DAQ-2024-008324

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DAQC-522-24
Site ID 10313 (B1)

MEMORANDUM

TO: FILE – GRAYMONT WESTERN US INC. – Cricket Mountain Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: May 29, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Millard County,
FRS ID #UT0000004902700005

INSPECTION DATE: May 22, 2024

SOURCE LOCATION: Highway 257, Cricket Mountain, 32 miles Southwest of Delta,
Millard County

MAILING ADDRESS: Cricket Mountain Plant, P.O. Box 669, 32 Miles Southwest of
Delta, UT 84624

SOURCE CONTACTS: Eric Bennett – Quality/Environmental Technician
[phone]

Cade Nielson – Quality/Environmental Supervisor
[phone]

OPERATING STATUS: Operating. Units 1,3,4 on line unit 5 taken off line during
inspections.

PROCESS DESCRIPTION: The Cricket Mountain Lime Plant consists of quarries and a lime
processing plant, including mining activities, limestone
processing, five rotary lime kilns, post-kiln lime handling, and
truck and rail load out facilities. The rotary kilns are used to
convert crushed limestone ore into quicklime. The products
produced for sale are lime, limestone, and kiln dust. The major
sources of air emissions are from mining and material handling
and the combustion of fuels for the kiln operation.

Limestone is blasted to loosen it from the quarry face. The
blasted material is loaded into haul trucks and transferred to a
feeder at the primary crushing plant. The limestone material is
crushed in a horizontal crusher and then sized by a triple deck
screener. After sizing, the limestone is conveyed to one of the
three stockpiles: waste, small stone, and large stone. From the
limestone stockpiles, the material is conveyed into bottom dump
haul trucks and trucked from the quarry to the processing plant.

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Water sprays are used to control the fugitive dust on the
crushers, screens, and conveyors. A water truck is used to
control the fugitive dust from the roadways, along with chemical
treatment.

At the processing plant, the limestone is dumped into one of
three hoppers and then conveyed to one of three radial stackers.
The stone is finally conveyed from the stackers to the desired
live pile, through another screen, fed to the stone grinding
facility, and then to the kiln preheater. The material is fed into
the preheater by hydraulic rams. The stone passes through the
preheater and into a coal fired rotary kiln that operates at
approximately 2,200 degrees F. The tumbling action of the kiln
and the high temperature chemically alters the limestone to lime.
The lime exits the kiln and is air cooled, crushed, and screened to
create the required product size. The lime is then transferred by
conveyor to storage silos, which feed the truck and railcar load
out facility. All equipment located at the processing plant is
vented into baghouses for emissions control.

APPLICABLE
REGULATIONS: Title V Operating Permit 2700005004, issued
September 13, 2021.
Last revised April 1, 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 HH-Standards of Performance for Lime
Manufacturing 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,
40 CFR 63 Subpart A-General Provisions,
40 CFR 63 Subpart ZZZZ-National Emission Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,
40 CFR 63 Subpart AAAAA-National Emission Standards for
Hazardous Air Pollutants for Lime Manufacturing Plants.
If the permittee is operating as an area HAP source in
accordance with the alternate operating scenario (AOS) in
Section II.D of this permit, 40 CFR 63 Subpart CCCCCC-
National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities applies and 40
CFR 63 Subpart AAAAA does not apply.

SOURCE INSPECTION
EVALUATION:

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SECTION I: GENERAL PROVISIONS

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.

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 the conditions of
this permit. See each condition below for specific 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. The permittee appeared to be in compliance with all conditions of this permit
at the time of inspection. See specific conditions below.

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))
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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))

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: In Compliance. This permit expires September 13, 2026. Application is due March 13, 2026.

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: In Compliance. This permit expires September 13, 2026. Application is due March 13, 2026.

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: Not Evaluated. This is a statement of fact.

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. Emission 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.
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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.

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. Access was granted to the facility and records. No claims of confidentiality
were made.

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 documents submitted by Graymont in the past year have been signed by
the 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
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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;

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 latest annual compliance certification was sent on August 30, 2023. This
report 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))

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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))

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)(a)(xiii) 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: No permit shields are listed for this source.

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
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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))

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:

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

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. The company has provided all records as requested. Monitoring reports have
been submitted every six months. Deviation reports are submitted as necessary.

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))

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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))

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. Latest inventory was
submitted April 12, 2024.

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 K-1: Lime Kiln #1
Rotary lime kiln and preheater exhaust stack, with emissions controlled by a baghouse (D-85).

II.A.3 K-2: Lime Kiln #2
Rotary lime kiln and preheater exhaust stack, with emissions controlled by a cyclone and baghouse
(D-275).

II.A.4 K-3: Lime Kiln #3
Rotary lime kiln and preheater exhaust stack, with emissions controlled by a cyclone and baghouse
(D-375).

II.A.5 K-4: Lime Kiln #4
Rotary lime kiln and preheater exhaust stack, with emissions controlled by a cyclone and baghouse
(D-485).

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II.A.6 K-5: Lime Kiln #5
Rotary lime kiln and preheater exhaust stack, with emissions controlled by a baghouse (D-585).

II.A.7 K-1-5: Lime Kilns #1 through #5
Combination of 5 rotary lime kilns listed above.

II.A.8 ME: Miscellaneous Engines
Unit includes five kiln drive engines (KDE) used to rotate the kilns during power outages and certain
maintenance activities. KDE 1 (74 hp), KDE 2 (45 hp), KDE 4 (65 hp), and KDE 5 (173.5 hp) shall use
diesel for fuel. KDE 3 (55 hp) shall use gasoline for fuel.

II.A.9 A:NSPS-OOO: Observation Point A: NSPS Subpart OOO Baghouses
Baghouse exhaust stacks: D-7122 (grinding mill, direct-fire heater, material separator), D-7133 (screen, 3
bucket elevators, 3 storage silos), D-7141 (truck & rail loadouts), D-310 (kiln #3 stone dressing screen),
D-414 (kiln #4 stone dressing screen) & D-403 (C-408 & C-409 to reclaim pile), D-514 (kiln #5 stone
dressing screen), D-503 (kiln #5 stone transfer from C-510 and C-511 to C-512).

II.A.10 A: NON-NSPS-OOO: Observation Point A: Non-Subpart OOO Baghouses
Baghouse exhaust stacks: D-10 (kilns #1 & #2 stone reclaim screens), D-331 (kilns #1 & #2 loadout area
and screen house), D-479 (dolomitic (435) system includes: 2 elevators, vibratory conveyor, belt
conveyors, and mixing screw conveyor, S-471, T-471, T-472, T-473, T-474), D-330 (kiln #3 cooler pit),
D-488 (R-486 (dolomitic lime crusher), BRI-474 and BRI 014 (briquetters), T-470 (silo)), D-83 (kilns #1
and #2 lime kiln dust (LKD) silo), D-341 (T-341 lime silo), D-333 (lime rail loadout, S-466 screen),
D-466 (LKD silo), D-381 (T-381 LKD silo), D-382 (loadout spout for T-381 LKD silo).

II.A.11 A: SCREENS: Observation Point A: Limestone Screens
S-10 (Kilns #1 & #2 scalp screen), S-310 (Kiln #3 scalp screen) & S-411 (Kiln #4 scalp screen), Sugar
Stone System screen (S-2).

II.A.12 A: COAL SILO: Observation Point A: Coal Silo
The coal storage system controlled by baghouses: D-91 (Kiln #1 coal silo), D-94 (Kiln #2 coal silo) &
D-391 (Kiln #3 coal silo).

II.A.13 A: DROP POINTS: Observation Point A: Drop Points
Material drop points: stacker belts (C-309, C-9, C-409, C-311, C-11, C-412), silo loadout (U-465, K1,
K2, K3 rail load out, K1, K2, K3 kiln dust silo load out & K1, K2, K3 core bin load out), drop to bunkers
from D-10, D-310, C-465 & PH-0, and drop to: hopper (HP-1), conveyors (C10-C13), screen (S-2), rail
loadout (203255SSS001) for Sugar Stone System.

II.A.14 A: CRUSHER: Observation Point A: Dolomitic Lime Crusher
Crusher: R-486 (dolomitic lime crusher).

II.A.15 B: DROP POINTS: Observation Point B: Drop Points
Material drop points to hoppers.

II.A.16 C: NSPS-OOO: Observation Point C: NSPS Subpart OOO Baghouses
Baghouse exhaust stack: D-415 (stone transfer to Kiln #4 preheater).

II.A.17 C: NON-NSPS-OOO: Observation Point C: Non-Subpart OOO Baghouses
Baghouse exhaust stacks: D-447 (Kiln #4 cooler and screen house), D-463 (kiln #4 product loadout and
C-463), D-530, D-547, D-564 (three baghouses for Kiln #5 screen house), D-486 (Kiln #4 LKD silo),
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D-489 (kiln #4 LKD silo), D-586 (Kiln #5 LKD silo), D-589 (Kiln #5 LKD silo loadout).

II.A.18 C: COAL SILO: Observation Point C: Coal Silo
The coal storage system controlled by a baghouse: D-491 (Kiln #4 coal silo), D-591 (Kiln #5 coal silo).

II.A.19 C: DROP POINTS: Observation Point C: Drop Points
Drop to: LKD pugging T-486, LKD loadout (T-486), dolomitic lime recycle bin (N-470), PH-421 to
bunker & N-432 (Kiln #4 core bin) loadout, belt conveyors of the 435 material handling system.

II.A.20 D: SCREENS: Observation Point D: Limestone Screens
Screens: S-1 (primary screen).

II.A.21 D: DROP POINTS: Observation Point D: Drop Points
Material drop points: stacker belts (C-3, C-304, C-4 & sugar stone stacker) & loadout operations (C-305,
C-5 & C-045).

II.A.22 A, C NSPS-OOO: A, C NSPS Subpart OOO Baghouses
Includes baghouse exhaust stacks identified under A:NSPS-OOO and C:NSPS-OOO.

II.A.23 A, C NON-NSPS-OOO: Non-Subpart OOO Baghouses
Includes baghouse exhaust stacks identified under A:NON-NSPS-OOO and C:NON-NSPS-OOO.

II.A.24 A, D SCREENS: Limestone Screens
Includes limestone screens identified under A:SCREENS and D:SCREENS.

II.A.25 A, C COAL SILO: Coal Silo
Includes coal storage systems controlled by baghouses that are identified under A:COAL SILO and C:
COAL SILO.

II.A.26 A, B, C, D TRANSFER PTS: Conveyor Transfer Points
Material transfer to and from conveyor belts, observable from Observation Points A, B, C, or D. Includes
conveyor transfer points observable from Observation Point C including the limestone grinding plant and
sugar stone system.

II.A.27 A, C COAL TRANSFER PTS: Coal Conveyor Transfer Points
Includes coal processing and conveying equipment, observable from Observation Point A or C.

II.A.28 A, B, C, D DROP POINTS: Drop Points
Includes material drop points identified under A: DROP POINTS, B: DROP POINTS, C: DROP
POINTS, and D: DROP POINTS.

II.A.29 A: GENERATOR: Sugar Stone System
A 130.1 hp generator (GEN-1) fired on diesel fuel only. Supplies power to the screen in Sugar Stone
System, observable from observation point A.

II.A.30 LS-GRIND: Direct Fire Heating System
Heating system within the limestone grinding plant.

II.A.31 D: NSPS-OOO: Observation Point D: NSPS Subpart OOO Baghouses
Baghouse exhaust stack: D-1 (quarry crusher and screen).

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II.A.32 D: CRUSHERS: Observation Point D: Limestone Crushers
Crushers: R-1 (primary crusher).

II.A.33 LQ: Limestone Quarries
All mining activities, including drilling & blasting, not otherwise specified. No unit -specific applicable
requirements.

II.A.34 MISC: Miscellaneous Emissions
Emission sources with no unit-specific requirements such as painting, laboratory, acetylene combustion,
parts cleaners and comfort heaters. No unit-specific applicable requirements.

II.A.35 AB: Abrasive Blasting
Equipment used for abrasive blasting.

II.A.36 TANKS: Fuel Storage Tanks
Four 10,150-gallon diesel storage tanks and one 12,000-gallon diesel storage tank, one 2,000-gallon
gasoline tank, and one 500-gallon gasoline tank. Throughput is less than 10,000 gallons per month for the
gasoline storage tanks.

II.A.37 HR: Haul Roads
HR-1 haul road from paved highway to plant and from plant to quarry, and HR-2 haul road inside the
quarry.

II.A.38 SS: Sugar Stone System
This system stores, screens, and loads sugar stone (approximately 6"x3"). Includes a hopper (HP-1),
screen (S-2), loadout system (203255SSS001), conveyors, and generator (GEN-1).

II.A.39 PCS-0: Portable Crushing System
Includes a feed hopper (HP-2), primary crusher and secondary crusher (Unit #PCS-1), screen and
conveyor transfer points (Unit #PCS-2), conveyor drop points (Unit # PCS-3), and three diesel engines
(Unit #PCS-4).

II.A.40 PCS-1: Portable Crushing System Crushers
Primary crusher (ICR101) and secondary crusher (ICR102) used to crush limestone at the quarry. Each
crusher is rated at 690 tons per hour.

II.A.41 PCS-2: Portable Crushing System Screen/Conveyor Transfer Points
Screen and material transfer points to and from conveyor belts used in the portable crushing system
observable from Observation Points A, B, C, or D.

II.A.42 PCS-3: Portable Crushing System Conveyor Drop Points
Material drop points to the fines and product stockpiles.

II.A.43 PCS-4: Portable Crushing System Engines
Three diesel engines, 740 hp combined, that power the crushers, screen, and conveyor belts in the
portable crushing system.

II.A.44 PW: Pressure Washers
A portable pressure washer is used to wash equipment prior to performing maintenance. It consists of an
18 hp gasoline engine to pressurize the water and a burner to heat the water. The burner uses diesel fuel
14
at a maximum rate of 0.42 MMBtu/hr. A second pressure washer is stationary with a 0.4 MMBtu/hr
propane heater and an electric motor. No unit-specific applicable requirements.

II.A.45 PSH: Processed Stone Handling Operations
Includes the following emission units that transport material from the storage piles (fines, small stone,
medium stone, large stone (sugar)) to the kiln preheaters. Bins N11, N26, and N314, bin transfer points:
Bin N11 to Conveyor C13/C21, Conveyor C21 to Bin N26, Bin N314 to Conveyor C314; Preheater
transfer points: Conveyor C13 to Kiln #1 Preheater, Bin N26 to Kiln #2 Preheater, Conveyor C314 to
Kiln #3 Preheater, Conveyor C514 to Kiln #5 Preheater, and Conveyor C413 to Kiln #4 (controlled by
baghouse D415).

II.A.46 NSPS-CI-ICE: NSPS Stationary Compression Ignition (CI) Internal Combustion Engines (ICE)
Stationary CI ICE that are ordered after July 11, 2005, manufactured after April 1, 2006, and are not fire
pump engines. Stationary CI ICE that are modified, or reconstructed after July 11, 2005 are also included
in this unit. These emission units are subject to 40 CFR 60 Subpart IIII and have a displacement of less
than 10 liters per cylinder. KDE 1, KDE 2, KDE 5, and both limestone fines products (LFP) engines are
included in this unit.

II.A.47 NESHAP-CI-RICE: NESHAP Stationary Compression Ignition (CI) Reciprocating Internal
Combustion Engines (RICE)
Existing stationary CI RICE with a site rating of less than or equal to 500 brake HP that are constructed or
reconstructed before June 12, 2006. These units are subject to 40 CFR 63 Subpart ZZZZ. KDE 4 and the
sugar stone generator (GEN-1) are included in this unit.

II.A.48 NESHAP-SI-RICE:NESHAP Stationary Spark Ignition (SI) Reciprocating Internal Combustion
Engines (RICE)
Existing stationary SI RICE with a site rating of less than or equal to 500 brake HP that are constructed or
reconstructed before June 12, 2006. These units are subject to 40 CFR 63 Subpart ZZZZ. KDE 3 is
included in this unit.

II.A.49 Limestone Fines Product (LFP) Loadout System
System produces a limestone fines product that is loaded into trucks for transportation and sale. Unit
includes a hopper (LFP-1), screen (LFP-2), conveyors (LFP-3), tent storage area (LFP-4), product loadout
hopper (LFP-5), product loadout conveyor (LFP-6), and two diesel engines.

II.A.50 E: LFP Screen/Conveyor Transfer Points
Includes LFP-2 screen, LFP-3 conveyors, and LFP-6 product loadout conveyor, all observable from
observation point E.

II.A.51 LFP Engines
Includes two diesel engines rated at 130 hp and 52 hp.

Status: In Compliance. No unapproved equipment was observed onsite.

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).

15
II.B.1.a Condition:

Visible emissions shall not exceed 20 percent opacity unless otherwise specified in this permit (note that
this condition does apply to fugitive emissions but does not apply to fugitive dust).
[Origin: DAQE-AN103130047-24]. [R307-305-3, R307-401-8]

II.B.1.a.1 Monitoring:

Unless otherwise specified, a visual opacity survey of each affected emission unit shall be
performed on a monthly basis while the unit is operating. Permittee is not required to perform
monthly surveys on natural gas combustion sources and petroleum storage tanks. The visual
opacity survey shall be performed by an individual trained on the observation procedures of 40
CFR 60, Appendix A, Method 9. If visible emissions other than condensed water vapor are
observed from an emission unit, an opacity determination of that emission unit shall be performed
by a certified observer within 24 hours of the initial survey. The opacity determination shall be
performed in accordance with 40 CFR 60, Appendix A, Method 9.

II.B.1.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is performed, a notation of the determination will be
made in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also 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. Visual emission observations have been performed and recorded at least monthly.
Records were inspected onsite, and no exceedances of the 20% opacity limit were discovered.
Readings are taken by certified observers. VEOs are done by tablet and tracked on Spreadsheet
which shows columns for 7%, 10%, 15%, and 20% units. All units are listed with groupings
broken out by area and reading points.

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]. [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.

16
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. Graymont certified compliance with this condition in the most recent annual
compliance certification. The maintenance is done by third party vendors.

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]. [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. Graymont certified compliance with this condition in the most recent annual
compliance certification. The maintenance is done by third party vendors.

II.B.1.d Condition:

i. The permittee shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel
(ULSD), which has a sulfur content of 15 ppm or less.
ii. The permittee shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the
kiln drive engines 1, 2, 4, and 5; GEN-1 engine; portable engines; and LFP engines.
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.1.d.1 Monitoring:

Records required for this permit condition shall serve as monitoring.

II.B.1.d.2 Recordkeeping:

The permittee shall maintain records of diesel fuel purchase invoices or certifications of sulfur
content obtained from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate
the diesel fuel meets the ULSD requirements. Records demonstrating compliance with this
condition shall be maintained in accordance with Provision I.S.1 of this permit.

17
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. Fuel records were provided and indicated only ULSD is purchased (from Holly
Frontier).

II.B.1.e Condition:

The permittee shall implement a fugitive dust control plan acceptable to the Director for control of all
dust sources associated with the Cricket Mountain Plant. The permittee shall operate in accordance with
the most current fugitive dust control plan approved by the Director. [Origin: DAQE-AN103130047-24].
[R307-401-8]

II.B.1.e.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust. At least
once during each permit term, the fugitive dust control plan shall be reviewed and evaluated. If
the plan review indicates changes to the dust control plan are necessary to reflect current site
operations, an updated fugitive dust control plan shall be submitted.

II.B.1.e.2 Recordkeeping:

For each plan review, a record of the date and results of the review shall be maintained. Records
that demonstrate compliance with the most recently approved fugitive dust control plan shall also
be maintained. All records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.e.3 Reporting:

If changes to the dust control plan are necessary to reflect current site operations, an updated
fugitive dust control plan shall be submitted. There are no additional reporting requirements for
this provision except those specified in Section I of this permit.

Status: In Compliance. Graymont is operating under an August 15, 2017, fugitive dust control plan, which
was approved in DAQC-1384-17, dated October 18, 2017. All dust mitigating activities at mining
sites are recorded and were reviewed onsite. No violations were discovered. MgCl2 is applied three
times per year, paved roads are swept monthly, and water trucks operate daily on haul roads. An
updated FDCP was sent to DAQ (attn Bryce Bird) the week of May 13, 2024.

II.B.1.f 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-AN103130047-24].
[40 CFR 60.11(d), R307-401-8]
18
II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

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

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. Graymont employs a computerized tracking system to
schedule and record maintenance activities. Work orders are generated, and applicable data is
added as maintenance activities are completed.

II.B.1.g Condition:

Unless otherwise specified in this permit, visible emissions shall not exceed 10 percent opacity from
screens and conveyor transfer points. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.1.g.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.1.g.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.1.g.3 Reporting:

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

Status: In Compliance. Visual emission observations have been performed and recorded at least monthly.
Records were inspected onsite, and no exceedances of the 10% opacity limit were discovered.
Readings are taken by certified observers.
19
II.B.1.h Condition:

For all emission units subject to 40 CFR 63 Subpart AAAAA, the permittee shall prepare and implement
a written operations, maintenance, and monitoring (OM&M) plan in accordance with 40 CFR 63.7100(d).
Any subsequent changes to the plan shall be submitted to the Director for review and approval. Pending
approval by the Director of an initial or amended plan, the permittee shall comply with the provisions of
the submitted plan. Each plan shall contain the information required in 40 CFR 63.7100(d)(1)-(7). This
condition does not apply if the permittee is operating in accordance with the alternate operating scenario
(AOS) in Section II.D of this permit. [Origin: 40 CFR 63 Subpart AAAAA]. [40 CFR 63.6(e)(1)(iii),
40 CFR 63.7100(d), 40 CFR 63 Subpart AAAAA Table 3(5)]

II.B.1.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.h.2 Recordkeeping:

In addition to the records specified in 40 CFR 63.7132, the permittee shall document activities
performed to assure proper operation and maintenance of each affected emission unit and the
monitoring that demonstrates compliance with this condition and 40 CFR 63.7100(d). Records
and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and Provision
I.S.1 of this permit.

II.B.1.h.3 Reporting:

The permittee shall report each instance in which the operating limit is not met. The permittee
shall submit a compliance report semiannually containing the information required in Table 8 to
40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131.

If the permittee submits the compliance report along with, or as part of, the semiannual
monitoring report required in Section I of this permit and the compliance report includes all
required information concerning deviations from any emission limitation (including any
operating limit), submission of the compliance report shall be deemed to satisfy any obligation to
report the same deviations in the semiannual monitoring report. However, submission of a
compliance report shall not otherwise affect any obligation the permittee may have to report
deviations from permit requirements to the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as specified in Section I of
this permit.

Status: In Compliance. An OM&M plan is in place. The most recent revision is dated January 12, 2021.
Semi-annual AAAAA reports have been submitted, with the most recent report received by DAQ
on February 1, 2024. The company is not operating under the AOS as detailed in section II.D.

II.B.1.i Condition:

For all emission units subject to 40 CFR 63 Subpart AAAAA that are equipped with an add-on air
pollution control device, the permittee shall
(i) Vent captured emissions through a closed system, except that dilution air may be added to emission
streams for the purpose of controlling temperature at the inlet to a fabric filter; and
20
(ii) Operate each capture/collection system according to the procedures and requirements in the OM&M
plan.
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart AAAAA]. [40 CFR 63.7090(b), 40 CFR 63 Subpart AAAAA
Table 3(6)]

II.B.1.i.1 Monitoring:

The permittee shall inspect each capture/collection and closed vent system at least once each
calendar year to ensure that each system is operating in accordance with the operating
requirements in the above condition. [40 CFR 63.7113(f)] Records required for this permit
condition will also serve as monitoring.

II.B.1.i.2 Recordkeeping:

In addition to the records specified in 40 CFR 63.7132, the results of each inspection and
documentation demonstrating compliance with the OM&M requirements shall be recorded.
Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.

II.B.1.i.3 Reporting:

The permittee shall report each instance in which the operating limit is not met. The permittee
shall submit a compliance report semiannually containing the information required in Table 8 to
40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131.

If the permittee submits the compliance report along with, or as part of, the semiannual
monitoring report required in Section I of this permit and the compliance report includes all
required information concerning deviations from any emission limitation (including any
operating limit), submission of the compliance report shall be deemed to satisfy any obligation to
report the same deviations in the semiannual monitoring report. However, submission of a
compliance report shall not otherwise affect any obligation the permittee may have to report
deviations from permit requirements to the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Baghouse inspections have been performed and recorded on a monthly basis
instead of the annual requirement. Semi-annual “Lime MACT Malfunction” reports are submitted
to DAQ. The OM&M plan covers all equipment. Records are kept on site.

II.B.1.j Condition:

At all times, for all emission units subject to 40 CFR 63 Subpart AAAAA, the permittee shall always
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. The general duty to minimize emissions does not require the permittee to make
any further efforts to reduce emissions if levels required by the applicable standard have been achieved.
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
21
the source. This condition does not apply if the permittee is operating in accordance with the AOS in
Section II.D of this permit. [Origin: 40 CFR 63 Subpart AAAAA]. [40 CFR 63.7100(c)]

II.B.1.j.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.j.2 Recordkeeping:

In addition to the records specified in 40 CFR 63.7132, the permittee shall document activities
performed to assure proper operation and maintenance. Records shall be maintained in
accordance with 40 CFR 63.7133 and Provision I.S.1 of this permit.

II.B.1.j.3 Reporting:

Reports shall be submitted in accordance with 40 CFR 63.7131 and as specified in Section I of
this permit.

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. Graymont employs a computerized tracking system to
schedule and record maintenance activities. Work orders are generated, and applicable data is
added as maintenance activities are completed.

II.B.2 Conditions on Lime Kiln #1 (Unit #K-1).

II.B.2.a Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
does not apply if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA Table 3].
[40 CFR 60.342(a)(2), 40 CFR 63.7090(b), R307-401-8]

II.B.2.a.1 Monitoring:

Prior to the PM performance test specified in this permit, the permittee shall install, calibrate,
maintain and operate a continuous monitoring system to monitor and record the opacity of a
representative portion of the gases discharged into the atmosphere in accordance with the
standard operating procedures incorporated into the OM&M plan, R307-170, UAC, 40 CFR 63,
Subpart A, and 40 CFR 60, Appendix B, PS-1. The permittee shall install the COMS at the outlet
of the control device. The span of the system shall be set at a minimum of 40 percent opacity. At
no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

Continuous compliance shall be demonstrated by collecting COMS data at least once every 15
seconds, determining block averages for each 6-minute period and demonstrating that for each 6-
minute block period the average opacity does not exceed 15 percent.

The permittee shall monitor continuously (or collect data at all required intervals) at all times that
the emission unit is operating, except for monitor malfunctions, associated repairs, required
quality assurance or control activities (including, as applicable, calibration checks and required
zero adjustments). Data recorded during the conditions described below shall not be used either
22
in data averages or calculations of emission or operating limits; or in fulfilling a minimum data
availability requirement.
(1) Monitoring system breakdowns, repairs, preventive maintenance, calibration checks, and
zero (low-level) and high-level adjustments;
(2) Periods of non-operation of the process unit (or portion thereof), resulting in cessation of the
emissions to which the monitoring applies.
The permittee shall use all the data collected during all other periods in assessing the operation of
the control device and associated control system.

II.B.2.a.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8 and 40 CFR 63.7132. Records and results of
monitoring shall be maintained in accordance with R307-170, 40 CFR 63.7133, and Provision
I.S.1 of this permit.

II.B.2.a.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6 minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the quarterly report required
above, and the compliance report includes all required information concerning deviations from
any emission limitation (including any operating limit), submission of the compliance report shall
be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring
report required in Section I of this permit. However, submission of a compliance report shall not
otherwise affect any obligation the permittee has to report deviations from permit requirements to
the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: Not Evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. Opacity reading
during the inspection was 1.0%. The company is not operating under the AOS as detailed in
section II.D.

II.B.2.b Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 0.020 grain/dscf and 0.12 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 6.0 lb/hour and 0.016 grain/dscf
23
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, 40 CFR 63 Subpart AAAAA Table 1, SIP Section
IX.H.23.b]. [40 CFR 60 Subpart HH, 40 CFR 63.7090(a), R307-401-8, SIP Section IX.H.23.b]

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 60 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 or 1A, and Occupational Safety and Health Administration
(OSHA) and/or Mine Safety and Health Administration (MSHA) approved access shall
be provided to the test location. Sampling sites shall be located at the outlet of the
control device(s) and prior to any releases to the atmosphere.
(2) Volumetric Flow Rate - 40 CFR 60, Appendix A, Method 2 or other EPA-approved
testing method acceptable to the Director.
(3) Conduct gas molecular weight analysis using 40 CFR 60, Appendix A, Method 3, 3A,
3B, or other EPA-approved testing method acceptable to the Director.
(4) Measure moisture content of the stack gas using 40 CFR 60, Appendix A, Method 4, or
other EPA-approved testing method acceptable to the Director.
(5) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine the
particulate matter concentration. The minimum sample volume for each run shall be
60 dry standard cubic feet (dscf). The permittee shall conduct three separate test runs
for each performance test. The minimum sample time for each run shall be at least 120
minutes.
The back half condensables shall also be tested using 40 CFR 51, Appendix M, Method
202, or other EPA-approved testing method, as acceptable to the Director, to
demonstrate compliance with the PM10 (Filterable + Condensable) limit.
(6) Each performance test shall be conducted based on representative performance (i.e.,
performance based on normal operating conditions) of the affected source and under the
specific conditions in Table 5 to 40 CFR 63 Subpart AAAAA. Representative
conditions exclude periods of startup and shutdown. The permittee shall not conduct
performance tests during periods of startup, shutdown, or malfunction. (40 CFR
63.7112(b), (c))
(7) 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.

The emission rate of particulate matter (lb/tsf) from each kiln shall be computed for
each run using the following equation.

E = CkQk/PK

Where: E = Emission rate of PM, pounds per ton (lb/ton) of stone feed.
24
Ck = Concentration of PM in the kiln effluent, grain/dry standard cubic feet
(gr/dscf).
Qk = Volumetric flow rate of kiln effluent gas, dry standard cubic feet per hour
(dscf/hr).
P = Stone feed rate, tons per hour (ton/hr).
K = Conversion factor, 7000 grains per pound (grains/lb).

(d) Production Rate During Testing. Tests shall be conducted at a production rate of no less
than 90% of the maximum production achieved in the previous three (3) years.

The permittee shall determine the mass rate of stone feed to the kiln using any suitable device
during the kiln PM emissions test. The measuring device shall be accurate to within +/- 5 percent
of the mass rate of stone feed over its operating range and shall be calibrated and maintained
according to manufacturer's instructions. [40 CFR 60.343(d), 40 CFR 63.7112 Table 5].

During startup, kilns shall be tested hourly to determine when lime product meets the definition
of on-specification lime product. (40 CFR 63.7112(m)).

II.B.2.b.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]

In addition to the records specified in 40 CFR 63.7132:
Results of all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. The permittee shall record the process information that is
necessary to document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon request, the
permittee shall make available to the Director such records as may be necessary to determine the
conditions of performance tests.

Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h). The 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.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
25
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Stack testing of Kiln #1 was last conducted September 20-22, 2022. Test results
were submitted to DAQ and evaluated in DAQC-09-23. DAQ calculated results for PM were
0.0002 gr/dscf and 0.020 lb/ton. Next stack test is due in 2025.

II.B.2.c Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
SO2: 22.4 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.2.c.1 Monitoring:

(I) Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at
the direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. The source test protocol shall be approved by the Director prior
to performing the test(s). A pretest conference shall be held, if directed by the
Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant
emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) Production Rate During Testing. Tests shall be conducted at a production rate of no
less than 90% of the maximum production achieved in the previous three (3) years.
(II) The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a
flow monitoring device) for the continuous measurement of SO2 emissions on a kiln prior to
that kiln burning pet coke or coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.
26
After installation of an SO2 CEMS,
a. compliance with the SO2 limit shall be based on a 3-hour block average,
b. compliance with the SO2 limit shall be demonstrated using the CEMS regardless of fuel
burned in the kiln, and
c. stack testing, as specified in (I) above, shall not be required.

The monitoring system shall comply with all applicable sections of R307-170, UAC and 40
CFR 60, Appendix B, Performance Specification 2 - SO2 and NOx Continuous Emission
Monitoring Systems. Except for system breakdown, repairs, calibration checks, and zero
and span adjustments required under 40 CFR 60.13(d), 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(e) and R307-170.

When the SO2 CEMS has been installed calibrated, and is operating, the emission rate of
SO2 in pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period
shall be calculated by the following formula:

Eh = K * Chp * Qhs * ((100 - %H2O)/100)

Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hour
K = 1.66 x 10-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.

The Director shall consider the continuous monitoring requirements to be met when the following
provisions are met:
a. The SO2 CEMS shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
b. Prior to installation of a SO2 CEMS on a kiln, the average of three one-hour stack test results
is less than the corresponding SO2 emission limit for that kiln.
c. After installation of the SO2 CEMS on a kiln, the 3-hour block average is less than the
corresponding SO2 emission limit for that kiln.
d. Three-hour block averages shall begin at 12:01 a.m. and end every 3 hours, thereafter.

At no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.2.c.2 Recordkeeping:

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

For the SO2 CEMS, the permittee shall record the output of the system for measuring the SO2
emissions in addition to the records specified in R307-170-8. Records shall be maintained in
accordance with R307-170 and Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit:
27
(a) The 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.
(b) For the SO2 CEMS, the permittee shall submit a quarterly report in accordance with the
reporting provisions in R307-170-9. All exceedances shall be reported in the quarterly report
with explanations and corrective actions, in accordance with R307-170. The quarterly
reports 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: In Compliance. Stack testing of Kiln #1 was last conducted September 20-22, 2022. Test results
were submitted to DAQ and evaluated in DAQC-09-23. DAQ calculated results for SO2 were 0.7
lb/hr. Next stack test is due in 2025.

II.B.2.d Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
NOx: 90.0 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.2.d.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) Production Rate During Testing. Tests shall be conducted at a production rate of no less
than 90% of the maximum production achieved in the previous three (3) years.

II.B.2.d.2 Recordkeeping:

28
Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.d.3 Reporting:

The 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 Kiln #1 was last conducted September 20-22, 2022. Test results
were submitted to DAQ and evaluated in DAQC-09-23. DAQ calculated results for NOX were 68.0
lb/hr. Next stack test is due in 2025.

II.B.2.e Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
only applies if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH]. [40 CFR 60.342(a)(2), R307-401-8]

II.B.2.e.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous monitoring
system to monitor and record the opacity of a representative portion of the gases discharged into
the atmosphere from the kiln stack. The monitoring system shall operate continuously and shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Performance Specification 1 - Specifications and test procedures for continuous opacity
monitoring systems in stationary sources. The permittee shall install the COMS at the outlet of
the control device. The span of the system shall be set at a minimum of 40 percent opacity.

Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
under 40 CFR 60.13(d), 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(e) and R307-170. The Director shall consider the continuous monitoring
requirements to be met when the opacity monitor operates in accordance with 40 CFR 60.13 and
R307-170 UAC. At no time shall the permittee allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.2.e.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8. Records and results of monitoring shall be
maintained in accordance with R307-170 and Provision I.S.1 of this permit.

II.B.2.e.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6-minute periods during which the average
29
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

There are no additional reporting requirements except as outlined in Section I of this permit.

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.2.f Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 0.020 grain/dscf and 0.12 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 6.0 lb/hour and 0.016 grain/dscf
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, SIP Section IX.H.23.b]. [40 CFR 60 Subpart HH,
R307-401-8, SIP Section IX.H.23.b]

II.B.2.f.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test. A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - The emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved method, as acceptable to
the Director. An Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
(2) Sample Methods
PM - 40 CFR 60, Appendix A, Method 5 shall be used to determine the particulate
matter concentration (cs) and the volumetric flow rate (Qsd) of the effluent gas. The
minimum sample volume for each run shall be 60 (dscf). The permittee shall conduct
three separate test runs for each performance test. The minimum sample time for each
run shall be at least 120 minutes.

PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201, 201a, or other EPA-approved method as
acceptable to the Director. The back half condensables shall also be tested using 40
CFR 51, Appendix M, Method 202, or other EPA-approved method acceptable to the
Director. All particulate captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
30
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as
appropriate, or other EPA-approved method as acceptable to the Director. The back half
condensables shall also be tested using 40 CFR 51, Appendix M, Method 202, or other
EPA-approved method as acceptable to the Director. The portion of the front half of
the catch considered PM10 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director.
(d) 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.

The emission rate (E) of particulate matter shall be computed for each run using the
following equation.

E = (csQsd)/PK)

where: E = emission rate of particulate matter, kg/Mg (1b/ton) of stone feed.
cs = concentration of particulate matter, g/dscm (gr/dscf).
Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr).
P = stone feed rate, Mg/hr (ton/hr).
K = conversion factor, 1000 g/kg (7000 gr/lb).
(e) 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 install, calibrate, maintain, and operate a device for measuring the mass rate
of stone feed to any affected rotary lime kiln. The measuring device used shall be accurate to
within +/- 5 percent of the mass rate over its operating range. This monitoring device shall be
used to determine the stone feed rate (P) for each run. (40 CFR 60.343(d), 40 CFR 60.344(b)(3)).

II.B.2.f.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]

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

II.B.2.f.3 Reporting:

The 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: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.3 Conditions on Lime Kiln #2 (Unit #K-2).

31
II.B.3.a Condition:

Visible emissions shall not exceed 15 percent opacity from baghouse exhaust stacks. This condition does
not apply if the permittee is operating in accordance with the AOS in Section II.D of this permit. [Origin:
DAQE-AN103130047-24, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA Table 3].
[40 CFR 60.342(a)(2), 40 CFR 63.7090(b), R307-401-8]

II.B.3.a.1 Monitoring:

Prior to the PM performance test specified in this permit, the permittee shall install, calibrate,
maintain and operate a continuous monitoring system to monitor and record the opacity of a
representative portion of the gases discharged into the atmosphere in accordance with the
standard operating procedures incorporated into the OM&M plan, R307-170, UAC, 40 CFR 63,
Subpart A, and 40 CFR 60, Appendix B, PS-1. The COMS shall be installed at the outlet of the
control device. The span of the system shall be set at a minimum of 40 percent opacity. At no
time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere, except
as provided by the provisions of R307-107 (Breakdowns), UAC.

Continuous compliance shall be demonstrated by collecting COMS data at least once every 15
seconds, determining block averages for each 6-minute period and demonstrating that for each 6-
minute block period the average opacity does not exceed 15 percent.

The permittee shall monitor continuously (or collect data at all required intervals) at all times that
the emission unit is operating, except for monitor malfunctions, associated repairs, required
quality assurance or control activities (including, as applicable, calibration checks and required
zero adjustments). Data recorded during the conditions described below shall not be used either
in data averages or calculations of emission or operating limits; or in fulfilling a minimum data
availability requirement.
(1) Monitoring system breakdowns, repairs, preventive maintenance, calibration checks, and
zero (low-level) and high-level adjustments;
(2) Periods of non-operation of the process unit (or portion thereof), resulting in cessation of the
emissions to which the monitoring applies.
The permittee shall use all the data collected during all other periods in assessing the operation of
the control device and associated control system.

II.B.3.a.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8 and 40 CFR 63.7132. Records and results of
monitoring shall be maintained in accordance with R307-170, 40 CFR 63.7133, and Provision
I.S.1 of this permit.

II.B.3.a.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6 minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

32
The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the quarterly report required
above, and the compliance report includes all required information concerning deviations from
any emission limitation (including any operating limit), submission of the compliance report shall
be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring
report required in Section I of this permit. However, submission of a compliance report shall not
otherwise affect any obligation the permittee has to report deviations from permit requirements to
the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: Not Evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. Opacity reading
during the inspection was not done as unit shutdown. The company is not operating under the AOS
as detailed in section II.D.

II.B.3.b Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 8.23 lb/hour, 0.020 grain/dscf, and 0.12 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 6.58 lb/hour and 0.016 grain/dscf
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, 40 CFR 63 Subpart AAAAA Table 1, SIP Section
IX.H.23.b]. [40 CFR 60 Subpart HH, 40 CFR 63.7090(a), R307-401-8, SIP Section IX.H.23.b]

II.B.3.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 60 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 or 1A, and Occupational Safety and Health Administration
(OSHA) and/or Mine Safety and Health Administration (MSHA) approved access shall
be provided to the test location. Sampling sites shall be located at the outlet of the
control device(s) and prior to any releases to the atmosphere.
(2) Volumetric Flow Rate - 40 CFR 60, Appendix A, Method 2 or other EPA-approved
testing method acceptable to the Director.
(3) Conduct gas molecular weight analysis using 40 CFR 60, Appendix A, Method 3, 3A,
3B, or other EPA-approved testing method acceptable to the Director.
(4) Measure moisture content of the stack gas using 40 CFR 60, Appendix A, Method 4, or
other EPA-approved testing method acceptable to the Director.
(5) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine the
particulate matter concentration. The minimum sample volume for each run shall be 60
33
(dscf). The permittee shall conduct three separate test runs for each performance test.
The minimum sample time for each run shall be at least 1200 minutes.
The back half condensables shall also be tested using 40 CFR 51, Appendix M, Method
202, or other EPA-approved testing method, as acceptable to the Director, to
demonstrate compliance with the PM10 (Filterable + Condensable) limit.
(6) Each performance test shall be conducted based on representative performance (i.e.,
performance based on normal operating conditions) of the affected source and under the
specific conditions in Table 5 to 40 CFR 63 Subpart AAAAA. Representative
conditions exclude periods of startup and shutdown. The permittee shall not conduct
performance tests during periods of startup, shutdown, or malfunction. (40 CFR
63.7112(b), (c))
(7) 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.

The emission rate of particulate matter (lb/tsf) from each kiln shall be computed for
each run using the following equation.

E = CkQk/PK

Where: E = Emission rate of PM, pounds per ton (lb/ton) of stone feed.
Ck = Concentration of PM in the kiln effluent, grain/dry standard cubic feet
(gr/dscf).
Qk = Volumetric flow rate of kiln effluent gas, dry standard cubic feet per hour
(dscf/hr).
P = Stone feed rate, tons per hour (ton/hr).
K = Conversion factor, 7000 grains per pound (grains/lb).

(d) Production Rate During Testing. Tests shall be conducted at a production rate of no less than
90% of the maximum production achieved in the previous three (3) years.

The permittee shall determine the mass rate of stone feed to the kiln using any suitable device
during the kiln PM emissions test. The measuring device shall be accurate to within +/- 5 percent
of the mass rate of stone feed over its operating range and shall be calibrated and maintained
according to manufacturer's instructions. [40 CFR 60.343(d), 40 CFR 63.7112 Table 5]

During startup, kilns shall be tested hourly to determine when lime product meets the definition
of on-specification lime product. (40 CFR 63.7112(m)).

II.B.3.b.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]

In addition to the records specified in 40 CFR 63.7132:
Results of all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. The permittee shall record the process information that is
necessary to document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon request, the
34
permittee shall make available to the Director such records as may be necessary to determine the
conditions of performance tests.

Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.

II.B.3.b.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h). The 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.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Stack testing of Kiln #2 was last conducted September 20-22, 2022. Test results
were submitted to DAQ and evaluated in DAQC-009-23. DAQ calculated results for PM were
0.0002 gr/dscf and 0.018 lb/ton. Next stack test is due in 2025.

II.B.3.c Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
SO2: 22.4 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.3.c.1 Monitoring:

(I) Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may be also required at
the direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. The source test protocol shall be approved by the Director prior
to performing the test(s). A pretest conference shall be held, if directed by the Director.
35
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant
emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) 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) The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a flow
monitoring device) for the continuous measurement of SO2 emissions on a kiln prior to that
kiln burning coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.

After installation of an SO2 CEMS,
a. compliance with the SO2 limit shall be based on a 3-hour block average,
b. compliance with the SO2 limit shall be demonstrated using the CEMS regardless of fuel
burned in the kiln, and
c. stack testing, as specified in (I) above, shall not be required.
The monitoring system shall comply with all applicable sections of R307-170, UAC and 40
CFR 60, Appendix B, Performance Specification 2 - SO2 and NOx Continuous Emission
Monitoring Systems. Except for system breakdown, repairs, calibration checks, and zero
and span adjustments required under 40 CFR 60.13(d), 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(e) and R307-170.

When the SO2 CEMS has been installed calibrated, and is operating, the emission rate of SO2
in pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period shall
be calculated by the following formula:
Eh = K * Chp * Qhs * ((100 - %H2O)/100)

Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hour
K = 1.66 x 10-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.

The Director shall consider the continuous monitoring requirements to be met when the following
provisions are met:
a. The SO2 CEMS shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
b. Prior to installation of a SO2 CEMS on a kiln, the average of three one-hour stack test results
is less than the corresponding SO2 emission limit for that kiln.
36
c. After installation of the SO2 CEMS on a kiln, the 3-hour block average is less than the
corresponding SO2 emission limit for that kiln.
d. Three-hour block averages shall begin at 12:01 a.m. and end every 3 hours, thereafter.

At no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.3.c.2 Recordkeeping:

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

For the SO2 CEMS, the permittee shall record the output of the system for measuring the SO2
emissions in addition to the records specified in R307-170-8. Records shall be maintained in
accordance with R307-170 and Provision I.S.1 of this permit.

II.B.3.c.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit:
(a) The 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.
(b) For the SO2 CEMS, the permittee shall submit a quarterly report in accordance with the
reporting provisions in R307-170-9. All exceedances shall be reported in the quarterly
report with explanations and corrective actions, in accordance with R307-170. The quarterly
reports 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: In Compliance. Stack testing of Kiln #2 was last conducted September 20-22, 2022. Test results
were submitted to DAQ and evaluated in DAQC-009-23. DAQ calculated result for SO2 was 0.1
lb/hr. Next stack test is due in 2025.

No coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu has been burned.

II.B.3.d Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
NOx: 120.0 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.3.d.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
37
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) 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.3.d.2 Recordkeeping:

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

II.B.3.d.3 Reporting:

The 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 Kiln #2 was last conducted September 20-22, 2022. Test results
were submitted to DAQ and evaluated in DAQC-009-23. DAQ calculated result for NOX was 28.5
lb/hr. Next stack test is due in 2025.

II.B.3.e Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
only applies if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH]. [40 CFR 60.342(a)(2), R307-401-8]

II.B.3.e.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous monitoring
system to monitor and record the opacity of a representative portion of the gases discharged into
the atmosphere from the kiln stack. The monitoring system shall operate continuously and shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Performance Specification 1 - Specifications and test procedures for continuous opacity
monitoring systems in stationary sources. The permittee shall install the COMS at the outlet of
the control device. The span of the system shall be set at a minimum of 40 percent opacity.

Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
38
under 40 CFR 60.13(d), 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(e) and R307-170. The Director shall consider the continuous monitoring
requirements to be met when the opacity monitor operates in accordance with 40 CFR 60.13 and
R307-170 UAC. At no time shall the permittee allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.3.e.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8. Records and results of monitoring shall be
maintained in accordance with R307-170 and Provision I.S.1 of this permit.

II.B.3.e.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6-minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

There are no additional reporting requirements except as outlined in Section I of this permit.

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.3.f Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 8.23 lb/hour, 0.020 grain/dscf, and 0.12 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 6.58 lb/hour and 0.016 grain/dscf
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, SIP Section IX.H.23.b]. [40 CFR 60 Subpart HH, R307-
401-8, SIP Section IX.H.23.b]

II.B.3.f.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test. A
pretest conference shall be held, if directed by the Director.
(c) Methods.
39
(1) Sample Location - The emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved method, as acceptable to
the Director. An Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
(2) Sample Methods
PM - 40 CFR 60, Appendix A, Method 5 shall be used to determine the particulate
matter concentration (cs) and the volumetric flow rate (Qsd) of the effluent gas. The
minimum sample volume for each run shall be 60 (dscf). The permittee shall conduct
three separate test runs for each performance test. The minimum sample time for each
run shall be at least 120 minutes.

PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201, 201a, or other EPA-approved method as
acceptable to the Director. The back half condensables shall also be tested using 40
CFR 51, Appendix M, Method 202, or other EPA-approved method acceptable to the
Director. All particulate captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as
appropriate, or other EPA-approved method as acceptable to the Director. The back half
condensables shall also be tested using 40 CFR 51, Appendix M, Method 202, or other
EPA-approved method as acceptable to the Director. The portion of the front half of
the catch considered PM10 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director.
(d) 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.

The emission rate (E) of particulate matter shall be computed for each run using the
following equation.

E = (csQsd)/PK)

where: E = emission rate of particulate matter, kg/Mg (1b/ton) of stone feed.
cs = concentration of particulate matter, g/dscm (gr/dscf).
Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr).
P = stone feed rate, Mg/hr (ton/hr).
K = conversion factor, 1000 g/kg (7000 gr/lb).
(e) 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 install, calibrate, maintain, and operate a device for measuring the mass rate
of stone feed to any affected rotary lime kiln. The measuring device used shall be accurate to
within +/- 5 percent of the mass rate over its operating range. This monitoring device shall be
used to determine the stone feed rate (P) for each run. (40 CFR 60.343(d), 40 CFR 60.344(b)(3)).

II.B.3.f.2 Recordkeeping:
40
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 all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. Records and results of monitoring shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.3.f.3 Reporting:

The 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: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.4 Conditions on Lime Kiln #3 (Unit #K-3).

II.B.4.a Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
does not apply if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA Table 3]. [40
CFR 60.342(a)(2), 40 CFR 63.7090(b), R307-401-8]

II.B.4.a.1 Monitoring:

Prior to the PM performance test specified in this permit, the permittee shall install, calibrate,
maintain and operate a continuous monitoring system to monitor and record the opacity of a
representative portion of the gases discharged into the atmosphere in accordance with the
standard operating procedures incorporated into the OM&M plan, R307-170, UAC, 40 CFR 63,
Subpart A, and 40 CFR 60, Appendix B, PS-1. The COMS shall be installed at the outlet of the
control device. The span of the system shall be set at a minimum of 40 percent opacity. At no
time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere, except
as provided by the provisions of R307-107 (Breakdowns), UAC.

Continuous compliance shall be demonstrated by collecting COMS data at least once every 15
seconds, determining block averages for each 6-minute period and demonstrating that for each 6-
minute block period the average opacity does not exceed 15 percent.

The permittee shall monitor continuously (or collect data at all required intervals) at all times that
the emission unit is operating, except for monitor malfunctions, associated repairs, required
quality assurance or control activities (including, as applicable, calibration checks and required
zero adjustments). Data recorded during the conditions described below shall not be used either
in data averages or calculations of emission or operating limits; or in fulfilling a minimum data
availability requirement.
(1) Monitoring system breakdowns, repairs, preventive maintenance, calibration checks, and
zero (low-level) and high-level adjustments;
41
(2) Periods of non-operation of the process unit (or portion thereof), resulting in cessation of the
emissions to which the monitoring applies.
The permittee shall use all the data collected during all other periods in assessing the operation of
the control device and associated control system.

II.B.4.a.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8 and 40 CFR 63.7132. Records and results of
monitoring shall be maintained in accordance with R307-170, 40 CFR 63.7133, and Provision
I.S.1 of this permit.

II.B.4.a.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6 minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the quarterly report required
above, and the compliance report includes all required information concerning deviations from
any emission limitation (including any operating limit), submission of the compliance report shall
be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring
report required in Section I of this permit. However, submission of a compliance report shall not
otherwise affect any obligation the permittee has to report deviations from permit requirements to
the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: Not Evaluated. COMS requirements are evaluated by DAQ’s CEM specialist. Reading during the
inspection was 0.7%. The company is not operating under the AOS as detailed in section II.D.

II.B.4.b Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 7.49 lb/hour, 0.020 grain/dscf, and 0.10 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 7.54 lb/hour and 0.016 grain/dscf
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, 40 CFR 63 Subpart AAAAA Table 1, SIP Section
IX.H.23.b]. [40 CFR 60 Subpart HH, 40 CFR 63.7090(a), R307-401-8, SIP Section IX.H.23.b]

II.B.4.b.1 Monitoring:

42
Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 60 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 or 1A, and Occupational Safety and Health Administration
(OSHA) and/or Mine Safety and Health Administration (MSHA) approved access shall
be provided to the test location. Sampling sites shall be located at the outlet of the
control device(s) and prior to any releases to the atmosphere.
(2) Volumetric Flow Rate - 40 CFR 60, Appendix A, Method 2 or other EPA-approved
testing method acceptable to the Director.
(3) Conduct gas molecular weight analysis using 40 CFR 60, Appendix A, Method 3, 3A,
3B, or other EPA-approved testing method acceptable to the Director.
(4) Measure moisture content of the stack gas using 40 CFR 60, Appendix A, Method 4, or
other EPA-approved testing method acceptable to the Director.
(5) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine the
particulate matter concentration. The minimum sample volume for each run shall be 30
(dscf). The permittee shall conduct three separate test runs for each performance test.
The minimum sample time for each run shall be at least 120 minutes.
The back half condensables shall also be tested using 40 CFR 51, Appendix M, Method
202, or other EPA-approved testing method, as acceptable to the Director, to
demonstrate compliance with the PM10 (Filterable + Condensable) limit.
(6) Each performance test shall be conducted based on representative performance (i.e.,
performance based on normal operating conditions) of the affected source and under the
specific conditions in Table 5 to 40 CFR 63 Subpart AAAAA. Representative
conditions exclude periods of startup and shutdown. The permittee shall not conduct
performance tests during periods of startup, shutdown, or malfunction. (40 CFR
63.7112(b), (c))
(7) 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.

The emission rate of particulate matter (lb/tsf) from each kiln shall be computed for
each run using the following equation.

E = CkQk/PK

Where: E = Emission rate of PM, pounds per ton (lb/ton) of stone feed.
Ck = Concentration of PM in the kiln effluent, grain/dry standard cubic feet
(gr/dscf).
Qk = Volumetric flow rate of kiln effluent gas, dry standard cubic feet per hour
(dscf/hr).

P = Stone feed rate, tons per hour (ton/hr).
K = Conversion factor, 7000 grains per pound (grains/lb).
43
(d) Production Rate During Testing. Tests shall be conducted at a production rate of no less
than 90% of the maximum production achieved in the previous three (3) years.

The permittee shall determine the mass rate of stone feed to the kiln using any suitable device
during the kiln PM emissions test. The measuring device shall be accurate to within +/- 5 percent
of the mass rate of stone feed over its operating range and shall be calibrated and maintained
according to manufacturer's instructions. [40 CFR 60.343(d), 40 CFR 63.7112 Table 5].

During startup, kilns shall be tested hourly to determine when lime product meets the definition
of on-specification lime product. (40 CFR 63.7112(m)).

II.B.4.b.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]

In addition to the records specified in 40 CFR 63.7132:
Results of all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. The permittee shall record the process information that is
necessary to document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon request, the
permittee shall make available to the Director such records as may be necessary to determine the
conditions of performance tests.

Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.

II.B.4.b.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h). The 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.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

44
Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Stack testing of Kiln #3 was last conducted June 1, 2022. Test results were
submitted to DAQ and evaluated in DAQC-1226-22. DAQ calculated results for PM were 0.0002
gr/dscf and 0.002 lb/ton. Next stack test is due in 2025.

II.B.4.c Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
SO2: 27.2 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.4.c.1 Monitoring:

(I) Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may be also required at
the direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. The source test protocol shall be approved by the Director prior
to performing the test(s). A pretest conference shall be held, if directed by the
Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant
emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) 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) The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a
flow monitoring device) for the continuous measurement of SO2 emissions on a kiln prior to
that kiln burning coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.

After installation of an SO2 CEMS,
a. compliance with the SO2 limit shall be based on a 3-hour block average,
45
b. compliance with the SO2 limit shall be demonstrated using the CEMS regardless of
fuel burned in the kiln, and
c. stack testing, as specified in (I) above, shall not be required.

The monitoring system shall comply with all applicable sections of R307-170, UAC and 40
CFR 60, Appendix B, Performance Specification 2 - SO2 and NOx Continuous Emission
Monitoring Systems. Except for system breakdown, repairs, calibration checks, and zero
and span adjustments required under 40 CFR 60.13(d), 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(e) and R307-170.

When the SO2 CEMS has been installed calibrated, and is operating, the emission rate of
SO2 in pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period
shall be calculated by the following formula:

Eh = K * Chp * Qhs * ((100 - %H2O)/100)

Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hour
K = 1.66 x 10-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.

The Director shall consider the continuous monitoring requirements to be met when the following
provisions are met:
a. The SO2 CEMS shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
b. Prior to installation of a SO2 CEMS on a kiln, the average of three one-hour stack test results
is less than the corresponding SO2 emission limit for that kiln.
c. After installation of the SO2 CEMS on a kiln, the 3-hour block average is less than the
corresponding SO2 emission limit for that kiln.
d. Three-hour block averages shall begin at 12:01 a.m. and end every 3 hours, thereafter.

At no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.4.c.2 Recordkeeping:

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

For the SO2 CEMS, the permittee shall record the output of the system for measuring the SO2
emissions in addition to the records specified in R307-170-8. Records shall be maintained in
accordance with R307-170 and Provision I.S.1 of this permit.

II.B.4.c.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit:
(a) The 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.
46
(b) For the SO2 CEMS, the permittee shall submit a quarterly report in accordance with the
reporting provisions in R307-170-9. All exceedances shall be reported in the quarterly
report with explanations and corrective actions, in accordance with R307-170. The quarterly
reports 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: In Compliance. Stack testing of Kiln #3 was last conducted June 1, 2022. Test results were
submitted to DAQ and evaluated in DAQC-1226-22. DAQ calculated results for SO2 was 3.7 lb/hr.
Next stack test is due in 2025.

Coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu has not been burned.

II.B.4.d Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
NOx: 160.0 lb/hr
[DAQE-AN103130047-24]. [R307-401-8]

II.B.4.d.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) 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.d.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.
47
II.B.4.d.3 Reporting:

The 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 Kiln #3 was last conducted June 1, 2022. Test results were
submitted to DAQ and evaluated in DAQC-1226-22. DAQ calculated result for NOX was 38.0
lb/hr. Next stack test is due in 2025.

II.B.4.e Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
only applies if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH]. [40 CFR 60.342(a)(2), R307-401-8]

II.B.4.e.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous monitoring
system to monitor and record the opacity of a representative portion of the gases discharged into
the atmosphere from the kiln stack. The monitoring system shall operate continuously and shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Performance Specification 1 - Specifications and test procedures for continuous opacity
monitoring systems in stationary sources. The permittee shall install the COMS at the outlet of
the control device. The span of the system shall be set at a minimum of 40 percent opacity.

Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
under 40 CFR 60.13(d), 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(e) and R307-170. The Director shall consider the continuous monitoring
requirements to be met when the opacity monitor operates in accordance with 40 CFR 60.13 and
R307-170 UAC. At no time shall the permittee allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.4.e.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8. Records and results of monitoring shall be
maintained in accordance with R307-170 and Provision I.S.1 of this permit.

II.B.4.e.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6-minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.
48
There are no additional reporting requirements except as outlined in Section I of this permit.

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.4.f Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 7.49 lb/hour, 0.020 grain/dscf, and 0.10 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 7.54 lb/hour and 0.016 grain/dscf
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, SIP Section IX.H.23.b]. [40 CFR 60 Subpart HH, R307-
401-8, SIP Section IX.H.23.b]

II.B.4.f.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test. A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - The emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved method, as acceptable to
the Director. An Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
(2) Sample Methods
PM - 40 CFR 60, Appendix A, Method 5 shall be used to determine the particulate
matter concentration (cs) and the volumetric flow rate (Qsd) of the effluent gas. The
minimum sample volume for each run shall be 60 (dscf). The permittee shall conduct
three separate test runs for each performance test. The minimum sample time for each
run shall be at least 120 minutes.

PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201, 201a, or other EPA-approved method as
acceptable to the Director. The back half condensables shall also be tested using 40
CFR 51, Appendix M, Method 202, or other EPA-approved method acceptable to the
Director. All particulate captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as
appropriate, or other EPA-approved method as acceptable to the Director. The back half
condensables shall also be tested using 40 CFR 51, Appendix M, Method 202, or other
EPA-approved method as acceptable to the Director. The portion of the front half of
49
the catch considered PM10 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director.
(d) 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.
The emission rate (E) of particulate matter shall be computed for each run using the
following equation.

E = (csQsd)/PK)

where: E = emission rate of particulate matter, kg/Mg (1b/ton) of stone feed.
cs = concentration of particulate matter, g/dscm (gr/dscf).
Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr).
P = stone feed rate, Mg/hr (ton/hr).
K = conversion factor, 1000 g/kg (7000 gr/lb).
(e) 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 install, calibrate, maintain, and operate a device for measuring the mass rate
of stone feed to any affected rotary lime kiln. The measuring device used shall be accurate to
within +/- 5 percent of the mass rate over its operating range. This monitoring device shall be
used to determine the stone feed rate (P) for each run. (40 CFR 60.343(d), 40 CFR 60.344(b)(3)).

II.B.4.f.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]

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

II.B.4.f.3 Reporting:

The 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: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.5 Conditions on Lime Kiln #4 (Unit #K-4).

II.B.5.a Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
does not apply if the permittee is operating in accordance with the AOS in Section II.D of this permit.
50
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA Table 3]. [40
CFR 60.342(a)(2), 40 CFR 63.7090(b), R307-401-8]

II.B.5.a.1 Monitoring:

Prior to the PM performance test specified in this permit, the permittee shall install, calibrate,
maintain and operate a continuous monitoring system to monitor and record the opacity of a
representative portion of the gases discharged into the atmosphere in accordance with the
standard operating procedures incorporated into the OM&M plan, R307-170, UAC, 40 CFR 63,
Subpart A, and 40 CFR 60, Appendix B, PS-1. The COMS shall be installed at the outlet of the
control device. The span of the system shall be set at a minimum of 40 percent opacity. At no
time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere, except
as provided by the provisions of R307-107 (Breakdowns), UAC.

Continuous compliance shall be demonstrated by collecting COMS data at least once every 15
seconds, determining block averages for each 6-minute period and demonstrating that for each 6-
minute block period the average opacity does not exceed 15 percent.

The permittee shall monitor continuously (or collect data at all required intervals) at all times that
the emission unit is operating, except for monitor malfunctions, associated repairs, required
quality assurance or control activities (including, as applicable, calibration checks and required
zero adjustments). Data recorded during the conditions described below shall not be used either
in data averages or calculations of emission or operating limits; or in fulfilling a minimum data
availability requirement.
(1) Monitoring system breakdowns, repairs, preventive maintenance, calibration checks, and
zero (low-level) and high-level adjustments;
(2) Periods of non-operation of the process unit (or portion thereof), resulting in cessation of
the emissions to which the monitoring applies.
The permittee shall use all the data collected during all other periods in assessing the operation of
the control device and associated control system.

II.B.5.a.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8 and 40 CFR 63.7132. Records and results of
monitoring shall be maintained in accordance with R307-170, 40 CFR 63.7133, and Provision
I.S.1 of this permit.

II.B.5.a.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6 minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
51
permittee submits the compliance report along with, or as part of, the quarterly report required
above, and the compliance report includes all required information concerning deviations from
any emission limitation (including any operating limit), submission of the compliance report shall
be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring
report required in Section I of this permit. However, submission of a compliance report shall not
otherwise affect any obligation the permittee has to report deviations from permit requirements to
the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: Not Evaluated. CEM and COMS requirements are evaluated by DAQ’s CEM specialist. Reading
during the inspection was 1.6%. The company is not operating under the AOS as detailed in
section II.D.

II.B.5.b Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 17.14 lb/hour, 0.020 grain/dscf, and 0.12 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 13.7 lb/hour and 0.016 grain/dscf
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, 40 CFR 63 Subpart AAAAA Table 1, SIP Section
IX.H.23.b]. [40 CFR 60 Subpart HH, 40 CFR 63.7090(a), R307-401-8, SIP Section IX.H.23.b]

II.B.5.b.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 60 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 or 1A, and Occupational Safety and Health Administration
(OSHA) and/or Mine Safety and Health Administration (MSHA) approved access shall
be provided to the test location. Sampling sites shall be located at the outlet of the
control device(s) and prior to any releases to the atmosphere.
(2) Volumetric Flow Rate - 40 CFR 60, Appendix A, Method 2 or other EPA-approved
testing method acceptable to the Director.
(3) Conduct gas molecular weight analysis using 40 CFR 60, Appendix A, Method 3, 3A,
3B, or other EPA-approved testing method acceptable to the Director.
(4) Measure moisture content of the stack gas using 40 CFR 60, Appendix A, Method 4, or
other EPA-approved testing method acceptable to the Director.
(5) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine the
particulate matter concentration. The minimum sample volume for each run shall be 60
(dscf). The permittee shall conduct three separate test runs for each performance test.
The minimum sample time for each run shall be at least 120 minutes.
52
The back half condensables shall also be tested using 40 CFR 51, Appendix M, Method
202, or other EPA-approved testing method, as acceptable to the Director, to
demonstrate compliance with the PM10 (Filterable + Condensable) limit.
(6) Each performance test shall be conducted based on representative performance (i.e.,
performance based on normal operating conditions) of the affected source and under the
specific conditions in Table 5 to 40 CFR 63 Subpart AAAAA. Representative
conditions exclude periods of startup and shutdown. The permittee shall not conduct
performance tests during periods of startup, shutdown, or malfunction. (40 CFR
63.7112(b), (c))
(7) 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.

The emission rate of particulate matter (lb/tsf) from each kiln shall be computed for
each run using the following equation.

E = CkQk/PK

Where: E = Emission rate of PM, pounds per ton (lb/ton) of stone feed.
Ck = Concentration of PM in the kiln effluent, grain/dry standard cubic feet
(gr/dscf).
Qk = Volumetric flow rate of kiln effluent gas, dry standard cubic feet per hour
(dscf/hr).
P = Stone feed rate, tons per hour (ton/hr).
K = Conversion factor, 7000 grains per pound (grains/lb).

(d) 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 the mass rate of stone feed to the kiln using any suitable device
during the kiln PM emissions test. The measuring device shall be accurate to within +/- 5 percent
of the mass rate of stone feed over its operating range and shall be calibrated and maintained
according to manufacturer's instructions. [40 CFR 60.343(d), 40 CFR 63.7112 Table 5].

During startup, kilns shall be tested hourly to determine when lime product meets the definition
of on-specification lime product. (40 CFR 63.7112(m)).

II.B.5.b.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]

In addition to the records specified in 40 CFR 63.7132:
Results of all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. The permittee shall record the process information that is
necessary to document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon request, the
permittee shall make available to the Director such records as may be necessary to determine the
conditions of performance tests.
53
Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.

II.B.5.b.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h). The 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.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Stack testing of Kiln #4 was last conducted August 10, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for PM were 0.002
gr/dscf and 0.01 lb/ton. Next test is due in 2026.

II.B.5.c Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
SO2: 38.4 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.5.c.1 Monitoring:

(I) Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may be also required at
the direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. The source test protocol shall be approved by the Director prior
to performing the test(s). A pretest conference shall be held, if directed by the
Director.
(c) Methods.
54
(1) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant
emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) 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) The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a
flow monitoring device) for the continuous measurement of SO2 emissions on a kiln prior to
that kiln burning coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.

After installation of an SO2 CEMS,
a. compliance with the SO2 limit shall be based on a 3-hour block average,
b. compliance with the SO2 limit shall be demonstrated using the CEMS regardless of fuel
burned in the kiln, and
c. stack testing, as specified in (I) above, shall not be required.

The monitoring system shall comply with all applicable sections of R307-170, UAC and 40
CFR 60, Appendix B, Performance Specification 2 - SO2 and NOx Continuous Emission
Monitoring Systems. Except for system breakdown, repairs, calibration checks, and zero
and span adjustments required under 40 CFR 60.13(d), 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(e) and R307-170.

When the SO2 CEMS has been installed calibrated, and is operating, the emission rate of
SO2 in pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period
shall be calculated by the following formula:

Eh = K * Chp * Qhs * ((100 - %H2O)/100)

Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hour
K = 1.66 x 10-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.

The Director shall consider the continuous monitoring requirements to be met when the following
provisions are met:
a. The SO2 CEMS shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
55
b. Prior to installation of a SO2 CEMS on a kiln, the average of three one-hour stack test results
is less than the corresponding SO2 emission limit for that kiln.
c. After installation of the SO2 CEMS on a kiln, the 3-hour block average is less than the
corresponding SO2 emission limit for that kiln.
d. Three-hour block averages shall begin at 12:01 a.m. and end every 3 hours, thereafter.

At no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.5.c.2 Recordkeeping:

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

For the SO2 CEMS, the permittee shall record the output of the system for measuring the SO2
emissions in addition to the records specified in R307-170-8. Records shall be maintained in
accordance with R307-170 and Provision I.S.1 of this permit.

II.B.5.c.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit:
(a) The 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.
(b) For the SO2 CEMS, the permittee shall submit a quarterly report in accordance with the
reporting provisions in R307-170-9. All exceedances shall be reported in the quarterly
report with explanations and corrective actions, in accordance with R307-170. The quarterly
reports 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: In Compliance. Stack testing of Kiln #4 was last conducted August 10, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for SO2 were 1.2
lb/hr. Next test is due in 2026.

II.B.5.d Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
NOx: 200.0 lb/hr
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.5.d.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
56
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) 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.5.d.2 Recordkeeping:

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

II.B.5.d.3 Reporting:

The 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 Kiln #4 was last conducted August 10, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for NOX were 131.9
lb/hr. Next test is due in 2026.

II.B.5.e Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
only applies if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH]. [40 CFR 60.342(a)(2), R307-401-8]

II.B.5.e.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous monitoring
system to monitor and record the opacity of a representative portion of the gases discharged into
the atmosphere from the kiln stack. The monitoring system shall operate continuously and shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Performance Specification 1 - Specifications and test procedures for continuous opacity
monitoring systems in stationary sources. The permittee shall install the COMS at the outlet of
the control device. The span of the system shall be set at a minimum of 40 percent opacity.

Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
57
under 40 CFR 60.13(d), 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(e) and R307-170. The Director shall consider the continuous monitoring
requirements to be met when the opacity monitor operates in accordance with 40 CFR 60.13 and
R307-170 UAC. At no time shall the permittee allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.5.e.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8. Records and results of monitoring shall be
maintained in accordance with R307-170 and Provision I.S.1 of this permit.

II.B.5.e.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6-minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

There are no additional reporting requirements except as outlined in Section I of this permit.

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.5.f Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 17.14 lb/hour, 0.020 grain/dscf, and 0.12 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 13.7 lb/hour and 0.016 grain/dscf
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, SIP Section IX.H.23.b]. [40 CFR 60 Subpart HH, R307-
401-8, SIP Section IX.H.23.b]

II.B.5.f.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test. A
pretest conference shall be held, if directed by the Director.
(c) Methods.
58
(1) Sample Location - The emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved method, as acceptable to
the Director. An Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
(2) Sample Methods
PM - 40 CFR 60, Appendix A, Method 5 shall be used to determine the particulate
matter concentration (cs) and the volumetric flow rate (Qsd) of the effluent gas. The
minimum sample volume for each run shall be 60 (dscf). The permittee shall conduct
three separate test runs for each performance test. The minimum sample time for each
run shall be at least 120 minutes.

PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201, 201a, or other EPA-approved method as
acceptable to the Director. The back half condensables shall also be tested using 40
CFR 51, Appendix M, Method 202, or other EPA-approved method acceptable to the
Director. All particulate captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as
appropriate, or other EPA-approved method as acceptable to the Director. The back half
condensables shall also be tested using 40 CFR 51, Appendix M, Method 202, or other
EPA-approved method as acceptable to the Director. The portion of the front half of
the catch considered PM10 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director.
(d) 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.

The emission rate (E) of particulate matter shall be computed for each run using the
following equation.

E = (csQsd)/PK)

where: E = emission rate of particulate matter, kg/Mg (1b/ton) of stone feed.
cs = concentration of particulate matter, g/dscm (gr/dscf).
Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr).
P = stone feed rate, Mg/hr (ton/hr).
K = conversion factor, 1000 g/kg (7000 gr/lb).
(e) 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 install, calibrate, maintain, and operate a device for measuring the mass rate
of stone feed to any affected rotary lime kiln. The measuring device used shall be accurate to
within +/- 5 percent of the mass rate over its operating range. This monitoring device shall be
used to determine the stone feed rate (P) for each run. (40 CFR 60.343(d), 40 CFR 60.344(b)(3)).

II.B.5.f.2 Recordkeeping:
59
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 all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. Records and results of monitoring shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.5.f.3 Reporting:

The 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: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.6 Conditions on Lime Kiln #5 (Unit #K-5).

II.B.6.a Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
does not apply if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA Table 3]. [40
CFR 60.342(a)(2), 40 CFR 63.7090(b), R307-401-8]

II.B.6.a.1 Monitoring:

Prior to the PM performance test specified in this permit, the permittee shall install, calibrate,
maintain and operate a continuous monitoring system to monitor and record the opacity of a
representative portion of the gases discharged into the atmosphere in accordance with the
standard operating procedures incorporated into the OM&M plan, R307-170, UAC, 40 CFR 63,
Subpart A, and 40 CFR 60, Appendix B, PS-1. The permittee shall install the COMS at the outlet
of the control device. The span of the system shall be set at a minimum of 40 percent opacity. At
no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

Continuous compliance shall be demonstrated by collecting COMS data at least once every 15
seconds, determining block averages for each 6-minute period and demonstrating that for each 6-
minute block period the average opacity does not exceed 15 percent.

The permittee shall monitor continuously (or collect data at all required intervals) at all times that
the emission unit is operating, except for monitor malfunctions, associated repairs, required
quality assurance or control activities (including, as applicable, calibration checks and required
zero adjustments). Data recorded during the conditions described below shall not be used either
in data averages or calculations of emission or operating limits; or in fulfilling a minimum data
availability requirement.
(1) Monitoring system breakdowns, repairs, preventive maintenance, calibration checks, and
zero (low-level) and high-level adjustments;
60
(2) Periods of non-operation of the process unit (or portion thereof), resulting in cessation of the
emissions to which the monitoring applies.
The permittee shall use all the data collected during all other periods in assessing the operation of
the control device and associated control system.

II.B.6.a.2 Recordkeeping:

The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8 and 40 CFR 63.7132. Records and results of
monitoring shall be maintained in accordance with R307-170, 40 CFR 63.7133, and Provision
I.S.1 of this permit.

II.B.6.a.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6 minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the quarterly report required
above, and the compliance report includes all required information concerning deviations from
any emission limitation (including any operating limit), submission of the compliance report shall
be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring
report required in Section I of this permit. However, submission of a compliance report shall not
otherwise affect any obligation the permittee has to report deviations from permit requirements to
the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: Not Evaluated. CEM and COMS requirements are evaluated by DAQ’s CEM specialist. This unit
was offline. The company is not operating under the AOS as detailed in section II.D.

II.B.6.b Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 0.020 grain/dscf and 0.10 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 11.7 lb/hour and 0.016 grain/dscf
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, 40 CFR 63 Subpart AAAAA Table 1, SIP Section
IX.H.23.b]. [40 CFR 60 Subpart HH, 40 CFR 63.7090(a), R307-401-8, SIP Section IX.H.23.b]

II.B.6.b.1 Monitoring:

61
Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 60 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 or 1A, and Occupational Safety and Health Administration
(OSHA) and/or Mine Safety and Health Administration (MSHA) approved access shall
be provided to the test location. Sampling sites shall be located at the outlet of the
control device(s) and prior to any releases to the atmosphere.
(2) Volumetric Flow Rate - 40 CFR 60, Appendix A, Method 2 or other EPA-approved
testing method acceptable to the Director.
(3) Conduct gas molecular weight analysis using 40 CFR 60, Appendix A, Method 3, 3A,
3B, or other EPA-approved testing method acceptable to the Director.
(4) Measure moisture content of the stack gas using 40 CFR 60, Appendix A, Method 4, or
other EPA-approved testing method acceptable to the Director.
(5) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine the
particulate matter concentration. The minimum sample volume for each run shall be 60
(dscf). The permittee shall conduct three separate test runs for each performance test.
The minimum sample time for each run shall be at least 120 minutes.
The back half condensables shall also be tested using 40 CFR 51, Appendix M, Method
202, or other EPA-approved testing method, as acceptable to the Director, to
demonstrate compliance with the PM10 (Filterable + Condensable) limit.
(6) Each performance test shall be conducted based on representative performance (i.e.,
performance based on normal operating conditions) of the affected source and under the
specific conditions in Table 5 to 40 CFR 63 Subpart AAAAA. Representative
conditions exclude periods of startup and shutdown. The permittee shall not conduct
performance tests during periods of startup, shutdown, or malfunction. (40 CFR
63.7112(b), (c))
(7) 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.

The emission rate of particulate matter (lb/tsf) from each kiln shall be computed for
each run using the following equation.

E = CkQk/PK

Where: E = Emission rate of PM, pounds per ton (lb/ton) of stone feed.
Ck = Concentration of PM in the kiln effluent, grain/dry standard cubic feet
(gr/dscf).
Qk = Volumetric flow rate of kiln effluent gas, dry standard cubic feet per hour
(dscf/hr).
P = Stone feed rate, tons per hour (ton/hr).
K = Conversion factor, 7000 grains per pound (grains/lb).

62
(d) 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 the mass rate of stone feed to the kiln using any suitable device
during the kiln PM emissions test. The measuring device shall be accurate to within +/- 5 percent
of the mass rate of stone feed over its operating range and shall be calibrated and maintained
according to manufacturer's instructions. [40 CFR 60.343(d), 40 CFR 63.7112 Table 5].

During startup, kilns shall be tested hourly to determine when lime product meets the definition
of on-specification lime product. (40 CFR 63.7112(m)).

II.B.6.b.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]

In addition to the records specified in 40 CFR 63.7132:
Results of all stack testing shall be recorded in accordance with the associated test method and
Provision I.S.1 of this permit. The permittee shall record the process information that is
necessary to document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon request, the
permittee shall make available to the Director such records as may be necessary to determine the
conditions of performance tests.

Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.
II.B.6.b.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h). The 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.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

63
Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Stack testing of Kiln #5 was last conducted August 8, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for PM were 0.002
gr/dscf and 0.02 lb/ton. Next test is in 2026.

II.B.6.c Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
SO2: 59.0 lb/hr and 1.01 lb/ton lime
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.6.c.1 Monitoring:

(I) Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at
the direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. The source test protocol shall be approved by the Director prior
to performing the test(s). A pretest conference shall be held, if directed by the
Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved
testing method, as acceptable to the Director. Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant
emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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. To
determine emission rates in units of lbs/ton lime, the emission rate in lbs/hour shall be
divided by the tons/hour lime production rate. Lime production rate shall either be a
direct measurement or shall be calculated using the following conversion factor: 2
tons of limestone feed equates to 1 ton of lime produced (2 tons limestone : 1 ton
lime).
(e) 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) The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a
64
flow monitoring device) for the continuous measurement of SO2 emissions on a kiln prior to
that kiln burning pet coke or coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.

After installation of an SO2 CEMS,
a. compliance with the SO2 limit shall be based on a 3-hour block average,
b. compliance with the SO2 limit shall be demonstrated using the CEMS regardless of fuel
burned in the kiln, and
c. stack testing, as specified in (I) above, shall not be required.

The monitoring system shall comply with all applicable sections of R307-170, UAC and 40
CFR 60, Appendix B, Performance Specification 2 - SO2 and NOx Continuous Emission
Monitoring Systems. Except for system breakdown, repairs, calibration checks, and zero
and span adjustments required under 40 CFR 60.13(d), 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(e) and R307-170.

When the SO2 CEMS has been installed calibrated, and is operating, the emission rate of
SO2 in pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period
shall be calculated by the following formula:

Eh = K * Chp * Qhs * ((100 - %H2O)/100)

Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hour
K = 1.66 x 10-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume

The Director shall consider the continuous monitoring requirements to be met when the following
provisions are met:
a. The SO2 CEMS shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
b. Prior to installation of a SO2 CEMS on a kiln, the average of three one-hour stack test results
is less than the corresponding SO2 emission limit for that kiln.
c. After installation of the SO2 CEMS on a kiln, the 3-hour block average is less than the
corresponding SO2 emission limit for that kiln.
d. Three-hour block averages shall begin at 12:01 a.m. and end every 3 hours, thereafter.

At no time shall the permittee allow excess gaseous emissions to be emitted to the atmosphere,
except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.6.c.2 Recordkeeping:

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

For the SO2 CEMS, the permittee shall record the output of the system for measuring the SO2
emissions in addition to the records specified in R307-170-8. Records shall be maintained in
accordance with R307-170 and Provision I.S.1 of this permit.

II.B.6.c.3 Reporting:

65
In addition to the reporting requirements specified in Section I of this permit:
(a) The 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.
(b) For the SO2 CEMS, the permittee shall submit a quarterly report in accordance with the
reporting provisions in R307-170-9. All exceedances shall be reported in the quarterly
report with explanations and corrective actions, in accordance with R307-170. The quarterly
reports 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: In Compliance. Stack testing of Kiln #5 was last conducted August 8, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for SO2 were 0.4 lb/hr
and 0.04 lb/ton. Next test is due in 2026.

No coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu has been burned.

II.B.6.d Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
NOx: 210.0 lb/hr and 3.60 lb/ton lime
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.6.d.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing
method, as acceptable to the Director, shall be used to determine the pollutant emission
rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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. To determine emission rates in units of lbs/ton
lime, the emission rate in lbs/hour shall be divided by the tons/hour lime production rate.
Lime production rate shall either be a direct measurement or shall be calculated using the
66
following conversion factor: 2 tons of limestone feed equates to 1 ton of lime produced (2
tons limestone : 1 ton lime).
(e) 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.6.d.2 Recordkeeping:

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

II.B.6.d.3 Reporting:

The 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 Kiln #5 was last conducted August 8, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for NOX were
128.8 lb/hr and 1.19 lb/ton. Next test is due in 2026.

II.B.6.e Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
CO: 233.0 lb/hr and 4.00 lb/ton lime
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.6.e.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test(s). A
pretest conference shall be held, if directed by the Director.

(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the pollutant emission rate.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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
67
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation. To determine emission rates in units of lbs/ton
lime, the emission rate in lbs/hour shall be divided by the tons/hour lime production rate.
Lime production rate shall either be a direct measurement or shall be calculated using the
following conversion factor: 2 tons of limestone feed equates to 1 ton of lime produced (2
tons limestone : 1 ton lime).
(e) 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.6.e.2 Recordkeeping:

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

II.B.6.e.3 Reporting:

The 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 Kiln #5 was last conducted August 8, 2023. Test results were
submitted to DAQ and evaluated in DAQC-1229-23. DAQ calculated results for CO were 13.9
lb/hr and 0.13 lb/ton. Next test is due in 2026.

II.B.6.f Condition:

Visible emissions shall not exceed 15 percent opacity from the baghouse exhaust stack. This condition
only applies if the permittee is operating in accordance with the AOS in Section II.D of this permit.
[Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart HH]. [40 CFR 60.342(a)(2), R307-401-8]

II.B.6.f.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous monitoring
system to monitor and record the opacity of a representative portion of the gases discharged into
the atmosphere from the kiln stack. The monitoring system shall operate continuously and shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Performance Specification 1 - Specifications and test procedures for continuous opacity
monitoring systems in stationary sources. The permittee shall install the COMS at the outlet of
the control device. The span of the system shall be set at a minimum of 40 percent opacity.

Except for system breakdown, repairs, calibration checks, and zero and span adjustments required
under 40 CFR 60.13(d), 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(e) and R307-170. The Director shall consider the continuous monitoring
requirements to be met when the opacity monitor operates in accordance with 40 CFR 60.13 and
R307-170 UAC. At no time shall the permittee allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107 (Breakdowns), UAC.

II.B.6.f.2 Recordkeeping:

68
The permittee shall record the output of the system for measuring the opacity of emissions in
addition to the records specified in R307-170-8. Records and results of monitoring shall be
maintained in accordance with R307-170 and Provision I.S.1 of this permit.

II.B.6.f.3 Reporting:

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program. These quarterly reports are considered prompt notifications of deviation, as required in
Provision I.S.2.c of this permit, provided all information required by Provision I.S.2.c is included
in the report. For the purpose of reporting required under 40 CFR 60.7(c), periods of excess
emissions that shall be reported are defined as all 6-minute periods during which the average
opacity of the visible emissions from the lime kiln is greater than 15 percent opacity. All
exceedances shall be reported in the quarterly report with explanations and corrective actions, in
accordance with R307-170.

There are no additional reporting requirements except as outlined in Section I of this permit.

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.6.g Condition:

Emissions to the atmosphere from the baghouse exhaust stack shall not exceed the following rates and
concentrations (standardized at 68 degrees F, 29.92 in Hg):
i. PM: 0.020 grain/dscf and 0.10 lb/ton of stone feed (tsf)
ii. PM10 (Filterable + Condensable): 11.7 lb/hour and 0.016 grain/dscf
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: DAQE-AN103130047-24, SIP Section IX.H.23.b]. [40 CFR 60 Subpart HH, R307-
401-8, SIP Section IX.H.23.b]

II.B.6.g.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source test protocol
shall outline the proposed test methodologies, stack to be tested, and procedures to be used.
The source test protocol shall be approved by the Director prior to performing the test. A
pretest conference shall be held, if directed by the Director.

(c) Methods.
(1) Sample Location - The emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved method, as acceptable to
the Director. An Occupational Safety and Health Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to the test
location.
(2) Sample Methods
PM - 40 CFR 60, Appendix A, Method 5 shall be used to determine the particulate
matter concentration (cs) and the volumetric flow rate (Qsd) of the effluent gas. The
minimum sample volume for each run shall be 60 (dscf). The permittee shall conduct
69
three separate test runs for each performance test. The minimum sample time for each
run shall be at least 120 minutes.

PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201, 201a, or other EPA-approved method as
acceptable to the Director. The back half condensables shall also be tested using 40
CFR 51, Appendix M, Method 202, or other EPA-approved method acceptable to the
Director. All particulate captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as
appropriate, or other EPA-approved method as acceptable to the Director. The back half
condensables shall also be tested using 40 CFR 51, Appendix M, Method 202, or other
EPA-approved method as acceptable to the Director. The portion of the front half of
the catch considered PM10 shall be based on information in Appendix B of the fifth
edition of the EPA document, AP-42, or other data acceptable to the Director.
(d) 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.

The emission rate (E) of particulate matter shall be computed for each run using the
following equation.

E = (csQsd)/PK)

where: E = emission rate of particulate matter, kg/Mg (1b/ton) of stone feed.
cs = concentration of particulate matter, g/dscm (gr/dscf).
Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr).
P = stone feed rate, Mg/hr (ton/hr).
K = conversion factor, 1000 g/kg (7000 gr/lb).
(e) 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 install, calibrate, maintain, and operate a device for measuring the mass rate
of stone feed to any affected rotary lime kiln. The measuring device used shall be accurate to
within +/- 5 percent of the mass rate over its operating range. This monitoring device shall be
used to determine the stone feed rate (P) for each run. (40 CFR 60.343(d), 40 CFR 60.344(b)(3)).

II.B.6.g.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]

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

70
II.B.6.g.3 Reporting:

The 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: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.7 Conditions on Lime Kilns #1 through #5 (Unit #K-1-5).

II.B.7.a Condition:

The permittee shall use only the following fuels in the kilns.
Kiln #1, 5: Coal
Petroleum coke (pet coke)*
Coal with sulfur content exceeding 1.0 lb/MMBtu*
Propane and fuel oil as startup fuel
Kiln #2, 3, 4: Coal
Coal with sulfur content exceeding 1.0 lb/MMBtu*
Propane and fuel oil as startup fuel
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.7.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

*Prior to burning pet coke or coal with a sulfur content in excess of 1.0 lb/MMBtu, the permittee
shall install, calibrate, operate an SO2 CEM on that kiln.

II.B.7.a.2 Recordkeeping:

Use of fuel which has not been approved for use shall be recorded in a log. The log shall include
the date, time, type and quantity of non-approved fuel used. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.7.a.3 Reporting:

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

Status: In Compliance. Fuel receipt records have been kept and were made available. Fuel oil and propane
are used as startup fuel, and coal with sulfur content less than 1.0 lb/MMBtu is burned during
normal operation. No other fuels have been burned.

71
II.B.7.b Condition:

For kilns #1, #2, #3, #4, #5 collectively, the following limits shall not be exceeded: 4,706 tons lime per
day and 1,516,250 tons lime per rolling 12-month period. [Origin: DAQE-AN103130047-24].
[R307-401-8]

II.B.7.b.1 Monitoring:

Production shall be monitored on a daily basis. Compliance with the 12-month production
limitation shall be demonstrated through a rolling 12-month total. The permittee shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records required for this permit condition will also serve as monitoring.

II.B.7.b.2 Recordkeeping:

Production shall be determined using plant production records, such as scale records or sales
receipts. Production totals shall be kept on a daily basis in an operations log. Records of
production shall be kept for all periods of operation. The rolling 12-month totals shall be
recorded monthly. Records shall be kept in accordance with Provision I.S.1 of this permit.

II.B.7.b.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Daily production was below
4,706 tons for all days checked, with a daily maximum of 2,664 tons during the 12-month period
preceding this inspection. The rolling production for the 12-month period ending April 30, 2024,
was 590,936 tons. Records are kept in files downstairs and tracked by condition number. Columns
show monthly/highest day/highest number/12-month totals.

II.B.7.c Condition:

Unless otherwise specified in this permit, the sulfur content of any coal or any mixture of coals burned
shall not exceed 1.0 pound sulfur per MMBtu heat input. Except for diesel, the sulfur content of any fuel
oil burned as a startup fuel shall not exceed 0.85 pounds sulfur per MMBtu heat input. [Origin: DAQE-
AN103130047-24, R307-203]. [R307-203-1, R307-401]

II.B.7.c.1 Monitoring:

(a) For coal: The sulfur content shall be determined by the permittee or the fuel supplier using
ASTM Method D3174-12(2018), D3176-15, D4239-18e1, D5016-16, or an approved
equivalent ASTM Method. If certification is provided by the fuel supplier, the sulfur content
shall be tested quarterly from a composite sample. If the permittee chooses to test the sulfur
content of the coal, the composite sample shall be tested quarterly from a composite grab
sample taken every 24 hours of operation.

After an SO2 CEMS has been installed, calibrated, and is operating on a kiln, the coal that is
burned in that kiln is exempt from the 1.0 pound of sulfur per MMBTU heat input limitation
of UAC R307-203-1(1).

72
(b) For fuel oil: The sulfur content shall be determined by the permittee or the fuel supplier
using ASTM Method D3175-75, or an approved equivalent ASTM Method. The sulfur
content shall be tested if directed by the Director.

II.B.7.c.2 Recordkeeping:

Records, or supplier furnished certifications, of the testing shall be kept for all periods when the
plant is in operation and shall be made available to the director upon request. Records of supplier
certifications for fuel oil, shall contain the following specifications for each purchase of fuel oil
from the vendor: weight percent sulfur, gross heating value (btu per unit volume), and density.
Results of monitoring, or records of supplier furnished certifications, that demonstrate
compliance with this condition shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.7.c.3 Reporting:

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

Status: In Compliance. Trip tickets are kept on file for daily coal deliveries and include fuel analysis.
Sulfur content was below the permit limit in records reviewed onsite. Coal has been received from
the Bronco and Wolverine mines in Central Utah.

II.B.8 Conditions on Miscellaneous Engines (Unit #ME).

II.B.8.a Condition:

The permittee shall not allow, cause or permit the emissions of visible pollutants from gasoline powered
engines. [Origin: R307-305-3(2)]. [R307-305-3(2)]

II.B.8.a.1 Monitoring:

The permittee shall make at least one visual opacity survey each quarter for each engine. The
visual opacity survey shall be performed while the unit is operating 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.

II.B.8.a.2 Recordkeeping:

The permittee shall maintain a log of the visual opacity surveys including the date, emission unit,
and if visible emissions are observed. Records 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. Quarterly opacity surveys have been performed and recorded as required. No
deviations were discovered while reviewing records during this inspection.

73
II.B.8.b Condition:

Visible emissions shall not exceed 20 percent opacity from all diesel engines. [Origin: DAQE-
AN103130047-24]. [R307-305-3, R307-401-8]

II.B.8.b.1 Monitoring:

The permittee shall make at least one visual opacity survey each quarter for each engine. The
visual opacity survey shall be performed while the unit is operating 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 visible emissions are observed from an emission
unit, an opacity determination of that emission unit shall be performed by a certified observer
within 24 hours of the initial survey. The opacity determination shall be performed in accordance
with 40 CFR 60, Appendix A, Method 9.

II.B.8.b.2 Recordkeeping:

The permittee shall maintain a log of the visual opacity surveys, opacity determinations, and all
data required by 40 CFR 60, Appendix A, Method 9 in accordance with Provision I.S.1 of this
permit.

II.B.8.b.3 Reporting:

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

Status: In Compliance. Quarterly opacity surveys have been performed and recorded as required. No
deviations were discovered while reviewing records during this inspection.

II.B.9 Conditions on Observation Points A, C: NSPS Subpart OOO Baghouses (Unit #A, C:NSPS-OOO).

II.B.9.a Condition:

Visible emissions shall not exceed 7 percent opacity. [Origin: DAQE-AN103130047-24, 40 CFR 60
Subpart OOO]. [40 CFR 60.672(a), R307-401-8]

II.B.9.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.
74
For affected emission units constructed, modified, or reconstructed on or after April 22, 2008, the
permittee shall conduct monitoring according to 40 CFR 60.674(c), (d), or (e). Observed visible
emissions shall not exceed 7 percent opacity.

II.B.9.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

For affected emission units constructed, modified, or reconstructed on or after April 22, 2008,
records shall be kept in accordance with 40 CFR 60.676(b) and Provision I.S.1 of this permit.
Records shall be made available to the director upon request.

II.B.9.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. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed coming from these sources during this inspection.

II.B.9.b Condition:

Unless otherwise specified, emissions of particulate matter (PM) shall not exceed 0.05 g/dscm (0.022
grains/dscf). [Origin: 40 CFR 60 Subpart OOO]. [40 CFR 60.672(a)]

II.B.9.b.1 Monitoring:

A) Stack testing shall be performed as specified below:
(1) Frequency. Emissions shall be tested at least once every five years. Tests may also be
required at the direction of the Director.
(2) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and provide a copy of the test protocol. The source shall
attend a pretest conference if determined necessary by the Director.
(3) Methods.
(a) Sample Location - the emission point shall conform to the requirements of 40 CFR
60, Appendix A, Method 1, and Occupational Safety and Health Administration
(OSHA) or Mine Safety and Health Administration (MSHA) approved access
shall be provided to the test location.
(b) Sample Method - 40 CFR 60, Appendix A, Method 5 or Method 17 shall be used
to determine the particulate matter concentration. The minimum sample volume
shall be 1.70 dscm (60 dscf). For Method 5, if the gas stream being sampled is at
ambient temperature, the sampling probe and filter may be operated without
heaters. If the gas stream is above ambient temperature, the sampling probe and
filter may be operated at a temperature high enough, but no higher than 121 deg. C
(250 deg F), to prevent water condensation on the filter.
(4) Calculations. To determine mass emission rates (lb./hr., etc.) the pollutant
concentration as determined by the appropriate methods above shall be multiplied by
75
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.
(5) 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.

B) For the D-7122 baghouse only, in addition to the stack testing required above, the permittee
shall use two indicators, differential pressure and visible emissions, to provide reasonable
assurance of compliance with the PM emission limitation. [40 CFR 64.6]
(1) Measurement Approach:
(a) Indicator No. 1: Pressure drop across the baghouse shall be measured using a
differential pressure gauge.
(b) Indicator No. 2: Visible emissions from the baghouse exhaust shall be monitored
using EPA Reference Method 22 procedures.
(2) Indicator Range: Excursions are defined for the two indicators as follows. Each
excursion triggers an inspection, corrective action, and a reporting requirement.
(a) Indicator No. 1: An excursion is defined as a pressure drop outside the range of 4
to 12 inches of water column.
(b) Indicator No. 2: An excursion is defined as the presence of visible emissions.
(3) Performance Criteria:
(a) Data Representativeness:
i) Indicator No. 1: The differential pressure gauge shall measure pressure drop
with pressure taps located at the baghouse inlet and outlet. The minimum
accuracy of the gauge shall be +/- 0.25 inches of water.
ii) Indicator No. 2: Visible emissions shall be monitored at the baghouse exhaust
while the baghouse is operating.
(b) QA/QC Practices and Criteria:
i) Indicator No. 1: The pressure gauge shall be calibrated according to the
manufacturer's recommendations or at least annually.
ii) Indicator No. 2: The visible emissions observer shall be familiar with EPA
Reference Method 22 and shall follow Method 22 procedures.
(c) Monitoring Frequency:
i) Indicator No. 1: Pressure drop shall be monitored continuously.
ii) Indicator No. 2: The visible emissions observer shall perform a 6-minute
Method 22 observation once each day.
(d) Data Collection Procedure:
i) Indicator No. 1: One pressure drop reading shall be recorded each hour for
comparison to the indicator range.
ii) Indicator No. 2: The permittee shall record the results of each visible emission
observation in a log.
(e) Averaging Period: Indicator No. 1, 2: N/A

C) For the D-7122 baghouse only, during the stack test required in A. above, the permittee shall
acquire new test data to evaluate or update the indicator range and excursion level for the
indicators. Any resultant changes to the monitoring shall be addressed in accordance with
40 CFR 64.7(e).

II.B.9.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.
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For the D-7122 baghouse only:
(i) The permittee shall maintain records of test data from the most recent stack test and any
calculations used to evaluate or revise the indicator range and excursion level. The
permittee shall maintain records of all calibration checks, adjustments and maintenance.
(ii) In addition to the recordkeeping requirement described in Provision I.S.1 of this permit, the
permittee shall maintain a file of the occurrence and duration of any excursion, corrective
actions taken, and any other supporting information required to be maintained under 40
CFR 64 (such as data used to document the adequacy of monitoring, or records of
monitoring maintenance or corrective actions).
(iii) Instead of paper records, the permittee may maintain records on alternative media, such as
microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such
alternative media allows for expeditious inspection and review, and does not conflict with
other applicable recordkeeping requirements. (40 CFR 64.9(b)).

II.B.9.b.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit, the 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.

For the D-7122 baghouse only, monitoring reports shall also include, at a minimum, the
following information, as applicable:
(i) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions taken;
(40 CFR 64.9(a)(2)(i))
(ii) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero and
span or other daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii))
(iii) Test data and any calculations used to evaluate or revise the indicator range and excursion
level.

Status: In Compliance. The most recent stack tests were conducted on the dates listed in the table below.
All baghouses listed below are Observation Point A, NSPS Subpart OOO Baghouses except D-415
and D-591, which are Observation Point C, NSPS Subpart OOO Baghouses. Test results have been
submitted to DAQ for review, and all results listed are taken from DAQ calculation.

Baghouse Test Date Results (gr/dscf) Limit (gr/dscf) Next due date
Baghouse D-310 6/2/2022 0.0003 0.022 2027
Baghouse D-403 9/19/2022 0.003 0.022 2027
Baghouse D-414 9/19/2022 0.001 0.022 2027
Baghouse D-7122 6/3/2022 0.0003 0.022 2027
Baghouse D-7133 6/3/2022 0.0042 0.022 2027
Baghouse D-7141 6/3/2022 0.0008 0.022 2027
Baghouse D-415 9/30/2020 0.0002 0.022 2025

II.B.9.c Condition:

All affected emission units constructed, modified, or reconstructed on or after April 22, 2008, shall meet a
particulate matter (PM) limit of 0.014 grains/dscf. [Origin: 40 CFR 60 Subpart OOO].
[40 CFR 60.672(a)]

77
II.B.9.c.1 Monitoring:

A) The permittee shall demonstrate compliance with the particulate matter standard by
performing stack testing as specified below:
(1) Frequency. Emissions shall be tested at least once every five years, based on the date
of the most recent stack test. Tests may also be required at the direction of the Director.
[R307-415-6a(3)]
(2) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and provide a copy of the test protocol. The source shall
attend a pretest conference if determined necessary by the Director.
(3) Methods.
(a) Sample Location - the emission point shall conform to the requirements of 40 CFR
60, Appendix A, Method 1, and Occupational Safety and Health Administration
(OSHA) or Mine Safety and Health Administration (MSHA) approved access
shall be provided to the test location.
(b) Sample Method - 40 CFR 60, Appendix A, Method 5 or Method 17 shall be used
to determine the particulate matter concentration. The minimum sample volume
shall be 1.70 dscm (60 dscf). For Method 5, if the gas stream being sampled is at
ambient temperature, the sampling probe and filter may be operated without
heaters. If the gas stream is above ambient temperature, the sampling probe and
filter may be operated at a temperature high enough, but no higher than 121 deg. C
(250 deg F), to prevent water condensation on the filter.
(4) 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.
(5) 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.
B) The permittee shall monitor the baghouses according to 40 CFR 60.674(c), (d), or (e).

II.B.9.c.2 Recordkeeping:

Records shall be kept in accordance with 40 CFR 60.676(b). Results of all stack testing shall be
recorded and maintained in accordance with the associated test method. All records shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.9.c.3 Reporting:

Notification of the actual date of initial startup of each affected emission unit shall be submitted
in accordance with 40 CFR 60.676(i). Reports shall be submitted in accordance with 40 CFR
60.676(f). The 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. Only Kiln #5 associated baghouses and D-7142 rail loadout are applicable to the
new construction testing requirement. D-7142 has not been constructed. Kiln #5 began operations
in December 2011 and was initially tested July 10-19, 2012. Kiln #5 coal silo baghouse D-591 was
also constructed after April 22, 2008, but is under a more stringent limit listed in Condition
II.B.12.c below.
78
All baghouses listed below are Observation Point A, NSPS Subpart OOO Baghouses. The most
recent stack tests were conducted on the dates listed in the table below. Results of testing these
baghouses have been submitted to DAQ and await review. Listed results for these three baghouses
are taken from the stack testing contractor calculations.

Baghouse Test Date Results (gr/dscf) Limit (gr/dscf) Next due date
Baghouse D-503 10/13/2021 0.0009 0.014 2026
Baghouse D-514 10/13/2021 0.0007 0.014 2026

II.B.10 Conditions on Observation Point A, C: Non-Subpart OOO Baghouses (Unit #A, C: NON-NSPS-
OOO).

II.B.10.a Condition:

Visible emissions shall not exceed 10 percent opacity. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.10.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.10.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.10.a.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed coming from these sources during this inspection.

II.B.10.b Condition:

79
The pressure drop on the D-488 baghouse shall not be less than 4.0 inches of water column or more than
8.0 inches of water column. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.10.b.1 Monitoring:

The pressure drop shall be monitored weekly, while the unit is operating, with equipment located
such that an inspector/operator can safely read the output at any time. All instruments shall be
calibrated according to the manufacturer's instructions at least once every 12 months.

II.B.10.b.2 Recordkeeping:

Results of pressure drop monitoring shall be recorded weekly. Records of calibrations and results
of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.10.b.3 Reporting:

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

Status: In Compliance. Pressure drop is monitored continuously in the control room. The system triggers
an alarm if the pressure drop is outside of the limits. Yearly calibrations are tracked in the
maintenance system. Dp during inspection was 7.8 inches.

II.B.10.c Condition:

Emissions shall not exceed the following rates and concentrations from the D-488 baghouse exhaust stack
(standardized at 68 degrees F, 29.92 in Hg):
i. PM: 0.29 lb/hour and 0.020 grain/dscf
ii. PM10 (Filterable): 0.15 lb/hour and 0.010 grain/dscf
iii. PM2.5 (Filterable): 0.15 lb/hour and 0.010 grain/dscf
[Origin: DAQE-AN103130047-24, SIP Section IX.H.23.b]. [R307-401-8, SIP Section IX.H.23.b]

II.B.10.c.1 Monitoring:

The permittee shall demonstrate compliance with each of the three particulate matter standards by
performing stack testing as specified below:
(a) Frequency. Emissions shall be tested every three years. Tests may also be required at the
direction of the Director.
(b) Notification. At least 30 days before the test, the permittee shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and procedures to
be used. The source test protocol shall be approved by the Director prior to performing the
test(s). A pretest conference shall be held, if directed by the Director.
(c) Methods.
(1) Sample Location - the emission point shall be designed to conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing method, as
acceptable to the Director. Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) The following methods shall be used to measure particulate emissions:
80
a) For PM, 40 CFR 60, Appendix A, Method 5, or other EPA-approved testing
method, as acceptable to the Director.
b) For PM10,
For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Methods 201, 201a, or other EPA-approved method
as acceptable to the Director. The back half condensables shall also be tested using
the EPA-approved method acceptable to the Director. All particulate captured shall
be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops
should be explored. If no reasonable method to eliminate the drops exists, then the
following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e
as appropriate, or other EPA-approved method as acceptable to the Director. The
back half condensables shall also be tested using the EPA method as acceptable to
the Director. The portion of the front half of the catch considered PM10 shall be
based on information in Appendix B of the fifth edition of the EPA document, AP-
42, or other data acceptable to the Director.
c) For PM2.5, 40 CFR 60, Appendix A, Method 5, 40 CFR 51, Appendix M, Method
201A, or other EPA-approved testing method, as acceptable to the Director. If
other approved testing methods are used which cannot measure the PM2.5 fraction
of the filterable particulate emissions, all of the filterable particulate emissions shall
be considered PM2.5. The portion of the front half of the catch considered PM2.5
shall be based on information in Appendix B of the fifth edition of the EPA
document, AP-42, or other data acceptable to the Director.
d) The minimum sample volume for each run shall be 60 dscf. The permittee shall
conduct three separate test runs for each performance test. The minimum sample
time for each run shall be at least 120 minutes.
(3) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
(d) 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.
(e) Production Rate During Testing. Tests shall be conducted at a production rate of no less than
90% of the maximum production achieved in the previous three (3) years.

II.B.10.c.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]

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

II.B.10.c.3 Reporting:

The 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.
81
Status: In Compliance. Stack testing was last conducted August 9, 2023. Test results were submitted to
DAQ and audited in DAQC-1229-23. DAQ calculated test results for PM indicate emissions of
0.0002 gr/dscf. Next stack test is due in 2026.

II.B.11 Conditions on Observation Point A, D: Limestone Screens (Unit #A, D: SCREENS).

II.B.11.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103130047-24, 40
CFR 60 Subpart OOO]. [40 CFR 60.672(b), R307-401-8]

II.B.11.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.11.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

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. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed coming from these sources during this inspection.

II.B.12 Conditions on Observation Point A, C: Coal Silo (Unit #A, C: COAL SILO).

II.B.12.a Condition:

Visible emissions shall be no greater than 10 percent opacity from all affected emission units constructed,
reconstructed, or modified after October 27, 1974 and on or before April 28, 2008. [Origin: DAQE-
AN103130047-24, 40 CFR 60 Subpart Y]. [40 CFR 60.254(a), R307-401-8]

82
II.B.12.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.12.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 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. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed coming from these sources during this inspection.

II.B.12.b Condition:

Visible emissions from all affected emission units constructed, reconstructed, or modified after
April 28, 2008, shall be no greater than 10 percent opacity. [Origin: DAQE-AN103130047-24, 40 CFR
60 Subpart Y]. [40 CFR 60.254(b)(1), R307-401-8]

II.B.12.b.1 Monitoring:

Compliance shall be demonstrated in accordance with 40 CFR 60.255(b) and as specified below.

40 CFR 60, Appendix A, Method 9 and the procedures of 40 CFR 60.11 shall be used to
determine opacity, with the exceptions specified in (i) and (ii).
(i) Duration of the Method 9 performance test shall be 1 hour (ten 6-minute averages).
(ii) If, during the initial 30 minutes of the Method 9 observation, all of the 6-minute average
opacity readings are less than or equal to half the applicable opacity limit, then the
observation period may be reduced from 1 hour to 30 minutes.

83
A visible emissions observer may conduct visible emission observations from a pre-determined
observation location (A, B, C or D) for up to three fugitive, stack, or vent emission points within
a 15-second interval if the following conditions specified in (i) through (iii) are met.
(i) No more than three emissions points shall be read concurrently.
(ii) All three emissions points shall be within a 70 degree viewing sector or angle in front of the
observer such that the proper sun position can be maintained for all three points.
(iii) If an opacity reading for any one of the three emissions points is within 5 percent opacity
from the applicable standard (excluding readings of zero opacity), then the observer shall
stop taking readings for the other two points and continue reading just that single point.

An initial performance test shall be performed for all affected emission units. Thereafter a new
performance test shall be conducted according to the requirements in paragraphs (i) and (ii)
below. As an alternative, the permittee may elect to comply with the requirements of 40 CFR
60.255(f).
(i) If any 6-minute average opacity reading in the most recent performance test exceeds half the
applicable opacity limit, a new performance test shall be conducted within 90 operating days
of the date that the previous performance test was required to be completed.
(ii) If all 6-minute average opacity readings in the most recent performance test are equal to or
less than half the applicable opacity limit, a new performance test shall be conducted within
12 calendar months of the date that the previous performance test was required to be
completed.

II.B.12.b.2 Recordkeeping:

The permittee shall maintain a logbook on-site in accordance with 40 CFR 60.258(a) and
Provision I.S.1 of this permit.

II.B.12.b.3 Reporting:

Reports shall be submitted as required in 40 CFR 60.258(c)-(d) and as specified in Section I of
this permit.

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed coming from these sources during this inspection.

II.B.12.c Condition:

Gases discharged into the atmosphere from any mechanical vent on an affected emission unit constructed,
modified, or reconstructed on or after April 28, 2008, shall not contain particulate matter in excess of
0.010 grains/dscf. [Origin: 40 CFR 60 Subpart Y]. [40 CFR 60.254(b)(2)]

II.B.12.c.1 Monitoring:

Compliance shall be demonstrated in accordance with 40 CFR 60.255(b) and as specified below.

a) An initial performance test shall be performed for all affected emission units. Thereafter, a
new performance test shall be conducted according the following requirements in paragraphs
(i) through (iii) or as specified in 40 CFR 60.255(d).
(i) If the results of the most recent performance test demonstrate that emissions are greater
than 50 percent of the applicable emissions standard, a new performance test shall be
84
conducted within 12 calendar months of the date that the previous performance test was
required to be completed.
(ii) If the results of the most recent performance test demonstrate that emissions are 50
percent or less of the applicable emissions standard, a new performance test shall be
conducted within 24 calendar months of the date that the previous performance test was
required to be completed.
(iii) If an affected emission unit has not operated for the 60 calendar days prior to the due
date of a performance test, the permittee is not required to perform the subsequent
performance test until 30 calendar days after the next operating day.
b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
c) 40 CFR 60, Appendix A, Method 1 or 1A shall be used to select sampling port locations and
the number of traverse points in each stack or duct. Sampling sites shall be located at the
outlet of the control device (or at the outlet of the emissions source if no control device is
present) prior to any releases to the atmosphere.
d) 40 CFR 60, Appendix A, Method 2, 2A, 2C, 2D, 2F, or 2G shall be used to determine the
volumetric flow rate of the stack gas.
e) 40 CFR 60, Appendix A, Method 3, 3A, 3B, or an approved alternative, shall be used to
determine the dry molecular weight of the stack gas.
f) 40 CFR 60, Appendix A, Method 4 shall be used to determine the moisture content of the
stack gas.
g) 40 CFR 60, Appendix A, Method 5 or 5D or 40 CFR 60, Appendix A, Method 17 shall be
used to determine the PM concentration as follows:
(i) The sampling time and sample volume for each run shall be at least 60 minutes and 0.85
dscm (30 dscf). Sampling shall begin no less than 30 minutes after startup and shall
terminate before shutdown procedures begin. A minimum of three valid test runs are
needed to comprise a PM performance test.
(ii) Method 5D shall be used for positive pressure fabric filters and other similar applications
(e.g., stub stacks and roof vents).
(iii) Method 17 may be used in accordance with 40 CFR 60.257(b)(5)(v) and provided the
stack gas temperature does not exceed a temperature of 160 degrees C (320 degrees F).

II.B.12.c.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit. The permittee shall also maintain a logbook
on-site in accordance with 40 CFR 60.258(a).

II.B.12.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall be submitted as required in 40 CFR 60.258(c)-(d) and as specified in
Section I of this permit.

Status: In Compliance. This applies to kiln #5 coal silo baghouse D-591. A stack test was last performed
on D-591 baghouse on August 9, 2023. Test results were submitted to DAQ and evaluated in
DAQC-1229-23. The DAQ calculated emissions of PM were 0.0001 gr/dscf. Next test is due in
2026.

85
II.B.13 Conditions on Observation Point A, B, C, D: Conveyor Transfer Points (Unit #A, B, C, D:
TRANSFER POINTS).

II.B.13.a Condition:

Visible emissions shall be no greater than 10 percent opacity from all affected emission units constructed,
modified, or reconstructed on or after August 31, 1983 but before April 22, 2008. [Origin: DAQE-
AN103130047-24, 40 CFR Subpart OOO]. [40 CFR 60.672(b), R307-401-8]

II.B.13.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.13.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.13.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. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed during this inspection.

II.B.13.b Condition:

Visible emissions shall be no greater than 7 percent opacity from all affected emission units constructed,
modified, or reconstructed on or after April 22, 2008. [Origin: 40 CFR 60 Subpart OOO, DAQE-
AN103130047-24]. [40 CFR 60.672(b), R307-401-8]

II.B.13.b.1 Monitoring:

In lieu of visible emissions observations, the permittee shall perform monthly periodic
inspections to check that water is flowing to the discharge spray nozzles in the wet suppression
86
system. The permittee shall initiate corrective action within 24 hours and complete corrective
action as expediently as practical if the permittee finds that water is not flowing properly during
an inspection of the water spray nozzles.

II.B.13.b.2 Recordkeeping:

Records shall be kept in accordance with 40 CFR 60.676(b) and Provision I.S.1 of this permit.
Records shall be made available to the director upon request.

II.B.13.b.3 Reporting:

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

Status: In Compliance. Water sprays have been installed on all equipment covered in this condition. No
visible emissions were observed coming from any conveying operation or rock piles. Monthly
checks have been performed and recorded on a more frequent weekly basis.

II.B.14 Conditions on Observation Point A, C: Coal Conveyor Transfer Points (Unit #A, C: COAL
TRANSFER POINTS).

II.B.14.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN103130047-24, 40
CFR 60 Subpart Y]. [40 CFR 60.254(a), R307-401-8]

II.B.14.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.14.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

87
There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed during this inspection.

II.B.15 Conditions on Observation Point A, B, C, D: Drop Points (Unit #A, B, C, D: DROP POINTS).

II.B.15.a Condition:

Visible emissions shall not exceed 20 percent opacity. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.15.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.15.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.15.a.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No excess emissions were
observed during this inspection.

II.B.16 Conditions on A: Generator: Sugar Stone System

88
II.B.16.a Condition:

Hours of operation shall not exceed 750 hours per rolling 12-month period. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.16.a.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months.

II.B.16.a.2 Recordkeeping:

Hours of operation shall be kept in a log. Records shall be kept on a daily basis for each day the
generator operates. Records shall include the date the generator was used and the duration in
hours of generator usage. The rolling 12-month totals shall be recorded monthly. Records shall
be maintained in accordance with Provision I.S.1 of this permit.

II.B.16.a.3 Reporting:

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

Status: In Compliance. Records of hours are kept. The 12-month rolling total through April 30, 2024, was
532 hours.

II.B.16.b Condition:

Visible emissions shall not exceed 20 percent opacity. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.16.b.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.16.b.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
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data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.16.b.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. The emergency generator
was not operating during this inspection.

II.B.17 Conditions on Direct Fire Heating System (Unit #LS-GRIND).
II.B.17.a Condition:

All used oil burned as fuel shall meet the following:
not more than 5 ppm by weight – Arsenic
not more than 2 ppm by weight – Cadmium
not more than 10 ppm by weight – Chromium
not more than 100 ppm by weight – Lead
not more than 1,000 ppm by weight - Total Halogens
not more than 0.50 percent by weight – Sulfur
Flash point shall not be less than 100 degrees Fahrenheit.
Sources utilizing used oil as a fuel shall comply with the State Division of Waste Management and
Radiation Control in accordance with R315-15, UAC. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.17.a.1 Monitoring:

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 before used oil fuel is transferred to a holding tank or burned.

II.B.17.a.2 Recordkeeping:

The permittee shall maintain test certification data for each load of used oil fuel received.
Records shall document the results of EPA test methods or ASTM methods either by permittee
testing or test reports provided by the vendor. The permittee shall record the quantities of used
oil burned. All records and certifications shall be maintained in accordance with Provision I.S.1
of this permit.

II.B.17.a.3 Reporting:

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

Status: In Compliance. Used oil has not been burned.

II.B.17.b Condition:

The permittee shall use propane, diesel and used oil in any combination in the direct fire heating system
for the limestone grinding plant. [Origin: DAQE-AN103130047-24]. [R307-401-8]
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II.B.17.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.17.b.2 Recordkeeping:

Use of fuel which has not been approved for use shall be recorded in a log. The log shall include
the date, time, type and quantity of non-approved fuel used. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.17.b.3 Reporting:

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

Status: In Compliance. Only propane has been used. This unit is not set up to run on diesel fuel.

II.B.18 Conditions on Observation Point D: NSPS Subpart OOO Baghouses (Unit #D: NSPS-OOO).

II.B.18.a Condition:

Emissions of particulate matter (PM) shall be no greater than 0.022 grains/dscf. [Origin: 40 CFR 60
Subpart OOO]. [40 CFR 60.672(a)]

II.B.18.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every three calendar years. Tests may also be required
at the direction of the Director.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Methods.
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) or
Mine Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
(2) Sample Method - 40 CFR 60, Appendix A, Method 5 or Method 17 shall be used to
determine the particulate matter concentration. The minimum sample volume shall be
1.70 dscm (60 dscf). For Method 5, if the gas stream being sampled is at ambient
temperature, the sampling probe and filter may be operated without heaters. If the gas
stream is above ambient temperature, the sampling probe and filter may be operated at a
temperature high enough, but no higher than 121 deg. C (250 deg F), to prevent water
condensation on the filter.
(d) 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.
(e) 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.

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II.B.18.a.2 Recordkeeping:

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

II.B.18.a.3 Reporting:

Reports shall be submitted in accordance with 40 CFR 60.676(f). The 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. A stack test was last performed on D-1 quarry stacker baghouse on August 9, 2023.
Test results were submitted to DAQ and evaluated in DAQC-1229-23. The DAQ calculated
emissions of PM was 0.001 gr/dscf. Next test is due in 2026.

II.B.18.b Condition:

Visible emissions shall be no greater than 7 percent opacity. [Origin: DAQE-AN103130047-24, 40 CFR
60 Subpart OOO]. [40 CFR 60.672(a), R307-401-8]

II.B.18.b.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.18.b.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.18.b.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. Records were reviewed onsite and appeared complete. Opacity observations were
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conducted on a monthly basis using the survey group alternate method. No emissions were
observed during this inspection.

II.B.19 Conditions on Observation Point D: Limestone Crushers (Unit #D: CRUSHERS).

II.B.19.a Condition:

Visible emissions shall not exceed 15 percent opacity. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.19.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.19.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.19.a.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No emissions were
observed during this inspection.

II.B.20 Conditions on Abrasive Blasting (Unit #AB).

II.B.20.a Condition:

(i) Except as provided in (ii) below, visible emissions shall not exceed 20% opacity, except for an
aggregate period of three minutes in any one hour.
(ii) If the abrasive blasting operation complies with the performance standards in R307-306-6, visible
emissions from the operation shall not exceed 40% opacity, except for an aggregate period of 3 minutes
in any one hour
[Origin: R307-306]. [R307-306]
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II.B.20.a.1 Monitoring:

(a) Visible emissions shall be measured at least semi-annually using EPA Method 9. Visible
emissions from intermittent sources shall use procedures similar to Method 9, but the
requirement for observations to be made at 15 second intervals over a six-minute period shall
not apply.
(b) Visible emissions from unconfined blasting shall be measured at the densest point of the
emission after a major portion of the spent abrasive has fallen out, at a point not less than
five feet nor more than twenty-five feet from the impact surface from any single abrasive
blasting nozzle.
(c) An unconfined blasting operation that uses multiple nozzles shall be considered a single
source unless it can be demonstrated by the permittee that each nozzle, measured separately,
meets the visible emission standards in R307-306-4.
(d) Emissions from confined blasting shall be measured at the densest point after the air
pollutant leaves the enclosure.

II.B.20.a.2 Recordkeeping:

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

II.B.20.a.3 Reporting:

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

Status: In Compliance. This equipment was not operated during the 12-month period prior to inspection.

II.B.21 Conditions on Fuel Storage Tanks (Unit #TANKS)

II.B.21.a Condition:

For each gasoline storage tank:
The permittee shall not allow gasoline to be handled in a manner that would result in vapor releases to the
atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the
following:
(1) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when
not in use;
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators.
(5) Portable gasoline containers that meet the requirements of 40 CFR part 59, subpart F, are considered
acceptable for compliance with paragraph (3) of this section.

At all times, the permittee shall operate and maintain any affected emission unit, 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 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.

94
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 3 of 40 CFR 63 Subpart CCCCCC.

This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart CCCCCC]. [40 CFR 63.11111(b), 40 CFR 63.11115, 40 CFR
63.11116, 40 CFR 63.11130]

II.B.21.a.1 Monitoring:

Records required for this permit condition will serve as monitoring. Additionally, the permittee
shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of
40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130].

II.B.21.a.2 Recordkeeping:

The permittee shall keep records demonstrating monthly throughput is less than the 10,000-gallon
threshold level. Records shall be available within 24 hours of a request by the Director to
document gasoline throughput in the affected emission unit. [40 CFR 63.11111(e), 40 CFR
63.11116(b)]

The permittee shall keep records of the occurrence and duration of each malfunction of operation
(i.e., process equipment) or the air pollution control and monitoring equipment. Records shall be
kept of actions taken during periods of malfunction to minimize emissions, including corrective
actions to restore malfunctioning process and air pollution control and monitoring equipment to
its normal or usual manner of operation. [40 CFR 63.11115(b), 40 CFR 63.11125(d)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]

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

II.B.21.a.3 Reporting:

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

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.22 Conditions on Haul Roads (Unit #HR).

II.B.22.a Condition:

Visible emissions from haul road traffic shall be minimized in accordance with the fugitive dust control
plan. [Origin: DAQE-AN103130047-24]. [R307-401-8]

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II.B.22.a.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust.

II.B.22.a.2 Recordkeeping:

Records that demonstrate compliance with the most recently approved fugitive dust control plan
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.22.a.3 Reporting:

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

Status: In Compliance. Fugitive dust is controlled through applications of water and MgCl2, monthly
sweeping, road speed limits, and daily watering applications. Records have been kept as required
and indicated compliance with this condition. Haul roads had been watered on the day of
inspection and a crust was visible on dirt berms lining the roads.

II.B.22.b Condition:

Truck hauling of stone from the quarry to the plant shall not exceed 108 round trips per 24-hour period
(midnight to midnight). [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.22.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.22.b.2 Recordkeeping:

The number of round trips per 24-hour period shall be recorded in a log on a daily basis. Records
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.22.b.3 Reporting:

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

Status: In Compliance. Haul trips are recorded daily. Records were reviewed onsite with no deviations
discovered. Hauling is done by a third party and trips are accounted for by trip tickets as part of a
fee agreement. The highest daily round trips recorded in records reviewed onsite for the previous
12 months was 54 trips.

II.B.23 Conditions on Sugar Stone System (Unit #SS).

II.B.23.a Condition:

Production of sugar stone shall not exceed 135,000 tons per rolling 12-month period. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

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II.B.23.a.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months. Records required for this permit condition will also serve as monitoring.

II.B.23.a.2 Recordkeeping:

Production shall be determined using plant production records, such as scale records or sales
receipts. Records of production shall be kept on a daily basis for all periods of operation. The
rolling 12-month totals shall be recorded monthly. Records shall be kept in accordance with
Provision I.S.1 of this permit.

II.B.23.a.3 Reporting:

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

Status: In Compliance. Records are tracked and kept on site. Review of records showed 21,968 tons of
sugar stone were produced during the 12-month period ending April 30, 2024.

II.B.24 Conditions on Portable Crushing System (Unit #PCS-0).

II.B.24.a Condition:

Hours of operation shall not exceed 4,000 hours per rolling 12-month period. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.24.a.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months.

II.B.24.a.2 Recordkeeping:

Hours of operation for each emission unit shall be recorded in a log on a daily basis. The rolling
12-month totals shall be recorded monthly. Records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.24.a.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 total as of April 30, 2024, was 96 hours. The portable crushing
system was onsite during the 12-month period March and April 2024 only.

II.B.24.b Condition:

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Production of limestone shall not exceed 750,000 tons per rolling 12-month period. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.24.b.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months. Records required for this permit condition will also serve as monitoring.

II.B.24.b.2 Recordkeeping:

Production shall be determined using plant production records, such as scale records or sales
receipts. Records of production shall be kept on a daily basis for all periods of operation. The
rolling 12-month totals shall be recorded monthly. Records shall be kept in accordance with
Provision I.S.1 of this permit.

II.B.24.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 total as of April 30, 2024, was 14,002 tons. The portable crushing
system was onsite during the 12-month period March and April 2024 only.

II.B.25 Conditions on Portable Crushing System Crushers (Unit #PCS-1).

II.B.25.a Condition:

Visible emissions shall be no greater than 15 percent opacity from each affected emission unit
constructed, modified, or reconstructed after August 31, 1983 but before April 22, 2008. [Origin: DAQE-
AN103130047-24, 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b), R307-401-8]

II.B.25.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

98
II.B.25.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.25.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. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No observations made.
The portable crushing system was onsite during the 12-month period March and April 2024 only.

II.B.25.b Condition:

Within 60 days after achieving the maximum production rate at which the affected emission unit will be
operated, but not later than 180 days after initial startup, visible emissions shall be no greater than 12
percent opacity from each affected emission unit constructed, modified, or reconstructed on or after April
22, 2008. [Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b),
R307-401-8]

II.B.25.b.1 Monitoring:

The permittee shall conduct an initial performance test using 40 CFR 60, Appendix A, Method 9,
and the procedures in 40 CFR 60.11, with the additions specified in 40 CFR 60.675(c)(1). The
duration of the Method 9 observations shall be 30 minutes (five 6-minute averages). Compliance
shall be based on the average of the five 6-minute averages. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) within a 15-second interval if the following conditions are
met:
(i) No more than three emission points shall be read concurrently.
(ii) All three emission points shall be within a 70 degree viewing sector or angle in front of the
observer such that the proper sun position can be maintained for all three points.
(iii) If an opacity reading for any one of the three emission points equals or exceeds the
applicable standard, then the observer shall stop taking readings for the other two points and
continue reading just that single point.

Before the initial Method 9 performance test, the permittee shall provide a 7-day advance
notification to the Director of the anticipated date for conducting the opacity observations.

Repeat performance tests shall be conducted according to 40 CFR 60.675 every 5 years from the
previous performance test.

II.B.25.b.2 Recordkeeping:

Records documenting the results of monitoring shall be kept in accordance with Provision I.S.1
of this permit.

99
II.B.25.b.3 Reporting:

Notification of the actual date of initial startup of each affected emission unit shall be submitted
in accordance with 40 CFR 60.676(i). Reports shall be submitted in accordance with 40 CFR
60.676(f) and as specified in Section I of this permit.

Status: In Compliance. Initial observations were done in 2021 and submitted to DAQ. Next observations
are due in 2026.

II.B.26 Conditions on PCS-2: Portable Crushing System Screen/Conveyor Transfer Points

II.B.26.a Condition:

Visible emissions from each screening operation and each conveyor transfer point shall be no greater than
10 percent opacity. [Origin: DAQE-AN103130047-24, 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b),
R307-401-8]

II.B.26.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.26.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.26.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. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No observations made.
The portable crushing system was onsite during the 12-month period March and April 2024 only.

II.B.27 Conditions on Portable Crushing System Conveyor Drop Points (Unit #PCS-3).

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II.B.27.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [Origin: DAQE-AN103130047-24].
[R307-401-8]

II.B.27.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.27.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.27.a.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No observations made.
The portable crushing system was onsite during the 12-month period March and April 2024 only.

II.B.28 Conditions on Portable Crushing System Engines (Unit #PCS-4).

II.B.28.a Condition:

Visible emissions shall not exceed 20 percent opacity. [Origin: DAQE-AN103130047-24].
[R307-401-8]

II.B.28.a.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
101
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.28.a.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.28.a.3 Reporting:

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

Status: In Compliance. Records were reviewed onsite and appeared complete. Opacity observations were
conducted on a monthly basis using the survey group alternate method. No observations made.
The portable crushing system was onsite during the 12-month period March and April 2024 only.

II.B.29 Conditions on Processed Stone Handling Operations (Unit #PSH)

II.B.29.a Condition:

Stack emissions of PM shall not exceed 0.05 grams per dry standard cubic meter (g/dscm). This
condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of this
permit. [Origin: 40 CFR 63 Subpart AAAAA]. [40 CFR 63.7090(a)]

II.B.29.a.1 Monitoring:

Stack testing shall be performed as specified below:
(a) Frequency. Emissions shall be tested every five years, based on the date of the most recent
stack test. Tests may also be required at the direction of the Director.
(b) Notification. At least 60 days before the test, the source shall notify the Director of the date,
time, and place of testing and submit a copy of the test protocol. The source shall attend a
pretest conference if determined necessary by the Director.
(c) Sample Method - PM emissions shall be measured using Method 5 or Method 17 in 40 CFR
part 60 appendix A. (Method 17 may be used only with exhaust gas temperatures of not
more than 250 degrees Fahrenheit). The sample volume shall be at least 1.70 dscm (60
dscf). For Method 5, if the gas stream being sampled is at ambient temperature, the
sampling probe and filter may be operated without heaters. If the gas stream is above
ambient temperature, the sampling probe and filter may be operated at a temperature high
enough to prevent water condensation on the filter, but no higher than 121 degrees Celsius
(250 degrees Fahrenheit). The permittee shall conduct three separate test runs for each
performance test. Each test run shall last at least 1 hour.
102
(d) Each performance test shall be conducted based on representative performance (i.e.,
performance based on normal operating conditions) of the affected source and under the
specific conditions in Table 5 to 40 CFR 63 Subpart AAAAA. Representative conditions
exclude periods of startup and shutdown. The permittee shall not conduct performance tests
during periods of startup, shutdown, or malfunction. (40 CFR 63.7112(b), (c)).

II.B.29.a.2 Recordkeeping:

In addition to the records specified in 40 CFR 63.7132:
Results of stack testing shall be recorded in accordance with the associated test met hod and
Provision I.S.1 of this permit. The permittee shall record the process information that is
necessary to document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon request, the
permittee shall make available to the Director such records as may be necessary to determine the
conditions of performance tests.

Records and results of monitoring shall be maintained in accordance with 40 CFR 63.7133 and
Provision I.S.1 of this permit.

II.B.29.a.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h). The 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.

The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. The last performance test was conducted on the D-415 baghouse on September 15,
2020. Test results were submitted to DAQ and reviewed in DAQC-1564-20. DAQ calculated
emissions of PM were 0.0003 g/dscf. Next stack test is due in 2025.

II.B.29.b Condition:

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Stack emissions shall not exceed 7 percent opacity. This condition does not apply if the permittee is
operating in accordance with the AOS in Section II.D of this permit. [Origin: 40 CFR 63 Subpart
AAAAA, DAQE-AN103130047-24]. [40 CFR 63.7090(a), R307-401-8]

II.B.29.b.1 Monitoring:

The permittee shall demonstrate ongoing compliance by:
(i) Conducting a monthly 1-minute visible emission (VE) check of each emission unit in
accordance with (a) - (c) below; the check shall be conducted while the affected source is in
operation.
(a) Conduct visual inspections that consist of a visual survey of each stack or process
emission point over the test period to identify if there are VE, other than condensed
water vapor. If wet dust suppression is used to control PM from PSH operations, the
visible mist generated by the spray shall not be confused with particulate matter
emissions and shall not be considered VE. When a water mist of this nature is present,
the permittee shall observe emissions at a point in the plume where the mist is no longer
visible.
(b) Select a position at least 15 but not more 1,320 feet from the affected emission point
with the sun or other light source generally at the observer's back. The observer shall,
when possible, select a position that minimizes interference from other fugitive
emission sources (e.g., road dust). The required observer position relative to the sun
shall be followed.
(c) The observer conducting the VE checks need not be certified to conduct EPA Method 9
in 40 CFR 60 appendix A, but shall meet the training requirements as described in EPA
Method 22 of 40 CFR 60 appendix A.
(ii) If no VE are observed in 6 consecutive monthly checks for any emission unit, the permittee
may decrease the frequency of VE checking from monthly to semi-annually for that
emission unit. If VE are observed during any semiannual check, the permittee shall resume
VE checking of that emission unit on a monthly basis and maintain that schedule until no VE
are observed in 6 consecutive monthly checks;
(iii) If no VE are observed during the semiannual check for any emission unit, the permittee may
decrease the frequency of VE checking from semi-annually to annually for that emission
unit. If VE are observed during any annual check, the permittee shall resume VE checking
of that emission unit on a monthly basis and maintain that schedule until no VE are observed
in 6 consecutive monthly checks; and
(iv) If VE are observed during any VE check, the permittee shall conduct a 6-minute test of
opacity in accordance with Method 9 of 40 CFR 60 appendix A. The permittee shall begin
the Method 9 test within 1 hour of any observation of VE and the 6-minute opacity reading
shall not exceed the applicable opacity limit.

In addition, the permittee shall conduct opacity observations every five years, based on the date
of the last performance test, using Method 9 in 40 CFR part 60 appendix A. The test duration
shall be for at least 3 hours and at least thirty, 6-minute averages shall be obtained. If a fabric
filter controls emissions from only an individual, enclosed storage bin, the test duration shall be
for at least 1 hour and ten 6-minute averages shall be obtained. The permittee shall submit a
notification of intent to conduct a performance test at least 60 calendar days before the
performance test is scheduled to begin.

II.B.29.b.2 Recordkeeping:

104
In addition to the records specified in 40 CFR 63.7132, results of monitoring and all data required
by 40 CFR 60, Appendix A, Method 9 shall be recorded and maintained in accordance with 40
CFR 63.7133 and Provision I.S.1 of this permit.

II.B.29.b.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the 5-year
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h).
The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

The permittee shall report the opacity or visible emission results in accordance with 40 CFR
63.10(d)(3). For the periodic monitoring in II.B.29.b.1(i)-(iv), the permittee shall report the
opacity or visible emission results before the close of business on the 30th day following the
completion of the opacity or visible emission observations only if visible emissions are observed
and a subsequent visual opacity test is required.

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Graymont has chosen to remain on the monthly VEO schedule regardless of
observation results. Records were reviewed onsite and appeared complete. No emissions were
observed during this inspection. Semi-annual compliance reports have been submitted.

Five-year opacity observations of the Process Stone Handling Operations were last conducted April
20 through May 5, 2021. Results were submitted to DAQ.

II.B.29.c Condition:

Fugitive emissions shall not exceed 10 percent opacity. This condition does not apply if the permittee is
operating in accordance with the AOS in Section II.D of this permit. [Origin: 40 CFR 63 Subpart
AAAAA, DAQE-AN103130047-24]. [40 CFR 63.7090(a), R307-401-8]

II.B.29.c.1 Monitoring:

The permittee shall demonstrate ongoing compliance by:
(i) Conducting a monthly 1-minute visible emission (VE) check of each emission unit in
accordance with (a) - (c) below; the check shall be conducted while the affected source is in
operation.
105
(a) Conduct visual inspections that consist of a visual survey of each stack or process
emission point over the test period to identify if there are VE, other than condensed
water vapor. If wet dust suppression is used to control PM from PSH operations, the
visible mist generated by the spray shall not be confused with particulate matter
emissions and shall not be considered VE. When a water mist of this nature is present,
the permittee shall observe emissions at a point in the plume where the mist is no
longer visible.
(b) Select a position at least 15 but not more 1,320 feet from the affected emission point
with the sun or other light source generally at the observer's back. The observer shall,
when possible, select a position that minimizes interference from other fugitive
emission sources (e.g., road dust). The required observer position relative to the sun
shall be followed.
(c) The observer conducting the VE checks need not be certified to conduct EPA Method
9 in 40 CFR 60 appendix A, but shall meet the training requirements as described in
EPA Method 22 of 40 CFR 60 appendix A.
(ii) If no VE are observed in 6 consecutive monthly checks for any emission unit, the permittee
may decrease the frequency of VE checking from monthly to semi-annually for that
emission unit. If VE are observed during any semiannual check, the permittee shall resume
VE checking of that emission unit on a monthly basis and maintain that schedule until no
VE are observed in 6 consecutive monthly checks;
(iii) If no VE are observed during the semiannual check for any emission unit, the permittee
may decrease the frequency of VE checking from semi-annually to annually for that
emission unit. If VE are observed during any annual check, the permittee shall resume VE
checking of that emission unit on a monthly basis and maintain that schedule until no VE
are observed in 6 consecutive monthly checks; and
(iv) If VE are observed during any VE check, the permittee shall conduct a 6-minute test of
opacity in accordance with Method 9 of 40 CFR 60 appendix A. The permittee shall begin
the Method 9 test within 1 hour of any observation of VE and the 6-minute opacity reading
shall not exceed the applicable opacity limit.

In addition, the permittee shall conduct opacity observations every five years, based on the date
of the last performance test, using Method 9 in 40 CFR 60 appendix A. The test duration shall be
for at least 3 hours, but the 3-hour test may be reduced to 1 hour if, during the first 1-hour period,
there are no individual readings greater than 10 percent opacity and there are no more than three
readings of 10 percent during the first 1-hour period. The permittee shall submit a notification of
intent to conduct a performance test at least 60 calendar days before the performance test is
scheduled to begin.

II.B.29.c.2 Recordkeeping:

In addition to the records specified in 40 CFR 63.7132, results of monitoring and all data required
by 40 CFR 60, Appendix A, Method 9 shall be recorded and maintained in accordance with 40
CFR 63.7133 and Provision I.S.1 of this permit.

II.B.29.c.3 Reporting:

The permittee shall submit a Notification of Compliance Status, including the performance test
results, before the close of business on the 60th calendar day following completion of the 5-year
performance test.

Performance test results shall be documented in complete test reports that contain the information
required in 40 CFR 63.7(g) and 40 CFR 63.7112(h).
106
The permittee shall submit a compliance report semiannually containing the information required
in Table 8 to 40 CFR 63 Subpart AAAAA and in accordance with 40 CFR 63.7131. If the
permittee submits the compliance report along with, or as part of, the semiannual monitoring
report required in Section I of this permit and the compliance report includes all required
information concerning deviations from any emission limitation (including any operating limit),
submission of the compliance report shall be deemed to satisfy any obligation to report the same
deviations in the semiannual monitoring report. However, submission of a compliance report
shall not otherwise affect any obligation the permittee has to report deviations from permit
requirements to the permit authority. [40 CFR 63.7131(f)]

The permittee shall report the opacity or visible emission results in accordance with 40 CFR
63.10(d)(3). For the periodic monitoring in II.B.29.c.1(i)-(iv), the permittee shall report the
opacity or visible emission results before the close of business on the 30th day following the
completion of the opacity or visible emission observations only if visible emissions are observed
and a subsequent visual opacity test is required.

Reports shall be submitted in accordance with 40 CFR 63.7131 and as outlined in Section I of
this permit.

Status: In Compliance. Graymont has chosen to remain on the monthly VEO schedule regardless of
observation results. Records were reviewed onsite and appeared complete. No emissions were
observed during this inspection. Semi-annual compliance reports have been submitted.

Five-year opacity observations of the Process Stone Handling Operations were last conducted April
20 through May 5, 2021. Results were submitted to DAQ.

II.B.29.d Condition:

Fugitive emissions from PSH operations shall not exceed 10 percent opacity. This condition only applies
if the permittee is operating in accordance with the AOS in Section II.D of this permit. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.29.d.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.29.d.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
107
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.29.d.3 Reporting:

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

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.29.e Condition:

Stack emissions from PSH operations shall not exceed 7 percent opacity. This condition only applies if
the permittee is operating in accordance with the AOS in Section II.D of this permit. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.29.e.1 Monitoring:

A certified observer shall conduct a visible emissions observation, in accordance with 40 CFR 60,
Appendix A, Method 9, of affected emission units monthly. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (A, B, C or D) monthly. A certified observer shall determine the unit with
the highest observed opacity. A visible emissions observation shall be conducted, in accordance
with Method 9, on that unit. If this unit does not exceed its opacity limitation, no further
observation is required for any other affected emission units, surveyed for this location, with an
equal or higher opacity limit. If the unit exceeds its opacity limitation, a visual observation shall
be conducted on the unit that appears to have the next highest opacity, and so on, until an
emission unit of this group does not exceed the opacity limitation. Once an emission unit has
been determined to comply with this condition, units with the same or higher opacity limit, that
were surveyed from the same location and appear to have less visible emissions, shall be
considered to be in compliance with their opacity limitation.

II.B.29.e.2 Recordkeeping:

The permittee shall record the location of each visual opacity observation and keep a list of the
emission units checked during the observation. The records required by this provision and all
data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.29.e.3 Reporting:

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

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS
in Section II.D of this permit.

II.B.30 Conditions on NSPS-CI-ICE: NSPS Stationary Compression Ignition (CI) Internal Combustion
Engines (ICE).

108
II.B.30.a Condition:

For KDE 1, KDE 2, KDE 5, and both LFP engines:
2007 model year and later non-emergency stationary affected emission units with a displacement of less
than 30 liters per cylinder shall comply with the emission standards for new CI engines in 40 CFR
60.4201 for their 2007 model year and later stationary CI ICE, as applicable. Modified or reconstructed
non-emergency stationary affected emission units shall meet the emission standards for new CI engines in
40 CFR 60.4201 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 non-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 60.4204(b), 40
CFR 60.4204(d), 40 CFR 60.4204(e), 40 CFR 63 Subpart ZZZZ]
II.B.30.a.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4204(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. [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 with maximum engine power less than 100 HP, the permittee
shall keep a maintenance plan and records of conducted maintenance to demonstrate
compliance 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, if
the permittee does not install and configure the engine and control device according to the
manufacturer's emission-related written instructions, or changes the emission-related settings
in a way that is not permitted by the manufacturer, the permittee shall conduct an initial
performance test to demonstrate compliance with the applicable emission standards within 1
year of such action.
(b) For affected emission units 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 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.
[40 CFR 60.4211(g)]

For modified or reconstructed affected emission units that shall comply with the emission
standards specified in 40 CFR 60.4204(e), the permittee shall demonstrate compliance by
purchasing, or otherwise owning or operating, an engine certified to the emission standards in 40
CFR 60.4204(e) 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)].

109
II.B.30.a.2 Recordkeeping:

The permittee shall keep records of engine certifications indicating compliance with the
standards. The permittee shall keep records demonstrating compliance with the manufacturer's
emission-related specifications for engine installation and configuration or results of performance
tests, as applicable. Records and results of monitoring shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.30.a.3 Reporting:

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

Status: In Compliance. Only approved engines have been purchased and installed.

II.B.30.b Condition:

For KDE 1, KDE 2, KDE 5, and both LFP engines:
The permittee shall operate and maintain affected emission units that achieve the emission standards as
required in 40 CFR 60.4204 over the entire life of the engine. The permittee shall do all of the following,
except as permitted in II.B.30.b.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), 40 CFR 63 Subpart ZZZZ]

II.B.30.b.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
changes emission-related settings in a way that is not permitted by the manufacturer, the
permittee shall demonstrate compliance as follows:
i. For affected emission units with maximum engine power less than 100 HP, the permittee
shall keep a maintenance plan and records of conducted maintenance to demonstrate
compliance 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, if the permittee does not install and configure the engine and control device
according to the manufacturer's emission-related written instructions, or changes the
emission-related settings in a way that is not permitted by the manufacturer, the
permittee shall conduct an initial performance test to demonstrate compliance with the
applicable emission standards within 1 year of such action.
ii. For affected emission units 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 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
110
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.
[40 CFR 60.4211(g)].

II.B.30.b.2 Recordkeeping:

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

II.B.30.b.3 Reporting:

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. Graymont operates and maintains affected engines according
to subpart ZZZZ and IIII requirements. Graymont employs a computerized tracking system to
schedule and record preventative and as needed maintenance. Work orders are generated, and
applicable data is added as maintenance activities are completed.

II.B.30.c Condition:

For KDE 1, KDE 2, KDE 5, and both LFP engines:
For all affected emission units, with a displacement of less than 30 liters per cylinder, the permittee shall
use diesel fuel that meets the requirements of 40 CFR 1090.305 for nonroad diesel fuel. [Origin: 40 CFR
60 Subpart IIII]. [40 CFR 60.4207(b), 40 CFR 63 Subpart ZZZZ]

II.B.30.c.1 Monitoring:

For all diesel fuel combusted, the permittee shall demonstrate compliance either by measuring the
fuel parameters in accordance with 40 CFR 1090.300 or by maintaining the specified records.

II.B.30.c.2 Recordkeeping:

The permittee shall maintain records documenting the results of diesel fuel testing or keep diesel
fuel purchase invoices or certifications obtained from the diesel fuel supplier. 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.

II.B.30.c.3 Reporting:

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

Status: In Compliance. Fuel records show that Graymont uses ultra-low sulfur diesel.

II.B.30.d Condition:

111
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
(h).
(a) After December 31, 2008, the permittee shall not install stationary CI ICE (excluding fire pump
engines) that do not meet the applicable requirements for 2007 model year engines.
(b) After December 31, 2009, the permittee shall not install stationary CI ICE with a maximum engine
power of less than 19 KW (25 HP) (excluding fire pump engines) that do not meet the applicable
requirements for 2008 model year engines.
(c) After December 31, 2014, the permittee shall not install non-emergency stationary CI ICE with a
maximum engine power of greater than or equal to 19 KW (25 HP) and less than 56 KW (75 HP)
that do not meet the applicable requirements for 2013 model year non-emergency engines.
(d) After December 31, 2013, the permittee shall not install non-emergency stationary CI ICE with a
maximum engine power of greater than or equal to 56 KW (75 HP) and less than 130 KW (175 HP)
that do not meet the applicable requirements for 2012 model year non-emergency engines.
(e) After December 31, 2012, the permittee shall not install non-emergency stationary CI ICE with a
maximum engine power of greater than or equal to 130 KW (175 HP), including those above 560
KW (750 HP), that do not meet the applicable requirements for 2011 model year non-emergency
engines.
(f) After December 31, 2016, the permittee shall not install non-emergency stationary CI ICE with a
maximum engine power of greater than or equal to 560 KW (750 HP) that do not meet the applicable
requirements for 2015 model year non-emergency engines.
(g) After December 31, 2018, the permittee shall not install non-emergency stationary CI ICE with a
maximum engine power greater than or equal to 600 KW (804 HP) and less than 2,000 KW (2,680
HP) and a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per
cylinder that do not meet the applicable requirements for 2017 model year non-emergency engines.
(h) 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 paragraphs (a) and through (g) of
this section after the dates specified in paragraphs (a) and through (g) of this section.
[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4200(a)(4), 40 CFR 60.4208, 40 CFR 63 Subpart ZZZZ]

II.B.30.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.30.d.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. Records shall be maintained as described
in Provision I.S.1 of this permit.

II.B.30.d.3 Reporting:

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

Status: In Compliance. Only approved engines have been purchased and installed.

II.B.31 Conditions on NESHAP-CI-RICE: NESHAP Stationary Compression Ignition (CI) Reciprocating
Internal Combustion Engines (RICE).

II.B.31.a Condition:
112
For KDE 4:
The permittee shall comply with the following requirements at all times for each non-emergency CI RICE
less than 100 HP:
1. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 1,000 hours of operation or annually, whichever comes first;
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace
as necessary;
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
2. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6602, 40 CFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2c, 40 CFR 63
Subpart ZZZZ Table 8]

II.B.31.a.1 Monitoring:

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.31.a.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

113
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.31.a.3 Reporting:

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. These requirements have been incorporated into the
maintenance program. All requested maintenance records were provided during inspection.

II.B.31.b Condition:

For GEN-1:
For each affected non-emergency CI RICE greater than or equal to 100 HP and less than or equal to 300
HP, the permittee shall limit concentration of CO in the stationary RICE exhaust to 230 ppmvd or less at
15 percent O2, at all times except during periods of startup. During periods of startup, the permittee shall
minimize the engine's time spent at idle and minimize the engine's startup time to a period needed for
appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup
emission limitations apply.

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.

This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6602, 40 CFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2c, 40 CFR 63
Subpart ZZZZ Table 8]

II.B.31.b.1 Monitoring:

The permittee shall demonstrate ongoing compliance by performing an emissions test at least
once every five years, based on the date of the most recent test, using the methods specified in 40
CFR 63 Subpart ZZZZ Table 4. At least 30 days before the test, the source shall notify the
Director of the date, time and place of testing. [R307-165]

Each performance test shall be conducted according to the requirements specified in 40 CFR 63
Subpart ZZZZ Table 4, number 3.a. The permittee shall conduct three separate test runs for each
required performance test, as specified in 40 CFR 63.7(e)(3). Each test run shall last at least 1
hour. Compliance with the numerical emission limitations is based on the results of testing the
average of three 1-hour runs using the testing requirements and procedures in 40 CFR 63.6620
and 40 CFR 63 Subpart ZZZZ Table 4. [40 CFR 63.6602, 40 CFR 63.6620(b), (d)]

The engine percent load during a performance test shall be determined by documenting the
calculations, assumptions, and measurement devices used to measure or estimate the percent load
in a specific application. [40 CFR 63.6620(i)]

114
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.31.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.31.b.3 Reporting:

A written report of the average percent load determination shall be included in the Notification of
Compliance Status. The following information shall be included in the written report: the engine
model number, the engine manufacturer, the year of purchase, the manufacturer's site-rated brake
horsepower, the ambient temperature, pressure, and humidity during the performance test, and all
assumptions that were made to estimate or calculate percent load during the performance test
shall be clearly explained. If measurement devices such as flow meters, kilowatt meters, beta
analyzers, stain gauges, etc. are used, the model number of the measurement device, and an
estimate of its accurate in percentage of true value shall be provided. [40 CFR 63.6620(i)]

The permittee shall report each instance in which it did not meet an applicable emission limitation
in 40 CFR 63 Subpart ZZZZ Table 2c. These instances are deviations from the emission
limitations. These deviations shall be reported according to the requirements in 40 CFR 63.6650.
[40 CFR 63.6640(b)]

The permittee shall submit each report in 40 CFR 63 Subpart ZZZZ Table 7 as applicable. [40
CFR 63.6650(a)]

If there are no deviations from any applicable emission limitations, the permittee shall submit a
compliance report semiannually for affected emission units according to the requirements of 40
CFR 63.6650(b)(1)-(5) that contains the information required in 40 CFR 63.6650(c)(1)-(3) and a
statement that there were no deviations from the emission limitations during the reporting period.
[40 CFR 63 Subpart ZZZZ Table 7.1.a]

If a deviation from any emission limitation occurs during the reporting period, the permittee shall
submit a compliance report semiannually according to the requirements of 40 CFR 63.6650(b),
(f) that contains the information required in 40 CFR 63.6650(c)(1)-(3), (d). [40 CFR 63 Subpart
ZZZZ Table 7.1.b]

If a malfunction occurs during the reporting period, the permittee shall submit a compliance
report semiannually according to the requirements of 40 CFR 63.6650(b) that contains the
information required in 40 CFR 63.6650(c)(1)-(4). [40 CFR 63 Subpart ZZZZ Table 7.1.c]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8 and shall submit all of the applicable notifications
in 40 CFR 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) by the
115
dates specified. [40 CFR 63.6645(a), 40 CFR 63.6665] The permittee shall also report each
instance in which it did not meet the applicable requirements in Table 8. [40 CFR 63.6640(e)]

The results of ongoing compliance testing shall be submitted to the Director within 60 days of
completion of testing. There are no additional reporting requirements for this provision except
those specified in Section I of this permit.

Status: In Compliance. This condition applies to the Sugar Stone generator only. The Sugar Stone
generator is a non-emergency, existing, 100 hp, CI RICE. The last stack test was on June 3, 2022,
and results were submitted to DAQ. The DAQ (DAQC-1225-22) calculated value was 74.2 ppmdv
@15% O2. The next test is due in 2027. Reports have been submitted as required.

II.B.31.c Condition:

For KDE 4 and GEN-1:
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. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. 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 ZZZZ]. [40 CFR
63.6595(a)(1), 40 CFR 63.6605(b)]

II.B.31.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.31.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and
Provision I.S.1 of this permit.

II.B.31.c.3 Reporting:

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

Status: In Compliance. The company has a maintenance tracking system which includes all applicable
requirements.

II.B.31.d Condition:

For KDE 4 and GEN-1:
The permittee shall comply with the following requirements at all times for each non-emergency CI RICE
less than or equal to 300 HP:
1. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 1,000 hours of operation or annually, whichever comes first;
116
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace
as necessary;
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
2. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6603, 40 CFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d, 40 CFR 63
Subpart ZZZZ Table 8]

II.B.31.d.1 Monitoring:

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.31.d.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.31.d.3 Reporting:

117
The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. These requirements have been incorporated into the
maintenance program. All requested maintenance records were provided during inspection.
Engine startup time is minimized.

II.B.32 Conditions on NESHAP-SI-RICE: NESHAP Stationary Spark Ignition (SI) Reciprocating Internal
Combustion Engines (RICE).
II.B.32.a Condition:

For KDE 3:
The permittee shall comply with the following requirements at all times for each non-emergency SI RICE
less than 100 HP:
1. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 1,440 hours of operation or annually, whichever comes first;
b. Inspect spark plugs every 1,440 hours of operation or annually, whichever comes first, and
replace as necessary;
c. Inspect all hoses and belts every 1,440 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
2. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
This condition does not apply if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6602, 40 CFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2c, 40 CFR 63
Subpart ZZZZ Table 8]

II.B.32.a.1 Monitoring:

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(j).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

118
II.B.32.a.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.32.a.3 Reporting:

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. These requirements have been incorporated into the
maintenance program. All requested maintenance records were provided during inspection.
Engine startup time is minimized.

II.B.32.b Condition:

For KDE 3:
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. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. 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 ZZZZ]. [40 CFR
63.6595(a)(1), 40 CFR 63.6605(b)]

II.B.32.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

119
II.B.32.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and
Provision I.S.1 of this permit.

II.B.32.b.3 Reporting:

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. These requirements have been incorporated into the
maintenance program. All requested maintenance records were provided during inspection.

II.B.32.c Condition:
For KDE 3:
The permittee shall comply with the following requirements at all times for each non-emergency SI RICE
less than or equal to 500 HP:
1. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 1,440 hours of operation or annually, whichever comes first;
b. Inspect spark plugs every 1,440 hours of operation or annually, whichever comes first, and
replace as necessary;
c. Inspect all hoses and belts every 1,440 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
2. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
This condition only applies if the permittee is operating in accordance with the AOS in Section II.D of
this permit. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6595(a)(1), 40 CFR 63.6603, 40 CFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d, 40 CFR 63
Subpart ZZZZ Table 8]

II.B.32.c.1 Monitoring:

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(j).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

120
II.B.32.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.32.c.3 Reporting:

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

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

Status: In Compliance. The source appeared to be operated and maintained in a manner consistent with
good air pollution control practices. These requirements have been incorporated into the
maintenance program. All requested maintenance records were provided during inspection.
Engine startup time is minimized.

II.B.33 Conditions on Limestone Fines Product (LFP) Loadout System

II.B.33.a Condition:

Hours of operation shall not exceed 6,500 hours per rolling 12-month period. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.33.a.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months.

II.B.33.a.2 Recordkeeping:

121
Hours of operation for each emission unit shall be recorded in a log on a daily basis. The rolling
12-month totals shall be recorded monthly. Records shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.33.a.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 total as of April 30, 2024, was 103 hours.

II.B.33.b Condition:

Production of limestone shall not exceed 200,000 tons per rolling 12-month period. [Origin: DAQE-
AN103130047-24]. [R307-401-8]

II.B.33.b.1 Monitoring:

Compliance with the limitation shall be demonstrated through a rolling 12-month total. The
permittee shall calculate a new 12-month total by the 25th day of each month using data from the
previous 12 months. Records required for this permit condition will also serve as monitoring.

II.B.33.b.2 Recordkeeping:

Production shall be determined using plant production records, such as scale records or sales
receipts. Records of production shall be kept on a daily basis for all periods of operation. The
rolling 12-month totals shall be recorded monthly. Records shall be kept in accordance with
Provision I.S.1 of this permit.

II.B.33.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 total as of April 30, 2024, was 24,692 tons.

II.B.34 Conditions on E: LFP Screen/Conveyor Transfer Points

II.B.34.a Condition:

Within 60 days after achieving the maximum production rate at which the affected emission unit will be
operated, but not later than 180 days after initial startup, visible emissions from each screening operation
and each conveyor transfer point shall be no greater than 7 percent opacity from all affected emission
units constructed, modified, or reconstructed on or after April 22, 2008. [Origin: DAQE-AN103130047-
24, 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b), R307-401-8]
II.B.34.a.1 Monitoring:

The permittee shall conduct an initial performance test using 40 CFR 60, Appendix A, Method 9,
and the procedures in 40 CFR 60.11, with the additions specified in 40 CFR 60.675(c)(1). The
duration of the Method 9 observations shall be 30 minutes (five 6-minute averages). Compliance
122
shall be based on the average of the five 6-minute averages. Alternately, to satisfy this
requirement, the permittee may survey a group of affected units visible from a pre-determined
observation location (E) within a 15-second interval if the following conditions are met:
(i) No more than three emission points shall be read concurrently.
(ii) All three emission points shall be within a 70 degree viewing sector or angle in front of the
observer such that the proper sun position can be maintained for all three points.
(iii) If an opacity reading for any one of the three emission points equals or exceeds the
applicable standard, then the observer shall stop taking readings for the other two points and
continue reading just that single point.

Before the initial Method 9 performance test, the permittee shall provide a 7-day advance
notification to the Director of the anticipated date for conducting the opacity observations.

Repeat performance tests shall be conducted according to 40 CFR 60.675 every 5 years from the
previous performance test.

II.B.34.a.2 Recordkeeping:

Records documenting the results of monitoring shall be kept in accordance with Provision I.S.1
of this permit.

II.B.34.a.3 Reporting:

Notification of the actual date of initial startup of each affected emission unit shall be submitted
in accordance with 40 CFR 60.676(i). Reports shall be submitted in accordance with 40 CFR
60.676(f) and as specified in Section I of this permit.

Status: In Compliance. An initial Notification of Compliance Status was received April 1, 2022, and
included results of 30-minute minimum opacity tests. Next test is due in 2027.

II.B.35 Conditions on LFP Engines

II.B.35.a Condition:

Visible emissions shall not exceed 20 percent opacity. [Origin: DAQE-AN103130047-24]. [R307-401-8]

II.B.35.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis
while the unit is operating. The visual opacity survey shall be performed 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 visible emissions are observed from an
emission unit, an opacity determination of that emission unit shall be performed by a certified
observer within 24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9.

II.B.35.a.2 Recordkeeping:
The permittee shall maintain a log of the visual opacity surveys, opacity determinations, and all
data required by 40 CFR 60, Appendix A, Method 9. Records shall be maintained in accordance
with Provision I.S.1 of this permit.

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II.B.35.a.3 Reporting:

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

Status: In Compliance. Visual emission observations have been performed and recorded at least monthly.
Records were inspected onsite and no exceedances of the 20% opacity limit were discovered.
Readings are taken by certified observers.

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

Not applicable to this source.

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

Alternate Operating Scenario (AOS) for Synthetic Minor Operations for HAPs:
If the permittee chooses to comply with the following AOS requirements, the source shall be reclassified
to an area source of HAPs, as defined in 40 CFR 63.2, effective on the date AOS operations commence.
As noted in Section II.B of this permit, once reclassified, the requirements of 40 CFR 63 Subpart
AAAAA shall no longer apply.

Effective on the date AOS operations commence, the limits of the AOS shall apply permanently and a
modification to the referenced approval order shall be required for the permittee to remove or modify
these limits. All other requirements in this permit, except as specifically noted in Section II.B, shall
continue to apply in addition to the AOS limits listed in this section.
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.D.1 AOS Conditions.

II.D.1.a Condition:

The permittee shall notify the Director at least 30 days prior to the effective date on which AOS
operations will commence. The notification shall include test results for HCl and total organic HAPs that
demonstrate the source meets the definition of area source given in 40 CFR 63.2.
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.D.1.a.1 Monitoring:

Methods for measuring HCl and total HAPs shall be those specified in 40 CFR 63.7142, or other
EPA-approved methods, as acceptable to the Director. Records required for this permit condition
will also serve as monitoring.

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II.D.1.a.2 Recordkeeping:

The notification shall include:
(a) Documentation of the testing that includes the test results for HCl and total organic HAPs
that demonstrate the source meets the definition of area source given in 40 CFR 63.2 and the
methods used for measuring HCl and total HAPs as specified in 40 CFR 63.7142, or other
EPA-approved methods, as acceptable to the Director.
(b) The date when AOS operations will commence and the AOS conditions limiting HAPs
emissions become effective.
(c) The proposed schedule for CEMS installation.

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

II.D.1.a.3 Reporting:

The permittee shall submit the notification at least 30 days prior to the effective date on which
AOS operations will commence. There are no additional reporting requirements except as
outlined in Section I of this permit.

Status: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS.

II.D.1.b Condition:

Facility-wide emissions shall be limited to:
i. 9.5 tons of HCl per 12-month block period, and
ii. 24 tons of total HAPs per 12-month block period.
Total HAPs emissions shall include the following compounds:
(a) Organic HAPs: acetaldehyde benzene, chlorine, ethylbenzene, formaldehyde, hexane, toluene,
and xylenes
(b) Metal HAPs: arsenic, cadmium, chromium compounds, cobalt, lead, manganese, mercury,
nickel, and selenium
(c) HCl
[Origin: DAQE-AN103130047-24]. [R307-401-8]

II.D.1.b.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system(s) for the continuous measurement of HCl emissions on Kilns
#1-#5. The CEMS(s) shall be installed and used as the primary method of compliance within
180 days from the date AOS operation commences. At a minimum, the HCl CEMS shall
consist of HCl concentration monitor(s) for each kiln, flow monitors, and a data acquisition
system capable of recording measurements from Kilns #1-#5.
(b) Except as specified in paragraph (d), the permittee shall demonstrate compliance with the
HCl emission limit using CEMS data as outlined in paragraph (c). The HCl CEMS shall
operate during all periods the kilns are in operation.
(c) When the HCl CEMS have been installed, calibrated, and are operating, HCl emissions shall
be calculated as follows for each kiln:
(1) Hourly HCl emissions (Eh) shall be calculated using CEMS data as follows:

Eh = K * C * Q
125
Where:
Eh = hourly HCl mass emission rate during unit operation, lb/hr
K = 9.46E-8 for HCl, lb/scf/ppm
C = HCl concentration averaged for each one-hour period, ppmvw, as measured
by the CEMS
Q = volumetric flow rate averaged for each one-hour period, scfh (wet)

(2) The daily HCl emissions (Ed) in pounds shall be calculated by summing the hourly HCl
emissions (Eh) measured during the day. For purposes of this subsection, a "day" is
defined as a period of 24-hours commencing at midnight and ending the following
midnight.
(3) Measured monthly HCl emissions shall be calculated by summing the daily emissions
for all operating days in each month.
(d) If the CEMS are not in operation when AOS operations commence, compliance with the
HCl emission limit shall be demonstrated as follows for the first 180 days of operation under
the AOS:
(1) Emissions shall be estimated by multiplying the lime throughput (tons/month) for each
kiln by HCl emission factors.
(2) The following emission factors shall be used:
a) 1.67E-1 lbs HCl/ton of lime for the dolomitic lime line
b) 1.26E-1 lbs HCl/ton of lime for the high calcium line
(e) To demonstrate compliance with the 12-month block period, the permittee shall calculate a
monthly total by the 25th day of each month using data from the previous month. The
monthly totals shall be added to determine HCl and total HAPs emissions for the current 12-
month block. The 12-month block period starts on the day AOS operations commence. A
new 12-month block period will begin each year on the date AOS operations commenced.
(f) The permittee shall demonstrate compliance with the total HAPs limit using the following
data:
(1) HCl CEMS data, as per paragraph (b).
(2) Emission rates in lbs/hr measured in the most recent stack test for organic HAPs and
metal HAPs. Stack testing requirements are specified in paragraph (g).
(3) Monthly hours of operations.
(g) Stack testing of organic and metal HAPs shall be performed on each kiln as specified below:
(1) Frequency. Initial compliance testing shall be performed as soon as possible and in no
case later than 180 days after the date AOS operation commences. After the initial
compliance testing, emissions shall be tested every three years. Tests may also be
required at the direction of the Director.
(2) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place of testing and submit a copy of the test protocol. The source test
protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. The source test protocol shall be approved by the Director prior
to performing the test(s). A pretest conference shall be held, if directed by the Director.
(3) Methods.
a) Sample Location - the emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing
method, as acceptable to the Director. Occupational Safety and Health
Administration (OSHA) or Mine Safety and Health Administration (MSHA)
approved access shall be provided to the test location.
b) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine the volumetric flow rate.
126
c) Organic HAPs - 40 CFR 60, Appendix A, Method 320 and Method 18, or other
EPA-approved testing method, as acceptable to the Director.
d) Chlorine - 40 CFR 60, Appendix A, Method 26A, or other EPA-approved testing
method, as acceptable to the Director.
e) Metal HAPs - 40 CFR 60, Appendix A, Method 29, or other EPA-approved testing
method, as acceptable to the Director.
(4) 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.
(5) Production Rate During Testing. Tests shall be conducted at a production rate of no less
than 90% of the maximum production achieved in the previous three (3) years.
(h) The permittee shall follow the data replacement procedure below when the HCl CEMS data
are not valid or unavailable due to monitor downtime or because the monitor is out of
control, as determined by 40 CFR 60 Appendix F, Procedure 1 and/or 6:

Ema = Em * (1 +(1/DA - 1) * C

Where:
Ema = adjusted monthly HCl emissions, lbs
Em = total unadjusted HCl mass emission for the month, prior to data replacement
procedure, lb/hr
DA = data availability, fraction of operating time for which monitor data is available
during the reporting period (e.g. 95% data availability = 0.95) and,
C = Conservative Factor = 1.05 = 5% increase

(i) The monitoring system shall operate continuously and shall comply with all applicable
sections of R307-170, UAC, 40 CFR 60 Subpart A and Appendix B, and either Performance
Specification (PS) PS-18 or PS-15 as applicable and as approved by the Director.
(j) The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
(1) Except for system breakdown, repairs, calibration checks, and zero and span
adjustments required under 40 CFR 60.13(d), 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(e) and R307-170, UAC. Flow
measurement shall be in accordance with the requirements of 40 CFR 52; Appendix E,
40 CFR 60 Appendix B; or 40 CFR 75, Appendix A.
(2) Initial performance specification test shall be performed within 60 days of installation.
The performance specification test shall be conducted in accordance with the
procedures contained in 40 CFR 60, Appendix B, PS-15 or 18. The Director shall be
notified prior to conducting the performance specification test.
(3) At no time shall the permittee allow excess gaseous emissions to be emitted to the
atmosphere, except as provided by the provisions of R307-107(Breakdowns), UAC.

II.D.1.b.2 Recordkeeping:

In addition to the recordkeeping requirements specified in Provision I.S.1 of this permit, the
permittee shall keep the following records:
(a) Records of HCl CEMS data and all calculated emissions shall be tabulated for each day. A
monthly total of HCl emissions shall be recorded each month.
127
(b) If the CEMS are not in operation during the first 180 days of AOS operation, the permittee
shall record the calculated HCl emissions estimated using the emission factors in
II.D.1.b.1(d). Documentation of all calculations, including the monthly lime throughput, and
the monthly total of HCl emissions shall be recorded each month.
(c) Results of all stack testing shall be recorded and maintained in accordance with the
associated test method.
(d) Hours of operation shall be recorded on a daily basis for all periods of operation.
(e) Documentation of all calculations used to demonstrate compliance with the total HAPs limit
shall be recorded each month.
(f) The permittee shall record the output of the system for measuring HCl emissions in addition
to the records specified in R307-170-8.
(g) By the 25th day of each month, using data from the previous month, the permittee shall
record the cumulative monthly totals of HCl and total HAPs emissions calculated for the
current 12-month block.

Results of monitoring and all records used to demonstrate compliance with this condition shall be
maintained in accordance with R307-170 and Provision I.S.1 of this permit.
II.D.1.b.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit:
(a) The results of stack testing shall be submitted to the Director within 60 days of completion
of the testing.
(b) The permittee shall submit quarterly reports in accordance with the reporting provisions in
R307-170-9. All exceedances shall be reported in the quarterly report with explanations and
corrective actions, in accordance with R307-170. The reports shall also include:
(1) Total HCl emissions for the current 12-month block, and
(2) Total HAPs emissions for the current 12-month block.

The quarterly reports 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: Not applicable at this time. The permittee is in the exploratory phase of operating under the AOS.

EMISSION INVENTORY: Taken from DAQ’s 2022 emissions inventory database: 2023 report is
under review and unavaible.

128

PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

COMPLIANCE STATUS &
RECOMMENDATION: Graymont should be found in compliance with the Title V permit
conditions evaluated at the time of this inspection.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: None

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual

ATTACHMENT: VEO form