September 15 , 2011

Richard Johnson Ash Grove Cement Company 100 Montana Highway 518 Clancy, MT 59634

RE: Renewal Title V Operating Permit #OP 2005

- 06

Dear Mr. Johnson :

The Department of Environmental Quality has prepared the enclosed Final Operating Permit #OP 2005

- 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 #OP 2005

- 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 Qua lity 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 CompanyOP2005

- 06 i Date of Decision: 08/15/11

Effective Date: 09/15/11 STATE OF MONTANA Department of E nvironmental 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 Appli cation Deemed Administratively Complete: March 29, 2010

Renewal Application Received: March 29, 2010

AFS Number: 030

- 043

- 0001 A

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

75

- 2

- 217 and 218 and the Adm inistrative 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. F ACILITY

- W IDE

................................ ................................ ................................ ........................... 3

B. EU001

– A IR S EPARATOR (AS)

................................ ................................ ................................ .. 6

C. EU002

– C LINKER C OOLER (CLC)

................................ ................................ ............................. 7

D. EU003

– C ONVEY /P RIMARY C RUSHING (CPC)

................................ ................................ .......... 9

E. EU004

– F

UEL C ONVEYORS (FC)

................................ ................................ .............................. 10

F. EU005

– F

UEL T RANSFER (FT)

................................ ................................ ................................ .. 12

G. EU006

– C EMENT K ILN (KILN)

................................ ................................ ................................ 14

H. EU007

– P RODUCT S EPARATOR AND C EMENT C OOLERS (PSC)

................................ ............... 17

I. EU008

– R OAD D UST (RD)

................................ ................................ ................................ ........ 18

J. EU009

– S TORAGE L OADOUT

– B (SLB)

................................ ................................ ................... 20

K. EU010

– S TONE T RANSFER (ST)

................................ ................................ ............................... 21

L. EU011

– T RANSFER B ELT C ONVEYORS (TBC)

................................ ................................ ......... 21

M. EU012

– T RANSFER

/C ONVEY TO B ALL M ILL (TBM)

................................ ................................ 23

N. EU013

– T RANSFER TO / FROM F INISH M ILL (TFM)

................................ ................................ ... 24

O. EU014

– T RANSFER TO L IMESTONE S ILOS (TLS)

................................ ................................ ...... 25

P. EU015

– W IND E ROSION (WE)

– ( FROM QUARRY ACTIVITI ES )

................................ ................. 26

SECTION IV. NON

- APPLICABLE REQUIREME NTS

................................ ............................... 28

F ACILITY

- W IDE

................................ ................................ ................................ ................................ . 28

E MISSION U NITS

................................ ................................ ................................ ................................ 29

SECTION V. GENERAL PERMIT CONDI TIONS

................................ ................................ ......... 30

A. C OMPLIANCE R EQUIREMENTS

................................ ................................ ................................ ... 30

B. C ERTIFICATION R EQUIREMENTS

................................ ................................ ............................... 30

C. P ERMIT S HIELD

................................ ................................ ................................ ......................... 31

D. M ONITORING

, R ECORDKEEPING

, AND R EPORTING R EQUIREMENTS

................................ ......... 32

E. P ROMPT D EVIATION R EPORTING

................................ ................................ ............................... 33

F. E MERGENCY P ROVISIONS

................................ ................................ ................................ .......... 34

G. I NSPECTION AND E NTRY

................................ ................................ ................................ ........... 34

H. F EE P AYMENT

................................ ................................ ................................ ........................... 35

I. M INOR P ERMIT M ODIFICATIONS

................................ ................................ ............................... 35

J. C HANGES N OT R EQUIRING P ERMIT R EVISION

................................ ................................ .......... 35

K. S IGNIFICANT P ERMIT M ODIFICATIONS

................................ ................................ ...................... 36

L. R EOPENING FOR C AUSE

................................ ................................ ................................ ............. 37

M. P ERMIT E XPIRATION AND R ENEWAL

................................ ................................ ......................... 37

N. S EVERABILITY C LAUSE

................................ ................................ ................................ ............. 38

O. T RANSFER OR A SSIGNMENT OF O WNERSHIP

................................ ................................ ............. 38

P. E MISSIONS T RADING

, M ARKETABLE P ERMITS

, E CONOMIC I NCENTIVES

................................ .. 38 Q. N O P ROPERTY R IGHTS C ONVEYED

................................ ................................ ........................... 38

R. T ESTING R EQUIREMEN TS

................................ ................................ ................................ .......... 38

S. S OURCE T ESTING P ROTOCOL

................................ ................................ ................................ .... 38

T. M ALFUNCTIONS

................................ ................................ ................................ ........................ 38

U. C IRCUMVENTION

................................ ................................ ................................ ....................... 39

V. M OTOR V EHICLES

................................ ................................ ................................ ..................... 39

W. A NNUAL E MISSIONS I NVENTORY

................................ ................................ .............................. 39OP2005

- 06 iii Date of Decision: 08/15/11

Effective Date: 09/15/11 X. O PEN B URNING

................................ ................................ ................................ ......................... 39

Y. M ONTANA A IR Q UALITY P ERMITS

................................ ................................ ............................ 39

Z. N ATIONAL E MISSION S TANDARD FOR A SBESTOS

................................ ................................ ..... 40

AA. A SBESTOS

................................ ................................ ................................ ................................ .. 40

BB. S TRATOSPHERIC O ZONE P ROTECTION

– S ERVICING OF M OTOR V EHICLE A IR C ONDITIONERS 40

CC. S TRATOSPHERIC O ZONE P ROTECTION

– R ECYCLING AND E MISSION R EDUCTIONS

.................. 40

DD. E M ERGENCY E PISODE P LAN

................................ ................................ ................................ ...... 41

EE. D EFINITIONS

................................ ................................ ................................ .............................. 41

APPENDIX A INSIGNIFICANT EMISSI ON UNITS

................................ ................................ . A

- 1

APPENDIX B DEFINITIONS AND ABBR EVIATIONS

................................ ............................ B

- 1

APPE NDIX C NOTIFICATION ADDRESS ES

................................ ................................ ............ C

- 1

APPENDIX D AIR QUALITY INSPECTO R INFORMATION

................................ ................. D

- 1

APPENDIX E POLLUTION CONTROL DE VICE INSPECTION AND MAINTENANCE

PLAN

............................................................ .......................................E

- 1

APPENDIX F CAM PLAN

– KILN STACK ELECTROST ATIC PRECIPITATOR

............. F

- 1

APPENDIX G CAM PLAN

– FINISH MILL HOUSE BA GHOUSE

................................ ......... G

- 1

APPENDIX H CAM PLAN

– CLINKER COOLER STACK BAGHOUSE

.............................. H

- 1OP2005

- 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 genera l 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: J eff Briggs Phone: (406) 44 4

- 7128

E

- Mail : Jeff

. briggs@ashgrove.com

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

Nature of Business: Portland Cement Manufacturing

Description of Process:

The product ion 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 wate r 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

c onveyor 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

Devi ce/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 Enclosu res
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 Baghou se (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 NoneOP2005

- 06 3 Date of Decision: 08/15/11

Effective Date: 09/15/11 SECTION III. PERMIT CONDITIONS

The following requirements and cond itions 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, Airborn e 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 * P 0.67 or E= 55 * P 0.11

- 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 Emi ssions,

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 AR M 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.1 7 ARM 17.8.1212 Reporting Requirements Compliance Monitoring

------- A.1 8 ARM 17.8.1207 Reporting Requirements Annual Certification

-------

Conditions

A.1. Pursuant to ARM 17.8.105, any p erson 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 tes t, 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 cas e 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 o n 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 disch arged 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 Gr ove 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

sou rce 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 reasona ble 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 N ovember 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 r ate 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 exc ess 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 * P 0.67
For process weight rates in excess of 30 tons per hour: E = 55.0 * P 0.11

– 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 specif ied 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 other wise 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 su bmerged 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 i n 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

- ef fluent 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 v olatility 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),

NO T 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 complian ce 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 submi t 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

semiannu al monitoring reports), shall contain certification by a responsible official of truth, accuracy and completeness. ThisOP2005

- 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 informatio n 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 17.8.120 7,

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 c ertification 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 comple te.”

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.1 0

., B.1 1 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.1 0

., B.1 1 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 gr eater averaged over six consecutive minutes (ARM 17.8.3 40 ).

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 emiss ion 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 M anual, 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 a nd 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.1 0

. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

B.1 1

. The semiannual monitoring report shall p rovide (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 Requirement s C.1, C.5.,
C.9., C.10.,
C.12., C.13

., C.14 Opacity 2 0% Method 9 As Required by the Department

and Section

III.A.1 Semiannual

C.2, C.3.,
C.6., C.7.,
C.9., C.1 1

., C.12., C.13

., C.14 Particulate Matter E=55.0P 0.11

- 40 Operation and

maintenance of bag house 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 SemiannualOP2005

- 06 8 Date of Decision: 08/15/11

Effective Date: 09/15/11 Condition s

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 2 0% or greater averaged over six consecutive minutes (ARM 17.8.304(1)).

C.2. Pursuant to ARM 17.8.310, th e particulate emissions from process weight shall not exceed the value calculated by E=55.0P 0.11

- 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 bagh ouse 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).

Complianc e 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 e mission 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 met hod 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 spec ified 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 preven tive 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 inspecti on 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 thi s 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 reportin g 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.1 0 Opacity 7% Method 9 Once during 5

- year permit term As required by the

Protocol

D.2.,D. 5

., D. 7., D.9

., D.1 0 Particul ate

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.1 0 Emissions

Control Equipment Operation and

maintenance of emission control equipment Operation and

maintenance of baghouse Semiannual S emiannual

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 great er 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 De monstration

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 Pro tocol 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. Th e 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 App endix 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 17.8.1 06 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 requirement s (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 perform ed 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 t he 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=55.0p 0.11

- 40 Use and maintenance

of structural

enc losures 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=55.0p 0.11

- 40, where E = rate of emission in pounds per hour and p = proces s 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 Convey ors

. 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

duri ng 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 ac tions are taken, then Ash Grove shall immediately conduct a subsequent visual survey (and subsequent Method 9 source test if visible

emiss ions 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 d oes 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 compli ance 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 b usiness 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 certificati on 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. 6OP2005

- 06 12 Date of Decision: 08/15/11

Effective Date: 09/15/11 F. EU00 5

– Fuel Transfer (FT)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Report ing 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=55.0p 0.11

- 40 Use and

maintenance

of structural

enclosure Whenever

process equi pment 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 consecut ive 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 = 55.0p 0.11

- 40, where E = rate of emission in pounds per hour and p = process weight rate in tons per hour (A RM 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 duri ng the visual survey, Ash Grove must either conduct a Method 9 source test , or shut d own 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 t ake corrective action to contain or minimize

the source of emissions. If corrective ac tions are taken, then Ash Grove shall immediately conduct a subsequent visual survey (and subsequent Method 9 source test if visible emissions remain) to monitor complia nce. 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 th e 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. Eac h 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 1 7.8.1213).

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 Sec tion 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 s urvey (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. A sh 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 recor d 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 requi red 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 t he semiannual period; and

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

III.F. 6.OP2005

- 06 14 Date of Decision: 08/15/11

Effective Date: 09/15/11 G. EU00 6

– 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=4.10p 0.67

- 40 (less

than 30 tons/hr)

E=55.0p 0.11

- 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.1 1

., 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.1 2

., 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 in to 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 th e 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

emiss ion limit shall be calculated using E=4.10p 0.67 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 calculate d using E = 55.0p 0.11 , 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 amo unt 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 di oxins 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 t he inlet to the particulate matter control device is 204° C (4 00° 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 appl icable 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 Me thod 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 25 th 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 sh all 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 da ys 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 temper ature 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 in spection 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 th e 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 t his 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 17.8.12 12).

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 devi ce inlet g as 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 Operatio n and Ma intenance 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 ab ove 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 in spection and maintenance of the ESP as required by Sect ion III.G. 8 ;

c. A summary of any timeframe when the logs required in Section II I.G.12 and G.1 9 were

not maintained ; and

d. Any reporting required by 4 0 CFR Part 64 (CAM), Appendix F , as applicable, during that semiannual period.

H. EU00 7

– 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% M ethod 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 O peration 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 a ny 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 Gr ove 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% opacit y 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 per mit 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, insp ect, 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 accord ance 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 p erformed 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 So urce 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 monitori ng 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. EU00 8

– 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 Airb orne 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 precaution s 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 sh all 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 hour s, Ash Grove shall visually survey active roads for any sources of excessive emissions. If visible emissions are observed duri ng the visual survey,

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

emissions. If corr ective ac tions 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 a nd/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 req uired 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 I II.I.3

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

III.I.5OP2005

- 06 20 Date of Decision: 08/15/11

Effective Date: 09/15/11 J. EU00 9

– 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 Par ticulate

Matter E=55.0P 0.11

- 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 proces s weight shall not exceed the value calculated by E=55.0P 0.11

- 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 accor dance 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 acco rdance 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 recordke eping 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 Secti on 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 II I.J.4 (ARM 17.8.1212).OP2005

- 06 21 Date of Decision: 08/15/11

Effective Date: 09/15/11 K. EU0 10

– 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 Departm ent
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 em issions 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 1 7.8.1212).

L. EU0 11

– 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 Dep artment 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=55.0P 0.11

- 40 Method 5 As required by the Dep artment and

Section III.A.1 As required by

the Protocol

Operation and

maintenance of baghouse Whenever process

equipment is operating SemiannualOP2005

- 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

f rom 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

- 4 0, 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 an d 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 t o 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 th e semiannual period

.OP2005

- 06 23 Date of Decision: 08/15/11

Effective Date: 09/15/11 M. EU0 12

– 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 requi red 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=55.0P 0.11

- 40 Method 5 As requir ed 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 outdo or 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 acco rdance 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 wi th 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 Protoco l 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 i nspection 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 certificatio n 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 bag house as requi red in Section III.M.5 ; and

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

.

N. EU0 13

– Transfer to/from Finish Mill (TFM)

Condition(s) Pollutant/

Parameter Permit Limit Compliance Demonstration

Meth od Frequency Reporting Requirements

N.1., N. 5

., N. 10 ., N. 12

., N.1 3 ., N.1 4 Opacity 40% Method 9 Every 2 years As required by the

Protocol
N.2., N. 6.,

N.10 ., N. 12

., N.1 3 ., N.1 4 Particulate

Matter 0.02 gr/dscf Method 5 Every 2 years As required by t he

Protocol
N.3., N. 7

., N. 9 ., N.1 3

., N.1 4 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 o f 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 equipm ent 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 Demonstratio n

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 17.8.1 504 is summarized in Appendix G and is available in full upon request by the D epartment 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 m aintained 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 thi s 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 cer tification 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 pe riod.

O. EU0 14

– 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 Depar tment 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=55.0P 0.11

- 40 Method 5 As required by the Depart ment and Section

III.A.1 As required by

the Protocol

Operation and maintenance of baghouse Whenever process equipment is operating SemiannualOP2005

- 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

fro m 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 wi th 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 particulat e 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 m aintenance 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

requ irements (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 r equired by Section III.O.5 ; and

b. A summary of results of any soure testing that was perfo rmed during the semiannual period

.

P. EU0 15

– 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 A irborne Particulate

Matter 20% Method 9 As required by the Department

and Section III.A.1 AnnuallyOP2005

- 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 cont rol 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 Demonstrat ion

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 ce rtification 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 se miannual 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 issu ance 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 a dministrated 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 l isted 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 a ffected 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 GGG G

- 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

- applicabl e 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 plan ned 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 Departm ent, 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 determin e 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

p ermittee 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 shal l 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 un less 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 c ertification 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, Su bchapter 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 inclu de 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 a nd 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 (b ased 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 compli ance status of

the source

4. All compliance certifications must be submitted to the Environmental Pr otection 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 en forceable 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 app licable 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 re issuance) 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

a dministrator 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 pu rsuant to Sec.

7414 of the FCAAOP2005

- 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 Ai r Act, Title 75, Chapter 2, MCA

f. The emergency powers of the Department under the Montana Clean Air Ac t, 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, i f 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 f

inal 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 1 7.8.132, 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, whe n 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 Sect ions 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 fol lowing 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 analyt ical techniques or methods used

e. T he results of such analy ses

f. The operating conditions at the time of sampling or measurementOP2005

- 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 infor mation, 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 mo nitoring 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 y ear. 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 tim e frames (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 wit h 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 regu lar semiannual (or other routin e) 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 §120 1(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 operatio n and causes the source to exceed a technology

based 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 designe d 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 identif y the cause(s) of the emergency

b. The permitted facility was at t he time being properly operated

c. During the pe riod 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 cred entials 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 emissions

related activity is conducted, or where records must be kept und er the conditions of the permit

b. Have access to and copy, at reasonable times, an y records that must be kept und er 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 o r required under the permi t

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 pe rmit or applicable requirementsOP2005

- 06 35 Date of Decision: 08/15/11

Effective Date: 09/15/11 2. The permi ttee 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 Titl e 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 fe e 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 f ee, 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

establ ished 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. Chan ges 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

ap plicable emission limitations on emission units covered by the permit; andOP2005

- 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 sha ll 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 applicabl e 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 contempor aneous 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, co nsistent with the requirements of the rule or

d. Any other change determined by t he Department to be significant

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including those for applications, public participation, and re view 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, updati ng, 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 und er 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 applicat ion, 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 ren ewal 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 p ermit 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 adm inistrative 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 m ay 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 exclusiv e 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, Su bchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325.

W. Annua l Emissions Inventory ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 (STATE ONLY)

The permittee shall supply the Depa rtment 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 t o 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 approv al 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 holdi ng 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 constr uction 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 cond itions 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 con tribute 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 reduc tions 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 lo cation 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 ch ange, 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).

A A. 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 Conditioner s 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 pr ovided 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 com ply 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 dispo sing 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 requ irements 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 s hall 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 l egally 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 re ferenced regulations.OP2005

- 06 42 Date of Decision: 08/15/11

Effective Date: 09/15/11 APPENDICESOP2005

- 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 req uirement 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, t he 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

.

"Admini strative 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 m inor administrative change at the source

(c) Requires more frequent monit oring or reporting by Ash Grove

(d) Requires changes in monitoring or reporting requirements that the Department deems to be no less stringent than current monit oring or reporting requireme nts

(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 th e Department has determined to be similar to

those revisi ons 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 implementat ion plan approved or promulgated by the administrator through rule m aking 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 th e FCAA, including parts C and D

(c) Any standard or other requirement under Sec. 7411 of t he 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 p lan required under Sec. 7412(r)

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or

reg ulations 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 incinerati on, under Sec. 7429 of the

F CAAOP2005

- 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 promulgat ed 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 requirem ent 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 S ubchapter 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 t erm 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

admi nistrator, 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 CF R 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 tho se 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 m aking under Title I of the FCAAOP2005

- 06 B

- 3 Date of Decision: 08/15/11

Effective Date: 09/15/11 (b) Any term, condition or other requirem ent contained in any air quality preconstruction permit issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter th at 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 applicati on 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 qualit y standard has been p romulgated

(c) Any pollutant that is subject to any standard promulga ted under Sec. 7411 of the FCAA

(d) Any Class I or II substance subject to a standard promulgated under or esta blished by Title VI

of the FCAA or

(e) Any pollutant subject to a standard or other r equirement 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 establish ed 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 establis hed in Sec. 7412(e) of

the FCAA

(ii) Any pollutant for which the requirements o f 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 o f 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 qua rter 1980 dollars) or

(ii) The delegation of authority to such representative is approv ed in advance by the Department

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectivelyOP2005

- 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 pr incipal 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 Con trol 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

E PA 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

NO 2 nitrogen dioxide

O 2 oxygen Pb lead

PM particulate matter

PM10 particulate matter less than 10 micron s in size psi pounds per square inch

scf standard cubic feet

SIC Source Industrial Classification

SO 2 sulfur dioxide

SOx oxides of sulfur

tpy tons per year
U.S.C. United States Code

VE visible emissions

VOC volatile organic compoundOP2005

- 06 C

- 1 Date of Decision: 08/15/11

Effective Date: 09/15/11 Appendix C NOTIFICATI ON 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 O ffice

10 W. 15 th 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 Re gulatory Assistance Air and Radiation Program US EPA Region VIII 8P

- AR

999 18 th Street, Suite 300
Denver, CO 80202

- 2466OP2005

- 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 Highw ay 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 us ed. 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

- toe d 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 receive d 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 t his 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 w riting 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, t he 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 inf

ormation 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, rev erse 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 compart ments
Transformer

- rectifier set information Rapper system informationOP2005

- 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 leas t 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 shal l 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 st atic 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) Trans former/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 Discha rge 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) Sc rew conveyor

b. Bag Cleaning System

(1) Pulse

- Jet

(a) Inlet diffuser or blast plate (b) Air pulse diaphragmsOP2005

- 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

- p ipe 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) Damper s 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

abr asions).

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) Dr ive 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 s heet c. Check for erosion of the axial inlet spinner vanes d. Hopper e. Screw conveyorOP2005

- 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 inspect ion, 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 performe d, 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 ann ual 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 mon itoring 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 ES P 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 excurs ion 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 in spection, 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 possibl e.
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 : Val idate 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 establ ish 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

- 0 6

. To receive a hard copy of this appendix, please contact one of the f ollowing:

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 Plan t 100 MT Highway 518 Clancy, MT 59634 Phone (406) 442

- 8855OP2005

- 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 mon itored using a differential pressure transducer. The signal from the pressure transducer is recorded using a data acquisition system. II. Indicator Range 1 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. Monitori ng 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 continuous ly

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 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

- 0 6 . 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 A ve. 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

- 8855OP2005

- 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. I ndicator Range 1 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 Representati veness

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 t ube 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 histor ies 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 necess arily 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

- 0 6

. To receive a hard copy of this appendix, please contact one of the following:

The Departm

ent 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

Cl ancy, MT 59634 Phone (406) 442

- 8855