Missouri Department of Natural Resources

Air Pollution Control Program

PERMIT TO OPERATE

Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to operate the air

contaminant source(s) described below, in accordance with the laws, rules, and conditions set forth here in.

Operating Permit Number: OP 2005 009

Expiration Date:

Installation ID: 173-0001

Project Number: 173-0001-0001

Installation Name and Address

Continental Cement Company, L.L.C.

10107 Highway 79

Hannibal, MO 63401

Ralls County

Parent Company's Name and Address

Continental Cement Company, L.L.C.

10107 Highway 79

Hannibal, MO 63401

Installation Description:

Continental Cement Company operates a long wet process cement kiln to manufacture

portland cement near the city of Hannibal in Ralls county. The installation is located in an

attainment area. The installation is an existing major source of particulate matter less than ten

(10) microns, sulfur oxides and nitrogen oxides.

Effective Date Director or Designee

Department of Natural Resources
Continental Cement Company, L.L.C. 2

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Table of Contents

I. INSTALLATION DESCRIPTION AND EQUIPMENT LISTING ..........................................................................9

INSTALLATION DESCRIPTION............................................................................................................................ 9

EMISSION UNITS WITH LIMITATIONS.............................................................................................................. 9

EMISSION UNITS WITHOUT LIMITATIONS.................................................................................................... 10

DOCUMENTS INCORPORATED BY REFERENCE........................................................................................... 12

II. PLANT WIDE EMISSION LIMITATIONS......................................................................................................13

Permit Condition PW001 – Cement Kiln ................................................................................................................ 13

10 CSR 10-6.075 ......................................................................................................................................................................................13

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 13

40 CFR Part 63, Subpart EEE...................................................................................................................................................................13

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– MONITORING AND COMPLIANCE PROVISIONS §63.1206(A) THROUGH (B)(5)...................................................... 13

40 CFR Part 63, Subpart A.......................................................................................................................................................................13

GENERAL PROVISIONS ............................................................................................................................................. 13

Permit Condition PW002 – Cement Kiln ................................................................................................................ 15

10 CSR 10-6.075 ......................................................................................................................................................................................15

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 15

40 CFR Part 63, Subpart EEE...................................................................................................................................................................15

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– OPERATING REQUIREMENTS – GENERAL - §63.1206(C)(1)................................................................................. 15

- STARTUP, SHUTDOWN AND MALFUNCTION PLAN - §63.1206(C)(2).................................................................... 15

- AUTOMATIC WASTE FEED CUTOFF (AWFCO) - §63.1206(C)(3) ........................................................................ 15

40 CFR Part 63, Subpart A.......................................................................................................................................................................15

GENERAL PROVISIONS – STARTUP, SHUTDOWN AND MALFUNCTION PLAN §63.6(E)(3)........................................ 15

Permit Condition PW003 – Cement Kiln ................................................................................................................ 19

10 CSR 10-6.075 ......................................................................................................................................................................................19

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 19

40 CFR Part 63, Subpart EEE...................................................................................................................................................................19

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– OPERATING REQUIREMENTS - COMBUSTION SYSTEM LEAKS - §63.1206(C)(5) ................................................. 19

40 CFR Part 63, Subpart A.......................................................................................................................................................................19

GENERAL PROVISIONS ............................................................................................................................................. 19

Permit Condition PW004 – Cement Kiln ................................................................................................................ 21

10 CSR 10-6.075 ......................................................................................................................................................................................21

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 21

40 CFR Part 63, Subpart EEE...................................................................................................................................................................21

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– RECORD KEEPING AND REPORTING REQUIREMENTS - §63.1211(A)..................................................................... 21

40 CFR Part 63, Subpart A.......................................................................................................................................................................21

GENERAL PROVISIONS – EXCESS EMISSIONS AND CONTINUOUS MONITORING SYSTEM PERFORMANCE REPORT

AND SUMMARY REPORT - §63.10(E)(3) .................................................................................................................. 21

Permit Condition PW005 – Cement Kiln ................................................................................................................ 23

10 CSR 10-6.075 ......................................................................................................................................................................................23

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 23

40 CFR Part 63, Subpart EEE...................................................................................................................................................................23

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– OPERATING REQUIREMENTS – OPERATOR TRAINING AND CERTIFICATION - §63.1206(C)(6)............................ 23

40 CFR Part 63, Subpart A.......................................................................................................................................................................23

GENERAL PROVISIONS ............................................................................................................................................. 23

Permit Condition PW006 – Cement Kiln ................................................................................................................ 25

10 CSR 10-6.075 ......................................................................................................................................................................................25

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 25

40 CFR Part 63, Subpart EEE...................................................................................................................................................................25
Continental Cement Company, L.L.C. 3

Installation ID Number: 173-0001 Project Number: 173-0001-0001

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– OPERATING REQUIREMENTS – OPERATION AND MAINTENANCE PLAN - §63.1206(C)(7)................................... 25

40 CFR Part 63, Subpart A.......................................................................................................................................................................25

GENERAL PROVISIONS – OPERATION AND MAINTENANCE REQUIREMENTS §63.6(E)(1) AND (2) .......................... 25

Permit Condition PW007 – Cement Kiln ................................................................................................................ 26

10 CSR 10-6.075 ......................................................................................................................................................................................26

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 26

40 CFR Part 63, Subpart EEE...................................................................................................................................................................26

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– OPERATING REQUIREMENTS – SUMMARY OF NOTIFICATION REQUIREMENTS - §63.1210(A) – SUMMARY OF

REPORTING REQUIREMENTS - §63.1211(A) ............................................................................................................. 26

40 CFR Part 63, Subpart A.......................................................................................................................................................................26

GENERAL PROVISIONS ............................................................................................................................................. 26

Permit Condition PW008 – Cement Kiln ................................................................................................................ 27

10 CSR 10-6.075 ......................................................................................................................................................................................27

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 27

40 CFR Part 63, Subpart EEE...................................................................................................................................................................27

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– DOCUMENTATION OF COMPLIANCE - §63.1211(C).............................................................................................. 27

40 CFR Part 63, Subpart A.......................................................................................................................................................................27

GENERAL PROVISIONS ............................................................................................................................................. 27

Permit Condition PW009 – Cement Kiln ................................................................................................................ 28

10 CSR 10-6.075 ......................................................................................................................................................................................28

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 28

40 CFR Part 63, Subpart EEE1 .................................................................................................................................................................28

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– DATA COMPRESSION - §63.1211(D)..................................................................................................................... 28

40 CFR Part 63, Subpart A.......................................................................................................................................................................28

GENERAL PROVISIONS ............................................................................................................................................. 28

Permit Condition PW010 – Cement Kiln ................................................................................................................ 29

10 CSR 10-6.075 ......................................................................................................................................................................................29

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 29

40 CFR Part 63, Subpart EEE...................................................................................................................................................................29

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– ............................................................................................................................................................................... 29

40 CFR Part 63, Subpart A.......................................................................................................................................................................29

GENERAL PROVISIONS ............................................................................................................................................. 29

Permit Condition PW011 – Cement Kiln ................................................................................................................ 38

10 CSR 10-6.075 ......................................................................................................................................................................................38

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 38

40 CFR Part 63, Subpart EEE...................................................................................................................................................................38

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– WAIVER OF PERFORMANCE TEST §63.1207.......................................................................................................... 38

40 CFR Part 63, Subpart A.......................................................................................................................................................................38

GENERAL PROVISIONS ............................................................................................................................................. 38

Permit Condition PW012 – Cement Kiln ................................................................................................................ 39

10 CSR 10-6.075 ......................................................................................................................................................................................39

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 39

40 CFR Part 63, Subpart EEE...................................................................................................................................................................39

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– FEEDSTREAM ANALYSIS - §63.1209(C)(1)............................................................................................................ 39

40 CFR Part 63, Subpart A.......................................................................................................................................................................39

GENERAL PROVISIONS ............................................................................................................................................. 39

Permit Condition PW013 – Cement Kiln ................................................................................................................ 41

10 CSR 10-6.075 ......................................................................................................................................................................................41

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 41

40 CFR Part 63, Subpart EEE...................................................................................................................................................................41
Continental Cement Company, L.L.C. 4

Installation ID Number: 173-0001 Project Number: 173-0001-0001

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– ALTERNATE MONITORING REQUIREMENTS OTHER THAN CONTINUOUS EMISSIONS MONITORING SYSTEMS

(CEMS) - §63.1209(G)............................................................................................................................................. 41

40 CFR Part 63, Subpart A.......................................................................................................................................................................41

GENERAL PROVISIONS ............................................................................................................................................. 41

Permit Condition PW014 – Cement Kiln ................................................................................................................ 42

10 CSR 10-6.075 ......................................................................................................................................................................................42

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 42

40 CFR Part 63, Subpart EEE...................................................................................................................................................................42

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– ALTERNATE STANDARDS FOR EXISTING OR NEW HAZARDOUS WASTE BURNING CEMENT KILNS USING MACT -

§63.1206(B)(10)....................................................................................................................................................... 42

40 CFR Part 63, Subpart A.......................................................................................................................................................................42

GENERAL PROVISIONS ............................................................................................................................................. 42

Permit Condition PW015 – Cement Kiln ................................................................................................................ 44

10 CSR 10-6.075 ......................................................................................................................................................................................44

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 44

40 CFR Part 63, Subpart EEE...................................................................................................................................................................44

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– ALTERNATE STANDARDS FOR EXISTING OR NEW HAZARDOUS WASTE BURNING CEMENT KILNS USING MACT

– CMS MONITORING §63.1209(B)(1) THROUGH (B)(5)........................................................................................... 44

40 CFR Part 63, Subpart A.......................................................................................................................................................................44

GENERAL PROVISIONS ............................................................................................................................................. 44

Permit Condition PW016 – Milling, Conveying, Storage and Loading Systems .................................................... 45

10 CSR 10-6.075 ......................................................................................................................................................................................45

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS 40 CFR PART 63, SUBPART LLL .................... 45

40 CFR Part 63, Subpart A.......................................................................................................................................................................45

GENERAL PROVISIONS – STARTUP, SHUTDOWN AND MALFUNCTION PLAN §63.6(E)(3)........................................ 45

Permit Condition PW017 – Milling, Conveying, Storage and Loading Systems .................................................... 46

10 CSR 10-6.075 ......................................................................................................................................................................................46

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 46

40 CFR Part 63, Subpart LLL...................................................................................................................................................................46

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – OPERATIONS AND MAINTENANCE PLAN §63.1350(A) AND (B)............................. 46

40 CFR Part 63, Subpart A.......................................................................................................................................................................46

GENERAL PROVISIONS – OPERATION AND MAINTENANCE REQUIREMENTS §63.6(E)(1) AND (2) .......................... 46

Permit Condition PW018 – Milling, Conveying, Storage and Loading Systems .................................................... 48

10 CSR 10-6.075 ......................................................................................................................................................................................48

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 48

40 CFR Part 63, Subpart LLL...................................................................................................................................................................48

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – NOTIFICATION REQUIREMENTS §63.1353, REPORTING REQUIREMENTS

§63.1354(A) AND RECORD KEEPING REQUIREMENTS §63.1355(A) AND (B) ........................................................... 48

40 CFR Part 63, Subpart A.......................................................................................................................................................................48

GENERAL PROVISIONS ............................................................................................................................................. 48

Permit Condition PW019 – Milling, Conveying, Storage and Loading Systems .................................................... 49

10 CSR 10-6.075 ......................................................................................................................................................................................49

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 49

40 CFR Part 63, Subpart LLL...................................................................................................................................................................49

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – PERFORMANCE TESTING REQUIREMENTS §63.1349 ............................................. 49

40 CFR Part 63, Subpart A.......................................................................................................................................................................49

GENERAL PROVISIONS ............................................................................................................................................. 49

Permit Condition PW020 – Milling, Conveying, Storage and Loading Systems .................................................... 50

10 CSR 10-6.075 ......................................................................................................................................................................................50

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 50

40 CFR Part 63, Subpart LLL...................................................................................................................................................................50
Continental Cement Company, L.L.C. 5

Installation ID Number: 173-0001 Project Number: 173-0001-0001

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – ALTERNATE MONITORING REQUIREMENTS §63.1350 .......................................... 50

Permit Condition PW021 – Fugitive Emissions ...................................................................................................... 51

10 CSR 10-6.170 ......................................................................................................................................................................................51

RESTRICTION OF PARTICULATE MATTER TO THE AMBIENT AIR BEYOND THE PREMISES OF ORIGIN .................... 51

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS .................................................................................52

Permit Condition EU0010-01 Cement Kiln.......................................................................................................... 53

10 CSR 10-6.075 ......................................................................................................................................................................................53

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 53

40 CFR Part 63, Subpart EEE...................................................................................................................................................................53

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– DIOXINS AND FURANS........................................................................................................................................... 53

40 CFR Part 63, Subpart A.......................................................................................................................................................................53

GENERAL PROVISIONS ............................................................................................................................................. 53

Permit Condition EU0010-02 Cement Kiln............................................................................................................ 57

10 CSR 10-6.075 ......................................................................................................................................................................................57

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 57

40 CFR Part 63, Subpart EEE...................................................................................................................................................................57

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– MERCURY.............................................................................................................................................................. 57

40 CFR Part 63, Subpart A.......................................................................................................................................................................57

GENERAL PROVISIONS ............................................................................................................................................. 57

Permit Condition EU0010-03 Cement Kiln............................................................................................................ 60

10 CSR 10-6.075 ......................................................................................................................................................................................60

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 60

40 CFR Part 63, Subpart EEE...................................................................................................................................................................60

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– LEAD AND CADMIUM (SEMI-VOLATILE METALS)................................................................................................ 60

40 CFR Part 63, Subpart A.......................................................................................................................................................................60

GENERAL PROVISIONS ............................................................................................................................................. 60

Permit Condition EU0010-04 Cement Kiln............................................................................................................ 63

10 CSR 10-6.075 ......................................................................................................................................................................................63

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 63

40 CFR Part 63, Subpart EEE...................................................................................................................................................................63

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– ARSENIC, BERYLLIUM AND CHROMIUM (LOW VOLATILITY METALS) ................................................................ 63

40 CFR Part 63, Subpart A.......................................................................................................................................................................63

GENERAL PROVISIONS ............................................................................................................................................. 63

Permit Condition EU0010-05 Cement Kiln............................................................................................................ 66

10 CSR 10-6.075 ......................................................................................................................................................................................66

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 66

40 CFR Part 63, Subpart EEE...................................................................................................................................................................66

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– CARBON MONOXIDE AND HYDROCARBONS ......................................................................................................... 66

40 CFR Part 63, Subpart A.......................................................................................................................................................................66

GENERAL PROVISIONS ............................................................................................................................................. 66

Permit Condition EU0010-06 Cement Kiln............................................................................................................ 70

10 CSR 10-6.075 ......................................................................................................................................................................................70

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 70

40 CFR Part 63, Subpart EEE...................................................................................................................................................................70

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– HYDROCHLORIC ACID AND CHLORINE GAS ......................................................................................................... 70

40 CFR Part 63, Subpart A.......................................................................................................................................................................70

GENERAL PROVISIONS ............................................................................................................................................. 70

Permit Condition EU0010-07 Cement Kiln........................................................................................................... 73

10 CSR 10-6.075 ......................................................................................................................................................................................73
Continental Cement Company, L.L.C. 6

Installation ID Number: 173-0001 Project Number: 173-0001-0001

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 73

40 CFR Part 63, Subpart EEE...................................................................................................................................................................73

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– PARTICULATE MATTER (NOTE: WHEN THE PERMITTEE COMPLIES WITH THE PARTICULATE MATTER

REQUIREMENTS UNDER §63.1207(A)(7) , THE PERMITTEE IS EXEMPT FROM THE NEW SOURCE PERFORMANCE

STANDARD FOR PARTICULATE MATTER AND OPACITY UNDER §60.60.).................................................................. 73

40 CFR Part 63, Subpart A.......................................................................................................................................................................73

GENERAL PROVISIONS ............................................................................................................................................. 73

Permit Condition EU0010-08 Cement Kiln............................................................................................................ 76

10 CSR 10-6.075 ......................................................................................................................................................................................76

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 76

10 CSR 10-6.220 ......................................................................................................................................................................................76

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 76

40 CFR Part 63, Subpart EEE...................................................................................................................................................................76

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– OPACITY (NOTE: WHEN THE PERMITTEE COMPLIES WITH THE PARTICULATE MATTER REQUIREMENTS UNDER

§63.1207(A)(7), THE PERMITTEE IS EXEMPT FROM THE NEW SOURCE PERFORMANCE STANDARD FOR

PARTICULATE MATTER AND OPACITY UNDER §60.60.)............................................................................................ 76

40 CFR Part 63, Subpart A.......................................................................................................................................................................76

GENERAL PROVISIONS ............................................................................................................................................. 76

Permit Condition EU0010-09 Cement Kiln............................................................................................................ 78

10 CSR 10-6.075 ......................................................................................................................................................................................78

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY REGULATIONS ......................................................................... 78

40 CFR Part 63, Subpart EEE...................................................................................................................................................................78

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM HAZARDOUS WASTE COMBUSTORS

– DESTRUCTION AND REMOVAL EFFICIENCY (DRE) – PRINCIPAL ORGANIC HAZARDOUS CONSTITUENT............ 78

40 CFR Part 63, Subpart A.......................................................................................................................................................................78

GENERAL PROVISIONS ............................................................................................................................................. 78

Permit Condition EU0010-10 Cement Kiln............................................................................................................ 82

10 CSR 10-6.260 ......................................................................................................................................................................................82

RESTRICTION OF EMISSION OF SULFUR COMPOUNDS.............................................................................................. 82

Permit Condition EU0010-11 ................................................................................................................................. 82

10 CSR 10-6.220 ......................................................................................................................................................................................82

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 82

10 CSR 10-6.060 ......................................................................................................................................................................................82

CONSTRUCTION PERMITS REQUIRED ....................................................................................................................... 82

CONSTRUCTION PERMIT NUMBER 1086-004D ........................................................................................................ 82

Permit Condition EU0020-01 Clinker Cooler ........................................................................................................ 83

40 CFR Part 63, Subpart LLL...................................................................................................................................................................83

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – PARTICULATE MATTER ......................................................................................... 83

40 CFR Part 63, Subpart A.......................................................................................................................................................................83

GENERAL PROVISIONS ............................................................................................................................................. 83

Permit Condition EU0020-02 Clinker Cooler ........................................................................................................ 84

10 CSR 10-6.220 ......................................................................................................................................................................................84

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 84

40 CFR Part 63, Subpart LLL...................................................................................................................................................................84

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – OPACITY ................................................................................................................ 84

40 CFR Part 63, Subpart A.......................................................................................................................................................................84

GENERAL PROVISIONS ............................................................................................................................................. 84

Permit Condition EU0030-01 through EU0390-01 and EU0420-01....................................................................... 85

10 CSR 10-6.400 ......................................................................................................................................................................................85

RESTRICTION OF EMISSION OF PARTICULATE MATTER FROM INDUSTRIAL PROCESSES......................................... 85

Permit Condition EU0400-01, EU0410-01, EU0430-01, EU0440-01 .................................................................... 86

10 CSR 10-6.400 ......................................................................................................................................................................................86
Continental Cement Company, L.L.C. 7

Installation ID Number: 173-0001 Project Number: 173-0001-0001

RESTRICTION OF EMISSION OF PARTICULATE MATTER FROM INDUSTRIAL PROCESSES......................................... 86

Permit Condition EU0110, EU0140 through EU0180, EU0245, EU0300 through EU0380, EU0400 through

EU0450 .................................................................................................................................................................... 87

10 CSR 10-6.075 ......................................................................................................................................................................................87

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY.................................................................................................. 87

10 CSR 10-6.220 ......................................................................................................................................................................................87

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 87

40 CFR Part 63, Subpart LLL...................................................................................................................................................................87

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – OPACITY ................................................................................................................ 87

40 CFR 63, Subpart A ..............................................................................................................................................................................87

GENERAL PROVISIONS ............................................................................................................................................. 87

Permit Condition EU0200 through 230-02, and 250 through 280-02 ..................................................................... 89

10 CSR 10-6.075 ......................................................................................................................................................................................89

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY.................................................................................................. 89

10 CSR 10-6.220 ......................................................................................................................................................................................89

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 89

40 CFR Part 63, Subpart LLL...................................................................................................................................................................89

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM THE PORTLAND CEMENT

MANUFACTURING INDUSTRY – OPACITY ................................................................................................................ 89

40 CFR Part 63, Subpart A.......................................................................................................................................................................89

GENERAL PROVISIONS ............................................................................................................................................. 89

Permit Condition EU0445-01 .................................................................................................................................. 90

10 CSR 10-6.220 ......................................................................................................................................................................................90

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 90

10 CSR 10-6.060 ......................................................................................................................................................................................90

CONSTRUCTION PERMITS REQUIRED ....................................................................................................................... 90

CONSTRUCTION PERMIT NUMBER 0198-014 ........................................................................................................... 90

Permit Condition EU0460-01 through EU0490-01 ................................................................................................. 91

10 CSR 10-6.060 ......................................................................................................................................................................................91

EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS ................................................................................... 91

40 CFR Part 61 Subpart FF ......................................................................................................................................................................91

NATIONAL EMISSION STANDARD FOR BENZENE WASTE OPERATIONS................................................................... 91

Permit Condition EU0460-02 through EU0490-02 ................................................................................................. 94

10 CSR 10-6.070 ......................................................................................................................................................................................94

NEW SOURCE PERFORMANCE REGULATIONS.......................................................................................................... 94

40 CFR Part 60 Subpart Kb ......................................................................................................................................................................94

STANDARDS OF PERFORMANCE FOR VOLATILE ORGANIC LIQUID STORAGE VESSELS FOR WHICH CONSTRUCTION,

RECONSTRUCTION, OR MODIFICATION COMMENCED AFTER JULY 23, 1984.......................................................... 94

Permit Condition EU0500-01 through EU0540-01 ................................................................................................. 95

10 CSR 10-6.220 ......................................................................................................................................................................................95

RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS................................................................................. 95

10 CSR 10-6.060 ......................................................................................................................................................................................95

CONSTRUCTION PERMITS REQUIRED ....................................................................................................................... 95

CONSTRUCTION PERMIT NUMBER 122001-014 ....................................................................................................... 95

IV. CORE PERMIT REQUIREMENTS ................................................................................................................97

V. GENERAL PERMIT REQUIREMENTS........................................................................................................102

PERMIT DURATION................................................................................................................................................. 102

GENERAL RECORD KEEPING AND REPORTING REQUIREMENTS............................................................................ 102

RISK MANAGEMENT PLANS UNDER SECTION 112(R)............................................................................................ 103

SEVERABILITY CLAUSE.......................................................................................................................................... 103

GENERAL REQUIREMENTS ..................................................................................................................................... 103

INCENTIVE PROGRAMS NOT REQUIRING PERMIT REVISIONS................................................................................ 103

REASONABLY ANTICIPATED OPERATING SCENARIOS ........................................................................................... 104

COMPLIANCE REQUIREMENTS ............................................................................................................................... 104
Continental Cement Company, L.L.C. 8

Installation ID Number: 173-0001 Project Number: 173-0001-0001

PERMIT SHIELD ...................................................................................................................................................... 105

EMERGENCY PROVISIONS ...................................................................................................................................... 105

OPERATIONAL FLEXIBILITY................................................................................................................................... 105

OFF-PERMIT CHANGES........................................................................................................................................... 106

RESPONSIBLE OFFICIAL ......................................................................................................................................... 106

REOPENING PERMIT FOR CAUSE............................................................................................................................ 107

STATEMENT OF BASIS ............................................................................................................................................ 107

ATTACHMENTS.................................................................................................................................................. 108

STATEMENT OF BASIS ................................................................................................................................1

PERMIT REFERENCE DOCUMENTS ............................................................................................................................. 1

APPLICABLE REQUIREMENTS INCLUDED IN THE OPERATING PERMIT BUT NOT IN THE APPLICATION ..................... 1

OTHER AIR REGULATIONS DETERMINED NOT TO APPLY TO THE OPERATING PERMIT ............................................ 1

CONSTRUCTION PERMIT REVISIONS .......................................................................................................................... 2

NSPS APPLICABILITY ................................................................................................................................................ 2

MACT APPLICABILITY .............................................................................................................................................. 5

NESHAP APPLICABILITY .......................................................................................................................................... 9

OTHER REGULATORY DETERMINATIONS................................................................................................................. 10

OTHER REGULATIONS NOT CITED IN THE OPERATING PERMIT OR THE ABOVE STATEMENT OF BASIS ................. 15
Continental Cement Company, L.L.C. 9

Installation ID Number: 173-0001 Project Number: 173-0001-0001

I. Installation Description and Equipment Listing

INSTALLATION DESCRIPTION

Continental Cement Company operates a long wet process cement kiln to manufacture portland cement near the

city of Hannibal in Ralls county. The installation is located in an attainment area. The installation is an existing

major source of particulate matter less than ten (10) microns (PM10), sulfur oxides (SOX) and nitrogen oxides

(NOX).

The installation contains quarry operations, raw material handling and storage, kiln pyro-processing, cement

kiln dust and coal/gypsum handling, clinker cooling, finish mill systems and cement storage and loadout. The

installation is subject to the Portland Cement Manufacturing MACT and the Hazardous Waste Combustor

MACT.

Reported Air Pollutant Emissions, tons per year

Year Particulate

Matter

< Ten Microns

(PM-10)

Sulfur

Oxides

(SOx)

Nitrogen

Oxides

(NOx)

Volatile

Organic

Compounds

(VOC)

Carbon

Monoxide

(CO)

Lead

(Pb)

Hazardous

Air

Pollutants

(HAPs)

1996 322.60 1034.30 1809.20 35.00 63.40 0.10 -

1997 358.13 814.61 1370.06 39.05 61.53 - -

1998 329.05 1339.00 1486.24 6.94 60.93 - -

1999 245.45 1079.06 1953.20 6.60 42.72 0.25 -

2000 186.41 606.52 1922.01 6.63 78.60 0.25 0.21

2001 207.54 546.12 2056.97 6.66 81.48 1.08 -

EMISSION UNITS WITH LIMITATIONS

The following list provides a description of the equipment at this installation which emit air pollutants and

which are identified as having unit-specific emission limitations.

Emission

Unit

2000 EIQ

Point Description Control Device Manufacture Year

EU0010 KP-1 cement kiln ESP Amer. Air 1966

EU0020 CM-1 clinker cooler KDC - 5 Amerex 1966

EU0030 CM-2a dust collector discharges to apron pan

conveyor

SC-3 DCE Vokes 1966

EU0040 CM-2 clinker transfer drag to apron pan

conveyor

KAP - 1 Fuller 1966

EU0050 CM-1a Clean-up screw discharges to apron pan

conveyor

Enclosure sock 1966

EU0060 CM-3 clinker apron pan conveyor transfer point

to bucket elevator KAP - 2 DCE Vokes 1966

EU0070 CM-4a clinker transfer - east elevator to belt

conveyor

KDC-1B DCE Vokes 1966

EU0080 CM-4 clinker transfer - west elevator to belt

conveyor

KDC-1A DCE Vokes 1966

EU0090 CM-4b clinker transfer - conveyor1a to conveyor

1d KDC-1C/KBC-1B2 DCE Vokes 1966

EU0100 CM-4c clinker transfer - conveyor 1b to

conveyor 1c KDC-1D/KBC-1A2 DCE Vokes 1966

EU0110 CM-12c clinker hopper Enclosure walls 1966

EU0120 CM-7a clinker transfer – hopper to conveyor belt Enclosed/Skirting 1966

EU0130 CM-7b clinker transfer - conveyor belt to elevator KDC-3, CR-DC BHA-DCE

Vokes 1966

EU0140 CM-8 clinker storage silos- F Silos KDC-3 BHA 1966

EU0150 CM-8a clinker storage silos - North Silos KDC-1 BHA 1966

EU0160 CM-8b clinker storage silos - South Silos KDC-2 BHA 1966
Continental Cement Company, L.L.C. 10

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Emission

Unit

2000 EIQ

Point Description Control Device Manufacture Year

EU0170 CM-8c clinker storage silos - North fringe FDC-1F BHA 1966

EU0180 CM-8d clinker storage silos - South fringe FDC-2F BHA 1966

EU0190 CM9.1a,b,c,2a,b,c clinker weighing and transfer - mill 1-2 FDC-1a,b,c/FDC-2a,b,c Flex -Kleen 1966

EU0200 CM-10 clinker grinding ( mill # 1 ) FDC-1E BHA 1966

EU0210 CM-10a Finish Mill #1 Elevator O-Sepa - 1DC Fuller 1966

EU0220 CM-10c finish mill #1 air separator O-Sepa - 1DC Fuller 1966

EU0230 CM-10d finish mill #1 - surge bin O-Sepa - 1DC Fuller 1966

EU0240 CM-10e finish mill #1 - 1G fringe bin FDC-1 A Flex -Kleen 1966

EU0245 CM-10j Mill Building 1966

EU0250 CM-10.1 clinker grinding ( mill # 2 ) FDC-2E BHA 1966

EU0260 CM-10F finish mill #2 - elevator O-Sepa - 2DC Fuller/BHA 1966

EU0270 CM-10g finish mill #2 air separator O-Sepa - 2DC Fuller/BHA 1966

EU0280 CM-10h finish mill #2 - surge bin O-Sepa - 2DC Fuller/BHA 1966

EU0290 CM-10I finish mill #2 - 2G fringe bin FDC-2 A Flex -Kleen 1966

EU0300 CM-11 clinker reclaim elevator discharge KDC-3 BHA 1966

EU0310 CM-12 clinker transfer tripper to clinker storage

pile KDC - 5 Amerex 1966

EU0320 SH-1 cement storage - stockhouse #6 XDC - 1 Torit 1966

EU0330 SH-2 cement storage silos CDC 1 BHA 1966

EU0340 SH-2 cement storage silos CDC 2 BHA 1966

EU0350 SH-2 cement storage silos CDC 3 BHA 1966

EU0360 SH-2 cement storage silos CDC 4 BHA 1966

EU0370 SH-2 cement storage silos CDC 5 BHA 1966

EU0380 SH-2 cement storage silos CDC 6 BHA 1966

EU0390 SH-3 cement transfer - silos into pump/air slide

system CDC 9,10 BHA 1966

EU0400 SH-4 cement handling - bulk truck loading lines CDC 11,12 Flex - Kleen 1966

EU0410 SH-5 cement handling - bulk railcar/truck

loading lines CDC 13, 14,15 W. W. Sly 1966

EU0420 SH-7 cement storage silos BDC - 1 Dustex 1966

EU0430 SH-8 cement barge loading BLDC - 1 Fuller 1966

EU0440 SH-9 cement barge loading BLDC - 2 Fuller 1966

EU0450 SG-10 Syn-Gyp Building 1997

EU0460 SF-2A,2B Supplemental fuel storage tanks (6) 1986

EU0470 SF-3A,3B Supplemental fuel burn tanks (2) 1990

EU0480 SF- 60 Supplemental fuel storage tank 2004

EU0490 SF- 21 Supplemental fuel storage tank pending

EU0500 Artificial Soils Project 1991

EU0510 Artificial Soils Project 1991

EU0520 Artificial Soils Project 1991

EU0530 Artificial Soils Project 1991

EU0540 Artificial Soils Project 1991

EMISSION UNITS WITHOUT LIMITATIONS

The following list provides a description of the equipment that does not have unit specific limitations at the time

of permit issuance.

Description of Emission Source 

haul road unpaved - coal barge and truck to coal stockpile

haul road paved - coal barge and truck to coal stockpile

haul road unpaved - clinker barge and truck to stockhouse 5
Continental Cement Company, L.L.C. 11

Installation ID Number: 173-0001 Project Number: 173-0001-0001

haul road paved - clinker barge and truck to stockhouse 5

haul road unpaved - coal truck and barge plant entrance to stockhouse 5

haul road paved - coal truck and barge plant entrance to stockhouse 5

haul road unpaved - clinker truck to hopper

coal storage pile ( staging )

haul road - coal stockpile to hopper

haul road unpaved - gypsum - plant entrance to stockhouse 5

haul road paved - gypsum - plant entrance to stockhouse 5

gypsum storage pile 

haul road - unpaved gypsum from stockhouse 5 to hopper

hopper conveyor

conveyor to elevator transfer point

coal transfer (rail) - elevator to belt conveyor MBE-1/MBC-2

coal transfer point (rail) - belt conveyor to truck

haul road - coal transfer to coal storage pile CG-4

coal transfer point - elevator to coal conveyor MBE-1/MBC-3

coal transfer point - conveyor to conveyor MBC-3/MBC-4

coal transfer point - conveyor to conveyor MBC-4/MBC-5

coal transfer point - conveyor to silo MBC-4/Coal Silo

gypsum transfer point - elevator to conveyor MBE-1/MBC-3

gypsum transfer point - conveyor to conveyor MBC-3/MBC-4

gypsum transfer point - conveyor to silo MBC-4/MBC-5

gypsum transfer point - conveyor MBC-5 to Bin 1

gypsum transfer point - conveyor MBC-6 to Bin 2

coal/coke storage pile 

haul road (unpaved) plant entrance to outdoor storage pile

Synthetic Gypsum Storage Pile - outdoor

haul road - unpaved, Synthetic Gypsum Storage Pile to hopper

quarries - drilling

quarries - blasting

quarries - loading haul trucks

haul roads - quarries to primary crusher

haul road unpaved - plant entrance to stockhouse 5 clay

haul road paved - plant entrance to stockhouse 5 clay

haul road, unpaved - plant entrance to underground mine

haul road, unpaved - plant entrance to clay storage pile

clay storage pile ( underground mine )

clay storage pile ( outdoor )

clay storage pile - stockhouse # 5

haul road, unpaved - clay storage pile to primary crusher

haul roads - stockhouse 5 to primary crusher - clay

raw material unloading

primary crusher

raw material conveyor transfer point LCB 2 to LCB 2a

crushed limestone reclaim hopper

raw material conveyor transfer point LCB 2a to LCB 2b, or RM-13

crushed limestone stockpile - using combined emission factor

raw material conveyor transfer point LCB 2b to LCB 3, or Silo F

transfer, secondary crusher to conveyor to mill, clay
Continental Cement Company, L.L.C. 12

Installation ID Number: 173-0001 Project Number: 173-0001-0001

haul road unpaved - plant entrance to underground mine - clay

haul road unpaved - plant entrance to outdoor clay storage pile

clay storage pile - underground

outdoor clay storage pile

haulroad unpaved - clay storage piles to primary crusher

waste dust agglomerator

haul road - waste dust to landfill

waste dust truck unloading at landfill

waste dust storage pile at landfill

clinker storage pile in stockhouse 5 using combined activity factor

clinker storage pile in stockhouse 5 using wind erosion factor

haul road - clinker from stockhouse 5 to hopper

clinker transfer - outside clinker storage piles to hopper

haul road - outside stockpile to stockhouse 5

outside clinker storage piles using combined emission factor

syn-gyp process building

haul road to storage pile

haul road to highway

DOCUMENTS INCORPORATED BY REFERENCE

These documents have been incorporated by reference into this permit.

1) Construction Permit Number 0686-002

2) Construction Permit Number 0686-002A

3) Construction Permit Number 1086-004

4) Construction Permit Number 1086-004A

5) Construction Permit Number 1086-004B

6) Construction Permit Number 1086-004C

7) Construction Permit Number 1086-004D

8) Construction Permit Number 0890-008

9) Construction Permit Number 0198-014

10) Construction Permit Number 122001-014

11) Construction Permit Number 092002-022
Continental Cement Company, L.L.C. 13

Installation ID Number: 173-0001 Project Number: 173-0001-0001

II. Plant Wide Emission Limitations

The installation shall comply with each of the following emission limitations. Consult the appropriate sections

in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the

applicable requirements.

Permit Condition PW001 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Monitoring and Compliance Provisions §63.1206(a) through (b)(5)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The emission standards and operating requirements apply at all times except: (§63.1206(b)(1)(i))

(1) During periods of startup, shutdown and malfunction; and,

(2) When hazardous waste is not in the combustion chamber (i.e., the hazardous waste feed to the

combustor has been cutoff for a period of time not less than the hazardous waste residence time), and

the permittee has documented in the operating record that the permittee is complying with the alternate

mode of compliance defined in Appendix A of the Initial Comprehensive Performance Test Plan, or

otherwise applicable requirements and standards promulgated under authority of sections 112 (e.g.,

subpart LLL of this part for cement kilns) or 129 of the Clean Air Act in lieu of the emission standards

of §§63.1203 through 63.1205; the monitoring and compliance standards of §63.1206 and §§63.1207

through 63.1209, except the modes of operation requirements of §63.1209(q); and the notification,

reporting, and record keeping requirements of §§63.1210 through 63.1212.. (§63.1206(b)(1)(ii)).

Changes in design, operation or maintenance that may adversely affect compliance. If the permittee

plans to change (as defined in §63.1205(b)(5)(iii)) the design, operation or maintenance practices of

the source in a manner that may adversely affect compliance with an emission standard that is not

monitored with a CEMS: (§63.1206(b)(5)(i))

• Restriction on Waste Burning – Except as provided by §63.1206(b)(5)(i)(C)(2), after the change and prior to

submitting the notification of compliance, the permittee must not burn hazardous waste for more than a total

of 720 hours (renewable at the discretion of the Administrator) and only for purposes of pretesting or

comprehensive performance testing. Pretesting is defined at §63.1207(h)(2)(i), and(ii)).

(§63.1206(b)(5)(i)(C)(1))

• The permittee may petition the Administrator to obtain written approval to burn hazardous waste in the

interim prior to submitting a Notification of Compliance for purposes other than testing or pretesting. The

permittee must specify operating requirements, including limits on operating parameters, that the permittee

determines will ensure compliance with the emission standards of this subpart based on available

information. The Administrator will review, modify as necessary, and approve if warranted the interim

operating requirements. (§63.1206(b)(5)(i)(C)(2))

• Definition of Change – “Change means any change in design, operation, or maintenance practices that were

documented in the comprehensive performance test plan, Notification of Compliance, or startup, shutdown,

and malfunction plan. (§63.1206(b)(5)(iii))

Compliance Dates: 

• The permittee must comply with the standards of this subpart no later than September 30, 2003, unless the

Administrator grants an extension of time under §63.6(i) or §63.1213. (§63.1206(a)(1))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 14

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Monitoring:

• Changes in design, operation or maintenance that may adversely affect compliance. If the permittee plans to

change (as defined in §63.1205(b)(5)(iii)) the design, operation or maintenance practices of the source in a

manner that may adversely affect compliance with an emission standard that is not monitored with a CEMS:

(§63.1206(b)(5)(i))

The permitee must conduct a comprehensive performance test under the requirements of §§ 63.1207(f)(1)

and (g)(1) to document compliance with the affected emission standard(s) and establish operating parameter

limits as required under § 63.1209, and submit to the Administrator a Notification of Compliance under §§

63.1207(j) and 63.1210(d); (§63.1206(b)(5)(i)(B))

• The Administrator will determine compliance with the emission standards of this subpart as provided by

§63.6(f)(2). Conducting performance testing under operating conditions representative of the extreme range

of normal conditions is consistent with the requirements of §§63.6(f)(2)(iii)(B) and 63.7(e)(1) to conduct

performance testing under representative operating conditions. (§63.1206(b)(2))

• The Administrator will make a finding concerning compliance with the emission standards and other

requirements of this subpart as provided by §63.6(f)(3). (§63.1206(b)(3))

• The Administrator may grant an extension of compliance with the emission standards of this subpart as

provided by §§63.6(i) and 63.1213. (§63.1206(b)(4))

Record Keeping and Reporting: 

• Changes that may adversely affect compliance:

Notification. The permittee must notify the Administrator at least 60 days prior to the change, unless the

permittee documents circumstances that dictate that such prior notice is not reasonably feasible. The

notification must include: (§63.1206(b)(5)(i)(A))

(1) A description of the changes and which emission standards may be affected; and

(§63.1206(b)(5)(i)(A)(1))

(2) A comprehensive performance test schedule and test plan under the requirements of § 63.1207(f) that

will document compliance with the affected emission standard(s); (§63.1206(b)(5)(i)(A)(2))

• Restriction on waste burning: The permittee may petition the Administrator to obtain written approval to

burn hazardous waste in the interim prior to submitting a Notification of Compliance for purposes other than

testing or pretesting. The permittee must specify operating requirements, including limits on operating

parameters that the permittee determines will ensure compliance with the emission standards of this subpart

based on available information. The Administrator will review, modify as necessary, and approve if

warranted the interim operating requirements. (§63.1206(b)(5)(i)(C)(2))

• Changes that will not affect compliance: If the permittee determine that a change will not adversely affect

compliance with the emission standards or operating requirements, the permittee must document the change

in the operating record upon making such change. The permittee must revise as necessary the performance

test plan, Documentation of Compliance, Notification of Compliance, and start-up, shutdown, and

malfunction plan to reflect these changes. (§63.1206(b)(5)(ii)

 The permittee must maintain copies of the performance test plan, Documentation of Compliance,

Notification of Compliance, and start-up shutdown and malfunction plan. The permittee shall keep a copy

of the plans, documentation, and notifications on-site at all times. The plans, documentation, and

notifications shall be made available immediately for inspection to the Department of Natural Resources’

personnel upon request.
Continental Cement Company, L.L.C. 15

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW002 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Operating Requirements – General - §63.1206(c)(1) 

 - Startup, Shutdown and Malfunction Plan - §63.1206(c)(2)

 - Automatic Waste Feed Cutoff (AWFCO) - §63.1206(c)(3)

40 CFR Part 63, Subpart A

General Provisions – Startup, Shutdown and Malfunction Plan §63.6(e)(3)

Emission Limitation:

General:

• The permittee must maintain at the affected source a current startup, shutdown, and malfunction plan and

must make the plan available upon request for inspection and copying by the Administrator. In addition, if

the startup, shutdown, and malfunction plan is subsequently revised as provided in §63.6(e)(3)(viii), the

permittee must maintain at the affected source each previous (i.e., superseded) version of the startup,

shutdown, and malfunction plan, and must make each such previous version available for inspection and

copying by the Administrator for a period of five years after revision of the plan. If at any time after

adoption of a startup, shutdown, and malfunction plan the affected source ceases operation or is otherwise

no longer subject to the provisions of part 63, the permittee must retain a copy of the most recent plan for

five years from the date the source ceases operation or is no longer subject to part 63 and must make the

plan available upon request for inspection and copying by the Administrator. [§63.6(e)(3)(v)]

• The permittee must operate only under the operating requirements specified in the Documentation of

Compliance under §63.1211(c) or the Notification of Compliance under §§63.1207(j) and 63.1210(b),

except: (§63.1206(c)(1)(i))

(1) During performance tests under approved test plans according to §63.1207(e), (f) and (g), and

(§63.1206(c)(1)(i)(A))

(2) Under the conditions of periods of startup, shutdown, malfunction, or when waste is not in the

combustion chamber. §63.1206(b)(1)(i) or (ii). (§63.1206(c)(1)(i)(B))

• The Documentation of Compliance and the Notification of Compliance must contain operating requirements

including, but not limited to, the operating requirements in §63.1206(c) and §63.1209. (§63.1206(c)(1)(ii))

• Failure to comply with the operating requirements is failure to ensure compliance with the emission

standards of this subpart. (§63.1206(c)(1)(iii))

• Operating requirements in the Notification of Compliance are applicable requirements for purposes of Parts

70 and 71 of this chapter. (§63.1206(c)(1)(iv))

• The operating requirements specified in the Notification of Compliance will be incorporated in the Title V

permit. (§63.1206(c)(1)(v))

Startup, shutdown, and malfunction plan:

• The permittee is subject to the startup, shutdown and malfunction plan requirements of §63.6(e)(3).

(§63.1206(c)(2)(i))

• If the permittee elects to comply with §§270.235(a)(1)(iii), 270.235(a)(2)(iii), or 270.235(b)(1)(ii) of this

chapter to address RCRA concerns that the permittee minimizes emissions of toxic compounds from startup,

shutdown, and malfunction events (including releases from emergency safety vents):. (§63.1206(c)(2)(ii))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 16

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The startup, shutdown, and malfunction plan must include a description of potential causes of malfunctions,

including releases from that may result in significant releases of hazardous air pollutants, and actions the

source is taking to minimize the frequency and severity of those malfunctions. (§63.1206(c)(2)(ii)(A))

• Permittee must submit the startup, shutdown, and malfunction plan to the Administrator for review and

approval. (§63.1206(c)(2)(ii)(B))

• Responsibility of the permittee. The permittee is responsible for ensuring that the permittee submits any

supplementary and additional information supporting the plan in a timely manner to enable the

Administrator to consider whether to approve the plan. Neither the submittal of the plan, nor the

Administrator's failure to approve or disapprove the plan, relieves permittee of the responsibility to comply

with the provisions of this subpart. (§63.1206(c)(2)(ii)(B)(2))

• Changes to the plan that may significantly increase emissions:. (§63.1206(c)(2)(ii)(C))

(1) Permittee must request approval in writing from the Administrator within five days after making a

change to the startup, shutdown, and malfunction plan that may significantly increase emissions of

hazardous air pollutants. (§63.1206(c)(2)(ii)(C)(1))

(2) To request approval of such changes to the startup, shutdown, and malfunction plan, permittee must

follow the procedures provided by §63.1206(c)(2)(ii)(B) for initial approval of the plan.

(§63.1206(c)(2)(ii)(C)(2))

• The permittee must identify in the plan a projected oxygen correction factor based on normal operations to

use during periods of startup and shutdown. (§63.1206(c)(2)(iii))

• Compliance with automatic waste feed cutoff (AWFCO) requirements during malfunctions.

[§63.1206(c)(2)(v)(A)] 

(1) During malfunctions, the automatic waste feed cutoff requirements of §63.1206(c)(3) continue to

apply, except for §§63.1206(c)(3)(v) and (c)(3)(vi). If the permittee exceeds a subpart EEE emission

standard monitored by a CEMS or COMs or operating limit specified under §63.1209, the automatic

waste feed cutoff system must immediately and automatically cutoff the hazardous waste feed, except

as provided by §63.1206(c)(3)(viii). If the malfunction itself prevents immediate and automatic cutoff

of the hazardous waste feed, however, the permittee must cease feeding hazardous waste as quickly as

possible. [§63.1206(c)(2)(v)(A)(1)]

(2) Although the automatic waste feed cutoff requirements continue to apply during a malfunction, an

exceedance of an emission standard monitored by a CEMS or COMS or operating limit specified

under §63.1209 is not a violation of subpart EEE if the permittee takes the corrective measures

prescribed in the startup, shutdown, and malfunction plan. [§63.1206(c)(2)(v)(A)(2)]

• Compliance with AWFCO requirements when burning hazardous waste during startup and shutdown.

[§63.1206(c)(2)(v)(B)] 

(1) If the permittee feeds hazardous waste during startup or shutdown, the permittee must include waste

feed restrictions (e.g., type and quantity), and other appropriate operating conditions and limits in the

startup, shutdown, and malfunction plan. [§63.1206(c)(2)(v)(B)(1)]

(2) The permittee must interlock the operating limits the permittee establishes under

§63.1206(c)(2)(v)(B)(1) with the automatic waste feed cutoff system required under §63.1206(c)(3),

except for §§63.1206(c)(3)(v) and (c)(3)(vi). [§63.1206(c)(2)(v)(B)(2)]

(3) When feeding hazardous waste during startup or shutdown, the automatic waste feed cutoff system

must immediately and automatically cutoff the hazardous waste feed if the permittee exceeds the

operating limits the permittee establishes under §63.1206(c)(2)(v)(B)(1), except as provided by

§63.1206(c)(3)(viii). [§63.1206(c)(2)(v)(B)(3)]

(4) Although the automatic waste feed cutoff requirements of §63.1206 apply during startup and

shutdown, an exceedance of an emission standard or operating limit is not a violation of subpart EEE

if the permittee complies with the operating procedures prescribed in the startup, shutdown, and

malfunction plan. [§63.1206(c)(2)(v)(B)(4)]
Continental Cement Company, L.L.C. 17

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee must record the (projected oxygen correction factor) plan in the operating record.

(§63.1206(c)(2)(iv))

• The permittee shall develop and implement a written startup, shutdown, and malfunction plan that describes,

in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and

malfunction and a program of corrective action for malfunctioning process and air pollution control

equipment used to comply with the relevant standard. As required under §63.8(c)(1)(i), the plan shall

identify all routine or otherwise predictable CMS malfunctions. This plan shall be developed by the

permittee by the source’s compliance date for that relevant standard. The plan shall be incorporated by

reference into the source’s Title V permit. The purpose of the startup, shutdown, and malfunction plan is to:

(§63.6(e)(3)(i))

(1) Ensure that, at all times, the permittee operates and maintains affected sources including associated air

pollution control equipment, in a manner consistent with good air pollution control practices for

minimizing emissions at least to the levels required by all relevant standards; (§63.6(e)(3)(i)(A))

(2) Ensure that the permittee is prepared to correct malfunctions as soon as practicable after their

occurrence in order to minimize excess emissions of hazardous air pollutants; and (§63.6(e)(3)(i)(B))

(3) Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (including

corrective action taken to restore malfunctioning process and air pollution control equipment to its

normal or usual manner of operation). (§63.6(e)(3)(i)(C))

• Upon the compliance date, the permittee must operate the hazardous waste combustor with a functioning

system that immediately and automatically cuts off the hazardous waste feed, except as provided by

§63.1206(c)(3)(viii): (§63.1206(c)(3)(i))

(1) When any of the following are exceeded: Operating parameter limits specified under §63.1209; an

emission standard monitored by a CEMS; or the allowable combustion chamber pressure;

(§63.1206(c)(3)(i)(A)) 

(2) When the span value of any CMS detector, except a CEMS, is met or exceeded;

((§63.1206(c)(3)(i)(B))

(3) Upon malfunction of a CMS monitoring an operating parameter limit specified under §63.1209 or an

emission level; or (§63.1206(c)(3)(i)(C))

(4) When any component of the automatic waste feed cutoff system fails. (§63.1206(c)(3)(i)(D))

• Ducting of Combustion Gases – During an AWFCO, the permittee must continue to duct combustion gases

to the air pollution control system while hazardous waste remains in the combustion chamber (i.e., if the

hazardous waste residence time has not transpired since the hazardous waste feed cutoff system was

activated). (§63.1206(c)(3)(ii))

• Restarting Waste Feed – The permittee must continue to monitor during the cutoff the operating parameters

for which limits are established under §63.1209 and the emissions required under that section to be

monitored by a CEMS, and the permittee must not restart the hazardous waste feed until the operating

parameters and emission levels are within the specified limits. (§63.1206(c)(3)(iii))

• Failure of the AWFCO System – If the AWFCO system fails to automatically and immediately cutoff the

flow of hazardous waste upon exceedance of parameter required to be interlocked with the AWFCO system

under §63.1206(c)(3)(i), the permittee has failed to comply with the AWFCO requirements of

§63.1206(c)(3). (§63.1206(c)(3)(iv))

• Ramping Down Waste Feed – The permittee may ramp down the waste feedrate of pumpable hazardous

waste over a period not to exceed one minute, except as provided by §63.1206(c)(3)(viii)(B). If the

permittee elects to ramp down the waste feed, the permittee must document ramp down procedures in the

operating and maintenance plan. The procedures must specify that the ramp down begins immediately upon

initiation of automatic waste feed cutoff and the procedures must prescribe a bona fide ramping down. If an

emission standard or operating limit is exceeded during the ramp down, the permittee has failed to comply

with the emission standards or operating requirements of this subpart. (§63.1206(c)(3)(viii)(A))
Continental Cement Company, L.L.C. 18

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Ramping Down Waste Feed – If the automatic waste feed cutoff is triggered by an exceedance of any of the

following operating limits, the permittee may not ramp down the waste feed cutoff: Minimum combustion

chamber temperature, maximum hazardous waste feedrate, or any hazardous waste firing system operating

limits that may be established for the permittee’s combustor. (§63.1206(c)(3)(viii)(B))

Testing:

• The AWFCO system and associated alarms must be tested at least weekly to verify operability, unless the

permittee documents in the operating record that weekly inspections will unduly restrict or upset operations

and that less frequent inspection will be adequate. At a minimum, the permittee must conduct operability

testing at least monthly. The permittee must document and record in the operating record AWFCO

operability test procedures and results. (§63.1206(c)(3)(vii))

Monitoring:

• During periods of startup, shutdown, and malfunction, the permittee shall operate and maintain such source

(including associated air pollution control equipment) in accordance with the procedures specified in the

startup, shutdown, and malfunction plan developed under §63.6(e)(3). (§63.6(e)(3)(ii))

• Corrective Measures – If, after any AWFCO, there is an exceedance of an emission standard or operating

requirement, irrespective of whether the exceedance occurred while hazardous waste remained in the

combustion chamber (i.e., whether the hazardous waste residence time has transpired since the hazardous

waste feed cutoff system was activated), the permittee must investigate the cause of the AWFCO, take

appropriate corrective measures to minimize future AWFCOs, and record the findings and corrective

measure in the operating record. (§63.1206(c)(3)(v))

Record Keeping:

• The permittee shall keep a copy of the startup, shutdown, malfunction plan on-site at all times. The plan

shall be made available immediately for inspection to the Department of Natural Resources’ personnel upon

request.

• When actions taken by the permittee during a startup, shutdown, or malfunction (including actions taken to

correct a malfunction) are consistent with the procedures specified in the startup, shutdown and malfunction

plan, the permittee shall keep records for that event that demonstrate the procedures specified in the plan

were followed. These records may take the form of a “checklist,” or other effective form of record keeping,

that confirms conformance with the startup, shutdown, and malfunction plan for that event. In addition the

permittee shall keep records of these events as specified in §63.10(b) (and elsewhere in this part), including

records of the occurrence and duration of each startup, shutdown, or malfunction operation and each

malfunction of the air pollution control equipment. Furthermore, the permittee shall confirm that actions

taken during the relevant reporting period during periods of startup, shutdown, and malfunction were

consistent with the affected source's startup, shutdown and malfunction plan in the semiannual (or more

frequent) startup, shutdown, and malfunction report required in §63.10(d)(5). (§63.6(e)(3)(iii))

• If an action taken by the permittee during a startup, shutdown, or malfunction (including an action taken to

correct a malfunction) is not consistent with the procedures specified in the affected source’s startup,

shutdown, and malfunction plan, and the source exceeds the relevant emission standard, then the permittee

must report such actions within two working days after commencing actions inconsistent with the plan,

followed by a letter within seven days after the end of the event, in accordance with §63.10(d)(5) (unless the

permittee makes alternative reporting arrangements, in advance, with the Administrator) (§63.6(e)(3)(iv))

• The permittee must record the startup, shutdown, and malfunction plan in the operating record.

[§63.1206(c)(2)(iv)]

(1) The permittee must document and record in the operating record: Results of an excessive exceedance

during malfunctions investigation including a summary of the investigation and evaluation, and any

changes to the startup, shutdown and malfunction plan; [§63.1206(c)(2)(iv)(A)(3)(ii)]

(2) AWFCO investigation and corrective measures taken; [§63.1206(c)(3)(v)]

(3) AWFCO operability test procedures and results; [§63.1206(c)(3)(vii)]

(4) Ramp down procedures. [§63.1206(c)(3)(viii)(A)]
Continental Cement Company, L.L.C. 19

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Reporting:

• Excessive exceedances during malfunctions. For each set of ten exceedances of an emission standard or

operating requirement while hazardous waste remains in the combustion chamber (i.e., when the hazardous

waste residence time has not transpired since the hazardous waste feed was cutoff) during a 60 day block

period, the permittee must: [§63.1206(c)(2)(iv)(A)(3)]

(1) Within 45 days of the 10th exceedance, complete an investigation of the cause of each exceedance and

evaluation of approaches to minimize the frequency, duration, and severity of each exceedance, and

revise the startup, shutdown, and malfunction plan as warranted by the evaluation to minimize the

frequency, duration, and severity of each exceedance; and [§63.1206(c)(2)(iv)(A)(3)(i)]

(2) Record the results of the investigation and evaluation in the operating record, and include a summary

of the investigation and evaluation, and any changes to the startup, shutdown, and malfunction plan, in

the excess emissions report required under §63.10(e)(3). [§63.1206(c)(2)(iv)(A)(3)(ii)]

Excessive Exceedance Reporting –

• For each set of ten exceedances of an emission standard or operating requirement while hazardous waste

remains in the combustion chamber (i.e., when the hazardous waste residence time has not transpired since

the hazardous waste feed was cutoff) during a 60-day block period, the permittee must submit to the

Administrator a written report within five calendar days of the 10th exceedance documenting the

exceedances and results of the investigation and corrective measures taken. (§63.1206(c)(3)(vi)(A))

• On a case-by-case basis, the Administrator may require excessive exceedance reporting when fewer than ten

exceedances occur during a 60-day period. (§63.1206(c)(3)(vi)(B))

Permit Condition PW003 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Operating Requirements - Combustion System Leaks - §63.1206(c)(5)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

Combustion system leaks of hazardous air pollutants must be controlled by: (§63.1206(c)(5)(i)

• Keeping the combustion zone sealed to prevent combustion system leaks; or (§63.1206(c)(5)(i)(A))

• Maintaining the maximum combustion zone pressure lower than ambient pressure using an instantaneous

monitor; or (§63.1206(c)(5)(i)(B))

Alternate Standard Provision:

Combustion system leaks of hazardous air pollutants must be controlled by: (§63.1206(c)(5)(i)

• Upon prior written approval of the Administrator, an alternative means of control to provide control of

combustion system leaks equivalent to maintenance of combustion zone pressure lower than ambient

pressure. (§63.1206(c)(5)(i)(C))

• Upon prior written approval of the Administrator , other technique(s) which can be demonstrated to prevent

fugitive emissions without use of instantaneous pressure limits. (§63.1206(c)(5)(i)(D))

Operating Parameters:

• If the permittee complies with the requirements for combustion system leaks under §63.1206(c)(5) by

maintaining the maximum combustion chamber zone pressure lower than ambient pressure to prevent

combustion system leaks from hazardous waste combustion, the permittee must perform instantaneous

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 20

Installation ID Number: 173-0001 Project Number: 173-0001-0001

monitoring of pressure and the automatic waste feed cutoff system must be engaged when negative pressure

is not adequately maintained. (§63.1209(p))

Monitoring:

• The permittee must use continuous monitoring systems (CMS) (e.g., thermocouples, pressure transducers,

and flow meters) to document compliance with the applicable operating parameter limits under this section.

(§63.1209(b)(1))

• Except as specified in §§63.1209(b)(i) and (ii), the permittee must install and operate continuous emission

monitoring systems other than CEMS in conformance with §63.8(c)(3) that requires the permittee, at a

minimum, to comply with the manufacturer’s written specifications or recommendations for installation,

operation and calibration or the system: (§63.1209(b)(2))

(1) CMS must sample the regulated parameter without interruption, and evaluate the detector response at

least once each 15 seconds and compute and record the average values at least every 60 seconds.

(§63.1209(b)(3))

• The span of the non-CEMS CMS detector must not be exceeded. The permittee must interlock the span

limits into the automatic waste feed cutoff system required by §63.1206(c)(3). (§63.1209(b)(4))

(1) Hazardous Waste Feed is Cutoff – Except as provided by §63.1209(b)(5)(iii)(B), the permittee must

continue monitoring operating parameter limits with a CMS when the hazardous waste feed is cutoff if

the source is operating. The permittee must not resume feeding hazardous waste if an operating

parameter exceeds its limit. (§63.1209(b)(5)(iii)(A))\

(2) The permittee is not subject to the CMS requirements during periods of time the permittee meets the

requirements of §63.1206(b)(1)(ii) (compliance with emissions standards for non-hazardous waste

burning sources when the permittee is not burning hazardous waste). (§63.1209(b)(5)(iii)(B))

Record Keeping:

• The permittee must specify in the performance test work plan and Notification of Compliance the method

that will be used to control combustion system leaks. If controls combustion system leaks by maintaining

the combustion zone pressure lower than ambient pressure using an instantaneous monitor, the permittee

must also specify in the performance workplan and Notification of Compliance the monitoring and

recording frequency of the pressure monitor, and specify how the monitoring approach will be integrated

into the automatic waste feed cutoff system. (§63.1206(c)(5)(ii))

• The permittee shall maintain records on-site for the most recent sixty (60) months and shall immediately

make such records available to any Missouri Department of Natural Resources’ personnel upon verbal

request.

Reporting:

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW005.
Continental Cement Company, L.L.C. 21

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW004 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Record Keeping and Reporting Requirements - §63.1211(a)

40 CFR Part 63, Subpart A

General Provisions – Excess Emissions and Continuous Monitoring System Performance Report and

Summary Report - §63.10(e)(3)

Emission Limitation:

• The permittee must submit an excessive emissions and continuous monitoring system performance report

and summary report as required in §63.10(e)(3). (§63.1211(a))

• The permittee of an affected source required to install a CMS by a relevant standard shall submit an excess

emissions and continuous monitoring system performance report and/or a summary report to the

Administrator semiannually, except when: (§63.10(e)(3)(i))

(1) More frequent reporting is specifically required by a relevant standard; (§63.10(e)(3)(i)(A))

(2) The Administrator determines on a case-by-case basis that more frequent reporting is necessary to

accurately assess the compliance status of the source; or (§63.10(e)(3)(i)(B))

(3) The CMS data are to be used directly for compliance determination and the source experienced excess

emissions, in which case quarterly reports shall be submitted. Once a source reports excess emissions,

the source shall follow a quarterly reporting format until a request to reduce reporting frequency under

§63.10(e)(3)(ii) is approved. (§63.10(e)(3)(i)(C))

• The permittee who is required by a relevant standard to submit excess emissions and continuous monitoring

system performance (and summary) reports on a quarterly (or more frequent) basis may reduce the

frequency of reporting for that standard to semiannual if the following conditions are met: (§63.10(e)(3)(ii))

(1) For one full year (e.g., four quarterly or 12 monthly reporting periods) the affected source’s excess

emissions and continuous monitoring system performance reports continually demonstrate that the

source is in compliance with the relevant standard; (§63.10(e)(3)(ii)(A))

(2) The permittee continues to comply with all record keeping and monitoring requirements specified in

this subpart and the relevant standard; (§63.10(e)(3)(ii)(B))

(3) The Administrator does object to a reduced frequency of reporting for the affected source, as provided

in §63.10(e)(3)(iii). (§63.10(e)(3)(ii)(C))

• As soon as CMS data indicate that the source is not in compliance with any emission limitation or operating

parameter specified in the relevant standard, the frequency of reporting shall revert to the frequency

specified in the relevant standard, and the permittee shall submit an excess emissions and continuous

monitoring system performance (a summary) report for the noncomplying emission points at the next

appropriate reporting period following the noncomplying event. After demonstrating ongoing compliance

with the relevant standard for another full year, the permittee may again request approval from the

Administrator to reduce the frequency of reporting for that standard, as provided for in §63.10(e)(3)(ii) and

§63.10(e)(3)(iii). (§63.10(e)(3)(iv))

• All excess emissions and monitoring system performance reports and all summary reports, if required, shall

be delivered or post-marked by the 30th day following the end of each calendar half or quarter, as

appropriate. (§63.10(e)(3)(v))

• If the total duration of excess emissions or process or control system parameter exceedance for the reporting

period is less than 1% of the total operating time for the reporting period, and CMS downtime for the

reporting period is less than 5% of the total operating time for the reporting period, only the summary report

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 22

Installation ID Number: 173-0001 Project Number: 173-0001-0001

shall be submitted and the full excess emissions and continuous monitoring system performance report need

not be submitted unless required by the Administrator. (§63.10(e)(3)(vii))

• If the total duration of excess emissions or process or control system parameter exceedance for the reporting

period is 1% or greater of the total operating time for the reporting period, the total CMS downtime for the

reporting period is 5% or greater of the total operating time for the reporting period, both the summary

report and the excess emissions and continuous monitoring system performance report shall be submitted.

(§63.10(e)(3)(viii))

Monitoring:

None.

Record Keeping:

The permittee shall maintain copies of the excess emissions and continuous monitoring system performance

report and/or summary report. The permittee shall keep a copy of the reports on site at all times. The reports

shall be made available immediately for inspection to the Department of Natural Resources’ personnel upon

request.

Reporting:

• The frequency of reporting of excess emissions and continuous monitoring system performance (and

summary) reports required to comply with a relevant standard may be reduced only after the permittee

notifies the Administrator in writing of his or her intention to make such a change and the Administrator

does not object to the intended change. In deciding whether to approve a reduced frequency of reporting,

the Administrator may review information concerning the source’s entire previous performance history

during the 5 year record keeping period prior to the intended change, including performance test results,

monitoring data and evaluations of permittee’s conformance with operation and maintenance requirements.

Such information may be used by the Administrator to make a judgement about the sources potential for

noncompliance in the future. If the Administrator disapproves the permittee’s request to reduce the

frequency of reporting, the Administrator will notify the permittee in writing within 45 days after receiving

notice of the permittee’s intention. The notification from the Administrator to the permittee will specify the

grounds on which the disapproval is based. In the absence of a notice of disapproval within 45 days,

approval is automatically granted. (§63.10(e)(3)(iii))

• As soon as CMS data indicate that the source is not in compliance with any emission limitation or operating

parameter specified in the relevant standard, the permittee shall submit an excess emissions and continuous

monitoring system performance (an summary) report for the noncomplying emission points at the next

appropriate reporting period following the noncomplying event. (§63.10(e)(3)(iv))

• Written reports of excess emissions or exceedances of process or control system parameters shall include all

the information required in §63.10(c)(5) through (c)(13), in §63.8(c)(7) and §63.8(c)(8), and in the relevant

standard, and they shall contain the name, title, and signature of the responsible official who is certifying the

accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS

has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report.

(§63.10(e)(3)(v))

• As required under §63.10(e)(3)(vii) and (viii), one summary report shall be submitted for the hazardous air

pollutants monitored at each affected source (unless the relevant standard specifies that more than one

summary report is required, e.g., one summary report for each hazardous air pollutant monitored). The

summary report shall be entitled “Summary Report – Gaseous and Opacity Excess Emission and

Continuous Monitoring system Performance” and shall contain the following information:

(§63.10(e)(3)(vi))

(1) The company name and address of the affected source; (§63.10(e)(3)(vi)(A))

(2) An identification of each hazardous air pollutant monitored at the affected source;

(§63.10(e)(3)(vi)(B))

(3) The beginning and ending dates of the reporting period; (§63.10(e)(3)(vi)(C))

(4) A brief description of the process units; (§63.10(e)(3)(vi)(D))
Continental Cement Company, L.L.C. 23

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(5) The emission and operating parameter limitations specified in the relevant standard(s);

(§63.10(e)(3)(vi)(E))

(6) The monitoring equipment manufacturer(s) and model number(s); (§63.10(e)(3)(vi)(F))

(7) The date of the latest CMS certification or audit; (§63.10(e)(3)(vi)(G))

(8) The total operating time of the affected source during the reporting period; (§63.10(e)(3)(vi)(H))

(9) An emission data summary (or similar summary if the permittee monitors control system parameters),

including the total duration of excess emissions during the reporting period (recorded in minutes for

opacity and hours for gases), the total duration of excess emissions expressed ass a percent of the total

source operating time during that reporting period, and a breakdown of the total duration of excess

emissions during the reporting period into those that are due to startup/shutdown, control equipment

problems, process problems, other known causes, and other unknown causes; (§63.10(e)(3)(vi)(I))

(10) A CMS performance summary (or similar summary if the permittee monitors control system

parameter), including the total CMS downtime during the reporting period (recorded in minutes for

opacity and hours for gases), the total duration of CMS downtime, expressed as a percent of the total

source operating time during that reporting period, and a breakdown of the total CMS downtime

during the reporting period into periods that are due to monitoring equipment malfunctions,

nonmonitoring equipment malfunctions, quality assurance/quality control calibrations, other known

causes, and other unknown causes; (§63.10(e)(3)(vi)(J))

(11) A description of any changes in CMS, processes, or controls since the last reporting period;

((§63.10(e)(3)(vi)(K))

(12) The name, title, and signature of the responsible official who is certifying the accuracy of the report;

and (§63.10(e)(3)(vi)(L))

(13) The date of the report. (§63.10(e)(3)(vi)(M))

Permit Condition PW005 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Operating Requirements – Operator Training and Certification - §63.1206(c)(6)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must establish training programs for all categories of personnel whose activities may

reasonably be expected to directly affect emissions of hazardous air pollutants from the source. Such

persons include, but are not limited to chief facility operators, control room operators, continuous

monitoring system operators, persons that sample and analyze feedstreams, persons that manage and charge

feedstreams to the combustor, persons that operate emission control devices, and ash and waste handlers.

Each training program shall be of a technical level commensurate with the person’s job duties specified in

the training manual. Each commensurate training program shall require an examination to be administered

by the instructor at the end of the training course. Passing of this test shall be deemed the “certification” for

personnel, except that for control room operators the training and certification programs shall be as specified

in §63.1206(c)(6)(iii) and (iv). (§63.1206(c)(6)(i))

• The permittee must ensure that the source is operated and maintained at all times by persons who are trained

and certified to perform these and any other duties that may affect emissions of hazardous air pollutants. A

certified control room operator must be on duty at the site at all times the source is in operation.

(§63.1206(c)(6)(ii))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 24

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Cement kiln control room operators must be trained and certified under: (§63.1206(c)(6)(iv))

(1) A site-specific, source-developed and implemented program that meets the requirements of

§63.1206(c)(6)(v); or (§63.1206(c)(6)(iv)(A))

(2) A State program. (§63.1206(c)(6)(iv)(B)) 

• Site-specific, source developed and implemented training programs for control room operators must include

the following elements: (§63.1206(c)(6)(v))

(1) Training on the following subjects: (§63.1206(c)(6)(v)(A))

(a) Environmental concerns, including types of emissions; (§63.1206(c)(6)(v)(A)(1))

(b) Basic combustion principles, including products of combustion; (§63.1206(c)(6)(v)(A)(2))

(c) Operation of the specific type of combustor used by the operator, including proper startup, waste

firing, and shutdown procedures; (§63.1206(c)(6)(v)(A)(3))

(d) Combustion controls and continuous monitoring systems; (§63.1206(c)(6)(v)(A)(4)) 

(e) Operation of air pollution control equipment and factors affecting performance;

(§63.1206(c)(6)(v)(A)(5))

(f) Inspection and maintenance of the combustor, continuous monitoring systems, and air pollution

control devices; (§63.1206(c)(6)(v)(A)(6))

(g) Actions to correct malfunctions or conditions that may lead to malfunction;

(§63.1206(c)(6)(v)(A)(7))

(h) Residue characteristics and handling procedures; and (§63.1206(c)(6)(v)(A)(8))

(i) Applicable Federal, state, and local regulations, including Occupational Safety and Health

Administration workplace standards; and (§63.1206(c)(6)(v)(A)(9))

(2) An examination designed and administered by the instructor; and (§63.1206(c)(6)(v)(B))

(3) Written material covering the training course topics that may serve as reference material following

completion of the course. (§63.1206(c)(6)(v)(C))

• To maintain control room operator qualification under a site- specific, source developed and implemented

training program as provided by §63.1206(c)(6)(v), control room operators must complete an annual review

or refresher course covering, at a minimum, the following topics: (§63.1206(c)(6)(vi))

(1) Update of regulations; (§63.1206(c)(6)(vi)(A))

(2) Combustor operation, including startup and shutdown procedures, waste firing, and residue handling;

(§63.1206(c)(6)(vi)(B))

(3) Inspection and maintenance; (§63.1206(c)(6)(vi)(C))

(4) Responses to malfunctions or conditions that may lead to malfunction; and (§63.1206(c)(6)(vi)(D))

(5) Operating problems encountered by the operator. (§63.1206(c)(6)(vi)(E))

Monitoring:

• The permittee must establish a training and certification program for each person who has responsibilities

affecting operations that may affect emissions of hazardous air pollutants from the source.

(§63.1206(c)(6)(i))

Record Keeping and Reporting:

• The permittee must record the operator training and certification program in the operating record.

(§63.1206(c)(6)(vii))

• The permittee shall maintain training records on-site for the most recent 60 months and shall immediately

make such records available to any Missouri Department of Natural Resources’ personnel upon verbal

request.
Continental Cement Company, L.L.C. 25

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW006 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Operating Requirements – Operation and Maintenance Plan - §63.1206(c)(7)

40 CFR Part 63, Subpart A

General Provisions – Operation and Maintenance Requirements §63.6(e)(1) and (2)

Emission Limitation:

• The permittee must prepare and at all times operate according to an operation and maintenance plan that

describes in detail procedures for operation, inspection, maintenance and corrective measures for all

components of the combustor, including associated pollution control equipment, that could affect emissions

of regulated hazardous air pollutants. (§63.1206(c)(7)(i)(A))

• The plan must prescribe how the permittee will operate and maintain the combustor in a manner consistent

with good air pollution control practices for minimizing emissions at least to the levels achieved during the

comprehensive performance test. (§63.1206(c)(7)(i)(B))

• The plan ensures compliance with the operation and maintenance requirements of §63.6(e) and minimizes

emissions of pollutants, automatic waste feed cutoffs and malfunctions. (§63.1206(c)(7)(i)(C)) 

• Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable

independent of emissions limitations or other requirements in relevant standards. (§63.6(e)(1)(iii))

Monitoring:

• As specified in the operation and maintenance plan.

• At all times, including periods of startup, shutdown, and malfunction, permittee must operate and maintain

any affected source, including associated air pollution control equipment and monitoring equipment, in a

manner consistent with safety and good air pollution control practices for minimizing emissions. During a

period of startup, shutdown, or malfunction, this general duty to minimize emissions requires that the owner

or operator reduce emissions from the affected source to the greatest extent which is consistent with safety

and good air pollution control practices. The general duty to minimize emissions during a period of startup,

shutdown, or malfunction does not require the permittee to achieve emissions levels that would be required

by the applicable standards at other times if this is not consistent with safety and good air pollution

practices, nor does it require the owner or operator to make nay further efforts to reduce emissions if levels

required by the applicable standard have been achieved. Determination of whether such operation and

maintenance procedures are being used will be based on information available to the Administrator which

may include, but is not limited to, monitoring results, review of operation and maintenance procedures

(including the startup, shutdown, and malfunction plan required in §63.6(e)(3)), review of operation and

maintenance records, and inspection of the source. (§63.6(e)(1)(i))

• Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup,

shutdown, and malfunction plan required in §63.6(e)(3). To the extent that an unexpected event arises

during a startup, shutdown, or malfunction, the permittee must comply by minimizing emissions during

such a startup, shutdown, and malfunction event consistent with safety and good air pollution control

practices. (§63.6(e)(1)(ii))

Record Keeping and Reporting:

• The permittee must record the plan in the operating record. (§63.1206(c)(7)(i)(D))

• The permittee shall maintain the records specified in the operation and maintenance plan. The permittee

shall maintain training records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request.

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 26

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW007 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Operating Requirements – Summary of Notification Requirements - §63.1210(a) – Summary of

Reporting Requirements - §63.1211(a)

40 CFR Part 63, Subpart A

General Provisions

Notification, Request, Petition or Application:

Summary of Requirements: (§63.1210(a))

• The permittee must submit the following notifications to the Administrator: (§63.1210(a)(1))

(1) Notification of changes in design, operation and maintenance in §63.1206(b)(5)(i).

(2) Notification that the permittee is subject to special compliance requirements as specified in §63.9(d).

(3) Notification of performance test and continuous monitoring system evaluation, including the

performance test plan and CMS performance evaluation plan (The permittee may also be required on a

case-by-case basis to submit a feedstream analysis plan under §63.1209(c)(3)) as specified in

§63.1207(e), §63.9(e), §63.9(g)(1) and (3).Notification and documentation of any change in

information already provided under §63.9 as specified in §63.9(j);

(4) Notification of compliance, including results of performance tests and continuous monitoring system

performance evaluations as specified in §63.1210(b), §63.1207(j), §63.1207(k), §63.1207(l), §63.9(h),

§63.10(d)(2) and §63.10(e)(2).

• For notifications required to comply with alternative requirements please refer to §63.1210(a)(2). For

record keeping and reporting requirements see §63.1211(b) and §63.1211(a).

Monitoring/Record Keeping:

The permittee must retain the following in the operating record: [§63.1211(b)]

(1) Information required to document and maintain compliance with the regulations of subpart EEE, including

data recorded by continuous monitoring systems (CMS), and copies of all notifications, reports, plans,

and other documents submitted to the Administrator as specified in §63.1200 and §§63.10(b) and (c);

(2) If the permittee elects to comply with all applicable requirements and standards promulgated under

authority of the Clean Air Act, including Sections 112 and 129, in lieu of the requirements of subpart

EEE when not burning hazardous waste, the permittee must document in the operating record that the

permittee is in compliance with those requirements as specified in §63.1206(b)(1)(ii);

(3) Documentation that a change will not adversely affect compliance with the emission standards or

operating requirements as specified in §63.1206(b)(5)(ii); 

(4) Calculation of hazardous waste residence time as specified in §63.1206(b)(11);

(5) Startup, shutdown, and malfunction plan as specified in §63.1206(c)(2);

(6) Documentation of the permittee’s investigation and evaluation of excessive exceedances during

malfunctions as specified in §63.1206(c)(2)(v)(A);

(7) Corrective measures for any automatic waste feed cutoff that results in an exceedance of an emission

standard or operating parameter limit as specified in §63.1206(c)(3)(v);

(8) Documentation and results of the automatic waste feed cutoff operability testing as specified in

§63.1206(c)(3)(vii);

(9) Method used for control of combustion system leaks as specified in §63.1206(c)(5)(ii);

(10) Operator training and certification program as specified in §63.1206(c)(6);

(11) Operation and maintenance plan as specified in §63.1206(c)(7)(i)(D);

(12) Feedstream analysis plan as specified in §63.1209(c)(2); 

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 27

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(13) Documentation of changes in modes of operation as specified in §63.1209(q);

(14) Documentation of compliance as specified in §63.1211(c).

The permittee shall maintain all records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request.

Reporting

• The permittee must submit the following reports to the Administrator: [§63.1211(a)]

(1) Compliance progress reports, if required as a condition of an extension of the compliance date granted

under §63.6(i) as specified in §63.10(d)(4);

(2) Periodic startup, shutdown, and malfunction reports as specified in §63.10(d)(5)(i); 

(3) Immediate startup, shutdown, and malfunction reports as specified in §63.10(d)(5)(ii); 

(4) Excessive emissions and continuous monitoring system performance report and summary report as

specified in §63.10(e)(3);Startup, shutdown, and malfunction plan as specified in

§63.1206(c)(2)(ii)(B); 

(5) Excessive exceedances reports as specified in §63.1206(c)(3)(vi); 

Permit Condition PW008 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Documentation of Compliance - §63.1211(c)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• By the compliance date, the permittee must develop and include in the operating record a Documentation of

Compliance. (§63.1211(c)(1))

• The permittee must comply with the emission standards and operating parameter limits specified in the

Documentation of Compliance. (§63.1211(c)(4))

Monitoring:

None.

Record Keeping:

The permittee shall include in the operating record, the Documentation of Compliance. (§63.1211(c)(1))

Reporting:

Documentation of Compliance

• The Documentation of Compliance must identify the applicable emission standards under this subpart and

the limits on the operating parameters under §63.1209 that will ensure compliance with those emission

standards. (§63.1211(c)(2))

• The permittee must include a signed and dated certification in the Documentation of Compliance that:

(§63.1211(c)(3))

(1) Required CEMs and CMS are installed, calibrated and continuously operating in compliance with the

requirements of this subpart; and (§63.1211(c)(3)(i))

(2) Based on an engineering evaluation prepared under the permittee’s direction or supervision in

accordance with a system designed to ensure that qualified personnel properly gathered and evaluated

the information and supporting documentation and considering at a minimum the design, operation

and maintenance characteristics of the combustor and emissions control equipment, the types,

quantities, and characteristics of feedstreams and available emissions data: (§63.1211(c)(3)(ii))

(a) The permittee is in compliance with the emission standards of this subpart; and

(§63.1211(c)(3)(ii)(A))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 28

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(b) The limits on the operating parameters under §63.1209 ensure compliance with the emission

standards of this subpart. (§63.1211(c)(3)(ii)(B))

Permit Condition PW009 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors – Data

Compression - §63.1211(d)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

The permittee may submit a written request to the Administrator for approval to use data compression

techniques to record data from CMS, including CEMS, on a frequency less than that required by §63.1209. The

permittee must submit the request for review and approval as part of the comprehensive performance test plan.

(§63.1211(d))

Monitoring:

Data Compression:

• The permittee must record a data value at least once each ten minutes. (§63.1211(d)(1))

• For each CEMS or operating parameter for which the permittee request to use data compression techniques,

the permittee must recommend: (§63.1211(d)(2))

(1) A fluctuation limit that defines the maximum permissible deviation of a new data value from a

previously generated value without requiring the permittee to revert to recording each one-minute

value. (§63.1211(d)(2)(i))

(a) If the permittee exceeds a fluctuation limit, the permittee must record each one-minute value for

a period of time not less than ten minutes. (§63.1211(d)(2)(i)(A))

(b) If neither the fluctuation limit nor the data compression limit are exceeded during that period of

time, the permittee may reinitiate recording data values on a frequency of at least once each ten

minutes; and (§63.1211(d)(2)(i)(B))

(2) A data compression limit defined as the closest level to an operating parameter limit or emission

standard at which reduced data recording is allowed. (§63.1211(d)(2)(ii))

(a) Within this level and the operating parameter limit or emission standard, the permittee must

record each one-minute average. (§63.1211(d)(2)(ii)(A))

(b) The data compression limit should reflect a level at which the permittee is unlikely to exceed the

specific operating parameter limit or emission standard, considering its averaging period, with

the addition of a new one-minute average. (§63.1211(d)(2)(ii)(B))

Record Keeping:

As required by the data compression techniques.

Reporting:

The permittee may submit a written request to the Administrator for approval to use data compression

techniques to record data from CMS, including CEMS, on a frequency less than that required by §63.1209. The

permittee must submit the request for review and approval as part of the comprehensive performance test plan.

(§63.1211(d))
Continental Cement Company, L.L.C. 29

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW010 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors – 

Performance Testing Requirements §63.1207

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The provisions of §63.7 apply, except as noted below: (§63.1207(a))

• Comprehensive Performance Test – The permittee must conduct comprehensive performance tests to

demonstrate compliance with the emission standards provided by §63.1203, §63.1204, and §63.1205,

establish limits for the operating parameters provided by §63.1209, and demonstrate compliance with the

performance specifications for continuous monitoring systems. (§63.1207(b)(1))

• Initial Comprehensive Performance Test Date – Except as provided by §63.1207(c)(2), the permittee must

commence the initial comprehensive performance test no later than six months after the compliance date.

(§63.1207(c)(1))

• Data in lieu of the initial comprehensive performance test. (§63.1207) (c)(2))

(1) The permittee may request that previous emissions test data serve as documentation of conformance

with the emission standards of this subpart provided that the previous testing was:

(a) Initiated after 54 months prior to the compliance date, except as provided by paragraph (c)(2)(iii)

or (c)(2)(iv) of this section

(b) Results in data that meet the quality assurance objectives (determined on a site specific basis)

such that the results demonstrate compliance with the applicable standards.

(c) Was in conformance with the requirements of paragraph (g)(1) of this section; and,

(d) Was sufficient to establish the applicable operating parameter limits under § 63.1209.

(2) The permittee must submit data in lieu of the initial comprehensive performance test in lieu of (i.e., if

the data are in lieu of all performance testing) or with the notification of performance test required

under paragraph (e) of this section.

(3) The data in lieu of test age restriction provided in paragraph (c)(2)(i)(A) of this section does not apply

for the duration of the interim standards (i.e., the standards published in the Federal Register on

February 13, 2002. Paragraph (c)(2)(i)(A) of this section does not apply until EPA promulgates

permanent replacement standards pursuant to the Settlement Agreement noticed in the Federal

Register on November 16, 2001.

(4) The data in lieu test age restriction provided in paragraph (c)(2)(i)(A) of this section does not apply to

DRE data provided the permittee does not feed hazardous waste at a location in the combustion system

other than the normal flame zone.

• Frequency of Testing – Except as otherwise specified in §63.1207(d)(4), the permittee must conduct testing

periodically as prescribed below. The date of commencement of the initial comprehensive performance test

is the basis for establishing the deadline to commence the initial confirmatory performance test and the next

comprehensive performance test. The permittee may conduct performance testing at any time prior to the

required date. The deadline for commencing subsequent confirmatory and comprehensive performance

testing is based on the date of commencement of the previous comprehensive performance test. Unless the

Administrator grants a time extension under §63.1207(i), the testing must be conducted as follows:

(§63.1207(d))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 30

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(1) Comprehensive Performance Testing – Except as otherwise specified in §63.1207(d)(4), the permittee

must commence testing no later than 61 months after the date of commencing the previous

comprehensive performance test. If the permittee submits data in lieu of the initial performance test,

the permittee must commence the subsequent comprehensive performance test within 61 months of the

date six months after the compliance date. (§63.1207(d)(1))

(2) Confirmatory performance testing. Except as otherwise specified in paragraph (d)(4) of this section,

the permittee must commence confirmatory performance testing no later than 31 months after the date

of commencing the previous comprehensive performance test. If the permittee submits data in lieu of

the initial performance test, the permittee must commence the initial confirmatory performance test

within 31 months of the date six months after the compliance date. To ensure that the confirmatory

test is conducted approximately midway between comprehensive performance test, the Administrator

will not approve a test plan that schedules testing within 18 months of commencing the previous

comprehensive performance test.

(3) Duration of Testing – The permittee must complete performance testing within 60 days after the date

of commencement, unless the Administrator determines that a time extension is warranted based on

the documentation in writing of factors beyond the permittee’s control that prevent the permittee from

meeting the 60-day deadline. (§63.1207(d)(3))

(4) Applicable testing requirements under the interim standards. 

(a) Waiver of periodic comprehensive performance tests. Except as provided by paragraph (c)(2) of

this section, the permittee must conduct only an initial comprehensive performance test under the

interim standards (i.e., the standards published in the Federal Register on February 13, 2002; all

subsequent comprehensive performance testing requirements are waived under the interim

standards. The provisions in the introductory text to paragraph (d) and n paragraph (d)(1) of this

section do not apply until EPA promulgates permanent replacement standard pursuant to the

Settlement Agreement noticed in the Federal Register on November 16, 2001.

(b) Waiver of confirmatory performance tests. The permittee is not required to conduct a

confirmatory test under the interim standards (i.e., the standards published in the Federal

Register on February 13, 2002. The confirmatory testing requirements in the introductory text to

paragraph (d) and in paragraph (d)(2) of this section are waived until EPA promulgates

permanent replacement standard pursuant to the Settlement Agreement noticed in the Federal

Register on November 16, 2001.

• Failure to submit a timely notification of compliance. (§63.1207(k))

(1) If the permittee fails to postmark a Notification of Compliance by the specified date, the permittee

must cease hazardous waste burning immediately. (§63.1207(k)(1))

(2) Prior to submitting a revised Notification of Compliance as provided by §63.1207(k)(3), the permittee

may burn hazardous waste only for the purpose of pretesting or comprehensive performance testing

and only for a maximum of 720 hours (renewable at the discretion of the Administrator).

(§63.1207(k)(2))

(3) The permittee must submit to the Administrator a Notification of Compliance subsequent to a new

comprehensive performance test before resuming hazardous waste burning. (§63.1207(k)(3))

• §63.1209(j) through (p) require the permittee to establish limits on operating parameters based on

comprehensive performance testing to ensure the permittee maintains compliance with the emission

standards of this subpart. For several parameters, the permittee must establish a limit for the parameter to

ensure compliance with more than one emission standard. An example is a limit on minimum combustion

chamber temperature to ensure compliance with both the DRE standards of §63.1209(j) and the dioxin/furan

standard of §63.1209(k). If the performance tests for such standards are not performed simultaneously, the

most stringent limit for a parameter derived from independent performance tests applies. (§63.1209(i))
Continental Cement Company, L.L.C. 31

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Notification of Compliance

• The Notification of Compliance status requirements of §63.9(h) apply, except that: (§63.1210(b)(1))

(1) The notification is a Notification of Compliance, rather than compliance status: (§63.1210(c)(1)(i))

(2) The notification is required for the initial comprehensive performance test and each subsequent

comprehensive and confirmatory performance test; and (§63.1210(b)(1)(ii))

(3) The permittee must postmark the notification before the close of business on the 90th day following

completion of relevant compliance demonstration activity specified in this subpart rather than the 60th

day as required by §63.9(h)(2)(ii). (§63.1210(b)(1)(iii))

• Upon postmark of the Notification of Compliance, the operating parameter limits identified in the

Notification of Compliance, as applicable, shall be complied with, the limits identified in the

Documentation of Compliance or a previous Notification of Compliance are no longer applicable.

(§63.1210(c)(2))

• The Notification of Compliance requirements of §63.1207(j) also apply. (§63.1210(c)(3))

Test Plan:

• Content of Performance Test Plan - The provisions of §63.7(c)(2)(i)-(iii) and (v) regarding the content of the

test plan apply. In addition, the permittee must include the following information in the test plan:

(§63.1207(f))

Comprehensive Performance Test Plan: 

• An analysis of each feedstream, including hazardous waste, other fuels, and industrial furnace feedstocks, as

fired, that includes: (§63.1207(f)(1)(i))

(1) Heating value, levels of semivolatile metals, low volatile metals, mercury and total chlorine (organic

and inorganic); and (§63.1207(f)(1)(i)(A))

(2) Viscosity or description of the physical form of the feedstream; (§63.1207(f)(1)(i)(B))

• For organic hazardous air pollutants established by 42 U.S.C. 7412(b)(1), excluding caprolactam (CAS

number 105602) as provided by §63.60: (§63.1207(f)(1)(ii))

(1) Except as provided by paragraph f(1)(ii)(o), an identification of such organic hazardous air pollutants

that are present in each hazardous waste feedstream. The permittee need not analyze for organic

hazardous air pollutants that would reasonably not be expected to be found in the feedstream. The

permittee must identify any constituents the permittee excludes from analysis and explain the basis for

excluding them. The permittee must conduct the feedstream analysis according to §63.1208(b)(8).;

(§63.1207(f)(1)(ii)(A))

(a) The permittee may use any reliable analytical method to determine feedstream concentrations of

metals, chlorine and other constituents. It is the permittee’s responsibility to ensure that the

sampling and analysis procedures are unbiased, precise and that the results are representative of

the feedstream. (§63.1208(b)(8))

(2) An approximate quantification of such identified organic hazardous air pollutants in the feedstreams,

within the precision produced by the analytical procedures of §63.1208(b)(8); and

(§63.1207(f)(1)(ii)(B))

(a) The permittee must demonstrate that: (§63.1208(b)(8))

(i). Each analyte is not present above the reported level at the 80% upper confidence limit

around the mean; and (§63.1208(b)(8)(i))

(ii). The analysis could have detected the presence of the constituent at or below the reported

level at the 80% upper confidence limit around the mean (See Guidance for Data Quality

Assessment – Practical Methods for Data Analysis, EPA QA/G-9, January 1998,

EPA/600/R-96/084). (§63.1208(b)(8)(ii))

(3) A description of blending procedures, if applicable, prior to firing the hazardous waste feedstream,

including a detailed analysis of the materials prior to blending and blending ratios;

(§63.1207(f)(1)(ii)(C))
Continental Cement Company, L.L.C. 32

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(4) The Administrator may approve on a case-by-case basis a hazardous waste feedstream analysis for

organic hazardous air pollutants in lieu of the analysis required under §63.1207(f)(1)(ii)(A) if the

reduced analysis is sufficient to ensure that the POHCs used to demonstrate compliance with the

applicable DRE standard of §63.1203, §63.1204, or §63.1205, continue to be representative of the

organic hazardous air pollutants in the permittee’s hazardous waste feedstreams;

(§63.1207(f)(1)(ii)(D))

• A detailed engineering description of the hazardous waste combustor, including: (§63.1207(f)(1)(iii))

(1) Manufacturer’s name and model number of the hazardous waste combustor; (§63.1207(f)(1)(iii)(A))

(2) Type of hazardous waste combustor; (§63.1207(f)(1)(iii)(B))

(3) Maximum design capacity in appropriate units; (§63.1207(f)(1)(iii)(C))

(4) Description of the feed system for each feedstream; (§63.1207(f)(1)(iii)(D))

(5) Capacity of each feed system; (§63.1207(f)(1)(iii)(E))

(6) Description of automatic hazardous waste feed cutoff system(s); (§63.1207(f)(1)(iii)(F))

(7) Description of the design, operation and maintenance practices for any air pollution control system;

and (§63.1207(f)(1)(iii)(G))

(8) Description of the design, operation, and maintenance practices of any stack gas monitoring and

pollution control monitoring systems; (§63.1207(f)(1)(iii)(H))

• A detailed description of sampling and monitoring procedure including sampling and monitoring locations

in the system, the equipment to be used, sampling and monitoring frequency, and planned analytical

procedures for sample analysis; (§63.1207(f)(1)(iv))

• A detailed test schedule for each hazardous waste for which the performance test is planned, including

date(s), duration, quantity of hazardous waste to be burned, and other relevant factors; (§63.1207(f)(1)(v))

• A detailed test protocol, including, for each hazardous waste identified, the ranges of hazardous waste

feedrate for each feed system, and, as appropriate, the feedrates of other fuels and feedstocks, and any other

relevant parameters that may affect the ability of the hazardous waste combustor to meet the emission

standards; (§63.1207(f)(1)(vi))

• A description of, and planned operating conditions for, any emission control equipment that will be used;

(§63.1207(f)(1)(vii))

• Procedures for rapidly stopping the hazardous waste feed and controlling emissions in the event of an

equipment malfunction; (§63.1207(f)(1)(viii))

• A determination of the hazardous waste residence time as required by §63.1206(b)(11); (§63.1207(f)(1)(ix))

• If the permittee is requesting to extrapolate metal feedrate limits from comprehensive performance test

levels under §§63.1209(l)(1)(i) or 63.1209(n)(2)(ii)(A): (§63.1207(f)(1)(x))

(1) A description of the extrapolation methodology and rationale for how the approach ensures

compliance with the emission standards; (§63.1207(f)(1)(x)(A))

(2) Documentation of the historical range of normal (i.e., other than during compliance testing) metals

feedrates for each feedstream; (§63.1207(f)(1)(x)(B))

(3) Documentation that the level of spiking recommended during the performance test will mask sampling

and analysis imprecision and inaccuracy to the extent that the extrapolated feedrate limits adequately

assure compliance with the emission standards.

• If the permittee does not continuously monitor regulated constituents in natural gas, process air feedstreams,

and feedstreams from vapor recovery systems under §63.1209(c)(5), the permittee must include

documentation of the expected levels of regulated constituents in those feedstreams; (§63.1207(f)(1)(xi))

• Documentation justifying the duration of system conditioning required to ensure the combustor has

achieved steady-state operations under performance test operating conditions, as provided by

§63.1207(g)(1)(iii); and (§63.1207(f)(1)(xii))

• If the permittee is not required to conduct performance testing to document compliance with the mercury,

semivolatile metal, low volatile metal or hydrochloric acid/chlorine gas emission standards under
Continental Cement Company, L.L.C. 33

Installation ID Number: 173-0001 Project Number: 173-0001-0001

§63.1207(m), the permittee must include with the comprehensive performance test plan documentation of

compliance with the provisions of §63.1207(m). (§63.1207(f)(xvi))

• If the permittee proposes to use a surrogate for measuring or monitoring gas flowrate, the permittee must

document in the comprehensive performance test plan that the surrogate adequately correlates with gas

flowrate, as required by §63.1207(m)(7) and §63.1209(j)(2), (k)(3), (m)(2)(i), (m)(5)(i) and (o)(2)(i).

(§63.1207(f)(1)(xvii))

• The permittee must submit an application to request alternative monitoring under §63.1209(g)(1) not later

than with the comprehensive performance test plan, as required by §63.1209(g)(1)(iii)(A).

(§63.1207(f)(1)(xviii))

• The permittee must document the temperature location measurement in the comprehensive performance test

plan, as required by §§63.1209(j)(1)(i) and 63.1209(k)(2)(i). (§63.1207(f)(1)(xix))

• For purposes of calculating semivolatile metal, low volatile metal, mercury, and total chlorine (organic and

inorganic), and ash feedrate limits, a description of how the permittee will handle performance test

feedstream analytical results that determines these constituents are not present at detectable levels.

(§63.1207(f)(1)(xxvi))

• If the permittee is not required to conduct performance testing to document compliance with the mercury,

semivolatile metal, low volatile metal, or hydrochloric acid/chlorine gas emission standard under

§63.1207(m), the permittee must include with the comprehensive performance test documentation of

compliance with the provisions of that section. (§63.1207(f)(1)(xxvii))

Monitoring:

• The permittee must calculate the hazardous waste residence time and include the calculation in the

performance test plan under §63.1207(f) and the operating record. The permittee must also provide the

hazardous waste residence time in the Documentation of Compliance under §63.1211(d) and the

Notification of Compliance under §§63.1207(j) and 63.1210(d). (§63.1206(b)(11))

• The permittee must conduct a minimum of three runs of a performance test required under §63.1207 to

document compliance with the emission standards of this subpart. (§63.1206(b)(12)(i))

• The permittee must document compliance with the emission standards based on the arithmetic average of

the emission results of each run, except that the permittee must document compliance with the destruction

and removal efficiency standard for each run of the comprehensive performance test individually.

(§63.1206(b)(12)(ii))

• Changes in design, operation or maintenance that may adversely affect compliance with any emission

standard not monitored with a CEM – The permittee must conduct a comprehensive performance test under

the requirements of §§63.1207(f)(1) and (g)(1) to document compliance with the affected emission

standard(s) and establish operating parameter limits are required under §63.1209, and submit to the

Administrator a Notification of Compliance under §§63.1207(j) and 63.1210(d); and (§63.1206(b)(5)(i)(B))

• The permittee must comply with the provisions of §63.7(e). Conducting performance testing under

operating conditions representative of the extreme range of normal conditions is consistent with the

requirements of §63.7(e)(1) to conduct performance testing under representative operating conditions.

(§63.1207(g))

Comprehensive Performance Testing:

• Operations During Testing – For the following parameters, the permittee must operate the combustor during

the performance test under normal conditions (or conditions that will result in higher than normal

emissions): (§63.1207(g)(1)(i))

(1) The permittee must feed normal (or higher) levels of chlorine during the dioxin/furan performance

test; (§63.1207(g)(1)(i)(A))

(2) The permittee must conduct the following tests when the particulate matter control device undergoes

its normal (or more frequent) cleaning cycle; the particulate matter, semivolatile metal, and low

volatile metal performance tests.
Continental Cement Company, L.L.C. 34

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Given that the permittee must establish limits for the applicable operating parameters specified in §63.1209

based on operations during the comprehensive performance test, the permittee may conduct testing under

two or more operating modes to provide operating flexibility. (§63.1207(g)(1)(ii))

• Prior to obtaining performance test data, the permittee must operate under performance test conditions until

the permittee reaches steady-state operations with respect to emissions of pollutants, the permittee must

measure during the performance test and operating parameters under §63.1209 for which the permittee must

establish limits. During system conditioning, the permittee must ensure that each operating parameter for

which the permittee must establish a limit is held at the level planned for the performance test. The

permittee must include documentation in the performance test plan under §63.1207(f) justifying the duration

of system conditioning. (§63.1207(g)(1)(iii)(A)

• If the permittee operates a hazardous waste cement kiln that recycles collected particulate matter (i.e.,

cement kiln dust) into the kiln – The permittee must sample and analyze the recycled particulate matter prior

to obtaining performance test data for levels of selected metals that must be measured during performance

testing to document that the system has reached steady-state conditions (i.e., that metal levels have

stabilized). The permittee must document the rationale for selecting metals that are indicative of system

equilibrium and include the information in the performance test plan under §63.1207(f). To determine

system equilibrium, the permittee must sample and analyze the recycled particulate matter hourly for each

selected metal, unless the permittee submits in the performance test plan a justification for reduced sampling

and analysis and the Administrator approves in writing a reduced sampling and analysis frequency.

(§63.1207(g)(1)(iii)(B)

Subsequent Testing:

• Current operating parameter limits established under §63.1209 are waived during subsequent

comprehensive performance testing. (§63.1207(h)(1))

• Current operating parameter limits are also waived during pretesting prior to comprehensive performance

testing for an aggregate time not to exceed 720 hours of operation (renewable at the discretion of the

Administrator), Under an approved test plan or if the source records the results of pretesting. Pretesting

means: (§63.1207(h)(2))

(1) Operations when stack emissions testing for dioxin/furan, mercury, semivolatile metals, low volatile

metals, particulate matter, or hydrochloric acid/chlorine gas is being performed; and

(§63.1207(h)(2)(i))

(2) Operations to reach steady-state operating conditions prior to stack emissions testing under

§63.1207(g)(1)(iii). (§63.1207(h)(2)(ii))

Failure of Performance Test: The provisions of this paragraph do not apply to the initial comprehensive

performance test if the permittee conducts the test prior to September 30, 2003 (or later compliance date

approved under §63.6(i)).

• If the permittee determines (based on CEM recordings, results of analyses of stack samples, or results of

CMS performance evaluations) that the permittee has exceeded any emission standard during a

comprehensive performance test for a mode of operation, the permittee must cease hazardous waste burning

immediately under that mode of operation. The permittee must make this determination within 90 days

following completion of the performance test. (§63.1207(l)(1)(i))

• If the permittee has failed to demonstrate compliance with the emission standards for any mode of

operation: (§63.1207(l)(1)(ii))

(1) Prior to submitting a revised Notification of Compliance as provided by §63.1207(l)(1)(ii)(C), the

permittee may burn hazardous waste only for the purpose of pretesting or comprehensive performance

testing under revised operating conditions, and only for a maximum of 720 hours (renewable at the

discretion of the Administrator), except as provided by §63.1207(l)(3); (§63.1207(l)(1)(ii)(A))

(2) The permittee must conduct a comprehensive performance test under revised operating conditions

following the requirements for performance testing of this section; and (§63.1207(l)(1)(ii)(B))
Continental Cement Company, L.L.C. 35

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(3) The permittee must submit to the Administrator a Notification of Compliance subsequent to the new

comprehensive performance test. (§63.1207(l)(1)(ii)(C))

• The permittee may petition the Administrator to obtain written approval to burn hazardous waste in the

interim prior to submitting a Notification of Compliance for purposes other than testing or pretesting. The

permittee must specify operating requirements, including limits on operating parameters, that the permittee

determines will ensure compliance with the emission standards of this subpart based on available

information including data from the failed performance test. The Administrator will review, modify as

necessary, and approve if warranted the interim operating requirements. An approval of interim operating

requirements will include a schedule for submitting a Notification of Compliance. (§63.1207(l)(3))

Record Keeping:

• The permittee shall maintain a copy of the following in the operating record:

(1) Intent to conduct a comprehensive performance test;

(2) Site-specific test plan;

(3) CMS performance evaluation plan;

(4) Public notice for the approved test and CMS performance evaluation plans;

(5) Comprehensive performance test plan results;

(6) Extension requests for performance testing;

(7) Approval/denial for the extension requests for performance testing;

(8) Notification of Compliance; 

(9) Extension request for the Notification of Compliance; and

(10) Approval/denial for the extension request for Notification of compliance.

• The permittee shall maintain records on-site for the most recent sixty (60) months and shall immediately

make such records available to any Missouri Department of Natural Resources’ personnel upon verbal

request.

Reporting:

• Notification of performance test and CMS performance evaluation, and approval of test plan and CMS

performance evaluation plan. [§63.1207(e)]

• The provisions of §63.7(b) and (c) and §63.8(e) apply, except: (§63.1207(e)(1))

• Comprehensive Performance Test – The permittee must submit to the Administrator a notification of intent

to conduct a comprehensive performance test and CMS performance evaluation and a site-specific test plan

and CMS performance evaluation plan at least one year before the performance test and performance

evaluation are scheduled to begin. (§63.1207(e)(1)(i)

(1) The Administrator will notify the permittee of approval or intent to deny approval of the test plan and

CMS performance test evaluation plan within nine months after receipt of the original plan.

(§63.1207(e)(1)(i)(A))

(2) The permittee must submit to the Administrator a notification of the permittee’s intention to conduct

the comprehensive performance test at least 60 calendar days before the test is scheduled to begin.

(§63.1207(e)(1)(i)(B))

• After the Administrator has approved the test and CMS performance evaluation plans, the permittee must

make the plans available to the public for review. The permittee must issue a public notice announcing the

approval of the plans and the location where the plans are available for review. (§63.1207(e)(2))

• Petitions for time extension if Administrator fails to approve or deny test plans. You may petition the

Administrator under §63. 7(h) to obtain a “waiver” of any performance test-initial or periodic performance

test; comprehensive or confirmatory test. The “waiver” would be implemented as an extension of time to

conduct the performance test at a later date. (§63.1207(e)(3))

• Qualifications for the waiver. (§63.1207(e)(1)(ii)(3)(i))

(1) You may not petition the Administrator for a waiver under this section if the Administrator has issued a

notification of intent to deny the permittee’s test plan(s) under (§63.7(c)(3)(i)(B));

(§63.1207(e)(1)(ii)(3)(i)(A))
Continental Cement Company, L.L.C. 36

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(2) You must submit a site-specific emissions testing plan and a continuous monitoring system performance

evaluation test plan at least one year before a comprehensive performance test is scheduled to begin as

required by (§63.1207(c)(1)), or at least 60 days before a confirmatory performance test is scheduled to

begin as required by paragraph (d) of this section. The test plans must include all required

documentation, including the substantive content requirements of paragraph (f) of this section and §63.

8(e); and (§63.1207(e)(1)(ii)(3)(i)(B))

(3) You must make a good faith effort to accommodate the Administrator’s comments on the test plans.

(§63.1207(e)(1)(ii)(3)(i)(C))

• Procedures for obtaining a waiver and duration of the waiver: (§63.1207(e)(1)(ii)(3)(ii))

(1) You must submit to the Administrator a waiver petition or request to renew the petition under §63.7(h)

separately for each source at least 60 days prior to the scheduled date of the performance test;

(§63.1207(e)(1)(ii)(3)(ii)(A))

(2) The Administrator will approve or deny the petition within 30 days of receipt and notify you promptly

of the decision; (§63.1207(e)(1)(ii)(3)(ii)(B))

(3) The Administrator will not approve an individual waiver petition for a duration exceeding 6 months;

(§63.1207(e)(1)(ii)(3)(ii)(C))

(4) The Administrator will include a sunset provision in the waiver ending the waiver within 6 months;

(§63.1207(e)(1)(ii)(3)(ii)(D))

(5) You may submit a revised petition to renew the waiver under §63.7(h)(3)(iii) at least 60 days prior to

the end date of the most recently approved waiver petition; (§63.1207(e)(1)(ii)(3)(ii)(E))

(6) The Administrator may approve a revised petition for a total waiver period up to 12 months

(§63.1207(e)(1)(ii)(3)(ii)(F)). 

• Content of the waiver. (§63.1207(e)(1)(ii)(3)(iii))

(1) You must provide documentation to enable the Administrator to determine that the source is meeting

the relevant standard(s) on a continuous basis as required by §63.7(h)(2). For extension requests for

the initial comprehensive performance test, you must submit your Documentation of Compliance to

assist the Administrator in making this determination. (§63.1207(e)(1)(ii)(3)(iii)(A))

(2) You must include in the petition information justifying your request for a waiver, such as the

technical or economic infeasibility, or the impracticality, of the affected source performing the

required test, as required by §63.7(h)(3)(iii). (§63.1207(e)(1)(ii)(3)(iii)(B))

• Public notice. You must notify the public (e.g., distribute public mailing list) of your petition to waive a

performance test. (§63.1207(e)(1)(ii)(3)(iv)).

• After the initial comprehensive performance test, the permittee may request up to a one-year time extension

for conducting a comprehensive or confirmatory performance test to consolidate performance testing with

other state or federally required emission testing, or for other reasons deemed acceptable by the

Administrator. If the Administrator grants a time extension for a comprehensive performance test, the

deadlines for commencing the next comprehensive and confirmatory tests are based on the date that the

subject comprehensive performance test commences. (§63.1207(i))

(1) The permittee must submit in writing to the Administrator any request under §63.1207(i) for a time

extension for conducting a performance test. (§63.1207(i)(1))

(2) The permittee must include in the request for an extension for conducting a performance test the

following: (§63.1207(i)(2))

(i) A description of the reasons for requesting the time extension; (§63.1207(i)(2)(i))

(ii) The date by which the permittee will commence performance testing. (§63.1207(i)(2)(ii))

(3) The Administrator will notify the permittee in writing of approval or intention to deny approval of the

permittee’s request for an extension for conducting a performance test within 30 calendar days after

receipt of sufficient information to evaluate the permittee’s request. The 30-day approval or denial

period will begin after the permittee has been notified in writing that the permittee’s application is

complete. The Administrator will notify the permittee in writing whether the application contains
Continental Cement Company, L.L.C. 37

Installation ID Number: 173-0001 Project Number: 173-0001-0001

sufficient information to make a determination within 30 calendar days after receipt of the original

application and within 30 calendar days after receipt of any supplementary information that the

permittee submits. (§63.1207(i)(3))

(4) When notifying the permittee that the application is not complete, the Administrator will specify the

information needed to complete the application. The Administrator will also provide notice of

opportunity for the permittee to present, in writing, within 30 calendar days after notification of the

incomplete application, additional information or arguments to the Administrator to enable further

action on the application. (§63.1207(i)(4))

(5) Before denying any request for an extension for performance testing, the Administrator will notify the

permittee in writing of the Administrator’s intention to issue the denial, together with: (§63.1207(i)(5))

(i) Notice of information and findings on which the intended denial is base; and (§63.1207(i)(5)(i))

(ii) Notice of opportunity for the permittee to present in writing, within 15 calendar days after

notification of the intended denial, additional information or arguments to the Administrator

before further action on the request. (§63.1207(i)(5)(ii))

(6) The Administrator’s final determination to deny any request for an extension will be in writing and

will set forth specific grounds upon which the denial is based. The final determination will be made

within 30 calendar days after the presentation of additional information or argument (if the application

is complete), or within 30 days after the final date specified for the presentation if no presentation is

made. (§63.1207(i)(6))

• Notification of Compliance – Comprehensive Performance Test – Except as provided by paragraphs (j)(4)

and (j)(5) of this section, within 90 days of completion of a comprehensive performance test, the permittee

must postmark a Notification of Compliance documenting compliance or noncompliance with the emission

standards and continuous monitoring system requirements and identifying operating parameter limits under

§63.1209. (§63.1207(j)(1)(i))

• Notification of Compliance – Comprehensive Performance Test - Upon postmark of the Notification of

Compliance, the permittee must comply with all operating requirements specified in the Notification of

Compliance in lieu of the limits specified in the Documentation of Compliance required under §63.1211(c).

(§63.1207(j)(1)(ii))

• See §§63.7(g), 63.9(h) and 63.1210(b) for additional requirements pertaining to the Notification of

Compliance (e.g., the permittee must include results of performance tests in the Notification of

Compliance). (§63.1207(j)(3))

• Time extension – The permittee may submit a written request to the Administrator for a time extension

documenting that, for reasons beyond the permittee’s control, the permittee may not be able to meet the 90-

day deadline for submitting the Notification of Compliance after completion of testing. The Administrator

will determine whether a time extension is warranted. (§63.1207(j)(4))

• Early compliance – If you conduct the initial comprehensive performance test prior to the compliance date,

you must postmark the Notification of Compliance within 90 days of completion of the performance test or

by the compliance date, whichever is later. (§63.1207(j)(5)).

• Failure to Submit Timely Notification of Compliance – The permittee must submit to the Administrator a

Notification of compliance subsequent to a new comprehensive performance test before resuming hazardous

waste burning. (§63.1207(k)(3))
Continental Cement Company, L.L.C. 38

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW011 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Waiver of Performance Test §63.1207

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The waiver provision of §63.1207(m) applies in addition to the provisions of §63.7(h). (§63.1207(m)(1))

• The permittee is not required to conduct performance tests to document compliance with the mercury,

semivolatile metal, low volatile metal or hydrochloric acid/chlorine gas emission standards under the

conditions specified below. The permittee is deemed to be in compliance with an emission standard if the

twelve-hour rolling average maximum theoretical emission concentration (MTEC) determined as specified

below does not exceed the emission standard: (§63.1207(m)(2))

(1) Determine the feedrate of mercury, semivolatile metals, low volatile metals, or total chlorine and

chloride from all feedstreams; (§63.1207(m)(2)(i))

(2) Determine the stack gas flowrate; and (§63.1207(m)(2)(ii))

(3) Calculate a MTEC for each standard assuming all mercury, semivolatile metals, low volatile metals, or

total chlorine (organic and inorganic) from all feedstreams is emitted; (§63.1207(m)(2)(iii))

Monitoring:

• To document compliance with this provision, the permittee must: (§63.1207(m)(3))

(1) Monitor and record the feedrate of mercury, semivolatile metals, low volatile metals, and total chlorine

and chloride from all feedstreams according to §63.1209(c) as specified in PW012;

(§63.1207(m)(3)(i))

(2) Monitor with a CMS and record in the operating record the gas flowrate (either directly or by

monitoring a surrogate parameter that the permittee has correlated to gas flowrate);

(§63.1207(m)(3)(ii))

(3) Continuously calculate and record in the operating record the MTEC under the procedures of

§63.1207(m)(2); and (§63.1207(m)(3)(iii))

(4) Interlock the MTEC calculated in §63.1207(m)(2)(iii) to the AWFCO system to stop hazardous waste

burning when the MTEC exceeds the emission standard. (§63.1207(m)(3)(iv))

• In lieu of the requirement in §63.1207(m)(3)(iii) and (iv), the permittee may: (§63.1207(m)(4))

(1) Identify in the notification of compliance a minimum gas flowrate limit and a maximum feedrate limit

of mercury, semivolatile metals, low volatile metals, and/or total chlorine and chloride from all

feedstreams that ensures the MTEC as calculated in §63.1207(m)(2)(iii) is below the applicable

emission standard; and (§63.1207(m)(4)(i))

(2) Interlock the minimum gas flowrate limit and maximum feedrate limit in §63.1207(m)(3)(iv) to the

AWFCO system to stop hazardous waste burning when the gas flowrate or mercury, semivolatile

metals, low volatile metals, and/or total chlorine and chloride feedrate exceeds the limit in

§63.1207(m)(4)(i). (§63.1207(m)(4)(ii))

• When the permittee determines the feedrate of mercury, semivolatile metals, low volatile metals or total

chlorine and chloride for purposes of this provision, except as provided by §63.1207(m)(6), the permittee

must assume that the analyte is present at the full detection limit when the feedstream analysis determines

that the analyte is not detected in the feedstream. (§63.1207(m)(5))

• The permittee may assume that mercury is present in raw material at half the detection limit when the raw

material feedstream analysis determines that mercury is not detected. (§63.1207(m)(6))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 39

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Record Keeping:

• The permittee shall specify the method used for determining compliance with the mercury, semivolatile

metal, low volatile metal or hydrochloric acid/chlorine gas emission standards.

• If the permittee complies with the requirements under §63.1207(m), the permittee shall maintain records of: 

(1) The feedrate of mercury, semivolatile metals, low volatile metals and total chlorine and chloride from

all feedstreams; (§63.1207(m)(3)(i))

(2) The gas flowrate (either directly or by monitoring a surrogate parameter) in the operating record;

(§63.1207(m)(3)(ii))

(3) The MTEC in the operating record; and (§63.1207(m)(3)(iii))

(4) When the AWFCO system is not burning hazardous waste due to an MTEC exceedance or a gas

flowrate exceedance. (§63.1207(m)(3)(iv))

• The permittee shall maintain records of the data recorded by the continuous monitoring system. 

• The permittee shall maintain records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request.

Reporting:

• The permittee must state in the site-specific test plan that the permittee submits for review and approval

under §63.1207(e) that the permittee intends to comply with the provisions of this paragraph. The permittee

must include in the test plan documentation that any surrogate that is proposed for gas flowrate adequately

correlates with the gas flowrate. (§63.1207(m)(7))

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition PW012 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Feedstream Analysis - §63.1209(c)(1)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• Prior to feeding the material, the permittee must obtain an analysis of each feedstream that is sufficient to

document compliance with the applicable feedrate limits provided by this section. (§63.1209(c)(1))

• The permittee must develop and implement a feedstream analysis plan and record it in the operating record.

The plan must specify at a minimum: (§63.1209(c)(2))

(1) The parameters for which the permittee will analyze each feedstream to ensure compliance with the

operating parameter limits; (§63.1209(c)(2)(i))

(2) Whether the permittee will obtain the analysis by performing sampling and analysis or by other

methods, such as using analytical information obtained from others or using other published or

documented data or information; (§63.1209(c)(2)(ii))

(3) How the permittee will use the analysis to document compliance with applicable feedrate limits (e.g.,

if the permittee blends hazardous wastes and obtains analyses of the waste prior to blending but not of

the blended, as-fired, waste, the plan must describe how the permittee will determine the pertinent

parameters of the blended waste); (§63.1209(c)(2)(iii))

(4) The test methods which the permittee will use to obtain the analyses; (§63.1209(c)(2)(iv))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 40

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(5) The sampling method which the permittee will use to obtain a representative sample of each

feedstream to be analyzed using sampling methods described in Appendix IX, part 266, of chapter 40,

or an equivalent method; and (§63.1209(c)(2)(v))

(6) The frequency with which the permittee will review or repeat the initial analysis of the feedstream to

ensure that the analysis is accurate and up to date. (§63.1209(c)(2)(vi))

• The requirements of §§63.8(d) (Quality control program) and (e) (Performance evaluation of continuous

monitoring systems) apply, except that the permittee must conduct performance evaluations of components

of the CMS under the frequency and procedures (for example, submittal of performance evaluation test plan

for review and approval) applicable to performance tests as provided by §63.1207. (§63.1209(d)(1))

Monitoring:

• To comply with the applicable feedrate limits, the permittee must monitor and record feedrates as follows:

(§63.1209(c)(4))

(1) Determine and record the value of the parameter for each feedstream by sampling and analysis or

other method; (§63.1209(c)(4)(i))

(2) Determine and record the mass or volume flowrate of each feedstream by a CMS. If the permittee

determines flowrate of a feedstream by volume, the permittee must determine and record the density

of the feedstream by sampling and analysis (unless the permittee reports the constituent concentration

in units of weight per unit volume (e.g., mg/l)); and (§63.1209(c)(4)(ii))

(3) Calculate and record the mass feedrate of the parameter per unit time. (§63.1209(c)(4)(iii)) 

• The permittee is not required to monitor levels of metals or chlorine in the following feedstreams to

document compliance with the feedrate limits provided that the permittee document in the comprehensive

performance test plan the expected levels of the constituent in the feedstream and account for those assumed

feedrate levels in documenting compliance with feedrate limits: natural gas, process air and feedstreams

from vapor recovery systems. (§63.1209(c)(5))

• Conduct of Monitoring – The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and Maintenance of Continuous Monitoring Systems – The provisions of §63.8(c) apply.

(§63.1209(f))

Record Keeping:

• The permittee shall maintain a copy of the feedstream analysis plan on site at all times and maintain a copy

in the operating record. (§63.1209(c)(2))

• The permittee shall maintain a record of the value of the parameter for each feedstream by sampling and

analysis or other method; (§63.1209(c)(4)(i))

• The permittee shall maintain a record of the mass or volume flowrate of each feedstream by a CMS. If the

permittee determines flowrate of a feedstream by volume, the permittee must determine and record the

density of the feedstream by sampling and analysis (unless the permittee reports the constituent

concentration in units of weight per unit volume (e.g., mg/l); (§63.1209(c)(4)(ii))

• The permittee shall maintain a record of the mass feedrate of the parameter per unit time;

(§63.1209(c)(4)(iii))

• The permittee shall maintain records of the data recorded by the continuous monitoring system;

• The permittee shall maintain records on-site for the most recent sixty (60) months and shall immediately

make such records available to any Missouri Department of Natural Resources’ personnel upon verbal

request.

Reporting:

• The permittee must submit the feedstream analysis plan to the Administrator for review and approval, if

requested. (§63.1209(c)(3))

• The permittee shall place the feedrate limits in the Title V Operating Permit.
Continental Cement Company, L.L.C. 41

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW013 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Alternate Monitoring Requirements Other than Continuous Emissions Monitoring Systems (CEMS) -

§63.1209(g)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• Requests to use alternative methods. (§63.1209(g)(1))

(1) The permittee may submit an application to the Administrator for approval of alternative monitoring

requirements to document compliance with the emission standards of this subpart. For requests to use

additional CEMS, however, the permittee must use §63.1209(a)(5) and §63.8(f). (§63.1209(g)(1)(i))

(a) The Administrator will not approve averaging periods for operating parameter limits longer than

specified unless the permittee documents using data or information that the longer averaging

period will ensure that emissions do not exceed levels achieved during the comprehensive

performance test over any increment of time equivalent to the time required to conduct three runs

of the performance test. (§63.1209(g)(1)(i)(A))

(b) If the Administrator approves the application to use an alternative monitoring requirement, the

permittee must continue to use that alternative monitoring requirement until the permittee

receives approval under §63.1209(g)(1) to use another monitoring requirement.

(§63.1209(g)(1)(i)(B))

(2) The permittee may submit an application to waive an operating parameter limit based on

documentation that neither that operating parameter limit nor an alternative operating parameter limit

is needed to ensure compliance with the emission standards of this subpart. (§63.1209(g)(1)(ii))

(3) The permittee must comply with the procedures for applications submitted under §63.1209(g)(1)(i)

and (ii): (§63.1209(g)(1)(iii))

• The Administrator may determine on a case-by-case basis at any time (e.g., during review of the

comprehensive performance test plan, during compliance certification review) that the permittee may need

to limit additional or alternative operating parameters (e.g., opacity in addition to or in lieu of operating

parameter limits on the particulate matter control device) or that alternative approaches to establish limits on

operating parameters may be necessary to document compliance with the emission standards of this subpart.

(§63.1209(g)(2))

Monitoring:

As required by the alternative monitoring request.

Record Keeping:

• The permittee shall maintain a copy of the alternative monitoring application.

• The permittee shall maintain a copy of the alternative monitoring approval or denial. 

• As required by the alternative monitoring request.

Reporting:

• The permittee must submit the application to the Administrator not later than the comprehensive

performance test plan. (§63.1209(g)(1)(iii)(A)

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 42

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee must include the following in the application: (§63.1209(g)(1)(iii)(B))

(1) Data or information justifying the request for an alternative monitoring requirement (or for a waiver of

an operating parameter limit), such as the technical or economic infeasibility or the impracticality of

using the required approach; (§63.1209(g)(1)(iii)(B)(1))

(2) A description of the proposed alternative monitoring requirement, including the operating parameter to

be monitored, the monitoring approach/technique (e.g., type of detector, monitoring location), the

averaging period for the limit, and how the limit is to be calculated; and (§63.1209(g)(1)(iii)(B)(2))

(3) Data of information documenting that the alternative monitoring requirement would provide

equivalent or better assurance of compliance with the relevant emission standard, or that it is the

monitoring requirement that best assures compliance with the standard and that is technically and

economically practicable. (§63.1209(g)(1)(iii)(B)(3))

• The Administrator will notify the permittee of approval or intention to deny approval of the request within

90 calendar days after receipt of the original request and within 60 calendar days after receipt of any

supplementary information the permittee submits. The Administrator will not approve an alternative

monitoring request unless the alternative monitoring requirement provides equivalent or better assurance of

compliance with the relevant emission standard, or is the monitoring requirement that best assures

compliance with the standard and that is technically and economically practicable. Before disapproving any

request, the Administrator will notify the permittee of the Administrator’s intention to disapprove the

request together with: (§63.1209(g)(1)(iii)(C))

(1) Notice of the information and findings on which the intended disapproval is based; and

(§63.1209(g)(1)(iii)(C)(1))

(2) Notice of opportunity for the permittee to present additional information to the Administrator before

final action on the request. At the time the Administrator notifies the permittee of intention to

disapprove the request, the Administrator will specify how much time the permittee will have after

being notified of the intended disapproval to submit the additional information.

(§63.1209(g)(1)(iii)(C)(2))

(3) The permittee is responsible for ensuring that the permittee submits any supplementary and additional

information supporting the permittee’s application in a timely manner to enable the Administrator to

consider the application during review of the comprehensive performance test plan. Neither the

permittee’s submittal of an application, nor the Administrator’s failure to approve or disapprove the

application, relieves the permittee of the responsibility to comply with the provisions of this subpart.

(§63.1209(g)(1)(iii)(D))

Permit Condition PW014 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Alternate Standards for Existing or New Hazardous Waste Burning Cement Kilns using MACT -

§63.1206(b)(10)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee may petition the Administrator to recommend alternative semivolatile metal, low volatile

metal, mercury or hydrochloric acid/chlorine gas emission standards if: (§63.1206(b)(10)(i))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 43

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(1) The permittee achieves one or more of these standards while using MACT because of the raw material

contribution to emissions of the regulated metals or hydrochloric acid/chlorine gas; or

(§63.1206(b)(10)(i)(A))

(2) The permittee determines that mercury is not present at detectable levels in the raw material.

(§63.1206(b)(10)(i)(B))

• The alternative standard that the permittee recommends under §63.1206(b)(10)(i)(A) may be an operating

requirement, such as a hazardous waste feedrate limitation for metals and/or chlorine, and/or an emission

limitation. (§63.1206(b)(10)(ii))

• The alternative standard must include a requirement to use MACT, or better, applicable to the standard for

which the source is seeking relief, as defined in §63.1206(b)(10)(viii) and (ix). (§63.1206(b)(10)(iii))

• The permittee must not operate pursuant to the recommended alternative standards in lieu of emission

standards specified in §63.1204(a) and (b): (§63.1206(b)(10)(vii))

(1) Unless the Administrator approves the provisions of the alternative standard petition request or

establishes other alternative standards; and (§63.1206(b)(10)(vii)(A))

(2) Until the permittee submits a revised Notification of Compliance that incorporates the revised

standards. (§63.1206(b)(10)(vii)(B))

Monitoring:

• As specified in the alternate plan approved by the Administrator.

Record Keeping:

• As specified in the alternate plan approved by the Administrator.

Reporting:

Alternative Standard Petition

• The alternative standard petition the permittee submits under §63.1206(b)(10)(i)(A) must include data or

information documenting that raw material contributions to emissions of the regulated metals or

hydrochloric acid/chlorine gas prevents the permittee from complying with the emission standard even

though the source is using MACT, as defined in §63.1206(b)(10)(viii) and (ix), for the standard for which

the permittee is seeking relief. (§63.1206(b)(10)(iv)(A))

• Alternate standard petitions that the permittee submits under §63.1206(b)(10)(i)(B) must include data or

information documenting that mercury is not present at detectable levels in raw materials.

(§63.1206(b)(10)(iv)(B))

• The permittee must include data or information with semivolatile metal and low volatility metal alternative

standard petitions that the permittee submits under §63.1206(b)(10)(i)(A) documenting that increased

chlorine feedrates associated with the burning of hazardous waste, when compared to non-hazardous waste

operations, do not significantly increase metal emissions attributable to raw materials. (§63.1206(b)(10)(v))

• The permittee must include data or information with semi-volatile metal, low volatile metal and

hydrochloric acid/chlorine gas alternative standard petitions that the permittee submits under

§63.1206(b)(10)(i)(A) documenting that semivolatile metal, low volatile metal and hydrochloric

acid/chlorine gas emissions attributable to the hazardous waste only will not exceed the emission standards

in §63.1204(a) and (b). (§63.1206(b)(10)(vi))
Continental Cement Company, L.L.C. 44

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW015 – Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Alternate Standards for Existing or New Hazardous Waste Burning Cement Kilns using MACT –

CMS Monitoring §63.1209(b)(1) through (b)(5)

40 CFR Part 63, Subpart A

General Provisions

CMS Monitoring 

• The permittee must use continuous monitoring systems (CMS) (e.g., thermocouples, pressure transducers,

and flow meters) to document compliance with the applicable operating parameter limits under this section.

(§63.1209(b)(1))

• The permittee must install and operate continuous monitoring systems other than CEMS in conformance

with §63.8(c)(3) that requires the permittee, at a minimum, to comply with the manufacturer’s written

specifications or recommendations for installation, operation and calibration or the system: (§63.1209(b)(2))

(1) Calibration of thermocouples and pyrometers. The calibration of thermocouples must be verified at a

frequency and in a manner consistent with manufacturer specifications, but no less frequent than once

per year. The permittee must operate and maintain optical pyrometers in accordance with manufacturer

specifications unless otherwise approved by the Administrator. The permittee must calibrate optical

pyrometers in accordance with the frequency and procedures recommended by the manufacturer, but no

less frequent than once per year, unless otherwise approved by the Administrator. And,

[§63.1209(b)(2)(i)]

• CMS must sample the regulated parameter without interruption, and evaluate the detector response at least

once each 15 seconds and compute and record the average values at least every 60 seconds.

(§63.1209(b)(3))

• The span of the non-CEMS CMS detector must not be exceeded. The permittee must interlock the span

limits into the automatic waste feed cutoff system required by §63.1206(c)(3). (§63.1209(b)(4))

• Calculation of Rolling Averages: (§63.1209(b)(5))

(1) Calculation of rolling averages initially. Continuous monitoring systems must begin recording oneminute average values by 12:01 a.m., hourly rolling average values by 1:01 a.m.(e.g., when 60 oneminute values will be available for calculating the initial hourly rolling average), and twelve-hour

rolling averages by 12:01 p.m.(e.g., when 720 one-minute averages are available to calculate a 12-hour

rolling average), for those sources that come into compliance on the regulatory compliance date.

Sources that elect to come into compliance before the regulatory compliance date must begin

recording one-minute, hourly rolling average, and 12-hour rolling average values within 60 seconds,

60 minutes (when 60 one-minute values will be available for calculating the initial hourly rolling

average), and 720 minutes (when 720 one-minute values will be available for calculating the initial 12-

hour hourly rolling average) respectively, from the time at which compliance begins.

(§63.1209(b)(5)(i))

(2) The permittee must ignore periods of time when one-minute values are not available for calculating

the rolling averages. When one-minute values become available again, the first one-minute value is

added to the previous one-minute values to calculate rolling average. (§63.1209(b)(5)(ii))

(3) Calculation of rolling averages when the hazardous waste feed is cutoff. (§63.1209(b)(5)(iii))

(a) Hazardous Waste Feed is Cutoff – Except as provided by §63.1209(b)(5)(iii)(B), the permittee

must continue to monitor operating parameter limits with a CMS when the hazardous waste feed

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 45

Installation ID Number: 173-0001 Project Number: 173-0001-0001

is cutoff if the source is operating. The permittee must no resume feeding hazardous waste if an

operating parameter exceeds its limit. (§63.1209(b)(5)(iii)(A))

(b) The permittee is not subject to the CMS requirements during periods of time the permittee meets

the requirements of §63.1206(b)(1)(ii) (compliance with emissions standards for non hazardous

waste burning sources when the permittee is not burning hazardous waste).

(§63.1209(b)(5)(iii)(B))

Permit Condition PW016 – Milling, Conveying, Storage and Loading Systems

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations 40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Startup, Shutdown and Malfunction Plan §63.1354(b)(4) and (b)(5)

40 CFR Part 63, Subpart A

General Provisions – Startup, Shutdown and Malfunction Plan §63.6(e)(3)

Emission Limitation:

The permittee shall develop and implement a written startup, shutdown, and malfunction plan that

describes, in detail, procedures for operating and maintaining the source during periods of startup,

shutdown, and malfunction and a program of corrective action for malfunctioning process and air

pollution control equipment used to comply with the relevant standard. As required under §63.8(c)(1)(i),

the plan shall identify all routine or otherwise predictable CMS malfunctions. This plan shall be

developed by the permittee by the source’s compliance date for that relevant standard. The plan shall be

incorporated by reference into the source’s title V permit. The purpose of the startup, shutdown, and

malfunction plan is to: (§63.6(e)(3)(i))

• Ensure that, at all times, the permittee operates and maintains affected sources including associated air

pollution control equipment, in a manner consistent with good air pollution control practices for minimizing

emissions at least to the levels required by all relevant standards; (§63.6(e)(3)(i)(A))

• Ensure that the permittee is prepared to correct malfunctions as soon as practicable after their occurrence in

order to minimize excess emissions of hazardous air pollutants; and (§63.6(e)(3)(i)(B))

• Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (including

corrective action taken to restore malfunctioning process and air pollution control equipment to its normal

or usual manner of operation). (§63.6(e)(3)(i)(C))

Monitoring:

• During periods of startup, shutdown, and malfunction, the permittee shall operate and maintain such

source (including associated air pollution control equipment) in accordance with the procedures specified

in the startup, shutdown, and malfunction plan developed under §63.6(e)(3)(i). (§63.6(e)(3)(ii))

Record Keeping:

• The permittee shall keep a copy of the startup, shutdown, malfunction plan on-site at all times. The plan

shall be made available immediately for inspection to the Department of Natural Resources’ personnel upon

request.

• When actions taken by the permittee during a startup, shutdown, or malfunction (including actions taken to

correct a malfunction) are consistent with the procedures specified in the startup, shutdown and malfunction

plan, the permittee shall keep records for that event that demonstrate the procedures specified in the plan

were followed. These records may take the form of a “checklist,” or other effective form of record keeping,

that confirms conformance with the startup, shutdown, and malfunction plan for that event. In addition the

permittee shall keep records of these events as specified in §63.10(b) (and elsewhere in this part), including

records of the occurrence and duration of each startup, shutdown, or malfunction operation and each

malfunction of the air pollution control equipment. (§63.6(e)(3)(iii))
Continental Cement Company, L.L.C. 46

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• If an action taken by the permittee during a startup, shutdown, or malfunction (including an action taken to

correct a malfunction) is not consistent with the procedures specified in the startup, shutdown, and

malfunction plan, the permittee shall record the actions taken for that event. ((§63.6(e)(3)(iv))

Reporting:

• As required by §63.10(d)(5), if actions taken by an permittee during a startup, shutdown, or malfunction of

an affected source (including actions taken to correct a malfunction) are consistent with the procedures

specified in the source’s startup, shutdown, and malfunction plan specified in §63.6(e)(3), the permittee

shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or

malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be

submitted simultaneously with the excess emissions and continuous monitoring system performance reports;

and (§63.1354(b)(4))

• Any time an action taken by an permittee during a startup, shutdown, or malfunction (including actions

taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and

malfunction plan, the permittee shall make an immediate report of the actions taken for that event within 2

working days, by telephone call or facsimile (FAX) transmission. The immediate report shall be followed

by a letter, certified by the permittee or other responsible official, explaining the circumstances of the event,

the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess

emissions and/or parameter monitoring exceedances are believed to have occurred. (§63.1354(b)(5))

Permit Condition PW017 – Milling, Conveying, Storage and Loading Systems

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Operations and Maintenance Plan §63.1350(a) and (b)

40 CFR Part 63, Subpart A

General Provisions – Operation and Maintenance Requirements §63.6(e)(1) and (2)

Emission Limitation:

• The permittee shall prepare for each affected source subject to the provisions of this subpart, a written

operations and maintenance plan. The plan shall include the following information: (§63.1350(a))

(1) Procedures for proper operation and maintenance of the affected source and air pollution control

devices in order to meet the emission limits and operating limits of §§63.1343 through 63.1348;

(§63.1350(a)(1))

(2) Corrective actions to be taken when required by §63.1350(e); (§63.1350(a)(2))

(3) Procedures to be used to periodically monitor affected sources subject to opacity standards under

§§63.1346 and 63.1348. Such procedures must include the provisions of §63.1350(a)(4)(i) through

(a)(4)(iv). (§63.1350(a)(4))

(a) The permittee must conduct a monthly 1-minute visible emissions test of each affected source in

accordance with Method 22 of Appendix A to part 60 of this chapter. The test must be

conducted while the affected source is in operation. (§63.1350(a)(4)(i))

(b) If no visible emissions are observed in six consecutive monthly tests for any affected source, the

permittee may decrease the frequency of testing from monthly to semi-annually for that affected

source. If visible emissions are observed during any semi-annual test, the permittee must resume

testing of that affected source on a monthly basis and maintain that schedule until no visible

emissions are observed in six consecutive monthly tests. (§63.1350(a)(4)(ii))

(c) If no visible emissions are observed during the semi-annual test for any affected source, the

permittee may decrease the frequency of testing from semi-annually to annually for that affected

source. If visible emissions are observed during any annual test, the permittee must resume
Continental Cement Company, L.L.C. 47

Installation ID Number: 173-0001 Project Number: 173-0001-0001

testing of that affected source on a monthly basis and maintain that schedule until no visible

emission are observed in six consecutive monthly test. (§63.1350(a)(4)(iii))

(d) If visible emissions are observed during any Method 22 test, the permittee must conduct a 6-

minute test of opacity in accordance with Method 9 of appendix A to part 60 of this chapter. The

Method 9 test must begin within one hour of any observation of visible emissions.

(§63.1350(a)(4)(iv))

(e) The requirement to conduct Method 22 visible emissions monitoring under this paragraph shall

not apply to any totally enclosed conveying system transfer point, regardless of the location of

the transfer point. "Totally enclosed conveying system transfer point" shall mean a conveying

system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these

transfer points shall be operated and maintained as total enclosures on a continuing basis in

accordance with the facility operations and maintenance plan. (§63.1350(a)(4)(v))

(f) If any partially enclosed or unenclosed conveying system transfer point is located in a building,

the permittee of the portland cement plant shall have the option to conduct a Method 22 visible

emissions monitoring test according to the requirements of §63.1350(a)(4)(i) through (a)(4)(iv)

for each such conveying system transfer point located within the building, or for the building

itself, according to §63.1350(a)(4)(vii). (§63.1350(a)(4)(vi))

(g) If visible emissions from a building are monitored, the requirements of §63.1350(a)(4)(i) through

(iv) apply to the monitoring of the building, and you must also test visible emissions from each

side, roof and vent of the building for at least one minute. The test must be conducted under

normal operating conditions. (§63.1350(a)(4)(vii))

• Failure to comply with any provision of the operations and maintenance plan developed in accordance with

§63.1350(a) shall be a violation of the standard. (§63.1350(b))

• Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable

independent of emissions limitations or other requirements in relevant standards. (§63.6(e)(1)(iii))

Monitoring:

• At all times, including periods of startup, shutdown, and malfunction, the permittee shall operate and

maintain any affected source, including associated air pollution control equipment, in a manner consistent

with good air pollution control practices for minimizing emissions at least to the levels required by all

relevant standards. (§63.6(e)(1)(i))

• Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup,

shutdown, and malfunction plan required in §63.6(e)(3) of this section. (§63.6(e)(1)(ii))

Record Keeping:

• As specified in the Operations and Maintenance Plan.

• The permittee shall keep a copy of the Operations and Maintenance plan on-site at all times. The plan shall

be made available immediately for inspection to the Department of Natural Resources’ personnel upon

request.

Reporting:

• The plan shall be submitted to the Administrator for review and approval as part of the application for a part

70 permit. (§63.1350(a))

• All failures to comply with any provision of the operation and maintenance plan developed in accordance

with §63.1350(a) shall be included in the semiannual summary report. (§63.1354(b)(9)(v))
Continental Cement Company, L.L.C. 48

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW018 – Milling, Conveying, Storage and Loading Systems

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Notification Requirements §63.1353, Reporting Requirements §63.1354(a) and Record

Keeping Requirements §63.1355(a) and (b)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The notification provisions of 40 CFR part 63, subpart A that apply and those that do not apply to permittee

subject to this subpart are listed in Table 1 of §60.1353, which is incorporated by reference in this permit.”

If MDNR requires a notice that contains all of the information required in a notification listed in this

section, the permittee may send the Administrator a copy of the notice sent to MDNR to satisfy the

requirements of this section for that notification. (§63.1353(a))

• Each permittee subject to the requirements of this subpart shall comply with the notification requirements in

§63.9 as listed below. (§63.1353(b))

Monitoring and Record Keeping:

• The permittee shall maintain files of all information (including all reports and notifications) required by this

section recorded in a form suitable and readily available for inspection and review as required by

§63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of

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

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. (§63.1355(a))

• The permittee shall maintain records for each affected source as required by §63.10(b)(2) and (b)(3) of this

part; and (§63.1355(b))

(1) All documentation supporting initial notifications and notifications of compliance status under §63.9;

(§63.1355(b)(1))

(2) All records of applicability determination, including supporting analyses; and (§63.1355(b)(2))

(3) If the permittee has been granted a waiver under §63.8(f)(6), any information demonstrating whether a

source is meeting the requirements for a waiver of record keeping or reporting requirements

(§63.1355(b)(3))

Reporting:

• Initial notifications as required by §63.9(b) through (d). For the purposes of this subpart, a Title V or 40

CFR part 70 permit application may be used in lieu of the initial notification required under §63.9(b),

provided the same information is contained in the permit application as required by §63.9(b), and the State

to which the permit application has been submitted has an approved operating permit program under part 70

of this chapter and has received delegation of authority from the EPA. Permit applications shall be

submitted by the same due dates as those specified for the initial notification. (§63.1353(b)(1))

• Notification of performance tests, as required by §§63.7 and 63.9(e). (§63.1353(b)(2))

• Notification of opacity and visible emission observations required by §63.1349 in accordance with

§§63.6(h)(5) and 63.9(f). (§63.1353(b)(3))

• Notification, as required by §63.9(g), of the date that the continuous emission monitor performance

evaluation required by §63.8(e) is scheduled to begin. (§63.1353(b)(4))

• Notification of compliance status, as required by §63.9(h). (§63.1353(b)(5))

• The reporting provisions of subpart A of this part that apply and those that do not apply to the permittee

subject to this subpart are listed in Table 1 of this subpart. If MDNR requires a report that contains all of
Continental Cement Company, L.L.C. 49

Installation ID Number: 173-0001 Project Number: 173-0001-0001

the information required in a report listed in this section, the permittee may send the Administrator a copy of

the report sent to the State to satisfy the requirements of this section for that report. (§63.1354(a))

• As required by §63.10(d)(4), the permittee who is required to submit progress reports as a condition of

receiving an extension of compliance under §63.6(i) shall submit such reports by the dates specified in the

written extension of compliance. (§63.1354(b)(3))

• The permittee shall submit a summary report semiannually which contains the information specified in

§63.10(e)(3)(vi). In addition, the summary report shall include (§63.1354(b)(9):

(1) All failures to comply with any provision of the operation and maintenance plan developed in

accordance with §63.1350(a). (§63.1354(b)(9)(v))

Permit Condition PW019 – Milling, Conveying, Storage and Loading Systems

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Performance Testing Requirements §63.1349 

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee subject to this subpart shall demonstrate initial compliance with the emission limits of

§63.1343 and §63.1345 through §63.1348 using the test methods and procedures in §63.1349(b) and

§63.7. (§63.1349(a))

Performance Testing:

• Performance tests to demonstrate initial compliance with this subpart shall be conducted as specified in

§63.1349(b)(1) through §63.1349(b)(4). (§63.1349(b))

Monitoring:

• As required by the test methods and procedures in §63.1349(b) and §63.7.

Record Keeping:

• As required by the test methods and procedures in §63.1349(b) and §63.7

Reporting:

• Performance test results shall be documented in complete test reports that contain the information required

by §63.1349(a)(1) through (a)(10) of this section, as well as all other relevant information. The plan to be

followed during testing shall be made available to the Administrator prior to testing, if requested.

(§63.1349(a))

• A brief description of the process and the air pollution control system; (§63.1349(a)(1))

• Sampling location description(s); (§63.1349(a)(2))

• A description of sampling and analytical procedures and any modification to standard procedures;

(§63.1349(a)(3))

• Test results; (§63.1349(a)(4))

• Quality assurance procedures and results; (§63.1349(a)(5))

• Records of operating conditions during the test, preparation of standards, and calibration procedures;

(§63.1349(a)(6))

• Raw data sheets for field sampling and field and laboratory analyses; (§63.1349(a)(7))

• Documentation of calculation; (§63.1349(a)(8))

• All data recorded and used to establish parameters for compliance monitoring; and (§63.1349(a)(9)) 

• Any other information required by the test method. (§63.1349(a)(10))
Continental Cement Company, L.L.C. 50

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition PW020 – Milling, Conveying, Storage and Loading Systems

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Alternate Monitoring Requirements §63.1350

Emission Limitation:

• The permittee may submit an application to the Administrator for approval of alternate monitoring

requirements to demonstrate compliance with the emission standards of this subpart, except for emission

standards for THC, subject to the provisions of §63.1350(l)(1) through (l)(6). (§63.1350(l))

• The Administrator may decide at any time, on a case-by-case basis that additional or alternative operating

limits, or alternative approaches to establishing operating limits, are necessary to demonstrate compliance

with the emission standards of this subpart. (§63.1350(l)(6))

Monitoring:

• If the application to use an alternate monitoring requirement is approved, the permittee must continue to

use the original monitoring requirement until approval is received to use another monitoring requirement.

(§63.1350(l)(2))

Record Keeping:

• If the application to use an alternate monitoring requirement is approved, the permittee must continue to

use the original record keeping requirements for the original monitoring requirements until approval is

received to use another monitoring requirement. 

Reporting:

• The Administrator will not approve averaging periods other than those specified in this section, unless the

permittee documents, using data or information, that the longer averaging period will ensure that emissions

do not exceed levels achieved during the performance test over any increment of time equivalent to the time

required to conduct three runs of the performance test. (§63.1350(l)(1))

• The permittee shall submit the application for approval of alternate monitoring requirements no later than

the notification of performance test. The application must contain the information specified in

§63.1350(l)(3)(i) through (l)(3)(iii): (§63.1350(l)(3)

(1) Data or information justifying the request, such as the technical or economic infeasibility, or the

impracticality of using the required approach. (§63.1350(l)(3)(i))

(2) A description of the proposed alternative monitoring requirement, including the operating parameter to

be monitored, the monitoring approach and technique, the averaging period for the limit, and how the

limit is to be calculated; and (§63.1350(l)(3)(ii))

(3) Data or information documenting that the alternative monitoring requirement would provide

equivalent or better assurance of compliance with the relevant emission standard. (§63.1350(l)(3)(iii)

• The Administrator will notify the permittee of the approval or denial of the application within 90 calendar

days after receipt of the original request, or within 60 calendar days of the receipt of any supplementary

information, whichever is later. The Administrator will not approve an alternate monitoring application

unless it would provide equivalent or better assurance of compliance with the relevant emission standard.

Before disapproving any alternate monitoring application, the Administrator will provide (§63.1350(l)(4)):

(1) Notice of the information and findings upon which the intended disapproval is based; and

(§63.1350(l)(4)(i))

(2) Notice of opportunity for the permittee to present additional supporting information before final action

is taken on the application. This notice will specify how much additional time is allowed for the

permittee to provide additional supporting information. (§63.1350(l)(4)(ii))
Continental Cement Company, L.L.C. 51

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee is responsible for submitting any supporting information in a timely manner to enable the

Administrator to consider the application prior to the performance test. Neither submittal of an application,

nor the Administrator’s failure to approve or disapprove the application relieves the permittee of the

responsibility to comply with any provision of this subpart. (§63.1350(l)(5))

Permit Condition PW021 – Fugitive Emissions

10 CSR 10-6.170

Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin

Emission Limitation:

1) The permittee shall not cause or allow to occur any handling, transporting or storing of any material;

construction, repair, cleaning or demolition of a building or its appurtenances; construction or use of a road,

driveway or open area; or operation of a commercial or industrial installation without applying reasonable

measures as may be required to prevent, or in a manner which allows or may allow, fugitive particulate

matter emissions to go beyond the premises of origin in quantities that the particulate matter may be found

on surfaces beyond the property line or origin. The nature or origin of the particulate matter shall be

determined to a reasonable degree of certainty by a technique proven to be accurate and approved by the

director;

2) The permittee shall not cause nor allow to occur any fugitive particulate matter emissions to remain visible

in the ambient air beyond the property line of origin. 

3) Should it be determined that noncompliance has occurred, the director may require reasonable control

measures as may be necessary.

Monitoring:

1) The permittee shall conduct inspections of its facilities sufficient to determine compliance with this

regulation. At a minimum, the observer should be trained and knowledgeable about the effects on visibility

of emissions caused by background contrast, ambient lighting, observer position relative to lighting, wind

and the presence of uncombined water. If a violation of this regulation is discovered, the source shall

undertake corrective action to eliminate the violation.

The following monitoring schedule must be maintained:

a) Weekly observations shall be conducted for a minimum of four consecutive weeks after permit issuance.

Should no violation of this regulation be observed during this period thenb) Observations must be made once every two weeks for a period of four weeks. If a violation is noted,

monitoring reverts to weekly. Should no violation of this regulation be observed during this period

thenc) Observations must be made once per month. If a violation is noted, monitoring reverts to weekly.

2) If the source reverts to weekly monitoring at any time, monitoring frequency will progress in an identical

manner to the initial monitoring frequency.

Record Keeping:

A log must be maintained noting the following:

1) Whether air emissions (except water vapor) remain visible in the ambient air beyond the property line of

origin.

2) Whether the visible emissions were normal for the installation.

3) Equipment malfunctions that could cause an exceedance of 10 CSR 10-6.170.

4) Any violations of 10 CSR 10-6.170 and any corrective actions undertaken to correct the violation.

Attachment A contains a log including these record keeping requirements. This log, or an equivalent created by

the permittee, must be used to certify compliance with this requirement.

Reporting:

All exceedances and a description of a corrective action taken shall be reported to the Air Pollution Control

Program, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 semi-annually. 
Continental Cement Company, L.L.C. 52

Installation ID Number: 173-0001 Project Number: 173-0001-0001

III. Emission Unit Specific Emission Limitations

The installation shall comply with each of the following emission limitations. Consult the appropriate sections

in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the

applicable requirements.

Emission

Unit

2000 EIQ

Point Description Control Device Manufacture Year

EU0010 KP-1 cement kiln ESP Amer. Air 1966

EU0020 CM-1 clinker cooler KDC - 5 Amerex 1966

EU0030 CM-2a dust collector discharges to apron pan

conveyor

SC-3 DCE Vokes 1966

EU0040 CM-2 clinker transfer drag to apron pan

conveyor

KAP - 1 Fuller 1966

EU0050 CM-1a Clean-up screw discharges to apron pan

conveyor

Enclosure sock 1966

EU0060 CM-3 clinker apron pan conveyor transfer point

to bucket elevator KAP - 2 DCE Vokes 1966

EU0070 CM-4a clinker transfer - east elevator to belt

conveyor

KDC-1B DCE Vokes 1966

EU0080 CM-4 clinker transfer - west elevator to belt

conveyor

KDC-1A DCE Vokes 1966

EU0090 CM-4b clinker transfer - conveyor1a to conveyor

1d KDC-1C DCE Vokes 1966

EU0100 CM-4c clinker transfer - conveyor 1b to

conveyor 1c KDC-1D/KBC-1A2 DCE Vokes 1966

EU0110 CM-12c clinker hopper Enclosure walls 1966

EU0120 CM-7a clinker transfer – hopper to conveyor belt Enclosed/Skirting 1966

EU0130 CM-7b clinker transfer - conveyor belt to elevator KDC-3, CR-DC BHA-DCE

Vokes 1966

EU0140 CM-8 clinker storage silos- F Silos KDC-3 BHA 1966

EU0150 CM-8a clinker storage silos - North Silos KDC-1 BHA 1966

EU0160 CM-8b clinker storage silos - South Silos KDC-2 BHA 1966

EU0170 CM-8c clinker storage silos - North fringe FDC-1F BHA 1966

EU0180 CM-8d clinker storage silos - South fringe FDC-2F BHA 1966

EU0190 CM9.1a,b,c,2a,b,c clinker weighing and transfer - mill 1-2 FDC-1a,b,c/FDC-2a,b,c Flex -Kleen 1966

EU0200 CM-10 clinker grinding ( mill # 1 ) FDC-1E BHA 1966

EU0210 CM-10a Finish Mill #1 Elevator O-Sepa - 1DC Fuller 1966

EU0220 CM-10c finish mill #1 air separator O-Sepa - 1DC Fuller 1966

EU0230 CM-10d finish mill #1 - surge bin O-Sepa - 1DC Fuller 1966

EU0240 CM-10e finish mill #1 - 1G fringe bin FDC-1 A Flex -Kleen 1966

EU0245 CM-10j Mill Building 1966

EU0250 CM-10.1 clinker grinding ( mill # 2 ) FDC-2E BHA 1966

EU0260 CM-10F finish mill #2 - elevator O-Sepa - 2DC Fuller/BHA 1966

EU0270 CM-10g finish mill #2 air separator O-Sepa - 2DC Fuller/BHA 1966

EU0280 CM-10h finish mill #2 - surge bin O-Sepa - 2DC Fuller/BHA 1966

EU0290 CM-10I finish mill #2 - 2G fringe bin FDC-2 A Flex -Kleen 1966

EU0300 CM-11 clinker reclaim elevator discharge KDC-3 BHA 1966

EU0310 CM-12 clinker transfer tripper to clinker storage

pile KDC - 5 Amerex 1966

EU0320 SH-1 cement storage - stockhouse #6 XDC - 1 Torit 1966

EU0330 SH-2 cement storage silos CDC 1 BHA 1966

EU0340 SH-2 cement storage silos CDC 2 BHA 1966

EU0350 SH-2 cement storage silos CDC 3 BHA 1966

EU0360 SH-2 cement storage silos CDC 4 BHA 1966

EU0370 SH-2 cement storage silos CDC 5 BHA 1966
Continental Cement Company, L.L.C. 53

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Emission

Unit

2000 EIQ

Point Description Control Device Manufacture Year

EU0380 SH-2 cement storage silos CDC 6 BHA 1966

EU0390 SH-3 cement transfer - silos into pump/air slide

system CDC 9,10 BHA 1966

EU0400 SH-4 cement handling - bulk truck loading lines CDC 11,12 Flex - Kleen 1966

EU0410 SH-5 cement handling - bulk railcar/truck

loading lines CDC 13, 14,15 W. W. Sly 1966

EU0420 SH-7 cement storage silos BDC - 1 Dustex 1966

EU0430 SH-8 cement barge loading BLDC - 1 Fuller 1966

EU0440 SH-9 cement barge loading BLDC - 2 Fuller 1966

EU0450 SG-10 Syn-Gyp Buiding 1997

EU0460 SF-2A,2B Supplemental fuel storage tanks (6) 1986

EU0470 SF-3A,3B Supplemental fuel burn tanks (2) 1990

EU0480 SF- 60 Supplemental fuel storage tank 2004

EU0490 SF- 21 Supplemental fuel storage tank pending

EU0500 Artificial Soils Project 1991

EU0510 Artificial Soils Project 1991

EU0520 Artificial Soils Project 1991

EU0530 Artificial Soils Project 1991

EU0540 Artificial Soils Project 1991

Permit Condition EU0010-01 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Dioxins and Furans

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gasses to be emitted into the atmosphere that

contain(§63.1204(a)(1): 

(1) dioxins and furans in excess of 0.20 ng TEQ/dscm corrected to seven percent (7%) oxygen; or

(§63.1204(a)(1)(i))

(2) dioxins and furans in excess of 0.40 ng TEQ/dscm corrected to seven percent (7%) oxygen provided

that the combustion gas temperature at the inlet to the initial particulate matter control device is 400°F

or lower based on the average of the test run average temperature. (§63.1204(a)(1)(ii))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, the permittee may

round the resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• If the kiln is not burning hazardous waste, the permittee may comply with the alternate mode of operation

defined in the Comprehensive Performance Test Plan as follows: 

“Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension

granted to Continental Cement. The regulatory compliance date is September 30, 2003.

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 54

Installation ID Number: 173-0001 Project Number: 173-0001-0001

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”

 Alternate Standard Provision:

To utilize this provision as specified in §63.1206(b)(10), please refer to permit condition PW014

Operating Parameters:

• The permittee must comply with the dioxin and furans emission standard by establishing and complying

with the following operating parameter limits. The permittee must base the limits on operations during the

comprehensive performance test, unless the limits are based on manufacturer specifications(§63.1209(k)) or

based upon the results of previous performance tests submitted and approved as data in lieu of testing as

described by 63. 1206(b)(7). 

(1) Gas Temperature at the inlet to a dry particulate matter control device. (§63.1209(k)(1))

(a) If the combustor is equipped with an electrostatic precipitator, the permittee must establish a

limit on the maximum temperature of the gas at the inlet to the device on an hourly rolling

average. The permittee must establish the hourly rolling average limit as the average of the test

run averages. (§63.1209(k)(1)(i))

(2) Minimum combustion chamber temperature. (§63.1209(k)(2))

(a) The permittee must measure the temperature of each combustion chamber at a location that best

represents, as practicable, the bulk gas temperature in the combustion zone. The permittee must

document the temperature measurement location in the test plan the permittee submits under

§63.1207(e) and (f); (§63.1209(k)(2)(i))

(b) The permittee must establish a minimum hourly rolling average limit as the average of the test

run averages; (§63.1209(k)(2)(ii)), or based upon the results of previous performance tests

submitted and approved as data in lieu of testing as described by 63.1206(b)(7).

(3) Maximum flue gas flowrate or production rate. (§63.1209(k)(3))

(a) As an indicator of gas residence time in the control device the permittee must establish and

comply with a limit on the maximum flue gas flowrate, the maximum production rate, or another

parameter that the permittee documents in the site-specific test plan as an appropriate surrogate

for gas residence time, as the average of the maximum hourly rolling averages for each run;

(§63.1209(k)(3)(i))

(b) The permittee must comply with this limit on an hourly rolling average basis;

(§63.1209(k)(3)(ii))

(4) Maximum hazardous waste feedrate. (§63.1209(k)(4))

(a) The permittee must establish limits on the maximum pumpable and total (i.e., pumpable and

nonpumpable) hazardous waste feedrate for each location where waste is fed; (§63.1209(k)(4)(i))

(b) The permittee must establish the limits as the average of the maximum hourly rolling averages

for each run. (§63.1209(k)(4)(ii))

(c) The permittee must comply with the feedrate limit(s) on a hourly rolling average basis;

(§63.1209(k)(4)(iii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))2

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln;i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 55

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Operating under otherwise applicable standards after the hazardous waste residence time has transpired. As

provided by Sec. §63.1206(b)(1)(ii), the permittee may operate under otherwise applicable requirements

promulgated under sections 112 and 129 of the Clean Air Act in lieu of the substantive requirements of this

subpart. (§63.1209(q)(1))

• The otherwise applicable requirements promulgated under sections 112 and 129 of the Clean Air Act are

applicable requirements under this subpart. (§63.1209(q)(1)(i))

• The permittee must specify (e.g., by reference) the otherwise applicable requirements as a mode of

operation in the permittee’s Documentation of Compliance under Sec. 63.1211(c), the permittee’s

Notification of Compliance under Sec. 63.1207(j), and the permittee’s title V permit application. These

requirements include the otherwise applicable requirements governing emission standards, monitoring and

compliance, and notification, reporting, and record keeping. (§63.1209(q)(1)(ii))

• Calculating rolling averages under different modes of operation. When the permittee transitions to a

different mode of operation, the permittee must calculate rolling averages as follows: (§63.1209(q)(2))

(1) Retrieval approach. Calculate rolling averages anew using the continuous monitoring system values

previously recorded for that mode of operation (i.e., the permittee ignores continuous monitoring

system values subsequently recorded under other modes of operation when the permittee transitions

back to a mode of operation); or (§63.1209(q)(2)(i))

(2) Start anew. Calculate rolling averages anew without considering previous recordings.

(§63.1209(q)(2)(ii))

(a) Rolling averages must be calculated as the average of the available one-minute values for the

parameter until enough one-minute values are available to calculate hourly or 12-hour rolling

averages, whichever is applicable to the parameter. (§63.1209(q)(2)(ii)(A))

(b) The permittee may not transition to a new mode of operation using this approach if the most

recent operation in that mode resulted in an exceedance of an applicable emission standard

measured with a CEMS or operating parameter limit prior to the hazardous waste residence time

expiring; or (§63.1209(q)(2)(ii)(B))

(3) Seamless transition. Continue calculating rolling averages using data from the previous operating

mode provided that both the operating limit and the averaging period for the parameter are the same

for both modes of operation. (§63.1209(q)(2)(iii))2

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee must use Method 0023A, Sampling Method for Polychlorinated Dibenzo-p-Dioxins and

Polychlorinated Dibenzofurans emissions from Stationary Sources, EPA Publication SW-846, as

incorporated by reference in §63.1208(a), to determine compliance with the emission standard for dioxins

and furans; (§63.1208(b)(1)(i))

• The permittee must sample for a minimum of three hours, and the permittee must collect a minimum sample

volume of 2.5 dscm; (§63.1208(b)(1)(ii))

• The permittee may assume that nondetects are present a zero concentration. (§63.1208(b)(1)(iii))

Monitoring:

• The permittee shall comply with the comprehensive and confirmatory performance testing as specified in

permit conditions PW011.

• The permittee shall monitor the gas temperature at the inlet to a dry particulate matter control device on an

hourly rolling average;(§63.1209(k)(1)(i))

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln;i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 56

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall monitor the temperature of each combustion chamber at a location that best represents,

as practicable, the bulk gas temperature in the combustion zone on an hourly rolling average;

(§63.1209(k)(2)(i) and (ii))

• The permittee shall monitor the maximum flue gas flowrate or production rate on an hourly rolling average;

(§63.1209(k)(3)(i) and (ii))

• The permittee shall monitor the maximum hazardous waste feedrate for each location where waste is fed on

an hourly rolling average; (§63.1209(k)(4)(i) and (ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. 

• Conduct of monitoring – The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and Maintenance of Continuous Monitoring Systems – The provisions of §63.8(c) apply except:

(§63.1209(f))

Record Keeping:

• The permittee shall comply with the comprehensive and confirmatory performance testing record keeping

requirements as stated in permit conditions PW010.

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records of the hourly rolling average for the following:

• Gas temperature at the inlet to a dry particulate matter control device. (§63.1209(k)(1)(i))

• Combustion chamber temperature of each chamber; (§63.1209(k)(2)(i))

• Flue gas flowrate, production rate or another parameter that the permittee documents in the site-specific test

plan as an appropriate surrogate for the gas residence time; (§63.1209(k)(3)(i))

• Maximum pumpable and total (pumpable and non-pumpable) hazardous waste feedrate for each location

where waste is fed. (§63.1209(k)(4)(i))

• The permittee shall maintain records of the comprehensive and confirmatory performance test plans. 

• The permittee shall maintain records of the comprehensive and confirmatory performance test results.

• The permittee shall maintain records on the calibration checks of the CMS equipment.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

• The permittee shall maintain records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request

Record Keeping /Reporting for Alternate Standard Provision:

• The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the

kiln and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or

Alternate Standard Provisions. Attachment G contains a log including these record keeping requirements.

This log or an equivalent created by the permittee, must be used to certify compliance with this requirement.

These records shall be made available to either the Director upon written request or Department inspection

personnel upon verbal request

Reporting:

• The permittee shall comply with the comprehensive and confirmatory performance testing reporting

requirements as stated in permit conditions PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.
Continental Cement Company, L.L.C. 57

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition EU0010-02 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations 

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Mercury

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

mercury in excess of 120 μg/dscm corrected to seven percent oxygen; (§63.1204(a)(2))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, you may round the

resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• If the kiln is not burning hazardous waste and the permittee is complying with the alternate mode of

operation defined in the Comprehensive Performance Test Plan as follows: 

“Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”, the permittee is not subject to this permit condition, except for the monitoring and record keeping

of the hazardous waste feed and the method of compliance.

Alternate Standard Provision:

• To utilize this provision as specified in §63.1206(b)(10), please refer to permit condition PW014.

• The permittee must utilize a hazardous waste feedrate corresponding to an MTEC of 120 μg/dscm or less;

(§63.1206(b)(10)(viii)(A))

Operating Parameters:

• The permittee must comply with the mercury emission standard by establishing and complying with the

following operating parameter limits. The permittee must base the limits on operations during the

comprehensive performance test, unless the limits are based on manufacturer specifications: (§63.1209(l))

(1) Feedrate of Total Mercury – The permittee must establish a 12-hour rolling average limit for the total

feedrate of mercury in all feedstreams as the average of the test run averages, unless mercury feedrate

limits are extrapolated from performance test feedrate levels under the following provisions:

(§63.1209(l)(1))

(a) The permittee may request as part of the performance test plan under §§63.7(b) and (c) and

§§63.1207(e) and (f) to use the mercury feedrates and associated emission rates during the

comprehensive performance test to extrapolate to higher allowable feedrate limits and emission

rates. (§63.1209(l)(1)(i))

(b) The extrapolation methodology will be reviewed and approved, as warranted, by the

Administrator. The review will consider in particular whether: (§63.1209(l)(1)(ii))

(i) Performance test metal feedrates are appropriate (i.e., whether feedrates are at least at

normal levels; depending on the heterogeneity of the waste, whether some level of spiking

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 58

Installation ID Number: 173-0001 Project Number: 173-0001-0001

would be appropriate; and whether the physical form and species of spiked material is

appropriate); and (§63.1209(l)(1)(ii)(A))

(ii) Whether the extrapolate feedrates the permittee requests are warranted considering

historical metal feedrate data. (§63.1209(l)(1)(ii)(B))

(c) The Administrator will review the performance test results in making a finding of compliance

required by §§63.6(f)(3) and 63.1206(b)(3) to ensure that the permittee have interpreted emission

test results properly and that the extrapolation procedure is appropriate for the source.

(§63.1209(l)(1)(iii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q)) 

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee must use Method 29, provided in Appendix A, part 60 of chapter 40, to demonstrate

compliance with the emission standard for mercury. (§63.1208(b)(2))

• The permittee may use any reliable analytical method to determine feedstream concentrations of metals,

chlorine and other constituents. It is the responsibility of the permittee to ensure that the sampling and

analysis procedures are unbiased, precise, and that the results are representative of the feedstream. For each

feedstream, the permittee must demonstrate that: (§63.1208(b)(8))

(1) Each analyte is not present above the reported level at the 80% upper confidence limit around the

mean; and (§63.1208(b)(8)(i))

(2) The analysis could have detected the presence of the constituent at or below the reported level at the

80% upper confidence limit around the mean. (See Guidance for Data Quality Assessment – Practical

Methods for Data Analysis, EPA QA/G-9, January 1998, EPA/600/R-96/084). (§63.1208(b)(8)(ii))

Monitoring:

• To document compliance with the operating requirement of §63.1206(b)(15)(ii), the permittee must:

(§63.1206(b)(15)(iii))

(1) Monitor and record the feedrate of mercury for each hazardous waste feedstream according to

§63.1209(c); (§63.1206(b)(15)(iii)(A))

(2) Monitor with a CMS and record in the operating record the gas flowrate (either directly or by

monitoring a surrogate parameter that the permittee has correlated to gas flowrate);

(§63.1206(b)(15)(iii)(B))

(3) Continuously calculate and record in the operating record a MTEC assuming mercury from all

hazardous waste feedstreams is emitted; (§63.1206(b)(15)(iii)(C))

(4) Interlock the MTEC calculated in §63.1206(b)(15)(iii)(C) to the AWFCO system to stop hazardous

waste burning when the MTEC exceeds the operating requirement of §63.1206(b)(15)(ii).

(§63.1206(b)(15)(iii)(D))

• In lieu of the requirement in §63.1206(b)(15)(iii), the permittee may: (§63.1206(b)(15)(iv))

(1) Identify in the Notification of Compliance a minimum gas flowrate limit and a maximum feedrate

limit of mercury from all hazardous waste feedstreams that ensures the MTEC calculated in

§63.1206(b)(15)(iii)(C) is below the operating requirement of §63.1206(b)(15)(ii); and

(§63.1206(b)(15)(iv)(A))

(2) Interlock the minimum gas flowrate limit and maximum feedrate limits in §63.1206(b)(15)(iv)(A) to

the AWFCO system to stop hazardous waste burning when the gas flowrate or mercury feedrate

exceeds the limits in §63.1206(b)(15)(iv)(A). (§63.1206(b)(15)(iv)(B))
Continental Cement Company, L.L.C. 59

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Notification requirement. The permittee must notify in writing the RCRA authority (MDNR Hazardous

Waste Program) that the permittee intends to comply with the alternative standard. (§63.1206(b)(15)(v))

• The permittee may petition the Administrator to use CEMS for compliance monitoring for particulate

matter, mercury, semivolatile metals, low volatile metals, and hydrochloric acid/chlorine gas under §63.8(f)

in lieu of compliance with the corresponding operating parameter limits under §63.1209. (§63.1209(a)(5))

• The permittee shall comply with the comprehensive performance testing as specified in permit condition

PW010.(“permittee shall monitor total feedrate of mercury on a 12-hour rolling average basis”)

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must begin calculating rolling averages anew (i.e.,

without considering previous recordings) when the permittee begins complying with the operating

parameter limits for the alternative mode of operation. (§63.1209(q) and (q)(ii))

• Conduct of monitoring – The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and Maintenance of Continuous Monitoring Systems – The provisions of §63.8(c) apply except:

(§63.1209(f)(1)(2)and(3))(incorporated by reference), and (§63.1209(q)(incorporated by reference)

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW010.

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records on an hourly rolling average for the following:

(1) Total feedrate of mercury in all feedstreams; (§63.1209(l)(1))

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• The permittee shall maintain records of the calibration checks of the CMS equipment.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

• The permittee shall maintain records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.
Continental Cement Company, L.L.C. 60

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition EU0010-03 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations 

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors – Lead

and Cadmium (Semi-Volatile Metals)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

lead and cadmium in excess of 330 μg/dscm, combined emissions, corrected to seven percent (7%) oxygen;

(§63.1204(a)(3))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, the permittee may

round the resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• If the kiln is not burning hazardous waste and the permittee is complying with the alternate mode of

compliance defined in the Comprehensive Performance Test Plan defined as follows: 

 “Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”, the permittee is not subject to this permit condition, except for the monitoring and record keeping

of the hazardous waste feed and the method of compliance.

Alternate Standard Provision:

• To utilize this provision as specified in §63.1206(b)(10), please refer to permit condition PW014.

The permittee must utilize a hazardous waste feedrate corresponding to an MTEC of 31,000 μg/dscm or less

and use of a particulate matter control device that achieves particulate matter emissions of 0.15 kg/Mg dry

feed or less; (§63.1206(b)(10)(viii)(B))

Operating Parameters:

• The permittee must comply with the semivolatile metal (cadmium and lead) emission standards by

establishing and complying with the following operating parameter limits. The permittee must base the

limits on operations during the comprehensive performance test, unless the limits are based on manufacturer

specifications. (§63.1209(n))

(1) The permittee must establish a limit on the maximum inlet temperature to the primary dry metals

emissions control device (e.g., electrostatic precipitator, baghouse) on an hourly rolling average basis

as the average of the test run averages. (§63.1209(n)(1))

(2) Maximum Feedrate of semivolatile metals. (§63.1209(n)(2))

(i) The permittee must establish feedrate limits for semivolatile metals (cadmium and lead) as

follows, except as provided by §63.1209(n)(2)(ii): (§63.1209(n)(2)(i))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln;i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 61

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(a) The permittee must establish a 12-hour rolling average limit for the feedrate of cadmium

and lead, combined, in all feedstreams as the average of the test run averages;

(§63.1209(n)(2)(i)(A))

(ii) Feedrate extrapolation. (§63.1209(n)(2)(ii))

(a) The permittee may request as part of the performance test plan under §§63.7(b) and (c) and

§§63.1207(e) and (f) to use the semivolatile metal feedrates and associated emission rates

during the comprehensive performance test to extrapolate to higher allowable feedrate

limits and emission rates. (§63.1209(n)(2)(ii)(A))

(b) The extrapolation methodology will be reviewed and approved, as warranted, by the

Administrator. The review will consider in particular whether: (§63.1209(n)(2)(ii)(B))

(i) Performance test metal feedrates are appropriate (i.e., whether feedrates are at least at

normal levels; depending on the heterogeneity of the waste, whether some level of

spiking would be appropriate; and whether the physical form and species of spiked

material is appropriate); and (§63.1209(n)(2)(ii)(B)(1))

(ii) Whether the extrapolated feedrates the permittee requests are warranted considering

historical metal feedrate data. (§63.1209(n)(2)(ii)(B)(2))

(c) The Administrator will review the performance test results in making a finding of

compliance required by §§63.6(f)(3) and 63.1206(b)(3) to ensure that the permittee has

interpreted emission test results properly and that the extrapolation procedure is appropriate

for the source. (§63.1209(n)(2)(ii)(C))

(3) The permittee must establish operating parameter limits on the particulate matter control device as

specified by §63.1209(m)(1). (§63.1209(n)(3))

(4) Maximum flue gas flowrate or production rate. (§63.1209(n)(5))

(i) As an indicator of gas residence time in the control device, the permittee must establish a limit

on the maximum flue gas flowrate, the maximum production rate, or another parameter that the

permittee documents in the site-specific test plan as an appropriate surrogate for gas residence

time, as the average of the maximum hourly rolling averages for each run. (§63.1209(n)(5)(i))

(ii) The permittee must comply with this limit on an hourly rolling average basis.

(§63.1209(n)(5)(ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee must use Method 29, provided in appendix A, part 60 of chapter 40, to determine compliance

with the emission standard for cadmium and lead (combined). (§63.1208(b)(3))

• The permittee may use any reliable analytical method to determine feedstream concentrations of metals. It

is the responsibility of the permittee to ensure that the sampling and analysis procedures are unbiased,

precise, and that the results are representative of the feedstream. For each feedstream, the permittee must

demonstrate that: (§63.1208(b)(8))

(1) Each analyte is not present above the reported level at the 80% upper confidence limit around the

mean; and (§63.1208(b)(8)(i))

(2) The analysis could have detected the presence of the constituent at or below the reported level at the

80% upper confidence limit around the mean. (See Guidance for Data Quality Assessment – Practical

Methods for Data Analysis, EPA QA/G-9, January 1998, EPA/600/R-96/084). (§63.1208(b)(8)(ii))
Continental Cement Company, L.L.C. 62

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Monitoring:

• The permittee may petition the Administrator to use CEMS for compliance monitoring for semivolatile

metals under §63.8(f) in lieu of compliance with the corresponding operating parameter limits under

§63.1209. (§63.1209(a)(5))

• The permittee shall comply with the comprehensive performance testing as specified in permit condition

PW011.

• The permittee shall monitor the inlet temperature to the primary dry metals emissions control device (e.g.,

electrostatic precipitator, baghouse) on an hourly rolling average; (§63.1209(n)(1))

• The permittee must regularly inspect the data recorded by the operating parameter monitoring system at a

sufficient frequency to ensure the control device is operating properly. An excursion is determined to have

occurred any time that the actual value of a selected operating parameter is less than the minimum operating

limit (or, if applicable, greater than the maximum operating limit) established for the parameter in

accordance with the requirements of §63.1209(m)(1)(iv)(A)(3). (§63.1209(m)(1)(iv)(C))

• The permittee shall establish a 12-hour rolling average limit for the feedrate of cadmium and lead, combined

in all feedstreams or the average of the test run averages; (§63.1209(n)(4))

• The permittee shall monitor the flue gas flowrate or production rate on an hourly rolling average;

(§63.1209(n)(5)(ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. Conduct of monitoring – The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and Maintenance of Continuous Monitoring Systems – The provisions of §63.8(c) apply except:

(§63.1209(f))

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW010.

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records on an hourly rolling average for the following:

(1) Inlet temperature to the primary dry metals emissions control device; (§63.1209(n)(1))

(2) The flue gas flowrate or production rate; (§63.1209(n)(5)(ii))

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• The permittee must install, calibrate, operate and maintain a monitoring device equipped with a recorder to

measure the values for each operating parameter selected in accordance with the requirements of

§63.1209(m)(1)(iv)(A)(1). 

• The recorder must record the detector responses at least every 60 seconds, as required in the definition of

continuous monitor. (§63.1209(m)(1)(iv)(B))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

• The permittee shall maintain records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate
Continental Cement Company, L.L.C. 63

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition EU0010-04 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations 

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Arsenic, Beryllium and Chromium (Low Volatility Metals)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

arsenic, beryllium and chromium in excess of 56 μg/dscm, combined emissions, corrected to seven percent

(7%) oxygen; (§63.1204(a)(4))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, the permittee may

round the resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• If the kiln is not burning hazardous waste and the permittee is complying with the alternate mode of

operation defined in the Comprehensive Performance Test Plan defined as follows: 

 “Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”, the permittee is not subject to this permit condition, except for the monitoring and record keeping

of the hazardous waste feed and the method of compliance.

Alternate Standard Provision:

• To utilize this provision as specified in §63.1206(b)(10), please refer to permit condition PW014.

The permittee must utilize a hazardous waste feedrate corresponding to an MTEC of 54,000 μg/dscm or less

and use of a particulate matter control device that achieves particulate matter emissions of 0.15 kg/Mg dry

feed or less; (§63.1206(b)(10)(viii)(C))

Operating Parameters:

• The permittee must comply with the low volatile metal (arsenic, beryllium, and chromium) emission

standards by establishing and complying with the following operating parameter limits. The permittee must

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 64

Installation ID Number: 173-0001 Project Number: 173-0001-0001

base the limits on operations during the comprehensive performance test, unless the limits are based on

manufacturer specifications: (§63.1209(n))

(1) The permittee must establish a limit on the maximum inlet temperature to the primary dry metals

emissions control device (e.g., electrostatic precipitator, baghouse) on an hourly rolling average basis

as the average of the test run averages. (§63.1209(n)(1))

(2) Maximum Feedrate of low volatile metals. (§63.1209(n)(2))

(a) The permittee must establish feedrate limits for low volatile metals (arsenic, beryllium and

chromium) as follows, except as provided by §63.1209(n)(2)(ii): (§63.1209(n)(2)(i))

(i) The permittee must establish a 12-hour rolling average limit for the feedrate of arsenic,

beryllium and chromium, combined, in all feedstreams as the average of the test run

averages; and (§63.1209(n)(2)(i)(B))

(ii) The permittee must establish a 12-hour rolling average limit for the feedrate of arsenic,

beryllium, and chromium, combined, in all pumpable feedstreams as the average of the test

run averages. Dual feedrate limits for both pumpable and total feedstreams are not

required, however, if the permittee bases the total feedrate limit solely on the feedrate of

pumpable feedstreams. (§63.1209(n)(2)(i)(C))

(b) Feedrate extrapolation. (§63.1209(n)(2)(ii))

(i) The permittee may request as part of the performance test plan under §§63.7(b) and (c) and

§§63.1207(e) and (f) to use the low volatile metal feedrates and associated emission rates

during the comprehensive performance test to extrapolate to higher allowable feedrate

limits and emission rates. (§63.1209(n)(2)(ii)(A))

(ii) The extrapolation methodology will be reviewed and approved, as warranted, by the

Administrator. The review will consider in particular whether: (§63.1209(n)(2)(ii)(B))

1. Performance test metal feedrates are appropriate (i.e., whether feedrates are at least at

normal levels; depending on the heterogeneity of the waste, whether some level of

spiking would be appropriate; and whether the physical form and species of spiked

material is appropriate); and (§63.1209(n)(2)(ii)(B)(1))

2. Whether the extrapolated feedrates the permittee requests are warranted considering

historical metal feedrate data. (§63.1209(n)(2)(ii)(B)(2))

(iii) The Administrator will review the performance test results in making a finding of

compliance required by §§63.6(f)(3) and 63.1206(b)(3) to ensure that the permittee has

interpreted emission test results properly and that the extrapolation procedure is appropriate

for the source. (§63.1209(n)(2)(ii)(C))

(3) The permittee must establish operating parameter limits on the particulate matter control device as

specified by §63.1209(m)(1): (§63.1209(n)(3))

(a) The permittee must install, calibrate, operate and maintain a monitoring device equipped with a

recorder to measure the values for each operating parameter selected in accordance with the

requirements of §63.1209(m)(1)(iv)(A)(1). The permittee must install, calibrate, and maintain

the monitoring equipment in accordance with the equipment manufacturer’s specifications. The

recorder must record the detector responses at least every 60 seconds, as required in the

definition of continuous monitor. (§63.1209(m)(1)(iv)(B))

(b) The permittee must regularly inspect the data recorded by the operating parameter monitoring

system at a sufficient frequency to ensure the control device is operating properly. An excursion

is determined to have occurred any time that the actual value of a selected operating parameter is

less than the minimum operating limit (or, if applicable, greater than the maximum operating

limit) established for the parameter in accordance with the requirements of

§63.1209(m)(1)(iv)(A)(3). (§63.1209(m)(1)(iv)(C))
Continental Cement Company, L.L.C. 65

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(4) Maximum flue gas flowrate or production rate: (§63.1209(n)(5))

(a) As an indicator of gas residence time in the control device, the permittee must establish a limit

on the maximum flue gas flowrate, the maximum production rate, or another parameter that the

permittee documents in the site-specific test plan as an appropriate surrogate for gas residence

time, as the average of the maximum hourly rolling averages for each run. (§63.1209(n)(5)(i))

(b) The permittee must comply with this limit on an hourly rolling average basis.

(§63.1209(n)(5)(ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee must use Method 29, provided in Appendix A, part 60 of chapter 40, to demonstrate

compliance with the emission standard for arsenic, beryllium and chromium. (§63.1208(b)(4))

• The permittee may use any reliable analytical method to determine feedstream concentrations of metals. It

is the responsibility of the permittee to ensure that the sampling and analysis procedures are unbiased,

precise, and that the results are representative of the feedstream. For each feedstream, the permittee must

demonstrate that: (§63.1208(b)(8))

(1) Each analyte is not present above the reported level at the 80% upper confidence limit around the mean;

and (§63.1208(b)(8)(i))

(2) The analysis could have detected the presence of the constituent at or below the reported level at the 80%

upper confidence limit around the mean. (See Guidance for Data Quality Assessment – Practical Methods

for Data Analysis, EPA QA/G-9, January 1998, EPA/600/R-96/084). (§63.1208(b)(8)(ii))

Monitoring:

• The permittee may petition the Administrator to use CEMS for compliance monitoring for low volatile

metals under §63.8(f) in lieu of compliance with the corresponding operating parameter limits under

§63.1209. (§63.1209(a)(5))

• The permittee shall comply with the comprehensive performance testing as specified in permit condition

PW010.

• The permittee shall monitor the inlet temperature to the primary dry metals emissions control device (e.g.,

electrostatic precipitator, baghouse) on an hourly rolling average; (§63.1209(n)(1))

• The permittee shall establish a 12-hour rolling average limit for the feedrate of low volatile metals,

combined in all feedstreams or the average of the test run averages; (§63.1209(n)(2)(i)(B))

• The permittee shall monitor the feedrate for low volatile metals, combined, in all pumpable feedstreams on a

12-hour rolling average; (§63.1209(n)(2)(i)(C))

• Control device operating parameters. The permittee must establish operating parameter limits on the

particulate matter control device as specified by §63.1209(m)(1): (§63.1209(n)(3))

• The permittee must install, calibrate, operate and maintain a monitoring device equipped with a recorder to

measure the values for each operating parameter selected in accordance with the requirements of

§63.1209(m)(1)(iv)(A)(1). The permittee must install, calibrate, and maintain the monitoring equipment in

accordance with the equipment manufacturer’s specifications. The recorder must record the detector

responses at least every 60 seconds, as required in the definition of continuous monitor.

(§63.1209(m)(1)(iv)(B))

• The permittee must regularly inspect the data recorded by the operating parameter monitoring system at a

sufficient frequency to ensure the control device is operating properly. An excursion is determined to have

occurred any time that the actual value of a selected operating parameter is less than the minimum operating
Continental Cement Company, L.L.C. 66

Installation ID Number: 173-0001 Project Number: 173-0001-0001

limit (or, if applicable, greater than the maximum operating limit) established for the parameter in

accordance with the requirements of §63.1209(m)(1)(iv)(A)(3). (§63.1209(m)(1)(iv)(C))

• The permittee shall monitor the flue gas flowrate or production rate on an hourly rolling average;

(§63.1209(n)(5)(ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. The permittee must begin calculating rolling averages anew (i.e., without

considering previous recordings) when the permittee begins complying with the operating parameter limits

for the alternative mode of operation. (§63.1209(q))2

• Conduct of monitoring. The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and maintenance of continuous monitoring systems. The provisions of §63.8(c) apply except:

[§63.1209(f)]

(1) §63.8(c)(3). The requirements of §63.1211(c), that requires CMSs to be installed, calibrated, and

operational on the compliance date, shall be complied with instead of §63.8(c)(3); (§63.1209(f)(1))

(2) §§63.8(c)(4)(i), (c)(5), and (c)(7)(i)(C) pertaining to COMS apply only to hazardous waste burning

cement kilns. (§63.1209(f)(3))

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition EU0010-05 Cement Kiln 

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations 

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Carbon Monoxide and Hydrocarbons

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

carbon monoxide and hydrocarbons, either (§63.1204(a)(5)(ii)):

(1) Carbon monoxide in the kiln stack in excess of 100 parts per million by volume, over an hourly rolling

average (monitored continuously with a continuous emissions monitoring system), dry basis and

corrected to seven percent (7%) oxygen. If the permittee elects to comply with this carbon monoxide

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln;i.e.,

calculations of averages for that mode are seamless.

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 67

Installation ID Number: 173-0001 Project Number: 173-0001-0001

standard rather than the hydrocarbon standard under §63.1204(a)(5)(ii)(A), the permittee must also

document that, during the destruction and removal efficiency (DRE) test runs or their equivalent as

provided by §63.1206(b)(7), hydrocarbons in the by-pass duct or mid-kiln gas sampling system do not

exceed 20 parts per million by volume during those runs, over an hourly rolling average (monitored

continuously with a continuous emissions monitoring system), dry basis, corrected to seven percent

(7%) oxygen, and reported as propane, or (§63.1204(a)(5)(ii)(B))

(2) Hydrocarbons in the kiln stack in excess of 20 parts per million by volume, over an hourly rolling

average (monitored continuously with a continuous emissions monitoring system), dry basis, corrected

to seven percent (7%) oxygen, and reported as propane. (§63.1204(a)(5)(ii)(A))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, you may round the

resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• If the kiln is not burning hazardous waste and the permittee is complying with the alternate mode of

compliance defined in the Comprehensive Performance Test Plan as follows: 

 “Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect”, the permittee is not subject to this permit condition, except for the monitoring and record keeping of

the hazardous waste feed and the method of compliance.

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee may use applicable test methods in EPA Publication SW-846, as incorporated by reference in

§63.1208(a), as necessary to demonstrate compliance with requirements of this subpart, except as otherwise

specified in §63.1208(b)(2) – (b)(6). (§63.1208(b)(7))

Monitoring:

• Carbon monoxide standard using continuous emissions monitoring system and document compliance with

the hydrocarbon standard during the destruction and removal efficiency performance test or its equivalent.

(§63.1206(b)(6))

(1) If a DRE test performed pursuant to 63.1207(c)(2)is acceptable as documentation of compliance with

the DRE standard, the permittee may use the highest hourly rolling average hydrocarbon level

achieved during the DRE test runs to document compliance with the hydrocarbon standard. An

acceptable DRE test is any test for which the data and results are determined to meet quality assurance

objectives (on a site-specific basis) such that the results adequately demonstrate compliance with the

DRE standard.

(2) If during this acceptable DRE test, the permittee did not obtain hydrocarbon emissions data sufficient

to document compliance with the hydrocarbon standard, the permittee must either: (§63.1206(b)(6)(ii))

(a) Perform, as part of the performance test, an “equivalent DRE test” to document compliance with

the hydrocarbon standard. An equivalent DRE test is comprised of a minimum of three runs

each with a minimum duration of one hour during which the permittee operates the combustor as

close as reasonably possible to the operating parameter limits that the permittee established

based on the initial DRE test. The permittee must use the highest hourly rolling average

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 68

Installation ID Number: 173-0001 Project Number: 173-0001-0001

hydrocarbon emission level achieved during the equivalent DRE test to document compliance

with the hydrocarbon standard; or (§63.1206(b)(6)(ii)(A))

(b) Perform a DRE test as part of the performance test. (§63.1206(b)(6)(ii)(B))

• CEMS - The permittee must use either a carbon monoxide or hydrocarbon CEMS to demonstrate and

monitor compliance with the carbon monoxide and hydrocarbon standard under this subpart. The permittee

must also use an oxygen CEMS to continuously correct the carbon monoxide or hydrocarbon levels to seven

percent (7%) oxygen. (§63.1209(a)(1)(i))

• CEMS - The permittee must install, calibrate, maintain and continuously operate the CEMS and COMS in

compliance with the quality assurance procedures provided in the appendix to this subpart and Performance

Specifications 4B (carbon monoxide and oxygen), and 8A (hydrocarbons) in Appendix B, part 60 of chapter

40. (§63.1209(a)(2))

• CO CEMS - Except as provided by §63.1209(a)(3)(ii), if a carbon monoxide CEMS detects a response that

results in a one-minute average at or above the 3,000 ppmv span level required by Performance

Specification 4B in Appendix B, part 60 of chapter 40, the one-minute average must be recorded as 10,000

ppmv. The one-minute 10,000 ppmv value must be used for calculating the hourly rolling average carbon

monoxide level. (§63.1209(a)(3)(i))

• Carbon monoxide CEMS that use a span value of 10,000 ppmv when one-minute carbon monoxide levels

are equal to or exceed 3,000 ppmv are not subject to §63.1209(a)(3)(i) . Carbon monoxide CEMS that use a

span value of 10,000 are subject to the same CEMS performance and equipment specifications when

operating in the ranges of 3,000 ppmv to 10,000 ppmv that are provided by Performance Specification 4B

for other carbon monoxide CEMS, except: (§63.1209(a)(3)(ii))

(1) Calibration drift must be less than 300 ppmv; and (§63.1209(a)(3)(ii)(A))

(2) Calibration error must be less than 500 ppmv. (§63.1209(a)(3)(ii)(B))

• Hydrocarbon CEMS – Except as provided by §63.1209(a)(4)(ii), if a hydrocarbon CEMS detects a response

that results in a one-minute average at or above the 100 ppmv span level required by Performance

Specification 8A in Appendix B, part 60 of chapter 40, the one-minute average must be recorded as 500

ppmv. The one-minute 500 ppmv value must be used for calculating the hourly rolling average HC level.

(§63.1209(a)(4)(i))

• Hydrocarbon CEMS that use a span value of 500 ppmv when one-minute hydrocarbon levels are equal to or

exceed 100 ppmv are not subject to §63.1209(a)(4)(i). Hydrocarbon CEMS that use a span value of 500

ppmv are subject to the same CEMS performance and equipment specifications when operating in the range

of 100 ppmv to 500 ppmv that are provided by Performance Specification 8A for other hydrocarbon CEMS,

except: (§63.1209(a)(4)(ii))

(1) The zero and high-level calibration gas must have a hydrocarbon level of between 0 and 100 ppmv,

and between 250 and 450 ppmv, respectively; (§63.1209(a)(4)(ii)(A))

(2) The strip chart recorder, computer, or digital recorder must be capable of recording all readings within

the CEM measurement range and must have a resolution of 2.5 ppmv; (§63.1209(a)(4)(ii)(B))

(3) The CEMS calibration must not differ by more than ±15 ppmv after each 24-hour period of the seven

day test at both zero and high levels; (§63.1209(a)(4)(ii)(C))

(4) The calibration error must be no greater than 25 ppmv; and (§63.1209(a)(4)(ii)(D))

(5) The zero level, mid-level, and high-level calibration gas used to determine calibration error must have

a hydrocarbon level of 0-200 ppmv, 150-200 ppmv, and 350-400 ppmv, respectively.

(§63.1209(a)(4)(ii)(E))

• The requirements of §§63.8(d) (Quality control program) and (e) (Performance evaluation of continuous

monitoring systems) apply, except that the permittee must conduct performance evaluations of components

of the CMS under the frequency and procedures (for example, submittal of performance evaluation test plan

for review and approval) applicable to performance tests as provided by §63.1207. (§63.1209(d)(1))
Continental Cement Company, L.L.C. 69

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee must comply with the quality assurance procedures for CEMS prescribed in Appendix to

Subpart EEE of Part 63 – Quality Assurance Procedures for Continuous Emissions Monitors Used for

Hazardous Waste Combustors. (§63.1209(d)(2))

• The permittee must comply with the quality assurance procedures for CEMS prescribed in Appendix to

Subpart EEE of Part 63 – Quality Assurance Procedures for Continuous Emissions Monitors Used for

Hazardous Waste Combustors. (§63.1209(d)(2))

• Conduct of monitoring – The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and Maintenance of Continuous Monitoring Systems – The provisions of §63.8(c) apply except:

(§63.1209(f))

• The performance specifications for carbon monoxide, hydrocarbon and oxygen CEMSs in subpart B, part 60

of chapter 40 requires detectors to measure the sample concentration at least once every 15 seconds for

calculating an average emission rate once every 60 seconds shall be complied with instead of

§63.8(c)(4)(ii); and (§63.1209(f)(2))

• Sections 63.8(c)(4)(i), (c)(5), and (c)(7)(i)(C) pertaining to COMS apply only to owners and operators of

hazardous waste burning cement kilns. (§63.1209(f)(3))

Calculation of Rolling Averages:

• The carbon monoxide or hydrocarbon CEMS must begin recording one-minute average values by 12:01 am

and hourly rolling average values by 1:01 am, when 60 one-minute values will be available for calculating

the initial hourly rolling average for those sources that come into compliance on the regulatory compliance

date. Sources that elect to come into compliance before the regulatory compliance date must begin recording

one-minute and hourly rolling average values 60 seconds and 60 minutes (when 60 one-minute values will

be available for calculating the initial rolling average), respectively, from the time at which compliance

begins. (§63.1209(a)(6)(i))

• The permittee must ignore periods of time when one-minute values are not available for calculating the

hourly rolling average. When one-minute values become available again, the first one-minute value is

added to the previous 59 values to calculate the hourly rolling average. (§63.1209(a)(6)(ii))2

• Except as provided by paragraph §63.1209(a)(6)(iii)(B) of this section, the permittee must continue

monitoring carbon monoxide and hydrocarbons when the hazardous waste feed is cutoff if the source is

operating. The permittee must not resume feeding hazardous waste if the emission levels exceed the

standard.(§63.1209(a)(6)(iii)(A))

• The permittee is not subject to the CEMS requirement of this subpart during periods of time the permittee

meets the requirement of §63.1206(b)(1)(ii) (compliance with emission standards for nonhazardous waste

burning sources when the permittee is not burning hazardous waste). (§63.1209(a)(6)(iii)(B))

• The performance specifications for carbon monoxide, hydrocarbon, and oxygen CEMSs in subpart B, part

60 of this chapter that requires detectors to measure the sample concentration at least once every 15 seconds

for calculating an average emission rate once every 60 seconds shall be complied with instead of section

63.8 (c)(4)(ii); and....(§63.1209(f)(2))

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW010.

• The permittee shall maintain records of all calibration records obtained during compliance with the quality

assurance procedures provide in the appendix to this subpart and Performance Specifications 4B (carbon

monoxide and oxygen), and 8A (hydrocarbons) in Appendix B, part 60 of chapter 40. (§63.1209(a)(2))

• The permittee shall maintain records of the quality assurance procedures provided in the appendix to this

subpart and Performance Specifications 4B (carbon monoxide and oxygen), and 8A (hydrocarbons) in

Appendix B, part 60 of chapter 40. (§63.1209(a)(2))

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln;i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 70

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall maintain records of the quality assurance procedures for CEMS prescribed in Appendix

to Subpart EEE of Part 63 – Quality Assurance Procedures for Continuous Emissions Monitors Used for

Hazardous Waste Combustors. (§63.1209(d)(2))

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition EU0010-06 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations 

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Hydrochloric Acid and Chlorine Gas

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

hydrochloric acid and chlorine gas in excess of 130 parts per million by volume, combined emissions,

expressed as hydrochloric acid equivalents, dry basis, corrected to seven percent (7%) oxygen.

(§63.1204(a)(6))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, the permittee may

round the resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• If the kiln is not burning hazardous waste and the permittee is complying with the alternate mode of

compliance defined in the Comprehensive Performance Test Plan as follows: 

“Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 71

Installation ID Number: 173-0001 Project Number: 173-0001-0001

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”, the permittee is not subject to this permit condition, except for the monitoring and record keeping

of the hazardous waste feed and the method of compliance.

Alternate Standard Provision:

• To utilize this provision as specified in §63.1206(b)(10), please refer to permit condition PW014.

The permittee must utilize a hazardous waste chlorine feedrate corresponding to an MTEC of 720,000

μg/dscm or less; (§63.1206(b)(10)(viii)(D))

Operating Parameters:

• The permittee must comply with the hydrogen chloride and chlorine gas emissions standard by establishing

and complying with the following operating parameter limits. The permittee must base the limits on

operations during the comprehensive performance test, unless the limits are based on manufacturer

specifications. (§63.1209(o))

(1) The permittee must establish a 12-hour rolling average limit for the total feedrate of chlorine (organic

and inorganic) in all feedstreams as the average of the test run averages. (§63.1209(o)(1))

(2) Maximum flue gas flowrate or production rate: (§63.1209(o)(2))

(a) As an indicator of gas residence time in the control device, the permittee must establish a limit

on the maximum flue gas flowrate, the maximum production rate, or another parameter that the

permittee documents in the site-specific test plan as an appropriate surrogate for gas residence

time, as the average of the maximum hourly rolling averages for each run. (§63.1209(o)(2)(i))

(b) The permittee must comply with this limit on an hourly rolling average basis;

(§63.1209(o)(2)(ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee may use Methods 26A, 320 or 321, provided in Appendix A, part 60 of chapter 40, to

demonstrate compliance with the emission standard for hydrochloric acid and chlorine gas (combined). The

permittee may use Methods 320 or 321 to make major source determinations under §63.9(b)(2)(v).

(§63.1208(b)(5))

• The permittee may use any reliable analytical method to determine feedstream concentrations of chlorine.

It is the responsibility of the permittee to ensure that the sampling and analysis procedures are unbiased,

precise, and that the results are representative of the feedstream. For each feedstream, the permittee must

demonstrate that: (§63.1208(b)(8))

(1) Each analyte is not present above the reported level at the 80% upper confidence limit around the

mean; and (§63.1208(b)(8)(i))

(2) The analysis could have detected the presence of the constituent at or below the reported level at the

80% upper confidence limit around the mean. (See Guidance for Data Quality Assessment – Practical

Methods for Data Analysis, EPA QA/G-9, January 1998, EPA/600/R-96/084). (§63.1208(b)(8)(ii))

Monitoring:

• The permittee may petition the Administrator to use CEMS for compliance monitoring for hydrochloric

acid/chlorine gas under §63.8(f) in lieu of compliance with the corresponding operating parameter limits

under §63.1209. (§63.1209(a)(5))

• The permittee shall comply with the comprehensive performance testing as specified in permit condition

PW011.
Continental Cement Company, L.L.C. 72

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall monitor the feedrate of total chlorine and chloride (organic and inorganic) in all

feedstreams on an 12- hour rolling average; (§63.1209(o)(1))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. 

• Conduct of monitoring. The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and maintenance of continuous monitoring systems. The provisions of §63.8(c) apply except:

(§63.1209(f))

(1) §63.8(c)(3). The requirements of §63.1211(c), that requires CMSs to be installed, calibrated, and

operational on the compliance date, shall be complied with instead of §63.8(c)(3); (§63.1209(f)(1))

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW011.

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records on an hourly rolling average for the following:

(1) The flue gas flowrate or production rate; (§63.1209(o)(2)(ii))

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records on a 12-hour rolling average for the following:

(1) The feedrate total chlorine and chloride (organic and inorganic) in all feedstreams; (§63.1209(o)(1))

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• The permittee shall maintain records on the calibration checks of the CMS equipment.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. 

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.
Continental Cement Company, L.L.C. 73

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition EU0010-07 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Particulate Matter (NOTE: When the permittee complies with the particulate matter requirements

under §63.1207(a)(7) , the permittee is exempt from the New Source Performance Standard for

particulate matter and opacity under §60.60.)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

particulate matter in excess of 0.15 kg/Mg dry feed. (§63.1204(a)(7))

• The permittee must use suitable methods to determine the kiln raw material feedrate. (§63.1204(a)(7)(i))

• Except as provided in §63.1204(a)(7)(iii), the permittee must compute the particulate matter emission rate,

E from the following equation: E = (Cs ×Qsd ) P

Where:

E = emission rate of particulate matter, kg/Mg of kiln raw material feed;

Cs = concentration of particulate matter, kg/dscm;

Qsd = volumetric flowrate of effluent gas, dscm/hr; and,

P = total kiln raw material feed (dry basis), Mg/hr (§63.1204(a)(7)(ii))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, the permittee may

round the resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• PM & Opacity – CEMS correlation tests – Any particulate matter and opacity standards of parts 60, 61, 63,

264, 265 and 266 of this chapter (i.e., any title 40 particulate or opacity standards) applicable to a hazardous

waste combustor do not apply while the permittee conducts particulate matter continuous emissions

monitoring system (CEMS) correlation tests under the conditions of §63.1206(b)(8)(iii) through (vii).

(§63.1206(b)(8)(i))

• PM & Opacity – CEMS correlation tests - Any permit or other emissions or operating parameter limits or

conditions, including any limitation on workplace practices, that are applicable to hazardous waste

combustors to ensure compliance with any particulate matter and opacity standards of parts 60, 61, 63, 264,

265 and 266 of this chapter (i.e., any title 40 particulate or opacity standards) do not apply while the

permittee conducts particulate matter CEMS correlation tests under the conditions of §63.1206(b)(8)(iii)

through (vii). (§63.1206(b)(8)(ii))

• For the provisions of this section to apply, the permittee must: (§63.1206(b)(8)(iii))

(1) Develop a particulate matter CEMS correlation test plan that includes the following information. This

test plan may be included as part of the comprehensive performance test plan required under

§§63.1207(e) and (f): (§63.1206(b)(8)(iii)(A))

(a) Number of test conditions and number of runs for each test condition; (§63.1206(b)(8)(iii)(A)(1))

(b) Target particulate matter emission level for each test condition; (§63.1206(b)(8)(iii)(A)(2))

(c) How the permittee plans to modify operations to attain the desired particulate matter emission

levels; and (§63.1206(b)(8)(iii)(A)(3))

(d) Anticipated normal particulate matter emission levels; and (§63.1206(b)(8)(iii)(A)(4))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 74

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The particulate matter and opacity standards and associated operating limits and conditions will not be

waived for more than 96 hours, in the aggregate, for a correlation test, including all runs of all test

conditions, unless more time is approved by the Administrator. (§63.1206(b)(8)(v))

• The permittee must return to operating conditions indicative of compliance with the applicable particulate

matter and opacity standards as soon as possible after correlation testing is completed. (§63.1206(b)(8)(vii))

• If the kiln is not burning hazardous waste, the permittee may comply with the alternate mode of operation

defined in the Comprehensive Performance Test Plan defined as follows: 

“Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”.

Alternate Standard Provision:

If the permittee selects the alternate emission standard provision for semivolatile metals and/or low volatile

metals, the permittee must utilize a particulate matter control device that achieves particulate matter

emissions of 0.15 kg/Mg dry feed or less; (§63.1206(b)(10)(viii)(B and/or C))

Operating Parameters:

• The permittee must comply with the particulate matter emission standard by establishing and complying

with the following operating parameter limits. The permittee must base the limits on operations during the

comprehensive performance test, unless the limits are based on manufacturer specifications. (§63.1209(m))

(1) Control Device Operating Parameter Limits (OPLs) (§63.1209(m)(1)(iii))

(2) Maximum flue gas flowrate or production rate: (§63.1209(m)(2))

(a) As an indicator of gas residence time in the control device, the permittee must establish a limit

on the maximum flue gas flowrate, the maximum production rate, or another parameter that the

permittee documents in the site-specific test plan as an appropriate surrogate for gas residence

time, as the average of the maximum hourly rolling averages for each run. (§63.1209(m)(2)(i))

(b) The permittee must comply with this limit on an hourly rolling average basis:

(§63.1209(m)(2)(ii))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§3.1209(q))

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee must use Methods 5 or 5I, provided in Appendix A, part 60 of chapter 40, to demonstrate

compliance with the emission standard for particulate matter. (§63.1208(b)(6))

• The permittee may use any reliable analytical method to determine feedstream concentrations of metals,

chlorine and other constituents. It is the responsibility of the permittee to ensure that the sampling and

analysis procedures are unbiased, precise, and that the results are representative of the feedstream. For each

feedstream, the permittee must demonstrate that: (§63.1208(b)(8))

(1) Each analyte is not present above the reported level at the 80% upper confidence limit around the

mean; and (§63.1208(b)(8)(i))

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless.
Continental Cement Company, L.L.C. 75

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(2) The analysis could have detected the presence of the constituent at or below the reported level at the

80% upper confidence limit around the mean. (See Guidance for Data Quality Assessment – Practical

Methods for Data Analysis, EPA QA/G-9, January 1998, EPA/600/R-96/084). (§63.1208(b)(8)(ii))

Monitoring:

• The stack sampling team must be on-site and prepared to perform correlation testing no later than 24 hours

after the permittee modifies operations to attain the desired particulate matter emissions concentrations,

unless the permittee documents in the correlation test plan that a longer period of conditioning is

appropriate. (§63.1206(b)(8)(vi))

• CEMS - The permittee must install, calibrate, maintain and operate a particulate matter CEMS to

demonstrate and monitor compliance with the particulate matter standards under this subpart. However,

compliance with the requirements in their section to install, calibrate, maintain and operate the PM CEMS is

not required until such time that the Agency promulgates all performance specifications and operational

requirements applicable to PM CEMS. (§63.1209(a)(1)(iii))

• The permittee may petition the Administrator to use CEMS for compliance monitoring for particulate

matter, mercury, semivolatile metals, low volatile metals, and hydrochloric acid/chlorine gas under §63.8(f)

in lieu of compliance with the corresponding operating parameter limits under §63.1209. (§63.1209(a)(5))

• The permittee must comply with the quality assurance procedures for CEMS prescribed in Appendix to

Subpart EEE of Part 63 – Quality Assurance Procedures for Continuous Emissions Monitors Used for

Hazardous Waste Combustors. (§63.1209(d)(2))

• The permittee shall monitor the flue gas flowrate or production rate on an hourly rolling average;

(§63.1209(m)(2))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW011.

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records on an hourly rolling average for the following:

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• The permittee shall maintain records of the CEMS correlation test plan that includes the following

information. This test plan may be included as part of the comprehensive performance test plan required

under §§63.1207(e) and (f): (§63.1206(b)(8)(iii)(A))

(1) Number of test conditions and number of runs for each test condition; (§63.1206(b)(8)(iii)(A)(1))

(2) Target particulate matter emission level for each test condition; (§63.1206(b)(8)(iii)(A)(2))

(3) How the permittee plans to modify operations to attain the desired particulate matter emission levels;

and (§63.1206(b)(8)(iii)(A)(3))

(4) Anticipated normal particulate matter emission levels. (§63.1206(b)(8)(iii)(A)(4))

• The permittee shall maintain records of the CEMS correlation test plan;

• The permittee shall maintain records of the calibration checks on the CMS equipment.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))
Continental Cement Company, L.L.C. 76

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall maintain records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• Submit the particulate matter CEMS correlation test plan to the Administrator for approval at least 90

calendar days before the correlation test is scheduled to be conducted. (§63.1206(b)(8)(iii)(B))

• The Administrator will review and approve/disapprove the correlation test plan under the procedures for

review and approval of the site-specific test plan provided by §63.7(c)(3)(i) and (iii). If the Administrator

fails to approve or disapprove the correlation test plan within the time period specified by §63.7(c)(3)(i), the

plan is considered approved, unless the Administrator has requested additional information.

(§63.1206(b)(8)(iv))

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition EU0010-08 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Opacity (NOTE: When the permittee complies with the particulate matter requirements under

§63.1207(a)(7), the permittee is exempt from the New Source Performance Standard for particulate

matter and opacity under §60.60.)

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• The permittee must not discharge or cause combustion gases to be emitted into the atmosphere that contain

an opacity greater than 20 percent. (§63.1204(a)(7))

• The emission limits provided by §63.1204(a) are presented with two significant figures. Although the

permittee must perform intermediate calculations using at least three significant figures, the permittee may

round the resultant emission levels to two significant figures to document compliance. (§63.1204(f))

• PM & Opacity – CEMS correlation tests – Any particulate matter and opacity standards of parts 60, 61, 63,

264, 265 and 266 of this chapter (i.e., any title 40 particulate or opacity standards) applicable to a hazardous

waste combustor do not apply while the permittee conduct particulate matter continuous emissions

monitoring system (CEMS) correlation tests under the conditions of §63.1206(b)(8)(iii) through (vii).

(§63.1206(b)(8)(i))

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 77

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• PM & Opacity – CEMS correlation tests - Any permit or other emissions or operating parameter limits or

conditions, including any limitation on workplace practices, that are applicable to hazardous waste

combustors to ensure compliance with any particulate matter and opacity standards of parts 60, 61, 63, 264,

265 and 266 of this chapter (i.e., any title 40 particulate or opacity standards) do not apply while the

permittee conducts particulate matter CEMS correlation tests under the conditions of §63.1206(b)(8)(iii)

through (vii). (§63.1206(b)(8)(ii))

• The particulate matter and opacity standards and associated operating limits and conditions will not be

waived for more than 96 hours, in the aggregate, for a correlation test, including all runs of all test

conditions. (§63.1206(b)(8)(v))

• The permittee must return to operating conditions indicative of compliance with the applicable particulate

matter and opacity standards as soon as possible after correlation testing is completed. (§63.1206(b)(8)(vii))

Test Methods:

• The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• If the permittee determines compliance with the opacity standard under the monitoring requirements of

§63.1209(a)(1)(iv) and (a)(1)(v), the permittee must use Method 9, provided in Appendix A, part 60 of

chapter 40. (§63.1208(b)(9))

Monitoring:

• COMS – For cement kilns, except as provided by §63.1209(a)(1)(iv) and (a)(1)(v), the permittee must use a

COMS to demonstrate and monitor compliance with the opacity standard under §§63.1204(a)(7) and (b)(7)

at each point where emissions are vented form these affected sources including the bypass stack of a

preheater or preheater/precalciner kiln with dual stacks. (§63.1209(a)(1)(ii))

(1) The permittee must maintain and operate each COMS in accordance with the requirements of §63.8(c)

except for the requirements under §63.8(c)(3). The requirements of §63.1211(d) shall be complied

with instead of §63.8(c)(3); and (§63.1209(a)(1)(ii)(A))

(2) Compliance is based on six-minute block average. (§63.1209(a)(1)(ii)(B))

• COMS - The permittee must install, calibrate, maintain and continuously operate the CEMS and COMS in

compliance with the quality assurance procedures provided in the appendix to this subpart and Performance

Specifications 1 (opacity) in Appendix B, part 60 of chapter 40. (§63.1209(a)(2))

• Conduct of monitoring – The provisions of §63.8(b) apply. (§63.1209(e))

• Operation and Maintenance of Continuous Monitoring Systems – The provisions of §63.8(c) apply except:

(§63.1209(f))

• Sections 63.8(c)(4)(i), (c)(5) and (c)(7)(i)(C) pertaining to COMS apply only to owners and operators of

hazardous waste burning cement kilns. (§63.1209(f)(3))

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW010.

• The permittee shall maintain records of the data recorded by the COMs; (§63.1209(a)(1)(ii)) or

• The permittee shall maintain records of all observation results (see Attachment B), noting:

(1) Whether any air emissions (except for water vapor) were visible from the emission units,

(2) All emission units from which visible emissions occurred, and

(3) Whether the visible emissions were normal for the process.

• The permittee shall maintain records of any Method 9 test performed in accordance with this permit

condition.

• The permittee shall maintain records of any equipment malfunctions.

• The permittee shall maintain records of all calibration records obtained during compliance with the quality

assurance procedures provide in the Appendix to this subpart and Performance Specifications 1 (opacity) in

Appendix B, part 60 of chapter 40. (§63.1209(a)(2))
Continental Cement Company, L.L.C. 78

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall maintain records of the quality assurance procedures provided in the appendix to this

subpart and Performance Specifications 1 (opacity) in Appendix B, part 60 of chapter 40. (§63.1209(a)(2))

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition EU0010-09 Cement Kiln

10 CSR 10-6.075

Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE1

National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors –

Destruction and Removal Efficiency (DRE) – Principal Organic Hazardous Constituent

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

• Except as provided in §63.1204(c)(2), the permittee must achieve a destruction and removal efficiency

(DRE) of 99.99% for each principle organic hazardous constituent (POHC) designated under

§63.1204(c)(3). The permittee must calculate DRE for each POHC from the following equation: 

DRE = [ ] 1− ( ) Wout Win ×100%

Where:

Win = mass feedrate of one POHC in a waste feedstream; and

Wout = mass emission rate of the same POHC present in exhaust emissions prior to release to the

atmosphere. (63.1204(c)(1))

• If the permittee burns the dioxin-listed hazardous wastes FO20, FO21, FO22, FO23, FO26 or FO27 (see

§261.31 of this chapter), the permittee must achieve a DRE of 99.9999% for each POHC that the permittee

designates under §63.1204(c)(3). The permittee must demonstrate this DRE performance on POHCs that

are more difficult to incinerate that tetro-, penta-, and hexachlorodibenzo-p-dioxins and dibenzofurans. The

permittee must use the equation in §63.1204(c)(1) to calculate DRE for each POHC. In addition, the

 

1 Applicable only to the cement kiln as of September 30, 2004. The date of September 30, 2004 reflects the one-year extension granted

to Continental Cement. The regulatory compliance date is September 30, 2003.
Continental Cement Company, L.L.C. 79

Installation ID Number: 173-0001 Project Number: 173-0001-0001

permittee must notify the Administrator of the intent to incinerate hazardous wastes FO20, FO21, FO22,

FO23, FO26 or FO27. (§63.1204(c)(2))

• The permittee must treat the POHCs in the waste feed that are specified under §63.1204(c)(3)(ii) to the

extent required by §63.1204(c)(1) and §63.1204(c)(2). (§63.1204(c)(3)(i))

• The permittee must specify one or more POHCs from the list of hazardous air pollutants established by 42

U.S.C. 7412(b)(1), excluding caprolactam (CAS number 105602) as provided by §63.60, for each waste to

be burned. The permittee must base this specification on the degree of difficulty of incineration of the

organic constituents in the waste and on their concentration or mass in the waste feed, considering the

results of waste analyses or other data and information. (§63.1204(c)(3)(ii))

• If the kiln is not burning hazardous waste and the permittee is complying with the alternate mode of

operation defined in the Comprehensive Performance Test Plan defined as follows: 

“Mode B2, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs,

HCl & CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard,

compliance with the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet

temperature will be determined by calculated three-hour rolling average of recorded one-minute averages.

All Subpart EEE standards and regulations not specifically mentioned in this paragraph will remain in

effect.”, the permittee is not subject to this permit condition, except for the monitoring and record keeping

of the hazardous waste feed and the method of compliance.

Operating Parameters:

• To remain in compliance with the DRE standard, the permittee must establish operating limits during the

comprehensive performance test (or during a previous DRE test under provisions of §63.1206(b)(7)) for the

following parameters, unless the limits are based on manufacturer specifications and comply with those

limits at all times that hazardous waste remains in the combustion chamber (i.e., the hazardous waste

residence time has not transpired since the hazardous waste feed cutoff system was activated): (§63.1209(j))

(1) Minimum combustion chamber temperature: (§63.1209(j)(1))

(a) The permittee must measure the temperature of each combustion chamber at a location that best

represents, as practicable, the bulk gas temperature in the combustion zone. The permittee must

document the temperature measurement location in the test plan the permittee submits under

§63.1207(e); (§63.1209(j)(1)(i))

(b) The permittee must establish a minimum hourly rolling average limit as the average of the test

run averages; (§63.1209(j)(1)(ii))

(2) Maximum flue gas flowrate or production rate: (§63.1209(j)(2))

(a) As an indicator of gas residence time in the control device the permittee must establish and

comply with a limit on the maximum flue gas flowrate, the maximum production rate, or another

parameter that the permittee documents in the site-specific test plan as an appropriate surrogate

for gas residence time, as the average of the maximum hourly rolling averages for each run;

(§63.1209(j)(2)(i))

(b) The permittee must comply with this limit on an hourly rolling average basis; (§63.1209(j)(2)(ii))

(3) Maximum hazardous waste feedrate: (§63.1209(j)(3))

(a) The permittee must establish limits on the maximum pumpable and total (i.e., pumpable and

nonpumpable) hazardous waste feedrate for each location where hazardous waste is fed;

(§63.1209(j)(3)(i))

(b) The permittee must establish the limits as the average of the maximum hourly rolling averages

for each run. (§63.1209(j)(3)(ii))

 

2 Mode B is not a change in operations, but a change in compliance requirements when hazardous waste is not in the kiln; i.e.,

calculations of averages for that mode are seamless. 
Continental Cement Company, L.L.C. 80

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(c) The permittee must comply with the feedrate limit(s) on a hourly rolling average basis;

(§63.1209(j)(3)(iii))

(4) The permittee must specify operating parameters and limits to ensure that good operation of each

hazardous waste firing system is maintained. (§63.1209(j)(4)

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Test Methods:

The permittee must use the following test methods to determine compliance with the emission standards:

(§63.1208(b))

• The permittee may use applicable test methods in EPA Publication SW-846, as incorporated by reference in

§63.1208(a), as necessary to demonstrate compliance with requirements of this subpart, except as otherwise

specified in §63.1208(b)(2) – (b)(6). (§63.1208(b)(7))

• The permittee may use any reliable analytical method to determine feedstream concentrations of metals,

chlorine and other constituents. It is the responsibility of the permittee to ensure that the sampling and

analysis procedures are unbiased, precise, and that the results are representative of the feedstream. For each

feedstream, the permittee must demonstrate that: (§63.1208(b)(8))

(1) Each analyte is not present above the reported level at the 80% upper confidence limit around the

mean; and (§63.1208(b)(8)(i))

(2) The analysis could have detected the presence of the constituent at or below the reported level at the

80% upper confidence limit around the mean. (See Guidance for Data Quality Assessment – Practical

Methods for Data Analysis, EPA QA/G-9, January 1998, EPA/600/R-96/084). (§63.1208(b)(8)(ii))

Monitoring:

• Except as provided in §63.1206(b)(7)(ii) and (b)(7)(iii), The permittee: (§63.1206(b)(7)(i))

(1) Must document compliance with the DRE standard under §§63.1203 through 63.1205 only once

provided that the permittee does not modify the source after the DRE test in a manner that could affect

the ability of the source to achieve the DRE standard; and (§63.1206(b)(7)(i)(A))

(2) May use any DRE test data that documents that the source achieves the required level of DRE

provided.(§63.1206(b)(7)(i)(B))

(a) The permittee had not modified the design or operation or its source in a manner that could affect

the ability of the source to achieve DRE standard since the DRE was performed; and,

(§63.1206(b)(7)(i)(B)(1))

(b) The DRE test data meet quality assurance objectives determined on a site-specific basis.

(§63.1206(b)(7)(i)(B)(2))

• For sources that feed hazardous waste at a location in the combustion system other than the normal flame

zone, the permittee must demonstrate compliance with the DRE standard during each comprehensive

performance test: (§63.1206(b)(7)(ii))

• For sources that do not use DRE previous testing to document conformance with the DRE standard pursuant

to Sec. 63.1207(c)(2), the permittee must perform DRE testing during the initial comprehensive

performance test. (§63.1206(b)(7)(iii))

• Minimum combustion chamber temperature. (§63.1209(j)(1))

(1) The permittee must measure the temperature of each combustion chamber at a location that best

represents, as practicable, the bulk gas temperature in the combustion zone. The permittee must

document the temperature measurement location in the test plan the permittee submit under §

63.1207(e); (§63.1209(j)(1)(i))

(2) The permittee must establish a minimum hourly rolling average limit as the average of the test run

averages; (§63.1209(j)(1)(ii))
Continental Cement Company, L.L.C. 81

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Maximum flue gas flowrate or production rate. (§63.1209(j)(2))

(1) As an indicator of gas residence time in the control device, permittee must establish and comply with a

limit on the maximum flue gas flowrate, the maximum production rate, or another parameter that the

permittee document in the site-specific test plan as an appropriate surrogate for gas residence time, as

the average of the maximum hourly rolling averages for each run. (§63.1209(j)(2)(i))

(2) Permittee must comply with this limit on a hourly rolling average basis; (§63.1209(j)(2)(ii))

• Maximum hazardous waste feedrate. (§63.1209(j)(3)) 

(1) The permittee must establish limits on the maximum pumpable and total (i.e., pumpable and

nonpumpable) hazardous waste feedrate for each location where hazardous waste is fed.

(§63.1209(j)(3)(i)) 

(2) The permittee must establish the limits as the average of the maximum hourly rolling averages for

each run. (§63.1209(j)(3)(ii))

(3) The permittee must comply with the feedrate limit(s) on a hourly rolling average basis;

(§63.1209(j)(1)(iii))

• Operation of waste firing system. The permittee must specify operating parameters and limits to ensure that

good operation of each hazardous waste firing system is maintained. (§63.1209(j)(4))

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

Record Keeping:

• The permittee shall comply with the comprehensive performance testing record keeping requirements as

stated in permit condition PW011.

• The permittee shall maintain records of the data recorded by the continuous monitoring systems. The

permittee shall maintain records on an hourly rolling average for the following:

(1) The temperature in each combustion chamber; (§63.1209(j)(1))

(2) The flue gas flowrate or production rate; (§63.1209(j)(2))

(3) The pumpable and total (i.e., pumpable and nonpumpable) hazardous waste feedrates; (§63.1209(j)(3))

• The permittee shall maintain records on the key parameters for the hazardous waste firing system;

(§63.1209(j)(4)

• The permittee shall maintain records of the comprehensive performance test plans. 

• The permittee shall maintain records of the comprehensive performance test results.

• If the permittee operates under different modes of operation other than compliance mode B, the alternate

mode of compliance defined in the Comprehensive Performance Test Plan, the permittee must establish

operating parameter limits for each mode. The permittee must document in the operating record when the

permittee changes a mode of operation and begins complying with the operating parameter limits for an

alternative mode of operation. (§63.1209(q))

• The permittee shall maintain records on-site for the most recent 60 months and shall immediately make such

records available to any Missouri Department of Natural Resources’ personnel upon verbal request

Record Keeping /Reporting for Alternate Standard Provision:

The permittee shall create and maintain a log indicating whether or not hazardous waste is being fed to the kiln

and whether the installation is complying with the requirements of 40 CFR 63, Subpart EEE or Alternate

Standard Provisions. Attachment G contains a log including these record keeping requirements. This log or an

equivalent created by the permittee, must be used to certify compliance with this requirement. These records

shall be made available to either the Director upon written request or Department inspection personnel upon

verbal request

Reporting:
Continental Cement Company, L.L.C. 82

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall comply with the comprehensive performance testing reporting requirements as stated in

permit condition PW010.

• Excessive emissions and continuous monitoring system performance report and summary report as specified

in permit condition PW004.

Permit Condition EU0010-10 Cement Kiln

10 CSR 10-6.260

Restriction of Emission of Sulfur Compounds

Emission Limitation:

• Emissions from any existing or source operation shall not contain more than two thousand parts per million

by volume (2000 ppmv) of sulfur dioxide.

• Emissions from any existing or source operation shall not contain more than seventy milligrams (70 mg) per

cubic meter of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any

consecutive three hour time period.

• No person shall cause or permit the emission of sulfur compounds from any source, which causes or

contributes to concentrations exceeding those specified in 10 CSR 10-6.010 Ambient Air Quality Standards.

Record Keeping: 

The installation shall maintain records of fuel usage and of the sulfur content of fuel. All records shall be

maintained for five years. These records shall be made available immediately for inspection to the

Department of Natural Resources’ personnel upon request.

Reporting:

The permittee shall report to the Air Pollution Control Enforcement Section, P.O. Box 176, Jefferson City,

MO 65102, no later than ten (10) days after any exceedance of 10 CSR 10-6.260 demonstrated by the

appropriate record keeping forms.

10 CSR 10-6.260(4) is a state-only requirement

Permit Condition EU0010-11

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

10 CSR 10-6.060

Construction Permits Required

Construction Permit Number 1086-004D

Emission Limitation:

It shall be a condition of this permit whereby Continental has demonstrated at least a 99.99% destruction and

removal efficiency (DRE) for all organic compounds, Continental must monitor oxygen levels in the kiln by the

use of an oxygen continuous emission monitor device which will demonstrate that sufficient oxygen is present

in the kiln to maintain this level of destruction. The six minute rolling average concentration of oxygen in the

combustion air shall not be less than one percent (1%) measured at a point where the combustion air

exits the kiln and the minimum temperature in the burning zone of the kiln shall not be less than its BIF limit on

a hourly rolling average basis as measured by a temperature sensitive device.

Continuous compliance shall be monitored by the use of an oxygen CEM at the back end of the kiln.

Continental has installed a computerized interlock system in which a waste fuel cutoff device will immediately

cut off the waste fuel supply if the oxygen content of the kiln gases are not within the limits specified above.

The waste fuel will not be restarted until such time as the oxygen concentration is within the limits specified

above. (Special Condition Number 3)
Continental Cement Company, L.L.C. 83

Installation ID Number: 173-0001 Project Number: 173-0001-0001

The combined heat content of coal, solid waste fuels and liquid waste fuels shall be 8000 BTU per pound or

greater, as measured at the burner tip. Records of the heat content of each tank of liquid waste fuel, as fired, and

each solid waste fuel, as fired, directly to the kiln shall be kept onsite.(Special condition 8A)

Record Keeping:

For Special Conditions 3 and 8A, record keeping shall be kept on-hand for a period of five-years of operation,

and shall be made immediately available to the Department of Natural Resources’ personnel upon request.

(Special Condition Number 13)

Permit Condition EU0020-01 Clinker Cooler

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Particulate Matter

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

The permittee shall not cause to be discharged into the atmosphere from the clinker cooler any gases

which contain particulate matter in excess of 0.050 kg per Mg (0.10 lb per ton) of feed (dry basis) to the

kiln. (§63.1345(a)(1))

Performance Testing:

• The permittee shall demonstrate initial compliance with the clinker cooler by conducting a performance test

as specified in §63.1349(b)(1)(i) through (b)(1)(iii). (§63.1349(b)(1)

• EPA Method 5 of appendix A to part 60 of this chapter shall be used to determine PM emissions. Each

performance test shall consist of three separate runs under the conditions that exist when the clinker cooler

is operating at the representative performance conditions in accordance with §63.7(e). Each run shall be

conducted for at least one hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). The average

of the three runs shall be used to determine compliance. A determination of the particulate matter collected

in the impingers (“back half”) of the Method 5 particulate sampling train is not required to demonstrate

initial compliance with the PM standards of this subpart. However, this shall not preclude the permitting

authority from requiring a determination of the “back half” for other purposes. (§63.1349(b)(1)(i))

• Suitable methods shall be used to determine the kiln feed rate, except for fuels, for each run.

(§63.1349(b)(1)(ii))

• The emission rate, E of PM shall be computed for each run using the following equation

(§63.1349(b)(1)(iii)): E = ( ) CsQsd P Where:

E = emission rate of PM, kg/Mg of kiln feed

Cs = concentration of PM, kg/dscm

Qsd = volumetric flow rate of effluent gas, dscm/hr

P = total kiln feed (dry basis), Mg/hr

• Except as provided in §63.1349(e), performance tests required under §63.1349(b)(1)and (b)(2) shall be

repeated every five years, except that the permittee of a kiln, in-line kiln/raw mill or clinker cooler is not

required to repeat the initial performance test of opacity for the kiln, inline kiln/raw mill or clinker cooler.

(§63.1349((c)

Record Keeping:

• The permittee shall maintain files of all information (including all reports and notifications) required by this

section recorded in a form suitable and readily available for inspection and review as required by

§63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of

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

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. (§63.1355(a))
Continental Cement Company, L.L.C. 84

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• The permittee shall maintain records for each affected source as required by §63.10(b)(2) and (b)(3); and

(§63.1355(b))

(1) All documentation supporting initial notifications and notifications of compliance status under

§63.9; (§63.1355(b)(1))

(2) All records of applicability determination, including supporting analyses; and (§63.1355(b)(2))

(3) If the permittee has been granted a waiver under §63.8(f)(6), any information demonstrating

whether a source is meeting the requirements for a waiver of record keeping or reporting

requirements. (§63.1355(b)(3))

Reporting:

• The permittee shall comply with the reporting requirements for the performance test stated in Permit

Condition: PW004.

• As required by §63.10(d)(2), the permittee shall report the results of performance tests as part of the

notification of compliance status. (§63.1354(b)(1))

Permit Condition EU0020-02 Clinker Cooler

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Opacity

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

No permittee shall cause to be discharged into the atmosphere from the clinker cooler any gases which

exhibit opacity greater than ten percent. (§63.1345(a)(2))

Performance Testing:

• The opacity exhibited during the period of the Method 5 performance test for particulate matter required by

§63.1349(b)(1)(i) shall be determined as required in §63.1349(b)(1)(v) through (vi). (§63.1349(b)(1))

• Except as provided in §63.1349(b)(1)(vi), the opacity exhibited ruing the period of the Method 5

performance tests required by §63.1349(b)(1)(i) shall be determined through the use of a continuous opacity

monitor (COM). The maximum six-minute average opacity during the three Method 5 test runs shall be

determined during each Method 5 test run, and used to demonstrate initial compliance with the applicable

opacity limits of §63.1343(b)(2). (§63.1349(b)(1)(v))

Monitoring:

• The permittee of a clinker cooler shall monitor opacity at each point where emissions are vented from the

clinker cooler in accordance with §63.1350(d)(1) through (d)(3). §63.1350(d)

• Except as provide in §63.1350(d)(2), the permittee shall install, calibrate, maintain, and continuously

operate a COM located at the outlet of the clinker cooler PM control device to continuously monitor the

opacity. The COM shall be installed, maintained, calibrated, and operated as required by subpart A, general

provisions of this part, and according to PS-1 of appendix B to part 60 of this chapter. (§63.1350(d)(1))

• To remain in compliance, the opacity must be maintained such that the 6-minute average opacity for any 6-

minute block period does not exceed 10 percent. If the average opacity for any 6-minute block period

exceeds 10 percent, this shall constitute a violation of the standard. (§63.1350(d)(3))

Record Keeping:

• The permittee shall maintain files of all information (including all reports and notifications) required by this

section recorded in a form suitable and readily available for inspection and review as required by

§63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of
Continental Cement Company, L.L.C. 85

Installation ID Number: 173-0001 Project Number: 173-0001-0001

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

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. (§63.1355(a))

• The permittee shall maintain records for each affected source as required by §63.10(b)(2) and (b)(3); and

(§63.1355(b))

(1) All documentation supporting initial notifications and notifications of compliance status under §63.9;

(§63.1355(b)(1))

(2) All records of applicability determination, including supporting analyses; and (§63.1355(b)(2))

(3) If the permittee has been granted a waiver under §63.8(f)(6), any information demonstrating whether a

source is meeting the requirements for a waiver of record keeping or reporting requirements.

(§63.1355(b)(3))

• The permittee shall maintain all records required by §63.10(c). (§63.1355(c))

Reporting:

• As required by §63.10(d)(3), the permittee shall report the opacity results from tests required by §63.1349.

(§63.1354(b)(2))

• As required by §63.10(e)(2), the permittee using a continuous opacity monitoring system to determine

opacity compliance during any performance test required under §63.7 and described in §63.6(d)(6) shall

report the results of the continuous opacity monitoring system performance evaluation conducted under

§63.8(e). (§63.1354(b)(7))

• As required by §63.10(e)(3), the permittee equipped with a continuous emission monitor shall submit an

excess emissions and continuous monitoring system performance report for any event when the continuous

monitoring system data indicates the source is not in compliance with the applicable emission limitation or

operating parameter limit. (§63.1354(b)(8))

• If the total continuous monitoring system downtime for any CEM or any continuous monitoring system

(CMS) for the reporting period is ten percent or greater of the total operating time for the reporting period,

the permittee shall submit an excess emissions and continuous monitoring performance report along with

the summary report (mentioned in PW003). (§63.1354(b)(10))

Permit Condition EU0030-01 through EU0390-01 and EU0420-01 

10 CSR 10-6.400

Restriction of Emission of Particulate Matter from Industrial Processes

Emission Limitation:

The permittee shall not emit particulate matter in excess of :

• 50.1 lbs/hr from EU0030.

• 50.1 lbs/hr from EU0040.

• 50.1 lbs/hr from EU0050.

• 50.1 lbs/hr from EU0060.

• 50.1 lbs/hr from EU0070.

• 50.1 lbs/hr from EU0080.

• 50.1 lbs/hr from EU0090.

• 50.1 lbs/hr from EU0100.

• 58.5 lbs/hr from EU0110.

• 58.5 lbs/hr from EU0120.

• 58.5 lbs/hr from EU0130.

• 50.1 lbs/hr from EU0140.

• 50.1 lbs/hr from EU0150.

• 50.1 lbs/hr from EU0160.

• 50.1 lbs/hr from EU0170.
Continental Cement Company, L.L.C. 86

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• 50.1 lbs/hr from EU0180.

• 47.5 lbs/hr from EU0190.

• 48.4 lbs/hr from EU0200.

• 48.4 lbs/hr from EU0210.

• 66.0 lbs/hr from EU0220.

• 51.8 lbs/hr from EU0230.

• 50.2 lbs/hr from EU0240.

• 48.4 lbs/hr from EU0250.

• 66.0 lbs/hr from EU0260.

• 66.0 lbs/hr from EU0270.

• 51.8 lbs/hr from EU0280.

• 50.2 lbs/hr from EU0290.

• 58.5 lbs/hr from EU0300.

• 50.1 lbs/hr from EU0310.

• 57.1 lbs/hr from EU0320.

• 51.3 lbs/hr from EU0330.

• 51.3 lbs/hr from EU0340.

• 51.3 lbs/hr from EU0350.

• 51.3 lbs/hr from EU0360.

• 51.3 lbs/hr from EU0370.

• 51.3 lbs/hr from EU0380.

• 57.4 lbs/hr from EU0390.

• 51.3 lbs/hr from EU0420.

The concentration of particulate matter in the exhaust gases shall not exceed 0.3gr/scf from EU0030 through

EU0390 and EU0420.

Monitoring/Record Keeping:

• The permittee shall retain the potential to emit calculations in the Statement of Basis which demonstrate that

the above emissions limitations will not be exceeded.

• The calculation shall be made available immediately for inspection to the Department of Natural Resources’

personnel upon request.

• All records shall be kept for a period of five years.

Permit Condition EU0400-01, EU0410-01, EU0430-01, EU0440-01 

10 CSR 10-6.400

Restriction of Emission of Particulate Matter from Industrial Processes

Emission Limitation:

The permittee shall not emit particulate matter in excess of 

• 63.0 lbs/hr from EU0400.

• 63.0 lbs/hr from EU0410.

• 88.2 lbs/hr from EU0430.

• 88.2 lbs/hr from EU0440.

The concentration of particulate matter in the exhaust gases shall not exceed 0.3gr/scf from EU0400, EU0410,

EU0430, EU0440.
Continental Cement Company, L.L.C. 87

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Monitoring:

The permittee shall comply with the monitoring requirements listed below:

• Baghouse operation and maintenance:

(1) The baghouse shall be maintained such that the pressure drop remains in the normal operating range (-

1.0 in H2O to –10.0 inch H2O), whenever the emission unit is in operation.

(2) All instruments and control equipment shall be calibrated, maintained and operated according to the

manufacture specifications and recommendations.

(3) Check and document the baghouse pressure drop weekly. If the pressure drop falls out of the normal

operating range, corrective action shall be taken within eight hours to return the pressure drop to

normal.

(4) Check and document the cleaning sequence of the baghouse monthly. 

(5) Thoroughly inspect bags for leaks and wear quarterly.

(6) Inspect every six months all components that are not subject to wear or plugging, including structural

components, housing, ducts and hoods.

(7) If leaks or abnormal conditions are detected the appropriate measures for remediation shall be

implemented within eight hours.

Record Keeping:

• The permittee shall document all pressure drop readings. (See Attachment E)

• The permittee shall maintain a written or electronic record of all inspections and any action resulting from

the inspection. (see Attachment F)

• All instrument calibrations shall be recorded.

• All bag replacements shall be documented.

• All records shall be maintained for five years. These records shall be made available immediately for

inspection to the Department of Natural Resources’ personnel upon request.

Reporting:

All exceedances and a description of a corrective action taken shall be reported to the Air Pollution Control

Program, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 semi-annually.

Permit Condition EU0110, EU0140 through EU0180, EU0245, EU0300 through EU0380,

EU0400 through EU0450

10 CSR 10-6.075

Maximum Achievable Control Technology

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Opacity

40 CFR 63, Subpart A

General Provisions

Emission Limitation:

The permittee shall not cause to be discharged any gases from EU0110, EU0140 through EU0180,

EU0245, EU0300 through EU0380, EU0400 through EU0450 which exhibit opacity in excess of ten

percent. (§63.1348)

Performance Testing:

• The permittee of any subject to limitations on opacity under this subpart that is not subject to §63.1349(b)(1)

shall demonstrate initial compliance with the affected opacity limit by conducting a test in accordance with

Method 9 of 40 CFR 60. The performance test shall be conducted under the conditions that exist when the

affected source is operating at the representative performance conditions in accordance with §63.7(e). The

maximum 6-minute average opacity exhibited during the test period shall be used to determine whether the
Continental Cement Company, L.L.C. 88

Installation ID Number: 173-0001 Project Number: 173-0001-0001

affected source is in initial compliance with the standard. The duration of the method 9 performance test

shall be 3 hours (30 6-minute averages), except that the duration of the Method 9 performance test may be

reduced to 1 hour if the conditions of §63.1349(b)(2)(i) through (ii) apply. (§63.1349(b)(2)):

(1) There are no individual readings greater than 10 percent opacity (§63.1349(b)(2)(i));

(2) There are no more than three readings of 10 percent for the first 1-hour period. (§63.1349(b)(2)(ii))

• Performance tests required under §63.1349(b)(2) shall be repeated every five years. (§63.1349(c))

Monitoring:

• The permittee subject to a limitation on opacity under §63.1346 or §63.1348 shall monitor opacity in

accordance with the operation and maintenance plan developed in accordance with §63.1350(a).

(§63.1350(j))

• The permittee must conduct a monthly 1-minute visible emissions test of each affected source in accordance

with Method 22 of appendix A to part 60 of this chapter. The test must be conducted while the affected

source is in operation. (§63.1350(a)(4)(i))

• If no visible emissions are observed in six consecutive monthly tests for any affected source, the permittee

may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible

emissions are observed during any semi-annual test, the permittee must resume testing of that affected

source on a monthly basis and maintain that schedule until no visible consecutive monthly tests.

(§63.1350(a)(4)(ii))

• If no visible emissions are observed during the semi-annual test for any affected source, the permittee may

decrease the frequency of testing from semi-annually to annually for that affected source. If visible

emissions are observed during any annual test, the permittee must resume testing of that affected source on a

monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly

tests. (§63.1350(a)(4)(iii))

• If visible emissions are observed during any Method 22 test, the permittee must conduct a 6-minute test of

opacity in accordance with Method 9 of appendix A to part 60 of this chapter. The Method 9 test must

begin within one hour of any observation of visible emissions. (§63.1350(a)(4)(iv))

Record Keeping:

• The permittee shall maintain files of all information (including all reports and notifications) required by this

section recorded in a form suitable and readily available for inspection and review as required by

§63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of

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

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. (§63.1355(a))

• The permittee shall maintain records for each affected source as required by §63.10(b)(2) and (b)(3); and

(§63.1355(b))

(1) All documentation supporting initial notifications and notifications of compliance status under

§63.9; (§63.1355(b)(1))

(2) All records of applicability determination, including supporting analyses; and (§63.1355(b)(2))

(3) If the permittee has been granted a waiver under §63.8(f)(6), any information demonstrating

whether a source is meeting the requirements for a waiver of record keeping or reporting

requirements. (§63.1355(b)(3))

Reporting:

As required by §63.10(d)(3), the permittee shall report the opacity results from tests required by §63.1349.

(§63.1354(b)(2))
Continental Cement Company, L.L.C. 89

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition EU0200 through 230-02, and 250 through 280-02

10 CSR 10-6.075

Maximum Achievable Control Technology

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

40 CFR Part 63, Subpart LLL

National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry – Opacity

40 CFR Part 63, Subpart A

General Provisions

Emission Limitation:

The permittee shall not cause to be discharged from the mill sweep or air separator air pollution control

devices any gases, which exhibit opacity in excess of ten percent. (§63.1347)

Performance Testing:

• The permittee of any installation subject to limitations on opacity under this subpart that is not subject to

§63.1349(b)(1) shall demonstrate initial compliance with the affected installation opacity limit by

conducting a test in accordance with Method 9 of 40 CFR 60. The performance test shall be conducted

under the conditions that exist when the affected installation is operating at the representative performance

conditions in accordance with §63.7(e). The maximum 6-minute average opacity exhibited during the test

period shall be used to determine whether the affected source is in initial compliance with the standard. The

duration of the method 9 performance test shall be 3 hours (30 6-minute averages), except that the duration

of the Method 9 performance test may be reduced to 1 hour if the conditions of §63.1349(b)(2)(i) through

(ii) apply. (§63.1349(b)(2)):

(1) There are no individual readings greater than 10 percent opacity (§63.1349(b)(2)(i));

(2) There are no more than three readings of 10 percent for the first 1-hour period. (§63.1349(b)(2)(ii))

• Performance tests required under §63.1349(b)(2) shall be repeated every five years. (§63.1349(c))

Monitoring:

• The permittee of a raw mill or finish mill shall monitor opacity by conducting daily visual emissions

observations of the mill sweep and air separator PMCDs of these affected sources, in accordance with the

procedures of Method 22 of appendix A of part 60 of this chapter. The Method 22 test shall be conducted

while the affected source is operating at the representative performance conditions in accordance with

63.7(e). The duration of the Method 22 test shall be six minutes. If visible emissions are observed during

any Method 22 visible emissions test, the permittee must (§63.1350(e)):

(1) Initiate, within one-hour, the corrective actions specified in the site specific operating and

maintenance plan developed in accordance with §63.1350(a)(1) and (a)(2). (§63.1350(e)(1))

(2) Within 24 hours of the end of the Method 22 test in which visible emissions were observed,

conduct a follow up Method 22 test of each stack from which visible emissions were observed

during the previous Method 22 test. If visible emissions are observed during the follow up Method

22 test from any stack from which visible emissions were observed during the previous Method 22

test, conduct a visual opacity test of each stack from which emissions were observed during the

follow up Method 22 test in accordance with Method 9 of appendix A to part 60 of this chapter.

The duration of the Method 9 test shall be 30 minutes.

Record Keeping:

• The permittee shall maintain files of all information (including all reports and notifications) required by this

section recorded in a form suitable and readily available for inspection and review as required by

§63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of

data shall be retained on site. The remaining three years of data may be retained off site. The files may be
Continental Cement Company, L.L.C. 90

Installation ID Number: 173-0001 Project Number: 173-0001-0001

maintained on microfilm, on a computer, on floppy disks, optical disks, on magnetic tape, or on microfiche.

(§63.1355(a))

• The permittee shall maintain records for each affected source as required by §63.10(b)(2) and (b)(3); and

(§63.1355(b))

(1) All documentation supporting initial notifications and notifications of compliance status under

§63.9; (§63.1355(b)(1))

(2) All records of applicability determination, including supporting analyses; and (§63.1355(b)(2))

(3) If the permittee has been granted a waiver under §63.8(f)(6), any information demonstrating

whether a source is meeting the requirements for a waiver of record keeping or reporting

requirements. (§63.1355(b)(3))

Reporting:

As required by §63.10(d)(3), the permittee shall report the opacity results from tests required by §63.1349.

(§63.1354(b)(2))

Permit Condition EU0445-01

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

10 CSR 10-6.060

Construction Permits Required

Construction Permit Number 0198-014

Emission Limitation:

Continental Cement shall not emit more than 15.0 tons of particulate matter less than ten microns (PM10) from

the SynGyp process in any cumulative 12-month period. (Special Condition # 1)

Monitoring and Record Keeping:

Continental Cement shall maintain an accurate record of PM10 emissions from the SynGyp process. These

records shall include monthly and cumulative 12-month totals. These records shall be kept on-site for the most

recent 60-month period of operation and shall be made immediately available to Department of Natural

Resources’ personnel upon request. The records shall be maintained on the attached form (see Attachment I), or

any other substantially conforming form containing the same information. (Special Condition 2)

Unit No. 2000 EIQ Point Description Control Device Volume (gal) Year

EU0460 SF-2A,2B Supplemental fuel storage

tanks (6)

Vapor

balance/recoverycharcoal canisters 

25,000 1986

EU0470 SF-3A,3B Supplemental fuel burn tanks

(2)

Vapor

balance/recoverycharcoal canisters

75,000 1990

EU0480 SF- 60 Supplemental fuel storage tank Vapor

balance/recoverycharcoal canisters

75,000 2004

EU0490 SF- 21 Supplemental fuel storage tank Vapor

balance/recoverycharcoal

canisters/vent to

kiln

5,000 pending
Continental Cement Company, L.L.C. 91

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Permit Condition EU0460-01 through EU0490-01

10 CSR 10-6.060

Emission Standards for Hazardous Air Pollutants

40 CFR Part 61 Subpart FF

National Emission Standard for Benzene Waste Operations

Emission Limitation:

• For each waste stream that contains benzene, including (but not limited to) organic waste streams that

contain less than ten (10) percent water and aqueous waste stream, even if the wastes are not discharged to

an individual drain system, the permittee shall: (§61.342(c)(1))

(1) Remove or destroy the benzene contained in the waste using a treatment process or wastewater

treatment system that complies with the standards specified in §61.348. (§61.342(c)(1)(i))

(2) Comply with the standards specified in §§61.343 through 61.347 for each waste management unit that

receives or manages the waste stream prior to and during treatment of the waste stream in accordance

with §61.342(c)(1)(i). (§61.342(c)(1)(ii))

• The permittee shall install, operate and maintain a fixed-roof and closed-vent system that routes all organic

vapors vented from the tank to a control device. (§61.343(a)(1))

Operating Parameters:

• The fixed-roof shall meet the following requirements: (§61.343(a)(1)(i))

(1) The cover and all openings (e.g., access hatches, sampling ports and gauge wells) shall be designed to

operate with no detectable emissions as indicated by an instrument reading of less than 500 ppmv

above background, as determined initially and thereafter at least once per year by the methods

specified in §61.355(h). (§61.343(a)(1)(i)(A))

(2) Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that is gasketed

and latched) at all times that waste is in the tank except when it is necessary to use the opening for

waste sampling or removal, or for equipment inspection, maintenance, or repair. (§61.343(a)(1)(i)(B))

• The closed-vent system and control device shall be designed and operated in accordance with the

requirements of §61.349. (§61.343(a)(1)(ii))

• The closed-vent system shall: (§61.349(a)(1))

(1) Be designed to operate with no detectable emissions as indicated by an instrument reading of less than

500 ppmv above background, as determined initially and thereafter at least once per year by the

methods specified in §61.355(h). (§61.349(a)(1)(i))

(2) All gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place.

(§61.349(a)(1)(iii))

(3) For each closed-vent system complying with §61.349(a), one or more devices which vent directly to

the atmosphere may be used on the closed-vent system provided each device remains in a closed,

sealed position during normal operations except when the device needs to open to prevent physical

damage or permanent deformation of the closed-vent system resulting from malfunction of the unit in

accordance with good engineering and safety practices for handling flammable, explosive, or other

hazardous materials. (§61.349(a)(1)(iv))

• The control device shall be designed and operated in accordance with the following conditions: A vapor

recovery system (e.g., a carbon adsorption system or a condenser) shall recover or control the organic

emissions vented to it with an efficiency of 95 weight percent or greater, or shall recover or control the

benzene emissions vented to it with an efficiency of 98 weight percent or greater. (§61.349(a)(2)) and

(§61.349(a)(2)(ii))

• Each closed-vent system and control device used to comply with this subpart shall be operated at all times

when waste is placed in the waste management unit vented to the control device except when maintenance

or repair of the waste management unit cannot be completed without a shutdown of the control device.

(§61.349(b))
Continental Cement Company, L.L.C. 92

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Monitoring:

• The permittee shall demonstrate that the carbon adsorption system recovers or controls the organic

emissions vented to it with an efficiency of 95 weight percent or greater, or recovers or controls the

benzene emissions vented to it with an efficiency of 98 weight percent or greater by using one of the

following methods: (modified §61.349(c))

(1) Engineering calculations in accordance with requirements specified in §61.356(f); or (§61.349(c)(1))

(2) Performance tests conducted using the test methods and procedures that meet the requirements

specified in §61.355. (§61.349(c)(2))

• The Administrator may request at any time the permittee demonstrate that the carbon adsorption system

recovers or controls the organic emissions vented to it with an efficiency of 95 weight percent or greater, or

recovers or controls the benzene emissions vented to it with an efficiency of 98 weight percent or greater by

conducting a performance test using the test methods and procedures as required in §61.355. (§61.349(e))

• Each closed-vent system and control device shall be visually inspected initially and quarterly thereafter.

The visual inspection shall include inspection of ductwork and piping and connections to covers and control

devices for evidence of visible defects such as holes in ductwork or piping and loose connections.

(§61.349(f))

• Except as provided in §61.350, if visible defects are observed during an inspection, or if other problems are

identified, or if detectable emissions are measured, a first effort to repair the closed-vent system and control

device shall be made as soon as practicable but no later than 5 calendar days after detection. Repair shall be

completed no later than 15 calendar days after the emissions are detected or the visible defect is observed.

(§61.349(g))

(1) Delay of repair of facilities or units that are subject to the provisions of this subpart will be allowed if

the repair is technically impossible without a complete or partial facility or unit shutdown.

(§61.350(a))

(2) Repair of such equipment shall occur before the end of the next facility or unit shutdown. (§61.350(b))

• For a carbon adsorption system that does not regenerate the carbon bed directly on site in the control device

(e.g., a carbon canister), either the concentration level of the organic compounds or the concentration level

of benzene in the exhaust vent stream from the carbon adsorption system shall be monitored on a regular

schedule, and the existing carbon shall be replaced with fresh carbon immediately when carbon

breakthrough is indicated. The device shall be monitored on a daily basis or at intervals no greater than 20

percent of the design carbon replacement interval, whichever is greater. As an alternative to conducting this

monitoring, an permittee may replace the carbon in the carbon adsorption system with fresh carbon at a

regular predetermined time interval that is less than the carbon replacement interval that is determined by

the maximum design flow rate and either the organic concentration or the benzene concentration in the gas

stream vented to the carbon adsorption system. (§61.354(d))

• The permittee shall test equipment for compliance with not detectable emissions as required in §§61.343

through 61.347, and §61.349 in accordance with the following requirements: (§61.355(h))

(1) Monitoring shall comply with method 21 from appendix A of 40 CFR Part 60. (§61.355(h)(1))

(2) The detection instrument shall meet the performance criteria of method 21. (§61.355(h)(2))

(3) The instrument shall be calibrated before use on each day of its use by the procedures specified in

method 21. (§61.355(h)(3))

(4) Calibration gases shall be: (§61.355(h)(4))

(i) Zero air (less than 10 ppm of hydrocarbon in air); and (§61.355(h)(4)(i))

(ii) A mixture of methane or n-hexane and air at a concentration of approximately but less than

10,000 ppm methane or n-hexane. (§61.355(h)(4)(ii))

(5) The background level shall be determined as set forth in method 21. (§61.355(h)(5))

(6) The instrument probe shall be traversed around all potential leak interfaces as close as possible to the

interface as described in method 21. (§61.355(h)(6))
Continental Cement Company, L.L.C. 93

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(7) The arithmetic difference between the maximum concentration indicated by the instrument and the

background level is compared to 500 ppm for determining compliance. (§61.355(h)(7))

Record Keeping: 

• The permittee using control equipment in accordance with §§61.343 through 61.347 shall maintain

engineering design documentation for all control equipment that is installed on the waste management unit.

The documentation shall be retained for the life of the control equipment. If a control device is used, then

the permittee shall maintain the control device records required by §61.356(f). (§61.356(d))

• The permittee using a closed-vent system and control device in accordance with §61.349 shall maintain the

following records. The documentation shall be retained for the life of the control device. (§61.356(f))

(1) A statement signed and dated by the permittee certifying that the closed-vent system and control

device is designed to operate at the documented performance level when the waste management unit

vented to the control device is or would be operating at the highest load or capacity expected to occur.

(§61.356(f)(1))

(2) If engineering calculations are used to determine control device performance in accordance with

§61.349(c), then a design analysis for the control device that includes for example: (§61.356(f)(2))

(i) Specifications, drawing, schematics, and piping and instrumentation diagrams prepared by the

permittee, or the control device manufacturer or vendor that describe the control device design

based on acceptable engineering texts. The design analysis shall address the following vent

stream characteristics and control device operating parameters: (§61.356(f)(2)(i))

 (a) For a carbon adsorption system that does not regenerate the carbon bed directly on-site in

the control device, such as a carbon canister, the design analysis shall consider the vent

stream composition, constituent concentration, flow rate, relative humidity and

temperature. The design analysis shall also establish the design exhaust vent stream

organic compound concentration level or the design exhaust vent stream benzene

concentration level, capacity of carbon bed, type and working capacity of activated carbon

used for carbon bed and design carbon replacement interval based on the total carbon

working capacity of the control device and source operating schedule. (§61.356(f)(2)(i)(G))

(3) If performance tests are used to determine control device performance in accordance with §61.349(c):

(§61.356(f)(3))

(i) A description of how it is determined that the test is conducted when the waste management unit

or treatment process is operating at the highest load or capacity level. This description shall

include the estimated or design flow rate and organic content of each vent stream and definition

of the acceptable operating ranges of key process and control parameter during the test program.

(§61.356(f)(3)(i))

(ii) A description of the control device including the type of control device, control device

manufacturer’s name and model number, control device dimensions, capacity and construction

materials. (§61.356(f)(3)(ii))

(iii) A detailed description of sampling and monitoring procedures, including sampling and

monitoring locations in the system, the equipment to be used, sampling and monitoring

frequency and planned analytical procedures for sample analysis. (§61.356(f)(3)(iii))

(iv) All test results. (§61.356(f)(3)(iv))

• The permittee shall maintain a record for each visual inspection required by §§61.343 through 61.347 that

identifies a problem (such as a broken seal, gap or other problem) which could result in benzene emissions.

The record shall include the date of the inspection, waste management unit and control equipment location

where the problem is identified, a description of the problem, a description of the corrective action taken

and the date the corrective action was completed. (§61.356(g))

• The permittee shall maintain a record for each test of not detectable emissions required by §§61.343 through

61.347 and §61.349. The record shall include the following information: date the test is performed,
Continental Cement Company, L.L.C. 94

Installation ID Number: 173-0001 Project Number: 173-0001-0001

background level measured during test, and maximum concentration indicated by the instrument reading

measured for each potential leak interface. If detectable emissions are measured at a leak interface, then the

record shall also include the waste management unit, control equipment, and leak interface location where

detectable emissions were measured, a description of the problem, a description of the corrective action

taken, and the date the corrective action was completed. (§61.356(h))

• For each control device, the permittee shall maintain documentation that includes the following information

regarding the control device operation: (§61.356(j))

(1) Dates of startup and shutdown of the closed-vent system and control device. (§61.356(j)(1))

(2) A description of the operating parameter (or parameters) to be monitored to ensure that the control

device will be operated in conformance with these standards and the control device’s design

specifications and an explanation of the criteria used for selection of the parameter (or parameters).

This documentation shall be kept for the life of the control device. (§61.356(j)(2))

(3) If a carbon adsorber that is not regenerated directly on site in the control device is used, then the

permittee shall maintain records of dates and times when the control device is monitored, when

breakthrough is measured, and shall record the date and time when the existing carbon in the control

device is replaced with fresh carbon. (§61.356(j)(10))

Reporting: 

• If the total annual benzene quantity from facility waste is equal to or greater than 10 Mg/yr, then the

permittee shall submit to the Administrator the following reports: (§61.357(d))

(1) Beginning 3 months after the date that the equipment necessary to comply with these standards has

been certified in accordance with §61.357(d)(1), the permittee shall submit quarterly to the

Administrator a certification that all of the required inspections have been carried out in accordance

with the requirements of this subpart. (§61.357(d)(6))

(2) Beginning 3 months after the date that the equipment necessary to comply with these standards has

been certified in accordance with §61.357(d)(1), the permittee shall submit a report quarterly to the

Administrator that includes: (§61.357(d)(7))

(3) Beginning one year after the date that the equipment necessary to comply with these standards has

been certified in accordance with §61.357(d)(1), the permittee shall submit annually to the

Administrator a report that summarizes all inspections required by §§61.342 through 61.354 during

which detectable emissions are measured or a problem (such as a broken seal, gap or other problem)

that could result in benzene emissions is identified, including information about the repairs or

corrective action taken. (§61.357(d)(8))

Permit Condition EU0460-02 through EU0490-02 

10 CSR 10-6.070

New Source Performance Regulations

40 CFR Part 60 Subpart Kb

Standards of Performance for Volatile Organic Liquid Storage Vessels for Which Construction,

Reconstruction, or Modification Commenced After July 23, 1984 

Emission Limitation:

• Each storage vessel with design capacity greater than or equal to 151m3 (39,900 gal) containing a volatile

organic liquid (VOL) that, as stored, has a maximum true vapor pressure equal to or greater than 5.2 kPa

(0.75 psia) but less than 76.6 kPa (11.1 psia) shall be equipped with a closed vent system and control device

meeting the following specifications:

(1) The closed vent system shall be designed to collect all VOC vapors and gases discharged from the

storage vessel and operated with no detectable emissions as indicated by an instrument reading of less

than 500 ppm above background and visual inspections, as determined in CFR 60, Subpart VV,

§60.485(b). §60.112b(a)(3)(I)
Continental Cement Company, L.L.C. 95

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(2) The control device shall be designed and operated to reduce inlet VOC emissions by 95 percent or

greater. §60.112b(a)(3)(ii)

Monitoring:

The permittee shall routinely(weekly) monitor the HC concentration in ppm from the exit of the carbon

absorbers.(§60.113b(c)(2))

Record Keeping:

• The permittee shall keep the following records. (§60.115b(c))

(1) A copy of the Compliance Plan (§60.115b(c)(1))

(2) A record of the monitored HC concentration in ppm from the exit of the carbon absorbers (modified

§60.115b(c)(2))

• These records shall be kept for at least five (5) years and shall be made available immediately for inspection

to the Department of Natural Resources’ personnel upon verbal request or to the Director upon written

request.

Reporting:

• The permittee is exempt from §60.8 of the General Provisions and shall meet the following requirements.

(§60.113b(c))

• Submit for approval by the Administrator as an attachment to the notification required by §60.7(a)(1) or, if

the facility is exempt from §60.7(a)(1), as an attachment to the notification required by §60.7(a)(2), an

operating plan containing the information listed below. (§60.113b(c)(1))

• Documentation demonstrating that the control device will achieve the required control efficiency during

maximum loading conditions. This documentation is to include a description of the gas stream which enters

the control device, including flow and VOC content under varying liquid level conditions (dynamic and

static) and manufacturer’s design specifications for the control device. If the control device or the closed

vent capture system receives vapors, gases, or liquids other than fuels from sources that are not designated

sources under this subpart, the efficiency demonstration is to include consideration of all vapors, gases, and

liquids received by the closed vent capture system and control device. If an enclosed combustion device

with a minimum residence time of 0.75 seconds and a minimum temperature of 816°C is used to meet the

95 percent requirement, documentation that those conditions will exist is sufficient to meet the requirements

of this paragraph. (§60.113b(c)(1)(i))

• A description of the parameter or parameters to be monitored to ensure that the control device will be

operated in conformance with its design and an explanation of the criteria used for selection of that

parameter (or parameters). (§60.113b(c)(1)(ii))

Unit No. 2000 EIQ Point Description Year

EU0500-EU0540 AS-3A,4A,5A,6A,7A Artificial Soils Project 1991

Permit Condition EU0500-01 through EU0540-01

10 CSR 10-6.220

Restriction of Emission of Visible Air Contaminants

10 CSR 10-6.060

Construction Permits Required

Construction Permit Number 122001-014

Emission Limitation:

• Continental Cement Company shall not discharge into the atmosphere for this artificial soil program PM10

in excess of 15 tons in any 12-consecutive month period. (Special Condition #1)
Continental Cement Company, L.L.C. 96

Installation ID Number: 173-0001 Project Number: 173-0001-0001

• Continental Cement Company shall water unpaved haul road and vehicular activity areas around storage

piles whenever conditions exist which would cause visible fugitive emissions to enter the ambient air

beyond the property boundary. (Special Condition #2)

Monitoring and Record Keeping:

The permittee shall monitor the amount of artificial soil replacement and maintain records on the PM10

emissions on a rolling 12-month basis. Attachment A (as presented in Construction Permit Number 

122001-014) or an equivalent form approved by Air Pollution Control Program (APCP) shall be used for record

keeping. Continental Cement shall maintain all records required by this permit for not less than five (5) years

and shall make them available immediately to any Missouri Department of Natural Resources’ personnel upon

request. 

Reporting:

Continental Cement shall report to the Air Pollution Control Enforcement Section, P.O. Box 176, 205 Jefferson

Street, Jefferson City, MO 65102, no later than (10) days after the end of the month where records show that the

source exceeded the emission limitation.
Continental Cement Company, L.L.C. 97

Installation ID Number: 173-0001 Project Number: 173-0001-0001

IV. Core Permit Requirements

The installation shall comply with each of the following emission limitations. Consult the appropriate sections

in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the

applicable requirements.

10 CSR 10-6.050, Start-up, Shutdown and Malfunction Conditions

(a.) In the event of a malfunction, which results in excess emissions that exceed one hour, the permittee shall

submit to the director within two business days in writing the following information:

(1.) Name and location of installation;

(2.) Name and telephone number of person responsible for the installation;

(3.) Name of the person who first discovered the malfunction and precise time and date that the

malfunction was discovered.

(4.) Identity of the equipment causing the excess emissions;

(5.) Time and duration of the period of excess emissions;

(6.) Cause of the excess emissions;

(7.) Air pollutants involved;

(8.) Best estimate of the magnitude of the excess emissions expressed in the units of the applicable

requirement and the operating data and calculations used in estimating the magnitude;

(9.) Measures taken to mitigate the extent and duration of the excess emissions; and

(10.) Measures taken to remedy the situation that caused the excess emissions and the measures taken or

planned to prevent the recurrence of these situations.

(b.) The permittee shall submit the paragraph (a.) information list to the director in writing at least ten days

prior to any maintenance, start-up or shutdown, which is expected to cause an excessive release of

emissions that exceed one hour. If notice of the event cannot be given ten days prior to the planned

occurrence, it shall be given as soon as practicable prior to the release. If an unplanned excess release of

emissions exceeding one hour occurs during maintenance, start-up or shutdown, the director shall be

notified verbally as soon as practical during normal working hours and no later than the close of business

of the following working day. A written notice shall follow within ten working days.

(c.) Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under

section 643.140, RSMo, the permittee may provide information showing that the excess emissions were

the consequence of a malfunction, start-up or shutdown. The information, at a minimum, should be the

paragraph (a.) list and shall be submitted not later than 15 days after receipt of the notice of excess

emissions. Based upon information submitted by the permittee or any other pertinent information

available, the director or the commission shall make a determination whether the excess emissions

constitute a malfunction, start-up or shutdown and whether the nature, extent and duration of the excess

emissions warrant enforcement action under section 643.080 or 643.151, RSMo. 

(d.) Nothing in this rule shall be construed to limit the authority of the director or commission to take

appropriate action, under sections 643.080, 643.090 and 643.151, RSMo to enforce the provisions of the

Air Conservation Law and the corresponding rule. 

(e.) Compliance with this rule does not automatically absolve the permittee of liability for the excess

emissions reported.

10 CSR 10-6.065, Operating Permits

The permittee shall file for renewal of this operating permit no sooner than eighteen months, nor later than six

months, prior to the expiration date of this operating permit. The permittee shall retain the most current

operating permit issued to this installation on-site and shall immediately make such permit available to any

Missouri Department of Natural Resources’ personnel upon request.
Continental Cement Company, L.L.C. 98

Installation ID Number: 173-0001 Project Number: 173-0001-0001

10 CSR 10-6.110, Submission of Emission Data, Emission Fees and Process Information

(a.) The permittee shall complete and submit an Emission Inventory Questionnaire (EIQ) in accordance with

the requirements outlined in this rule.

(b.) The permittee shall pay an annual emission fee per ton of regulated air pollutant emitted according to the

schedule in the rule. This fee is an emission fee assessed under authority of RSMo. 643.079 to satisfy the

requirements of the Federal Clean Air Act, Title V.

(c.) The fees shall be due April 1 each year for emissions produced during the previous calendar year. The

fees shall be payable to the Department of Natural Resources and shall be accompanied by the Emissions

Inventory Questionnaire (EIQ) form or equivalent approved by the director.

10 CSR 10-6.130, Controlling Emissions During Episodes of High Air Pollution Potential

This rule specifies the conditions that establish an air pollution alert (yellow/orange/red/purple), or emergency

(maroon) and the associated procedures and emission reduction objectives for dealing with each. The permittee

shall submit an appropriate emergency plan if required by the Director.

10 CSR 10-6.150, Circumvention

The permittee shall not cause or permit the installation or use of any device or any other means which, without

resulting in reduction in the total amount of air contaminant emitted, conceals or dilutes an emission or air

contaminant which violates a rule of the Missouri Air Conservation Commission.

10 CSR 10-6.180, Measurement of Emissions of Air Contaminants

(a.) The director may require any person responsible for the source of emission of air contaminants to make or

have made tests to determine the quantity or nature, or both, of emission of air contaminants from the

source. The director may specify testing methods to be used in accordance with good professional

practice. The director may observe the testing. All tests shall be performed by qualified personnel.

(b.) The director may conduct tests of emissions of air contaminants from any source. Upon request of the

director, the person responsible for the source to be tested shall provide necessary ports in stacks or ducts

and other safe and proper sampling and testing facilities, exclusive of instruments and sensing devices as

may be necessary for proper determination of the emission of air contaminants.

(c.) The director shall be given a copy of the test results in writing and signed by the person responsible for the

tests.

10 CSR 10-3.030, Open Burning Restrictions

(a.) The permittee shall not conduct, cause, permit or allow a salvage operation, the disposal of trade wastes or

burning of refuse by open burning.

(b.) Exception - Open burning of trade waste or vegetation may be permitted only when it can be shown that

open burning is the only feasible method of disposal or an emergency exists which requires open burning.

(c.) Any person intending to engage in open burning shall file a request to do so with the director. The request

shall include the following:

(1.) The name, address and telephone number of the person submitting the application; The type of

business or activity involved; A description of the proposed equipment and operating practices, the

type, quantity and composition of trade wastes and vegetation to be burned and expected

composition and amount of air contaminants to be released to the atmosphere where known;

(2.) The schedule of burning operations;

(3.) The exact location where open burning will be used to dispose of the trade wastes and vegetation;

(4.) Reasons why an emergency exists or why no method other than open burning is feasible; and
Continental Cement Company, L.L.C. 99

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(5.) Evidence that the proposed open burning has been approved by the fire control authority which has

jurisdiction. 

(d.) Upon approval of the open burning permit application by the director, the person may proceed with the

operation under the terms of the open burning permit. Be aware that such approval shall not exempt

Continental Cement Company, L.L.C., from the provisions of any other law, ordinance or regulation. 

(e.) The permittee shall maintain files with letters from the director approving the open burning operation and

previous Department of Natural Resources’ inspection reports.

10 CSR 10-3.090, Restriction of Emission of Odors

No person may cause, permit or allow the emission of odorous matter in concentrations and frequencies or for

durations that odor can be perceived when one volume of odorous air is diluted with seven volumes of odor-free

air for two separate trials not less than 15 minutes apart within the period of one hour.

This requirement is not federally enforceable.

10 CSR 10-6.100, Alternate Emission Limits

Proposals for alternate emission limitations shall be submitted on Alternate Emission Limits Permit forms

provided by the department. An installation permittee must obtain an Alternate Emission Limits Permit in

accordance with 10 CSR 10-6.100 before alternate emission limits may become effective.

This requirement is not federally enforceable.

10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants

40 CFR Part 61 Subpart M, National Emission Standard for Asbestos

(a) The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for any

activities occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart

M, National Emission Standard for Asbestos. 

(b) The permittee shall conduct monitoring to demonstrate compliance with registration, certification,

notification, and Abatement Procedures and Practices standards as specified in 40 CFR Part 61, Subpart

M.

10 CSR 10-6.250, Asbestos Abatement Projects – Certification, Accreditation, and Business Exemption

Requirements

The permittee shall conduct all asbestos abatement projects within the procedures established for certification

and accreditation by 10 CSR 10-6.250. This rule requires individuals who work in asbestos abatement projects

to be certified by the Missouri Department of Natural Resources Air Pollution Control Program. This rule

requires training providers who offer training for asbestos abatement occupations to be accredited by the

Missouri Department of Natural Resources Air Pollution Control Program. This rule requires persons who hold

exemption status from certain requirements of this rule to allow the department to monitor training provided to

employees. Each individual who works in asbestos abatement projects must first obtain certification for the

appropriate occupation from the department. Each person who offers training for asbestos abatement

occupations must first obtain accreditation from the department. Certain business entities that meet the

requirements for state-approved exemption status must allow the department to monitor training classes

provided to employees who perform asbestos abatement.

This requirement is not federally enforceable.

Title VI – 40 CFR Part 82, Protection of Stratospheric Ozone

(a.) The permittee shall comply with the standards for labeling of products using ozone-depleting substances

pursuant to 40 CFR Part 82, Subpart E:
Continental Cement Company, L.L.C. 100

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(1.) All containers in which a class I or class II substance is stored or transported, all products containing

a class I substance, and all products directly manufactured with a class I substance must bear the

required warning statement if it is being introduced into interstate commerce pursuant to §82.106.

(2.) The placement of the required warning statement must comply with the requirements pursuant to

§82.108. 

(3.) The form of the label bearing the required warning statement must comply with the requirements

pursuant to §82.110. 

(4.) No person may modify, remove, or interfere with the required warning statement except as described

in §82.112.

(b.) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR

part 82, Subpart F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B: 

(1.) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices pursuant to §82.156.

(2.) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with

the standards for recycling and recovery equipment pursuant to §82.158.

(3.) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an

approved technician certification program pursuant to §82.161.

(4.) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with

record keeping requirements pursuant to §82.166. ("MVAC-like" appliance as defined at §82.152).

(5.) Persons owning commercial or industrial process refrigeration equipment must comply with the leak

repair requirements pursuant to §82.156.

(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.

(c.) If the permittee manufactures, transforms, imports, or exports a class I or class II substance, the permittee

is subject to all the requirements as specified in 40 CFR part 82, Subpart A, Production and Consumption

Controls. 

(d.) If the permittee performs a service on motor (fleet) vehicles when this service involves ozone-depleting

substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the

permittee is subject to all the applicable requirements as specified in 40 CFR part 82, Subpart B, Servicing

of Motor Vehicle Air conditioners. The term "motor vehicle" as used in Subpart B does not include a

vehicle in which final assembly of the vehicle has not been completed. The term "MVAC" as used in

Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or system

used on passenger buses using HCFC-22 refrigerant. 

The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that is listed in

the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G,

Significant New Alternatives Policy Program. Federal Only - 40 CFR part 82

10 CSR 10-6.280, Compliance Monitoring Usage

(a.) The permittee is not prohibited from using the following in addition to any specified compliance methods

for the purpose of submission of compliance certificates:

(1.) Monitoring methods outlined in 40 CFR Part 64;

(2.) Monitoring method(s) approved for the permittee pursuant to 10 CSR 10-6.065, “Operating

Permits”, and incorporated into an operating permit; and

(3.) Any other monitoring methods approved by the director.

(b.) Any credible evidence may be used for the purpose of establishing whether a permittee has violated or is

in violation of any such plan or other applicable requirement. Information from the use of the following

methods is presumptively credible evidence of whether a violation has occurred by a permittee:

(1.) Monitoring methods outlined in 40 CFR Part 64;
Continental Cement Company, L.L.C. 101

Installation ID Number: 173-0001 Project Number: 173-0001-0001

(2.) A monitoring method approved for the permittee pursuant to 10 CSR 10-6.065, “Operating Permits”,

and incorporated into an operating permit; and

(3.) Compliance test methods specified in the rule cited as the authority for the emission limitations.

(c.) The following testing, monitoring or information gathering methods are presumptively credible testing,

monitoring, or information gathering methods:

(1.) Applicable monitoring or testing methods, cited in: 

• 10 CSR 10-6.030, “Sampling Methods for Air Pollution Sources”; 

• 10 CSR 10-6.040, “Reference Methods”; 

• 10 CSR 10-6.070, “New Source Performance Standards”; 

• 10 CSR 10-6.080, “Emission Standards for Hazardous Air Pollutants”; or

(2.) Other testing, monitoring, or information gathering methods, if approved by the director, that

produce information comparable to that produced by any method listed above.
Continental Cement Company, L.L.C. 102

Installation ID Number: 173-0001 Project Number: 173-0001-0001

V. General Permit Requirements

Permit Duration

10 CSR 10-6.065(6)(C)1.B.

This permit is issued for a term of five years, commencing on the date of issuance. This permit will expire at

the end of this period unless renewed.

General Record Keeping and Reporting Requirements

10 CSR 10-6.065(6)(C)1.C

I) Record Keeping

A) All required monitoring data and support information shall be retained for a period of at least five years

from the date of the monitoring sample, measurement, report or application.

B) Copies of all current operating and construction permits issued to this installation shall be kept on-site

for as long as the permits are in effect. Copies of these permits shall be made immediately available to

any Missouri Department of Natural Resources’ personnel upon request.

II) Reporting

A) The permittee shall submit a report of all required monitoring by:

1) October 1st for monitoring which covers the January through June time period, and

2) April 1st for monitoring which covers the July through December time period.

3) Exception: For monitoring requirements which require reporting more frequently than semiannually, the permittee shall report no later than 30 days after the end of the calendar quarter in

which the measurements were taken.

B) Each report must identify any deviations from permit requirements, since the previous report, that have

been monitored by the monitoring systems required under the permit, and any deviations from the

monitoring, record keeping and reporting requirements of the permit.

C) All reports shall be submitted to the Air Pollution Control Program, Enforcement Section, P.O. Box 176,

Jefferson City, MO 65102.

D) Submit supplemental reports as indicated here. All reports of deviations shall identify the cause or

probable cause of the deviations and any corrective actions or preventative measures taken.

1) Notice of any deviation resulting from an emergency (or upset) condition as defined in paragraph

(6)(C)7 of 10 CSR 10-6.065 (Emergency Provisions) shall be submitted to the permitting authority

either verbally or in writing within two working days after the date on which the emission limitation

is exceeded due to the emergency, if you wish to assert an affirmative defense. The affirmative

defense of emergency shall be demonstrated through properly signed, contemporaneous operating

logs, or other relevant evidence that indicate an emergency occurred and that you can identify the

cause(s) of the emergency. The permitted installation must show that it was operated properly at the

time and that during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or requirements in the permit. The notice

must contain a description of the emergency, the steps taken to mitigate emissions, and the

corrective actions taken.

2) Any deviation that poses an imminent and substantial danger to public health, safety or the

environment shall be reported as soon as practicable.

3) Any other deviations identified in the permit as requiring more frequent reporting than the

permittee's semiannual report shall be reported on the schedule specified in the permit.

4) These supplemental reports shall be submitted to the Air Pollution Control Program, Enforcement

Section, P.O. Box 176, Jefferson City, MO 65102.
Continental Cement Company, L.L.C. 103

Installation ID Number: 173-0001 Project Number: 173-0001-0001

E) Every report submitted shall be certified by the responsible official, except that, if a report of a deviation

must be submitted within ten days after the deviation, the report may be submitted without a

certification if the report is resubmitted with an appropriate certification within ten days after that,

together with any corrected or supplemental information required concerning the deviation.

F) The permittee may request confidential treatment of information submitted in any report of deviation.

Risk Management Plans Under Section 112(r)

10 CSR 10-6.065(6)(C)1.D.

The permittee shall comply with the requirements of 40 CFR Part 68, Accidental Release Prevention

Requirements. If the permittee has more than a threshold quantity of a regulated substance in process, as

determined by 40 CFR Section 68.115, the permittee shall submit a Risk Management Plan in accordance with

40 CFR Part 68 no later than the latest of the following dates:

1) June 21, 1999;

2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or

3) The date on which a regulated substance is first present above a threshold quantity in a process.

Severability Clause

10 CSR 10-6.065(6)(C)1.F.

In the event of a successful challenge to any part of this permit, all uncontested permit conditions shall continue

to be in force. All terms and conditions of this permit remain in effect pending any administrative or judicial

challenge to any portion of the permit. If any provision of this permit is invalidated, the permittee shall comply

with all other provisions of the permit.

General Requirements

10 CSR 10-6.065(6)(C)1.G

1) The permittee must comply with all of the terms and conditions of this permit. Any noncompliance with a

permit condition constitutes a violation and is grounds for enforcement action, permit termination, permit

revocation and re-issuance, permit modification or denial of a permit renewal application.

2) The permittee may not use as a defense in an enforcement action that it would have been necessary for the

permittee to halt or reduce the permitted activity in order to maintain compliance with the conditions of the

permit.

3) The permit may be modified, revoked, reopened, reissued or terminated for cause. Except as provided for

minor permit modifications, the filing of an application or request for a permit modification, revocation and

re-issuance, or termination, or the filing of a notification of planned changes or anticipated noncompliance,

will not stay any permit condition.

4) This permit does not convey any property rights of any sort, nor grant any exclusive privilege.

5) The permittee shall furnish to the Air Pollution Control Program, upon receipt of a written request and

within a reasonable time, any information that the Air Pollution Control Program reasonably may require to

determine whether cause exists for modifying, reopening, reissuing or revoking the permit or to determine

compliance with the permit. Upon request, the permittee also shall furnish to the Air Pollution Control

Program copies of records required to be kept by the permittee. The permittee may make a claim of

confidentiality for any information or records submitted pursuant to 10 CSR 10-6.065(6)(C)1.

Incentive Programs Not Requiring Permit Revisions

10 CSR 10-6.065(6)(C)1.H.

No permit revision will be required for any installation changes made under any approved economic incentive,

marketable permit, emissions trading, or other similar programs or processes provided for in this permit.
Continental Cement Company, L.L.C. 104

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Reasonably Anticipated Operating Scenarios

10 CSR 10-6.065(6)(C)1.I.

The permit shall include terms and conditions for reasonably anticipated operating scenarios identified by the

applicant and approved by the permitting authority. The permit shall authorize the permittee to make changes

among alternative operating scenarios authorized in the permit without notice, but shall require the permittee,

contemporaneous with changing from one operating scenario to another, to record in a log at the permitted

installation the scenario under which it is operating. The permit shield shall apply to these terms and conditions.

(§63.1206(b)(1)(ii)) 

On May 19, 2003 the installation petitioned to define the Alternate Mode of Operation when Hazardous Waste

Time has Expired (§63.1206(b)(1)(ii)) and to Use Kiln Differential Pressure as an Indicator of Combustion

Zone Pressure for Operating Requirements-Combustion System Leaks (§63.1206(c)(5)). The petition was

granted and is incorporated in this permit as an Alternative Operating Scenario. 

Compliance Requirements

10 CSR 10-6.065(6)(C)3.

I) Any document (including reports) required to be submitted under this permit shall contain a certification

signed by the responsible official.

II) Upon presentation of credentials and other documents as may be required by law, the permittee shall allow

authorized officials of the Missouri Department of Natural Resources, or their authorized agents, to perform

the following (subject to the installation’s right to seek confidential treatment of information submitted to,

or obtained by, the Air Pollution Control Program):

A) Enter upon the premises where a permitted installation is located or an emissions-related activity is

conducted, or where records must be kept under the conditions of this permit;

B) Have access to and copy, at reasonable times, any records that must be kept under the conditions of this

permit;

C) Inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including

monitoring and air pollution control equipment), practices, or operations regulated or required under this

permit; and

D) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the Act, sample or

monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the

terms of this permit, and all applicable requirements as outlined in this permit.

III) All progress reports required under an applicable schedule of compliance shall be submitted semiannually

(or more frequently if specified in the applicable requirement). These progress reports shall contain the

following:

A) Dates for achieving the activities, milestones or compliance required in the schedule of compliance, and

dates when these activities, milestones or compliance were achieved, and

B) An explanation of why any dates in the schedule of compliance were not or will not be met, and any

preventative or corrective measures adopted.

IV) The permittee shall submit an annual certification that it is in compliance with all of the federally

enforceable terms and conditions contained in this permit, including emissions limitations, standards, or

work practices. These certifications shall be submitted annually by April 1st, unless the applicable

requirement specifies more frequent submission. These certifications shall be submitted to EPA Region

VII, 901 North 5th Street, Kansas City, Kansas 66101, as well as the Air Pollution Control Program,

Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and Part 64 exceedances and

excursions must be included in the compliance certifications. The compliance certification shall include the

following:

A) The identification of each term or condition of the permit that is the basis of the certification,
Continental Cement Company, L.L.C. 105

Installation ID Number: 173-0001 Project Number: 173-0001-0001

B) The current compliance status, as shown by monitoring data and other information reasonably available

to the installation,

C) Whether compliance was continuous or intermittent,

D) The method(s) used for determining the compliance status of the installation, both currently and over the

reporting period, and

E) Such other facts as the Air Pollution Control Program will require in order to determine the compliance

status of this installation.

Permit Shield

10 CSR 10-6.065(6)(C)6.

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

as of the date that this permit is issued, provided that:

A) The applicable requirements are included and specifically identified in this permit; or

B) The permitting authority, in acting on the permit revision or permit application, determines in writing

that other requirements, as specifically identified in the permit, are not applicable to the installation, and

this permit expressly includes that determination or a concise summary of it. 

II) Be aware that there are exceptions to this permit protection. The permit shield does not affect the following:

A) The provisions of section 303 of the Act or section 643.090, RSMo concerning emergency orders,

B) Liability for any violation of an applicable requirement which occurred prior to, or was existing at, the

time of permit issuance,

C) The applicable requirements of the acid rain program,

D) The administrator's authority to obtain information, or

E) Any other permit or extra-permit provisions, terms or conditions expressly excluded from the permit

shield provisions.

Emergency Provisions

10 CSR 10-6.065(6)(C)7.

I) An emergency or upset as defined in 10 CSR 10-6.065(6)(C)7. shall constitute an affirmative defense to an

enforcement action brought for noncompliance with technology-based emissions limitations. To establish

an emergency- or upset-based defense, the permittee must demonstrate, through properly signed,

contemporaneous operating logs or other relevant evidence, the following:

A) That an emergency or upset occurred and that the permittee can identify the source of the emergency or

upset,

B) That the installation was being operated properly,

C) That the permittee took all reasonable steps to minimize emissions that exceeded technology-based

emissions limitations or requirements in this permit, and

D) That the permittee submitted notice of the emergency to the Air Pollution Control Program within two

working days of the time when emission limitations were exceeded due to the emergency. This notice

must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective

actions taken.

II) Be aware that an emergency or upset shall not include noncompliance caused by improperly designed

equipment, lack of preventative maintenance, careless or improper operation, or operator error.

Operational Flexibility

10 CSR 10-6.065(6)(C)8.

An installation that has been issued a Part 70 operating permit is not required to apply for or obtain a permit

revision in order to make any of the changes to the permitted installation described below if the changes are not
Continental Cement Company, L.L.C. 106

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Title I modifications, the changes do not cause emissions to exceed emissions allowable under the permit, and

the changes do not result in the emission of any air contaminant not previously emitted. The permittee shall

notify the Air Pollution Control Program and the Administrator at least seven days in advance of these changes,

except as allowed for emergency or upset conditions. Emissions allowable under the permit means a federally

enforceable permit term or condition determined at issuance to be required by an applicable requirement that

established an emissions limit (including a work practice standard) or a federally enforceable emissions cap that

the source has assumed to avoid an applicable requirement to which the source would otherwise be subject. 

I) Section 502(b)(10) changes. Changes that, under section 502(b)(10) of the Act, contravene an express

permit term may be made without a permit revision, except for changes that would violate applicable

requirements of the Act or contravene federally enforceable monitoring (including test methods), record

keeping, reporting or compliance requirements of the permit.

A) Before making a change under this provision, The permittee shall provide advance written notice to the

Air Pollution Control Program and to the Administrator, describing the changes to be made, the date on

which the change will occur, and any changes in emission and any permit terms and conditions that are

affected. The permittee shall maintain a copy of the notice with the permit, and this agency shall place a

copy with the permit in the public file. Written notice shall be provided to the administrator and this

agency at least seven days before the change is to be made. If less than seven days notice is provided

because of a need to respond more quickly to these unanticipated conditions, The permittee shall provide

notice to the administrator and the permitting authority as soon as possible after learning of the need to

make the change. 

B) The permit shield shall not apply to these changes. 

Off-Permit Changes

10 CSR 10-6.065(6)(C)9.

I) Except as noted below, The permittee may make any change in its permitted operations, activities or

emissions that is not addressed in, constrained by or prohibited by this permit without obtaining a permit

revision. Insignificant activities listed in the application, but not otherwise addressed in or prohibited by

this permit, shall not be considered to be constrained by this permit for purposes of the off-permit provisions

of this section. Off-permit changes shall be subject to the following requirements and restrictions:

A) The change must meet all applicable requirements of the Act and may not violate any existing permit

term or condition; The permittee may not change a permitted installation without a permit revision, if

this change is subject to any requirements under Title IV of the Act or is a Title I modification;

B) The permittee must provide written notice of the change to the permitting authority and to the

administrator no later than the next annual emissions report. This notice shall not be required for

changes that are insignificant activities under paragraph (6)(B)3. of this rule. This written notice shall

describe each change, including the date, any change in emissions, pollutants emitted and any applicable

requirement that would apply as a result of the change.

C) The permittee shall keep a record describing all changes made at the installation that result in emissions

of a regulated air pollutant subject to an applicable requirement and the emissions resulting from these

changes; and 

D) The permit shield shall not apply to these changes.

Responsible Official

10 CSR 10-6.020(2)(R)12.

The application utilized in the preparation of this was signed by Doug Sisco, Plant Manager. If this person

terminates employment, or is reassigned different duties such that a different person becomes the responsible

person to represent and bind the installation in environmental permitting affairs, the permittee of this air

contaminant source shall notify the Director of the Air Pollution Control Program of the change. Said
Continental Cement Company, L.L.C. 107

Installation ID Number: 173-0001 Project Number: 173-0001-0001

notification shall be in writing and shall be submitted within 30 days of the change. The notification shall

include the name and title of the new person assigned by the source permittee to represent and bind the

installation in environmental permitting affairs. All representations, agreement to terms and conditions and

covenants made by the former responsible person that were used in the establishment of limiting permit

conditions on this permit will continue to be binding on the installation until such time that a revision to this

permit is obtained that would change said representations, agreements and covenants.

Reopening Permit For Cause

10 CSR 10-6.065(6)(E)6.

In accordance with 10 CSR 10-6.065(6)(E)6.A., this permit may be reopened with cause if:

1) The Missouri Department of Natural Resources receives notice from the Environmental Protection Agency

(EPA) that a petition for disapproval of a permit pursuant to 40 CFR § 70.8(d) has been granted, provided

that the reopening may be stayed pending judicial review of that determination,

2) The Missouri Department of Natural Resources or EPA determines that the permit contains a material

mistake or that inaccurate statements were made which resulted in establishing the emissions limitation

standards or other terms of the permit,

3) Additional applicable requirements under the Act become applicable to the installation; however, reopening

on this ground is not required if the permit has a remaining term of less than three (3) years, the effective

date of the requirement is later than the date on which the permit is due to expire, or the additional

applicable requirements are implemented in a general permit that is applicable to the installation and the

installation receives authorization for coverage under that general permit,

4) The installation is an affected source under the acid rain program and additional requirements (including

excess emissions requirements), become applicable to that source, provided that, upon approval by EPA,

excess emissions offset plans shall be deemed to be incorporated into the permit; or

5) The Missouri Department of Natural Resources or EPA determines that the permit must be reopened and

revised to assure compliance with applicable requirements.

Statement of Basis

10 CSR 10-6.065(6)(E)1.C.

This permit is accompanied by a statement setting forth the legal and factual basis for the draft permit

conditions (including references to applicable statutory or regulatory provisions). This Statement of Basis,

while referenced by the permit, is not an actual part of the permit.
Continental Cement Company, L.L.C. 108

Installation ID Number: 173-0001 Project Number: 173-0001-0001

ATTACHMENTS
Continental Cement Company, L.L.C. 109

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment A

Fugitive Emission Observations

Visible Emissions Abnormal Emissions

Beyond

Boundary

Date Time

No Yes

Normal Less

Than

Greater

Than Cause CorrectiveAction

Signature
Continental Cement Company, L.L.C. 110

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment B

(Outdoor) Observation Log

Responsible Facility

Operator:

Date:

Sky Conditions:

Precipitation:

Wind Direction:

Wind Speed:

Process Unit:

Sketch process unit: indicate observer position relative to source and sun; indicate potential emission points

and/or actual emission points.

OBSERVATIONS

Clock

Time

Observation Period

Duration, min:sec

Accumulated

Emission Time,

min:sec

Begin Observation
Continental Cement Company, L.L.C. 111

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment C

This sheet or something similar may be used to help show compliance with inspection, maintenance, repair and

malfunction record keeping requirements in the permit.

Inspection/Maintenance/Repair/Malfunction Log

Date Equipment/Emission Unit Activities Performed
Continental Cement Company, L.L.C. 112

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment D

This record keeping sheet or something similar may be used for the record keeping requirements 10 CSR 10-

6.220, Restriction of Emission of Visible Air Contaminants.

Opacity Emission Observations (Method 9)

Company____________ Observer____________

Location____________ Observer Certification Date____________

Date____________ Type Facility____________

Time____________ Pt. Of Emiss.____________

Control Device____________

Seconds Steam Plume (check if applicable)

Hour Min 0 15 30 45 Attached Detached Comments

0

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

SUMMARY OF AVERAGE OPACITY

Time Opacity

Set Number Start – End Sum Average

Readings ranged from to % opacity.

The Source was/was not in compliance with at the time evaluation was made.

(Signature of Observer)
Continental Cement Company, L.L.C. 113

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment E

This sheet or an equivalent may be used to satisfy pressure drop record keeping requirements.

Pressure Drop Log for Baghouses

Control Device

ID

Week Beginning

(Month/Day/Year)

Week Ending

(Month/Day/Year)

Pressure Drop

(inches water)

Within

specifications?

(Yes/No)
Continental Cement Company, L.L.C. 114

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment F

Maintenance/Inspection Activities Schedule and Log

Date Maintenance Activities Repair Actions Replacements Notes
Continental Cement Company, L.L.C. 115

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment G

Compliance Methodology Log

Date Emission Unit Is Hazardous Waste Being Fed

to the Kiln (Yes/No)?

40 CFR Part 63,

Subpart EEE Alternate Provisions
Continental Cement Company, L.L.C. 116

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment H

PM10 Compliance Worksheet – Artificial Soil Program

Continental Cement Company

Ralls County, S2, T56N, R4W

Project Number: 2001-07-050

Installation ID Number: 173-0001

This sheet covers the period from ____________________ to ____________________

 Month, Year Month, Year

Month Amount of

Artificial soil

placement 

(tons)

Note 1

Comp-PM10

Emission Factor

 (lbs/ton)

 Note 2

Monthly PM10

Emissions

 (tons) 

Note 3

12-Month PM10

Emissions

(tons/year)

Note 4

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

0.2596

Note 1: Amount of artificial soil placement during this month.

Note 2: Sum of the emissions (lb/hr) / maximum hourly design rate.

Note 3: Column 1 x Column 2 x 0.0005.

Note 4: Sum of last 12-months of Column 3*.

*A 12-month Total PM10 emissions of not in excess of 15 tons for Column 4 indicates compliance.
Continental Cement Company, L.L.C. 117

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Attachment I

PM10 Compliance Form

This sheet covers the period from ______________________ to ________________________

(month/year) (month/year)

I II III IV

Date

(month/year)

Amount of

SybGyp

Produced

(tons)

PM10 Emission

Factor

(Lb/ton)

PM10 Emissions

This Month

(tons)

12-Month

Emissions

(tons)

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

0.1386

Notes:

1. A 12-month total PM10 emissions of not more than 15.0 tons indicates compliance.

2. Column III = Column I x Column II x 0.0005

3. Column Iv = Column III for month + previous eleven months of Column III
Continental Cement Company, L.L.C.. SB - 1

Installation ID Number: 173-0001 Project Number: 173-0001-0001

STATEMENT OF BASIS

Permit Reference Documents

These documents were relied upon in the preparation of the operating permit. Because they are not incorporated

by reference, they are not an official part of the operating permit.

1) Part 70 Operating Permit Application, received March 14, 1997

2) 2001 Emissions Inventory Questionnaire received March 30, 2002;

3) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary Point

and Area Sources, Fifth Edition.

Applicable Requirements Included in the Operating Permit but Not in the Application

In the operating permit application, the installation indicated they were not subject to the following

regulation(s). However, in the review of the application, the agency has determined that the installation is

subject to the following regulation(s) for the reasons stated.

10 CSR 10-6.075, Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE, National Emission Standards for Hazardous Air Pollutants from Hazardous

Waste Combustors

This rule had not been promulgated at the time of the application; however, it has been determined to be

applicable to the installation and, therefore, has been included in the operating permit.

10 CSR 10-6.075, Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from Portland

Cement Manufacturing Industry

This rule had not been promulgated at the time of the application; however, it has been determined to be

applicable to the installation and, therefore, has been included in the operating permit.

10 CSR 10-6.100, Alternative Emission Limits

This rule has been included in the operating permit because the rule is a core permit requirement.

10 CSR 10-6.130, Controlling Emissions During Episodes of High Air Pollution Potential

This rule has been included in the operating permit because the rule is a core permit requirement.

10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants 

This rule has not been created at the time of the application; however, it has been determined to be applicable to

the installation and, therefore, has been included in the operating permit.

10 CSR 10-6.260, Restriction of Emission of Sulfur Compounds

This rule had not been addressed in the application; however, it has been determined to be applicable to the

installation and, therefore, has been included in the operating permit.

40 CFR Part 82, Protection of Stratospheric Ozone

This rule has been included in the operating permit because the rule is a core permit requirement.

Other Air Regulations Determined Not to Apply to the Operating Permit

The Air Pollution Control Program (APCP) has determined the following requirements to not be applicable to

this installation at this time for the reasons stated.
Continental Cement Company, L.L.C.. SB - 2

Installation ID Number: 173-0001 Project Number: 173-0001-0001

10 CSR 10-3.050, Restriction of Emission of Particulate Matter from Industrial Processes

This rule has been rescinded and been replaced by 10 CSR 10-6.400

10 CSR 10-3.080, Restriction of Emission of Visible Air Contaminants

This rule has been rescinded and been replaced by 10 CSR 10-6.220

10 CSR 10-6.350, Emission Limitation and Emission Trading of Oxides of Nitrogen

This rule is not applicable because Continental Cement is not a fossil fuel-fired electric generating unit.

Construction Permit Revisions

The following revisions were made to construction permits for this installation:

1) Construction Permit # 1086-004D

On August 6, 2003, the installation was issued an amendment to Special Condition # 7 of the Construction

Permit # 1086-004C. The condition was revised to initially establish the maximum amounts of liquid waste

and total hazardous waste that can be fed to the kiln based on data from a 1992 Boiler and Industrial

Furnace (BIF) trial burn. The condition was also revised to allow alternate feed limits validated by future

compliance tests to replace existing limits. The permit was amended to reflect transition from RCRA to

MACT regulations. Unnecessary or no longer valid conditions were eliminated. See EU0010-11

2) Construction Permit # 1086-004C

Special Condition # 7 of this permit was amended through the Construction Permit # 1086-004D

3) Construction Permit # 1086-004B

The conditions of this permit were superceded by the conditions of Construction Permit # 1086-004C.

4) Construction Permit # 1086-004A

The conditions of this permit were superceded by the conditions of Construction Permit # 1086-004C.

5) Construction Permit # 1086-004

The conditions of this permit were superceded by the conditions of Construction Permit # 1086-004C.

6) Construction Permit # 092002-022

This is a construction permit for a construction of a new kiln. The installation requested that the construction

permit be listed, however, no provisions of the construction permit were incorporated into the Part 70 permit,

because no construction was done yet.

7) Construction Permit Number 122001-014

The Special Condition was gap-filled as follows: “The permittee shall monitor the amount of artificial soil

replacement and maintain records on the PM10 emissions on a rolling 12-month basis.” Was added to the

Monitoring and Record Keeping of Permit Condition EU0470-01 through EU0510-01.

NSPS Applicability

10 CSR 10-6.070, New Source Performance Regulations

40 CFR 60, Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which

Construction, Reconstruction, or Modification Commenced After June 11, 1973 and Prior to May 19, 1978
Continental Cement Company, L.L.C.. SB - 3

Installation ID Number: 173-0001 Project Number: 173-0001-0001

The requirements of this part apply to storage vessels for petroleum liquids for which construction,

reconstruction, or modification commenced after June 11, 1973 and prior to May 19, 1978. There are no storage

vessels on site that meet the criteria of this supbart. (see table below)

10 CSR 10-6.070, New Source Performance Regulations

40 CFR 60, Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which

Construction, Reconstruction, or Modification Commenced After May 18, 1978 and Prior to July 23, 1984

The requirements of this part apply to storage vessels for petroleum liquids for which construction,

reconstruction, or modification commenced after May 18, 1978 and prior to July 23, 1984. There are no storage

vessels on site that meet the criteria of this supbart. (see table below)

10 CSR 10-6.070, New Source Performance Regulations

40 CFR 60, Subpart Kb, Standards of Performance for Storage Vessels for Volatile Organic Liquid Storage

Vessels (Including Petroleum Storage Vessels) for Which Construction, Reconstruction, or Modification

Commenced After July 23, 1984

The requirements of this part apply to any liquid hazardous waste storage tank operated on premises of

Continental Cement Co. Continental Cement is required to follow the regulations of this part.

Burn Tanks #1, #2 and Syn fuel storage tanks #1 through #6 are subject to Subpart Kb. Since the applicability

date and minimum volume are July 24, 1984 and 40 cubic meters (m3

) respectively, the rule does/does not apply

to Diesel fuel tank, Bulk oil storage tank, Waste oil storage tank, Unleaded gasoline tank or Grinding aid tank.

Continental Cement Tanks

Tank No. Location Contents Size(gal) Year Inst. Subpart Kb Applicability

1 Supplemental fuel storage tank #1 HWDF 25,000 1986 Yes

2 Supplemental fuel storage tank #2 HWDF 25,000 1986 Yes

3 Supplemental fuel storage tank #3 HWDF 25,000 1986 Yes

4 Supplemental fuel storage tank #4 HWDF 25,000 1986 Yes

5 Supplemental fuel storage tank #5 HWDF 25,000 1986 Yes

6 Supplemental fuel storage tank #6 HWDF 25,000 1986 Yes

7 Supplemental fuel burn tank#7 HWDF 5,000 1990 Yes

8 Supplemental fuel burn tank#8 HWDF 75,000 1990 Yes

9 Supplemental fuel burn tank#9 HWDF 75,000 1990 Yes

10 Diesel fuel tank Diesel 20,000 1966 No

13 Supplemental fuel burn tank#13 HWDF 75,000 2004 Yes

17 Bulk oil storage tank Oil 6,000 1990 No

18 Waste oil portable totes Waste oil 50-600 1990 No

19 Unleaded gasoline tank Gasoline 500 1966 No

20 Grinding aid tank Blended

glycols 6,000 1966 No

21 Diesel tank (stores) Diesel 250 1990 No

22 Diesel tank (packhouse) Diesel 150 1966 No

23 Diesel tank (generator) Diesel 500 1966 No

24 Diesel tank (firepump) Diesel 300 2003 No

25 Gasoline tank MFR Gasoline 500 1990 No

26 Diesel tank MFR Diesel 500 1990 No

27 Acetic acid tank Acetic

acid 6,000 1966 No

28 Quarry fuel tank Diesel 250 1990 No

29 Mobile shop waste oil tank Waste oil 1800 1990 No
Continental Cement Company, L.L.C.. SB - 4

Installation ID Number: 173-0001 Project Number: 173-0001-0001

10 CSR 10-6.070, New Source Performance Regulations

40 CFR 60, Subpart F, Standards of Performance for Portland Cement Plants

From 67 16619, Apr 5: “Section 63.1356(a) of the final rule is being revised to clarify that in exempting

affected sources subject to the portland cement NESHAP from duplicative requirements under 40 CFR part 60,

subpart F, it was not our intention that these sources would then become affected sources under the

requirements of 40 CFR part 60, subpart OOO (NSPS for Nonmetallic Mineral Processing Plants). The

requirements of 40 CFR part 60, subpart OOO may apply to certain sources at a portland cement plant

depending on whether or not 40 CFR part 60, subpart F, applies to that source. In particular, 40 CFR 60.670(b)

states that if an emission source is subject to 40 CFR part 60, subpart F, or follows in the plant process a source

that is subject to subpart F, then 40 CFR part 60, subpart OOO does not apply to that source. The purpose of

Sec. 63.1356(a) of the final rule is to avoid having a source that is subject to certain requirements under this

subpart also be subject to the same requirements under 40 CFR part 60, subparts F or OOO. The list of affected

sources in the portland cement NESHAP is being amended by combining into one paragraph the affected

sources, ``bagging system'' and ``bulk loading or unloading system,'' making the rule language consistent with

the NSPS for portland cement plants (40 CFR part 60, subpart F).” All emission points subject to 40CFR 63

Subpart LLL , section 63.1356(a) are exempted from 40 CFR 60 Subpart F, thus subpart F is not applicable.

10 CSR 10-6.070, New Source Performance Regulations

40 CFR 60, Subpart Y, Standards of Performance for Coal Preparation Plants

Any facility affected that commences construction or modification after October, 24, 1974, is subject to the

requirements of Subpart Y. All of the units used in coal preparation were constructed in 1966 thus Subpart Y

does not apply.

Subpart Y does not apply to transfer of coal from a coal mill to the kiln. From 67 16619, Apr 5: “Section

63.1356 of the final rule is being revised to clarify that the systems used to convey and transfer coal from the

coal mill to the kiln at portland cement plants that are major sources of HAP are not subject to the NSPS for

coal preparation plants (40 CFR part 60, subpart Y). The final portland cement NESHAP already cover

conveying system transfer points associated with coal preparation plants at portland cement plants that are

major sources. There is no need for these sources to be subject to duplicative requirements, i.e., to also be

covered by the NSPS for coal preparation plants. Further, these emission sources will be subject to more

stringent opacity requirements (10 percent) under the NESHAP than under the NSPS for coal preparation plants

(40 CFR part 60, subpart Y). Other coal conveying transfer points will continue to be subject to the NSPS for

coal preparation plants.” 

10 CSR 10-6.070, New Source Performance Regulations

40 CFR 60, Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants

The provisions of Subpart OOO are applicable to: each crusher, grinding mill, screening operation, bucket

elevator, belt. The only emissions points that Subpart OOO would be applicable are listed in the table below. 

Only facilities that commenced construction, reconstruction or modification after August 31, 1983 are subject to

this rule. Since all the units in the table below were constructed in 1966, Subpart OOO does not apply. 

Description EIQ Point Year

Raw Material Unloading RM-8 1966

Primary Crusher RM-9 1966

Conveying Transport Point RM-10 1966

Crushed Limestone Reclaim Hopper RM-11 1966

Raw Material Conveyor RM-12 1966

Raw Material Conveyor RM-13a 1966
Continental Cement Company, L.L.C.. SB - 5

Installation ID Number: 173-0001 Project Number: 173-0001-0001

MACT Applicability

10 CSR 10-6.075, Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart EEE, National Emission Standards for Hazardous Air Pollutants from Hazardous

Waste Combustors

The provisions of this subpart apply to all hazardous waste combustors: hazardous waste incinerators,

hazardous waste burning cement kilns and hazardous waste burning lightweight kilns. Since Continental

Cement utilizes hazardous liquid and solids as a fuel source the part is fully applicable.

Continental Cement is a wet process kiln that utilizes Electrostatic Precipitator (ESP) as a control emission unit

on its kiln exhaust. There is no mid-kiln sampling point. 40 CFR 63, Subpart EEE covers variety of sampling

techniques and emission control options (i.e. activated carbon injection, baghouses, sampling at the kiln

exhaust, etc.). Regulatory text contained in the permit was limited only to the options applicable to Continental

Cement’s facility.

The original version of the MACT was published in Federal Register, vol. 64, NO. 189 on September 30, 1999.

Since then, there were several revisions to the MACT. A timeline of changes is presented below:

Original FR, vol. 64, No.189, September 30, 1999

Amended: 

FR, vol. 64, November 19, 1999

FR, vol. 65, No.132, June 10, 2000

FR, vol. 65, No. 218, November 09, 2000

FR, vol. 66, No. 93, May 14, 2001

FR, vol.66, No. 128, July 03, 2001

FR, vol. 66, No. 228, October 16, 2001

FR, vol. 66, No. 235, December 06, 2001

FR, vol. 67, No.30, February 13, 2002

FR vol. 67, No. 31, February 14, 2002

FR, vol 67, No. 244, December 19, 2002

On February 13, 2002 and February 14, 2002 EPA published interim rules in response to a court imposed

remand of parts of the regulation. The rules are applicable until a new version of MACT is finalized (projected

for 2005). This permit incorporates all of the changes to the MACT wording since September 30, 1999.

After 40 CFR Part 63, Subpart EEE is revised, the installation will be subject to the revised standards. For an

operating permit with an expiration date more than three (3) years away, the permit should be reopened to

incorporate the new requirements. The mechanism for this reopening, under the current Part 70 rules, would be

a “reopening for cause”, upon rule modifications in the federal register. The changes to the permit will be made

as expeditiously as possible, but no later than eighteen (18) months. As long as the installation is meeting the

requirements of the revised rule, it is deemed to be in compliance. The Air Pollution Control Program will not

view the installation as being in violation of the operating permit if the installation is complying with the

revisions to a Federal or State Statute or Regulation, as published in the Federal Register or Missouri Register. 

Continental Cement applied and was granted a one (1) year extension on 40 CFR 63, Subpart EEE compliance

on August 05, 2003. Based on the Compliance Extension letter Continental Cement Co. must comply with all

provisions of 40 CFR 63, Subpart EEE no later than September 30, 2004. 
Continental Cement Company, L.L.C.. SB - 6

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Alternate Standard Provision:

On May 19, 2003, Continental Cement petitioned the Air Pollution Control Program to “Define Alternate Mode

of Operation When Hazardous Waste Residence Time has Expired - §63.1206(b)(1)(ii)”. Continental Cement

proposed the following wording for the Alternate Standard Provision; “If the kiln is not burning hazardous

waste, the permittee may comply with the alternate mode of operation defined in the Comprehensive

Performance Test Plan defined as follows: 

“Mode B, where the Operational Parameter Limits for: minimum combustion zone temperature, maximum

production rate, maximum hazardous waste feed rate; and the Performance Standards for: SVMs, LVMs, HCl

& CL, CO, and HG; will no longer apply to the kiln system. For the Dioxin/Furan Standard, compliance with

the Operational Parameter Limit for maximum Air Pollution Control Device (APCD) inlet temperature will be

determined by calculated three-hour rolling average of recorded one-minute averages. All Subpart EEE

standards and regulations not specifically mentioned in this paragraph will remain in effect.”

The petition was approved on December 16, 2003, thus the above language is being placed in the body of the

permit under Alternate Standard Provision heading. 

Continental Cement will operate parts of the installation under either 40 FR 63 Subpart EEE or 40 FR 63

Subpart LLL. Continental Cement requested the flexibility to switch between the EEE operation mode and an

alternate operation mode as defined in the Initial Comprehensive Test Plan. 

10 CSR 10-6.075, Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants From the Portland

Cement Manufacturing Industry

• The provisions of this subpart apply to each new and existing portland cement plant that is a major or an

area source. The affected sources subject to this regulation are:

• Each kiln and each in-line kiln/raw mill at any major or area source, including alkali bypasses, except for

kilns and in-line kiln/raw mills that burn hazardous waste and are subject to and regulated under subpart

EEE of this part;

• Each clinker cooler at any portland cement plant that is a major source;

• Each raw mill at any portland cement plant that is a major source;

• Each finish mill at any portland cement plant that is a major source;

• Each raw material dryer at any portland cement plant that is a major source and each greenfield raw material

dryer at any portland cement plant that is a major or area source;

• Each conveying system transfer point at any portland cement plant that is a major source;

• Each bagging system at any portland cement plant that is a major source; and

• Each bulk loading or unloading system at any portland cement plant that is a major source;

• The installation is a major source of HAPs, and therefore the clinker cooler, finish mills, conveying system

transfer points, bagging systems and bulk loading /unloading systems are covered by the MACT. For the

rotary kiln, the provisions of 40 CFR Part 63, Subpart EEE, National Emission Standards for Hazardous Air

Pollutants from Hazardous Waste Combustors, are to be followed.

According to 40 CFR Part 63, Subpart LLL – The first source affected are the raw material storage just

prior to the raw mill. If the emission units are not the raw material storage prior to the raw mill, the

emission units are not covered by LLL:

“...the first affected source in the sequence of materials handling operations subject to this

NESHAP is the raw material storage, which is just prior to the raw mill. The primary and
Continental Cement Company, L.L.C.. SB - 7

Installation ID Number: 173-0001 Project Number: 173-0001-0001

secondary crushers and any other equipment in the non-metallic mineral processing plant, which

precede the raw material storage are not affected sources under this NESHAP. The first conveyor

system transfer point subject to this NESHAP is the transfer point associated with the conveyor

transferring material from the raw material storage to the raw mill.”

Based on this definition, since the facility does not utilize a raw mill (wet slurry operation) the first

emission units affected by 40 CFR Part 63 are the kiln dust processing units. 

63 CFR Subpart LLL in §63.1350(a)(4)(v) states the following: The requirement to conduct Method 22 visible

emissions monitoring under this paragraph shall not apply to any totally enclosed conveying system transfer

point, regardless of the location of the transfer point. "Totally enclosed conveying system transfer point" shall

mean a conveying system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these

transfer points shall be operated and maintained as total enclosures on a continuing basis in accordance with the

facility operations and maintenance plan. The following points are totally enclosed:

CG-9e hopper conveyor

CG-9f conveyor to elevator transfer point

CG-9g coal transfer (rail) - elevator to belt conveyor MBE-1/MBC-2

CG-12 coal transfer point - elevator to coal conveyor MBE-1/MBC-3

CG-12a coal transfer point - conveyor to conveyor MBC-3/MBC-4

CG-12b coal transfer point - conveyor to conveyor MBC-4/MBC-5

CG-13 coal transfer point - conveyor to silo MBC-4/Coal Silo

CG-14 gypsum transfer point - elevator to conveyor MBE-1/MBC-3

CG-14a gypsum transfer point - conveyor to conveyor MBC-3/MBC-4

CG-14b gypsum transfer point - conveyor to silo MBC-4/MBC-5

CG-14c gypsum transfer point - conveyor MBC-5 to Bin 1

CG-14d gypsum transfer point - conveyor MBC-6 to Bin 2

RM-21 clay storage pile - underground

CM-2a dust collector discharges to apron pan conveyor

CM-2 clinker transfer drag to apron pan conveyor

CM-1a clean-up screw discharges to apron pan conveyor

CM-3 clinker apron pan conveyor transfer point to bucket elevator

CM-4a clinker transfer-east elevator to belt conveyor

CM-4 clinker transfer-west elevator to belt conveyor

CM-4b clinker transfer-conveyor 1a to conveyor 1d

CM-4c clinker transfer-conveyor 1b to conveyor 1c

CM-7a clinker transfer-hopper to conveyor belt

CM-7b clinker transfer-conveyor belt to elevator

If any partially enclosed or unenclosed conveying system transfer point is located in a building, the permittee of

the portland cement plant shall have the option to conduct a Method 22 visible emissions monitoring test

according to the requirements of §63.1350(a)(4)(i) through (iv) for each such conveying system transfer point

located within the building, or for the building itself, according to §63.1350 (a)(4)(vii).

If visible emissions from a building are monitored, the requirements of §63.1350(a)(4)(i) through (iv) apply to

the monitoring of the building, and you must also test visible emissions from each side, roof and vent of the

building for at least one -minute. The test must be conducted under normal operating conditions.
Continental Cement Company, L.L.C.. SB - 8

Installation ID Number: 173-0001 Project Number: 173-0001-0001

The following emission units are located within the “mill building” CG-10j

CG-15 gypsum bin 1 and 2

CG-16 gypsum transfer - bins onto belt conveyor

RM-14 transfer point (tripper) to raw materials storage silos

RM-14a limestone silos

RM-14b clay silos

RM-15 transfer to secondary crusher, conveyor, limestone

RM-16 transfer, secondary crusher to conveyor to mill, limestone

RM-17 transfer, conveyor to mill, raw material

RM-18 transfer to secondary crusher, conveyor, clay

RM-19 transfer, secondary crusher to conveyor to mill clay

CM-9.1a,b,c clinker weighing and transfer

CM-9.2a,b,c clinker weighing and transfer

CM-10e1g fringe bin

CM-10i2g fringe bin

The following emission units are located within the “packhouse building” 

SH-3 cement transfer, silos into pump/air slide system

SH-4 cement handling, bulk truck loading lines/bins

SH-5 cement handling, bulk truck/rail loading lines/bins

 The following emission units are located within the “syn-gyp process building” SG-10 

SG-4 storage pile

SG-5 loading hopper

SG-6 transfer - hopper to belt conveyor

SG-7 transfer - belt conveyor to agglomerator

SG-8 transfer - agglomerator discharge to stacker belt conveyor

SG-9 transfer - stacker to storage pile

10 CSR 10-6.075, Maximum Achievable Control Technology Regulations

40 CFR Part 63, Subpart DD, National Emission Standards for Hazardous Air Pollutants from Off-Site Waste

and Recovery Operations

The installation is not subject to 40 CFR Part 63, Subpart DD, due to the exemption stated in §63.683(c)(1).

According to §63.683(c)(1):

“An off-site material management unit is exempted from the requirements specified in §63.683(b), if the

unit is also subject to another subpart under 40 CFR Part 61 or 40 CFR Part 63, and the owner or operator

is controlling the HAP listed in Table 1 of this subpart that are emitted from the unit in compliance with the

provisions specified in the other applicable subpart.”

According to §63.680(b)(2)(vi), the following materials are not off-site materials:

“Waste that is generated by or transferred from units complying with all applicable requirements specified

by 61.342(b) under 40 CFR 61 subpart FF – National Emission Standards for Benzene Waste Operations

for a facility at which the total annual benzene quantity from the facility waste is equal to or greater than 10

megagrams per year.” 

The off-site waste is placed in hazardous waste storage tanks complying with 40 CFR Part 61, Subpart FF,

therefore when the waste leaves these storage tanks or is "transferred from” these units complying with 40

CFR Part 61, Subpart FF, the waste is no longer off-site waste.

According to the July 1, 1996 Preamble:
Continental Cement Company, L.L.C.. SB - 9

Installation ID Number: 173-0001 Project Number: 173-0001-0001

“Some NESHAP already regulate air emissions from the off-site management of certain wastes

containing HAP. To avoid duplication of requirements in these cases, the Off-Site Waste and Recovery

Operations NESHAP does not apply to waste management units that either receive waste from units

complying with all applicable regulations under the HON, or receive waste from units complying with

all applicable requirements specified by §61.342(b) under 40 CFR Part 61, Subpart FF – National

Emission Standards for Benzene Waste Operations for a plant a which the total annual benzene quantity

is greater than or equal to ten (10) Mg/yr.”

The cement kiln and the hazardous waste storage tanks are complying with 40 CFR Part 61, Subpart FF,

therefore the requirements for 40 CFR Part 63, Subpart DD were not included in the operating permit.

40 CFR Part 63, Subpart B, Requirements for Control Technology Determinations for Major Sources in

Accordance with Clean Air Act Sections, Section 112(g) and 112(j)

Continental Cement submitted Phase 1 Notification. It was determined that no provisions of 112(j) are

applicable because Continental Cement Co. does not operate any equipment covered by the regulation.

NESHAP Applicability

10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants,

40 CFR, Part 61, Subpart FF, National Emission Standards for Benzene Waste Operation

As a Benzene waste processing facility Continental Cement is required to comply with the provisions of this

rule.

10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants

40 CFR Part 61, Subpart M, National Emission Standard for Asbestos

The installation is subject to the requirements of 40 CFR Part 61, Subpart M.

10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants

40 CFR Part 61, Subpart V, National Emission Standard for Equipment Leaks (Fugitive Emission Sources)

The provisions of this subpart apply to each of the following sources that are intended to operate in volatile

hazardous air pollutant (VHAP) service: pumps, compressors, pressure relief devices, sampling connection

systems, open-ended valves or lines, valves, flanges and other connectors, product accumulator vessels, and

control devices or systems required by this subpart.

40 CFR Part 63, Subpart DD references Subpart V, however as stated previously, the installation is not subject

to the requirements of 40 CFR Part 63, Subpart DD. The installation is subject to 40 CFR Part 61, Subpart M

and Subpart FF and neither subpart references Subpart V. Therefore, the installation is not subject to the

requirements of 40 CFR Part 61, Subpart V and it was not included in the operating permit.
Continental Cement Company, L.L.C.. SB - 10

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Other Regulatory Determinations

10 CSR 10-6.400, Restriction of Emission of Particulate Matter from Industrial Processes

Emission

Unit

2000

EIQ

Point

Description Year Pollnt

MHD

R

Effic. EF Source SCC Unc.

Lb/hr

Cont.

lb/hr

10-6.400

lb/hr

EU0010 KP-1 cement kiln 1966 PM(1)

EU0020 CM-1 clinker cooler 1966 PM(1)

EU0030 CM-2a dust collector discharges to

apron pan conveyor

1966 PM 89.1 99 0.00150 Fire 305-

02-006

0.13 0.0013 50.12

EU0040 CM-2 clinker transfer drag to

apron pan conveyor

1966 PM 89.1 89.46 0.00150 Fire 305-

02-006

0.13 0.0013 50.12

EU0050 CM-1a Clean-up screw discharges

to apron pan conveyor

1966 PM 89.1 89.46 0.00150 Fire 305-

02-006

0.13 0.0013 50.12

EU0060 CM-3 clinker apron pan conveyor

transfer point to bucket

elevator

1966 PM 89.1 89.46 0.00150 Fire 305-

02-006

0.13 0.0013 50.12

EU0070 CM-4a clinker transfer - east

elevator to belt conveyor

1966 PM 89.1 89.46 0.00150 Fire 305-

02-006

0.13 0.0013 50.12

EU0080 CM-4 clinker transfer - west

elevator to belt conveyor

1966 PM 89.1 89.46 0.0015 Fire 305-

02-006

0.13 0.0013 50.12

EU0090 CM-4b clinker transfer -

conveyor1a to conveyor 1d

1966 PM 89.1 89.46 0.0015 Fire 305-

02-006

0.13 0.0013 50.12

EU0100 CM-4c clinker transfer - conveyor

1b to conveyor 1c

1966 PM 89.1 89.46 0.0015 Fire 305-

02-006

0.13 0.0013 50.12

EU0110 CM-12c clinker hopper 1966 PM 200 0.0026 305-

01-108

0.52 0.52 58.51

EU0120 CM-7a clinker transfer – hopper to

conveyor belt 

1966 PM 200 0.0015 305-

02-006

0.30 0.30 58.51

EU0130 CM-7b clinker transfer - conveyor

belt to elevator

1966 PM 200 99.8 0.0015 Fire 305-

02-006

0.30 0.0006 58.51

EU0140 CM-8 clinker storage silos- F

Silos

1966 PM 89.1 99 0.0026 Fire 305-

01-108

0.23 0.0023 50.12

EU0150 CM-8a clinker storage silos - North

Silos

1966 PM 89.1 99 0.0026 Fire 305-

01-108

0.23 0.0023 50.12

EU0160 CM-8b clinker storage silos - South

Silos

1966 PM 89.1 99 0.0026 Fire 305-

01-108

0.23 0.0023 50.12

EU0170 CM-8c clinker storage silos - North

fringe

1966 PM 89.1 99 0.0026 Fire 305-

01-108

0.23 0.0023 50.12

EU0180 CM-8d clinker storage silos - South

fringe

1966 PM 89.1 99 0.0026 Fire 305-

01-108

0.23 0.0023 50.12

EU0190 CM9.1a,b,c,

2a,b,c

clinker weighing and

transfer - mill 1-2

1966 PM 65 89.46 0.0024 Fire 305-

00-728

0.15 0.016 47.05

EU0200 CM-10 clinker grinding ( mill # 1 ) 1966 PM 75 89.46 0.008 Fire 305-

00-717

0.6 0.06 48.43

EU0210 CM-10a Finish Mill #1 Elevator 1966 PM 75 99 0.0015 Fire 305-

02-006

0.11 0.0011 48.43

EU0220 CM-10c finish mill #1 air separator 1966 PM 390 99 0.028 Fire 305-

00-729

10.92 0.07 66.02

EU0230 CM-10d finish mill #1 - surge bin 1966 PM 105 99 0.0026 Fire 305-

01-108

0.273 0.0027 51.77

EU0240 CM-10e finish mill #1 - 1G fringe

bin

1966 PM 90 89.46 0.0026 Fire 305-

01-108

0.234 0.025 50.226

EU0250 CM-10.1 clinker grinding ( mill # 2 ) 1966 PM 75 89.46 0.008 Fire 305-

00-717

0.6 0.063 48.43

EU0260 CM-10F finish mill #2 - elevator 1966 PM 390 99 0.0015 Fire 305-

02-006

0.58 0.006 66.02

EU0270 CM-10g finish mill #2 air separator 1966 PM 390 99 0.028 Fire 305-

00-729

10.92 0.109 66.02

EU0280 CM-10h finish mill #2 - surge bin 1966 PM 105 99 0.0026 Fire 305-

01-108

0.27 0.003 51.77

EU0290 CM-10i finish mill #2 - 2G fringe

bin

1966 PM 90 89.46 0.0026 AP-42 305-

01-108

0.23 0.024 50.23

EU0300 CM-11 clinker reclaim elevator

discharge

1966 PM 390 99.8 0.0015 AP-42 305-

02-006

0.3 0.003 58.50

EU0310 CM-12 clinker transfer tripper to

clinker storage pile

1966 PM 89 99 0.0015 AP-42 305-

03-006

0.134 0.0013 50.10
Continental Cement Company, L.L.C.. SB - 11

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Emission

Unit

2000

EIQ

Point

Description Year Pollnt

MHD

R

Effic. EF Source SCC Unc.

Lb/hr

Cont.

lb/hr

10-6.400

lb/hr

EU0320 SH-1 cement storage - stockhouse

#6

1966 PM 175 93.4 0.0026 AP-42 305-

01-108

0.445 0.03 57.07

EU0330 SH-2 cement storage silos 1966 PM 100 89.46 0.0026 AP-42 305-

01-108

0.26 0.027 51.28

EU0340 SH-2 cement storage silos 1966 PM 100 89.46 0.0026 AP-42 305-

01-108

0.26 0.027 51.28

EU0350 SH-2 cement storage silos 1966 PM 100 89.46 0.0026 AP-42 305-

01-108

0.26 0.027 51.28

EU0360 SH-2 cement storage silos 1966 PM 100 89.46 0.0026 AP-42 305-

01-108

0.26 0.027 51.28

EU0370 SH-2 cement storage silos 1966 PM 100 89.46 0.0026 AP-42 305-

01-108

0.26 0.027 51.28

EU0380 SH-2 cement storage silos 1966 PM 100 89.46 0.0026 AP-42 305-

01-108

0.26 0.027 51.28

EU0390 SH-3 cement transfer - silos into

pump/air slide system

1966 PM 180 89.46 0.0026 AP-42 305-

01-108

0.468 0.049 57.37

EU0400 SH-4 cement handling - bulk

truck loading lines

1966 PM 300 89.46 0.0026 AP-42 305-

01-108

0.78 0.082 63.00

EU0410 SH-5 cement handling - bulk

railcar/truck loading lines

1966 PM 300 89.46 0.0026 AP-42 305-

01-108

0.78 0.082 63.00

EU0420 SH-7 cement storage silos 1966 PM 100 99.0 0.0026 AP-42 305-

01-108

0.26 0.0026 51.28

EU0430 SH-8 cement barge loading 1966 PM 2200 99.0 0.0026 AP-42 305-

01-108

5.72 0.0026 88.24

EU0440 SH-9 cement barge loading 1966 PM 2200 99.0 0.0026 AP-42 305-

01-108

5.72 0.0026 88.24

1 The particulate limit required by respective MACTs for EU0010 and EU0020 are far more stringent than the limit

imposed by CSR 10-6.400, thus no emission limit for CSR 10-6.400 was calculated.

40 CFR 63.2 Definitions defines the Potential to Emit as: “... the maximum capacity of a stationary source to

emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity

of the stationary source to emit a pollutant, including air pollution control equipment and restrictions on hours

of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its

design if the limitation or the effect it would have on emissions is federally enforceable. “ 

Potentials to emit presented in the above table were calculated based on sources Maximum Hourly Design Rate

(MHDR). All emission factors used are for an uncontrolled total particulate matter (PM). 

Sample of calculations for EU0220 Finish Mill#1 Air Separator (EP: CM-10c)

Uncontrolled emission rate = MHDR * Emission Factor = 390 [ton/hr] * 0.028 [lbs/ton] = 10.92 lbs/hr

10 CSR10-6.400 limit for EU0220 is calculated using the following equation:

E = 55.0 * E0.11 – 40 = 55.0 * (390)0.11 – 40 = 66.02 lbs/hr

The uncontrolled emission rate at MHDR is 10.92 lbs/hr while the regulatory limit of 10CSR10-6.400 is 66.02

lbs/hr. Since the potential emissions is below the 10 CSR 6.400 Restriction of Emission of Particulate Matter

from Industrial Processes limit the installation is required to maintain calculations for the process for emission

unit EU0220. Using the same reasoning, we ask the installation to maintain on file calculation for emission

units EU0030 through EU0100, EU0130 through EU0300, EU0320 through EU0390 and EU0420. (Please see

the table above for numerical details)

For emission points EU0400, EU0410, EU430 and EU440 the uncontrolled emissions exceed the 10CSR10-

6.400 limit. However, the controlled emissions are far below the regulatory limit. In order to assure that the
Continental Cement Company, L.L.C.. SB - 12

Installation ID Number: 173-0001 Project Number: 173-0001-0001

installation meet the regulatory requirement we ask the permittee to monitor the corresponding emission control

equipment and adhere to record keeping and reporting requirements. The rationale behind this request is that in

case of the control equipment failing the installation may exceed the limit. Periodic monitoring of the

equipment will assure its proper working conditions. 

10CSR 10-6.400(3)(A)4 limits the concentration of particulate matter to 0.30 grains per standard cubic foot of

exhaust gases. The limit is applicable to the points listed below. Data for the controlled potential were taken

from previous table. As shown in the table below all affected emission units have emissions less than 0.3

grains/standard cubic foot.

Sample of calculations for EU0220 Finish Mill#1 Air Separator (EP: CM-10c). Calculations for other affected

points are synonymous.

[0.07 lb/hr / 60 min/hr] * [7000 grains/lb] = 8.2 grains/min

[8.2 grains/min]/[1200stdft3/min] = 0.007 grains/stdft3

stdft3 indicates a (standard cubic foot)

all flowrates are at Standard temperature (70°F) and standard pressure (14.7 psi)

EU Description Controlled Potential 

[lb/hr]

Flow

[stdft3

/min]

Controlled

Potential

[grains/min]

Controlled

Potential

[grains/stdft3

]

EU0030 dust collector discharges to

apron pan conveyor

1.4 1200 163.3 0.14

EU0040 clinker transfer drag to apron

pan conveyor

1.4 1200 163.3 0.14

EU0050 dust collector discharges to

apron pan conveyor

1.4 1200 163.3 0.14

EU0060 clinker apron pan conveyor

transfer point to bucket

elevator

1.4 1200 163.3 0.14

EU0070 clinker transfer - east elevator

to belt conveyor

1.4 1000 163.3 0.16

EU0080 clinker transfer - west elevator

to belt conveyor

0.2 2000 23.3 0.01

EU0090 clinker transfer - east belt

conveyor to north tripper belt

0.2 1200 23.3 0.02

EU0100 clinker transfer - west belt

conveyor to south tripper belt

0.2 5000 23.3 0.005

EU0130 clinker transfer – conveyor belt

to elevator

1.3 1500 151.7 0.1

EU0140 clinker storage silos- F Silos 1.3 2000 151.7 0.08

EU0150 clinker storage silos - North

Silos

1.3 2000 151.7 0.08

EU0160 clinker storage silos - South

Silos

1.3 5000 151.7 0.03

EU0170 clinker storage silos - North

interstices

1.3 5000 151.7 0.03

EU0180 clinker storage silos - South

interstices

1.3 5000 151.7 0.03
Continental Cement Company, L.L.C.. SB - 13

Installation ID Number: 173-0001 Project Number: 173-0001-0001

EU0190 clinker weighing and transfer -

mill 1-2

1.3 5000 151.7 0.03

EU0200 clinker grinding ( mill # 1 ) 0.004 3000 0.5 0.0001

EU0210 finish Mill #1 Elevator 0.005 3000 0.6 0.0002

EU0220 finish mill #1 air separator 0.07 1200 0.8 0.0007

EU0230 finish mill #1 - surge bin 0.07 1000 0.8 0.0008

EU0240 finish mill #1 - 1G fringe bin 0.07 1200 0.8 0.0007

EU0250 clinker grinding ( mill # 2 ) 0.07 1200 0.8 0.0007

EU0260 finish mill #2 - elevator 0.004 1000 0.5 0.0005

EU0270 finish mill #2 air separator 0.02 1000 2.3 0.008

EU0280 finish mill #2 - surge bin 0.07 1000 8.2 0.008

EU0290 finish mill #2 - 2G fringe bin 0.07 1200 8.2 0.007

EU0300 clinker reclaim elevator 0.07 1200 8.2 0.007

EU0320 cement storage - stockhouse #6 0.3 1200 35.0 0.03

EU0330 cement storage silos 0.4 1000 46.7 0.04

EU0340 cement storage silos 0.4 1500 46.7 0.03

EU0350 cement storage silos 0.4 1500 46.7 0.03

EU0360 cement storage silos 0.4 1200 46.7 0.04

EU0370 cement storage silos 0.4 1200 46.7 0.04

EU0380 cement storage silos 0.4 1200 46.7 0.04

EU0390 cement transfer - silos into

pump/air slide system

0.4 1200 46.7 0.04

EU0400 cement handling - bulk truck

loading lines

0.1 1000 11.7 0.1

EU0410 cement handling - bulk railcar

loading lines

0.1 1000 11.7 0.1

EU0420 cement storage silos 0.4 1200 46.7 0.04

EU0430 cement barge loading 8.8 5000 1026.7 0.2

EU0440 cement barge loading 8.8 5000 1026.7 0.2

Emission Units Without Limitation

The sources listed as units without limitation in this permit fall into two categories. 

Fugitive sources, which do not emit regulated pollutants from a discrete stack or vent. These sources emit

particulate matter and volatile organic compounds directly into the ambient air. These sources do not have any

type of capture/control devices and are not covered or required to control their emissions based on any past or

current regulations. These sources are not subject to any specific rule except the installation wide requirement

of 10 CSR 10-6.170 and must comply with this requirement. Storage piles and haul roads are included in that

category.

The following storage piles and haul roads were placed in the Emission Units Without Limitations category:

2000 EIQ 

Point Description 

CG-2A haul road unpaved - coal barge and truck to coal stockpile

CG-2B haul road paved - coal barge and truck to coal stockpile

CG-3A haul road unpaved - clinker barge and truck to stockhouse 5

CG-3B haul road paved - clinker barge and truck to stockhouse 5

CG-3D haul road unpaved - coal truck and barge plant entrance to stockhouse 5

CG-3E haul road paved - coal truck and barge plant entrance to stockhouse 5

CG-3C haul road unpaved - clinker truck to hopper

CG-4 coal storage pile ( staging )
Continental Cement Company, L.L.C.. SB - 14

Installation ID Number: 173-0001 Project Number: 173-0001-0001

CG-5 haul road - coal stockpile to hopper

CG-6A haul road unpaved - gypsum - plant entrance to stockhouse 5

CG-6B haul road paved - gypsum - plant entrance to stockhouse 5

CG-7 gypsum storage pile 

CG-8 haul road - unpaved gypsum from stockhouse 5 to hopper

CG-11 haul road - coal transfer to coal storage pile CG-4

CG-17 coal/coke storage pile 

CG-18 haul road (unpaved) plant entrance to outdoor storage pile

CG-19 Synthetic Gypsum Storage Pile - outdoor

CG-20 haul road - unpaved, Synthetic Gypsum Storage Pile to hopper

RM-5A haul road unpaved - plant entrance to stockhouse 5 clay

RM-5B haul road paved - plant entrance to stockhouse 5 clay

RM-6 clay storage pile

RM-20 haul road, unpaved - plant entrance to underground mine

RM-20a haul road, unpaved - plant entrance to clay storage pile

RM22 clay storage pile ( outdoor )

RM-23 haul road, unpaved - clay storage pile to primary crusher

RM-7 haul roads - stockhouse 5 to primary crusher - clay

RM-20 haulroad unpaved - plant entrance to underground mine - clay

RM-20a haulroad unpaved - plant entrance to outdoor clay storage pile

RM-22 outdoor clay storage pile

RM-23 haulroad unpaved - clay storage piles to primary crusher

KP-4 haul road - waste dust to landfill

KP-5 waste dust truck unloading at landfill

KP-7 waste dust storage pile at landfill

CM-6 haul road - clinker from stockhouse 5 to hopper

CM-14 haul road - outside stockpile to stockhouse 5

CM-15 outside clinker storage piles using combined emission factor

CM-14 haul road - outside stockpile to stockhouse 5

SF-33 haul road – supplemental fuels

SF-36 haul road – supplemental fuels

SF-37 haul road – supplemental fuels

SF-49 haul road – supplemental fuels

SF-51 haul road – supplemental fuels 

SG-4 synthetic gypsum storage pile

SG-11 haul road unpaved from storage pile to highway

1. The provisions of Subpart OOO are applicable to: each crusher, grinding mill, screening operation, bucket

elevator, belt. The only emissions points that Subpart OOO would be applicable to are listed in the table

below. 

Only facilities that commenced construction, reconstruction or modification after August 31, 1983 are

subject to this rule. Since all the units in the table below were constructed in 1966, Subpart OOO does not

apply. Since these units have no emission controls 10 CSR 10-6.220, Restriction of Emission of Visible Air

Contaminants does not apply either. Thus, the only applicable rule is the installation wide requirement of 

10 CSR 10-6.170.
Continental Cement Company, L.L.C.. SB - 15

Installation ID Number: 173-0001 Project Number: 173-0001-0001

Description EIQ Point Year

Raw Material Unloading RM-8 1966

Primary Crusher RM-9 1966

Conveying Transport Point RM-10 1966

Crushed Limestone Reclaim Hopper RM-11 1966

Raw Material Conveyor RM-12 1966

Raw Material Conveyor RM-13a 1966

2. The points listed below have no applicable requirements except for the installation wide requirement of 10

CSR 10-6.170. 

2000 EIQ 

Point Description

RM-1 quarries - drilling

RM-2 quarries - blasting

RM-3 quarries - loading haul trucks

RM-4A haul roads - quarries to primary crusher

RM-4B haul roads - quarries to primary crusher

Other Regulations Not Cited in the Operating Permit or the Above Statement of Basis

Any regulation which is not specifically listed in either the Operating Permit or in the above Statement of Basis

does not appear, based on this review, to be an applicable requirement for this installation for one or more of the

following reasons: 

1. The specific pollutant regulated by that rule is not emitted by the installation;

2. The installation is not in the source category regulated by that rule; 

3. The installation is not in the county or specific area that is regulated under the authority of that rule; 

4. The installation does not contain the type of emission unit which is regulated by that rule;

5. The rule is only for administrative purposes.

Should a later determination conclude that the installation is subject to one or more of the regulations cited in

this Statement of Basis or other regulations which were not cited, the installation shall determine and

demonstrate, to the APCP's satisfaction, the installation's compliance with that regulation(s). If the installation

is not in compliance with a regulation which was not previously cited, the installation shall submit to the APCP

a schedule for achieving compliance for that regulation(s).

Prepared by:

Slawomir Szydlo, P.E.

Environmental Engineer