DAQ-2024-012011

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DAQC-1203-24
Site ID 10007 (B1)

MEMORANDUM

TO: FILE – HOLCIM (US) INC. – Devil’s Slide Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: November 18, 2024

SUBJECT: FULL COMPLIANCE EVALUATION (FCE), Major, Morgan County,
FRS #UT0000004902900001

INSPECTION DATE: November 15, 2024 – Additional records were received on
November 19 and 26, 2024.

SOURCE LOCATION: Devil’s Slide Plant
6055 East Croydon Road
Morgan, UT 84050

Take the Croydon Road (Exit 111) and follow the road around to
the plant (approximately 1 mile).

MAILING ADDRESS: Devil’s Slide Plant
6055 East Croydon Road
Morgan, UT 84050

Corporate Office:
Holcim (US) Inc.
8700 West Bryn Mawr Avenue
Chicago, IL 60631

SOURCE CONTACTS: Javier Sosa Ortiz, Plant Manager
Mobile: [phone]
[e-mail]

Clinton Badger, Plant Environmental Manager
Mobile: [phone]
[e-mail]

Mark Miller, Regional Environmental Director
Mobile: [phone]
[e-mail]

Facility Number: 801-829-6821

OPERATING STATUS: Operating

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PROCESS
DESCRIPTION:

Holcim (US) Inc. operates the Devil's Slide Portland Cement manufacturing plant near Morgan, UT. This
plant has been in operation since 1907, with recent major modifications made to most of the process
during 1996 and 1997. At the Devil's Slide plant, cement is made when raw materials such as limestone
and sandstone (quarried on-site), iron ore, bottom ash, and clay are proportioned, ground, and mixed, and
then fed into an inline rotating kiln. The intense heat of the kiln alters the materials and recombines them
into small stones called cement clinker. The clinker is cooled and ground with gypsum into a fine
powdered cement. The final product is stored on site for later packaging and shipping. The major sources
of air emissions are the combustion of fuels for the kiln operation and from the kiln and clinker cooling
process. The Devil's Slide plant is a major source for emissions of PM10, SO2, NOx, CO, VOC, and
HAPs. This source is subject to 40 CFR 60 Subpart A- General Provisions, 40 CFR 60 Subpart Y-
Standards of Performance for Coal Preparation and Processing Plants, 40 CFR 60 Subpart OOO-
Standards of Performance for Nonmetallic Mineral Processing Plants, 40 CFR 63 Subpart A- General
Provisions, 40 CFR 63 Subpart LLL- National Emission Standards for Hazardous Air Pollutants from the
Portland Cement Manufacturing Industry, and 40 CFR 63 Subpart ZZZZ- National Emission Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.

APPLICABLE
REGULATIONS:
Title V Operating Permit # 2900001004, dated November 18,
2021, revised March 25, 2022.

40 CFR 60 Subpart A-General Provisions
40 CFR 60 Subpart Y-Standards of Performance for Coal
Preparation and Processing Plants
40 CFR 60 Subpart OOO-Standards of Performance for
Nonmetallic Mineral Processing Plants
40 CFR 63 Subpart A-General Provisions
40 CFR 63 Subpart LLL-National Emission Standards for
Hazardous Air Pollutants from the Portland Cement
Manufacturing Industry
40 CFR 60 Subpart JJJJ-Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines
40 CFR 60 Subpart IIII-Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines
40 CFR 63 Subpart ZZZZ-National Emission Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines.

SOURCE EVALUATION:

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: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies)
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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: This is a statement of fact and not an inspection item.

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]

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: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal

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

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

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

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 – The permit expires November 18, 2026. Application for renewal is due
May 18, 2026.

I.E Application Shield
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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: Application for permit renewal is due May 18, 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: This is a statement of fact and not an inspection item.

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 – The annual emission fee was paid on September 4, 2024, before the
due date of October 3, 2024.

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: This is a statement of fact and not an inspection item.

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: This is a statement of fact and not an inspection item.

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))
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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 – Required records were made available and no claims of confidentiality
were made at time of the inspection.

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 – Reports and certifications submitted, by the Devil’s Slide Plant,
appeared to have certification statements and were signed by responsible officials.

I.L Compliance Certification

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

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

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

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

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

Status: In Compliance – The most recent annual compliance certification (ACC) was emailed
to the DAQ, on July 30, 2024. A hard copy of the ACC was received on October 3, 2024.
A revised hard copy of the ACC was submitted on November 22, 2024. The initial hard
copy and the revised hard copy of the report are considered to have been received on
the same date as the initial emailed report, July 30, 2024. See the attached
correspondence, dated September 30, 2024, with the forwarded email dated July 30,
2024.

I.M Permit Shield

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

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

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

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

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

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: Not Applicable – See section III of this permit.

I.N Emergency Provision

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
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corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards, or other requirements in this
permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two working days of
the time when emission limitations were exceeded due to the emergency. This notice must
contain a description of the emergency, any steps taken to mitigate emissions, and corrective
actions taken. This notice fulfills the requirement of Provision I.S.2.c below.
(R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: In Compliance – No emergency events were reported since the last inspection, which
was conducted on November 8 and 27, 2023.

I.O Operational Flexibility

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

I.P Off-permit Changes

Off-permit changes are governed by R307-415-7d(2)

I.Q Administrative Permit Amendments

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

I.R Permit Modifications

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

Status: These are statements of fact and not inspection items. (I.O through I.R).

I.S Records and Reporting
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I.S.1 Records

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

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.

Status: In Compliance – Required records were provided at time of the inspection and after the
inspection.

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 most recent six-month monitoring reports were received by the
DAQ. The six-month monitoring reports for report periods July 1, 2023, through
December 31, 2023, and January 1, 2024, through June 30, 2024, were revised and
deemed acceptable. Deviation reports regarding the deviations that occurred in the
January 1, 2024, through June 30, 2024, report period were eventually submitted after
the source received numerous Notice of Violations (NOVs). See Previous Enforcement
Actions below.

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: This is a statement of fact and not an inspection item.

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 – The 2023 triannual emission inventory was submitted on April 15,
2024, and resubmitted on July 30, 2024, upon request. The 2026 triannual emission
inventory will be due by April 15, 2027. See the SLEIS database.

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: This is a statement of fact and not an inspection item.

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 GEN: Emergency Generators

Two diesel-powered emergency backup generators, approximately 755 HP and 166 HP.
The 166 HP unit is subject to 40 CFR 63 Subpart ZZZZ requirements.

II.A.3 Quarry: Quarry Operations & Stockpiles

Drilling operations, rock blasting, truck loading, rock fall from dozer push, haul roads,
limestone & sand storage piles and Cement Kiln Dust (CKD) storage pile. The drill rig is
equipped with a baghouse.

II.A.4 Crusher: Impact Crusher & Conveying Operations

Dump pocket/feeder (#211-AF1), impact crusher, conveyors and associated transfer
points, with emissions controlled by baghouses (#291-BFx) or enclosures.
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II.A.5 MSA: Preblending Hall

Limestone & sandstone are pre-blended in an enclosed blending hall. No unit-specific
applicable requirements.

II.A.6 Coal: Coal Milling, Processing & Conveying

Equipment for the handling, conveying, storage and milling of coal. Emissions are
controlled by baghouses: HAC #L61-BF1 (mill discharge) and #L91-BF1 (bin vent).
Equipment does not include conveying system used to convey coal from the mill to the
kiln.

II.A.7 Raw Meal Prep: Raw Meal Preparation System

Equipment used in preparation of kiln feed (raw meal), including material transfer points,
conveyors, bag filters, bins. (HAC #31x-xxx to 39x-xxx excluding #361-RM1)

II.A.8 Clinker: Clinker Manufacture System – MHO

Equipment for the calcination of raw material, including material transfer points,
conveyors, bag filters, bins (HAC #411-xxx, 431-xxx, 4A1-xxx except 4A1-BFx).

II.A.9 Coal: Coal Transfer Equipment

Equipment in the clinker manufacturing system for transfers from coal mill to the kiln
(HAC #L91-xxx).

II.A.10 Kiln: In-Line Kiln/Raw Mill

Emissions from five-stage kiln system (HAC #441-xxx, 461-xxx) and raw mill (#361-
RM1) are controlled by main baghouse (#421-BF1). Alkali bypass emissions are
controlled by baghouse (#4A1-BF1). Both baghouses exit through the main stack.

II.A.11 Cooler: Clinker Cooler

Grate cooler (#417-GQ1) for cooling clinker, controlled by baghouse (#471-BF1).

II.A.12 Cooler Sys: Clinker Cooler System – MHO

Transfer equipment and dust control for clinker cooler system. (HAC #47x-xxx to 49x-xxx
excluding 471-BF1, 471-GQ1).

Equipment for grinding of clinker and additive addition, including material transfer points,
conveyors, bag filters, bins. (HAC #52x-xxx to 59x-xxx, K93-xxx & T93-xxx)

II.A.14 Packing: Packing & Distribution System

Equipment for shipping of cement products: conveyor transfer points, bins, bag filters and
other miscellaneous transfer points. (HAC #61x-xxx to 6Ex-xxx)

II.A.15 MHO: Material Handling Operations

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All raw material, clinker, or finished product storage bins, conveying system transfer
points including those associated with coal preparation used to convey coal from the mill
to the kiln, bagging systems, and bulk loading/unloading systems identified as affected
sources in 40 CFR 63.1340, Subpart LLL.

Status: In Compliance – No unapproved equipment was noted at time of the inspections. The
SNCR (Item II.A.10) has not been constructed to date. Finish Mill #4 (item II.A.13)
may be added in the future. See status of condition II.B.6.o.

II.B Requirements and Limitations

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

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

II.B.1.a Condition:

For each affected emission unit subject to 40 CFR 63 Subpart LLL, the permittee shall
prepare a written operations and maintenance (O & M) plan in accordance with 40 CFR
63.1347(a). The plan shall include the following information:

(1) Procedures for proper operation and maintenance of the affected source and air
pollution control devices in order to meet the emission limits and operating limits
referenced in 40 CFR 63.1347(a)(1). The O&M plan shall address periods of
startup and shutdown.

(2) Corrective actions to be taken when required by 40 CFR 63.1350(f)(3).

(3) Procedures to be used during an inspection of the components of the combustion
system of the in-line kiln/raw mill at least once per year.

Failure to comply with any provision of the operations and maintenance plan is a violation
of the standard.

[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1347]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance
with 40 CFR 63.1355, Table 1 to 40 CFR 63 Subpart LLL-Applicability of General
Provisions, and Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

In addition to the requirements in Section I of this permit, one summary report shall be
submitted semiannually within 60 days of the reporting period for the hazardous air
pollutants monitored at each affected source. The summary report shall be entitled
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"Summary Report - Gaseous and Opacity Excess Emission and Continuous Monitoring
System Performance" and shall contain the following information:

(A) The company name and address of the affected source;

(B) An identification of each hazardous air pollutant monitored at the affected source;

(C) The beginning and ending dates of the reporting period;

(D) A brief description of the process units;

(E) The emission and operating parameter limitations specified in 40 CFR 63 Subpart
LLL;

(F) The monitoring equipment manufacturer(s) and model number(s);

(G) All exceedances of maximum control device inlet gas temperature limits specified
in 40 CFR 63.1346(a) and (b);

(H) Notification of any failure to calibrate thermocouples and other temperature
sensors as required under 40 CFR 63.1350(g)(1)(iii),

(I) Notification of any failure to maintain the activated carbon injection rate, and the
activated carbon injection carrier gas flow rate or pressure drop, as applicable, as
required under 40 CFR 63.1346(c)(2);

(J) Notification of failure to conduct any combustion system component inspections
conducted within the reporting period, as required under 40 CFR 63.1347(a)(3);

(K) Any and all failures to comply with any provision of the operation and
maintenance plan developed in accordance with 40 CFR 63.1347(a);

(L) The date of the latest continuous monitoring system (CMS) certification or audit;

(M) The total operating time of the affected source during the reporting period;

(N) An emission data summary (or similar summary if the permittee monitors control
system parameters), including the total duration of excess emissions during the
reporting period (recorded in minutes for opacity and hours for gases), the total
duration of excess emissions expressed as a percent of the total source operating
time during that reporting period, and a breakdown of the total duration of excess
emissions during the reporting period into those that are due to startup/shutdown,
control equipment problems, process problems, other known causes, and other
unknown causes;

(O) A CMS performance summary (or similar summary if the permittee monitors
control system parameters), including the total CMS downtime during the
reporting period (recorded in minutes for opacity and hours for gases), the total
duration of CMS downtime expressed as a percent of the total source operating
time during that reporting period, and a breakdown of the total CMS downtime
during the reporting period into periods that are due to monitoring equipment
malfunctions, non-monitoring equipment malfunctions, quality assurance/quality
control calibrations, other known causes, and other unknown causes;
14
(P) A description of any changes in CMS, processes, or controls since the last
reporting period;

(Q) The name, title, and signature of the responsible official who is certifying the
accuracy of the report; and

(R) The date of the report,

(S) As required by 40 CFR 63.10(e)(3), the permittee of an affected source equipped
with a continuous emission monitor shall submit an excess emissions and
continuous monitoring system performance report for any event when the
continuous monitoring system data indicate the source is not in compliance with
the applicable emission limitation or operating parameter limit. (40 CFR
63.1354(b)(8)).

(T) If the total continuous monitoring system downtime for any CEM or any
continuous monitoring system (CMS) for the reporting period is ten percent or
greater of the total operating time for the reporting period, the permittee shall
submit an excess emissions and continuous monitoring system performance report
along with the summary report. (40 CFR 63.1354(b)(10))

(U) For each failure to meet a standard or emissions limit caused by a malfunction at
an affected source, the permittee shall report the failure in the semi-annual
compliance report. The report shall contain the date, time and duration, and the
cause of each event (including unknown cause, if applicable), and a sum of the
number of events in the reporting period. The report shall list for each event the
affected source or equipment, an estimate of the amount of each regulated
pollutant emitted over the emission limit for which the source failed to meet a
standard, and a description of the method used to estimate the emissions. The
report shall also include a description of actions taken during a malfunction of an
affected source to minimize emissions in accordance with 40 CFR 63.1348(d),
including actions taken to correct a malfunction. (40 CFR 63.1354(c))

(V) For each PM CPMS, HCl, Hg, and THC CEMS, or Hg sorbent trap monitoring
system, within 60 days after the reporting periods, the permittee shall report all of
the calculated 30-operating day rolling average values derived from the CPMS,
CEMS, CMS, or Hg sorbent trap monitoring systems. (40 CFR 63.1354(b)(9)(vi)

(W) In response to each violation of an emissions standard or established operating
parameter limit, the date, duration and description of each violation and the
specific actions taken for each violation including inspections, corrective actions
and repeat performance tests and the results of those actions. (40 CFR
63.1354(b)(9)(vii))

(X) Within 60 days after the date of completing each performance evaluation or test,
as defined in 40 CFR 63.2, conducted to demonstrate compliance with any
standard covered by 40 CFR 63 Subpart LLL, the permittee shall submit the
relative accuracy test audit data and performance test data, except opacity data, to
the EPA by successfully submitting the data in accordance with 40 CFR
63.1354(b)(11)(i)(C).

(Y) For PM performance test reports used to set a PM CPMS operating limit, the
electronic submission of the test report shall also include the make and model of
15
the PM CPMS instrument, serial number of the instrument, analytical principle of
the instrument (e.g. beta attenuation), span of the instruments primary analytical
range, milliamp value equivalent to the instrument zero output, technique by
which this zero value was determined, and the average milliamp signals
corresponding to each PM compliance test run. (40 CFR 63.1354(b)(11)(ii))

The permittee shall submit all reports to the Director as well as a copy of each report to the
EPA as specified in 40 CFR 63.1354(b)(9) and (b)(12).
(origin: 40 CFR 63.10(e)(3), 40 CFR 63.1354(b)(8)-(12), 40 CFR 63.1354(c)).

Status: In Compliance – The source maintains their operation and maintenance plan (O&M)
Plan), dated March 2021. The Semiannual Excess Emission and CMS Performance
and Summary reports are submitted by February 28th and August 30th of every
year. The latest report, dated July 30, 2024, was received on October 3, 2024. The
next report is due by February 28, 2025.

II.B.1.b 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-AN100070027-20].
[40 CFR 60.11(d), R307-401-8]

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.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.b.3 Reporting:

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

Status: In Compliance – The Devil’s Slide Plant maintains and uses Standard Operating
Procedures (SOPs), the QAP Plan, and their O&M Plan to keep process and control
equipment in working order. The SAP database is used to track maintenance and to
produce work orders.

II.B.1.c Condition:

All paved/unpaved roads and other operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated and/or swept using a mobile sweeper to
control fugitive dust. The application of water or chemical treatment shall be used for
unpaved roads and unpaved operational areas. Treatment shall be of sufficient frequency
16
and quantity to maintain surface material in a damp/moist condition unless the temperature
is below freezing. The mobile sweeper shall operate as necessary to control visible fugitive
dust emissions from paved surfaces. [Origin: DAQE-AN100070027-20]. [R307-205-7,
R307-401-8]

II.B.1.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.c.2 Recordkeeping:

Instances of water and/or chemical treatment and/or mobile sweeping shall be recorded
and maintained by the permittee for all periods when the plant is in operation. The records
shall include the following items as applicable:

(a) Date and type of control, i.e., water spray, chemical treatment, mobile sweeping.

(b) Number of treatments made, dilution ratio, and quantity.

(c) Precipitation received, if any, and approximate amount.

(d) Time of day that treatments are made.

(e) Records of temperature if the temperature is below freezing.

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

II.B.1.c.3 Reporting:

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

Status: In Compliance – All on-site paved (plant) and unpaved (quarry) roads are watered
on an as needed basis. All on-site paved roads are swept on an as needed basis. No
chemicals such as Mag Chloride are used at the facility. Hard copy water records are
maintained and include the above information. There are two dedicated sweepers
and three dedicated water trucks on-site.

II.B.1.d 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.d.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.d.2 Recordkeeping:

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the
requirements of Provision I.S.1 of this permit.
17
II.B.1.d.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 – Holcim Devil’s Slide Plant certifies compliance with this condition
in their Annual Compliance Certification report. Mechanical Services & Systems,
Inc. (MSS) services all on-site air conditioners (A/Cs). This is done on an as needed
basis. Invoices are kept as record of the services conducted.

II.B.1.e 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.e.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.e.2 Recordkeeping:

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

II.B.1.e.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 – Holcim Devil’s Slide Plant certifies compliance with this condition
in their Annual Compliance Certification report. Mechanical Service & Systems, Inc.
(MSS) maintains the refrigerants for the small on-site HVAC units. This includes the
recycling and emission reduction of the refrigerants. Invoices are kept as record of
the services conducted.

II.B.1.f Condition:

The permittee shall install and operate baghouse dust collectors at all conveyor transfer
points at the following affected emission units: Crusher: Impact Crusher & Conveying
Operations, Coal: Coal Milling, Processing & Conveying, and Raw Meal Prep: Raw Meal
Preparation System. The collectors shall operate whenever dry conditions warrant or as
determined necessary by the Director. [Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.1.f.1 Monitoring:

Visual inspections shall be made monthly to demonstrate compliance with this condition.

II.B.1.f.2 Recordkeeping:

18
A log of the visual inspections shall be kept, including the date and time of each inspection
and the name of the person making the inspection. Records demonstrating compliance
with this condition 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 – All conveyor transfer points, regarding the above-mentioned
emission units, are vented to a baghouse. Monthly visual inspections are tracked in
the Parsable database.

II.B.1.g Condition:

Mining operations and transporting of materials from the mine to the plant shall be limited
to between 5:00 a.m. and 8:00 p.m. each day. [Origin: DAQE-AN100070027-20].
[R307-401-8]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

Mining and transporting operations shall be determined by maintenance of a supervisor
log or equivalent. Records shall be kept in the log when mining operations and
transporting of materials from the mine to the plant occur outside of the schedule listed
above. Records 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 – The quarry operates Monday through Wednesday at 5:30 AM –
6:30 PM and Thursday through Sunday at 5:30 AM – 3:30 PM. Hours of operation
are tracked by hours of equipment use.

II.B.1.h Condition:

All PM10 stack emission releases shall be vented vertically without any restriction to
upward momentum at or beyond the stack opening. [Origin: DAQE-AN100070027-20].
[R307-401-8]

II.B.1.h.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.h.2 Recordkeeping:

19
Records shall be kept of each PM10 stack that does not meet the venting requirements in
the above condition. Records shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.1.h.3 Reporting:

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

Status: In Compliance – All required vents have been installed in all of the stacks, plant
wide.

II.B.1.i Condition:

Visible emissions from abrasive blasting operations shall not exceed 40% opacity, except
for an aggregate period of three minutes in any one hour. [Origin: R307-206].
[R307-206-4]

II.B.1.i.1 Monitoring:

(a) Visible emissions shall be measured at least once during each semi-annual period the unit operates 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 emission and performance standards provided in R307-206-2 through 4.

(d) Visible emissions from confined blasting shall be measured at the densest point after the air pollutant leaves the enclosure.

II.B.1.i.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.i.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit.

Status:

In Compliance – Sand blasting operations are contracted out to Hunt Electric.
These operations are used to remove material build up from two substations and
three transformers.

II.B.2 Conditions on GEN: Emergency Generators.

II.B.2.a Condition:
20
For the 755 HP generator:

The emergency engine shall not operate on site for more than 100 hours per calendar year
for maintenance checks and readiness testing. The engine may be operated for up to 50
hours per calendar year in non-emergency situations. Any operation in non-emergency
situations shall be counted as part of the 100 hours per calendar year for maintenance and
testing. There is no time limit on the use of the engine during emergencies. [Origin:
DAQE-AN100070027-20]. [R307-401-8]

II.B.2.a.1 Monitoring:

To determine the duration of operation, the permittee shall install a non-resettable hour
meter for the emergency engine. Records required for this permit condition will also serve
as monitoring.

II.B.2.a.2 Recordkeeping:

To demonstrate compliance with the annual operation limitation, records documenting the
operation of the emergency engine shall be kept in a log and shall include the following:

i. The date the emergency engine was used

ii. The duration of operation in hours

iii. The reason for the emergency engine usage

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

II.B.2.a.3 Reporting:

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

Status: In Compliance – According to the source, the 755 horsepower (hp) emergency
generator has not been used, in the event of an emergency, for years. The generator is
tested monthly for five to ten minutes. Preventative maintenance (PM) is conducted
annually by Wheeler Cat. The last annual PM maintenance inspection was conducted
on March 4, 2024. Records are maintained and hours of generator operation
(emergency, testing, and maintenance) are recorded electronically.

II.B.2.b Condition:

For both the 755 HP and the 166 HP generators:
Visible emissions shall be no greater than 10 percent opacity.
[Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.2.b.1 Monitoring:

During any period that the emergency generator(s) is(are) operated for longer than 12
hours consecutively, visual observation(s) of each generator exhaust shall be made 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 any visible emissions are observed, then a 6-minute opacity determination
21
shall be performed while the unit is operating in accordance with 40 CFR 60, Appendix A,
Method 9 by a certified visual emissions observer. If the generator(s) continue to operate
on consecutive days following the initial observation, an opacity determination shall be
performed on a daily basis.

II.B.2.b.2 Recordkeeping:

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

II.B.2.b.3 Reporting:

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

Status: Not Applicable – According to the Devil’s Slide Plant, the 166 hp and 755 hp
emergency generators have not been used, in the event of an emergency, for years.
The generators are tested monthly for five to ten minutes. Therefore, the generators
have not operated for longer than 12 maintenance hours for the last several years.
Preventative maintenance (PM) is conducted annually by Wheeler Cat. The last
annual PM inspections, for both generators, was conducted on March 4, 2024. See
status of condition II.B.2.a.

II.B.2.c Condition:

For the 166 HP emergency generator:

The permittee shall comply with the following requirements at all times:

1. The permittee shall operate the emergency affected emission unit according to the
requirements in paragraphs 1.a through 1.c. In order for the engine to be
considered an emergency stationary RICE under 40 CFR 63 Subpart ZZZZ, any
operation other than as described in 40 CFR 63.6640(f) is prohibited. If the engine
is not operated according to the requirements in 40 CFR 63.6640(f), it will not be
considered an emergency engine and shall meet all requirements for non-
emergency engines

a. There is no time limit on the use of emergency stationary RICE in emergency
situations

b. Emergency stationary RICE may be operated for any combination of the
purposes specified in 40 CFR 63.6640(f)(2) for a maximum of 100 hours per
calendar year. Any operation for non-emergency situations as allowed by
paragraph 1.c counts as part of the 100 hours per calendar year allowed by this
paragraph.

(i) Emergency stationary RICE may be operated for maintenance
checks and readiness testing, provided that the tests are
22
recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or
equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. A petition for
approval of additional hours to be used for maintenance checks and
readiness testing is not required if the permittee maintains records
indicating that federal, state, or local standards require maintenance
and testing of emergency RICE beyond 100 hours per calendar year

c. The permittee may operate the affected emission unit up to 50 hours per
calendar year in non-emergency situations as specified in 40 CFR
63.6640(f)(3).

2. The permittee shall meet the following requirements at all times, except during
periods of startup.

a. Change oil and filter every 500 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

3. 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.

[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6602, 40 CFR 63.6605(a), 40 CFR
63.6625(h), 40 CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2c, 40
CFR 63 Subpart ZZZZ Table 8]

II.B.2.c.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40
CFR 63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut
down the engine in order to perform the work practice requirements on the required
schedule, or if performing the work practice on the required schedule would otherwise
pose an unacceptable risk under federal, state, or local law, the work practice can be
delayed until the emergency is over or the unacceptable risk under federal, state, or local
law has abated. The work practice shall be performed as soon as practicable after the
emergency has ended or the unacceptable risk under federal, state, or local law has abated.
[40 CFR 63 Subpart ZZZZ Table 2c Footnote 1]

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
23
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.2.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)]

For each affected emission unit that does not meet the standards applicable to non-
emergency engines, the permittee shall keep the records required in 40 CFR 63.6655(f).

If additional hours are to be used for maintenance checks and readiness testing, the
permittee shall maintain records indicating that federal, state, or local standards require
maintenance and testing of emergency RICE beyond 100 hours per calendar year.
[40 CFR 63.6640(f)]

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.2.c.3 Reporting:

The permittee shall report any failure to perform the work practice on the schedule
required and the federal, state or local law under which the risk was deemed unacceptable.
[40 CFR 63 Subpart ZZZZ Table 2c Footnote 1]

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)]

24
There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In Compliance – According to the source, the 166 hp emergency generator has not
been used, in the event of an emergency, for years. The generator is tested monthly
for five to ten minutes. Preventative maintenance (PM) is conducted annually by
Wheeler Cat. The last annual PM inspection was conducted on March 4, 2024.
Maintenance records are maintained and hours of generator operation (emergency,
testing, and maintenance) are recorded electronically. See status of condition II.B.2.b.

II.B.2.d Condition:

For the 166 HP emergency generator:

At all times the permittee shall operate and maintain the 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.
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 63.6605(b)]

II.B.2.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.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 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.2.d.3 Reporting:

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

Status: In Compliance – According to the source, the 166 hp emergency generator has not
been used, in the event of an emergency, for years. The generator is tested monthly
for five to ten minutes. Preventative maintenance (PM) is conducted annually by
Wheeler Cat. Maintenance records are maintained and hours of generator operation
(emergency, testing, and maintenance) are recorded electronically. See status of
condition II.B.2.c.

II.B.2.e Condition:

For both the 755 HP and the 166 HP generators:
The permittee shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the emergency generators. All diesel fuel combusted in the emergency engines shall
25
meet the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15
ppm or less. [Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.2.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.e.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.

II.B.2.e.3 Reporting:

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

Status: In Compliance – According to the Rhinehart Oil Co., LLC invoice, Ultra Low Sulfur
Diesel #2 (ULSD) was delivered to the plant on October 29, 2024. The diesel is used
plant wide including in the 166 hp and 755 hp generators. See attached fuel invoice.

II.B.3 Conditions on Quarry: Quarry Operations & Stockpiles.

II.B.3.a Condition:

Visible fugitive dust emissions shall be no greater than 20 percent opacity from haul road
traffic and mobile equipment in operational areas. [Origin: DAQE-AN100070027-20].
[R307-205, R307-401-8]
II.B.3.a.1 Monitoring: An opacity survey of haul road traffic and mobile equipment in operational areas shall be performed on a monthly basis in accordance with procedures similar to 40 CFR 60, Appendix A, Method 9. The opacity determination shall be performed as follows: The requirement for observations to be made at 15-second intervals over a six-minute period shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than half the vehicle length behind the vehicle and not less than half the height of the vehicle.
II.B.3.a.2 Recordkeeping:

Results of opacity observations shall be recorded and maintained as described in Provision
I.S.1 of this permit.

II.B.3.a.3 Reporting:

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

Status: In Compliance – Monthly Visible Emission Observations (VEOs) of quarry haul
roads and operational areas have been conducted accordingly. Review of the hard
26
copy VEO records indicated that there was no exceedance of the 20% opacity limit
since the last inspection. Records are archived for at least five years.

II.B.3.b Condition:

Visible emissions shall be no greater than 20 percent opacity from stockpiles. [Origin:
DAQE-AN100070027-20]. [R307-205, R307-401-8]

II.B.3.b.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly
basis 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 for point sources, and in
accordance with 40 CFR 51, Appendix M, Method 203A for fugitive sources.

II.B.3.b.2 Recordkeeping:

The permittee shall record the date of each visual opacity survey and a list of the emission
points checked during the visual opacity survey. The permittee shall maintain all records
required by this provision and all data required by 40 CFR 60, Appendix A, Method 9 or
by 40 CFR 51, Appendix M, Method 203A in accordance with Provision I.S.1 of this
permit.

II.B.3.b.3 Reporting:

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

Status: In Compliance – Monthly VEOs of the sand, clay, and lime stockpiles have been
performed accordingly. Review of the hard copy VEO records indicated that there
was no exceedance of the 20% opacity limit since the last inspection. Records are
archived for at least five years.

II.B.3.c Condition:

Visible emissions shall be no greater than 10 percent opacity from the drill rig baghouse.
[Origin: DAQE-AN100070027-20]. [R307-205, R307-401-8]

II.B.3.c.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly
basis while the unit is operating by an individual trained on the observation procedures of
40 CFR 60, Appendix A, Method 9. If visible emissions other than steam 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 while the unit is operating in accordance with 40 CFR 60, Appendix A,
Method 9.

II.B.3.c.2 Recordkeeping:

27
The permittee shall record the date of each visual opacity survey and a list of the emission
points checked during the visual opacity survey. The permittee shall maintain all records
required by this provision and all data required by 40 CFR 60, Appendix A, Method 9 in
accordance with Provision I.S.1 of this permit.

II.B.3.c.3 Reporting:

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

Status: In Compliance – Monthly VEOs of the drill rig baghouse have been performed
accordingly. Review of the hard copy VEO records indicated that there was no
exceedance of the 10% opacity limit since the last inspection. Records are archived
for at least five years.

II.B.4 Conditions on Crusher: Impact Crusher & Conveying Operations.

II.B.4.a Condition:

Visible emissions shall be no greater than 15 percent opacity from the crusher. [Origin: 40
CFR 60 Subpart OOO, DAQE-AN100070027-20]. [40 CFR 60.672(b), R307-401-8]

II.B.4.a.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis 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 for point sources, and in accordance with 40 CFR 51, Appendix M, Method 203A for fugitive sources.
II.B.4.a.2 Recordkeeping:

The permittee shall record the date of each visual opacity survey and a list of the emission
points checked during the visual opacity survey. The permittee shall maintain all records
required by this provision and all data required by 40 CFR 60, Appendix A, Method 9 or
by 40 CFR 51, Appendix M, Method 203A in accordance with Provision I.S.1 of this
permit.

II.B.4.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 – Monthly VEOs of the crusher have been performed accordingly.
Review of the electronic VEO records indicated that there was no exceedance of the
15% opacity limit since the last inspection. Records are archived for at least five
years.

II.B.4.b Condition:

Visible emissions shall be no greater than 7 percent opacity from baghouse stacks.
[Origin: 40 CFR 60 Subpart OOO]. [40 CFR 60.672(a)]
28
II.B.4.b.1 Monitoring: A visual opacity survey of each affected emission unit shall be performed on a monthly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other than steam 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.4.b.2 Recordkeeping:

The permittee shall record the date of each visual opacity survey and a list of the emission
points checked during the visual opacity survey. The permittee shall maintain all records
required by this provision and all data required by 40 CFR 60, Appendix A, Method 9 in
accordance with Provision I.S.1 of this permit.

II.B.4.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 – Monthly VEOs of the crusher baghouse stacks have been performed
accordingly. Review of the hard copy VEO records indicated that there was no
exceedance of the 7% opacity limit since the last inspection. Records are archived for
at least five years.

II.B.4.c Condition: Permittee shall install water sprays to control fugitive emissions in the crusher dump pocket. The sprays shall operate whenever dry conditions warrant or as determined necessary by the Director. Sprays shall not be required to operate during periods of freezing temperatures. [Origin: DAQE-AN100070027-20]. [R307-401-8]
II.B.4.c.1 Monitoring:

Visual inspections shall be made monthly to demonstrate compliance with this condition.

II.B.4.c.2 Recordkeeping:

A log of the visual inspections shall be maintained in accordance with Provision I.S.1 of
this permit, including the date and time of each inspection and the name of the person
making the inspection.

II.B.4.c.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit.

Status:

In Compliance – Water sprays have been installed in the crusher dumb pocket.
Records indicate that the sprays are inspected daily. They are also maintained in
accordance with the facility’s O&M Plan and Subpart OOO.

II.B.4.d Condition:

29
Visible emissions shall be no greater than 10 percent opacity for fugitive emissions from
transfer points on belt conveyors or any other Subpart OOO affected facility.
[40 CFR 60 Subpart OOO]. [40 CFR 60.672(b)]

II.B.4.d.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly
basis 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 for point sources, and in
accordance with 40 CFR 51, Appendix M, Method 203A for fugitive sources.

II.B.4.d.2 Recordkeeping:

The permittee shall record the date of each visual opacity survey and a list of the emission
points checked during the visual opacity survey. The permittee shall maintain all records
required by this provision and all data required by 40 CFR 60, Appendix A, Method 9 or
by 40 CFR 51, Appendix M, Method 203A in accordance with Provision I.S.1 of this
permit.

II.B.4.d.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 – Monthly VEOs of the conveyor transfer points have been conducted
accordingly. Review of the hard copy VEO records indicated that there was no
exceedance of the 10% opacity limit since the last inspection. Records are archived
for at least five years.

II.B.4.e Condition:

Emissions of particulate matter (PM) shall be no greater than 0.05 g/dscm (0.022 gr/dscf)
from the baghouse stacks. [Origin: 40 CFR 60 Subpart OOO]. [40 CFR 60.672(a)]

II.B.4.e.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested at least once every five years, based on the
date of the last test. 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 provide 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
30
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, or other
EPA-approved testing method, as acceptable to the Director, 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.

II.B.4.e.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.

II.B.4.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. Reports shall be submitted in accordance with 40 CFR
60.676(f) and as specified in Section I of this permit.

Status: In Compliance – The latest stack tests were conducted by Mostardi Platt on July 18,
2023, and July 21, 2023. The report was received, by the DAQ, on January 18, 2024.
The stack test is conducted every five years.

Stack Test Summary:
Baghouse Stacks PM10 Limit (gr/dscf) PM10 Results (gr/dscf)
Primary Crusher
Baghouse (7/18/2023)
0.022 0.0001
Transfer Baghouse
(7/21/2023)
0.022 0.0004

II.B.5 Conditions on Coal: Coal Milling, Processing & Conveying.

II.B.5.a Condition:

Visible emissions shall be less than 20 percent opacity. [Origin: 40 CFR 60 Subpart Y,
DAQE-AN100070027-20]. [40 CFR 60.254(a), R307-401-8]

II.B.5.a.1 Monitoring:

31
A visual opacity survey of each affected emission unit shall be performed on a monthly
basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. If visible emissions other than steam 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.5.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.5.a.3 Reporting:

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

Status: In Compliance – Monthly observations of the coal operations have been performed
accordingly. Review of the electronic observation records indicated that there was no
exceedance of the 20% opacity limit since the last inspection. Records are archived
for at least five years.

II.B.6 Conditions on Kiln: In-Line Kiln/Raw Mill

II.B.6.a Condition:

The sulfur content of any coal or mixture of coals burned in the kiln shall not exceed 1.0 lb
sulfur per MMBTU of heat input. The sulfur content of any fuel oil burned in the kiln shall
not exceed 0.85 lbs sulfur per million gross BTU heat input.
[Origin: DAQE-AN100070027-20, R307-203-1]. [R307-203-1, R307-401-8]

II.B.6.a.1 Monitoring:

Certification of fuels shall be either by permittee's testing or test reports from the fuel
marketer. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials (ASTM), UAC R307-203-
1(4).

(a) For determining sulfur content in coal, D4239-2018 is to be used

(b) For determining sulfur content in oil, ASTM Method D2880-71 or D4294-89 is to
be used.

(c) For determining the gross calorific (or Btu) content of coal, ASTM Method
D5865/D5865M is to be used.

If these methods are superseded, the approved method put forth by ASTM shall be used.

II.B.6.a.2 Recordkeeping:

Results from laboratory analysis or vendor certifications shall be maintained. Records of
fuel sulfur content shall be kept for all periods when the plant is in operation and shall be
32
made available to the director upon request. Records shall be maintained in accordance
with Provision I.S.1 of this permit.

II.B.6.a.3 Reporting:

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

Status: In Compliance – The Kemmerer Operations, LLC and SGS invoice / Lab Analysis,
dated October 11, 2024, indicated that low sulfur coal is delivered to the plant. Fuel
oil is not burned in the kiln and is not burned on-site.

II.B.6.b Condition:

At all times, emissions of SO2 from the kiln main stack shall not exceed 475 lbs/hr on a
rolling 24-hour average and 457 tons per rolling 12-month period.
[Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.6.b.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln main stack. The permittee shall record the output
of the system, which shall measure the SO2 emissions. The monitoring system shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B.
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 and Section UAC R307-170.

II.B.6.b.2 Recordkeeping:

The permittee shall record a new 12-month total by the 20th day of each month using data
from the previous 12 months. The permittee shall keep the records specified in R307-170-
8 and any additional records required by provision I.S.1 of this permit. Records shall be
maintained in accordance with Provision I.S.1.

II.B.6.b.3 Reporting:

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

Status: In Compliance – Continuous Emission Monitoring (CEM) allows for the real time
SO2 monitoring of the kiln main stack. The data is updated daily with the 12-month
rolling totals. The SO2 12-month rolling total was 45.0 short tons as of November 15,
2024. And 4.1 lb/hr on a rolling 24-hour average at time of the inspection. SO2
reports are submitted on a quarterly basis to the DAQ CEMs Specialist.

II.B.6.c Condition:

At all times, emissions of CO from the kiln main stack shall not exceed 438 lbs/hr.
[Origin: DAQE-AN100070027-20]. [R307-401-8]
33
II.B.6.c.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. The unit shall be tested within two years after the date of the most
recent stack test. The Director may require the permittee to perform a stack test at
any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of
the date, time, place of testing, and submit a source test protocol containing the
items in R307-165-3. The source shall obtain approval of the protocol from the
Director prior to conducting the test. The source shall attend a pretest conference
if determined necessary by the Director.

(c) Access. Occupational Safety and Health Administration (OSHA)- or Mine Safety
and Health Administration (MSHA)-approved access shall be provided to the test
location.

(d) Methods. 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing
method as acceptable to the Director, shall be used to determine CO emissions.

(e) Testing and Test Conditions. The permittee shall conduct testing according to the
approved source test protocol and according to the test conditions contained in
R307-165-4.

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 this permit.

II.B.6.c.3 Reporting:

Within 60 days of completion of the testing, the permittee shall submit a written report of
the results from the stack testing to the Director. The report shall include validated results
and supporting information, shall clearly identify test 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 – The latest bi annual stack test was conducted by Mostardi Platt on
July 18, 2024.

Stack CO Limits (lbs/hr) CO Results (lbs/hr)
Main Kiln Stack 438 200.0

II.B.6.d Condition:

At all times, emissions of NOx from the kiln main stack shall not exceed 1,817 tons per
rolling 12-month period. [Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.6.d.1 Monitoring:

The permittee shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln main stack. The permittee shall record the output
34
of the system, which shall measure the NOx emissions. The monitoring system shall
comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B.
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 and Section UAC R307-170.

II.B.6.d.2 Recordkeeping:

The permittee shall keep the records specified in R307-170-8 and any additional records
required by provision I.S.1 of this permit. These records shall be maintained in accordance
with Provision I.S.1.

II.B.6.d.3 Reporting:

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

Status: In Compliance – Continuous Emission Monitoring (CEM) allows for the real time
NOx monitoring of the kiln main stack. The data is updated daily with the 12-month
rolling totals. The NOx 12-month rolling total was 1,178 tons, as of November 15,
2024. NOx reports are submitted on a quarterly basis to the DAQ CEMs Specialist.

II.B.6.e Condition:

The permittee shall use only the following fuels in the kiln:

(1) Coal
(2) Diaper Derived Fuel (DDF)
(3) Tire Derived Fuel (TDF)
(4) Natural Gas
(5) Coke
(6) Fuel Oil
(7) Used Oil
(8) Synthetic Fuel
(9) Wood
(10) Any Non-Recyclable plastics, paper, and fibers from Municipal Solid Waste,
Commercial or Industrial Waste recycling centers; or as byproducts from
manufacturing facilities that meet the definition of Non-Hazardous Secondary
materials under 40 CFR part 241. Examples include but are not limited to
manufactured waste plastics, cellulose products, poly scrap and plastic films from
the recycling of paperboard materials
(11) Coal Additives consisting of alternative fuels approved by the Director. Prior to
burning any proposed coal additive, the permittee shall obtain approval from the
Director. To obtain approval, the permittee shall submit Safety Data Sheets (SDS)
or the results of suitable tests giving data on metals, organic compounds, heat
content, and all data as needed to determine emissions from the proposed coal
additive.

35
Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously approved coal additive to
another previously approved coal additive.

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

[Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.6.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.e.2 Recordkeeping:

Records of material used as fuel in the kiln shall be maintained. Copies of Director
approval of each coal additive shall be maintained. All records shall be maintained in
accordance with provision I.S.1 of this permit.

II.B.6.e.3 Reporting:

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

Status: In Compliance – The facility currently fuels the kiln with coal, DDF (plastics), TDF
(tires), natural gas, and wood. No coal additives are currently being used. Therefore,
an approval letter is not required. The kiln is initially fired with natural gas.

II.B.6.f Condition:

The concentration of contaminants or parameters in any used oil fuel shall not exceed the
following levels:

Arsenic 5 ppm by weight,
Cadmium 2 ppm by weight,
Chromium 10 ppm by weight,
Lead 100 ppm by weight,
Total Halogens 1,000 ppm by weight,
Sulfur 0.5 percent by weight.

Flash point of any used oil shall not be less than 100 degrees F. Any used oil fuel that
contains more than 1,000 ppm by weight of total halogens shall be considered a hazardous
waste and shall not be burned in the kiln. If used oil is utilized as a fuel, the permittee shall
comply with the Standards for the Management of Used Oil in accordance with R315-15,
UAC. [Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.6.f.1 Monitoring:

The permittee shall provide test certification for each load of used oil fuel received.
Certification shall be made either by permittee's testing or through test reports from the
36
used oil fuel marketer. The oil shall be tested for halogen content using ASTM Method
D-808-81, EPA Method 8240 or EPA Method 8260 before used oil fuel is burned.

II.B.6.f.2 Recordkeeping:

The permittee shall record the quantity of used oil burned on a daily basis. The permittee
shall maintain records of fuel analyses or vendor documentation showing contaminant
levels or property values for all used oil combusted. Records of used oil fuel consumption
and the test reports shall be kept for all periods when the plant is in operation. All records
shall be documented and maintained consistent with the requirements of Provision I.S.1 of
this permit.

II.B.6.f.3 Reporting:

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

Status: Not Applicable – Used oil is not used on-site. See status of condition II.B.6.a.

II.B.6.g Condition:

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

II.B.6.g.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349 and 40 CFR 63.7.
(40 CFR 63.1348(a))

(a) The permittee shall demonstrate compliance with the temperature operating limits
by using the following performance test methods and procedures. The permittee
shall use the arithmetic average of the temperatures measured during the three
runs to determine the applicable temperature limit

(i) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD, and,
where applicable, the temperature at the inlet to the alkali bypass PMCD shall
be continuously recorded during the period of the Method 23 test, and the
continuous temperature record(s) shall be included in the performance test
report.

(ii) Average temperatures shall be calculated for each run of the performance test

37
(iii) The run average temperature shall be calculated for each run, and the average
of the run average temperatures shall be determined and included in the
performance test report and will determine the applicable temperature limit.

(40 CFR 63.1348(a)(3)(ii), 40 CFR 63.1349(b)(3)(ii)-(iv))

(b) Continuous Monitoring Requirements
The permittee shall demonstrate compliance with the emissions standards and
operating limits by using the performance test methods and procedures in 40 CFR
63.1350 and 63.8 for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350 and the
site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions,
repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable,
calibration checks and required zero and span adjustments), the permittee shall
operate the monitoring system and collect data at all required intervals at all times
the affected source is operating.

The permittee shall not use data recorded during monitoring system startup,
shutdown or malfunctions or repairs associated with monitoring system
malfunctions in calculations used to report emissions or operating levels. A
monitoring system malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring system to provide valid data. Monitoring
system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other
periods in assessing the operation of the control device and associated control
system.

(i) The permittee shall comply with the monitoring requirements of paragraphs
(A) through (D) below and 40 CFR 63.1350(m)(1) through (4) to demonstrate
continuous compliance with the D/F emissions standard. The permittee shall
also develop an emissions monitoring plan in accordance with 40 CFR
63.1350(p)(1) through (4).

a. The permittee shall install, calibrate, maintain, and continuously operate a
CMS to record the temperature of the exhaust gases from the kiln and
alkali bypass, if applicable, at the inlet to, or upstream of, the kiln and/or
alkali bypass PMCDs

i. The temperature recorder response range shall include zero and
1.5 times the average temperature established according to the
requirements in 40 CFR 63.1349(b)(3)(iv).

ii. The calibration reference for the temperature measurement shall
be a National Institute of Standards and Technology calibrated
reference thermocouple-potentiometer system or alternate
reference, subject to approval by the Administrator.

iii. The calibration of all thermocouples and other temperature
sensors shall be verified at least once every three months.
38
b. The permittee shall monitor and continuously record the temperature of
the exhaust gases from the kiln and alkali bypass, if applicable, at the inlet
to the kiln and/or alkali bypass PMCD.

c. The required minimum data collection frequency shall be one minute.

d. The permittee shall comply with the monitoring requirements specified in
40 CFR 63.1350(g)(4) and (5).

Performance tests are required at regular intervals and shall be repeated every 30
months. Performance tests shall be completed no more than 31 calendar months
after the previous performance test except where that specific pollutant is
monitored using CEMS

(40 CFR 63.1348(b)(1), (4), 40 CFR 63.1349(c), 40 CFR 63.1350(g))

The permittee may undertake a change in operations as specified in 40 CFR
63.1348(c).

The permittee shall conduct performance tests under conditions based on
representative performance of the affected source for the period being tested. The
permittee shall make available, upon request, such records as may be necessary to
determine the conditions of performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped
with a CMS, the permittee shall maintain the average emissions or the operating
parameter values within the operating parameter limits established through
performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of this section is a violation. (40 CFR
63.1350(a))

II.B.6.g.2 Recordkeeping:

Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.6.g.3 Reporting:

In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall comply with the
following.

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

39
(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

Status: In Compliance – The latest 30-month Dioxins/Furans (D/F) stack tests were
conducted on July 18-20, 2023, and July 19-21, 2023. The stack tests are conducted to
determine temperatures of the main baghouse and the alkali baghouse while the raw
mill is in operation and not in operation. After the stack tests are conducted, the
CEMs determine if the baghouses exceed the new established temperatures.
According to the real time electronic tracking system, the temperatures appeared
below the established temperatures at time of the inspection. The next D/F stack test
will be due in January of 2025. There are plans to conduct the stack test every two
years in the future.

Stack Test Summary:
Stacks New Established Temperatures (Degrees C)
Main Baghouse - Mill On 279.1
Main Baghouse - Mill Off 359.9
Alkali Baghouse - Mill On 271.3
Alkali Baghouse – Mill Off 353.4

II.B.6.h Condition:

Emissions of Dioxins/Furans (D/F) shall be no greater than 0.2 ng/dscm (TEQ) on a dry
basis, corrected to 7 percent oxygen during normal operation. If the average temperature at
the inlet to the first PM control device (fabric filter or electrostatic precipitator) during the
D/F performance test is 400 degrees F or less this limit is changed to 0.40 ng/dscm (TEQ).

[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.6.h.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349 and 40 CFR 63.7. (40
CFR 63.1348(a))

(a) The permittee shall demonstrate compliance by conducting separate performance
tests while the raw mill is operating and while the raw mill is not operating. The
permittee shall determine the D/F TEQ concentration for each run and calculate
the arithmetic average of the TEQ concentrations measured for the three runs to
determine continuous compliance

(i) The permittee shall conduct a performance test using Method 23 of 40 CFR
60, Appendix A-7. If the kiln or in-line kiln/raw mill is equipped with an
alkali bypass, simultaneous performance tests of the kiln or in-line kiln/raw
mill exhaust and the alkali bypass shall be conducted. The permittee may
conduct a performance test of the alkali bypass exhaust when the raw mill of
the in-line kiln/raw mill is operating or not operating.

a. Each performance test shall consist of three separate runs conducted under
representative conditions. The duration of each run shall be at least 3
hours, and the sample volume for each run must be at least 2.5 dscm (90
dscf).

40
(b) If sorbent injection is employed as an emission control technique for D/F control,
the permittee shall operate the sorbent injection system in accordance with
paragraphs (b)(i) and (ii).

(i) The rolling three-hour average activated sorbent injection rate shall be equal
to or greater than the sorbent injection rate determined in accordance with 40
CFR 63.1349(b)(3)(vi).

(ii) The permittee shall either:

a. Maintain the minimum activated carbon injection carrier gas flow rate, as
a rolling three-hour average, based on the manufacturer's specifications.
These specifications must be documented in the test plan developed in
accordance with 40 CFR 63.7(c), or

b. Maintain the minimum activated carbon injection carrier gas pressure
drop, as a rolling three-hour average, based on the manufacturer's
specifications. These specifications must be documented in the test plan
developed in accordance with 40 CFR 63.7(c).

(c) Except as provided in paragraph (d), the permittee shall specify and use the brand
and type of sorbent used during the performance test until a subsequent
performance test is conducted, unless the site-specific performance test plan
contains documentation of key parameters that affect adsorption and the permittee
establishes limits based on those parameters, and the limits on these parameters
are maintained.

(d) The permittee may substitute, at any time, a different brand or type of sorbent
provided that the replacement has equivalent or improved properties compared to
the sorbent specified in the site-specific performance test plan and used in the
performance test. The permittee shall maintain documentation that the substitute
sorbent will provide the same or better level of control as the original sorbent.

(e) If activated carbon injection is used, the permittee shall demonstrate compliance
with the activated carbon injection rate operating limits by using the performance
test methods and procedures in (i) through (iii). The permittee shall also develop a
carrier gas parameter (either the carrier gas flow rate or the carrier gas pressure
drop) during the initial performance test and updated during any subsequent
performance test conducted. Compliance is demonstrated if the system is
maintained within +/- 5 percent accuracy during the performance test determined
in accordance with the procedures and criteria submitted for review in the
monitoring plan required in 40 CFR 63.1350(p).

(i) If sorbent injection is used for D/F control, the permittee shall record the rate
of sorbent injection to the kiln exhaust, and where applicable, the rate of
sorbent injection to the alkali bypass exhaust, continuously during the period
of the Method 23 test in accordance with the conditions in 40 CFR
63.1350(m)(9), and include the continuous injection rate record(s) in the
performance test report. The permittee shall determine the sorbent injection
rate parameters by calculating the run average sorbent injection rate for each
run and determine and include the average of the run average injection rates
in the performance test report and determine the applicable injection rate
limit.
41
(ii) The permittee shall include the brand and type of sorbent used during the
performance test in the performance test report.

(40 CFR 63.1346(c), (d), (e), 40 CFR 63.1348(a)(3)(iii), (iv), 40 CFR
63.1349(b)(3) and (b)(3)(i), 40 CFR 63.1349(b)(3)(v)-(vi))

(f) Continuous Monitoring Requirements:

The permittee shall demonstrate compliance with the emissions standards and
operating limits by using the performance test methods and procedures in 40 CFR
63.1350 and 63.8 for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350 and the
site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions,
repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable,
calibration checks and required zero and span adjustments), the permittee shall
operate the monitoring system and collect data at all required intervals at all times
the affected source is operating.

The permittee shall not use data recorded during monitoring system startup,
shutdown or malfunctions or repairs associated with monitoring system
malfunctions in calculations used to report emissions or operating levels. A
monitoring system malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring system to provide valid data. Monitoring
system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other
periods in assessing the operation of the control device and associated control
system.

The performance test required under paragraph (a) shall be repeated every 30
months. Performance tests shall be completed no more than 31 calendar months
after the previous performance test except where that specific pollutant is
monitored using CEMS.

(i) If activated carbon injection is used to comply with the D/F emissions
limitation, the permittee shall demonstrate compliance using a CMS. The
permittee shall install, operate, calibrate, and maintain a continuous monitor
to record the rate of activated carbon injection. The accuracy of the rate
measurement device must be +/- 1 percent of the rate being measured.

a. The permittee shall verify the calibration of the device at least once every
three months

b. Each hour, the permittee shall calculate the three-hour rolling average
activated carbon injection rate for the previous three hours of process
operation. See 40 CFR 63.1349(b)(3).

c. When the operating status of the raw mill of the in-line kiln/raw mill is
changed from off to on or from on to off, the calculation of the three-hour
rolling average activated carbon injection rate shall begin anew, without
42
considering previous recordings.

(ii) If activated carbon injection is used to comply with the D/F emissions
limitation, the permittee shall demonstrate compliance using a CMS. The
permittee shall install, operate, calibrate, and maintain a continuous monitor
to record the activated carbon injection system carrier gas parameter (either
the carrier gas flow rate or the carrier gas pressure drop) established during
the D/F performance test in accordance with 40 CFR 63.1349(b)(3). Each
hour, the permittee shall calculate the three-hour rolling average of the
selected parameter value for the previous 3 hours of process operation using
all of the one-minute data available (i.e., the CMS is not out-of-control.)

(iii) If carbon injection is employed as an emission control technique, the
permittee shall comply with the additional monitoring requirements of 40
CFR 63.1350(m)(1) through (m)(4) and (m)(9).

(iv) The permittee shall also develop an emissions monitoring plan in accordance
with 40 CFR 63.1350(p)(1) through (4).

(40 CFR 63.1348(b)(1), (5), 40 CFR 63.1349(c), 40 CFR 63.1350(h))

The permittee may undertake a change in operations as specified in 40 CFR
63.1348(c).

The permittee shall conduct performance tests under conditions based on
representative performance of the affected source for the period being tested. The
permittee shall make available, upon request, such records as may be necessary to
determine the conditions of performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped with
a CMS, the permittee shall maintain the average emissions or the operating parameter
values within the operating parameter limits established through performance tests.
Any instance where the permittee fails to comply with the continuous monitoring
requirements of this section is a violation. (40 CFR 63.1350(a)).

II.B.6.h.2 Recordkeeping:

Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.6.h.3 Reporting:

In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall also comply with the
following:

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.
43
(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

Status: In Compliance – The latest 30-month D/F stack testing was conducted on July 18-20,
2023, and July 19-21, 2023. Two separate tests are performed on the main kiln stack.
One is performed when the raw mill is operating and the other is performed when
the raw mill is not operating. The next D/F stack test will be due in January of 2025.
See Status of condition II.B.6.g.

Stack D/F Limit
(ng/dscm@7% O2 TEQ)
D/F Results (ng/dscm@7% O2
Main Kiln Stack - Mill
On
0.4 0.002
Main Kiln Stack - Mill
Off
0.2 0.0018

II.B.6.i Condition:

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

II.B.6.i.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.i.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.6.i.3 Reporting:

Reports shall be submitted in accordance with Section I and condition II.B.1.a.3(U) of this
permit.

Status: In Compliance – The facility maintains and uses SOPs, their O&M Plan, and QAP
Plan to keep process and control equipment in working order. Records are
maintained hard copy and electronically. Reports are submitted as required.

II.B.6.j Condition:

(i) Combined PM emissions from the in-line kiln/raw mill and the alkali bypass stack
shall be no greater than 0.07 lb/ton clinker during normal operation.

(ii) Existing kilns that combine the clinker cooler exhaust and/or alkali bypass and/or
coal mill exhaust with the kiln exhaust and send the combined exhaust to the PM
44
control device as a single stream may meet an alternative PM emissions limit
calculated in accordance with 40 CFR 63.1343(b)(2)

[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)]

(i) Emissions of PM10 shall be no greater than 14 lbs/hr.

[DAQE-AN100070027-20]. [R307-401-8]

II.B.6.j.1 Monitoring:

The PM performance tests shall be performed using Method 5 or 5I and consist of three
test runs. (40 CFR 63.1343 Table 1 Footnote 1)

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349 and 40 CFR 63.7.
(40 CFR 63.1348(a)) At least 60 days before the test, the source shall notify the Director
of the date, time, place of testing, and submit a source test protocol containing the items in
R307-165-3

(a) The permittee shall demonstrate compliance with the PM emissions standards by
using the following test methods and procedures. Initial compliance shall be
demonstrated by conducting a performance test using Method 5 or Method 5I in
40 CFR 60 Appendix A-3. The permittee shall also monitor continuous
performance through use of a PM continuous parametric monitoring system (PM
CPMS).

(i) The permittee shall establish a site-specific operating limit for the PM CPMS.
The permittee shall use the PM CPMS to demonstrate continuous compliance
with the operating limit.

a. The PM CPMS shall provide a 4-20 milliamp or digital signal output and
the establishment of its relationship to manual reference method
measurements shall be determined in units of milliamps or the monitor's
digital equivalent

b. The PM CPMS operating range shall be capable of reading PM
concentrations from zero to a level equivalent to three times the allowable
emission limit. If the PM CPMS is an auto-ranging instrument capable of
multiple scales, the primary range of the instrument shall be capable of
reading PM concentration from zero to a level equivalent to three times
the allowable emission limit

c. During the initial performance test or any such subsequent performance
test that demonstrates compliance with the PM limit, the permittee shall
record and average all milliamp or digital output values from the PM
CPMS for the periods corresponding to the compliance test runs (e.g.,
average all the PM CPMS output values for three corresponding Method
5I test runs).

(ii) The permittee shall determine the operating limit as specified in paragraphs
(iii) through (iv). If the PM performance test demonstrates PM emission levels
45
to be below 75 percent of the emission limit the permittee shall use the
average PM CPMS value recorded during the PM compliance test, the
milliamp or digital equivalent of zero output from the PM CPMS, and the
average PM result of the compliance test to establish the operating limit. If the
PM compliance test demonstrates PM emission levels to be at or above 75
percent of the emission limit the permittee shall use the average PM CPMS
value recorded during the PM compliance test to establish the operating limit.
The permittee shall verify an existing or establish a new operating limit after
each repeated performance test. The permittee shall repeat the performance
test at least annually and reassess and adjust the site-specific operating limit in
accordance with the results of the performance test

(iii) If the average of the three Method 5 or 5I compliance test runs is below 75
percent of the PM emission limit, the permittee shall calculate an operating
limit by establishing a relationship of PM CPMS signal to PM concentration
using the PM CPMS instrument zero, the average PM CPMS values
corresponding to the three compliance test runs, and the average PM
concentration from the Method 5 or 5I compliance test with the procedures in
(iii)(A) through (D).

a. Determine the PM CPMS instrument zero output with one of the
procedures specified in 40 CFR 63.1349(b)(1)(iii)(A).

b. Determine the PM CPMS instrument average in milliamps or digital
equivalent, and the average of the corresponding three PM compliance test
runs, as specified in 40 CFR 63.1349(b)(1)(iii)(B).

c. With the instrument zero expressed in milliamps or a digital value, the
three run average PM CPMS milliamp or digital signal value, and the
three run PM compliance test average, determine a relationship of lb/ton-
clinker per milliamp or digital signal value as specified in 40 CFR
63.1349(b)(1)(iii)(C)

d. Determine the source specific 30-day rolling average operating limit using
the lb/ton-clinker per milliamp or digital signal value as specified in 40
CFR 63.1349(b)(1)(iii)(D). This sets the operating limit at the PM CPMS
output value corresponding to 75 percent of the emission limit.

(iv) If the average of the three PM compliance test runs is at or above 75 percent
of the PM emission limit the permittee shall determine the operating limit by
averaging the PM CPMS milliamp or digital equivalent output corresponding
to the three PM performance test runs that demonstrate compliance with the
emission limit as specified in 40 CFR 63.1349(b)(1)(iv).

(v) To determine continuous operating compliance, the permittee shall record the
PM CPMS output data for all periods when the process is operating, and use
all the PM CPMS data for calculations when the source is not out-of-control.
The permittee shall demonstrate continuous compliance by using all quality-
assured hourly average data collected by the PM CPMS for all operating hours
to calculate the arithmetic average operating parameter in units of the
operating limit (milliamps or the digital equivalent) on a 30 operating day
rolling average basis, updated at the end of each new kiln operating day. The
46
permittee shall determine the 30 kiln operating day average as specified in 40
CFR 63.1349(b)(1)(v).

(vi) For each performance test, the permittee shall conduct at least three separate
test runs under the conditions that exist when the affected source is operating
at the level reasonably expected to occur. Conduct each test run to collect a
minimum sample volume of 1 dscm for determining compliance with an
existing source limit. Calculate the time weighted average of the results from
three consecutive runs, including applicable sources, to determine compliance.
Determination of the particulate matter collected in the impingers ('back half')
of the Method 5 or Method 5I particulate sampling train is not required to
demonstrate compliance with the PM standards. For kilns with inline raw
mills, testing shall be conducted while the raw mill is on and while the raw
mill is off.

As part of demonstration of compliance with the PM10 limit, all of the
filterable particulate emissions measured shall be considered PM10. Every
three years, the permittee shall use 40 CFR 51, Appendix M, Method 202 or
other EPA-approved testing method, as acceptable to the Director, to measure
condensable PM. The back-half condensables shall not be used for PM10
compliance demonstration but shall be used for inventory purposes

(vii) The permittee shall demonstrate initial compliance by conducting separate
performance tests while the raw mill is under normal operating conditions and
while the raw mill is not operating, and calculate the time weighted average
emissions. The operating limit shall then be determined using 40 CFR
63.1349(b)(1)(i).

(viii) When there is an alkali bypass and/or an inline coal mill with a separate stack
associated with a kiln, the main exhaust and alkali bypass and/or inline coal
mill shall be tested simultaneously and the combined emission rate of PM
from the kiln and alkali bypass and/or inline coal mill shall be computed for
each run as specified in 40 CFR 63.1349(b)(1)(viii)

(40 CFR 63.1348(a)(1), 40 CFR 63.1349(b)(1), DAQE-AN100070027-20)

(b) Continuous Monitoring Requirements:

The permittee shall demonstrate compliance with the emissions standards and
operating limits by using the performance test methods and procedures in 40 CFR
63.1350 and 63.8 for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350 and the
site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions,
repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable,
calibration checks and required zero and span adjustments), the permittee shall
operate the monitoring system and collect data at all required intervals at all times
the affected source is operating.

The permittee shall not use data recorded during monitoring system startup,
47
shutdown or malfunctions or repairs associated with monitoring system
malfunctions in calculations used to report emissions or operating levels. A
monitoring system malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring system to provide valid data. Monitoring
system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other
periods in assessing the operation of the control device and associated control
system.

The permittee shall use the following monitoring methods and procedures.

(i) The permittee shall use a PM CPMS to establish a site-specific operating
limit corresponding to the results of the performance test demonstrating
compliance with the PM limit. The permittee shall conduct a performance
test using Method 5 or Method 5I at appendix A-3 to 40 CFR part 60. The
permittee shall use the PM CPMS to demonstrate continuous compliance
with this operating limit. The permittee shall repeat the performance test
annually and reassess and adjust the site-specific operating limit in
accordance with the results of the performance test using the procedures in
II.B.6.j.1(a)(i) through (vi). The test shall also be repeated if the permittee
changes the analytical range of the instrument, or replaces the instrument
itself or any principle analytical component of the instrument that would
alter the relationship of output signal to in-stack PM concentration.

(ii) To determine continuous compliance, the permittee shall use the PM CPMS
output data for all periods when the process is operating and the PM CPMS
is not out-of-control. The permittee shall demonstrate continuous
compliance by using all quality-assured hourly average data collected by
the PM CPMS for all operating hours to calculate the arithmetic average
operating parameter in units of the operating limit (milliamps or the digital
equivalent) on a 30 operating day rolling average basis, updated at the end
of each new kiln operating day.

(iii) For any exceedance of the 30 process operating day PM CPMS average
value from the established operating parameter limit, the permittee shall:

a. Within 48 hours of the exceedance, visually inspect the APCD[;

b. If inspection of the APCD identifies the cause of the exceedance, take
corrective action as soon as possible and return the PM CPMS
measurement to within the established value; and

c. Within 30 days of the exceedance or at the time of the annual
compliance test, whichever comes first, conduct a PM emissions
compliance test to determine compliance with the PM emissions limit
and to verify or re-establish the PM CPMS operating limit within 45
days. The permittee is not required to conduct additional testing for any
exceedances that occur between the time of the original exceedance and
the PM emissions compliance test required under this paragraph.

(iv) PM CPMS exceedances leading to more than four required performance
tests in a 12-month process operating period (rolling monthly) constitute a
presumptive violation of 40 CFR 63 Subpart LLL.
48
(v) The permittee shall determine hourly clinker production by one of two
methods:

a. Install, calibrate, maintain, and operate a permanent weigh scale system
to measure and record weight rates in tons-mass per hour of the amount
of clinker produced. The system of measuring hourly clinker
production must be maintained within +/- 5 percent accuracy, or

b. Install, calibrate, maintain, and operate a permanent weigh scale system
to measure and record weight rates in tons-mass per hour of the amount
of feed to the kiln. The system of measuring feed must be maintained
within +/- 5 percent accuracy. Calculate the hourly clinker production
rate using a kiln-specific feed to clinker ratio based on reconciled
clinker production determined for accounting purposes and recorded
feed rates. Update this ratio monthly. Note that if this ratio changes at
clinker reconciliation, the permittee shall use the new ratio going
forward, but does not have to retroactively change clinker production
rates previously estimated.

(vi) During each quarter of source operation, the permittee shall determine,
record, and maintain a record of the ongoing accuracy of the system of
measuring hourly clinker production (or feed mass flow).

(vii) If clinker production is measured directly, record the daily clinker
production rates; if the kiln feed rates are measured and the clinker
production calculated, record the hourly kiln feed and clinker production
rates.

(viii) The permittee shall develop an emissions monitoring plan in accordance
with 40 CFR 63.1350(p)(1) through (4).

Performance tests for PM shall be repeated every 12 months. Performance
tests required every 12 months shall be completed no more than 13 calendar
months after the previous performance test.

(40 CFR 63.1348(b)(1), (2), 40 CFR 63.1349(c), 40 CFR 63.1350(b), (d))

The permittee may undertake a change in operations as specified in 40 CFR 63.1348(c).

The permittee shall conduct performance tests under conditions based on representative
performance of the affected source for the period being tested. The permittee shall make
available, upon request, such records as may be necessary to determine the conditions of
performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped with a
CMS, the permittee shall maintain the average emissions or the operating parameter values
within the operating parameter limits established through performance tests. Any instance
where the permittee fails to comply with the continuous monitoring requirements of this
section is a violation. (40 CFR 63.1350(a)).

II.B.6.j.2 Recordkeeping:

49
Records and results of monitoring shall be maintained in accordance with 40 CFR
63.1355, Table 1 to 40 CFR 63 Subpart LLL-Applicability of General Provisions, and
Provision I.S.1 of this permit.

II.B.6.j.3 Reporting:

In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall also comply with the
following.

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

(d) For PM performance test reports used to set a PM CPMS operating limit, the
electronic submission of the test report shall also include the information specified
in 40 CFR 63.1349(b)(1)(vii) and 40 CFR 63.1354(b)(11).

Status: In Compliance – The annual combined PM10 stack testing was conducted on July 8,
2024, July 16, 2024, and July 19, 2024. The tests were performed on the main kiln
stack (raw mill and alkali bypass) and the clinker cooler stack.

Stacks Combined PM10 Limit (lb/ton) Results (lb/ton)
Main Kiln stack/Mill/Alkali
Bypass
0.07 0.017
Main Kiln Mill Off 0.07 0.022
Clinker Cooler Stack 0.07 0.007

II.B.6.k Condition:

Emissions of mercury shall be no greater than 55 lb/MM tons clinker based on a rolling
30-day average during normal operation. The 30-day period means all operating hours
within 30 consecutive kiln operating days excluding periods of startup and shutdown.

The permittee shall ensure appropriate corrections for moisture are made when measuring
flowrates used to calculate mercury emissions.
[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.6.k.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349, R307-170, and 40
CFR 63.7. (40 CFR 63.1348(a))

The permittee shall demonstrate compliance with the mercury standards by using the
performance test methods and procedures in paragraph (a). The permittee shall
demonstrate compliance by operating a mercury CEMS or a sorbent trap based CEMS.

50
In calculating a 30 operating day emissions value using an integrating sorbent trap CEMS,
the permittee shall follow the procedures specified in 40 CFR 63.1348(a)(5)(i) and (ii).

(a) The permittee shall operate a mercury CEMS or a sorbent trap monitoring system
in accordance with the following requirements. If a mercury CEMS or a sorbent
trap monitoring system is used, the permittee shall install, operate, calibrate, and
maintain an instrument for continuously measuring and recording the exhaust gas
flow rate to the atmosphere according to the requirements in paragraph (vi). The
emission rate shall be calculated as specified in 40 CFR 63.1349(b)(5)(ii).

(i) The permittee shall install and operate a mercury continuous emissions
monitoring system (Hg CEMS) in accordance with Performance Specification
12A (PS 12A) of appendix B to 40 CFR part 60 or an integrated sorbent trap
monitoring system in accordance with Performance Specification 12B (PS
12B) of appendix B to 40 CFR part 60. The permittee shall monitor mercury
continuously according to paragraphs (ii) through (vi). The permittee shall
also develop an emissions monitoring plan in accordance with 40 CFR
63.1350(p)(1) through (4).

(ii) The permittee shall use a span value for any Hg CEMS that represents the
mercury concentration corresponding to approximately two times the
emissions standard and may be rounded up to the nearest multiple of 5
micrograms/m3 of total mercury or higher level if necessary to include Hg
concentrations which may occur (excluding concentrations during in-line raw
'mill off' operation). As specified in PS 12A, Section 6.1.1, the data recorder
output range must include the full range of expected Hg concentration values
which would include those expected during 'mill off' conditions. Engineering
judgments made and calculations used to determine the corresponding span
concentration from the emission standard shall be documented in the site-
specific monitoring plan and associated records.

(iii) The permittee shall quality assure data measured above the span value as
specified in 40 CFR 63.1350(k)(2) or other EPA-approved alternative, as
acceptable to the Director.

(iv) The permittee shall operate and maintain each Hg CEMS or an integrated
sorbent trap monitoring system according to the quality assurance
requirements in Procedure 5 of appendix F to 40 CFR part 60. During the
RATA of integrated sorbent trap monitoring systems required under
Procedure 5, the permittee may apply the appropriate exception for sorbent
trap section 2 breakthrough in 40 CFR 63.1350(k)(3).

(v) Relative accuracy testing of mercury monitoring systems under PS 12A, PS
12B, or Procedure 5 shall be conducted at normal operating conditions. The
testing shall occur with the raw mill on.

(vi) If a Hg CEMS or an integrated sorbent trap monitoring system is used, the
permittee shall install, operate, calibrate, and maintain instruments for
continuously measuring and recording the exhaust gas flow rate to the
atmosphere according to the requirements in 40 CFR 63.1350(n)(1) through
(10) to allow determination of the pollutant mass emission rate from sources
subject to an emission limitation that has a pounds per ton of clinker unit and
that is required to be monitored by a CEMS.
51
(vii) If an integrated sorbent trap monitoring system conforming to PS 12B is
operated, the permittee may use a monitoring period at least 24 hours but no
longer than 168 hours in length. The permittee should use a monitoring period
that is a multiple of 24 hours (except during relative accuracy testing as
allowed in PS 12B).

(40 CFR 63.1348(a)(5), 40 CFR 63.1349(b)(5), 40 CFR 63.1350(k), (n))

(b) Continuous Monitoring Requirements:

The permittee shall demonstrate compliance with the emissions standards and
operating limits by using the performance test methods and procedures in 40 CFR
63.1350 and 63.8 for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350, R307-
170, and the site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions,
repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable,
calibration checks and required zero and span adjustments), the permittee shall
operate the monitoring system and collect data at all required intervals at all times
the affected source is operating.

The permittee shall not use data recorded during monitoring system startup,
shutdown or malfunctions, or repairs associated with monitoring system
malfunctions in calculations used to report emissions or operating levels. A
monitoring system malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring system to provide valid data. Monitoring
system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other
periods in assessing the operation of the control device and associated control
system.

(i) The permittee shall demonstrate compliance using the monitoring methods
and procedures in II.B.6.k.1.(a)(i)-(vii). If an integrated sorbent trap
monitoring system is used to determine ongoing compliance, use the
procedures described in 40 CFR 63.1348(a)(5) to assign hourly mercury
concentration values and to calculate rolling 30 operating day emissions
rates. Since the permittee assigns the mercury concentration measured with
the sorbent trap to each relevant hour respectively for each operating day of
the integrated period, the permittee may schedule the sorbent trap change
periods to any time of the day (i.e., the sorbent trap replacement need not be
scheduled at 12:00 midnight nor must the sorbent trap replacements occur
only at integral 24-hour intervals).

(ii) Mercury shall be measured either upstream of the coal mill or in the coal
mill stack.

(iii) The permittee shall determine hourly clinker production by one of two
methods:

52
a. Install, calibrate, maintain, and operate a permanent weigh scale system
to measure and record weight rates in tons-mass per hour of the amount
of clinker produced. The system of measuring hourly clinker
production must be maintained within +/- 5 percent accuracy, or

b. Install, calibrate, maintain, and operate a permanent weigh scale system
to measure and record weight rates in tons-mass per hour of the amount
of feed to the kiln. The system of measuring feed must be maintained
within +/- 5 percent accuracy. Calculate the hourly clinker production
rate using a kiln-specific feed to clinker ratio based on reconciled
clinker production determined for accounting purposes and recorded
feed rates. Update this ratio monthly. Note that if this ratio changes at
clinker reconciliation, the permittee shall use the new ratio going
forward, but does not have to retroactively change clinker production
rates previously estimated.

(iv) During each quarter of source operation, the permittee shall determine,
record, and maintain a record of the ongoing accuracy of the system of
measuring hourly clinker production (or feed mass flow).

(v) If clinker production is measured directly, record the daily clinker
production rates; if the kiln feed rates are measured and the clinker
production calculated, record the hourly kiln feed and clinker production
rates

(vi) The permittee shall develop an emissions monitoring plan in accordance
with 40 CFR 63.1350(p)(1) through (4)

((40 CFR 63.1348(b)(1), (7), 40 CFR 63.1350(d), (k))

The permittee may undertake a change in operations as specified in 40 CFR
63.1348(c).

The permittee shall conduct performance tests under conditions based on
representative performance of the affected source for the period being tested. The
permittee shall make available, upon request, such records as may be necessary to
determine the conditions of performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped
with a CMS, the permittee shall maintain the average emissions or the operating
parameter values within the operating parameter limits established through
performance tests. Any instance where the permittee fails to comply with the
continuous monitoring requirements of this section is a violation. (40 CFR
63.1350(a)).

II.B.6.k.2 Recordkeeping:

Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, R307-170, and Provision I.S.1 of this
permit.

II.B.6.k.3 Reporting:
53
In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall also comply with the
following

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

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

Status: In Compliance – The CEMs have been installed and operated. CEM requirements
are evaluated by DAQ’s CEM Specialist. This includes reviewing Relative Accuracy
Test Audits (RATA) and quarterly State Electronic Data Reports (SEDR). Mercury
is included in the RATA report.

II.B.6.1 Condition:

Emissions of total hydrocarbon (THC) shall be no greater than 24 ppmvd, on a dry basis,
measured as propane, corrected to 7 percent oxygen, based on a rolling 30-day average
during normal operation. The 30-day period means all operating hours within 30
consecutive kiln operating days excluding periods of startup and shutdown.

Any source subject to the 24 ppmvd THC limit may elect to meet an alternative limit of 12
ppmvd for total organic HAP.
[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.6.l.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349, R307-170, and 40
CFR 63.7. (40 CFR 63.1348(a))

(a) THC Compliance: The permittee shall demonstrate compliance with the THC
emissions standards by using the following performance test methods and
procedures. The permittee shall operate a CEMS in accordance with the following
requirements. For the purposes of conducting the accuracy and quality assurance
evaluations for CEMS, the THC span value (as propane) is 50 to 60 ppmvw and
the reference method (RM) is Method 25A of 40 CFR 60, Appendix A. THC shall
be measured either upstream of the coal mill or the coal mill stack.

(i) The permittee shall install, operate, and maintain a THC continuous
emission monitoring system in accordance with Performance Specification 8
or Performance Specification 8A of appendix B to 40 CFR 60 and comply
with all of the requirements for continuous monitoring systems found in the
general provisions, subpart A of 40 CFR 63. The permittee shall operate and
54
maintain each CEMS according to the quality assurance requirements in
Procedure 1 of appendix F in 40 CFR 60. For THC continuous emission
monitoring systems certified under Performance Specification 8A, conduct
the relative accuracy test audits required under Procedure 1 in accordance
with Performance Specification 8, Sections 8 and 11 using Method 25A in
appendix A to 40 CFR part 60 as the reference method; the relative accuracy
must meet the criteria of Performance Specification 8, Section 13.2.

(ii) Performance tests on alkali bypass and coal mill stacks shall be conducted
using Method 25A in appendix A to 40 CFR part 60 and repeated every 30
months.

(b) Total Organic HAP Emission Tests: If the permittee elects to demonstrate
compliance with the total organic HAP emissions limit in lieu of the THC
emissions limit, the permittee shall demonstrate compliance with the total organic
HAP emissions standards by using the following performance test methods and
procedures, instead of conducting the compliance test specified under THC
Compliance. The time weighted average total organic HAP concentration
measured during the separate initial performance test specified by 40 CFR
63.1349(b)(7) shall be used to determine initial compliance. The time weighted
average THC concentration measured during the initial performance test specified
by paragraph (a) shall be used to determine the site-specific THC limit. Using the
fraction of time the inline kiln/raw mill is on and the fraction of time that the
inline kiln/raw mill is off, the permittee shall calculate this limit as a time
weighted average of the THC levels measured during raw mill on and raw mill off
testing using one of the two approaches in (vii) or (viii) depending on the level of
organic HAP measured during the compliance test.

(i) The permittee shall use Method 320 of 40 CFR 63 Appendix A, Method 18
of 40 CFR 60 Appendix A, ASTM D6348-03 or a combination to
determine emissions of total organic HAP. Each performance test shall
consist of three separate runs under the conditions that exist when the
affected source is operating at representative performance conditions in
accordance with 40 CFR 63.7(e). Each run shall be conducted for at least 1
hour

(ii) At the same time that the permittee is conducting the performance test for
total organic HAP, the permittee shall also determine a site-specific THC
emissions limit by operating a THC CEMS in accordance with the
requirements of paragraph (A). The duration of the performance test shall
be at least 3 hours and the average THC concentration (as calculated from
the recorded output) during the 3-hour test shall be calculated. The
permittee shall establish the THC operating limit and determine compliance
with it according to paragraphs (vii) and (viii). It is permissible to extend
the testing time of the organic HAP performance test if the permittee
believes extended testing is required to adequately capture organic HAP
and/or THC variability over time

a. The permittee shall continuously monitor THC according to paragraph (a)
or in accordance with Performance Specification 8 or 8A of appendix B to
40 CFR 60 and comply with all of the requirements for continuous
monitoring systems found in the general provisions, subpart A of 40 CFR
63. The permittee shall operate and maintain each CEMS according to the
55
quality assurance requirements in Procedure 1 of appendix F in 40 CFR
part 60.

(iii) The permittee shall use the fraction of time the raw mill is on and the
fraction of time that the raw mill is off and calculate this limit as a weighted
average of the THC levels measured during three raw mill on and three raw
mill off tests.

(iv) If the organic HAP emissions are below 75 percent of the organic HAP
standard and the permittee determines the operating limit with paragraph
(vi) the THC CEMS shall be calibrated and operated on a measurement
scale no greater than 180 ppmvw, as carbon, or 60 ppmvw as propane.

(v) The THC CEMS measurement scale shall be capable of reading THC
concentrations from zero to a level equivalent to two times the highest THC
emissions average determined during the performance test, including mill
on or mill off operation. Note: This may require the use of a dual range
instrument to meet this requirement and paragraph (iv).

(vi) The operating limit shall be determined as specified in paragraphs (vii) and
(viii). If the organic HAP performance test demonstrates average organic
HAP emission levels are below 75 percent of the emission limit (9 ppmv)
the permittee shall use the average THC value recorded during the organic
HAP performance test, and the average total organic HAP result of the
performance test to establish the operating limit. If the organic HAP
compliance test results demonstrate that average organic HAP emission
levels are at or above 75 percent of the emission limit, the operating limit is
established as the average THC value recorded during the organic HAP
performance test. The permittee shall establish a new operating limit after
each performance test. The permittee shall repeat the performance test no
later than 30 months following the last performance test and reassess and
adjust the site-specific operating limit in accordance with the results of the
performance test.

(vii) If the average organic HAP results for the three Method 18 and/or Method
320 performance test runs are below 75 percent of the organic HAP
emission limit, the permittee shall calculate an operating limit by
establishing a relationship of THC CEMS signal to the organic HAP
concentration using the average THC CEMS value corresponding to the
three organic HAP compliance test runs and the average organic HAP total
concentration from the Method 18 and/or Method 320 performance test
runs with the procedures in (A) and (B).

a. Determine the THC CEMS average values in ppmvw, and the average of
the corresponding three total organic HAP compliance test runs, as
specified in 40 CFR 63.1349(b)(7)(viii)(A)

b. Use the three run average THC CEMS value, and the three run average
organic HAP concentration from the three Method 18 and/or Method 320
compliance tests to determine the operating limit in units of ppmvw THC,
as propane, as specified in 40 CFR 63.1349(b)(7)(viii)(B).

56
(viii) If the average of the three organic HAP performance test runs is at or above
75 percent of the organic HAP emission limit, the permittee shall determine
the operating limit as specified in 40 CFR 63.1349(b)(7)(ix) by averaging
the THC CEMS output values corresponding to the three organic HAP
performance test runs that demonstrate compliance with the emission limit.
If the new THC CEMS value is below the current operating limit, the
permittee may opt to retain the current operating limit, but must still submit
all performance test and THC CEMS data according to the reporting
requirements

(ix) The permittee shall conduct separate performance tests while the raw mill is
operating ('mill on') and while the raw mill is not operating ('mill off').
Using the fraction of time the raw mill is on and the fraction of time that the
raw mill is off, calculate this limit as a weighted average of the THC levels
measured during raw mill on and raw mill off compliance testing as
specified in 40 CFR 63.1349(b)(7)(x).

(x) To determine continuous compliance with the THC operating limit, the
permittee shall record the THC CEMS output data for all periods when the
process is operating and the THC CEMS is not out-of-control. The
permittee shall demonstrate continuous compliance by using all quality-
assured hourly average data collected by the THC CEMS for all operating
hours to calculate the arithmetic average operating parameter in units of the
operating limit (ppmvw) on a 30 operating day rolling average basis,
updated at the end of each new kiln operating day. The permittee shall
determine the 30 kiln operating day average as specified in 40 CFR
63.1349(b)(7)(xi)

(xi) Use EPA Method 18 or Method 320 of appendix A to 40 CFR part 60 to
determine organic HAP emissions. For each performance test, conduct at
least three separate runs under the conditions that exist when the affected
source is operating at the level reasonably expected to occur. The permittee
shall conduct three separate test runs with the raw mill on, and three
separate runs under the conditions that exist when the affected source is
operating at the level reasonably expected to occur with the mill off.
Conduct each Method 18 test run to collect a minimum target sample
equivalent to three times the method detection limit. Calculate the average
of the results from three runs to determine compliance

(xii) If the THC level exceeds the site-specific THC emissions limit by 10
percent or more, the permittee shall

a. As soon as possible but no later than 30 days after the exceedance,
conduct an inspection and take corrective action to return the THC CEMS
measurements to within the established value; and

b. Within 90 days of the exceedance or at the time of the 30 month
compliance test, whichever comes first, conduct another performance test
to determine compliance with the organic HAP limit and to verify or re-
establish the site-specific THC emissions limit.

57
(c) The permittee shall develop an emission monitoring plan and comply with the
monitoring requirements as specified in 40 CFR 63.1350(m)(1) through (4) and 40
CFR 63.1350(p)(1) through (4).

(40 CFR 63.1348(a)(4), 40 CFR 63.1349(b)(4), (b)(7), 40 CFR 63.1350(i), 40
CFR 63.1350(j))

Continuous Monitoring Requirements:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the performance test methods and procedures in 40 CFR 63.1350 and 63.8
for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350, R307-170, and
the site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating.

The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions, or repairs associated with monitoring system malfunctions in calculations
used to report emissions or operating levels. A monitoring system malfunction is any
sudden, infrequent, not reasonably preventable failure of the monitoring system to provide
valid data. Monitoring system failures that are caused in part by poor maintenance or
careless operation are not malfunctions. The permittee shall use all the data collected
during all other periods in assessing the operation of the control device and associated
control system.

The permittee shall demonstrate compliance using the monitoring methods and procedures
in paragraphs (a)(i) and (ii), (b)(ii)(A), and (c). THC shall be measured either upstream of
the coal mill or the coal mill stack.

Performance tests are required at regular intervals and shall be repeated every 30 months.
Performance tests shall be completed no more than 31 calendar months after the previous
performance test except where that specific pollutant is monitored using CEMS.
((40 CFR 63.1348(b)(1), (6), 40 CFR 63.1349(c), 40 CFR 63.1350(i), (j))

The permittee may undertake a change in operations as specified in 40 CFR 63.1348(c).

The permittee shall conduct performance tests under conditions based on representative
performance of the affected source for the period being tested. The permittee shall make
available, upon request, such records as may be necessary to determine the conditions of
performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped with a
CMS, the permittee shall maintain the average emissions or the operating parameter values
within the operating parameter limits established through performance tests. Any instance
where the permittee fails to comply with the continuous monitoring requirements of this
section is a violation. (40 CFR 63.1350(a)).
58
II.B.6.l.2 Recordkeeping:

Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, R307-170, and Provision I.S.1 of this
permit.

II.B.6.l.3 Reporting:

In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall also comply with the
following.

Performance test results shall be documented in complete test reports in accordance with
40 CFR 63.1349(a).

The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a) and (b) as
applicable.

The permittee shall comply with the notification provisions of 40 CFR 63.1353.

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

Status: In Compliance – The CEMs have been installed and operated. CEM requirements
are evaluated by DAQ’s CEM specialist. This includes reviewing Relative Accuracy
Test Audits (RATA) and quarterly State Electronic Data Reports (SEDR). THC is
included with the rest of the RATA Testing Reports.

II.B.6.m Condition:

Emissions of HCl shall be no greater than 3 ppmvd, on a dry basis, corrected to 7 percent
oxygen, during normal operation. If using a CEMS to determine compliance with the HCl
standard, this standard is based on a rolling 30-day average. The 30-day period means all
operating hours within 30 consecutive kiln operating days excluding periods of startup and
shutdown. [Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.6.m.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349, R307-170, and 40
CFR 63.7. (40 CFR 63.1348(a))

(a) The permittee shall monitor HCl emissions continuously. The permittee shall
monitor compliance with the HCl emissions limit by operating an HCl CEMS in
accordance with Performance Specification (PS) 15 or PS 18 of appendix B to 40
CFR part 60, or, upon promulgation, in accordance with any other performance
specification for HCl CEMS in appendix B to 40 CFR part 60. The permittee shall
operate, maintain, and quality assure a HCl CEMS installed and certified under PS
15 according to the quality assurance requirements in Procedure 1 of appendix F
to 40 CFR part 60 except that the Relative Accuracy Test Audit requirements of
59
Procedure 1 must be replaced with the validation requirements and criteria of
sections 11.1.1 and 12.0 of PS 15. If the HCl CEMS is installed and operated in
accordance with PS 18, the permittee shall operate, maintain, and quality assure
the HCl CEMS using the associated procedure 6 of appendix F to 40 CFR part 60.
For any performance specification used, the permittee shall use Method 321 of
appendix A to 40 CFR part 63 as the reference test method for conducting relative
accuracy testing. The span value and calibration requirements in 40 CFR
63.1350(l)(1)(i) and (ii) apply to HCl CEMS other than those installed and
certified under PS 15 or PS 18.

(b) The permittee shall develop an emission monitoring plan and comply with the
monitoring requirements as specified in 40 CFR 63.1350(m)(1) through (4) and 40
CFR 63.1350(p)(1) through (4).

[40 CFR 63.1348(a)(6), 40 CFR 63.1349(b)(6), 40 CFR 63.1350(l)]

(c) Continuous Monitoring Requirements:
The permittee shall demonstrate compliance with the emissions standards and
operating limits by using the performance test methods and procedures in 40 CFR
63.1350 and 63.8 for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350, R307-
170, and the site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions,
repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable,
calibration checks and required zero and span adjustments), the permittee shall
operate the monitoring system and collect data at all required intervals at all times
the affected source is operating.

The permittee shall not use data recorded during monitoring system startup,
shutdown or malfunctions, or repairs associated with monitoring system
malfunctions in calculations used to report emissions or operating levels. A
monitoring system malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring system to provide valid data. Monitoring
system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other
periods in assessing the operation of the control device and associated control
system.

The permittee shall demonstrate compliance using the performance test methods,
monitoring methods, and procedures in 40 CFR 63.1349(b)(6), 40 CFR
63.1350(l)(1), paragraphs (a) and (b) above, or other EPA-approved alternative, as
acceptable to the Director. Hourly HCl concentration data shall be obtained. HCl
may be measured either upstream of the coal mill or in the coal mill stack.

Performance tests are required at regular intervals and shall be repeated every 30
months. Performance tests shall be completed no more than 31 calendar months
after the previous performance test except where that specific pollutant is
monitored using CEMS.

60
((40 CFR 63.1348(b)(1), (8), 40 CFR 63.1349(b)(6), 40 CFR 63.1349(c), 40 CFR
63.1350(l))

The permittee may undertake a change in operations as specified in 40 CFR 63.1348(c).

The permittee shall conduct performance tests under conditions based on representative
performance of the affected source for the period being tested. The permittee shall make
available, upon request, such records as may be necessary to determine the conditions of
performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped with a
CMS, the permittee shall maintain the average emissions or the operating parameter values
within the operating parameter limits established through performance tests. Any instance
where the permittee fails to comply with the continuous monitoring requirements of this
section is a violation. (40 CFR 63.1350(a)).

II.B.6.m.2 Recordkeeping:

Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, R307-170, and Provision I.S.1 of this
permit.

II.B.6.m.3 Reporting:

In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall also comply with the
following.

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

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

Status: In Compliance – The CEMs have been installed and operated. CEM requirements
are evaluated by DAQ’s CEM specialist. This includes reviewing Relative Accuracy
Test Audits (RATA) and quarterly State Electronic Data Reports (SEDR). HCL is
included in the RATA report.

II.B.6.n Condition:

During periods of startup and shutdown, the permittee shall meet the requirements listed in
(1) through (3).

61
(1) During startup the permittee shall use any one or combination of the following
clean fuels: natural gas, synthetic natural gas, propane, distillate oil, synthesis gas
(syngas), and ultra-low sulfur diesel (ULSD) until the kiln reaches a temperature
of 1200 degrees Fahrenheit.

(2) Combustion of the primary kiln fuel may commence once the kiln temperature
reaches 1200 degrees Fahrenheit.

(3) All dry sorbent and activated carbon systems that control hazardous air pollutants
shall be turned on and operating at the time the gas stream at the inlet to the
baghouse reaches 300 degrees Fahrenheit (five-minute average) during startup.
Temperature of the gas stream is to be measured at the inlet of the baghouse every
minute. Such injection systems can be turned off during shutdown. Particulate
control and all remaining devices that control hazardous air pollutants shall be
operational during startup and shutdown.

[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343, 40 CFR 63.1346(g)]

II.B.6.n.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.n.2 Recordkeeping:

The permittee shall keep records of the date, time and duration of each startup or shutdown
period for any affected source that is subject to a standard during startup or shutdown that
differs from the standard applicable at other times, and the quantity of feed and fuel used
during the startup or shutdown period.

Records demonstrating compliance with this condition shall be maintained in accordance
with 40 CFR 63.1346(g)(4), 40 CFR 63.1355, Table 1 to 40 CFR 63 Subpart LLL-
Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.6.n.3 Reporting:

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

Status: In Compliance – All requirements, mentioned in this condition, are met prior to
introducing feed to the kiln. These requirements and other aspects of the kiln are
electronically controlled and monitored by the Control Room.

II.B.6.o Condition:

By September 10, 2023, the permittee shall submit documentation to the Director on the
status of construction of the SNCR system. The referenced approval order (AO) may
become invalid if construction is not commenced by September 10, 2023 or if construction
is discontinued for 18 months or more. To ensure proper credit when notifying the
Director, send the documentation to the Director, attn.: NSR Section.
[Origin: DAQE-AN100070031-22, R307-401-18]. [R307-401-18]

II.B.6.o.1 Monitoring:

62
Records required for this permit condition will serve as monitoring.

II.B.6.o.2 Recordkeeping:

The permittee shall maintain a copy of each notification required by this permit condition
in accordance with Provision I.S.1 of this permit.

II.B.6.o.3 Reporting:

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

Status: In Compliance – The construction notice regarding the status of the NSCR System
was emailed, to the DAQ, on December 1, 2023. The NSCR is still currently under
evaluation. See condition II.A and inspection memo dated January 14, 2024.

II.B.7 Conditions on Cooler: Clinker Cooler

II.B.7.a Condition:

Production of clinker shall be no greater than 930,000 tons per rolling 12-month period.
[Origin: DAQE-AN100070027-20]. [R307-401-8]

II.B.7.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 20th day of each month using
kiln production data from the previous 12 months.

II.B.7.a.2 Recordkeeping:

Production shall be determined by maintenance of a supervisor log or equivalent. Records
shall be kept on a daily basis for all periods when the plant is in operation. Records and
results of monitoring 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 – According to the source’s electronic records 709,839 short tons
and/or 643,961 metric tons of clinkers were produced as of November 14, 2024.

II.B.7.b Condition:

At all times the permittee shall operate and maintain any affected source, including
associated air pollution control equipment and monitoring equipment, in a manner
consistent with safety and good air pollution control practices for minimizing emissions.
Determination of whether such operation and maintenance procedures are being used will
be based on information available to the Director which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation
and maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart LLL].
[40 CFR 63.1348(d)]
63
II.B.7.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.7.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.7.b.3 Reporting:

Reports shall be submitted in accordance with Section I and condition II.B.1.a.3(U) of this
permit.

Status: In Compliance – The facility maintains and uses SOPs and their O&M Plan to keep
process and control equipment in working order. Records are maintained
electronically and reports are submitted as required.

II.B.7.c Condition:

(i) Emissions of PM shall be no greater than 0.07 lb/ton clinker during normal
operation.

(ii) Existing kilns that combine the clinker cooler exhaust and/or alkali bypass and/or
coal mill exhaust with the kiln exhaust and send the combined exhaust to the PM
control device as a single stream may meet an alternative PM emissions limit
calculated in accordance with 40 CFR 63.1343(b)(2).

[Origin: 40 CFR 63 Subpart LLL]. [40 CFR 63.1343(a), 40 CFR 63.1343(b)(1)]

II.B.7.c.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the test methods and procedures in 40 CFR 63.1349 and 40 CFR 63.7.
(40 CFR 63.1348(a))

(a) The permittee shall demonstrate compliance with the PM emissions standards by
using the following test methods and procedures. Initial compliance shall be
demonstrated by conducting a performance test using Method 5 or Method 5I in
40 CFR 60 Appendix A-3. The permittee shall also monitor continuous
performance through use of a PM continuous parametric monitoring system (PM
CPMS).

(i) The permittee shall establish a site-specific operating limit for the PM CPMS.
The permittee shall use the PM CPMS to demonstrate continuous compliance
with the operating limit.

a. The PM CPMS shall provide a 4-20 milliamp or digital signal output and
the establishment of its relationship to manual reference method
measurements shall be determined in units of milliamps or the monitor's
digital equivalent.

64
b. The PM CPMS operating range shall be capable of reading PM
concentrations from zero to a level equivalent to three times the allowable
emission limit. If the PM CPMS is an auto-ranging instrument capable of
multiple scales, the primary range of the instrument shall be capable of
reading PM concentration from zero to a level equivalent to three times
the allowable emission limit.

c. During the initial performance test or any such subsequent performance
test that demonstrates compliance with the PM limit, the permittee shall
record and average all milliamp or digital output values from the PM
CPMS for the periods corresponding to the compliance test runs (e.g.,
average all the PM CPMS output values for three corresponding Method
5I test runs).

(ii) The permittee shall determine the operating limit as specified in paragraphs
(iii) through (iv). If the PM performance test demonstrates PM emission
levels to be below 75 percent of the emission limit the permittee shall use the
average PM CPMS value recorded during the PM compliance test, the
milliamp or digital equivalent of zero output from the PM CPMS, and the
average PM result of the compliance test to establish the operating limit. If
the PM compliance test demonstrates PM emission levels to be at or above 75
percent of the emission limit the permittee shall use the average PM CPMS
value recorded during the PM compliance test to establish the operating limit.
The permittee shall verify an existing or establish a new operating limit after
each repeated performance test. The permittee shall repeat the performance
test at least annually and reassess and adjust the site-specific operating limit
in accordance with the results of the performance test

(iii) If the average of the three Method 5 or 5I compliance test runs is below 75
percent of the PM emission limit, the permittee shall calculate an operating
limit by establishing a relationship of PM CPMS signal to PM concentration
using the PM CPMS instrument zero, the average PM CPMS values
corresponding to the three compliance test runs, and the average PM
concentration from the Method 5 or 5I compliance test with the procedures in
(iii)(A) through (D).

a. Determine the PM CPMS instrument zero output with one of the
procedures specified in 40 CFR 63.1349(b)(1)(iii)(A)

b. Determine the PM CPMS instrument average in milliamps or digital
equivalent, and the average of the corresponding three PM compliance test
runs, as specified in 40 CFR 63.1349(b)(1)(iii)(B).

c. With the instrument zero expressed in milliamps or a digital value, the
three run average PM CPMS milliamp or digital signal value, and the
three run PM compliance test average, determine a relationship of lb/ton-
clinker per milliamp or digital signal value as specified in 40 CFR
63.1349(b)(1)(iii)(C).

d. Determine the source specific 30-day rolling average operating limit using
the lb/ton-clinker per milliamp or digital signal value as specified in 40
CFR 63.1349(b)(1)(iii)(D). This sets the operating limit at the PM CPMS
output value corresponding to 75 percent of the emission limit.
65
(iv) If the average of the three PM compliance test runs is at or above 75 percent
of the PM emission limit the permittee shall determine the operating limit by
averaging the PM CPMS milliamp or digital equivalent output corresponding
to the three PM performance test runs that demonstrate compliance with the
emission limit as specified in 40 CFR 63.1349(b)(1)(iv).

(v) To determine continuous operating compliance, the permittee shall record the
PM CPMS output data for all periods when the process is operating, and use
all the PM CPMS data for calculations when the source is not out-of-control.
The permittee shall demonstrate continuous compliance by using all quality-
assured hourly average data collected by the PM CPMS for all operating
hours to calculate the arithmetic average operating parameter in units of the
operating limit (milliamps or the digital equivalent) on a 30 operating day
rolling average basis, updated at the end of each new kiln operating day. The
permittee shall determine the 30 kiln operating day average as specified in 40
CFR 63.1349(b)(1)(v).

(vi) For each performance test, the permittee shall conduct at least three separate
test runs each while the mill is on and the mill is off under the conditions that
exist when the affected source is operating at the level reasonably expected to
occur. Conduct each test run to collect a minimum sample volume of 1 dscm
for determining compliance with an existing source limit. Calculate the time
weighted average of the results from three consecutive runs, including
applicable sources, to determine compliance. The permittee need not
determine the particulate matter collected in the impingers ('back half') of the
Method 5 or Method 5I particulate sampling train to demonstrate compliance
with the PM standards

(vii) The permittee shall demonstrate initial compliance by conducting separate
performance tests while the raw mill is under normal operating conditions
and while the raw mill is not operating, and calculate the time weighted
average emissions. The operating limit shall then be determined using 40
CFR 63.1349(b)(1)(i)

(40 CFR 63.1348(a)(1), 40 CFR 63.1349(b)(1))

(b) Continuous Monitoring Requirements
The permittee shall demonstrate compliance with the emissions standards and
operating limits by using the performance test methods and procedures in 40 CFR
63.1350 and 63.8 for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350 and the
site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions,
repairs associated with monitoring system malfunctions, and required monitoring
system quality assurance or quality control activities (including, as applicable,
calibration checks and required zero and span adjustments), the permittee shall
operate the monitoring system and collect data at all required intervals at all times
the affected source is operating.

The permittee shall not use data recorded during monitoring system startup,
shutdown or malfunctions, or repairs associated with monitoring system
66
malfunctions in calculations used to report emissions or operating levels. A
monitoring system malfunction is any sudden, infrequent, not reasonably
preventable failure of the monitoring system to provide valid data. Monitoring
system failures that are caused in part by poor maintenance or careless operation
are not malfunctions. The permittee shall use all the data collected during all other
periods in assessing the operation of the control device and associated control
system.

The permittee shall use the following monitoring methods and procedures.

(i) The permittee shall use a PM CPMS to establish a site-specific operating
limit corresponding to the results of the performance test demonstrating
compliance with the PM limit. The permittee shall conduct a performance
test using Method 5 or Method 5I at appendix A-3 to 40 CFR part 60. The
permittee shall use the PM CPMS to demonstrate continuous compliance
with this operating limit. The permittee shall repeat the performance test
annually and reassess and adjust the site-specific operating limit in
accordance with the results of the performance test using the procedures in
II.B.7.c.1(a)(i) through (vi). The test shall also be repeated if the permittee
changes the analytical range of the instrument, or replaces the instrument
itself or any principle analytical component of the instrument that would
alter the relationship of output signal to in-stack PM concentration.

(ii) To determine continuous compliance, the permittee shall use the PM CPMS
output data for all periods when the process is operating and the PM CPMS
is not out-of-control. The permittee shall demonstrate continuous
compliance by using all quality-assured hourly average data collected by the
PM CPMS for all operating hours to calculate the arithmetic average
operating parameter in units of the operating limit (milliamps) on a 30
operating day rolling average basis, updated at the end of each new kiln
operating day.

(iii) For any exceedance of the 30 process operating day PM CPMS average
value from the established operating parameter limit, the permittee shall:

a. Within 48 hours of the exceedance, visually inspect the APCD;

b. If inspection of the APCD identifies the cause of the exceedance, take
corrective action as soon as possible and return the PM CPMS
measurement to within the established value; and

c. Within 30 days of the exceedance or at the time of the annual
compliance test, whichever comes first, conduct a PM emissions
compliance test to determine compliance with the PM emissions limit
and to verify or re-establish the PM CPMS operating limit within 45
days. The permittee is not required to conduct additional testing for any
exceedances that occur between the time of the original exceedance and
the PM emissions compliance test required under this paragraph.

(iv) PM CPMS exceedances leading to more than four required performance
tests in a 12-month process operating period (rolling monthly) constitute a
presumptive violation of 40 CFR 63 Subpart LLL

67
(v) The permittee shall determine hourly clinker production by one of two
methods:

a. Install, calibrate, maintain, and operate a permanent weigh scale system
to measure and record weight rates in tons-mass per hour of the amount
of clinker produced. The system of measuring hourly clinker production
must be maintained within +/- 5 percent accuracy, or

b. Install, calibrate, maintain, and operate a permanent weigh scale system
to measure and record weight rates in tons-mass per hour of the amount
of feed to the kiln. The system of measuring feed must be maintained
within +/- 5 percent accuracy. Calculate the hourly clinker production
rate using a kiln-specific feed to clinker ratio based on reconciled
clinker production determined for accounting purposes and recorded
feed rates. Update this ratio monthly. Note that if this ratio changes at
clinker reconciliation, the permittee shall use the new ratio going
forward, but does not have to retroactively change clinker production
rates previously estimated.

(vi) During each quarter of source operation, the permittee shall determine,
record, and maintain a record of the ongoing accuracy of the system of
measuring hourly clinker production (or feed mass flow).

(vii) If clinker production is measured directly, record the daily clinker
production rates; if the kiln feed rates are measured and the clinker
production calculated, record the hourly kiln feed and clinker production
rates.

(viii) The permittee shall develop an emissions monitoring plan in accordance
with 40 CFR 63.1350(p)(1) through (4)

Performance tests for PM shall be repeated every 12 months. Performance tests required
every 12 months shall be completed no more than 13 calendar months after the previous
performance test

(40 CFR 63.1348(b)(1), (2), 40 CFR 63.1349(c), 40 CFR 63.1350(b), (d))

The permittee may undertake a change in operations as specified in 40 CFR 63.1348(c).

The permittee shall conduct performance tests under conditions based on representative
performance of the affected source for the period being tested. The permittee shall make
available, upon request, such records as may be necessary to determine the conditions of
performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped with a
CMS, the permittee shall maintain the average emissions or the operating parameter values
within the operating parameter limits established through performance tests. Any instance
where the permittee fails to comply with the continuous monitoring requirements of this
section is a violation. (40 CFR 63.1350(a)).

II.B.7.c.2 Recordkeeping:
68
Records and results of monitoring shall be maintained in accordance with 40 CFR
63.1355, Table 1 to 40 CFR 63 Subpart LLL-Applicability of General Provisions, and
Provision I.S.1 of this permit.

II.B.7.c.3 Reporting:

In addition to the reporting requirements in Section I of this permit, the permittee shall
report the results of the performance test before the close of business on the 60th day
following the completion of the performance test. The permittee shall also comply with the
following.

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

(d) For PM performance test reports used to set a PM CPMS operating limit, the
electronic submission of the test report shall also include the information specified
in 40 CFR 63.1349(b)(1)(vii) and 40 CFR 63.1354(b)(11).

Status: In Compliance – See status of condition II.B.6.j, regarding the clinker cooler stack
test results.

II.B.7.d Condition:

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

II.B.7.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.7.d.2 Recordkeeping:

The permittee shall keep records of the date, time and duration of each startup or shutdown
period for any affected source that is subject to a standard during startup or shutdown that
differs from the standard applicable at other times, and the quantity of feed and fuel used
during the startup or shutdown period.

Records demonstrating compliance with this condition shall be maintained in accordance
with 40 CFR 63.1355, Table 1 to 40 CFR 63 Subpart LLL-Applicability of General
Provisions, and Provision I.S.1 of this permit.

II.B.7.d.3 Reporting:
69
In addition to the reporting requirements of Section I of this permit, the permittee shall
comply with the reporting requirements specified in 40 CFR 63.1354.

Status: Not Applicable – The dry sorbent and activated carbon systems are not used on-site.

II.B.8 Conditions on Finish Mill: Finish Mill Operations

II.B.8.a Condition:

Visible emissions shall be no greater than 10 percent opacity during all modes of
operation.
[Origin: 40 CFR 63 Subpart LLL, DAQE-AN100070027-20]. [40 CFR 63.1343, 40 CFR
63.1345, R307-401-8]

II.B.8.a.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the performance test methods and procedures in 40 CFR 63.1350 and 63.8
for each affected source.

The permittee shall monitor and collect data according to 40 CFR 63.1350, R307-170, if
applicable, and the site-specific monitoring plan required by 40 CFR 63.1350(p).

Except for periods of startup and shutdown, monitoring system malfunctions, repairs
associated with monitoring system malfunctions, and required monitoring system quality
assurance or quality control activities (including, as applicable, calibration checks and
required zero and span adjustments), the permittee shall operate the monitoring system and
collect data at all required intervals at all times the affected source is operating.

The permittee shall not use data recorded during monitoring system startup, shutdown or
malfunctions, or repairs associated with monitoring system malfunctions in calculations
used to report emissions or operating levels. A monitoring system malfunction is any
sudden, infrequent, not reasonably preventable failure of the monitoring system to provide
valid data. Monitoring system failures that are caused in part by poor maintenance or
careless operation are not malfunctions. The permittee shall use all the data collected
during all other periods in assessing the operation of the control device and associated
control system.

(i) The permittee shall demonstrate compliance using the following monitoring
methods and procedures based on the maximum 6-minute average opacity exhibited
during the performance test period. Corrective actions shall be initiated within one
hour of detecting visible emissions above the applicable limit. The permittee shall
also develop an opacity monitoring plan in accordance with paragraph (iv) below.

(a) The permittee shall monitor opacity by conducting daily visible emissions
observations of the mill sweep and air separator PM control devices (PMCD) on
the raw mill or finish mill in accordance with the procedures of Method 22 of
appendix A-7 to 40 CFR part 60. The duration of the Method 22 performance test
shall be 6 minutes.

(b) Within 24 hours of the end of the Method 22 performance test in which visible
emissions were observed, the permittee shall conduct a follow up Method 22
70
performance test of each stack from which visible emissions were observed during
the previous Method 22 performance test

(c) If visible emissions are observed during the follow-up Method 22 performance test
required by paragraph (B) of this section from any stack from which visible
emissions were observed during the previous Method 22 performance test required
by paragraph (A) of the section, the permittee shall then conduct an opacity test of
each stack from which emissions were observed during the follow up Method 22
performance test in accordance with Method 9 of appendix A-4 to 40 CFR part 60.
The duration of the Method 9 test shall be 30 minutes

(d) If visible emissions are observed during any Method 22 visible emissions test
conducted, the permittee shall initiate, within one-hour, the corrective actions
specified in the operation and maintenance plan

(e) The requirements to conduct daily Method 22 testing under this section do not
apply to any specific raw mill or finish mill equipped with a COMS or BLDS

(ii) If a COMS is installed in lieu of conducting the daily visible emissions testing, the
permittee shall demonstrate compliance using a COMS that it is installed, operated,
and maintained in accordance with the following requirements.

The COMS shall be installed at the outlet of the PM control device of the raw mill or
finish mill and the COMS shall be installed, maintained, calibrated, and operated as
required by the general provisions in subpart A of this part and according to PS-1 of
appendix B to 40 CFR part 60.

(iii) If a bag leak detection system (BLDS) is installed on a raw mill or finish mill in
lieu of conducting the daily visible emissions testing, the permittee shall
demonstrate compliance using a BLDS that is installed, operated, and maintained in
accordance with 40 CFR 63.1350(m)(1) through (m)(4), (m)(10), and (m)(11)

(iv) The permittee shall develop an opacity monitoring plan in accordance with 40 CFR
63.1350(p)(1) through (4) and paragraph (p )(5), if applicable.

(40 CFR 63.1348(b)(1), (3), 40 CFR 63.1350(f))

The permittee may undertake a change in operations as specified in 40 CFR 63.1348(c).

The permittee shall conduct performance tests under conditions based on representative
performance of the affected source for the period being tested. The permittee shall make
available, upon request, such records as may be necessary to determine the conditions of
performance tests. (40 CFR 63.1349(e))

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. For each existing unit that is equipped with a
CMS, the permittee shall maintain the average emissions or the operating parameter values
within the operating parameter limits established through performance tests. Any instance
where the permittee fails to comply with the continuous monitoring requirements of this
section is a violation. (40 CFR 63.1350(a))

II.B.8.a.2 Recordkeeping:

71
Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, 40 CFR 63.1350(p)(5), R307-170, if
applicable, and Provision I.S.1 of this permit.

II.B.8.a.3 Reporting: In addition to the reporting requirements in Section I of this permit, the permittee shall also comply with the following.
(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).

(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

Reports shall be submitted quarterly, as outlined in R307-170, Continuous Emission Monitoring Program, if applicable. The reports are considered prompt notification of permit deviation required in Provision I.S.2.c of this permit, if all information required by Provision I.S.2.c is included in the report
Status: In Compliance – According to the source, ten minute daily visible emission
observations (Method 22) are conducted of the raw mills and finish mills. In
accordance with Subpart LLL. Observations are maintained in a google spreadsheet.

II.B.8.b Condition:

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

II.B.8.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.8.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.8.b.3 Reporting: Reports shall be submitted in accordance with Section I and condition II.B.1.a.3(U) of this permit.
Status: In Compliance – The facility maintains and uses SOPs and their O&M Plan to keep
process and control equipment in working order. Records are maintained
electronically and reports are submitted as required.

72
II.B.9 Conditions on MHO: Material handling operations

II.B.9.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: 40 CFR 63 Subpart
LLL, DAQE-AN100070027-20]. [40 CFR 63.1345, R307-401-8]

II.B.9.a.1 Monitoring:

The permittee shall demonstrate compliance with the emissions standards and operating
limits by using the performance test methods and procedures in 40 CFR 63.1350 and 63.8
for each affected source. The permittee shall monitor and collect data according to 40 CFR
63.1350.

The permittee shall demonstrate compliance using the following monitoring methods and
procedures. Corrective actions shall be initiated within one hour of detecting visible
emissions above the applicable limit.

(a) The permittee shall conduct a monthly 10-minute visible emissions test of each
affected source in accordance with Method 22 of appendix A-7 to 40 CFR part 60.
The performance test shall be conducted while the affected source is in operation

(b) If no visible emissions are observed in six consecutive monthly tests for any
affected source, the permittee may decrease the frequency of performance testing
from monthly to semi-annually for that affected source. If visible emissions are
observed during any semi-annual test, the permittee shall resume performance
testing of that affected source on a monthly basis and maintain that schedule until
no visible emissions are observed in six consecutive monthly tests.

(c) If no visible emissions are observed during the semi-annual test for any affected
source, the permittee may decrease the frequency of performance testing from
semi-annually to annually for that affected source. If visible emissions are
observed during any annual performance test, the permittee shall resume
performance testing of that affected source on a monthly basis and maintain that
schedule until no visible emissions are observed in six consecutive monthly tests.

(d) If visible emissions are observed during any Method 22 performance test, of
appendix A-7 to 40 CFR part 60, the permittee shall conduct 30 minutes of opacity
observations, recorded at 15-second intervals, in accordance with Method 9 of
appendix A-4 to 40 CFR part 60 of this chapter. The Method 9 performance test
shall begin within 1 hour of any observation of visible emissions.

(e) Any totally enclosed conveying system transfer point, regardless of the location of
the transfer point is not required to conduct Method 22 visible emissions
monitoring under this paragraph. The enclosures for these transfer points shall be
operated and maintained as total enclosures on a continuing basis in accordance
with the facility operations and maintenance plan.

(f) If any partially enclosed or unenclosed conveying system transfer point is located
in a building, the permittee shall conduct a Method 22 performance test, of
appendix A-7 to 40 CFR part 60, according to the requirements of paragraphs (a)
through (d) of this section for each such conveying system transfer point located
73
within the building, or for the building itself, according to paragraph (g) of this
section.

(g) If visible emissions from a building are monitored, the requirements of paragraphs
(a) through (d) of this section apply to the monitoring of the building, and the
permittee shall also test visible emissions from each side, roof, and vent of the
building for at least 10 minutes.

(h) If visible emissions are observed during any Method 22 visible emissions test
conducted, the permittee shall initiate, within one-hour, the corrective actions
specified in the facility operation and maintenance plan as required in 40 CFR
63.1347.

(40 CFR 63.1348(b)(1), (3), 40 CFR 63.1350(f))

The permittee may undertake a change in operations as specified in 40 CFR 63.1348(c).

The permittee shall conduct performance tests under conditions based on representative
performance of the affected source for the period being tested. The permittee shall make
available, upon request, such records as may be necessary to determine the conditions of
performance tests. (40 CFR 63.1349(e)).

The permittee shall demonstrate compliance on a continuous basis by meeting the
requirements of this monitoring condition. Any instance where the permittee fails to
comply with the continuous monitoring requirements of this section is a violation.
(40 CFR 63.1350(a)).

II.B.9.a.2 Recordkeeping:

Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.9.a.3 Reporting:

(a) Performance test results shall be documented in complete test reports in
accordance with 40 CFR 63.1349(a).
(b) The permittee shall comply with the reporting provisions of 40 CFR 63.1354(a)
and (b) as applicable.

(c) The permittee shall comply with the notification provisions of 40 CFR 63.1353.

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

Status: In Compliance – According to the source, ten minute monthly visible emission
observations (Method 22) are conducted of the open and partially opened conveyor
transfer points in accordance with Subpart LLL. Regardless of observation results,
the monthly tests are continually conducted. Making on-site testing more stringent
than this permit requires. Observations are maintained in the Parsable Database.

II.B.9.b Condition:

74
At all times the permittee shall operate and maintain any affected source, including
associated air pollution control equipment and monitoring equipment, in a manner
consistent with safety and good air pollution control practices for minimizing emissions.
Determination of whether such operation and maintenance procedures are being used will
be based on information available to the Director which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review of operation
and maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart LLL].
[40 CFR 63.1348(d)]

II.B.9.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.9.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.1355, Table 1 to 40 CFR 63
Subpart LLL-Applicability of General Provisions, and Provision I.S.1 of this permit.

II.B.9.b.3 Reporting:

Reports shall be submitted in accordance with Section I and condition II.B.1.a.3(U) of this
permit.

Status: In Compliance – The facility maintains and uses SOPs and their O&M Plan to keep
process and control equipment in good working order. Records are maintained
electronically and reports are submitted as required.

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

N/A

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

N/A

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

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

EMISSION INVENTORY: The 2023 triannual Emissions Inventory was submitted on April 15,
2024. It was revised and resubmitted on July 30, 2024.

The 2026 triannual emission inventory will be due by April 15,
2027.
75

PREVIOUS ENFORCEMENT
ACTIONS:
1) NOV – Dated December 19, 2023 (DAQC-1321-23) - In
process of being settled.

2) NOV – Dated March 1, 2024 (DAQC-182-24) – Settled
(DAQC-321-24)

3) NOV – Dated March 27, 2024 (DAQC-144-24) – In process of
being settled.

4) NOV – Dated August 2, 2024 (DAQC-715-24) – In process of
being settled.

COMPLIANCE STATUS &
RECOMMENDATIONS:
In Compliance with the conditions of the Title V Operating Permit
2900001004, dated November 18, 2021, and revised March 25,
2022, at time of the inspection.

The AG Office is currently in the process of resolving the three
outstanding NOVs. The source is considered to have achieved
compliance.

HPV STATUS: Yes

76
COMPLIANCE ASSISTANCE: 1) Discussed and reviewed ACC, six-month monitoring, and
deviation reports and requested that they be revised and
resubmitted.

2) Discussed submitting Ownership and Company Name Change
form, to the DAQ, when required.

RECOMMENDATION FOR
NEXT INSPECTION:
It should be noted that the kiln is taken off-line from the middle of
February to the middle of March. This is done once a year to
conduct maintenance. Inspect as usual.

ATTACHMENTS: VEO Form
Correspondence
Diesel Fuel Invoice

Joe Rockwell <[e-mail]>
Fwd: Holcim Devil's Slide Annual Compliance Certification
1 message
Clinton Badger <[e-mail]>Mon, Sep 30, 2024 at 4:05 PM
To: Joe Rockwell <[e-mail]>
Cc: Mark MILLER <[e-mail]>
Good afternoon Joe,
Please see below email submitted for the Annual Compliance Certification on 30 July 2024, please let me know if you
have any questions or other items you are looking for.
---------- Forwarded message ---------
From: Clinton Badger <[e-mail]>
Date: Tue, Jul 30, 2024 at 4:31 PM
Subject: Holcim Devil's Slide Annual Compliance Certification
To: Bird, Bryce <[e-mail]>
Cc: Mark MILLER <[e-mail]>
Mr. Bird,
Please find attached Annual Compliance Certification. Please let us know if you have any questions.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
12/2/24, 8:12 PM State of Utah Mail - Fwd: Holcim Devil's Slide Annual Compliance Certification
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1811660345352438987&simpl=msg-f:1811660345352438987 1/2
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Annual Compliance Certification.pdf
282K
12/2/24, 8:12 PM State of Utah Mail - Fwd: Holcim Devil's Slide Annual Compliance Certification
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1811660345352438987&simpl=msg-f:1811660345352438987 2/2
Joe Rockwell <[e-mail]>
Resubmitted Reports
2 messages
Clinton Badger <[e-mail]>Fri, Oct 4, 2024 at 4:11 PM
To: Joe Rockwell <[e-mail]>
Good Afternoon,
Thanks for the call yesterday, please find attached scanned copies of the reports I dropped off and stamped at the
Division of Air Quality office yesterday.
As always please reach out if you have any questions or concerns.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Resubmittal of Reports to UT DAQ 3 October 2024.pdf
2422K
Joe Rockwell <[e-mail]>Fri, Oct 4, 2024 at 5:18 PM
To: Clinton Badger <[e-mail]>
I'll take a look.
Thanks Clint,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
12/2/24, 8:14 PM State of Utah Mail - Resubmitted Reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1812023118848981487&simpl=msg-f:18120231188489814…1/2

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/2/24, 8:14 PM State of Utah Mail - Resubmitted Reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1812023118848981487&simpl=msg-f:18120231188489814…2/2
Joe Rockwell <[e-mail]>
Semi Annual Monitoring Report H1 Permit year - 1 July 2023 - 31 December 2023
2 messages
Clinton Badger <[e-mail]>Fri, Oct 4, 2024 at 4:18 PM
To: Joe Rockwell <[e-mail]>
Good Afternoon,
Following up from yesterday's phone call, I am providing a copy of the report as discussed, originally submitted and
stamped by DAQ 30 January 2024.
As always please reach out if you have any questions or concerns.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Semi Annul Monitoring Report July-December 2023 - Submitted and Stamped 30 January 2024.pdf
110K
Joe Rockwell <[e-mail]>Fri, Oct 4, 2024 at 5:21 PM
To: Clinton Badger <[e-mail]>
I'll take a look.
Thanks Clint and have a good weekend!
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116
12/2/24, 8:17 PM State of Utah Mail - Semi Annual Monitoring Report H1 Permit year - 1 July 2023 - 31 December 2023
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1812023565187454251&simpl=msg-f:18120235651874542…1/2

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/2/24, 8:17 PM State of Utah Mail - Semi Annual Monitoring Report H1 Permit year - 1 July 2023 - 31 December 2023
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1812023565187454251&simpl=msg-f:18120235651874542…2/2
Joe Rockwell <[e-mail]>
Summary Report - Excess Emissions and CMS
2 messages
Clinton Badger <[e-mail]>Fri, Nov 15, 2024 at 1:07 PM
To: Joe Rockwell <[e-mail]>
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Summary Report - Gaseuous and Opacity Excess Emission and CMS Performance Report Jan-Jun 2024.pdf
495K
Joe Rockwell <[e-mail]>Tue, Nov 19, 2024 at 11:42 AM
To: Clinton Badger <[e-mail]>
Thanks for the report Clint.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/2/24, 8:19 PM State of Utah Mail - Summary Report - Excess Emissions and CMS
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1815820376235844470&simpl=msg-f:18158203762358444…1/1
Joe Rockwell <[e-mail]>
10007 Holcim Title V payment
2 messages
David Beatty <[e-mail]>Tue, Nov 19, 2024 at 1:08 PM
To: Joe Rockwell <[e-mail]>
Paid in full on 09/04/2024 $178,807.87
--
David P. Beatty, P.E.
Manager | Operating Permits Section
Phone: [phone]
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Joe Rockwell <[e-mail]>Tue, Nov 19, 2024 at 1:40 PM
To: David Beatty <[e-mail]>
Really appreciate it, Dave.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
11/20/24, 10:45 AM State of Utah Mail - 10007 Holcim Title V payment
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816182877308959973&simpl=msg-f:18161828773089599…1/1
Joe Rockwell <[e-mail]>
Holcim Devil's Slide -ULSD Invoices
2 messages
Clinton Badger <[e-mail]>Tue, Nov 19, 2024 at 2:54 PM
To: Joe Rockwell <[e-mail]>
Joe,
Please see attached copies of the two most recent fuel invoices for ULSD. Let me know if you have any questions or
would like to see additional records.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
2 attachments
Fuel Invoice 13 November 2024.pdf
59K
Fuel Invoice 24 October 2024.pdf
59K
Joe Rockwell <[e-mail]>Tue, Nov 19, 2024 at 10:10 PM
To: Clinton Badger <[e-mail]>
Thanks Clint.
Joe Rockwell | Environmental Scientist
Phone: [phone]
11/20/24, 10:43 AM State of Utah Mail - Holcim Devil's Slide -ULSD Invoices
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816189485307187384&simpl=msg-f:18161894853071873…1/2

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
11/20/24, 10:43 AM State of Utah Mail - Holcim Devil's Slide -ULSD Invoices
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816189485307187384&simpl=msg-f:18161894853071873…2/2
Joe Rockwell <[e-mail]>
Submitted revised reports
2 messages
Clinton Badger <[e-mail]>Fri, Nov 22, 2024 at 5:11 PM
To: Joe Rockwell <[e-mail]>
Joe,
I wanted to let you know I was able to resubmit the revised reports to the DAQ, once I scan the date received stamped
versions I will fwd your way.
I still need to get you supplemental info to your question about stack test.
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Joe Rockwell <[e-mail]>Mon, Nov 25, 2024 at 4:24 PM
To: Clinton Badger <[e-mail]>
Thanks Clint.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/2/24, 8:21 PM State of Utah Mail - Submitted revised reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816469888427891449&simpl=msg-f:18164698884278914…1/2
12/2/24, 8:21 PM State of Utah Mail - Submitted revised reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816469888427891449&simpl=msg-f:18164698884278914…2/2
Joe Rockwell <[e-mail]>
Annual Compliance Certification Resubmitted
1 message
Clinton Badger <[e-mail]>Tue, Nov 26, 2024 at 8:37 AM
To: Joe Rockwell <[e-mail]>
Please see attached scanned copy of the resubmitted ACC, stamped received DAQ last week.
As the scanned copy can be hard to read, let me know if you would also like the spreadsheet or PDF version to compare.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Holcim - Annual Compliance Certification.pdf
1380K
12/2/24, 8:22 PM State of Utah Mail - Annual Compliance Certification Resubmitted
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816799941630503817&simpl=msg-f:1816799941630503817 1/1
Joe Rockwell <[e-mail]>
6 Month Monitoring Report (JAN - JUN 2024)
1 message
Clinton Badger <[e-mail]>Tue, Nov 26, 2024 at 8:42 AM
To: Joe Rockwell <[e-mail]>
Please see attached scanned copy of the resubmitted 6 Month Monitoring report, stamped received by DAQ last week.
Also included are the previously submitted deviation reports for reference. Please let me know if you have any questions
or need supplemental information.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Semi Annual Montoring Report H1- 2024 (JAN-JUN 2024).pdf
387K
12/2/24, 8:24 PM State of Utah Mail - 6 Month Monitoring Report (JAN - JUN 2024)
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816800294992758511&simpl=msg-f:1816800294992758511 1/1
Joe Rockwell <[e-mail]>
6 Month Monitoring Report (JUL - DEC 2023)
1 message
Clinton Badger <[e-mail]>Tue, Nov 26, 2024 at 8:42 AM
To: Joe Rockwell <[e-mail]>
Please see attached scanned copy of the resubmitted 6 Month Monitoring report, stamped received by bDAQ last week.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
Semi Annual Montoring Report H2- 2023 (JUL-DEC 2023).pdf
48K
12/2/24, 8:25 PM State of Utah Mail - 6 Month Monitoring Report (JUL - DEC 2023)
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816800299009960961&simpl=msg-f:1816800299009960961 1/1
Joe Rockwell <[e-mail]>
Follow up on stack test queston for PM
1 message
Clinton Badger <[e-mail]>Tue, Nov 26, 2024 at 12:49 PM
To: Joe Rockwell <[e-mail]>
Joe,
I pulled a few things from both stack test reports, let me know if you'd like further
clarification from our stack testing company.
From 2023 DAQ Inspecon Notes
Stacks PM10 Limit (lb/ton)Results (lb/ton)
Main Kiln
stack/Mill/Alkali Bypass
0.07 0.006 (page 10 of 2023 Report)
Clinker Cooler Stack 0.07 0.002 (page 12 of 2023 Report)
Mill off is on page 11 @ 0.002
New 2024
Stacks PM10 Limit (lb/ton)Results (lb/ton)
Main Kiln stack/ Mill/
Alkali Bypass
0.07 0.017 (page 6 of 2024 Report)
Main Kiln Mill off 0.07 0.022 (page 7 of 2024 Report)
Clinker Cooler Stack 0.07 0.007 (page 8 of 2024 Report)
Below are extracted from the attached stack test reports:
2023 Kiln Mill on results
------------------------------------------------------------------------------2023 Kiln Mill Off results
12/2/24, 8:26 PM State of Utah Mail - Follow up on stack test queston for PM
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816815788673502073&simpl=msg-f:1816815788673502073 1/4
------------------------------------------------------------------------------2023 Clinker Cooler Results
------------------------------------------------------------------------------2024 Kiln Mill on results

------------------------------------------------------------------------------2024 Kiln Mill Off results
12/2/24, 8:26 PM State of Utah Mail - Follow up on stack test queston for PM
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816815788673502073&simpl=msg-f:1816815788673502073 2/4
------------------------------------------------------------------------------2024 Clinker Cooler Results
2023 PM Stack Test and SSOL submitted Jan 20…
PM and CO 2024 Final Report - stamped recieve…
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
12/2/24, 8:26 PM State of Utah Mail - Follow up on stack test queston for PM
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816815788673502073&simpl=msg-f:1816815788673502073 3/4
12/2/24, 8:26 PM State of Utah Mail - Follow up on stack test queston for PM
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1816815788673502073&simpl=msg-f:1816815788673502073 4/4
Joe Rockwell <[e-mail]>
Holcim Devil’s Slide
1 message
Clinton Badger <[e-mail]>Mon, Dec 2, 2024 at 8:10 AM
To: Joe Rockwell <[e-mail]>
Good morning Joe,
I wanted to make sure you received everything that was submitted post inspection.
If you need anything else or any clarification please let me know.
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email in
error, please delete it immediately and notify us by email or telephone.
12/2/24, 8:29 PM State of Utah Mail - Holcim Devil’s Slide
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1817342319828744923&simpl=msg-f:1817342319828744923 1/1
Joe Rockwell <[e-mail]>
NOV's
2 messages
Clinton Badger <[e-mail]>Wed, Dec 4, 2024 at 1:52 PM
To: Joe Rockwell <[e-mail]>
Joe,
As discussed yesterday please see below information from NOV's let me know if you have any questions.
NOV DateSent Date
Received Violation Status
DAQ
1321-23
12/19/2023 1/2/2024 Failure to submit a complete and accurate SEDR for 202023
and 302023 on or before the required due dates for the S02,
NOx, Hg, THC, & HCl monitoring systems. Failure to submit
prompt (within 14 days) written deviation reports for
deviation from the Title V Permit requirements to submit
accurate and complete SEDR reports for 2Q2023 and
3Q2023.
Open
DAQ
182-24
3/1/2024 3/5/2024 Failure to notify the Director at least 60 days before
performance testing, Failure to submit the performance test
report before the close of business on the 60th day following
the completion of testing. Failure to submit prompt (within 14
days) written deviation reports for failure to submit a pretest
protocol to the DAQ at least 60 days prior to testing and
failure to submit the results of a completed stack test within
60 days of completion of the testing or before the close of
business on the 60th day following the completion of the
performance test.
Settled, reference DAQ-321-24,
Paid 1,000 Fine
DAQ
144-24
3/27/2024 3/29/2024 Failure to submit a complete and accurate SEDR for 4Q
2023 on or before January 30, 2024 (S02, NOx, Hg, THC, &
HCl). Failure to submit a complete, unmodified electronic
data report in an ASCII format specified by the DAQ Director
by January 30, 2024, for 4Q2023. Failure to provide a
narrative description explaining each event of monitor
unavailability for approximately 209 events listed as "Daily
Calibrations" in the 2Q2023, 3Q2023, and 402023 SEDR
submittals. Allegedly making false material statements,
representations, or certifications in the 2Q 2023, 3Q 2023,
and 4Q 2023 SEDR submittals.
Open
DAQ
715-24
8/2/2024 8/6/2024 Failure to conduct a complete RATA of the HCI monitor on
the Kiln Main Stack at least once in the four calendar
quarters of 2023.
Open, submitted test results
from HCl spike test completed
May 2024
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
12/4/24, 3:21 PM State of Utah Mail - NOV's
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1817544538515622194&simpl=msg-f:18175445385156221…1/2
This email is confidential and intended only for the use of the above named addressee. If you have received this email in error,
please delete it immediately and notify us by email or telephone.
Joe Rockwell <[e-mail]>Wed, Dec 4, 2024 at 2:56 PM
To: Clinton Badger <[e-mail]>
Thank you very much Clint.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
12/4/24, 3:21 PM State of Utah Mail - NOV's
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1817544538515622194&simpl=msg-f:18175445385156221…2/2
Invoice No:IN-328697-24
Invoice Date:
Delivery Date:
Account ID:R10008902
Lift Date/Time:
Thu 10/24/2024
Thu 10/24/2024
Thu 10/24/24 10:46a
Parkland USA Corp dba Rhinehart Oil
4475 W California Ave
Salt Lake City, UT 84104
[phone]
Remit To:Parkland USA Corp dba Rhinehart Oil
PO Box 913504
Denver, CO 80291-3504
Effective March 1, 2022 All card transactions above $200.00 will include a 2.5% processing fee.
Alternate payment options remain in place and include cash, check, and ACH direct payment.
Bill To:
Reference No.:P.O. No:
Salesperson:
TFDD2663990 5500014122
Rob Campbell Carrier:Parkland USA dba Rhinehart Oil
ON-733778-24Order No:
Ship To:
ID:1
North American Business Services
PO Box 7500
Concord, ON L4K 1B6
6055 East Croydon Road
Croydon, UT 84018
Holcim LTD
Holnam Inc
Description BOL No Unit Price TotalUnits
Dsl Fuel 2 Dyed Uls 1201105 2.772110 23,407.70 8,444.00
This product is Dyed Diesel Fuel. NON-TAXABLE USE ONLY. Penalty for taxable use. Off-Highway use/Not legal for motor vehicles.
NA1993, DIESEL FUEL, COMBUSTIBLE LIQUID, 3, PG III
Tax and Other Charges Summary TotalBasisRate
8.44 Federal Lust Tax - Dsl Fuel 2 Dyed Uls 0.001000 8,444.00
18.10 Federal Oil Spill Rec - Diesel - Dsl Fuel 2 Dyed Uls 0.002143 8,444.00
34.18 Federal SF Crude Oil Recovery - Dsl Fuel 2 Dyed Uls 0.004048 8,444.00
54.89 UT Clean Up Fee - Dsl Fuel 2 Dyed Uls 0.006500 8,444.00
6.76 UT Regulatory Comp Fee - Dsl Fuel 2 Dyed Uls 0.000800 8,444.00
1,112.54 UT State Sales Tax - Dsl Fuel 2 Dyed Uls 4.8500%$22,938.97
Invoice Total
****Payment Terms Summary****
$24,642.61
Due by Sun 12/08/2024 (Net 45 Days)24,642.61
Invoice No:IN-342750-24
Invoice Date:
Delivery Date:
Account ID:R10008902
Lift Date/Time:
Tue 10/29/2024
Tue 10/29/2024
Tue 10/29/24 10:48a
Parkland USA Corp dba Rhinehart Oil
4475 W California Ave
Salt Lake City, UT 84104
[phone]
Remit To:Parkland USA Corp dba Rhinehart Oil
PO Box 913504
Denver, CO 80291-3504
Effective March 1, 2022 All card transactions above $200.00 will include a 2.5% processing fee.
Alternate payment options remain in place and include cash, check, and ACH direct payment.
Bill To:
Reference No.:P.O. No:
Salesperson:
TFDD2668528 5500014122
Rob Campbell Carrier:Parkland USA dba Rhinehart Oil
ON-740813-24Order No:
Ship To:
ID:1
North American Business Services
PO Box 7500
Concord, ON L4K 1B6
6055 East Croydon Road
Croydon, UT 84018
Holcim LTD
Holnam Inc
Description BOL No Unit Price TotalUnits
Dsl Fuel 2 Dyed Uls 1201433 2.696218 21,502.34 7,975.00
This product is Dyed Diesel Fuel. NON-TAXABLE USE ONLY. Penalty for taxable use. Off-Highway use/Not legal for motor vehicles.
NA1993, DIESEL FUEL, COMBUSTIBLE LIQUID, 3, PG III
Tax and Other Charges Summary TotalBasisRate
7.98 Federal Lust Tax - Dsl Fuel 2 Dyed Uls 0.001000 7,975.00
17.09 Federal Oil Spill Rec - Diesel - Dsl Fuel 2 Dyed Uls 0.002143 7,975.00
32.28 Federal SF Crude Oil Recovery - Dsl Fuel 2 Dyed Uls 0.004048 7,975.00
51.84 UT Clean Up Fee - Dsl Fuel 2 Dyed Uls 0.006500 7,975.00
6.38 UT Regulatory Comp Fee - Dsl Fuel 2 Dyed Uls 0.000800 7,975.00
1,021.47 UT State Sales Tax - Dsl Fuel 2 Dyed Uls 4.8500%$21,061.18
Invoice Total
****Payment Terms Summary****
$22,639.38
Due by Fri 12/13/2024 (Net 45 Days)22,639.38