September 15, 2011

Richard Johnson

Ash Grove Cement Company

100 Montana Highway 518

Clancy, MT 59634

RE: Renewal Title V Operating Permit #OP2005-06

Dear Mr. Johnson:

The Department of Environmental Quality has prepared the enclosed Final Operating Permit #OP2005-

06, for Ash Grove Cement Company, located in Montana City, Montana. Please review the cover page of 

the attached permit for information pertaining to the action taking place on Permit #OP2005-06. 

If you have any questions, please contact Julie Merkel, the permit writer, at (406) 444-3626 or by email at 

jmerkel@mt.gov.

Sincerely,

Vickie Walsh

Air Permitting Program Supervisor

Air Resources Management Bureau

(406) 444-9741

Julie A Merkel

Air Quality Specialist

Air Resources Management Bureau

(406) 444-3626

VW: JM: 

Enclosure 

Cc: Christopher Ajayi, US EPA Region VIII 8P-AR

Carson Coate, US EPA Region Viii, Montana Office

Jeff Briggs, Ash Grove Cement Company
OP2005-06 i Date of Decision: 08/15/11

Effective Date: 09/15/11

STATE OF MONTANA

Department of Environmental Quality

Helena, Montana 59620

AIR QUALITY OPERATING PERMIT OP2005-06

Issued to: Ash Grove Cement Company

Montana City Plant

100 Montana Highway 518

Clancy, MT 59634

Final Date: September 15, 2011

Expiration Date: September 15, 2016

Effective Date: September 15, 2011

Date of Decision: August 15, 2011

End of EPA 45-day Review: August 11, 2011

Proposed Issue Date: June 27, 2011

Draft Issue Date: May 6, 2011

Application Deemed Technically Complete: March 29, 2010

Application Deemed Administratively Complete: March 29, 2010

Renewal Application Received: March 29, 2010

AFS Number: 030-043-0001A

Permit Issuance and Appeal Processes: In accordance with Montana Code Annotated (MCA) Sections 

75-2-217 and 218 and the Administrative Rules of Montana (ARM), ARM Title 17, Chapter 8, 

Subchapter 12, Operating Permit Program, this operating permit is hereby issued by the Department of 

Environmental Quality (Department) as effective and final on September 15, 2011. This permit must be 

kept on-site at the above named facility.
OP2005-06 ii Date of Decision: 08/15/11

Effective Date: 09/15/11

Montana Air Quality Operating Permit

Department of Environmental Quality

SECTION I. GENERAL INFORMATION ........................................................................................1

SECTION II. SUMMARY OF EMISSION UNITS.............................................................................2

SECTION III. PERMIT CONDITIONS............................................................................................3

A. FACILITY-WIDE........................................................................................................................... 3

B. EU001 – AIR SEPARATOR (AS).................................................................................................. 6

C. EU002 – CLINKER COOLER (CLC)............................................................................................. 7

D. EU003 – CONVEY/PRIMARY CRUSHING (CPC).......................................................................... 9

E. EU004 – FUEL CONVEYORS (FC).............................................................................................. 10

F. EU005 –FUEL TRANSFER (FT).................................................................................................. 12

G. EU006 – CEMENT KILN (KILN)................................................................................................ 14

H. EU007 – PRODUCT SEPARATOR AND CEMENT COOLERS (PSC)............................................... 17

I. EU008 –ROAD DUST (RD)........................................................................................................ 18

J. EU009 –STORAGE LOADOUT – B (SLB)................................................................................... 20

K. EU010 – STONE TRANSFER (ST)............................................................................................... 21

L. EU011 – TRANSFER BELT CONVEYORS (TBC)......................................................................... 21

M. EU012 –TRANSFER/CONVEY TO BALL MILL (TBM)................................................................ 23

N. EU013 –TRANSFER TO/FROM FINISH MILL (TFM) ................................................................... 24

O. EU014 –TRANSFER TO LIMESTONE SILOS (TLS)...................................................................... 25

P. EU015 – WIND EROSION (WE) – (FROM QUARRY ACTIVITIES)................................................. 26

SECTION IV. NON-APPLICABLE REQUIREMENTS...............................................................28

FACILITY-WIDE................................................................................................................................. 28

EMISSION UNITS ................................................................................................................................ 29

SECTION V. GENERAL PERMIT CONDITIONS .........................................................................30

A. COMPLIANCE REQUIREMENTS................................................................................................... 30

B. CERTIFICATION REQUIREMENTS ............................................................................................... 30

C. PERMIT SHIELD ......................................................................................................................... 31

D. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS ......................................... 32

E. PROMPT DEVIATION REPORTING............................................................................................... 33

F. EMERGENCY PROVISIONS.......................................................................................................... 34

G. INSPECTION AND ENTRY ........................................................................................................... 34

H. FEE PAYMENT ........................................................................................................................... 35

I. MINOR PERMIT MODIFICATIONS ............................................................................................... 35

J. CHANGES NOT REQUIRING PERMIT REVISION .......................................................................... 35

K. SIGNIFICANT PERMIT MODIFICATIONS...................................................................................... 36

L. REOPENING FOR CAUSE............................................................................................................. 37

M. PERMIT EXPIRATION AND RENEWAL......................................................................................... 37

N. SEVERABILITY CLAUSE ............................................................................................................. 38

O. TRANSFER OR ASSIGNMENT OF OWNERSHIP ............................................................................. 38

P. EMISSIONS TRADING, MARKETABLE PERMITS, ECONOMIC INCENTIVES .................................. 38

Q. NO PROPERTY RIGHTS CONVEYED ........................................................................................... 38

R. TESTING REQUIREMENTS .......................................................................................................... 38

S. SOURCE TESTING PROTOCOL .................................................................................................... 38

T. MALFUNCTIONS ........................................................................................................................ 38

U. CIRCUMVENTION....................................................................................................................... 39

V. MOTOR VEHICLES ..................................................................................................................... 39

W. ANNUAL EMISSIONS INVENTORY .............................................................................................. 39
OP2005-06 iii Date of Decision: 08/15/11

Effective Date: 09/15/11

X. OPEN BURNING ......................................................................................................................... 39

Y. MONTANA AIR QUALITY PERMITS............................................................................................ 39

Z. NATIONAL EMISSION STANDARD FOR ASBESTOS ..................................................................... 40

AA. ASBESTOS.................................................................................................................................. 40

BB. STRATOSPHERIC OZONE PROTECTION – SERVICING OF MOTOR VEHICLE AIR CONDITIONERS 40

CC. STRATOSPHERIC OZONE PROTECTION – RECYCLING AND EMISSION REDUCTIONS .................. 40

DD. EMERGENCY EPISODE PLAN...................................................................................................... 41

EE. DEFINITIONS.............................................................................................................................. 41

APPENDIX A INSIGNIFICANT EMISSION UNITS .................................................................A-1

APPENDIX B DEFINITIONS AND ABBREVIATIONS ............................................................B-1

APPENDIX C NOTIFICATION ADDRESSES............................................................................C-1

APPENDIX D AIR QUALITY INSPECTOR INFORMATION.................................................D-1

APPENDIX E POLLUTION CONTROL DEVICE INSPECTION AND MAINTENANCE 

PLAN ...................................................................................................E-1

APPENDIX F CAM PLAN – KILN STACK ELECTROSTATIC PRECIPITATOR ............. F-1

APPENDIX G CAM PLAN – FINISH MILL HOUSE BAGHOUSE .........................................G-1

APPENDIX H CAM PLAN – CLINKER COOLER STACK BAGHOUSE..............................H-1
OP2005-06 1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this 

permit have the meaning assigned to them in the referenced regulations.

SECTION I. GENERAL INFORMATION

The following general information is provided pursuant to ARM 17.8.1210(1).

Company Name: Ash Grove Cement Company

Mailing Address: 100 Montana Highway 518

City: Clancy State: Montana Zip: 59634

Plant Location: Approximately 1.8 km east of the I-15 and Highway 518 interchange near 

Montana City and approximately 5 km south of East Helena.

Responsible Official: Richard Johnson Phone: (406) 442-8855

E-mail: Dick.johnson@ashgrove.com

Facility Contact Person: Jeff Briggs Phone: (406) 444-7128

E-Mail: Jeff.briggs@ashgrove.com

Primary SIC Code: 3241 (plant), 1422 (quarry)

Nature of Business: Portland Cement Manufacturing

Description of Process: 

The production of Portland cement begins at the quarry. For Ash Grove, approximately 85 to 99 percent 

of the raw material used in the cement process are combined high and low-grade limestone quarried from 

Clark’s Gulch quarry. Limestone rock and other raw materials are blasted and loaded onto trucks and 

transported to the crusher or to stockpiles. The raw materials are conveyed from the primary and 

secondary crushers and delivered by bucket elevator to the storage bins. From the storage bins, the raw 

materials are conveyed to the ball mill where the ore is ground with water to form a slurry and sent to 

storage tanks. In the tanks, the slurry is blended thoroughly before entering the kiln. Slurry is pumped to 

the uphill end of the kiln and heated, evaporating water from the slurry forming clinker. The Ash Grove 

plant uses a combination of natural gas, coal and/or coke, heavy oils and pitch as fuel sources for the 

clinker production. When the clinker leaves the kiln, it is cooled, transported by drag chains, pan 

conveyor and bucket elevator to the clinker bins or outside storage. From there, clinker and gypsum go to 

the finish ball mill, where it is ground together with gypsum to produce Portland cement. The final 

cement product is conveyed to storage silos where it is loaded into railroad cars, bulk trucks, or bagged 

and loaded onto trucks. 
OP2005-06 2 Date of Decision: 08/15/11

Effective Date: 09/15/11

SECTION II. SUMMARY OF EMISSION UNITS

The emission units regulated by this permit are the following (ARM 17.8.1211):

Emissions Unit 

ID

Description Pollution Control 

Device/Practice

AS Air Separator Baghouse (DA-21)

CLC Clinker Cooler Baghouse (DA-23)

CPC Convey/Primary Crusher Baghouse (DA-1)

FC Fuel Conveyors None/ Conveyor and Transfer 

Point Covers, and Structural 

Enclosures

FT Fuel Transfer None/Structural Enclosures

KILN Cement Kiln Electrostatic Precipitator 

PSC Product Separator and Cement Coolers Baghouse (DA-9 East)

RD Road Dust None/Reasonable Precautions

SLB Storage Loadout - B Baghouse (DA-15)

ST Stone Transfer None

TBC Transfer Belt Conveyors Baghouse (DA-4)

TBM Transfer/Convey to Ball Mill Baghouse (DA-6)

TFM Transfer to/from Finish Mill Baghouse (DA-9 West)

TLS Transfer to Limestone Silos Baghouse (DA-5)

WE Wind Erosion None
OP2005-06 3 Date of Decision: 08/15/11

Effective Date: 09/15/11

SECTION III. PERMIT CONDITIONS

The following requirements and conditions are applicable to the facility or to specific emission units 

located at the facility (ARM 17.8.1211, 1212, and 1213).

A. Facility-Wide

Conditions Rule Citation Rule Description Pollutant/Parameter Limit

A.1 ARM 17.8.105 Testing Requirements Testing Requirements -------

A.2 ARM 17.8.304(1) Visible Air Contaminants Opacity 40%

A.3 ARM 17.8.304(2) Visible Air Contaminants Opacity 20%

A.4 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20%

A.5 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions -------

A.6 ARM 17.8.308 Particulate Matter, Airborne Reasonable Precaution, 

Construction

20%

A.7 ARM 17.8.309 Particulate Matter, Fuel 

Burning Equipment

Particulate Matter E= 0.882 * H-0.1664 Or

E= 1.026 * H-0.233

A.8 ARM 17.8.310 Particulate Matter, 

Industrial Processes

Particulate Matter E= 4.10 * P0.67 or

E= 55 * P0.11- 40

A.9 ARM 17.8.322(4) Sulfur Oxide Emissions, 

Sulfur in Fuel

Sulfur in Fuel (liquid or 

solid fuels)

1 lb/MMBtu fired

A.10 ARM 17.8.322(5) Sulfur Oxide Emissions, 

Sulfur in Fuel

Sulfur in Fuel (gaseous) 50 gr/100 CF

A.11 ARM 17.8.324(3) Hydrocarbon Emissions, 

Petroleum Products

Gasoline Storage Tanks -------

A.12 ARM 17.8.324 Hydrocarbon Emissions, 

Petroleum Products

65,000 Gallon Capacity -------

A.13 ARM 17.8.324 Hydrocarbon Emissions, 

Petroleum Products

Oil-effluent Water 

Separator

-------

A.14 ARM 17.8.342 NESHAPs General 

Provisions

SSM Plans Submittal

A.15 ARM 17.8.1211(1)(c) 

and 40 CFR Part 98

Greenhouse Gas Reporting Reporting -------

A.16 ARM 17.8.1212 Reporting Requirements Prompt Deviation 

Reporting

-------

A.17 ARM 17.8.1212 Reporting Requirements Compliance Monitoring -------

A.18 ARM 17.8.1207 Reporting Requirements Annual Certification -------

Conditions

A.1. Pursuant to ARM 17.8.105, any person or persons responsible for the emission of any air 

contaminant into the outdoor atmosphere shall, upon written request of the Department, provide 

the facilities and necessary equipment (including instruments and sensing devices) and shall 

conduct test, emission or ambient, for such periods of time as may be necessary using methods 

approved by the Department.

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 

17.8.105. In addition, for such sources, compliance with limits and conditions listing “as required 

by the Department” as the frequency, is verified annually using emission factors and engineering 

calculations by the Department’s compliance inspectors during the annual emission inventory 

review; in the case of Method 9 tests, compliance is monitored during the regular inspection by the 

compliance inspector.
OP2005-06 4 Date of Decision: 08/15/11

Effective Date: 09/15/11

A.2. Pursuant to ARM 17.8.304(1), Ash Grove shall not cause or authorize emissions to be discharged 

into the outdoor atmosphere from any source installed on or before November 23, 1968, that 

exhibit an opacity of 40% or greater averaged over six consecutive minutes, unless otherwise 

specified by rule or in this permit.

A.3. Pursuant to ARM 17.8.304(2), Ash Grove shall not cause or authorize emissions to be discharged 

into the outdoor atmosphere from any source installed after November 23, 1968, that exhibit an 

opacity of 20% or greater averaged over six consecutive minutes, unless otherwise specified by 

rule or in this permit.

A.4. Pursuant to ARM 17.8.308(1), Ash Grove shall not cause or authorize the production, handling, 

transportation, or storage of any material unless reasonable precautions to control emissions of 

particulate matter are taken. Such emissions of airborne particulate matter from any stationary 

source shall not exhibit an opacity of 20% or greater averaged over six consecutive minutes, 

unless otherwise specified by rule or in this permit.

A.5. Pursuant to ARM 17.8.308(2), Ash Grove shall not cause or authorize the use of any street, road 

or parking lot without taking reasonable precautions to control emissions of airborne particulate 

matter, unless otherwise specified by rule or in this permit.

A.6. Pursuant to ARM 17.8.308, Ash Grove shall not operate a construction site or demolition project 

unless reasonable precautions are taken to control emissions of airborne particulate matter. Such 

emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 

20% or greater averaged over six consecutive minutes, unless otherwise specified by rule or in this 

permit.

A.7. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, Ash Grove shall 

not cause or authorize particulate matter caused by the combustion of fuel to be discharged from 

any stack or chimney into the outdoor atmosphere in excess of the maximum allowable emissions 

of particulate matter for existing fuel burning equipment and new fuel burning equipment 

calculated using the following equations:

For existing fuel burning equipment (installed before November 23, 1968): 

E =0.882 * H-0.1664

For new fuel burning equipment (installed on or after November 23, 1968):

E =1.026 * H-0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum 

allowable particulate emissions rate in pounds per MMBtu.

A.8. Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, Ash Grove shall 

not cause or authorize particulate matter to be discharged from any operation, process, or activity 

into the outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate 

matter calculated using the following equations:

For process weight rates up to 30 tons per hour: E = 4.10 * P0.67

For process weight rates in excess of 30 tons per hour: E = 55.0 * P0.11– 40

Where E = rate of emissions in pounds per hour and p = process weight rate in tons per hour.

A.9. Pursuant to ARM 17.8.322(4), Ash Grove shall not burn liquid or solid fuels containing sulfur in 

excess of 1 pound per million BTU fired, unless otherwise specified by rule or in this permit.
OP2005-06 5 Date of Decision: 08/15/11

Effective Date: 09/15/11

A.10. Pursuant to ARM 17.8.322(5), Ash Grove shall not burn any gaseous fuel containing sulfur 

compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen 

sulfide at standard conditions, unless otherwise specified by rule or in this permit.

A.11. Pursuant to ARM 17.8.324(3), Ash Grove shall not load or permit the loading of gasoline into any 

stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except 

through a permanent submerged fill pipe, unless such tank is equipped with a vapor loss control 

device or is a pressure tank as described in ARM 17.8.324(1), unless otherwise specified by rule 

or in this permit.

A.12. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, Ash Grove shall 

not place, store or hold in any stationary tank, reservoir or other container of more than 65,000 

gallon capacity any crude oil, gasoline or petroleum distillate having a vapor pressure of 2.5 

pounds per square inch absolute or greater under actual storage conditions, unless such tank, 

reservoir or other container is a pressure tank maintaining working pressure sufficient at all times 

to prevent hydrocarbon vapor or gas loss to the atmosphere, or is designed and equipped with a 

vapor loss control device, properly installed, in good working order and in operation. 

A.13. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, Ash Grove shall 

not use any compartment of any single or multiple-compartment oil-effluent water separator, 

which compartment receives effluent water containing 200 gallons a day or more of any petroleum 

product from any equipment processing, refining, treating, storing or handling kerosene or other 

petroleum product of equal or greater volatility than kerosene, unless such compartment is 

equipped with a vapor loss control device, constructed so as to prevent emission of hydrocarbon 

vapors to the atmosphere, properly installed, in good working order and in operation. 

A.14. Pursuant to ARM 17.8.342 and 40 CFR 63.6, Ash Grove shall submit to the Department a copy of 

any startup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6(e)(3) within 30 

days of the effective date of this operating permit (if not previously submitted), within 30 days of 

the compliance date of any new National Emission Standard for Hazardous Air Pollutants 

(NESHAPs) or Maximum Achievable Control Technology (MACT) standard, and within 30 days 

of the revision of any such SSM plan, when applicable. The Department requests submittal of 

such plans in electronic form, when possible.

A.15. Pursuant to ARM 17.8.1211(1)(c) and 40 CFR Part 98, Ash Grove shall comply with requirements 

of 40 CFR Part 98 – Mandatory Greenhouse Gas Reporting, as applicable (ARM 17.8.1211(1)(c), 

NOT an applicable requirement under Title V).

A.16. Ash Grove shall promptly report deviations from permit requirements including those attributable 

to upset conditions, as upset is defined in the permit. To be considered prompt, deviations shall be 

reported to the Department using the schedule and content as described in Section V.E (unless 

otherwise specified in an applicable requirement) (ARM 17.8.1212).

A.17. On or before February 15 and August 15 of each year, Ash Grove shall submit to the Department 

the compliance monitoring reports required by Section V.D. These reports must contain all 

information required by Section V.D, as well as the information required by each individual 

emissions unit. For the reports due by February 15 of each year, Ash Grove may submit a single 

report, provided that it contains all the information required by Section V.B & V.D. Per ARM 

17.8.1207, 

any application form, report, or compliance certification submitted 

pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including 

semiannual monitoring reports), shall contain certification by a 

responsible official of truth, accuracy and completeness. This 
OP2005-06 6 Date of Decision: 08/15/11

Effective Date: 09/15/11

certification and any other certification required under ARM Title 17, 

Chapter 8, Subchapter 12, shall state that, “based on information and 

belief formed after reasonable inquiry, the statements and information 

in the document are true, accurate and complete.”

A.18. By February 15 of each year, Ash Grove shall submit to the Department the compliance 

certification required by Section V.B. The annual certification required by Section V.B must 

include a statement of compliance based on the information available that identifies any observed, 

documented or otherwise known instance of noncompliance for each applicable requirement. Per 

ARM 17.8.1207,

any application form, report, or compliance certification submitted 

pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including annual 

certifications), shall contain certification by a responsible official of 

truth, accuracy and completeness. This certification and any other 

certification required under ARM Title 17, Chapter 8, Subchapter 12, 

shall state that, “based on information and belief formed after 

reasonable inquiry, the statements and information in the document 

are true, accurate and complete.”

B. EU001 – Air Separator (AS)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

B.1, B.4, B.7, 

B.9., B.10., 

B.11

Opacity 10% Method 9 As Required by 

the Department 

and Section 

III.A.1

Semi-Annual

B.2, B.5, B.7, 

B.9., B.10., 

B.11

Particulate Matter 0.01 gr/dscf Method 5 Once during 5-

year permit term

Semi-Annual

B.3, B.6, B.8, 

B.10., B.11

Emission Control 

Equipment

Operation and 

maintenance of 

emission control 

equipment

Operation and 

maintenance 

of baghouse

Whenever process 

equipment is 

operating

Semi-Annual

Conditions

B.1. Ash Grove shall not cause or authorize emissions to be discharged into the outdoor atmosphere 

from the air separator baghouse that exhibit an opacity of 10% or greater averaged over six 

consecutive minutes (ARM 17.8.340).

B.2. Particulate emissions from the air separator baghouse shall not exceed 0.01 gr/dscf (ARM 

17.8.752).

B.3. Ash Grove shall operate and maintain the baghouse when process equipment is operating (ARM 

17.8.749). 

Compliance Demonstration

B.4. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 test, to 

demonstrate compliance with the 10% opacity limit in Section III.B.1. The test methods and 

procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures manual (ARM 17.8.106 and ARM 17.8.1213).
OP2005-06 7 Date of Decision: 08/15/11

Effective Date: 09/15/11

B.5. A Method 5 or other Department approved test shall be performed once during the 5-year permit 

period, to monitor compliance with the particulate emission limit in Section III.B.2. The test shall 

be conducted in accordance with the Montana Source Test Protocol and Procedures Manual and 

maintained on site (ARM 17.8.106 and ARM 17.8.1213). 

B.6. Ash Grove shall operate, inspect, and maintain the baghouse in accordance with Appendix E to 

monitor compliance with Section III.B.3 (ARM 17.8.1213).

Recordkeeping

B.7. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

B.8. Ash Grove shall maintain, on site, records of all inspection and maintenance activities performed 

on the baghouse in accordance with the requirements in Appendix E. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212).

Reporting

B.9. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106).

B.10. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212).

B.11. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of any source testing that was performed during the semiannual period;

b. A summary of any instance that the baghouse was not operated and maintained as required by 

Section III.B.6;

c. A summary of any instance in which the documents required in Section III.B.7, Section 

III.B.8, and Section III.B.9 were not maintained

C. EU002 – Clinker Cooler (CLC)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

C.1, C.5., 

C.9., C.10., 

C.12., C.13., 

C.14

Opacity 20% Method 9 As Required by 

the Department 

and Section 

III.A.1

Semiannual

C.2, C.3., 

C.6., C.7., 

C.9., C.11., 

C.12., C.13., 

C.14

Particulate Matter E=55.0P0.11 - 40 Operation and 

maintenance of 

baghouse

Whenever process 

equipment is 

operating

Semiannual

Method 5 Once during 5-

year permit term

As required by 

the Protocol

C.4., C.8.,. 

C.12., C.13., 

C.14

PM CAM Plan ARM 17.8.1506 Provisions from 

CAM Plan, 

Appendix H

Ongoing Semiannual
OP2005-06 8 Date of Decision: 08/15/11

Effective Date: 09/15/11

Conditions

C.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from the clinker cooler baghouse that exhibit an opacity of 20% or greater averaged over six 

consecutive minutes (ARM 17.8.304(1)).

C.2. Pursuant to ARM 17.8.310, the particulate emissions from process weight shall not exceed the 

value calculated by E=55.0P0.11 - 40, where E = rate of emission in pounds per hour and P = 

process weight rate in tons per hour (ARM 17.8.310).

C.3. Ash Grove shall operate and maintain the baghouse when process equipment is operating (ARM 

17.8.749). 

C.4. Ash Grove shall provide a reasonable assurance of compliance with emission limitations or 

standards for the anticipated range of operations at the Clinker Cooler for PM (ARM 17.8.1504).

Compliance Demonstration

C.5. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 test, to 

demonstrate compliance with the 20% opacity limit in Section III.C.1. The test methods and 

procedures shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures manual and maintained on site (ARM 17.8.106 and ARM 17.8.1213).

C.6. A Method 5 or other Department approved test shall be performed once during the 5-year permit 

period, to monitor compliance with the particulate emission limit in Section III.C.2. The test shall 

be conducted in accordance with the Montana Source Test Protocol and Procedures Manual and 

maintained on site (ARM 17.8.106 and ARM 17.8.1213). 

C.7. Ash Grove shall operate, inspect, and maintain the baghouse in accordance with Appendix E to 

monitor compliance with Section III.C.3 (ARM 17.8.1213).

C.8. Ash Grove shall monitor compliance by following the Compliance Assurance Monitoring (CAM) 

Plan (Appendix H). The CAM Plan, written by Ash Grove in accordance with ARM 17.8.1504 is 

summarized in Appendix H and is available in full upon request by the Department or the facility 

(ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

C.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

C.10. If visual surveys are performed, Ash Grove shall maintain a log to verify that the visual surveys 

were performed as specified in Section III.C.5. Each log entry must include the date, time, results 

of survey (and results of subsequent Method 9, if applicable), and observer’s initials If any 

corrective action is required, the time, date, observer’s initials, and any preventive or corrective 

action taken must be recorded in the log (ARM 17.8.1212).

C.11. Ash Grove shall maintain, on site, records of all inspection and maintenance activities performed 

on the baghouse in accordance with the requirements in Appendix E. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212).
OP2005-06 9 Date of Decision: 08/15/11

Effective Date: 09/15/11

C.12. Ash Grove shall prepare and keep data in accordance with 40 CFR Part 64 and the CAM Plan, 

Appendix H of this permit (ARM 17.8.1212 and 40 CFR 64).

Reporting

C.13. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212).

C.14. The semiannual reporting shall provide (ARM 17.8.1212);

a. A summary of results of any source testing that was performed during that semiannual period;

b. A summary of any instance that the baghouse was not operated and maintained as required by 

Section III.C.3;

c. A summary of any time period when documents required in Section III.C.10, and Section 

III.C.11 were not maintained;

d. Any reporting required by 40 CFR Part 64 and the CAM Plan Appendix H of this permit, as 

applicable, during that semiannual period.

D. EU003 – Convey/Primary Crushing (CPC)

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

D.1., D.4., 

D.7., D.9., 

D.10

Opacity 7% Method 9 Once during 5-year 

permit term

As required by the 

Protocol

D.2.,D.5., 

D.7., D.9., 

D.10

Particulate 

Matter

0.02 gr/dscf Method 5 Once during 5-year 

permit term

As required by the 

Protocol

D.3.,D.6., 

D.8., D.9., 

D.10

Emissions 

Control 

Equipment

Operation and 

maintenance of emission 

control equipment

Operation and 

maintenance of 

baghouse

Semiannual Semiannual

Conditions

D.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any transfer point or belt conveyor or from any other affected facility any stack emissions 

that exhibit greater than 7 percent opacity (40 CFR 60.672(a)(2)).

D.2. Particulate emissions from the dust collection system shall not exceed 0.02 gr/dscf (ARM 

17.8.752).

D.3. Ash Grove shall operate and maintain emission control equipment when process equipment is 

operating (ARM 17.8.749).

Compliance Demonstration

D.4. A Method 9 test shall be performed once during the 5-year permit period to monitor compliance 

with the 7% opacity limit in Section III.D.1. The test methods and procedures shall be conducted 

in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1213). 
OP2005-06 10 Date of Decision: 08/15/11

Effective Date: 09/15/11

D.5. A Method 5 or other Department approved test shall be performed once during the 5-year permit 

period to monitor compliance with the particulate emission limitation in Section III.D.2. The test 

methods and procedures shall be conducted in accordance with 40 CFR 60.675(b) and the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

D.6. Ash Grove shall inspect and maintain the baghouse in accordance with Appendix E of this permit 

to monitor compliance with Section III.D.3 (ARM 17.8.1213).

Recordkeeping

D.7. All source testing recordkeeping shall be performed in accordance with the Source Test Protocol 

and Procedures Manual and maintained on site (ARM 17.8.106 and ARM 17.8.1212).

D.8. Ash Grove shall maintain records of all inspection and maintenance activities performed on the 

baghouse in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212).

Reporting

D.9. The annual compliance certification required by Section V.B must contain a certification statement 

for the above applicable requirements (ARM 17.8.1212).

D.10. The semiannual reporting shall provide (ARM 17.8.1212): 

a. A summary of the records required by Section III.D.8 for any time period that the 

records were not maintained

b. A summary of results of any source testing that was performed during that semiannual 

period.

E. EU004 – Fuel Conveyors (FC)

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

E.1., E.3., 

E.4., E.5., 

E.6., E.7

Opacity 20% Method 9 As required by the 

Department and 

Section III.A.1

Semiannual

Use and maintenance 

of structural 

enclosures and covers

Whenever process 

equipment is 

operating

Semiannual

E.2., E.4., 

E.5., E.6., E.7

Particulate 

Matter

E=55.0p0.11-40 Use and maintenance 

of structural 

enclosures and covers

Whenever process 

equipment is 

operating

Semiannual

Conditions

E.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed after November 23, 1968 that exhibit an opacity of 20% or greater 

averaged over six consecutive minutes (ARM 17.8.304).

E.2. Pursuant to ARM 17.8.310, the particulate emissions from process weight shall not exceed the 

value calculated by E=55.0p0.11-40, where E = rate of emission in pounds per hour and p = process 

weight rate in tons per hour (ARM 17.8.310).
OP2005-06 11 Date of Decision: 08/15/11

Effective Date: 09/15/11

Compliance Demonstration

E.3. As required by the Department and Section III.A.1, Ash Grove shall conduct either a semiannual 

Method 9 source test or a weekly visual survey of visible emissions on the Fuel Conveyors. 

Under the visual survey option, once per calendar week, during daylight hours, Ash Grove shall 

visually survey the Fuel Conveyors for any visible emissions. If visible emissions are observed 

during the visual survey, Ash Grove must either conduct a Method 9 source test, or shut down the 

equipment for repairs. The Method 9 source test or source shutdown must begin within one hour 

of any observation of visible emissions. If visible emissions meet or exceed 15% opacity based on 

the Method 9 source test, Ash Grove shall immediately take corrective action to contain or 

minimize the source of emissions. If corrective actions are taken, then Ash Grove shall 

immediately conduct a subsequent visual survey (and subsequent Method 9 source test if visible 

emissions remain) to monitor compliance. The person conducting the visual survey shall record 

the results of the survey (including the results of any Method 9 source test performed) in a log, 

including any corrective action taken. Conducting a visual survey does not relieve Ash Grove of 

the liability for a violation determined using Method 9 (ARM 17.8.101(27)). 

Method 9 source tests must be performed in accordance with the Montana Source Test Protocol 

and Procedures Manual, except that prior notification of the test is not required. Each observation 

period must be a minimum of 6 minutes unless any one reading is 20% or greater, then the 

observation period must be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.1213).

E.4. Whenever process equipment is operating, Ash Grove shall use and maintain, as they were 

intended, all conveyor covers, transfer point cover, or structural enclosures surrounding process 

equipment to monitor compliance with Section III.E.1 and III.E.2 (ARM 17.8.1213).

Recordkeeping

E.5. If visual surveys are performed, Ash Grove shall maintain a log to verify that the visual surveys 

were performed as specified in Section III.E.3. Each log entry must include the date, time, results 

of survey (and results of subsequent Method 9, if applicable), and observer’s initials If any 

corrective action is required, the time, date, observer’s initials, and any preventive or corrective 

action taken must be recorded in the log (ARM 17.8.1212)

E.6. Ash Grove shall maintain on site a log of all repair and maintenance activity to structural 

enclosures. The log must include, but is not limited to, the date, time, and action(s) taken. The 

maintenance log shall be maintained as a permanent business record for at least five years 

following the activity. The log shall be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212).

Reporting

E.7. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212).

E.8. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of any source testing that was performed during the semiannual 

period; and

b. A summary of any time frame in which the log was not maintained as required in Section 

III.E.6
OP2005-06 12 Date of Decision: 08/15/11

Effective Date: 09/15/11

F. EU005 –Fuel Transfer (FT)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

F.1., F.3., 

F.5., F.6., F.7

Opacity 20% Method 9 As required by 

the 

Department 

and Section 

III.A.1

Semiannual

F.2., F.4., 

F.5., F.6., F.7

Particulate Matter E=55.0p0.11-40 Use and 

maintenance 

of structural 

enclosure

Whenever 

process 

equipment is 

operating 

Semiannual

Conditions

F.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed after November 23, 1968, that exhibit an opacity of 20% or greater 

averaged over six consecutive minutes (ARM 17.8.304(2)).

F.2. Pursuant to ARM 17.8.310, the particulate emissions from process weight shall not exceed the 

value calculated by E = 55.0p0.11-40, where E = rate of emission in pounds per hour and p = 

process weight rate in tons per hour (ARM 17.8.310).

Compliance Demonstration

F.3. As required by the Department and Section III.A.1, Ash Grove shall conduct either a semiannual 

Method 9 source test or a weekly visual survey of visible emissions on the Fuel Transfer. Under 

the visual survey option, once per calendar week, during daylight hours, Ash Grove shall visually 

survey the Fuel Transfer for any visible emissions. If visible emissions are observed during the 

visual survey, Ash Grove must either conduct a Method 9 source test, or shut down the equipment 

for repairs. The Method 9 source test or source shutdown must begin within one hour of any 

observation of visible emissions. If visible emissions meet or exceed 15% opacity based on the 

Method 9 source test, Ash Grove shall immediately take corrective action to contain or minimize 

the source of emissions. If corrective actions are taken, then Ash Grove shall immediately conduct 

a subsequent visual survey (and subsequent Method 9 source test if visible emissions remain) to 

monitor compliance. The person conducting the visual survey shall record the results of the 

survey (including the results of any Method 9 source test performed) in a log, including any 

corrective action taken. Conducting a visual survey does not relieve Ash Grove of the liability for 

a violation determined using Method 9 (ARM 17.8.101(27)). 

Method 9 source tests must be performed in accordance with the Montana Source Test Protocol 

and Procedures Manual, except that prior notification of the test is not required. Each observation 

period must be a minimum of 6 minutes unless any one reading is 20% or greater, then the 

observation period must be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.1213).

F.4. During truck or rail car unloading, Ash Grove shall use and maintain the structural enclosure

surrounding the hopper, dual flow feeder, and a portion of a conveyor belt CB-22 for monitoring 

pertaining to the particulate matter limit in Section III.F.2 (ARM 17.8.309).
OP2005-06 13 Date of Decision: 08/15/11

Effective Date: 09/15/11

Recordkeeping

F.5. If visual surveys are performed, Ash Grove shall maintain a log to verify that the visual surveys 

were performed as specified in Section III.E.3. Each log entry must include the date, time, results 

of survey (and results of subsequent Method 9, if applicable), and observer’s initials If any 

corrective action is required, the time, date, observer’s initials, and any preventive or corrective 

action taken must be recorded in the log (ARM 17.8.1212)

F.6. Ash Grove shall maintain on site a log of all repair and maintenance activity to structural

enclosures. The log must include, but is not limited to, the date, time, and action(s) taken. The 

maintenance log shall be maintained as a permanent business record for at least five years 

following the activity. The log shall be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.106 and ARM 17.8.1212).

Reporting

F.7. The annual compliance certification required by Section V.B must contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

F.8. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of any source testing that was performed during the semiannual 

period; and

b. A summary of any time frame when the log was not maintained as required in Section 

III.F.6.
OP2005-06 14 Date of Decision: 08/15/11

Effective Date: 09/15/11

G. EU006 – Cement Kiln (KILN)

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting

Requirements

G.1., G.8., 

G.9., G.10., 

G.17., G.89., 

G.22., G.24., 

G.25., G.26

Opacity 40% Operation and 

maintenance of 

ESP

Whenever process 

equipment is 

operating

Semiannual

Method 9 Annually As required by 

Protocol

G.2., G.8., 

G.10., G.17., 

G.18., G.23., 

G.24., G.25., 

G.26

Particulate 

Matter

E=4.10p0.67-40 (less 

than 30 tons/hr)

E=55.0p0.11-40 (greater 

than 30 tons/hr)

Operation and 

maintenance of 

ESP

Whenever process 

equipment is 

operating

Semiannual

Method 5 Annually As required by 

Protocol

G.3., G.11., 

G.18., 

G.22.,G.24., 

G.25., G.26

Sulfur Oxide As allowed in ARM 

17.8.322

Method 6 Every 5 years As required by 

the Protocol

G.4., G.12., 

G.19., G.24., 

G.25., G.26

Operational 

Limit

250 tons/year Recordkeeping When using glass Semiannual

G.5., G.8., 

G.10., G.13., 

G.14., G.23.,

G.24., G.25., 

G.26

D/F 0.20 ng per dscm 

Corrected to 7% 

Oxygen

Method 23 Every 30 Months Semiannual

Inspection of 

Combustion 

Components

Annual Annual

G.6., G.15., 

G.20., G.23.,

G.24., G.25., 

G.26

Operational 

Limit

Inlet temperature to 

PMCD

Continuous 

Monitor

Ongoing Semiannual

G.7., G.16., 

G.21., G.24., 

G.25., G.26

PM CAM Plan ARM 17.8.1506 Provisions from 

CAM Plan, 

Appendix F

Ongoing Semiannual

Conditions

G.1. Ash Grove may not cause or authorize to be discharged into the atmosphere from the cement kiln 

any stack emissions that exhibit an opacity of 40% or greater averaged over six consecutive 

minutes (ARM 17.8.304 and ARM 17.8.752).

G.2. Ash Grove shall not cause or authorize to be discharged into the atmosphere from the cement kiln 

any stack emissions which contain particulate matter in excess of the amount allowed by the 

following equations (ARM 17.8.310 and ARM 17.8.752):

a. If the process weight rate of the kiln is less than or equal to 30 tons per hour, then the 

emission limit shall be calculated using E=4.10p0.67 where E = rate of emission in pounds 

per hour and p = process weight rate in tons per hour.

b. If the process weight rate of the kiln is greater than 30 tons per hour, then the emission 

limit shall be calculated using E = 55.0p0.11, where E = rate of emission in pounds per 

hour and P = process weight rate in tons per hour.

G.3. Ash Grove shall apply a sulfur dioxide control process (the kiln) to remove the sulfur dioxide from 

the gases emitted by burning of fuel of any sulfur content which results in an emission of sulfur in 

pounds per hour not in excess of the pounds per hour of sulfur that would have been emitted by 

burning fuel of the sulfur content indicated without such a cleaning device (ARM 17.8.322).
OP2005-06 15 Date of Decision: 08/15/11

Effective Date: 09/15/11

G.4. The amount of post-consumer recycled glass used by Ash Grove in the cement kiln shall be 

limited to 250 tons during any rolling 12-month period (ARM 17.8.752).

G.5. Ash Grove shall not cause to be discharged into the atmosphere from the kiln any gases that 

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

a. 0.20 ng per dscm (8.7x10-11 gr per dscf) (TEQ) corrected to 7% oxygen; and

b. 0.40 ng per dscm (1.7x10 -10 gr per dscf) (TEQ) corrected to 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 (40 CFR 63.1343).

G.6. Ash Grove shall operate the kiln such that the temperature of the gas at the inlet to the kiln 

particulate matter control device (PMCD) does not exceed the applicable temperature limit 

specified in 40 CFR 63.1344(b) (NESHAP, 40 CFR 63, Subpart LLL).

G.7. Ash Grove shall provide a reasonable assurance of compliance with emission limitations or 

standards for the anticipated range of operations at the Cement Kiln for PM (ARM 17.8.1504).

Compliance Demonstration

G.8. Ash Grove shall inspect and maintain the Electrostatic Precipitator (ESP) in accordance with 

Appendix E of this permit to monitor compliance with the opacity limit in Section III.G.1 and 

Section III.G.2 (ARM 17.8.749).

G.9. Ash Grove shall perform a Method 9 test at least once per calendar year. The test methods shall 

be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213).

G.10. Ash Grove shall perform a Method 5 test at least once per calendar year. The test methods shall 

be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213).

G.11. Ash Grove shall conduct a Method 6 or other test approved by the Department at least once every 

five years. The tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

G.12. Ash Grove shall maintain a log of the amount of recycled glass used in the kiln each month. By 

the 25th day of each month, Ash Grove shall total the amount of recycled glass used in the kiln 

during the previous 12 months to monitor compliance with the limitation in Section III.G.4 (ARM 

17.8.749 and ARM 17.8.1213).

G.13. Ash Grove shall monitor compliance with the D/F emission limit by conducting a performance 

test using Method 23 of Appendix A of 40 CFR 60. The performance test shall be conducted 

every 30 months. Ash Grove shall repeat the performance test for the kiln within 90 days of 

initiating any significant change in the feed or fuel from that used in the previous performance test 

(40 CFR 63.1349 and ARM 17.8.1213).

G.14. Ash Grove shall install, calibrate, maintain and continuously operate a continuous monitor to 

record the temperature of the exhaust gases from the kiln for monitoring of D/F emissions. The 

calibration of all thermocouples and other temperature sensors shall be completed at least once 

every 3 months (40 CFR 63.1350 and ARM 17.8.1213).
OP2005-06 16 Date of Decision: 08/15/11

Effective Date: 09/15/11

G.15. Ash Grove shall conduct an inspection of the components of the combustion system of the kiln at 

least once per year (40 CFR 63.1350 and ARM 17.8.1213).

G.16. Ash Grove shall monitor compliance by following the Compliance Assurance Monitoring (CAM) 

Plan (Appendix F). The CAM Plan, written by Ash Grove in accordance with ARM 17.8.1504 is 

summarized in Appendix F and is available in full upon request by the Department or the facility 

(ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

G.17. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the ESP in accordance with the requirements in Appendix E of this permit. All inspection and 

maintenance records must be available to the Department upon request (ARM 17.8.1212).

G.18. All test records must be maintained on site and submitted to the Department in accordance with 

the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

G.19. Ash Grove shall maintain on site, records as required by Section III.G.12 and submit the 

information to the Department upon request (ARM 17.8.1212).

G.20. Ash Grove shall maintain on site, records of calibration as required by Section III.G.14 (ARM 

17.8.1212).

G.21. Ash Grove shall prepare and keep data in accordance with 40 CFR Part 64 and the CAM Plan, 

Appendix F of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

G.22. Ash Grove shall submit Method 9, Method 5, Method 6 or other Department approved test reports 

in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1212).

G.23. Ash Grove shall submit a summary report semiannually, which contains the information specified 

in 40 CFR 63.10(e)(3)(vi). In addition, the summary report shall include the following (ARM 

17.8.1212):

a. All exceedances of maximum control device inlet gas temperature limits;

b. All failures to calibrate thermocouples and other temperature sensors;

c. The results of any combustion system component inspections conducted within the 

reporting period; and

d. All failures to comply with any provision of the Operation and Maintenance Plan (40 

CFR 63.1354)

G.24. If an action taken by Ash Grove during a startup, shutdown, or malfunction is not consistent with 

the procedures specified in the affected source’s startup, shutdown, and malfunction plan, Ash 

Grove shall record the actions taken and shall report such actions within 2 working days followed 

by a letter within 7 working days after the event (40 CFR 63.6(e)(3)).

G.25. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 
OP2005-06 17 Date of Decision: 08/15/11

Effective Date: 09/15/11

G.26. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of any source testing that was performed during that semiannual 

period;

b. A summary of any instance that varied from the inspection and maintenance of the ESP 

as required by Section III.G.8;

c. A summary of any timeframe when the logs required in Section III.G.12 and G.19 were 

not maintained; and

d. Any reporting required by 40 CFR Part 64 (CAM), Appendix F, as applicable, during that 

semiannual period.

H. EU007 – Product Separator and Cement Coolers (PSC)

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

H.1., H.4., H.7., 

H.8., H.9., 

H.10., H.11

Opacity 40% Method 9 Once during 5-year 

permit term

As required by 

Protocol

H.2., H.5., H.8., 

H.9., H.10., 

H.11

Particulate 

Matter

0.02 gr/dscf Method 5 Once during 5-year 

permit term

As required by 

Protocol

H.3., H.6., H.7., 

H.10., H.11 

Emission 

Control 

Equipment

Operation and 

maintenance of 

emission control 

equipment

Operation and 

maintenance 

of baghouse

Whenever process 

equipment is 

operating

Semiannual

Conditions

H.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or 

greater averaged over six consecutive minutes (ARM 17.8.304).

H.2. Particulate emissions from the dust collection system shall not exceed 0.02 gr/dscf (ARM 

17.8.752).

H.3. Ash Grove shall operate and maintain emissions control equipment when process equipment is 

operating (ARM 17.8.729).

Compliance Demonstration

H.4. Ash Grove shall perform a Method 9 test once during the 5-year permit period to monitor 

compliance with the 40% opacity limit in Section III.H.1. The test shall be conducted in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1213).

H.5. A Method 5 or other Department approved test shall be performed once during the 5-year permit 

period to monitor compliance with the particulate emission limit in Section III.H.2. The test shall 

be conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213).
OP2005-06 18 Date of Decision: 08/15/11

Effective Date: 09/15/11

H.6. Ash Grove shall operate, inspect, and maintain a baghouse in accordance with Appendix E to 

monitor compliance with Section III.H.3 (ARM 17.8.1213).

Recordkeeping

H.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the baghouse in accordance with the requirements in Appendix E. All inspections and 

maintenance records must be available to the Department for inspection and must be submitted to 

the Department upon request (ARM 17.8.1212).

H.8. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

H.9. All test reports shall be submitted in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

H.10. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

H.11. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of any source testing that was performed during the semiannual 

period; and

b. A summary of any time the baghouse was not operated, inspected, and maintained as 

required by Section III.H.6.

I. EU008 –Road Dust (RD) 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

I.1., I.3.,I.5., 

I.6., I.7., I.8

Opacity 20% Visual Survey Weekly Semiannual

I.2., I.4., I.5., 

I.6., I.7., I.8

Airborne Particulate 

Matter

Reasonable 

Precautions

Water and/or chemical 

dust suppressants

As needed Semiannual

Conditions

I.1. Ash Grove may not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater averaged over six consecutive minutes (ARM 17.8.308(1)).

I.2. Ash Grove shall not cause or authorize the use of any street, road, or parking lot without taking 

reasonable precautions to control emissions of airborne particulate matter (ARM 17.8.308(2)).
OP2005-06 19 Date of Decision: 08/15/11

Effective Date: 09/15/11

Compliance Demonstration

I.3. Once per calendar week, during daylight hours, Ash Grove shall visually survey active roads for 

any sources of excessive emissions. If visible emissions are observed during the visual survey, 

Ash Grove shall immediately take corrective action to contain or minimize the source of 

emissions. If corrective actions are taken, then Ash Grove shall immediately conduct a 

subsequent visual survey. The person conducting the visual survey shall record the results of the 

survey in a log, including any corrective action taken. Conducting a visual survey does not 

relieve Ash Grove of the liability for a violation determined using Method 9 (ARM 17.8.101(27)

and ARM 17.8.1213). 

I.4. Ash Grove shall treat all unpaved portions of the haul roads, access roads, parking lots, or the 

general plant area with water and/or chemical dust suppressant as necessary to maintain 

compliance with the reasonable precautions limitation (ARM 17.8.752).

Recordkeeping

I.5. Ash Grove shall maintain on site a weekly log recording the results of the visual surveys. The log 

shall include, but is not limited to, the date, time, observer(s), observer(s) location, the area being 

surveyed, and the results of the visual survey(s). If any preventative or corrective action is 

required, the time, date, and a description of the action taken must be included in the log. The log 

shall be maintained as a permanent business record for at least five years following the activity. 

The log shall be available to the Department for inspection and must be submitted to the 

Department upon request (ARM 17.8.1212).

I.6. If visual surveys are performed, Ash Grove shall maintain a log to verify that the visual surveys 

were performed as specified in Section III.I.3. Each log entry must include the date, time, results 

of survey (and results of subsequent Method 9, if applicable), and observer’s initials If any 

corrective action is required, the time, date, observer’s initials, and any preventive or corrective 

action taken must be recorded in the log (ARM 17.8.1212).

Reporting

I.7. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

I.8. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of any deviations from the visual surveys required by Section III.I.3

b. A summary of the log of any preventative and corrective actions as required by Section

III.I.5
OP2005-06 20 Date of Decision: 08/15/11

Effective Date: 09/15/11

J. EU009 –Storage Loadout – B (SLB) 

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

J.1., J.3., J.4., 

J.5., J.6., J.7

Opacity 40% Method 9 As required by the 

Department and 

Section III.A.1

As required by 

the Protocol

O&M of baghouse Whenever process 

equipment is operating

Semiannual

J.2., J.3., J.4., 

J.5., J.6., J.7

Particulate 

Matter

E=55.0P0.11-40 Method 5 As required by the 

Department and 

Section III.A.1

As required by 

the Protocol

O&M of baghouse Whenever process 

equipment is operating

Semiannual

Conditions

J.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed on or before November 23, 1968 that exhibit an opacity of 40% or 

greater averaged over six consecutive minutes (ARM 17.8.304).

J.2. Pursuant to ARM 17.8.310, the particulate emissions from process weight shall not exceed the 

value calculated by E=55.0P0.11-40, where E = rate of emission in pounds per hour and P = process 

weight rate in tons per hour (ARM 17.8.310).

Compliance Demonstration

J.3. Ash Grove shall inspect and maintain a baghouse in accordance with Appendix E to monitor the 

opacity limit in Section III.J.1 and Section III.J.2 (ARM 17.8.304 and Appendix E).

Recordkeeping

J.4. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the baghouse in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212).

J.5. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

J.6. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

J.7. The semiannual reporting shall provide a summary of any time the baghouse was not inspected 

and maintained as required by Section III.J.3 and Section III.J.4 (ARM 17.8.1212).
OP2005-06 21 Date of Decision: 08/15/11

Effective Date: 09/15/11

K. EU010 – Stone Transfer (ST)

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

 Method Frequency

Reporting 

Requirements

K.1., K.2., 

K.3., K.4., K.5

Opacity 20% Method 9 As required by the Department 

and Section III.A.1

Semiannual

Conditions

K.1. Ash Grove may not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater over six consecutive minutes (ARM 17.8.308).

Compliance Demonstration

K.2. Ash Grove shall perform a Method 9 test on transfer points as requested by the Department and 

Section III.A.1 to monitor compliance with Section III.K.1. The test and procedures shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213). 

Recordkeeping

K.3. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

K.4. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

K.5. The semiannual reporting shall provide a summary of any source testing that was performed 

during the annual period (ARM 17.8.1212).

L. EU011 – Transfer Belt Conveyors (TBC)

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

L.1., L.3., L.5., 

L.6., L.7., L.8., 

L.9.

Opacity 40% Method 9 As required by the 

Department and 

Section III.A.1

As required by 

the Protocol

Operation and 

maintenance of 

baghouse

Whenever process 

equipment is 

operating

Semiannual

L.2., L.4., L.5., 

L.6., L.7., L.8., 

L.9.

Particulate 

Matter

E=55.0P0.11-40 Method 5 As required by the 

Department and 

Section III.A.1

As required by 

the Protocol

Operation and 

maintenance of 

baghouse

Whenever process 

equipment is 

operating

Semiannual
OP2005-06 22 Date of Decision: 08/15/11

Effective Date: 09/15/11

Conditions

L.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed on or before November 23, 1968 that exhibit an opacity of 40% or 

greater averaged over six consecutive minutes (ARM 17.8.304).

L.2. The particulate emissions from process weight shall not exceed the value calculated by E=55.0 * 

P

0.11

-40, where E is the rate of emissions in pounds/hour and P is the process weight rate in 

tons/hour (ARM 17.8.310).

Compliance Demonstration

L.3. As required by the Department and Section III.A.1, a Method 9 opacity test shall be performed in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1213).

L.4. Ash Grove shall inspect and maintain a baghouse in accordance with Appendix E to monitor the 

opacity limit in Section III.L.1 (ARM 17.8.304 and Appendix E).

L.5. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 5 test or 

another approved test to monitor compliance with the particulate emissions limit in Section 

III.L.2. The test shall be performed in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

Recordkeeping

L.6. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 

17.8.1212).

L.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the baghouse in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212).

Reporting

L.8. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

L.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of any time the baghouse was not inspected and maintained as required 

by Section III.L.4; and

b. A summary of results of any source testing that was performed during the semiannual 

period.
OP2005-06 23 Date of Decision: 08/15/11

Effective Date: 09/15/11

M. EU012 –Transfer/Convey to Ball Mill (TBM) 

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

M.1., M.3., M.5., 

M.6., M.7., M.8., M.9

Opacity 40% Method 9 As required by the 

Department and 

Section III.A.1

As required by 

the Protocol

Operation and 

Maintenance of 

baghouse

Whenever process 

equipment is 

operating

Semiannual

M.2., M.4., M.5., 

M.6., M.7., M.8., M.9

Particulate 

Matter

E=55.0P0.11-40 Method 5 As required by the 

Department and 

Section III.A.1

As required by 

the 

Department

Operation and 

maintenance of 

baghouse

Whenever process 

equipment is 

operating

Semiannual

Conditions

M.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed on or before November 23, 1968 that exhibit an opacity of 40% or 

greater averaged over six consecutive minutes (ARM 17.8.304).

M.2. The particulate emissions from process weight shall not exceed the value calculated by E=55.0 * 

P

0.11

-40, where E is the rate of emissions in pounds/hour and P is the process weight in tons/hour 

(ARM 17.8.310).

Compliance Demonstration

M.3. As required by the Department and Section III.A.1, Ash Grove shall conduct a Method 9 opacity 

test in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 

and ARM 17.8.1213).

M.4. As required by the Department and Section III.A.1, Ash Grove shall conduct a Method 5 test or 

another Department approved test to monitor compliance with the particulate emissions limit in 

Section III.M.2. The test shall be conducted in accordance with the Montana Source Test Protocol 

and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

M.5. Ash Grove shall inspect and maintain the baghouse in accordance with Appendix E of this permit 

to monitor compliance with the limits in Sections III.M.1 and III.M.2 (ARM 17.8.1213).

Recordkeeping

M.6. All source test recordkeeping shall be performed in accordance with the test method used and the 

Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 

17.8.106 and ARM 17.8.1212).

M.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the baghouse in accordance with Appendix E of this permit. All inspection and maintenance 

records shall be available to the Department for inspection and shall be submitted to the 

Department upon request (ARM 17.8.1212).
OP2005-06 24 Date of Decision: 08/15/11

Effective Date: 09/15/11

Reporting

M.8. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

M.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of any time that records were not maintained for all inspection and 

maintenance activities performed on the baghouse as required in Section III.M.5; and

b. A summary of results of any source testing that was performed during the semiannual 

period.

N. EU013 –Transfer to/from Finish Mill (TFM) 

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

N.1., N.5., 

N.10., N.12., 

N.13., N.14

Opacity 40% Method 9 Every 2 years As required 

by the 

Protocol

N.2., N.6., 

N.10., N.12., 

N.13., N.14

Particulate 

Matter

0.02 gr/dscf Method 5 Every 2 years As required 

by the 

Protocol

N.3., N.7., 

N.9., N.13., 

N.14

Emission 

Control 

Equipment

Operation and 

maintenance of emission 

control equipment

Operation and 

maintenance of 

baghouse

Whenever process 

equipment is 

operating

Semiannual

N.4., N.8., 

N.11., N.14.

PM CAM Plan ARM 17.8.1506 Provisions from 

CAM Plan, 

Appendix G

Ongoing Semiannual

Conditions

N.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or 

greater averaged over six consecutive minutes (ARM 17.8.304).

N.2. Particulate emissions from the dust collection system shall not exceed 0.02 gr/dscf (ARM 

17.8.752).

N.3. Ash Grove shall operate and maintain emission control equipment when process equipment is 

operating (ARM 17.8.749).

N.4. Ash Grove shall provide a reasonable assurance of compliance with emission limitations or 

standards for the anticipated range of operations at the Finish Mill House Baghouse for PM (ARM 

17.8.1504).

Compliance Demonstration

N.5. Ash Grove shall perform a Method 9 test every two years to monitor compliance with the opacity 

limit in Section III.N.1. The test methods and procedures shall be conducted in accordance with 

the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213).

N.6. Ash Grove shall conduct a Method 5 or another Department approved test every two years to 

monitor compliance with the particulate emission limit in Section III.N.2. The test shall be 

conducted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.106 and ARM 17.8.1213).
OP2005-06 25 Date of Decision: 08/15/11

Effective Date: 09/15/11

N.7. Ash Grove shall operate, inspect, and maintain a baghouse in accordance with Appendix E of this 

permit to monitor compliance with Section III.N.3 (ARM 17.8.1213).

N.8. Ash Grove shall monitor compliance by following the Compliance Assurance Monitoring (CAM) 

Plan (Appendix G). The CAM Plan, written by Ash Grove in accordance with ARM 17.8.1504 is 

summarized in Appendix G and is available in full upon request by the Department or the facility 

(ARM 17.8.1503 and ARM 17.8.1213).

Recordkeeping

N.9. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

N.10. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the baghouse in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212).

N.11. Ash Grove shall prepare and keep data in accordance with 40 CFR Part 64 and the CAM Plan, 

Appendix G of this permit (ARM 17.8.1212 and 40 CFR Part 64).

Reporting

N.12. Any compliance source test reports must be submitted in accordance with the Montana Source 

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

N.13. The annual compliance certification required by Section V.B must contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

N.14. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of any time the baghouse was not operated, inspected, and maintained as 

required by Section III.N.6;

b. A summary of results of any source testing that was performed during the semiannual 

period; and

c. Any reporting required by 40 CFR Part 64 (CAM), Appendix G, as applicable, 

during that semiannual period.

O. EU014 –Transfer to Limestone Silos (TLS) 

Condition(s) Pollutant/

Parameter

Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

O.1., O.3., 

O.5., O.6., 

O.7., O.8., 

O.9

Opacity 40% Method 9 As required by the 

Department and Section 

III.A.1

As required by 

the Protocol

Operation and 

maintenance of baghouse

Whenever process 

equipment is operating

Semiannual

O.2.,O.4., 

O.5., O.6., 

O.7., O.8., 

O.9 

Particulate 

Matter

E=55.0P0.11-40 Method 5 As required by the 

Department and Section 

III.A.1

As required by 

the Protocol

Operation and 

maintenance of baghouse

Whenever process 

equipment is operating

Semiannual
OP2005-06 26 Date of Decision: 08/15/11

Effective Date: 09/15/11

Conditions

O.1. Ash Grove may not cause or authorize emissions to be discharged into the outdoor atmosphere 

from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or 

greater averaged over six consecutive minutes (ARM 17.8.304).

O.2. The particulate emissions from process weight shall not exceed the value calculated by E=55.0 * 

P

0.11

– 40, where e is the rate of emissions in pounds/hour and P is the process weight rate in 

tons/hour (ARM 17.8.310).

Compliance Demonstration

O.3. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 opacity 

test in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 

and ARM 17.8.1213).

O.4. As required by the Department and Section III.A.1, Ash Grove shall perform a Method 9 or 

another Department approved test to monitor compliance with the particulate emissions limit in 

Section III.O.2. The test shall be conducted in accordance with the Montana Source Test Protocol 

and Procedures (ARM 17.8.106 and ARM 17.8.1213).

O.5. Ash Grove shall inspect and maintain the baghouse in accordance with Appendix E of this permit 

to monitor compliance with the limits in Section III.O.1 and 2 (ARM 17.8.1213).

Recordkeeping

O.6. All compliance source test recordkeeping shall be performed in accordance with the test method 

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on 

site (ARM 17.8.106).

O.7. Ash Grove shall maintain on site records of all inspection and maintenance activities performed on 

the baghouse in accordance with the requirements in Appendix E of this permit. All inspection 

and maintenance records must be available to the Department for inspection and must be 

submitted to the Department upon request (ARM 17.8.1212).

Reporting

O.8. The annual compliance certification must contain a certification statement for the above applicable 

requirements (ARM 17.8.1212). 

O.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of any time the baghouse was not inspected and maintained as required 

by Section III.O.5; and

b. A summary of results of any soure testing that was performed during the semiannual 

period.

P. EU015 – Wind Erosion (WE) – (from quarry activities)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

 Method Frequency

Reporting 

Requirements

P.1., P.2., 

P.3., P.4., P.5

Airborne Particulate 

Matter

20% Method 9 As required by the Department 

and Section III.A.1

Annually
OP2005-06 27 Date of Decision: 08/15/11

Effective Date: 09/15/11

Conditions

P.1. Ash Grove may not cause or authorize the production, handling, transportation, or storage of any 

material unless reasonable precautions to control emissions of airborne particulate matter are 

taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit 

an opacity of 20% or greater averaged over six consecutive minutes (ARM 17.8.308(1)).

Compliance Demonstration

P.2. Ash Grove shall perform a Method 9 test as required by the Department and Section III.A.1. The 

test methods and procedures shall be conducted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1213). 

Recordkeeping

P.3. Ash Grove shall maintain on site any Method 9 test report. The test report shall be submitted in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and 

ARM 17.8.1212).

Reporting

P.4. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

P.5. The semiannual monitoring report shall provide a summary of results of any source testing that 

was performed during that semiannual period (ARM 17.8.1212).
OP2005-06 28 Date of Decision: 08/15/11

Effective Date: 09/15/11

SECTION IV. NON-APPLICABLE REQUIREMENTS

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable 

to the facility or to a specific emissions unit at the time of the permit issuance are listed below (ARM 

17.8.1214). The following list does not preclude the need to comply with any new requirements that may 

become applicable during the permit term.

Facility-Wide

The following table contains non-applicable requirements that are administrated by the Air Resources 

Management Bureau of the Department of Environmental Quality.

Rule Citation Reason

ARM 17.8.320

ARM 17.8.321

ARM 17.8.323

ARM 17.8.330 through 334

ARM 17.8.340

These rules are not applicable because the 

facility is not listed in the source category cited 

in the rule.

ARM 17.8.1106 to 1107

ARM 17.8.1110 to 1111

These rules do not apply because no changes 

have been made at the facility that would 

trigger these procedural requirements.

40 CFR 60, Subparts C, Ca, Cb, Cc, Cd

40 CFR 60, Subparts D, Da, Db, Dc

40 CFR 60, Subparts E, Ea, Eb

40 CFR 60, Subpart G, H, I, J

40 CFR 60, Subparts K, Ka, Kb 

40 CFR 60, Subparts L-X

40 CFR 60, Subpart Z

40 CFR 60, Subparts AA-EE

40 CFR 60, Subparts GG-HH

40 CFR 60, Subparts KK-NN

40 CFR 60, Subparts PP-XX

40 CFR 60, Subparts AAA-BBB

40 CFR 60, Subparts DDD

40 CFR 60, Subparts FFF-LLL

40 CFR 60, Subpart NNN

40 CFR 60, Subparts PPP-QQQ

40 CFR 60, Subparts RRR-WWW

40 CFR 60, Subparts BBBB-DDDD

40 CFR 61, Subparts B-F

40 CFR 61, Subparts H-L

40 CFR 61, Subparts N-R

40 CFR 61, Subpart T

40 CFR 61, Subparts V-W

40 CFR 61, Subpart Y

40 CFR 61, Subpart BB

40 CFR 61, Subpart FF

40 CFR 63, Subparts F-I

40 CFR 63, Subparts L-O

40 CFR 63, Subparts Q-U

40 CFR 63, Subparts W-Y

40 CFR 63, Subparts AA-EE

40 CFR 63, Subparts GG-MM

These requirements are not applicable because 

the facility is not an affected source as defined 

in these regulations.
OP2005-06 29 Date of Decision: 08/15/11

Effective Date: 09/15/11

40 CFR 63, Subparts OO-WW

40 CFR 63, Subpart YY

40 CFR 63, Subparts CCC-EEE

40 CFR 63, Subparts GGG-JJJ

40 CFR 63, Subparts MMM-RRR

40 CFR 63, Subparts TTT-VVV

40 CFR 63, Subpart XXX

40 CFR 63, Subpart CCCC

40 CFR 63, Subparts GGGG-HHHH

40 CFR 63, Subparts SSSS-VVVV

40 CFR 63, Subpart XXXX

40 CFR 63, Subpart QQQQQ

40 CFR 63, Appendices B-E

40 CFR 68

40 CFR 72-78

40 CFR 79-80

40 CFR 85-97 (83 and 84 are reserved)

Emission Units

The permit application identified applicable requirements: non-applicable requirements for individual or 

specific emission units were not listed. The Department has listed all non-applicable requirements in 

Section IV.A, these requirements relate to each specific unit, as well as facility wide.
OP2005-06 30 Date of Decision: 08/15/11

Effective Date: 09/15/11

SECTION V. GENERAL PERMIT CONDITIONS

A. Compliance Requirements

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)-(c)&(e), §1206(6)(c)&(b)

1. The permittee must comply with all conditions of the permit. Any noncompliance with the 

terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and 

may result in enforcement action, permit modification, revocation and reissuance, or 

termination, or denial of a permit renewal application under ARM Title 17, Chapter 8, 

Subchapter 12.

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, 

or termination, or of a notification of planned changes or anticipated noncompliance does not 

stay any permit condition.

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

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

conditions of the permit. If appropriate, this factor may be considered as a mitigating factor 

in assessing a penalty for noncompliance with an applicable requirement if the source 

demonstrates that both the health, safety or environmental impacts of halting or reducing 

operations would be more serious than the impacts of continuing operations, and that such 

health, safety or environmental impacts were unforeseeable and could not have otherwise 

been avoided.

4. The permittee shall furnish to the Department, within a reasonable time set by the Department 

(not to be less than 15 days), any information that the Department may request in writing to 

determine whether cause exists for modifying, revoking and reissuing, or terminating the 

permit, or to determine compliance with the permit. Upon request, the permittee shall also 

furnish to the Department copies of those records that are required to be kept pursuant to the 

terms of the permit. This subsection does not impair or otherwise limit the right of the 

permittee to assert the confidentiality of the information requested by the Department, as 

provided in 75-2-105, MCA.

5. Any schedule of compliance for applicable requirements with which the source is not in 

compliance with at the time of permit issuance shall be supplemental to, and shall not 

sanction noncompliance with, the applicable requirements on which it was based.

6. For applicable requirements that will become effective during the permit term, the source 

shall meet such requirements on a timely basis unless a more detailed plan or schedule is 

required by the applicable requirement or the Department.

B. Certification Requirements

ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)-(d)

1. Any application form, report, or compliance certification submitted pursuant to ARM Title 

17, Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, 

accuracy and completeness. This certification and any other certification required under 

ARM Title 17, Chapter 8, Subchapter 12, shall state that, based on information and belief 

formed after reasonable inquiry, the statements and information in the document are true, 

accurate and complete.
OP2005-06 31 Date of Decision: 08/15/11

Effective Date: 09/15/11

2. Compliance certifications shall be submitted by February 15 of each year, or more frequently 

if otherwise specified in an applicable requirement or elsewhere in the permit. Each 

certification must include the required information for the previous calendar year (i.e., 

January 1 – December 31).

3. Compliance certifications shall include the following:

a. The identification of each term or condition of the permit that is the basis of the 

certification

b. The identification of the method(s) or other means used by the owner or operator for 

determining the status of compliance with each term and condition during the 

certification period, consistent with ARM 17.8.1212

c. The status of compliance with each term and condition for the period covered by the 

certification, including whether compliance during the period was continuous or 

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as 

described above)

d. Such other facts as the Department may require to determine the compliance status of 

the source

4. All compliance certifications must be submitted to the Environmental Protection Agency, as well 

as to the Department, at the addresses listed in the Notification Addresses Appendix of this 

permit.

C. Permit Shield

ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)-(4)

1. The applicable requirements and non-federally enforceable requirements are included and 

specifically identified in this permit and the permit includes a precise summary of the 

requirements not applicable to the source. Compliance with the conditions of the permit shall 

be deemed compliance with any applicable requirements and any non-federally enforceable 

requirements as of the date of permit issuance.

2. The permit shield described in 1 above shall remain in effect during the appeal of any permit 

action (renewal, revision, reopening, or revocation and reissuance) to the Board of 

Environmental Review (Board), until such time as the Board renders its final decision.

3. Nothing in this permit alters or affects the following:

a. The provisions of Sec. 7603 of the FCAA, including the authority of the 

administrator under that section

b. The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance

c. The applicable requirements of the Acid Rain Program, consistent with Sec. 7651g(a) 

of the FCAA

d. The ability of the administrator to obtain information from a source pursuant to Sec. 

7414 of the FCAA
OP2005-06 32 Date of Decision: 08/15/11

Effective Date: 09/15/11

e. The ability of the Department to obtain information from a source pursuant to the 

Montana Clean Air Act, Title 75, Chapter 2, MCA

f. The emergency powers of the Department under the Montana Clean Air Act, Title 

75, Chapter 2, MCA

g. The ability of the Department to establish or revise requirements for the use of 

Reasonably Available Control Technology (RACT) as defined in ARM Title 17, 

Chapter 8. However, if the inclusion of a RACT into the permit pursuant to ARM 

Title 17, Chapter 8, Subchapter 12, is appealed to the Board, the permit shield, as it 

applies to the source’s existing permit, shall remain in effect until such time as the 

Board has rendered its final decision.

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action 

for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 

17.8.106, Source Testing Protocol.

5. Pursuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in 

these rules shall preclude the use, including the exclusive use, of any credible evidence or 

information relevant to whether a source would have been in compliance. However, when 

compliance or noncompliance is demonstrated by a test or procedure provided by permit or 

other applicable requirements, the source shall then be presumed to be in compliance or 

noncompliance unless that presumption is overcome by other relevant credible evidence.

6. The permit shield will not extend to minor permit modifications or changes not requiring a 

permit revision (see Sections I & J).

7. The permit shield will extend to significant permit modifications and transfer or assignment of 

ownership (see Sections K & N).

D. Monitoring, Recordkeeping, and Reporting Requirements

ARM 17.8, Subchapter 12, Operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring 

records that include the following information:

a. The date, place as defined in the permit, and time of sampling or measurement

b. The date(s) analyses were performed

c. The company or entity that performed the analyses

d. The analytical techniques or methods used

e. The results of such analyses

f. The operating conditions at the time of sampling or measurement
OP2005-06 33 Date of Decision: 08/15/11

Effective Date: 09/15/11

2. The permittee shall retain records of all required monitoring data and support information for 

a period of at least five years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records and all 

original strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by the permit. All monitoring data, support information, and required reports 

and summaries may be maintained in computerized form at the plant site if the information is 

made available to Department personnel upon request, which may be for either hard copies or 

computerized format. Strip-charts must be maintained in their original form at the plant site 

and shall be made available to Department personnel upon request.

3. The permittee shall submit to the Department, at the addresses located in the Notification 

Addresses Appendix of this permit, reports of any required monitoring by February 15 and 

August 15 of each year, or more frequently if otherwise specified in an applicable 

requirement or elsewhere in the permit. The monitoring report submitted on February 15 of 

each year must include the required monitoring information for the period of July 1 through 

December 31 of the previous year. The monitoring report submitted on August 15 of each 

year must include the required monitoring information for the period of January 1 through 

June 30 of the current year. All instances of deviations from the permit requirements must be 

clearly identified in such reports. All required reports must be certified by a responsible 

official, consistent with ARM 17.8.1207.

E. Prompt Deviation Reporting

ARM 17.8, Subchapter 12, Operating Permit Program §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those attributable 

to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective 

actions or preventive measures taken. To be considered prompt, deviations shall be reported to the 

Department within the following timeframes (unless otherwise specified in an applicable 

requirement):

1. For deviations which may result in emissions potentially in violation of permit limitations:

a. An initial phone notification (or faxed or electronic notification) describing the incident 

within 24 hours (or the next business day) of discovery: and,

b. A follow-up written, faxed, or electronic report within 30 days of discovery of the 

deviation that describes the probable cause of the reported deviation and any corrective 

actions or preventative measures taken.

2. For deviations attributable to malfunctions, deviations shall be reported to the Department in 

accordance with the malfunction reporting requirements under ARM 17.8.110; and

3. For all other deviations, deviations shall be reported to the Department via a written, faxed, or 

electronic report within 90 days of discovery (as determined through routine internal review by 

the permittee).

Prompt deviation reports do not need to be resubmitted with regular semiannual (or other routine) reports, 

but may be referenced by the date of submittal.
OP2005-06 34 Date of Decision: 08/15/11

Effective Date: 09/15/11

F. Emergency Provisions

ARM 17.8, Subchapter 12, Operating Permit Program §1201(13) and §1214(5), (6)&(8)

1. An “emergency” means any situation arising from sudden and reasonably unforeseeable events 

beyond the control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation and causes the source to exceed a technologybased emission limitation under this permit due to the unavoidable increases in emissions 

attributable to the emergency. An emergency shall not include noncompliance to the extent 

caused by improperly designed equipment, lack of reasonable preventive maintenance, careless 

or improper operation, or operator error.

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

technology-based emission limitation if the permittee demonstrates through properly signed, 

contemporaneous logs, or other relevant evidence, that:

a. An emergency occurred and the permittee can identify the cause(s) of the emergency

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

c. During the period of the emergency the permittee took all reasonable steps to 

minimize levels of emissions that exceeded the emission standards or other 

requirements in the permit

d. The permittee submitted notice of the emergency to the Department within 2 working 

days of the time when emission limitations were exceeded due to the emergency. 

This notice fulfills the requirements of ARM 17.8.1212(3)(c). This notice must 

contain a description of the emergency, any steps taken to mitigate emissions, and 

corrective actions taken.

3. These emergency provisions are in addition to any emergency, malfunction or upset provision 

contained in any applicable requirement.

G. Inspection and Entry

ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the 

permittee shall allow the Department, the administrator, or an authorized representative 

(including an authorized contractor acting as a representative of the Department or the 

administrator) to perform the following:

a. Enter the premises where a source required to obtain a permit is located or emissionsrelated activity is conducted, or where records must be kept under the conditions of 

the permit

b. Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of the permit

c. Inspect at reasonable times any facilities, emission units, equipment (including 

monitoring and air pollution control equipment), practices, or operations regulated or 

required under the permit

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder, 

sample or monitor, at reasonable times, any substances or parameters at any location 

for the purpose of assuring compliance with the permit or applicable requirements
OP2005-06 35 Date of Decision: 08/15/11

Effective Date: 09/15/11

2. The permittee shall inform the inspector of all workplace safety rules or requirements at the 

time of inspection. This section shall not limit in any manner the Department’s statutory 

right of entry and inspection as provided for in 75-2-403, MCA.

H. Fee Payment

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air 

Quality Permit Application, Operation, and Open Burning Fees §505(3)-(5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Chapter 8, 

Subchapter 5.

2. Annually, the Department shall provide the permittee with written notice of the amount of the 

fee and the basis for the fee assessment. The air quality operation fee is due 30 days after 

receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any 

portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days after 

receipt of the notice. Any remaining fee, which may be due after the completion of an appeal, 

is due immediately upon issuance of the Board’s decision or upon completion of any judicial 

review of the Board’s decision.

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 

90 days of the due date of the fee, the Department may impose an additional assessment of 15% 

of the fee (or any required portion of an appealed fee) or $100, whichever is greater, plus 

interest on the fee (or any required portion of an appealed fee), computed at the interest rate 

established under 15-31-510(3), MCA.

I. Minor Permit Modifications

ARM 17.8, Subchapter 12, Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the 

permit application that require revision, updating, supplementation, or deletion, and may 

reference any required information that has been previously submitted.

2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed 

pursuant to ARM 17.8.1226.

J. Changes Not Requiring Permit Revision

ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)-(3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided 

the following conditions are met:

a. The proposed changes do not require the permittee to obtain an air quality 

preconstruction permit under ARM Title 17, Chapter 8, Subchapter 7;

b. The proposed changes are not modifications under Title I of the FCAA, or as defined 

in ARM Title 17, Chapter 8, Subchapters 8, 9, or 10;

c. The emissions resulting from the proposed changes do not exceed the emissions 

allowable under this permit, whether expressed as a rate of emissions or in total 

emissions;

d. The proposed changes do not alter permit terms that are necessary to enforce 

applicable emission limitations on emission units covered by the permit; and
OP2005-06 36 Date of Decision: 08/15/11

Effective Date: 09/15/11

e. The facility provides the administrator and the Department with written notification 

at least seven days prior to making the proposed changes.

2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to 

their respective copies of this permit.

3. Pursuant to the conditions above, the permittee is authorized to make Sec. 502(b)(10) changes, 

as defined in ARM 17.8.1201(30), without a permit revision. For each such change, the written 

notification required under 1.e above shall include a description of the change within the 

source, the date on which the change will occur, any change in emissions, and any permit term 

or condition that is no longer applicable as a result of the change.

4. The permittee may make a change not specifically addressed or prohibited by the permit terms 

and conditions without requiring a permit revision, provided the following conditions are met:

a. Each proposed change does not weaken the enforceability of any existing permit 

conditions;

b. The Department has not objected to such change;

c. Each proposed change meets all applicable requirements and does not violate any 

existing permit term or condition; and

d. The permittee provides contemporaneous written notice to the Department and the 

administrator of each change that is above the level for insignificant emission units as 

defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes 

each such change, including the date of the change, any change in emissions, 

pollutants emitted, and any applicable requirement that would apply as a result of the 

change.

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to 

ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases 

and decreases in emissions pursuant to ARM 17.8.1224(4).

K. Significant Permit Modifications

ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 below must be used for any application requesting a 

significant modification of this permit. Significant modifications include the following:

a. Any permit modification that does not qualify as either a minor modification or as an 

administrative permit amendment

b. Every significant change in existing permit monitoring terms or conditions

c. Every relaxation of permit reporting or recordkeeping terms or conditions that limit 

the Department’s ability to determine compliance with any applicable rule, consistent 

with the requirements of the rule or

d. Any other change determined by the Department to be significant

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including 

those for applications, public participation, and review by affected states and the administrator, 

as they apply to permit issuance and renewal, except that an application for a significant permit 

modification need only address in detail those portions of the permit application that require 

revision, updating, supplementation or deletion.
OP2005-06 37 Date of Decision: 08/15/11

Effective Date: 09/15/11

3. The permit shield provided for in ARM 17.8.1214 shall extend to significant modifications.

L. Reopening for Cause

ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

This permit may be reopened and revised under the following circumstances:

1. Additional applicable requirements under the FCAA become applicable to the facility when the 

permit has a remaining term of 3 or more years. Reopening and revision of the permit shall be 

completed not later than 18 months after promulgation of the applicable requirement. No 

reopening is required under ARM 17.8.1228(1)(a) if the effective date of the applicable 

requirement is later than the date on which the permit is due to expire, unless the original 

permit or any of its terms or conditions have been extended pursuant to ARM 17.8.1220(12) or 

17.8.1221(2);

2. Additional requirements (including excess emission requirements) become applicable to an 

affected source under the Acid Rain Program. Upon approval by the administrator, excess 

emission offset plans shall be deemed incorporated into the permit;

3. The Department or the administrator determines that the permit contains a material mistake or 

that inaccurate statements were made in establishing the emission standards or other terms or 

conditions of the permit; or

4. The administrator or the Department determines that the permit must be revised or revoked and 

reissued to ensure compliance with the applicable requirements.

M. Permit Expiration and Renewal

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of five years.

2. Renewal of this permit is subject to the same procedural requirements that apply to permit 

issuance, including those for application, content, public participation, and affected state and 

administrator review.

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and 

administratively complete renewal application has been submitted consistent with ARM

17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been 

submitted, all terms and conditions of the permit, including the application shield, remain in 

effect after the permit expires until the permit renewal has been issued or denied.

4. For renewal, the permittee shall submit a complete air quality operating permit application to 

the Department not later than six months prior to the expiration of this permit, unless otherwise 

specified. If necessary to ensure that the terms of the existing permit will not lapse before 

renewal, the Department may specify, in writing to the permittee, a longer time period for 

submission of the renewal application. Such written notification must be provided at least 1 

year before the renewal application due date established in the existing permit.
OP2005-06 38 Date of Decision: 08/15/11

Effective Date: 09/15/11

N. Severability Clause

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of 

an initial permit under this subchapter shall not impair in any manner the underlying 

applicability of all applicable requirements, and such requirements continue to apply as if a 

final permit decision had not been reached by the Department.

2. If any provision of a permit is found to be invalid, all valid parts that are severable from the 

invalid part remain in effect. If a provision of a permit is invalid in one or more of its 

applications, the provision remains in effect in all valid applications that are severable from the 

invalid applications.

O. Transfer or Assignment of Ownership

ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, 

the applicant must include in its request to the Department a written agreement containing a 

specific date for the transfer of permit responsibility, coverage and liability between the current 

and new permittee.

2. The permit shield provided for in ARM17.8.1214 shall not extend to administrative permit 

amendments.

P. Emissions Trading, Marketable Permits, Economic Incentives

ARM 17.8, Subchapter 12, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification 

procedures may be used for permit modifications involving the use of economic incentives, 

marketable permits, emissions trading, and other similar approaches, to the extent that such minor 

permit modification procedures are explicitly provided for in the Montana State Implementation Plan 

or in applicable requirements promulgated by the administrator.

Q. No Property Rights Conveyed

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privilege.

R. Testing Requirements

ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105.

S. Source Testing Protocol

ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106.

T. Malfunctions

ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110.
OP2005-06 39 Date of Decision: 08/15/11

Effective Date: 09/15/11

U. Circumvention

ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111.

V. Motor Vehicles

ARM 17.8, Subchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325.

W. Annual Emissions Inventory

ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 

(STATE ONLY)

The permittee shall supply the Department with annual production and other information for all 

emission units necessary to calculate actual or estimated actual amount of air pollutants emitted 

during each calendar year. Information shall be gathered on a calendar-year basis and submitted to 

the Department by the date required in the emission inventory request, unless otherwise specified in 

this permit. Information shall be in the units required by the Department.

X. Open Burning

ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606.

Y. Montana Air Quality Permits

ARM 17.8, Subchapter 7, Permit, Construction and Operation of Air Contaminant Sources §745 and 

764 (ARM 17.8.745(1) and 764(1)(b) are STATE ENFORCEABLE ONLY until approval by the 

EPA as part of the SIP)

1. Except as specified, no person shall construct, install, alter or use any air contaminant source or 

stack associated with any source without first obtaining a permit from the Department or 

Board. A permit is not required for those sources or stacks as specified by ARM 

17.8.744(1)(a)-(k).

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748, and 764.

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of 

operation at a facility holding an air quality preconstruction permit issued under Chapter 8 that 

does not increase the facility’s potential to emit by more than 5 tons per year of any pollutant, 

except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP):

a. Any construction or changed condition that would violate any condition in the 

facility’s existing air quality preconstruction permit or any applicable rule contained 

in Chapter 8 is prohibited, except as provided in ARM 17.8.745(2);

b. Any construction or changed conditions of operation that would qualify as a major 

modification under Subchapters 8, 9 or 10 of Chapter 8;

c. Any construction or changed condition of operation that would affect the plume rise 

or dispersion characteristic of emissions that would cause or contribute to a violation 

of an ambient air quality standard or ambient air increment as defined in ARM 

17.8.804;
OP2005-06 40 Date of Decision: 08/15/11

Effective Date: 09/15/11

d. Any construction or improvement project with a potential to emit more than 15 tons 

per year may not be artificially split into smaller projects to avoid air quality 

preconstruction permitting; or

e. Emission reductions obtained through offsetting within a facility are not included 

when determining the potential emission increase from construction or changed 

conditions of operation, unless such reductions are made federally enforceable.

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the 

Department if the change would include a change in control equipment, stack height, stack 

diameter, stack gas temperature, source location or fuel specifications, or would result in an 

increase in source capacity above its permitted operation or the addition of a new emission unit. 

The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de 

minimis change, or as soon as reasonably practicable in the event of an unanticipated 

circumstance causing the de minimis change, and must include the information requested in 

ARM 17.8.745(1) (STATE ENFORCEABLE ONLY until approval by the EPA as part of the 

SIP).

Z. National Emission Standard for Asbestos

40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abatement activities except in accordance with 40 CFR 

61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos).

AA. Asbestos

ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq., and ARM 17.74.401, et seq. (State only)

BB.Stratospheric Ozone Protection – Servicing of Motor Vehicle Air Conditioners

40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and this service involves ozone-depleting 

substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the 

applicable requirements as specified in 40 CFR 82, Subpart B.

CC. Stratospheric Ozone Protection – Recycling and Emission Reductions

40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 82, 

Subpart F, except as provided for MVACs in Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the 

required practices pursuant to §82.156;

2. Equipment used during the maintenance, service, repair or disposal of appliances must comply 

with the standards for recycling and recovery equipment pursuant to §82.158;

3. Persons performing maintenance, service, repair or disposal of appliances must be certified by 

an approved technical certification program pursuant to §82.161;
OP2005-06 41 Date of Decision: 08/15/11

Effective Date: 09/15/11

4. Persons disposing of small appliances, MVACs and MVAC-like (as defined at §82.152) 

appliances must comply with recordkeeping requirements pursuant to §82.166;

5. Persons owning commercial or industrial process refrigeration equipment must comply with the 

leak repair requirements pursuant to §82.156; and

6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must 

keep records of refrigerant purchased and added to such appliances pursuant to §82.166.

DD. Emergency Episode Plan

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of Montana 

Air Quality Control Implementation Plan.

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, shall 

submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP) that details 

how the source will curtail emissions during an air pollutant emergency episode. The industrial 

EEAP shall be in accordance with the Department’s EEAP and shall be submitted according to a 

timetable developed by the Department, following Priority I reclassification.

EE.Definitions

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this 

permit, shall have the meaning assigned to them in the referenced regulations.
OP2005-06 42 Date of Decision: 08/15/11

Effective Date: 09/15/11

APPENDICES
OP2005-06 A-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix A INSIGNIFICANT EMISSION UNITS

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to 

assist Ash Grove, the permitting authority, inspectors, and the public.

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emissions unit 

located within a source that: (i) has a potential to emit less than five tons per year of any regulated 

pollutant; (ii) has a potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less 

than 500 pounds per year of hazardous air pollutants listed pursuant to Sec. 7412 (b) of the FCAA; and 

(iv) is not regulated by an applicable requirement, other than a generally applicable requirement that 

applies to all emission units subject to Subchapter 12.

List of Insignificant Activities:

The following table of insignificant sources and/or activities were provided by Ash Grove. Because there 

are no requirements to update such a list, the emission units and/or activities may change from those 

specified in the table.

Emissions Unit ID Description

CCP Coal/Coke Preparation

CDA Clinker Drag Conveyor A

CDB Clinker Drag Conveyor B

CSA Transfer to/from Cement Storage Silos A

CSB Transfer to/from Cement Storage Silos B

DL Dust Loadout

DT Dust Return System

EC Clinker Bucket Conveyor

PLO2 Product Loadout 2

PST Petroleum Storage Tanks

QA Quarry Activities

RT Raw Material Transfer

SC Slag/Silica/Clinker Conveyors

SLA Storage Loadout A

SLM Specialty Bin

SLN Storage Loadout at New Silos

TFS Transfer from Silos

TSC Transfer/Secondary Crushing

VE Vehicle Emissions

.
OP2005-06 B-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix B DEFINITIONS and ABBREVIATIONS

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq.

"Administrative permit amendment" means an air quality operating permit revision that:

(a) Corrects typographical errors

(b) Identifies a change in the name, address or phone number of any person identified in the air 

quality operating permit, or identifies a similar minor administrative change at the source

(c) Requires more frequent monitoring or reporting by Ash Grove

(d) Requires changes in monitoring or reporting requirements that the Department deems to be 

no less stringent than current monitoring or reporting requirements

(e) Allows for a change in ownership or operational control of a source if the Department has 

determined that no other change in the air quality operating permit is necessary, consistent 

with ARM 17.8.1225 or

(f) Incorporates any other type of change that the Department has determined to be similar to 

those revisions set forth in (a)-(e), above

"Applicable requirement" means all of the following as they apply to emission units in a source 

requiring an air quality operating permit (including requirements that have been promulgated or approved 

by the Department or the administrator through rule making at the time of issuance of the air quality 

operating permit, but have future-effective compliance dates, provided that such requirements apply to 

sources covered under the operating permit):

(a) Any standard, rule, or other requirement, including any requirement contained in a consent 

decree or judicial or administrative order entered into or issued by the Department, that is 

contained in the Montana state implementation plan approved or promulgated by the 

administrator through rule making under Title I of the FCAA

(b) Any federally enforceable term, condition or other requirement of any air quality 

preconstruction permit issued by the Department under Subchapters 7, 8, 9 and 10 of this 

chapter, or pursuant to regulations approved or promulgated through rule making under Title 

I of the FCAA, including parts C and D

(c) Any standard or other requirement under Sec. 7411 of the FCAA, including Sec. 7411(d)

(d) Any standard or other requirement under Sec. 7412 of the FCAA, including any requirement 

concerning accident prevention under Sec. 7412(r)(7), but excluding the contents of any risk 

management plan required under Sec. 7412(r)

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or 

regulations promulgated thereunder

(f) Any requirements established pursuant to Sec. 7661c(b) or Sec. 7414(a)(3) of the FCAA

(g) Any standard or other requirement governing solid waste incineration, under Sec. 7429 of the 

FCAA
OP2005-06 B-2 Date of Decision: 08/15/11

Effective Date: 09/15/11

(h) Any standard or other requirement for consumer and commercial products, under Sec. 

7511b(e) of the FCAA

(i) Any standard or other requirement for tank vessels, under Sec. 7511b(f) of the FCAA

(j) Any standard or other requirement of the regulations promulgated to protect stratospheric 

ozone under Title VI of the FCAA, unless the administrator determines that such 

requirements need not be contained in an air quality operating permit

(k) Any national ambient air quality standard or increment or visibility requirement under part C 

of Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to 

Sec. 7661c(e) of the FCAA or

(l) Any federally enforceable term or condition of any air quality open burning permit issued by 

the Department under Subchapter 6

"Department" means the Montana Department of Environmental Quality.

“Excess Emissions” means any visible emissions from a stack or source, viewed during the visual 

surveys, that meets or exceeds 15% opacity (or 30% opacity if associated with a 40% opacity limit) 

during normal operating conditions.

"Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit 

any regulated air pollutant or any pollutant listed under Sec. 7412(b) of the FCAA. This term is not 

meant to alter or affect the definition of the term "unit" for purposes of Title IV of the FCAA.

"FCAA" means the Federal Clean Air Act, as amended.

"Federally enforceable" means all limitations and conditions which are enforceable by the 

administrator, including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements 

within the Montana state implementation plan, and any permit requirement established pursuant to 40 

CFR 52.21 or under regulations approved pursuant to 40 CFR Part 51, Subpart I, including operating 

permits issued under an EPA approved program that is incorporated into the Montana state 

implementation plan and expressly requires adherence to any permit issued under such program.

"Fugitive emissions" means those emissions that could not reasonably pass through a stack, chimney, 

vent, or other functionally equivalent opening.

"General air quality operating permit" or "general permit" means an air quality operating permit that 

meets the requirements of ARM 17.8.1222, covers multiple sources in a source category, and is issued in 

lieu of individual permits being issued to each source.

"Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to Sec. 

112(b) of the FCAA. 

"Non-federally enforceable requirement" means the following as they apply to emission units in a 

source requiring an air quality operating permit:

(a) Any standard, rule, or other requirement, including any requirement contained in a consent 

decree, or judicial or administrative order entered into or issued by the Department, that is not 

contained in the Montana state implementation plan approved or promulgated by the 

administrator through rule making under Title I of the FCAA
OP2005-06 B-3 Date of Decision: 08/15/11

Effective Date: 09/15/11

(b) Any term, condition or other requirement contained in any air quality preconstruction permit 

issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter that is not federally 

enforceable

(c) Does not include any Montana ambient air quality standard contained in Subchapter 2 of this

chapter

"Permittee" means the owner or operator of any source subject to the permitting requirements of this 

subchapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has 

submitted a timely and complete permit application for issuance, renewal, amendment, or modification 

pursuant to this subchapter.

"Regulated air pollutant" means the following:

(a) Nitrogen oxides or any volatile organic compounds

(b) Any pollutant for which a national ambient air quality standard has been promulgated

(c) Any pollutant that is subject to any standard promulgated under Sec. 7411 of the FCAA

(d) Any Class I or II substance subject to a standard promulgated under or established by Title VI 

of the FCAA or

(e) Any pollutant subject to a standard or other requirement established or promulgated under 

Sec. 7412 of the FCAA, including but not limited to the following:

(i) Any pollutant subject to requirements under Sec. 7412(j) of the FCAA. If the 

administrator fails to promulgate a standard by the date established in Sec. 7412(e) of the 

FCAA, any pollutant for which a subject source would be major shall be considered to be 

regulated on the date 18 months after the applicable date established in Sec. 7412(e) of 

the FCAA

(ii) Any pollutant for which the requirements of Sec. 7412(g)(2) of the FCAA have been met 

but only with respect to the individual source subject to Sec. 7412(g)(2) requirement

"Responsible official" means one of the following:

(a) For a corporation: a president, secretary, treasurer, or vice-president of the corporation in 

charge of a principal business function, or any other person who performs similar policy or 

decision-making functions for the corporation, or a duly authorized representative of such 

person if the representative is responsible for the overall operation of one or more 

manufacturing, production, or operating facilities applying for or subject to a permit and 

either:

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures 

exceeding $25 million (in second quarter 1980 dollars) or 

(ii) The delegation of authority to such representative is approved in advance by the 

Department

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively
OP2005-06 B-4 Date of Decision: 08/15/11

Effective Date: 09/15/11

(c) For a municipality, state, federal, or other public agency: either a principal executive officer 

or ranking elected official. For the purposes of this part, a principal executive officer of a 

federal agency includes the chief executive officer having responsibility for the overall 

operations of a principal geographic unit of the agency (e.g., a regional administrator of the 

environmental protection agency).

(d) For affected sources: the designated representative in so far as actions, standards, 

requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated 

thereunder are concerned, and the designated representative for any other purposes under this 

subchapter.
OP2005-06 B-5 Date of Decision: 08/15/11

Effective Date: 09/15/11

Abbreviations:

ARM Administrative Rules of Montana

ASTM American Society of Testing Materials

BACT Best Available Control Technology

BDT bone dry tons

BTU British Thermal Unit

CFR Code of Federal Regulations

CO carbon monoxide

DEQ Department of Environmental Quality

dscf dry standard cubic foot

dscfm dry standard cubic foot per minute

EEAP Emergency Episode Action Plan

EPA U.S. Environmental Protection Agency

EPA Method Test methods contained in 40 CFR 60, Appendix A

EU emissions unit

FCAA Federal Clean Air Act

gr grains

HAP hazardous air pollutant

IEU insignificant emissions unit

Mbdft thousand board feet

Method 5 40 CFR 60, Appendix A, Method 5

Method 9 40 CFR 60, Appendix A, Method 9

MMbdft million board feet

MMBTU million British Thermal Units

NOx oxides of nitrogen

NO2 nitrogen dioxide

O2 oxygen

Pb lead

PM particulate matter

PM10 particulate matter less than 10 microns in size

psi pounds per square inch

scf standard cubic feet

SIC Source Industrial Classification

SO2 sulfur dioxide

SOx oxides of sulfur

tpy tons per year

U.S.C. United States Code

VE visible emissions

VOC volatile organic compound
OP2005-06 C-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix C NOTIFICATION ADDRESSES

Compliance Notifications:

Montana Department of Environmental Quality

Permitting and Compliance Division

Air Resources Management Bureau

P.O. Box 200901

Helena, MT 59620-0901

United States EPA

Air Program Coordinator

Region VIII, Montana Office

10 W. 15th Street, Suite 3200

Helena, MT 59626

Permit Modifications:

Montana Department of Environmental Quality

Permitting and Compliance Division

Air Resources Management Bureau

P.O. Box 200901

Helena, MT 59620-0901

Office of Partnerships and Regulatory Assistance

Air and Radiation Program

US EPA Region VIII 8P-AR

999 18th Street, Suite 300

Denver, CO 80202-2466
OP2005-06 D-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix D AIR QUALITY INSPECTOR INFORMATION

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to 

assist Ash Grove, permitting authority, inspectors, and the public.

1. Direction to Plant:

Exit Interstate 15 at the Montana City exit. Proceed east on Highway 518 for approximately 1 mile. 

The facility is located directly south of Highway 518.

2. Safety Equipment Required:

a. All inspectors will be required to wear hard hats at all times when in the plant area. Hard hats 

will be furnished by the inspector and are to be maintained in good repair.

b. Protective eye equipment will be used. Eye protection is mandatory in all plant areas. Safety 

glasses will meet or exceed ANSI Standard Z-87. 

c. Respirators and other personal equipment are to be used where needed and all such equipment 

will be provided by the inspector.

d. Steel-toed safety boots shall be worn by all inspectors.

e. Hearing protection with a minimum noise reduction rating of 24 DBA is mandatory in posted 

areas. 

3. Facility Plot Plan:

A copy of the facility Plot Plan is on file with the Department or may be received by contacting an 

Ash Grove representative.
OP2005-06 E-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix E Pollution Control Device Inspection and Maintenance Plan

A. Initial Submittal 

Ash Grove Cement Company shall submit to the Department, no later than 60 days from the date 

the operating permit is deemed effective, a Pollution Control Device Inspection and Maintenance 

Plan (Plan). The Plan shall cover all pollution control devices in accordance with the operating 

permit. 

Ash Grove Cement Company shall implement the requirements of Section C of this Appendix no 

later than 60 days from the date the operating permit is deemed final. 

B. Provisions For Changing the Plan

The requirements of Appendix E or the Plan may be changed if both Ash Grove Cement 

Company and the Department mutually agree in writing to any changes. Changes to Appendix E 

or the Plan cannot be implemented until both Ash Grove Cement Company and the Department 

agree in writing.

C. Minimum Requirements for Pollution Control Device Inspection and Maintenance Plan 

At a minimum, the Plan shall include the information outlined below unless otherwise approved 

in writing by the Department. 

1. Pollution Control Device Equipment Information

For each pollution control device, Ash Grove Cement Company shall provide the 

following information as applicable:

Collector identification

Plant location

Point and equipment the collector controls

Manufacturer

Model number

Serial number

Rated capacity

Airlock information

Existence of magnahelic gages etc.

Bag cleaning type (i.e. pulse-jet, reverse air, shaker)

Number of bags or cartridges

Bags or cartridge length

Bag material

Number of compartments per unit

Air flow rate

Air to cloth ratios

Exit gas temperature

Plate and wire cleaning mechanism

Number of plates

Number of wires

Number of compartments

Transformer-rectifier set information

Rapper system information
OP2005-06 E-2 Date of Decision: 08/15/11

Effective Date: 09/15/11

2. Schedule for Regular Inspection and Preventative Maintenance for Pollution Control 

Devices. 

A. Calendar Day

Ash Grove Cement Company shall perform the following activities at least daily.

1. ESP

Check exhaust for excess visible emissions (during daylight hours).

If excess visible emissions are observed, Ash Grove Cement Company shall investigate to determine the 

reason for the excess visible emissions. Ash Grove’s actions shall include, but are not limited to:

Check dust discharge system for proper operation.

Check that the rappers are operating.

1. Observe transformer-rectifier control meter readings.

2. Fabric Filters

Check exhaust for excess visible emissions (during daylight hours).

If excess visible emissions are observed, Ash Grove shall investigate to determine the reason for the 

excess visible emissions. Ash Grove’s actions shall include, but are not limited to:

Check and record fabric pressure loss and fan static pressure or fan amps (if available).

Check compressed air system for air leakage (if applicable).

1.. Multiclones

Check exhaust for excess visible emissions.

If excess visible emissions are observed, Ash Grove shall investigate to determine the reason for the 

excess visible emissions.

B. Calendar Quarter

Ash Grove shall perform the following list of activities on the ESP at least once 

per calendar quarter.

1. Check all rappers for proper operation.

2. Check hopper heaters for proper operation (if applicable).

3. Check hopper-level alarm systems for proper operation (if applicable).

C. Annually

The following inspections and preventative maintenance shall be performed at 

least once per calendar year. At minimum, the following items shall be inspected 

on each dust collector:
OP2005-06 E-3 Date of Decision: 08/15/11

Effective Date: 09/15/11

1. ESP

a. Collector Items

(1) Ducting to ESP and ducting from ESP

(2) Condition of exterior shell

(3) Doors and door seals

(4) Hopper including hopper level detectors and vibrators

b. Rapping System

(1) Motors

(2) Hammers

(3) Hammer shaft bearings

(4) Drive chains

(5) Sprockets

Fan Items

(1) Fan(s) for corrosion and material buildup

(2) Fan bearings 

(3) Bearing lubrication

(4) Fan housing

(5) Fan exit damper

 

Electrical/Instrumentation

(1) Transformer/rectifiers sets

(2) Oil filled cables and insulators

(3) Rapper shaft insulators

(4) High voltage controls

(5) Electrical cabinet cleanliness

(6) Instrumentation including voltage and current meters (check and 

calibrate) 

Collecting and Discharge Electrodes

(1) Check particle buildups

(2) Alignment and spacing

2. Fabric Filters

a. Collector Items

(1) Ducting to fabric filter and ducting from fabric filter

(2) Condition of exterior shell

(3) Doors including seals

(4) Hopper

(5) Screw conveyor

b. Bag Cleaning System

(1) Pulse-Jet

(a) Inlet diffuser or blast plate

(b) Air pulse diaphragms
OP2005-06 E-4 Date of Decision: 08/15/11

Effective Date: 09/15/11

(c) Solenoid(s) that activate pulse-pipes (i.e. check that cleaning 

sequence and cycle times for proper valve and timer 

operation)

(d) Pulse-pipe alignment and clamps

(e) Compressed air lines including oilers and filters

(2) Shaker

(a) Shaker motors and shaker mechanisms

(b) Bag tension and bag suspension

(c) Inlet diffuser or blast plate

(3) Reverse Air

(a) Reverse air fan

(b) Dampers and damper drive systems (pistons, etc.)

(c) Bag tension

(d) Inlet diffuser or blast plate

c. Bags

Proper fastening, bag tension, hanging, and excess particle accumulation.

(1) Thoroughly inspect bags for possible leaks (e.g. tears, holes, and 

abrasions).

d. Fan Items

(1) Fan(s) for corrosion and material buildup

(2) Fan bearings 

(3) Bearing lubrication

(4) Fan housing

e. Airlock

(1) Rotary feeder rotor condition

(2) Rotor bearing

(3) Drive sprocket

(4) Driven sprocket

(5) Drive chain

(6) Lubrication

f. Electrical/Instrumentation

(1) Fan motor

(2) Airlock motor

(3) Magnahelic tubing and enclosures (where applicable)

3. Multiclones

a. Check for erosion of the outlet tubes

b. Check gaskets on the clean side tube sheet 

c. Check for erosion of the axial inlet spinner vanes

d. Hopper

e. Screw conveyor
OP2005-06 E-5 Date of Decision: 08/15/11

Effective Date: 09/15/11

3. Documentation

A. Daily Observations

Ash Grove Cement Company shall record the identification information for the dust 

collector, the date and time of inspection, the inspector’s name, if excess visible 

emissions are observed. If excess visible emissions are observed, the corrective action 

taken shall be recorded. 

B. Quarterly and Annual Inspections

Ash Grove Cement Company shall record the identification information for the dust 

collector, the date of inspection, the inspector(s) name(s), and the items inspected for 

each piece of pollution control equipment. The report shall state whether maintenance or 

repairs were warranted. If maintenance is performed, Ash Grove Cement Company shall 

record the date(s) of the maintenance activity and the item(s) repaired or replaced. 

C. Component Failure Records

Ash Grove Cement Company shall keep records of component failure that are discovered 

during daily or annual inspections or that become apparent at any other time. The action 

taken upon discovery of a component failure shall be recorded. 

D. Record Retention

Pursuant to ARM 17.8.1212(2)(b), Ash Grove Cement Company shall retain records of 

all required monitoring data and support information for a period of at least five years 

from the date of the monitoring sample, measurement, report, or application.
OP2005-06 F-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix F CAM Plan – Kiln Stack Electrostatic Precipitator

Monitoring Approach -- ESP

I. Indicator ESP Power: Average hourly electrical power (kW) to the ESP

II. Measurement Approach The electrical power input is measured using a voltmeter and an 

ammeter. The total power (P) input to the ESP is the sum of the 

products of the secondary voltage (V) and current (I) in each field. 

(P = V1I + V2I2 + V3I3). The one-minute total power values 

collected will be summed and averaged hourly.

III. Indicator Value Because of the nature of the ESP, a lower end value will be 

established for power input. An excursion occurs if the hourly 

average power input drops below its respective hourly average 

indicator value (i.e., a total ESP power input less than the lowest 

average kW). The indicator value will be established during a 

source test. Excursions trigger an inspection, corrective action, 

and a reporting requirement. If appropriate corrective action does 

not expeditiously return the indicator parameter to within 48 hours, 

all reasonable efforts will be taken to remedy the malfunction as 

expeditiously as possible.

IV. Performance Criteria

 A. Data Representativeness

 B. Verification of Operational Status

 C. QA/QC Practices and Criteria

 D. Monitoring Frequency

 E. Data Collection Procedures

 F. Averaging period

 G. Performance Testing

The voltage and current are measured using the instrumentation 

specifically designed and installed on the ESP to measure and 

control the performance of the ESP.

kW: Continuous monitoring of total ESP power input

kW: Validate voltage controller output on an annual basis in 

accordance with good engineering practice

kW: The secondary voltage monitor and current monitor will 

measure their respective values on a fifteen second or less basis. 

The plant will calculate a one-hour block kW arithmetic mean 

value based on the available values. The plant will record at least 

ninety-five percent of the one-hour values.

kW: Record one-hour average

kW: One-hour average

After conducting the initial performance test to establish the 

indicator parameter values, Ash Grove will perform a 40 CFR Part 

60, Appendix A, Method 5 test once per calendar year to verify 

compliance with the kiln particulate matter emissions standards set 

out in the air permit.

Although the complete hard copy of Appendix F is not included in the permit, the contents of Appendix F, Ash 

Grove’s CAM plan remain as applicable requirements as stated in the Title V Operating Permit #OP2005-06. 

To receive a hard copy of this appendix, please contact one of the following:

The Department of Environmental Quality

Permitting and Compliance Division

Air Resources Management Bureau

1520 E. Sixth Ave.

P.O. Box 200901

Helena, Montana 59620-0901

Bureau Phone (406) 444-3490

OR

Ash Grove Cement Company.

Montana City Plant

100 MT Highway 518

Clancy, MT 59634

Phone (406) 442-8855
OP2005-06 G-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix G CAM Plan – Finish Mill House Baghouse

Monitoring Approach - Baghouse

I. Indicator

 Measurement Approach

Baghouse Differential Pressure

Inlet and outlet of the baghouse is monitored using a differential 

pressure transducer. The signal from the pressure transducer is 

recorded using a data acquisition system.

II. Indicator Range1 An excursion is defined as a daily average differential pressure of 

below 2 or above 10 inches of water pressure. An excursion triggers 

an inspection and possible corrective action.

III. Performance Criteria

 A. Data Representativeness

 B. Verification of Operational Status

 C. QA/QC Practices and Criteria

 D. Monitoring Frequency

 E. Data Collection Procedures

 F. Averaging Period

Pressure drop across the baghouse is measured across the tube sheet. 

The minimum accuracy of the device is +1 inch water pressure

N/A 

Pressure transducer is calibrated in accordance with manufacturer’s 

recommendations.

Pressure drop is continuously monitored and recorded. Data is 

stored in the plant histories and is accessed by the data acquisition 

system.

A data acquisition system measures pressure drop continuously

24-hour

1The above indicator ranges are a 24-hour average pressure range. Short-term spikes above or below this average do 

not necessarily indicate upset conditions. After cleaning, there may be a period of time required for the bags to 

build up a coating. During this period of time, the baghouse differential pressure may be out of range.

Although the complete hard copy of Appendix G is not included in the permit, the contents of Appendix G, 

Ash Grove’s CAM plan remain as applicable requirements as stated in the Title V Operating Permit #OP2005-

06. To receive a hard copy of this appendix, please contact one of the following:

The Department of Environmental Quality

Permitting and Compliance Division

Air Resources Management Bureau

1520 E. Sixth Ave.

P.O. Box 200901

Helena, Montana 59620-0901

Bureau Phone (406) 444-3490

OR

Ash Grove Cement Plant.

Montana City Plant

100 MT Highway 518

Clancy, MT 59634

Phone (406) 442-8855
OP2005-06 H-1 Date of Decision: 08/15/11

Effective Date: 09/15/11

Appendix H CAM Plan – Clinker Cooler Stack Baghouse

Monitoring Approach

I. Indicator

 Measurement Approach

Baghouse Differential Pressure

Inlet and outlet of the baghouse is monitored using a differential 

pressure transducer. The signal from the pressure transducer is 

recorded using a data acquisition system.

II. Indicator Range1 An excursion is defined as a daily average differential pressure of 

below 2 or above 10 inches of water pressure. An excursion triggers 

an inspection and possible corrective action.

III. Performance Criteria

 A. Data Representativeness

 B. Verification of Operational Status

 C. QA/QC Practices and Criteria

 D. Monitoring Frequency

 E. Data Collection Procedures

 F. Averaging Period

Pressure drop across the baghouse is measured across the tube sheet. 

The minimum accuracy of the device is +1 inch water pressure

N/A

Pressure transducer is calibrated in accordance with manufacturer’s 

recommendations

Pressure drop is continuously monitored and recorded. Data is 

stored in the plant histories and is accessed by the data acquisition 

system.

A data acquisition system measures pressure drop continuously.

24-hour

1 The above indicator ranges are a 24-hour average pressure range. Short-term spikes above or below this average 

do not necessarily indicate upset conditions. After cleaning, there may be a period of time required for the bags to 

build up a coating. During this period of time, the baghouse differential pressure may be out of range.

Although the complete hard copy of Appendix H is not included in the permit, the contents of Appendix H, 

Grove’s CAM plan remain as applicable requirements as stated in the Title V Operating Permit #OP2005-06. 

To receive a hard copy of this appendix, please contact one of the following:

The Department of Environmental Quality

Permitting and Compliance Division

Air Resources Management Bureau

1520 E. Sixth Ave.

P.O. Box 200901

Helena, Montana 59620-0901

Bureau Phone (406) 444-3490

OR

Ash Grove Cement Company

Montana City Plant

100 MT Highway 518

Clancy, MT 59634

Phone (406) 442-8855