Tarmac America, LLC 

Titan America Pennsuco Complex 

11000 NW 121 Way 

Medley, Florida 33178 

Facility ID No. 0250020 

Miami-Dade County 

FINAL Title V Air Operation Permit No. 0250020-018-AV 

Permitting Authority:

State of Florida 

Department of Environmental Protection 

Division of Air Resources Management 

Bureau of Air Regulation 

Mail Station #5505 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Telephone: 850/488-0114 

Fax: 850/921-9533 

Compliance Authority:

Miami-Dade County 

Department of Environmental Resources Management 

Air Facilities Section 

33 SW 2nd Avenue, Suite 900 

Miami, Florida 33150-1540 

Telephone: (305) 372-6925 

Fax: (305) 372-6954 
Table of Contents

Section Page Numbers

PLACARD PAGE 3 

I. FACILITY INFORMATION 4 

Subsection A. Facility Description 4 

Subsection B. Emissions Unit ID No(s). and Brief Description(s) 4 

Subsection C. Relevant Documents 5 

Subsection D. Shutdown Operations 5 

II. FACILITY WIDE CONDITIONS 6 

III. EMISSIONS UNIT (S) SPECIFIC CONDITIONS 

Subsection A. Cement Plant Raw Material Handling System 8 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 10 

Subsection C. Cement Plant Clinker Handling & Storage System 18 

Subsection D. Cement Plant Finish Mill System 20 

Subsection E. Cement Plant Product Storage and Packhouse/Loadout System 23 

Subsection F. Cement Plant Coal Handling System 25 

Subsection G. Facility Fugitive Emissions 27 

Subsection H. Aggregate Plant Operation 29 

Subsection I. Concrete Block Plant Operation 32 

Subsection J. Concrete Batch Ready Mix Plants Operation 34 

IV. FACILITY COMMON AND GENERAL CONDITIONS 35 

List of Appendices made part of this Permit (attached) 3 
Florida Department of 

Environmental Protection 

Bob Martinez Center 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Charlie Crist 

Governor 

Jeff Kottkamp

Lt. Governor 

Michael W. Sole 

Secretary

Permittee: FINAL Permit No.: 0250020-018-AV 

Mr. Hardy Johnson, President Facility ID No.: 0250020 

Tarmac America, Inc SIC Nos.: 3241, 3271, 3273, 1422, 1442 

455 Fairway Drive Project: Title V Air Operation Permit Renewal 

Deerfield Beach, Florida 33441 

PERMITTING ACTION: This permitting action is for the renewal of the Titan America Pennsuco Title V 

Operation Permit No. 0250020-009-AV and its revisions. The key changes since the Initial Title V Operation 

Permit are explained in a separate and more detailed Statement of Basis that accompanies this permit. This facility 

is located at 11000 NW 121 Way, Medley, Miami-Dade County. UTM Coordinates: Zone 17, 562.8 km East and 

2861.7 km North; Latitude: 25° 52’ 30” North and Longitude: 80° 22’ 30” West. 

This Title V Air Operation Permit Renewal is issued under the provisions of Chapter 403, Florida Statutes (F.S.), 

and Florida Administrative Code (F.A.C.) Chapters 62-4, 62-204, 62-210, 62-212 and 62-213, 62-296, and 62-297. 

The above named permittee is hereby authorized to operate the facility shown on the application and approved 

drawing(s), plans, and other documents, attached hereto or on file with the permitting authority, in accordance with 

the terms and conditions of this permit. 

A detailed Statement of Basis is attached for informational purposes. The following attachments are made a part of 

this permit: 

Appendix A: 40 CFR 60, Subpart A, General Provisions - Standards of Performance for New Stationary 

Sources (NSPS) 

Appendix A-1: 40 CFR 63, Subpart A, General Provisions - National Emissions Standards for Hazardous Air 

Pollutants for Source Categories (NESHAP) 

Appendix CAM: Compliance Assurance Monitoring 

Appendix CG: Common and General Conditions 

Appendix CP-1 Compliance Plan 

Appendix CF: Citation Format 

Appendix F: 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants 

Appendix H-1: Permit History (for information purpose) 

Appendix LLL: 40 CFR 63, Subpart LLL - National Emissions Standards for Hazardous Air Pollutants from the 

Portland Cement Manufacturing Industry – Major Sources 

Appendix OOO: 40 CFR 60, Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing 

Plants. 

Appendix U-1: List of Unregulated Emission Units and/or Activities 

Appendix SS-1: Stack Sampling Facilities 

Appendix TV-6: Title V Conditions 

Appendix Y: 40 CFR 60, Subpart Y - Standards of Performance for Coal Preparation Plants 

Table 297.310-1: Calibration Schedule 

Figure 1: Summary Report: Gaseous and Opacity Excess Emissions and Monitoring System Performance 

Table 1: Summary of Air Pollutant Standards for the Nonmetallic Mineral Processing Plant 

Effective Date: October 26, 2005 

Renewal Application Due Date: April 25, 2010 

Expiration Date: October 25, 2010 

Florida Department of Environmental Protection 

__________________________ 

Joseph Kahn, Director 

Division of Air Resource Management
Section I. Facility Information 

Tarmac America, LLC Title V Operation Permit Renewal 

Subsection A. Facility Description.

Titan America (through various subsidiaries or affiliates) operates the Pennsuco Facility in Medley, 

Miami-Dade County, Florida. The facility consists of a portland cement plant, an aggregate plant, two 

batch “ready-mix” concrete plants, and a cement block plant. 

The portland cement plant has an allowable production rate of 2,190,000 TPY of clinker and is capable of 

producing approximately 2,400,000 TPY of cement. It includes fuel and raw material storage, feed bins, 

a coal mill, a dry process pyroprocessing line, transfer equipment, finish mills, clinker and cement silos, 

and product packaging and load out facilities. 

The aggregate plant consists of a quarry, crushers, decks, bins, screens, transfer equipment and piles. It is 

permitted to process 14,560,000 tons per year (TPY) of raw material from the on-site limestone quarry 

and shipments received from other sources. A portion is consumed in the adjacent cement plant while the 

remainder is supplied to other users. 

Two concrete “ready-mix” plants include batching, cement and fly ash silos, additive tanks, racks, 

stackers, hoppers and truck loadouts. 

The concrete block plant includes aggregate and cement storage silos, mixers, curing kilns, mold shop 

storage and loadout. It operates at about 50 cubic yards per hours and makes about 5,500 blocks per hour. 

Pollution control equipment for the block and ready-mix plants consists of baghouses on storage silos and 

key process steps and reasonable precautions to control fugitive dust. Pollution prevention measurements 

for the aggregate plant consist of reasonable precautions to control fugitive dust. 

Pollution control equipment for the cement plant consists of a common fabric filter system (baghouse) for 

particulate emissions (PM/PM10) from the kiln, raw mill, coal mill and cooler; absorption of sulfur 

compounds and metals into the product; combustion controls for volatile organic compounds (VOC) and 

carbon monoxide (CO); indirect firing, multiple burn points, and a Low NOX calciner for NOX; and 

baghouses for particulate emissions from other process emission units. 

Subsection B. Emissions Unit ID Nos. and Brief Descriptions per ARMS Database. 

ARMS Emissions Unit No. Brief Description of Facility Emissions Units 

010 Finish Mill System: Finish Mill No. 1 

011 Finish Mill System: Finish Mill No. 2 

012 Finish Mill System: Finish Mill No. 3 

013 Finish Mill System: Finish Mill No. 4 

030 Finish Mill System: Finish Mill No. 6 

014 Cement Handling System: Cement Storage Silos. 1 through 12 

015 Cement Handling System: Cement Distribution, Rail and Truck Loadout 

016 Cement Handling System: Cement Packhouse 

022 Nonmetallic Mineral Processing Plant Equipment and Operations at 

Aggregate Plant Subject to 40 CFR 60, Subpart OOO 

023 Nonmetallic Mineral Processing Plant Equipment and Operations at 

Aggregate Plant NOT Subject to 40 CFR 60, Subpart OOO 

024 Concrete Block Plant 

025 Two Concrete Batch Ready Mix Plants 

026 Coal Handling System 

027 Clinker Handling and Storage System 

028 Pyroprocessing/Raw Mill System 

029 Raw Material Handling System 

031 Unregulated Emissions Units and/or Activities: Fugitive Emissions 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 4 of 37 
Section I. Facility Information 

The Department has determined that this facility is a major source of hazardous air pollutants (HAPs). 

Please reference the Permit No., Facility ID No., and appropriate Emissions Unit(s) ID No(s) on all 

correspondence, test report submittals, applications, etc. 

Subsection C. Relevant Documents 

The documents listed below are not a part of this permit; however, they are specifically related to this 

permitting action. 

1. FINAL Title V Air Operation Permit 0250020-009-AV. Effective Date: October 26, 2000. 

2. Air Construction Permit 0250020-010-AC to modernize cement plant issued May 1, 2001. 

3. Air Construction Permit 0250020-012-AC to increase hours of operation for the aggregate plant and 

replace hourly and daily production limits with monthly and yearly limits. The permit was issued 

January 25, 2002. 

4. Title V Air Operation Permit Revision 0250020-011-AV to incorporate the aggregate plant into the 

Title V Operation Permit and a compliance plan for NOX and clarifications related to the wet process 

plant and modernization of the facility. The permit was issued March 21, 2002. 

5. Air Construction Permit 0250020-014-AC to construct the 5,500 blocks per hour concrete block plant 

that replaced two smaller block plants. The permit was issued September 20, 2002. 

6. Air Construction Permit 0250020-016-AC to keep Finish Mill 1 and upgrade Finish Mill 3. The 

permit was issued May 31, 2005. 

7. Air Construction Permit 0250020-017-AC (PSD-FL-360) to increase cement production, establish 

best available control technology (BACT) for carbon monoxide (CO) and establish a Facility Fugitive 

Emissions Control Plan. The permit was issued December 2, 2005. 

8. Air Construction Permit 0250020-019-AC to use Finish Mill 2 as a backup. The permit was issued 

October 13, 2006. 

These documents are provided to the permittee for information purposes only: 

1. Appendix H-1: Permit History. 

2. Statement of Basis. 

These documents and all related applications, permits and correspondence are on file with the permitting 

and compliance authorities: 

1. All permit documents and related applications listed in attached Appendix H-1. 

2. Title V Operation Permit Renewal Application received April 28, 2005. 

3. Revised Title V Operation Permit Renewal Application received February 24, 2006. 

4. DEP’s electronic communications dated April 7, May 17, June 8, and July 13, 2006. 

5. Titan’s electronic communications dated April 6, April 10, May 1, May 17, June 9, July 27, August 7, 

and November 14, 2006. Titan’s Statement of Compliance received August 28, 2006. 

6. DERM’s electronic mail dated July 14, 2006. Titan Compliance Status Confirmation. 

Subsection D. Information on Shutdown Operations 

Since the time the existing Pennsuco Facility was constructed in 1960 to the present, several emissions 

units operations have shutdown or were permitted but never operated or were never built. 

These emissions units are listed in Appendix H-1: Permit History. 

Titan America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 5 of 37 
Section II. Facility-Wide Conditions 

The following conditions apply facility-wide: 

1. APPENDIX TV-6, TITLE V CONDITIONS, is a part of this permit. 

{Permitting Note: APPENDIX TV-6, TITLE V CONDITIONS, is distributed to the permittee only. 

Other persons requesting copies of these conditions shall be provided a copy when requested or 

otherwise appropriate.} 

2. General Pollutant Emissions Limiting Standards. Objectionable Odor Prohibited. No person shall 

cause, suffer, allow, or permit the discharge of air pollutants, which cause or contribute to an 

objectionable odor. [Rule 62-296.320(2), F.A.C.] 

3. General Particulate Emissions Limiting Standards - General Visible Emissions Standard: Except for 

emissions units that are subject to a Particulate Matter or opacity limit set forth or established by rule 

and reflected by conditions in this permit, no person shall cause, let, permit, suffer or allow to be 

discharged into the atmosphere the emissions of air pollutants from any activity, the density of which 

is equal to or greater than that designated as Number 1 on the Ringelmann Chart (20 percent opacity). 

EPA Method 9 is the method of compliance pursuant to Chapter 62-297, F.A.C. 

[Rules 62-296.320(4)(b) 1. & 4., F.A.C.] 

4. Prevention of Accidental Releases (Section 112(r) of CAA):

a. The permittee shall submit its Risk Management Plan (RMP) to the Chemical Emergency 

Preparedness and Prevention Office (CEPPO) RMP Reporting Center when, and if, such 

requirement becomes applicable. Any Risk Management Plan original submittals, revisions or 

updates to submittals, should be sent to: 

RMP Reporting Center 

P.O. Box 1515 

Lanham-Seabrook, Maryland 20703-1515 

Telephone: 301/429-5018 

b. The permittee shall submit to the permitting authority Title V certification forms or a compliance 

schedule in accordance with Rule 62-213.440(2), F.A.C. 

[40 CFR 68] 

5. Unregulated Emission Units and/or Activities: Appendix U-1, List of Unregulated Emission Units 

and/or Activities, is a part of this permit.

6. General Pollutant Emissions Limiting Standards - Volatile Organic Compounds (VOC) Emissions or 

Organic Solvents (OS) Emissions: The permittee shall allow no person to store, pump, handle, 

process, load, unload or use in any process or installation, volatile organic compounds or organic 

solvents without applying known and existing vapor emissions control devices or systems deemed 

necessary and ordered by the Department. The Department has not required or deemed anything 

necessary to date. [Rule 62-296.320(1)(a), F.A.C.; and SIP approved] 

7. Emissions of Unconfined Particulate Matter: Pursuant to Rules 62-296.320(4)(c)1, 3, & 4, F.A.C., 

reasonable precautions to prevent emissions of unconfined particulate matter at this facility include 

the following requirements (see Condition 57 of APPENDIX TV-6, TITLE V CONDITIONS, 

Condition 12 of Appendix CG, Subsection G, Facility Fugitives Emissions and Appendix CP-1): 

1. Paving and maintenance of roads, parking areas and yards. 

2. Application of water or chemicals to control emissions from such activities as demolition 

of buildings, grading roads, construction, and land clearing. 

3. Application of asphalt, water, chemicals or other dust suppressants to unpaved roads, 

yards, open stock piles and similar activities. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 6 of 37 
Section II. Facility-Wide Conditions 

4. Removal of particulate matter from roads and other paved areas under the control of the 

owner or operator of the facility to prevent reentrainment, and from buildings or work 

areas to prevent particulate from becoming airborne. 

5. Landscaping or planting of vegetation. 

6. Use of hoods, fans, filters, and similar equipment to contain, capture and/or vent 

particulate matter. 

7. Confining abrasive blasting where possible. 

8. Enclosure or covering of conveyor systems. 

8. Recording, Monitoring and Reporting: When appropriate, any recording, monitoring, or reporting 

requirements that are time-specific shall be in accordance with the effective date of the permit, which 

defines day one. [Rule 62-213.440, F.A.C.] 

9. Statement of Compliance: The annual statement of compliance pursuant to Rule 62-213.440(3)(a)2., 

F.A.C., shall be submitted to DERM and EPA within 60 (sixty) days after the end of the calendar year 

using DEP Form No. 62-213.900(7), F.A.C. [Rule 62-213.440(3) and 62-213.900, F.A.C.] 

{Permitting Note: This condition implements the requirements of Rules 62-213.440(3)(a)2 & 3, 

F.A.C. (see Condition 51. of APPENDIX TV-6, TITLE V CONDITIONS)} 

10. Annual Report Required: On or before March 1 of each calendar year, a completed DEP Form 

62-210.900(5), Annual Operations Report (AOR) Form for Air Pollutant Emitting Facility, shall be 

submitted to the DERM, Air Facilities Section. Included with this report shall be additional reports, 

if any, required by this permit in Section III -- Emissions Units and Conditions and Section IV – 

Common and General Conditions. [Rule 62-4.070(3), F.A.C.; and Rule 62-210.900(5), F.A.C.] 

11. Miami-Dade County Compliance Authority: The permittee shall submit all compliance related 

notifications and reports required of this permit to DERM at the following address: 

Miami-Dade County 

Department of Environmental Resources 

Air Quality Management Division 

33 SW 2nd Avenue, Suite 900 

Miami, Florida 33130-1540 

12. EPA Compliance Authority: Any reports, data, notifications, certifications, and requests required to 

be sent to the United States Environmental Protection Agency, Region 4, should be sent to: 

United States Environmental Protection Agency Region 4 

Air, Pesticides & Toxics Management Division 

Air & EPCRA Enforcement Branch 

Air Enforcement Section 

61 Forsyth Street 

Atlanta, Georgia 30303-8960 

Telephone: 404/562-9155; Fax: 404/562-9163 

13. Certification by Responsible Official (RO): In addition to the professional engineering certification 

required for applications by Rule 62-4.050(3), F.A.C., any application form, report, compliance 

statement, compliance plan and compliance schedule submitted pursuant to Chapter 62-213, F.A.C., 

shall contain a certification signed by a responsible official that, based on information and belief 

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

and complete. Any responsible official who fails to submit any required information or who has 

submitted incorrect information shall, upon becoming aware of such failure or incorrect submittal, 

promptly submit such supplementary information or correct information. 

[Rule 62-213.420(4), F.A.C.]

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 7 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection A. Cement Plant Raw Material Handling

This subsection addresses the following emissions units system. 

ARMS Emissions Unit No. Brief Description of Emissions Unit 

029 Cement Plant Raw Material Handling System 

The raw material handling operations are controlled by the following baghouses: 

Emission Point Descriptions of Emissions Points 

Baghouse I.D. 311.BF650 Dust collector for limestone and mineral aggregate feed bins/conveying 

Baghouse I.D. 311.BF750 Dust collector for raw material conveyance from feed bins to raw mill 

Baghouse I.D. 311.BF470 Dust collector for raw material conveyance from feed bins to raw mill 

Baghouse I.D. 311.BF950 Dust collector for raw material conveyance from feed bins to raw mill 

Operational Requirements 

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

[Permit 0250020-017-AC] 

2. Raw Material Handling System Throughput Specification: The maximum dry throughput rate is 

3,723,000 TPY. The owner or operator shall record all throughput rates on a rolling 12-month basis, 

and maintain records for a minimum of 5 years. [Permit 0250020-017-AC; and 62-213.440, F.A.C.] 

Emissions Limitations, Test Methods and Performance Standards 

3. Visible Emissions Limits: Visible emissions are limited to 5 percent from each of the above listed 

baghouses. Compliance shall be determined in the manner described in 40 CFR 63.1350(a)(4)(i), (ii), 

(iii) and (iv) below except that the applicable standard is 5% instead of 10%. Numeration tracks the 

referenced CFR provision. 

(4) Procedures to be used to periodically monitor affected sources subject to opacity standards under 

Sections 63.1346 and 63.1348. Such procedures must include the provisions of Paragraphs 

(a)(4)(i) through (a)(4)(iv) of this section. 

(i) The owner or operator must conduct a monthly 1-minute visible emissions test of each 

affected source in accordance with Method 22 of Appendix A to [40 CFR] Part 60 of this 

chapter. The test must be conducted while the affected source is in operation. 

(ii) If no visible emissions are observed in six consecutive monthly tests for any affected 

source, the owner or operator may decrease the frequency of testing from monthly to 

semi-annually for that affected source. If visible emissions are observed during any semiannual test, the owner or operator 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. 

(iii) If no visible emissions are observed during the semi-annual test for any affected source, 

the owner or operator 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 owner or operator must resume testing of that affected source on a monthly basis and 

maintain that schedule until no visible emissions are observed in six (6) consecutive 

monthly tests. 

(iv) If visible emissions are observed during any Method 22 test, the owner or operator 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. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 8 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection A. Cement Plant Raw Material Handling

{Note: The applicant advised that the baghouses are designed to control particulate emissions to 

0.0095 grains/dry standard cubic foot (gr/dscf). The 5% opacity limitation is consistent with this 

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

in this emission unit system will be less than 13 TPY. This annual emission estimate is part of the 

facility-wide netting calculation to escape PSD applicability for PM/PM10. Exceedance of the 5% 

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

exceedance of the opacity limitations given in 40 CFR 63, Subpart LLL.} 

[Permit 0250020-017-AC; 40 CFR 63.1348] 

Test Procedures, Recordkeeping and Additional Requirements 

4. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 9 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

This subsection addresses the following emissions unit. 

ARMS Emissions Unit No. Brief Description of Emissions Unit 

028 Cement Plant Pyroprocessing and Raw Mill System 

The pyroprocessing and raw mill system are controlled by the following baghouses: 

Emission Point Descriptions of Emissions Point 

Baghouse I.D: 331.BF200 Main Stack & dust collector for preheater/kiln/cooler/raw mill/coal mill 

Baghouse I.D: 331.BF740 Dust collector for kiln dust conveyance and storage bin 

Baghouse I.D: 341.BF350 Dust collector for preheater feed silo 

Baghouse I.D: 351.BF440 Dust collector for raw meal conveyance from feed silo to preheater 

Baghouse I.D: 351.BF470 Dust collector for raw meal conveyance from feed silo to preheater

Baghouse I.D: 331.BF645 Dust collector for truck loadout of kiln dust 

Operational Requirements 

1. Hours of Operation: This emissions unit system is allowed to operate 8760 hours per year. 

[Permit 0250020-017-AC] 

2. Pyroprocessing System Production Limits: The maximum production of clinker shall not exceed 250 

TPH on a 24-hour block average and 2,190,000 TPY. 

[Permit 0250020-017-AC; Rule 62-210.200, (Definitions – Potential to Emit), F.A.C.] 

3. Fuels: Allowable fuels fired in the pyroprocessing/raw mill emission unit consist of natural gas, 

bituminous coal, petroleum coke, No. 2 fuel oil with used oil blend and No. 6 fuel oil with used oil 

blend. Fuel oil includes on-spec used oil (refer to definition in specific condition 13). 

{Note: There is no heat input limitation. For reference, the design heat input capacities of the kiln 

burner and calciner burner are 290 million Btu per hour (mmBtu/hr) and 385 mmBtu/hr respectively. 

The clinker production effectively limits PTE.} 

[Permit 0250020-017-AC]

Emissions Limitations and Performance Standards 

4. Visible Emissions Limits: Visible emissions are limited to 5 percent from each of the above listed 

baghouses, except for the main stack baghouse, I.D.331.BF200. Compliance shall be determined in the 

manner described in 40 CFR 63.1350(a)(4)(i), (ii), (iii) and (iv) below except that the applicable standard 

is 5% instead of 10%. Numeration tracks the referenced CFR provision. 

(4) Procedures to be used to periodically monitor affected sources subject to opacity standards under 

Sections 63.1346 and 63.1348. Such procedures must include the provisions of Paragraphs (a)(4)(i) 

through (a)(4)(iv) of this section. 

(i) The owner or operator must conduct a monthly 1-minute visible emissions test of each 

affected source in accordance with Method 22 of Appendix A to [40 CFR] Part 60 of this 

chapter. The test must be conducted while the affected source is in operation. 

(ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, 

the owner or operator 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 

owner or operator 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. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 10 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

(iii) If no visible emissions are observed during the semi-annual test for any affected source, the 

owner or operator 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 owner or 

operator must resume testing of that affected source on a monthly basis and maintain that 

schedule until no visible emissions are observed in six (6) consecutive monthly tests. 

(iv) If visible emissions are observed during any Method 22 test, the owner or operator 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. 

{Note: The applicant advised that the baghouses are designed to control particulate emissions to 0.0095 

grains/dry standard cubic foot (gr/dscf). The 5% opacity limitation is consistent with this design and 

provides reasonable assurance that annual emissions of PM/PM10 for all emission points, except for the 

main stack, in this emission unit system will be less than 7 TPY. This annual emission estimate is part of 

the facility-wide netting calculation to escape PSD applicability for PM/PM10. Exceedance of the 5% 

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

of the opacity limitations given in 40 CFR 63, Subpart LLL} 

5. Main Stack - Pyroprocessing/Raw Mill Emission Limits: Emissions exiting the main stack from the 

Pyroprocessing/Raw Mill system shall not exceed the limits shown in the following table: 

PARAMETER EMISSION LIMIT AVERAGING

TIME 

COMPLIANCE 

METHOD LIMIT BASIS 

Opacity6 10 Percent 6 minute block COMS, Method 9 PTE, Avoid PSD 

40 CFR Subpart LLL 

0.063 lb/ton of dry kiln feed PM6

26.8 lb/hr 

3 hours5 Annual Method 5 PTE, Avoid PSD 

40 CFR Subpart LLL 

0.053 lb/ton of dry kiln feed PM106

22.5 lb/hr 

3 hours5 Annual Method 5 PTE, Avoid PSD 

40 CFR Subpart LLL 

0.50 lb/ton of clinker 30 days2

SO2

320 lb/hour 24 hours1

CEMS 

Method 6 or 6C PTE, Avoid PSD 

2.17 lb/ton of clinker 12-months3

NOX (as NO2) 720 lb/hour 24 hours1

 

CEMS 

Method 7 or 7E PTE, Avoid PSD 

2.0 lb/ton of clinker 30 days2

CO 

576 lb/hour 1 24 hours1

 CEMS/Method 10 BACT 

0.16 lb/ton of clinker 2 30 days2

VOC4

40 lb/hour 24 hours1

CEMS 

Method 25 or 25A PTE, Avoid PSD 

Mercury (Hg) 229 lb/yr (base + 199 lb/yr) 12-month Fuels, Materials8 PTE, Avoid PSD 

Temperature7 Baghouse Temperature (T) <

T during Dioxin/Furan Tests Continuous Established during Method 23 

40 CFR 63, Subpart 

LLL 

0.2 ng TEQ/dscm (T>204 oC) Dioxin/Furan 

0.4 ng TEQ/dscm (T<204 o

C) 

3 hours 30 Months, Method 23 40 CFR 63, Subpart 

LLL 

1 Compliance with the short-term emission limit for SO2, NOX, CO, and VOC shall be based on a 24-hour block 

average computed in accordance with Specific Condition 10. Compliance with lb/hr SO2 emissions limitations 

in this condition will insure compliance with Miami-Dade County Code, Section 24-17(2)(a) limiting 

emissions to 1.2 lb SO2/MMBtu heat input when solid fuel is fired, or 0.8 lb SO2/MMBtu heat input when 

liquid fuel is fired, based on a 24 hour average. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 11 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

2 Compliance with the long-term emission limit for SO2, CO, and VOC shall be based on a 30 operating-day 

block average computed in accordance with Specific Condition 10. 

3 Compliance with the long-term emission limit for NOX shall be based on 12 month rolling average computed 

in accordance with Specific Condition 10. 

4 VOC emissions shall be expressed as propane. 

5 The averaging times for PM and PM10 correspond to the required length of sampling for the initial and 

subsequent emission tests (e.g., a minimum of 3 one-hour test runs). Compliance demonstration with these 

limits shall be conducted pursuant to 40 CFR 63.1349(b)(1). 

6 Compliance with the Opacity, PM and PM10 permit limits given for in-line kiln/raw mill will insure 

compliance with applicable limits from 40 CFR 63, Subpart LLL for the in-line kiln/raw mill, and clinker 

cooler, and 40 CFR 60, Subpart Y for the coal mill. 

7 The temperature requirements for the operation of in-line kiln/raw mill are in accordance with 40 CFR 

63.1344(a) & (b), and 63.1349(b)(3). 

8 Determined by raw materials and fuels entering the process. Refer to Conditions 6 and 12. 

[Permit 0250020-017-AC (PSD-FL-360) including BACT determination for CO; Permit 

0250020-019-AC; Rule 62-210.200, (Definitions – Potential to Emit), F.A.C. to avoid PSD applicability 

for other pollutants; 62-212.400, F.A.C.; 40 CFR 63.1343 and 63.1345] 

{Permitting Note: For compliance with the long term CO, NOX, SO2, and VOC limits (30-day block and 

12-month rolling averages), the averaging periods began January 1, 2006.} 

6. Mercury Emissions from the Pyroprocessing/Raw Mill System: Mercury emissions exiting the main 

stack from the Pyroprocessing/Raw Mill system shall not exceed 229 pounds per year on a 12-month 

rolling basis. [Permit 0250020-017-AC; Rule 62-210.200, (Definitions – Potential to Emit), F.A.C. 

to avoid PSD applicability for Hg] 

Test Methods and Monitoring Procedures 

7. Determination of Clinker Production Rate during Testing: Prior to any emission testing to demonstrate 

compliance with any emission limit, the permittee shall determine the clinker production rate for the test 

as described in Specific Condition 15. The permittee shall notify the DERM of the preheater kiln feed 

rate and the factor used to determine the clinker production rate in advance of the commencement of any 

test(s). The rate of clinker production shall be used to determine compliance with all clinker-based 

emission limits in the permit for that test. [DERM Requirement. Rule 62-4.070(3), F.A.C.] 

8. Testing Procedures and Methods: In addition to the CEMS or COMS compliance requirements listed in 

Condition 10, the main stack & dust collector, Baghouse I.D. 331.BF200, serving the 

preheater/kiln/cooler/raw mill/coal mill shall be tested according to the EPA Methods and at the 

frequencies listed below: 

POLLUTANT TEST METHOD FREQUENCY 

PM/PM10 EPA Method 5 Annual 

Opacity EPA Method 9 Annual 

SO2 EPA Methods 6 or 6C Annual* 

NOX (as NO2) EPA Methods 7 or 7E Annual* 

CO EPA Method 10 Annual* 

VOC EPA Methods 25 or 25A Annual* 

Dioxins/Furans EPA Method 23 30 months 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 12 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

* The tests conducted annually for the relative accuracy test audit (RATA) for the CEM system may be 

used to satisfy this requirement provided the owner or operator satisfies the prior notification 

requirements and emission testing requirements of this permit for performance and compliance tests. 

The result from the actual referenced method (RM) test during the RATA needs to show compliance 

with the allowable permit emission limit. 

[Permit 0250020-017-AC; Rules 62-297.310(7) and 62-212.400, F.A.C.;] 

9. Feed or Fuel Changes and D/F and PM Performance Testing: The owner or operator shall notify the 

compliance authority prior to initiating any significant change in the feed or fuel used in the most recent 

compliant performance test for D/F or PM. For purposes of this condition, significant means any of the 

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

used; a change in the loss on ignition (LOI) characteristic of the fly ash; a change between nonbeneficiated fly ash and beneficiated fly ash. Based on the information provided, the compliance 

authority will, within seven days of notification from the permittee, determine if the proposed change 

would be reasonably expected to cause a change in D/F emissions such that performance testing pursuant 

to 40 CFR 63.1349 will be required for the new feed or fuel. If the compliance authority fails to respond 

within seven days of notification and the permittee believes such change would not reasonably be 

expected to cause an increase in D/F emissions that might jeopardize compliance with the applicable D/F 

standard, the change may be implemented immediately without performance testing. A significant 

change shall not include switching to a feed/fuel mix for which the permittee already tested in 

compliance with the dioxin/furan and PM emission limits. [Permit 0250020-017-AC] 

10. Continuous Emission Monitoring Systems: The owner or operator shall install, calibrate, maintain, and 

operate continuous emission monitoring systems (CEMS) in the in-line kiln/raw mill stack to measure 

and record the emissions of NOX, SO2, CO, and VOC from the in-line kiln/raw mill, in a manner 

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

express the results in units of pounds per ton of clinker produced and pounds per hour. Emissions of 

VOC shall be reported in units of the standards (lb/hour, lb/ton clinker) and ppmvd as propane corrected 

to 7% oxygen. 

a. Compliance Demonstration: Compliance with the short-term emission limits for NOX, SO2, CO, and 

VOC shall be based on a 24-hour block average. The 24-hour block shall begin at midnight of each 

operating day and shall be calculated from 24 consecutive hourly average values. If there are less 

than 24 hours during the block, the 24-hr block average shall be the average of all valid hourly 

average values available during the 24 hour block. Compliance with the long-term emission limits 

for SO2, CO, and VOC shall be based on a 30 operating-day block average that shall be computed as 

the arithmetic average of all valid hourly averages occurring within each 30 operating-day block. 

For purposes of the SO2, CO, and VOC long-term emission limits, an operating day is any day that 

the kiln produces clinker or fires fuel. The first 30 operating day block shall begin the first operating 

day on or after January 1, 2006. 

b. Compliance with the long-term NOX emissions limit: Compliance with the long-term NOX emission 

limit shall be based on a 12 month rolling average that shall be recomputed each month as the 

arithmetic average of that month and the preceding 11 months. Each monthly average shall be 

computed by averaging all valid hourly averages occurring within each calendar month. The first 12 

month period shall commence on January 1, 2006. 

c. Valid Hourly Averages: Each hourly average shall be computed as the arithmetic average of the data 

points generated by the CEM system. Data points must be generated at least once per minute. For 

an hourly average to be considered valid, at least two data points separated by a period of 15 minutes 

or more must be used to compute the hourly average. 

• Hours during which there is no preheater feed and no fuel fired to the kiln systems are not valid. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 13 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

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

excluded from the production-normalized emission rate computation (pounds per ton of dry 

preheater feed or pounds per ton of clinker). These hours are included in any pollutant mass 

emission rate computation (pounds per hour). 

d. Data Availability: During each semiannual (six-month) period, CEM system valid hourly averages 

shall be obtained for at least 95 percent of the operating hours for which the plant is producing 

clinker. If the CEM system does not obtain valid hourly averages for 95 percent or more of the 

operating hours per semiannual period for which the plant is producing clinker, the permittee shall 

also submit a continuous monitoring system performance report with the excess emissions report. 

This report must include corrective actions, and it shall be submitted within 30 days following the 

end of each reporting period. 

e. Compliance Assurance: CEM system breakdowns, malfunctions, repairs, calibration checks, zero 

adjustments, and span adjustments all result in periods during which CEM system data are not 

obtained. During such periods in excess of five percent of the total operating hours per calendar 

quarter, the permittee shall assure compliance with the emissions standards of this permit through 

stack tests, alternative monitoring systems, or other methods as approved by the Department. 

[Permit 0250020-017-AC] 

11. Continuous Emissions Monitor System (CEMS) Requirements: All CEM systems shall be operational, 

recording and continuously transmitting available data. The monitoring systems shall be certified in 

accordance with the appropriate Performance Specification in 40 CFR 60 Appendix B. The systems 

shall comply with the requirements for continuous monitoring systems found in the general provisions of 

40 CFR 63, Subpart A including development of a quality control program. Data on monitoring 

equipment specifications, manufacturer, type calibration and maintenance requirements, and the 

proposed location of each monitor shall be provided to the DERM for review at least 45 days prior to 

replacement of any CEMS. [Permit 0250020-017-AC; and 62-204.800, F.A.C.] 

12. Mercury Compliance Demonstration: The owner or operator shall demonstrate compliance with the 

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

12-month mercury throughput. The following sampling and analytical procedures shall be used: 

a. Samples of the raw mill feed and all fuels shall be collected each day. A single composite daily 

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

made from each of the daily composite samples. 

b. Each monthly composite sample shall be analyzed to determine the representative mercury 

concentration for the month. 

c. For each composite sample, the monthly mercury throughput rate (pounds per month) shall be the 

product of the mercury concentration from the monthly composite sample and the corresponding 

monthly processing rate. 

d. For each month, the mass of mercury introduced into the pyroprocessing system (pounds per month) 

shall be the sum of the monthly mercury throughput rates for each raw material and fuel. 

e. The consecutive 12-month mercury throughput rate shall be the sum of the individual monthly 

records for the current month and the preceding eleven months (pounds of mercury per consecutive 

12-months). Such records, including calculations and data, shall be completed no later than 25 days 

following the month of the records. The first 12-month rolling period shall begin on August 1, 2006. 

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

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

unless prior written approval is received from the Department. If the mercury concentration is below 

detection limit or below the limits of quantification, the detection limit will be assumed for the 

concentration of the raw material or fuel, the permittee shall report the detection limit as the 

corresponding level. [Permit 0250020-019-AC; Compliance with 229 lb Hg/12-month limitation] 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 14 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

On-Specification Used Fuel Oil 

13. Limits and Test Methods Applicable to On-Spec Fuel Oil: 

a. "Non-hazardous on-specification" used oil is defined as each used oil delivery that meets the 40 CFR 

279 (Standards for the Management of Used Oil) specifications listed below. Used oil that does not 

meet all of the following specifications shall not be fired. 

CONSTITUENT/PROPERTY LIMIT TEST METHOD (2)

Arsenic 5 ppm EPA SW-846 (3040-7130) 

Cadmium 2 ppm EPA SW-846 (3040-7130) 

Chromium 10 ppm EPA SW-846 (3040-7130) 

Lead 100 ppm EPA SW-846 (3040-7130) 

Total Halogens <1000 ppm (1) ASTM E442 

PCBs <50 ppm ASTM D4059 

Flash Point 100 °F (minimum) ASTM D93 

Sulfur % by weight (informational) ASTM D2622, D4294-90, or 

both D4057-88 & D129-91 

Heat of Combustion Btu/gal (informational) ASTM D240-76 

Density Lb/gal (informational) ASTM D1298-80 

(1) 40 CFR 279.10(b)(1) (ii) Rebuttable presumption for used oil. Used oil containing more than 

1,000 ppm total halogens is presumed to be a hazardous waste because it has been mixed with 

halogenated hazardous waste listed in subpart D of 40 CFR part 261. Persons may rebut this 

presumption by demonstrating that the used oil does not contain hazardous waste (for example, 

by using an analytical method from SW–846, Edition III, to show that the used oil does not 

contain significant concentrations of halogenated hazardous constituents listed in appendix VIII 

of 40 CFR part 261). EPA Publication SW–846, Third Edition, is available from the 

Government Printing Office, Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 

15250–7954, (202) 512–1800 (document number 955–001–00000–1”). If successfully rebutted 

for used oil up to 4000 ppm total halogens, used oil up to 4000 ppm maximum total halogens 

may be fired. 

(2) Other test methods may be used only after receiving written approval from the DERM. 

b. Analysis of Used Oil Fuel. The permittee may determine that the used oil to be burned for energy 

recovery meets the fuel specifications of §279.11 by performing analyses, or obtaining copies of 

analyses or other information, documenting that the used oil fuel meets the specifications. 

c. Record Retention. The permittee must keep copies of analyses of the used oil (or other information 

used to make the determination) for five years. 

d. Fuel Analysis for On-specification Used Oil Requirements. Fuel analysis shall be in accordance 

with 40 CFR 266.43(b)(1) & (6). A sample shall be taken from the outlet of the blend tank on the 

first working day (i.e., Monday-Friday; exceptions: holidays) of each month, if any used oil was 

placed in the blend tank the previous month; or, the sample can be taken directly from the used oil 

mobile collection tank after final collection and prior to the time of initial transfer; but, that sampling 

frequency shall be no less than quarterly and the sampling methodology shall have been established 

with the DERM, Miami-Dade County prior to sampling. Upon taking a sample, the sample shall be 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 15 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

analyzed for the following constituent/property and associated unit and using the following test 

methods (or their latest version): 

e. Submittal of Samples. The results of each sample analysis (on the laboratory’s letterhead) shall be 

submitted to the DERM within 30-days after the sample is taken and analyzed. 

f. Sample Results. The results of each sample analysis (on the laboratory’s letterhead) shall be 

submitted to the DERM within 30 days after a sample is taken and analyzed. 

[Permit 0250020-017-AC; 40 CFR 279.11 (which is adopted by reference in Rule 62-710.210(2), 

F.A.C.), 40 CFR 279.72; 40 CFR 63.1343 and 63.1345] 

14. Used Oil Usage Records: In order to document compliance with the used oil limitations, the following 

requirements shall be adhered to as a minimum: 

a. Transfers to Storage Tank. The dates and quantities of both on-specification used oil and purchased 

fuel oil transferred to the in-line kiln/raw mill's storage tank shall be reported quarterly (i.e., Jan.-

Mar., April-June, July-Sept., and Oct.-Dec.) to the DERM and due during the month following the 

end of the quarter. 

b. Recordkeeping. When burning used oil, records shall be maintained in accordance with applicable 

provisions of 40 CFR 279, Subpart B and Subpart G (July 1, 1996 version), Standards for the 

Management of Used Oil and Chapter 62-710, F.A.C. 

c. Delivery Receipts. The following shall be recorded on the delivery receipt: 

• the use of tamper proof seals on the delivery receipt 

• the volume of fuel delivery 

• a cross reference to the analysis which establishes that the used oil meets EPA used oil fuel 

specifications 

• the results of the screening analysis 

• the name of the person performing the test 

• the specific test kit used 

• the amount of oil sampled 

• the amount and name of the solution used to dilute the oil 

d. Delivery Procedures. The following procedures shall be implemented: 

• On and off specification used oil that is delivered without a delivery receipt containing all the 

above information, or which is not properly sealed, or for which the delivery receipt does not 

contain all the necessary information, is not to be accepted and the DERM is to be notified by 

phone immediately (with written confirmation to follow), if such a delivery is attempted. 

• Verification by signature on the delivery receipt shall be provided by plant personnel that the 

delivery truck arrived on site with all seals intact. As delivered samples of all used oil fuel 

received shall be accumulated through each quarter for each supplier. 

[Permit 0250020-017-AC; DERM Requirements] 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 16 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection B. Cement Plant Pyroprocessing and Raw Mill System 

Process and Production Recording 

15. Production Rate Recording: The owner or operator shall record the preheater kiln feed rate using the 

F.L. Smidth automated preheater feed weighing device and record the daily clinker production. The 

clinker production rate for the purposes of determining compliance with Specific Condition 2, shall be 

determined as the product of Preheater Kiln Feed and the Loss on Ignition (LOI) factor. LOI for the 

preheater kiln feed is based on a 30 operating-day block average of daily measurements. For purposes of 

this requirement, an operating day is any day that the kiln produces clinker or fires fuel. The calculation 

shall be expanded as needed to consider the additional feed points and LOI. [Permit 0250020-017-AC] 

16. Excess Emissions Reports: In case of excess emissions resulting from malfunctions, the owner or 

operator shall notify the DERM in accordance with Rule 62-4.130, F.A.C. A full written report on the 

malfunctions shall be submitted in a quarterly report. 

[Rules 62-210.700(6) and 62-4.070(3), F.A.C.] 

Test Procedures, Recordkeeping and Additional Requirements 

17. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 17 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection C. Cement Plant Clinker Handling & Storage 

This subsection addresses the following emissions units system. 

ARMS Emissions Unit No. Brief Description of Emissions Unit 

027 Cement Plant Clinker Handling & Storage System 

The clinker handling operations are controlled by the following baghouses: 

Emissions Point Descriptions of Emissions Points 

Baghouse I. D: 441.BF540 Conveyance/transfer from cooler to new clinker silos and off-spec silo 

Baghouse I. D: 481.BF140 Conveyance/transfer/storage for new clinker silos and off-spec silo 

Baghouse I. D: 481.BF330 Storage from off-spec silo and conveyance from new clinker silos 

Baghouse I. D: 481.BF540 Conveyance from new clinker silos and off-spec silo to old clinker storage 

Baghouse I. D: 481.BF640 Conveyance from new clinker and off-spec silos to old clinker storage area 

Baghouse I. D: 481.BF730 Conveyance/transfer to old clinker area and storage clinker silos 2, 5, 18 

Baghouse I. D: 481.BF930 Storage clinker silos 21, 22, 26, 27 

Baghouse I.D: F-633 Storage clinker silos 12, 19, 20, 23, 28 

Baghouse K-447 Storage clinker silo 17 

Operational Requirements 

1. Hours of Operation: This emissions unit is allowed to operate 8760 hours per year. Production is 

automatically limited by the clinker production limits established in Subsection B., Specific 

Condition 2 for the pyroprocessing system. [Permits 0250020-017-AC and 0250020-019-AC] 

Emissions Limitations, Test Methods and Performance Standards 

2. Visible Emissions Limits: Visible emissions are limited to 5 percent from each of the above listed 

baghouses. Compliance shall be determined in the manner described in 40 CFR 63.1350(a)(4)(i), (ii), 

(iii) and (iv) below except that the applicable standard is 5% instead of 10%. Numeration tracks the 

referenced CFR provision. 

(4) Procedures to be used to periodically monitor affected sources subject to opacity standards under 

Sections 63.1346 and 63.1348. Such procedures must include the provisions of Paragraphs 

(a)(4)(i) through (a)(4)(iv) of this section. 

(i) The owner or operator must conduct a monthly 1-minute visible emissions test of each 

affected source in accordance with Method 22 of Appendix A to [40 CFR] Part 60 of this 

chapter. The test must be conducted while the affected source is in operation. 

(ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, 

the owner or operator 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 

owner or operator 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. 

(iii)If no visible emissions are observed during the semi-annual test for any affected source, the 

owner or operator 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 owner or 

operator must resume testing of that affected source on a monthly basis and maintain that 

schedule until no visible emissions are observed in six (6) consecutive monthly tests. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 18 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection C. Cement Plant Clinker Handling & Storage 

(iv) If visible emissions are observed during any Method 22 test, the owner or operator 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. 

{Note: The applicant advised that the baghouses are designed to control particulate emissions to 

0.0095 grains/dry standard cubic foot (gr/dscf) and 0.01 gr/acf (Baghouse F-633). The 5% opacity 

limitation is consistent with this design and provides reasonable assurance that annual emissions of 

PM/PM10 for all emission points in this emission unit system will be less than 19.70 TPY. This annual 

emission estimate is part of the facility-wide netting calculation to escape PSD applicability for 

PM/PM10. Exceedance of the 5% opacity limit shall be deemed an exceedance of this permit 

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

LLL} 

[Permits 0250020-017-AC; and 40 CFR 63.1348] 

Test Procedures, Recordkeeping and Additional Requirements 

3. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 19 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection D. Cement Plant Finish Mills 1 - 6 

This subsection addresses the following emissions units. 

ARMS Emissions Unit No. Brief Descriptions of Emissions Units 

010 Cement Plant Finish Mill No. 1 

011 Cement Plant Finish Mill No. 2 

012 Cement Plant Finish Mill No. 3 

013 Cement Plant Finish Mill No. 4 

030 Cement Plant Finish Mill No. 6 

The finish mill handling operations are controlled by the following baghouses: 

Emissions Point Descriptions of Emissions Points 

Baghouse I.D. F-113 Dust collector – Finish Mill No. 1 – Feeder 

Baghouse I.D. F-130 Dust collector – Finish Mill No. 1 – Mill Sweep 

Baghouse I.D. F-213 Dust collector – Finish Mill No. 2 – Feeder 

Baghouse I.D. F-230 Dust collector – Finish Mill No. 2 – Mill Sweep 

Baghouse I.D. F-313 Dust collector – Finish Mill No. 3 – Feeder 

Baghouse I.D. F-332 Dust collector – Finish Mill No. 3 – Mill Sweep 

Baghouse I.D. 533.BF340 Dust collector – Finish Mill No. 3 – O-Sepa Cement Separator 

Baghouse I.D. F-432 Dust collector – Finish Mill No. 4 – Belt conveyor/Separator 

Baghouse I.D. F-430 Dust collector – Finish Mill No. 4 – Ball Mill/Mill Sweep 

Baghouse I.D. F-730 Dust collector – Finish Mill No. 4 – O-Sepa Cement Separator 

Baghouse I.D. 536.BF340 Dust collector – Finish Mill No. 6 – O-Sepa Cement Separator 

Baghouse I.D. 536.BF500 Dust collector – Finish Mill No. 6 – Sweep 

Baghouse I.D. 516.BF510 Dust collector – Finish Mill No. 6 – Feeder 

Operational Requirements 

1. Hours of Operation: These emissions unit system is allowed to operate 8,760 hours per year. Finish 

Mill No. 2 (EU 011) shall not operate unless one of the other Finish Mills is not in operation. 

[Permits 0250020-017-AC and 0250020-019-AC] 

2. Finish Mill Process Rates: The maximum total hourly process rate of cement is 359 TPH on a 24-

hour block average. The individual process rates are 25 TPH (Finish Mill 1); 25 TPH (Finish Mill 2); 

84 TPH (Finish Mill 3); 140 TPH (Finish Mill 4); and 110 TPH (Finish Mill 6). The owner or 

operator shall record all hourly process rates, and maintain records for a minimum of 5 years. 

[Permits 0250020-017-AC and 0250020-019-AC] 

Emissions Limitations, Test Methods and Performance Standards 

3. Visible Emissions Limits: Visible emissions are limited to 5 percent from each of the above listed 

baghouses. For baghouses F-113, F-213, F-313, and 516.BF510, compliance shall be determined in 

the manner described in 40 CFR 63, Section 63.1350(a)(4)(i), (ii), (iii) and (iv) below except that the 

applicable standard is 5% instead of 10%. Numeration tracks the referenced CFR provision. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 20 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection D. Cement Plant Finish Mills 1 - 6 

(4) Procedures to be used to periodically monitor affected sources subject to opacity standards under 

Sections 63.1346 and 63.1348. Such procedures must include the provisions of Paragraphs 

(a)(4)(i) through (a)(4)(iv) of this section. 

(i) The owner or operator must conduct a monthly 1-minute visible emissions test of each 

affected source in accordance with Method 22 of Appendix A to [40 CFR] Part 60 of this 

chapter. The test must be conducted while the affected source is in operation. 

(ii) If no visible emissions are observed in six consecutive monthly tests for any affected 

source, the owner or operator may decrease the frequency of testing from monthly to semiannually for that affected source. If visible emissions are observed during any semi-annual 

test, the owner or operator 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. 

(iii) If no visible emissions are observed during the semi-annual test for any affected source, the 

owner or operator 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 owner or 

operator must resume testing of that affected source on a monthly basis and maintain that 

schedule until no visible emissions are observed in six (6) consecutive monthly tests. 

(iv) If visible emissions are observed during any Method 22 test, the owner or operator 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. 

{Note: The applicant advised that the baghouses are designed to control particulate emissions to 

0.0095 grains/dry standard cubic foot (gr/dscf) and 0.01 gr/acf (F-113; F-130; F-213; F-230; F-313; 

F-330; F-430; and F-432). The 5% opacity limitation is consistent with this design and provides 

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

system will be less than 136.15 TPY. This annual emission estimate is part of the facility-wide netting 

calculation to escape PSD applicability for PM/PM10. Exceedance of the 5% opacity limit shall be 

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

limitations given in 40 CFR 63, Subpart LLL} 

[Permits 0250020-017-AC and 0250020-019-AC; 40 CFR 63.1348] 

Monitoring Requirements 

4. Finish Mill Monitoring: For baghouses F-130, F-230, F-332, 533.BF340, F-432, F-430, F-730, 

536.BF340 and 536.BF500, the owner or operator of a finish mill shall monitor opacity by conducting 

daily visual emissions observations of the mill sweep and air separator PMCDs (PM control devices) 

of these affected sources, in accordance with the procedures of Method 22 of Appendix A, 40 CFR 

Part 60 and as required by 40 CFR 63.1350(e), Subpart LLL. 

Pursuant to 40 CFR 63.1350(e):

The owner or operator 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 to Part 60 of this chapter. The Method 

22 test shall be conducted while the affected source is operating at the representative performance 

conditions. The duration of the Method 22 test shall be six minutes. If visible emissions are observed 

during any Method 22 visible emissions test, the owner or operator must: 

(1) Initiate, within one-hour, the corrective actions specified in the site specific operating and 

maintenance plan developed in accordance with paragraphs (a)(1) and (a)(2) of this section; and 

Tarmac America, LLC Title V Operation Permit Renewal 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection D. Cement Plant Finish Mills 1 - 6 

(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. 

[Permits 0250020-017-AC and 0250020-019-AC; 40 CFR 63.1350, Monitoring Requirements] 

Test Procedures, Recordkeeping and Additional Requirements 

5. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 22 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection E. Cement Plant Storage & Packhouse/Loadout System 

This subsection addresses the following emissions units system. 

ARMS Emissions Unit No. Brief Descriptions of Emissions Units 

014 Cement Plant Storage Silos 1 through 12 

015 Cement Plant Distribution Rail Truck Load 

016 Cement Plant Packhouse 

The cement handling operations are controlled by the following baghouses: 

Emissions Point No. Description of Emissions Points 

Baghouse I.D. F-511 Dust collector - Cement Silos 1-6 

Baghouse I.D. F-512 Dust collector - Cement Silos 7-9 

Baghouse I.D. F-513 Dust collector - Cement Silo 10 

Baghouse I.D. F-514 Dust collector - Cement Silo 11 

Baghouse I.D. F-515 Dust collector - Cement Silo 12 

Baghouse I.D. B-110 Dust collector - Bulk Loadout Unit 1 (Rail/Truck). 

Baghouse I.D. B-210 Dust collector - Bulk Loadout Unit 2 (Truck). 

Baghouse I.D. VL002 Dust collector - Bulk Loadout Unit 2 - Line 2 (Truck Loadout Operation) 

Baghouse I.D. B-372 Dust collector - Bulk Loadout Unit 3 - Line 1 

Baghouse I.D. B-374 Dust collector - Bulk Loadout Unit 3 - Line 2 

Baghouse I.D. B-382 Dust collector - Bulk Loadout Unit 3 - Line 3 

Baghouse I.D. VL003 Dust collector - Bulk Loadout Unit 3 - Line 3 (Truck Loadout Operation) 

Baghouse I.D. B-120 Dust collector - Packhouse 

Baghouse I.D. B-200 Dust collector - Packhouse 

Baghouse I.D. B-400 Dust collector - Packhouse 

Operational Requirements 

1. Hours of Operation: These emissions units are allowed to operate 8,760 hours per year. 

[Permits 0250020-017-AC and 0250020-019-AC] 

2. Cement Storage Silo/Packhouse/Loadout Process and Production Design Specifications: The 

maximum process input rate to each cement silo and loadout operation is 500 TPH on a 24-hour block 

average. The maximum production rate of cement in the Packhouse is 170 TPH on a 24-hour block 

average. [Permit 0250020-017-AC and 0250020-019-AC] 

Emissions Limitations, Test Methods and Performance Standards 

3. Visible Emissions Limits: Visible emissions are limited to 5 percent from each of the above listed 

baghouses. Compliance shall be determined in the manner described in 40 CFR 63, Section 

63.1350(a)(4)(i), (ii), (iii) and (iv) below except that the applicable standard is 5% instead of 10%. 

Numeration tracks the referenced CFR provision. 

(4) Procedures to be used to periodically monitor affected sources subject to opacity standards under 

Sections 63.1346 and 63.1348. Such procedures must include the provisions of Paragraphs 

(a)(4)(i) through (a)(4)(iv) of this section. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection E. Cement Plant Storage and Packhouse/Loadout System 

(i) The owner or operator must conduct a monthly 1-minute visible emissions test of each 

affected source in accordance with Method 22 of Appendix A to [40 CFR] Part 60 of this 

chapter. The test must be conducted while the affected source is in operation. 

(ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, 

the owner or operator 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 

owner or operator 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. 

(iii)If no visible emissions are observed during the semi-annual test for any affected source, the 

owner or operator 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 owner or 

operator must resume testing of that affected source on a monthly basis and maintain that 

schedule until no visible emissions are observed in six (6) consecutive monthly tests. 

(iv) If visible emissions are observed during any Method 22 test, the owner or operator 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. 

{Note: The applicant advised that the baghouses are designed to control particulate emissions to 0.01 

grains/actual cubic foot (gr/acf) except for baghousesVL002 and VL003 which are designed to 0.03 

gr/acf. The 5% opacity limitation is consistent with this design and provides reasonable assurance 

that annual emissions of PM/PM10 for all emission points in this emission unit system will be less than 

36.30 TPY. This annual emission estimate is part of the facility-wide netting calculation to escape 

PSD applicability for PM/PM10. Exceedance of the 5% opacity limit shall be deemed an exceedance 

of this permit condition and not necessarily an exceedance of the opacity limitations given in 40 CFR 

63, Subpart LLL} 

[Permits 0250020-017-AC; 40 CFR 63.1348] 

Test Procedures, Recordkeeping and Additional Requirements 

4. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 24 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection F. Cement Plant Coal & Petroleum Coke Handling System 

This subsection addresses the following emissions units system. 

ARMS Emissions Unit No. Brief Description of Emissions Unit 

026 Cement Plant: Coal and Petroleum Coke Handling System 

The provisions of 40 CFR 60 Subpart Y, Standards of Performance for Coal Preparation Plants and 40 

CFR 60, Subpart A- General Provisions are applicable to this process emissions unit system (Appendix A 

and Appendix Y attached). 

The coal handling operations are controlled by the following baghouses: 

Emission Point Description of Emissions Points 

Baghouse I.D. 461-BF500 Coal Mill*

Baghouse I.D. 461-BF130 Coal Feed Bin 

Baghouse I.D. 461-BF230 Petroleum Coke Feed Bin 

Baghouse I.D. 461-BF750 Coke/Petroleum Coke (Transfer ) Surge Bin Feeder 

Baghouse I.D. 461-BF650 Coal (Transfer) / Surge Bin (Feeder) 

Baghouse I.D. 461-BF350 Coal Mill Feed 

* This emissions unit discharges to the common (main) stack. The Clinker Cooler which is limited to 

10% opacity, discharges to the common (main) stack and therefore determines the opacity limit for this 

emissions unit. Total PM/PM10 emissions from Pyroprocessing/Raw Mill/Coal Mill Systems shall not 

exceed 117 and 99 TPY respectively. [Permits 0250020-017-AC and 0250020-019-AC] 

All of the above process emissions units are subject to 40 CFR 60, Subpart Y, NSPS for Coal Preparation 

Plants, except units solely engaged in processing, handling or storage of petroleum coke. 

Operational Requirements 

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

[Permit 0250020-017-AC] 

2. Coal/Petroleum Coke Maximum Usage: The maximum combined usage of coal and petroleum coke 

is 30 TPH on a 24-hour block average and 263,000 TPY. The maximum petroleum coke usage rate 

shall not exceed 20 TPH on a 24-hour block average. Daily records of usage must be kept on site and 

retained for a minimum of 5 years. [Permit 0250020-017-AC] 

Emissions Limitations, Test Methods and Performance Standards 

3. Visible Emissions Limits: Visible emissions are limited to 5 percent from each of the above listed 

baghouses, except for the coal mill main baghouse 461-BF500. Compliance shall be demonstrated by 

EPA Reference Method 9 and the procedures specified in 40 CFR 60.11. 

For the coal mill main, baghouse 461-BF500, the opacity shall not exceed 10%. Compliance shall be 

demonstrated pursuant to EPA Reference Method 9. Annual emissions of PM10 for the 

kiln/cooler/coal mill main stack shall not exceed 99 TPY. 

{Note: The applicant advised that the baghouses are designed to control particulate emissions to 

0.0095 grains/dry standard cubic foot (gr/dscf) and to 0.01 grains/actual cubic foot (gr/acf) (for 

baghouses 461-BF300; 461.BF350). The 5% opacity limitation is consistent with this design and 

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

emission unit system will be less than 3.10 TPY. This annual emission estimate is part of the facilitywide netting calculation to escape PSD applicability for PM/PM10. Exceedance of the 5% opacity 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection F. Cement Plant Coal & Petroleum Coke Handling System 

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

opacity limitations given in 40 CFR 60, Subpart Y} 

[Permits 0250020-017-AC and 0250020-019-AC; 40 CFR 60, Subpart Y; Rules 62-297.620(4); 

40 CFR 63.1348] 

4. Particulate and Fugitive Emissions: Particulate and fugitive emissions from coal handling facilities 

shall be minimized by following the procedures listed below: 

a. All conveyers and transfer points shall be enclosed or covered to preclude particulate emissions 

(except those directly associated with coal stacking/reclaiming). 

b. Coal storage piles shall be shaped, compacted and oriented to minimize wind erosion. 

c. Water sprays or chemical wetting agents and stabilizers shall be applied to storage piles, handling 

equipment, etc., during dry periods as necessary to all facilities to maintain an opacity of less than 

20 percent at the property line for fugitive emission sources. 

[Permits 0250020-017-AC; Rule 62-296.320(4)(c), F.A.C.] 

Test Procedures, Recordkeeping and Additional Requirements 

5. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 26 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection G. Facility Fugitive Emissions 

This subsection addresses the following emissions units 

ARMS Emissions 

Unit No. Brief Description of Emissions Unit and/or Activities 

031 

Facility-wide particulate matter fugitive emissions from miscellaneous 

activities, such as truck operations throughout the facility, wind erosion, etc. 

Fugitive Emissions – Transportation, Miscellaneous Transfers, and Storage 

Unregulated Emissions Units and/or Activities: An emissions unit which emits no “emissions-limited 

pollutant” and which is subject to no unit-specific work practice standard, though it may be subject to 

regulations applied on a facility-wide basis (e.g., unconfined emissions, odor, general opacity) or to 

regulations that require only that it be able to prove exemption from unit-specific emissions or work 

practice standards. 

Vehicular traffic and coal, petcoke, and raw material transfer points generate fugitive PM emissions from 

the handling, transfer, and storage between the unloading areas and the storage building. The activities 

are listed in the following table: 

Activity Description Estimated Emissions (PM and PM10)*

Coal Handling Drop Operations 0.17 and 0.059 TPY 

Coal Handling Vehicular Traffic 6.9 and 2.4 TPY 

Raw Material Blending Drop Operations 1.6 and 0.6 TPY 

Raw Material Blending Vehicular Traffic 14 and 4.9 TPY 

Total Quantifiable Emissions Fugitive Emissions 23 and 8 TPY 

* The estimates given were included in calculations by the applicant demonstrating that the modernization 

and production increase projects related to the cement plant do not trigger PSD. It is not practicable to 

actually measure the emissions directly. Reasonable assurance that these emissions are controlled to 

the levels given above is by adherence to the Reasonable Precautions listed below.

[Permits 0250020-017-AC] 

1. Reasonable Precautions for Emissions of Unconfined Particulate Matter: This facility is subject to 

applicable requirements of Rule 62-296.320(4)(c)1, 2, 3, & 4, F.A.C. Refer to Appendix CG: 

Common and General Conditions. 

2. Additional Reasonable Precautions for Emissions of Unconfined Particulate Matter: Pursuant to 

Rule 62-296.320(4)(c)2, F.A.C, the permittee shall implement the following additional reasonable 

precautions at this facility: 

Personnel 

a. Aggregate and material handling personnel, their supervisors, and environmental personnel, shall 

be trained in visible emissions, permit conditions related to fugitive emissions, and the Best 

Management Practices developed by Titan to implement the Fugitive Dust Improvement Plan 

under Construction Permit 0250020-017-AC. 

b. Personnel shall be trained on proper operation of wet-dry sweeper and water trucks. Training 

shall include but not be limited to speed, nozzle operation, and cleaning patterns around the plants 

that comprise the facility. 

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Titan Pennsuco Complex DEP File No. 0250020-018-AV 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection G. Facility Fugitive Emissions 

Roads 

The permittee shall: 

c. Continue to identify areas where the installation of speed bumps would be beneficial in reducing 

vehicular speed and fugitive emissions. 

d. Continue cleaning and maintaining paved road surfaces, which includes removing silt build-up, 

repairing all potholes, sweeping on a daily basis and utilizing a water truck to control visible 

emissions. 

e. Continue to maintain dedicated berm areas that have been established throughout the facility to 

further reduce wind erosion from ground areas. 

f. Operate the sprinkler system, as needed, to reduce dust along the aggregate road between the pits 

and the raw materials storage building and other areas of the facility. 

g. Maintain and continuously improve the main entrance by establishing green areas between the 

security gate and the main facilities. 

Materials 

h. To the extent feasible, raw materials and fuels for the cement facility will be stored inside the raw 

material building. Outside material storage will be maintained to control fugitive emission from 

all raw material and fuels. All material within the raw material building will be moved by 

stacker/reclaimer and covered conveyor belts. 

i. All conveyors are to be enclosed on at least three sides. 

j. The facility shall continue to maintain the clinker production area and continue to implement a 

cleaning process inside buildings to minimize dust emitted to the outside environment. 

k. Unloading and reclaiming of materials will be curtailed during windy or dry conditions. 

l. Raw materials will be managed to minimize their time in storage. 

Trucks 

m. All trucks leaving the aggregate facility will be required to dewater and drive through the tire 

wash system. 

n. Titan America/Tarmac will work with all transport companies to further educate drivers in the 

Florida Department of Transportation requirements that all loads be tarped prior to leaving the 

facility. 

o. All trucks traveling within the cement facility should stay on asphalt or concrete surfaces. All 

road surfaces outside of the aggregate facility shall be constructed of concrete and/or asphalt. 

[Rule 62-296.320(4)(c)2.,F.A.C., Rule 62-4. 070(3)F.A.C., Application received April 18, 2005 and, 

Fugitive Dust Improvement Plan dated August 19, 2005] 

3. Fugitive Dust Improvement Plan - Appendix CP-1: The owner or operator shall complete the 

Fugitive Dust Improvement Plan described within the Compliance Plan under Appendix CP-1 that is 

part of this permit. The permittee shall submit quarterly progress reports to include a status report on 

the action implemented. The first quarterly report was submitted in January 2006. The updates shall 

be submitted every 3 months thereafter for a two-year period. The progress reports shall be submitted 

to the Compliance Authority (Miami-Dade County DERM). 

4. Unconfined Emissions of Particulate Matter: Refer to Section II, Specific Condition No. 7.

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection H. Aggregate Plant 

This subsection addresses the following emissions units. 

ARMS Emissions 

Unit No. Brief Descriptions of Emissions Units 

022 Nonmetallic Mineral Processing Plant Equipment and Operations at the 

Aggregate Plant Subject to 40 CFR 60, Subpart OOO 

023 Nonmetallic Mineral Processing Plant Equipment and Operations at the 

Aggregate Plant NOT Subject to 40 CFR 60, Subpart OOO 

This Subsection covers raw materials processing (limestone & overburden) from the quarry up to the raw 

materials storage. The quarry and its associated processing plant have been in operation since 1960 and 

consist of nonmetallic mineral processing operations such as crushing, screening, conveying, storage, and 

rail and truck loadout operations. The above emissions unit (EU 022) also includes an aggregate plant, 

that is adjacent to the portland cement manufacturing plant. 

At least two construction permits directly related to these two units have been issued. They are permit 

AC13-234568, issued by the Florida Department of Environmental Protection on November 18, 1993 and 

Permit 0250020-012-AC, issued by the DERM on January 25, 2002. 

{Permitting Note: Table 1, Emissions Unit Identification & Summary of Air Pollutant Standards for the 

Nonmetallic Mineral Processing Plant (E.U. ID Nos. 022 and 023), contains a list of equipment units and 

their corresponding air pollutant standards, it also summarizes maximum visible emissions standards. 

An affected facility in fixed or portable nonmetallic mineral processing plant is each crusher, grinding 

mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck 

or railroad loading station. The information contained in the table is for convenience purposes only and 

does not supersede any of the terms or conditions of this permit} 

Regulations and Requirements

1. Emissions unit (E.U. 022) shall comply with all applicable requirements contained in the attached 

Appendix OOO: 40 CFR 60, Subpart OOO, Standards of Performance for Nonmetallic Mineral 

Processing Plants; and the attached Appendix A: 40 CFR 60, Subpart A – NSPS, General Provisions. 

The term "Administrator" when used in 40 CFR 60 shall mean the Secretary or the Secretary's 

designee. 

Essential Potential to Emit (PTE) Parameters 

2. Permitted Capacity: 

a. The processed raw material throughput is limited to 1,213,333 tons per month and 14,560,000 

tons in any consecutive 12-month period. See Table 1 of this subsection for the capacity of each 

component of the nonmetallic mineral processing plant equipment. 

b. For testing purposes, the maximum throughput is 2,000 tons per hour. 

[Permit 0250020-012-AC; Rule 297.310(2)(b), F.A.C.; Rule 62-210.200, F.A.C. (Definitions, 

Potential to Emit), and Rule 62-4.070(3), F.A.C., Reasonable Assurance for Specific Condition 4 and 

to net out of PSD] 

3. Hours of Operation: The referenced emissions unit(s) may operate continuously (8760 hours per 

year). [Permit 0250020-012-AC] 

Emissions Limitations and Standards 

4. Particulate Matter Limitations: The maximum allowable particulate matter emissions are 35.4 TPY 

of PM and 14 TPY of PM10. [Permit 0250020-012-AC] 

Tarmac America, LLC Title V Operation Permit Renewal 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection H. Aggregate Plant 

5. Visible Emissions:

a. No person shall cause, let, permit, suffer or allow to be discharged into the atmosphere the 

emissions of air pollutants from any activity, which exhibit opacity greater than 20 percent.

[Rule 62-296.320(4)(b), F.A.C.] 

b. No owner or operator shall cause to be discharged into the atmosphere from any crusher subject 

to NSPS Subpart OOO, at which a capture system is not used, fugitive emissions which exhibit 

opacity greater than 15 percent. [40 CFR 60.672(c)] 

c. No visible emissions from wet screening operations and subsequent screening operations, bucket 

elevators, and belt conveyors that process saturated material in the production line up to the next 

crusher, grinding mill or storage bin. (For those operations/equipment subject to NSPS Subpart 

OOO.) [40 CFR 60.672(h)(1)] 

Test Methods and Procedures 

6. Visible Emissions Test Required: During the calendar year prior to expiration of this permit, the 

owner or operator shall determine compliance with all visible emissions limits on all nonmetallic 

mineral processing equipment, excluding storage piles. The owner or operator shall use EPA 

Method 9 and the procedures in 40 CFR 60.11, with the following additions: 

a. The minimum distance between the observer and the emissions unit shall be 4.57 meters (15 

feet). 

b. The observer shall, when possible, select a position that minimizes interference from other 

fugitive emissions units (e.g., road dust). The required observer position relative to the sun (EPA 

Method 9, Section 2.1) must be followed. 

c. For affected emissions units using wet dust suppression for particulate matter control, a visible 

mist is sometimes generated by the spray. The water mist must not be confused with particulate 

matter emissions and is not to be considered a visible emission. When a water mist of this nature 

is present, the observation of emissions is to be made at a point in the plume where the mist is no 

longer visible. 

[Rules 62-204.800 and 62-4.070(3), F.A.C; and, 40 CFR 60.675(c)(1), (2) & (3)]

7. Change of processing material (Saturated vs. Unsaturated): Any screening operation, bucket elevator, 

or belt conveyor that process saturated material and is subject to 40 CFR 672(h) and subsequently 

processes unsaturated material, shall submit a report of this change to the Department within 30 days 

following change. This screening operation, bucket elevator, or belt conveyor is then subject to the 

10 percent opacity limit in 40 CFR 672(b) and the emissions test requirement of 40 CFR 60.11 and 40 

CFR 60, Subpart OOO. Likewise a screening operation, bucket elevator, or belt conveyor that 

processes unsaturated material but subsequently processes saturated material shall submit a report of 

this change to the Department within 30 days following such change. This screening operation, 

bucket elevator, or belt conveyor is then subject to the no visible emissions limit in 40 CFR 

60.672(h). [40 CFR 60.676(g)] 

8. Annual Operating Report Supplemental Information: Annual-operating reports for the emissions 

units covered under this permit subsection shall include the following supplemental information that 

was recorded in the previous calendar year: 

• The amount of material processed on a monthly basis; and 

• A consecutive 12-month total of the amount of material processed, calculated from the monthly 

totals for the previous twelve calendar months. 

[Rule 62-4.070(3), F.A.C.] 

Tarmac America, LLC Title V Operation Permit Renewal 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection H. Aggregate Plant 

Reporting for Replacement of Facilities at Nonmetallic Mineral Processing Plants 

9. Replacement Exemption: When an existing facility is replaced by a piece of equipment of equal or 

smaller size, as defined in 40 CFR 60.671, having the same function as the existing facility, the new 

facility is exempt from provisions of 40 CFR 60.672 (standards for particulate matter), 40 CFR 

60.674 (Monitoring of operations), and 40 CFR 60.675 (Test methods and procedures). 

Reconstruction costs shall be calculated per 40 CFR 60.673. [40 CFR 60.670(d)(1)] 

10. Replacement Not Exempted: Replacing all existing facilities in a production line with new facilities 

does not qualify for the exemption described above. [40 CFR 60.670(d)(3)] 

11. Exemption Requirements: When seeking exemption, the permittee shall submit the following 

information to the DERM, Air Facilities Section, postmarked 60 days or as soon as practicable before 

the change is commenced and shall include the expected completion date of the change(s), as well as 

the following information: 

The required information shall be submitted for both the existing facility that was replaced, and the 

replacement equipment. 

When Replacing.... Required Information Rule Reference 

a crusher, grinding mill, bucket 

elevator, bagging operation, or 

enclosed truck or railcar loading 

station 

Rated capacity in tons per hour; Model 

and Serial Numbers 

40 CFR 60.676(a)(1) 

a screening operation The total surface area of the top screen; 

Model and Serial Numbers 

40 CFR 60.676(a)(2) 

a conveyer belt The width of the belt 40 CFR 60.676(a)(3) 

a storage bin The rated capacity in tons 40 CFR 60.676(a)(4) 

[40 CFR 60.7 and 40 CFR 60.676(a)] 

12. Replacement Prohibition: The permittee shall not replace any facility covered under this permit 

subsection with a piece of equipment of larger size or different function without applying for, and 

receiving, a modification of this permit to allow such replacement, unless this requirement is 

specifically waived in writing by the DERM, Air Facilities Section. [40 CFR 60.670] 

13. Unconfined Emissions of Particulate Matter: Refer to Section II. Specific Condition 7. 

[Rule 62-296.320 (4)(c) (2), F.A.C.; 40 CFR 60.670; Permit No. AC13-234568] 

14. Facility Common and General Conditions: This emissions unit is subject to all applicable 

requirements of the attached Appendices, made part of the permit. 

15. Aggregate Plant Reasonable Precautions. The following shall constitute additional reasonable 

precautions to control Unconfined Emissions of Particulate Matter for this plant: 

a. Paved parking and trafficked areas shall be maintained and kept free of particulate matter buildup. 

b. Sprinkling with water shall be used as necessary on paved areas and stockpiles. 

[Rule 62-296.320 (4)(c) (2), F.A.C.; 40 CFR 60.670; Permit No 0250020-012-AC issued 1/25/02, 

Permit No. AC13-234568 issued 11/18/93] 

Tarmac America, LLC Title V Operation Permit Renewal 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection I. Concrete Block Plant 

This subsection addresses the following emissions unit. 

ARMS Emissions Unit No. Brief Description of Emissions Unit 

024 Concrete Block Plant 

Operational Requirements 

1. Permitted Capacity: The maximum hourly production for the concrete block plant shall not exceed 

5,500 blocks per hour, approximately 96 tons per hour of concrete block. 

[Permit No. 0250020-014-AC] 

2. Hours of Operation: The Concrete Block Plant shall not exceed 6,240 hours of operation per year. 

The permittee shall keep a daily log of the number of hours of operation. [Permit 0250020-014-AC] 

3. Plant Design: The concrete block plant consists of three Aggregate Storage Silos with Weigh 

Hoppers, and two Cement Storage Silos. Each Cement Storage Silo has two Baghouses, a Mixer, and 

a Weigh Hopper with Baghouse. A total of five baghouses are associated with the Concrete Block 

Plant. The baghouses have the following design specifications: 

Source I.D. Visible 

Emissions* Manufacturer Model 

No. 

Number of 

Cartridges 

Flow 

Rate 

(acfm) 

Cloth 

Area 

(ft2

) 

Air-toCloth 

Ratio 

Cement Silo #1 5% 

Initial/Annual C & W Mfg. CP-310

[2 units] 4 1600 304 5.3 

Cement Silo #2 5% 

Initial/Annual C & W Mfg. CP-310

[2 units] 4 1600 304 5.3 

Weigh Hopper #1 5% 

Initial/Annual C & W Mfg. CP-100

[1 unit] 1 400 110 4.0 

Weigh Hopper #2 5% 

Initial/Annual C & W Mfg. CP-100

[1 unit] 1 400 110 4.0 

*Emissions from enclosed storage and conveying equipment shall not exceed 5 %. 

[Permit 0250020-014-AC; Rule 62-296.414(1) F.A.C.] 

Emissions Limits, Test Methods and Reasonable Precautions 

4. Visible Emissions (VE) Limit: Visible emissions limits for the baghouses shall not exceed 5% as 

stated above. 

5. Test Procedures: All emissions tests performed on the Concrete Block Plant shall comply with the 

following requirements: 

a. The test Method for visible emissions shall be EPA Method 9. 

b. Test procedures shall meet all applicable requirements of Chapter 62-297, F.A.C. 

c. Visible emissions tests of silo dust collector exhaust points shall be conducted while loading the 

silo at a rate that is representative of the normal silo loading rate. The minimum loading rate 

shall be 25 tons per hour unless such rate is unachievable in practice. If emissions from the weigh 

hopper (batcher) operation are also controlled by the silo dust collector, then the batching 

operation shall be in operation during the visible emissions test. The batching rate during the 

emissions test shall be representative of the normal batching rate and duration. Each test report 

shall state the actual silo loading rate during emissions testing and, if applicable, whether or not 

batching occurred during emissions testing. 

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Section III. Emissions Unit(s) and Specific Conditions 

Subsection I. Concrete Block Plant 

d. If emissions from the weigh hopper (batcher) operation are controlled by a dust collector which is 

separate from the silo dust collector, visible emissions tests of the weigh hopper (batcher) dust 

collector exhaust point shall be conducted while batching at a rate that is representative of the 

normal batching rate and duration. Each test report shall state the actual batching rate during 

emissions testing. 

e. Each dust collector exhaust point shall be tested for a minimum of 30 minutes or, if the operation 

is normally completed within less than 30 minutes and does not recur within that time, the test 

shall last for the length of the loading operation. 

[Rules 62-296.414(3)F.A.C., and 62-297.310(4)(a), F.A.C.; Permit No. 0250020-014-AC] 

6. Annual Testing: Each dust collector exhaust point shall be tested annually for compliance with the 

visible emissions limiting standard of Rule 62-296.414 (1) F.A.C. 

[Rule 62-296.414(1), F.A.C., Permit No. 0250020-014-AC] 

7. Unconfined Emissions of Particulate Matter: Refer to Section II, Specific Condition N. 7. 

[Rule 62-296.414(2), F.A.C., Rule 62-296.320(4)(c), F.A.C., Permit No. 0250020-014-AC] 

8. Concrete Block Plant Reasonable Precautions. The permittee shall take reasonable precautions to 

control unconfined emissions from hoppers, storage and conveying equipment, conveyor drop points, 

truck loading and unloading, roads, parking areas, stock piles, and yards as required by Rule 62-

296.320 (4) F.A.C. The following shall constitute additional reasonable precautions to control 

Unconfined Emissions of Particulate Matter for this plant: 

a. Reduction of stock pile height or installation of wind breaks to mitigate wind entrainment of 

particulate matter from stock piles. 

b. Use of spray bar, chute, or partial enclosure to mitigate emissions at the drop point to the truck. 

[Rule 62-296.414(2), F.A.C.; Permit No. 0250020-014-AC issued 9/20/02] 

Test Procedures, Recordkeeping and Additional Requirements 

9. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 33 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection J. Concrete Batch Ready Mix Plant 

This subsection addresses the following emissions unit. 

ARMS Emissions Unit No. Brief Description of Emissions Unit 

025 Two Concrete Batch Ready Mix Plants 

Operational Requirements 

1. Compliance Plan: The applicant may operate both concrete batch ready mix plants subject to the 

additional terms in the attached Compliance Plan in Appendix CP-1. 

2. Permitted Capacity: The maximum hourly production rate of each plant shall not exceed 243.75 tons 

per hour, approximately 130 cubic yard/hr. [Permit AC13-158138, Applicant’ Request November 14, 

2006] 

3. Hours of Operation: These plants emissions units may operate continuously, i.e., 8,760 hours per 

year. [Requested by applicant November 14, 2000] 

4. Plants Design: The Ready Mix Plants have a total of six storage silos, one of which is a split silo. 

Emissions are controlled by dust collectors. The two weigh hoppers’ emissions are controlled by 

separate dust collectors. The baghouses have the following design specifications: 

Source I.D. Visible 

Emissions* Manufacturer Model No. Flow Rate (acfm)

Cloth Area 

(ft )

2

Air-to-Cloth 

Ratio

Cement/Flyash 

Silo No. 1 

5% 

Initial/Annual C&W Mfg. CP-310 1,600 267 6.0 

Cement/Flyash 

Silo No. 2 

5% 

Initial/Annual C&W Mfg. CP-310 1,600 304 5.3 

Cement/Flyash 

Silo No. 3 

5% 

Initial/Annual C&W Mfg. CP-310(2) 1,600 267 6.0 

Cement/Flyash 

Silo No. 4 

5% 

Initial/Annual C&W Mfg. CP-340 1,800 267 6.7 

Cement Silo 

No. 5 – Left 

5% 

Initial/Annual C&W Mfg. CP-310 1,600 267 6.0 

Cement Silo 

No. 5 – Right 

5% 

Initial/Annual C&W Mfg. CP-310 1,600 267 6.0 

Cement/Fly ash 

Silo No. 6 

5% 

Initial/Annual C&W Mfg. CP-310(2) 1,600 267 6.0 

Weigh/Loadout 

No. 1 

5% 

Initial/Annual C&W Mfg. KR-1100 6,500 912 7.1 

Weigh/Loadout 

No. 2 

5% 

Initial/Annual Vince Hagen VH-1083-JP 6,500 1083 6.0 

* Rule 62-296.414 (1) F.A.C. 

Emissions Limits, Test Methods and Reasonable Precautions 

5. Visible Emissions (VE) Limit and Test Method: Visible emissions limits for the baghouses shall not 

exceed 5% as stated above. EPA Method 9 shall be used to test for compliance with the VE 

emissions limits. Annual test shall meet the requirements of Chapter 62- 297. F.A.C. [Rule 62-4.070 

(3)F.A.C] 

Titan America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 34 of 37 
Section III. Emissions Unit(s) and Specific Conditions 

Subsection J. Concrete Batch Ready Mix Plant 

6. Unconfined Emissions of Particulate Matter: Refer to Section II, Specific Condition N. 7. 

[Rule 62-296.414(2), F.A.C., Rule 62-296.320(4)(c), F.A.C., Permit No. AC13-158138] 

7. Ready Mix Plants Reasonable Precautions: The following shall constitute additional reasonable 

precautions to control Unconfined Emissions of Particulate Matter for these plants: 

a. Paved parking and trafficked areas shall be maintained and kept free of particulate matter buildup. 

b. Sprinkling with water shall be used as necessary on paved areas and stockpiles. 

c. Return concrete material shall be confined to the area around the industrial wastewater system. 

[Rule 62-296.414(2), F.A.C.; Permit No. AC13-158138 issued 5/18/1989] 

Test Procedures, Recordkeeping and Additional Requirements 

8. Common and General Conditions: This emissions unit is subject to all applicable requirements of the 

attached Appendices, made part of the permit. 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 35 of 37 
Section IV. Common and General Conditions 

Facility-Wide Requirements 

General Requirements 

This Section addresses the following emissions unit(s), emissions unit systems, and the regulations to 

which they are subject which are contained in the Appendices listed in the Placard Page and attached as 

part of the permit. 

ARMS Emissions 

Unit No. 

Brief Description of Emissions Units 

010 Cement Plant Finish Mill System: Finish Mill No. 1 

011 Cement Plant Finish Mill System: Finish Mill No. 2 

012 Cement Plant Finish Mill System: Finish Mill No. 3 

013 Cement Plant Finish Mill System: Finish Mill No. 4 

030 Cement Plant Finish Mill System: Finish Mill No. 6 

014 Cement Handling System: Cement Storage Silos. 1 through 12 

015 Cement Handling System: Cement Distribution, Rail and Truck Loadout 

016 Cement Handling System: Cement Packhouse 

022 Nonmetallic Mineral Processing Plant Equipment and Operations at the 

Aggregate Plant Subject to 40 CFR 60, Subpart OOO 

023 Nonmetallic Mineral Processing Plant Equipment and Operations at the 

Aggregate Plant NOT Subject to 40 CFR 60, Subpart OOO 

024 Concrete Block Plant 

025 Two Concrete Ready Mix Plants 

026 Cement Plant Coal Handling System 

027 Cement Plant Clinker Handling and Storage System 

028 Cement Plant Pyroprocessing/Raw Mill System 

029 Cement Plant Raw Material Handling System 

031 Facility Fugitive Emissions: Unregulated Emissions Units and/or Activities 

1. All of the listed emission units (except emissions units 022, 023, 024, 025 and 031) have at least one 

component that is subject to 40 CFR 63, Subpart LLL - National Emission Standards for Hazardous 

Air Pollutants from the Portland Cement Manufacturing Industry. The listed emission units shall 

comply with Subpart LLL only to the extent that the regulations apply to the facility or its 

operations. 

2. Some of the listed cement plant emission units have at least one component that was subject to 40 

CFR 60, Subpart F - Standards of Performance for Portland Cement Plants (NSPS) when originally 

constructed. The listed emission units shall comply with Subpart F only to the extent that the 

applicable Subpart F requirements were not subsumed by 40 CFR 63, Subpart LLL. Specifically, 40 

CFR 63.1356 exempts units from compliance with NSPS Subpart F if they are complying with 

NESHAP Subpart LLL. 

3. The listed emission units shall comply with 40 CFR 60 Subpart A, General Provisions and 40 CFR 

63, Subpart A, General Provisions only to the extent that the requirements apply to the facility or its 

operations. 

Titan America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 36 of 37 
Section IV. Common and General Conditions 

Facility-Wide Requirements 

4. Emissions Unit 026 is subject to 40 CFR 60 Subpart Y, Standards of Performance for Coal 

Preparation Plants as applicable. 

5. Emissions Unit 022 is subject to 40 CFR 60, Subpart OOO - Standards of Performance for 

Nonmetallic Mineral Processing Plants. 

6. Source Obligation: If a previously permitted facility or modification becomes a facility or 

modification which would be subject to the preconstruction review requirements of this rule if it 

were a proposed new facility or modification solely by virtue of a relaxation in any federally 

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

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

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

or modification as though construction had not yet commenced on it. 

[Rule 62-212.400 (12) (b) F.A.C.] 

{This facility modification avoided preconstruction review pursuant to Paragraph 62-212.400, 

F.A.C., except for CO, by taking federally enforceable limitations on the capacity to emit certain 

criteria pollutants from each of the emission units listed above. Refer to PSD-FL-360/ 0250020-017-

AC and 0250020-019-AC .} 

The Department adopted the provisions of the referenced NSPS and NESHAPS regulations from 40 CFR 

60 and 40 CFR 63, respectively by reference into Rule 62-204.800, F.A.C. The provisions of these 

regulations are included in this permit as attached Appendices. 

{Permitting Note: The numbering of the original rules has been preserved for ease of reference to the 

rules. The term "Administrator" when used in 40 CFR 60 shall mean the Secretary or the Secretary's 

designee.} 

Tarmac America, LLC Title V Operation Permit Renewal 

Titan Pennsuco Complex DEP File No. 0250020-018-AV 

Page 37 of 37 
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