DAQ-2024-008175

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DAQC-521-24
Site ID 10303 (B1)

MEMORANDUM

TO: FILE – ASH GROVE CEMENT COMPANY – Leamington Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: May 28, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Juab County,
FRS# UT0000004902300015

DATE OF INSPECTION: May 21, 2024

SOURCE LOCATION: Highway 132, Leamington, Utah

MAILING ADDRESS: P.O. Box 38069, Leamington, Utah 84638

SOURCE CONTACT: Cody Watkins – Plant Engineer, 435-857-1283

OPERATING STATUS: Operating

PROCESS DESCRIPTION: Ash Grove Cement Company manufactures Portland cement at the
Leamington facility. There is a limestone quarry and a cement
manufacturing plant on site.

At the quarry, a process of drilling and blasting is used to loosen
limestone deposits. After blasting, a bulldozer cleans up the area and
pushes access roads through the blasted materials. Front-end loaders fill
haul trucks with the blasted material and transfer the material to a
stationary crusher. Waste rock is separated and transferred to the dump
slope. The limestone is crushed in the stationary crusher and transferred
to storage piles by conveyor. The main crusher has water sprays at the
bin and the drop point. A three-sided containment is currently in place.
The unit has three sides with curtain front and water sprays. A baghouse
controls emissions from the crusher face and first transfer. There is a
baghouse at the end of the overland belt and first feed drop. Water sprays
are on the last feed point and on the storage, pile drops.

A reclaiming system uses a series of rakes to pull the crushed limestone
from the storage piles onto a conveyor, which transports it to the raw
material storage silos. Shale, sandstone, and iron slag are transported to
the plant from offsite and dumped into an underground hopper. From the
hopper, an enclosed elevator carries the materials to raw material storage
silos. Silos are equipped with a topside baghouse or bin vent, which
operates during loading and transfer processes. From the raw material

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storage silos, the raw limestone is weighed and combined with the shale,
sandstone, and iron in appropriate proportions and conveyed to the raw
mill for grinding. The raw mill is a vertical impact pistil crusher
controlled by the main baghouse. The finely ground raw mill product is
sent to the kiln feed silos for mixing and storage. From these storage
silos, the ground aggregate is conveyed through both the preheater and
the kiln. In the kiln, the material is changed into cement clinker by a
process involving countercurrent heat transfer. The preheater and kiln are
fired by coal, natural gas, tire derived fuel, cherry pits, or fuel oil. The
company does not currently use used oil fuels. The kiln product (clinker)
goes to the clinker cooler and then to storage silos. The cooled clinker is
then conveyed to the finish mill where gypsum is added to the clinker.
These materials are ground into a finished product. The finished product
(cement powder) is then conveyed to storage silos to await shipping. The
load out facility is equipped to load trucks and rail cars. All processes
from the storage piles on are controlled by baghouses. The source has
computerized systems to track the operating parameters and maintenance
functions of this plant.

APPLICABLE
REGULATIONS: Title V Operating Permit 2300015005, September 22, 2023,
Last revision May 13, 2024
40 CFR 60 Subpart A-General Provisions,
40 CFR 60 Subpart Y-Standards of Performance for Coal Preparation
and Processing Plants,
40 CFR 60 Subpart OOO-Standards of Performance for Nonmetallic
Mineral Processing Plants,
40 CFR 60 Subpart IIII-Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines, 4
0 CFR 60 Subpart JJJJ-Standards of Performance for Stationary Spark
Ignition Internal Combustion Engines,
40 CFR 63 Subpart A-General Provisions,
40 CFR 63 Subpart LLL-National Emission Standards for Hazardous Air
Pollutants from the Portland Cement Manufacturing Industry, and
40 CFR 63 Subpart ZZZZ-National Emission Standards for Hazardous
Air Pollutants for Stationary Reciprocating Internal Combustion Engines.

SOURCE INSPECTION
EVALUATION:
Title V Operating Permit 2300015004

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: Not evaluated. This is a statement of fact.

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I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. The permittee appeared to be operating in compliance with this permit. See
status of each condition below for details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 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 this permit. (R307-415-6a(6)(b))

I.C.3 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 this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 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 shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: In compliance. It appears that all conditions have been complied with.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

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I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: This permit expires on September 22, 2028.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: This permit expires on September 22, 2028.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: There are no challenges to any portion of this permit at this time.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. Permit fees have been paid as invoiced.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: Not evaluated. This is a statement of fact.

I.I Revision Exception.

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. (R307-415-6a(8))

Status: Not evaluated. This is a statement of fact.

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I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance. Entry into the facility was allowed for inspection and a records review.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All applications, forms, reports, and compliance certifications submitted
pursuant to this permit have contained certification as to truth, accuracy, and completeness by
a responsible official.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

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I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance. The most recent annual certification was submitted January 25, 2024. The
certification was reviewed under separate cover and found to meet the requirements of this
condition.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

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I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: Not evaluated. This is a statement of fact.

I.N Reserved

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: Not evaluated. This is a statement of fact.

I.P Off-permit Changes.
Off-permit changes are governed by R307-415-7d(2).

Status: Not evaluated. This is a statement of fact.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: Not evaluated. This is a statement of fact.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: Not evaluated. This is a statement of fact.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

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I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit.
(R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

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I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records are kept as required. Monitoring reports have been submitted every
six months. Deviation reports have been submitted as required.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

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I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: Not evaluated. This is a statement of fact.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance. Emission inventories have been submitted as required.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: Not evaluated. This is a statement of fact.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3 211.BF1: Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction of quarried
material to 3 inch minus sized material. The crusher is equipped with a baghouse and with water sprays
on the feed hopper. (pre-1983)

II.A.4 211.BF2: Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end
of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer point is equipped
with a baghouse & water sprays. (pre-1983)

II.A.5 315.SX1 thru 4: Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four silos are
controlled by one common baghouse (stack C125).

II.A.6 315.BF2: Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a baghouse.

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II.A.7 317.BF3: Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of the raw
mill where finely ground raw material is picked up. Combustion gases and fine raw materials are then
vented to a baghouse on the main stack (D38). The following equipment is installed: selective non-
catalytic reduction (SNCR) for NOx control; NOx, CO, total hydrocarbons, and oxygen (O2) CEMS;
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring
system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption
capacity. The carbon injection system is not an emission point as it is in an enclosed building.

II.A.8 412.BF1 and 2: Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a
baghouse.

II.A.9 411.BF1 and 2: Kiln Feed Blending Silos (2)
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are
controlled by one common baghouse.

II.A.10 414.BF1: Kiln Feed Alleviator
A baghouse controls particulate from the central material silo between the blending silos and the
preheater. Raw feed is removed from the system near the top of the preheater tower.

II.A.11 419.BF1: Clinker Cooler
Grate type cooler used for cooling clinker from the kiln prior to transfer to clinker storage. The clinker
cooler vent air is controlled by a baghouse on the clinker cooler stack (F31). A PM CPMS is installed.

II.A.12 419.BF8 and 419.BF10: Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor
belts. One baghouse (419.BF10) controls particulate from the outside clinker belt. The other conveyor and
transfer points are controlled by a second baghouse (419.BF8).

II.A.13 419.BF9: Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated when
loading the east and west clinker silos and the out-of-spec silo are controlled by a baghouse.

II.A.14 419.BF9: East Clinker Belt
Clinker from the clinker cooler is transferred into the East clinker silo by conveyor belt. The discharge
from the belt is controlled by a baghouse.

II.A.15 419.BF9: West Clinker Belt
Clinker from the clinker cooler is transferred into the West clinker silo by conveyor belt. The discharge
from the belt is controlled by a baghouse.

II.A.16 511.BF3: Clinker Reclaim Hopper
Imported clinker is fed to the clinker tunnel conveyor belt by the outside clinker hopper. Emissions during
transfer of clinker to the conveyor are controlled by a baghouse that discharges into the clinker tunnel.

II.A.17 511.BF1: East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions
during transfer of clinker to the conveyor are controlled by a baghouse that discharges into the clinker
tunnel.

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II.A.18 511.BF2: West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo. Emissions
during transfer of clinker to the conveyor are controlled by a baghouse that discharges into the clinker
tunnel.

II.A.19 511.BF4: Gypsum Silo Discharge
Gypsum is fed to the clinker tunnel conveyor belt from the gypsum storage silo. Emissions during transfer
of gypsum to the conveyor are controlled by a baghouse that discharges into the clinker tunnel.

II.A.20 512.SX1: Gypsum Silo
Gypsum is stored in the gypsum storage silo. A baghouse is installed on the gypsum storage silo to
control dust during loading.

II.A.21 514.BF2: Finish Mill
The finish mill (ball mill) grinds clinker and gypsum to produce finished cement product. Dust generated
during milling is controlled by a baghouse (stack G105).

II.A.22 514.BF1: Finish Mill Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized cement
particles to the finish mill. Dust generated by the finish mill separator is controlled by a baghouse (stack
G55).

II.A.23 611.BF1: Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A single
common baghouse is located on top of the silos (stack H7) and is used to control emissions during loading
and unloading operations.

II.A.24 611.BF3: North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a
baghouse during unloading from the silos for rail shipping.

II.A.25 611.BF2, 611.BF4, 611.BF5: South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is controlled by a
baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses
(611.BF4, 611.BF5) control emissions from the cement conveyor fluid slides and truck loading chutes.

II.A.26 41B.BF1: Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The coal
storage silo is equipped with a baghouse.

II.A.27 41B.BF2: Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and
are controlled by a baghouse.

II.A.28 316.BF1 thru 5: Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw mill feed.
This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are controlled by
five equivalent baghouses.

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II.A.29 511.BF1 thru 4: Clinker Tunnel Exitway
The clinker reclaim hopper baghouse (511.BF3), east clinker silo discharge baghouse (511.BF1), west
clinker silo discharge baghouse (511.BF2), and gypsum silo discharge baghouse (511.BF4) all discharge
in the clinker tunnel. Emissions are discharged through the tunnel exitway.

II.A.30 MHO: Materials Handling Operation
Includes the following emission units: 315.SX1 thru 4; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2;
412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.SX1; 611.BF1 thru
5; 512.BF2 & 3; 413.BF1.

II.A.31 316.BF6: Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a baghouse.

II.A.32 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS
consists of a screen and conveyors. Emissions are controlled by water sprays at the screen and material
handling drop points.

II.A.33 512.BF2 and 3: Limestone Silo & Belt
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt.
Emissions from the silo and conveyor are controlled by two baghouses. 512.BF2 discharges in the clinker
tunnel. 512.BF3 is located on top of the silo.

II.A.34 311.BC1: Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse controls emissions from the conveyor belt that
transfers the stacked material to the raw material silos.

II.A.35 GEN: Emergency Generators
One diesel-fired emergency generator rated at 762 hp (Kiln) permitted in 2022, one diesel-fired
emergency generator rated at 762 hp (Shipping) permitted in 2024, and two natural gas-fired emergency
generators rated at 304 hp each (Main office, control room) permitted in 2024.

II.A.36 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The system
includes the following equipment: elevator from baghouse (317.BE1), pneumatic air slide (317.AS12),
alkali silo (413.BN1), pug mill (413.MZ1), pug mill loadout (wetted material), fringe bin (Finish Mill)
(514.BN1), 14 inch knife gate (317.GA2), 8 inch knife gate (317.GA4), 8 inch air slides (317.AS21,
317.AS22, 317.AS23), surge bin (317.BN1), pneumatic blower system (413.BL2). Emissions from the
dust shuttle system are controlled by a baghouse on the fringe bin (514.BF3) and a baghouse on the alkali
silo (413.BF1).

II.A.37 Portable Crusher
Portable crusher used for crushing limestone. The portable crusher is not a stationary source and has no
unit specific applicable requirements.

II.A.38 Stockpiles
Unit includes two stockpiles: one for coal storage (1 acre, 20,000 tpy annual throughput) and one for
alternative fuels (AF) and alternative raw materials (ARM) storage (0.25 acre, 8,000 tpy annual
throughput).

14
II.A.39 Miscellaneous Storage Tanks
Unit includes: one diesel storage tank (<2,000 gal), one gasoline storage tank (500 gal) that dispenses less
than 10,000 gallons per calendar month, and three ammonia storage tanks (8,000 gal each). No unit
specific applicable requirements.

Status: In compliance. No unapproved equipment was observed onsite. II.A.35 – the three new generators
have not been purchased yet.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

Unless otherwise specified in this permit, at all times, including periods of startup, shutdown, and
malfunction, the permittee shall, to the extent practicable, maintain and operate any permitted plant
equipment, including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director which may
include, but is not limited to, monitoring results, opacity observations, review of operating and
maintenance procedures, and inspection of the source. [Origin: DAQE-AN103030033-24]. [40 CFR
60.11(d), R307-401-4, R307-401-8(2)]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The facility appeared to be well maintained. A work order system is in place to
track maintenance. The facility is using a PM schedule through an electronic database called
Bentley. Additionally, an emergency work order system is in place to meet Portland Cement MACT
regulations.

15
II.B.1.b Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[Origin: 40 CFR 82 Subpart F]. [40 CFR 82.150(b)]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The permittee certified compliance with this condition in the most recent annual
compliance certification. All maintenance is done by third party vendor.

II.B.1.c Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle air
conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. [Origin:
40 CFR 82 Subpart B]. [40 CFR 82.30(b)]

II.B.1.c.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart B.

II.B.1.c.2 Recordkeeping:

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.c.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The permittee certified compliance with this condition in the most recent annual
compliance certification. All maintenance is done by third party vendor.

16
II.B.1.d Condition:

Unless otherwise specified in this permit, and except for blasting, visible emissions shall be no greater
than 20 percent opacity. [Origin: R307-305-3(1), DAQE-AN103030033-24]. [R307-305-3(1),
R307-401-8]

II.B.1.d.1 Monitoring:

(a) The permittee shall conduct a monthly 6-minute visible emissions test of each affected
source in accordance with 40 CFR 60, Appendix A, Method 22. The test shall 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 permittee may decrease the frequency of testing from monthly to semi-annually for that
affected source. If visible emissions are observed during any semi-annual test, the permittee
must resume testing of that affected source on a monthly basis and maintain that schedule
until no visible emissions are observed in six consecutive monthly tests.
(c) If no visible emissions are observed during the semi-annual test for any affected source, the
permittee may decrease the frequency of testing from semiannually to annually for that
affected source. If visible emissions are observed during any annual test, the permittee shall
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.
(d) If visible emissions are observed during any Method 22 test, the permittee shall conduct a
i. six-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, for point sources, or
ii. one-minute test of opacity with five second observation intervals in accordance with 40
CFR 51, Appendix M, Method 203C, or other EPA-approved testing method, as
acceptable to the Director, for fugitive emission sources.
The Method 9 or 203C test shall begin within one hour of any observation of visible
emissions.

II.B.1.d.2 Recordkeeping:

Records of visible emission tests performed and data required by 40 CFR 60, Appendix A,
Method 22, Method 9, or 40 CFR 51, Appendix M, Method 203C, or other EPA-approved testing
method, as acceptable to the Director, shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.1.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The permittee is conducting 6-minute tests on a weekly basis and is not using the
skip monitoring provisions. Records were provided during inspection and appeared complete. The
company is using a computer tracking system with readings done on tablet.

17
II.B.1.e Condition:

All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water
sprayed and/or chemically treated to control fugitive dust. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a condition to minimize fugitive dust as necessary to meet an
opacity limitation of 20 percent from fugitive dust sources. The permittee is not required to apply water to
surfaces during freezing conditions. If chemical treatment is to be used, the plan shall be pre-approved by
the Director. All disturbed surfaces not involved with operations shall be stabilized to minimize
generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [Origin:
DAQE-AN103030033-24]. [R307-401-8]

II.B.1.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.e.2 Recordkeeping:

Instances of water and/or chemical application to unpaved areas shall be recorded and maintained
by the permittee for all periods when the plant is in operation. The ambient temperature shall be
recorded any time water should be applied but cannot be due to freezing conditions. Records
demonstrating compliance with this condition and records of all methods used to control fugitive
dust shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. A fugitive dust control plan is followed. The permittee waters unpaved roads areas
as necessary. Watering records were provided during this inspection. FDCP was updated in 2022.

II.B.1.f Condition:

All paved roads and paved operational areas shall be swept and/or water sprayed to minimize fugitive
dust as necessary to maintain an opacity limitation of 20 percent from fugitive dust sources. The sweeping
and/or water spray shall be conducted as dry conditions warrant or as determined necessary by the
Director. [Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.f.2 Recordkeeping:

Instances of each sweeping event or water application to the paved areas shall be recorded and
maintained by the permittee for all periods when the plant is in operation. Records demonstrating
compliance with this condition shall be maintained in accordance with Provision I.S.1 of this
permit.

18
II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: A fugitive dust control plan is followed. The permittee sweeps and waters paved roads areas as
necessary. Sweeping logs were provided.

II.B.1.g Condition:

For all emission units subject to 40 CFR 63 Subpart LLL:
The permittee shall prepare and implement a written operations and maintenance (O&M) plan in
accordance with 40 CFR 63.1347(a). The plan shall include the following elements:
(1) Procedures for proper operation and maintenance of the affected source and air pollution control
devices in accordance with 40 CFR 63.1347(a)(1). The O&M plan shall address periods of startup
and shutdown.
(2) Corrective actions to be taken when required by 40 CFR 63.1350(f)(3).
(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.
Failure to comply with any provision of the O&M plan is a violation of the standard.
[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1347(a), 40 CFR 63.1347(b)]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

The permittee shall maintain files of all information (including all reports and notifications)
required by this condition in a form suitable and readily available for expeditious inspection and
review. Records shall be maintained in accordance with Provision I.S.1 of this permit and 40
CFR 63.1355.

II.B.1.g.3 Reporting:

One summary report shall be submitted semiannually for the hazardous air pollutants monitored
at each affected source. All reports shall be submitted in accordance with 40 CFR 63.1354 and as
specified in Section I of this permit.

Status: In compliance. 40 CFR 63.1354 requires “a summary report semiannually to the EPA via the
Compliance and Emissions Data Reporting Interface (CEDRI).” There is no reporting requirement
to Utah DAQ. The company complies with the O&MP section of this condition and 40 CFR
63.1347.

19
II.B.1.h Condition:

For all emission units subject to 40 CFR 63 Subpart LLL:
At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the Director which may
include, but is not limited to, monitoring results, review of operation and maintenance procedures, review
of operation and maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart LLL].
[40 CFR 63.1348(d)]

II.B.1.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.h.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. The
permittee shall keep records of actions taken during periods of malfunction to minimize
emissions in accordance with 40 CFR 63.1348(d) including corrective actions to restore
malfunctioning process and air pollution control and monitoring equipment to its normal or usual
manner of operation. (40 CFR 63.1355(g)(2)) Records shall be maintained in accordance with
Provision I.S.1 of this permit and 40 CFR 63.1355.

II.B.1.h.3 Reporting:

Reports shall be submitted in accordance with 40 CFR 63.1354 and as specified in Section I of
this permit.

Status: In compliance. The facility appeared to be well maintained. A work order system is in place to
track maintenance. The facility is using a PM schedule through an electronic database called
Bentley.

II.B.1.i Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouses unless otherwise
specified in this permit. [Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.1.i.1 Monitoring:

(a) The permittee shall conduct a monthly 6-minute visible emissions test of each affected
source in accordance with 40 CFR 60, Appendix A, Method 22. The test shall 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 permittee may decrease the frequency of testing from monthly to semi-annually for that
affected source. If visible emissions are observed during any semi-annual test, the permittee
must resume testing of that affected source on a monthly basis and maintain that schedule
until no visible emissions are observed in six consecutive monthly tests.
(c) If no visible emissions are observed during the semi-annual test for any affected source, the
permittee may decrease the frequency of testing from semi-annually to annually for that
affected source. If visible emissions are observed during any annual test, the permittee shall
20
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.
(d) If visible emissions are observed during any Method 22 test, the permittee shall conduct a 6-
minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-
approved testing method, as acceptable to the Director. The Method 9 test shall begin within
one hour of any observation of visible emissions.

II.B.1.i.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9, or other EPA-approved testing method, as acceptable to the Director, for each determination
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.i.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The permittee is conducting 6-minute tests on a weekly basis, and is not using the
skip monitoring provisions. Records were provided during inspection and appeared complete.

II.B.2 Conditions on Stationary Crusher (211.BF1).

II.B.2.a Condition:

The permittee shall operate water sprays or chemical dust suppression sprays to control fugitive
emissions. The sprays shall operate whenever dry conditions warrant or as determined necessary by the
Director. Water sprays shall not be required during periods of freezing temperatures. [Origin: DAQE-
AN103030033-24]. [R307-401-8]

II.B.2.a.1 Monitoring:

Visual inspections of the water or chemical dust suppression spray system(s) shall be made
weekly to ensure proper operating condition.

II.B.2.a.2 Recordkeeping:

An operator's log shall be maintained of all monitoring provisions listed above. Records of water
or chemical dust suppression spray system inspections shall be kept for all periods of operation
and the ambient temperature shall be recorded any time water should be applied but cannot be
due to freezing conditions. Records shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.2.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Water sprays are installed. Visual inspections are performed and recorded every
day of operation.

21
II.B.2.b Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse. [Origin: DAQE-
AN103030033-24]. [R307-401-8]

II.B.2.b.1 Monitoring:

Compliance with the visible emission limitation shall be demonstrated by one of the following
options.

Option A:
(I) The permittee shall monitor opacity by conducting daily visual emissions observations in
accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The duration of the
Method 22 test shall be 6 minutes.
(II) If visible emissions are observed during any Method 22 visible emissions test, the permittee
shall:
a) Initiate corrective actions, within one-hour; and
b) Within 24 hours of the end of the Method 22 test in which visible emissions were
observed, conduct a followup Method 22 test of each stack from which visible emissions
were observed during the previous Method 22 test. If visible emissions are observed
during the followup Method 22 test from any stack from which visible emissions were
observed during the previous Method 22 test, conduct a visual opacity test of each stack
in accordance with 40 CFR 60, Appendix A, Method 9, or other EPA-approved testing
method, as acceptable to the Director. The duration of the Method 9 test shall be 30
minutes.
(III) Performance Criteria:
a) The Method 22 test, and Method 9 test if applicable, shall be conducted while the
affected unit is operating at representative performance conditions.
b) The visual observer shall be familiar with 40 CFR, Appendix A, Method 22 and follow
Method 22 procedures. The opacity determination shall be conducted by a certified
visible emissions observer in accordance with 40 CFR 60, Appendix A, Method 9.
c) The observation shall be documented by the observer and all data required by 40 CFR
60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the
Director, shall be maintained if the opacity determination is conducted.

Option B:
(I) A BLDS shall be installed on the baghouse exhaust stack and generate a signal proportional
to PM concentration. An alarm shall sound when the signal exceeds a preset limit.
(II) The permittee shall maintain and operate the fabric filter such that the bag leak detector
alarm is not activated and alarm condition does not exist for more than 5 percent of the total
operating time in a 6-month block period. Each time the alarm activates, alarm time shall be
counted as the actual amount of time taken by the permittee to initiate corrective actions. If
inspection of the fabric filter demonstrates that no corrective actions are necessary, no alarm
time shall be counted.
(III) Performance Criteria:
a) For a positive-pressure fabric filter, the bag leak detector shall be installed in the exit
vent. For a negative-pressure or induced-air fabric filter, the bag leak detector shall be
installed downstream of the fabric filter. If multiple bag leak detectors are required (for
either type of fabric filter), detectors may share the system instrumentation and alarm.
b) The baseline output of the system shall be established as follows:
i) Adjust the range and the averaging period of the device; and
22
ii) Establish the alarm set points and the alarm delay time.
c) The sensor on the BLDS shall provide output of relative PM emissions.
d) The BLDS shall have an alarm that will activate automatically when it detects PM
emissions greater than or equal to 50% of scale during normal operating conditions.
e) The presence of an alarm condition shall be clearly apparent to facility operating
personnel.
f) The probe shall be inspected at least monthly for dust buildup.
g) Lens cleaning, O-ring replacement, and window value rechecks shall be performed at
least annually.
h) The BLDS shall be certified by the manufacturer to be capable of detecting PM
emissions at concentrations of 10 milligrams per actual cubic meter (0.0044 grains per
actual cubic foot) or less. "Certify" shall mean that the instrument manufacturer has
tested the instrument on gas streams having a range of particle size distributions and
confirmed by means of valid filterable PM tests that the minimum detectable
concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 grains
per actual cubic foot) or less.
i) All BLDS shall be installed, operated, adjusted, and maintained so that they are based on
the manufacturer's written specifications and recommendations.
j) After initial adjustment, the range, averaging period, alarm set points, or alarm delay
time shall not be adjusted except as specified in the BLDS standard operating procedure
(SOP). In no event shall the range be increased by more than 100 percent or decreased
by more than 50 percent over a 1 calendar year period unless a responsible official as
defined in R307-415-3 certifies in writing to the Director that the fabric filter has been
inspected and found to be in good operating condition.
k) The BLDS signal shall be monitored continuously. The instantaneous values from the
transmitter output shall be displayed and recorded. All alarms shall be logged
electronically.

II.B.2.b.2 Recordkeeping:

In addition to the recordkeeping requirements described in Provision I.S.1 of this permit, the
following records shall be maintained:
(a) The permittee shall continuously record the output from the BLDS during periods of normal
operation. Normal operation does not include periods when the BLDS is being maintained or
during startup, shutdown or malfunction.
(b) Alarm times as defined in Monitoring shall be recorded.
(c) Records of visual emission observations and visual opacity tests required by 40 CFR 60,
Appendix A, Methods 22 and 9 shall be maintained if a BLDS is not used.

II.B.2.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Monthly probe checks have been performed and recorded. Annual checks have
been performed. Alarms and corrective action records were made available during this inspection.
The BLDS system is online and is tracked on the control room monitor board.

23
II.B.3 Conditions on Raw Material Transfer (211.BF2).

II.B.3.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103030033-24].
[R307-401-8]

II.B.3.a.1 Monitoring:

(a) The permittee shall conduct a monthly 6-minute visible emissions test of each affected
source in accordance with 40 CFR 60, Appendix A, Method 22. The test shall 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 permittee may decrease the frequency of testing from monthly to semi-annually for that
affected source. If visible emissions are observed during any semi-annual test, the permittee
must resume testing of that affected source on a monthly basis and maintain that schedule
until no visible emissions are observed in six consecutive monthly tests.
(c) If no visible emissions are observed during the semi-annual test for any affected source, the
permittee may decrease the frequency of testing from semiannually to annually for that
affected source. If visible emissions are observed during any annual test, the permittee shall
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.
(d) If visible emissions are observed during any Method 22 test, the permittee shall conduct a
six-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director. The Method 9 test shall begin
within one hour of any observation of visible emissions.

II.B.3.a.2 Recordkeeping:

Records of visible emission tests performed and data required by 40 CFR 60, Appendix A,
Method 22 and 9, or other EPA-approved testing method, as acceptable to the Director, shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The permittee is conducting 6-minute tests on a weekly basis, and is not using the
skip monitoring provisions. Records were provided during inspection and appeared complete.

II.B.3.b Condition:

The permittee shall operate water sprays or chemical dust suppression sprays to control fugitive
emissions. The sprays shall operate whenever dry conditions warrant or as determined necessary by the
Director. Water sprays shall not be required during periods of freezing temperatures. [Origin: DAQE-
AN103030033-24]. [R307-401-8]

24
II.B.3.b.1 Monitoring:

Visual inspections of the water or chemical dust suppression spray system(s) shall be made
weekly to ensure proper operating condition.

II.B.3.b.2 Recordkeeping:

An operator's log shall be maintained of all monitoring provisions listed above. Records of water
or chemical dust suppression spray system inspections shall be kept for all periods of operation
and the ambient temperature shall be recorded any time water should be applied but cannot be
due to freezing conditions. Records shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.3.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily water spray inspections have been performed and recorded when the source
was operating.

II.B.4 Conditions on Kiln & Pre-Calciner and Raw Mill (317.BF3)

II.B.4.a Condition:

At all times, emissions of NOx shall not exceed 2.8 lbs per ton clinker based upon a 30-day rolling
average and 1,347.2 tons per rolling 12-month period. [Origin: DAQE-AN103030033-24, SIP Section
IX.H.23.a]. [R307-401-8, SIP Section IX.H.23.a]

II.B.4.a.1 Monitoring:

The permittee shall install, calibrate, maintain and continuously operate a continuous emissions
monitoring system that complies with all applicable sections of R307-170, UAC, 40 CFR 60.13,
and 40 CFR 60, Appendix B. While the affected emission unit is operating, hourly NOx emission
rates expressed in tons per hour shall be determined in accordance with R307-170 using the
appropriate conversion factors. The applicable performance specification in R307-170 shall be 40
CFR 60, Appendix B, Performance Specification 6 - "Specifications and Test Procedures for
Continuous Emission Rate Monitoring Systems in Stationary Sources". By the 25th day of each
month a new 12-month NOx emission total for the common stack shall be calculated as the sum
of the monthly NOx emission totals for each of the previous 12 months.

For the NOx mass emission limits, during any time when the CEMS are inoperable and otherwise
not measuring emissions of NOx from the kiln, the permittee shall apply the missing data
substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR
Part 75, Subpart D, whichever is deemed appropriate by the UDAQ. In calculating the 30-day
rolling average emission rate the total pounds of NOx emitted during a specified period shall
include all kiln emissions that occur during the specified period including during each startup,
shutdown, or malfunction.

25
Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
under paragraph (d) 40 CFR 60.13, the permittee shall continuously operate all required
continuous monitoring devices and shall meet minimum frequency of operation requirements as
outlined in 40 CFR 60.13 and Section UAC R307-170.

The permittee shall determine clinker production according to the requirements in 40 CFR
63.1350(d).

II.B.4.a.2 Recordkeeping:

The permittee shall record the output of the system: the quantity of NOx emissions at the kiln
stack. Additionally, the permittee shall keep the records specified in R307-170-8 and any records
required by Provision I.S.1 of this permit.

Any information used to determine compliance shall be recorded for all periods when the source
is in operation. Any or all of these records shall be made available to the Director upon request.
[SIP Section IX.H.21.d]

Results of monitoring shall be maintained in accordance with Provision I.S.1.

II.B.4.a.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional
reporting provisions contained in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision
I.S.2.c is included in the report.

Status: Condition not evaluated. CEM requirements are audited by DAQ’s CEM specialist. Readings
during inspection were: NOx 30 day 2.62 lb/ton clinker and 1253.9 tons 12 month total.

II.B.4.b Condition:

The permittee shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF)
C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke
F. Fuel Oil
G. Used Oil Fuel
H. Synthetic Fuel
I. Wood
J. Cherry Pits
K. Tire Poly Cord Fuel
L. Plastic Resin Waste Product
M. Coal Additives consisting of alternative fuels approved by the Director. Prior to burning any
proposed coal additive, the permittee shall obtain approval from the Director. To obtain approval, the
permittee shall submit Material Safety Data Sheets (MSDS) or the results of suitable tests giving data
similar to a Proximate and Ultimate analysis of the proposed coal additive.
26
Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another previously
approved coal additive.

The average quantity of coal additives burned shall not be greater than 15% of the total daily heat
input of the kiln and precalciner. The permittee may increase the average quantity of coal additives
up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in
accordance with the approval process described for new coal additives above.

Additionally, the permittee shall be limited to a maximum TDF consumption not to exceed 15% of
the combined energy input to the rotary kiln and pre-calciner.
[Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.4.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.b.2 Recordkeeping:

The fuel usage records shall include the type, quantity, and respective heating value for each
material used as fuel. The permittee shall calculate a new 12-month total for each fuel type by the
25th day of each month using data from the previous 12 months. Copies of Director approval of
each coal additive shall be maintained. Records shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.4.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The company uses TDF, NG, Coal, and approved additives. During inspection use
was TDF 0.03 TPH, Coal 205.0 TPH and NG 170451 BTU/hr.

II.B.4.c Condition:

Consumption of used oil fuel shall be no greater than 85,724 gallons per rolling 12-month period. [Origin:
DAQE-AN103030033-24]. [R307-401-8]

II.B.4.c.1 Monitoring:

Consumption shall be determined using purchase records and inventory information. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months. Consumption shall be calculated through use of the plant data acquisition
system.

II.B.4.c.2 Recordkeeping:

Records of used oil combusted shall be kept daily for all periods when the plant is in operation.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

27
II.B.4.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. No fuel oil was burned during the 12-month period preceding this inspection.

II.B.4.d Condition:

The permittee shall meet the following requirements when used oil or tire derived fuel (TDF) is burned in
the rotary kiln:
i. Combustion gas temperature at the rotary kiln exit shall not drop below 1500 degrees Fahrenheit for
more than five minutes in any 60-minute period.
ii. Oxygen content at the kiln system ID fan shall not drop below 2% for more than five minutes in any
60-minute period.
[Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.4.d.1 Monitoring:

The permittee shall continuously monitor the temperature and oxygen content at all times used oil
or TDF is burned in the kiln using equipment approved by the Director. Calibration procedure
and frequency shall be according to manufacturer's specifications. Use of factory calibrated
thermocouples for temperature measurement is approved. All monitoring equipment for both
temperature and oxygen shall be located such that an inspector can safely read the output at any
time.

Additionally, the permittee shall monitor the quantities and times that used oil or TDF is burned
in kiln.

II.B.4.d.2 Recordkeeping:

The permittee shall record the temperature and oxygen content at no less than every 5 minutes
during operations when used oil or TDF is burned in the kiln. The permittee shall record the
quantities and times when used oil or TDF is burned in the kiln. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.4.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. TDF use was 0.03 tons/hr and all parameters were tracked.

28
II.B.4.e Condition:

The concentration of contaminants or parameters in any used oil fuel burned in the Kiln shall not exceed
the following levels:
Arsenic 5 ppm by weight,
Barium 100 ppm by weight,
Cadmium 2 ppm by weight,
Chromium 10 ppm by weight,
Lead 100 ppm by weight,
Total Halogens 1,000 ppm by weight,
Sulfur 0.5 percent by weight, and
Flash Point not less than 100 degrees F.

Used oil exceeding any of the above contaminants shall not be burned until the permittee has submitted
and received approval of a modeling analysis of the projected emissions for each contaminant from the
Director. The modeling analysis shall show in each case that the resulting concentration of contaminant in
the ambient air does not exceed the TLV/100 value at the fence line for the given contaminant. Any used
oil fuel that contains more than 1,000 ppm by weight of total halogens shall be considered a hazardous
waste and shall not be burned in the kiln. [Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.4.e.1 Monitoring:

The permittee shall maintain test certification data for each load of used oil fuel received.
Certification shall be either by permittee testing or test reports provided by the used oil fuel
vendor. The used oil fuel shall be tested for halogen content by ASTM Method D-808-81, EPA
Method 8240 or Method 8260, or other method acceptable to the Director, before used oil fuel is
transferred to a holding tank or burned.

II.B.4.e.2 Recordkeeping:

Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation. Records shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.4.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not evaluated. Used oil fuel has not been burned in the past 12 months.

II.B.4.f Condition:

As part of demonstration of compliance with the dioxin/furans (D/F) emission limitation under 40 CFR
63.1343, the permittee shall operate the kiln such that the temperature of the gas at the inlet to the kiln
particulate matter control device (PMCD), does not exceed the applicable temperature limit (for both raw
mill operating and not operating) as determined in accordance with 40 CFR 63.1349(b)(3)(iv) and
established during the performance test (for both raw mill operating and not operating), except during
periods of startup and shutdown when the temperature limit may be exceeded by no more than 10 percent.
The permittee shall conduct an inspection of the components of the combustion system of each kiln or in-
29
line kiln/raw mill at least once per year. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1346(a), 40 CFR
63.1346(b), 40 CFR 63.1347(a)(3)]

II.B.4.f.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348.
A. The permittee shall demonstrate continuous compliance using a continuous monitoring
system (CMS) that is installed, operated and maintained to record the temperature of
specified gas streams in accordance with the following requirements. (40 CFR
63.1348(b)(4))
i) The permittee shall install, calibrate, maintain, and continuously operate a CMS to
record the temperature of the exhaust gases from the kiln and alkali bypass, if applicable,
at the inlet to, or upstream of, the kiln and/or alkali bypass PMCDs.
a) The temperature recorder response range shall include zero and 1.5 times the
average temperature established according to the requirements in 40 CFR
63.1349(b)(3)(iv).
b) The calibration reference for the temperature measurement shall be a National
Institute of Standards and Technology calibrated reference thermocouple-
potentiometer system or alternate reference, subject to approval by the
Administrator.
c) The calibration of all thermocouples and other temperature sensors shall be verified
at least once every three months.
ii) The permittee shall monitor and continuously record the temperature of the exhaust
gases from the kiln and alkali bypass, if applicable, at the inlet to the kiln and/or alkali
bypass PMCD.
iii) The required minimum data collection frequency shall be one minute.
iv) Every hour, record the calculated rolling three-hour average temperature using the
average of 180 successive one-minute average temperatures in accordance with 40 CFR
63.1349(b)(3).
v) 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
shall begin anew, without considering previous recordings.
(40 CFR 63.1350(g))
B. The permittee shall install, operate, and maintain each continuous parameter monitoring
system (CPMS) according to 40 CFR 63.1350(m)(1)-(4).
C. The permittee shall develop a site-specific monitoring plan according to the requirements in
40 CFR 63.1350(p)(1)-(4).
D. Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating. (40 CFR
63.1348(b)(1)(ii))
E. The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions or repairs associated with monitoring system malfunctions in calculations used
to report emissions or operating levels. A monitoring system malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring system to provide valid data.
Monitoring system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other periods in
assessing the operation of the control device and associated control system. (40 CFR
63.1348(b)(1)(iii))
30
F. For each existing unit that is equipped with a CMS, the permittee shall maintain the average
emissions or the operating parameter values within the operating parameter limits established
through performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of 40 CFR 63.1350 is a violation. (40 CFR 63.1350(a)).

II.B.4.f.2 Recordkeeping:

The permittee shall comply with the recordkeeping requirements specified in Provision I.S.1 of
this permit and 40 CFR 63.1355. Additionally, the permittee shall keep a log of the annual
inspections of the components of the combustion system of each kiln or in-line kiln/raw mill.

II.B.4.f.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349 and 63.1354 and the notification
requirements specified in 40 CFR 63.1353.

Status: In compliance. The components of the combustion system of each kiln or in-line kiln/raw material
was last inspected from March 1-March29, 2024 during the annual shutdown. The temperatures
are 228 F with the Raw Mill On and 389 F with the Raw Mill Off. Reporting meets the
requirements of 40 CFR 63.1349 and 63.1354. All parameters are tracked in control room with set
points and alarms.

II.B.4.g Condition:

At all times, emissions of Dioxins/Furans (D/F) from the kiln shall not exceed 0.2 ng/dscm (TEQ) on a
dry basis, corrected to 7 percent oxygen. If the average temperature at the inlet to the first PM control
device (fabric filter or electrostatic precipitator) during the D/F performance test is 400 degrees
Fahrenheit or less, this limit is changed to 0.40 ng/dscm (TEQ). [Origin: 40 CFR 63 Subpart LLL,
DAQE-AN103030033-24]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1), R307-401-8]

II.B.4.g.1 Monitoring:

The permittee shall demonstrate compliance as required in 40 CFR 63.1348.

II.B.4.g.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355.

II.B.4.g.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354 and the
notification requirements specified in 40 CFR 63.1353.

31
Status: In compliance. 40 CFR 63.1349 and 40 CFR 63.1354 of Subpart LLL requires an initial stack test,
followed by continuous monitoring of inlet and exhaust gas temperatures. Subpart LLL is unclear
on subsequent performance testing requirements. Section 63.1349(c) states:

“Performance test frequency. Except as provided in 63.1348(b), performance tests are required at
regular intervals for affected sources that are subject to a dioxin, organic HAP or HCl emissions
limit. Performance tests required every 30 months must be completed no more than 31 calendar
months after the previous performance test except where that specific pollutant is monitored using
CEMS; performance tests required every 12 months must be completed no more than 13 calendar
months after the previous performance test.”

63.1348(b) requires a continuous monitoring system and does not mention performance testing.
However, DAQE-AN103030033-24 requires testing every 30 months. Ash Grove has been testing
for D/F every two years.

Inlet and exhaust gas temperatures are monitored in the control room. Stack testing was last
conducted June 22-23, 2022. Test results were submitted to DAQ and reported in DAQC-1155-22.
The results indicated compliance with the 0.4 ng/dscm limit. Next test is scheduled for June 10,
2024.

II.B.4.h Condition:

Unless otherwise specified in this permit, the sulfur content of any coal, oil, or mixture thereof, burned in
any fuel burning or process installation not covered by New Source Performance Standards for sulfur
emissions shall contain no more than 1.0 pound sulfur per million gross Btu heat input for any mixture of
coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil except used oil. [Origin: DAQE-
AN103030033-24]. [R307-203, R307-401-8]

II.B.4.h.1 Monitoring:

Certification of fuels shall be either by permittee's testing or test reports from the fuel marketer.
Methods for determining sulfur content of coal and fuel oil shall be those methods of the
American Society for Testing and Materials (ASTM), in accordance with UAC R307-203-
1(1)(a), (b), and UAC R307-203-1(4).
(a) For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85, or other
method acceptable to the Director, shall be used.
(b) For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89, or other
method acceptable to the Director, shall be used.
(c) For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85, or other method acceptable to the Director, shall be used.

II.B.4.h.2 Recordkeeping:

The permittee shall record the following specifications for each purchase of fuel oil from the
vendor: weight percent sulfur, gross heating value (btu per unit volume), and density as
ascertained in accordance with the ASTM methods. Records of fuel sulfur content in any coal or
oil burned shall be kept for all periods when the plant is in operation and shall be made available to
the director upon request.

32
Fuel receipt records showing sulfur content of the delivered fuel or records of all sulfur content
testing performed on the delivered fuel shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.4.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Coal trip tickets are kept on file. Spreadsheets were reviewed during inspection and
no exceedances were found. Coal was received from the Bronco coal mine in Utah. No fuel oil has
been burned.

II.B.4.i Condition:

Emissions of CO shall be no greater than 13,045 tons per rolling 12-month period and 6,600 pounds per
hour. [Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.4.i.1 Monitoring:

The permittee shall install, calibrate, maintain and continuously operate a continuous emissions
monitoring system that complies with all applicable sections of R307-170, UAC; and 40 CFR 60,
Appendix B. While the affected emission unit is operating, hourly CO emission rates expressed in
tons per hour shall be determined in accordance with R307-170 using the appropriate conversion
factors. The applicable performance specification in R307-170 shall be 40 CFR 60, Appendix B,
Performance Specification 6 - "Specifications and Test Procedures for Continuous Emission Rate
Monitoring Systems in Stationary Sources". By the 25th day of each month a new 12-month CO
emission total for the common stack shall be calculated as the sum of the monthly CO emission
totals for each of the previous 12 months.

Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
under paragraph (d) 40 CFR 60.13, the permittee shall continuously operate all required
continuous monitoring devices and shall meet minimum frequency of operation requirements as
outlined in 40 CFR 60.13 and Section UAC R307-170.

II.B.4.i.2 Recordkeeping:

The permittee shall record the output of the system: the quantity of CO emissions at the kiln
stack. Additionally, the permittee shall keep the records specified in R307-170-8 and any records
required by provision I.S.1 of this permit. These records shall be maintained in accordance with
Provision I.S.1.

II.B.4.i.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional
reporting provisions contained in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit
deviations required in Provision I.S.2.c of this permit if all information required by Provision
I.S.2.c is included in the report.

33
Status: In compliance. Records show 3,061 tons of CO were generated through the 12-month period ending
April 30, 2024. Alarm set points warn the control room operators if the hourly limit is being
reached.

II.B.4.j Condition:

Production of clinker shall be no greater than 962,265 tons per 12-month rolling period. [Origin: DAQE-
AN103030033-24]. [R307-401-8]

II.B.4.j.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.j.2 Recordkeeping:

Daily records of clinker production and kiln feed rates shall be kept for all periods of operation.
The permittee shall calculate a new 12-month total for clinker production by the 25th day of each
month using data from the previous 12 months. Production shall be calculated through use of the
plant data acquisition system. Records shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.4.j.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records show 763,227 tons of clinker was produced during the 12-month period
ending April 30, 2024.

II.B.4.k Condition:

No greater than 10 percent of the kiln gases shall be routed to the Coal Grinding System (designated as
41B.BF2). [Origin: Alternative Monitoring EPA Approval 11/6/02]. [40 CFR 63.8(f)]

II.B.4.k.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.k.2 Recordkeeping:

Records verifying the percent of kiln gases routed to the coal grinding system shall be maintained
in accordance with Provision I.S.1 of this permit and made available for review by the Director or
his representative.

II.B.4.k.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

34
Status: In compliance. Piping design guarantees no more than 10 percent of kiln gases can be routed to the
Coal Grinding System.

II.B.4.l Condition:

At all times, emissions of filterable PM from the kiln shall not exceed 0.07 lb/ton clinker. Combined PM
emissions from the kiln and the inline coal mill stack are subject to the PM emissions limit. [Origin: 40
CFR 63 Subpart LLL, DAQE-AN103030033-24, SIP Section IX.H.23.a]. [40 CFR 63.1343(b)(1), 40
CFR 63.1343(b)(2), SIP Section IX.H.23.a]

II.B.4.l.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348.
A. The permittee shall demonstrate compliance with PM emissions standards by using the test
methods and procedures in 40 CFR 63.1349(b)(1). The permittee shall conduct a
performance test using Method 5 or Method 5I at 40 CFR 60 appendix A-3. The permittee
shall also monitor continuous performance through use of a PM continuous parametric
monitoring system (PM CPMS).
i) For PM performance test reports used to set a PM CPMS operating limit, the electronic
submission of the test report shall also include the make and model of the PM CPMS
instrument, serial number of the instrument, analytical principle of the instrument (e.g.
beta attenuation), span of the instruments primary analytical range, milliamp value or
digital equivalent to the instrument zero output, technique by which this zero value was
determined, and the average milliamp or digital equivalent signals corresponding to each
PM compliance test run.
ii) When there is an alkali bypass and/or an inline coal mill with a separate stack associated
with a kiln, the main exhaust and alkali bypass and/or inline coal mill shall be tested
simultaneously and the combined emission rate of PM from the kiln and alkali bypass
and/or inline coal mill shall be computed for each run using Equation 8 in 40 CFR
63.1349(b)(1)(viii).
iii) The permittee of a kiln with an in-line raw mill and subject to limitations on PM
emissions shall demonstrate initial compliance by conducting separate performance tests
while the raw mill is under normal operating conditions and while the raw mill is not
operating, and calculate the time weighted average emissions. The operating limit shall
then be determined using 40 CFR 63.1349(b)(1)(i).
(40 CFR 63.1343(b)(1), 40 CFR 63.1348(a)(1), 40 CFR 63.1349(b)(1))
B. The permittee shall demonstrate continuous compliance using the following monitoring
methods and procedures. (40 CFR 63.1348(b)(2))
i) The permittee shall use a PM CPMS to establish a site-specific operating limit
corresponding to the results of the performance test demonstrating compliance with the
PM limit. The permittee shall conduct the performance test using Method 5 or Method 5I
at 40 CFR 60 appendix A-3. The permittee shall use the PM CPMS to demonstrate
continuous compliance with this operating limit. The permittee shall repeat the
performance test annually and reassess and adjust the site-specific operating limit in
accordance with the results of the performance test using the procedures in 40 CFR
63.1349(b)(1)(i) through (vi). The permittee shall also repeat the test if the permittee
changes the analytical range of the instrument, or if the permittee replaces the instrument
itself or any principle analytical component of the instrument that would alter the
relationship of output signal to in-stack PM concentration.
ii) To determine continuous compliance, the permittee shall use the PM CPMS output data
for all periods when the process is operating and the PM CPMS is not out-of-control.
35
The permittee shall demonstrate continuous compliance by using all quality-assured
hourly average data collected by the PM CPMS for all operating hours to calculate the
arithmetic average operating parameter in units of the operating limit (milliamps) on a
30 operating day rolling average basis, updated at the end of each new kiln operating
day.
iii) For any exceedance of the 30 process operating day PM CPMS average value from the
established operating parameter limit, the permittee shall:
a) Within 48 hours of the exceedance, visually inspect the APCD;
b) If inspection of the APCD identifies the cause of the exceedance, take corrective
action as soon as possible and return the PM CPMS measurement to within the
established value; and
c) Within 30 days of the exceedance or at the time of the annual compliance test,
whichever comes first, conduct a PM emissions compliance test to determine
compliance with the PM emissions limit and to verify or re-establish the PM CPMS
operating limit within 45 days. The permittee is not required to conduct additional
testing for any exceedances that occur between the time of the original exceedance
and the PM emissions compliance test required under this paragraph.
iv) PM CPMS exceedances leading to more than four required performance tests in a 12-
month process operating period (rolling monthly) constitute a presumptive violation of
this subpart.
(40 CFR 63.1350(b))
C. The permittee shall determine clinker production according to the requirements in 40 CFR
63.1350(d).
D. The permittee shall develop a site-specific monitoring plan according to the requirements in
40 CFR 63.1350(p)(1)-(4).
E. Performance tests shall be completed no more than 13 calendar months after the previous
performance test. (40 CFR 63.1349(c)) Performance tests shall be conducted as specified
based on representative performance of the affected source for the period being tested. Upon
request, the permittee shall make available such records as may be necessary to determine
the conditions of performance tests. (40 CFR 63.1349(e))
F. Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating. (40 CFR
63.1348(b)(1)(ii))
G. The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions or repairs associated with monitoring system malfunctions in calculations used
to report emissions or operating levels. A monitoring system malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring system to provide valid data.
Monitoring system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other periods in
assessing the operation of the control device and associated control system. (40 CFR
63.1348(b)(1)(iii))
H. For each existing unit that is equipped with a CMS, the permittee shall maintain the average
emissions or the operating parameter values within the operating parameter limits established
through performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of 40 CFR 63.1350 is a violation. (40 CFR 63.1350(a)).
36
Additionally, stack testing shall be performed as specified below:
(i) If performance testing would be required less than 15 operating days after the Kiln has
completed Startup after being down for more than 24 hours, then performance testing may
be deferred up to 15 operating days after completion of the Startup. Tests may also be
required at the direction of the Director.

(ii) Notification. The Director shall be notified at least 60 days prior to conducting any required
emission testing. A source test protocol shall be submitted to DAQ when the testing
notification is submitted to the Director. The source test protocol shall be approved by the
Director prior to performing the test(s). The source test protocol shall outline the proposed
test methodologies, stack to be tested, procedures to be used, the date, time, and place of
testing. A pretest conference shall be held, if directed by the Director.
(iii) Methods.
a. Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA) and/or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
b. 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate.
c. The initial and subsequent PM performance tests shall be performed using Method 5 or
5I and consist of three runs, with each run at least 120 minutes in duration and each run
collecting a minimum sample of 60 dry standard cubic feet. The back half condensables
shall also be tested using Method 202. Determination of the particulate matter collected
in the impingers ("back half") of the Method 5 or Method 5I particulate sampling train is
not required to demonstrate compliance with the PM standards but shall be used for
inventory purposes.
(iv) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.

II.B.4.l.2 Recordkeeping:

Any information used to determine compliance shall be recorded for all periods when the source
is in operation. Any or all of these records shall be made available to the Director upon request.
[SIP Section IX.H.21.d]

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355.

II.B.4.l.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354 and the
notification requirements specified in 40 CFR 63.1353.

37
Status: 40 CFR 63.1343(b)(1) and 40 CFR 63.1343(b)(2) require an initial performance test only. A
subsequent performance test is optional (or necessary upon adding or changing equipment) but is
not required. State rule requires testing at least once every five years of all sources with established
emission limitations specified in approval orders issued under R307-401.

Stack testing of the main kiln and coal mill was last conducted June 20-23, 2023. Test results were
submitted to DAQ and audited in DAQC-935-23. DAQ calculated test results of 0.007 lb/ton clinker
(mill on) and 0.006 lb/ton clinker (mill off) indicate compliance with the PM limit of 0.07 lb/ton
clinker. Next test is scheduled for June 10, 2024.

Continuous compliance is demonstrated by monitoring and recording backscatter according to a
site specific monitoring plan. The Pm 30 day avg (backscatter) was 0.015 lbs/ton clinker.

II.B.4.m Condition:

At all times, emissions of mercury (Hg) from the kiln shall not exceed 55 lb/MM tons clinker based on a
rolling 30-day average. The 30-day period means all operating hours within 30 consecutive kiln operating
days excluding periods of startup and shutdown. The permittee shall ensure appropriate corrections for
moisture are made when measuring flow rates used to calculate mercury emissions. [Origin: 40 CFR 63
Subpart LLL, DAQE-AN103030033-24]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1), R307-401-8]

II.B.4.m.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348, 40 CFR 63.1350(k),
and R307-170.

II.B.4.m.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit, R307-170, and 40
CFR 63.1355.

II.B.4.m.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354, and R307-170
and the notification requirements specified in 40 CFR 63.1353 and R307-170.

Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring
Program. The reports are considered prompt notification of permit deviation required in Provision
I.S.2.c of this permit, if all information required by Provision I.S.2.c is included in the report.

Status: Condition not evaluated. CEM requirements are audited by DAQ’s CEM specialist. Reading
during the inspection was 10.8 lb/MM tons clinker 30-day average. .

II.B.4.n Condition:

At all times, emissions of total hydrocarbons (THC) from the kiln shall not exceed 24 ppmvd, measured
as propane, corrected to 7 percent oxygen, based on a rolling 30-day average. The 30-day period means
all operating hours within 30 consecutive kiln operating days excluding periods of startup and shutdown.
The permittee may elect to meet an alternative limit of 12 ppmvd for total organic HAP. [Origin: 40 CFR
63 Subpart LLL, DAQE-AN103030033-24]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1), R307-401-8]
38
II.B.4.n.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348 and R307-170.
A. i) The permittee shall demonstrate compliance with the THC emissions standards by using
the performance test methods and procedures in 40 CFR 63.1349(b)(4)(i). The permittee
shall use the average THC concentration obtained during the first 30 kiln operating days
after the compliance date to determine initial compliance.
ii) If the permittee elects to demonstrate compliance with the total organic HAP emissions
limit in lieu of the THC emissions limit, the permittee shall demonstrate compliance with
the total organic HAP emissions standards by using the performance test methods and
procedures in 40 CFR 63.1349(b)(7).
iii) To demonstrate initial compliance, the permittee shall conduct the separate performance
tests as specified in 40 CFR 63.1349(b)(7) while the raw mill of the inline kiln/raw mill
is operating and while the raw mill of the inline kiln/raw mill is not operating.
iv) The time weighted average total organic HAP concentration measured during the
separate initial performance test specified by 40 CFR 63.1349(b)(7) shall be used to
determine initial compliance.
v) The time weighted average THC concentration measured during the initial performance
test specified by 40 CFR 63.1349(b)(4) shall be used to determine the site-specific THC
limit. Using the fraction of time the inline kiln/raw mill is on and the fraction of time that
the inline kiln/raw mill is off, calculate this limit as a time weighted average of the THC
levels measured during raw mill on and raw mill off testing using one of the two
approaches in 40 CFR 63.1349(b)(7)(vii) or (viii) depending on the level of organic HAP
measured during the compliance test.
(40 CFR 63.1348(a)(4))
B. i) The permittee shall operate a CEMS in accordance with the requirements in 40 CFR
63.1350(i). For the purposes of conducting the accuracy and quality assurance
evaluations for CEMS, the THC span value (as propane) is 50 to 60 ppmvw and the
reference method (RM) is Method 25A of 40 CFR 60 appendix A.
ii) Use the THC CEMS to conduct the initial compliance test for the first 30 kiln operating
days of kiln operation after the compliance date.
iii) If kiln gases are diverted through an alkali bypass or to a coal mill and exhausted
through a separate stack, the permittee shall calculate a kiln-specific THC limit using
Equation 9 in 40 CFR 63.1349(b)(4)(iii).
iv) THC shall be measured either upstream of the coal mill or the coal mill stack.
v) Instead of conducting the performance test specified in paragraph B., the permittee may
conduct a performance test to determine emissions of total organic HAP by following
the procedures in 40 CFR 63.1349(b)(7).
(40 CFR 63.1349(b)(4))
C. The permittee shall comply with the following monitoring requirements:
i) The permittee shall install, operate, and maintain a THC continuous emission monitoring
system in accordance with Performance Specification 8 or Performance Specification 8A
of 40 CFR 60 appendix B and comply with all of the requirements for continuous
monitoring systems found in the general provisions, 40 CFR 63 subpart A. The permittee
shall operate and maintain each CEMS according to the quality assurance requirements
in Procedure 1 of 40 CFR 60 appendix F. For THC continuous emission monitoring
systems certified under Performance Specification 8A, conduct the relative accuracy test
audits required under Procedure 1 in accordance with Performance Specification 8,
Sections 8 and 11 using Method 25A in 40 CFR 60 appendix A as the reference method;
the relative accuracy shall meet the criteria of Performance Specification 8, Section 13.2.
39
ii) Performance tests on alkali bypass and coal mill stacks shall be conducted using Method
25A in 40 CFR 60 appendix A and repeated every 30 months.
iii) If complying with the total organic HAP emissions limits, the permittee shall
continuously monitor THC according to paragraph i) and ii) of this section or in
accordance with Performance Specification 8 or Performance Specification 8A of 40
CFR 60 appendix B and comply with all of the requirements for continuous monitoring
systems found in the general provisions, 40 CFR 63 subpart A. The permittee shall
operate and maintain each CEMS according to the quality assurance requirements in
Procedure 1 of 40 CFR 60 appendix F.
(40 CFR 63.1350(i), (j))
D. The permittee shall demonstrate continuous compliance using the monitoring methods and
procedures in paragraph C. (40 CFR 63.1350(i) and (j)). THC shall be measured either
upstream of the coal mill or in the coal mill stack. (40 CFR 63.1348(b)(6))
E. The permittee shall install, operate, and maintain each continuous parameter monitoring
system (CPMS) according to 40 CFR 63.1350(m)(1)-(4).
F. The permittee shall develop a site-specific monitoring plan according to the requirements in
40 CFR 63.1350(p)(1)-(4).
G. Performance tests shall be conducted as specified based on representative performance of the
affected source for the period being tested. Upon request, the permittee shall make available
such records as may be necessary to determine the conditions of performance tests. (40 CFR
63.1349(e))
H. Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating. (40 CFR
63.1348(b)(1)(ii))
I. The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions or repairs associated with monitoring system malfunctions in calculations used
to report emissions or operating levels. A monitoring system malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring system to provide valid data.
Monitoring system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other periods in
assessing the operation of the control device and associated control system. (40 CFR
63.1348(b)(1)(iii))
J. For each existing unit that is equipped with a CMS, the permittee shall maintain the average
emissions or the operating parameter values within the operating parameter limits established
through performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of 40 CFR 63.1350 is a violation. (40 CFR 63.1350(a)).

II.B.4.n.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit, R307-170, and 40
CFR 63.1355.

40
II.B.4.n.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354, and R307-170
and the notification requirements specified in 40 CFR 63.1353 and R307-170.

Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring
Program. The reports are considered prompt notification of permit deviation required in Provision
I.S.2.c of this permit, if all information required by Provision I.S.2.c is included in the report.

Status: Condition not evaluated. CEM requirements are audited by DAQ’s CEM specialist. Reading
during the inspection was 12.9 ppmdv 30-day average. .

II.B.4.o Condition:

Emissions of hydrochloric acid (HCl) from the kiln shall not exceed 3 ppmvd, corrected to 7 percent
oxygen. This condition applies to major sources of HAP as defined in 40 CFR 63.2.

If using a CEMS to determine compliance with the HCl standard, this standard is based on a rolling 30-
day average. The 30-day period means all operating hours within 30 consecutive kiln operating days
excluding periods of startup and shutdown.
[Origin: 40 CFR 63 Subpart LLL, DAQE-AN103030033-24]. [40 CFR 63.1343(a), 40 CFR
63.1343(b)(1), R307-401-8]

II.B.4.o.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348, 40 CFR 63.1350(l),
and R307-170.

II.B.4.o.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit, R307-170, and 40
CFR 63.1355.

II.B.4.o.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354, and R307-170
and the notification requirements specified in 40 CFR 63.1353 and R307-170.

Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring
Program. The reports are considered prompt notification of permit deviation required in Provision
I.S.2.c of this permit, if all information required by Provision I.S.2.c is included in the report.

Status: Condition not evaluated. CEM requirements are audited by DAQ’s CEM specialist. Reading
during the inspection was 0.8 ppmdv 30-day average.

41
II.B.4.p Condition:

For kiln limits originating in 40 CFR 63.1343(b), during periods of startup and shutdown, the permittee
shall comply with the following work practices.
(1) During startup the permittee shall use any one or combination of the following clean fuels: natural
gas, synthetic natural gas, propane, distillate oil, synthesis gas (syngas), and ultra-low sulfur diesel
(ULSD) until the kiln reaches a temperature of 1200 degrees Fahrenheit.
(2) Combustion of the primary kiln fuel may commence once the kiln temperature reaches 1200 degrees
Fahrenheit.
(3) All dry sorbent and activated carbon systems that control hazardous air pollutants shall be turned on
and operating at the time the gas stream at the inlet to the baghouse reaches 300 degrees Fahrenheit
(five minute average) during startup. Temperature of the gas stream shall be measured at the inlet of
the baghouse every minute. Such injection systems can be turned off during shutdown. Particulate
control and all remaining devices that control hazardous air pollutants shall be operational during
startup and shutdown.
[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343, 40 CFR 63.1346(g)]

II.B.4.p.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.p.2 Recordkeeping:

The permittee shall keep records as specified in 40 CFR 63.1355 during periods of startup and
shutdown. (40 CFR 63.1346(g)(4)) Records demonstrating compliance with this condition shall
be maintained in accordance with Provision I.S.1 of this permit and 40 CFR 63.1355.

II.B.4.p.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1354.

Status: In compliance. Natural gas is used during startup and shutdown. Interlocks are set to not allow coal
as fuel below 1,200 degrees Fahrenheit upon startup, and dry sorbent and activated carbon systems
start up at 300 degrees and above.

II.B.4.q Condition:

Emissions of SO2 shall be no greater than 0.4 lbs per ton clinker (3-hr average).
[Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.4.q.1 Monitoring:

Stack testing shall be performed as specified below:
(i) Frequency. Emissions shall be tested once every two years. Tests may also be required at the
direction of the Director.
(ii) Notification. The Director shall be notified at least 30 days prior to conducting any required
emission testing. A source test protocol shall be submitted to DAQ when the testing
notification is submitted to the Director. The source test protocol shall be approved by the
Director prior to performing the test(s). The source test protocol shall outline the proposed
42
test methodologies, stack to be tested, procedures to be used, the date, time, and place of
testing. A pretest conference shall be held, if directed by the Director.
(iii) Methods.
a. Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA) and/or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test location.
b. 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate.
c. 40 CFR 60, Appendix A-4, Method 6 or 6C, or other EPA approved method, as acceptable
to the Director.
(iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.
(v) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.

The permittee shall determine clinker production according to the requirements in 40 CFR
63.1350(d).

II.B.4.q.2 Recordkeeping:

Results of monitoring and stack testing shall be recorded and maintained in accordance with the
associated test method and Provision I.S.1 of this permit.

II.B.4.q.3 Reporting:

Results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional reporting requirements for this provision except those
specified in Section I of this permit.

Status: In compliance. Stack testing of the main kiln and coal mill was last conducted June 20-23, 2023.
Test results were submitted to DAQ and audited in DAQC-935-23. DAQ calculated test results of
0.003 lb/ton clinker indicate compliance with the SO2 limit of 0.02 lb/ton clinker. Next test is due in
2025.

II.B.5 Conditions on Clinker Cooler (419.BF1).

II.B.5.a Condition:

At all times, emissions of filterable PM from the clinker cooler shall not exceed 0.07 lb/ton clinker.
[Origin: 40 CFR 63 Subpart LLL, DAQE-AN103030033-24]. [40 CFR 63.1343(b)(1), R307-401-8]

II.B.5.a.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348.
A. The permittee shall demonstrate compliance with PM emissions standards by using the test
methods and procedures in 40 CFR 63.1349(b)(1). The permittee shall conduct a
performance test using Method 5 or Method 5I at 40 CFR 60 appendix A-3. The permittee
43
shall also monitor continuous performance through use of a PM continuous parametric
monitoring system (PM CPMS).
i) For PM performance test reports used to set a PM CPMS operating limit, the electronic
submission of the test report shall also include the make and model of the PM CPMS
instrument, serial number of the instrument, analytical principle of the instrument (e.g.
beta attenuation), span of the instruments primary analytical range, milliamp value or
digital equivalent to the instrument zero output, technique by which this zero value was
determined, and the average milliamp or digital equivalent signals corresponding to each
PM compliance test run.
(40 CFR 63.1348(a)(1), 40 CFR 63.1349(b)(1))
B. The permittee shall demonstrate continuous compliance using the following monitoring
methods and procedures. (40 CFR 63.1348(b)(2))
i) The permittee shall use a PM CPMS to establish a site-specific operating limit
corresponding to the results of the performance test demonstrating compliance with the
PM limit. The permittee shall conduct the performance test using Method 5 or Method 5I
at 40 CFR 60 appendix A-3. The permittee shall use the PM CPMS to demonstrate
continuous compliance with this operating limit. The permittee shall repeat the
performance test annually and reassess and adjust the site-specific operating limit in
accordance with the results of the performance test using the procedures in 40 CFR
63.1349(b)(1)(i) through (vi). The permittee shall also repeat the test if the permittee
changes the analytical range of the instrument, or if the permittee replaces the instrument
itself or any principle analytical component of the instrument that would alter the
relationship of output signal to in-stack PM concentration.
ii) To determine continuous compliance, the permittee shall use the PM CPMS output data
for all periods when the process is operating and the PM CPMS is not out-of-control.
The permittee shall demonstrate continuous compliance by using all quality-assured
hourly average data collected by the PM CPMS for all operating hours to calculate the
arithmetic average operating parameter in units of the operating limit (milliamps) on a
30 operating day rolling average basis, updated at the end of each new kiln operating
day.
iii) For any exceedance of the 30 process operating day PM CPMS average value from the
established operating parameter limit, the permittee shall:
a) Within 48 hours of the exceedance, visually inspect the APCD;
b) If inspection of the APCD identifies the cause of the exceedance, take corrective
action as soon as possible and return the PM CPMS measurement to within the
established value; and
c) Within 30 days of the exceedance or at the time of the annual compliance test,
whichever comes first, conduct a PM emissions compliance test to determine
compliance with the PM emissions limit and to verify or re-establish the PM CPMS
operating limit within 45 days. The permittee is not required to conduct additional
testing for any exceedances that occur between the time of the original exceedance
and the PM emissions compliance test required under this paragraph.
iv) PM CPMS exceedances leading to more than four required performance tests in a 12-
month process operating period (rolling monthly) constitute a presumptive violation of
this subpart.
(40 CFR 63.1350(b)).
C. The permittee shall determine clinker production according to the requirements in 40 CFR
63.1350(d).
D. The permittee shall develop a site-specific monitoring plan according to the requirements in
40 CFR 63.1350(p)(1)-(4).
44
E. Performance tests shall be completed no more than 13 calendar months after the previous
performance test. (40 CFR 63.1349(c)) Performance tests shall be conducted as specified
based on representative performance of the affected source for the period being tested. Upon
request, the permittee shall make available such records as may be necessary to determine
the conditions of performance tests. (40 CFR 63.1349(e))
F. Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating. (40 CFR
63.1348(b)(1)(ii))
G. The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions or repairs associated with monitoring system malfunctions in cal culations used
to report emissions or operating levels. A monitoring system malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring system to provide valid data.
Monitoring system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other periods in
assessing the operation of the control device and associated control system. (40 CFR
63.1348(b)(1)(iii))
H. For each existing unit that is equipped with a CMS, the permittee shall maintain the average
emissions or the operating parameter values within the operating parameter limits established
through performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of 40 CFR 63.1350 is a violation. (40 CFR 63.1350(a))

Additionally, stack testing shall be performed as specified below:
(i) If performance testing would be required less than 15 operating days after the Kiln has
completed Startup after being down for more than 24 hours, then performance testing may be
deferred up to 15 operating days after completion of the Startup. Tests may also be required
at the direction of the Director.
(ii) Notification. The Director shall be notified at least 60 days prior to conducting any required
emission testing. A source test protocol shall be submitted to DAQ when the testing
notification is submitted to the Director. The source test protocol shall be approved by the
Director prior to performing the test(s). The source test protocol shall outline the proposed
test methodologies, stack to be tested, procedures to be used, the date, time, and place of
testing. A pretest conference shall be held, if directed by the Director.
(iii) Methods.
a. Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director, and Occupational Safety and Health Administration (OSHA) and/or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
b. 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate.
c. The initial and subsequent PM performance tests shall be performed using Method 5 or
5I and consist of three 1-hr tests. Determination of the particulate matter collected in the
impingers ("back half") of the Method 5 or Method 5I particulate sampling train is not
required to demonstrate compliance with the PM standards.
(iv) Production Rate During Testing. The production rate during all compliance testing shall be
no less than 90% of the maximum production achieved in the previous three (3) years.

45
II.B.5.a.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355.

II.B.5.a.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354 and the
notification requirements specified in 40 CFR 63.1353.

Status: In compliance with stack testing requirements. CEM requirements are audited by DAQ’s CEM
specialist.

Stack testing of the clinker cooler was last conducted June 20-23, 2023. Test results were submitted
to DAQ and audited in DAQC-935-23. DAQ calculated test results of 0.007 lb/ton clinker indicate
compliance with the PM limit of 0.07 lb/ton clinker. Next test is scheduled for June 10, 2024.

II.B.5.b Condition:

For clinker cooler limits originating in 40 CFR 63.1343(b), during periods of startup and shutdown, the
permittee shall comply with the following work practices:

All dry sorbent and activated carbon systems that control hazardous air pollutants shall be turned on and
operating at the time the gas stream at the inlet to the baghouse reaches 300 degrees Fahrenheit (five
minute average) during startup. Temperature of the gas stream shall be measured at the inlet of the
baghouse every minute. Such injection systems can be turned off during shutdown. Particulate control
and all remaining devices that control hazardous air pollutants shall be operational during periods of
startup and shutdown. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343, 40 CFR 63.1348(b)(9)]

II.B.5.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.5.b.2 Recordkeeping:

The permittee shall keep records as specified in 40 CFR 63.1355 during periods of startup and
shutdown. Records demonstrating compliance with this condition shall be maintained in
accordance with Provision I.S.1 of this permit and 40 CFR 63.1355.

II.B.5.b.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1354.

Status: In compliance. Pollution control equipment is operated in accordance with 40 CFR 63.1348(b)(9).
Interlocks are set to ensure this requirement is met upon startup (at 300 degrees Fahrenheit as
specified). 40 CFR 63.1348(b)(9) allows this system to be turned off during shutdown.

46
II.B.6 Conditions on Finish Mill (514.BF2).

II.B.6.a Condition:

Visible emissions shall be no greater than 10 percent opacity during all modes of operation. [Origin: 40
CFR 63 Subpart LLL, DAQE-AN103030033-24]. [40 CFR 63.1343(b)(1), 40 CFR 63.1345, R307-401-8]

II.B.6.a.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348 and, if applicable,
R307-170.
A. The permittee shall demonstrate continuous compliance by using the monitoring methods
and procedures in 40 CFR 63.1350(f) based on the maximum 6-minute average opacity
exhibited during the performance test period. The permittee shall initiate corrective actions
within one hour of detecting visible emissions above the applicable limit.
i) For a finish mill, the permittee shall monitor opacity by conducting daily visible
emissions observations of the mill sweep and air separator PM control devices (PMCD)
of these affected sources in accordance with the procedures of Method 22 of 40 CFR 60
appendix A-7. The duration of the Method 22 performance test shall be 6 minutes.
ii) Within 24 hours of the end of the Method 22 performance test in which visible
emissions were observed, the permittee shall conduct a follow up Method 22
performance test of each stack from which visible emissions were observed during the
previous Method 22 performance test.
iii) If visible emissions are observed during the follow-up Method 22 performance test
required by paragraph ii) of this section, the permittee shall then conduct an opacity test
of each stack from which emissions were observed during the follow up Method 22
performance test in accordance with Method 9 of 40 CFR 60 appendix A-4. The
duration of the Method 9 test shall be 30 minutes.
iv) If visible emissions are observed during any Method 22 visible emissions test
conducted under this section, the permittee shall initiate, within one-hour, the corrective
actions specified in the operation and maintenance plan as required in 40 CFR 63.1347.
v) The requirements under this section to conduct daily Method 22 testing do not apply to
any specific finish mill equipped with a COMS or BLDS.
vi) If the permittee installs a COMS in lieu of conducting the daily visible emissions
testing, the permittee shall demonstrate compliance using a COMS that it is installed,
operated, and maintained in accordance with the requirements in paragraph vi)a).
a) The COMS shall be installed at the outlet of the PM control device of the finish
mill and the COMS shall be installed, maintained, calibrated, and operated as
required by the general provisions in 40 CFR 60 subpart A and according to PS-1
of 40 CFR 60 appendix B.
vii) If the permittee installs a BLDS on a finish mill in lieu of conducting the daily visible
emissions testing, the permittee shall demonstrate compliance using a BLDS that is
installed, operated, and maintained in accordance with the requirements of paragraphs
B. through D. of this section. (40 CFR 63.1350(m)(1)-(4), (m)(10), and (m)(11))
(40 CFR 63.1348(b)(3), 40 CFR 63.1350(f))
B. The permittee shall install, operate, and maintain each continuous parameter monitoring
system (CPMS) according to 40 CFR 63.1350(m)(1)-(4).
C. If a fabric filter bag leak detection system is used, the permittee shall install, calibrate,
maintain, and continuously operate a BLDS as specified in paragraphs C.i) through viii).
i) The permittee shall install and operate a BLDS for each exhaust stack of the fabric
filter.
47
ii) Each BLDS shall be installed, operated, calibrated, and maintained in a manner
consistent with the manufacturer's written specifications and recommendations and in
accordance with the guidance provided in EPA-454/R-98-015, September 1997.
iii) The BLDS shall be certified by the manufacturer to be capable of detecting PM
emissions at concentrations of 10 or fewer milligrams per actual cubic meter.
iv) The BLDS sensor shall provide output of relative or absolute PM loadings.
v) The BLDS shall be equipped with a device to continuously record the output signal
from the sensor.
vi) The BLDS shall be equipped with an alarm system that will alert an operator
automatically when an increase in relative PM emissions over a preset level is detected.
The alarm shall be located such that the alert is detected and recognized easily by an
operator.
vii) For positive pressure fabric filter systems that do not duct all compartments of cells to a
common stack, a BLDS shall be installed in each baghouse compartment or cell.
viii) Where multiple bag leak detectors are required, the system's instrumentation and alarm
may be shared among detectors.
(40 CFR 63.1350(m)(10))
D. For each BLDS, the permittee shall initiate procedures to determine the cause of every alarm
within 8 hours of the alarm. The permittee shall alleviate the cause of the alarm within 24
hours of the alarm by taking whatever corrective action(s) are necessary. Corrective actions
may include, but are not limited to the following:
i) Inspecting the fabric filter for air leaks, torn or broken bags or filter media, or any
other condition that may cause an increase in PM emissions;
ii) Sealing off defective bags or filter media;
iii) Replacing defective bags or filter media or otherwise repairing the control device;
iv) Sealing off a defective fabric filter compartment;
v) Cleaning the BLDS probe or otherwise repairing the BLDS; or
vi) Shutting down the process producing the PM emissions.
(40 CFR 63.1350(m)(11))
E. The permittee shall develop a site-specific monitoring plan according to the requirements in
40 CFR 63.1350(p)(1)-(5).
F. Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating. (40 CFR
63.1348(b)(1)(ii))
G. The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions or repairs associated with monitoring system malfunctions in calculations used
to report emissions or operating levels. A monitoring system malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring system to provide valid data.
Monitoring system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other periods in
assessing the operation of the control device and associated control system. (40 CFR
63.1348(b)(1)(iii))
H. For each existing unit that is equipped with a CMS, the permittee shall maintain the average
emissions or the operating parameter values within the operating parameter limits established
through performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of 40 CFR 63.1350 is a violation. (40 CFR 63.1350(a)).

48
II.B.6.a.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355. Records shall also be maintained in accordance with R307-170 if a COMS is used.

Additionally, records of visual emission observations and visual opacity tests required by 40 CFR
60, Appendix A, Methods 22 and 9 shall be maintained in accordance with Provision I.S.1 of this
permit if a COMS or BLDS is not used.

II.B.6.a.3 Reporting:

In addition to the reporting requirements of Provision I.S.2 of this permit, the permittee shall
comply with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354 and the
notification requirements specified in 40 CFR 63.1353.

If a COMS is used:
i. The permittee shall also comply with the reporting and notification requirements specified in
R307-170.
ii. Reports shall be submitted quarterly, as required by R307-170, Continuous Emission
Monitoring Program. The reports are considered prompt notification of permit deviation
required in Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is
included in the report.

Status: In compliance with BLDS requirements. CEM requirements are evaluated by DAQ’s CEM
specialist. BLDS requirements are recorded. Alarm events and corrective action records were
provided during this inspection.

II.B.7 Conditions on Finish Mill Separator (514.BF1).

II.B.7.a Condition:

Visible emissions shall be no greater than 10 percent opacity during all modes of operation. [Origin: 40
CFR 63 Subpart LLL, DAQE-AN103030033-24]. [40 CFR 63.1345, R307-401-8]

II.B.7.a.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348 and, if applicable,
R307-170.
A. The permittee shall demonstrate continuous compliance by using the monitoring methods
and procedures in 40 CFR 63.1350(f) based on the maximum 6-minute average opacity
exhibited during the performance test period. The permittee shall initiate corrective actions
within one hour of detecting visible emissions above the applicable limit.
i) For a finish mill, the permittee shall monitor opacity by conducting daily visible
emissions observations of the mill sweep and air separator PM control devices (PMCD)
of these affected sources in accordance with the procedures of Method 22 of 40 CFR 60
appendix A-7. The duration of the Method 22 performance test shall be 6 minutes.
ii) Within 24 hours of the end of the Method 22 performance test in which visible
emissions were observed, the permittee shall conduct a follow up Method 22
performance test of each stack from which visible emissions were observed during the
previous Method 22 performance test.
49
iii) If visible emissions are observed during the follow-up Method 22 performance test
required by paragraph ii) of this section, the permittee shall then conduct an opacity test
of each stack from which emissions were observed during the follow up Method 22
performance test in accordance with Method 9 of 40 CFR 60 appendix A-4. The
duration of the Method 9 test shall be 30 minutes.
iv) If visible emissions are observed during any Method 22 visible emissions test
conducted under this section, the permittee shall initiate, within one-hour, the corrective
actions specified in the operation and maintenance plan as required in 40 CFR 63.1347.
v) The requirements under this section to conduct daily Method 22 testing do not apply to
any specific finish mill equipped with a COMS or BLDS.
vi) If the permittee installs a COMS in lieu of conducting the daily visible emissions
testing, the permittee shall demonstrate compliance using a COMS that it is installed,
operated, and maintained in accordance with the requirements in paragraph vi)a).
a) The COMS shall be installed at the outlet of the PM control device of the finish
mill and the COMS shall be installed, maintained, calibrated, and operated as
required by the general provisions in 40 CFR 60 subpart A and according to PS-1
of 40 CFR 60 appendix B.
vii) If the permittee installs a BLDS on a finish mill in lieu of conducting the daily visible
emissions testing, the permittee shall demonstrate compliance using a BLDS that is
installed, operated, and maintained in accordance with the requirements of paragraphs
B. through D. of this section. (40 CFR 63.1350(m)(1)-(4), (m)(10), and (m)(11))
(40 CFR 63.1348(b)(3), 40 CFR 63.1350(f))
B. The permittee shall install, operate, and maintain each continuous parameter monitoring
system (CPMS) according to 40 CFR 63.1350(m)(1)-(4).
C. If a fabric filter bag leak detection system is used, the permittee shall install, calibrate,
maintain, and continuously operate a BLDS as specified in paragraphs C.i) through viii).
i) The permittee shall install and operate a BLDS for each exhaust stack of the fabric
filter.
ii) Each BLDS shall be installed, operated, calibrated, and maintained in a manner
consistent with the manufacturer's written specifications and recommendations and in
accordance with the guidance provided in EPA-454/R-98-015, September 1997.
iii) The BLDS shall be certified by the manufacturer to be capable of detecting PM
emissions at concentrations of 10 or fewer milligrams per actual cubic meter.
iv) The BLDS sensor shall provide output of relative or absolute PM loadings.
v) The BLDS shall be equipped with a device to continuously record the output signal
from the sensor.
vi) The BLDS shall be equipped with an alarm system that will alert an operator
automatically when an increase in relative PM emissions over a preset level is detected.
The alarm shall be located such that the alert is detected and recognized easily by an
operator.
vii) For positive pressure fabric filter systems that do not duct all compartments of cells to a
common stack, a BLDS shall be installed in each baghouse compartment or cell.
viii) Where multiple bag leak detectors are required, the system's instrumentation and alarm
may be shared among detectors.
(40 CFR 63.1350(m)(10))
D. For each BLDS, the permittee shall initiate procedures to determine the cause of every alarm
within 8 hours of the alarm. The permittee shall alleviate the cause of the alarm within 24
hours of the alarm by taking whatever corrective action(s) are necessary. Corrective actions
may include, but are not limited to the following:
i) Inspecting the fabric filter for air leaks, torn or broken bags or filter media, or any other
condition that may cause an increase in PM emissions;
50
ii) Sealing off defective bags or filter media;
iii) Replacing defective bags or filter media or otherwise repairing the control device;
iv) Sealing off a defective fabric filter compartment;
v) Cleaning the BLDS probe or otherwise repairing the BLDS; or
vi) Shutting down the process producing the PM emissions.
(40 CFR 63.1350(m)(11))
E. The permittee shall develop a site-specific monitoring plan according to the requirements in
40 CFR 63.1350(p)(1)-(5).
F. Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating. (40 CFR
63.1348(b)(1)(ii))
G. The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions or repairs associated with monitoring system malfunctions in calculations used
to report emissions or operating levels. A monitoring system malfunction is any sudden,
infrequent, not reasonably preventable failure of the monitoring system to provide valid data.
Monitoring system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other periods in
assessing the operation of the control device and associated control system. (40 CFR
63.1348(b)(1)(iii))
H. For each existing unit that is equipped with a CMS, the permittee shall maintain the average
emissions or the operating parameter values within the operating parameter limits established
through performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of 40 CFR 63.1350 is a violation. (40 CFR 63.1350(a)).

II.B.7.a.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355. Records shall also be maintained in accordance with R307-170 if a COMS is used.

Additionally, records of visual emission observations and visual opacity tests required by 40 CFR
60, Appendix A, Methods 22 and 9 shall be maintained in accordance with Provision I.S.1 of this
permit if a COMS or BLDS is not used.

II.B.7.a.3 Reporting:

In addition to the reporting requirements of Provision I.S.2 of this permit, the permittee shall
comply with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354 and the
notification requirements specified in 40 CFR 63.1353.

If a COMS is used:
i. The permittee shall also comply with the reporting and notification requirements specified in
R307-170.
ii. Reports shall be submitted quarterly, as required by R307-170, Continuous Emission
Monitoring Program. The reports are considered prompt notification of permit deviation
required in Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is
included in the report.

51
Status: In compliance with BLDS requirements. CEM requirements are evaluated by DAQ’s CEM
specialist. BLDS requirements are recorded. Alarm events and corrective actions are recorded in
Ash Grove’s Bentley database. In addition, a PC MACT work order system is used to ensure
MACT required corrective actions are performed immediately.

II.B.8 Conditions on Coal Silo (41B.BF1).

II.B.8.a Condition:

Visible emissions shall not exceed 10 percent opacity. [Origin: 40 CFR 60 Subpart Y, DAQE-
AN103030033-24]. [40 CFR 60.254(a), R307-401-8]

II.B.8.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions are
observed, an opacity determination of that emission unit shall be performed by a certified visible
emissions observer within 24 hours of the initial observation in accordance with 40 CFR 60,
Appendix A, Method 9 and 40 CFR 60.257(a)(1) and (3). For each affected emission unit, if no
visible emissions are observed for eight consecutive weeks the observation frequency shall be
reduced to a monthly basis. If visible emissions are observed during any monthly observation the
frequency shall revert back to a weekly basis.

II.B.8.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.8.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Visual observations have been conducted and recorded weekly.

II.B.9 Conditions on Coal Grinding System (41B.BF2).

II.B.9.a Condition:

Visible emissions shall not exceed 10 percent opacity. [Origin: 40 CFR 60 Subpart Y, DAQE-
AN103030033-24]. [40 CFR 60.254(a), R307-401-8]

52
II.B.9.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions are
observed, an opacity determination of that emission unit shall be performed by a certified visible
emissions observer within 24 hours of the initial observation in accordance with 40 CFR 60,
Appendix A, Method 9 and 40 CFR 60.257(a)(1) and (3). For each affected emission unit, if no
visible emissions are observed for eight consecutive weeks the observation frequency shall be
reduced to a monthly basis. If visible emissions are observed during any monthly observation the
frequency shall revert back to a weekly basis.

II.B.9.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.9.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Visual observations have been conducted and recorded weekly.

II.B.9.b Condition:

During all periods of operation, the permittee shall record the operating temperature of the Coal Grinding
System baghouse. [Origin: Alternative Monitoring EPA Approval 11/6/02]. [40 CFR 63.8(f)]

II.B.9.b.1 Monitoring:

The permittee shall install and operate a temperature alarm on the baghouse inlet in accordance
with the manufacturer's specifications.

II.B.9.b.2 Recordkeeping:

Records required by this permit condition and copies of the manufacturer's alarm specifications
shall be maintained in accordance with Provision I.S.1 of this permit and made available for
review by the Director or his representative.

II.B.9.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The permittee has monitored and recorded the operating temperature of the Coal
Grinding System baghouse.

53
II.B.9.c Condition:

During normal operation, emissions of PM from the kiln shall be no greater than 0.07 lb/ton clinker.
Combined PM emissions from the kiln and/or the inline coal mill stack are subject to the PM emissions
limit. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(b)(1), 40 CFR 63.1343(b)(2)]

II.B.9.c.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348 and condition
II.B.4.l.1 of this permit.

For purposes of determining exhaust gas flow rate to the atmosphere from a coal mill stack, the
permittee shall either install, operate, calibrate and maintain an instrument for continuously
measuring and recording the exhaust gas flow rate according to the requirements in 40 CFR
63.1350(n)(1) through (10) or use the maximum design exhaust gas flow rate. For purposes of
determining the combined emissions from kilns that exhaust kiln gases to a coal mill that
exhausts through a separate stack, instead of installing a CEMS on the coal mill stack, the
permittee may use the results of the initial and subsequent performance test to demonstrate
compliance with the relevant emissions limit. (40 CFR 63.1349(a)).

II.B.9.c.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355.

II.B.9.c.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354 and the
notification requirements specified in 40 CFR 63.1353.

Status: In compliance. See the status under Condition II.B.4.l.1 above.

II.B.9.d Condition:

During normal operation, emissions of mercury (Hg) from the kiln shall be no greater than 55 lb/MM tons
clinker based on a rolling 30-day average. The 30-day period means all operating hours within 30
consecutive kiln operating days excluding periods of startup and shutdown. The permittee shall ensure
appropriate corrections for moisture are made when measuring flow rates used to calculate mercury
emissions. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.9.d.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348, condition II.B.4.m.1
of this permit, and R307-170, as applicable.

For purposes of determining exhaust gas flow rate to the atmosphere from a coal mill stack, the
permittee shall either install, operate, calibrate and maintain an instrument for continuously
measuring and recording the exhaust gas flow rate according to the requirements in 40 CFR
63.1350(n)(1) through (10) or use the maximum design exhaust gas flow rate. For purposes of
determining the combined emissions from kilns that exhaust kiln gases to a coal mill that
54
exhausts through a separate stack, instead of installing a CEMS on the coal mill stack, the
permittee may use the results of the initial and subsequent performance test to demonstrate
compliance with the relevant emissions limit. (40 CFR 63.1349(a)).

II.B.9.d.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit, R307-170, as
applicable, and 40 CFR 63.1355.

II.B.9.d.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354, and R307-170, as
applicable, and the notification requirements specified in 40 CFR 63.1353 and R307-170, as
applicable.

Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring
Program, as applicable. The reports are considered prompt notification of permit deviation
required in Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is
included in the report.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist.

II.B.9.e Condition:

During normal operation, emissions of total hydrocarbons (THC) from the kiln shall be no greater than 24
ppmvd, measured as propane, corrected to 7 percent oxygen, based on a rolling 30-day average. The 30-
day period means all operating hours within 30 consecutive kiln operating days excluding periods of
startup and shutdown. The permittee may elect to meet an alternative limit of 12 ppmvd for total organic
HAP. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.9.e.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348, condition II.B.4.n.1
of this permit, and R307-170, as applicable.

For purposes of determining exhaust gas flow rate to the atmosphere from a coal mill stack, the
permittee shall either install, operate, calibrate and maintain an instrument for continuously
measuring and recording the exhaust gas flow rate according to the requirements in 40 CFR
63.1350(n)(1) through (10) or use the maximum design exhaust gas flow rate. For purposes of
determining the combined emissions from kilns that exhaust kiln gases to a coal mill that
exhausts through a separate stack, instead of installing a CEMS on the coal mill stack, the
permittee may use the results of the initial and subsequent performance test to demonstrate
compliance with the relevant emissions limit. (40 CFR 63.1349(a)).

II.B.9.e.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit, R307-170, as
applicable, and 40 CFR 63.1355.

55
II.B.9.e.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354, and R307-170, as
applicable, and the notification requirements specified in 40 CFR 63.1353 and R307-170, as
applicable.

Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring
Program, as applicable. The reports are considered prompt notification of permit deviation
required in Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is
included in the report.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist.

II.B.9.f Condition:

During normal operation, emissions of hydrochloric acid (HCl) from the kiln shall be no greater than 3
ppmvd, corrected to 7 percent oxygen. This condition applies to major sources of HAP as defined in 40
CFR 63.2.

If using a CEMS to determine compliance with the HCl standard, this standard is based on a rolling 30-
day average. The 30-day period means all operating hours within 30 consecutive kiln operating days
excluding periods of startup and shutdown. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40
CFR 63.1343(b)(1)]

II.B.9.f.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348, condition II.B.4.o.1
of this permit, and R307-170, as applicable.

For purposes of determining exhaust gas flow rate to the atmosphere from a coal mill stack, the
permittee shall either install, operate, calibrate and maintain an instrument for continuously
measuring and recording the exhaust gas flow rate according to the requirements in 40 CFR
63.1350(n)(1) through (10) or use the maximum design exhaust gas flow rate. For purposes of
determining the combined emissions from kilns that exhaust kiln gases to a coal mill that
exhausts through a separate stack, instead of installing a CEMS on the coal mill stack, the
permittee may use the results of the initial and subsequent performance test to demonstrate
compliance with the relevant emissions limit. (40 CFR 63.1349(a)).

II.B.9.f.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit, R307-170, as
applicable, and 40 CFR 63.1355.

II.B.9.f.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee shall comply
with the reporting requirements specified in 40 CFR 63.1349, 40 CFR 63.1354, and R307-170, as
applicable, and the notification requirements specified in 40 CFR 63.1353 and R307-170, as
applicable.

56
Reports shall be submitted quarterly, as required by R307-170, Continuous Emission Monitoring
Program, as applicable. The reports are considered prompt notification of permit deviation
required in Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is
included in the report.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist.

II.B.10 Conditions on Materials Handling Operation (MHO).

II.B.10.a Condition:

Visible emissions shall be no greater than 10 percent opacity from each affected unit. [Origin: 40 CFR 63
Subpart LLL]. [40 CFR 63.1345]

II.B.10.a.1 Monitoring:

The permittee shall demonstrate compliance as specified in 40 CFR 63.1348.
a) The permittee shall demonstrate continuous compliance by using the monitoring methods and
procedures in 40 CFR 63.1350(f) based on the maximum 6-minute average opacity exhibited
during the performance test period. The permittee shall initiate corrective actions within one
hour of detecting visible emissions above the applicable limit.
i) The permittee shall conduct a monthly 10-minute visible emissions test of each affected
source in accordance with Method 22 of 40 CFR 60 appendix A-7. The performance test
shall 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 permittee may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the permittee shall resume performance 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 permittee may decrease the frequency of performance testing from semi-annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the permittee shall resume performance 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 performance test, of 40 CFR 60
appendix A-7, the permittee shall conduct 30 minutes of opacity observations, recorded
at 15-second intervals, in accordance with Method 9 of 40 CFR 60 appendix A-4. The
Method 9 performance test, of 40 CFR 60 appendix A-4, shall begin within 1 hour of
any observation of visible emissions.
v) Any totally enclosed conveying system transfer point, regardless of the location of the
transfer point is not required to conduct Method 22 visible emissions monitoring under
this paragraph. The enclosures for these transfer points shall be operated and maintained
as total enclosures on a continuing basis in accordance with the facility operations and
maintenance plan.
vi) If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the permittee shall conduct a Method 22 performance test, of 40 CFR 60
appendix A-7, according to the requirements of paragraphs i) through iv) of this section
for each such conveying system transfer point located within the building, or for the
building itself, according to paragraph vii) of this section.
57
vii) If visible emissions from a building are monitored, the requirements of paragraphs i)
through iv) of this section apply to the monitoring of the building, and the permittee shall
also test visible emissions from each side, roof, and vent of the building for at least 10
minutes.
viii) If visible emissions are observed during any Method 22 visible emissions test, the
permittee shall initiate, within one-hour, the corrective actions specified in the operation
and maintenance plan as required in 40 CFR 63.1347.
(40 CFR 63.1348(b)(3), 40 CFR 63.1350(f)).

II.B.10.a.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit and 40 CFR
63.1355.

Results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 22
and 9 shall be recorded and maintained in accordance with Provision I.S.1 of this permit.

II.B.10.a.3 Reporting:

The permittee shall comply with the reporting requirements specified in Section I of this permit,
40 CFR 63.1349, 40 CFR 63.1354 and the notification requirements specified in 40 CFR
63.1353.

Status: In compliance. Monthly tests have been performed and recorded.

II.B.11 Conditions on Limestone Bypass System (LBS).

II.B.11.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103030033-24, 40 CFR
60 Subpart OOO]. [40 CFR 60.672(b)]

II.B.11.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer. If any visible emissions are
observed, an opacity determination of that emission unit shall be performed by a certified visible
emissions observer within 24 hours of the initial observation in accordance with 40 CFR 60,
Appendix A, Method 9 and 40 CFR 60.675(c) and (e). For each affected emission unit, if no
visible emissions are observed for eight consecutive weeks the observation frequency shall be
reduced to a monthly basis. If visible emissions are observed during any monthly observation the
frequency shall revert back to a weekly basis.

II.B.11.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

58
II.B.11.a.3 Reporting:

Reports shall be submitted in accordance with 40 CFR 60.676(f) and as specified in Section I of
this permit.

Status: In compliance. Visible emissions have been performed and recorded on a weekly basis.

II.B.11.b Condition:

Limestone bypass material processed shall be no greater than 150,000 tons per 12-month rolling period.
[Origin: DAQE-AN103030033-24]. [R307-401-8]

II.B.11.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.11.b.2 Recordkeeping:

Daily records of limestone bypass material processed shall be kept for all periods of operation.
The permittee shall calculate a new 12-month total by the 25th day of each month using data from
the previous 12 months. Production shall be calculated through use of the plant data acquisition
system. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.11.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The 12 month rolling total ending April 30, 2024 was 74,685 tons. Records show
tracking is done in system with automatic updates and totals in spreadsheet.

II.B.11.c Condition:

Permittee shall operate water sprays or chemical dust suppression sprays to control fugitive emissions.
The sprays shall operate whenever dry conditions warrant or as determined necessary by the Director.
Water sprays shall not be required during periods of freezing temperatures. [Origin: DAQE-
AN103030033-24]. [R307-401-8]

II.B.11.c.1 Monitoring:

Visual inspections of the water or chemical dust suppression spray system(s) shall be made
weekly to ensure proper operating condition.

II.B.11.c.2 Recordkeeping:

An operator's log shall be maintained of all monitoring provisions listed above. Records of water
or chemical dust suppression spray system inspections shall be kept for all periods of operation
and the ambient temperature shall be recorded any time water should be applied but cannot be
due to freezing conditions. Records shall be maintained in accordance with Provision I.S.1 of this
permit.

59
II.B.11.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records of weekly inspections were provided.

II.B.12 Conditions on GEN: Emergency Generators.

II.B.12.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [Origin: R307-305-3(3), DAQE-
AN103030033-24]. [R307-305-3(3), R307-401-8]

II.B.12.a.1 Monitoring:

During any period that the emergency generator(s) is(are) operated for longer than 12 hours
consecutively, visual observation(s) of each generator exhaust shall be made by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is
not required to be a certified visual emissions observer. If any visible emissions are observed,
then a 6-minute opacity determination shall be performed in accordance with 40 CFR 60,
Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, by
a certified visual emissions observer. If the generator(s) continue to operate on consecutive days
following the initial observation, an opacity determination shall be performed on a daily basis.

II.B.12.a.2 Recordkeeping:

The permittee shall record the date of each visual opacity survey and keep a list of the emission
points checked during the visual opacity survey. The permittee shall also keep a log of the
following information for each observed visual emission: date and time visual emissions
observed, emission point location and description, time and date of opacity test, and percent
opacity. The records required by this provision and all data required by 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director, shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.12.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. No approved generator operating for longer than 12 hours during the 12-month
period preceding this inspection. The three newly approved generators have not been purchased or
installed. All compliance is based on the existing single 762 Hp engine.

II.B.12.b Condition:

For the 762 hp (kiln, shipping) engines:
2007 model year and later emergency affected emission units with a displacement of less than 30 liters
per cylinder that are not fire pump engines shall comply with the emission standards for new nonroad CI
ICE in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine power for their
2007 model year and later emergency stationary CI ICE. Modified or reconstructed affected emission
60
units shall meet the emission standards for new nonroad CI ICE in 40 CFR 60.4202 applicable to the
model year, maximum engine power, and displacement of the modified or reconstructed engine. If the
permittee conducts performance tests in-use on emergency stationary CI ICE with a displacement of less
than 30 liters per cylinder they shall meet the not-to-exceed (NTE) standards as indicated in 40 CFR
60.4212. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4205(b), 40 CFR 60.4205(e), 40 CFR 60.4205(f)]

II.B.12.b.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4205(b) for the same model year and maximum engine power. The engine shall be
installed and configured according to the manufacturer's emission-related specifications, except
as permitted below. (Origin: 40 CFR 60.4211(c))

If the permittee does not install, configure, operate, and maintain affected emission units and
control devices according to the manufacturer's emission-related written instructions, or changes
emission-related settings in a way that is not permitted by the manufacturer, the permittee shall
demonstrate compliance as follows:
(a) For affected emission units greater than 500 HP:
i. Keep a maintenance plan and records of conducted maintenance; and
ii. To the extent practicable, maintain and operate the engine in a manner consistent with
good air pollution control practice for minimizing emissions; and
iii. Conduct an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of startup, or within 1 year after an engine and control
device is no longer installed, configured, operated, and maintained in accordance with the
manufacturer's emission-related written instructions, or within 1 year after changing
emission-related settings in a way that is not permitted by the manufacturer. The
permittee shall conduct subsequent performance testing every 8,760 hours of engine
operation or 3 years, whichever comes first, thereafter to demonstrate compliance with
the applicable emission standards.
(Origin: 40 CFR 60.4211(g))

For modified or reconstructed affected emission units that must comply with the emission
standards specified in 40 CFR 60.4205(f), the permittee shall demonstrate compliance by
purchasing, or otherwise owning or operating, an engine certified to the emission standards in 40
CFR 60.4205(f) or by conducting a performance test to demonstrate initial compliance with the
emission standards according to the requirements specified in 40 CFR 60.4212. The test shall be
conducted within 60 days after the engine commences operation after the modification or
reconstruction. [40 CFR 60.4211(e)]

II.B.12.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.12.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Engines purchased meet the specifications required by this section for the model
year. Visual inspection of name plate and records confirm compliance.

61
II.B.12.c Condition:

For the 762 hp (kiln, shipping) engines:
For all affected emission units, except those that are modified, reconstructed, or removed from one
existing location and reinstalled at a new location, the permittee shall comply with paragraphs (a) through
(b).
(a) After December 31, 2008, the permittee shall not install affected emission units (excluding fire pump
engines) that do not meet the applicable requirements for 2007 model year engines.
(b) In addition to the requirements specified in 40 CFR 60.4202 and 40 CFR 60.4205, the permittee shall
not import stationary CI ICE with a displacement of less than 30 liters per cylinder that do not meet
the applicable requirements specified in 40 CFR 60.4208 after the dates specified in 40 CFR
60.4208.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4208]

II.B.12.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.12.c.2 Recordkeeping:

The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart IIII for the respective model year engine.
Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.12.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The engine purchased meets the specifications required by this section for the model
year. Visual inspection of name plate and records confirm compliance.

II.B.12.d Condition:

For the 762 hp (kiln, shipping) engines:
The permittee shall operate and maintain affected emission units that achieve the emission standards as
required in 40 CFR 60.4205 over the entire life of the engine. The permittee shall do all of the following,
except as permitted in II.B.12.d.1(b):
(1) Operate and maintain the stationary CI ICE and control device according to the manufacturer's
emission-related written instructions;
(2) Change only those emission-related settings that are permitted by the manufacturer; and
(3) Meet the requirements of 40 CFR part 1068, as applicable.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4206, 40 CFR 60.4211(a)]

II.B.12.d.1 Monitoring:

(a) The permittee shall document activities performed to assure proper operation and
maintenance.
(b) If the permittee does not install, configure, operate, and maintain affected emission units and
control devices according to the manufacturer's emission-related written instructions, or
62
changes emission-related settings in a way that is not permitted by the manufacturer, the
permittee shall demonstrate compliance as follows:
(1) For affected emission units greater than 500 HP:
a. Keep a maintenance plan and records of conducted maintenance; and
b. To the extent practicable, maintain and operate the engine in a manner consistent
with good air pollution control practice for minimizing emissions; and
c. Conduct an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of startup, or within 1 year after an engine and
control device is no longer installed, configured, operated, and maintained in
accordance with the manufacturer's emission-related written instructions, or within 1
year after changing emission-related settings in a way that is not permitted by the
manufacturer. The permittee shall conduct subsequent performance testing every
8,760 hours of engine operation or 3 years, whichever comes first, thereafter to
demonstrate compliance with the applicable emission standards.
(Origin: 40 CFR 60.4211(g)).

II.B.12.d.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.12.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The engine is maintained per manufacturer instructions and no modifications have
been made.

II.B.12.e Condition:

For the 762 hp (kiln, shipping) engines:
The permittee of affected emission units with a displacement of less than 30 liters per cylinder that use
diesel fuel shall use diesel fuel that meets the following ULSD per-gallon standards of 40 CFR 1090.305
for nonroad diesel fuel.
1. Maximum sulfur content of 15 ppm and
2. A minimum cetane index of 40 or a maximum aromatic content of 35 volume percent.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4207(b)]

II.B.12.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.12.e.2 Recordkeeping:

The permittee shall maintain documentation that all diesel fuel meets the specifications of 40
CFR 1090.305. Certification of diesel fuel shall be either by the permittee’s own testing using
ASTM Method D2880-71, D4294-89, or other method approved by the Director, or by fuel
receipt records from the vendor documenting test results. The diesel fuel purchase invoices and/or
certifications shall indicate the diesel fuel meets the requirements in 40 CFR 1090.305. Records
demonstrating compliance with this condition shall be maintained in accordance with Provision
I.S.1. of this permit.
63
II.B.12.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Diesel fuel meets the specifications under this condition. Records are kept
confirming compliance.

II.B.12.f Condition:

For the 762 hp (kiln, shipping) engines:
The permittee shall operate the emergency affected emission units according to the requirements in
paragraphs (1) through (3). In order for the engine to be considered an emergency stationary ICE under
40 CFR 60 Subpart IIII, any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in (1) through (3), is prohibited.
If the engine is not operated in accordance with paragraphs (1) through (3), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) Emergency stationary ICE may be operated for the purpose specified in paragraph (a) for a
maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by
paragraph (3) counts as part of the 100 hours per calendar year allowed by this paragraph (2).
(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or local
standards require maintenance and testing of emergency ICE beyond 100 hours per calendar
year.
(3) Emergency engines may operate up to 50 hours per calendar year in non-emergency situations. The
50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar
year for maintenance and testing provided in paragraph (2). Except as provided in 40 CFR
60.4211(f)(3)(i), the 50 hours per calendar year for non-emergency situations cannot be used for
peak shaving or non-emergency demand response, or to generate income for a facility to an electric
grid or otherwise supply power as part of a financial arrangement with another entity.
[Origin: 40 CFR 40 CFR 60 Subpart IIII]. [40 CFR 60.4211(f)]

II.B.12.f.1 Monitoring:

If an emergency affected emission unit does not meet the standards applicable to non-emergency
engines, the permittee shall install a non-resettable hour meter prior to startup of the engine.
[Origin: 40 CFR 60.4209(a)] Records required for this permit condition will also serve as
monitoring.

II.B.12.f.2 Recordkeeping:

Records of each affected emission unit shall be kept on a monthly basis in an operation and
maintenance log. Records shall distinguish between maintenance-related hours and emergency
use-related hours. If additional hours are to be used for maintenance checks and readiness testing,
the permittee shall maintain records indicating that federal, state, or local standards require
maintenance and testing of emergency ICE beyond 100 hours per calendar year.
64
Starting with the model years in Table 5 of 40 CFR 60 Subpart IIII, if an affected emission unit
does not meet the standards applicable to non-emergency engines in the applicable model year,
the permittee shall keep records of the operation of the engine in emergency and non-emergency
service that are recorded through the non-resettable hour meter. The permittee shall record the
time of operation of the engine and the reason the engine was in operation during that time.
(Origin: 40 CFR 60.4214(b))

Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.12.f.3 Reporting:

For each affected emergency emission unit with a maximum engine power more than 100 HP that
operates for the purpose specified in 40 CFR 60.4211(f)(3)(i), the permittee shall submit an
annual report according to the requirements in 40 CFR 60.4214(d).

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. Handwritten hour logs with all required information are maintained. Review of this
record confirms compliance.

II.B.12.g Condition:

For the 304 hp natural gas-fired generators (main office, control room):

(i) For stationary SI ICE with a maximum engine power greater than or equal to 75 KW (100 HP)
(except gasoline and rich burn engines that use LPG), the permittee shall comply with the emission
standards in Table 1 of 40 CFR 60 Subpart JJJJ. (40 CFR 60.4233(e))
(ii) For emergency stationary SI ICE with a maximum engine power of greater than 19 KW (25 HP), the
permittee shall not install engines that do not meet the applicable requirements in 40 CFR 60.4233
after January 1, 2011. (40 CFR 60.4236(c)) This requirement does not apply to affected emission
units that have been modified or reconstructed, and it does not apply to affected emission units that
were removed from one existing location and reinstalled at a new location. (40 CFR 60.4236(e))
(iii) The permittee shall operate and maintain affected emission units that achieve the emission standards
as required in this condition over the entire life of the engine (40 CFR 60.4234)
(iv) The air-to-fuel ratio (AFR) controller, if used, shall be maintained and operated appropriately by the
permittee in order to ensure proper operation of affected emission units and control device to
minimize emissions at all times. (40 CFR 60.4243(g))
(v) The permittee may operate the engines using propane for a maximum of 100 hours per year as an
alternative fuel solely during emergency operations, but must keep records of such use. If propane is
used for more than 100 hours per year in an engine that is not certified to the emission standards
when using propane, the permittee is required to conduct a performance test to demonstrate
compliance with the emission standards of 40 CFR 60.4233. (40 CFR 60.4243(e))
[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4233(e), 40 CFR 60.4234, 40 CFR 60.4236, 40 CFR
60.4243, 40 CFR 63 Subpart ZZZZ]

65
II.B.12.g.1 Monitoring:

(a) For affected emission units subject to 40 CFR 60.4233(e), the permittee shall demonstrate
compliance according to one of the methods specified in paragraphs (a)(1) and (2) of this
section.
(1) Purchasing an engine certified according to procedures specified in 40 CFR 60 Subpart
JJJJ, for the same model year and demonstrating compliance according to one of the
methods specified in paragraphs (1)a) and b) of this section.
a) If the permittee operates and maintains the certified stationary SI internal
combustion engine and control device according to the manufacturer's emission-
related written instructions, the permittee shall keep records of conducted
maintenance to demonstrate compliance, but no performance testing is required.
The permittee shall also meet the requirements as specified in 40 CFR part 1068,
subparts A through D, as they apply. If the permittee adjusts engine settings
according to and consistent with the manufacturer's instructions, the affected
emission unit will not be considered out of compliance.
b) If the permittee does not operate and maintain the certified stationary SI internal
combustion engine and control device according to the manufacturer's emission-
related written instructions, the engine will be considered a non-certified engine,
and the permittee shall demonstrate compliance according to (i) of this section.
(i) If the affected emission unit is greater than or equal to 100 HP and less than or
equal to 500 HP, the permittee shall keep a maintenance plan and records of
conducted maintenance and shall, to the extent practicable, maintain and
operate the engine in a manner consistent with good air pollution control
practice for minimizing emissions. In addition, the permittee shall conduct an
initial performance test within 1 year of engine startup to demonstrate
compliance.
(2) Purchasing a non-certified engine and demonstrating compliance with the emission
standards specified in 40 CFR 60.4233(e) and according to the requirements specified
in 40 CFR 60.4244, as applicable, and according to paragraph (2)a) of this section.
a) If the affected emission unit is greater than 25 HP and less than or equal to 500
HP, the permittee shall keep a maintenance plan and records of conducted
maintenance and shall, to the extent practicable, maintain and operate the engine
in a manner consistent with good air pollution control practice for minimizing
emissions. In addition, the permittee shall conduct an initial performance test to
demonstrate compliance.
(Origin: 40 CFR 60.4243(b))
(b) For affected emission units less than or equal to 500 HP and the permittee purchases a non-
certified engine or does not operate and maintain the certified affected emission unit and
control device according to the manufacturer's written emission-related instructions, the
permittee is required to perform initial performance testing as indicated in this section, but is
not required to conduct subsequent performance testing unless the stationary engine
undergoes rebuild, major repair or maintenance as specified in 40 CFR 60.4243(f). (Origin:
40 CFR 60.4243(f))
(c) The permittee shall conduct performance tests in accordance with the procedures in 40 CFR
60.4244(a) through (f). (Origin: 40 CFR 60.4244)

Records required for this permit condition will also serve as monitoring.

66
II.B.12.g.2 Recordkeeping:

(a) For each affected emission unit, the permittee shall keep records of the information in
paragraphs (a)(1) through (4) of this section.
(1) All notifications submitted to comply with this condition and all documentation
supporting any notification.
(2) Maintenance conducted on each affected emission unit.
(3) If the affected emission unit is a certified engine, documentation from the manufacturer
that the affected emission unit is certified to meet the emission standards and
information as required in 40 CFR parts 1048, 1054, and 1060, as applicable.
(4) If the affected emission unit is not a certified engine or is a certified engine operating in
a non-certified manner and subject to section (a)(1)b) of monitoring, documentation
that the engine meets the emission standards.
(Origin: 40 CFR 60.4245(a))
(b) The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart JJJJ for the respective model year engine.
(c) If the engines are operated using propane for a maximum of 100 hours per year as an
alternative fuel solely during emergency operations, the permittee shall keep records of such
use. (40 CFR 60.4243(e))

Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.12.g.3 Reporting:

For affected emission units that are subject to performance testing, the permittee shall submit a
copy of each performance test as conducted in 40 CFR 60.4244 within 60 days after the test has
been completed. (Origin: 40 CFR 60.4245(d))

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: These engines have not been purchased or installed. No determination made.

II.B.12.h Condition:

For the 304 hp natural gas-fired generators (main office, control room):

The permittee shall operate the emergency affected emission unit according to the requirements in
paragraphs (1) through (3). In order for the engine to be considered an emergency stationary ICE under
40 CFR 60 Subpart JJJJ, any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in (1) through (3), is prohibited.
If the engine is not operated in accordance with paragraphs (1) through (3), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.
(2) Emergency stationary ICE may be operated for the purpose specified in 40 CFR 60.4243(d)(2)(i) for
a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed
by paragraph (3) counts as part of the 100 hours per calendar year allowed by this paragraph.
(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
67
authority and transmission operator, or the insurance company associated with the engine. The
permittee may petition for approval of additional hours to be used for maintenance checks and
readiness testing, but a petition is not required if the permittee maintains records indicating that
federal, state, or local standards require maintenance and testing of emergency ICE beyond 100
hours per calendar year.
(3) Emergency stationary ICE may operate up to 50 hours per calendar year in non-emergency
situations, as specified in 40 CFR 60.4243(d)(3).
[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4243(d), 40 CFR 63 Subpart ZZZZ]

II.B.12.h.1 Monitoring:

If the emergency stationary SI ICE that is greater than or equal to 130 HP and less than 500 HP
that was built on or after January 1, 2011, does not meet the standards applicable to non-
emergency engines, the permittee shall install a non-resettable hour meter. (40 CFR 60.4237(b))
Records required for this permit condition will also serve as monitoring.

II.B.12.h.2 Recordkeeping:

Records shall be kept in accordance with 40 CFR 60.4243(d), as applicable.

For each affected emission unit greater than or equal to 130 HP and less than 500 HP
manufactured on or after July 1, 2011 that does not meet the standards applicable to non-
emergency engines, the permittee shall keep records of the hours of operation of the affected
emission unit that is recorded through the non-resettable hour meter. The permittee shall
document how many hours are spent for emergency operation, including what classified the
operation as emergency and how many hours are spent for non-emergency operation.
(Origin: 40 CFR 60.4245(b))

Documentation shall be kept that demonstrates compliance with this provision. Records shall be
maintained as described in Provision I.S.1 of this permit.

II.B.12.h.3 Reporting:

The permittee shall submit an annual report in accordance with 40 CFR 60.4245(e), as applicable.
There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: These engines have not been purchased or installed. No determination made.

II.B.12.i Condition:

For the 762 hp (shipping) engine:
The permittee shall submit an Initial Notification as required in 40 CFR 63.6645(f) for each new or
reconstructed emergency stationary RICE. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6590(b)(1)]

II.B.12.i.1 Monitoring:

Records required for this permit condition will serve as monitoring.

68
II.B.12.i.2 Recordkeeping:

The permittee shall keep a copy of each notification in accordance with 40 CFR 63.6660 and
Provision I.S.1 of this permit.

II.B.12.i.3 Reporting:

For each affected emission unit, the permittee shall submit an Initial Notification containing the
information in 40 CFR 63.9(b)(2)(i) through (v), and a statement that the stationary RICE has no
additional requirements and that explains the basis of the exclusion (for example, that it operates
exclusively as an emergency stationary RICE if it has a site rating of more than 500 brake HP
located at a major source of HAP emissions). There are no additional reporting requirements for
this provision except those specified in Section I of this permit.

Status: This engine has not been purchased or installed. No determination made.

II.B.13 Conditions on Dust Shuttle System

II.B.13.a Condition:

The fringe bin baghouse (514.BF3) and the alkali silo baghouse (413.BF1) shall be operating at all times
when the dust shuttle system is operating to assist in the capture of mercury emissions. [Origin: DAQE-
AN103030033-24]. [R307-401-8]

II.B.13.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.13.a.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.13.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. This system has been installed and is operating at all times when the dust shuttle
system is operating.

II.B.14 Conditions on Stockpiles

II.B.14.a Condition:

For the coal storage stockpile, which includes the equipment used in the loading, unloading, and
conveying operations of the affected facility, the permittee shall prepare and operate in accordance with a
submitted fugitive coal dust emissions control plan that is appropriate for the site conditions as specified
below.
i. The fugitive coal dust emissions control plan shall identify and describe the control measures the
permittee will use to minimize fugitive coal dust emissions from each open storage pile.
69
ii. For open coal storage piles, the fugitive coal dust emissions control plan shall require that one or more
of the control measures specified in 40 CFR 60.254(c)(2) be used to minimize to the greatest extent
practicable fugitive coal dust. The permittee shall select, for inclusion in the fugitive coal dust
emissions control plan, the control measure or measures listed in 40 CFR 60.254(c)(2) that are most
appropriate for site conditions. The plan shall also explain how the measure or measures selected are
applicable and appropriate for site conditions. In addition, the plan shall be revised as needed to
reflect any changing conditions at the source.
iii. Petitions to approve, for inclusion in the plan, alternative control measures shall be as specified in 40
CFR 60.254(c)(3).
iv. The permittee shall submit the fugitive coal dust emissions control plan to the Director prior to startup
of the new affected facility. The plan shall be revised as needed to reflect any changing conditions at
the source. Such revisions shall be dated and submitted to the Director before a source can operate
pursuant to these revisions. The Director may also object to such revisions as specified in 40 CFR
60.254(c)(5).
v. Where appropriate chemical dust suppression agents are selected by the permittee as a control
measure to minimize fugitive coal dust emissions, (1) only chemical dust suppressants with
Occupational Safety and Health Administration (OSHA)-compliant material safety data sheets
(MSDS) shall be allowed; (2) the MSDS shall be included in the fugitive coal dust emissions control
plan; and (3) the permittee shall consider and document in the fugitive coal dust emissions control
plan the site-specific impacts associated with the use of such chemical dust suppressants.
[Origin: 40 CFR 60 Subpart Y]. [40 CFR 60.250(d), 40 CFR 60.254(c)]

II.B.14.a.1 Monitoring:

Adherence to the most recently submitted fugitive coal dust emissions control plan shall be
monitored to demonstrate that appropriate control measures are being implemented to minimize
fugitive coal dust to the greatest extent practicable. The plan shall be revised as needed to reflect
any changing conditions at source.

Records required for this permit condition will also serve as monitoring.

II.B.14.a.2 Recordkeeping:

The permittee shall keep a copy of the most recently submitted fugitive coal dust control plan on
site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have
been included in the plan and that the source is operating in accordance with the submitted plan.

For petitions to approve alternative control measures, the permittee shall keep a copy of the
submitted petition and any approvals received.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

The permittee shall submit the fugitive coal dust emissions control plan to the Director prior to
startup of each new affected facility. Plan revisions that reflect changing conditions at the source
shall be dated and submitted before the source can operate pursuant to those revisions. If an
objection is raised in accordance with 40 CFR 60.254(c)(5), the permittee shall submit a revised
plan within 30 days from receipt of the objection.

70
There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. The FDCP was submitted to DAQ and approved in letter dated May 14, 2024.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios
(R307-415-6a(9))

Not applicable to this source.
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. 40 CFR 63 Subpart CCCCCC (NESHAP for Source Category: Gasoline Dispensing Facilities)

This regulation is not applicable to the Permitted Source for the following reason(s): it applies to
area sources of HAPs and the permitted source is a major HAP source. [Last updated March 21,
2023]

III.B. 40 CFR 60 Subpart OOO (NSPS / Standards of Performance for Nonmetallic Mineral Processing
Plants)

This regulation is not applicable to the 211.BF1: Stationary Crusher for the following reason(s): it
was constructed in 1981, prior to the Subpart OOO applicability date of August 31, 1983 [Last
updated March 21, 2023]

III.C. 40 CFR 60 Subpart OOO (NSPS / Standards of Performance for Nonmetallic Mineral Processing
Plants)

This regulation is not applicable to the 211.BF2: Raw Material Transfer for the following reason(s):
it was constructed in 1981, prior to the Subpart OOO applicability date of August 31, 1983. [Last
updated March 21, 2023]

III.D. 40 CFR 63.1349(b)(3), 63.1350(g) (NESHAP for the Portland Cement Manufacturing Industry)

This regulation is not applicable to the 41B.BF2: Coal Grinding System for the following reason(s):
EPA granted a waiver in a letter dated November 6, 2002 from Martin Hestmark, EPA, to Robert
Vantuyl, Ash Grove. The waiver is contingent on Ash Grove's compliance with Conditions II.B.4.f,
II.B.4.g, II.B.4.k, and II.B.9.b of this permit. [Last updated March 21, 2023]

71
SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

EMISSIONS
INVENTORY: Taken from DAQ’s 2022 emissions inventory database:

Pollutant Tons/yr

PM10 ....................... 90.07
PM2.5..................... 42.09
SO2 ........................ 11.03
NOx.................. 1,191.20
CO ..................... 2,380.75
VOC ....................... 49.97
Benzene.................... 1.25
Ammonia ............... 75.59

PREVIOUS ENFORCMENT
ACTIONS: None within the last five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: This facility should be considered in compliance with the Title V
Conditions evaluated during this inspection.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: Some discussion on new sources (generators) and certification
requirements.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal

ATTACHMENTS: VEO form