Iowa Department of Natural Resources

Title V Operating Permit

Name of Permitted Facility: Lehigh Cement Company

Facility Location: 700 25th Street N.W.

 Mason City, IA 50401

Air Quality Operating Permit Number: 04-TV-011

Expiration Date: July 28, 2009

EIQ Number: 92-3163

Facility File Number: 17-01-005

________________________________________________________________________

Responsible Official

Name: Verne A. Stuessy

Title: Plant Manager

Mailing Address: 700 25th Street N.W.

 Mason City, IA 50401

Phone #: (641) 421-3400

Permit Contact Person for the Facility

Name: Rita Dunn

Title: Environmental Coordinator

Mailing Address: 700 25th Street N.W.

 Mason City, IA 50401

Phone #: (641) 421-3459

________________________________________________________________________

This permit is issued in accordance with 567 Iowa Administrative Code Chapter 22, and is issued

subject to the terms and conditions contained in this permit.

For the Director of the Department of Natural Resources

________________________________________________________________________

Douglas A. Campbell, Supervisor of Air Operating Permits Section Date
2 04-TV-011 7/29/004

Table of Contents

I. Facility Description and Equipment List ...................................................................... 5

II. Plant - Wide Conditions................................................................................................ 11

III. Emission Point Specific Conditions ............................................................................. 14

A. Material Transfer Fugitive Emission Sources Subject Only to

Administrative Consent Order 1999-AQ-32 and the Fugitive Dust Rule.......14

B. Storage Piles..........................................................................................................18

C. Haulroads..............................................................................................................20

D. Conveying System Transfer Points\Raw and Finish Mills\Storage Bins\

Bulk Loading and Unloading Units Subject to 40 Subpart LLL......................25

E. Non-Fugitive Sources Subject to Administrative Consent Order

1999-AQ-32............................................................................................................34

F. Non-Fugitive Sources Subject to Administrative Consent Order

1999-AQ-32 and 40 CFR 60 Subpart F...............................................................38

 G. Miscellaneous Sources.........................................................................................43

IV. General Conditions..........................................................................................................61

G1. Duty to Comply

G2. Permit Expiration

G3. Certification Requirement for Title V Related Documents

G4. Annual Compliance Certification

G5. Semi-Annual Monitoring Report

G6. Annual Fee

G7. Inspection of Premises, Records, Equipment, Methods and Discharges

G8. Duty to Provide Information

G9. General Maintenance and Repair Duties

G10. Recordkeeping Requirements for Compliance Monitoring

G11. Evidence used in establishing that a violation has or is occurring.

G12. Prevention of Accidental Release: Risk Management Plan Notification and 

Compliance Certification

G13. Hazardous Release

G14. Excess Emissions and Excess Emissions Reporting Requirements

G15. Permit Deviation Reporting Requirements

G16. Notification Requirements for Sources That Become Subject to NSPS and 

 NESHAP Regulations

G17. Requirements for Making Changes to Emission Sources That Do Not

Require Title V Permit Modification

G18. Duty to Modify a Title V Permit

G19. Duty to Obtain Construction Permits

G20. Asbestos

G21. Open Burning

G22. Acid Rain (Title IV) Emissions Allowances

G23. Stratospheric Ozone and Climate Protection (Title VI) Requirements

G24. Permit Reopenings
3 04-TV-011 7/29/004

G25. Permit Shield

G26. Severability

 G27. Property Rights

G28. Transferability

G29. Disclaimer

G30. Notification and Reporting Requirements for Stack Tests or Monitor

Certification

G31. Prevention of Air Pollution Emergency Episodes

G32. Contacts List

V. Appendix A...Administrative Consent Order No. 1999-AQ-32..............................74

 VI. Appendix B.....Operation & Maintenance Plans.......................................................90

 VII. Appendix C.....Applicable Limits and Requirements From 40 CFR 63

 Subpart LLL.......................................................................................122

 VIII. Appendix D...IDNR Air Quality Policy 3b08 (Opacity)..........................................136

Abbreviations

acfm........................... actual cubic feet per minute

CFR ........................... Code of Federal Regulation

dscf......................dry standard cubic feet

dscm.....................dry standard cubic meters

o

F ............................... degrees Fahrenheit

EIQ ............................ emissions inventory questionnaire

ESP.............................electrostatic precipitator

gr./dscf....................... grains per dry standard cubic foot

gr./100 cf ................... grains per one hundred cubic feet

hp./hr.....................horsepower hours

IAC............................ Iowa Administrative Code

IDNR ......................... Iowa Department of Natural Resources

KWH....................kilowatts per hour

MVAC....................... motor vehicle air conditioner

N/A.............................not applicable

ng./dscm.................nanogram per dry standard cubic meter

NSPS ......................... new source performance standard

ppmv.......................... parts per million by volume

lb./hr .......................... pounds per hour

lb./MMBtu................. pounds per million British thermal units

MMcf./hr...............million cubic feet per hour

scfm ........................... standard cubic feet per minute

TEQ.....................toxicity equivalents

TPD.............................tons per day

TPY ........................... tons per year

TPH......................tons per hour

USEPA ...................... United States Environmental Protection Agency

VMT/hr.................vehicle miles traveled per hour
4 04-TV-011 7/29/004

Pollutants

PM ............................. particulate matter

PM10 .......................... particulate matter ten microns or less in diameter

SO2 ............................ sulfur dioxide

NOx............................ nitrogen oxides

VOC .......................... volatile organic compound

CO ............................. carbon monoxide

HAP........................... hazardous air pollutant

D/F.......................dioxins and furans
5 04-TV-011 7/29/004

I. Facility Description and Equipment List

Facility Name: Lehigh Cement Company

Permit Number: 04-TV-011

Facility Description: Portland Cement Plant

________________________________________________________________________

Equipment List

_______________________________________________________________________

A. Material Transfer Fugitive Emission Sources Subject Only to Administrative Consent

Order 1999-AQ-32 and the Fugitive Dust Rule.

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP1 EU1 Railcar Unloading

EP7 EU7A Limestone Transfer

EU14A Clay Delivery and Distribution EU14 EU14B Clay Transfer to Process

EP15A EU15A Raw Material Transfer-Clay Crushing System

EP15B EU15B Raw Material Transfer-Clay Crushing System

EP39-2 EU39-2 Gypsum/Anhydrite Bucket Transfer

EP40 EU40 Coal Crusher

EP56A EU56A Truck Loading - Limestone

EP57A EU57A Truck Loading - Clay

EP58A EU58A Coal Transfer

EU59A Sand Delivery & Unloading EU59A

EU59B Sand Transfer to Process

EU60A Clay Delivery & Unloading EP60A

EU60B Clay Transfer to Process

EU61A Clay Delivery and Unloading EP61A EU61B Clay Transfer to Process
6 04-TV-011 7/29/004

A. Material Transfer Fugitive Emission Sources Subject Only to Administrative Consent

Order 1999-AQ-32 and the Fugitive Dust Rule (cont.)

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP62-1 EU62-1 Coal Transfer

EP63A EU63A Kiln Dust Unloading

EP73A EU73A Limestone Transfer to Process Pile at Crusher

EP74A EU74A Limestone Transfer to Process Pile at Crusher

EP75A EU75A Clinker Transfer to Craneway

EP76A EU76A Clinker, Gypsum, Slag Transfer

B. Storage Piles

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP14 EU14 Clay Storage Pile No. 1

EP58 EU58 Coal Storage Pile

EP59 EU59 Sand Storage Pile

EP60 EU60 Clay Storage Pile No. 2

EP61 EU61 Clay Storage Pile No. 3

EP63 EU63 Kiln Dust Storage Pile

EP73 EU73 Quarry Run Limestone Storage Ple

EP74 EU74 Quarry Run Limestone Storage Ple

EP75 EU75 Clinker Storage Pile

EP76 EU76 Raw Materials Storage Pile
7 04-TV-011 7/29/004

C. Haulroads

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP56 EU56 Limestone Quarry Haulroad

EP57 EU57 Clay Quarry Haulroad

EP63B EU63B Kiln Dust Haulroad

EP80 EU80 Cement Haulroad-Cement Loadout to U.S. 65

D. Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP11 EU11 Raw Material Transfer-Apron Feeder to Collection Belt

EP18 EU18 Grinding Circuit-Raw Material Transfer

EP19 EU19 Raw Material Transfer to Homoginizing Silo

EP20 EU20 Raw Material Transfer-IBAU Bin Bottom Elevator

EP21 EU21 Raw Material Transfer-IBAU Elevator W to top Silo Conveyor

EP22 EU22 Raw Material Transfer-IBAU Elevator S to top Silo Conveyor

EP23 EU23 IBAU Bin S Top Elevator Raw Material Transfer

EP24 EU24 Raw Material Transfer

EP33 EU33 Outhaul Conveyor Transfer

EP34 EU34 Clinker Truck Loadout

EP35 EU35 Outhaul Conveyor Transfer to Clinker Silo

EP36 EU36 Clinker Withdrawal Conveyor Transfer

EP37 EU37 Clinker Belt 206 to 208 Transfer

EP39 EU39 Clinker Transfer

EU38 Clinker Belt 208 to Belt 211 Transfer EP39-1 EU39-1 Clinker Ladder

EP39-3 EU39-3 Clinker Bucket Transfer

EU41 No. 3 Finish Mill

EP41 EU41A Vibrating Conveyor Transfer

EU41B Air Separator
8 04-TV-011 7/29/004

D. Conveying System Transfer Points\Raw and Finish Mills\Storage Bins\Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL (cont.)

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EU41 No. 3 Finish Mill

EP42 EU41A Vibrating Conveyor Transfer

EU41B Air Separator

EU43 No. 5 Finish Mill

EP43 EU43A Vibrating Conveyor Transfer

EU43B Air Separator

EU44 No. 6 Finish Mill

EP44 EU44A Vibrating Conveyor Transfer

EU44B Air Separator

EU45 No. 4 Finish Mill

EP45 EU45A Vibrating Conveyor Transfer

EU5B Air Separator

EU46 Clinker Transfer EP46 EU46A Clinker Transfer

EP47 EU47 Storage Silo

EP48 EU48 Transfer Bucket Elevator

EP49 EU49 Direct Cement Loadout (Emergency Only)

EP50 EU50 Silo Row 40 Cement Bulk Loadout

EP51 EU51 Silo Row 30 Cement Loadout

EP52 EU52 Silo Row 50 Rail/Truck Cement Loading System

EP53 EU53 Silo Row 50 Cement Loadout Spout

E. Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EU2 Primary Crusher EP2 EU2A Raw Material Transfer

EU3 Screening

EU3A Raw Material TP-Belt 2 to Screen

EU3B Raw Material TP- Screen to Belt 3 EP3

EU3C Raw Material TP- Screen to Belt 4
9 04-TV-011 7/29/004

E. Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 (cont.)

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EU5 Secondary Crusher

EP5 EU5A Raw Material Transfer-Stone 5 to 6

EU5B Raw Material Transfer

EU6 Raw Material Transfer EP6 EU6A Raw Material Transfer

F. Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40

CFR 60 Subpart F

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP8 EU8 Raw Material Transfer-Belt D-49 to D-01

EP9 EU9 Raw Material Transfer-Belt D-01 to D-02

EP10 EU10 Raw Material Transfer-Belt D-02 to Stone Bin

EP12 EU12 Raw Material Transfer-Reclaim Belt 2 to Crusher/Stone Belt 2

EP13 EU13 Raw Material Transfer-Crusher/Stone Belt 2 to Crusher Belt 2

EP15 EU15 Clay Crushing

G. Miscellaneous Sources

Emission

Point

Number

Associated

Emission Unit

Number

Associated Emission Unit Description

EP25

EP27 EU25 Kiln/Calciner/Preheater

EP26 EU26 Clinker Cooler

EU28 Kiln Dust Disposal Tank EP28 EU29 Kiln Dust Loadout

EP55 EU55 Limestone Drilling

EP55A EU55A Quarry Blasting

EP62 EU62 Coal Mill

EP92 EU92 Secondary Fuel Receiving
10 04-TV-011 7/29/004

Insignificant Equipment List

________________________________________________________________________

________________________________________________________________________

Insignificant Emission

Unit Number Insignificant Emission Unit Description

IN-A1 Plant Used Oil Tank < 1,000 gal.

IN-A2 Quarry Used Oil Tank < 1,000 gal.

IN-A3 Kerosene Tank < 1,000 gal.

IN-A4 Underground Diesel Tank < 1,000 gal.

IN-A5 Underground Gasoline Tank < 1,000 gal.

65 East HCl Tank 5,400 gal.

66 Center HCl Tank 5,400 gal.

67 West HCl Tank 5,400 gal.

68 Grinding Aid Concentrate Tank 12,000 gal.

69A Grinding Aid Tank (with water) 1,872 gal.

69B Grinding Aid Tank (with water) 1,872 gal.

70A Airlon Concentrate Tank 6,000 gal.

70B Airlon Holding Tank (with water) 1,512 gal

71 Mixing Tank

72 Grinding Aid No. 2 Concentrate 8,000 gal.
11 04-TV-011 7/29/004

II. Plant-Wide Conditions

Facility Name: Lehigh Cement Company

Permit Number: 04-TV-011

Permit conditions are established in accord with 567 Iowa Administrative Code rule 22.108

______________________________________________________________________________

Permit Duration

The term of this permit is: Five (5) years

Commencing on: July 29, 2004

Ending on: July 28, 2009

Amendments, modifications and reopenings of the permit shall be obtained in accordance with

567 Iowa Administrative Code rules 22.110 - 22.114. Permits may be suspended, terminated, or

revoked as specified in 567 Iowa Administrative Code Rules 22.115.

____________________________________________________________________________

Emission Limits

Unless specified otherwise in the Source Specific Conditions, the following limitations and

supporting regulations apply to all emission points at this plant:

Opacity (visible emissions): 40% opacity

Authority for Requirement: 567 IAC 23.3(2)"d"

Sulfur Dioxide (SO2): 500 parts per million by volume

Authority for Requirement: 567 IAC 23.3(3)"e"

Particulate Matter (state enforceable only)1:

No person shall cause or allow the emission of particulate matter from any source in excess of

the emission standards specified in this chapter, except as provided in 567 – Chapter 24. For

sources constructed, modified or reconstructed after July 21, 1999, the emission of particulate

matter from any process shall not exceed an emission standard of 0.1 grain per dry standard

cubic foot of exhaust gas, except as provided in 567 – 21.2(455B), 23.1(455B), 23.4(455B) and

567 – Chapter 24.

For sources constructed, modified or reconstructed prior to July 21, 1999, the emission of

particulate matter from any process shall not exceed the amount determined from Table I, or

amount specified in a permit if based on an emission standard of 0.1 grain per standard cubic

foot of exhaust gas or established from standards provided in 23.1(455B) and 23.4(455B).

Authority for Requirement: 567 IAC 23.3(2)"a" (as revised 7/21/1999)

 

1

 Pending approval into Iowa's State Implementation Plan (SIP), paragraph 567 IAC 23.3(2)"a" (as revised

7/21/1999) is considered state enforceable only.
12 04-TV-011 7/29/004

Particulate Matter2:

The emission of particulate matter from any process shall not exceed the amount determined

from Table I, except as provided in 567 — 21.2(455B), 23.1(455B), 23.4(455B) and 567 —

Chapter 24. If the director determines that a process complying with the emission rates specified

in Table I is causing or will cause air pollution in a specific area of the state, an emission

standard of 0.1 grain per standard cubic foot of exhaust gas may be imposed.

Authority for Requirement: 567 IAC 23.3(2)"a" (prior to 7/21/1999)

Fugitive Dust: Attainment and Unclassified Areas - No person shall allow, cause or permit any

materials to be handled, transported or stored; or a building, its appurtenances or a construction

haul road to be used, constructed, altered repaired or demolished, with the exception of farming

operations or dust generated by ordinary travel on unpaved public roads, without taking

reasonable precautions to prevent particulate matter in quantities sufficient to create a nuisance,

as defined in Iowa Code section 657.1, from becoming airborne. All persons, with the above

exceptions, shall take reasonable precautions to prevent the discharge of visible emissions of

fugitive dusts beyond the lot line of the property on which the emissions originate. The highway

authority shall be responsible for taking corrective action in those cases where said authority has

received complaints of or has actual knowledge of dust conditions which require abatement

pursuant to this subrule. Reasonable precautions may include, but not limited to, the following

procedures.

1. Use, where practical, of water or chemicals for control of dusts in the demolition of

existing buildings or structures, construction operations, the grading of roads or the

clearing of land.

2. Application of suitable materials, such as but not limited to asphalt, oil, water or

chemicals on unpaved roads, material stockpiles, race tracks and other surfaces which

can give rise to airborne dusts.

3. Installation and use of containment or control equipment, to enclose or otherwise limit

the emissions resulting from the handling and transfer of dusty materials, such as but

not limited to grain, fertilizers or limestone.

4. Covering at all times when in motion, open-bodied vehicles transporting materials

likely to give rise to airborne dusts.

5. Prompt removal of earth or other material from paved streets or to which earth or other

material has been transported by trucking or earth-moving equipment, erosion by

water or other means.

Authority for Requirement: 567 IAC 23.3(2)"c"

__________________________________________________________________________

Compliance Plan

The owner/operator shall comply with the applicable requirements listed below. The compliance

status is based on information provided by the applicant.

Unless otherwise noted in Section III of this permit, Lehigh Cement Company. is in compliance

 

2

 Paragraph 567 IAC 23.3(2)"a" (prior to 7/21/1999) is the general particulate matter emission standard currently in

the Iowa SIP..
13 04-TV-011 7/29/004

with all applicable requirements and shall continue to comply with all such requirements. For

those applicable requirements which become effective during the permit term, Lehigh Cement

Company shall comply with such requirements in a timely manner.

Authority for Requirement: 567 IAC 22.108(15)

Operational Limits & Requirements

The owner/operator of this facility shall comply with the operational limits and requirements

listed below.

Terms and Conditions: The Permittee shall comply with all applicable requirements of Iowa

Department of Natural Resources Administrative Consent Order No. 1999-AQ-32. The Permittee

shall also comply with all applicable requirements of 40 CFR 63 Subpart LLL-National

Emission Standards for Hazardous Air Pollutants for Source Categories; Portland Cement

Manufacturing Industry, and the applicable requirements of 40 CFR 63 Subpart A General

Provisions as listed in Table 1 of 40 CFR 63 Subpart LLL. Per 40 CFR 63.1356 any affected

source subject to the provisions of 40 CFR 63 Subpart LLL will be exempt from any otherwise

applicable new source performance standard contained in 40 CFR 60 Subpart F or Subpart OOO,

and the requirements of 40 CFR 60 Subpart Y do not apply to conveying system transfer points

used to convey coal from the mill to the kiln that are associated with coal preparation.

Applicable Limits and Requirements From Iowa Department of Natural Resources

Administrative Consent Order No. 1999-AQ-32

See Appendix A.

Applicable Limits and Requirements From 40 CFR 63 Subpart LLL-National Emission

Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing

Industry.

See Appendix C.

Authority for Requirement: Iowa Department of Natural Resources Administrative Consent

 Order 1999-AQ-3

 40 CFR 63 Subpart LLL

 567 IAC 23.1(4)"bl"
14 04-TV-011 7/29/004

III. Emission Point-Specific Conditions

Facility Name: Lehigh Cement Company

Permit Number: 04-TV-011

______________________________________________________________________________

Emission Point ID Number: See Table: Material Transfer Fugitive Emission

Sources Subject Only to Administrative Consent Order 1999-AQ-32 and the

Fugitive Dust Rule

Associated Equipment

Associated Emission Unit ID Numbers: See Table: Material Transfer Fugitive Emission Sources

Subject Only to Administrative Consent Order 1999-AQ-32 and the Fugitive Dust Rule

______________________________________________________________________________

Table: Material Transfer Fugitive Emission Sources Subject Only to Administrative Consent

Order 1999-AQ-32 and the Fugitive Dust Rule

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description Raw Material Rated

Capacity/Size

EP1 EU1 Railcar Unloading Coal, Gypsum,

Anhydrite 300 TPH

EP7 EU7A Limestone Transfer Limestone 750 TPH

EU14A Clay Delivery and Distribution 500 TPH EP14

EU14B Clay Transfer to Process Clay 500 TPH

EP15A EU15A Raw Material Transfer – Clay

Crushing System

Clay & Crushed

Limestone 500 TPH

EP15B EU15B Raw Material Transfer - Clay

Crushing System

Clay & Crushed

Limestone 500 TPH

EP39-2 EU39-2 Gypsum/Anhydrite Bucket

Transfer Gypsum/Anhydrite 150 TPH

EP40 EU40 Coal Crusher Coal 55 TPH

EP56A EU56A Truck Loading - Limestone Limestone 1,000 TPH

EP57A EU57A Truck Loading - Clay Clay 500 TPH

EP58A EU58A Coal Transfer Coal 7,200 TPD

EU59A Sand Delivery & Unloading 500 TPH EP59A EU59B Sand Transfer to Process Sand 500 TPH
15 04-TV-011 7/29/004

Table: Material Transfer Fugitive Emission Sources Subject Only to Administrative Consent

Order 1999-AQ-32 and the Fugitive Dust Rule (cont.)

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description Raw Material Rated

Capacity/Size

EU60A Clay Delivery & Unloading 500 TPH EP60A EU60B Clay Transfer to Process Clay 500 TPH

EU61A Clay Delivery & Unloading 500 TPH EP61A EU61B Clay Transfer to Process Clay 500 TPH

EP62-1 EU62-1 Coal Transfer Coal 55 TPH

EP63A EU63A Kiln Dust Unloading Kiln Dust 300 TPD

EP73A EU73A Limestone Transfer to Process

Pile at Crusher Limestone 19,200 TPD

EP74A EU74A Limestone Transfer-Process Pile

at Crusher Limestone 2,000 TPD

EP75A EU75A Clinker Transfer to Craneway Clinker 1,200 TPD

EP76A EU76A Clinker, Gypsum, Slag Transfer Clinker, Gypsum, Slag 3,600 TPD

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from these emission points shall not exceed the levels specified below.

Pollutant: Fugitive Dust

Emission Limit: No person shall allow, cause or permit any materials to be handled, transported

or stored; or a building, its appurtenances or a construction haul road to be used, constructed,

altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance. All

persons shall take reasonable precautions to prevent the discharge of visible emissions of fugitive

dusts beyond the lot line of the property on which the emissions originate.

Authority for Requirement: 567 IAC 23.3(2)"c"
16 04-TV-011 7/29/004

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

Table: Material Transfer Fugitive Emission Sources Subject Only to Administrative Consent

Order 1999-AQ-32 and the Fugitive Dust Rule-Operational Limits & Requirements

Process Throughput

Limit

 Emission

Point

Number

Associated

Emission

Unit

Number

Max. No.

of

Transfers

Maximum

Daily

Throughput

-Each

Transfer

(tons/day)

Maximum Calendar

Year ThroughputEach Transfer

(tons/year)

Reporting &

Recordkeeping(1)

Authority for

Requirements

EP1 EU1 3 7,200 200,000

EP7 EU7A 1 19,200(2) 2,500,000

EU14A 2 12,000 200,000 EP14 EU14B 1 12,000 200,000

EP15A EU15A

EP15B EU15B 4 12,000 200,000

EP39-2 EU39-2 2 3,600 100,000

EP40 EU40 1 1,320 200,000

EP56A EU56A 2 16,000(3) 1,675,800

EP57A EU57A 2 12,000(4) 141,667

EP58A EU58A 1 7,200 200,000

EU59A 2 12,000 2,190,000 EP59A EU59B 1 12,000 2,190,000

EU60A 2 12,000 2,190,000 EP60A EU60B 1 12,000 2,190,000

EU61A 2 12,000 2,190,000 EP61A EU61B 1 12,000 2,190,000

Section V(3)

Iowa

Department of

Natural

Resources

Administrative

Consent Order

No. 199-AQ32

EP62-1 EU62-1 4 1,320 481,800

EP63A EU63A 1 300 70,080

EP73A EU73A 1 19,200(2) 500,000

EP74A EU74A 1 2,000(5) 70,000

EP75A EU75A 1 1,200(6) 15,000

EP76A EU76A 1 3,600 50,000

The total daily

throughput and

throughput rates for

each source shall be

entered into a daily

log, and annual

throughputs totaled

annually to

demonstrate

compliance with

the daily and

annual throughput

limits.

(1)The records shall be kept on site for a minimum of five years, and shall be available for

inspection by the Department.

(2)Maximum hourly throughput will be 1,200 ton/hour for the period 7:00 a.m. through 11:00

p.m. and 750 ton/hour at other times. Maximum daily throughput will not be exceeded on any

one day.
17 04-TV-011 7/29/004

(3)Maximum hourly throughput will be 1,000 ton/hour for the period 7:00 a.m. through 11:00

p.m. and 666 ton/hour at other times. Maximum daily throughput will not be exceeded on any

one day.

(4)Maximum hourly throughput will be 1,000 ton/hour for the period 8:00 a.m. through 8:00 p.m.

and 460 ton/hour at other times. Maximum daily throughput will not be exceeded on any one

day.

(5)Maximum hourly throughput will be 250 ton/hour for the period 8:00 a.m. through 4:00 p.m.

and 83.3 ton/hour at other times. Maximum daily throughput will not be exceeded on any one

day.

(6)Maximum hourly throughput will be 100 ton/hour for the period 7:00 a.m. through 7:00 p.m.

and 50 ton/hour at other times. Maximum daily throughput will not be exceeded on any one day.

If the sources footnoted above operate within the maximum hourly throughput time periods

indicated, then the sources daily logs and annual throughput totals shall be used to demonstrate

compliance. If these sources operate at other times during any day, then compliance will be

demonstrated for that calendar day by entering the hourly throughput and total daily throughput

rates for each of these sources in daily logs to demonstrate compliance with the daily and annual

throughput limits.

Authority for Requirement: Section V(3) Iowa Department of Natural Resources Administrative

 Consent Order No. 199-AQ-32

The coal crusher (emission point 40) shall be operated only in an enclosed structure with all

access doors and any other openings closed during normal operations except for doors during

ingress and egress.

Authority for Requirement: Section V(4) Iowa Department of Natural Resources Administrative

 Consent Order No. 199-AQ-32

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 22.108(3)"b"
18 04-TV-011 7/29/004

Emission Point ID Numbers: See Table: Storage Piles

Associated Equipment

Associated Emission Unit ID Numbers: See Table: Storage Piles

___________________________________________________________________________

Table: Storage Piles

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description Raw Material Size

EP14 EU14 Clay Storage Pile No. 1 Clay 1 acre

EP58 EU58 Coal Storage Pile Coal 3 acres

EP59 EU59 Sand Storage pile Sand 4 acres

EP60 EU60 Clay Storage Pile No.2 Clay 1 acre

EP61 EU61 Clay Storage Pile No. 3 Clay 1 acre

EP63 EU63 Kiln Dust Storage Pile Kiln Dust 2 acres

EP73 EU73 Quarry Run Limestone Storage Pile Limestone 1 acre

EP74 EU74 Quarry Run Limestone Storage Pile Limestone 0.5 acre

EP75 EU75 Clinker Storage Pile Clinker 0.5 acre

EP76 EU76 Raw Materials Storage Pile

Clinker, Gypsum,

Granulated Blast

Furnace Slag

0.75 acre

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from these emission points shall not exceed the levels specified below.

Pollutant: Fugitive Dust

Emission Limit: No person shall allow, cause or permit any materials to be handled, transported

or stored; or a building, its appurtenances or a construction haul road to be used, constructed,

altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance. All

persons shall take reasonable precautions to prevent the discharge of visible emissions of fugitive

dusts beyond the lot line of the property on which the emissions originate.

Authority for Requirement: 567 IAC 23.3(2)"c"
19 04-TV-011 7/29/004

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

1. Unless otherwise allowed for below, the only storage piles allowed within the Lehigh facility

shall be the storage piles listed in the table: Storage Piles above and the storage piles shall not

exceed the sizes listed under "Size" in same table.

2. Lehigh may relocate a pile specified in the table: Storage Piles above only after providing

written notice to DNR and submitting the results of computer dispersion modeling showing

that no exceedances of the PM10 NAAQS would result. If an exceedance of the PM10 NAAQS

would result based on the computer modeling results, Lehigh shall not move the pile as

proposed and the pile shall remain at the location designated in Exhibit D, Appendix A.

3. Notwithstanding the requirements of 1. and 2. above, Lehigh may operate temporary piles of

materials (not identified in the table: Storage Piles above) that result from maintenance or

other similar activities. No such temporary pile shall be maintained for more than one 72-

hour period.

4. Notwithstanding the requirements of 1, 2 and 3 above Lehigh may maintain temporary piles

of overflow raw materials and product (not identified in the table: Storage Piles above) that

may result from unforseen and unplanned operating conditions or problems. Lehigh shall

take all reasonable measures to limit the size of any such pile and the fugitive emissions that

result therefrom. No more than two such temporary piles may exist at one time. No such

temporary pile shall be maintained for more than one (1) month. Lehigh shall maintain

records that include the pile location, planned or actual pile size, pile material content, and

the planned removal date for each pile. The records shall be retained for a period of five

years following the date of the above entries and shall be made available to the DNR upon

request. This record keeping shall be an on-going requirement and shall not terminate.

 Authority for Requirement: Section V Iowa Department of Natural Resources Administrative

Consent Order No. 1999-AQ-32

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 22.108(3)"b"
20 04-TV-011 7/29/004

Emission Point ID Numbers: See Table: Haulroads

Associated Equipment

Associated Emission Unit ID Numbers: See Table: Haulroads 

_____________________________________________________________________________

Table: Haulroads

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description Raw Material Rated Capacity

EP56 EU56 Limestone Quarry Haulroad Unpaved Road 70 trips/day

EP57 EU57 Clay Quarry Haulroad Unpaved Road 1,667 VMT/yr.

EP63B EU63B Kiln Dust Haulroad Paved Road 10 trips/day

EP80 EU80 Cement Haulroad-Cement

Loadout to U.S. 65 Paved Road 222 trips/day

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from these emission points shall not exceed the levels specified below.

Pollutant: Fugitive Dust

Emission Limit: No person shall allow, cause or permit any materials to be handled, transported

or stored; or a building, its appurtenances or a construction haul road to be used, constructed,

altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance. All

persons shall take reasonable precautions to prevent the discharge of visible emissions of fugitive

dusts beyond the lot line of the property on which the emissions originate.

Authority for Requirement: 567 IAC 23.3(2)"c"

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

1. Lehigh must have speed controls designed to ensure that the average speed of the haul trucks

on the limestone and clay haul roads (emission points EP56 and EP57) does not exceed 18.5

miles per hour. The speed controls shall consist of a combination of speed limit signs, stop

signs, and governors on the accelerators of each haul road truck, or other methods approved

in writing by DNR.

2. The maximum number of round trips per day and per calendar year on the limestone haul
21 04-TV-011 7/29/004

road (EP56) for all of the haul trucks, combined, shall be limited to 70 and 17,640 trips,

respectively. The number of trips per day on the limestone haul road shall be entered in a

daily log to demonstrate compliance with this requirement. Daily logs shall be retained for a

period of five years following the date of such entries and shall be made available to the

DNR upon request.

3. Fugitive emissions from the limestone haul road (EP56) shall be controlled by applying a

chemical dust suppressant. A control efficiency of 90 percent shall be maintained on the first

1.41 miles of the limestone haul road from the quarry. This will require a ground inventory

of 0.25 gallons of chemical dust suppressant per square yard. This section of limestone haul

road is 30 feet wide and 1.41 miles long, giving it a total area of 24,816 square yards. At

least 6,204 gallons of the selected chemical dust suppressant shall be applied initially to

achieve this ground level inventory. At least 1,241 gallons of the selected chemical dust

suppressant shall be applied every calendar month with no more than 35 days between

applications, to maintain the ground inventory. This equates to 0.05 gallons of chemical dust

suppressant per square yard. In the event that the manufacturer or distributor of a chemical

dust suppressant recommends that amounts other than those specified above be applied,

Lehigh shall notify DNR in writing of the change in application rates and the

manufacturer's/distributor's recommendations.

A control efficiency of 95 percent shall be maintained on the remaining length of the

limestone haul road from 1.41 miles from the quarry to the primary limestone crusher

(emission point EP2). This will require a ground inventory of 0.25 gallons of chemical dust

suppressant per square yard. The remaining limestone haul road is 30 feet wide and 2.89

miles long, giving it a total area of 50,864 square yards. At least 12,716 gallons of the

selected chemical dust suppressant shall be applied initially to achieve this ground level

inventory. At least 2,543 gallons of the selected chemical dust suppressant shall be applied

not less than once every other week to maintain the ground inventory. This equates to 0.05

gallons of chemical dust suppressant per square yard.

If the selected chemical dust suppressant can not be applied because the ambient air

temperature (as measured at the facility during daylight operating hours) will be less than

350 F (1.70 C) or conditions due to weather, in combination with the application of the

chemical dust suppressant, could create hazardous driving conditions, then the chemical dust

suppressant application shall be postponed and applied as soon after the scheduled

application date as the conditions preventing the application have abated. Records of the

applications shall be maintained and shall include the dates of each application, the chemical

used, the application intensity (gals./sq.yd.), dilution ratio, the areas treated, the operator's

initials, and documentation of road and weather conditions, if necessary. If the selected

chemical dust suppressant is not applied as planned, then the records should so indicate and

provide an explanation. The records shall be retained for a period of five years following the

date of the above entries and shall be made available to the DNR upon request.

4. The maximum number of round trips per day and per calendar year on the clay haul

road (EP57) for all of the haul trucks, combined, shall be limited to 130 and 1,667 trips,

respectively. The number of trips per day on the clay haul road shall be entered in a daily log

to demonstrate compliance with this requirement. Daily logs shall be retained for a period of
22 04-TV-011 7/29/004

five years following the date of such entries and shall be made available to the DNR upon

request.

5. Fugitive emissions from the clay haul road (EP57) shall be controlled to an effective control

efficiency of 95 percent by applying a chemical dust suppressant. A control efficiency of 95

percent will require a ground inventory of 0.25 gallons the selected chemical dust

suppressant per square yard. The clay haul road is 30 feet wide and 0.9 miles long, giving it

a total area of 15,840 square yards. At least 3,960 gallons of the selected chemical dust

suppressant shall be applied initially to achieve this ground level inventory. At least 792

gallons of the selected chemical dust suppressant shall be applied not less than once every

other week to maintain the ground inventory. This equates to 0.05 gallons of chemical dust

suppressant per square yard. In the event that the manufacturer or distributor of a chemical

dust suppressant recommends that amounts other than those specified above be applied,

Lehigh shall notify DNR in writing of the change in application rates and the

manufacturer's/distributor's recommendations.

If the selected chemical dust suppressant can not be applied because the ambient air

temperature (as measured at the facility during daylight operating hours) will be less than

350 F (1.70 C) or conditions due to weather, in combination with the application of the

chemical dust suppressant, could create hazardous driving conditions, then the chemical dust

suppressant application shall be postponed and applied as soon after the scheduled

application date as the conditions preventing the application have abated. Records of the

applications shall be maintained and shall include the dates of each application, the chemical

used, the application intensity (gals./sq.yd.), dilution ratio, the areas treated, the operator's

initials, and documentation of road and weather conditions, if necessary. If the selected

chemical dust suppressant is not applied as planned, then the records should so indicate and

provide an explanation. The records shall be retained for a period of five years following the

date of the above entries and shall be made available to the DNR upon request.

It is not uncommon for this clay haul road to go unused for periods greater than one-half

month. In the event Lehigh does not use the clay haul road for a period greater than one-half

month, Lehigh shall not be required to apply the chemical dust suppressant as provided in the

above paragraph, on the condition that such event is noted and explained in the records

required herein and that, prior to use, an application will be made, weather permitting and

requiring.

6. The maximum number of round trips per day and per calendar year on the paved haul road

 from the product loadout silos to U.S. Highway 65 (emission point EP80) for all haul trucks

 combined shall be limited to the values listed below.

Month Maximum Number of Trips per Day

January 80

February 69

March 200

April 250

May 250

June 250

July 203
23 04-TV-011 7/29/004

Month Maximum Number of Trips per Day

August 250

September 250

October 250

November 250

December 250

Calendar Year Maximum Number of Trips Per Year

January through December 37,302

The number of round trips per day on this haul road shall be entered in a monthly log to

demonstrate compliance with this requirement. Monthly logs shall be retained for a period of

five years following the date of such entries and shall be made available to the DNR upon

request.

7. Fugitive emissions from the paved haul road from the product loadout silos to U.S. Highway

65 shall be controlled to an effective control efficiency of 80 percent by water flushing

followed by sweeping. Using an application rate of 0.48 gallons per square yard, this haul

road shall require a water flushing followed by sweeping application after every 362 vehicle

passes to maintain an 80 percent control efficiency. Based on a worse-case round trip

estimate of 222 trips per day, the water flushing followed by sweeping will have to be

accomplished every two days. The haul road is 24 feet wide and 2072 feet long, giving a

total area of 5,525 square yards. Based on an application rate of 0.48 gallons of water per

square yard, 2,652 gallons of water will be required for each application.

If water flushing followed by sweeping cannot be accomplished because the ambient air

temperature (as measured at the facility during daylight operating hours) will be less than

350 F (1.70 C) or conditions due to weather, in combination with the application of the water,

could create hazardous driving conditions, then the water flushing and sweeping shall be

postponed and accomplished as soon after the scheduled date as the conditions preventing the

application have abated. Additionally, water flushing and sweeping need not occur when a

rain gauge located at the site indicates that at least 0.2 inches of precipitation (water

equivalent) has occurred within the preceding 24-hour time period. Records of the

applications shall be maintained and shall include the dates and times of each application, the

calculated application intensity, the areas treated, the operator's initials, and documentation

road and weather conditions, if necessary. If the water flushing is not acocmplished because

ambient air temperatures are less than 350 F during the entire day, or precipitation exceeding

0.2 inches has occurred in the preceding 24 hours, then the records shall indicate this. The

records shall be retained for a period of five years following the date of the above entries and

shall be made available to the DNR upon request.

Authority for Requirement: Section V(6 through 12) Iowa Department of Natural Resources 

 Administrative Consent Order No. 1999-AQ-32
24 04-TV-011 7/29/004

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 22.108(3)"b"
25 04-TV-011 7/29/004

Emission Point ID Numbers: See Table: Conveying System Transfer Points\

Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL

Associated Equipment

See Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk

Loading and Unloading Units Subject to 40 CFR 63 Subpart LLL, below

________________________________________________________________________

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description

Control

Equipment

Number

Control

Equipment

Description

Raw

Material

Rated

Capacity

(Tons/hr)

EP11 EU11 Raw Material Transfer-Apron

Feeder to Collection Belt CE11 Baghouse CrushedLimestone 440

EP18 EU18 Grinding Circuit-Raw Material

Transfer CE-18 Baghouse Raw Clay 800

EP19 EU19 Raw Material Transfer to

Homoginizing Silo CE-19 Baghouse Raw Mix 200

EP20 EU20 Raw Material Transfer-IBAU Bin

Bottom Elevator CE-20 Baghouse Raw Mix 550

EP21 EU21 Raw Material Transfer-IBAU

Elevator W to top Silo Conveyor CE-21 Baghouse Raw Mix 550

EP22 EU22 Raw Material Transfer-IBAU

Elevator S to top Silo Conveyor CE-22 Baghouse Raw Mix 550

EP23 EU23 IBAU Bin S Top Elevator Raw

Material Transfer CE-23 Baghouse Raw Mix 550

EP24 EU24 Raw Material Transfer CE-24 Baghouse Raw Mix 225

EP33 EU33 Outhaul Conveyor Transfer CE33 Baghouse Clinker 180

EP34 EU34 Clinker Truck Loadout CE34 Baghouse Clinker 100

EP35 EU35 Outhaul Conveyor Transfer to

Clinker Silo CE35 Baghouse Clinker 300

EP36 EU36 Clinker Withdrawal Conveyor

Transfer CE36 Baghouse Clinker 180

EP37 EU37 Clinker Belt 206 to 208 Transfer CE37 Baghouse Clinker 300

EP39 EU39 Clinker Transfer CE39 Baghouse Clinker 114.58
26 04-TV-011 7/29/004

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL (Cont.)

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description

Control

Equipment

Number

Control

Equipment

Description

Raw

Material

Rated

Capacity

(Tons/hr)

EU38 Clinker Belt 208 to Belt 211

Transfer 300

EP39-1

EU39-1 Clinker Ladder

CE38 Baghouse Clinker

150

EP39-3 EU39-3 Clinker Bucket Transfer None None Clinker 150

EU41 No. 3 Finish Mill

EP41 EU41A Vibrating Conveyor Transfer

EU41B Air Separator

CE-41 Baghouse Clinker 30 

EU41 No. 3 Finish Mill

EP42 EU41A Vibrating Conveyor Transfer

EU41B Air Separator

CE-41 Baghouse Clinker 30

EU43 No. 5 Finish Mill

EP43 EU43A Vibrating Conveyor Transfer

EU43B Air Separator

CE-43 Baghouse Clinker 30

EU44 No. 6 Finish Mill

EP44 EU44A Vibrating Conveyor Transfer

EU44B Air Separator

CE-44 Baghouse Clinker 30

EU45 No. 4 Finish Mill

EP45 EU45A Vibrating Conveyor Transfer

EU5B Air Separator

CE-45 Baghouse Clinker 75

EU46 Clinker Transfer

EP46

EU46A Clinker Transfer

CE-46 Baghouse Clinker 75

EP47 EU47 Storage Silo CE47 Baghouse Cement 100

EP48 EU48 Transfer Bucket Elevator CE48 Baghouse Cement 350

EP49 EU49 Direct Cement Loadout

(Emergency Only) None None Cement 300
27 04-TV-011 7/29/004

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL (Cont.)

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description

Control

Equipment

Number

Control

Equipment

Description

Raw

Material

Rated

Capacity

(Tons/hr)

EP50 EU50 Silo Row 40 Cement Bulk Loadout CE50 Baghouse Cement 350

EP51 EU51 Silo Row 30 Cement Loadout CE51 Baghouse Cement 350

EP52 EU52 Silo Row 50 Rail/Truck Cement

Loading System CE52 Baghouse Cement 400

EP53 EU53 Silo Row 50 Cement Loadout

Spout CE53 Baghouse Cement 400 TPH

Applicable Requirements

Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)

The emissions from these emission points shall not exceed the levels specified in Table:

Conveying System Transfer Points\Raw and Finish Mills\Storage Bins\Bulk Loading and

Unloading Units Subject to 40 CFR 63 Subpart LLL-Emission Limits.

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL -Emission Limits

Emission

Point

Number

Associated

Emission Unit

Number

Opacity

Limit

PM10 Limit

(lb/hr)

PM Limit

(gr/scf) Construction Permit No.

EP11 EU11 10% 0.86 0.1 82-A-022-S3

EP18 EU18 10% 1.41 0.1 82-A-028-S1

EP19 EU19 10% 1.37 0.1 77-A-223-S2

EP20 EU20 10% 0.29 0.1 82-A-032-S2

EP21 EU21 10% 0.29 0.1 82-A-029-S2

EP22 EU22 10% 0.92 0.1 82-A-031-S2

EP23 EU23 10% 0.88 0.1 82-A-030-S2

EP24 EU24 10% 1.34 0.1 82-A-033-S2

EP33 EU33 10% 0.51 0.1 80-A-175-S2

EP34 EU334 10% 0.17 0.1 80-A-177-S2

EP35 EU35 10% 1.37 0.1 80-A-179-S2

EP36 EU36 10% 0.69 0.1 80-A-178-S2

EP37 EU37 10% 0.17 0.1 80-A-174-S2

EP39 EU39 10% 1.08 0.1 86-A-021-S2

EU38 EP39-1 EU39-1 10% 0.86 0.1 99-A-225-S3

EP39-3 EU39-3 10% N/A 0.1 None

EU41

EP41 EU41A

EU41B

10% 1.16 0.1 00-A-397-S1

EU41

EP42 EU41A

EU41B

10% 1.16 0.1 00-A-397-S1
28 04-TV-011 7/29/004

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL-Emission Limits (cont.)

Emission

Point

Number

Associated

Emission Unit

Number

Opacity

Limit

PM10 Limit

(lb/hr)

PM Limit

(gr/scf)

Construction

Permit No.

EU43

EP43 EU43A

EU43B

10% 1.46 0.1 00-A-398-S1

EU44

EP44 EU44A

EU44B

10% 1.46 0.1 00-A-400-S1

EU45

EP45 EU45A

EU45B

10% 5.14 0.1 82-A-038-S2

EU46 EP46 EU46A 10% 0.77 0.1 82-A-037-S2

EP47 EU47 10% 1.29 0.1 78-A-322-S2

EP48 EU48 10% 0.51 0.1 83-A-008-S2

EP49 EU49 10% N/A N/A None

EP50 EU50 10% 0.17 0.1 83-A-009-S2

EP51 EU51 10% 0.17 0.1 83-A-010-S2

EP52 EU52 10% 1.08 0.1 90-A-365-S2

EP53 EU53 10% 1.08 0.1 90-A-366-S2

Pollutant: Opacity

Emission Limit: 10 %(1)

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Conveying

System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL-Emission Limits

 567 IAC 23.1(4)"bl"

 40 CFR 63.1348

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

 startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance

 with the particulate standard.

Pollutant: Particulate Matter

Emission Limit: 0.1 gr/scf

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Conveying

System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL-Emission Limits

 567 IAC 23.3(2)"a"
29 04-TV-011 7/29/004

Pollutant: PM10

Emission Limit: As specified in Table: Conveying System Transfer Points\ Raw and Finish

Mills\ Storage Bins\ Bulk Loading and Unloading Units Subject to 40 CFR 63 Subpart LLLEmission Limits

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Conveying

System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL-Emission Limits

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL-Operational Limits & Requirements

 Emission

Point

Number

Associated

Emission Unit

Number

Hours of

Operation Limit Reporting & Recordkeeping Authority for Requirements

EP11 EU11

EP18 EU18

EP19 EU19

EP20 EU20

EP21 EU21

EP22 EU22

EP23 EU23

Each emission

source shall not

operate more than

7,884 hours per

rolling twelvemonth period.

EU41

EP41 EU41A

EU41B

EU41

EP42 EU41A

EU41B

EU43

EP43 EU43A

EU43B

EU44

EP44 EU44A

EU44B

EU45

EP45 EU45A

EU45B

EU46 EP46 EU46A

Each emission

source shall not

operate more than

7,534 hours per

rolling twelvemonth period

Iowa DNR Construction Permits

specified in Table: Conveying

System Transfer Points\ Raw and

Finish Mills\ Storage Bins\ Bulk

Loading and Unloading Units

Subject to 40 CFR 63 Subpart

LLL-Emission Limits

Section V(2)

Iowa Department of Natural

Resources Administrative

Consent Order No.

1999-AQ-32

EP39 EU39

This emission

source shall not

operate more than

5,843 hours per

rolling twelvemonth period.

1. For the first twelve months

of operation, determine the

cumulative

 hours of operation of each

 source for each month of

 operation.

2. After the first twelve

 months of operation

 determine the annual hours

 of operation of each

 emission source on a

 rolling twelve-month total

 for each month of

 operation.

Iowa DNR Construction Permit

86-A-021-S2
30 04-TV-011 7/29/004

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL-Operational Limits & Requirements

 (cont.)

Process Throughput

Limit

Emission

Point

Number

Associated

Emission

Unit

Number

Max. No.

of

Transfers

Maximum

Daily

Throughput

-Each

Transfer

(tons/day)

Maximum Calendar

Year ThroughputEach Transfer

(tons/year)

Reporting &

Recordkeeping

Authority for

Requirements

EP39-3 EU39-3 2 3,600 500,000

EP49 EU49 1 300 5,000

The total daily

throughput and

throughput rates for

each source shall be

entered into a daily

log, and annual

throughputs totaled

annually to

demonstrate

compliance with

the daily and

annual throughput

limits.

Section V(3)

Iowa

Department of

Natural

Resources

Administrative

Consent Order

No. 199-AQ32

Additional Reporting & Record keeping:

All records as required by this permit shall be kept on-site for a minimum of five (5) years and

shall be available for inspection by the DNR. Records shall be legible and maintained in an

orderly manner. The records shall show the following:

Recordkeeping for NESHAP 40 CFR 63 Subpart LLL at the facility shall be done per 40 CFR

63.1355

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Conveying

System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL-Emission Limits

 567 IAC 23.1(4)"bl"

 40 CFR 63.1355
31 04-TV-011 7/29/004

Emission Point Characteristics

These emission points shall conform to the conditions specified in Table: Conveying System

Transfer Points\Raw and Finish Mills\Storage Bins\Bulk Loading and Unloading Units Subject

to 40 CFR 63 Subpart LLL-Emission Point Characteristics

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL -Emission Point Characteristics

Stack Characteristics

Emission

Point

Number

Emission

Unit

Number

Construction

Permit

Number

Height

(ft.)

Diameter

(inches)

Exhaust

Flowrate

(scfm)

Exhaust

Temp.

(

o

F)

 Discharge Style

EP11 EU11 82-A-022-S3 80 39 X 16 5,000 70 Horizontal

EP18 EU18 82-A-028-S1 110 24 6,600 200 Horizontal

EP19 EU19 77-A-223-S2 190 24 14,600 120 Horizontal

EP20 EU20 82-A-032-S2 110 26 X 18 1,400 200 Horizontal

EP21 EU21 82-A-029-S2 100 16 1,400 200 Horizontal

EP22 EU22 82-A-031-S2 110 16 4,300 200 Horizontal

EP23 EU23 82-A-030-S2 110 16 4,100 200 Horizontal

EP24 EU24 82-A-033-S2 190 24 6,300 200 Horizontal

EP33 EU33 80-A-175-S2 100 8 X 6 3,000 70 Horizontal

EP34 EU34 80-A-177-S2 100 12 X 12 1,000 70 Horizontal

EP35 EU35 80-A-179-S2 180 18 X 24 8,000 70 Horizontal

EP36 EU36 80-A-178-S2 30 18 X 12 4,000 70 Horizontal

EP37 EU37 80-A-174-S2 30 6 X 6 1,000 70 Horizontal

EP39 EU39 86-A-021-S2 80 20 12,000 70 Unobstructed Vertical

EU38 EP39-1 EU39-1 99-A-225-S3 55 17.9 X 20 8,000 -

10,000 70 - 200 Horizontal

EU41

EP41 EU41A

EU41B

00-A-396 80 16 X 16 13,500 170 Horizontal

EU41

EP42 EU41A

EU41B

00-A-397-S1 80 16 X 16 13,500 170 Horizontal

EU43

EP43 EU43A

EU43B

00-A398-S1 80 18 X 18 14,300 170 Horizontal

EU44

EP44 EU44A

EU44B

00-A-400-S1 80 16 X 16 14,300 170 Unobstructed Vertical

EU45

EP45 EU45A

EU45B

82-A-038-S2 95 48 60,000 200 Unobstructed Vertical
32 04-TV-011 7/29/004

Table: Conveying System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading

and Unloading Units Subject to 40 CFR 63 Subpart LLL -Emission Point Characteristics (cont.)

Stack Characteristics

Emission

Point

Number

Emission

Unit

Number

Construction

Permit #

Height

(ft.)

Diameter

(inches)

Exhaust

Flowrate

(scfm)

Exhaust

Temp.

(

o

F)

 Discharge Style

EU46 EP46 EU46A 82-A-037-S2 85 28 9,000 100 Horizontal

EP47 EU47 78-A-322-S2 150 24 X 24 15,000 70 Horizontal

EP48 EU48 83-A-008-S2 150 12 X 10 3,000 70 Horizontal

EP50 EU50 83-A-009-S2 150 4 X 12 1,000 70 Horizontal

EP51 EU51 83-A-010-S2 150 4 X 12 150 70 Horizontal

EP52 EU52 90-A-365-S2 150 20 X 17 6,300 70 Horizontal

EP53 EU53 90-A-366-S2 158 8 6,300 70 Horizontal

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Conveying

System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL -Emission Point Characteristics

The temperature and flowrate are intended to be representative and characteristic of the design of

the permitted emission point. The Department recognizes that the temperature and flowrate may

vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

The facility shall check the opacity as described in 40 CFR 63.1350 ((a)(4)(i-vii) and (e) of

Appendix C-Applicable Limits and Requirements From 40 CFR 63 Subpart LLLMonitoring Requirements.

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Conveying

System Transfer Points\ Raw and Finish Mills\ Storage Bins\ Bulk Loading and Unloading Units

Subject to 40 CFR 63 Subpart LLL -Emission Point Characteristics

 567 IAC 23.1(4)"bl"

 40 CFR 63.1350
33 04-TV-011 7/29/004

Agency Approved Operation & Maintenance Plan Required? Yes No 

For controlled sources only

Relevant requirements of O & M plan for this equipment: Particulate Matter and Opacity-

 see Appendix B.

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 23.1(4)"bl"

 40 CFR 63.1350(a)
34 04-TV-011 7/29/004

Emission Point ID Number: See Table: Non-Fugitive Sources Subject to

Administrative Consent Order 1999-AQ-32

Associated Equipment

See Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 

_____________________________________________________________________________

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description

Control

Equipment

Number

Control

Equipment

Description Raw Material

Rated

Capacity

(Tons/hr)

EU2 Primary Crusher EP2 EU2A Raw Material Transfer CE2 Baghouse Limestone and Other

Calcareous Materials 750

EU3 Screening 750

EU3A Raw Material Transfer-Belt 2 to

Screen 750

EU3B Raw Material Transfer-Screen to

Belt 3 487 EP3

EU3C Raw Material Transfer-Screen to

Belt 4

CE3 Baghouse Limestone and Other

Calcareous Materials

450

EU5 Secondary Crusher 450

EU5A Raw Material Transfer-Stone 5

to 6 EP5 450

EU5B Raw Material Transfer

CE5 Baghouse

Crushed Limestone

and Other

Calcareous Materials 450

EU6 Raw Material Transfer 487

EP6

EU6A Raw Material Transfer

CE6 Baghouse

Crushed Limestone

and Other

Calcareous Materials 750
35 04-TV-011 7/29/004

Applicable Requirements

Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.

The emissions from these emission points shall not exceed the levels specified in Table: NonFugitive Sources Subject to Administrative Consent Order 1999-AQ-32 -Emission Limits

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32

-Emission Limits

Emission

Point

Number

Associated

Emission Unit

Number

Opacity

Limit

PM10 Limit

(lb/hr)

PM Limit

(gr/scf) Construction Permit No.

EU2 EP2 EU2A 40% 2.4 0.1 77-A-260-S2

EU3

EU3A

EU3B EP3

EU3C

40% 1.03 0.1 77-A-313-S2

EU5

EP5 EU5A

EU5B

40% 0.81 0.1 00-A-395-S1

EU6 EP6 EU6A 40% 0.51 0.1 77-A-360-S2

Pollutant: Opacity

Emission Limit: 40 %(1)

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32-Emission Limits

 567 IAC 23.3(2)"d"

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

 startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance

 with the particulate standard.

Pollutant: Particulate Matter

Emission Limit: 0.1 gr/scf

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32-Emission Limits

 567 IAC 23.3(2)"a"

Pollutant: PM10

Emission Limit: As specified in Table: Non-Fugitive Sources Subject to Administrative Consent

Order 1999-AQ-32-Emission Limits

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32
36 04-TV-011 7/29/004

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32-Operational

Limits and Requirements

Emission

Point

Number

Associated

Emission Unit

Number

Hours of

Operation Limit Reporting & Recordkeeping Authority for Requirements

EU2 EP2 EU2A

EU3

EU3A

EU3B EP3

EU3C

EU5

EP5 EU5A

EU5B

EU6 EP6 EU6A

Each emission

source shall not

operate more

than 4,380 hours

per rolling

twelve (12)

month period.

After the first twelve (12)

months of operation,

determine the annual hours of

operation for each source on a

rolling twelve (12) month total

for each month of operation.

Administrative Consent Order

No. 1999-AQ-32

Iowa DNR Construction

Permits specified in Table:

Non-Fugitive Sources Subject

to ACO-Emission Limits

All records as required by this permit shall be kept on-site for a minimum of five (5) years and

shall be available for inspection by the DNR.

Emission Point Characteristics

These emission points shall conform to the conditions specified in Table: Non-Fugitive Sources

Subject to Administrative Consent Order 1999-AQ-32-Emission Point Characteristics

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32-Emission

Point Characteristics

Stack Characteristics

Emission

Point

Number

Emission

Unit

Number

Construction

Permit

Number

Height

(ft.)

Diameter

(inches)

Exhaust

Flowrate

(scfm)

Exhaust

Temp.

(

o

F)

 Discharge Style

EU2 EP2 EU2A 77-A-260-S2 60 36 X 42 28,000 70 Horizontal

EU3

EU3A

EU3B EP3

EU3C

77-A-313-S2 55 24 X 30 12,000 70 Horizontal

EU5

EP5 EU5A

EU5B

00-A-395-S1 55 18 9,500 70 Horizontal

EU6 EP6 EU6A 77-A-360-S2 55 12 X 24 3,800 70 Horizontal

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32-Emission Point Characteristics
37 04-TV-011 7/29/004

The temperature and flowrate are intended to be representative and characteristic of the design of

the permitted emission point. The Department recognizes that the temperature and flowrate may

vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

For Each Baghouse

Facility operation and maintenance plans must be sufficient to yield reliable data from the

relevant time period that are representative of the source’s compliance with the applicable

requirements.

Facility operation and maintenance plans are to be developed by the facility within six(6) months

of the issuance date of this permit and the data pertaining to the plan maintained on site for at

least 5 years. The plan and associated recordkeeping provides documentation of this facility’s

implementation of its obligation to operate according to good air pollution control practice.

Good air pollution control practice is achieved by adoption of quality control standards in the

operation and maintenance procedures for air pollution control that are comparable to industry

quality control standards for the production processes associated with this emission point.

Authority for Requirement: 567 IAC 22.108(3)"b"
38 04-TV-011 7/29/004

Emission Point ID Number: See Table: Non-Fugitive Sources Subject to

Administrative Consent Order 1999-AQ-32 and 40 CFR Subpart F

Associated Equipment

See Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40

CFR 60 Subpart F 

_____________________________________________________________________________

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR

60 Subpart F 

 Emission

Point

Number

Associated

Emission Unit

Number

Emission Unit Description

Control

Equipment

Number

Control

Equipment

Description Raw Material

Rated

Capacity

(Tons/hr)

EP8 EU8 Raw Material Transfer-Belt D-49

to D-01 CE8 Baghouse Crushed Limestone 585

EP9 EU9 Raw Material Transfer-Belt D-01

to D-02 CE9 Baghouse Crushed Limestone 585

EP10 EU10 Raw Material Transfer-Belt D-02

to Stone Bin CE10 Baghouse Crushed Limestone 585

EP12 EU12 Raw Material Transfer-Reclaim

Belt 2 to Crusher/Stone Belt 2 CE12 Baghouse Crushed Limestone 220

EP13 EU13

Raw Material TransferCrusher/Stone Belt 2 to Crusher

Belt 2

CE13 Baghouse Crushed Limestone 220

EP15 EU15 Clay Crushing CE15 Baghouse Clay and Crushed

Limestone 500

Applicable Requirements

Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.

The emissions from these emission points shall not exceed the levels specified in Table: NonFugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart

F -Emission Limits

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR

60 Subpart F -Emission Limits

Emission

Point

Number

Associated

Emission Unit

Number

Opacity

Limit

PM10 Limit

(lb/hr)

PM Limit

(gr/scf) Construction Permit No.

EP8 EU8 10% 0.36 0.1 82-A-027-S3

EP9 EU9 10% 0.54 0.1 82-A-020-S3

EP10 EU10 10% 0.54 0.1 82-A-021-S3

EP12 EU12 10% 0.36 0.1 82-A-024-S3

EP13 EU13 10% 0.36 0.1 82-A-023-S3

EP15 EU15 10% 0.79 0.1 82-A-019-S3
39 04-TV-011 7/29/004

Pollutant: Opacity

Emission Limit: 10 %(1)

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart FEmission Limits

 567 IAC 23.1(2)"c"

 40 CFR 60.6 (2)(c)

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

 startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance

 with the particulate standard.

Pollutant: Particulate Matter

Emission Limit: 0.1 gr/scf

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart FEmission Limits

 567 IAC 23.3(2)"a"

Pollutant: PM10

Emission Limit: Iowa DNR Construction Permits specified in Table: Non-Fugitive Sources

Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart F-Emission

Limits

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart FEmission Limits
40 04-TV-011 7/29/004

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR

60 Subpart F-Operational Limits and Requirements

 Emission

Point

Number

Associated

Emission Unit

Number

Hours of

Operation Limit Reporting & Recordkeeping Authority for Requirements

EP8 EU8

EP9 EU9

EP10 EU10

Each emission

source shall not

operate more

than 7,884 hours

per rolling

twelve-month

period.

EP12 EU12

EP13 EU13

EP15 EU15

Each emission

source shall not

operate more

than 876 hours

per rolling

twelve-month

period.

1. For the first twelve

months of operation,

determine the

cumulative hours of

 operation of each

 source for each month

 of operation.

2. After the first twelve

 months of operation

 determine the annual

 hours of operation of

 each emission source on

 a rolling twelve-month

 total for each month of

 operation.

Iowa DNR Construction

Permits

specified in Table: NonFugitive Sources Subject to

Administrative Consent Order

1999-AQ-32 and 40 CFR 60

Subpart F-Emission Limits

Section V(2)

Iowa Department of Natural

Resources Administrative

Consent Order No.

1999-AQ-32

Additional Reporting & Record keeping:

All records as required by this permit shall be kept on-site for a minimum of five (5) years and

shall be available for inspection by the DNR. Records shall be legible and maintained in an

orderly manner. The records shall show the following:

1. The owner or operator shall maintain a record of all inspections of the control equipment.

The owner or operator shall document the results of the inspections and note any repairs that

were the result of the inspections.

Control equipment parameters:

1. All control equipment shall be maintained according to the

 manufacturer's specifications.

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart FEmission Limits
41 04-TV-011 7/29/004

Emission Point Characteristics

These emission points shall conform to the conditions specified in Table: Non-Fugitive Sources

Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart F-Emission Point

Characteristics

Table: Non-Fugitive Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR

60 Subpart F-Emission Point Characteristics

Stack Characteristics

Emission

Point

Number

Emission

Unit

Number

Construction

Permit

Number

Height

(ft.)

Diameter

(inches)

Exhaust

Flowrate

(scfm)

Exhaust

Temp.

(

o

F)

 Discharge Style

EP8 EU8 82-A-027-S2 40 10 X 12 2,100 70 Horizontal

EP9 EU9 82-A-020-S3 80 11 X 20 3,100 70 Horizontal

EP10 EU10 82-A-021-S3 80 16 3,200 70 Horizontal

EP12 EU12 82-A-024-S3 80 16 2,100 70 Horizontal

EP13 EU13 82-A-023-S3 40 9 X 16 2,100 70 Horizontal

EU15

EP15 EU15A

EU15B

82-A-019-S2 47 30 9,300 70 Obstructed Vertical

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Non-Fugitive

Sources Subject to Administrative Consent Order 1999-AQ-32 and 40 CFR 60 Subpart F -

Emission Point Characteristics

The temperature and flowrate are intended to be representative and characteristic of the design of

the permitted emission point. The Department recognizes that the temperature and flowrate may

vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

The facility shall check the opacity weekly during a period when the emission unit on this

emission point is at or near full capacity and record the reading. Maintain a written record of the

observation and any action resulting from the observation for a minimum of five years. Opacity

shall be observed to ensure that no visible emissions occur during the material handling

operation of the unit. If visible emissions are observed corrective action will be taken as soon as

possible, but no later than eight hours from the observation of visible emissions. If corrective

action does not return the observation to no visible emissions, then a Method 9 observation will

be required. If an opacity (>10 %) is observed, this would be a violation and corrective action

will be taken as soon as possible, but no later than eight hours from the observation of visible

emissions. If weather conditions prevent the observer from conducting an opacity observation,

the observer shall note such conditions on the data observation sheet. At least three attempts

shall be made to retake opacity readings at approximately 2-hour intervals throughout the day. If

all observation attempts for a week have been unsuccessful due to weather, an observation shall

be made the next operating day where weather permits.
42 04-TV-011 7/29/004

Agency Approved Operation & Maintenance Plan Required? Yes No 

 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

For Each Baghouse

Facility operation and maintenance plans must be sufficient to yield reliable data from the

relevant time period that are representative of the source’s compliance with the applicable

requirements.

Facility operation and maintenance plans are to be developed by the facility within six(6) months

of the issuance date of this permit and the data pertaining to the plan maintained on site for at

least 5 years. The plan and associated recordkeeping provides documentation of this facility’s

implementation of its obligation to operate according to good air pollution control practice.

Good air pollution control practice is achieved by adoption of quality control standards in the

operation and maintenance procedures for air pollution control that are comparable to industry

quality control standards for the production processes associated with this emission point.

Authority for Requirement: 567 IAC 22.108(3)"b"
43 04-TV-011 7/29/004

Emission Point ID Number: See Table: Kiln/Calciner/Preheater

Associated Equipment

Associated Emission Unit ID Numbers: See Table: Kiln/Calciner/Preheater

Emissions Control Equipment ID Number: See Table: Kiln/Calciner/Preheater

Emissions Control Equipment Description: See Table: Kiln/Calciner/Preheater

Continuous Emissions Monitors ID Numbers: See Table: Kiln/Calciner/Preheater

_____________________________________________________________________________

Table: Kiln/Calciner/Preheater

 Emission

Point

Number

Associated

Emission

Unit Number

Emission

Unit

Description

Control

Equipment

Number

Control

Equipment

Description

Continuous

Emissions

Monitor

Number

Raw Material

Rated

Capacity

EP25 CE25 ESP ME25

EP27

EU25 Kiln/Calciner/

Preheater CE27 Baghouse ME27

Raw Mix and

Fuel 250 TPH

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from these emission points shall not exceed the levels specified in Table: Kiln/

Calciner/Preheater -Emission Limits..

Table: Kiln/Calciner/Preheater -Emission Limits

Emission

Point

Number

Associated

Emission

Unit

Number

Opacity

Limit

PM10

Limit

(lb/hr)

PM Limit

(lb./ton of

feed)

Dioxin and

Furan Limit

(ng./dscm)

SO2 Limit

(lb./MMBtu)

Construction

Permit No.

EP25 20% 52.8 77-A-221-S2

EP27 EU25 20%(1) 29.7 0.30 0.4 6 77-A-222-S4

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance with

the particulate standard.

Pollutant: Opacity

Emission Limit(s): 20% 

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Kiln/Calciner/

 Preheater-Emission Limits

 567 IAC 23.1(4)"bl"

 40 CFR 63.1343
44 04-TV-011 7/29/004

Pollutant: Particulate Matter

Emission Limit(s): 0.30 lb./ton of feed

Authority for Requirement: Iowa DNR Construction Permits specified in Table Kiln/Calciner/

 Preheater-Emission Limits

 567 IAC 23.1(4)"bl"

 40 CFR 63.1343

Pollutant: PM10

Emission Limit(s): As specified in Table: Kiln-Emission Limits

Authority for Requirement: Iowa DNR Construction Permits specified in Table: Kiln/Calciner/

 Preheater-Emission Limits

Pollutant: Sulfur Dioxide (SO2)

Emission Limit(s): 6 lb./MMBtu

Authority for Requirement: Iowa DNR Construction Permit 77-A-222-S4

 567 IAC 23.3(3)"a"

Pollutant: Dioxins and Furans (D/F)(2)

Emission Limit(s): 0.4 ng./dscm (1.7E-10 gr./dscf ) (TEQ)

Authority for Requirement: Iowa DNR Construction Permit 77-A-222-S4

 567 IAC 23.1(4)"bl"

 40 CFR 63.1343(b)(3)

(2) Limit is corrected to 7% oxygen and when the average of the performance test run average

temperatures at the inlet to the particulate matter control device is 204 oC (400 oF) or less. If the

average of the performance test run average temperatures at the inlet to the particulate matter

control device is greater than 204 oC (400 oF) then the D/F standard is 0.2 ng/dscm (8.7 E-11

gr./dscf)(TEQ) corrected to 7% oxygen.

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

Operating limits:

1. In accordance with Subpart F (Standards of Performance for Portland Cement Plants), the

facility shall record its daily production and kiln feed rates.

2. The throughput shall not exceed 1,850,000 short tons of raw kiln feed per twelve (12) month

rolling period and 925,000 short tons of clinker per twelve (12) month rolling period.

3. The kiln shall be operated such that the temperature of the gas at the inlet to the kiln

particulate matter control device (PMCD) and alkali bypass PMCD, if applicable, meets the

requirements of 40 CFR §63.1344 (Subpart LLL-National Emission Standards for Hazardous

Air Pollutants from the Portland Cement Manufacturing Industry).

4. The facility shall operate the kiln such that the temperature of the gas at the inlet to the alkali

bypass particulate matter control device (PMCD) does not exceed the applicable temperature

per 40 CFR §63.1344.
45 04-TV-011 7/29/004

5. In accordance with 40 CFR §63.1349(c), PM performance tests shall be repeated every 5

years.

6. In accordance with 40 CFR §63.1349(d), D/F performance tests shall be repeated every 30

months.

7. In accordance with 40 CFR §63.1349(e)(1) through (e)(3), PM and/or D/F performance tests

shall be completed within 360 hours after a planned operational change that has been

determined to have the the ability to impact the plants ability to affect compliance with the

applicable PM and/or D/F standards.

8. In accordance with 40 CFR §63.1350(i), the facility shall conduct an inspection of the

components of the combustion system of each kiln or in-line raw mill at least once per year.

Reporting & Record keeping: All records as required by this permit shall be kept on-site for a

minimum of five (5) years and shall be available for inspection by the DNR. Records shall be

legible and maintained in an orderly manner. The records shall show the following:

1. The sulfur content (in lb/MMBTU) of all individual fuels and the total sulfur (in lb/MMBTU)

of any combination of fuels that are fired in the kiln. The fuel analysis sent with the fuel

shipment can be an adequate demonstration for this record.

2. The daily production rates and kiln feed rates.

3. Copies of the excess emissions reports required per NSPS Subpart F and NESHAP Subpart

LLL.

4. After the first twelve (12) months of operation determine the annual raw kiln feed throughput

and clinker production on a rolling-12-month total for each month of operation.

5. Monitoring for NESHAP Subpart LLL at the facility (plant number 17-01-005) shall be done

per 40 CFR §63.1350.

6. Recordkeeping for NESHAP Subpart LLL at the facility (plant number 17-01-005) shall be

done per 40 CFR §63.1355.

Authority for Requirement: Iowa DNR Construction Permit 77-A-222-S4

Emission Point Characteristics

These emission points shall conform to the specifications listed below.

Emission Point EP25

Stack Height (feet): 240

Stack Diameter (feet): 7.0

Stack Exhaust Flow Rate (scfm): 206,000

Stack Temperature (oF): 265

Vertical, Unobstructed Discharge Required: Yes No 

Authority for Requirement: Iowa DNR Construction Permit 77-A-221-S2
46 04-TV-011 7/29/004

Emission Point EP27

Stack Height (feet): 160

Stack Diameter (inches): 84

Stack Exhaust Flow Rate (scfm): 77,000

Stack Temperature (o

F): 320

Vertical, Unobstructed Discharge Required: Yes No 

Authority for Requirement: Iowa DNR Construction Permit 77-A-222-S4

The temperature and flow rate are intended to be representative and characteristic of the design

of the permitted emission point. The Department recognizes that the temperature and flow rate

may vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Stack Testing:

Pollutant – Particulate Matter (PM) (NESHAP)

Stack Test to be Completed by (date) – December 4, 2007(1)

Test Method - 40 CFR 60, Appendix A, Method 5

Authority for Requirement – Iowa DNR Construction Permit 77-A-222-S4

 40 CFR 63.1348

 567 IAC 23.1(4)"bl"

 

Pollutant - Dioxins/Furans (D/F)

 Stack Tests to be Completed by (date) – June 4, 2005 and December 4, 2007(2)

Test Method - 40 CFR 60, Appendix A, Method 23 (3)

Authority for Requirement - Iowa DNR Construction Permit 77-A-222-S4

 40 CFR 63.1349(b)(3)

 567 IAC 23.1(4)"bl"

(1) And every five years thereafter.

(2) And every 30 months thereafter.

(3) Test shall be done in order to meet compliance as outlined in 40 CFR 63.1349.

Continuous Emissions Monitoring:

In accordance with NSPS Subpart F and NESHAP Subpart LLL, the facility (plant number 17-

01-005) shall install, calibrate, maintain, and operate a continuous opacity monitoring system

(COMS) for measuring the opacity of the emissions discharged to the atmosphere and record the

output of the system. The system shall be designed to meet the 40 CFR 60, Appendix B,

Performance Specification 1 (PS1).
47 04-TV-011 7/29/004

In accordance with NESHAP Subpart LLL [40 CFR §63.1350(f)], the facility (plant number 17-

01-005) shall install, calibrate, maintain, and continuously operate a continuous monitor to

record the temperature of the exhaust gases from the alkali bypass at the inlet to or upstream of

the alkali bypass particulate matter control device. Per 40 CFR §63.1350(f), the following shall

be done:

 The recorder response range must include zero and 1.5 times either of the average

temperatures established according to the requirements in 40 CFR §63.1349(b)(3)(iv).

 The reference method must be a National Institute of Standards and Technology calibrated

reference thermocouple-potentiometer system or alternate reference, subject to approval by

the Administrator.

 The three-hour average temperature shall be calculated as the average of 180 successive oneminute average temperatures.

 Periods of time when one-minute averages are not available shall be ignored when

calculating three-hour rolling averages. When one-minute averages become available, the

first one-minute average is added to the previous 179 values to calculate the three-hour

rolling average.

 When the operating status of the raw mill of the in-line kiln/raw mill is changed from off to

on, or from on to off the calculation of the three hour rolling average temperature must begin

anew, without considering the previous recordings.

 The calibration of all thermocouples and other temperature sensors shall be verified at least

once every three months.

Authority for Requirement - Iowa DNR Construction Permit 77-A-222-S4

The owner of this equipment or the owner’s authorized agent shall provide written notice to the

Director, not less than 30 days before a required stack test or performance evaluation of a

continuous emission monitor. Results of the test shall be submitted in writing to the Director in

the form of a comprehensive report within 6 weeks of the completion of the testing. 567 IAC

25.1(7)

Agency Approved Operation & Maintenance Plan Required? Yes No 

Relevant requirements of O & M plan for this equipment: Particulate Matter and Opacity

 see Appendix B.

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 22.108(3)"b"

 567 IAC 23.1(4)"bl"

 40 CFR 63 1350(a)
48 04-TV-011 7/29/004

Emission Point ID Number: EP26

Associated Equipment

Associated Emission Unit ID Numbers: EU26

Emissions Control Equipment ID Number: CE26

Emissions Control Equipment Description: Baghouse

Continuous Emissions Monitor ID Number: ME26

______________________________________________________________________________

Emission Unit vented through this Emission Point: EU26

Emission Unit Description: Clinker Cooler

Raw Material/Fuel: Cement Clinker

Rated Capacity: 250 TPH

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Opacity

Emission Limit(s): 10% (1)

Authority for Requirement: Iowa DNR Construction Permit 77-A-094-S1

 567 IAC 23.1(4)"bl"

 40 CFR 63.1345

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance with

the particulate standard.

Pollutant: Particulate Matter

Emission Limit(s): 0.1 lb./ton

Authority for Requirement: Iowa DNR Construction Permit 77-A-094-S1

 567 IAC 23.1(4)"bl"

 40 CFR 63.1345

Pollutant: PM10

Emission Limit(s): 22.6 lb./hr

Authority for Requirement: Iowa DNR Construction Permit 77-A-094-S1
49 04-TV-011 7/29/004

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

Process throughput:

1. The throughput shall not exceed 1,850,000 short tons of raw kiln feed per twelve (12) month

rolling period and 925,000 short tons of clinker per twelve (12) month rolling period.

Authority for Requirement: Iowa DNR Construction Permit 77-A-094-S1

 Section V(2) Iowa Department of Natural Resources 

 Administrative Consent Order No. 1999-AQ-32

Reporting & Record keeping: All records as required by this permit shall be kept on-site for a

minimum of five (5) years and shall be available for inspection by the DNR. Records shall be

legible and maintained in an orderly manner. The records shall show the following:

1. Copies of the excess emissions reports required per NSPS Subpart F and NESHAP Subpart

LLL.

2. Monitoring for NESHAP Subpart LLL at the facility (plant number 17-01-005) shall be done

per 40 CFR §63.1350.

3. Recordkeeping for NESHAP Subpart LLL at the facility (plant number 17-01-005) shall be

done per 40 CFR §63.1355.

4. After the first twelve (12) months of operation determine the annual raw kiln feed throughput

and clinker production on a rolling-12-month total for each month of operation.

Authority for Requirement: Iowa DNR Construction Permit 77-A-094-S1

Emission Point Characteristics

The emission point shall conform to the specifications listed below.

Stack Height (feet): 85

Stack Diameter (inches): 96

Stack Exhaust Flow Rate (scfm): 107,600

Stack Temperature (o

F): 210

Vertical, Unobstructed Discharge Required: Yes No 

Authority for Requirement: Iowa DNR Construction Permit 77-A-094-S1

The temperature and flow rate are intended to be representative and characteristic of the design

of the permitted emission point. The Department recognizes that the temperature and flow rate

may vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.
50 04-TV-011 7/29/004

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Continuous Emissions Monitoring:

Pollutant - Opacity

Operational Specifications – 40 CFR 63 Subpart A and 40 CFR 60, Appendix B PS-1

Date of Initial System Calibration and Quality Assurance – January 1990

Ongoing System Calibration/Quality Assurance - 40 CFR 63 Subpart A and 40 CFR 60,

 Appendix B PS-1

Reporting & Record keeping - 40 CFR 63 Subpart A and 40 CFR 60, Appendix B PS-1

Authority for Requirement – 567 IAC 23.1(3)"bl"

 40 CFR 63.1350(d)

The owner of this equipment or the owner’s authorized agent shall provide written notice to the

Director, not less than 30 days before a required stack test or performance evaluation of a

continuous emission monitor. Results of the test shall be submitted in writing to the Director in

the form of a comprehensive report within 6 weeks of the completion of the testing. 567 IAC

25.1(7)

 

Agency Approved Operation & Maintenance Plan Required? Yes No 

Relevant requirements of O & M plan for this equipment: Particulate Matter and Opacity

 see Appendix B.

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 22.108(3)"b"

 567 IAC 23.1(4)"bl"

 40 CFR 63 1350(a)
51 04-TV-011 7/29/004

Emission Point ID Number: EP28

Associated Equipment

Associated Emission Unit ID Numbers: EU28, EU29

Emissions Control Equipment ID Number: CE28

Emissions Control Equipment Description: Baghouse

______________________________________________________________________________

Emission Unit vented through this Emission Point: EU28

Emission Unit Description: Kiln Dust Disposal Tank

Raw Material/Fuel: Kiln Dust

Rated Capacity: 8 TPH

Emission Unit vented through this Emission Point: EU29

Emission Unit Description: Kiln Dust Loadout

Raw Material/Fuel: Kiln Dust

Rated Capacity: 8 TPH

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Opacity

Emission Limit(s): 40%(1)

Authority for Requirement: Iowa DNR Construction Permit 77-A-361-S2

 567 IAC 23.3(2)"d"

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance with

the particulate standard.

Pollutant: Particulate Matter

Emission Limits: 0.1 gr./scf

Authority for Requirement: Iowa DNR Construction Permit 77-A-361-S2

 567 IAC 23.3(2)"a"

Pollutant: PM10

Emission Limits: 1.0 lb./hr

Authority for Requirement: Iowa DNR Construction Permit 77-A-361-S2
52 04-TV-011 7/29/004

Emission Point Characteristics

The emission point shall conform to the specifications listed below.

Stack Height (feet): 72

Stack Diameter (inches): 18

Stack Exhaust Flow Rate (scfm): 5,800

Stack Temperature (oF): 70

Vertical, Unobstructed Discharge Required: Yes No 

Authority for Requirement: Iowa DNR Construction Permit 77-A-361-S2

The temperature and flow rate are intended to be representative and characteristic of the design

of the permitted emission point. The Department recognizes that the temperature and flow rate

may vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Facility operation and maintenance plans must be sufficient to yield reliable data from the

relevant time period that are representative of the source’s compliance with the applicable

requirements.

Facility operation and maintenance plans are to be developed by the facility within six(6) months

of the issuance date of this permit and the data pertaining to the plan maintained on site for at

least 5 years. The plan and associated recordkeeping provides documentation of this facility’s

implementation of its obligation to operate according to good air pollution control practice.

Good air pollution control practice is achieved by adoption of quality control standards in the

operation and maintenance procedures for air pollution control that are comparable to industry

quality control standards for the production processes associated with this emission point.

Authority for Requirement: 567 IAC 22.108(3)"b"
53 04-TV-011 7/29/004

Emission Point ID Number: EP55

Associated Equipment

Associated Emission Unit ID Numbers: EU55

Emissions Control Equipment ID Number: CE55

Emissions Control Equipment Description: Baghouse

______________________________________________________________________________

Emission Unit vented through this Emission Point: EU55

Emission Unit Description: Limestone Drilling

Raw Material/Fuel: Limestone

Rated Capacity: 900 TPH

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Opacity

Emission Limit(s): 40%(1)

Authority for Requirement: Iowa DNR Construction Permit 99-A-179-S1

 567 IAC 23.3(2)"d"

(1) Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of

(10%) will require the owner/operator to promptly investigate the emission unit and make

corrections to operations or equipment associated with the exceedence. The permit holder shall

also file an "indicator opacity exceedence report" with the DNR field office and keep records as

required in the policy. If exceedences continue after the corrections, the DNR may require

additional proof to demonstrate compliance (e.g., stack testing).

Pollutant: Particulate Matter

Emission Limits: 0.1 gr./scf

Authority for Requirement: Iowa DNR Construction Permit 99-A-179-S1

 567 IAC 23.3(2)"a"

Pollutant: PM10

Emission Limits: 0.6 lb./hr

Authority for Requirement: Iowa DNR Construction Permit 99-A-179-S1
54 04-TV-011 7/29/004

Emission Point Characteristics

The emission point shall conform to the specifications listed below.

Stack Height (feet): 11.5

Stack Diameter (feet): 0.5 X 0.67

Stack Exhaust Flow Rate (scfm): 3,500

Stack Temperature (oF): Ambient

Discharge Style: Downward

Authority for Requirement: Iowa DNR Construction Permit 99-A-179-S1

The temperature and flow rate are intended to be representative and characteristic of the design

of the permitted emission point. The Department recognizes that the temperature and flow rate

may vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Facility operation and maintenance plans must be sufficient to yield reliable data from the

relevant time period that are representative of the source’s compliance with the applicable

requirements.

Facility operation and maintenance plans are to be developed by the facility within six(6) months

of the issuance date of this permit and the data pertaining to the plan maintained on site for at

least 5 years. The plan and associated recordkeeping provides documentation of this facility’s

implementation of its obligation to operate according to good air pollution control practice.

Good air pollution control practice is achieved by adoption of quality control standards in the

operation and maintenance procedures for air pollution control that are comparable to industry

quality control standards for the production processes associated with this emission point.

Authority for Requirement: 567 IAC 22.108(3)"b"
55 04-TV-011 7/29/004

Emission Point ID Number: EP55A

Associated Equipment

Associated Emission Unit ID Numbers: EU55

______________________________________________________________________________

Emission Unit vented through this Emission Point: EU55A

Emission Unit Description: Quarry Blasting

Raw Material/Fuel: Limestone

Rated Capacity: 900 TPH

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Fugitive Dust

Emission Limit: No person shall allow, cause or permit any materials to be handled, transported

or stored; or a building, its appurtenances or a construction haul road to be used, constructed,

altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance. All

persons shall take reasonable precautions to prevent the discharge of visible emissions of fugitive

dusts beyond the lot line of the property on which the emissions originate.

Authority for Requirement: 567 IAC 23.3(2)"c"

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 22.108(3)"b"
56 04-TV-011 7/29/004

Emission Point ID Number: EP62

Associated Equipment

Associated Emission Unit ID Number: EU62

Emissions Control Equipment ID Number: CE62

Emissions Control Equipment Description: Baghouse

______________________________________________________________________________

Emission Unit vented through this Emission Point: EU62

Emission Unit Description: Coal Mill

Raw Material/Fuel: Coal

Rated Capacity: 8.4 TPH

Applicable Requirements

Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Opacity

Emission Limit(s): 20%(1)

Authority for Requirement: Iowa DNR Construction Permit 87-A-089-S2

 567 IAC 23.1(2)"v"

 40 CFR 60.252(c)

(1) If opacity greater than that observed in the initial performance test (0%) is viewed other than

startup, shutdown, or malfunction, a stack test may be required to demonstrate compliance with

the particulate standard.

Pollutant: Particulate Matter

Emission Limits: 0.1 gr./scf

Authority for Requirement: Iowa DNR Construction Permit 87-A-089-S2

 567 IAC 23.3(2)"a"

Pollutant: PM10

Emission Limits: 0.22 lb./hr

Authority for Requirement: Iowa DNR Construction Permit 87-A-089-S2

Emission Point Characteristics

The emission point shall conform to the specifications listed below.

Stack Height (feet): 50

Stack Diameter (inches): 26

Stack Exhaust Flow Rate (scfm): 800

Stack Temperature (o

F): 150

Vertical, Unobstructed Discharge Required: Yes No 
57 04-TV-011 7/29/004

Authority for Requirement: Iowa DNR Construction Permit 87-A-089-S2

The temperature and flow rate are intended to be representative and characteristic of the design

of the permitted emission point. The Department recognizes that the temperature and flow rate

may vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

listed below.

The facility shall check the opacity weekly during a period when the emission unit on this

emission point is at or near full capacity and record the reading. Maintain a written record of the

observation and any action resulting from the observation for a minimum of five years. Opacity

shall be observed to ensure that no visible emissions occur during the material handling

operation of the unit. If visible emissions are observed corrective action will be taken as soon as

possible, but no later than eight hours from the observation of visible emissions. If corrective

action does not return the observation to no visible emissions, then a Method 9 observation will

be required. If an opacity (>20 %) is observed, this would be a violation and corrective action

will be taken as soon as possible, but no later than eight hours from the observation of visible

emissions. If weather conditions prevent the observer from conducting an opacity observation,

the observer shall note such conditions on the data observation sheet. At least three attempts

shall be made to retake opacity readings at approximately 2-hour intervals throughout the day. If

all observation attempts for a week have been unsuccessful due to weather, an observation shall

be made the next operating day where weather permits.

Agency Approved Operation & Maintenance Plan Required? Yes No 

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Facility operation and maintenance plans must be sufficient to yield reliable data from the

relevant time period that are representative of the source’s compliance with the applicable

requirements.

Facility operation and maintenance plans are to be developed by the facility within six(6) months

of the issuance date of this permit and the data pertaining to the plan maintained on site for at

least 5 years. The plan and associated recordkeeping provides documentation of this facility’s

implementation of its obligation to operate according to good air pollution control practice.

Good air pollution control practice is achieved by adoption of quality control standards in the

operation and maintenance procedures for air pollution control that are comparable to industry

quality control standards for the production processes associated with this emission point.

Authority for Requirement: 567 IAC 22.108(3)"b"
58 04-TV-011 7/29/004

Emission Point ID Number: EP92

Associated Equipment

Associated Emission Unit ID Numbers: EU92

Emissions Control Equipment ID Number: CE92

Emissions Control Equipment Description: Baghouse

______________________________________________________________________________

Emission Unit vented through this Emission Point: EU92

Emission Unit Description: Secondary Fuel Receiving

Raw Material/Fuel: Secondary Fuel

Rated Capacity: 110 TPH

Applicable Requirements

BACT Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Opacity

Emission Limit(s): 5%(1)

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

 567 IAC 23.3(2)"d"

Pollutant: Particulate Matter

Emission Limits: 0.01 gr./dscf

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

Pollutant: PM10

Emission Limits: 0.01 gr./dscf

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

(1) The averaging period for this standard is one (1) hour.

Other Emission Limits (lb./hr, gr./dscf, lb./MMBtu, % opacity, etc.)

The emissions from this emission point shall not exceed the levels specified below.

Pollutant: Opacity

Emission Limit(s): 10%

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

 567 IAC 23.1(4)"bl"

 40 CFR 63.1348

Pollutant: PM10

Emission Limits: 0.34 lb./hr

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P
59 04-TV-011 7/29/004

Operational Limits & Requirements

The owner/operator of this equipment shall comply with the operational limits and requirements

listed below.

The facility is required to schedule a PM10 compliance test within thirty (30) days if it exceeds

the one (1) hour, 5% BACT opacity limit.

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

Reporting & Record keeping:

All records as required by this permit shall be kept on-site for a minimum of five (5) years and

shall be available for inspection by the DNR. Records shall be legible and maintained in an

orderly manner. The records shall show the following:

1. Recordkeeping for NESHAP 40 CFR 63 Subpart LLL at the facility shall be done per 40 CFR

 63.1355.

2. Copies of the excess emissions reports required per NSPS Subpart F and NESHAP Subpart

LLL.

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

Emission Point Characteristics

The emission point shall conform to the specifications listed below.

Stack Height, (ft, from the ground): 36.4

Stack Opening, (inches, dia.): 18

Exhaust Flow Rate (scfm): 4,000

Exhaust Temperature (F): 70

Discharge Style: Obstructed vertical

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

The temperature and flow rate are intended to be representative and characteristic of the design

of the permitted emission point. The Department recognizes that the temperature and flow rate

may vary with changes in the process and ambient conditions. If it is determined that any of the

emission point design characteristics are different than the values stated above, the

owner/operator must notify the Department and obtain a permit amendment, if required.
60 04-TV-011 7/29/004

Periodic Monitoring Requirements

The owner/operator of this equipment shall comply with the periodic monitoring requirements

The facility shall check the opacity as described in 40 CFR 63.1350 ((a)(4)(i-vii) and (e) of

Appendix C-Applicable Limits and Requirements From 40 CFR 63 Subpart LLLMonitoring Requirements.

Authority for Requirement: Iowa DNR Construction Permit 03-A-985-P

 567 IAC 23.1(4)"bl"

 40 CFR 63.1350

Stack Testing:

Pollutant – PM (BACT)

Stack Test to be Completed by (date) – Within 60 days of achieving maximum

 Production rate

Test Method – 40 CFR 51, Iowa Compliance Sampling Method 5

Authority for Requirement - Iowa DNR Construction Permit 03-A-985-P

Pollutant – PM10

Stack Test to be Completed by (date) – Within 60 days of achieving maximum

 Production rate

Test Method – 40 CFR 51, Appendix M, 201A with 202

Authority for Requirement - Iowa DNR Construction Permit 03-A-985-P

Pollutant – Opacity

Stack Test to be Completed by (date) – Within 60 days of achieving maximum

 Production rate

Test Method – 40 CFR 60, Appendix A, Method 9

Authority for Requirement – Iowa DNR Construction Permit 03-A-985-P

 567 IAC 23.1(4)"bl"

 40 CFR 63.1349(b)(2)

Agency Approved Operation & Maintenance Plan Required? Yes No 

Relevant requirements of O & M plan for this equipment: Particulate Matter and Opacity-

 see Appendix B.

Facility Maintained Operation & Maintenance Plan Required? Yes No 

Authority for Requirement: 567 IAC 23.1(4)"bl"

 40 CFR 63.1350(a)
61 04-TV-011 7/29/004

IV. General Conditions

This permit is issued under the authority of the Iowa Code subsection 455B.133(8) and in

accordance with 567 Iowa Administrative Code chapter 22.

G1. Duty to Comply

1. The permittee must comply with all conditions of the Title V permit. Any permit

noncompliance constitutes a violation of the Act and is grounds for enforcement action; for a

permit termination, revocation and reissuance, or modification; or for denial of a permit renewal

application. 567 IAC 22.108(9)"a"

2. Any compliance schedule shall be supplemental to, and shall not sanction noncompliance

with, the applicable requirements on which it is based. 567 IAC 22.105 (2)"h"(3)

3. Where an applicable requirement of the Act is more stringent than an applicable requirement

of regulations promulgated under Title IV of the Act, both provisions shall be enforceable by the

administrator and are incorporated into this permit. 567 IAC 22.108 (1)"b"

4. Unless specified as either "state enforceable only" or "local program enforceable only", all

terms and conditions in the permit, including provisions to limit a source's potential to emit, are

enforceable by the administrator and citizens under the Act. 567 IAC 22.108 (14)

5. It shall not be a defense for a permittee, in an enforcement action, that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. 567 IAC 22.108 (9)"b"

G2. Permit Expiration

1. Except as provided in 567 IAC 22.104, the expiration of this permit terminates the permittee's

right to operate unless a timely and complete application has been submitted for renewal. Any

testing required for renewal shall be completed before the application is submitted. 567 IAC

22.116(2)

2. To be considered timely, the owner, operator, or designated representative (where applicable)

of each source required to obtain a Title V permit shall present or mail the Air Quality Bureau,

Iowa Department of Natural Resources, Air Quality Bureau, 7900 Hickman Rd, Suite #1,

Urbandale, Iowa 50322, two copies (three if your facility is located in Linn or Polk county) of a

complete permit application, at least 6 months but not more than 18 months prior to the date of

permit expiration. An additional copy must also be sent to EPA Region VII, Attention: Chief of

Air Permits, 901 N. 5th St., Kansas City, KS 66101. The application must include all emission

points, emission units, air pollution control equipment, and monitoring devices at the facility.

All emissions generating activities, including fugitive emissions, must be included. The

definition of a complete application is as indicated in 567 IAC 22.105(2). 567 IAC 22.105

G3. Certification Requirement for Title V Related Documents

Any application, report, compliance certification or other document submitted pursuant to this

permit shall contain certification by a responsible official of truth, accuracy, and completeness.

All certifications shall state that, based on information and belief formed after reasonable

inquiry, the statements and information in the document are true, accurate, and complete. 567

IAC 22.107 (4)

G4. Annual Compliance Certification

By March 31 of each year, the permittee shall submit compliance certifications for the previous

calendar year. The certifications shall include descriptions of means to monitor the compliance

status of all emissions sources including emissions limitations, standards, and work practices in

accordance with applicable requirements. The certification for a source shall include the
62 04-TV-011 7/29/004

identification of each term or condition of the permit that is the basis of the certification; the

compliance status; whether compliance was continuous or intermittent; the method(s) used for

determining the compliance status of the source, currently and over the reporting period

consistent with all applicable department rules. For sources determined not to be in compliance

at the time of compliance certification, a compliance schedule shall be submitted which provides

for periodic progress reports, dates for achieving activities, milestones, and an explanation of

why any dates were missed and preventive or corrective measures. The compliance certification

shall be submitted to the administrator, director, and the appropriate DNR Field office. 567 IAC

22.108 (15)"e"

G5. Semi-Annual Monitoring Report

By March 31 and September 30 of each year, the permittee shall submit a report of any

monitoring required under this permit for the 6 month periods of July 1 to December 31 and

January 1 to June 30, respectively. All instances of deviations from permit requirements must be

clearly identified in these reports, and the report must be signed by a responsible official,

consistent with 567 IAC 22.107(4). The semi-annual monitoring report shall be submitted to the

director and the appropriate DNR Field office. 567 IAC 22.108 (5)

G6. Annual Fee

1. The permittee is required under subrule 567 IAC 22.106 to pay an annual fee based on the

total tons of actual emissions of each regulated air pollutant. Beginning July 1, 1996, Title V

operating permit fees will be paid on July 1 of each year. The fee shall be based on emissions for

the previous calendar year.

2. The fee amount shall be calculated based on the first 4,000 tons of each regulated air pollutant

emitted each year. The fee to be charged per ton of pollutant will be available from the

department by June 1 of each year. The Responsible Official will be advised of any change in the

annual fee per ton of pollutant.

3. The following forms shall be submitted annually by March 31 documenting actual emissions

for the previous calendar year.

a. Form 1.0 "Facility Identification";

b. Form 4.0 "Emissions unit-actual operations and emissions" for each emission unit;

c. Form 5.0 "Title V annual emissions summary/fee"; and

d. Part 3 "Application certification."

4. The fee shall be submitted annually by July 1. The fee shall be submitted with the following

forms:

a. Form 1.0 "Facility Identification";

b. Form 5.0 "Title V annual emissions summary/fee";

 c. Part 3 "Application certification."

5. If there are any changes to the emission calculation form, the department shall make revised

forms available to the public by January 1. If revised forms are not available by January 1, forms

from the previous year may be used and the year of emissions documented changed. The

department shall calculate the total statewide Title V emissions for the prior calendar year and

make this information available to the public no later than April 30 of each year.

6. Phase I acid rain affected units under section 404 of the Act shall not be required to pay a fee

for emissions which occur during the years 1993 through 1999 inclusive.

7. The fee for a portable emissions unit or stationary source which operates both in Iowa and out

of state shall be calculated only for emissions from the source while operating in Iowa.
63 04-TV-011 7/29/004

8. Failure to pay the appropriate Title V fee represents cause for revocation of the Title V permit

as indicated in 567 IAC 22.115(1)"d".

G7. Inspection of Premises, Records, Equipment, Methods and Discharges

Upon presentation of proper credentials and any other documents as may be required by law, the

permittee shall allow the director or the director's authorized representative to:

1. Enter upon the permittee's premises where a Title V source is located or emissions-related

activity is conducted, or where records must be kept under the conditions of the permit;

2. Have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

3. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution

control equipment), practices, or operations regulated or required under the permit; and

4. Sample or monitor, at reasonable times, substances or parameters for the purpose of ensuring

compliance with the permit or other applicable requirements. 567 IAC 22.108 (15)"b"

G8. Duty to Provide Information

The permittee shall furnish to the director, within a reasonable time, any information that the

director may request in writing to determine whether cause exists for modifying, revoking and

reissuing, or terminating the permit or to determine compliance with the permit. Upon request,

the permittee also shall furnish to the director copies of records required to be kept by the permit,

or for information claimed to be confidential, the permittee shall furnish such records directly to

the administrator of EPA along with a claim of confidentiality. 567 IAC 22.108 (9)"e"

G9. General Maintenance and Repair Duties

The owner or operator of any air emission source or control equipment shall:

1. Maintain and operate the equipment or control equipment at all times in a manner consistent

with good practice for minimizing emissions.

2. Remedy any cause of excess emissions in an expeditious manner.

3. Minimize the amount and duration of any excess emission to the maximum extent possible

during periods of such emissions. These measures may include but not be limited to the use of

clean fuels, production cutbacks, or the use of alternate process units or, in the case of utilities,

purchase of electrical power until repairs are completed.

4. Schedule, at a minimum, routine maintenance of equipment or control equipment during

periods of process shutdowns to the maximum extent possible. 567 IAC 24.2(1)

G10. Recordkeeping Requirements for Compliance Monitoring

1. In addition to any source specific recordkeeping requirements contained in this permit, the

permittee shall maintain the following compliance monitoring records, where applicable:

a. The date, place and time of sampling or measurements

b. The date the analyses were performed.

c. The company or entity that performed the analyses.

d. The analytical techniques or methods used.

e. The results of such analyses; and

f. The operating conditions as existing at the time of sampling or measurement.

g. The records of quality assurance for continuous compliance monitoring systems (including but

not limited to quality control activities, audits and calibration drifts.)

2. The permittee shall retain records of all required compliance monitoring data and support

information for a period of at least 5 years from the date of compliance monitoring sample,

measurement report or application. Support information includes all calibration and maintenance
64 04-TV-011 7/29/004

records and all original strip chart recordings for continuous compliance monitoring, and copies

of all reports required by the permit.

3. For any source which in its application identified reasonably anticipated alternative operating

scenarios, the permittee shall:

a. Comply with all terms and conditions of this permit specific to each alternative scenario.

b. Maintain a log at the permitted facility of the scenario under which it is operating.

c. Consider the permit shield, if provided in this permit, to extend to all terms and conditions

under each operating scenario. 567 IAC 22.108(4), 567 IAC 22.108(12)

G11. Evidence used in establishing that a violation has or is occurring.

Notwithstanding any other provisions of these rules, any credible evidence may be used for the

purpose of establishing whether a person has violated or is in violation of any provisions herein.

1. Information from the use of the following methods is presumptively credible evidence of

whether a violation has occurred at a source:

a. A monitoring method approved for the source and incorporated in an operating permit

pursuant to 567 Chapter 22;

b. Compliance test methods specified in 567 Chapter 25; or

c. Testing or monitoring methods approved for the source in a construction permit issued

pursuant to 567 Chapter 22.

2. The following testing, monitoring or information gathering methods are presumptively

credible testing, monitoring, or information gathering methods:

a. Any monitoring or testing methods provided in these rules; or

b. Other testing, monitoring, or information gathering methods that produce information

comparable to that produced by any method in subrule 21.5(1) or this subrule. 567 IAC 21.5(1)-

567 IAC 21.5(2)

G12. Prevention of Accidental Release: Risk Management Plan Notification and

Compliance Certification

If the permittee is required to develop and register a risk management plan pursuant to section

112(r) of the Act, the permittee shall notify the department of this requirement. The plan shall be

filed with all appropriate authorities by the deadline specified by EPA. A certification that this

risk management plan is being properly implemented shall be included in the annual compliance

certification of this permit. 567 IAC 22.108(6)

G13. Hazardous Release

The permittee must report any situation involving the actual, imminent, or probable release of a

hazardous substance into the atmosphere which, because of the quantity, strength and toxicity of

the substance, creates an immediate or potential danger to the public health, safety or to the

environment. A verbal report shall be made to the department at (515) 281-8694 and to the local

police department or the office of the sheriff of the affected county as soon as possible but not

later than six hours after the discovery or onset of the condition. This verbal report must be

followed up with a written report as indicated in 567 IAC 131.2(2). 567 IAC Chapter 131-State

Only

G14. Excess Emissions and Excess Emissions Reporting Requirements

1. Excess Emissions. Excess emission during a period of startup, shutdown, or cleaning of

control equipment is not a violation of the emission standard if the startup, shutdown or cleaning

is accomplished expeditiously and in a manner consistent with good practice for minimizing

emissions. Cleaning of control equipment which does not require the shutdown of the process

equipment shall be limited to one six-minute period per one-hour period. An incident of excess
65 04-TV-011 7/29/004

emission (other than an incident during startup, shutdown or cleaning of control equipment) is a

violation. If the owner or operator of a source maintains that the incident of excess emission was

due to a malfunction, the owner or operator must show that the conditions which caused the

incident of excess emission were not preventable by reasonable maintenance and control

measures. Determination of any subsequent enforcement action will be made following review

of this report. If excess emissions are occurring, either the control equipment causing the excess

emission shall be repaired in an expeditious manner or the process generating the emissions shall

be shutdown within a reasonable period of time. An expeditious manner is the time necessary to

determine the cause of the excess emissions and to correct it within a reasonable period of time.

A reasonable period of time is eight hours plus the period of time required to shut down the

process without damaging the process equipment or control equipment. In the case of an electric

utility, a reasonable period of time is eight hours plus the period of time until comparable

generating capacity is available to meet consumer demand with the affected unit out of service,

unless, the director shall, upon investigation, reasonably determine that continued operation

constitutes an unjustifiable environmental hazard and issue an order that such operation is not in

the public interest and require a process shutdown to commence immediately.

2. Excess Emissions Reporting

a. Oral Reporting of Excess Emissions. An incident of excess emission (other than an incident of

excess emission during a period of startup, shutdown, or cleaning) shall be reported to the

appropriate field office of the department within eight hours of, or at the start of the first working

day following the onset of the incident. The reporting exemption for an incident of excess

emission during startup, shutdown or cleaning does not relieve the owner or operator of a source

with continuous monitoring equipment of the obligation of submitting reports required in 567-

subrule 25.1(6). An oral report of excess emission is not required for a source with operational

continuous monitoring equipment (as specified in 567-subrule 25.1(1) ) if the incident of excess

emission continues for less than 30 minutes and does not exceed the applicable visible emission

standard by more than 10 percent opacity. The oral report may be made in person or by

telephone and shall include as a minimum the following:

i. The identity of the equipment or source operation from which the excess emission originated

and the associated stack or emission point.

ii. The estimated quantity of the excess emission.

iii. The time and expected duration of the excess emission.

iv. The cause of the excess emission.

v. The steps being taken to remedy the excess emission.

vi. The steps being taken to limit the excess emission in the interim period.

b. Written Reporting of Excess Emissions. A written report of an incident of excess emission

shall be submitted as a follow-up to all required oral reports to the department within seven days

of the onset of the upset condition, and shall include as a minimum the following:

i. The identity of the equipment or source operation point from which the excess emission

originated and the associated stack or emission point.

ii. The estimated quantity of the excess emission.

iii. The time and duration of the excess emission.

iv. The cause of the excess emission.

v. The steps that were taken to remedy and to prevent the recurrence of the incident of excess

emission.

vi. The steps that were taken to limit the excess emission.
66 04-TV-011 7/29/004

vii. If the owner claims that the excess emission was due to malfunction, documentation to

support this claim. 567 IAC 24.1(1)-567 IAC 24.1(4)

3. Emergency Defense for Excess Emissions. For the purposes of this permit, an “emergency”

means any situation arising from sudden and reasonably unforeseeable events beyond the control

of the source, including acts of God, which requires immediate corrective action to restore

normal operation, and that causes the source to exceed a technology-based emission limitation

under the permit due to unavoidable increases in emissions attributable to the emergency. An

emergency shall not include non-compliance, to the extent caused by improperly designed

equipment, lack of preventive maintenance, careless or improper operation or operator error. An

emergency constitutes an affirmative defense to an action brought for non-compliance with

technology based limitations if it can be demonstrated through properly signed contemporaneous

operating logs or other relevant evidence that:

a. An emergency occurred and that the permittee can identify the cause(s) of the emergency;

b. The facility at the time was being properly operated;

c. During the period of the emergency, the permittee took all reasonable steps to minimize levels

of emissions that exceeded the emissions standards or other requirements of the permit; and

d. The permittee submitted notice of the emergency to the director by certified mail within two

working days of the time when the emissions limitations were exceeded due to the emergency.

This notice must contain a description of the emergency, any steps taken to mitigate emissions,

and corrective actions taken. 567 IAC 22.108(16)

G15. Permit Deviation Reporting Requirements

A deviation is any failure to meet a term, condition or applicable requirement in the permit.

Reporting requirements for deviations that result in a hazardous release or excess emissions have

been indicated above (see G13 and G14). Unless more frequent deviation reporting is specified

in the permit, any other deviation shall be documented in the semi-annual monitoring report and

the annual compliance certification (see G4 and G5). 567 IAC 22.108(5)"b"

G16. Notification Requirements for Sources That Become Subject to NSPS and NESHAP

Regulations

During the term of this permit, the permittee must notify the department of any source that

becomes subject to a standard or other requirement under 567-subrule 23.1(2) (standards of

performance of new stationary sources) or section 111 of the Act; or 567-subrule 23.1(3)

(emissions standards for hazardous air pollutants), 567-subrule 23.1(4) (emission standards for

hazardous air pollutants for source categories) or section 112 of the Act. This notification shall

be submitted in writing to the department pursuant to the notification requirements in 40 CFR

Section 60.7, 40 CFR Section 61.07, and/or 40 CFR Section 63.9. 567 IAC 23.1(2), 567 IAC

23.1(3), 567 IAC 23.1(4)

G17. Requirements for Making Changes to Emission Sources That Do Not Require Title V

Permit Modification

1. Off Permit Changes to a Source. Pursuant to section 502(b)(10) of the CAAA, the permittee

may make changes to this installation/facility without revising this permit if:

a. The changes are not major modifications under any provision of any program required by

section 110 of the Act, modifications under section 111 of the act, modifications under section

112 of the act, or major modifications as defined in 567 IAC Chapter 22.

b. The changes do not exceed the emissions allowable under the permit (whether expressed

therein as a rate of emissions or in terms of total emissions);

c. The changes are not modifications under any provisions of Title I of the Act and the changes
67 04-TV-011 7/29/004

do not exceed the emissions allowable under the permit (whether expressed therein as a rate of

emissions or as total emissions);

d. The changes are not subject to any requirement under Title IV of the Act.

e. The changes comply with all applicable requirements.

f. For such a change, the permitted source provides to the department and the administrator by

certified mail, at least 30 days in advance of the proposed change, a written notification,

including the following, which must be attached to the permit by the source, the department and

the administrator:

i. A brief description of the change within the permitted facility,

ii. The date on which the change will occur,

iii. Any change in emission as a result of that change,

iv. The pollutants emitted subject to the emissions trade

v. If the emissions trading provisions of the state implementation plan are invoked, then Title V

permit requirements with which the source shall comply; a description of how the emissions

increases and decreases will comply with the terms and conditions of the Title V permit.

vi. A description of the trading of emissions increases and decreases for the purpose of

complying with a federally enforceable emissions cap as specified in and in compliance with the

Title V permit; and

vii. Any permit term or condition no longer applicable as a result of the change.

567 IAC 22.110(1)

2. Such changes do not include changes that would violate applicable requirements or

contravene federally enforceable permit terms and conditions that are monitoring (including test

methods), record keeping, reporting, or compliance certification requirements. 567 IAC

22.110(2)

3. Notwithstanding any other part of this rule, the director may, upon review of a notice, require

a stationary source to apply for a Title V permit if the change does not meet the requirements of

subrule 22.110(1). 567 IAC 22.110(3)

4. The permit shield provided in subrule 22.108(18) shall not apply to any change made

pursuant to this rule. Compliance with the permit requirements that the source will meet using

the emissions trade shall be determined according to requirements of the state implementation

plan authorizing the emissions trade. 567 IAC 22.110(4)

5. No permit revision shall be required, under any approved economic incentives, marketable

permits, emissions trading and other similar programs or processes, for changes that are provided

for in this permit. 567 IAC 22.108(11)

G18. Duty to Modify a Title V Permit

1. Administrative Amendment.

a. An administrative permit amendment is a permit revision that is required to do any of the

following:

i. Correct typographical errors

ii. Identify a change in the name, address, or telephone number of any person identified in the

permit, or provides a similar minor administrative change at the source;

iii. Require more frequent monitoring or reporting by the permittee; or

iv. Allow for a change in ownership or operational control of a source where the director

determines that no other change in the permit is necessary, provided that a written agreement

containing a specific date for transfer of permit responsibility, coverage and liability between the

current and new permittee has been submitted to the director.
68 04-TV-011 7/29/004

b. The permittee may implement the changes addressed in the request for an administrative

amendment immediately upon submittal of the request. The request shall be submitted to the

director.

c. Administrative amendments to portions of permits containing provisions pursuant to

Title IV of the Act shall be governed by regulations promulgated by the administrator

under Title IV of the Act.

2. Minor Permit Modification.

a. Minor permit modification procedures may be used only for those permit modifications that do

any of the following:

i. Do not violate any applicable requirements

ii. Do not involve significant changes to existing monitoring, reporting or recordkeeping

requirements in the Title V permit.

iii. Do not require or change a case by case determination of an emission limitation or other

standard, or increment analysis.

iv. Do not seek to establish or change a permit term or condition for which there is no

corresponding underlying applicable requirement and that the source has assumed in order to

avoid an applicable requirement to which the source would otherwise be subject. Such terms and

conditions include any federally enforceable emissions caps which the source would assume to

avoid classification as a modification under any provision under Title I of the Act; and an

alternative emissions limit approved pursuant to regulations promulgated under section 112(i)(5)

of the Act.;

v. Are not modifications under any provision of Title I of the Act; and

vi. Are not required to be processed as significant modification.

b. An application for minor permit revision shall be on the minor Title V modification

application form and shall include at least the following:

i. A description of the change, the emissions resulting from the change, and any new applicable

requirements that will apply if the change occurs.

ii. The permittee's suggested draft permit

iii. Certification by a responsible official, pursuant to 567 IAC 22.107(4), that the proposed

modification meets the criteria for use of a minor permit modification procedures and a request

that such procedures be used; and

iv. Completed forms to enable the department to notify the administrator and the affected states

as required by 567 IAC 22.107(7).

c. The permittee may make the change proposed in its minor permit modifi cation application

immediately after it files the application. After the permittee makes this change and until the

director takes any of the actions specified in 567 IAC 22.112(4) "a" to "c", the permittee must

comply with both the applicable requirements governing the change and the proposed permit

terms and conditions. During this time, the permittee need not comply with the existing permit

terms and conditions it seeks to modify. However, if the permittee fails to comply with its

proposed permit terms and conditions during this time period, existing permit term terms and

conditions it seeks to modify may subject the facility to enforcement action.

3. Significant Permit Modification. Significant Title V modification procedures shall be used for

applications requesting Title V permit modifications that do not qualify as minor Title V

modifications or as administrative amendments. These include but are not limited to all

significant changes in monitoring permit terms, every relaxation of reporting or recordkeeping
69 04-TV-011 7/29/004

permit terms, and any change in the method of measuring compliance with existing

requirements. Significant Title V modifications shall meet all requirements of 567 IAC Chapter

22, including those for applications, public participation, review by affected states, and review

by the administrator, and those requirements that apply to Title V issuance and renewal. 567 IAC

22.111-567 IAC 22.113 The permittee shall submit an application for a significant permit

modification not later than three months after commencing operation of the changed source

unless the existing Title V permit would prohibit such construction or change in operation, in

which event the operation of the changed source may not commence until the department revises

the permit. 567 IAC 22.105(1)"a"(4)

G19. Duty to Obtain Construction Permits

Unless exempted under 567 IAC 22.1(2), the permittee must not construct, install, reconstruct, or

alter any equipment, control equipment or anaerobic lagoon without first obtaining a

construction permit, conditional permit, or permit pursuant to 567 IAC 22.8, or permits required

pursuant to 567 IAC 22.4 and 567 IAC 22.5. Such permits shall be obtained prior to the initiation

of construction, installation or alteration of any portion of the stationary source. 567 IAC 22.1(1)

G20. Asbestos

The permittee shall comply with 567 IAC 23.1(3)"a", and 567 IAC 23.2(3)"g" when conducting

any renovation or demolition activities at the facility. 567 IAC 23.1(3)"a", and 567 IAC 23.2

G21. Open Burning

The permittee is prohibited from conducting open burning, except as may be allowed by 567

IAC 23.2. 567 IAC 23.2 except 23.2(3)"h"; 567 IAC 23.2(3)"h" - State Only

G22. Acid Rain (Title IV) Emissions Allowances

The permittee shall not exceed any allowances that it holds under Title IV of the Act or the

regulations promulgated there under. Annual emissions of sulfur dioxide in excess of the number

of allowances to emit sulfur dioxide held by the owners and operators of the unit or the

designated representative of the owners and operators is prohibited. Exceedences of applicable

emission rates are prohibited. “Held” in this context refers to both those allowances assigned to

the owners and operators by USEPA, and those allowances supplementally acquired by the

owners and operators. The use of any allowance prior to the year for which it was allocated is

prohibited. Contravention of any other provision of the permit is prohibited. 567 IAC 22.108(7)

G23. Stratospheric Ozone and Climate Protection (Title VI) Requirements

1. The permittee shall comply with the standards for labeling of products using ozone-depleting

substances pursuant to 40 CFR Part 82, Subpart E:

a. All containers in which a class I or class II substance is stored or transported, all products

containing a class I substance, and all products directly manufactured with a class I substance

must bear the required warning statement if it is being introduced into interstate commerce

pursuant to § 82.106.

b. The placement of the required warning statement must comply with the requirements pursuant

to § 82.108.

c. The form of the label bearing the required warning statement must comply with the

requirements pursuant to § 82.110.

d. No person may modify, remove, or interfere with the required warning statement except as

described in § 82.112.

2. The permittee shall comply with the standards for recycling and emissions reduction pursuant

to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:
70 04-TV-011 7/29/004

a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices pursuant to § 82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158.

c. Persons performing maintenance, service, repair, or disposal of appliances must be certified by

an approved technician certification program pursuant to § 82.161.

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with reporting and recordkeeping requirements pursuant to § 82.166. ("MVAC-like appliance" as

defined at § 82.152)

e. Persons owning commercial or industrial process refrigeration equipment must comply with

the leak repair requirements pursuant to § 82.156.

f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must

keep records of refrigerant purchased and added to such appliances pursuant to § 82.166.

3. If the permittee manufactures, transforms, imports, or exports a class I or class II substance,

the permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A,

Production and Consumption Controls.

4. If the permittee performs a service on motor (fleet) vehicles when this service involves ozonedepleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in

40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor

vehicle" as used in Subpart B does not include a vehicle in which final assembly of the vehicle

has not been completed. The term "MVAC" as used in Subpart B does not include the air-tight

sealed refrigeration system used as refrigerated cargo, or system used on passenger buses using

HCFC-22 refrigerant,

5. The permittee shall be allowed to switch from any ozone-depleting substance to any

alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated

pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program. 40 CFR

part 82

G24. Permit Reopenings

1. This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The

filing of a request by the permittee for a permit modification, revocation and reissuance, or

termination, or of a notification of planned changes or anticipated noncompliance does not stay

any permit condition. 567 IAC 22.108(9)"c"

2. Additional applicable requirements under the Act become applicable to a major part 70 source

with a remaining permit term of 3 or more years. Revisions shall be made as expeditiously as

practicable, but not later than 18 months after the promulgation of such standards and

regulations.

a. Reopening and revision on this ground is not required if the permit has a remaining term of

less than three years;

b. Reopening and revision on this ground is not required if the effective date of the requirement

is later than the date on which the permit is due to expire, unless the original permit or any of its

terms and conditions have been extended pursuant to 40 CFR 70.4(b)(10)(i) or (ii) as amended to

June 25, 1993.

c. Reopening and revision on this ground is not required if the additional applicable requirements

are implemented in a general permit that is applicable to the source and the source receives

approval for coverage under that general permit. 567 IAC 22.108(17)"a", 567 IAC 22.108(17)"b"
71 04-TV-011 7/29/004

3. A permit shall be reopened and revised under any of the following circumstances:

a. The department receives notice that the administrator has granted a petition for disapproval of

a permit pursuant to 40 CFR 70.8(d) as amended to June 25, 1993, provided that the reopening

may be stayed pending judicial review of that determination;

b. The department or the administrator determines that the Title V permit contains a material

mistake or that inaccurate statements were made in establishing the emissions standards or other

terms or conditions of the Title V permit;

c. Additional applicable requirements under the Act become applicable to a Title V source,

provided that the reopening on this ground is not required if the permit has a remaining term of

less than three years, the effective date of the requirement is later than the date on which the

permit is due to expire, or the additional applicable requirements are implemented in a general

permit that is applicable to the source and the source receives approval for coverage under that

general permit. Such a reopening shall be complete not later than 18 months after promulgation

of the applicable requirement.

d. Additional requirements, including excess emissions requirements, become applicable to a

Title IV affected source under the acid rain program. Upon approval by the administrator, excess

emissions offset plans shall be deemed to be incorporated into the permit.

e. The department or the administrator determines that the permit must be revised or revoked to

ensure compliance by the source with the applicable requirements. 567 IAC 22.114(1)

4. Proceedings to reopen and reissue a Title V permit shall follow the procedures applicable to

initial permit issuance and shall effect only those parts of the permit for which cause to reopen

exists. 567 IAC 22.114(2)

G25. Permit Shield

1. The director may expressly include in a Title V permit a provision stating that compliance

with the conditions of the permit shall be deemed compliance with any applicable requirements

as of the date of permit issuance, provided that:

a. Such applicable requirements are included and are specifically identified in the permit;

or

b. The director, in acting on the permit application or revision, determines in writing that other

requirements specifically identified are not applicable to the source, and the permit includes the

determination or a concise summary thereof.

2. A Title V permit that does not expressly state that a permit shield exists shall be presumed not

to provide such a shield.

3. A permit shield shall not alter or affect the following:

a. The provisions of Section 303 of the Act (emergency orders), including the authority of the

administrator under that section;

b. The liability of an owner or operator of a source for any violation of applicable requirements

prior to or at the time of permit issuance;

c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the

Act;

d. The ability of the department or the administrator to obtain information from the facility

pursuant to Section 114 of the Act. 567 IAC 22.108 (18)

G26. Severability

The provisions of this permit are severable and if any provision or application of any provision is

found to be invalid by this department or a court of law, the application of such provision to
72 04-TV-011 7/29/004

other circumstances, and the remainder of this permit, shall not be affected by such finding. 567

IAC 22.108 (8)

G27. Property Rights

The permit does not convey any property rights of any sort, or any exclusive privilege. 567 IAC

22.108 (9)"d"

G28. Transferability

This permit is not transferable from one source to another. If title to the facility or any part of it

is transferred, an administrative amendment to the permit must be sought to determine

transferability of the permit. 567 IAC 22.111 (1)"d"

G29. Disclaimer

No review has been undertaken on the engineering aspects of the equipment or control

equipment other than the potential of that equipment for reducing air contaminant emissions.

567 IAC 22.3(3)"c"

G30. Notification and Reporting Requirements for Stack Tests or Monitor Certification

The permittee shall notify the department's stack test contact in writing not less than 30 days

before a required test or performance evaluation of a continuous emission monitor is performed

to determine compliance with an applicable requirement. For the department to consider test

results a valid demonstration of compliance with applicable rules or a permit condition, such

notice shall be given. Such notice shall include the time, the place, the name of the person who

will conduct the test and other information as required by the department. Unless specifically

waived by the department's stack test contact, a pretest meeting shall be held not later than 15

days prior to conducting the compliance demonstration. The department may accept a testing

protocol in lieu of a pretest meeting. A representative of the department shall be permitted to

witness the tests. Results of the tests shall be submitted in writing to the department's stack test

contact in the form of a comprehensive report within six weeks of the completion of the testing.

Compliance tests conducted pursuant to this permit shall be conducted with the source operating

in a normal manner at its maximum continuous output as rated by the equipment manufacturer,

or the rate specified by the owner as the maximum production rate at which the source shall be

operated. In cases where compliance is to be demonstrated at less than the maximum continuous

output as rated by the equipment manufacturer, and it is the owner's intent to limit the capacity to

that rating, the owner may submit evidence to the department that the source has been physically

altered so that capacity cannot be exceeded, or the department may require additional testing,

continuous monitoring, reports of operating levels, or any other information deemed necessary

by the department to determine whether such source is in compliance.

Stack test notifications, reports and correspondence shall be sent to:

Stack Test Review Coordinator

Iowa DNR, Air Quality Bureau

7900 Hickman Road, Suite #1

Urbandale, IA 50322

(515) 242-6001

Within Polk and Linn Counties, stack test notifications, reports and correspondence shall also be

directed to the supervisor of the respective county air pollution program.

567 IAC 25.1(7)"a", 567 IAC 25.1(9)

G31. Prevention of Air Pollution Emergency Episodes

The permittee shall comply with the provisions of 567 IAC Chapter 26 in the prevention of

excessive build-up of air contaminants during air pollution episodes, thereby preventing the
73 04-TV-011 7/29/004

occurrence of an emergency due to the effects of these contaminants on the health of persons.

567 IAC 26.1(1)

G32. Contacts List

The current address and phone number for reports and notifications to the EPA administrator is:

Chief of Air Permits

EPA Region 7

Air Permits and Compliance Branch

901 N. 5th Street

Kansas City, KS 66101

(913) 551-7020

The current address and phone number for reports and notifications to the department or the

Director is:

Chief, Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite #1

Urbandale, IA 50322

(515) 242-5100

Reports or notifications to the DNR Field Offices or local programs shall be directed to the

supervisor at the appropriate field office or local program. Current addresses and phone numbers

are:

Field Office 1

909 West Main – Suite 4

Manchester, IA 52057

(563) 927-2640

Field Office 2

P.O. Box 1443

2300-15th St., SW

Mason City, IA 50401

(641) 424-4073

Field Office 3

1900 N. Grand Ave.

Spencer, IA 51301

(712) 262-4177

Field Office 4

1401 Sunnyside Lane

Atlantic, IA 50022

(712) 243-1934

Field Office 5

401 SW 7th Street, Suite I

Des Moines, IA 50309

(515) 725-0268

Field Office 6

1023 West Madison Street

Washington, IA 52353-1623

(319) 653-2135

Polk County Planning & Development

Air Quality Division

5885 NE 14th St.

Des Moines, IA 50313

(515) 286-3351

Linn County Public Health Dept.

Air Pollution Control Division

501 13th St., NW

Cedar Rapids, IA 52405

(319) 892-6000
74

Appendix A: Administrative Consent Order No. 1999-AQ-32
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

75

IN THE MATTER OF:

LEHIGH PORTLAND

CEMENT COMPANY

ADMINISTRATIVE CONSENT ORDER

NO. 1999-AQ-32

TO: LEHIGH PORTLAND CEMENT COMPANY

Verne Stuessy

Acting Plant Manager

700 25th Street N.W.

Mason City, Iowa 50401

LEHIGH PORTLAND CEMENT COMPANY

c/o CT Corporation System, Registered Agent

2222 Grand Avenue

Des Moines, Iowa 50312

I. SUMMARY

This Administrative Consent Order is entered into between the Iowa Department

of Natural Resources (DNR) and Lehigh Portland Cement Company (Lehigh) for the

purpose of addressing alleged monitored violations of the National Ambient Air Quality

Standards (NAAQS) for particulate matter with an aerodynamic diameter less than or

equal to 10 microns (PM-10) in Mason City, Iowa. This Administrative Consent Order

supersedes Administrative Order 97-AQ-18, which is hereby withdrawn.

The parties designate the following representatives for purposes of communications

regarding and notices required by this Administrative Consent Order:

FOR Iowa DNR: FOR Lehigh Portland Cement

Company:

Doug Campbell Verne Stuessy, Acting Plant Manager

Iowa Department of Natural Resources Lehigh Portland Cement Company

7900 Hickman Road, Suite 1 700 – 25th Street N.W.

Des Moines, Iowa 50322 Mason City, Iowa 50401

Ph: 515/281-8930

FAX: 515/242-5094

Ph: 515/421-3400

FAX: 515/421-3404

Either party may change its designated representative at any time by providing written

notice to the other party.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

76

II. NO ADMISSION

While Lehigh agrees to comply with the requirements contained herein, it

makes no admission as to the Statement of Facts and Conclusions of Law and hereby

denies the same.

III. STATEMENT OF FACTS

DNR finds as follows:

1. The 24-hour average PM-10 NAAQS is 150 micrograms per cubic meter

(ug/m3). DNR monitored six exceedances of this standard at a DNR monitoring site

located at the intersection of 17th and Quincy in Mason City, Iowa. On May 10, May 12,

and December 29, 1993, this monitoring site recorded 24-hour average PM-10

concentrations of 174, 172, and 178 ug/m3

, respectively. On February 22, 1994, the same

monitoring site recorded a 24-hour average PM-10 concentration of 160 ug/m3

. On

December 18, 1995, and March 5, 1996, the same monitoring site recorded 24-hour

average PM-10 concentrations of 239 and 286 ug/m3

, respectively.

2. Lehigh is a cement manufacturer located at 700 25th Street N.W. in Mason

City, Iowa, which is northwest of the 17th and Quincy PM-10 monitoring site. Air

dispersion modeling of this Lehigh facility has been conducted. This modeling has

established that Lehigh is a contributor to the PM-10 levels monitored.

3. Lehigh is not the sole contributor of PM-10 levels in Mason City and other

contributors also are being asked to address this concern as well.

4. DNR and Lehigh and other contributors have cooperated in an effort to

address the levels of PM-10 in Mason City. For that purpose, DNR and Lehigh have

agreed to enter into this Administrative Consent Order.

IV. CONCLUSIONS OF LAW

DNR concludes as follows:

1. This Administrative Consent Order is issued pursuant to the provisions of

Iowa Code sections 455B.134(9) and 455B.138(1), which authorize the Director to issue

any administrative orders necessary to secure compliance with or prevent a violation of

Iowa Code chapter 455B, Division II, and the rules promulgated and permits issued

pursuant thereto, and to prevent, abate, and control air pollution.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

77

2. The PM-10 emission sources located at Lehigh in Mason City, Iowa,

include “air contaminant sources” as defined by Iowa Code section 455B.131(2), and

“stationary sources” and “fugitive dust” sources as defined by 567 Iowa Administrative

Code (I.A.C.) 20.2.

3. According to 567 I.A.C. 28.1, the ambient air quality standards for the

State of Iowa shall be the National Primary and Secondary Ambient Air Quality

Standards located at 40 C.F.R. Part 50, as amended through July 18, 1997.

4. According to the provisions of 40 C.F.R. 50.6(a), the primary and

secondary 24-hour ambient air quality standard for PM-10 is 150 ug/m3

, 24-hour average

concentration. The standards are attained when the expected number of days per calendar

year with a 24-hour average concentration above 150 ug/m3

, as determined in accordance

with 40 C.F.R. Part 50, Appendix K, is equal to or less than one. In this case, the

observed number of days per calendar year with a 24-hour average concentration above

150 ug/m3, during the period 1993 through 1995, is greater than one, which constitutes a

violation of this standard.

5. An exceedance of the NAAQS for PM-10 constitutes “air pollution” as

defined by Iowa Code section 455B.131(3).

6. In accordance with the provisions of Iowa Code section 455B.134(9), the

Director shall issue orders consistent with the rules to cause the abatement or control of

air pollution.

7. According to the provisions of 567 I.A.C. 22.1(1) and 567 I.A.C. 22.1(3),

the owner or operator of a stationary source shall obtain a permit to install or alter

equipment or control equipment unless otherwise exempt. Any modifications occurring

as a result of this consent order and subject to the provisions of 567 I.A.C. chapter 22

shall require a construction permit or shall meet the requirements of a construction permit

exemption contained in the provisions of 567 I.A.C. 22.1(2).

8. According to the provisions of 567 I.A.C. 23.3(2)”c”(1), no person shall

allow, cause or permit any materials to be handled, transported or stored; or a building, its

appurtenances or a construction haul road to be used, constructed, altered, repaired or

demolished, with the exception of farming operations or dust generated by ordinary travel

on unpaved public roads, without taking reasonable precautions to prevent particulate

matter in quantities sufficient to create a nuisance, as defined in Iowa Code section 657.1,

from becoming airborne. All persons, with the above exceptions, shall take reasonable

precautions to prevent the discharge of visible emissions of fugitive dusts beyond the lot

line of the property on which the emissions originate. “Reasonable precautions” are

defined in this rule.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

78

V. ORDER

THEREFORE, DNR orders and LEHIGH AGREES to the following:

1. Within 120 days of the effective date of this Administrative Consent

Order, a continuous fenceline with controlled access gates or a physical barrier,

specifically a vertical wall and/or embankment under a railroad trestle, shall be erected to

enclose the plant area as depicted in Exhibit “A”, which is attached to this Administrative

Consent Order and by this reference made a part hereof. The fenceline shall be of a type

designed to preclude public access to the facility property. As proposed by Lehigh, the

portion of 25th Street that lies within the Lehigh facility property lines shall be vacated

and included within the confines of the continuous fenceline and physical barrier, such

that the general public is not allowed access.

2. Within 90 days of entering into this Administrative Consent Order, Lehigh

shall submit to DNR air quality construction permit applications which include the

emission rates, hours of operation, throughput rates, stack parameters, and stack

configurations listed in Exhibit “B.” By this reference, Exhibit “B” is made a part hereof.

Any required modifications to the sources shall be completed within 60 days of the

issuance of the permits (unless specifically stated otherwise in this order).

3. The emission sources listed in Exhibit “C” shall be limited to the daily and

calendar year throughputs listed in Exhibit “C.” By this reference, Exhibit “C” is made a

part hereof. The total daily throughput and daily throughput rates for each of the sources

listed in Exhibit “C” shall be entered in a daily log to demonstrate compliance with the

daily and annual throughput limits. For sources 7A, 56A, 57A, 73A, 74A, and 75A, if

the sources operate within the maximum hourly throughput time period indicated in

Exhibit “C”, then the source daily log shall be used to demonstrate compliance. If these

sources operate at other times during any day, then compliance will be demonstrated for

that calendar day by entering the hourly throughput and total daily throughput rates for

each of these sources in daily logs to demonstrate compliance with the daily and annual

throughput limits. Daily logs shall be retained for a period of two years following the

date of such entries and shall be made available to the DNR upon request. Record

keeping shall commence within 30 days of the effective date of this Administrative

Consent Order.

4. The coal crusher (source ID 40) shall be operated only in an enclosed

structure with all access doors and any other openings closed during normal operations,

except for doors during ingress and egress.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

79

5. Storage Piles:

(i). Within 60 days of the effective date of this Administrative Consent Order, Lehigh

shall locate the storage pile bases as designated in Exhibit “D” and shall limit the size of

the storage piles to no greater than the acreages designated in Exhibit “D.” Except as

otherwise provided in this paragraph 5, the storage piles designated in Exhibit “D” shall

be the only storage piles located within the facility. Exhibit “D” shall by this reference

become a part hereof. Lehigh may relocate a pile specified in Exhibit “D” only after

providing written notice to DNR and submitting the results of computer dispersion

modeling showing that no exceedances of the PM-10 NAAQS would result. If an

exceedance of the PM-10 NAAQS would result based on the computer dispersion

modeling results, Lehigh shall not move the pile as proposed and the pile shall remain at

the location designated in Exhibit “D”.

(ii). Notwithstanding the requirements of paragraph 5(i), Lehigh may operate

temporary piles of materials (not identified on Exhibit “D”) that result from maintenance

and other similar activities. No such temporary pile shall be maintained for more than

one 72-hr period.

(iii). Notwithstanding the requirements of paragraph 5(i) and 5(ii), Lehigh may maintain

temporary piles of overflow raw materials and product (not identified on Exhibit “D”)

that may result from unforeseen and unplanned operating conditions or problems. Lehigh

shall take all reasonable measures to limit the size of any such pile and the fugitive

emissions that result therefrom. No more than two such temporary piles may exist at one

time. No such temporary pile shall be maintained for more than one (1) month. Lehigh

shall maintain records that include the pile location, planned or actual pile size, pile

material content, and the planned removal date, for each pile. The records shall be

retained for a period of two years following the date of the above entries and shall be

made available to the DNR upon request. This record keeping shall be an on-going

requirement and shall not terminate. Record keeping shall commence within 30 days of

the effective date of this Administrative Consent Order.

6. Within 30 days of the effective date of this Administrative Consent Order,

Lehigh shall implement speed controls designed to ensure that the average speed of the

haul trucks on the limestone and clay haul roads (source IDs 56 and 57) does not exceed

18.5 miles per hour. The speed controls shall consist of a combination of speed limit

signs, stop signs, and governors on the accelerators of each haul road truck, or other

methods approved in writing by DNR.

7. The maximum number of round trips per day and per calendar year on the

limestone haul road (source ID 56) for all of the haul trucks, combined, shall be limited to

70 and 17,640 trips, respectively. The number of round trips per day on the limestone

haul road shall be entered in a daily log to demonstrate compliance with this requirement.

Daily logs shall be retained for a period of two years following the date of such entries

and shall be made available to the DNR upon request. Record keeping shall commence

within 30 days of the effective date of this Administrative Consent Order.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

80

8. Fugitive emissions from the limestone haul road (source ID 56) shall be

controlled by applying a chemical dust suppressant. Applications of the selected

chemical dust suppressant and the record keeping requirements described below shall

begin within 30 days of the effective date of this Administrative Consent Order. A

control efficiency of 90 percent shall be maintained on the first 1.41 miles of the

limestone haul road from the quarry. This will require a ground inventory of 0.25 gallons

of chemical dust suppressant per square yard. This section of the limestone haul road is

30 feet wide and 1.41 miles long, giving it a total area of 24,816 square yards. At least

6,204 gallons of the selected chemical dust suppressant shall be applied initially to

achieve this ground level inventory. At least 1,241 gallons of the selected chemical dust

suppressant shall be applied every calendar month with no more than 35 days between

applications, to maintain the ground inventory. This equates to 0.05 gallons of chemical

dust suppressant per square yard. In the event that the manufacturer or distributor of a

chemical dust suppressant recommends that amounts other than those specified above be

applied, Lehigh shall notify DNR in writing of the change in application rates and the

manufacturer’s/distributor’s recommendations.

A control efficiency of 95 percent shall be maintained on the remaining length of the

limestone haul road from 1.41 miles from the quarry to the primary limestone crusher

(source ID 2). This will require a ground inventory of 0.25 gallons of chemical dust

suppressant per square yard. The remaining limestone haul road is 30 feet wide and 2.89

miles long, giving it a total area of 50,864 square yards. At least 12,716 gallons of the

selected chemical dust suppressant shall be applied initially to achieve this ground level

inventory. At least 2,543 gallons of the selected chemical dust suppressant shall be

applied not less than at least once every other week to maintain the ground inventory.

This equates to 0.05 gallons of chemical dust suppressant per square yard.

If the selected chemical dust suppressant can not be applied because the ambient air

temperature (as measured at the facility during daylight operating hours) will be less than

350

 F (1.70 C) or conditions due to weather, in combination with the application of the

chemical dust suppressant, could create hazardous driving conditions, then the chemical

dust suppressant application shall be postponed and applied as soon after the scheduled

application date as the conditions preventing the application have abated. Records of the

applications shall be maintained and shall include the dates of each application, the

chemical used, the application intensity (gals. / sq.yd.), dilution ratio, the areas treated,

the operator’s initials, and documentation of road and weather conditions, if necessary. If

the selected chemical dust suppressant is not applied as planned, then the records should

so indicate and provide an explanation. The records shall be retained for a period of two

years following the date of the above entries and shall be made available to the DNR

upon request.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

81

9. The maximum number of round trips per day and per calendar year on the clay

haul road (source ID 57) for all of the haul trucks, combined, shall be limited to 130 and

1,667 trips, respectively. The number of round trips per day on the clay haul road shall

be entered in a daily log to demonstrate compliance with this requirement. Daily logs

shall be retained for a period of two years following the date of such entries and shall be

made available to the DNR upon request. Record keeping shall commence within 30

days of the effective date of this Administrative Consent Order.

10. Fugitive emissions from the clay haul road (source ID 57) shall be

controlled to an effective control efficiency of 95 percent by applying a chemical dust

suppressant. Applications of the selected chemical dust suppressant and the record

keeping requirements described below shall begin within 30 days of the effective date of

this Administrative Consent Order. A control efficiency of 95 percent will require a

ground inventory of 0.25 gallons of the selected chemical dust suppressant per square

yard. The clay haul road is 30 feet wide and 0.9 miles long, giving it a total area of

15,840 square yards. At least 3,960 gallons of the selected chemical dust suppressant

shall be applied initially to achieve this ground level inventory. At least 792 gallons of

the selected chemical dust suppressant shall be applied not less than once every other

week to maintain the ground inventory. This equates to 0.05 gallons of the selected

emulsion per square yard. In the event that the manufacturer or distributor of a chemical

dust suppressant recommends that amounts other than those specified above be applied,

Lehigh shall notify DNR in writing of the change in application rates and the

manufacturer’s/distributor’s recommendations.

If the selected chemical dust suppressant can not be applied because the ambient air

temperature (as measured at the facility during daylight operating hours) will be less than

350

 F (1.70 C) or conditions due to weather, in combination with the application of the

chemical dust suppressant, could create hazardous driving conditions, then the chemical

dust suppressant application shall be postponed and applied as soon after the scheduled

application date as the conditions preventing the application have abated. Records of the

applications shall be maintained and shall include the dates of each application, the

chemical used, the application intensity (gals. / sq.yd.), dilution ratio, the areas treated,

the operator’s initials, and documentation of road and weather conditions, if necessary. If

the selected chemical dust suppressant is not applied as planned, then the records should

so indicate and provide an explanation. The records shall be retained for a period of two

years following the date of the above entries and shall be made available to the DNR

upon request.

It is not uncommon for this clay haul road to go unused for periods greater than one-half

month. In the event Lehigh does not use the clay haul road for a period greater than onehalf month, Lehigh shall not be required to apply the chemical dust suppressant as

provided in the above paragraph, on the condition that such event is noted and explained

in the records required herein and that, prior to use, an application will be made, weather

permitting and requiring.
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

82

11. The maximum number of round trips per day and per calendar year on the paved

haul road from the product loadout silos to US Highway 65 (source IDs 801-812) for all

haul trucks, combined, shall be limited to the values listed below.

Month Maximum Number of Trips per Day

January 80

February 69

March 200

April 250

May 250

June 250

July 203

August 250

September 250

October 250

November 250

December 250

Calendar Year Maximum Number of Trips per Year

January through December 37,302

The number of round trips per day on this haul road shall be entered into a monthly log to

demonstrate compliance with this requirement. Monthly logs shall be retained for a

period of two years following the date of such entries and shall be made available to the

DNR upon request. Record keeping shall commence within 30 days of the effective date

of this Administrative Consent Order.

12. Fugitive emissions of the paved haul road from the product loadout silos

to US Highway 65 (source IDs 801-812) shall be controlled to an effective control

efficiency of 80 percent by water flushing followed by sweeping. Water flushing

followed by sweeping applications and the record keeping requirements described below

shall begin within 30 days of the effective date of this Administrative Consent Order.

Using an application rate of 0.48 gallons per square yard, this haul road shall require a

water flushing followed by sweeping application after every 362 vehicle passes to

maintain an 80 percent control efficiency. Based on a worse-case round trip estimate of

222 trips per day, the water flushing followed by sweeping will have to be accomplished

every two days. The haul road is 24 feet wide and 2072 feet long, giving it a total area of

5,525 square yards. Based on an application rate of 0.48 gallons of water per square

yard, 2,652 gallons of water will be required for each application.

If water flushing followed by sweeping can not be accomplished because the ambient air

temperature (as measured at the facility during daylight operating hours) will be less than

350

 F (1.70 C) or conditions due to weather, in combination with the application of the

water, could create hazardous driving conditions, then the water flushing and sweeping
IOWA DEPARTMENT OF NATURAL RESOURCES

Administrative Consent Order

ISSUED TO: Lehigh Portland Cement Company

83

shall be postponed and accomplished as soon after the scheduled date as the conditions

preventing the application have abated. Additionally, water flushing and sweeping need

not occur when a rain gauge located at the site indicates that at least 0.2 inches of

precipitation (water equivalent) has occurred within the preceding 24-hr time period.

Records of the applications shall be maintained and shall include the dates and times of

each application, the calculated application intensity, the areas treated, the operator’s

initials, and documentation road and weather conditions, if necessary. If the water

flushing is not accomplished because ambient air temperatures are less than 350

 F during

the entire day, or precipitation exceeding 0.2 inches has occurred in the proceeding 24

hours, then the records should indicate this. The records shall be retained for a period of

two years following the date of the above entries and shall be made available to the DNR

upon request.

13. Lehigh shall submit to the DNR Field Office #2 written quarterly reports

detailing progress toward the completion of the requirements of Sections V.1., V.2.,

V.5., and V.6. of this Administrative Consent Order. The quarterly reports shall be

due no later than 30 days following the close of each quarter. The first report shall be

due 30 days following the end of the quarter in which the Administrative Consent

Order is effective. Quarterly reporting may be terminated following submittal of a

final report and written request to the DNR, and a written response from the DNR

stating that all such described requirements of this Administrative Consent Order

have been completed. Record keeping required by this Administrative Consent

Order shall be an on-going requirement and shall not terminate.

VI. WAIVER OF APPEAL RIGHTS

This Administrative Consent Order is entered into knowingly and with the

consent of Lehigh. For that reason, Lehigh waives its right to appeal this Administrative

Consent Order or any part thereof.

VII. NONCOMPLIANCE

Failure to comply with this Administrative Consent Order may result in the

imposition of administrative penalties or referral to the Attorney General’s office to

obtain injunctive relief and civil penalties pursuant to the provisions of Iowa Code

section 455B.146. By agreeing to this Administrative Order, Lehigh is not agreeing to

such action or penalties.
75
85

EXHIBIT “B”

Point Source Emission Rates and Stack Parameters

Lehigh Portland Cement Company

Source

ID Source Description

Emission

Rate

(g/s)

Stack

Height

(m)

Exit

Temp

(K)

Exit

Velocity

(m/s)

Stack

Diameter

(m)

Rain Cap or

Angled Vent?

2 Limestone Primary Crushing 0.30240 18.29 293.0 0.00 1.11 Yes

3 Primary Screening System 0.12960 16.76 293.0 0.00 0.77 Yes

5 Limestone Secondary Crushing 0.10260 16.76 293.0 0.00 0.46 Yes

6 Limestone Transfer Points 0.06480 16.76 293.0 0.00 0.49 Yes

8 Limestone Transfer Points 0.04536 12.19 293.0 0.00 0.31 Yes

9 Limestone Transfer Points 0.06787 24.38 293.0 0.00 0.43 Yes

10 Limestone Transfer Points 0.06804 24.38 293.0 0.00 0.41 Yes

11 Limestone Transfer Points 0.10891 24.38 293.0 0.00 0.72 Yes

12 Limestone Transfer Points 0.04536 24.38 293.0 0.00 0.41 Yes

13 Limestone Transfer Points 0.04536 12.19 293.0 0.00 0.34 Yes

15 Clay Crushing System 0.09991 14.30 293.0 0.00 0.76 Yes

18 Clay Transfer Point 0.17775 33.53 366.5 0.00 0.61 Yes

19 Raw Mix Transfer Point 0.17280 57.91 322.1 0.00 0.60 Yes

20 Raw Mix Transfer Point 0.03657 33.53 366.5 0.00 0.62 Yes

21 Raw Mix Transfer Point 0.03657 30.48 366.5 0.00 0.41 Yes

22 Raw Mix Transfer Point 0.11588 33.53 366.5 0.00 0.41 Yes

23 Raw Mix Transfer Point 0.11115 33.53 366.5 0.00 0.41 Yes

24 Raw Mix Transfer Vent 0.16846 57.91 366.5 0.00 0.61 Yes

26 Clinker Cooler 2.85 25.91 442.6 13.99 2.44 No

27 Kiln Bypass Stack 3.74 48.77 505.4 12.62 2.13 No

28 Kiln Dust Disposal Tank 0.12604 21.94 293.0 16.09 0.46 No

33 Clinker Outhaul Transfer 0.06480 30.48 293.0 0.00 0.20 Yes

34 Clinker Bin to Truck Loadout 0.02160 30.48 293.0 0.00 0.34 Yes

35 Clinker Outhaul Transfer 0.17280 54.86 293.0 0.00 0.60 Yes

36 Clinker Withdrawal Transfer 0.08640 9.14 293.0 0.00 0.42 Yes

37 Clinker Transfer Point 0.02160 9.14 293.0 0.00 0.17 Yes

38 Clinker Transfer 0.02251 16.76 293.0 0.00 0.20 Yes

39 Clinker Transfer Elevator 0.13608 24.38 293.0 29.34 1.00 No

41 No. 3 Finishing Mill West Vt. 0.14580 24.38 293.0 0.00 0.46 Yes

42 No. 3 Finishing Mill West Vt. 0.14580 24.38 293.0 0.00 0.46 Yes

43 No. 5 Finishing Mill 0.18360 24.38 366.5 0.00 0.52 Yes

44 No. 6 Finishing Mill 0.18360 24.38 366.5 0.00 0.46 Yes

45 No. 4 Finishing Mill 0.64800 28.95 366.5 24.38 1.22 No

46 No. 4 Finishing Mill Conveyor 0.09720 25.91 310.9 0.00 0.71 Yes

47 Storage Silo Vent System 0.16200 45.72 293.0 0.00 0.66 Yes

48 Finished Cement Transfer Elv 0.06480 45.72 293.0 0.00 0.31 Yes

50 Cement Bulk Loadout 0.02160 45.72 293.0 0.00 0.20 Yes

51 Finished Cement Loadout 0.02160 45.72 293.0 0.00 0.20 Yes

52 Rail/Truck Loading System 0.13608 45.72 293.0 0.00 0.53 Yes

53 Finished Cement Loadout Spout 0.13608 45.72 293.0 0.00 0.20 Yes

62 Front Coal Mill D.C. 0.02808 15.24 338.7 17.92 0.66 No

Page 1 of 2
86

EXHIBIT “B”

Point Source Calendar Year Limitations

Lehigh Portland Cement Company

Source

ID

Source

Description

Maximum Calendar Year

Hours of Operation

(hours/year)

2 Limestone Primary Crushing 4380

3 Primary Screening System 4380

5 Limestone Secondary Crushing 4380

6 Limestone Transfer Points 4380

8 Limestone Transfer Points 7884

9 Limestone Transfer Points 7884

10 Limestone Transfer Points 7884

11 Limestone Transfer Points 7884

12 Limestone Transfer Points 876

13

Limestone Transfer Points

876

15 Clay Crushing System 876

18 Clay Transfer Point 7884

19 Raw Mix Transfer Point 7884

20 Raw Mix Transfer Point 7884

21 Raw Mix Transfer Point 7884

22 Raw Mix Transfer Point 7884

23 Raw Mix Transfer Point 7884

41 No. 3 Finishing Mill West Vt. 7534

42 No. 3 Finishing Mill West Vt. 7534

43 No. 5 Finishing Mill 7534

44 No. 6 Finishing Mill 7534

45 No. 4 Finishing Mill 7534

46 No. 4 Finishing Mill Conveyor 7534

Source

ID

Source

Description

Maximum Calendar Year

Throughput

(tons/year)

26 Clinker Cooler 1,850,000

27 Kiln Bypass Stack 1,850,000

Page 2 of 2
87

EXHIBIT “C”

Maximum Throughput Rates for Uncontrolled Sources

Lehigh Portland Cement Company

Source ID

Source

Description

Number

of

Transfers

Maximum

Daily

ThroughputEach Transfer

(tons/day)

Maximum

Calendar

Year

ThroughputEach Transfer

(tons/year)

1 Railcar Unloading 3 7,200 200,000

7A Limestone Transfer <> Storage Pile 1 19,200a 2,500,000

14A Raw Material Transfer/Clay Storage Pile 2 12,000 200,000

14B Raw Material Transfer/Clay Storage Pile 1 12,000 200,000

15A, 15B Clay Crushing Fugitives 4 12,000 200,000

39-2 (239) Gypsum/Anhydrite Bucket Transfer 2 3,600 100,000

39-3 (339) Clinker Bucket Transfer 2 3,600 500,000

40 Coal Crusher 1 1,320 200,000

49 Rail Leg Loadout 1 300 5,000

56A Limestone Transfer <> quarry to truck 2 16,000b 1,675,800

57A Clay Transfer <> quarry to truck 2 12,000c 141,667

58A Coal Transfer 1 7,200 200,000

59A Sand Transfer <> delivery 2 12,000 2,190,000

59B Sand Transfer <> to process 1 12,000 2,190,000

60A Clay Transfer <> delivery 2 12,000 2,190,000

60B Clay Transfer <> process 1 12,000 2,190,000

61A Clay Transfer <> delivery 2 12,000 2,190,000

61B Clay Transfer <> process 1 12,000 2,190,000

62-1 (162) Coal Transfer System 4 1,320 481,800

63A Kiln Dust Transfer 1 300 70,080

73A Limestone Transfer <>process pile at crusher 1 19,200a 500,000

74A Limestone Transfer <> at clay crusher 1 2,000d 70,000

75A Clinker Transfer <> Craneway 1 1,200e 15,000

76A Clinker, Gypsum, Slag Transfer <> east of

finish mill building

1 3,600 50,000

a

Maximum hourly throughput will be 1,200 ton/hour for the period 7:00 a.m. through 11:00 p.m. and 750

ton/hour at other times. Maximum daily throughput will not be exceeded on any one day.

b

Maximum hourly throughput will be 1,000 ton/hour for the period 7:00 a.m. through 11:00 p.m. and 666

ton/hour at other times. Maximum daily throughput will not be exceeded on any one day.

c

Maximum hourly throughput will be 1,000 ton/hour for the period 8:00 a.m. through 8:00 p.m. and 460

ton/hour at other times. Maximum daily throughput will not be exceeded on any one day.

d Maximum hourly throughput will be 250 ton/hour for the period 8:00 a.m. through 4:00 p.m. and 83.3

ton/hour at other times. Maximum daily throughput will not be exceeded on any one day.

e

 Maximum hourly throughput will be 100 ton/hour for the period 7:00 a.m. through 7:00 p.m. and 50

ton/hour at other times. Maximum daily throughput will not be exceeded on any one day.
88

EXHIBIT “D”

Lehigh Storage Pile Data

Storage Pile ID/(Material) Maximum Pile Size

(acres)

14 (clay 1) 1

58 (coal) 3

59 (sand) 4

60 (clay 2) 3

61 (clay 3) 3

63 (kiln dust) 2

73 (quarry run limestone) 1

74 (quarry run limestone) 0.5

75 (clinker) 0.5

76 (clinker, gypsum, granulated blast

furnace slag)

0.75

Page 1 of 2
89
90

Appendix B: Operation & Maintenance Plan
91

Lehigh Cement Company

LEHIGH MIDWEST

700 25th Street NW

Mason City, IA 50401

Phone: (641) 421-3400

Fax: (641) 421-34405

www.lehighcement.com

LEHIGH CEMENT COMPANY

Operation and Maintenance Plan

Mason City Facility

Portland Cement NESHAP

June 2002

Version 1.0

COPY NO: ________________________

ISSUED TO:________________________

DATE ISSUED:______________________
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DISTRIBUTION

COPY NO. ISSUED TO:

1 ENVIRONMENTAL MANAGER

2 PLANT MANAGER

3 MAINTENANCE SUPERVISOR

4 PRODUCTION SUPERVISOR

5 KILN CONTROL ROOM

6 FINISH MILL CONTROL ROOM
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Document

Version Date Description of Changes Prepared By Approved By

1.0 07/29/04 Initial issue. David M. Eckhardt

REVISION REVISION

SECTION TITLE NUMBER DATE

1 Introduction 0

2 Regulatory Overview 0

3 Responsibilities 0

4 Periodic Audit of OMP 0

A In-Line Kiln/Raw Mill System and Alkali Bypass 0

B Clinker Cooler 0

C Finish Mill System 0

D Storage and Material Handling Systems 0
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TABLE OF CONTENTS

1. INTRODUCTION ...................................................................................95

2. REGULATORY OVERVIEW ........................................................................95

A. BASIC REQUIREMENTS FOR THE OMP .................................................... 95

B. SUMMARY OF EMISSIONS STANDARDS.................................................... 96

C.COMPLIANCE DEMONSTRATION METHODS .............................................. 97

3. RESPONSIBILTIES ...................................................................................98

A. PLANT MANAGER .................................................................................. 98

B. PRODUCTION SUPERVISOR .................................................................... 98

C.MAINTENANCE SUPERVISOR .................................................................. 98

D.ELECTRICAL TECHNICIAN....................................................................... 99

E. CONTROL ROOM OPERATOR.................................................................. 99

F. ENVIRONMENTAL MANAGER................................................................. 100

4. PERIODIC AUDIT OF OMP .......................................................................100

PROCEDURES

A. IN-LINE KILN / RAW MILL SYSTEM ........................................................A-1

B. CLINKER COOLER...................................................................B-1

C.FINISH MILL SYSTEM........................................................................... C-1

D.STORAGE AND MATERIAL HANDLING SYSTEMS..................................... D-1

APPENDICES

Appendix 1: Affected Source List

Appendix 2: Method 22 Instructions

Appendix 3: Inspection Forms

Appendix 4: Records Retention Policy

Appendix 5: Site Diagrams
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1. INTRODUCTION

This Operation and Maintenance Plan ("OMP" or "Plan") has been developed to satisfy the

requirements of 40 CFR 63.1350 and § 63.6(e)(1) and (e)(2). The purpose of the OMP is to ensure

on-going compliance with the specific standards and requirements of 40 CFR Subpart LLL. As such,

the focus of this OMP is on the operation, maintenance, and inspection of those source components,

pollution control equipment, or monitoring devices that have a direct impact on the ability of affected

sources to meet emission standards and requirements.

The basic structure of this OMP is based on the requirements of 40 CFR 63.1350(a). The appendices

contain additional information, forms, references, and guidance intended to assist plant personnel with

the implementation and upkeep of the OMP. The information in the appendices is not required by 40

CFR 63.1350(a) to be included as a part of the OMP and therefore should not be considered legally

binding. It is the intention of Lehigh Cement Company to append, modify, and/or delete anything

contained in these appendices as necessary without notifying or receiving approval from the

Administrator.

2. REGULATORY OVERVIEW

As the result of a June 14, 1999 U.S. Environmental Protection Agency ("USEPA") rulemaking,

Lehigh Cement Company (hereinafter referred to as "LCC") will be subject to additional emissions

standards for hazardous air pollutants. The National Emissions Standards for Hazardous Air

Pollutants for Source Categories; Portland Cement Manufacturing Industry (hereinafter referred to as

the "PC NESHAP") or 40 CFR subpart LLL establishes limits for emissions of particulate matter

(as a surrogate for HAP metals), opacity, and dioxins/furans (D/F) for existing portland cement

plants. The compliance date for existing facilities is June 14, 2002.

LCC is a major source as defined in 40 CFR 63.2. As a major source, LCC is subject to emissions

standards for the in-line kiln/raw mill, finish mills, raw material storage bins, clinker storage bins,

finished product storage bins, conveying system transfer points, bagging systems, and bulk

loading and unloading systems.

A. Basic Requirements for the OMP

As provided in §63.1350(a), the written operations and maintenance plan

shall include the following information.

1. Procedures for the proper operation and maintenance of the

affected source and air pollution control devices in order to meet

the applicable emission limits and operating limits of the PC

NESHAP;

2. Corrective actions to be taken when required by §63.1350(e).

§63.1350(e) requires that the corrective actions specified in this

plan for the raw mills, finish mills, mill sweeps, and air separator

particulate matter control devices be initiated within one-hour;
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3. Procedures to be used during an inspection of the components of

the combustion system of the in-line kiln/raw mill at least once per

year; and

4. Procedures to be used to periodically monitor affected sources

subject to opacity standards under §§63.1346 and 63.1348. At

LCC, these affected sources include each new and existing raw

material, clinker, or finished product storage bin; conveying

system transfer points; bagging systems; and bulk loading and

unloading systems. These procedures must include the following -

a. Conduct a monthly 1-minute visible emissions test of each

affected source in accordance with Method 22 of Appendix

A of 40 CFR part 60. The test must be conducted while the

affected source is in operation.

b. If no visible emissions are observed in six consecutive

monthly tests for any affected source, the frequency of

testing may be decreased from monthly to semi-annually

for that affected source. If visible emissions are observed

during any semi-annual test, testing of that affected source

must be resumed on a monthly basis and that schedule must

be maintained until no visible emissions are observed in six

consecutive monthly tests.

c. If no visible emissions are observed during the semi-annual

test for any affected source, the frequency of testing may be

decreased from semi-annually to annually for that affected

source. If visible emissions are observed during any annual

test, testing of that affected source shall be resumed on a

monthly basis and that schedule shall be maintained until

no visible emissions are observed in six consecutive

monthly tests.

d. If visible emissions are observed during any Method 22

test, a 6-minute test of opacity must be conducted in

accordance with Method 9 of appendix A of 40 CFR part

60. The Method 9 test must begin within one hour of any

observation of visible emissions.

B. Summary of Emissions Standards

A summary of the affected sources at LCC and applicable standards are summarized in

Table 1 below. The compliance date for these affected sources is June 14, 2002.
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Table 1. Summary of Affected Sources and Standards.

Affected Source Pollutant Emission Limit

In-Line Kiln / Raw Mill Including Alkali

Bypass PM 0.15 kg/Mg feed (dry basis)

Opacity 20%

D/F

• 0.20 ng/dscm TEQ OR

• 0.40 ng/dscm TEQ (PM

control device operating at ≤

400°F)

Temp - Mill On (3-hr rolling avg) 1

Temp - Mill Off (3-hr rolling avg) 1

Clinker Cooler PM 0.050 kg/Mg feed (dry basis)

Opacity 10%

Finish Mills (including Air Separators) Opacity 10%

Raw Material, Clinker, Finished Product

Storage Opacity 10%

Conveying System Transfer Points Opacity 10%

Bulk Loading and Unloading Systems Opacity 10%

1

 Operating parameter limits determined during D/F performance test. Performance testing for D/F must be repeated every 30

months. Therefore, the most recent D/F performance test results should be consulted to determine current operating parameter

limits.

C. Compliance Demonstration Methods

A summary of the compliance demonstration requirements for each affected source group

at LCC is summarized in Table 2 below. The compliance date for these affected source

is June 14, 2002.

Table 2. Summary of Compliance Demonstration Requirements for Affected Sources.

Affected Source Pollutant Monitoring Requirement

In-Line Kiln / Raw Mill Including

Alkali Bypass PM None 1

Opacity Continuous Opacity Monitor

D/F Annual Combustion System

Inspection

Temperature Continuous Temperature Monitor2

Clinker Cooler Opacity Continuous Opacity Monitor

Finish Mills Opacity Bag Leak Detection Systems or

Daily 6-minute Method 22

Raw Material, Clinker, Finished

Product Storage Opacity Monthly or Semi-Annual (as

applicable) 1-minute Method 22
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Conveying System Transfer Points Opacity Monthly or Semi-Annual (as

applicable) 1-minute Method 22

Bulk Loading and Unloading

Systems Opacity Monthly or Semi-Annual (as

applicable) 1-minute Method 22 1

 EPA has deferred the requirement to install a PM CEM until a future rulemaking, at which time EPA will consider

what performance specification requirements should be established. Performance testing on PM emissions from the

in-line kiln/raw mill must be conducted every 5 years [40 CFR 63.1349(c)] to ensure the ability of the source to meet

the PM emission limit while the operation and maintenance requirements contained in this plan will be used to ensure

on-going compliance until such time as a PM CEMS is installed.

2

 The continuous temperature monitor must be calibrated quarterly.

3. RESPONSIBILTIES

Key responsibilities are assigned to allow for smooth implementation of this plan. Although

various plant personnel may perform specific procedures, overall responsibilities are outlined

below to assist plant personnel with OMP implementation and to establish a framework through

which NESHAP compliance will be maintained.

A. Plant Manager

The Plant Manager has overall responsibility for NESHAP regulatory compliance. The

Plant Manager is responsible for oversight of the air quality control program at the plant

and for ensuring that the procedures in this plan are implemented and adhered to by plant

personnel.

B. Production Supervisor

The Production Supervisor is responsible for day-to-day implementation of the O&M

plan at the facility. The Production Supervisor will report to the Plant Manager on all

matters of NESHAP compliance. Specific duties of the Production Supervisor might

include:

1. Notify Maintenance Supervisor and Plant Manager of potential and/or actual noncompliance with emissions or monitoring standards;

2. Oversight of training for production employees on the procedures outlined in the

O&M plan; and

3. Periodically review O&M plan in accordance with section 4 below and suggest

updates to any procedures or appendices necessary to effectively implement the

O&M plan.

C. Maintenance Supervisor

The Maintenance Supervisor will consult with plant personnel on inspection and

maintenance needs of affected sources and associated pollution control equipment. The

Maintenance Supervisor also provides guidance on the implementation and performance

of this plan. Specific duties of the Maintenance Supervisor might include:

1. Schedule and review the inspection and preventative maintenance procedures

included in this plan;
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2. Receive and review specific inspection and maintenance procedures conducted by

plant personnel;

3. Ensure that the necessary maintenance is carried out based on inspection results;

4. Ensure spare parts are maintained at the plant; and

5. Periodically review O&M plan in accordance with section 4 below and suggest

updates to any procedures or appendices necessary to effectively implement the

O&M plan.

D. Electrical Technician

The Electrical Technician is responsible for the proper operation, calibration, and

maintenance of operating parameter monitoring equipment and continuous opacity

monitoring equipment. Specific duties of the Electrical Technician might include:

1. Conduct or oversee the performance of quality control program as required by 40

CFR 63.8(d) and PS-1 of appendix B to part 60 for the COMS and/or continuous

temperature monitor at the inlet to the main stack electrostatic precipitator, (ESP),

bypass baghouse, and cooler vent baghouse;

2. Perform necessary corrective action for the COMS and continuous temperature

monitor at the inlet to the main stack ESP, bypass baghouse, and cooler vent

baghouse;

3. Maintain files of quality control program data, including periodic checks, audits, and

corrective action data; and

4. Ensure spare parts for the COMS and continuous temperature monitor at the inlet to

the main stack ESP, bypass baghouse, and cooler vent baghouse are maintained at

the plant.

E. Control Room Operator

The Control Room Operator has the overall responsibility of monitoring the continuous

opacity and temperature measurements at the inlet to the main stack ESP, bypass

baghouse, and cooler vent baghouse. Specific duties of the Control Room Operator

might include:

1. Monitor COMS fault warning systems and alarms;

2. Periodically check the data acquisition and management system computer to verify

that the computer is operational;

3. Checks to ensure that the three-hour rolling average temperature measured at the

inlet to the main stack ESP and bypass baghouse, is within applicable operating

limits;

4. Checks to ensure that the three-hour rolling average temperature measured at the

inlet to the main stack ESP and bypass baghouse is calculated anew each time the

raw mill is changed from on to off, or from off to on; and
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5. Reports any alarms, computer fault messages, malfunctions, process upsets, missing

or erroneous data, or process problems that impair the ability of the in-line kiln / raw

mill system to meet or demonstrate compliance with applicable opacity or operating

parameter limits to the Production Manager.

F. Environmental Manager

The environmental manager has the overall responsibility of ensuring compliance with all

federal, state, and local environmental regulations including the notification, reporting,

record keeping requirements of 40 CFR part 63 subparts A and LLL. Specific tasks of

the environmental manager might include:

1. Ensure that appropriate plant personnel are familiar with applicable emissions

standards and compliance demonstration requirements;

2. Inform plant personnel of the content of the operation and maintenance plan and

ensure that the plan is effectively implemented; and

3. Identify the need to update the operation and maintenance plan and revise the plan

according to the procedures outlined in section 4.

4. PERIODIC AUDIT OF OMP

A complete review of the O&M plan as well as all appendices including procedures, checklists,

forms, and affected source list will be conducted periodically. The suggested frequency for this

review is every five years to correspond with the Title V permit renewal process or as otherwise

necessary. The review will be coordinated by the Environmental Manager and will include input

by the Production Managers, Maintenance Supervisors, and other plant personnel, as necessary.

The results of checks, inspections, and maintenance performed during the year will be used as the

basis for this review.

A. The goal of this periodic review is to:

1. Update all requirements contained in the OMP to include any changes or

additions to Subpart LLL;

2. Update the OMP, as necessary, to reflect current equipment, personnel,

regulations, and procedures;

3. Ensure contents of OMP are effective for ensuring compliance with Subpart

LLL;

4. Update all appendices or other supporting documents to ensure effective

implementation of the procedures in the OMP;

5. Streamline regulatory compliance efforts by coordinating OMP responsibilities

with operating or construction permit requirements;

6. Evaluate the frequencies of preventative maintenance activities and determine if

individual procedures should be conducted more or less often; and
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7. Determine if specific preventative maintenance activities are necessary and

sufficient for the current scope of the OMP.

B. This periodic review will ensure that OMP along with all materials used in the

implementation of the plan are appropriate for NESHAP compliance while minimizing

extraneous activities and resource requirements.

C. Any changes determined to be necessary to the OMP (excluding any appendices, forms,

or other material used to implement the plan) will be submitted to the IDNR – Air

Quality Bureau – Compliance Section.

D. Notes on Revising the OMP

As required by 40 CFR 63.1350(a), the written operations and maintenance plan must be

submitted to the Administrator for review and approval as part of the application for a

part 70 permit. The OMP contains all information required by 40 CFR 63.1350.

However, the procedures used to implement the OMP are contained in the appendices to

the OMP. This structure allows the requirements of the OMP to be federally enforceable

as intended by 40 CFR 63.1350 while still allowing LCC the flexibility to revise, as

necessary, the procedures implementing the OMP.

E. OMP Recordkeeping Requirements

This OMP or the most current version of the OMP must be kept on-site for the life of

each 40 CFR 63 Subpart LLL affected source. All records in support of 40 CFR 63

Subpart LLL including notification, records, and reports must be kept on-site for 5 years

following the date on which the notification, record, or report is prepared [40 CFR

63.10(b)(1)].
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Issue Date: 07/29/04 .

Approved: .

Revision: 0 .

SYSTEM: In-Line Kiln / Raw Mill and Alkali Bypass

EQUIPMENT: Rotary Kiln and Ball Mill

PURPOSE: The purpose of this procedure is to provide air quality protection measures, achieve

emissions limits, and satisfy NESHAP Subpart LLL requirements for development

of operations and maintenance procedures. This procedure also explains the

regulatory standards, monitoring requirements, and operation, inspection and

maintenance procedures necessary to ensure on-going compliance with applicable

standards.

1. INTRODUCTION

A. The cement kiln system is a single dry process rotary kiln equipped with a

4 stage preheater precalciner. The kiln system uses a variety of fuels to

provide the thermal input necessary to convert raw materials into clinker.

These fuels include fossil fuels (i.e. coal, petroleum coke, etc.) as well as

natural gas. The raw materials fed to the kiln process include materials

obtained from both on-site and off-site sources. Raw materials may

include limestone, clay, sand, alumina, silica, iron ore, and/or other raw

material additives.

B. Hot exhaust gases from the rotary kiln pass counter-currently through the

downward-moving raw materials in the preheat tower. The hot exhaust

gases exiting the preheat tower are cooled in a spray tower before being

routed to the main stack ESP or to the raw mill. Exhaust gases entering

the raw mill are used as a source of heat for drying raw materials and

carrying the crushed materials into cyclones.

C. The kiln exhaust gases exiting the raw mill cyclone are then routed to the

particulate matter control device (PMCD), referred to as the main stack

ESP. Fines from the cyclone discharge are routed to the Raw Feed

Blending and Storage System.

D. The alkali bypass is an exhaust gas takeoff from the base of the preheater.

After the combustion gasses pass through the kiln, the alkali bypass

removes part of the gas stream. This is necessary because sulfur and

alkalis recycle in the gas stream. The alkali bypass purges sulfur and

alkalis from the system so they do not accumulate. Immediately as the gas
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enters the alkali bypass, the gas is quenched with ambient air to cool the

gas and precipitate the vapors in the gas stream. The gas then passes

through a spray tower followed by a bag house before exiting out the

bypass stack.

2. REGULATORY OVERVIEW

Standards affecting the in-line kiln/raw mill system include limits on particulate matter (PM),

opacity, and dioxins and furans (D/F).

A. Particulate Matter (PM)

PM emissions from the in-line kiln/raw mill system are limited as a surrogate for HAP

metals including arsenic, cadmium, chromium and lead. PM emissions from the in-line

kiln/raw mill and alkali bypass are limited to 0.15 kg PM per Mg (0.30 lb per ton) of kiln

feed (dry basis).

B. Dioxins and Furans (D/F)

D/F emissions from the in-line kiln/raw mill system and alkali bypass are limited to:

1. 0.20 ng per dscm (8.7x10-11 gr per dscf) (TEQ) corrected to seven percent oxygen; or

2. 0.40 ng per dscm (1.7x10-10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the average of

the performance test run average temperatures at the inlet to the particulate matter control device is 204

°C (400 °F) or less.

C. Opacity

Opacity from the in-line kiln/raw mill system and alkali bypass is limited to 20 percent

based on a six-minute average.

D. Temperature

The temperature of the kiln exhaust gases at the inlet to the particulate matter control

device is limited according to the average of the run average temperatures measured

during the most recent performance test conducted in accordance with 40 CFR

63.1349(b)(3). This performance testing must be repeated every 30 months.

During performance testing, temperature limits are established for two modes of

operation, (1) raw mill on and (2) raw mill off. Compliance with the temperature limits

are based on a three-hour rolling average period that begins anew each time the operating

mode is changed from on to off, or from off to on.

The operating temperature limit of the kiln exhaust gases at the inlet to the particulate

matter control device in the alkali bypass system must not exceed is limited according to

the average of the run average temperatures measured during the most recent

performance test conducted in accordance with 40 CFR 63.1349(b)(3) with the raw mill

on.
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3. OPERATING PROCEDURES

A. Dioxin / Furan and Temperature at PMCD Inlet

On-going compliance with the D/F limit will be achieved by operating the in-line kiln /

raw mill system below the operating limits set during the most recent D/F performance

test on the maximum temperature measured at the inlet to the particulate matter control

device. The temperature at the inlet to the main stack ESP and the alkali bypass is

regulated by spray towers. The spray towers cool kiln exhaust gases by introducing tiny

water droplets into the air stream.

Proper operation of the spray towers in cooling kiln exhaust gas is achieved through

automatic controls that regulate the water feed rate. Once the spray cooler has been

started and operation has stabilized as outlined in the Startup, Shutdown, and Malfunction

Plan, little additional operator attention is required.

The temperature of the kiln exhaust gas at the inlet to the ESP and alkali bypass are

continuously monitored as required by 40 CFR 63.1350(f)(1). These readings are used as

an indicator of proper operation of the spray tower.

B. Particulate Matter and Opacity

The affected source will ensure on-going compliance with the particulate matter and

opacity limits by properly operating the particulate matter control device, ESP and alkali

bypass baghouse, at all times that the kiln and/or roller mill are in operation. The ESP and

alkali bypass baghouse operate under negative pressure. The key operating parameters

affecting particulate matter emissions and opacity are given below.

1. Kiln / Raw Mill ESP

a) Operating Temperature.

The upper gas temperature of the kiln exhaust gases entering the baghouse must

be maintained below 500 °F to ensure that the integrity of the fabric filter

material (filament glass or similar) is maintained. The lower gas temperature of

the kiln exhaust gases entering the baghouse must be maintained above the dew

point of water and hydrochloric acid (180 °F) to prevent condensation.

Condensation must be avoided to prevent corrosion, bag blinding, and cakerelease problems.

The temperature of the kiln exhaust gases at the inlet to the Main Baghouse are

continuously monitored as required by 40 CFR 63.1350(f)(1).

b) ESP Voltage

Each of the 3 ESP fields can be individually controlled by adjusting the Voltage

to most effectively clean the gas passing through the field based on the dust

load. The Voltage electrically charges closely spaced large plates in the ESP.

The Voltage for each field is maintained at 65 KV during normal operation.

This requires little or no attention once the set point is determined.

c) ESP Charged Plate Cleaning
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Once the particles are attracted to the charged plates in the ESP. The plates in

each field are cleaned on a timed basis. The plates are hammered by a motor

driven cam on top of each field. The frequency of the plate cleaning can be

adjusted and they should be timed so that they do not interfere with the cleaning

time of downstream fields creating an opacity spike that corresponds with the

cleaning cycle. Once the cleaning timing and frequency are set they require

little or no attention when working properly.

d) Negative Pressure at ESP Inlet

Vacuum indication at the kiln baghouse inlet is monitored by the console

operator during operation as an indicator of proper operation of in-line kiln/raw

mill exhaust containment.

2. Alkali Bypass Baghouse

a) Operating Temperature.

The upper gas temperature of the kiln exhaust gases entering the baghouse must

be maintained below 500 °F to ensure that the integrity of the fabric filter

material (filament glass or similar) is maintained. The lower gas temperature of

the kiln exhaust gases entering the baghouse must be maintained above the dew

point of water and hydrochloric acid (180 °F) to prevent condensation.

Condensation must be avoided to prevent corrosion, bag blinding, and cakerelease problems.

The temperature of the kiln exhaust gas at the inlet to the alkali bypass is

continuously monitored as required by 40 CFR 63.1350(f)(1).

b) Pressure Drop.

The baghouse is operated to maintain a pressure drop across the system within a

range of 6 to 12 in. w.c. The pressure drop is an indication of filter cake

formation that impacts the effectiveness of particulate control. Filter cake

formation is function of the bag cleaning cycle. The frequency and duration of

bag cleaning is set to maintain a desired pressure drop rang however, the

pressure drop is affected by the dust load and draft passing through the bags.

c) Bag Cleaning Air Pressure

The plenum pulse cleaning air pressure is maintained at 60 to 100 psig to allow

for proper cleaning of the bags. The cleaning pressure is released on timed

intervals to clean the dust collection bags.

d) Negative Pressure at Baghouse Inlet

Vacuum indication at the kiln baghouse inlet is monitored by the console

operator during operation as an indicator of proper operation of bypass exhaust

containment.

4. MAINTENANCE AND INSPECTION PROCEDURES
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The maintenance and inspection procedures outlined below focus on those systems that could

impact the ability of the affected source to meet applicable Subpart LLL standards. These

procedures are also intended to satisfy the requirements of 40 CFR 63.1350(a)(3).

A. Rotary Kiln and Preheater

1. Annual Combustion System Inspection

40 CFR 63.1350(a)(3) requires the combustion system of the kiln be inspected at

least once per year. The purpose of the annual inspection is to ensure good

combustion and thus limit primary formation of D/F in the kiln. Primary D/F

formation in the kiln occurs as a result of insufficient oxygen, poor mixing, low

temperature, and short residence time. The following inspection procedures are

conducted annually to ensure that the specific components of the combustion

system that control these factors are sufficient for maintaining good combustion

practices.

a. Inspect burner for erosion, corrosion, plugging, or other alterations that may

adversely affect performance.

b. Check air supply and burner condition.

c. Inspect Coal Conveying system

d. Inspect burner valves and piping

The results of this annual inspection must be included in the Semi-Annual

Summary Report required by 40 CFR 63.10(e)(3)(vi) if the inspection was

conducted during the reporting period. [40 CFR 63.1354(b)(9)(iv)]

2. Periodic Inspection and Preventative Maintenance Procedures

a. During operation of the rotary kiln, the preheat tower is periodically

inspected to prevent plugging to the extent possible.

b. Preventative maintenance procedures include cleaning of the preheat tower

by plant operators, as necessary, to avoid plugging.

c. Frequency of preheat tower inspections for plugging will vary depending on

maintenance and malfunction history. As a general guideline,

inspections are routinely scheduled during each shift.

B. ESP

1. Monthly Inspection Procedures

The following inspection procedures have been developed to ensure proper

maintenance of certain components of the ESP that are critical to the ability of

the ESP to achieve applicable emission limits.

a. Verify that the ESP and immediate ductwork are free of leaks.
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b. Verify that the following ESP components are operational: plate

cleaning mechanism, fans, timing controls, and dust removal system.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed above are performed on a

monthly basis.

2. Annual Inspection Procedures

The following inspection procedures have been developed for preventative

maintenance of certain components of the ESP that are critical to achieve

applicable emission limits.

a. Verify integrity of containment structures including housing and piping (i.e.

check for wear and/or leakage);

b. Check the cleaning sequence of the ESP collection plates;

c. Inspect plates for wear.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed above are performed on an

annual basis.

3. Maintenance Procedures

Depending upon the outcome of periodic inspections, preventative maintenance

may be necessary. The specific preventative maintenance measures taken will

vary depending upon observations made during periodic inspections and may

include any of the following -

a. Repair/replacement of electrical components;

b. Repair/replace leaks in the containment structure of the dust collector

or immediate ductwork.

C. Alkali Bypass Dust Collector

1. Monthly Inspection Procedures

The following inspection procedures have been developed to ensure proper

maintenance of certain components of the bypass baghouse that are critical to

the ability of the baghouse to achieve applicable emission limits.

a. Verify that the bag cleaning system for each compartment in use is

functioning.

b. Verify that the dust collector and immediate ductwork are free of leaks.
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c. Verify that the following dust collector components are operational: bag

cleaning mechanism, fans, timing controls, and dust removal system.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed above are performed on a

monthly basis.

2. Annual Inspection Procedures

The following inspection procedures have been developed for preventative

maintenance of certain components of the main baghouse that are critical to the

ability of dust collector to achieve applicable emission limits.

a. Verify integrity of containment structures including housing and piping (i.e.

check for wear and/or leakage);

b. Check the cleaning sequence of the dust collector;

c. Inspect bags for leaks and wear.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed above are performed on an

annual basis.

3. Maintenance Procedures

Depending upon the outcome of periodic inspections, preventative maintenance

may be necessary. The specific preventative maintenance measures taken will

vary depending upon observations made during periodic inspections and may

include any of the following -

a. Repair/replacement of filter bags;

b. Repair/replace leaks in the containment structure of the dust collector

or immediate ductwork.

D. Spray Cooling Systems

1. Periodic Inspection Procedures

Continuous monitoring of the temperature of kiln exhaust gases at the inlet to

the Main Baghouse serves as an indicator of proper operation of the Spray

Tower. If temperature spikes are consistently observed, the following inspection

procedures of certain components of the Spray Tower may be used to identify

the appropriate preventative maintenance needs of the system.

a. Verify that water supply system is functioning;

b. Check for proper operation of water supply pumps and water line (i.e.

check for blockage and leakage);
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c. Check recirculating water system for plugging;

d. Verify that pressure drop indicators are functioning and check pressure

drop as an indicator of plugging in pipes, manifolds, and spray nozzles.

2. Maintenance Procedures

Depending upon the outcome of periodic inspections, preventative maintenance

may be necessary. The specific preventative maintenance measures taken will

vary depending upon observations made during periodic inspections and may

include any of the following -

a. Repair/replace leaks, cracks, and loose fittings;

b. Clean out plugged pipes, manifolds, spray nozzles, etc.;

5. MONITORING PROCEDURES

The monitoring procedures outlined below are consistent with Subpart LLL standards. These

procedures are intended to satisfy the requirements of 40 CFR 63.1350(c) and (f).

A. Continuous Opacity Monitor System (COMS)

As required by 40 CFR 63.1350(c)(1), a continuous opacity monitor system is used as an

indicator of compliance with the opacity standards for the in-line kiln / raw mill system

and alkali bypass. The COMS is calibrated, operated, and maintained in accordance with

the provisions of 40 CFR part 63 subpart A and PS-1 of appendix B to part 60.

B. Temperature Monitor

As required by 40 CFR 63.1350(f), a continuous monitor is used to record the

temperature of kiln exhaust gases at the inlet to the ESP and alkali bypass. The following

guidelines are followed when determining compliance with the temperature limit (3-hour

rolling average) on the kiln exhaust gases at the inlet to the particulate matter control

device -

1. The three-hour rolling average is calculated as the average of 180 successive oneminute average temperatures.

2. Periods of time when one-minute averages are not available are ignored when

calculating three-hour rolling averages. When one-minute averages become

available, the first one-minute average is added to the previous 179 values to

calculate the three-hour rolling average.

3. When the operating status of the raw mill is changed from off to on, or from on to

off, the calculation of the three-hour rolling average temperature begins anew,

without considering previous recordings.

Calibration of the thermocouple used to monitor compliance with the NESHAP operating

limits must be verified at least once every three months.
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Issue Date: 07/29/04 .

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SYSTEM: Clinker Cooler

EQUIPMENT: Clinker Cooler

PURPOSE: The purpose of this procedure is to provide air quality protection measures, achieve

emissions limits, and satisfy NESHAP Subpart LLL requirements for development

of operations and maintenance procedures. This procedure also explains the

regulatory standards, monitoring requirements, and operation, inspection and

maintenance procedures necessary to ensure on-going compliance with applicable

standards.

1. INTRODUCTION

A. The clinker cooler forces ambient air through moving grates on the floor

of the cooler that move hot clinker through the cooler as it exits the rotary

kiln. The ambient air cools the clinker as it is forced up through the

clinker bed. The hot air that passes through the clinker bed is preheated

and used for combustion air in the kiln system. The excess air is removed

from the cooler through the cooler vent system.

B. The cooler vent system draws heated air from the cooler. The heated air

passes through an air to air heat exchanger and then through a baghouse

before the air exits through the cooler vent stack.

2. REGULATORY OVERVIEW

Standards affecting the clinker cooler include limits on particulate matter (PM) and opacity.

A. Particulate Matter (PM)

PM emissions from the clinker cooler are limited as a surrogate for HAP metals including

arsenic, cadmium, chromium and lead. PM emissions from the in-line kiln/raw mill are

limited to 0.050 kg PM per Mg (0.30 lb per ton) of kiln feed (dry basis).

B. Opacity

Opacity from the in-line kiln/raw mill system is limited to 10 percent based on a sixminute average.
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3. OPERATING PROCEDURES

A. Particulate Matter and Opacity

The affected source will ensure on-going compliance with the particulate matter and

opacity limits by properly operating the particulate matter control device, the cooler vent

baghouse, at all times that the kiln is in operation. The cooler vent baghouse operates

under negative pressure with an air cleaning mechanism. The key operating parameters

of fabric filter control systems affecting particulate matter emissions and opacity are

given below.

1. Pressure Drop.

The baghouse is operated to maintain a pressure drop across the system. The

pressure drop is an indication of filter cake formation that impacts the

effectiveness of particulate control. Filter cake formation is function of the bag

cleaning cycle. The frequency and duration of bag cleaning is set to maintain a

desired pressure drop range.

2. Cleaning Air Pressure.

The cleaning pressure is maintained between 60 to 100 psig to allow for proper

cleaning of the bags.

3. Negative Pressure at Baghouse Inlet

Vacuum indication at the kiln baghouse inlet is monitored by the console

operator during operation as an indicator of proper operation of cooler vent

exhaust containment.

4. MAINTENANCE AND INSPECTION PROCEDURES

The maintenance and inspection procedures outlined below focus on those systems that could

impact the ability of the affected source to meet applicable Subpart LLL standards.

A. Dust Collector

1. Monthly Inspection Procedures

The following inspection procedures have been developed to ensure proper

maintenance of certain components of the cooler vent baghouse that are critical

to the ability of the baghouse to achieve applicable emission limits.

a. Verify that the dust collector, air to air heat exchanger, and immediate

ductwork are free of leaks.

b. Verify that the following dust collector components are operational: bag

cleaning mechanism, fans, timing controls, and dust removal system.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general
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guideline, the periodic inspection procedures listed above are performed on a

monthly basis.

2. Annual Inspection Procedures

The following inspection procedures have been developed for preventative

maintenance of certain components of the main baghouse that are critical to the

ability of dust collector to achieve applicable emission limits.

a. Verify integrity of containment structures including housing and piping (i.e.

check for wear and/or leakage);

b. Check the cleaning sequence of the dust collector;

c. Inspect bags for leaks and wear.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed above are performed on an

annual basis.

3. Maintenance Procedures

Depending upon the outcome of periodic inspections, preventative maintenance

may be necessary. The specific preventative maintenance measures taken will

vary depending upon observations made during periodic inspections and may

include any of the following -

c. Repair/replacement of filter bags;

d. Repair/replace leaks in the containment structure of the dust collector

or immediate ductwork.

5. MONITORING PROCEDURES

The monitoring procedures outlined below are consistent with Subpart LLL standards. These

procedures are intended to satisfy the requirements of 40 CFR 63.1350(d).

C. Continuous Opacity Monitor System (COMS)

As required by 40 CFR 63.1350(d)(1), a continuous opacity monitor system is used as an

indicator of compliance with the opacity standards for the clinker cooler. The COMS is

calibrated, operated, and maintained in accordance with the provisions of 40 CFR part 63

subpart A and PS-1 of appendix B to part 60.
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Issue Date: 07/29/04 .

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Revision: 0 .

SYSTEM: Finish Mill System

EQUIPMENT: Finish Mills 3, 4, 5 and 6

PURPOSE: The purpose of this procedure is to provide air quality protection measures, achieve

emissions limits, and satisfy NESHAP Subpart LLL requirements for development

of operations and maintenance procedures. This procedure also explains the

regulatory standards, monitoring requirements, and operation, inspection and

maintenance procedures necessary to ensure on-going compliance with applicable

standards.

1. INTRODUCTION

A. The finish mill system includes four separate milling systems that process clinker and

gypsum into a finely ground mixture. The clinker and gypsum are fed to the finish mills

via weigh feeders. Ground cement is then discharged from each mill into a bucket

elevator that transports the material to a mechanical air separator. The separator

segregates the ground cement by particle size and discharges materials meeting the size

specification to the Storage and Shipping Department.

B. Each finish mill is equipped with a dust collector to control particulate emissions from

the mill sweep and separator.

2. REGULATORY OVERVIEW

Standards affecting the finish mill system include limits on the opacity of discharges from the mill

sweep or air separator air pollution control devices.

A. Opacity

Opacity from the mill sweep / air separator air pollution control devices is limited to 10

percent based on a six-minute average.

3. OPERATING PROCEDURES

A. Opacity

The affected sources will ensure on-going compliance with the opacity limit by properly

operating each particulate matter control device at all times that the corresponding finish

mill is in operation. Each baghouse operates under negative pressure with a reverse air
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cleaning mechanism. The key operating parameters of fabric filter control systems

affecting the opacity of emissions are given below.

1. Pressure Drop.

The baghouse is operated to maintain a pressure drop across the system. The

pressure drop is an indication of filter cake formation that impacts the

effectiveness of particulate control. Filter cake formation is function of the bag

cleaning cycle. The frequency and duration of bag cleaning is set to maintain a

desired pressure drop range.

2. Cleaning Air Pressure (#4 Finish Mill)

The cleaning pressure is maintained between 60 to 100 psig to allow for proper

cleaning of the bags.

3. Reverse Air Bag Cleaning Systems (#3,5&6 Finish Mills)

The bag cleaning air is ambient air drawn into individual compartments in the

reverse flow direction of the dust-laden air. The dust-laden air is closed off

during this cleaning cycle so that the reverse air cleans the dust cake off of the

filter bags. This cleaning cycle must be operating and timed correctly to allow

for proper cleaning of the bags.

4. MAINTENANCE AND INSPECTION PROCEDURES

The maintenance and inspection procedures outlined below focus on those systems that could

impact the ability of the affected source to meet applicable Subpart LLL standards. These

procedures are also intended to satisfy the requirements of 40 CFR 63.1350(a)(3).

A. Dust Collectors

1. Monthly Inspection Procedures

The following inspection procedures have been developed to ensure proper

maintenance of certain components of the finish mill system dust collectors that

are critical to the ability of each to achieve applicable emission limits.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed below are performed each

month.

a. Verify that the dust collector and immediate ductwork are free of leaks;

b. Verify that the following dust collector components are operational:

bag cleaning mechanism, fans, timing controls, and dust removal

system.

2. Annual Inspection Procedures
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The following inspection procedures have been developed for preventative

maintenance of certain components of dust collectors that are critical to the

ability of each to achieve applicable emission limits.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed below are performed on an

annual basis.

a. Verify integrity of containment structures including housing and piping

(i.e. check for wear and/or leakage);

b. Check the cleaning sequence of the dust collector.

3. Maintenance Procedures

Depending upon the outcome of periodic inspections, preventative maintenance

may be necessary. The specific preventative maintenance measures taken will

vary depending upon observations made during periodic inspections and may

include any of the following -

a. Repair/replacement of filter bags;

b. Repair/replace leaks in the containment structure of the dust collector

or immediate ductwork.

5. PERIODIC MONITORING PROCEDURES

The periodic monitoring procedures outlined below are consistent with Subpart LLL standards and

the Settlement Agreement between USEPA and the American Portland Cement Alliance (APCA),

Case No. 99-1322. These procedures are intended to satisfy the requirements of 40 CFR

63.1350(e).

A. Visible Emissions Observations

Periodic visual emissions observations in accordance with 40 CFR 63.1350(e) The

periodic visual emissions observation requirements of 40 CFR 63.1350(e) are outlined

below.

1. Visual emissions observations of the mill sweep and air separator particulate

matter control device (PMCD) are conducted each day that the affected source is

in operation.

2. The procedures of Method 22 of part 60 will be used for all visual emissions

observations.

3. The duration of the Method 22 test is six minutes.

4. If visible emissions are observed, conduct a follow-up Method 22 test within 24

hours of the end of the Method 22 test in which visible emissions were observed

(ref. Settlement Agreement between USEPA and APCA, Case No. 99-1322).
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a. If visible emissions are observed during the follow-up Method 22 test,

conduct a Method 9 test;

b. The duration of the Method 9 test is 30 minutes.

5. The appropriate corrective actions outlined in section 6 below will be initiated

within one-hour after any visual emissions observation.

6. CORRECTIVE ACTIONS

The corrective actions provided in this section were developed to satisfy the requirements of 40

CFR 63.1350(e)(1). The procedures outlined below must be initiated within one-hour of

observing visual emissions as outlined in 40 CFR 63.1350(e).

A. Immediate Response Procedures

The following actions will be taken within one-hour of observing visual emissions

following the Method 22 procedures.

1. Record the time and location of the visual emissions observation;

2. Inform environmental manager (or other responsible personnel) of the

occurrence of a visual emissions observation including time and location;

3. Initiate all appropriate inspection procedures listed in section 4 above.

B. Subsequent Response Procedures

The following response procedures will be initiated if the Method 9 test conducted as a

result of two consecutive visual emissions observations indicates an excedence of the

opacity limit.

1. Based on the results of the inspection, initiate maintenance as appropriate; and

2. Record duration of excess emissions event and maintenance performed on the

particulate matter control device as required by 40 CFR 63.10(b)(2).
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Issue Date: 07/29/04 .

Approved: .

Revision: 0 .

SYSTEM: Storage and Material Handling Systems

EQUIPMENT: Raw Material, Clinker, Finished Product Storage Bins; Conveying System Transfer

Points; and Bulk Loading and Unloading Systems

PURPOSE: The purpose of this procedure is to provide air quality protection measures, achieve

emissions limits, and satisfy NESHAP Subpart LLL requirements for development

of operations and maintenance procedures. This procedure also explains the

regulatory standards, monitoring requirements, and operation, inspection and

maintenance procedures necessary to ensure on-going compliance with applicable

standards.

1. INTRODUCTION

A. The raw material, clinker, coal, and finished product storage systems consists of both

storage silos and surge bins. Affected sources include only those raw material, clinker,

and finished product storage bins that meet the EPA definition of a bin. EPA has defined

a bin as "a man-made enclosure for storage of raw materials, clinker, or finished product

prior to further processing."

B. Emissions from storage bins occur as a result bin loading and unloading as well as

entrainment of dust particles from air circulation in the bin. Stack emissions from raw

material, clinker, and finished product storage bins are controlled with fabric filter dust

collectors.

C. Conveying systems are used to transfer raw materials, solid fuels, clinker, and finished

product from one piece of equipment or location to another location within the facility.

Affected sources that comprise these systems include feeders, belt conveyors, bucket

elevators, and pneumatic systems.

D. Stack emissions from conveying system transfer points are controlled with fabric filter

dust collectors. Dust suppression of fugitive sources is sometimes accomplished through

the use of enclosures and drop chutes at transfer points.

E. The solid fuel (including coal and coke) received by the facility is transferred to either

outside storage piles or to storage in the craneway. The fuel is then conveyed to either

the kiln coal mill coal tank or the calciner coal mill coal tank before being conveyed to

one of the roller type coal mills.

F. The calciner coal mill is totally enclosed and vents with the kiln exit gasses.

G. Affected sources that are located within buildings that provide a total enclosure are

monitored at the extent of the building.
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H. The bulk loading and unloading systems include bulk load-out via railcar and truck and

the rail car unloading system.

I. Dust generated during bulk loading and unloading is collected and vented to dust

collectors. Fugitive emissions from bagging and bulk loading and unloading operations

are contained via loading spouts and enclosures to the extent possible.

2. REGULATORY OVERVIEW

Standards affecting the storage and material handling systems include limits on the opacity of

discharges from conveyor system transfer points; raw material, clinker, and finished product

storage bins; bagging and bulk loading and unloading systems; and dust collectors controlling

these sources.

A. Opacity

Opacity from each conveyor system transfer points; raw material, clinker, and finished

product storage bins; bulk loading and unloading systems is limited to 10 percent based

on a six-minute average.

3. OPERATING PROCEDURES

A. Opacity

Each affected source with uncontrolled emissions that have the potential to exceed the 10

percent opacity limit are equipped with fabric filter control equipment to ensure

compliance with the NESHAP standard. As such, affected sources will ensure on-going

compliance with the opacity limit by properly operating each particulate matter control

device at all times that the corresponding affected source is in operation. A variety of

fabric filter dust collectors are utilized depending on the characteristic of the system and

emissions being controlled. In each case, however, the key operating parameters of

fabric filter control systems affecting the opacity of emissions are the same.

1. Pressure Drop.

The baghouse is operated to maintain a pressure drop across the system. The

pressure drop is an indication of filter cake formation that impacts the

effectiveness of particulate control. Filter cake formation is function of the bag

cleaning cycle. The frequency and duration of bag cleaning is set to maintain

the desired pressure drop.

2. Cleaning Air Pressure.

The cleaning pressure is maintained between 60 to 100 psig to allow for proper

cleaning of the bags.

4. MAINTENANCE AND INSPECTION PROCEDURES
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The maintenance and inspection procedures outlined below focus on those systems that could

impact the ability of the affected source to meet applicable Subpart LLL standards. These

procedures are also intended to satisfy the requirements of 40 CFR 63.1350(a)(3).

A. Transfer Points and Dust Collectors

1. Monthly Inspection Procedures

The following inspection procedures have been developed to ensure proper

maintenance of certain components of affected dust collectors that are critical to

the ability of affected sources to achieve applicable emission limits.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed below are performed

monthly.

a. Verify that all housings and skirting are properly enclosing the affected

source.

b. Verify that dust collectors and immediate ductwork are free of leaks;

c. Verify that the following dust collector components are operational:

bag cleaning mechanism, fans, timing controls, and dust removal

system.

2. Annual Inspection Procedures

The following inspection procedures have been developed for preventative

maintenance of certain components of affected dust collectors that are critical to

the ability of each to achieve applicable emission limits.

The frequency of these inspection procedures will vary based on historical

inspection results, maintenance history, and operating schedule. As a general

guideline, the periodic inspection procedures listed below will be performed on

an annual basis.

a. Verify integrity of containment structures including housing and piping (i.e.

check for wear and/or leakage);

b. Check the cleaning sequence of dust collectors;

c. Inspect bags for leaks and wear.

3. Maintenance Procedures

Depending upon the outcome of periodic inspections, preventative maintenance

may be necessary. The specific preventative maintenance measures taken will

vary depending upon observations made during periodic inspections and may

include any of the following -

a. Repair/replacement of filter bags;
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b. Repair/replace leaks in the containment structure of the dust collector

or immediate ductwork.

5. PERIODIC MONITORING PROCEDURES

The periodic monitoring procedures outlined below are consistent with Subpart LLL standards.

These procedures are intended to satisfy the requirements of 40 CFR 63.1350(e).

A. Visible Emissions Observations

Periodic visual emissions observations in accordance with 40 CFR 63.1350(a) are

required for each affected source subject to the provisions of 40 CFR 63.1348. Refer to

the Appendix for a list of affected sources and associated control equipment subject to

this requirement. Note that this requirement does not apply to totally enclosed conveying

system transfer points.

Certain systems that include several affected sources that are contained in the same

building or structure will be visually inspected at the extent of the building by method 22

for all operating sources within the building or structure. If Emissions are detected

leaving the building or structure then an inspection of each source in the building or

structure will be initiated until the source of emissions is identified.

The periodic visual emissions observation requirements of 40 CFR 63.1350(a)(4) are

outlined below.

1. Visual emissions observations are conducted periodically while the affected source is

in operation. The frequency for visual emissions varies according to the

following:

a. Initially, visual emissions observations must be conducted on each affected

source on a monthly basis;

b. If no visible emissions are observed in six consecutive monthly tests for any

affected source, the frequency of visible emissions observations may be

decreased from monthly to semi-annually for that affected source.

c. If no visible emissions are observed during the semi-annual test for any

affected source, the frequency of visible emissions observations may be

decreased from semi-annually to annually for that affected source.

d. If visible emissions are observed during any semi-annual or annual test,

visible emissions observations of that affected source must resume on a

monthly basis and maintain that schedule until no visible emissions are

observed in six consecutive monthly tests.

2. The procedures of Method 22 of appendix A of part 60 will be used for all visual

emissions observations.

3. The duration of the Method 22 test is one minute.
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4. If visible emissions are observed during any Method 22 test, conduct a 6-minute

Method 9 test. The Method 9 test must begin within one hour of any

observation of visible emissions.
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Appendix C: Applicable Limits and Requirements From 40 CFR 63

 Subpart LLL
123 

Applicable Limits and Requirements From 40 CFR 63 Subpart LLL-National

Emission Standards for Hazardous Air Pollutants From the Portland Cement

Manufacturing Industry,

Applicability and designation of affected facility

(a) The affected sources subject to this subpart are:

(1) Each kiln and in-line kiln/raw mill.

(2) Each clinker cooler.

(3) Each raw mill.

(4) Each finish mill.

(5) Each raw material dryer.

(6) Each raw material, clinker, or finished product storage bin.

(7) Each conveying system transfer point.

(8) Each bagging system.

(9) Each bulk loading or unloading system.

(b) The first affected source in the sequence of materials handling operations subject to this

 subpart is the raw material storage, which is just prior to the raw mill.

 The primary and secondary crushers and any other equipment of the on-site nonmetallic

 mineral processing plant which precedes the raw material storage are not subject to this

 subpart. Furthermore, the first conveyor transfer point subject to this subpart is the transfer

 point associated with the conveyor transferring material from the raw material storage to the

 raw mill, emission unit 0300-4-F.

 40 CFR 63.1340

Emission Standards and Operating Limits

Standards for kilns and in-line kiln/raw mills.

(a) The permittee shall not cause to be discharged into the atmosphere from any kiln or in-line

kiln/raw mill (including any associated alkali bypass) any gases which:

(1) Contain particulate matter in excess of 0.15 kg per metric ton (0.30 lb. per ton) of feed (dry

basis) to the kiln.

(2) Exhibit greater than 20 percent opacity.

(3) Contain D/F (tetra-, penta-, hexa-, hepta-, and octa-chlorinated dibenzo dioxins and furans)

in excess of:

(i) 0.20 ng per dscm (8.7E-11 gr per dscf) (TEQ) corrected to seven percent oxygen:

or

(ii) 0.40 ng per dscm (1.7E-10 gr per dscf) (TEQ) corrected to seven percent oxygen,

when the average of the performance test run average temperatures at the inlet to

 particulate matter control device is 204 o

C (400 oF) or less.

40 CFR 63.1343(b)

Operating limits for kilns and in-line kiln/raw mills

(a) The permittee must operate the in-line kiln/raw mill such that:

(1) When the raw mill of the in-line kiln/raw mill is operating, the applicable temperature

limit for the main in-line kiln/raw mill exhaust, specified in paragraph (b) of this section
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and established during the performance test when the raw mill was operating is not

exceeded.

(2) When the raw mill of the in-line kiln/raw mill is not operating, the applicable temperature

limit for the main in-line kiln/raw mill exhaust, specified in paragraph (b) of this section and

established during the performance test when the raw mill was not operating is not

exceeded.

 (3) The applicable temperature for the alkali bypass, specified in paragraph (b) of this section

and established during the performance test when the raw mill was operating is not

exceeded.

(b) The temperature limit for affected sources meeting the limits of paragraphs (a)(1) through

(a)(3)of this section is determined in accordance with paragraph (b)(3)(iv) of Performance

testing requirements.

 40 CFR 63.1344

Standards for clinker coolers

(a) The permittee shall not cause to be discharged into the atmosphere from any clinker cooler any

gases which:

(1) contain particulate matter in excess of 0.050 kg per Mg (0.10 lb per ton) of feed (dry basis)

to the kiln.

(2) exhibit opacity greater than ten (10) percent.

 40 CFR 63.1345

Standards for new and reconstructed raw material dryers

 The permittee shall not cause to be discharged into the atmosphere from any new or

 reconstructed raw material dryer any gases which exhibit opacity greater than ten (10) percent.

 40 CFR 63.1346

Standards for raw and finish mills

 The permittee shall not cause to be discharged into the atmosphere from the mill sweep

 or air separator air pollution control devices of any raw or finish mill any gases which

 exhibit opacity greater than ten (10) percent.

 40 CFR 63.1347

Standards for affected sources other than kilns; in-line kiln/raw mills; clinker coolers;

 new and reconstructed raw material dryers; and raw and finish mills

The permittee shall not cause to be discharged into the atmosphere from any new or

existing raw material, clinker, or finished product storage bin; conveying system transfer

point; bagging system; or any existing raw material dryer any gases which exhibit opacity in

excess of ten percent.

40 CFR 63.1348

Monitoring and Compliance Provisions

Performance testing requirements

(a) The owner or operator shall demonstrate initial compliance with the above listed emission
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limits using the test methods and procedures in paragraph (b) of this section and 40 CFR 63.7.

Performance tests shall be documented in complete test reports that contain the information

required by paragraphs (a)(1) through (a)(10) of this section, as well as other relevant

information. The plan to be followed during testing shall be made available to the Administrator

prior to testing, if requested.

(1) A brief description of the process and the air pollution control system;

(2) Sampling location description(s);

(3) A description of sampling and analytical procedures and any modifications to standard

procedures;

(4) Test results;

(5) Quality assurance procedures and results;

(6) Records of operating conditions during the test, preparation of standards, and calibration

procedures;

(7) Raw data sheets for field sampling and field and laboratory analyses;

(8) Documentation of calculations;

(9) All data recorded and used to establish parameters for compliance monitoring; and

(10)Any other information required by the test method.

(b) Performance tests to demonstrate compliance with this subpart shall be conducted as

specified in paragraphs (1) to (4) of this section.

(1) The permittee shall demonstrate initial compliance for in-line kiln/raw mill particulate

matter emissions by conducting separate performance tests as specified in paragraphs

(b)(1)(i) to (b)(1)(iii) of this section while the raw mill of the in-line kiln/raw mill is under

normal operating conditions and while the raw mill of the in-line kiln/raw mill is not

operating. The permittee shall demonstrate initial compliance for clinker cooler particulate

matter emissions by conducting a performance test as specified in paragraphs

(b)(1)(i) to (b)(1)(iii) of this section. The opacity exhibited during the period of the Method

5 of Appendix A CFR Part 60 performance tests required by paragraph (b)(1)((i) of this

section shall be determined as required in paragraphs (b)(1)(i) through (iv) of this section.

EPA Method 5 of Appendix A CFR Part 60 shall be used to determine Particulate Matter

(PM) emissions. Each performance test shall consist of three separate runs under the

conditions that exist when the affected source is operating at the represented performance

conditions in accordance with 40 CFR 63.7(e).

(i) Each run shall be conducted for at least one hour, and the minimum sample volume

shall be 0.85 dscm (30 dscf). The average of the three runs shall be used to

determine compliance.

(ii) Suitable methods shall be used to determine the in-line kiln/raw mill feed rate,

except for fuels, for each run.

(iii) The emission rate, E, of PM shall be computed for each run using:

E=(CsQsd)/P

Where:

E = emission rate of particulate matter, kg/Mg of kiln feed.

Cs = concentration of PM, kg/dscm.

Qsd = volumetric flow rate of effluent gas, dscm/hr.

P = total kiln feed (dry basis), Mg/hr.

(iv)The opacity exhibited during the Method 5 test required by(b) (1)(i) above shall
126 

be determined through the use of a continuous opacity monitor (COM). The

maximum six-minute average opacity during the three Method 5 test runs shall be

determined during each Method 5 test run and used to demonstrate initial

 compliance with the applicable opacity limits of the kiln/raw mill.

 (2) The owner or operator of any affected sources subject to limitations on opacity under

 this subpart that is not subject to (b)(1) of this section shall demonstrate initial

 compliance with the affected source opacity limit by conducting a test in accordance

 Method 9 of Appendix A CFR Part 60. The performance test shall be conducted under

 the conditions that exist when the affected source is operating at the represented

performance conditions in accordance with 40 CFR 63.7(e). The maximum six-minute

average opacity exhibited during the test period shall be used to determine whether the

affected source is in compliance with the standard. The duration of the Method 9

performance test shall be

 3-hours (30 6-minute averages), except that the duration of the of the Method 9

 performance test may be reduced to 1-hour if (a) there are no individual readings greater

 than 10 percent opacity, and (b) there are no more than three readings of 10 percent for

 the first 1-hour period.

(3) The owner or operator of an affected source subject to limitations on D/F emissions

shall demonstrate initial compliance with the D/F emission limit by conducting a

performance test using Method 23 of Appendix A CFR Part 60. The owner or operator

 of an in-line kiln/raw mill shall demonstrate initial compliance by conducting separate

 performance tests while the raw mill of the in-line kiln/raw mill is under normal

operating conditions and while the raw mill of the in-line kiln/raw mill is not operating.

 (i) Each performance test shall consist of three separate runs; each run shall be

 conducted under the conditions that exist when the affected source is operating at

the represented performance conditions in accordance with 40 CFR 63.7(e)

 The duration of each run shall be at least three hours and the sample volume for

 each run shall be at least 2.5 dscm (90 dscf). The concentration shall be determined

for each run and the arithmetic average of the concentrations measured for the three

runs shall be calculated and used to determine compliance.

(ii) The temperature at the inlet to the kiln/raw mill Particulate Matter Control

Device (PMCD), and the temperature at the inlet to the alkali bypass PMCD

must be continuously recorded during the period of the Method 23 test, and the

temperature records must be included in the performance test report.

(iii) One-minute average temperatures must be calculated for each minute of each run

of the test.

(iv) The run average temperature must be calculated for each run, and the average of

the run average temperatures must be determined and included in the

performance test report and will determine the applicable temperature limit in

accordance with paragraph (b) of Operating limits for kilns and in-line kiln/raw

mills.

(c) Except as provided in paragraph (e) of this section, performance tests required under

paragraph (b)(1) shall be repeated every five years, except that the initial performance test of

opacity for the in-line kiln/raw mill and clinker cooler is not required.

(d) Performance tests D/F required under paragraph (b)(3) of this section shall be repeated every

30 months. 
127 

(e) (1) If a source plans to undertake a change in operations that may adversely affect compliance

with an applicable D/F standard under this subpart, the source must conduct a performance

test and establish new temperature limit(s) as specified in paragraph (b)(3) of this section.

 (2) If a source plans to undertake a change in operations that may adversely affect compliance

with an applicable PM standard under §63.1343, the source must conduct a performance test

as specified in paragraph (b)(1) of this section.

(3) In preparation for and while conducting a performance test required in paragraph (e)(1) of

this section, a source may operate under the planned operational change conditions for a

period not to exceed 360 hours. Provided that the conditions in paragraphs (e)(3)(i) through

(iv) of this section are met. The source shall submit temperature and other monitoring data

that are recorded during the pretest operations.

(i) The source must provide the administrator written notice at least 60 days prior to

 undertaking an operational change that may adversely affect compliance with an

 applicable standard under this subpart, or as soon as practicable where 60 days

 advance notice is not feasible. Notice provided under this paragraph shall include a

 description of the planned change, the emissions standards that may be affected by

 the change, and a schedule for completion of the performance test required under

 paragraph (e)(1) of this section, including when the planned operational change

 period would begin.

(ii) The performance test results must be documented in a test report according to

 paragraph (a) of this section.

(iii) A test plan must be made available to the Administrator prior to testing, if

 requested.

(iv) The performance test must be conducted, and it must be completed within 360

hours after the planned operational change period begins.

(f) The table below provides a summary of the performance test requirements of this section.

40 CFR 63.1349

Summary of Performance Test Requirements

__________________________________________________________________________

 Affected source and pollutant Performance test

__________________________________________________________________________

New and existing kiln and in-line kiln/raw mill PM EPA Method 5(1)

New and existing kiln and in-line kiln/raw mill Opacity COM

New and existing kiln and in-line kiln/raw mill D/F EPA Method 23(2)

New and existing clinker cooler PM EPA Method 5(1)

New and existing clinker cooler Opacity COM

New and existing raw and finish mill Opacity EPA Method 9(1)

New and existing raw material dryer and materials EPA Method 9(1)

handling processes(raw material storage, clinker storage,

finished product storage, conveyor transfer points, baging,

and bulk loading and unloading systems) Opacity

___________________________________________________________________________

(1) Required initially and every five (5) years thereafter.

(2) Required initially and every 30 months thereafter.
128 

Monitoring requirements

(a) The owner or operator of this facility shall prepare for each affected source subject to the

provisions of this subpart, a written operations and maintenance plan. The plan shall be

submitted to the Administrator for review and approval as part of the application for a part 70

permit and shall include the following information:

(1) Procedures for proper operation and maintenance of the affected source and air

pollution control devices in order to meet the emission limits and operating limits listed

above under Emission Standards and Operating Limits;

(2) Corrective actions to be taken when required by paragraph (e) of this section;

(3) Procedures to be used during an inspection of the components of the combustion system

 of each kiln and each in-line kiln/raw mill located at the facility at least once per year;

 and

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

standards under Standards for new and reconstructed raw material dryers, and

Standards for affected sources other than kiln;, in-line kiln/raw mills; clinker coolers;

new and reconstructed raw material dryers; and raw and finish mills. Such procedures

must include the provisions of (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 of 40 CFR

60. 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 semiannually 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 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 of 40 CFR 60. The Method 9 test must begin within one hour of

any observation of visible emissions.

(v) The requirement to conduct a Method 22 visible emissions monitoring under this

subsection shall not apply to any totally enclosed conveying system transfer

point regardless of the location of the transfer point. "Totally enclosed conveying

system transfer point" shall mean a conveying system transfer point that is enclosed

on all sides, top, and bottom.

 (vi) If any partially enclosed or unenclosed conveying system transfer point is located in

 a building, the owner or operator of the portland cement plant shall have the option

to conduct a Method 22 visible emissions monitoring test according to the

requirements of (i) to (iv), above, for each conveying system transfer point within

the building or for the building itself, according to (vii) below.

(vii) If visible emissions from a building are monitored, the requirements of (i) through
129 

(iv) above apply to the monitoring of the building, and you must also do the

following: Test visible emissions from each side, roof and vent of the building for

at least one minute. The test must be conducted under normal operating conditions.

(b) Failure to comply with any provision of the operations and maintenance plan developed in

accordance with paragraph (a) of this section shall be a violation of the standard.

(c) The owner or operator of the kiln or in-line kiln/raw mill shall monitor opacity where

emissions are vented from these affected sources and the alkali bypass.

(1) The owner or operator shall install, calibrate, and continuously operate a continuous

 opacity monitor (COM) to continuously monitor the opacity of the emissions discharged

to the atmosphere. The COM shall be installed, maintained, calibrated, and operated as

required by 40 CFR 63 Subpart A General Provisions, and according to Performance

Specifications 1 (PS-1) of 40 CFR 60, Appendix B.

(2) To remain in compliance, the opacity must be maintained such that the 6-minute average

opacity for any-minute block period does not exceed 20 percent. If the average opacity for

any 6-minute block period exceeds 20 percent, this shall constitute a violation of the

standard.

(d) The owner or operator of a clinker cooler shall monitor opacity at each point where

emissions are vented from the clinker cooler in accordance with paragraphs (d)(1) and (d)(2) of

this paragraph.

(1) The owner or operator shall install, calibrate, and continuously operate a continuous

 opacity monitor (COM) to continuously monitor the opacity of the emissions discharged

to the atmosphere. The COM shall be installed, maintained, calibrated, and operated as

required by 40 CFR 63 Subpart A General Provisions, and according to Performance

Specifications 1 (PS-1) of 40 CFR 60, Appendix B.

(2) To remain in compliance, the opacity must be maintained such that the 6-minute average

opacity for any-minute block period does not exceed 10 percent. If the average opacity for

any 6-minute block period exceeds 10 percent, this shall constitute a violation of the

standard.

(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 separator PMCDs of these affected sources,

in accordance with the procedures of Method 22 of 40 CFR 60, Appendix A . The Method 22

test shall be conducted while the affected source is conditions that exist when the affected

source is operating at the represented performance conditions in accordance with 40 CFR

63.7(e). The duration of the Method 22 test shall be six minutes. If visible emissions are

observed during the Method 22 visible emissions test, the

owner or operator must:

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

operations and maintenance plan developed in accordance with paragraphs (a)(1) and

(a)(2) of this section; and

(2) Within 24 hours of the end of the Method 22 test in which visible emissions were

observed, conduct a visual opacity test of each stack from which visible emissions

were observed in accordance with Method 9 of 40 CFR 60, Appendix A.

The duration of the Method 9 test shall be thirty minutes.
130 

(f) The owner or operator of an affected source subject to a limitation on D/F emissions shall

monitor D/F emissions in accordance with paragraphs (f)(1) through (f)(6) of this section.

(1) The owner or operator shall install, calibrate, maintain, and continuously operate a

continuous monitor to record the temperature of the exhaust gases from the kiln, in-line

kiln/raw mill and alkali bypass, if applicable, at the inlet to, or upstream of, the kiln, inline kiln/raw mill and/or alkali bypass PM control devices.

(i) The recorder response range must include zero and 1.5 times either of the

average temperatures established according to the requirements in (b)(3)(iv) of

Performance testing requirements.

(ii) The reference method must be a National Institute of Standards and Technology

 calibrated reference thermocouple-potentiometer system or alternate reference,

subject to approval by the Administrator.

(2) The owner or operator shall monitor and continuously record the temperature of the

exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the

inlet to the kiln, in-line kiln/raw mill and/or alkali bypass PMCD.

(3) The three-hour rolling average temperature shall be calculated as the average of 180

successive one-minute average temperatures.

(4) Periods of time when one-minute averages are not available shall be ignored when

calculating three-hour rolling averages. When one-minute averages become

available, the first one-minute average is added to the previous 179 values to calculate

the three-hour rolling average.

(5) When the operating status of the raw mill of the in-line kiln/raw mill is changed from

off to on, or from on to off the calculation of the three-hour rolling average temperature

must begin anew without considering previous readings.

(6) The calibration of all thermocouples and other temperature sensors shall be verified at

least once every three months.

(g) The owner or operator of any kiln or in-line kiln/raw mill subject to a D/F emission limit

under this subpart shall conduct an inspection of the components of each kiln or in-line

kiln/raw mill at least once per year.

(h) The owner or operator of an affected source subject to a limitation on opacity under

Standards for new and reconstructed raw material dryers, and Standards for affected sources

other than kiln;, in-line kiln/raw mills; clinker coolers; new and reconstructed raw material

dryers; and raw and finish mills shall monitor opacity in accordance with the operation and

maintenance plan developed in accordance with paragraph (a) of this section.

(i) The owner or operator of an affected source subject to a particulate matter standard under

Standards for kilns and in-line kiln/raw mills shall install, calibrate, maintain and operate a

particulate matter continuous emission monitoring system (PM CEMS) to measure the

particulate matter discharged to the atmosphere. The compliance deadline for installing the PM

CEMS and all requirements relating to performance of the PM CEMS and implementation of

the PM CEMS is deferred pending further rulemaking.

(j) An owner or operator may submit an application to the Administrator for approval of

alternate monitoring requirements to demonstrate compliance with the emission standards of

this subpart, except for emission standards for THC, subject to the provisions of paragraphs

(j)(1) to (j)(6) of this section.
131 

(1) The Administrator will not approve averaging periods other than those specified in

this section, unless the owner or operator documents, using data or information, that the

longer averaging period will ensure that emissions do not exceed levels achieved during

the performance test over any increment of time equivalent to the time required to

conduct three runs of the performance test.

(2) If the application to use an alternate monitoring requirement is approved, the owner

or operator must continue to use the original monitoring requirement until approval is

received to use another monitoring requirement.

(3) The owner or operator shall submit the application for approval of alternate

monitoring requirements no later than the notification of performance test. The

application must contain the information specified in paragraphs (j)(3)(i) through

(j)(3)(iii) of this section:

(i) Data or information justifying the request, such as the technical or economic

infeasibility, or the impracticality of using the required approach;

(ii) A description of the proposed alternative monitoring requirement, including the

operating parameter to be monitored, the monitoring approach and technique, the

averaging period for the limit, and how the limit is to be calculateed; and

(iii) Data or information documenting that the alternative monitoring requirement

would provide equivalent or better assurance of compliance with the relevant

emission standard.

(4) The Administrator will notify the owner or operator of the approval or denial of the

application within 90 calendar days after receipt of the original request, or within 60

calendar days of the receipt of any supplementary information, whichever is later.

The Administrator will not approve an alternative monitoring application unless it would

provide equivalent or better assurance of compliance with the relevant emission

standard. Before disapproving any alternate monitoring application, the Administrator

will provide:

(i) Notice of the information and findings upon which the intended disapproval is

based; and

(ii) Notice of opportunity for the owner or operator to present additional supporting

information before final action is taken on the application. This notice will

specify how much additional time is allowed for the owner or operator to

provide additional supporting information.

(5) The owner or operator is responsible for submitting any supporting information in a

timely manner to enable the Administrator to consider the application prior to the

performance test. Neither submittal of an application, nor the Administrator's failure to

prove or disprove the application relieves the owner or operator of the responsibility to

comply with any provision of this subpart.

(6) The Administrator may decide at any time, on a case-by-case basis that additional or

alternative operating limits, or alternative approaches to establishing operating limits,

are necessary to demonstrate compliance with the emission standards of this subpart.

40 CFR 63.1350

Reporting, and Recordkeeping

Reporting requirements

(a) The reporting provisions of subpart A of this part that apply and those that do not apply to 
132 

 owners or operators of affected sources subject to this subpart are listed in Table 1 of this

 subpart. If any State requires a report that contains all of the information required in a

 report that contains all of the information required in a report listed in this section, the owner or

operator may send the Administrator a copy of the report sent to the State to satisfy the

requirements of this section for that report.

(b) The owner or operator of an affected source shall comply with the reporting requirements

specified in Sec. 63.10 of the general provisions of this part 63, subpart A as follows:

(1) As required by Sec. 63.10(d)(2), the owner or operator shall report the results of

 performance tests as part of the notification of compliance status.

(2) As required by Sec. 63.10(d)(3), the owner or operator of an affected source shall

 report the opacity results from tests required by Sec. 63.1349.

(3) As required by Sec. 63.10(d)(4), the owner or operator of an affected source who is

 required to submit progress reports as a condition of receiving an extension of

 compliance under Sec. 63.6(i) shall submit such reports by the dates specified in the

 written extension of compliance.

(4) As required by Sec. 63.10(d)(5), if actions taken by an owner or operator during a

 startup, shutdown, or malfunction of an affected source (including actions taken to

 correct a malfunction) are consistent with the procedures specified in the source's

 startup, shutdown, and malfunction plan specified in Sec. 63.6(e)(3), the owner or

 operator shall state such information in a semiannual report. Reports shall only be

 required if a startup, shutdown, or malfunction occurred during the reporting period.

 The startup, shutdown, and malfunction report may be submitted simultaneously

 with the excess emissions and continuous monitoring system performance reports;

 and

(5) Any time an action taken by an owner or operator during a startup, shutdown, or

 malfunction (including actions taken to correct a malfunction) is not consistent with

 the procedures in the startup, shutdown, and malfunction plan, the owner or operator

 shall make an immediate report of the actions taken for that event within 2 working

 days, by telephone call or facsimile (FAX) transmission. The immediate report shall

 be followed by a letter, certified by the owner or operator or other responsible

 official, explaining the circumstances of the event, the reasons for not following the

 startup, shutdown, and malfunction plan, and whether any excess emissions and/or

 parameter monitoring exceedances are believed to have occurred.

 (6) As required by Sec. 63.10(e)(2), the owner or operator shall submit a written

 report of the results of the performance evaluation for the continuous monitoring

 system required by Sec. 63.8(e). The owner or operator shall submit the report

simultaneously with the results of the performance test.

 (7) As required by Sec. 63.10(e)(2), the owner or operator of an affected source using a

 continuous opacity monitoring system to determine opacity compliance during any

 performance test required under Sec. 63.7 and described in Sec. 63.6(d)(6) shall report

the results of the continuous opacity monitoring system performance

 evaluation conducted under Sec. 63.8(e).

(8) As required by Sec. 63.10(e)(3), the owner or operator of an affected source equipped

with a continuous emission monitor shall submit an excess emissions and continuous

monitoring system performance report for any event when the continuous monitoring

system data indicate the source is not in compliance with the applicable emission

limitation or operating parameter limit.
133 

 (9) The owner or operator shall submit a summary report semiannually which contains

 the information specified in Sec. 63.10(e)(3)(vi). In addition, the summary report

 shall include:

(i) All exceedences of maximum control device inlet gas temperature limits

 specified in Sec. 63.1344(a) and (b);

 (ii) All failures to calibrate thermocouples and other temperature

 sensors as required under Sec. 63.1350(f)(7) of this subpart; and

 (iii) All failures to maintain the activated carbon injection rate, and the activated

 carbon injection carrier gas flow rate or pressure

 drop, as applicable, as required under Sec. 63.1344(c).

 (iv) The results of any combustion system component inspections conducted within

 the reporting period as required under Sec. 63.1350(i).

(v)All failures to comply with any provision of the operation and

 maintenance plan developed in accordance with Sec. 63.1350(a).

 (10) If the total continuous monitoring system downtime for any CEM

 or any continuous monitoring system (CMS) for the reporting period

 is ten percent or greater of the total operating time for the reporting

 period, the owner or operator shall submit an excess emissions and continuous

 monitoring system performance report along with the summary report.

 40 CFR 63.1354

Recordkeeping requirements

(a) The permittee shall maintain files of all information (including all reports and notifications)

 required by this section recorded in a form suitable and readily available for inspection and

 review as required by Sec. 63.10(b)(1). The files shall be retained for at least five years

 following the date of each occurrence, measurement, maintenance, corrective action, report,

 or record. At a minimum, the most recent two years of data shall be retained on site. The 

 remaining three years of data may be retained off site. The files may be maintained on

 microfilm, on a computer, on floppy disks, on magnetic tape, or on

 microfiche.

(b) The owner or operator shall maintain records for each affected source as required by Sec.

 63.10(b)(2) and (b)(3) of this part; and

(1) All documentation supporting initial notifications and notifications of compliance

 status under Sec. 63.9;

 (2) All records of applicability determination, including supporting analyses; and

(3) If the owner or operator has been granted a waiver under Sec. 63.8(f)(6),

 any information demonstrating whether a source is meeting the requirements

 for a waiver of recordkeeping or reporting requirements.

(c) In addition to the recordkeeping requirements in paragraph (b) of this section, the

 owner or operator of an affected source equipped with a continuous monitoring

 system shall maintain all records required by Sec. 63.10(c).

 40 CFR 63.1355

 Temporary, conditioned exemption from particulate matter and opacity standards

(a) Subject to the limitations of paragraphs (b) through (f) of this section, an owner or

 operator conducting PM CEMS correlation tests (that is, correlation with manual stack
134 

 methods) is exempt from:

(1) Any particulate matter and opacity standards of part 60 or part 63 of this chapter that

 are applicable to cement kilns and in-line kiln/raw mills.

(2) Any permit or other emissions or operating parameter or other limitation on

 workplace practices that are applicable to cement kilns and in-line kiln raw mills

 to ensure compliance with any particulate matter and opacity standards of this part or

 part 60 of this chapter.

(b) The permittee must develop a PM CEMS correlation test plan. The plan must be submitted

 to the Administrator for approval at least 90 days before the correlation test is scheduled to

 be conducted.

 The plan must include:

 (1) The number of test conditions and the number of runs for each test condition;

(2) The target particulate matter emission level for each test condition;

(3) How the operation of the affected source will be modified to attain the desired

 particulate matter emission rate; and

(4) The anticipated normal particulate matter emission level.

(c) The Administrator will review and approve or disapprove the correlation test plan in

 accordance with Sec. 63.7(c)(3)(i) and (iii). If the Administrator fails to approve or

 disapprove the correlation test plan within the time period specified in Sec. 63.7(c)(3)(iii),

 the plan shall be considered approved, unless the Administrator has requested additional

 information.

(d) The stack sampling team must be on-site and prepared to perform correlation testing no

 later than 24 hours after operations are modified to attain the desired particulate matter

 emissions concentrations, unless the correlation test plan documents that a longer period

 is appropriate.

(e) The particulate matter and opacity standards and associated operating limits and

 conditions will not be waived for more than 96 hours, in the aggregate, for a correlation

 test, including all runs and conditions.

(f) The owner or operator must return the affected source to operating conditions indicative of

 compliance with the applicable particulate matter and opacity standards as soon as possible

 after correlation testing is completed.

 40 CFR 63.1357

Delegation of authority

(a) In delegating implementation and enforcement authority to a State under subpart E of this

 part, the authorities contained in paragraph (b) of this section shall be retained by the

 Administrator and not transferred to a State.

(b) Authority which will not be delegated to States:

 (1) Approval of alternative non-opacity emission standards under

 Sec. 63.6(g).

(2) Approval of alternative opacity standards under Sec. 63.6(h)(9).

(3) Approval of major changes to test methods under Secs. 63.7(e)(2)(ii) and 63.7(f).
135 

 A major change to a test method is a modification to a federally enforceable test

 method that uses unproven technology or procedures or is an entirely new method

 (sometimes necessary when the required test method is unsuitable).

(4) Approval of major changes to monitoring under Sec. 63.8(f). A major change to

 monitoring is a modification to federally enforceable monitoring that uses unproven

 technology or procedures, is an entirely new method (sometimes necessary when the

 required monitoring is unsuitable), or is a change in the averaging period.

(5) Waiver of recordkeeping under Sec. 63.10(f).

 40 CFR 63.1358

Authority for Requirement: 40 CFR 63 Subpart LLL and Subpart A

 567 IAC 23.1(4)"bl"
136 

Appendix D: IDNR Air Quality Policy 3-b-08 (Opacity)