DAQE-AN0007012 -02

May 17, 2002 Kevin Ovard Environmental Manager Holcim (US) Incorporated 6055 E. Croydon Road Morgan, Utah 84050 Dear Mr. Ovard: Re: Approval Order: Process Change for Aluminum and Hi-Grade Limestone Material Addition at the Devil’s Slide Cement Plant- CDS -A, ATT; NSPS, PSD, Title V MAJOR Project Code: N0007 -012 The attached document is the Approval Order (AO) for the above-referenced project. Future correspondence on thi s Approval Order should include the engineer's name as well as the DAQE number as shown on the upper right-hand corner of this letter. Please direct any technical questions you may have on this project to Mr. John D. Jenks. He may be reached at (801) 536 -4459. Sincerely, Richard W. Sprott, Executive Secretary Utah Air Quality Board RWS:JDJ:jc cc: Weber County Health Department Mike Owens, EPA Region VIII 

# State of Utah DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY Michael O. Leavitt

Governor Dianne R. Nielson, Ph.D.

Executive Director Richard W. Sprott

Director 150 North 1950 West

P.O. Box 144820 Salt Lake City, Utah 84114 -4820 (801) 536 -4099 Fax (801) 536 -4414 T.D.D. Web: www.deq.state.ut.us

## STATE OF UTAH **Department of Environmental Quality Division of Air Quality**  **APPROVAL ORDER: PROCESS CHANGE FOR ALUMINUM**  **AND HI -** **GRADE LIMESTONE MATERIAL ADDITION AT**

**THE DEVIL’S SLIDE CEMENT PLANT**

**Prepared By: John D. Jenks, Engineer Email: jjenks@deq.state.ut.us**  **(801) 536 -** **4459** 

### APPROVAL ORDER NUMBER **DAQE -** **AN0007012 -** **02 Date: May 17** **, 2002** 

## HOLCIM (US) INCORPORATED

**Source Contact Kevin Ovard**  **(801) 829 -** **2122 Richard W. Sprott**  **Executive Secretary Utah Air Quality Board** **ABSTRACT**

**Holcim (US)**  **Incorporated, has**  **submitted a**  **Notice of**  **Intent to**  **complete a**  **process change**  **at their**  **Devil’s Slide**  **Cement Plant.**  **T he**  **process change**  **involves the**  **storage and**  **use of**  **high -**  **grade limestone**  **and aluminum**  **containing ma** **terials. T**  **here will**  **be a**  **couple of**  **physical changes,**  **namely the**  **installation of an open** **- top**  **hopper, and a conveyor/feeder system. Whil e th** **e new equipment does have the**  **potential to**  **emit particulate**  **ma tter**  **in the**  **PM 10**  **and PM2.5**  **range, emissions**  **will be**  **reduced from**  **the current process of open pile storage. The Devil’s Slide Plant is located in Morgan County, which is an**  **attainment area**  **o**

**f the**  **National Am**  **bient Air**  **Quality Standards**  **(NAAQS) for**  **all pollutants.**  **N ew**  **Source Performance Standards (NSPS) A and F (Portland Cement Plants) apply to this source, but not to**  **this mo** **dification. National**  **Emission Standards**  **for Hazardous**  **Air Pollutants**  **(NESHAP) and**  **Maximum Available**  **Control Technology**  **(MACT) regulations**  **do not**  **apply to**  **this source.**  **T itle**  **V of**  **the 1990**  **Clean Air**  **Act applies**  **to this**  **source. T**  **he Title**  **V permit**  **will be**  **administratively amended**  **after the**  **AO has**  **been issued.**  **T he**  **emissions, in**  **tons per**  **year, will**  **not change**  **as Holcim**  **wishes to**  **retain the**  **flexibility of**  **their current**  **emission totals.**  **I n**  **addition, the**  **anticipated decrease**  **in actual**  **emissions is 616 pounds per year of PM 10**  **.** The project has been evaluated and found to be consistent with the requirements of the Utah Administrative Code Rule 307 (UAC R307). Apublic comment period was held in accordance with UAC R307 -401 -4 and no comments were received. This air quality Approval Order (AO) authorizes the project with the following conditions, and failure to comply with any of the conditions may constitute a violation of this order. **General Conditions:** 1 . This Approval Order (AO) applies to the following company: Site Office Holcim (US) Inc. 6055 E. Croydon Road Morgan, Utah 84050 Phone Number (801) 829 -6821 Fax Number (801) 829 -2100 The equipment listed in this AO shall be operated at the following location: PLANT LOCATION: 6055 E. Croydon Road, Morgan, Utah 84050Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 4,545.8 kilometers Northing, 455.4 kilometers Easting, Zone 12 2 . Definitions of terms, abbreviations, and references used in this AO conform to those used in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of Federal Regulations (40 CFR). These definitions take precedence, unless specifically defined otherwise herein.DAQE-AN0007012 -02

Page 3 3 . Holcim (US) Inc. shall conduct its operations of the Devil’s Slide Cement Plant in

accordance with the terms and conditions of this AO, which was written pursuant to Holcim (US) Inc.’s Notice of Intent submitted to the Division of Air Quality (DAQ) on October 23, 2001. 4 . This AO shall replace the AO dated May 2, 2001 (DAQE-303 -01). 5 . The approved installations and facilities shall consist of the following equipment or equivalent*: A . Five -stage suspension preheater kiln and “AS” precalciner using indirect coal firing Control Method: Kiln Main Stack Baghouse 135,000 ACFM ** Control Method: Alkali By-Pass Baghouse 75,000 ACFM ** B . Clinker Cooler Control Method: Cooler Baghouse 95,000 ACFM ** C . #1 Finish Mill Control Method: #1 Separator Baghouse 48,000 ACFM ** Control Method: #1 Cement Mill Baghouse nuisance dust collector D . #2 Finish Mill Control Method: #2 Separator Baghouse 43 ,000 ACFM ** Control Method: #2 Cement Mill Baghouse 17,000 ACFM ** E . #3 Finish Mill Control Method: #3 Separator Cyclone/Baghouse 4,706 ACFM ** Control Method: #3 Cement Mill Baghouse 25,588 ACFM ** F . Coal Mill Control Method: Baghouse 28,000 ACFM ** G . 62 additional baghouses of varying capacity for dust control. These include but are not limited to baghouses installed in the following areas: Material Handling Raw Material Grinding and Storage Feeding Cement and Clinker Storage (4 new silos) H . Various quarry drilling and blasting equipment I . Haul trucks and front-end loaders J . Various covered conveyors K. Open Top Material Hopper and Concrete Ramp L. Two Diesel Powered Emergency GeneratorsDAQE-AN0007012 -02

Page 4 * Equivalency shall be determined by the Executive Secretary.

** Flow rates are listed for informational purposes only **Limitations and Tests Pr ocedures**  6 . Emissions to the atmosphere at all times from the indicated emission point shall not exceed the following rates and concentrations:

Source: Kiln Main Stack Exhaust Pollutant lb/hr PM 10 ................................ ................................ .. 14 SO 2 ................................ ................................ .. 110 CO ................................ ................................ ... 438 7 . Stack testing to show compliance with the emission limitations stated in the above condition shall be performed as specified below: A . Testing Test Emissions Point Pollutant Status Frequency Kiln Main Stack PM 10 ...................... * ....................... @ SO 2 ........................ * ....................... # NO x ........................ ** ..................... ## CO ......................... * ....................... # B . Testing Status (To be applied above) * The initial testing has already been performed. ** Initial compliance testing shall be performed within 180 days of the issuance of this AO. The initial testing shall show the source to be emitting less than 460 lbs/hr of NOx. This limit is for initial compliance determination only. F ollowing a successful initial test, this emission limitation no longer applies. @ Test every five years. The Executive Secretary may require testing at any time. # Test every two years. The Executive Secretary may require testing at any time. ## Further compliance for NOx emissions shall be demonstrated through use of a continuous emissions monitoring system as outlined in Conditions 21 and 22. C . Notification The Executive Secretary shall be notified at least 30 days prior to conducting any required emission testing. Asource test protocol shall be submitted to DAQ when the testing notification is submitted to the Executive Secretary.DAQE-AN0007012 -02

Page 5 The source test protocol shall be approved by the Executive Secretary prior to

performing the test(s). The source test protocol shall outline the proposed test methodologies, and stack to be tested. A pretest conference shall be held, if directed by the Executive Secretary. D . Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Executive Secretary. Access that meets the standards of the Occupational Safety and Health Administration (OSHA) or the Mine Safety and Health Administration (MSHA) shall be provided. E . Volumetric Flow Rate 40 CFR 6 0, Appendix A, Method 2 F . PM 1 0 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. The back half condensibles shall also be tested using the method specified by the Executive Secretary. All particulate captured shall be considered PM 10 . For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half condensibles shall also be tested using the method specified by the Executive Secretary. The portion of the front half of the catch considered PM 10 shall be based on information in Appendix B of the fifth addition of the EPA document, AP -42, or other data acceptable to the Executive Secretary. The back half condensibles shall not be used for compliance demonstration but shall be used for inventory purposes. G . Sulfur Dioxide (SO2) 40 CFR 60, Appendix A, Method 6, 6A, 6B or 6C H . Nitrogen Oxides (NOx) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D or 7E I . Carbon Monoxide (CO) 40 CFR 60, Appendix A, Method 10DAQE-AN0007012 -02

Page 6 J . Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary, to give the results in the specified units of the emission limitation. K. Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years 8 . Visible emissions from the following emission points shall not exceed the following values: A . All kiln exhaust gases - 20% opacity B . All other point sources - 10% opacity Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. 9 . The following production limits shall not be exceeded: A . 691,250 tons of clinker produced per rolling 12 -month period B . 2310 tons of clinker produced per day C . 7900 hours per rolling 12 -month period for operation of the main kiln To determine compliance with a rolling 12 -month total the owner/operator shall calculate a new 12 -month total by the twentieth day of each month using data from the previous 12 months. Records of production shall be kept for all periods when the plant is in operation. Production shall be determined by maintenance of a supervisor log. The records of production shall be kept on a daily basis. 10 . The emergency generator hours of operation for maintenance purposes shall not exceed 60 hours per 12 -month period. Compliance with the annual limitation shall be determined on a rolling 12 -month total. Based on the twentieth day of each month a new 12 -month total shall be calculated using the previous 12 months of engine hours and shall be kept for all periods when the plant is in operation. Engine hours of operation shall be determined by examination of maintenance records, which shall be kept on site. **Roads and Fugitive Dust** 11 . The facility shall abide by all applicable requirements of UAC R307 - 205 for Fugitive Emission and Fugitive Dust sources. The provisions of R307 -205 shall not apply to any sources for which limitations for fugitive dust or fugitive emissions are assigned pursuant to R307 -401 or R307 -305 nor shall they apply to agricultural or horticultural activities.DAQE-AN0007012 -02

Page 7 12 . All unpaved roads and other unpaved operational areas that are used by mobile

equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. The opacity shall not exceed 20% during all times the areas are in use. If chemical treatment is to be used, the plan must be approved by the Executive Secretary. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A . Date B . Number of treatments made, dilution ratio, and quantity C . Precipitation received, if any, and approximate amount D . Time of day treatments were made E . Records of temperature if the temperature is below freezing. 13 . The haul road limitations shall be: A. Twenty-five (25) miles per hour for all haulers B. Fifteen (15) miles per hour for all loaders These limitations shall not be exceeded. The vehicle speed on the haul road shall be posted, at a minimum, on site at the beginning of the haul road so that it is clearly visible from the haul road. 14 . Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity. Visible emissions determinations for traffic sources shall use procedures similar to Method 9. The normal requirement for observations to be made at 15 -second intervals over a six-minute period, however, shall not apply. S ix points, distributed along the length of the haul road or in the operational area, shall be chosen by the Executive Secretary or the Executive Secretary’s representative. An opacity reading shall be made at each point when a vehicle passes the selected points. Opacity readings shall be made vehicle length or greater behind the vehicle and at approximately the height of the vehicle or greater. The accumulated six readings shall be averaged for the compliance value. 15 . A dust suppression system shall be installed at the following points to control fugitive emissions: A . Crusher dump pocket B . Conveyor transfer points The system shall operate whenever dry conditions warrant or as determined necessary by the Executive Secretary. **Fuels** 16 . The owner/operator shall use only the following fuels in the kiln:

A . Coal B . Diaper Derived Fuel (DDF) C . Tire Derived Fuel (TDF)DAQE-AN0007012 -02

Page 8 D . Natural Gas

E . Coke F . Fuel Oil G . Used Oil If any other fuel is to be used, an AO shall be required in accordance with R307 -401, UAC. 17 . The sulfur content of any coal or mixture of coals burned shall not exceed 1.0 pound of sulfur per million BTU of heat input. The sulfur content of any fuel oil or diesel burned shall not exceed 0.85 pounds sulfur per million gross BTU heat input. If any type of fuel that is to be used that has a higher sulfur content, an AO shall be required in accordance with R307 -401, UAC. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307 -203 - 1 (4) (a) F or determining sulfur content in coal, ASTM Methods D3177 -75 or D4239 - 85 are to be used. (b) F or determining sulfur content in oil, ASTM Methods D2880 -71 or D4294 - 89 are to be used. (c) F or determining the gross calorific (or BTU) content of coal, ASTM Methods D2015 -77 or D3286 - 85 are to be used. 18 . The concentration/parameters of contaminants in any used oil fuel shall not exceed the following levels: 1 ) Arsenic ................................ ..... 5 ppm by weight 2) Cadmium................................ .. 2 ppm by weight 3 ) Chromium .............................. 10 ppm by weight 4) Lead ................................ ..... 100 ppm by weight 5 ) Total halogens ................... 1,000 ppm by weight 6) Sulfur ................................ ....... 0.5 percent by weight A . The flash point of all used oil to be burned shall not be less than 100 F. B . The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel marketer. Records of used oil fuel consumption and the test reports shall be kept for all periods when the plant is in operation. C . Used oil that does not exceed any of the listed contaminants content may be burned. The owner/operator shall record the quantities of oil burned on a daily basis. D . Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be considered a hazardous waste and shall not be burned in the boiler. The oil shall be tested for halogen content by ASTM Method D - 808 - 81, EPA Method 8240 or Method 8260 before used oil fuel is transferred to t he boiler tank and burned.DAQE-AN0007012 -02

Page 9 E . Sources utilizing used oil as a fuel shall comply with the State Division of Solid

and Hazardous Waste in accordance with R315 - 15, UAC. **Federal Limitations and Requirements** 19 . In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18 and Subpart F, 40 CFR 60.60 to 60.66 (Standards of Performance for Portland Cement Plants) apply to this installation. To be in compliance, this facility must operate in accordance with the most current version of 40 CFR 60 applicable to this source. **Monitoring -**  **Continuous Emissions Monitoring** 20. The annual emissions of NOx from the main kiln stack shall not exceed 1,817 tons per rolling 12 -month period. Compliance with this limitation will be through installation and use of a continuous emissions monitoring system as outlined in Condition 22 below. 21. The owner/operator shall install, calibrate, maintain, and continuously operate a continuous emissions monitoring system on the kiln main stack. The owner/operator shall record the output of the system, for measuring the NO x emissions. The monitoring system shall comply with all applicable sections of R307 - 170, UAC; 40 CFR 51, Appendix P; and 40 CFR 60, Appendix B. All continuous emissions monitoring devices as required in federal regulations and state rules shall be installed and operational prior to placing the affected source in operation. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall continuously operate all required continuous monitoring devices and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307 - 170. **Records & Miscellaneous** 22. At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this Approval Order including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Executive Secretary which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded, and the records shall be maintained for a period of two years. 23. The owner/operator shall comply with UAC, R307 - 150 Series. Inventories, Testing and Monitoring. To be in compliance, this facility must operate in accordance with the most current version of the UAC, R307 - 150 series.DAQE-AN0007012 -02

Page 10 24. The owner/operator shall comply with R307 - 107, UAC, General Requirements:

Unavoidable Breakdown. To be in compliance, this facility must operate in accordance with the most current version of the UAC, R307 - 107. All records referenced in this AO, or in applicable NSPS, which are required to be kept by the owner/operator, shall be made available to the Executive Secretary or Executive Secretary’s representative upon request, and the records shall include the five-year period prior to the date of the request. Asummary of those records that are required as part of this Approval Order is included herein. This summary shall not be considered an additional requirement, but is included for informational purposes only. The condition that requires that these records be kept as part of the compliance with this AO is listed following the individual record. Examples of records to be kept at this source shall include the following as applicable: Production rate Condition number 9 Hours of operation Condition number 9 Test results Condition number 7 Fugitive emission control Condition number 12 CEMS 1 records Condition number 22 Maintenance records Condition number 23 Emission inventory Condition number 24 Upset, breakdown episodes Condition number 25 The list above may not be a complete list of all records that are required to be kept by Holcim (US) Inc.. F or a complete list of required records check all AO conditions, and all applicable Federal regulations such as NSPS standards that apply to this source. Any changes which may affect the terms or conditions of this Approval Order shall be reviewed in accordance with R307 -401, UAC. The Executive Secretary shall be notified in writing if the company is sold or changes its name. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting the Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of Intent (NOI) guide, and other air quality documents and forms may also be obtained on the Internet at the following web site: http://www.eq.state.ut.us/eqair/aq_home.htm Annual emissions for this source (the entire plant) are currently calculated at the following values:

Pollutant Tons/yr A . PM 10 ................................ .............................. 54.8 B . SO 2 ................................ .............................. 433.7 C . NO x ................................ ............................ 1856.0 D . CO ................................ ............................. 1728.1 E . VOC ................................ .............................. 32.8 1 CEMS = Continuous Emission Monitor SystemDAQE-AN0007012 -02

Page 11 The annual emission estimations above are for the purpose of determining the applicability of Prevention of Significant Deterioration, nonattainment area, maintenance area, and Title V source requirements of the UAC R307. They are not to be used for determining compliance. Approved By: Richard W. Sprott, Executive Secretary Utah Air Quality Board