ATTACHMENT F

Letter dated August 30, 2007, submitted by Chemstone 

in support of its BART determination 

(application for de minimis SO2 limits)
OIV

O-N MINERALS

CHEMSTONE OPERATIONS

1696 ORANDA ROAD

PO BOX 71

STRASBURG, VA 22657

0." MIN..AL8 TEL 540-465-5161

FAX 540-465-5150

www.oglebaynorton.com

August 30, 2007

Ms. Sharon G. Foley, P.E.

Air Permit Manager

DEQ -Valley Regional Office

P.O. Box 3000

4411 Early Road

Harrisonburg, VA 22801

RE: Best Available Retrofit Technology (BART) Permit Application

O-N Minerals (Chemstone) 80252 - Strasburg, Virginia

Shenandoah County Registration No.: 80252 Plant ID No.: 51-171-0003

Dear Ms. Foley:

In response to our Best Available Retrofit Technology (BART) Pennitting options, we

have forwarded our requested permit modifications for our Strasburg facility and we are

requesting an annual emission cap on S02 from the BART eligible emission units below

40 tons per year to keep our facility classified as a BART de minimus source for this

pollutant. (38 annual tons from our Rotary and one ton from our Calcimatic kiln

operations). Enclosed please find VDEQ Fonn 7.

We have provided a draft pennit with the hope that the DEQ will concur with our

proposed conditions. If the Department is not in agreement that the proposed pennit

conditions are acceptable, then we request a meeting with DEQ to discuss the remaining issues further.

If you have any questions or comments, please do not hesitate to call me at (540) 465-

6822.

Sincerely,

Karl D. Everett, PE

Senior Environmental Health & Safety Manager

Enclosures
COMMONWEALTH OF VIRGINIA

Department of Environmental Quality

AIR PERMIT APPLICATION

General information

CHECKALLFORMSTHATAPPLYANDLISTALLATTACHEDDOCUMENTS.

MAP AND LOCALITIES LIST (information), Pages iii-vi

CONFIDENTIAL INFORMATION,Page vii-viii

FORMULA-BASED HAZARDOUSAIR POLLUTANT INFORMATION,Page ix

HAZARDOUSAIR POLLUTANT LIST (information), Pages xi-xii

_ REQUEST FOR LOCAL GOVERNMENTCERTIFICATION FORM,Page xiii

.LCONTENTS AND DOCUMENTCERTIFICATION,Page 1

LGENERAL INFORMATION,Page 2

...!..GENERAL INFORMATION(oontinued), Page 3

_ FUEL-BURNING EQUIPMENT,Page 4

_ PROCESSING, Page 5

_INKS, COATINGS, STAINS, AND ADHESIVES, Page 6

_INCINERATORS, Page 7

_ VOLATILE ORGANIC COMPOUND/PETROLEUMSTORAGETANKS, Page B

VOLATILE ORGANICCOMPOUNDIPETROLEUMSTORAGETANKS-

- CONTINUED, Page 9

_ LOADING RACKSAND OIL-WATER SEPARATORS, Page 10

_ STACK PARAMETERSAND FUEL DATA, Page 11

_ AIR POLLUTIONCONTROLAND MONITORINGEQUIPMENT,PAGE 12

_AIR POLLUTION CONTROUSUPPLEMENTAL INFORMATION,PAGE 13

_PROPOSED MAXIMUMCRITERIA POLLUTANTEMISSIONS,Page 14

_ PAST ACTUAL ANNUAL CRITERIA POLLUTANT EMISSIONS, Page 15

_ TOXIC OR HAP EMISSIONS, Page 16

_ OTHER REGULATED EMISSIONS, Page 17

_ OPERATING PERIODS, Page 1B

LIST ATTACHED DOCUMENTS

_ MAP of SITE LOCATION

_ FACILITY SITE PLAN

_ PROCESS FLOW DIAGRAM/SCHEMATIC

_ MSDS or CPDS SHEETS

_ ESTIMATED EMISSIONS CALCULATIONS

_ STACK TESTS

_ AIR MODEL DATA

Note added form sheets above; also indicate the number of copies of each form in blank provided.

DOCUMENT CERTIFICATION FORM

(see other side for instructions)

I certify under penalty of law that this document and allattachments [as noted above] were prepared under my

direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and

evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those

persons directly responsible for gathering and evaluating the information, the information submitted is, to the best of

my knowledge and belief, true, accurate, and complete. Iam aware that there are significant penalties for submitting

false information, including the possibility of fine and imprisonment for knowing violations.

I certify that Iunderstand that the existence of a permit under [Article 6 of the Regulations] does not shield the

source from potential enforc~ent of a9Y rJgulation of the board governing the major NSR program and does not

relieve the source of the res6ohsibilitv1d lJiifp,y with any applicable provision of the major NSR regulations. . c;.,30

NAME:

SIGNATURE: DATE:

TITLE: General Manaaer REGISTRATION

COMPANY: O-N Minerals IChemstone) ComDanv NUMBER: B0252

References: Virainia Reaulations for the Control and Abatement of Air Pollution IReaulations), 9 VAC 5-20-230B and 9 VAC 5-BO-1140E. See reverse ofthis

form for instructions.

Page Revised November 1, 2002 1 FORM7
COMMONWEALTH OF VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR PERMIT APPLICA TION GENERAL INFORMATION

Page Revised July 14, 2005 Page 2 FORM 7

PERSONCOMPLETINGFORM DATE REGISTRATIONNUMBER

Karl Everett 8/29/07 80252

REASON(S) FOR SUBMISSION (Check all that apply):

CI STATE OPERATING PERMIT THIS PERMIT IS APPLIED FOR PURSUANT TO PROVISIONS OF THE

VIRGINIA ADMINISTRATIVECODE, 9 VAC 5 Chapter 80. Article 5 (SOP)

CI NEW (Greenfield) SOURCE THIS PERMIT IS APPLIED FOR PURSUANT TO THE

FOLLOWING PROVISION(S) OF THE VIRGINIA ADMINISTRATIVE CODE:

CI MODIFICATION of a SOURCE c=J 9 VAC 5 Chapter 80. Art. 6 (MINOR SOURCES)

c=J 9 VAC 5 Chapter 80. Art. 8 (PSD MAJOR SOURCES)

CI RELOCATION of a SOURCE c=J 9 VAC 5 Chapter 80. Art. 9 (NON-ATTAINMENT MAJOR SOURCES)

c==J Non-Binding Letter of EXEMPTION

CI AMENDMENT to a Permit dated: Permit type: c=J SOP(Art.5) c=J NSR (Art.6)

Amendment Type: THIS AMENDMENT IS REQUESTED PURSUANT TO THE PROVISIONS OF:

c=J Administrative Amendment c=J 9 VAC 5-80-970 (SOP Adm.) c=J 9 VAC 5-80-1270 (NSR Adm.)

c=J Minor Amendment c=J 9 VAC 5-80-980 (SOP Minor) c=J 9 VAC 5-80-1280 (NSR Minor)

c=J Significant Amendment c=J 9 VAC 5-80-990 (SOP Sig.) c=J 9 VAC 5-80-1290 (NSR. Sig.)

Complete Pages I, 2, and 3 and refer to the above checked provisions for additional

information requirements. Form 7 pages may be used to satisfy those requirements.

CI Notification of Change in Ownership - Effective Date:

CI Notification of Facility Name Change - Effective Date:

CI Notification of Owner Name Change - Effective Date:

DC] Other (Specify) : BART Permit application

COMPANYANDDIVISIONNAME:

O-N Minerals (Chern stone) Company

MAILINGADDRESS:

P.O. Box 71 Strasburg, VA 22657

TELEPHONE NUMBER:

I NUMBEROFEMPLOYEESATSITE: I PROPERTY AREA AT SITE: (540) 465-5161 103

EXACTSOURCELOCATION-INCLUDE NAMEOFCITY(COUNTY)ANDFULLSTREETADDRESSORDIRECTIONS:

1696 Oranda Road Strasburg, Virginia (Shenandoah County)

PERSONTOCONTACTONAIRPOLLUTIONMATTERS- NAMEANDTITLE: PHONENUMBER:(540) 465-5161

Karl D. Everett, PE FAXNUMBER:(540) 465-5150

E-MAILADDRESS:

Senior EHS Manager keverett@global.onco.com

DC] Please check here if you obtained this form from the DEQ website.

FOROFFICIALUSEONLY

COUNTYCODE: I PLANT ID NUMBER: I LAT/LONG:
COMMONWEALTH OF VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR PERMIT APPLICA TION GENERAL INFORMA TION (continued)

FOR PORTABLE PLANTS:

DESCRIBE THE PRODUCTS MANUFACTURED AND/OR SERVICES PERFORMED AT THIS FACILITY:

O-N Minerals (Chemstone)Companymanufactureslime and hydratedlime. The basic processesat

the facility in ShenandoahCounty are (1) quarryingraw limestone,(2) preparinglimestonefor kilns by

crushing and sizing,(3) calcining limestone,(4) processingthe limefurther by hydrating,and (5)

miscellaneouscrushing,transfer, storage, handling,and loadoutoperation. There are two types of

kilns in operationat this facility. They are a rotarykiln and a calcimaticor rotaryhearth kiln.

PLEASE LIST ALL THE FACILITIES INVIRGINIA UNDER COMMON OWNERSHIP OR CONTROL BY THE OWNER OF

THIS FACILITY:

O-N Minerals (Chemstone) Company Strasburg

O-N Minerals (Chemstone) Company Middletown

O-N Minerals (Chemstone) Company Winchester

O-N Minerals Company James River

MILESTONES. This section is to be completed if the permit application includes a new emissions unit or

modification to existing operations.

Page Revised July 27, 2004 Page 3 FORM 7

COMPANY NAME DATE REGISTRATION NUMBER

O-N Minerals(Chemstone) Company 8/29/07 80252

IS THIS FACILITY DESIGNED TO BE PORTABLE? DYES WNO

-IF YES, IS THIS FACILITYALREADY PERMITTED AS A PORTABLE PLANT? DYES WNO PERMIT DATE: N/A

IF NOT PERMITTED, IS THIS AN APPLICATION TO BE PERMITTEDAS A PORTABLE

DYES

NO

PLANT?

IF PERMITTED AS A PORTABLE FACILITY, IS THIS A NOTIFICATIONOF RELOCATION? DYES WNO

- DESCRIBE THE NEW LOCATION OR ADDRESS (INCLUDEA SITE

MAP):

- WILL THE PORTABLE FACILITY BE CO-LOCATED WITH ANOTHER SOURCE?

DYES

NO REG. NO.: N/A

- WILL THE PORTABLE FACILITY BE MODIFIEDOR RECONSTRUCTED AS A RESULT OF THE RELOCATION? DYES WNO

-WILL THERE BE ANY NEW EMISSIONSOTHER THAN THOSE ASSOCIATED WITH THE RELOCATION? DYES WNO

-IS THE FACILITY SUITABLE FOR THE AREA TO WHICH IT WILL BE LOCATED? (ATTACH DOCUMENTATION.) DYES WNO

MILESTONES* STARTING DATE ESTIMATED COMPLETION DATE

New equipment installation N/A N/A

Modification of existing process or equipment N/A N/A

Start-up dates N/A N/A