee shall immediately (within one working day) notify the Compliance Authority. Notification shall 

include pertinent information as to the cause of the problem, and what steps are being taken to correct the 

problem and to prevent its recurrence, and where applicable, the owner’s intent toward reconstruction of 

destroyed facilities. Such notification does not release the permittee from any liability for failure to comply 

with Department rules. If requested by the Compliance Authority, the owner or operator shall submit a 

quarterly written report describing the malfunction. [Rules 62-210.700(6) and 62-4.130, F.A.C.] 

36. SIP Quarterly Report: Within 30 days following the end of each calendar quarter, the permittee shall submit 

a report to the Compliance Authority summarizing: equipment malfunctions resulting in excluded CEMS 

data and/or excess emissions; mercury throughput rates; and the monitor availability of each CEMS. The 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

C. Pyroprocessing System 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 20 of 29 

report shall contain the information and follow the general format specified in Appendix F of this permit. 

[Rules 62-4.070(3), 62-4.130, and 62-212.400(BACT), F.A.C.] 

37. Used Oil Records: For each shipment of used oil received, the owner or operator shall maintain records 

from the vendor certifying that the used oil meets the above requirements for “on-specification” used oil 

fuel. Records shall include the following parameters: arsenic, cadmium, chromium, lead, total halogens, 

flash point, PCBs, sulfur content, coal ash, and heating value. Otherwise, the owner or operator shall 

sample and analyze each shipment of used oil received for the above parameters. If vendor certifications are 

relied upon, the owner or operator shall analyze at least one sample obtained each calendar year for the 

above parameters. If analytical results show that the used oil does not meet the above requirements, the 

owner or operator shall immediately: cease burning of the used oil, and notify the Compliance Authority of 

the analytical results. The analysis shall be performed via EPA-approved or ASTM methods. The permittee 

shall obtain, make, and keep the following records: 

a) Gallons of on-specification used oil received and burned each month; 

b) Name and address of all vendors delivering used oil to the facility; 

c) Copies of the vendor certifications, if obtained, and any supporting information; and 

d) Analytical results. 

The records shall be retained in a form suitable for inspection at the facility by the Department, and shall be 

retained permanently. [40 CFR 279.61, 40 CFR 761.20(e), and Rule 62-4.070(3), F.A.C.] 

38. O&M Plan for Baghouse: The permittee shall prepare an operation and maintenance (O&M) plan to address 

the schedule for inspection and preventive maintenance of the baghouse control system. The O&M plan 

shall be submitted to the Compliance Authority prior to expiration of this permit. The permittee shall 

maintain records of the condition of the control equipment for each inspection and any maintenance 

activities performed. [Rule 62-4.070(3), F.A.C., and 40 CFR 63.1350, Subpart LLL] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

D. Clinker and Additives Storage and Handling 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 21 of 29 

The specific conditions of this subsection apply to the following emissions unit after construction is complete. 

EU ID Emissions Unit Description

004 Clinker and Additives Storage and Handling. Includes clinker handling from clinker cooler to 

clinker silo discharge, and clinker and additive handling from storage to the finish mill. 

The following emissions points in the raw materials conveying, storage, and processing system are controlled by 

baghouses: 

Point ID Emissions Point Description

L03 Dust collector for clinker transfer cooler discharge 

L06 Dust collector for clinker transfer to clinker silo #1 

L08 Dust collector for clinker transfer to clinker silo #2 

M08 Dust collector for clinker transfer from clinker silos 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for, 

particulate matter (PM/PM10). To satisfy the BACT requirements for this unit the visible emissions limits 

act as surrogate standards for PM. 

2. NESHAP Requirements: This unit is subject to 40 CFR 63, Subpart A (Identification of General 

Provisions) and 40 CFR 63, Subpart LLL (National Emissions Standard for Hazardous Air Pollutants from 

the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions 

performance requirements are as stringent as or more stringent than the limits imposed by the applicable 

NESHAP provisions. Some separate reporting and monitoring may be required by the individual subpart. 

EQUIPMENT AND CONTROL TECHNOLOGY

3. Equipment Description: The permittee is authorized to construct, operate, and maintain equipment needed for 

the conveying and storage of clinker, and the additive (limestone and gypsum) storage and conveying to the 

finish mills. Equipment will include two clinker silos, gypsum and limestone pile covered storage, and 

associated conveyors, and control equipment. 

4. Baghouse Controls: Each emissions point identified for clinker storage and conveying shall be controlled 

by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a 

PM design specification of 0.01 gr/dscf and a PM10 design specification of 0.007 gr/dscf. 

[Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 

PERFORMANCE REQUIREMENTS

5. Hours of Operation: This emissions unit is allowed to operate 8,760 hours per year. [Applicant Request, 

Rule62-210.200(PTE), F.A.C 

EMISSIONS AND TESTING REQUIREMENTS

6. Emissions Limits: The following standards apply to each emissions point of this unit including all raw 

material storage and conveying system transfer points: 

c. Emissions are limited to 5% opacity from each of the above listed emissions points controlled by a 

baghouse. 

d. Emissions are limited to 10% opacity from any emissions point not controlled by a baghouse. 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

D. Clinker and Additives Storage and Handling 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 22 of 29 

[Rule 62-212.400(BACT), F.A.C.] 

{Note: The applicant advised that the baghouses are designed to control PM emissions to 0.01 grains/dry 

standard cubic foot (gr/dscf) and PM10 emissions to 0.007 gr/dscf. The 5% opacity limitation is consistent 

with this design and provides reasonable assurance that annual emissions of PM/PM10 for all emission 

points in this emission unit system will be no more than 4 TPY. Exceedance of the 5% opacity limit shall 

be deemed an exceedance of this permit condition and not necessarily an exceedance of the opacity 

limitations given in 40 CFR 63, Subpart LLL.} 

[Rules 62-4.070(3), 62-212.400, F.A.C. and 40 CFR 63.1348] 

7. Compliance Demonstrations: Each emission point shall be tested to demonstrate initial compliance with the 

emission standards for visible emissions. The tests shall be conducted within 60 days after achieving the 

maximum production rate at which the unit will be operated, but not later than 180 days after the initial 

startup. Compliance with the visible emission limits shall be demonstrated during each federal fiscal year 

(October 1st to September 30th). [Rules 62-4.070(3), 62-297.310(7)(a), F.A.C. and 40 CFR 63.1349(b)(2)] 

8. Periodic Monitoring Requirements: Each affected source subject to an opacity standard shall be periodically 

monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance 

with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL] 

9. Test Methods: Any required tests shall be performed in accordance with the following reference methods and 

the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions. 

Method Description of Method and Comments 

9 Visual Determination of the Opacity of Emissions from Stationary Sources 

22 Visual Determination of Fugitive Emissions From Material Sources 

REPORTING AND RECORD KEEPING

10. Baghouse O&M Plan: For each baghouse the permittee shall prepare an operation and maintenance (O&M) 

plan to address proper operation, parametric monitoring, and a schedule for conducting periodic inspections 

and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written 

log. The O&M plan shall be submitted to the Compliance Authority prior to the initial compliance tests for 

this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL] 

11. Test Reports: For each test conducted, the permittee shall file a test report including the information specified 

in Rule 62-297.310(8), F.A.C. with the compliance authority no later than 45 days after the last run of each 

test is completed. [Rules 62-297.310(8), F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

E. Finish Mill 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 23 of 29 

The specific conditions of this subsection apply to the following emissions unit after construction is complete. 

ID No. Emissions Unit Description

005 Finish Mill (Cement Grinding) 

The cement grinding process includes the following emission points controlled by fabric filter baghouses. 

Point ID Emissions Point Description

N93 Finish Mill Air Separator 

N94 Finish Mill 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for 

particulate matter (PM/PM10). To satisfy some of the BACT requirements for this unit the visible emissions 

limits act as surrogate standards for PM. 

2. NESHAP Requirements: This unit is subject to 40 CFR 63, Subpart A (Identification of General 

Provisions) and 40 CFR 63, Subpart LLL (National Emissions Standard for Hazardous Air Pollutants from 

the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions 

performance requirements are as stringent as or more stringent than the limits imposed by the applicable 

NESHAP provisions. Some separate reporting and monitoring may be required by the individual subpart. 

EQUIPMENT AND CONTROL TECHNOLOGY

3. Equipment Description: The permittee is authorized to construct, operate, and maintain one finish mill in a 

closed circuit with a high efficiency air separator and cyclones capable of processing approximately 159 tons 

per hour of cement. Other equipment will include associated enclosed conveyors, bucket elevators, belts, and 

control equipment. 

4. Baghouse Controls: Each emissions point identified for cement grinding shall be controlled by a baghouse 

system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design 

specification of 0.01 gr/dscf and a PM10 design specification of 0.007 gr/dscf. [Rules 62-4.070(3) and 62-

212.400(BACT), F.A.C.] 

PERFORMANCE REQUIREMENTS

5. Hours of Operation: This emissions unit is allowed to operate 8,760 hours per year. [Applicant Request, 

Rule62-210.200(PTE), F.A.C 

EMISSIONS AND TESTING REQUIREMENTS

6. Finish Mill: Visible emissions are limited to 5% opacity from the finish mill baghouse (Point ID N94). [Rule 

62-212.400(BACT), F.A.C.] 

{Note: The applicant advised that the baghouse is designed to control PM emissions to 0.01 grains/dry 

standard cubic foot (gr/dscf) and PM10 emissions to 0.007 gr/dscf. The 5% opacity limitation is consistent 

with this design and provides reasonable assurance that annual emissions of PM/PM10 for this emission 

point in this emission unit system will be less than 5.8 TPY. Exceedance of the 5% opacity limit shall be 

deemed an exceedance of this permit condition and not necessarily an exceedance of the opacity limitations 

given in 40 CFR 63, Subpart LLL.} 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

E. Finish Mill 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 24 of 29 

7. Finish Mill Air Separator: The following standards apply to the finish mill air separator (Point ID N93): 

PM/ PM10 Visible Emissions 

0.007 gr/dscf 5% Opacity 

All PM emitted from the baghouse exhaust is assumed to be PM10. The BACT requirements do not waive 

or vary any applicable NESHAP monitoring or record keeping requirements. 

[Rule 62-212.400(BACT), F.A.C.] 

{Permitting Note: This emissions point accounts for almost 25% (34.9 TPY) of the facility’s total PM 

emissions.} 

8. Testing Requirements: Emission point N93 shall be tested to demonstrate initial compliance with the 

applicable standards for PM/PM10, and visible emissions. All other emission points shall be tested for visible 

emissions only. The tests shall be conducted within 60 days after achieving a daily average clinker 

production rate of 125 tons per hour, but not later than 180 days after the initial startup. Thereafter, 

compliance with the visible emission limits shall be demonstrated during each federal fiscal year (October 1st

to September 30th). Compliance with the particulate matter standard shall be demonstrated during the 12 

month period prior to each renewal of the operation permit. [Rule 62-297.310(7) (a), F.A.C.] 

9. Periodic Monitoring Requirements: Each affected source subject to an opacity standard shall be periodically 

monitored using the procedures described in 40 CFR 63.1350(e) to ensure compliance with the emissions 

limits of condition No. 6 and 7. 

[Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL] 

10. Test Methods: Any required tests shall be performed in accordance with the following reference methods and 

the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions. 

Method Description of Method and Comments 

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture 

Content. Methods shall be performed as necessary to support other methods.

5 Determination of Particulate Emissions. The minimum sample volume shall be 30 dry 

standard cubic feet.

9 Visual Determination of the Opacity of Emissions from Stationary Sources 

22 Visual Determination of Fugitive Emissions From Material Sources 

REPORTING AND RECORD KEEPING

11. Baghouse O&M Plan: For each baghouse the permittee shall prepare an operation and maintenance (O&M) 

plan to address proper operation, parametric monitoring, and a schedule for conducting periodic inspections 

and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written 

log. The O&M plan shall be submitted to the Compliance Authority prior to the initial compliance tests for 

this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL] 

12. Test Reports: For each test conducted, the permittee shall file a test report including the information 

specified in Rule 62-297.310(8), F.A.C. with the compliance authority no later than 45 days after the 

last run of each test is completed. [Rules 62-297.310(8), F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

F. Cement Handling, Storage, Packing, and Loadout 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 25 of 29 

The specific conditions of this subsection apply to the following emissions unit after construction is complete. 

ID No. Emissions Unit Description

006 Cement Handling, Storage, Packing, and Loadout. Includes cement conveyance to silos, cement 

silos, loadout to trucks from silos, and cement bagging operations. 

The following emissions points in the cement handling, storage, packing, and loadout system are controlled by 

baghouses: 

Point ID Emissions Point Description

N91 Cement Transfer from Finish Mill 

Q25 Cement Silo #1 

Q26 Cement Silo #2 

Q14 Truck Loadout #1 

Q17 Truck Loadout #2 

R12A Packing Plant 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for 

particulate matter (PM/PM10). 

2. NESHAP Requirements: This unit is subject to 40 CFR 63, Subpart A (Identification of General 

Provisions) and 40 CFR 63, Subpart LLL (National Emissions Standard for Hazardous Air Pollutants from 

the Portland Cement Manufacturing Industry). The Department determines that the BACT emissions 

performance requirements are as stringent as or more stringent than the limits imposed by the applicable 

NESHAP provisions. Some separate reporting and monitoring may be required by the individual subpart. 

EQUIPMENT AND CONTROL TECHNOLOGY

3. Equipment Description: The permittee is authorized to construct, operate, and maintain equipment needed for 

cement storage, loadout to trucks, and bagging operations. Equipment will include two concrete cement silos 

with rotary shut-off valves, flow control valve, and airslides. The cement bagging operation includes a 

screen, surge hopper, bucket elevator and packer. Operation is estimated to be nominally 500 tons per hour of 

cement to truck loadout and/or bagging operation. 

4. Baghouse Controls: Each emissions point identified for finish mills cement processing shall be controlled 

by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a 

PM design specification of 0.01 gr/dscf and a PM10 design specification of 0.007 gr/dscf. 

[Rules 62-4.070(3) and 62-212.400(BACT), F.A.C.] 

PERFORMANCE REQUIREMENTS

5. Hours of Operation: This emissions unit is allowed to operate 8,760 hours per year. [Applicant Request, 

Rule62-210.200(PTE), F.A.C 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

F. Cement Handling, Storage, Packing, and Loadout 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 26 of 29 

EMISSIONS AND TESTING REQUIREMENTS

6. Emissions Limits: The following standards apply to each emissions point of this unit: 

a. Emissions are limited to 5% opacity from each of the above listed emissions points controlled by a 

baghouse. 

b. Emissions are limited to 10% opacity from any emissions point not controlled by a baghouse. 

[Rule 62-212.400(BACT), F.A.C.] 

{Note: The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) 

and PM10 emissions to 0.007 gr/dscf. The 5% opacity limitation is consistent with this design and provides 

reasonable assurance that annual emissions of PM/PM10 for all emission points in this emission unit system 

will be less than 15.1 TPY. Exceedance of the 5% opacity limit shall be deemed an exceedance of this 

permit condition and not necessarily an exceedance of the opacity limitations given in 40 CFR 63, Subpart 

LLL.} 

[Rules 62-4.070(3), 62-212.400, F.A.C. and 40 CFR 63.1348] 

7. Compliance Demonstrations: Each emission point shall be tested to demonstrate initial compliance with the 

emission standards for visible emissions. The tests shall be conducted within 60 days after achieving the 

maximum production rate at which the unit will be operated, but not later than 180 days after the initial 

startup. Compliance with the visible emission limits shall be demonstrated during each federal fiscal year 

(October 1st to September 30th). [Rules 62-4.070(3), 62-297.310(7)(a), F.A.C. and 40 CFR 63.1349(b)(2)] 

8. Periodic Monitoring Requirements: Each affected source subject to an opacity standard shall be periodically 

monitored using the procedures described in 40 CFR 63.1350(a) (4) (i) through (vii) to ensure compliance 

with the emissions limits of condition No. 6. [Rule 62-4.070(3), and 40 CFR, 63.1350, Subpart LLL] 

9. Test Methods: Any required tests shall be performed in accordance with the following reference methods and 

the applicable requirements of Appendix C of this permit, and the applicable NESHAP provisions. 

Method Description of Method and Comments 

9 Visual Determination of the Opacity of Emissions from Stationary Sources 

22 Visual Determination of Fugitive Emissions From Material Sources 

REPORTING AND RECORD KEEPING

10. Baghouse O&M Plan: For each baghouse the permittee shall prepare an operation and maintenance (O&M) 

plan to address proper operation, parametric monitoring, and a schedule for conducting periodic inspections 

and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written 

log. The O&M plan shall be submitted to the Compliance Authority prior to the initial compliance tests for 

this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL] 

11. Test Reports: For each test conducted, the permittee shall file a test report including the information specified 

in Rule 62-297.310(8), F.A.C. with the compliance authority no later than 45 days after the last run of each 

test is completed. [Rules 62-297.310(8), F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

G. Coal and Petroleum Coke Grinding System 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 27 of 29 

The specific conditions of this subsection apply to the following emissions unit. 

ID No. Emissions Unit Description

007 Coal and Petroleum Coke Grinding System. Includes coal/petroleum coke handling from railcar 

unloading to the pulverized fuel bin. 

The coal and petroleum coke grinding system includes the following emissions points controlled by fabric filter 

baghouses. 

Point ID Emissions Point Description

S22 Coal/Petroleum Coke Mill Including Thermal Dryer 

S26 Coal/Petroleum Coke Bin 

APPLICABLE STANDARDS AND REGULATIONS

1. BACT Determinations: A determination of the Best Available Control Technology (BACT) was made for 

particulate matter (PM/PM10). To satisfy some of the BACT requirements for this unit the visible emissions 

limits act as surrogate standards for PM. 

2. NSPS Requirements: This unit is subject to 40 CFR 60, Subpart A (Identification of General Provisions) 

and 40 CFR 60, Subpart Y (Standards of Performance for Coal Preparation Plants). The Department 

determines that the BACT emissions performance requirements are as stringent as or more stringent than the 

limits imposed by the applicable NSPS provisions. Some separate reporting and monitoring may be 

required by the individual subpart. 

EQUIPMENT AND CONTROL TECHNOLOGY

3. Equipment Description: The permittee is authorized to construct, operate, and maintain equipment needed for 

coal and petroleum coke grinding and storage. Equipment will include a coal/petroleum coke grinding mill, 

storage bins, and associated conveyor systems. Clinker cooler gas will be used for drying. 

4. Baghouse Controls: Each emissions point identified for the coal and petroleum coke grinding system shall 

be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to 

achieve a PM design specification of 0.01 gr/dscf and a PM10 design specification of 0.007 gr/dscf. [Rules 

62-4.070(3) and 62-212.400(BACT), F.A.C.] 

PERFORMANCE REQUIREMENTS

5. Hours of Operation: The hours of operation for this emissions unit are not limited (8760 hours per year). 

[Rule62-210.200(PTE), F.A.C.] 

6. Process Rate Limitation: The coal/petroleum coke mill may process up to 18.5 tons per hour of 

coal/petroleum coke. No more than 134,904 tons of coal/petroleum coke shall be process during any 

consecutive 12 months. [Rule62-210.200(PTE), F.A.C.] 

EMISSIONS AND TESTING REQUIREMENTS

7. Particulate Matter Standards: Particulate matter emissions from the thermal dryer (Point ID S22) shall not 

exceed 0.007 grains per dscf of exhaust as determined by EPA method 5. [Rules 62-212.400 (BACT), 

F.A.C. and 40 CFR 60.252] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

G. Coal and Petroleum Coke Grinding System 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 28 of 29 

8. Visible Emissions Standards: Visible emissions shall not exceed the following limits. 

• Visible emission from any emissions point described above and controlled by a baghouses shall not 

exceed 5% opacity. 

• Visible emissions from all coal/petcoke processing and conveying equipment, coal/petcoke storage 

system, or coal/petcoke transfer and loading system processing coal/petcoke, and not controlled by a 

baghouse, shall not exceed 10% opacity. 

[Rules 62-212.400 (BACT), F.A.C. and CFR 60.252] 

9. Testing Requirements: Emission point S22 shall be stack tested to demonstrate initial compliance with the 

applicable emission standards for PM/PM10 and visible emissions. All other emission points shall be tested 

for visible emissions only. The tests shall be conducted within 60 days after achieving the maximum 

production rate at which the unit will be operated, but not later than 180 days after the initial startup. 

Thereafter, compliance with the particulate limits (PM/PM10) shall be demonstrated within the 12 month 

period prior to each renewal of the operation permit and compliance with the visible emission limits shall be 

demonstrated during each federal fiscal year (October 1st to September 30th). [Rule 62-297.310(7)(a), 

F.A.C.] 

10. Test Methods: Any required tests shall be performed in accordance with the following reference methods and 

the applicable requirements of Appendix C of this permit, and the applicable NSPS provisions. 

Method Description of Method and Comments 

1 - 4 Determination of Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture 

Content. Methods shall be performed as necessary to support other methods.

5 Determination Particulate Matter from Stationary Sources 

9 Visual Determination of the Opacity of Emissions from Stationary Sources 

CONTINUOUS MONITORING REQUIREMENTS

11. Thermal Dryer Exit Temperature: A monitoring device for the continuous measurement of the temperature of 

the gas stream at the exit of the thermal dryer shall be installed, calibrated, maintained, and continuously 

operated to measure the temperature of the gas stream in accordance with the requirements of 40 CFR, 

Subpart Y. [CFR 60, Subpart Y] 

REPORTING AND RECORD KEEPING

12. Baghouse O&M Plan: For each baghouse the permittee shall prepare an operation and maintenance (O&M) 

plan to address proper operation, parametric monitoring, and a schedule for conducting periodic inspections 

and preventive maintenance. Baghouse inspections and maintenance activities shall be recorded in a written 

log. The O&M plan shall be submitted to the Compliance Authority prior to the initial compliance tests for 

this unit. [Rule 62-4.070(3), and 40 CFR 63.1350, Subpart LLL] 

13. Test Reports: For each test conducted, the permittee shall file a test report including the information 

specified in Rule 62-297.310(8), F.A.C. with the compliance authority no later than 45 days after the last 

run of each test is completed. [Rules 62-297.310(8), F.A.C.] 
SECTION III. EMISSIONS UNIT SPECIFIC CONDITIONS

H. Fugitive Dust From Storage Piles, Paved Roads, and Unpaved Roads 

American Cement Company Project No. 1190042-001-AC 

Sumterville Cement Plant Air Permit No. PSD-FL-361 

Page 29 of 29 

The following specific conditions apply to the following emissions units after construction. 

ID No. Emissions Unit Description

008 Fugitive Dust From Storage Piles, Paved Roads, and Unpaved Roads 

PERFORMANCE REQUIREMENTS

1. Unconfined Emissions of Particulate Matter

a. No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from 

any activity without taking reasonable precautions to prevent such emissions. Such activities include, 

but are not limited to: vehicular movement; transportation of materials; construction, alteration, 

demolition or wrecking; or industrially related activities such as loading, unloading, storing or handling. 

b. Reasonable precautions shall include the following: 

(1) Landscaping and planting of vegetation. 

(2) Application of water to control fugitive dust from activities such as demolition of buildings, 

grading roads, construction, and land clearing. 

(3) Water supply lines, hoses and sprinklers shall be located near all stockpiles of raw materials, coal, 

and petroleum coke. 

(4) All plant operators shall be trained in basic environmental compliance and shall perform visual 

inspections of raw materials, coal and petroleum coke periodically and before handling. If the 

visual inspections indicate a lack of surface moisture, such materials shall be wetted with 

sprinklers. Wetting shall continue until the potential for unconfined particulate matter emissions 

are minimized. 

(5) Water spray shall be used to wet the materials and fuel if inherent moisture and moisture from 

wetting the storage piles are not sufficient to prevent unconfined particulate matter emissions. 

(6) As necessary, applications of asphalt, water, or dust suppressants to unpaved roads, yards, open 

stockpiles and similar activities. 

(7) Paving of access roadways, parking areas, manufacture area, and fuel storage yard. 

(8) Removal of dust from buildings, roads, and other paved areas under the control of the owner or 

operator of the facility to prevent particulate matter from becoming airborne. 

(9) A vacuum sweeper shall be used to remove dust from paved roads, parking, and other work areas. 

(10) Enclosure or covering of conveyor systems where practicably feasible. 

(11) All materials at the plant shall be stored under roof. Materials, other than quarried materials, shall 

be stored on compacted clay or concrete, or in enclosed vessels. 

(12) Use of hoods, fans, filters, and similar equipment to contain, capture and/or vent particulate 

matter. 

(13) Confining abrasive blasting where possible. 

c. In determining what constitutes reasonable precautions for a particular source, the Department shall 

consider the cost of the control technique or work practice, the environmental impacts of the technique 

or practice, and the degree of reduction of emissions expected from a particular technique or practice. 

[Rules 62-212.400(BACT) and 62-296.320(4)(c), F.A.C.]